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NERC Petition in RD17-4, Exhibit A, Proposed Standards

ICR 201705-1902-006 · OMB 1902-0276 · Object 74001801.

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Exhibit A
Proposed Reliability Standards

Reliability Standard IRO-002-5 Clean and Redline

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

A. Introduction
1.

Title:

Reliability Coordination – Monitoring and Analysis

Number:

IRO-002-5

Purpose: To provide System Operators with the capabilities necessary to monitor
and analyze data needed to perform their reliability functions.

Applicability:
4.1. Functional Entities:
4.1.1. Reliability Coordinators

Effective Date: See Implementation Plan

B. Requirements and Measures
R1.

Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses. [Violation Risk Factor: Medium]
[Time Horizon: Operations Planning]

M1. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, a document that lists its data exchange capabilities with
its Balancing Authorities and Transmission Operators, and with other entities it deems
necessary, for it to perform its Operational Planning Analyses.
R2.

Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]

M2. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
as specified in the requirement.
R3.

Each Reliability Coordinator shall test its primary Control Center data exchange
capabilities specified in Requirement R2 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Reliability Coordinator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]

Page 1 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

Each Reliability Coordinator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telecommunication, monitoring and
analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations Planning,
Same-Day Operations, Real-time Operations]

M4. Each Reliability Coordinator shall have, and provide upon request evidence that could
include, but is not limited to, a documented procedure or equivalent evidence that
will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R5.

Each Reliability Coordinator shall monitor Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area. [Violation Risk Factor: High] [Time Horizon: Real-Time Operations]

M5. Each Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitored Facilities, the status of Remedial Action
Schemes, and non-BES facilities identified as necessary by the Reliability Coordinator,
within its Reliability Coordinator Area and neighboring Reliability Coordinator Areas to
identify any System Operating Limit exceedances and to determine any
Interconnection Reliability Operating Limit exceedances within its Reliability
Coordinator Area.
R6.

Each Reliability Coordinator shall have monitoring systems that provide information
utilized by the Reliability Coordinator’s operating personnel, giving particular
emphasis to alarm management and awareness systems, automated data transfers,
and synchronized information systems, over a redundant infrastructure. [Violation
Risk Factor: High] [Time Horizon: Real-time Operations]

M6. The Reliability Coordinator shall have, and provide upon request, evidence that could
include, but is not limited to, Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it has monitoring systems consistent with the requirement.
Page 2 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
“Compliance Enforcement Authority” means NERC or the Regional Entity, or any
entity as otherwise designated by an Applicable Governmental Authority, in
their respective roles of monitoring and/or enforcing compliance with
mandatory and enforceable Reliability Standards in their respective
jurisdictions.
1.2. Evidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•
•

•

The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R4 and Measures M1, M2, and M4.
The Reliability Coordinator shall retain evidence for Requirement R3 and
Measure M3 for the most recent 12 calendar months, with the exception of
operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.
The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.

1.3. Compliance Monitoring and Enforcement Program
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.

Page 3 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

Violation Severity Levels
R#

Violation Severity Levels

Lower VSL

Moderate VSL

High VSL

Severe VSL

R1.

The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with one applicable entity, or
5% or less of the applicable
entities, whichever is greater.

The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two applicable entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.

The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three applicable entities,
or more than 10% or less than
or equal to 15% of the
applicable entities, whichever is
greater.

The Reliability Coordinator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more applicable
entities or greater than 15% of
the applicable entities,
whichever is greater.

R2.

N/A

The Reliability Coordinator had
data exchange capabilities with
its Balancing Authorities and
Transmission Operators, and
with other entities it deems
necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Reliability
Coordinator's primary Control
Center, as specified in the
requirement.

The Reliability Coordinator did
not have data exchange
capabilities with its Balancing
Authorities and Transmission
Operators, and with other
entities it deems necessary, for
performing Real-time
monitoring and Real-time
Assessments as specified in the
requirement.

R3.

The Reliability Coordinator
tested its primary Control
Center data exchange

Page 4 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

R4.

Violation Severity Levels

Lower VSL

Moderate VSL

High VSL

Severe VSL

capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 90 calendar days but less
than or equal to 120 calendar
days since the previous test;

capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 120 calendar days but less
than or equal to 150 calendar
days since the previous test;

capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;

capabilities specified in
Requirement R2 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;

The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.

N/A

OR
The Reliability Coordinator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality;
OR
The Reliability Coordinator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R2 for redundant
functionality at least once
every 90 calendar days but,
following an unsuccessful test,
did not initiate action within 8
hours to restore the redundant
functionality.
The Reliability Coordinator
failed to provide its System
Operator with the authority to
approve planned outages and
Page 5 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

Violation Severity Levels

Lower VSL

Moderate VSL

High VSL

Severe VSL
maintenance of its
telecommunication, monitoring
and analysis capabilities.

R5.

N/A

The Reliability Coordinator did
not monitor Facilities, the
status of Remedial Action
Schemes, and non-BES facilities
identified as necessary by the
Reliability Coordinator, within
its Reliability Coordinator Area
and neighboring Reliability
Coordinator Areas to identify
any System Operating Limit
exceedances and to determine
any Interconnection Reliability
Operating Limit exceedances
within its Reliability
Coordinator Area.

R6.

N/A

The Reliability Coordinator did
not have monitoring systems
that provide information
utilized by the Reliability
Coordinator’s operating
personnel, giving particular
emphasis to alarm
management and awareness
systems, automated data
transfers, and synchronized

Page 6 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

Violation Severity Levels

Lower VSL

Moderate VSL

High VSL

Severe VSL
information systems, over a
redundant infrastructure.

Page 7 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

D. Regional Variances
None.

E. Associated Documents

The Implementation Plan and other project documents can be found on the project page.

Page 8 of 12

IRO-002-5 - Reliability Coordination - Monitoring and Analysis

Version History
Version

Date

Action

April 1,
2005

August 8,
2005

November Adopted by Board of Trustees
1, 2006

Change Tracking

Effective Date

New

Removed “Proposed” from Effective
Date

Errata
Revised

April 4,
2007

Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs

Revised to add missing
measures and compliance
elements

October
17, 2008

Adopted by NERC Board of Trustees

Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project

March 17, Order issued by FERC approving IRO2011
002-2 (approval effective 5/23/11)

FERC approval

February
24, 2014

Updated VSLs based on June 24,
2013 approval.

VSLs revised

July 25,
2011

Revised under Project 2006-06

Revised

August 4,
2011

Approved by Board of Trustees

Retired R1-R8 under Project
2006-06.

November Approved by Board of Trustees
13, 2014

Revisions under Project
2014-03

November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000

FERC approval

February
9, 2017

Adopted by Board of Trustees

Revised

Page 9 of 12

Supplemental Material

Guidelines and Technical Basis
None

Page 10 of 12

Supplemental Material

Rationale

During development of IRO-002-5, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of IRO-002-5, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure

Page 11 of 12

Supplemental Material
or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4 (R6 in IRO-002-5):
The requirement was added back from approved IRO-002-2 as the Project 2014-03 SDT found
no proposed requirements that covered the issues.

Page 12 of 12

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

A. Introduction
1.

Title:

Reliability Coordination – Monitoring and Analysis

Number:

IRO-002-45

Purpose:
ProvideTo provide System Operators with the capabilities necessary to
monitor and analyze data needed to perform their reliability functions.

Applicability:
4.1. Functional Entities:
4.1.1. Reliability CoordinatorCoordinators

5.
6.

Effective Date: See Implementation Plan.
Background:
See the Project 2014-03 project page.

B. Requirements and Measures
R1.

Each Reliability Coordinator shall have data exchange capabilities with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for it to perform its Operational Planning Analyses, Real-time monitoring, and Realtime Assessments. . [Violation Risk Factor: HighMedium] [Time Horizon: Operations
Planning, Same-Day Operations, Real-time Operations]

Each Reliability Coordinator shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Reliability Coordinator's
primary Control Center, for the exchange of Real-time data with its Balancing
Authorities and Transmission Operators, and with other entities it deems necessary,
for performing its Real-time monitoring, and Real-time Assessments. [Violation Risk
Factor: High] [Time Horizon: Same-Day Operations, Real-time Operations]

Page 1 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

R3.

M3. Each Reliability Coordinator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R2 for redundant functionality, or experienced an event that demonstrated the
redundant functionality; and if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R3. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R2.R4.
Each Reliability Coordinator shall provide its System Operators with the authority
to approve planned outages and maintenance of its telecommunication, monitoring
and analysis capabilities. [Violation Risk Factor: High] [Time Horizon: Operations
Planning, Same-Day Operations, Real-time Operations]
M1.M4. Each Reliability Coordinator shall have, and provide upon request evidence that
could include, but is not limited to, a documented procedure or equivalent evidence
that will be used to confirm that the Reliability Coordinator has provided its System
Operators with the authority to approve planned outages and maintenance of its
telecommunication, monitoring and analysis capabilities.
R3.R5.
Each Reliability Coordinator shall monitor Facilities, the status of Special
Protection SystemsRemedial Action Schemes, and non-BES facilities identified as
necessary by the Reliability Coordinator, within its Reliability Coordinator Area and
neighboring Reliability Coordinator Areas to identify any System Operating Limit
exceedances and to determine any Interconnection Reliability Operating Limit
exceedances within its Reliability Coordinator Area. [Violation Risk Factor: High] [Time
Horizon: Real-Time Operations]
M2.M5. M3. Each Reliability Coordinator shall have, and provide upon request,
evidence that could include, but is not limited to, Energy Management System
description documents, computer printouts, SCADA data collection, or other
equivalent evidence that will be used to confirm that it has monitored Facilities, the
status of Special Protection SystemsRemedial Action Schemes, and non-BES facilities
identified as necessary by the Reliability Coordinator, within its Reliability Coordinator
Area and neighboring Reliability Coordinator Areas to identify any System Operating
Limit exceedances and to determine any Interconnection Reliability Operating Limit
exceedances within its Reliability Coordinator Area.
R4.R6.
Each Reliability Coordinator shall have monitoring systems that provide
information utilized by the Reliability Coordinator’s operating personnel, giving
particular emphasis to alarm management and awareness systems, automated data
Page 2 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

transfers, and synchronized information systems, over a redundant infrastructure.
[Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M3.M6. The Reliability Coordinator shall have, and provide upon request, evidence that
could include, but is not limited to, Energy Management System description
documents, computer printouts, SCADA data collection, or other equivalent evidence
that will be used to confirm that it has monitoring systems consistent with the
requirement.

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
As defined in the NERC Rules of Procedure, “Compliance Enforcement
Authority” (CEA) means NERC or the Regional Entity, or any entity as otherwise
designated by an Applicable Governmental Authority, in their respective roles
of monitoring and/or enforcing compliance with the NERCmandatory and
enforceable Reliability Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Assessment Processes:
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Assessment Processes” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated reliability standard.
1.4. Data Retention
1.2. The Reliability CoordinatorEvidence Retention:
The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation:.
•
•

The Reliability Coordinator shall retain its current, in force document and
any documents in force for the current year and previous calendar year for
Requirements R1, R2, and R3R4 and Measures M1, M2, and M3M4.
The Reliability Coordinator shall keep data orretain evidence for
Requirement R4R3 and Measure M4M3 for the most recent 12 calendar
months, with the exception of operator logs and voice recordings which
shall be retained for a minimum of 90 calendar days.

Page 3 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

•

The Reliability Coordinator shall keep data or evidence for Requirements R5
and R6 and Measures M5 and M6 for the current calendar year and one
previous calendar year.

If a Reliability Coordinator is found non-compliant, it shall keep information
related to the non-compliance until found compliant.
1.6.1.3.
The Compliance Monitoring and Enforcement Authority shall keep the
last audit records and all requested and submitted subsequent audit records.
Program
1.7. Additional Compliance Information
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.

Page 4 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Violation Severity Levels
None.

Page 5 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Table of Compliance Elements
R#

Time
Horizon

VRF

R1.

Operations
Planning,
Same-Day
Operations,
Real-time
Operations

High

R2.

Operations
Planning,
Same-Day
Operations,
Real-time
Operations

High

Violation Severity Levels

Lower VSL

Moderate VSL

High VSL

The Reliability
Coordinator did
not have data
exchange
capabilities for
performing its
Operational
Planning
Analyses with
one applicable
entity, or 5% or
less of the
applicable
entities,
whichever is
greater.

The Reliability
Coordinator did not
have data exchange
capabilities for
performing its
Operational Planning
Analyses with two
applicable entities, or
more than 5% or less
than or equal to 10% of
the applicable entities,
whichever is greater.

The Reliability Coordinator did not have
data exchange capabilities for
performing its Operational Planning
Analyses with three applicable entities,
or more than 10% or less than or equal
to 15% of the applicable entities,
whichever is greater.

The Reliability
Coordinator did not
have data exchange
capabilities for
performing its
Operational Planning
Analyses with four or
more applicable
entities or greater
than 15% of the
applicable entities,
whichever is greater.

N/A

The Reliability Coordinator had data
exchange capabilities with its Balancing
Authorities and Transmission
Operators, and with other entities it
deems necessary, for performing Realtime monitoring and Real-time
Assessments, but did not have
redundant and diversely routed data
exchange infrastructure within the
Reliability Coordinator's primary
Control Center, as specified in the
requirement.The Reliability Coordinator

The Reliability
Coordinator did not
have data exchange
capabilities with its
Balancing Authorities
and Transmission
Operators, and with
other entities it deems
necessary, for
performing Real-time
monitoring and Realtime Assessments as

N/A

Severe VSL

Page 6 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

R3.

Time
Horizon

Violation Severity Levels

VRF

Lower VSL

Real-time
Operations The
Reliability
Coordinator
tested its primary
Control Center
data exchange
capabilities
specified in
Requirement R2
for redundant
functionality, but
did so more than
90 calendar days
but less than or
equal to 120
calendar days
since the
previous test;

Moderate VSL

HighThe Reliability
Coordinator tested its
primary Control Center
data exchange
capabilities specified in
Requirement R2 for
redundant
functionality, but did so
more than 120
calendar days but less
than or equal to 150
calendar days since the
previous test;
OR

The Reliability
Coordinator tested its
primary Control Center
data exchange
capabilities specified in
OR
Requirement R2 for
The Reliability
redundant functionality
Coordinator
at least once every 90
tested its primary calendar days but,
Control Center
following an

High VSL

Severe VSL

failed to provide its System Operator
with the authority to approve planned
outages and maintenance of its
telecommunication, monitoring and
analysis capabilities.

specified in the
requirement.

N/AThe
N/A
Reliability
Coordinator
tested its primary
Control Center
data exchange
capabilities
specified in
Requirement R2
for redundant
functionality, but
did so more than
150 calendar
days but less
than or equal to
180 calendar
days since the
previous test;

The Reliability
Coordinator tested its
primary Control
Center data exchange
capabilities specified
in Requirement R2 for
redundant
functionality, but did
so more than 180
calendar days since
the previous test;

OR
The Reliability
Coordinator
tested its primary
Control Center
data exchange

N/A

OR
The Reliability
Coordinator did not
monitor Facilities, the
status of Special
Protection Systems,
and non-BES facilities
identified as necessary
by the Reliability
Coordinator, within its
test its primary
Control Center data
exchange capabilities
Page 7 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Time
Horizon

Violation Severity Levels

VRF

Lower VSL
data exchange
capabilities
specified in
Requirement R2
for redundant
functionality at
least once every
90 calendar days
but, following an
unsuccessful
test, initiated
action to restore
the redundant
functionality in
more than 2
hours and less
than or equal to
4 hours.

Moderate VSL
unsuccessful test,
initiated action to
restore the redundant
functionality in more
than 4 hours and less
than or equal to 6
hours.

High VSL
capabilities
specified in
Requirement R2
for redundant
functionality at
least once every
90 calendar days
but, following an
unsuccessful
test, initiated
action to restore
the redundant
functionality in
more than 6
hours and less
than or equal to
8 hours.

Severe VSL
specified in
Requirement R2 for
redundant
functionality;
OR
The Reliability
Coordinator Area and
neighboring Reliability
Coordinator
Areastested its
primary Control
Center data exchange
capabilities specified
in Requirement R2 for
redundant
functionality at least
once every 90
calendar days but,
following an
unsuccessful test, did
not initiate action
within 8 hours to
identify any System
Operating Limit
exceedances and to
determine any
Interconnection
Reliability Operating
Limit exceedances

Page 8 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Time
Horizon

Violation Severity Levels

VRF

Lower VSL

Moderate VSL

High VSL

Severe VSL
within its Reliability
Coordinator
Arearestore the
redundant
functionality.

R4.

N/A

The Reliability
Coordinator failed to
provide its System
Operator with the
authority to approve
planned outages and
maintenance of its
telecommunication,
monitoring and
analysis capabilities.

R5.

N/A

Page 9 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Time
Horizon

Violation Severity Levels

VRF

Lower VSL

Moderate VSL

High VSL

Severe VSL
Limit exceedances and
to determine any
Interconnection
Reliability Operating
Limit exceedances
within its Reliability
Coordinator Area.

R4R6. Operations
Planning,
Same-Day
Operations,
Real-time
Operations

High

N/A

The Reliability
Coordinator did not
have monitoring
systems that provide
information utilized by
the Reliability
Coordinator’s
operating personnel,
giving particular
emphasis to alarm
management and
awareness systems,
automated data
transfers, and
synchronized
information systems,
over a redundant
infrastructure.

Page 10 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

D. Regional Variances
None.

Interpretations

None.

G.E.

None.

Associated Documents

The Implementation Plan and other project documents can be found on the project page.

Page 11 of 15

Standard IRO-002-4 5 - Reliability Coordination - Monitoring and Analysis

Version History
Version

Date

Action

April 1,
2005

August 8,
2005

November Adopted by Board of Trustees
1, 2006

Change Tracking

Effective Date

New

Removed “Proposed” from Effective
Date

Errata
Revised

April 4,
2007

Replaced Levels of Non-compliance
with the Feb 28, BOT approved
Violation Severity Levels (VSLs)
Corrected typographical errors in
BOT approved version of VSLs

Revised to add missing
measures and compliance
elements

October
17, 2008

Adopted by NERC Board of Trustees

Deleted R2, M3 and
associated compliance
elements as conforming
changes associated with
approval of IRO-010-1.
Revised as part of IROL
Project

March 17, Order issued by FERC approving IRO2011
002-2 (approval effective 5/23/11)

FERC approval

February
24, 2014

Updated VSLs based on June 24,
2013 approval.

VSLs revised

July 25,
2011

Revised under Project 2006-06

Revised

August 4,
2011

Approved by Board of Trustees

Retired R1-R8 under Project
2006-06.

November Approved by Board of Trustees
13, 2014

Revisions under Project
2014-03

November FERC approved IRO-002-4. Docket
19, 2015 No. RM15-16-000

FERC approval

February
9, 2017

Adopted by Board of Trustees

Revised

Page 12 of 15

Standard IRO-002-4 — Guidelines and Technical BasisSupplemental Material

Guidelines and Technical Basis
None

Page 13 of 15

Standard IRO-002-4 — Guidelines and Technical BasisSupplemental Material

Rationale:

During development of this standardIRO-002-5, text boxes wereare embedded within the
standard to explain the rationale for various parts of the standard. Upon BOT approvalBoard
adoption of IRO-002-5, the text from the rationale text boxes waswill be moved to this section.
Rationale text from the development of IRO-002-4 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Changes made to the proposed definitions were made in order to respond to issues raised in
NOPR paragraphs 55, 73, and 74 dealing with analysis of SOLs in all time horizons, questions on
Protection Systems and Special Protection Systems in NOPR paragraph 78, and
recommendations on phase angles from the SW Outage Report (recommendation 27). The
intent of such changes is to ensure that Real-time Assessments contain sufficient details to
result in an appropriate level of situational awareness. Some examples include: 1) analyzing
phase angles which may result in the implementation of an Operating Plan to adjust generation
or curtail transactions so that a Transmission facility may be returned to service, or 2)
evaluating the impact of a modified Contingency resulting from the status change of a Special
Protection Scheme from enabled/in-service to disabled/out-of-service.
Rationale for Requirements:
The data exchange elements of Requirements R1 and R2 from approved IRO-002-2 have been
added back into proposed IRO-002-4 in order to ensure that there is no reliability gap. The
Project 2014-03 SDT found no proposed requirements in the current project that covered the
issue. Voice communication is covered in proposed COM-001-2 but data communications needs
to remain in IRO-002-4 as it is not covered in proposed COM-001-2. Staffing of communications
and facilities in corresponding requirements from IRO-002-2 is addressed in approved PER-0042, Requirement R1 and has been deleted from this draft.
Rationale for R2:
Requirement R2 from IRO-002-3 has been deleted because approved EOP-008-1, Requirement
R1, part 1.6.2 addresses redundancy and back-up concerns for outages of analysis tools. New
Requirement R4 (R6 in IRO-002-5) has been added to address NOPR paragraphs 96 and 97:
“…As we explain above, the reliability coordinator’s obligation to monitor SOLs is important to
reliability because a SOL can evolve into an IROL during deteriorating system conditions, and for
potential system conditions such as this, the reliability coordinator’s monitoring of SOLs provides
a necessary backup function to the transmission operator….”
Rationale for Requirements R1 and R2:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure

Page 14 of 15

Standard IRO-002-4 — Guidelines and Technical BasisSupplemental Material

or malfunction of an individual component within the Reliability Coordinator's (RC) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R2 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the RC's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the RC's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R3:
The revised requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.
Rationale for R4: (R6 in IRO-002-5):
Requirement R4The requirement was added back from approved IRO-002-2 as the Project
2014-03 SDT found no proposed requirements that covered the issues.

Page 15 of 15

Reliability Standard TOP-001-4 Clean and Redline

TOP-001-4 - Transmission Operations

A. Introduction
1.

Title:

Transmission Operations

Number:

TOP-001-4

Purpose: To prevent instability, uncontrolled separation, or Cascading outages that
adversely impact the reliability of the Interconnection by ensuring prompt action to
prevent or mitigate such occurrences.

Applicability:
4.1. Functional Entities:
4.1.1. Balancing Authority
4.1.2. Transmission Operator
4.1.3. Generator Operator
4.1.4. Distribution Provider

Effective Date: See Implementation Plan

B. Requirements and Measures
R1.

Each Transmission Operator shall act to maintain the reliability of its Transmission
Operator Area via its own actions or by issuing Operating Instructions. [Violation Risk
Factor: High][Time Horizon: Same-Day Operations, Real-time Operations]

M1. Each Transmission Operator shall have and provide evidence which may include but is
not limited to dated operator logs, dated records, dated and time-stamped voice
recordings or dated transcripts of voice recordings, electronic communications, or
equivalent documentation, that will be used to determine that it acted to maintain
the reliability of its Transmission Operator Area via its own actions or by issuing
Operating Instructions.
R2.

Each Balancing Authority shall act to maintain the reliability of its Balancing Authority
Area via its own actions or by issuing Operating Instructions. [Violation Risk Factor:
High][Time Horizon: Same-Day Operations, Real-time Operations]

M2. Each Balancing Authority shall have and provide evidence which may include but is
not limited to dated operator logs, dated records, dated and time-stamped voice
recordings or dated transcripts of voice recordings, electronic communications, or
equivalent documentation, that will be used to determine that it acted to maintain
the reliability of its Balancing Authority Area via its own actions or by issuing
Operating Instructions.

Page 1 of 27

TOP-001-4 - Transmission Operations

R3.

Each Balancing Authority, Generator Operator, and Distribution Provider shall comply
with each Operating Instruction issued by its Transmission Operator(s), unless such
action cannot be physically implemented or it would violate safety, equipment,
regulatory, or statutory requirements. [Violation Risk Factor: High] [Time Horizon:
Same-Day Operations, Real-Time Operations]

M3. Each Balancing Authority, Generator Operator, and Distribution Provider shall make
available upon request, evidence that it complied with each Operating Instruction
issued by the Transmission Operator(s) unless such action could not be physically
implemented or it would have violated safety, equipment, regulatory, or statutory
requirements. Such evidence could include but is not limited to dated operator logs,
voice recordings or transcripts of voice recordings, electronic communications, or
other equivalent evidence in electronic or hard copy format. In such cases, the
Balancing Authority, Generator Operator, and Distribution Provider shall have and
provide copies of the safety, equipment, regulatory, or statutory requirements as
evidence for not complying with the Transmission Operator’s Operating Instruction. If
such a situation has not occurred, the Balancing Authority, Generator Operator, or
Distribution Provider may provide an attestation.
R4.

Each Balancing Authority, Generator Operator, and Distribution Provider shall inform
its Transmission Operator of its inability to comply with an Operating Instruction
issued by its Transmission Operator. [Violation Risk Factor: High] [Time Horizon:
Same-Day Operations, Real-Time Operations]

M4. Each Balancing Authority, Generator Operator, and Distribution Provider shall make
available upon request, evidence which may include but is not limited to dated
operator logs, voice recordings or transcripts of voice recordings, electronic
communications, or equivalent evidence in electronic or hard copy format, that it
informed its Transmission Operator of its inability to comply with its Operating
Instruction issued. If such a situation has not occurred, the Balancing Authority,
Generator Operator, or Distribution Provider may provide an attestation.
R5.

Each Transmission Operator, Generator Operator, and Distribution Provider shall
comply with each Operating Instruction issued by its Balancing Authority, unless such
action cannot be physically implemented or it would violate safety, equipment,
regulatory, or statutory requirements. [Violation Risk Factor: High] [Time Horizon:
Same-Day Operations, Real-Time Operations]
M5. Each Transmission Operator, Generator Operator, and Distribution Provider shall
make available upon request, evidence that it complied with each Operating
Instruction issued by its Balancing Authority unless such action could not be physically
implemented or it would have violated safety, equipment, regulatory, or statutory
requirements. Such evidence could include but is not limited to dated operator logs,
voice recordings or transcripts of voice recordings, electronic communications, or
other equivalent evidence in electronic or hard copy format. In such cases, the
Transmission Operator, Generator Operator, and Distribution Provider shall have and

Page 2 of 27

TOP-001-4 - Transmission Operations

provide copies of the safety, equipment, regulatory, or statutory requirements as
evidence for not complying with the Balancing Authority’s Operating Instruction. If
such a situation has not occurred, the Transmission Operator, Generator Operator, or
Distribution Provider may provide an attestation.
R6.

Each Transmission Operator, Generator Operator, and Distribution Provider shall
inform its Balancing Authority of its inability to comply with an Operating Instruction
issued by its Balancing Authority. [Violation Risk Factor: High] [Time Horizon: SameDay Operations, Real-Time Operations]

M6. Each Transmission Operator, Generator Operator, and Distribution Provider shall
make available upon request, evidence which may include but is not limited to dated
operator logs, voice recordings or transcripts of voice recordings, electronic
communications, or equivalent evidence in electronic or hard copy format, that it
informed its Balancing Authority of its inability to comply with its Operating
Instruction. If such a situation has not occurred, the Transmission Operator,
Generator Operator, or Distribution Provider may provide an attestation.
R7.

Each Transmission Operator shall assist other Transmission Operators within its
Reliability Coordinator Area, if requested and able, provided that the requesting
Transmission Operator has implemented its comparable Emergency procedures,
unless such assistance cannot be physically implemented or would violate safety,
equipment, regulatory, or statutory requirements. [Violation Risk Factor: High] [Time
Horizon: Real-Time Operations]

M7. Each Transmission Operator shall make available upon request, evidence that
comparable requested assistance, if able, was provided to other Transmission
Operators within its Reliability Coordinator Area unless such assistance could not be
physically implemented or would have violated safety, equipment, regulatory, or
statutory requirements. Such evidence could include but is not limited to dated
operator logs, voice recordings or transcripts of voice recordings, electronic
communications, or other equivalent evidence in electronic or hard copy format. If
no request for assistance was received, the Transmission Operator may provide an
attestation.
R8.

Each Transmission Operator shall inform its Reliability Coordinator, known impacted
Balancing Authorities, and known impacted Transmission Operators of its actual or
expected operations that result in, or could result in, an Emergency. [Violation Risk
Factor: High] [Time Horizon: Operations Planning, Same-Day Operations, Real-Time
Operations]

M8. Each Transmission Operator shall make available upon request, evidence that it
informed its Reliability Coordinator, known impacted Balancing Authorities, and
known impacted Transmission Operators of its actual or expected operations that
result in, or could result in, an Emergency. Such evidence could include but is not
limited to dated operator logs, voice recordings or transcripts of voice recordings,
Page 3 of 27

TOP-001-4 - Transmission Operations

electronic communications, or other equivalent evidence. If no such situations have
occurred, the Transmission Operator may provide an attestation.
R9.

Each Balancing Authority and Transmission Operator shall notify its Reliability
Coordinator and known impacted interconnected entities of all planned outages, and
unplanned outages of 30 minutes or more, for telemetering and control equipment,
monitoring and assessment capabilities, and associated communication channels
between the affected entities. [Violation Risk Factor: Medium] [Time Horizon:
Operations Planning, Same-Day Operations, Real-Time Operations]

M9. Each Balancing Authority and Transmission Operator shall make available upon
request, evidence that it notified its Reliability Coordinator and known impacted
interconnected entities of all planned outages, and unplanned outages of 30 minutes
or more, for telemetering and control equipment, monitoring and assessment
capabilities, and associated communication channels. Such evidence could include but
is not limited to dated operator logs, voice recordings or transcripts of voice
recordings, electronic communications, or other equivalent evidence. If such a
situation has not occurred, the Balancing Authority or Transmission Operator may
provide an attestation.
R10. Each Transmission Operator shall perform the following for determining System
Operating Limit (SOL) exceedances within its Transmission Operator Area: [Violation
Risk Factor: High] [Time Horizon: Real-Time Operations]
10.1.

Monitor Facilities within its Transmission Operator Area;

10.2.

Monitor the status of Remedial Action Schemes within its Transmission
Operator Area;

10.3.

Monitor non-BES facilities within its Transmission Operator Area identified as
necessary by the Transmission Operator;

10.4.

Obtain and utilize status, voltages, and flow data for Facilities outside its
Transmission Operator Area identified as necessary by the Transmission
Operator;

10.5.

Obtain and utilize the status of Remedial Action Schemes outside its
Transmission Operator Area identified as necessary by the Transmission
Operator; and

10.6. Obtain and utilize status, voltages, and flow data for non-BES facilities outside
its Transmission Operator Area identified as necessary by the Transmission
Operator.
M10. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to Energy Management System description
documents, computer printouts, Supervisory Control and Data Acquisition (SCADA)
data collection, or other equivalent evidence that will be used to confirm that it

Page 4 of 27

TOP-001-4 - Transmission Operations

monitored or obtained and utilized data as required to determine any System
Operating Limit (SOL) exceedances within its Transmission Operator Area.
R11. Each Balancing Authority shall monitor its Balancing Authority Area, including the
status of Remedial Action Schemes that impact generation or Load, in order to
maintain generation-Load-interchange balance within its Balancing Authority Area
and support Interconnection frequency. [Violation Risk Factor: High] [Time Horizon:
Real-Time Operations]
M11. Each Balancing Authority shall have, and provide upon request, evidence that could
include but is not limited to Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it monitors its Balancing Authority Area, including the status of
Remedial Action Schemes that impact generation or Load, in order to maintain
generation-Load-interchange balance within its Balancing Authority Area and support
Interconnection frequency.
R12. Each Transmission Operator shall not operate outside any identified Interconnection
Reliability Operating Limit (IROL) for a continuous duration exceeding its associated
IROL Tv. [Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M12. Each Transmission Operator shall make available evidence to show that for any
occasion in which it operated outside any identified Interconnection Reliability
Operating Limit (IROL), the continuous duration did not exceed its associated IROL Tv.
Such evidence could include but is not limited to dated computer logs or reports in
electronic or hard copy format specifying the date, time, duration, and details of the
excursion. If such a situation has not occurred, the Transmission Operator may
provide an attestation that an event has not occurred.
R13. Each Transmission Operator shall ensure that a Real-time Assessment is performed at
least once every 30 minutes. [Violation Risk Factor: High] [Time Horizon: Real-time
Operations]
M13. Each Transmission Operator shall have, and make available upon request, evidence to
show it ensured that a Real-Time Assessment was performed at least once every 30
minutes. This evidence could include but is not limited to dated computer logs
showing times the assessment was conducted, dated checklists, or other evidence.
R14. Each Transmission Operator shall initiate its Operating Plan to mitigate a SOL
exceedance identified as part of its Real-time monitoring or Real-time Assessment.
[Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M14. Each Transmission Operator shall have evidence that it initiated its Operating Plan for
mitigating SOL exceedances identified as part of its Real-time monitoring or Real-time
Assessments. This evidence could include but is not limited to dated computer logs
showing times the Operating Plan was initiated, dated checklists, or other evidence.

Page 5 of 27

TOP-001-4 - Transmission Operations

R15. Each Transmission Operator shall inform its Reliability Coordinator of actions taken to
return the System to within limits when a SOL has been exceeded. [Violation Risk
Factor: Medium] [Time Horizon: Real-Time Operations]
M15. Each Transmission Operator shall make available evidence that it informed its
Reliability Coordinator of actions taken to return the System to within limits when a
SOL was exceeded. Such evidence could include but is not limited to dated operator
logs, voice recordings or transcripts of voice recordings, or dated computer printouts.
If such a situation has not occurred, the Transmission Operator may provide an
attestation.
R16. Each Transmission Operator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telemetering and control
equipment, monitoring and assessment capabilities, and associated communication
channels between affected entities. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M16. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to a documented procedure or equivalent evidence
that will be used to confirm that the Transmission Operator has provided its System
Operators with the authority to approve planned outages and maintenance of
telemetering and control equipment, monitoring and assessment capabilities, and
associated communication channels between affected entities.
R17. Each Balancing Authority shall provide its System Operators with the authority to
approve planned outages and maintenance of its telemetering and control
equipment, monitoring and assessment capabilities, and associated communication
channels between affected entities. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M17. Each Balancing Authority shall have, and provide upon request, evidence that could
include but is not limited to a documented procedure or equivalent evidence that will
be used to confirm that the Balancing Authority has provided its System Operators
with the authority to approve planned outages and maintenance of its telemetering
and control equipment, monitoring and assessment capabilities, and associated
communication channels between affected entities.
R18. Each Transmission Operator shall operate to the most limiting parameter in instances
where there is a difference in SOLs. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M18. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to operator logs, voice recordings, electronic
communications, or equivalent evidence that will be used to determine if it operated
to the most limiting parameter in instances where there is a difference in SOLs.

Page 6 of 27

TOP-001-4 - Transmission Operations

R19. Each Transmission Operator shall have data exchange capabilities with the entities it
has identified it needs data from in order to perform its Operational Planning
Analyses. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning]
M19. Each Transmission Operator shall have, and provide upon request, evidence that
could include, but is not limited to, operator logs, system specifications, system
diagrams, or other evidence that it has data exchange capabilities with the entities it
has identified it needs data from in order to perform its Operational Planning
Analyses.
R20. Each Transmission Operator shall have data exchange capabilities, with redundant
and diversely routed data exchange infrastructure within the Transmission Operator's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Balancing Authority, and the entities it has identified it needs data from
in order for it to perform its Real-time monitoring and Real-time Assessments.
[Violation Risk Factor: High] [Time Horizon: Same-Day Operations, Real-time
Operations]
M20. Each Transmission Operator shall have, and provide upon request, evidence that
could include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Transmission Operator's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Balancing Authority, and the entities it has identified it needs data from
in order to perform its Real-time monitoring and Real-time Assessments as specified
in the requirement.
R21. Each Transmission Operator shall test its primary Control Center data exchange
capabilities specified in Requirement R20 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Transmission Operator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
M21. Each Transmission Operator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R20 for the redundant functionality, or experienced an event that demonstrated the
redundant functionality; and, if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R21. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R22. Each Balancing Authority shall have data exchange capabilities with the entities it has
identified it needs data from in order to develop its Operating Plan for next-day
operations. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning]
M22. Each Balancing Authority shall have, and provide upon request, evidence that could
include, but is not limited to, operator logs, system specifications, system diagrams, or

Page 7 of 27

TOP-001-4 - Transmission Operations

other evidence that it has data exchange capabilities with the entities it has identified
it needs data from in order to develop its Operating Plan for next-day operations.
R23. Each Balancing Authority shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Balancing Authority's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Transmission Operator, and the entities it has identified it needs data
from in order for it to perform its Real-time monitoring and analysis functions.
[Violation Risk Factor: High] [Time Horizon: Same-Day Operations, Real-time
Operations]
M23. Each Balancing Authority shall have, and provide upon request, evidence that could
include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Balancing Authority's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Transmission Operator, and the entities it has identified it needs data
from in order to perform its Real-time monitoring and analysis functions as specified
in the requirement.
R24. Each Balancing Authority shall test its primary Control Center data exchange
capabilities specified in Requirement R23 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Balancing Authority shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
M24. Each Balancing Authority shall have, and provide upon request, evidence that it tested
its primary Control Center data exchange capabilities specified in Requirement R23 for
redundant functionality, or experienced an event that demonstrated the redundant
functionality; and, if the test was unsuccessful, initiated action within two hours to
restore redundant functionality as specified in Requirement R24. Evidence could
include, but is not limited to: dated and time-stamped test records, operator logs,
voice recordings, or electronic communications.

C. Compliance
1.

Page 8 of 27

TOP-001-4 - Transmission Operations

The following evidence retention period(s) identify the period of time an entity
is required to retain specific evidence to demonstrate compliance. For instances
where the evidence retention period specified below is shorter than the time
since the last audit, the Compliance Enforcement Authority may ask an entity to
provide other evidence to show that it was compliant for the full-time period
since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•

Each Balancing Authority, Transmission Operator, Generator Operator, and
Distribution Provider shall each keep data or evidence for each applicable
Requirement R1 through R11, and Measure M1 through M11, for the current
calendar year and one previous calendar year, with the exception of operator
logs and voice recordings which shall be retained for a minimum of 90
calendar days, unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.

•

Each Transmission Operator shall keep data or evidence for Requirement R13
and Measure M13 for a rolling 30-day period, unless directed by its
Compliance Enforcement Authority to retain specific evidence for a longer
period of time as part of an investigation.

•

Each Transmission Operator shall retain evidence and that it initiated its
Operating Plan to mitigate a SOL exceedance as specified in Requirement R14
and Measurement M14 for three calendar years.

•

Each Transmission Operator and Balancing Authority shall each keep data or
evidence for each applicable Requirement R15 through R19, and Measure M15
through M19 for the current calendar year and one previous calendar year,
with the exception of operator logs and voice recordings which shall be
retained for a minimum of 90 calendar days.

•

Each Transmission Operator shall keep data or evidence for Requirement R20
and Measure M20 for the current calendar year and one previous calendar
year.

•

Each Transmission Operator shall keep evidence for Requirement R21 and
Measure M21 for the most recent twelve calendar months, with the exception
of operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.

•

Each Balancing Authority shall keep data or evidence for Requirement R22 and
Measure M22 for the current calendar year and one previous calendar year,
Page 9 of 27

TOP-001-4 - Transmission Operations

with the exception of operator logs and voice recordings which shall be
retained for a minimum of 90 calendar days.
•

Each Balancing Authority shall keep data or evidence for Requirement R23 and
Measure M23 for the current calendar year and one previous calendar year.

•

Each Balancing Authority shall keep evidence for Requirement R24 and
Measure M24 for the most recent twelve calendar months, with the exception
of operator logs and voice recordings which shall be retained for a minimum of
90 calendar days.

Page 10 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
R#

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

N/A

The Transmission Operator
failed to act to maintain the
reliability of its Transmission
Operator Area via its own
actions or by issuing Operating
Instructions.

N/A

The Balancing Authority failed
to act to maintain the reliability
of its Balancing Authority Area
via its own actions or by issuing
Operating Instructions.

N/A

The responsible entity did not
comply with an Operating
Instruction issued by the
Transmission Operator, and
such action could have been
physically implemented and
would not have violated safety,
equipment, regulatory, or
statutory requirements.

N/A

The responsible entity did not
inform its Transmission
Operator of its inability to
comply with an Operating
Instruction issued by its
Transmission Operator.

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TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

N/A

The responsible entity did not
comply with an Operating
Instruction issued by the
Balancing Authority, and such
action could have been
physically implemented and
would not have violated safety,
equipment, regulatory, or
statutory requirements.

N/A

The responsible entity did not
inform its Balancing Authority of
its inability to comply with an
Operating Instruction issued by
its Balancing Authority.

N/A

The Transmission Operator did
not provide comparable
assistance to other Transmission
Operators within its Reliability
Coordinator Area, when
requested and able, and the
requesting entity had
implemented its Emergency
procedures, and such actions
could have been physically
implemented and would not
have violated safety,
equipment, regulatory, or
statutory requirements.

Page 12 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

The Transmission Operator
did not inform one known
impacted Transmission
Operator or 5% or less of
the known impacted
Transmission Operators,
whichever is greater, of its
actual or expected
operations that resulted in,
or could have resulted in, an
Emergency on respective
Transmission Operator
Areas.
OR,
The Transmission Operator
did not inform one known
impacted Balancing
Authorities or 5% or less of
the known impacted
Balancing Authorities,
whichever is greater, of its
actual or expected
operations that resulted in,
or could have resulted in, an
Emergency on respective
Balancing Authority Areas.

The Transmission Operator did
not inform two known
impacted Transmission
Operators or more than 5%
and less than or equal to 10%
of the known impacted
Transmission Operators,
whichever is greater, of its
actual or expected operations
that resulted in, or could have
resulted in, an Emergency on
respective Transmission
Operator Areas.
OR,
The Transmission Operator did
not inform two known
impacted Balancing Authorities
or more than 5% and less than
or equal to 10% of the known
impacted Balancing
Authorities, whichever is
greater, of its actual or
expected operations that
resulted in, or could have
resulted in, an Emergency on
respective Balancing Authority
Areas.

The Transmission Operator did
not inform three known impacted
Transmission Operators or more
than 10% and less than or equal to
15% of the known impacted
Transmission Operators,
whichever is greater, of its actual
or expected operations that
resulted in, or could have resulted
in, an Emergency on respective
Transmission Operator Areas.
OR,
The Transmission Operator did
not inform three known impacted
Balancing Authorities or more
than 10% and less than or equal to
15% of the known impacted
Balancing Authorities, whichever
is greater, of its actual or expected
operations that resulted in, or
could have resulted in, an
Emergency on respective
Balancing Authority Areas.

The Transmission Operator did
not inform its Reliability
Coordinator of its actual or
expected operations that
resulted in, or could have
resulted in, an Emergency on
those respective Transmission
Operator Areas.
OR
The Transmission Operator did
not inform four or more known
impacted Transmission
Operators or more than 15% of
the known impacted
Transmission Operators of its
actual or expected operations
that resulted in, or could have
resulted in, an Emergency on
those respective Transmission
Operator Areas.
OR,
The Transmission Operator did
not inform four or more known
impacted Balancing Authorities
or more than 15% of the known
impacted Balancing Authorities
of its actual or expected
operations that resulted in, or
could have resulted in, an

Page 13 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

Emergency on respective
Balancing Authority Areas.

The responsible entity did
not notify one known
impacted interconnected
entity or 5% or less of the
known impacted entities,
whichever is greater, of a
planned outage, or an
unplanned outage of 30
minutes or more, for
telemetering and control
equipment, monitoring and
assessment capabilities, or
associated communication
channels between the
affected entities.

The responsible entity did not
notify two known impacted
interconnected entities or
more than 5% and less than or
equal to 10% of the known
impacted entities, whichever is
greater, of a planned outage,
or an unplanned outage of 30
minutes or more, for
telemetering and control
equipment, monitoring and
assessment capabilities, or
associated communication
channels between the affected
entities.

The responsible entity did not
notify three known impacted
interconnected entities or more
than 10% and less than or equal to
15% of the known impacted
entities, whichever is greater, of a
planned outage, or an unplanned
outage of 30 minutes or more, for
telemetering and control
equipment, monitoring and
assessment capabilities, or
associated communication
channels between the affected
entities.

The responsible entity did not
notify its Reliability Coordinator
of a planned outage, or an
unplanned outage of 30 minutes
or more, for telemetering and
control equipment, monitoring
and assessment capabilities, and
associated communication
channels.
OR,
The responsible entity did not
notify four or more known
impacted interconnected
entities or more than 15% of the
known impacted entities,
whichever is greater, of a
planned outage, or an
unplanned outage of 30 minutes
or more, for telemetering and
control equipment, monitoring
and assessment capabilities, or
associated communication
channels between the affected
entities.

R10

The Transmission Operator
did not monitor, obtain, or
utilize one of the items

The Transmission Operator did
not monitor, obtain, or utilize
two of the items required or

The Transmission Operator did
not monitor, obtain, or utilize
three of the items required or

The Transmission Operator did
not monitor, obtain, or utilize
four or more of the items

Page 14 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

required or identified as
necessary by the
Transmission Operator and
listed in Requirement R10,
Part 10.1 through 10.6.

identified as necessary by the
Transmission Operator and
listed in Requirement R10, Part
10.1 through 10.6.

identified as necessary by the
Transmission Operator and listed
in Requirement R10, Part 10.1
through 10.6.

required or identified as
necessary by the Transmission
Operator and listed in
Requirement R10 Part 10.1
through 10.6.

R11

N/A

The Balancing Authority did not
monitor the status of Remedial
Action Schemes that impact
generation or Load, in order to
maintain generation-Loadinterchange balance within its
Balancing Authority Area and
support Interconnection
frequency.

The Balancing Authority did not
monitor its Balancing Authority
Area, in order to maintain
generation-Load-interchange
balance within its Balancing
Authority Area and support
Interconnection frequency.

R12

N/A

The Transmission Operator
exceeded an identified
Interconnection Reliability
Operating Limit (IROL) for a
continuous duration greater
than its associated IROL Tv.

For any sample 24-hour
period within the 30-day
retention period, the
Transmission Operator’s
Real-time Assessment was
not conducted for one 30minute period within that
24-hour period.

For any sample 24-hour period
within the 30-day retention
period, the Transmission
Operator’s Real-time
Assessment was not conducted
for two 30-minute periods
within that 24-hour period.

For any sample 24-hour period
within the 30-day retention
period, the Transmission
Operator’s Real-time Assessment
was not conducted for three 30minute periods within that 24hour period.

For any sample 24-hour period
within the 30-day retention
period, the Transmission
Operator’s Real-time
Assessment was not conducted
for four or more 30-minute
periods within that 24-hour
period.

R13

Page 15 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

R14.

R15.

N/A

Moderate VSL

High VSL

Severe VSL

N/A

The Transmission Operator did
not initiate its Operating Plan
for mitigating a SOL exceedance
identified as part of its Realtime monitoring or Real-time
Assessment

N/A

The Transmission Operator did
not inform its Reliability
Coordinator of actions taken to
return the System to within
limits when a SOL had been
exceeded.

R16.

N/A

The Transmission Operator did
not provide its System
Operators with the authority to
approve planned outages and
maintenance of its
telemetering and control
equipment, monitoring and
assessment capabilities, and
associated communication
channels between affected
entities.

R17.

N/A

The Balancing Authority did not
provide its System Operators
with the authority to approve
planned outages and
maintenance of its
telemetering and control

Page 16 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

equipment, monitoring and
assessment capabilities, and
associated communication
channels between affected
entities.

R18

N/A

The Transmission Operator
failed to operate to the most
limiting parameter in instances
where there was a difference in
SOLs.

R19

The Transmission Operator
did not have data exchange
capabilities for performing
its Operational Planning
Analyses with one identified
entity, or 5% or less of the
applicable entities,
whichever is greater.

The Transmission Operator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with two identified entities, or
more than 5% or less than or
equal to 10% of the applicable
entities, whichever is greater.

The Transmission Operator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with three identified entities, or
more than 10% or less than or
equal to 15% of the applicable
entities, whichever is greater.

The Transmission Operator did
not have data exchange
capabilities for performing its
Operational Planning Analyses
with four or more identified
entities or greater than 15% of
the applicable entities,
whichever is greater.

R20

N/A

The Transmission Operator had
data exchange capabilities with its
Reliability Coordinator, Balancing
Authority, and identified entities
for performing Real-time
monitoring and Real-time
Assessments, but did not have
redundant and diversely routed
data exchange infrastructure
within the Transmission
Operator's primary Control

The Transmission Operator did
not have data exchange
capabilities with its Reliability
Coordinator, Balancing
Authority, and identified entities
for performing Real-time
monitoring and Real-time
Assessments as specified in the
Requirement.

Page 17 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

Center, as specified in the
Requirement.

R21

The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for
redundant functionality, but
did so more than 90
calendar days but less than
or equal to 120 calendar
days since the previous test;
OR
The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for
redundant functionality at
least once every 90 calendar
days but, following an
unsuccessful test, initiated
action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.

The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for
redundant functionality, but
did so more than 120 calendar
days but less than or equal to
150 calendar days since the
previous test;
OR
The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for
redundant functionality at least
once every 90 calendar days
but, following an unsuccessful
test, initiated action to restore
the redundant functionality in
more than 4 hours and less
than or equal to 6 hours.

The Transmission Operator tested
its primary Control Center data
exchange capabilities specified in
Requirement R20 for redundant
functionality, but did so more
than 150 calendar days but less
than or equal to 180 calendar
days since the previous test;
OR
The Transmission Operator tested
its primary Control Center data
exchange capabilities specified in
Requirement R20 for redundant
functionality at least once every
90 calendar days but, following an
unsuccessful test, initiated action
to restore the redundant
functionality in more than 6 hours
and less than or equal to 8 hours.

The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for redundant
functionality, but did so more
than 180 calendar days since
the previous test;
OR
The Transmission Operator did
not test its primary Control
Center data exchange
capabilities specified in
Requirement R20 for redundant
functionality;
OR
The Transmission Operator
tested its primary Control
Center data exchange
capabilities specified in
Requirement R20 for redundant
functionality at least once every
90 calendar days but, following
an unsuccessful test, did not
initiate action within 8 hours to

Page 18 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

restore the redundant
functionality.

R22

The Balancing Authority did
not have data exchange
capabilities for developing
its Operating Plan with one
identified entity, or 5% or
less of the applicable
entities, whichever is
greater.

The Balancing Authority did not
have data exchange
capabilities for developing its
Operating Plan with two
identified entities, or more
than 5% or less than or equal
to 10% of the applicable
entities, whichever is greater.

The Balancing Authority did not
have data exchange capabilities
for developing its Operating Plan
with three identified entities, or
more than 10% or less than or
equal to 15% of the applicable
entities, whichever is greater.

The Balancing Authority did not
have data exchange capabilities
for developing its Operating
Plan with four or more
identified entities or greater
than 15% of the applicable
entities, whichever is greater.

R23

N/A

The Balancing Authority had data
exchange capabilities with its
Reliability Coordinator,
Transmission Operator, and
identified entities for performing
Real-time monitoring and analysis
functions, but did not have
redundant and diversely routed
data exchange infrastructure
within the Balancing Authority's
primary Control Center, as
specified in the Requirement.

The Balancing Authority did not
have data exchange capabilities
with its Reliability Coordinator,
Transmission Operator, and
identified entities for
performing Real-time
monitoring and analysis
functions as specified in the
Requirement.

R24

The Balancing Authority
tested its primary Control
Center data exchange
capabilities specified in
Requirement R23 for
redundant functionality, but
did so more than 90

The Balancing Authority tested its
primary Control Center data
exchange capabilities specified in
Requirement R23 for redundant
functionality, but did so more
than 150 calendar days but less

The Balancing Authority tested
its primary Control Center data
exchange capabilities specified
in Requirement R23 for
redundant functionality, but did
so more than 180 calendar days
since the previous test;

Page 19 of 27

TOP-001-4 - Transmission Operations

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

calendar days but less than
or equal to 120 calendar
days since the previous test;
OR
The Balancing Authority
tested its primary Control
Center data exchange
capabilities specified in
Requirement R23 for
redundant functionality at
least once every 90 calendar
days but, following an
unsuccessful test, initiated
action to restore the
redundant functionality in
more than 2 hours and less
than or equal to 4 hours.

150 calendar days since the
previous test;
OR
The Balancing Authority tested
its primary Control Center data
exchange capabilities specified
in Requirement R23 for
redundant functionality at least
once every 90 calendar days
but, following an unsuccessful
test, initiated action to restore
the redundant functionality in
more than 4 hours and less
than or equal to 6 hours.

than or equal to 180 calendar
days since the previous test;
OR
The Balancing Authority tested its
primary Control Center data
exchange capabilities specified in
Requirement R23 for redundant
functionality at least once every
90 calendar days but, following an
unsuccessful test, initiated action
to restore the redundant
functionality in more than 6 hours
and less than or equal to 8 hours.

Severe VSL

OR
The Balancing Authority did not
test its primary Control Center
data exchange capabilities
specified in Requirement R23
for redundant functionality;
OR
The Balancing Authority tested
its primary Control Center data
exchange capabilities specified
in Requirement R23 for
redundant functionality at least
once every 90 calendar days
but, following an unsuccessful
test, did not initiate action
within 8 hours to restore the
redundant functionality.

Page 20 of 27

TOP-001-4 - Transmission Operations

D. Regional Variances
None.

E. Associated Documents

The Implementation Plan and other project documents can be found on the project page.
The Project 2014-03 SDT has created the SOL Exceedance White Paper as guidance on SOL
issues and the URL for that document is:
http://www.nerc.com/pa/stand/Pages/TOP0013RI.aspx.
Operating Plan - An Operating Plan includes general Operating Processes and specific
Operating Procedures. It may be an overview document which provides a prescription for
an Operating Plan for the next-day, or it may be a specific plan to address a specific SOL or
IROL exceedance identified in the Operational Planning Analysis (OPA). Consistent with the
NERC definition, Operating Plans can be general in nature, or they can be specific plans to
address specific reliability issues. The use of the term Operating Plan in the revised
TOP/IRO standards allows room for both. An Operating Plan references processes and
procedures, including electronic data exchange, which are available to the System Operator
on a daily basis to allow the operator to reliably address conditions which may arise
throughout the day. It is valid for tomorrow, the day after, and the day after that. Operating
Plans should be augmented by temporary operating guides which outline
prevention/mitigation plans for specific situations which are identified day-to-day in an OPA
or a Real-time Assessment (RTA). As the definition in the Glossary of Terms states, a
restoration plan is an example of an Operating Plan. It contains all the overarching
principles that the System Operator needs to work his/her way through the restoration
process. It is not a specific document written for a specific blackout scenario but rather a
collection of tools consisting of processes, procedures, and automated software systems
that are available to the operator to use in restoring the system. An Operating Plan can in
turn be looked upon in a similar manner. It does not contain a prescription for the specific
set-up for tomorrow but contains a treatment of all the processes, procedures, and
automated software systems that are at the operator’s disposal. The existence of an
Operating Plan, however, does not preclude the need for creating specific action plans for
specific SOL or IROL exceedances identified in the OPA. When a Reliability Coordinator
performs an OPA, the analysis may reveal instances of possible SOL or IROL exceedances for
pre- or post-Contingency conditions. In these instances, Reliability Coordinators are
expected to ensure that there are plans in place to prevent or mitigate those SOLs or IROLs,
should those operating conditions be encountered the next day. The Operating Plan may
contain a description of the process by which specific prevention or mitigation plans for
day-to-day SOL or IROL exceedances identified in the OPA are handled and communicated.
This approach could alleviate any potential administrative burden associated with perceived
requirements for continual day-to-day updating of “the Operating Plan document” for
compliance purposes.

Page 21 of 27

TOP-001-4 - Transmission Operations

Version History
Version

Date

Action

Change Tracking

April 1,
2005

Effective Date

New

August 8,
2005

Removed “Proposed” from Effective
Date

Errata

November
1, 2006

Adopted by Board of Trustees

Revised

May 12,
2010

Added Appendix 1 – Interpretation of
R8 approved by Board of Trustees on
May 12, 2010

Interpretation

September
15, 2011

FERC Order issued approved the
Interpretation of R8 (FERC Order
became effective November 21,
2011)

Interpretation

May 6,
2012

Revised under Project 2007-03

Revised

May 9,
2012

Adopted by Board of Trustees

Revised

February
12, 2015

Adopted by Board of Trustees

Revisions under Project
2014-03

November
19, 2015

FERC approved TOP-001-3. Docket
No. RM15-16-000. Order No. 817.

Approved

February
9, 2017

Adopted by Board of Trustees

Revised

Page 22 of 27

Supplemental Material

Guidelines and Technical Basis
None

Page 23 of 27

Supplemental Material

Rationale

During development of TOP-001-4, text boxes are embedded within the standard to explain the
rationale for various parts of the standard. Upon Board adoption of TOP-001-4, the text from
the rationale text boxes will be moved to this section.
Rationale text from the development of TOP-001-3 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Rationale for Requirement R3:
The phrase ‘cannot be physically implemented’ means that a Transmission Operator may
request something to be done that is not physically possible due to its lack of knowledge of the
system involved.
Rationale for Requirement R10:
New proposed Requirement R10 is derived from approved IRO-003-2, Requirement R1, adapted
to the Transmission Operator Area. This new requirement is in response to NOPR paragraph 60
concerning monitoring capabilities for the Transmission Operator. New Requirement R11
covers the Balancing Authorities. Monitoring of external systems can be accomplished via data
links.
The revised requirement addresses directives for Transmission Operator (TOP) monitoring of
some non-Bulk Electric System (BES) facilities as necessary for determining System Operating
Limit (SOL) exceedances (FERC Order No. 817 Para 35-36). The proposed requirement
corresponds with approved IRO-002-4 Requirement R4 (proposed IRO-002-5 Requirement R5),
which specifies the Reliability Coordinator's (RC) monitoring responsibilities for determining
SOL exceedances.
The intent of the requirement is to ensure that all facilities (i.e., BES and non-BES) that can
adversely impact reliability of the BES are monitored. As used in TOP and IRO Reliability
Standards, monitoring involves observing operating status and operating values in Real-time for
awareness of system conditions. The facilities that are necessary for determining SOL
exceedances should be either designated as part of the BES, or otherwise be incorporated into
monitoring when identified by planning and operating studies such as the Operational Planning
Analysis (OPA) required by TOP-002-4 Requirement R1 and IRO-008-2 Requirement R1. The SDT
recognizes that not all non-BES facilities that a TOP considers necessary for its monitoring needs
will need to be included in the BES.
The non-BES facilities that the TOP is required to monitor are only those that are necessary for
the TOP to determine SOL exceedances within its Transmission Operator Area. TOPs perform
various analyses and studies as part of their functional obligations that could lead to
identification of non-BES facilities that should be monitored for determining SOL exceedances.
Examples include:
•
•

OPA;
Real-time Assessments (RTA);

Page 24 of 27

Supplemental Material
•
•

Analysis performed by the TOP as part of BES Exception processing for including a
facility in the BES; and
Analysis which may be specified in the RC's outage coordination process that leads the
TOP to identify a non-BES facility that should be temporarily monitored for determining
SOL exceedances.

TOP-003-3 Requirement R1 specifies that the TOP shall develop a data specification which
includes data and information needed by the TOP to support its OPAs, Real-time monitoring,
and RTAs. This includes non-BES data and external network data as deemed necessary by the
TOP.
The format of the proposed requirement has been changed from the approved standard to
more clearly indicate which monitoring activities are required to be performed.
Rationale for Requirement R13:
The new Requirement R13 is in response to NOPR paragraphs 55 and 60 concerning Real-time
analysis responsibilities for Transmission Operators and is copied from approved IRO-008-1,
Requirement R2. The Transmission Operator’s Operating Plan will describe how to perform the
Real-time Assessment. The Operating Plan should contain instructions as to how to perform
Operational Planning Analysis and Real-time Assessment with detailed instructions and timing
requirements as to how to adapt to conditions where processes, procedures, and automated
software systems are not available (if used). This could include instructions such as an
indication that no actions may be required if system conditions have not changed significantly
and that previous Contingency analysis or Real-time Assessments may be used in such a
situation.
Rationale for Requirement R14:
The original Requirement R8 was deleted and original Requirements R9 and R11 were revised in
order to respond to NOPR paragraph 42 which raised the issue of handling all SOLs and not just
a sub-set of SOLs. The SDT has developed a white paper on SOL exceedances that explains its
intent on what needs to be contained in such an Operating Plan. These Operating Plans are
developed and documented in advance of Real-time and may be developed from Operational
Planning Assessments required per proposed TOP-002-4 or other assessments. Operating Plans
could be augmented by temporary operating guides which outline prevention/mitigation plans
for specific situations which are identified day-to-day in an Operational Planning Assessment or
a Real-time Assessment. The intent is to have a plan and philosophy that can be followed by an
operator.
Rationale for Requirements R16 and R17:
In response to IERP Report recommendation 3 on authority.
Rationale for Requirement R18:
Moved from approved IRO-005-3.1a, Requirement R10. Transmission Service Provider,
Distribution Provider, Load-Serving Entity, Generator Operator, and Purchasing-Selling Entity
are deleted as those entities will receive instructions on limits from the responsible entities

Page 25 of 27

Supplemental Material
cited in the requirement. Note – Derived limits replaced by SOLs for clarity and specificity. SOLs
include voltage, Stability, and thermal limits and are thus the most limiting factor.
Rationale for Requirements R19 and R20 (R19, R20, R22, and R23 in TOP-001-4):
Added for consistency with proposed IRO-002-4, Requirement R1. Data exchange capabilities
are required to support the data specification concept in proposed TOP-003-3.
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
or malfunction of an individual component within the Transmission Operator's (TOP) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R20 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the TOP's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the TOP's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R21:
The proposed requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.

Page 26 of 27

Supplemental Material
Rationale for Requirements R22 and R23:
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
or malfunction of an individual component within the Balancing Authority's (BA) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R23 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the BA's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the BA's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R24:
The proposed requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component(e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.

Page 27 of 27

Standard TOP-001-34 - Transmission Operations

A. Introduction
1.

Title:

Transmission Operations

Number:

TOP-001-3

Applicability:

4.1. Functional Entities:
4.1.1. Balancing Authority
4.1.2. Transmission Operator
4.1.3. Generator Operator
4.1.4. Distribution Provider
5.

Effective Date: See Implementation Plan
See Implementation Plan.

Background:
See Project 2014-03 project page.

B. Requirements and Measures
R1.

Page 1 of 44

Standard TOP-001-34 - Transmission Operations

the reliability of its Balancing Authority Area via its own actions or by issuing
Operating Instructions.

R3.

Standard TOP-001-34 - Transmission Operations

requirements. Such evidence could include but is not limited to dated operator logs,
voice recordings or transcripts of voice recordings, electronic communications, or
other equivalent evidence in electronic or hard copy format. In such cases, the
Transmission Operator, Generator Operator, and Distribution Provider shall have and
provide copies of the safety, equipment, regulatory, or statutory requirements as
evidence for not complying with the Balancing Authority’s Operating Instruction. If
such a situation has not occurred, the Transmission Operator, Generator Operator, or
Distribution Provider may provide an attestation.
R6.

Page 3 of 44

Standard TOP-001-34 - Transmission Operations

M9. Each Balancing Authority and Transmission Operator shall make available upon
request, evidence that it notified its Reliability Coordinator and known impacted
interconnected entities of all planned outages, and unplanned outages of 30 minutes
or more, for telemetering and control equipment, monitoring and assessment
capabilities, and associated communication channels. Such evidence could include but
is not limited to dated operator logs, voice recordings or transcripts of voice
recordings, electronic communications, or other equivalent evidence. If such a
situation has not occurred, the Balancing Authority or Transmission Operator may
provide an attestation.
R10. Each Transmission Operator shall perform the following as necessary for determining
System Operating Limit (SOL) exceedances within its Transmission Operator Area:
[Violation Risk Factor: High] [Time Horizon: Real-Time Operations]
10.1. Within Monitor Facilities within its Transmission Operator Area, monitor
Facilities and;
10.1. Monitor the status of Special Protection Systems, and
10.2. OutsideRemedial Action Schemes within its Transmission Operator Area,
obtain;
10.3.

Monitor non-BES facilities within its Transmission Operator Area identified as
necessary by the Transmission Operator;

10.4.

Obtain and utilize status, voltages, and flow data for Facilities outside its
Transmission Operator Area identified as necessary by the Transmission
Operator;

10.5.

Obtain and utilize the status of Special Protection SystemsRemedial Action
Schemes outside its Transmission Operator Area identified as necessary by
the Transmission Operator; and

Page 4 of 44

Standard TOP-001-34 - Transmission Operations

10.2.10.6. Obtain and utilize status, voltages, and flow data for non-BES facilities
outside its Transmission Operator Area identified as necessary by the
Transmission Operator.
M10. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to Energy Management System description
documents, computer printouts, SCADASupervisory Control and Data Acquisition
(SCADA) data collection, or other equivalent evidence that will be used to confirm
that it monitored or obtained and utilized status, voltages, and flow data for Facilities
and the status of Special Protection Systemsdata as required to determine any System
Operating Limit (SOL) exceedances within its Transmission Operator Area.
R11. Each Balancing Authority shall monitor its Balancing Authority Area, including the
status of Special Protection SystemsRemedial Action Schemes that impact generation
or Load, in order to maintain generation-Load-interchange balance within its
Balancing Authority Area and support Interconnection frequency. [Violation Risk
Factor: High] [Time Horizon: Real-Time Operations]
M11. Each Balancing Authority shall have, and provide upon request, evidence that could
include but is not limited to Energy Management System description documents,
computer printouts, SCADA data collection, or other equivalent evidence that will be
used to confirm that it monitors its Balancing Authority Area, including the status of
Special Protection SystemsRemedial Action Schemes that impact generation or Load,
in order to maintain generation-Load-interchange balance within its Balancing
Authority Area and support Interconnection frequency.
R12. Each Transmission Operator shall not operate outside any identified Interconnection
Reliability Operating Limit (IROL) for a continuous duration exceeding its associated
IROL Tv. [Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M12. Each Transmission Operator shall make available evidence to show that for any
occasion in which it operated outside any identified Interconnection Reliability
Operating Limit (IROL), the continuous duration did not exceed its associated IROL Tv.
Such evidence could include but is not limited to dated computer logs or reports in
electronic or hard copy format specifying the date, time, duration, and details of the
excursion. If such a situation has not occurred, the Transmission Operator may
provide an attestation that an event has not occurred.
R13. Each Transmission Operator shall ensure that a Real-time Assessment is performed at
least once every 30 minutes. [Violation Risk Factor: High] [Time Horizon: Real-time
Operations]
M13. Each Transmission Operator shall have, and make available upon request, evidence to
show it ensured that a Real-Time Assessment was performed at least once every 30
minutes. This evidence could include but is not limited to dated computer logs
showing times the assessment was conducted, dated checklists, or other evidence.

Page 5 of 44

Standard TOP-001-34 - Transmission Operations

R14. Each Transmission Operator shall initiate its Operating Plan to mitigate a SOL
exceedance identified as part of its Real-time monitoring or Real-time Assessment.
[Violation Risk Factor: High] [Time Horizon: Real-time Operations]
M14. Each Transmission Operator shall have evidence that it initiated its Operating Plan for
mitigating SOL exceedances identified as part of its Real-time monitoring or Real-time
Assessments. This evidence could include but is not limited to dated computer logs
showing times the Operating Plan was initiated, dated checklists, or other evidence.
R15. Each Transmission Operator shall inform its Reliability Coordinator of actions taken to
return the System to within limits when a SOL has been exceeded. [Violation Risk
Factor: Medium] [Time Horizon: Real-Time Operations]
M15. Each Transmission Operator shall make available evidence that it informed its
Reliability Coordinator of actions taken to return the System to within limits when a
SOL was exceeded. Such evidence could include but is not limited to dated operator
logs, voice recordings or transcripts of voice recordings, or dated computer printouts.
If such a situation has not occurred, the Transmission Operator may provide an
attestation.
R16. Each Transmission Operator shall provide its System Operators with the authority to
approve planned outages and maintenance of its telemetering and control
equipment, monitoring and assessment capabilities, and associated communication
channels between affected entities. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M16. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to a documented procedure or equivalent evidence
that will be used to confirm that the Transmission Operator has provided its System
Operators with the authority to approve planned outages and maintenance of
telemetering and control equipment, monitoring and assessment capabilities, and
associated communication channels between affected entities.
R17. Each Balancing Authority shall provide its System Operators with the authority to
approve planned outages and maintenance of its telemetering and control
equipment, monitoring and assessment capabilities, and associated communication
channels between affected entities. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M17. Each Balancing Authority shall have, and provide upon request, evidence that could
include but is not limited to a documented procedure or equivalent evidence that will
be used to confirm that the Balancing Authority has provided its System Operators
with the authority to approve planned outages and maintenance of its telemetering
and control equipment, monitoring and assessment capabilities, and associated
communication channels between affected entities.

Page 6 of 44

Standard TOP-001-34 - Transmission Operations

R18. Each Transmission Operator shall operate to the most limiting parameter in instances
where there is a difference in SOLs. [Violation Risk Factor: High] [Time Horizon:
Operations Planning, Same-Day Operations, Real-time Operations]
M18. M18. Each Transmission Operator shall have, and provide upon request, evidence that
could include but is not limited to operator logs, voice recordings, electronic
communications, or equivalent evidence that will be used to determine if it operated
to the most limiting parameter in instances where there is a difference in SOLs.
R19. Each Transmission Operator shall have data exchange capabilities with the entities
that it has identified that it needs data from in order to maintain reliability inperform
its Transmission Operator Area.Operational Planning Analyses. [Violation Risk Factor:
HighMedium] [Time Horizon: Operations Planning, Same-Day Operations, Real-time
Operations] ]
M19. M19. Each Transmission Operator shall have, and provide upon request, evidence that
could include, but is not limited to, operator logs, system specifications, system
diagrams, or other evidence that it has data exchange capabilities with the entities
that it has identified that it needs data from in order to maintain reliability inperform
its Transmission Operator AreaOperational Planning Analyses.
R20. Each Balancing AuthorityTransmission Operator shall have data exchange capabilities,
with redundant and diversely routed data exchange infrastructure within the
Transmission Operator's primary Control Center, for the exchange of Real-time data
with its Reliability Coordinator, Balancing Authority, and the entities that it has
identified that it needs data from in order for it to maintain reliability in its Balancing
Authority Area.perform its Real-time monitoring and Real-time Assessments.
[Violation Risk Factor: High] [Time Horizon: Operations Planning, Same-Day
Operations, Real-time Operations]
M20. M20. Each Transmission Operator shall have, and provide upon request, evidence that
could include, but is not limited to, system specifications, system diagrams, or other
documentation that lists its data exchange capabilities, including redundant and
diversely routed data exchange infrastructure within the Transmission Operator's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Balancing Authority, and the entities it has identified it needs data from
in order to perform its Real-time monitoring and Real-time Assessments as specified
in the requirement.
R21. Each Transmission Operator shall test its primary Control Center data exchange
capabilities specified in Requirement R20 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Transmission Operator shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]

Page 7 of 44

Standard TOP-001-34 - Transmission Operations

M21. Each Transmission Operator shall have, and provide upon request, evidence that it
tested its primary Control Center data exchange capabilities specified in Requirement
R20 for the redundant functionality, or experienced an event that demonstrated the
redundant functionality; and, if the test was unsuccessful, initiated action within two
hours to restore redundant functionality as specified in Requirement R21. Evidence
could include, but is not limited to: dated and time-stamped test records, operator
logs, voice recordings, or electronic communications.
R22. Each Balancing Authority shall have data exchange capabilities with the entities it has
identified it needs data from in order to develop its Operating Plan for next-day
operations. [Violation Risk Factor: Medium] [Time Horizon: Operations Planning]
M22. Each Balancing Authority shall have, and provide upon request, evidence that could
include, but is not limited to, operator logs, system specifications, system diagrams, or
other evidence that it has data exchange capabilities with the entities it has identified
it needs data from in order to develop its Operating Plan for next-day operations.
R23. Each Balancing Authority shall have data exchange capabilities, with redundant and
diversely routed data exchange infrastructure within the Balancing Authority's
primary Control Center, for the exchange of Real-time data with its Reliability
Coordinator, Transmission Operator, and the entities it has identified it needs data
from in order for it to perform its Real-time monitoring and analysis functions.
[Violation Risk Factor: High] [Time Horizon: Same-Day Operations, Real-time
Operations]
M20.M23. Each Balancing Authority shall have, and provide upon request, evidence that
could include, but is not limited to, operator logs, system specifications, system
diagrams, or other evidencedocumentation that it haslists its data exchange
capabilities, including redundant and diversely routed data exchange infrastructure
within the Balancing Authority's primary Control Center, for the exchange of Realtime data with its Reliability Coordinator, Transmission Operator, and the entities that
it has identified that it needs data from in order to maintain reliabilityperform its
Real-time monitoring and analysis functions as specified in its Balancing Authority
Areathe requirement.
R24. Each Balancing Authority shall test its primary Control Center data exchange
capabilities specified in Requirement R23 for redundant functionality at least once
every 90 calendar days. If the test is unsuccessful, the Balancing Authority shall
initiate action within two hours to restore redundant functionality. [Violation Risk
Factor: Medium ] [Time Horizon: Operations Planning]
M24. Each Balancing Authority shall have, and provide upon request, evidence that it tested
its primary Control Center data exchange capabilities specified in Requirement R23 for
redundant functionality, or experienced an event that demonstrated the redundant
functionality; and, if the test was unsuccessful, initiated action within two hours to
restore redundant functionality as specified in Requirement R24. Evidence could

Page 8 of 44

Standard TOP-001-34 - Transmission Operations

include, but is not limited to: dated and time-stamped test records, operator logs,
voice recordings, or electronic communications.

C. Compliance
1.

Compliance Monitoring Process
1.1. Compliance Enforcement Authority:
As defined in the NERC Rules of Procedure, “Compliance Enforcement
Authority” (CEA) means NERC or the Regional Entity, or any entity as otherwise
designated by an Applicable Governmental Authority, in their respective roles
of monitoring and/or enforcing compliance with the NERCmandatory and
enforceable Reliability Standards in their respective jurisdictions.
1.2. Compliance Monitoring and Assessment Processes
As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Assessment Processes” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated reliability standard.
1.3.1.2.
DataEvidence Retention:
The following evidence retention periodsperiod(s) identify the period of time an
entity is required to retain specific evidence to demonstrate compliance. For
instances where the evidence retention period specified below is shorter than
the time since the last audit, the Compliance Enforcement Authority may ask an
entity to provide other evidence to show that it was compliant for the full-time
period since the last audit.
The applicable entity shall keep data or evidence to show compliance as
identified below unless directed by its Compliance Enforcement Authority to
retain specific evidence for a longer period of time as part of an investigation.
•

Each Balancing Authority, Transmission Operator, Generator Operator, and
Distribution Provider shall each keep data or evidence for each applicable
Requirement R1 through R11, and R15 through R20 and Measure M1 through
M11, and M15 through M20 for the current calendar year and one previous
calendar year, with the exception of operator logs and voice recordings which
shall be retained for a minimum of ninety90 calendar days, unless directed by
its Compliance Enforcement Authority to retain specific evidence for a longer
period of time as part of an investigation.

•

Each Transmission Operator shall retain evidence for three calendar years of
any occasion in which it has exceeded an identified IROL and its associated
IROL Tv as specified in Requirement R12 and Measure M12 and that it initiated
its Operating Plan to mitigate a SOL exceedance as specified in Requirement
R14 and Measurement M14.

Page 9 of 44

Standard TOP-001-34 - Transmission Operations

•

If a Balancing Authority,Each Transmission Operator , Generator Operator, or
Distribution Provider is found non-compliant, it shall keep information related
to the non-compliance until mitigation is completeretain evidence and
approved or the time periodthat it initiated its Operating Plan to mitigate a
SOL exceedance as specified above, whichever is longerin Requirement R14
and Measurement M14 for three calendar years.
The Compliance Enforcement Authority shall keep the last audit records and all
requested and submitted subsequent audit records.

1.4. Additional Compliance Information
•

•

Each Transmission Operator shall keep data or evidence for Requirement R20
and Measure M20 for the current calendar year and one previous calendar
year.

•

Each Balancing Authority shall keep data or evidence for Requirement R22 and
Measure M22 for the current calendar year and one previous calendar year,
with the exception of operator logs and voice recordings which shall be
retained for a minimum of 90 calendar days.

•

Each Balancing Authority shall keep data or evidence for Requirement R23 and
Measure M23 for the current calendar year and one previous calendar year.

•

1.3. Compliance Monitoring and Enforcement Program

Page 10 of 44

Standard TOP-001-34 - Transmission Operations

As defined in the NERC Rules of Procedure, “Compliance Monitoring and
Enforcement Program” refers to the identification of the processes that will be
used to evaluate data or information for the purpose of assessing performance
or outcomes with the associated Reliability Standard.

Page 11 of 44

Standard TOP-001-34 - Transmission Operations

Violation Severity Levels
None.

Page 12 of 44

Standard TOP-001-34 - Transmission Operations

Table of Compliance Elements
R
#

Time
Horiz
on

R
1

Same
-Day
Oper
ation
s,
Realtime
Oper
ation
s

R
2

Same
-Day
Oper
ation
s,
Realtime
Oper
ation
s

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

High

N/A

The
Transmission
Operator
failed to act
to maintain
the
reliability of
its
Transmission
Operator
Area via its
own actions
or by issuing
Operating
Instructions.

High

N/A

The
Balancing
Authority
failed to act
to maintain
the
reliability of
its Balancing
Authority
Area via its
own actions
or by issuing

Page 13 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

Operating
Instructions.

R
3

Same
-Day
Oper
ation
s,
RealTime
Oper
ation
s

High

N/A

The
responsible
entity did
not comply
with an
Operating
Instruction
issued by the
Transmission
Operator,
and such
action could
have been
physically
implemente
d and would
not have
violated
safety,
equipment,
regulatory,
or statutory
requirement
s.

R
4

Same
-Day
Oper

High

N/A

The
responsible
entity did
not inform
Page 14 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

ation
s,
RealTime
Oper
ation
s

R
5

Same
-Day
Oper
ation
s,
Realtime
Oper
ation
s

Severe VSL

its
Transmission
Operator of
its inability
to comply
with an
Operating
Instruction
issued by its
Transmission
Operator.
High

N/A

The
responsible
entity did
not comply
with an
Operating
Instruction
issued by the
Balancing
Authority,
and such
action could
have been
physically
implemente
d and would
not have
violated
safety,

Page 15 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

equipment,
regulatory,
or statutory
requirement
s.

R
6

Same
-Day
Oper
ation
s,
RealTime
Oper
ation
s

High

N/A

Real-Time
Operations
N/A

Hig
h

N/A

The
responsible
entity did
not inform
its Balancing
Authority of
its inability
to comply
with an
Operating
Instruction
issued by its
Balancing
Authority.
N/A

The
Transmission
Operator did
not provide
comparable
assistance to
other
Transmission
Operators
within its
Reliability
Page 16 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

Coordinator
Area, when
requested
and able,
and the
requesting
entity had
implemente
d its
Emergency
procedures,
and such
actions
could have
been
physically
implemente
d and would
not have
violated
safety,
equipment,
regulatory,
or statutory
requirement
s.
For the Requirements R8 and R9 VSLs only, the intent of the SDT is to start with the Severe VSL first and then to work your way
to the left until you find the situation that fits. In this manner, the VSL will not be discriminatory by size of entity. If a small
entity has just one affected reliability entity to inform, the intent is that that situation would be a Severe violation.

Page 17 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

R
8

Oper
ation
s
Plan
ning,
Same
-Day
Oper
ation
s,
RealTime
Oper
ation
s

Violation Severity Levels

VRF

High

Lower VSL

Moderate VSL

High VSL

Severe VSL

The Transmission Operator did not
inform two known impacted
Transmission Operators or more
than 5% and less than or equal to
10% of the known impacted
Transmission Operators, whichever
is greater, of its actual or expected
operations that resulted in, or
could have resulted in, an
Emergency on respective
Transmission Operator Areas.
OR,
The Transmission Operator did not
inform two known impacted
Balancing Authorities or more than
5% and less than or equal to 10% of
the known impacted Balancing
Authorities, whichever is greater, of
its actual or expected operations
that resulted in, or could have
resulted in, an Emergency on
respective Balancing Authority
Areas.

The Transmission Operator did not
inform three known impacted
Transmission Operators or more than
10% and less than or equal to 15% of
the known impacted Transmission
Operators, whichever is greater, of its
actual or expected operations that
resulted in, or could have resulted in,
an Emergency on respective
Transmission Operator Areas.
OR,
The Transmission Operator did not
inform three known impacted
Balancing Authorities or more than
10% and less than or equal to 15% of
the known impacted Balancing
Authorities, whichever is greater, of
its actual or expected operations that
resulted in, or could have resulted in,
an Emergency on respective
Balancing Authority Areas.

Page 18 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

known impacted
Balancing
Authorities,
whichever is
greater, of its
actual or
expected
operations that
resulted in, or
could have
resulted in, an
Emergency on
respective
Balancing
Authority Areas.

Moderate VSL

High VSL

Severe VSL

more than
15% of the
known
impacted
Transmission
Operators of
its actual or
expected
operations
that resulted
in, or could
have
resulted in,
an
Emergency
on those
respective
Transmission
Operator
Areas.
OR,
The
Transmission
Operator did
not inform
four or more
known
impacted
Balancing
Authorities

Page 19 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

or more
than 15% of
the known
impacted
Balancing
Authorities
of its actual
or expected
operations
that resulted
in, or could
have
resulted in,
an
Emergency
on
respective
Balancing
Authority
Areas.

R
9

Oper
ation
s
Plan
ning,
Same
-Day
Oper
ation
s,

Medium

The responsible
entity did not
notify one known
impacted
interconnected
entity or 5% or
less of the known
impacted
entities,
whichever is

The responsible entity did not
notify two known impacted
interconnected entities or more
than 5% and less than or equal to
10% of the known impacted
entities, whichever is greater, of a
planned outage, or an unplanned
outage of 30 minutes or more, for
telemetering and control
equipment, monitoring and

The responsible entity did not notify
three known impacted
interconnected entities or more than
10% and less than or equal to 15% of
the known impacted entities,
whichever is greater, of a planned
outage, or an unplanned outage of
30 minutes or more, for telemetering
and control equipment, monitoring
and assessment capabilities, or

The
responsible
entity did
not notify its
Reliability
Coordinator
of a planned
outage, or
an
unplanned

Page 20 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

RealTime
Oper
ation
s

Violation Severity Levels

VRF
Lower VSL

greater, of a
planned outage,
or an unplanned
outage of 30
minutes or more,
for telemetering
and control
equipment,
monitoring and
assessment
capabilities, or
associated
communication
channels
between the
affected entities.

Moderate VSL

assessment capabilities, or
associated communication
channels between the affected
entities.

High VSL

associated communication channels
between the affected entities.

Severe VSL

outage of 30
minutes or
more, for
telemetering
and control
equipment,
monitoring
and
assessment
capabilities,
and
associated
communicati
on channels.
OR,
The
responsible
entity did
not notify
four or more
known
impacted
interconnect
ed entities
or more
than 15% of
the known
impacted
entities,
whichever is

Page 21 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

greater, of a
planned
outage, or
an
unplanned
outage of 30
minutes or
more, for
telemetering
and control
equipment,
monitoring
and
assessment
capabilities,
or
associated
communicati
on channels
between the
affected
entities.

R
1
0

RealTime
Oper
ation
s

Hig
h

N/A

The Transmission
Operator did not
monitor, obtain,
or utilize one of
the items
required or
identified as
necessary by the

The Transmission Operator did not
monitor one, obtain, or utilize two
of the items required or identified
as necessary by the Transmission
Operator and listed in Requirement
R10, Part 10.1 and did not obtain
and utilize one of the items listed in

The Transmission Operator did not
monitor Facilities and the status of
Special Protection Systems within its
Transmission Operator Area and did
not, obtain and, or utilize data
deemedthree of the items required or
identified as necessary from outside
itsby the Transmission Operator

The
Transmission
Operator did
not monitor,
obtain, or
utilize four
or more of
the items

Page 22 of 44

Standard TOP-001-34 - Transmission Operations

R
#

R11

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

Transmission
Operator and
listed in
Requirement
R10, Part 10.1.
OR,
The Transmission
Operator did not
obtain and utilize
one of the items
listed in
Requirement
R10, Part
through 10.26.

Requirement R10, Partthrough
10.2. 6.

Areaand listed in Requirement R10,
Part 10.1 through 10.6.

required or
identified as
necessary by
the
Transmission
Operator
and listed in
Requirement
R10 Part
10.1 through
10.6.

Real-Time
OperationsN/A

HighN/A

The Balancing Authority did not
monitor the status of Special
Protection SystemsRemedial Action
Schemes that impact generation or
Load, in order to maintain generationLoad-interchange balance within its
Balancing Authority Area and support
Interconnection frequency.

The
Balancing
Authority
did not
monitor its
Balancing
Authority
Area, in
order to
maintain
generationLoadinterchange
balance
within its
Balancing

N/A

Page 23 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

Authority
Area and
support
Interconnect
ion
frequency.

R12

R
1
3

Same
-Day
Oper
ation
s,

High

Real-Time
Operations N/A

HighN/A

N/A

For any sample
24-hour period
within the 30-day
retention period,
the Transmission
Operator’s Realtime Assessment

For any sample 24-hour period
within the 30-day retention period,
the Transmission Operator’s Realtime Assessment was not
conducted for two 30-minute
periods within that 24-hour period.

For any sample 24-hour period within
the 30-day retention period, the
Transmission Operator’s Real-time
Assessment was not conducted for
three 30-minute periods within that
24-hour period.

The
Transmission
Operator
exceeded an
identified
Interconnect
ion
Reliability
Operating
Limit (IROL)
for a
continuous
duration
greater than
its
associated
IROL Tv.
For any
sample 24hour period
within the
30-day
retention
period, the
Page 24 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

RealTime
Oper
ation
s

R14.

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

was not
conducted for
one 30-minute
period within
that 24-hour
period.

Real-Time
OperationsN/A

Transmission
Operator’s
Real-time
Assessment
was not
conducted
for four or
more 30minute
periods
within that
24-hour
period.
HighN/A

N/A

The
Transmission
Operator did
not initiate
its Operating
Plan for
mitigating a
SOL
exceedance
identified as
part of its
Real-time
monitoring
or Real-time
Assessment

Page 25 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

R15.

Real-Time
Operations N/A

N/AMedium

N/A

The
Transmission
Operator did
not inform
its Reliability
Coordinator
of actions
taken to
return the
System to
within limits
when a SOL
had been
exceeded.

R16.

Operations
Planning, SameDay Operations,
Real-Time
Operations N/A

N/AHigh

N/A

The
Transmission
Operator did
not provide
its System
Operators
with the
authority to
approve
planned
outages and
maintenance
of its
telemetering
and control
equipment,

Page 26 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

monitoring
and
assessment
capabilities,
and
associated
communicati
on channels
between
affected
entities.

R17.

Operations
Planning, SameDay Operations,
Real-Time
Operations N/A

High N/A

N/A

The
Balancing
Authority
did not
provide its
System
Operators
with the
authority to
approve
planned
outages and
maintenance
of its
telemetering
and control
equipment,
monitoring
and

Page 27 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

assessment
capabilities,
and
associated
communicati
on channels
between
affected
entities.

R18

R
1
9

Oper
ation
s
Plan
ning,
Same
-Day

High

Operations
Planning, SameDay Operations,
Real-time
OperationsN/A

HighN/A

N/A

The Transmission
Operator did not
have data
exchange
capabilities for
performing its
Operational
Planning

The Transmission Operator did not
have data exchange capabilities for
performing its Operational Planning
Analyses with two identified
entities, or more than 5% or less
than or equal to 10% of the

The Transmission Operator did not
have data exchange capabilities for
performing its Operational Planning
Analyses with three identified
entities, or more than 10% or less
than or equal to 15% of the applicable
entities, whichever is greater.

The
Transmission
Operator
failed to
operate to
the most
limiting
parameter in
instances
where there
was a
difference in
SOLs.
The
Transmission
Operator did
not have
data
exchange
capabilities
for
Page 28 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Oper
ation
s,
Realtime
Oper
ation
s

R20

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

Analyses with
one identified
entity, or 5% or
less of the
applicable
entities,
whichever is
greater.

applicable entities, whichever is
greater.

N/A

High VSL

Severe VSL

performing
its
Operational
Planning
Analyses
with four or
more
identified
entities or
greater than
15% of the
applicable
entities,
whichever is
greater.
The Transmission Operator had data
exchange capabilities with its
Reliability Coordinator, Balancing
Authority, and identified entities for
performing Real-time monitoring and
Real-time Assessments, but did not
have redundant and diversely routed
data exchange infrastructure within
the Transmission Operator's primary
Control Center, as specified in the
Requirement.

The
Transmission
Operator did
not have
data
exchange
capabilities
with its
Reliability
Coordinator,
Balancing
Authority,
and
identified
entities for

Page 29 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

performing
Real-time
monitoring
and Realtime
Assessments
as specified
in the
Requirement
.

R21

The Transmission Operator tested
its primary Control Center data
exchange capabilities specified in
Requirement R20 for redundant
functionality, but did so more than
120 calendar days but less than or
equal to 150 calendar days since
the previous test;
OR
The Transmission Operator tested
its primary Control Center data
exchange capabilities specified in
Requirement R20 for redundant
functionality at least once every 90
calendar days but, following an
unsuccessful test, initiated action
to restore the redundant
functionality in more than 4 hours
and less than or equal to 6 hours.

The Transmission Operator tested its
primary Control Center data exchange
capabilities specified in Requirement
R20 for redundant functionality, but
did so more than 150 calendar days
but less than or equal to 180 calendar
days since the previous test;
OR
The Transmission Operator tested its
primary Control Center data exchange
capabilities specified in Requirement
R20 for redundant functionality at
least once every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in more than
6 hours and less than or equal to 8
hours.

Page 30 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

The Transmission
Operator tested
its primary
Control Center
data exchange
capabilities
specified in
Requirement R20
for redundant
functionality at
least once every
90 calendar days
but, following an
unsuccessful test,
initiated action
to restore the
redundant
functionality in
more than 2
hours and less
than or equal to
4 hours.

Moderate VSL

High VSL

Severe VSL

OR
The
Transmission
Operator did
not test its
primary
Control
Center data
exchange
capabilities
specified in
Requirement
R20 for
redundant
functionality
;
OR
The
Transmission
Operator
tested its
primary
Control
Center data
exchange
capabilities
specified in
Requirement
R20 for
Page 31 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

redundant
functionality
at least once
every 90
calendar
days but,
following an
unsuccessful
test, did not
initiate
action within
8 hours to
restore the
redundant
functionality
.
R
2
0

R
2
2

Oper
ation
s
Plan
ning,
Same
-Day
Oper
ation
s,
Realtime
Oper

High

The Balancing
Authority did not
have data
exchange
capabilities for
developing its
Operating Plan
with one
identified entity,
or 5% or less of
the applicable
entities,
whichever is
greater.

The Balancing Authority did not
have data exchange capabilities for
developing its Operating Plan with
two identified entities, or more
than 5% or less than or equal to
10% of the applicable entities,
whichever is greater.

The Balancing Authority did not have
data exchange capabilities for
developing its Operating Plan with
three identified entities, or more than
10% or less than or equal to 15% of
the applicable entities, whichever is
greater.

The
Balancing
Authority
did not have
data
exchange
capabilities
for
developing
its Operating
Plan with
four or more
identified
entities or

Page 32 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

ation
s

R23

Severe VSL

greater than
15% of the
applicable
entities,
whichever is
greater.
N/A

N/A

The Balancing Authority had data
exchange capabilities with its
Reliability Coordinator, Transmission
Operator, and identified entities for
performing Real-time monitoring and
analysis functions, but did not have
redundant and diversely routed data
exchange infrastructure within the
Balancing Authority's primary Control
Center, as specified in the
Requirement.

The
Balancing
Authority
did not have
data
exchange
capabilities
with its
Reliability
Coordinator,
Transmission
Operator,
and
identified
entities for
performing
Real-time
monitoring
and analysis
functions as
specified in
the
Requirement
.

Page 33 of 44

Standard TOP-001-34 - Transmission Operations

R
#

R24

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

The Balancing
Authority tested
its primary
Control Center
data exchange
capabilities
specified in
Requirement R23
for redundant
functionality, but
did so more than
90 calendar days
but less than or
equal to 120
calendar days
since the
previous test;
OR
The Balancing
Authority tested
its primary
Control Center
data exchange
capabilities
specified in
Requirement R23
for redundant
functionality at
least once every
90 calendar days

The Balancing Authority tested its
primary Control Center data
exchange capabilities specified in
Requirement R23 for redundant
functionality, but did so more than
120 calendar days but less than or
equal to 150 calendar days since
the previous test;
OR
The Balancing Authority tested its
primary Control Center data
exchange capabilities specified in
Requirement R23 for redundant
functionality at least once every 90
calendar days but, following an
unsuccessful test, initiated action
to restore the redundant
functionality in more than 4 hours
and less than or equal to 6 hours.

The Balancing Authority tested its
primary Control Center data exchange
capabilities specified in Requirement
R23 for redundant functionality, but
did so more than 150 calendar days
but less than or equal to 180 calendar
days since the previous test;
OR
The Balancing Authority tested its
primary Control Center data exchange
capabilities specified in Requirement
R23 for redundant functionality at
least once every 90 calendar days but,
following an unsuccessful test,
initiated action to restore the
redundant functionality in more than
6 hours and less than or equal to 8
hours.

The
Balancing
Authority
tested its
primary
Control
Center data
exchange
capabilities
specified in
Requirement
R23 for
redundant
functionality
, but did so
more than
180 calendar
days since
the previous
test;
OR
The
Balancing
Authority
did not test
its primary
Control
Center data
exchange

Page 34 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

but, following an
unsuccessful test,
initiated action
to restore the
redundant
functionality in
more than 2
hours and less
than or equal to
4 hours.

Moderate VSL

High VSL

Severe VSL

capabilities
specified in
Requirement
R23 for
redundant
functionality
;
OR
The
Balancing
Authority
tested its
primary
Control
Center data
exchange
capabilities
specified in
Requirement
R23 for
redundant
functionality
at least once
every 90
calendar
days but,
following an
unsuccessful
test, did not
initiate

Page 35 of 44

Standard TOP-001-34 - Transmission Operations

R
#

Time
Horiz
on

Violation Severity Levels

VRF
Lower VSL

Moderate VSL

High VSL

Severe VSL

action within
8 hours to
restore the
redundant
functionality
.

Page 36 of 44

Standard TOP-001-34 - Transmission Operations

D. Regional Variances
None.

E. Interpretations
None.

F.E.

Associated Documents

TheThe Implementation Plan and other project documents can be found on the project
page.
The Project 2014-03 SDT has created the SOL Exceedance White Paper as guidance on SOL
issues and the URL for that document is:
http://www.nerc.com/pa/stand/Pages/TOP0013RI.aspx.

Operating Plan - An Operating Plan includes general Operating Processes and specific
Operating Procedures. It may be an overview document which provides a prescription for
an Operating Plan for the next-day, or it may be a specific plan to address a specific SOL or
IROL exceedance identified in the Operational Planning Analysis (OPA). Consistent with the
NERC definition, Operating Plans can be general in nature, or they can be specific plans to
address specific reliability issues. The use of the term Operating Plan in the revised
TOP/IRO standards allows room for both. An Operating Plan references processes and
procedures, including electronic data exchange, which are available to the System Operator
on a daily basis to allow the operator to reliably address conditions which may arise
throughout the day. It is valid for tomorrow, the day after, and the day after that. Operating
Plans should be augmented by temporary operating guides which outline
prevention/mitigation plans for specific situations which are identified day-to-day in an OPA
or a Real-time Assessment (RTA). As the definition in the Glossary of Terms states, a
restoration plan is an example of an Operating Plan. It contains all the overarching
principles that the System Operator needs to work his/her way through the restoration
process. It is not a specific document written for a specific blackout scenario but rather a
collection of tools consisting of processes, procedures, and automated software systems
that are available to the operator to use in restoring the system. An Operating Plan can in
turn be looked upon in a similar manner. It does not contain a prescription for the specific
set-up for tomorrow but contains a treatment of all the processes, procedures, and
automated software systems that are at the operator’s disposal. The existence of an
Operating Plan, however, does not preclude the need for creating specific action plans for
specific SOL or IROL exceedances identified in the OPA. When a Reliability Coordinator
performs an OPA, the analysis may reveal instances of possible SOL or IROL exceedances for
pre- or post-Contingency conditions. In these instances, Reliability Coordinators are
expected to ensure that there are plans in place to prevent or mitigate those SOLs or IROLs,
should those operating conditions be encountered the next day. The Operating Plan may
contain a description of the process by which specific prevention or mitigation plans for
day-to-day SOL or IROL exceedances identified in the OPA are handled and communicated.
This approach could alleviate any potential administrative burden associated with perceived

Page 37 of 44

Standard TOP-001-34 - Transmission Operations

requirements for continual day-to-day updating of “the Operating Plan document” for
compliance purposes.

Page 38 of 44

Standard TOP-001-34 - Transmission Operations

Version History
Version

Date

Action

Change Tracking

April 1,
2005

Effective Date

New

August 8,
2005

Removed “Proposed” from Effective
Date

Errata

November
1, 2006

Adopted by Board of Trustees

Revised

May 12,
2010

Added Appendix 1 – Interpretation of
R8 approved by Board of Trustees on
May 12, 2010

Interpretation

September
15, 2011

FERC Order issued approved the
Interpretation of R8 (FERC Order
became effective November 21,
2011)

Interpretation

May 6,
2012

Revised under Project 2007-03

Revised

May 9,
2012

Adopted by Board of Trustees

Revised

February
12, 2015

Adopted by Board of Trustees

Revisions under Project
2014-03

November
19, 2015

FERC approved TOP-001-3. Docket
No. RM15-16-000. Order No. 817.

Approved

February
9, 2017

Adopted by Board of Trustees

Revised

Page 39 of 44

Supplemental Material

Guidelines and Technical Basis
None

Page 40 of 44

Supplemental Material

Rationale:

During development of this standardTOP-001-4, text boxes wereare embedded within the
standard to explain the rationale for various parts of the standard. Upon BOT approvalBoard
adoption of TOP-001-4, the text from the rationale text boxes waswill be moved to this section.
Rationale text from the development of TOP-001-3 in Project 2014-03 follows. Additional
information can be found on the Project 2014-03 project page.
Rationale for Requirement R3:
The phrase ‘cannot be physically implemented’ means that a Transmission Operator may
request something to be done that is not physically possible due to its lack of knowledge of the
system involved.
Rationale for Requirement R10:
New proposed Requirement R10 is derived from approved IRO-003-2, Requirement R1, adapted
to the Transmission Operator Area. This new requirement is in response to NOPR paragraph 60
concerning monitoring capabilities for the Transmission Operator. New Requirement R11
covers the Balancing Authorities. Monitoring of external systems can be accomplished via data
links.
The revised requirement addresses directives for Transmission Operator (TOP) monitoring of
some non-Bulk Electric System (BES) facilities as necessary for determining System Operating
Limit (SOL) exceedances (FERC Order No. 817 Para 35-36). The proposed requirement
corresponds with approved IRO-002-4 Requirement R4 (proposed IRO-002-5 Requirement R5),
which specifies the Reliability Coordinator's (RC) monitoring responsibilities for determining
SOL exceedances.
The intent of the requirement is to ensure that all facilities (i.e., BES and non-BES) that can
adversely impact reliability of the BES are monitored. As used in TOP and IRO Reliability
Standards, monitoring involves observing operating status and operating values in Real-time for
awareness of system conditions. The facilities that are necessary for determining SOL
exceedances should be either designated as part of the BES, or otherwise be incorporated into
monitoring when identified by planning and operating studies such as the Operational Planning
Analysis (OPA) required by TOP-002-4 Requirement R1 and IRO-008-2 Requirement R1. The SDT
recognizes that not all non-BES facilities that a TOP considers necessary for its monitoring needs
will need to be included in the BES.
The non-BES facilities that the TOP is required to monitor are only those that are necessary for
the TOP to determine SOL exceedances within its Transmission Operator Area. TOPs perform
various analyses and studies as part of their functional obligations that could lead to
identification of non-BES facilities that should be monitored for determining SOL exceedances.
Examples include:
•
•

OPA;
Real-time Assessments (RTA);

Page 41 of 44

Supplemental Material
•
•

Page 42 of 44

Supplemental Material
cited in the requirement. Note – Derived limits replaced by SOLs for clarity and specificity. SOLs
include voltage, Stability, and thermal limits and are thus the most limiting factor.
Rationale for Requirements R19 and R20: (R19, R20, R22, and R23 in TOP-001-4):
Added for consistency with proposed IRO-002-4, Requirement R1. Data exchange capabilities
are required to support the data specification concept in proposed TOP-003-3.
The proposed changes address directives for redundancy and diverse routing of data exchange
capabilities (FERC Order No. 817 Para 47).
Redundant and diversely routed data exchange capabilities consist of data exchange
infrastructure components (e.g., switches, routers, servers, power supplies, and network
cabling and communication paths between these components in the primary Control Center for
the exchange of system operating data) that will provide continued functionality despite failure
or malfunction of an individual component within the Transmission Operator's (TOP) primary
Control Center. Redundant and diversely routed data exchange capabilities preclude single
points of failure in primary Control Center data exchange infrastructure from halting the flow of
Real-time data. Requirement R20 does not require automatic or instantaneous fail-over of data
exchange capabilities. Redundancy and diverse routing may be achieved in various ways
depending on the arrangement of the infrastructure or hardware within the TOP's primary
Control Center.
The reliability objective of redundancy is to provide for continued data exchange functionality
during outages, maintenance, or testing of data exchange infrastructure. For periods of planned
or unplanned outages of individual data exchange components, the proposed requirements do
not require additional redundant data exchange infrastructure components solely to provide
for redundancy.
Infrastructure that is not within the TOP's primary Control Center is not addressed by the
proposed requirement.
Rationale for Requirement R21:
The proposed requirement addresses directives for testing of data exchange capabilities used in
primary Control Centers (FERC Order No. 817 Para 51).
A test for redundant functionality demonstrates that data exchange capabilities will continue to
operate despite the malfunction or failure of an individual component (e.g., switches, routers,
servers, power supplies, and network cabling and communication paths between these
components in the primary Control Center for the exchange of system operating data). An
entity's testing practices should, over time, examine the various failure modes of its data
exchange capabilities. When an actual event successfully exercises the redundant functionality,
it can be considered a test for the purposes of the proposed requirement.

Page 43 of 44

Page 44 of 44

File Type	application/pdf
File Title	NERC Petition in RD17-4, Exhibit A, Proposed Standards
Author	Courtney Baughan
File Modified	2017-05-19
File Created	2017-02-08