CLO-003-1 Computational Load Protection Coordination & Disturbance Monitoring

Task 1: Develop Compliance Procedure

• Create an audit-ready compliance procedure for meeting the CLO-003-1 requirements, working collaboratively across engineering, field services, operations, and compliance departments. This includes:
• Identifying applicable Computational Load Sites and the owner of the main power transformer(s) at each site, which determines who holds R2-R5 and R6-R8 for FR and DDR data (the CLO holds R1 and R6-R8 for its SER data at every site), along with SMEs, roles, responsibilities, and ownership
• Determining specific actions and evidence to demonstrate compliance with specific requirements and measures
• Conducting a gap analysis comparing current practices versus the new requirements, identifying missing processes, incomplete documentation, any staff training needed, etc.
• Developing clear step-by-step procedures for CLO-003-1 that align with internal controls and documentation policies, including SER/FR/DDR device configuration, time synchronization, data retention and retrieval, and recording failure response
• Establishing compliance timelines that align with the implementation plan (R1-R8 at 36 months after the effective date for sites in service on or before the effective date, or at 15 months after the effective date or the in-service date, whichever is later, for sites in service after it; R9-R10 at 9 months)
• Defining and determining specific compliance evidence per site, including retention of R1-R8 evidence for three calendar years and R9-R10 evidence since the last audit

Task 2: Assess Disturbance Monitoring at each Site (R1-R5)

• Create an inventory of all disturbance monitoring equipment (DME) and circuit breakers at the site.
• Verify SER of breaker position (open/close) for breakers associated with equipment you own, including buses and, as applicable, main power transformers, on-site generation, and shunt static and dynamic reactive devices (R1).
• Where you own the main power transformer(s), verify FR on the high side of the main power transformer(s) or common point of connection: phase-to-neutral voltage for each phase, each phase current and the residual or neutral current, and three-phase real and reactive power (R2); a pre-trigger of at least two cycles and a total record of at least 2.0 seconds, a recording rate of at least 64 samples per cycle, and triggers for neutral (residual) overcurrent, AC phase overvoltage and undervoltage, and overfrequency and underfrequency (R3).
• Where you own the main power transformer(s), verify continuous DDR and storage at the same location of phase-to-neutral voltages, phase and residual or neutral currents, three-phase real and reactive power flows for all circuits where current is measured, and frequency (R4), with an input sampling rate of at least 960 samples per second and an output recording rate of at least 60 times per second (R5).
• Identify deficiencies and propose new equipment, or modifications to existing equipment where feasible, to meet the requirements.
• For sites not yet in service, review the DME design so recording is in place by the compliance date.

Task 3: Verify Time Synchronization (R6)

• Verify that each SER, FR, and DDR device synchronizes to Coordinated Universal Time (UTC), with or without a local time offset, with device clock accuracy within +/-1 millisecond of UTC.
• Document the time source, device configuration, and synchronization status indication as evidence (M6).

Task 4: Set Up Data Retention and Production (R7)

• Confirm that SER, FR, and DDR data is retrievable for 20 calendar days, inclusive of the day it was recorded.
• Develop the request-response procedure for providing data to the Transmission Planner, Planning Coordinator, Transmission Operator, Balancing Authority, Reliability Coordinator, Regional Entity, or NERC within 15 calendar days of a request, unless the requestor grants an extension.
• Format data on request: SER in ASCII CSV following Attachment 1 (Date, Time, Local Time Code, Site Name, Device, State); FR and DDR in CSV with appropriate headers or in IEEE C37.111 COMTRADE (1999 or later); file names in IEEE C37.232 COMNAME (2011 or later).

Task 5: Respond to Recording Failures (R8)

• On discovery of a failure of SER, FR, or DDR recording capability, track the 90-calendar-day deadline and plan restoration.
• Where restoration cannot be completed within 90 calendar days, prepare a CAP for submission to the Regional Entity within 90 calendar days, then track its implementation against the CAP timeline.
• Keep dated failure reports, restoration records, SCADA records, and CAP transmittals as evidence (M8).

Task 6: Develop the Protection System Settings Coordination Process (R9, R10)

• Develop the CLO's process for developing new and revised Protection System settings so that Protection Systems operate in the intended sequence during Faults (R9).
• For settings at sites that electrically join equipment owned by Transmission Owners, Generator Owners, or Distribution Providers, include provisions to respond to each owner's proposed settings by identifying coordination issues or affirming that none were identified; to verify that identified issues are addressed before implementation; and to communicate with the other owner(s) of the electrically joined equipment regarding revised settings resulting from unforeseen circumstances that arise during implementation or commissioning, Misoperation investigations, maintenance activities, or emergency replacements required as a result of Protection System component failure (Part 9.1).
• Apply the process to each new or revised settings package and keep dated documentation of its use (R10, M10).

Task 7: Prepare Extension Requests (where applicable)

• For sites in service no later than 12 months after the effective date where circumstances beyond your control prevent DME installation, prepare the extension request to the Compliance Enforcement Authority, including site identification, a plan and timetable for installing the DME, a description of the circumstances and why they are beyond your control, and any other relevant information.
• Track the filing deadline of 3 months before the compliance date, and prepare an updated request if more time is required.