Nerc Com-002-4

COM-002-4 – Operating Personnel Communications Protocols

A. Introduction
1. Title: Operating Personnel Communications Protocols
2. Number:

COM-002-4

3. Purpose:
To improve communications for the issuance of Operating Instructions
with predefined communications protocols to reduce the possibility of
miscommunication that could lead to action or inaction harmful to the reliability of the
Bulk Electric System (BES).
4. Applicability:
4.1. Functional Entities

5.

4.1.1

Balancing Authority

4.1.2

Distribution Provider

4.1.3

Reliability Coordinator

4.1.4

Transmission Operator

4.1.5

Generator Operator

Effective Date: The standard shall become effective on the first day of the first calendar
quarter that is twelve (12) months after the date that the standard is approved by an
applicable governmental authority or as otherwise provided for in a jurisdiction where
approval by an applicable governmental authority is required for a standard to go into
effect. Where approval by an applicable governmental authority is not required, the
standard shall become effective on the first day of the first calendar quarter that is
twelve (12) months after the date the standard is adopted by the NERC Board of
Trustees or as otherwise provided for in that jurisdiction.

B. Requirements
R1. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
develop documented communications protocols for its operating personnel that issue
and receive Operating Instructions. The protocols shall, at a minimum: [Violation
Risk Factor: Low][Time Horizon: Long-term Planning]
1.1. Require its operating personnel that issue and receive an oral or written
Operating Instruction to use the English language, unless agreed to otherwise.
An alternate language may be used for internal operations.
1.2. Require its operating personnel that issue an oral two-party, person-to-person
Operating Instruction to take one of the following actions:


Confirm the receiver’s response if the repeated information is correct.



Reissue the Operating Instruction if the repeated information is incorrect
or if requested by the receiver.

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COM-002-4 – Operating Personnel Communications Protocols



Take an alternative action if a response is not received or if the Operating
Instruction was not understood by the receiver.

1.3. Require its operating personnel that receive an oral two-party, person-to-person
Operating Instruction to take one of the following actions:



Repeat, not necessarily verbatim, the Operating Instruction and receive
confirmation from the issuer that the response was correct.
Request that the issuer reissue the Operating Instruction.

1.4. Require its operating personnel that issue a written or oral single-party to
multiple-party burst Operating Instruction to confirm or verify that the
Operating Instruction was received by at least one receiver of the Operating
Instruction.
1.5. Specify the instances that require time identification when issuing an oral or
written Operating Instruction and the format for that time identification.
1.6. Specify the nomenclature for Transmission interface Elements and
Transmission interface Facilities when issuing an oral or written Operating
Instruction.
R2. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
conduct initial training for each of its operating personnel responsible for the Realtime operation of the interconnected Bulk Electric System on the documented
communications protocols developed in Requirement R1 prior to that individual
operator issuing an Operating Instruction. [Violation Risk Factor: Low][Time
Horizon: Long-term Planning]
R3. Each Distribution Provider and Generator Operator shall conduct initial training for
each of its operating personnel who can receive an oral two-party, person-to-person
Operating Instruction prior to that individual operator receiving an oral two-party,
person-to-person Operating Instruction to either: [Violation Risk Factor: Low][Time
Horizon: Long-term Planning]


Repeat, not necessarily verbatim, the Operating Instruction and receive
confirmation from the issuer that the response was correct, or



Request that the issuer reissue the Operating Instruction.

R4. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
at least once every twelve (12) calendar months: [Violation Risk Factor:
Medium][Time Horizon: Operations Planning]
4.1. Assess adherence to the documented communications protocols in Requirement
R1 by its operating personnel that issue and receive Operating Instructions,
provide feedback to those operating personnel and take corrective action, as
deemed appropriate by the entity, to address deviations from the documented
protocols.
4.2. Assess the effectiveness of its documented communications protocols in
Requirement R1 for its operating personnel that issue and receive Operating
Instructions and modify its documented communication protocols, as necessary.

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COM-002-4 – Operating Personnel Communications Protocols

R5. Each Balancing Authority, Reliability Coordinator, and Transmission Operator that
issues an oral two-party, person-to-person Operating Instruction during an
Emergency, excluding written or oral single-party to multiple-party burst Operating
Instructions, shall either: [Violation Risk Factor: High][Time Horizon: Real-time
Operations]


Confirm the receiver’s response if the repeated information is correct (in
accordance with Requirement R6).



Reissue the Operating Instruction if the repeated information is incorrect
or if requested by the receiver, or



Take an alternative action if a response is not received or if the Operating
Instruction was not understood by the receiver.

R6. Each Balancing Authority, Distribution Provider, Generator Operator, and
Transmission Operator that receives an oral two-party, person-to-person Operating
Instruction during an Emergency, excluding written or oral single-party to multipleparty burst Operating Instructions, shall either: [Violation Risk Factor: High][Time
Horizon: Real-time Operations]


Repeat, not necessarily verbatim, the Operating Instruction and receive
confirmation from the issuer that the response was correct, or



Request that the issuer reissue the Operating Instruction.

R7. Each Balancing Authority, Reliability Coordinator, and Transmission Operator that
issues a written or oral single-party to multiple-party burst Operating Instruction
during an Emergency shall confirm or verify that the Operating Instruction was
received by at least one receiver of the Operating Instruction. [Violation Risk Factor:
High][Time Horizon: Real-time Operations]
C. Measures
M1. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
provide its documented communications protocols developed for Requirement R1.
M2. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
provide its initial training records related to its documented communications protocols
developed for Requirement R1 such as attendance logs, agendas, learning objectives, or
course materials in fulfillment of Requirement R2.
M3. Each Distribution Provider and Generator Operator shall provide its initial training
records for its operating personnel such as attendance logs, agendas, learning
objectives, or course materials in fulfillment of Requirement R3.
M4. Each Balancing Authority, Reliability Coordinator, and Transmission Operator shall
provide evidence of its assessments, including spreadsheets, logs or other evidence of
feedback, findings of effectiveness and any changes made to its documented
communications protocols developed for Requirement R1 in fulfillment of

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COM-002-4 – Operating Personnel Communications Protocols

Requirement R4. The entity shall provide, as part of its assessment, evidence of any
corrective actions taken where an operating personnel’s non-adherence to the protocols
developed in Requirement R1 is the sole or partial cause of an Emergency and for all
other instances where the entity determined that it was appropriate to take a corrective
action to address deviations from the documented protocols developed in Requirement
R1.
M5. Each Reliability Coordinator, Transmission Operator, and Balancing Authority that
issued an oral two-party, person-to-person Operating Instruction during an Emergency,
excluding oral single-party to multiple-party burst Operating Instructions, shall have
evidence that the issuer either: 1) confirmed that the response from the recipient of the
Operating Instruction was correct; 2) reissued the Operating Instruction if the repeated
information was incorrect or if requested by the receiver; or 3) took an alternative
action if a response was not received or if the Operating Instruction was not understood
by the receiver. Such evidence could include, but is not limited to, dated and timestamped voice recordings, or dated and time-stamped transcripts of voice recordings, or
dated operator logs in fulfillment of Requirement R5.
M6. Each Balancing Authority, Distribution Provider, Generator Operator, and
Transmission Operator that was the recipient of an oral two-party, person-to-person
Operating Instruction during an Emergency, excluding oral single-party to multipleparty burst Operating Instructions, shall have evidence to show that the recipient either
repeated, not necessarily verbatim, the Operating Instruction and received confirmation
from the issuer that the response was correct, or requested that the issuer reissue the
Operating Instruction in fulfillment of Requirement R6. Such evidence may include,
but is not limited to, dated and time-stamped voice recordings (if the entity has such
recordings), dated operator logs, an attestation from the issuer of the Operating
Instruction, memos or transcripts.
M7. Each Balancing Authority, Reliability Coordinator and Transmission Operator that
issued a written or oral single or multiple-party burst Operating Instruction during an
Emergency shall provide evidence that the Operating Instruction was received by at
least one receiver. Such evidence may include, but is not limited to, dated and timestamped voice recordings (if the entity has such recordings), dated operator logs,
electronic records, memos or transcripts.
D. Compliance
1. Compliance Monitoring Process
1.1. Compliance Enforcement Authority
As defined in the NERC Rules of Procedure, “Compliance Enforcement
Authority” means NERC or the Regional Entity in their respective roles of
monitoring and enforcing compliance with the NERC Reliability Standards.
1.2. Data Retention
The following evidence retention periods 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
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COM-002-4 – Operating Personnel Communications Protocols

provide other evidence to show that it was compliant for the full time period since
the last audit.
Each Balancing Authority, Distribution Provider, Generator Operator, Reliability
Coordinator, and Transmission Operator shall each keep data or evidence for each
applicable Requirement for the current calendar year and one previous calendar
year, with the exception of 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.
If a Balancing Authority, Distribution Provider, Generator Operator, Reliability
Coordinator, or Transmission Operator is found non-compliant, it shall keep
information related to the non-compliance until mitigation is complete and
approved or for the time period specified above, whichever is longer.
The Compliance Enforcement Authority shall keep the last audit records and all
requested and submitted subsequent audit records.
Compliance Monitoring and Assessment Processes
Compliance Audit
Self-Certification
Spot Checking
Compliance Investigation
Self-Reporting
Complaint
1.3. Additional Compliance Information
None

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COM-002-4 – Operating Personnel Communications Protocols

R#

R1

Time
Horizon

Long-term
Planning

VRF

Low

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

The responsible entity
did not specify the
instances that require
time identification
when issuing an oral
or written Operating
Instruction and the
format for that time
identification, as
required in
Requirement R1, Part
1.5

The responsible entity did
not require the issuer and
receiver of an oral or
written Operating
Instruction to use the
English language, unless
agreed to otherwise, as
required in Requirement
R1, Part 1.1. An alternate
language may be used for
internal operations.

The responsible entity did
not include Requirement
R1, Part 1.4 in its
documented
communication protocols.

Severe VSL

The responsible entity did not
include Requirement R1, Part
1.2 in its documented
communications protocols
OR
The responsible entity did not
include Requirement R1, Part
1.3 in its documented
communications protocols
OR
The responsible entity did not
develop any documented
communications protocols as
required in Requirement R1.

OR
The responsible entity
did not specify the
nomenclature for
Transmission
interface Elements
and Transmission
interface Facilities
when issuing an oral
or written Operating
Instruction, as
required in
Requirement R1, Part
1.6.

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COM-002-4 – Operating Personnel Communications Protocols

R#

Time
Horizon

VRF

Violation Severity Levels
Lower VSL

Moderate VSL

High VSL

Severe VSL

R2

Long-term
Planning

Low

N/A

N/A

An individual operator
responsible for the Realtime operation of the
interconnected Bulk
Electric System at the
responsible entity issued
an Operating Instruction,
prior to being trained on
the documented
communications protocols
developed in Requirement
R1.

An individual operator
responsible for the Real-time
operation of the interconnected
Bulk Electric System at the
responsible entity issued an
Operating Instruction during an
Emergency prior to being trained
on the documented
communications protocols
developed in Requirement R1.

R3

Long-term
Planning

Low

N/A

N/A

An individual operator at
the responsible entity
received an Operating
Instruction prior to being
trained.

An individual operator at the
responsible entity received an
Operating Instruction during an
Emergency prior to being
trained.

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COM-002-4 – Operating Personnel Communications Protocols

R#

Time
Horizon

VRF

Violation Severity Levels
Lower VSL

R4

Operations
Planning

Medium

The responsible entity
assessed adherence to
the documented
communications
protocols in
Requirements R1 by
its operating
personnel that issue
and receive Operating
Instructions and
provided feedback to
those operating
personnel and took
corrective action, as
appropriate
AND
The responsible entity
assessed the
effectiveness of its
documented
communications
protocols in
Requirement R1 for
its operating
personnel that issue
and receive Operating
Instructions and
modified its
documented
communication

Moderate VSL

High VSL

Severe VSL

The responsible entity
assessed adherence to the
documented
communications protocols
in Requirement R1 by its
operating personnel that
issue and receive
Operating Instructions, but
did not provide feedback
to those operating
personnel

The responsible entity did
not assess adherence to the
documented
communications protocols
in Requirements R1 by its
operating personnel that
issue and receive
Operating Instructions

The responsible entity did not
assess adherence to the
documented communications
protocols in Requirements R1 by
its operating personnel that issue
and receive Operating
Instructions

OR
The responsible entity
assessed adherence to the
documented
communications protocols
in Requirements R1 by its
operating personnel that
issue and receive
Operating Instructions and
provided feedback to those
operating personnel but
did not take corrective
action, as appropriate

OR
The responsible entity did
not assess the
effectiveness of its
documented
communications protocols
in Requirement R1 for its
operating personnel that
issue and receive
Operating Instructions.

OR
The responsible entity
assessed the effectiveness
of its documented
communications protocols

Page 8 of 12

AND
The responsible entity did not
assess the effectiveness of its
documented communications
protocols in Requirement R1 for
its operating personnel that issue
and receive Operating
Instructions.

COM-002-4 – Operating Personnel Communications Protocols

R#

Time
Horizon

VRF

Violation Severity Levels
Lower VSL

protocols, as
necessary
AND
The responsible entity
exceeded twelve (12)
calendar months
between assessments.

Moderate VSL

High VSL

in Requirement R1 for its
operating personnel that
issue and receive
Operating Instructions, but
did not modify its
documented
communication protocols,
as necessary.

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Severe VSL

COM-002-4 – Operating Personnel Communications Protocols

R#

Time
Horizon

VRF

Violation Severity Levels
Lower VSL

R5

Real-time
Operations

High

N/A

Moderate VSL

The responsible entity that
issued an Operating
Instruction during an
Emergency did not take
one of the following
actions:
•

•

•

High VSL

N/A

Confirmed the
receiver’s response if
the repeated
information was
correct (in
accordance with
Requirement R6).
Reissued the
Operating Instruction
if the repeated
information was
incorrect or if
requested by the
receiver.
Took an alternative
action if a response
was not received or if
the Operating
Instruction was not
understood by the
receiver.

Severe VSL

The responsible entity that
issued an Operating Instruction
during an Emergency did not
take one of the following
actions:
•

Confirmed the receiver’s
response if the repeated
information was correct (in
accordance with
Requirement R6).

•

Reissued the Operating
Instruction if the repeated
information was incorrect
or if requested by the
receiver.

•

Took an alternative action
if a response was not
received or if the Operating
Instruction was not
understood by the receiver.

AND
Instability, uncontrolled
separation, or cascading failures
occurred as a result.

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COM-002-4 – Operating Personnel Communications Protocols

R#

Time
Horizon

VRF

Violation Severity Levels
Lower VSL

R6

Real-time
Operations

High

N/A

Moderate VSL

The responsible entity did
not repeat, not necessarily
verbatim, the Operating
Instruction during an
Emergency and receive
confirmation from the
issuer that the response
was correct, or request that
the issuer reissue the
Operating Instruction
when receiving an
Operating Instruction.

High VSL

N/A

Severe VSL

The responsible entity did not
repeat, not necessarily verbatim,
the Operating Instruction during
an Emergency and receive
confirmation from the issuer that
the response was correct, or
request that the issuer reissue the
Operating Instruction when
receiving an Operating
Instruction
AND
Instability, uncontrolled
separation, or cascading failures
occurred as a result.

R7

Real-time
Operations

High

N/A

The responsible entity that N/A
that issued a written or oral
single-party to multipleparty burst Operating
Instruction during an
Emergency did not
confirm or verify that the
Operating Instruction was
received by at least one
receiver of the Operating
Instruction.

The responsible entity that that
issued a written or oral singleparty to multiple-party burst
Operating Instruction during an
Emergency did not confirm or
verify that the Operating
Instruction was received by at
least one receiver of the
Operating Instruction
AND
Instability, uncontrolled
separation, or cascading failures
occurred as a result.

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COM-002-4 – Operating Personnel Communications Protocols

E. Regional Variances
None

Version History
Version

Date

Action

Change Tracking

0

April 1, 2005

Effective Date

New

0

August 8, 2005

Removed “Proposed” from Effective
Date

Errata

1

February 7,
2006

Adopted by Board of Trustees

Added measures and
compliance elements

2

November 1,
2006

Adopted by Board of Trustees

Revised in accordance
with SAR for Project
2006-06, Reliability
Coordination (RC
SDT). Retired R1,
R1.1, M1, M2 and
updated the compliance
monitoring
information. Replaced
R2 with new R1, R2
and R3.

2a

February 9,
2012

Interpretation of R2 adopted by Board
of Trustees

Project 2009-22

3

November 7,
2012

Adopted by Board of Trustees

4

May 6, 2014

Adopted by Board of Trustees

4

April 16, 2015

FERC Order issued approving COM002-4