151 FERC ¶ 61,039

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 40

[Docket No. RM14-13-000; Order No. 808] 

Communications Reliability Standards

 

(Issued April 16, 2015)

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final rule.

SUMMARY: Pursuant to the Federal Power Act, the Commission approves two revised 

Reliability Standards, COM-001-2 (Communications) and COM-002-4 (Operating 

Personnel Communications Protocols), developed by the North American Electric 

Reliability Corporation (NERC), which the Commission has certified as the Electric 

Reliability Organization responsible for developing and enforcing mandatory Reliability 

Standards. The two revised Reliability Standards will enhance reliability by, among 

other things, requiring adoption of predefined communication protocols, annual 

assessment of those protocols and operating personnel’s adherence thereto, training on 

the protocols, and use of three-part communications. In addition, the Commission directs

NERC to develop a modification to Reliability Standard COM-001-2 that addresses

internal communications capabilities that could involve the issuance or receipt of 

Operating Instructions or other communications that could have an impact on reliability. 

DATES: This rule will become effective [INSERT DATE 60 days after publication in 

the FEDERAL REGISTER]. 
Docket No. RM14

-13-000 ii

FOR FURTHER INFORMATION CONTACT

:

Vincent Le (Technical Information)

Office of Electric Reliability

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6204

Vincent.le@ferc.gov

Michael Gandolfo (Technical Information)

Office of Electric Reliability

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6817

Michael.gandolfo@ferc.gov

Julie Greenisen (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6362

julie.greenisen@ferc.gov

SUPPLEMENTARY INFORMATION

:
151 FERC ¶ 61,039

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Before Commissioners: Norman C. Bay, Chairman;

 Philip D. Moeller, Cheryl A. LaFleur,

Tony Clark, and Colette D. Honorable.

Communications Reliability Standards Docket No. RM14-13-000

ORDER NO. 808

FINAL RULE

(Issued April 16, 2015)

1. Pursuant to section 215 of the Federal Power Act (FPA),1 the Commission 

approves two Reliability Standards, COM-001-2 (Communications) and COM-002-4 

(Operating Personnel Communications Protocols), developed by the North American 

Electric Reliability Corporation (NERC), which the Commission has certified as the 

Electric Reliability Organization responsible for developing and enforcing mandatory 

Reliability Standards. The Commission also approves three new defined terms for 

addition to the NERC Glossary of Terms Used in Reliability Standards (NERC 

Glossary), violation risk factors, violation severity levels, and NERC’s proposed 

implementation plan for both revised standards. Further, pursuant to section 215(d)(5) of 

the FPA, the Commission directs that NERC develop one modification to Reliability 

 1 16 U.S.C. 824o (2012). 
Docket No. RM14-13-000 - 2 -

Standard COM-001-2 that addresses internal communications capabilities to the extent 

that such communications could involve the issuance or receipt of Operating Instructions 

or other communications that could have an impact on reliability. 

2. Reliability Standard COM-001-2 is intended to establish a clear set of 

requirements for the communications capabilities that applicable functional entities must 

have in place and maintain. Reliability Standard COM-002-4 requires applicable entities

to develop communication protocols with certain minimum requirements, including use 

of three-part communication when issuing Operating Instructions.

2

 Reliability Standard 

COM-002-4 also sets out certain communications training requirements for all issuers 

and recipients of Operating Instructions, and establishes a flexible enforcement approach 

for failure to use three-part communication during non-emergencies and a “zerotolerance,” i.e., without exception, enforcement approach for failure to use three-part 

communication during an emergency.3

3. We find that Reliability Standards COM-001-2 and COM-002-4 will enhance 

reliability over the currently-effective versions of these Communications (COM)

 2 NERC proposes to define Operating Instruction as “[a] command by operating 

personnel responsible for the Real-time operation of the interconnected Bulk Electric 

System to change or preserve the state, status, output, or input of an Element of the Bulk 

Electric System or Facility of the Bulk Electric System. (A discussion of general 

information and of potential options or alternatives . . . is not considered an Operating 

Instruction.).”

3 See NERC Petition at 3 (“during Emergencies, operating personnel must use the 

documented communication protocols for three-part communications without 

exception.”).
Docket No. RM14-13-000 - 3 -

standards in several respects. For example, the Reliability Standards as modified expand 

applicability to include generator operators and distribution providers, eliminate certain 

ambiguities in the currently-effective standards, and clarify that the use of three-part 

communication is required for issuance and receipt of all Operating Instructions, with a 

zero-tolerance approach to enforcement of that requirement during an emergency. 

However, we are not persuaded that COM-001-2 adequately covers all situations in 

which Operating Instructions are issued or received and, therefore, direct NERC to 

develop a modification to that standard that addresses our concern, as further discussed 

below. 

I. Background

A. Regulatory Background 

4. Section 215 of the FPA requires a Commission-certified Electric Reliability 

Organization (ERO) to develop mandatory and enforceable Reliability Standards, subject 

to Commission review and approval.4

 Once approved, the Reliability Standards may be 

enforced by the ERO subject to Commission oversight, or by the Commission

 4 16 U.S.C. at 824o(c) and (d). 
Docket No. RM14-13-000 - 4 -

independently.5

 In 2006, the Commission certified NERC as the ERO pursuant to FPA 

section 215.

6

 

5. The Commission approved Reliability Standard COM-001-1 in Order No. 693.

7

 

In addition, the Commission directed NERC to develop modifications to COM-001-1 to:

(1) expand the applicability of the standard to include generator operators and distribution 

providers, (2) identify specific requirements for telecommunications facilities for use in 

normal and emergency conditions that reflect the roles of the applicable entities, and 

(3) include adequate flexibility for compliance to allow for the adoption of new 

technologies and cost-effective solutions.

8

 Similarly, the Commission approved

Reliability Standard COM-002-2 in Order No. 693. In addition, the Commission directed 

NERC to develop modifications to (1) include distribution providers as applicable 

entities, and (2) establish tightened communications protocols, especially for 

communications during alerts and emergencies.9

 5 See id. at 824o(e).

6 North American Electric Reliability Corp., 116 FERC ¶ 61,062, order on reh’g 

and compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa Inc. v. FERC, 

564 F.3d 1342 (D.C. Cir. 2009). 

7 See Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 

FERC Stats. & Regs. ¶ 31,242 at P 508, order on reh’g, Order No. 693-A, 120 FERC 

¶ 61,053 (2007); see also North American Electric Reliability Corp., Docket No. RD09-

2-000 (2009) (delegated letter order accepting Reliability Standard COM-001-1.1). 

8 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 508. 

9 Id. PP 531-535, 540. 
Docket No. RM14-13-000 - 5 -

6. NERC initiated Project 2006-06 to address the Order No. 693 directives related to 

Reliability Standards COM-001 and COM-002, resulting in two proposed Reliability 

Standards, COM-001-2 and COM-002-3. NERC also initiated Project 2007-02 to 

develop a new Reliability Standard (COM-003) that would require real-time system 

operators to use standardized communication protocols during normal and emergency 

operations, in order to improve situational awareness and shorten response time. The two 

projects ultimately merged when drafts of Reliability Standard COM-002-3 and COM003-1 were combined into a single proposed Reliability Standard, COM-002-4.

B. NERC Petition

7. On May 14, 2014, NERC filed a petition seeking approval of two revised 

communication standards, COM-001-2 (Communications) and COM-002-4 (Operating 

Personnel Communications Protocols).

10 Proposed Reliability Standard COM-001-2 

establishes a set of requirements for the communications capabilities that various 

functional entities must maintain to enable communications with other identified 

functional entities. Proposed Reliability Standard COM-002-4 requires applicable 

entities to develop documented communications protocols. NERC stated in its petition 

that the proposed standards are intended to address all relevant Commission directives 

 10 The COM Reliability Standards are not attached to the Final Rule. The 

complete text of the two Reliability Standards is available on the Commission’s eLibrary 

document retrieval system in Docket No. RM14-13 and is posted on the ERO’s web site, 

available at: http://www.nerc.com.
Docket No. RM14-13-000 - 6 -

from Order No. 693. In addition, NERC stated that the revisions reflected in proposed 

COM-002-4 are intended to address Recommendation No. 26 from the final report on the 

August 2003 blackout issued by the U.S.-Canada Power System Outage Task Force 

(Blackout Report) concerning the need to “[t]ighten communications protocols, 

especially for communications during alerts and emergencies.”11

Reliability Standard COM-001-2

8. NERC stated in its petition that Reliability Standard COM-001-2 establishes

requirements for Interpersonal Communication capabilities necessary to maintain 

reliability. NERC explained that proposed Reliability Standard COM-001-2 applies to 

reliability coordinators, balancing authorities, transmission operators, generator 

operators, and distribution providers. The proposed Reliability Standard includes eleven 

requirements and two new defined terms, “Interpersonal Communication” and 

“Alternative Interpersonal Communication,” that, according to NERC, collectively 

provide a comprehensive approach to establishing communications capabilities necessary

to maintain reliability.12 NERC stated that the definitions provide clarity that an entity’s 

 11 NERC Petition at 3 (quoting U.S.-Canada Power System Outage Task Force, 

Final Report on the August 14, 2003 Blackout in the United States and Canada: Causes 

and Recommendations at 3 (April 2004) (Blackout Report), available at 

http://energy.gov/sites/prod/files/oeprod/DocumentsandMedia/BlackoutFinal-Web.pdf). 

12 Id. at 15. NERC defines Interpersonal Communication as “[a]ny medium that 

allows two or more individuals to interact, consult, or exchange information” and 

Alternative Interpersonal Communication as “[a]ny Interpersonal Communication that is 

able to serve as a substitute for, and does not utilize the same infrastructure (medium) as, 

Interpersonal Communication used for day-to-day operation.” Id. 
Docket No. RM14-13-000 - 7 -

communication capability must be redundant and that each of the capabilities must not 

utilize the same medium. According to NERC, the definitions improve the language used 

in the current Reliability Standard by eliminating the use of the more ambiguous phrases 

“adequate and reliable” and “redundant and diversely routed” that relate to 

“telecommunications facilities for the exchange of Interconnection and operating

information.”13

9. The first six requirements of COM-001-2 address the Interpersonal 

Communication capability and Alternative Interpersonal Communication capability of 

the reliability coordinator, transmission operator, and balancing authority functions. 

Requirement R1 requires each reliability coordinator to have Interpersonal

Communication capability with all transmission operators and balancing authorities

within its reliability coordinator area, and with each adjacent reliability coordinator 

within the same interconnection. Requirement R2 requires each reliability coordinator to 

designate Alternative Interpersonal Communication capability with those same identified 

entities. Requirements R3 and R4 set out the communications capability requirements 

for a transmission operator. Under Requirement R3, Interpersonal Communication 

capability is required between the transmission operator’s reliability coordinator, each 

balancing authority within its transmission operator area, each distribution provider and 

generator operator within its transmission operator area, and each adjacent transmission 

 13 Id. at 15-16. 
Docket No. RM14-13-000 - 8 -

operator whether synchronously or asynchronously connected. Under Requirement R4, 

Alternative Interpersonal Communication capability must be designated between the

transmission operator’s reliability coordinator, each balancing authority within its 

transmission operator area, and each adjacent transmission operator. Requirements R5 

and R6 set out similar requirements for each balancing authority, again identifying the 

specific functional entities for which the balancing authority must maintain Interpersonal 

Communication capability and for which it must designate Alternative Interpersonal 

Communication capability. 

10. Requirements R7 and R8 address the communications capability that distribution 

providers and generator operators must maintain, with each required to have 

Interpersonal Communications capability with its balancing authority and its transmission 

operator. 

11. Requirement R9 requires each reliability coordinator, transmission operator, and 

balancing authority to test its Alternative Interpersonal Communication capability at least

once each calendar month, and to initiate action to repair or designate a replacement if the 

test is unsuccessful. Requirement R10 requires the same entities to notify applicable 

entities (as identified in R1, R3 and R5) of the detection of an Interpersonal 

Communication capability failure that lasts 30 minutes or longer. Finally, Requirement 

R11 requires distribution providers and generator operators to consult with affected 

balancing authorities and transmission operators when a failure is detected in their 

Interpersonal Communication capability, and to determine a mutually agreeable action 

for the restoration of that capability. 
Docket No. RM14-13-000 - 9 -

12. NERC stated in its petition that proposed Reliability Standard COM-001-2 

improves the currently-effective Reliability Standard by: (1) eliminating terms that do 

not adequately specify the desired actions that applicable entities are expected to take in 

relation to their telecommunication facilities; (2) clearly identifying the need for 

applicable entities to be capable of Interpersonal Communication and Alternative 

Interpersonal Communication; (3) not requiring specific technology or systems to be

utilized; and (4) including the distribution provider and generator operator as applicable

entities.14 NERC added that COM-001-2 also addresses relevant directives from Order 

No. 693 by (1) adding generator operators and distribution providers as applicable 

entities; (2) identifying specific requirements for telecommunications capabilities for use 

in all operating conditions that reflect the roles of the applicable entities and their impact 

on reliability; and (3) including adequate flexibility to permit the adoption of new 

technologies.

13. NERC proposed to retire currently-effective COM-001-1.1 when proposed 

Reliability Standard COM-001-2 becomes effective, with the exception of Requirement 

R4, which addresses communications protocols. NERC requested that Requirement R4 

be retired when proposed Reliability Standard COM-002-4 becomes effective.15

 14 NERC Petition at 18. 

15 Id. at 22. 
Docket No. RM14-13-000 - 10 -

Reliability Standard COM-002-4

14. NERC stated in its petition that Reliability Standard COM-002-4 improves

communications surrounding the issuance of Operating Instructions by requiring the use 

of predefined communications protocols to reduce the possibility of miscommunication 

that could lead to action or inaction harmful to reliability.

16 NERC noted that the 

proposed standard requires use of the same protocols regardless of operating condition 

(i.e., Emergency or non-emergency), but requires operating personnel to use the 

documented communication protocols for three-part communications “without 

exception” during an Emergency.17 As NERC explained:

[T]he proposed Reliability Standard employs the phrase 

“Operating Instruction during an Emergency” in certain 

requirements (R5, R6, R7) to provide a demarcation for what 

is subject to a zero-tolerance compliance approach and what 

is not.18 

 16 Id. at 23. NERC stated that COM-002-3 (which was adopted by the NERC 

Board but not submitted to the Commission for approval) is proposed for retirement in 

the Implementation Plan because the proposed Reliability Standard has been combined 

with proposed COM-003-1 to create proposed Reliability Standard COM-002-4. NERC 

stated that Reliability Standard COM-002-3 has not been submitted to the Commission 

for approval, therefore, the currently effective version of COM-002 is COM-002-2. Id. at 

23 n.43. Reliability Standard COM-002-4 combines proposed Reliability Standard 

COM-002-3 and the former draft COM-003-1 into a single standard that addresses 

communications protocols for operating personnel in Emergency and non-emergency 

conditions. Id. at 23-24.

17 Id. at 3. 

18 Id. at 25. 
Docket No. RM14-13-000 - 11 -

NERC explained that, for Operating Instructions issued during non-emergency 

operations, “an entity will be assessed under a compliance approach that focuses on 

whether an entity meets the initial training Requirement (either R2 or R3) and whether an 

entity performed the assessment and took corrective actions according to Requirement 

R4.”19 

15. Finally, NERC stated that the proposed Reliability Standard includes distribution 

providers and generator operators as applicable entities, in accordance with the 

Commission’s directive in Order No. 693, and in recognition of the fact that these types 

of entities can be recipients of Operating Instructions.

16. Proposed Reliability Standard COM-002-4 includes seven requirements. 

Requirement R1 requires entities that can both issue and receive Operating Instructions 

(balancing authorities, reliability coordinators and transmission operators) to have 

documented communications protocols that include a minimum set of elements, 

including use of the English language unless otherwise specified, and required use of 

three-part communications for issuance and receipt of Operating Instructions.

20 

Requirement R2 requires these same entities to conduct initial training on the 

communications protocols for each of their operating personnel responsible for the realtime operation of the bulk electric system. Requirement R3 requires distribution 

 19 Id. at 26. 

20 See id. at 29. 
Docket No. RM14-13-000 - 12 -

providers and generator operators (who generally only receive but do not issue Operating 

Instructions) to conduct initial training on three-part communication for each of their 

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. 

17. Requirement R4 requires each balancing authority, reliability coordinator and 

transmission operator to assess, at least once every twelve months, its operating

personnel’s adherence to the documented communication protocols required in 

Requirement R1, and to provide feedback to its operating personnel on their performance. 

18. Requirement R5 requires balancing authorities, reliability coordinators and 

transmission operators that issue an oral two-party, person-to-person “Operating

Instruction during an Emergency” to use three-part communication, and to take an 

alternative action if a confirmation is not received. Requirement R6 requires all 

applicable entities (balancing authorities, distribution providers, generator operators, and 

transmission operators) that receive an oral two-party, person-to-person “Operating 

Instruction during an Emergency” to use three-part communication, i.e., to repeat the 

Operating Instruction and receive confirmation from the issuer that the response was 

correct, or request that the issuer reissue the Operating Instruction. Both Requirement R5 

and R6 include the clarification that the requirement does not apply to single-party to 

multiple-party “burst” Operating Instructions. As noted above, NERC explains that 

Requirements R5 and R6 require use of three-part communication during an Emergency 

without exception, because “use of three-part communication is critically important if an 
Docket No. RM14-13-000 - 13 -

Emergency condition already exists, as further action or inaction could increase the 

harmful effects to the Bulk Electric System.”21 NERC further explains, however, that 

applicable entities are expected to use three-part communications at all times when 

issuing and receiving Operating Instructions.22

19. Finally, Requirement R7 requires that when a balancing authority, reliability 

coordinator, or transmission operator issues a written or oral single-party to multipleparty “burst” Operating Instruction during an Emergency, they must confirm or verify 

that at least one receiver received the Operating Instruction. 

20. NERC requested that proposed Reliability Standard COM-002-4 become effective 

on the first day of the first calendar quarter that is twelve months after the date that the 

standard is approved.

C. Notice of Proposed Rulemaking

21. On September 19, 2014, the Commission issued a Notice of Proposed Rulemaking 

(NOPR) proposing to approve Reliability Standards COM-001-2 and COM-002-4 

pursuant to FPA section 215(d)(2), along with the three new definitions referenced in the 

proposed standards (Operating Instruction, Interpersonal Communication, and 

 21 Id. at 39. 

22 Id. at 25-26.
Docket No. RM14-13-000 - 14 -

Alternative Interpersonal Communication), the assigned violation risk factors and 

violation severity levels, and the proposed implementation plan for each standard.23

22. In the NOPR, the Commission explained that the two revised standards addressed 

outstanding directives from Order No. 693, in that COM-001-2 has been expanded to 

include distribution providers and generator operators, and COM-002-4 has been 

expanded to include distribution providers.

24 The Commission also stated that Reliability

Standard COM-002-4 would enhance reliability by providing for improved 

communications through the required development of communication protocols.

23. In the NOPR, the Commission also discussed the following specific matters and 

asked for further comment: (1) responsibility for use of three-part communication by 

transmission owners and generator owners that receive Operator Instructions; (2) whether

COM-001-2 should be modified to address internal communication capability 

requirements, or to address testing requirements for distribution providers and generator 

operators; and (3) clarifications regarding the proposed terms Interpersonal 

Communication and Alternative Interpersonal Communication. 

24. Timely comments on the NOPR were filed by: NERC; the Edison Electric 

Institute and the Electric Power Supply Association (EEI/EPSA); ISO/RTO Council; the 

National Rural Electric Cooperative Association (NRECA); International Transmission 

 23 Communications Reliability Standards, Notice of Proposed Rulemaking, 79 FR 

58709 (Sept. 30, 2014), 148 FERC ¶ 61,210 (2014) (NOPR). 

24 Id. PP 22, 23. 
Docket No. RM14-13-000 - 15 -

Company (ITC); Idaho Power Company (Idaho Power); and Tri-State G&T. In addition, 

on March 6, 2015, NERC filed Supplemental Comments. 

II. Discussion

25. Pursuant to section 215(d)(2) of the FPA, we adopt our NOPR proposal and 

approve Reliability Standards COM-001-2 and COM-002-4, including the associated 

definitions, violation risk factors, violation severity levels, and implementation plans, as 

just, reasonable, not unduly discriminatory or preferential and in the public interest. We 

note that all of the commenters that addressed the overall value of the Reliability 

Standards supported, or did not oppose, approval of the two revised standards. We 

determine that COM-001-2 will enhance reliability by expanding the applicability of 

currently effective COM-001-1.1 to include generator operators and distribution 

providers as applicable entities under the COM-001 standard, and by expanding the 

applicability of COM-002-4 to include distribution providers. We further find that COM002-4 will enhance reliability by requiring all issuers and recipients of Operating 

Instructions to develop communications protocols that require use of three-part 

communications, by requiring training on those protocols, and by adopting a zerotolerance enforcement approach to the use of three-part communications during an 

Emergency. Moreover, we conclude that requiring issuers of Operating Instructions to 

perform an annual assessment of their personnel’s adherence to the communications 

protocols will help ensure a high level of compliance with three-part communications at 

all times. 
Docket No. RM14-13-000 - 16 -

26. Pursuant to section 215(d)(5) of the FPA, the Commission directs that NERC 

develop one modification to COM-001-2 to address our concerns regarding applicability

to certain internal communications, as discussed below.

27. Below, we discuss the following matters: (A) ensuring use of three-part 

communications by generator owners and transmission owners; (B) internal 

communication capability requirements; (C) testing requirements for distribution 

providers and generator operators; and (D) scope of the terms Interpersonal 

Communication and Alternative Interpersonal Communication. 

A. Applicability to Generator Owners and Transmission Owners 

NOPR

28. In the NOPR, the Commission raised the concern that generator owners and 

transmission owners are not “applicable entities” under either COM-001-2 or COM-002-

4, although these entities could, under some circumstances, receive and act on Operating 

Instructions.25 The Commission sought comment on the obligations of an applicable 

entity when issuing an Operating Instruction to a transmission owner or generator owner, 

including information regarding which entity is responsible if the transmission owner or 

generator owner fails to perform three-part communication properly. In addition, the 

Commission asked NERC to explain its auditing practices when reviewing operating 

agreements between transmission operators and transmission owners, and between 

 25 See id. PP 25-27. 
Docket No. RM14-13-000 - 17 -

generator operators and generation owners, including NERC’s approach to reviewing the 

protocols of any transmission owner or generator owner that acts on an Operating 

Instruction in order to ensure that three-part communication is used appropriately.

Comments 

29. All commenters that address this issue maintain that the two revised COM

Reliability Standards appropriately identify the entities that issue and/or receive 

Operating Instructions, and that the two standards should not be expanded to include 

transmission owners or generator owners.26 NERC states that the two COM standards 

are appropriately tailored to apply to those functional entities that operate the Bulk-Power 

System as described in the NERC Functional Model and, therefore, apply to transmission 

operators and generator operators rather than transmission owners and generator owners. 

However, NERC acknowledges that “there are instances in which Transmission Owners 

or Generator Owners may receive and act on Operating Instructions within areas operated 

by RTOs or ISOs.”27 NERC asserts that, in these instances, the generator owner or 

transmission owner is “acting on behalf of a registered Transmission Operator or 

Generator Operator under delegation as a member of the RTO or ISO.”28 NERC asserts 

that, if performance of a reliability requirement is not achieved for a delegated task, “the 

 26 See NERC Comments at 2, 8; EEI/EPSA Comments at 3-4; ISO/RTO Council 

Comments at 4; ITC Comments at 4-5; Tri-State G&T Comments at 1. 

27 NERC Comments at 8. 

28 Id. 
Docket No. RM14-13-000 - 18 -

relevant Transmission Operator or Generator Operator responsible for compliance with 

the Reliability Standards is and has been held accountable.”29

30. NERC provides several examples of the various approaches to assigning 

compliance responsibility, including a Joint Registration Organization or Coordinated 

Functional Registration (as used in ERCOT), and assignment of compliance 

responsibility through operating agreements and manuals (as used in PJM). In both 

circumstances, NERC and Regional Entity auditors review the relevant documents 

assigning compliance responsibility “to determine whether there are gaps in performance 

under the Reliability Standards as a result of the delegation.”30 In addition, NERC states 

that “the registered entity for a particular function retains responsibility for providing 

supporting documentation regarding how a task is delegated,” and “for providing proof of 

compliance under the Reliability Standards.”31

31. EEI/EPSA maintains that generator owners do not receive and act on Operating 

Instructions, and therefore should not be included as applicable entities under the 

proposed standards. EEI/EPSA further maintains that transmission owners do not 

typically receive and act on Operating Instructions, except in regions where the 

transmission owners have arrangements to do so under specific operating contracts, and, 

 29 Id. 

30 Id. at 10. 

31 Id. at 11. 
Docket No. RM14-13-000 - 19 -

in those cases, act “sol[ely] at the direction of a responsible regional TOP, having broad 

area responsibilities.”32

32. Like NERC, ISO/RTO Council acknowledges that transmission owners and 

generator owners may act on Operating Instructions from an ISO/RTO, at least within 

some ISO/RTO regions, but states that in those cases the ISOs have market rules and 

operating procedures in place for communicating Operating Instructions to utilities and 

other market participants within their footprint. ISO/RTO Council also asserts that ISOs 

and RTOs do not control the registration of transmission owners and generator owners 

within their footprint, but that the entity and the relevant Regional Entity “make the final 

determination on their registration.”33 Finally, ISO/RTO Council suggests that applying 

the requirements of the proposed COM standards to generator owners and transmission 

owners “seems to address an administrative concern as opposed to a reliability concern,” 

given that the “core reliability issue at hand is determining whether the RC, BA or TOP 

command was followed by the relevant recipient,” and given that ISOs and RTOs have

market rules or tariff provisions in place that require strict adherence by utilities and 

market participants.34 ISO/RTO Council also asserts that, if an ISO or RTO issues a 

command to an entity that is not registered as a transmission operator or generator 

operator, and there is a three-part communication failure resulting in an enforcement 

 32 EEI/EPSA Comments at 3.

33 ISO/RTO Council Comments at 3. 

34 Id. 
Docket No. RM14-13-000 - 20 -

action, then the NERC Rules of Procedure should be used to hold that entity 

responsible.35

33. ITC asserts that Operating Instructions, as defined by NERC, cannot apply to a 

generator owner or transmission owner. ITC raises a related question, however, as to 

whether a transmission operator can issue an Operating Instruction to another 

transmission operator under the proposed Reliability Standards.36 ITC seeks 

confirmation from the Commission that a transmission operator cannot issue such an 

instruction or directive to another transmission operator, or if no such confirmation is 

given, ITC asks that the Commission “explain the basis and process under which a 

Transmission Operator could issue such an Operating Instruction.”37 

34. Idaho Power asserts that COM-002-4 does not apply to generator owners or 

transmission owners, without further discussion of whether such entities could ever 

receive and act on Operating Instructions as defined by NERC. Tri-State G&T agrees 

that generator owners and transmission owners should not be added as applicable entities, 

as they rarely, if ever receive an Operating Instruction. 

 35 Id. at 4 (asserting that the NERC Rules of Procedure, Appendix 4C, Section 

5.11 allows for an ISO or RTO to include in an enforcement proceeding an entity that 

causes or contributes to an alleged violation of a Reliability Standard). 

36 ITC Comments at 5. 

37 Id. at 6. 
Docket No. RM14-13-000 - 21 -

Commission Determination 

35. While several commenters have acknowledged that transmission owners and 

generator owners can receive and act on Operating Instructions in certain regions, we are 

persuaded that the proposed Reliability Standards need not be expanded to include those 

entities at this time. In doing so, we are persuaded by the explanation of NERC that 

“[w]hile the Transmission Operator or Generator Operator may delegate tasks under the 

proposed Reliability Standards to other member entities within [an RTO or ISO], the 

Transmission Operator and Generator Operator retain responsibility for compliance with 

the Requirements in the proposed Reliability Standards.”38 Moreover, we rely on 

NERC’s explanation that NERC and Regional Entity auditors examine contractual

arrangements “to ascertain how tasks are delegated and to determine whether there are 

gaps in performance . . . as a result of the delegation. Responsibility will always rest with 

the entity registered with NERC as the Transmission Operator.”39 Thus, in the PJM 

example, if a transmission owner with delegated operating responsibilities fails to use 

three-part communication as required under COM-002-4, the registered entity that has 

delegated the operating responsibilities will remain responsible for the violation.

 38 See also ISO/RTO Council Comments at 3-4; EEI/EPSA Comments at 3-4 

(Commission approved Operating Agreements “contractually bind TOs to act in 

conformance with TOP obligations”).

39 NERC Comments at 10-11.
Docket No. RM14-13-000 - 22 -

36. ITC requests clarification whether or not a transmission operator can issue an 

Operating Instruction to another transmission operator, pursuant to COM-001-2 and 

COM-002-4. We find that the issue is beyond the scope of this rulemaking. The two 

standards at issue in this proceeding relate to requirements for communications capability 

and communications protocols, and do not address the relative authorities as between 

functional entities to require another entity to modify its operations in real-time, which is 

more properly addressed in the TOP and IRO Reliability Standards, including currently 

effective Reliability Standard TOP-1-1a.40

B. Internal Communication Capability 

NOPR

37. In the NOPR, the Commission raised the concern that Reliability Standard COM001-2 does not appear to carry forward an explicit requirement to maintain adequate 

internal communications capabilities, unlike the existing COM-001 standard, which 

states that each reliability coordinator, transmission operator, and balancing authority 

“shall provide adequate and reliable telecommunication facilities for the exchange of 

 40 Requirement R1 of TOP-1-1a states that “Each Transmission Operator shall 

have the responsibility and clear decision-making authority to take whatever actions are 

needed to ensure the reliability of its area and shall exercise specific authority to alleviate 

operating emergencies.” The obligation of a functional entity to respond to an Operating 

Instruction is also expected to be more explicitly addressed in other TOP and IRO 

standards under development or awaiting Commission approval, including proposed 

Reliability Standard IRO-001-4, which requires transmission operators, balancing 

authorities, generator operators, and distribution providers to comply with their 

Reliability Coordinator’s Operating Instructions except under certain described 

circumstances. 
Docket No. RM14-13-000 - 23 -

Interconnection and operating information . . . internally.”41 The Commission stated that 

maintaining adequate internal communications could be critical to reliability, pointing to 

specific recommendations in the 2003 Blackout Report. The Commission proposed to 

direct NERC to develop modifications to COM-001-2, or to develop a separate standard, 

“that ensures that entities maintain adequate internal communications capability, at least 

to the extent that such communications could involve the issuance or receipt of Operating 

Instructions or other communications that could have an impact on reliability.” 42 

Alternatively, the Commission suggested that a requirement for internal communication 

capability could be considered to be implicit in the proposed requirements for 

communications capability between functional entities, even if those functional entities 

reside within the same utility, and sought comment on this suggested interpretation as 

well as the proposed directive.

Comments

38. NERC and most other commenters assert that Reliability Standard COM-002-4 

can and should be read to apply to internal communications between functional entities 

within the same organization, as the Commission suggested in the NOPR.43 NERC and 

NRECA also assert that acceptance of this interpretation should eliminate the need for 

 41 NOPR, 148 FERC ¶ 61,210 at P 28 (quoting COM-001-1.1, Requirement R1). 

42 Id. P 30. 

43 NERC Comments at 13; see also, e.g., NRECA Comments at 1, Idaho Power 

Comments at 4, and Tri-State Comments at 1. 
Docket No. RM14-13-000 - 24 -

further modification to COM-002-4.44 ITC comments that COM-001-2 should apply to 

internal communications between different functional entities within the same 

organization but only “when those communications are performed by means other than in 

direct, face-to-face situations.”45 ITC continues, stating that “[f]or entities performing 

multiple functions that are located in close proximity such that direct, face-to-face 

communication is available, ITC does not see a reliability need for a requirement for 

Alternative Interpersonal Communication, and believes the Standards should be 

interpreted as not requiring AIC in these situations.”46 ITC also advocates that, if the 

Commission does not find that COM-001-2 as submitted includes these kinds of internal 

communications, the standard ought to be modified to do so.

39. EEI/EPSA acknowledges that the approach taken in COM-001-2 is different than 

the currently-effective COM standard with respect to internal communications, but 

maintains that this change is consistent with results-based standards. EEI/EPSA 

maintains that “a result-based standard should not need to specifically cite facility 

requirements or the specific internal communication obligations,” and maintains that 

COM-001-2 properly specifies communications capability “at the Functional Entity 

level.”47

 44 NERC Comments at 13; NRECA Comments at 1-2. 

45 ITC Comments at 7. 

46 Id.

47 Id. at 4-5. 
Docket No. RM14-13-000 - 25 -

Commission Determination 

40. We agree with NERC and other commenters that Reliability Standard COM-001-2 

applies to communications between functional entities within a single organization. For 

example, COM-001-2, Requirement R3, provides that “each Transmission Operator shall 

have Interpersonal Communication capability” with the reliability coordinator, and each 

balancing authority, distribution provider, and generator operator “within its 

Transmission Operator Area.” We agree with NERC, ITC and other commenters that a 

reasonable understanding of Requirement R3 is that the transmission operator must have 

Interpersonal Communication capability with a balancing authority, distribution provider 

and/or generator operator within the same organization. Moreover, we agree with ITC 

that the COM-001-2 requirements concerning Alternative Interpersonal Communication 

only apply when those communications are performed by means other than direct, faceto-face situations. 

41. However, the application of COM-001-2 to different functional entities within the 

same organization, as discussed above, does not fully address our concern set forth in the 

NOPR regarding internal communications.48 In particular, the NOPR explained that 

Requirement R1.1 of currently-effective COM-001-1.1 provides that each reliability 

coordinator, transmission operator, and balancing authority “shall provide adequate and 

reliable telecommunication facilities for the exchange of Interconnection and operating 

 48 See NOPR, 148 FERC ¶ 61,210 at PP 28-31. 
Docket No. RM14-13-000 - 26 -

information . . . internally.” This currently-effective Requirement applies more broadly 

to internal communications, including internal communications within the same 

functional entity. Thus, unlike the currently-effective Reliability Standard, COM-001-2 

does not address the adequacy of internal telecommunications (or other internal 

communication systems) that may have an adverse effect on reliability, even within a 

single functional entity, including: (1) communications between geographically separate 

control centers within the same functional entity; and (2) communications between a 

control center and field personnel. These scenarios present a gap in reliability of the 

Bulk-Power System that NERC should address. Accordingly, pursuant to section 

215(d)(5) of the FPA, we direct NERC to develop modifications to COM-001-2, or to 

develop a new standard, to address our concerns regarding ensuring the adequacy of 

internal communications capability whenever internal communications could directly 

affect the reliable operation of the Bulk-Power System. 

C. Testing Requirements for Distribution Providers and Generator 

Operators

NOPR 

42. In the NOPR, the Commission expressed concern that Reliability Standard COM001-2 did not include a requirement that distribution providers and generator operators 

test or actively monitor their telecommunications systems, but were merely required to 

consult with each affected entity to determine a mutually agreeable action for restoration 
Docket No. RM14-13-000 - 27 -

whenever a failure is detected.49 The Commission asked for comment on “why generator 

operators and distribution providers should not have some form of requirement to test or 

actively monitor vital primary and emergency telecommunication facilities.”50 

Comments

43. NERC and the other commenters on this issue maintain that there is no need for a 

testing requirement for generator operators and distribution providers comparable to that 

required for reliability coordinators, balancing authorities and transmission operators, 

because generator operators and distribution providers are required to maintain only 

primary Interpersonal Communication capability, which is tested through routine use.51 

NERC further explains that its approach is consistent with the Commission’s statement in 

Order No. 693 that “[w]e expect the telecommunication requirements for all applicable 

entities will vary according to their roles and that these requirements will be developed 

under the Reliability Standards development process.”52 NERC also explains that the 

standard drafting team found that the obligation to detect and address failures in a 

 49 NOPR, 148 FERC ¶ 61,210 at P 31 (citing to COM-001-2, Requirement R11). 

50 Id, (citing System Restoration Reliability Standards, Order No. 749, 134 FERC 

¶ 61,215, at P 28 (2011)).

51 See, e.g., NERC Comments at 14 (“routine use is sufficient to demonstrate 

functionality of this . . . primary capability”); EEI/EPSA Comments at 5-6 (“a system in 

regular use would gain little through routine testing”); and ISO/RTO Council Comments 

at 6-7 (“capability will be ‘tested’ through regular use”).

52 NERC Comments at 14-15 (quoting Order No. 693, FERC Stats. & Regs. 

¶ 31,242 at P 487). 
Docket No. RM14-13-000 - 28 -

primary communication system, as set out in Requirement R11 of COM-001-2, is 

sufficient, given “the limited impact a failure might have on Distribution Providers and 

Generator Operators overall.”53

Commission Determination

44. We are persuaded by the comments of NERC and others that additional testing 

requirements for distribution providers and generator operators are not necessary at this 

time. NERC and other commenters assert that the primary Interpersonal Communication 

systems used by a distribution provider or generator operator will effectively be tested 

through routine use, and that any potential failures in a given generator operator or 

distribution provider’s external communication system will not have a substantial impact

on the Bulk-Power System. In light of this explanation, as well as our recognition in 

Order No. 693 that telecommunication requirements for applicable entities will vary 

according to their roles, we decline to require any additional testing requirements for 

distribution providers and generator operators at this time. 

D. Definition of Interpersonal Communication and Alternative 

Interpersonal Communication 

NOPR

45. In the NOPR, the Commission sought clarification on the intended scope of the 

newly defined terms Interpersonal Communication and Alternative Interpersonal 

 53 NERC Comments at 14. 
Docket No. RM14-13-000 - 29 -

Communication.54 The Commission noted that NERC had explained the introduction of 

these terms as a means of eliminating the ambiguity in the terms “adequate and reliable” 

and “redundant and diversely routed” as currently used in Requirements R1 and R1.4 of 

COM-001-1.1. 

46. The Commission raised two concerns about the new terms as used in proposed 

Reliability Standard COM-001-2. First, the Commission noted that the definitions do not 

state a minimum expectation of communication performance, such as speed and quality.55 

Second, the Commission asked for clarification as to whether Interpersonal 

Communication includes mediums used directly to exchange or transfer data, which 

communications appear to be covered under the currently-approved version of COM001.56 The Commission, thus, asked for further explanation “regarding acceptable (and 

 54 NOPR, 148 FERC ¶ 61,210 at P 32. As previously noted, NERC is proposing to 

define the terms, respectively, as follows: 

Interpersonal Communication – Any medium that allows two 

or more individuals to interact, consult, or exchange 

information. 

Alternative Interpersonal Communication – Any 

Interpersonal Communication that is able to serve as a 

substitute for, and does not utilize the same infrastructure 

(medium) as, Interpersonal Communication used for day-today operation. 

55 NOPR, 148 FERC ¶ 61,210 at P 33. 

56 Id. As the Commission noted, COM-001-1.1, Requirement R1 addresses 

“telecommunications facilities for the exchange of Interconnection and operating 

information.” 
Docket No. RM14-13-000 - 30 -

unacceptable) performance of communication for both Interpersonal and Alternative 

Interpersonal Communications.”57

Comments 

47. With respect to minimum performance standards or specifications for the required 

communications mediums, none of the commenters believe such specifications are 

necessary or advisable. NERC maintains that additional specifications are not necessary 

because the standard as written requires applicable entities to have the working capability 

needed to maintain reliability.58 EEI/EPSA agrees that performance specifications are 

not necessary, and questions whether it is even possible to set such standards given the 

diversity of systems used.59 ISO/RTO Council asserts that it would be inadvisable to 

include technical specifications on the communication mediums required, as it could 

result in the use of the least expensive medium that could achieve compliance.60 Idaho 

Power suggests that the kinds of measurable characteristics that might be appropriate for 

use to establish minimum performance levels for data exchanges are not available here, 

because the proposed COM standards do not include data exchange. Tri-State G&T 

states that the most common expected mediums for communication under the standard 

 57 Id.

58 NERC Comments at 4, 15-16. 

59 EEI/EPSA Comments at 6-7.

60 ISO/RTO Council at 5. ISO/RTO Council also notes that its members already 

have requirements in place with their stakeholders on necessary technical requirements 

for voice and data exchange. 
Docket No. RM14-13-000 - 31 -

will likely be e-mail and telephone, and that there is no need to include minimum 

expectations of speed or performance because “all entities are focused on reliability and 

would always use the fastest and most reliable means of communication.”61

48. With respect to the transfer of data as opposed to communications between 

persons, all of the commenters to directly address the issue acknowledge that proposed 

Reliability Standard COM-001-2 is not intended to, and does not, cover data exchanges 

or transfers. NERC (through its initial and supplemental comments) and ISO/RTO 

Council maintain that COM-001-2 need not include requirements regarding data transfer 

capability because such capability is covered under other existing or proposed standards. 

49. With respect to existing standards, NERC states that the standard drafting team 

determined that IRO-010-1a and IRO-014-1 “provided the necessary mandatory 

Requirements to ensure proper data exchange is occurring.”62 ISO/RTO Council 

provides several additional examples of existing Reliability Standards that address data 

exchange and transfer capability, including BAL-004-2b, R14; IRO-002-2, R1; and TOP006-2, R1.63 

50. With respect to standards under development, NERC asserts that four proposed 

IRO and TOP standards, now approved by the Board, “include specific coverage related 

 61 Tri-State G&T Comments at 2. 

62 NERC Comments at 16. See also ISO/RTO Council Comments at 5-6 (noting 

that the standard drafting team explained that data communication is covered under 

Requirement R3 of IRO-010-1). 

63 ISO/RTO Council Comments at 6, n.10. 
Docket No. RM14-13-000 - 32 -

to data exchange,” and “collectively require data exchange capability” for reliability 

coordinators, transmission operators, balancing authorities, generator operators, and 

distribution providers.

64 NERC describes the specific requirements in proposed 

Reliability Standards TOP-001-3, IRO-010-2, TOP-003-3, and IRO-002-4 that will 

address data exchange capabilities and/or data exchange specifications for applicable 

functional entities. 

51. EEI/EPSA and Idaho Power also maintain that the term Interpersonal 

Communication does not cover data exchange, with EEI/EPSA asserting that the phrase 

requires a system “that enables effective communications between two or more 

individuals.”65 Moreover, EEI/EPSA understands the term Alternative Interpersonal 

Communication to require certain entities to have backup communications that do not 

utilize the same infrastructure. 

52. ITC asserts that the definitions of Interpersonal Communication and Alternative 

Interpersonal Communication “could ostensibly be interpreted to extend the Standard 

beyond verbal and written communications and Operating Instructions to include the 

transmission of electronic data between control systems that are monitored/used by 

 64 NERC Supp. Comments at 3. NERC identified these same four standards in its 

Initial Comments, but provides a more detailed discussion of the proposed standards and 

their status in its Supplemental Comments. 

65 EEI/EPSA at 7. Similarly, Idaho Power states that the term was intended to 

include voice and electronic messaging between people, and exclude data exchanges, 

such as SCADA and metering data. Idaho Power Comments at 4-5. 
Docket No. RM14-13-000 - 33 -

system operators.”66 ITC warns that “[i]f the Commission does indeed intend the scope 

of the Standards to extend to such electronic data transmission, the requirement for 

Alternative Interpersonal Communication may not be achievable” because “[i]t may 

simply not be possible to maintain a second pathway for the transmission of such data, 

whether by dint of data format, system compatibility, or the feasibility of installing a 

redundant system.”67 ITC accordingly recommends that if an alternative pathway for 

data transmission is deemed necessary, then the Commission should retain the language 

from COM-001-1 which requires “redundant and diversely routed systems.”68 

Commission Determination 

53. First, we are satisfied that technical specifications regarding minimum levels of 

performance for the mediums used to satisfy the requirements of COM-001-2 are not 

necessary at this time. In doing so, we note NERC’s explanation that the requirements in 

COM-001-2 are “absolute” and that entities must “have the capability in place to 

‘establish Interpersonal Communication capabilities necessary to maintain reliability.’”69 

Moreover, we are persuaded by the commenters that setting performance criteria for the 

email and telephonic communications at issue here is both impractical and unnecessary.

 66 ITC Comments at 8.

67 Id.

68 Id. at 9.

69 NERC Comments at 15-16. 
Docket No. RM14-13-000 - 34 -

54. Second, the NOPR raised concerns pertaining to whether COM-001-2 addresses 

“facilities that directly exchange or transfer data.” 70 In response, NERC states that data 

exchange capability is being addressed in proposed IRO and TOP standards.

71 

Accordingly, we do not make any determinations regarding data exchange capability in 

the immediate rulemaking. Rather, based on NERC’s explanation, we will address any 

issues regarding data exchange capability in the pending rulemaking pertaining to 

NERC’s proposed TOP and IRO Reliability Standards. 

III. Information Collection Statement

55. The collection of information contained in this Final Rule is subject to review by 

the Office of Management and Budget (OMB) under section 3507(d) of the Paperwork 

Reduction Act of 1995.72 OMB’s regulations require approval of certain information 

collection requirements imposed by agency rules.73 Upon approval of a collection(s) of 

information, OMB will assign an OMB control number and an expiration date. 

Respondents subject to the filing requirements of a rule will not be penalized for failing 

 70 See NOPR, 148 FERC ¶ 61,210 at P 33.

71 See NERC Supplemental Filing at 2-3. On March 18, 2015, NERC submitted a 

petition for approval of proposed Transmission Operations and Interconnection 

Reliability Operations and Coordination Reliability Standards, Docket No. RM15-15-

000, pending before the Commission.

72 44 U.S.C. 3507(d) (2012).

73 5 CFR 1320.11 (2013).
Docket No. RM14-13-000 - 35 -

to respond to these collections of information unless the collections of information 

display a valid OMB control number. 

56. The Commission solicited comments on the need for this information, whether the 

information will have practical utility, the accuracy of the burden estimates, ways to 

enhance the quality, utility, and clarity of the information to be collected or retained, and 

any suggested methods for minimizing respondents’ burden, including the use of 

automated information techniques. Specifically, the Commission asked that any revised 

burden or cost estimates submitted by commenters be supported by sufficient detail to

understand how the estimates were generated.

57. The Final Rule approves Reliability Standards COM-001-2 and COM-002-4, as 

well as NERC’s proposed retirement of currently-effective Reliability Standards COM001-1.1 and COM-002-2. Reliability Standard COM-001-2 establishes Interpersonal 

Communication capability necessary to maintain reliability, while Reliability Standard 

COM-002-4 improves communications related to Operating Instructions, requiring 

issuers of Operating Instructions to adopt predefined communications protocols and 

requiring both issuers and recipients of Operating Instructions to use three-part 

communications.

Public Reporting Burden: Reliability Standards COM-001-2 and COM-002-4 do not 

require responsible entities to file information with the Commission. However, the 

Reliability Standards require applicable entities to develop and maintain certain 

information, subject to audit. In particular, COM-001-2 requires that transmission 

operators, balancing authorities, reliability coordinators, distribution providers, and 
Docket No. RM14-13-000 - 36 -

generator operators must maintain documentation of Interpersonal Communication 

capability and designation of Alternate Interpersonal Communication, as well as evidence 

of testing of the Alternate Interpersonal Communication facilities. COM-002-4 requires 

balancing authorities, distribution providers, reliability coordinators, transmission 

operators, and generator operators to develop and maintain documented communication 

protocols, and to be able to provide evidence of training on the protocols and of their 

annual assessment of the protocols. Additionally, all applicable entities (balancing 

authorities, reliability coordinators, transmission operators, generator operators, and 

distribution providers) must be able to provide evidence of three-part communication 

when issuing or receiving an Operating Instruction during an Emergency. 

Many of the record retention or information collection requirements in COM-001-2 and 

COM-002-4 are translated in some form from the currently-effective Reliability 

Standards (COM-001-1 and COM-002-2). For these requirements, the Commission 

estimates a zero net change in burden. Accordingly, our estimate below shows the 

increase in record-retention or information collection burden, based on the new 

requirements to:

(1) develop communications protocols (a one-time burden 

under COM-002-4, Requirement R1), 

(2) maintain evidence of required training, assessments, and 

use of three-part communications, as applicable (an on-going 

burden under COM-002-4 Requirements R2, R3, R4, R5 and 

R6); and 

(3) maintain evidence to demonstrate Interpersonal 

Communication capability (a new, on-going burden for 

distribution providers and generator operators under COM001-2 Requirements R7 and R8). 
Docket No. RM14-13-000 - 37 -

The Commission’s estimate of the number of respondents is based on the NERC 

compliance registry as of August 15, 2014. According to the NERC compliance registry, 

NERC has registered 179 transmission operators, 107 balancing authorities, 15 reliability 

coordinators, 475 distribution providers, and 853 generator operators within the United 

States. However, under NERC’s compliance registration program, entities may be 

registered for multiple functions, so these numbers incorporate some double counting, 

which has been accounted for in the table below. The Commission estimates the annual 

reporting burden and cost as follows: 

Information 

Collection 

Requirement

Number and 

Type of 

Respondents

(1)

Annual 

Number of 

Responses 

per 

Respondent 

(2)

Total 

Number 

of 

Responses

(1)*(2)=(3)

Avg. Burden 

& Cost Per 

Response74

(4)

Total Annual 

Burden Hours 

& Total 

Annual Cost75

(3)*(4)=(5)

 74 The estimated hourly costs (salary plus benefits) are based on Bureau of Labor 

Statistics (BLS) information, as of March 19, 2015, for an electrical engineer 

($65.34/hour for review and documentation) and for an Information and Record Clerk 

($33.42/hour for record retention). These figures have been updated since issuance of the 

NOPR, and are available at: http://bls.gov/oes/current/naics3_221000.htm#17-0000. 

The first row of the table (one-time burden) is done by an engineer, and the latter three 

rows (ongoing burden) are done by a file clerk. 

75 This dollar burden figure in row 3 of this chart was incorrectly stated in the 

NOPR, which led to an incorrect estimate of the total dollar burden for the industry in 

row 5. Both estimates as stated in the NOPR were higher than the corrected and updated 

estimate reflected in this Final Rule. 
Docket No. RM14-13-000 - 38 -

(One-time) 

Development of 

Communication 

Protocols 

[COM-002-4 

R1]

212 

(BA, RC & 

TOP) 1 212

8 hrs. & 

$522.72 

1,696 hours & 

$110,816.64

(On-going) 

Maintain 

evidence of 

Interpersonal 

Communication 

capability 

[COM-001-2 

R7 and R8]76

1,217 

(DP & GOP) 1 1,217

4 hrs. & 

$133.68

4,868 hours &

$162,688.56

(On-going) 

Maintain 

evidence of 

training and 

assessments 

[COM-002-4 

R2, R4, R5 and 

R6]

212 

(BA, RC & 

TOP) 1 212

8 hrs. & 

$267.36

1,696 hours & 

$56,680.32

(On-going)

Maintain 

evidence of 

training 

[COM-002-4 

R3, and R6]

1,217 

(DP & GOP) 1 1,217

8 hrs. & 

$267.36

9,736 hours & 

$ 325,377.12

TOTAL

2,858

17,996 hours &

$655,562.64

Title: Mandatory Reliability Standards for the Bulk-Power System: COM Reliability 

Standards.

 76 No change is expected in the record-keeping burden under COM-001-2 for 

reliability coordinators, balancing authorities, and transmission operators as compared to 

the currently-effective COM-001 standard. 
Docket No. RM14-13-000 - 39 -

Action: Proposed FERC-725V 

OMB Control No: 1902-0277

Respondents: Businesses or other for-profit institutions; not-for-profit institutions.

Frequency of Responses: One-time and ongoing.

Necessity of the Information: The approval of Reliability Standards COM-001-2 and 

COM-002-4 implements the Congressional mandate of the Energy Policy Act of 2005 to 

develop mandatory and enforceable Reliability Standards to better ensure the reliability 

of the nation’s Bulk-Power System. Specifically, the purpose of the Reliability Standards 

is to establish Interpersonal Communication capability necessary to maintain reliability,

and to improve communications for the issuance of Operating Instructions with 

predefined communications protocols. The proposed Reliability Standards require 

entities to maintain records subject to review by the Commission and NERC to ensure 

compliance with the Reliability Standards.

Internal Review: The Commission has reviewed the requirements pertaining to the 

Reliability Standards for the Bulk-Power System and determined that the requirements 

are necessary to meet the statutory provisions of the Energy Policy Act of 2005. These 

requirements conform to the Commission’s plan for efficient information collection, 

communication and management within the energy industry. The Commission has 

assured itself, by means of internal review, that there is specific, objective support for the 

burden estimates associated with the information requirements. 

58. Interested persons may obtain information on the reporting requirements by 

contacting the following: Federal Energy Regulatory Commission, 888 First Street, NE, 
Docket No. RM14-13-000 - 40 -

Washington, DC 20426 [Attention: Ellen Brown, Office of the Executive Director, 

e-mail: DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873].

59. Comments concerning the information collections approved in this Final Rule and 

the associated burden estimates should be sent to the Commission in these dockets and 

may also be sent to the Office of Management and Budget, Office of Information and 

Regulatory Affairs [Attention: Desk Officer for the Federal Energy Regulatory 

Commission]. For security reasons, comments should be sent by e-mail to OMB at the 

following e-mail address: oira_submission@omb.eop.gov. Please reference FERC-725V

and the docket numbers of this Notice of Proposed Rulemaking (Docket No. RM14-13-

000) in your submission.

IV. Regulatory Flexibility Act Certification

60. The Regulatory Flexibility Act of 1980 (RFA)77 generally requires a description 

and analysis of proposed rules that will have significant economic impact on a substantial 

number of small entities. Reliability Standard COM-001-2 is expected to impose burdens 

for the first time on 1,217 entities (i.e., distribution providers and generator operators).78 

 77 5 U.S.C. 601-612.

78 The number of small distribution providers required to comply with the COM 

standards may decrease significantly. In March 2015, the Commission approved 

revisions to the NERC Rules of Procedure to implement NERC’s “risk based 

registration” program, which raised the registry threshold for distribution providers from 

a 25 MW to 75 MW peak load. North American Electric Reliability Corp., 150 FERC 

¶ 61,213 (2015). 
Docket No. RM14-13-000 - 41 -

Reliability Standard COM-002-4 may apply to as many as 1,279 entities.

79 Comparison 

of the applicable entities with FERC’s small business data indicates that approximately 

934 of the 1,279 entities are small entities.80

61. Reliability Standard COM-002-4 will serve to enhance reliability by, among other 

things, requiring adoption of predefined communication protocols, annual assessment of 

those protocols and operating personnel’s adherence thereto, training on the protocols, 

and use of three-part communications. The Commission estimates that each small 

balancing authority, reliability coordinator, and transmission operator subject to 

Reliability Standard COM-002-4 will incur one-time compliance costs of about $523 (i.e.

development of communication protocols), plus on-going annual costs of about $790 (i.e. 

performing training and maintaining evidence of training and assessments).81 The 

Commission estimates that each of the small distribution provider and generator operator 

entities potentially subject to Reliability Standards COM-001-2 and COM-002-4 will 

incur on-going annual costs of about $887 (i.e. performing training and maintaining 

 79 The applicable entities are balancing authorities, reliability coordinators, 

transmission operators, generator operators, and distribution providers. After accounting 

for entities registered for more than one function, the total count is 1,279 entities. 

80 The Small Business Administration sets the threshold for what constitutes a 

small business. Public utilities may fall under one of several different categories, each 

with a size threshold based on the company’s number of employees, including affiliates, 

the parent company, and subsidiaries. The possible categories for the applicable entities 

have a size threshold ranging from 250 employees to 1,000 employees. We are using the 

1000 employee threshold for this analysis. 

81 The ongoing annual costs for both paperwork and training are based on (8 hours 

* $33.42) + (8 * $65.34) = $790.16 or approximately $790.00.
Docket No. RM14-13-000 - 42 -

evidence of interpersonal communication capability and of training).82 The Commission 

does not consider the estimated costs per small entity to have a significant economic 

impact on a substantial number of small entities. Accordingly, the Commission certifies 

that this Final Rule will not have a significant economic impact on a substantial number 

of small entities.

V. Environmental Analysis

62. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

on the human environment.83 The Commission has categorically excluded certain actions 

from this requirement as not having a significant effect on the human environment. 

Included in the exclusion are rules that are clarifying, corrective, or procedural or that do 

not substantially change the effect of the regulations being amended.84 The actions 

approved herein fall within this categorical exclusion in the Commission’s regulations.

VI. Document Availability

63. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission's Home Page 

 82 The ongoing annual cost is based on (12 * $33.42) + (8 * $60.70) = $886.64 or 

approximately $887.00.

83 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, FERC Stats. & Regs. ¶ 30,783 (1987).

84 18 CFR 380.4(a)(2)(ii).
Docket No. RM14-13-000 - 43 -

(http://www.ferc.gov) and in the Commission's Public Reference Room during normal 

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington, DC 20426.

64. From the Commission's Home Page on the Internet, this information is available 

on eLibrary. The full text of this document is available on eLibrary in PDF and 

Microsoft Word format for viewing, printing, and/or downloading. To access this 

document in eLibrary, type the docket number excluding the last three digits of this 

document in the docket number field.

65. User assistance is available for eLibrary and the Commission’s website during 

normal business hours from the Commission’s Online Support at 202-502-6652 (toll free 

at 1-866-208-3676) or email at ferconlinesupport@ferc.gov, or the Public Reference 

Room at (202) 502-8371, TTY (202) 502-8659. E-mail the Public Reference Room 

at public.referenceroom@ferc.gov.

VII. Effective Date and Congressional Notification

66. This Final Rule is effective [insert date 60 days from publication in the Federal 

Register]. 

67. The Commission has determined, with the concurrence of the Administrator of the 

Office of Information and Regulatory Affairs of OMB, that this rule is not a “major rule” 

as defined in section 351 of the Small Business Regulatory Enforcement Fairness Act of 
Docket No. RM14-13-000 - 44 -

1996.85 The Commission will submit the Final Rule to both houses of Congress and to 

the General Accountability Office. 

68. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission's Home Page 

(http://www.ferc.gov) and in the Commission's Public Reference Room during normal 

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington, DC 20426.

By direction of the Commission. 

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.

 85 See 5 U.S.C. 804(2).