Table of Contents. Purpose. Real-Time Communications Guidelines for Generator Operators and Distribution Providers. Operating Procedure
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1 Table of Contents Purpose Responsibilities Scope/Applicability Background Scope / Applicability Detail Importance of Standard Communications Types of Communications Communication Requirements Primary and Alternative Interpersonal Communication methods Supporting Information... 9 Operationally Affected Parties... 9 References... 9 Definitions... 9 Version History Periodic Review Review Criteria Frequency Incorporation of Changes Technical Review Approval Purpose Describes ISO System Operations communications policy and standards as related to the ISO Tariff and NERC Registered Entities. Page 1 of 11
2 1. Responsibilities ISO System Operator Scheduling Coordinator (SC) Metered Subsystem (MSS), Utility Distribution Company (UDC), Small Utility Distribution Company (SUDC) Generator Operator (GOP) Distribution Provider (DP) Responsible for conducting operational communications in compliance with this procedure, ISO Tariff, and NERC Reliability Standards. Inform the ISO of any change or potential change in the current operating and communications status of any Generating Units under the Dispatch control of the ISO. MSS and UDC entities coordinate with ISO via Scheduling Coordinators and Transmission Operators (TOPs). For Distribution Provider facilities and Generator Operators (GOPs) directly connected to an MSS or UDC distribution system, ISO and the UDC or MSS representatives, as applicable, will coordinate communications to avoid conflicting operational directives. A GOP shall communicate with the ISO through its assigned SC. If communication methods with the SC become unavailable, then the Generator Operator shall communicate directly with the ISO Generation Dispatcher. Note: GOP is a NERC Registered entity. A Generator Owner (GO) should correlate with the ISO Tariff defined entity Participating Generator Agreement (PGA). GOs which are not also GOPs form agreements with SCs and GOPs, as applicable, in order to fulfill their operational obligations and comply with the ISO Tariff and NERC Standards. A Distribution Provider (DP) shall communicate with the ISO through either its assigned Scheduling Coordinator (SC) or Transmission Operator (TOP). If communication methods with the Scheduling Coordinator become unavailable, then the Distribution Provider shall communicate directly with the ISO Generation Dispatcher or Transmission Dispatcher, as applicable. Page 2 of 11
3 Note: DP is a NERC Registered entity. DPs which are not also MSSs/UDCs and/or Participating Transmission Owners (PTOs) and/or TOPs form agreements with SCs, MSSs and/or TOPs, as applicable, in order to fulfill their operational obligations and comply with the ISO Tariff and NERC Standards. 2. Scope/Applicability 2.1 Background This procedure discusses Real-Time communication obligations between the ISO and Generator Operators (GOPs) and Distribution (DPs). The California ISO (ISO) has jurisdiction for managing reliable operations within the ISO Balancing Authority Area (BAA) and Transmission Operator (TOP) jurisdiction. Close coordination is required between the ISO and its SCs, GOPs, TOPs, PTOs, UDCs, MSSs and DPs. If there is disagreement between the ISO and an entity relative to the action most appropriate for the reliable operation of the ISO BAA or any sub-region thereof, and due to operating considerations there is insufficient time to reach concurrence, the ISO will be the final authority. Inconsistent or otherwise questionable direction by the ISO will be reviewed after the fact to improve coordination. For GOPs within the ISO BAA, during an emergency (as declared by the ISO), the ISO jurisdiction is expanded to include all operations of the Participating Generators, which impact or may impact the ISO BAA. All GOPs, participating and non-participating, within the ISO Balancing Authority area are subject to the Dispatch Instructions, Operating Orders and Reliability Directives of the ISO as the Balancing Authority. In cases where implementing ISO directives would violate safety, equipment, or regulatory or statutory requirements, the entity shall immediately inform the ISO of the inability to perform the directive so that the ISO may implement alternate remedial actions. Page 3 of 11
4 2.2 Scope / Applicability Includes scope of operational communications for reliability between ISO and SCs as related to the UDCs, MSSs and other reliability entities, such as GOPs and DPs that those SCs represent. These operational expectations apply during normal, abnormal and emergency operations, and during periods when communications are disrupted. 3. Detail 3.1 Importance of Standard Communications Conducting communications in accordance with the Reliability Standards and this procedure ensure that accurate data and common understanding regarding Operational Events in both emergency and normal conditions is communicated and/or collected. Regardless of the instruction type, three-part-communication is always highly encouraged, especially for operational orders and transfer of critical information. Three-part-communication is mandatory during all communications occurring under emergency operating conditions. 3.2 Types of Communications The majority of operational communications can be grouped into three categories: Communication Categories 1. Operating Instruction (NERC) The ISO as a BA and a TOP may issue Operating Instructions under normal, abnormal and emergency conditions. Operating Instructions are defined as: A command by operating personnel responsible for the Real-time operation of the interconnected Bulk Electric System to change or preserve the state, status, output, or input of an Element of the Bulk Electric System or Facility of the Bulk Electric System. (NERC Glossary of Terms) Note: the ISO Tariff equivalent communications are called Dispatch Instructions and Operating Orders. The definitions of these NERC and ISO Tariff terms are very similar and for these purposes could be treated the same. Page 4 of 11
5 2. Reliability Directives (NERC) The ISO, as a BA and a TOP, may issue Reliability Directives. The ISO System Operators normally issue Dispatch Instructions, Operating Instructions, and Operating Orders. When issuing a Reliability Directive, the ISO System Operator shall declare the action as a Reliability Directive to the recipient. A Reliability Directive is defined as: A communication initiated by a Reliability Coordinator, Transmission Operator, or Balancing Authority where action by the recipient is necessary to address an Emergency or Adverse Reliability Impact. (NERC Glossary of Terms) Note: Although COM removes the term Reliability Directive, it is still a valid term under IRO R8 and TOP-001-1a R3 until April 1, Peak RC has confirmed that the Emergency Operations procedure will continue to refer to Reliability Directive until that time. 3. Requests for information A discussion of general information and of potential options or alternatives to resolve Bulk Electric System operating concerns is not a command and is not considered an Operating Instruction. 3.3 Communication Requirements Communication Requirements Three-part communication is mandatory when issuing Operating Instructions during normal, abnormal and emergency conditions. (COM R1.2, 1.3) The ISO utilizes Alert, Warning, & Emergency (AWE) messages for emergency notifications. A declared emergency in real-time includes: Transmission Emergency Warning Stage 1, 2, or 3 For more information refer to ISO Operating 4420, System Emergency. Page 5 of 11
6 Three-part communication is a verbal two-party, person-to-person communications protocol where information is: verbally stated by the party initiating the communication is repeated back by the receiving party to the initiating party is confirmed by the initiating party if the receiving party s repeat back is correct is reissued if the repeated information is incorrect or if requested by the receiver. Under normal and Emergency conditions, the ISO System Operator may issue written or verbal single-party to multiple-party burst Instructions. When issuing written or verbal single-party to multiple-party burst Instructions, under normal and Emergency conditions, the ISO System Operator shall verify that the Instruction was received by at least one receiver of the Instruction. (COM R1.4) Examples of verification methods include, but are not limited to: Phone call to one intended receiver to verify receipt Use of Peak RC s Reliability Messaging Tool (RMT) request acknowledgement feature reply acknowledging receipt Examples of multiple-party burst Instructions include but are not limited to: Multiple party conference bridges Reliability Messaging Tool (RMT) messages MNS messages ADS messages Page 6 of 11
7 If an Emergency Operating Instruction will be issued, it should be related to the specific action(s) to be taken by the recipient of the directive. Operating Instructions shall be: Issued in a clear, concise and definitive manner Specifically related to the immediate reliability concern Include the time for the issuance of the Directive and the completion time of the required action by the recipient. Include options previously discussed and shall not include options that are not viable. The ISO System Operator shall inform the receiving party that they are about to receive an Emergency Operating Instruction prior to issuing the instructions. When issuing an Emergency Operating Instruction, both the issuer and the receiver are responsible for ensuring all parties use Three- Part Communication Protocol. Upon issuing such instructions, the ISO System Operator must make certain that the recipient repeats the instructions back correctly and acknowledges the response as correct. If the recipient fails to repeat the instructions back correctly, the ISO System Operator must repeat the directive until any misunderstanding is resolved. If recipient disconnects prior to giving a repeat back, then the ISO System Operator shall re-establish communications in order to receive the repeat back. Use standard and complete terminology, avoiding profanity and slang. All ISO Operating Instructions are issued in Pacific Prevailing Time (PPT) unless stated otherwise. (COM R1.5) When Communicating with BES reliability entities that use unique or different terminology, then clarify the meaning to ensure that both parties are in agreement. When communicating with BES reliability entities regarding interties and/or interfaces, use common identifiers for elements and facilities. For example, when communicating with APS say Imperial Valley-North Gila, not TL (COM R1.6) Page 7 of 11
8 Use only approved acronyms that are commonly used by the other party. If there is any doubt whether the initiating or receiving party understands an acronym, then define and clarify it or do not use it. (COM , 1.3) 3.4 Primary and Alternative Interpersonal Communication methods The California ISO will take the following actions to ensure Primary and Alternative Interpersonal Communication methods will remain available for coordinating with external entities. Description The Primary Interpersonal Communication method used by the ISO is a turret phone system. The Alternative Interpersonal Communication method that is routinely tested by the ISO at least one time per month is a satellite phone. Step 1 ISO System Operator Action(s) In the event the Primary Interpersonal Communication method is unavailable, communicate instructions via a multi-party burst method (refer to section 3.3 for examples) to external entities as soon as possible, and no more than 60 minutes from the time of detection. 2 Note: COM R10 requires notification within sixty (60) minutes of the detection of a failure that lasts thirty (30) minutes or longer. When the Primary Interpersonal Communication method is unavailable, and use of satellite phones is not practical, use one of the other types of communications methods to contact external entities including, but may not be limited to: o Plain Old Telephone System (POTS) o RMT Messaging System Note: the nature of the communications outage will determine which alternative method is utilized, especially in cases where the Primary method may still be available in either the Folsom or Alhambra control center. Page 8 of 11
9 Step 3 Generator Operator (GOP) and Distribution Provider (DP) Action(s) In the event of the loss of the designated Primary Interpersonal Communication method, then notify the California ISO through the assigned SC or TOP. 4. Supporting Information Operationally Affected Parties Public, Peak RC References Resources studied in the development of this procedure and that may have an effect upon some steps taken herein include but are not limited to: ISO Tariff ISO Operating ISO Operating 4420, System Emergency ISO Operating NERC Standards COM R3, R4, R5, R6, R9, R10, COM Definitions Unless the context otherwise indicates, any word or expression defined in the Master Definitions Supplement to the ISO Tariff shall have the meaning when capitalized in this Operating The following additional terms are capitalized in this Operating when used as defined below: Term Operational Event Operational Communication Three Part Communications Definition Any event involving any element, condition, operation, schedule, or occurrence related to power system operation. Any communication pertinent to any element, condition, schedule, or occurrence related to power system operation. A communications protocol where information is verbally stated by a party initiating the communication, the information is repeated back by the receiving party to the Page 9 of 11
10 initiating party and acknowledged by the initiating party to the receiving party to ensure the accuracy of the communication. Version History Version Change By Date 1.0 New procedure to meet COM /01/15 requirements for GOPs and DPs effective 10/1/ Periodic Review Section 3.3: Replaced WECCNet with Reliability Messaging Tool (RMT). Section 3.4, Step 2: Replaced WECCNet with RMT. Throughout document updated and clarified requirements related to COM effective 7/1/16. 7/1/16 5. Periodic Review Review Criteria There are no specific review criteria identified for this procedure, follow instructions in s 5510 and Frequency Review as recommended in s 5510 and Incorporation of Changes There are no specific criteria for changing this document, follow instructions in s 5510 and Page 10 of 11
11 Technical Review Reviewed By Content Expert Signature Date Operations s 6/28/16 Real-Time Operations 6/29/16 Approval Approved By Signature Date Director, Real-Time Operations 6/28/16 Page 11 of 11
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