System Operator Certification Program Administrative

System Operator Certification Program

Administrative Guidelines

Maintaining

NERC System Operator Credential

Through the Use of

Continuing Education Credit Hours

North American Electric Reliability Council

NERC System Operator Certification Phase II Administrative Guidelines

Executive Summary

The Personnel Subcommittee (PS) and the Personnel Certification Governance Committee (PCGC) are seeking to implement a method to use continuing education credit hours to maintain a system operator’s credential rather than re-taking a NERC certification exam. The Personnel Subcommittee’s Continuing

Education Program is the first step in that direction; the program provides a mechanism for learning-activity providers to register and obtain approval for their continuing education programs. The PCGC’s proposed

System Operator Certification Continuing Education Program will allow system operators to accumulate continuing education credit hours in specified subjects and apply them toward maintaining their system operator credential. This white paper is designed to inform system operators about the program and to solicit their comments. The PCGC will review the comments received during this review period and adjust the proposed program as appropriate. The PCGC will also determine an implementation date.

Art Feeney

Salt River Project

Training Administrator

Transmission & Generation

Operations

Phone: (602) 236-3839 Fax:

(602) 236-3808 aefeeney@srpnet.com

Regarding the different levels of CE required for the various credentials, all credentials should have the same requirement. Like Dispatchers,

Professional Educators earn credentials in different areas of expertise

(English, History, Math, etc.), but unlike in this proposal, they are all held to the same continuing education requirement.

Details

The program provides that:



New candidates will have to pass an exam to earn a credential that will be valid for three years;



A certificate, valid for three years, will be issued to successful candidates;



Certified system operators will have to accumulate a specified number of continuing education credit hours (CEH), in specific subjects before their certificate expires to maintain their credential: o 240 CEH for Reliability Coordinator, o 180 CEH for Balancing and Interchange/Transmission Operator, o 120 CEH for Balancing Operators, and o 120 CEH for Transmission Operators;



If the certified operator submits the proper number of CEH in the proper subjects, they will be issued a new certificate valid for another three-year period;



Retaking the exam will not be an option;



If a system operator does not accumulate enough CEH prior to the certificate expiration date, their credential will be suspended (for organizational compliance to NERC policy/standards, a suspended credential is not a valid credential);



The credential will be suspended for a maximum of one year, at the end of which the credential will be revoked;



If, prior to the end of the one-year suspension, the system operator accumulates the proper number and type of CEH, their credential will be reinstated with the original expiration date (three years from the previous expiration date);



If the system operator does not accumulate the proper number and type of CEH prior to the end of the suspension period, their credential will be revoked and they will have to take an exam to become certified again;



Taking an exam will not be allowed until the suspension period has expired.

Draft for Comments

Page 2 of 110

July 28, 2004


Transition

A transition process has been designed so that people with current 5-year certificates can transition to the 3year program; it also allows operators certified at one level to transition to another level. The program is intended to allow people holding a reliability coordinator credential but not working as reliability coordinators to transition to a credential that more closely matches the work they perform without taking a new exam. People currently holding a transmission or balancing credential will have to pass an exam to move to the combined balancing and interchange/transmission credential or the reliability coordinator credential.

Art Feeney

Salt River Project



Operations

Phone: (602) 236-3839 Fax:


With the transition to a three-year CE program, SRP supports the idea that anyone taking the certification exam prior to its implementation will still be awarded a five-year certificate.

NERC System Operator Certification Phase II Preamble

The NERC system operator certification program consists of four exams, one for each of four specialties: Transmission Operator, Balancing and Interchange Operator, Balancing and

Interchange/Transmission Operator, and Reliability Coordinator. The exam content is geared toward new system operators acquiring their initial certification. Successfully passing one of the exams affirms that the system operator has at least a basic understanding of system operations.

NERC’s expectation is that the system operator’s employer will complete the necessary on-site training before allowing that system operator to hold a shift with specific responsibilities.

When the System Operator Certification Program was implemented in 1998, the plan was to have a continuing education program in place before the first group of certifications started expiring in

2003. Because the continuing education program did not develop as quickly as hoped, system operators have had to retake the initial test and become re-certified. This retest reaffirmed that the system operators had at least as much knowledge as when they took the test five years before.

The industry in general, and system operators in particular, recognize that this is not enough. Some method of affirming knowledge growth and performance improvement must be devised in order to better the NERC certification program. One of the primary purposes of continuing education is that it promotes ongoing development of an operator’s knowledge, rather than simply re-affirming an individual’s basic knowledge of principles and policies. It is hoped that by increasing a system operator’s knowledge, the performance of the system operator will improve as well. System operators have enthusiastically expressed an interest in such a program.

Comments:

Alan Gale

Chief System Operator

Electric System Control

The System Operators have expressed an interest in any program that will keep them from having to study for a test every 5 years. The goals stated above are a great high level statement, but the bottom line of every operator I have talked to is "anything to not have to take the test again".

The training level for each system will be different. The training

Draft for Comments

Page 3 of 110

July 28, 2004

NERC System Operator Certification Phase II

Mark Klohonatz

General Manager, System

Operations

Allegheny Power mklohon@alleghenypower.com

Administrative Guidelines necessary to safely operate a system with a peak load of 25,000MW will be SIGNIFICANTLY different from that necessary to run a system with a peak load of 500MW or even 50MW, but the knowledge to meet

CERTIFICATION is the same, this is the sticking point. Once you have taken and passed the test once, you are operating the system on a near daily basis. This hands on experience is what makes a better operator. Passing the test does not mean you can go sit at a desk alone and be proficient. It is the company's training program that must ensure safe and proficient operators. What is occuring is a

"raising of the bar". The minimum is no longer to be fully compliant.

Entities will have to go beyond the accepted standard in both time and money to meet the new bar.

What is not specified here is that this will NOT be a substitute for a company training program, it will be in addition to any company training program, just like the additional 40 hours of Emergency

Operations training that was "recommended" and imposed after the

August 14th blackout (without industry input).

The PCGC has indicated that all of the other NERC requirements for training are separate requirements. While the PCGC has only covered

Certification here, the topic of training should not be broached without a discussion of the other NERC requirements for training. Are Policy 8 and the 40 hours of Emergency Training going to go away with the adoption of this program? While this may be beyond the pervue of the

PCGC, it is a pivitol issue to the acceptance of the CE program.

Allegheny Power supports the concept of continuing education requirements for system operators and we believe that continuous involvement in a personal development plan is important to preparing system operators to maintain the overall reliability of the bulk power system. However, we are concerned that the program is evolving without the thorough consideration of all of the requirements with regard to training that have been proposed within the last year.

For instance, how do the emergency procedures requirements of this continuing education requirement coordinate with the emergency procedures requirements contained in the new P8 T3 Compliance

Template.

Also, because of the commitment necessary to complete the proposed training requirements in this CEH program, was there any consideration to the effect that either the CEH program or the emergency procedures program, or now the combination of the two, could possibly have on the extent of the Operator training program that there will be any opportunity to complete outside of these two programs?

In addition, some RTO's are also expecting to put required training programs into place. All of these programs cannot continue to be imposed mutually exclusive of each other and still expect that companies and operators will be able to keep up with the requirements and schedules necessary to maintain compliance.

There is not enough guidance in this proposal to allow potential third party providers of the training to know how they would be expected to

Draft for Comments

Page 4 of 110

July 28, 2004


Karl Tammar

NYISO

KTAMMAR@nyiso.com

Art Feeney

Salt River Project



Operations aefeeney@srpnet.com

Administrative Guidelines provide their courses. And NERC needs to provide such guidance to show support for the companies who will be trying to make diligent use of the program to keep their operators up-to-date. For instance,

NERC needs to support the program by requiring that third party providers who have courses certified should find convenient ways to make those couses available to operators trying to schedule into their training requirements. This kind of guidance should include the number of times and locations that courses need to be offered in order to maintain certification. It should include guidelines for making courses available either on-line or via teleconference or both, and this program should include acceptable guidelines for how testing of the material is accomplished so that each operator attending the training remotely can demonstrate proficiency in the material presented.

It is unrealistic to propose such a program and put it into place before many of the questions like this have been considered. The actual logistics of how qualified courses are made available to the operators will ultimately determine the success or failure of such a proposal.

NERC should not expect to propose a program with such extensive impacts to the staffing, scheduling, and budgets of the members who comply with the program without providing support to those companies by considering these areas before implementing the program.

Thank you for the opportunity to comment on this important topic.

The IRC supports the whitepaper’s intent of setting high standards in continuing education for system operators and the development of resources to provide this training.

The Salt River Project (SRP) offers the following comments in response to the NERC System Operator Certification Program Administrative

Guidelines, also known as the NERC Continuing Education White Paper.

SRP supports the concept of a NERC Continuing Education program as the path to re-certification for System Operators. We believe this program will have a positive impact on the reliability of interconnected operations and provide for the training that System Operators need to remain current in their profession.

Though a good first attempt at defining the scope of a System

Operator Continuing Education program, SRP believes there are

 changes that must be made to make this program workable. The following are of the greatest concern:

The proposed number of Continuing Education hours is onerous

 and can initially result in compromising the system reliability it was designed to preserve.

 Internal and external training resources are inadequate to provide the proposed level of training.

The Continuing Education requirement must be considered a part of training already required by NERC Policy 6.

 When including the NERC Policy 6 Emergency Training requirement into the overall training requirements, SRP believes that no more

Draft for Comments

Page 5 of 110

July 28, 2004


 than 45 hours of CE credits every three years is adequate for certification.

 Continuing Education requirements for professions similar to electric system operation should be reviewed to determine an adequate number of hours for the NERC Continuing Education program.

The remainder of this document elaborates further on the key issues indicated above as well as other comments less significant in nature.

Comment 1:

General Comment

The proposed number of CE hours will have a detrimental impact on system reliability in the near term. To comply with this proposal, an exceptional amount of resources, both human and financial, will need to be marshaled to create the required training opportunities.

Reliability Entities will have to wrestle with such issues as: requiring existing staff to work excessive overtime and/or staffing for relief shifts to deliver the prescribed training; and securing the resources necessary to provide for the training in-house or outsourcing it to a vendor. Any of these options have the potential of causing Reliability

Entities to operate in a less than reliable manner.

Whatever the methods of producing and delivering this level of training one constant remains: the human impact from excessive overtime.

SRP believes that System Operators will experience dangerous levels of on-the-job stress as a result of the extra overtime hours, for both receiving training and covering for those who are receiving training.

This can create an environment where the risk of operator error is substantially increased.

Hiring and staffing a relief/training shift is worse. Not only will existing staff be expected to operate the system, but also develop training materials, train the new staff, and all the while receive their own prescribed training. And at the same time, with existing staff stretched to the limit, significant numbers of new dispatchers will be populating

Control Centers, further raising the level of stress and the potential for disaster.

Few Reliability Entities have the required curriculum and staff to satisfy the proposed CE requirements. They will either have to, develop and deliver the training in-house, hire a vendor to deliver the training, or employ some combination of both. And regardless of the choice, a full-time training staff will be a necessity.

All this comes at a significant financial cost: Acquiring new dispatching personnel and the facilities to accommodate them versus the financial cost of overtime. Hiring additional training personnel to develop, deliver, and administer training versus the financial cost of purchasing and administering it. To the last point, with the lack of training available to the industry, costs will surely rise with the increased demand, and quality and effectiveness will go down, due to the haste of bringing products to market. Further exacerbating this, what is currently available is generic, much of it dealing with basic (non

Continuing Education) topics, and not nearly diverse enough to satisfy

Draft for Comments

Page 6 of 110

July 28, 2004


Thomas W Farr twfarr@cmsenergy.com

Hannah Peterson

Training Specialist

Midwest ISO, Inc.

HPeterson@midwestiso.org

A. Glazner

AGlazner@fmtn.org

Matthew Sadinsky

System Operations Success, Intl.

Matt@sosintl.com

Burrows Gerry

KCPL

Gerry.Burrows@kcpl.com

Anita Lee, P. Eng.

Manager, Operating Policies and

Procedures

Alberta Electrical System Operator anita.lee@aeso.ca the training needs of all certificates.

Comment 2:

General Comment

With the current requirements for 5 days of NERC Policy 6 Emergencyrelated training and WECC's 10 hours of MORC-related training per year, completing the proposed number of NERC CE hours in three years is onerous. SRP recently sent a number of its System Operators to 5 days of training at a vendor’s site. The 5-day investment yielded only 15 credentialed hours and 1 NERC policy hour. Put in term of weeks per year, this example equates to roughly 4 weeks per year of

CE for dispatchers with BIO&TO certificates (180 hours). Add to this the Emergency and WECC requirements plus any other companyspecific training and each dispatcher could potentially require well over

6 weeks of training each year.

The 3 year validity for a credential is too short of a time period. The 5 year is a good time period. With the CEH program in its infancy, a graduated scale of CEH's per year required would be a good scale to follow. At the end of the 5 year period the proposed number of CEH's would be acceptable.

Retaking taking the test should always be an option as long as participating utilities/entities have an ongoing training program.

The statements related to the credential suspension is vague. It indicates that the suspension can be up to one year. The initial indication is that there is no way to renew the credential with out accumulating the CEH's. A retest should be an option.

Once the suspension time period has expired an operator should be able to retake the exam. If the individual is off for a medical situation they could be off for a time period long enough not to be able to accumulate the CEH's.

The Midwest ISO supports continuing development of operators and appreciates the opportunity to provide comments regarding this critical initiative.

The CE hours seem to be excessive budget busters for smaller companys. I suggest 80 CE hours every three years.

Agreed. It is our observation at the CE program proposed here recognizes that System Operators are professionals that must stay current with an evolving body of knowledge.

The number of hours of training required by this proposal may require companies to staff up to meet this requirement. It is suggested to allow at least a 12 month transition time after approval of this process to allow companies to budgeting, staff up, and/or to allow companies to certify their own training program.

Thank you for the opportunity to comment on this important topic.

The Alberta Electrical System Operator (AESO) supports the whitepaper’s intent of setting high standards in continuing education for system operators and the development of resources to provide this training.

The AESO would like to keep the re-taking of an exam as an option for operator re-certification under extraordinary circumstances that

Draft for Comments

Page 7 of 110

July 28, 2004


Gordon Pietsch

Manager, System Operations

Great River Energy gpietsch@GREnergy.com

Gratien Charest

Administrative Guidelines prevent the operator from fulfilling the CEH requirements. (for example: long term sickness). AESO believes that the operator should have an alternative to be re-certified without being suspended and perhaps losing his employment.

The task performed by AESO operators include those described as

"Reliability Coordinator Operator", "Balancing Operator", "Transmission

Operator", "Interchange Operator" and "Market Operator". Presently, all operators at the AESO are NERC certified as "Reliability Coordinator

Operators" and this allows us the flexibility of moving operators from desk to desk as needed. The future System Operator certification program must maintain this flexibility, such that when operators are certified as a "Reliability Coordinator Operator" then they are also certified to perform the Balancing Operator, Transmission Operator,

Interchange Operator and Market Operator functions.

We also noted that the terms used in the document such as the

Reliability Coordinator Operator, Balancing and

Interchange/Transmission Operator and Balancing Operator should be defined in relation to the NERC Functional Model. For example, the

Reliability Coordinator Operator is a system operator performing the

Reliablility Coordinator function for an entity that is certified as a

Reliability Coordinator by NERC as per the NERC Functional Model.

We are supportive of the NERC Certification, testing, and CEH program as a means of optaining certification and maintaning certification.

We support the idea of testing in the 4 areas of certification for initial certification and the three year renewal period for recertification. We do differ in a few areas which I will explain.

We feel all four specialties should have equal requirements of 180 hours of CEH's over a period of 3 years. 30 of these CEH's would be on

NERC policies. We believe there should be an alternative method of recertification that would allow all four of the specialties to accumulate

50% of the required CEH's plus retest every three years. With these two alternatives avaliable it would allow for choice, flexability and unforseen situations that may occur at a company or for an individual system operator that would not allow them the time to accumulate the

180 hours. 30 of these hours would still be required on NERC policies.

Without these two alternatives individuals and companies could be put in difficult situations beyond their control.

If a system operator accumulates more than the required hours over a three year period any CEH's over the required amount that had been accumulated in the last six months prior to expiration should apply to the next three year period.

We believe that NERC and the white paper over looked a large group of NERC certified people that are not control room operators. These would include supervisors, engineers, and operations support personnel that are currently NERC Certified. We feel this group should be able to recertify every three years by taking only the test. Many of these people have other types of training that they are required to attend as part of their job that would not fall into the category of NERC certified CEH's.

240 CEH (for RC certification) would be acceptable if spread over 5

Draft for Comments

Page 8 of 110

July 28, 2004


Manager Control Center

TransÉnergie charest.gratien@hydro.qc.ca

Donnie Harrell

Sr. Analyst

Entergy Transmission dharrel@entergy.com

On behalf of Doug Hils (industry segment 1) and Walt Yeager

(industry segment 6)

Doug.Hils@cinergy.com

Will Behnke

Alliant Energy willbehnke@alliantenergy.com

Jule W. Tate

Manager, Power System

Operations Training

Progress Energy jule.tate@pgnmail.com

Jeffrey S. Crandall

NYSEG

Supervisor - Operations Support jscrandall@nyseg.com years; otherwise less CEH over 3 years (and applicable proportion for other certifications)

A certificate, valid for three years, will be issued to successful candidates.

Why the change from five years?

5yrs. Gives more time for CEH's to be accumulated.

Fees are collected on a more frequent bases, good for NERC, bad for those that pay. Typical government input.

1.) Why can't an operator have a RC certificate if they perform BA functions? Isn't the RC certificate an expanded version of the BA certificate or will they be changed?

2.) Why has the certification time period been changed to 3 years from 5 years?

The NERC certification exam is currently pass/fail. When maintaining certification through the Phase II System Operator Certification

Program (SOCP), a certification exam will be used for all initial certifications, but is not acceptable for recertification. Instead, the system operator certification is suspended if the continuing education requirement is not met. Certification testing again becomes a requirement once certification has been revoked.. It does not seem reasonable that testing is adequate some of the time, but not consistently. Since testing is adequate for intial certification purposes, it should also be adequate for recertification. Consideration might be given to a special re-test examination that could be taken upon expiration of a certificate.

The proposal is to breakdown the amount of required training hours to the individual’s certification credentials by authority. The higher authority the more hours it would take to maintain that level of certification. A suggestion would be to require the same number of training hours to maintain any certification credential.. Requiring a greater number of hours for different credential levels might conceivably damage the industry by providing incentive for operators and their companies to maintain a minimum credential.

Does the Transiton period require people who currently have 5 year certifications to sit another exam that has a three year certification expiration date? This is not clear. Also, do people who were certified with the old NERC Certification (Not the different credentials, i.e

Reliability Coordinator etc.) have to take the new Exam to enter the

CEH three year program?

I would recommend that the existing, periodic testing be included as an option to the continuing education proposal for re-certification.

Periodic testing could become more frequent, possibly at a 3-year interval. Re-certification test content should be different from that of the initial certification test, to include some of the fundamentals, but also include new and advanced concepts and principals.

Periodic testing at a 5-year or a 3-year interval is more than just a reaffirmation of an operator’s basic knowledge of principles and policies.

Draft for Comments

Page 9 of 110

July 28, 2004


Debra L. Yinger

Operations / Training

International Transmission Co. dyinger@Itctransco.com

John Theotonio on behalf of TRWG

John.Theotonio@NERC.net

Such testing would require that the individual re-learn the concepts and details that may have lapsed during the previous 3 or 5 years, then demonstrate understanding through the testing process. In addition, evolution of operating policies and industry standards will provide new test material in the future. On-going operator development will be required just to keep pace with the content of periodic, re-certification test material.

The continuing education concept introduces a variety challenges for control center management, and for the operators themselves. The resulting negative impacts on shift-work schedules, system operator staffing limitations, cost concerns, and administrative effort have been understated in the proposal. Re-certification at a fixed interval is less invasive overall and will permit the individuals to prepare for recertification testing on their own time schedule at their own pace.

If existing certification expires, the continuing education proposal allows for a one-year suspension followed by revocation of certification, but then permits certification again through the testing process after the one-year suspension time period expires. This seems a bit inconsistent. Allow previously certified operators to re-certify only through re-certification testing without the one-year suspension (my preference) or only through continuing education.

I agree that the test alone is not sufficient. I feel that an appropriate and reasonable amount of CE hours would be a benefit to the System

Operators, and would be accepted by the Operators.

TRWG questions how PCGC came up with the number of CE hours required for each of the credenitals. TRWG cannot agree with these numbers until it understands how they were derived. Another comment is that it does not appear that there are enough "qualified"

CE programs in existence that can support the total number of hours suggested.

It is important to note that TRWG agrees with the general philosophy that quality training is needed in the electric power industry. We ask

PCGC to take a look at the findings of the NERC and FERC independent studies on system operator training before making any firm decision.

The TRWG suggests the results of those studies be used to accredit training programs instead of implementing the recommendations of the NERC System Operator Certification Phase II.

TRWG would like to see the original NERC CE program and requirements be implemented. In addition to the CE program for

NERC Certification credentials the PCGC ask NERC to consider creating a training program certification. An accredited training program would be an avenue to accredit individual utility system operator training programs that would address both initial and continuing education.

Accredited training programs/would be required to address those items uncovered on the NERC and FERC studies.

To recap the above statement, each utility would be required to have an Accredited Training Program. The System Operator Certification

Program would stay in place without any additional requirements for

Draft for Comments

Page 10 of 110

July 28, 2004


Kathy Bauer

NorthWestern Energy

Kathleen.Bauer@northwestern.com

Cochran, Bob

Xcel Energy

Bob.Cochran@xcelenergy.com

Heather M. Boykin

Trans. Security Coordination

System Operations Center - Pine

Bluff hboykin@entergy.com

Herbert Ezzell

WAPA

EZZELLH@wapa.gov

Paul Steinberger on behalf of

MISO SOTWG

American Transmission Company psteinberger@atcllc.com training or certification. System Operators can elect to extend certification credentials through the NERC CE Program.

Utility Accredited Training Programs have to meet NERC standards.

There should only be one exam that covers the NERC policies only, do you understand the policies as written and intended. Certification by

NERC does not mean "qualified", Each control area should be responsible for the "qualified" in respect to system operators. disagree that test only proves old knowledge. test covers policy as it is not as it was five years ago. System operator interest in CE is in the hope that it replaces taking a test, not in that it forces growth of knowledge.

I think in your "details" section above, you are contradicting yourself.

" Retaking the exam will not be an option" and then "Taking an exam will not be allowed until the suspension period has expired".

I think that 240 CEH classes for Rel. Coord. would be acceptable in a

FIVE YEAR timeframe, but I think that that amount of hours for three years is potentially ridulous…it depends on HOW MANY of those hours our training guys are going to be able to provide and it also depends upon: what amount of money per person, per class you are going to charge and where the training is to take place.

With my background in the Nuclear Power (both Navy and civilian) and

Electrical industry I have been exposed to a significant amount of training, Both as a trainer and as a recepiant. I believe that this program is necessary and needed by this industry to inorder meet the operational and political challenges facing it. The continuing education program will provide the base for companies to build an effective training program if each company chooses to do so.

This program will require a significant increase in expenditures over previous budgets to meet the stated goals. The three elecrtical utility organizations I have worked for viewed training as a very low priority with respect to budget expenditures. The management expectations I experienced emphasized providinge the minimum necessary for the operator to qualify and letting the operator learn on the job (A common expression is it takes seven to ten years after qualification for an operator to learn all that is needed). The companies only provided dedicated training time and resources to meet industry required training, for example, the 5 days of training required by NERC's recommendation six.

I believe that a true continuing training program will only be achieved when FERC and NERC adopt training guidelines in line with those required by the Nuclear Regulatory Commission. This will require the industry to make the investments in training required to meets the coming challenges to the industry.

The NERC certification exam is currently pass/fail. When maintaining certification through the Phase II System Operator Certification

Program (SOCP), a certification exam will be used for all initial certifications, but is not acceptable for recertification. Instead, the system operator certification is suspended if the continuing education requirement is not met. Certification testing again becomes a requirement once certification has been revoked.. It does not seem reasonable that testing is adequate some of the time, but not consistently. Since testing is adequate for intial certification purposes, it should also be adequate for recertification. Consideration might be

Draft for Comments

Page 11 of 110

July 28, 2004


John Taylor

SPP

JTaylor@spp.org

Lisa Carter

Southwest Power Pool

LCarter@spp.org elm@dairynet.com

Administrative Guidelines given to a special re-test examination that could be taken upon expiration of a certificate.

The proposal is to breakdown the amount of required training hours to the individual’s certification credentials by authority. The higher authority the more hours it would take to maintain that level of certification. A suggestion would be to require the same number of training hours to maintain any certification credential.. Requiring a greater number of hours for different credential levels might concievebly damage the industry by providing insentive for operators and their companies to maintain a minimum credential..

The Preamble is right on-target strategically. I suggest adding the following to frame this as an operating issue as much as it is a training issue.

The ultimate goal of the certification process is to ensure reliable operation of the bulk electrical system in North America. Training and certification are tools to that end. Phase II of the NERC System

Operator Certification process is intended to relate recertification requirements to maintainting competent performance capability through ongoing traininng activities. The requirement for continuing education results from the changing nature of the industry. System operators must stay abreast of the tools, technology, and topology of the the bulk electrical system to competently operate that system. It is an operating requirement to be a competent system operator. It is a training and certification issue to ensure that operator competency is up to date and sufficient for the job. Change in this industry is ongoing, therefor training must be ongoing. To certify orpeators as having curent competency is a different process than certifying baseline knowledge as a system operator. Continuing relevant training and education is the appropriate process for recertifiying.

I would greatly appreciate any opportunity to participate in a continuing education program.

Jane Cocker

System Operations

Rochester Public Utilities

JCocker@RPU.ORG

Until it has been shown that the required number of CEH's for each of the 4 specialties can be achieved in the 3 year period, removing the taking of the exam as a means to maintain certification jeopardizes every certified operators job. A person must be given the chance to keep his/her job at the same qualification levels that are then required to get into that position. 3 years of experience at a position regardless of CEH's will increase an operators knowledge. If new areas or information is required for the position, update the test, don't remove it as a tool to remain certified.

Why is an exam good enough for a new candidate, but not acceptable for recertification? If the credential is revoked then taking the exam is good enough again? This is extremely inconsistant. Some sort of testing option should still be available.

The number of CEH's should be the same for all credentials. It should be feasible for an operator to maintain any credential they have successfully tested in. In this ever changing environment it is only prudent for an operator to maintain a credential that will allow them to work in different situations. I would think a broader knowledge base of how all aspects of the interconnected system work would be

Draft for Comments

Page 12 of 110

July 28, 2004


Pat Budler

Energy Delivery

Training Supervisor pbbudle@nppd.com

Boyer, Roger rboyer@pplweb.com

Kathy Davis

TVA Electric System Operations adavis@tva.go

Administrative Guidelines desirable. By differing the hours, operators may be forced into credentials that have a narrower focus.

Why transition operators out of an RA credential? They should be able to maintain which ever credential they choose that meets requirements for them to do their job.

How was the number of CEH's derived? They seem exceptionally high compared to other profesions.

Although increasing an operator's knowledge and performance improvements are desireable, that should not be part of the certification program. The language used in the last paragraph implies that there are two levels of certification, one when an operator passes the certification exam and then continuing education would improve the operator's basic knowledge and ability to operate the power system. Certification should mean an operator has enough knowledge of NERC policies and system operation to do the job. With rotating shifts, a newly certified operator may be on duty when crisis hits so the certification exam should ensure that the basic requirements are covered. From the certification program, the purpose of continuing education is to verify the operator has kept up with changing policy and knowledge to operate the system. It should NOT be to move to a different level.

It may be appropriate to have requirements for a certain amount of

NERC Certified training for each operator in a certain time period, but this should be done in the NERC Standard replacement for old

Operating Policy 8 on training requirements and be a part of the NERC compliance program.

Will never have the time to take the courses.

Details:

> Need to Clarify if the numbers of CEHs incliude the 40 hrs. of emergency training…or is it in addition to it?

> 240 hours will be a hardship especially if the number of operators on shift are down for any reason . It could also result in employees loosing their leave.

> With current headcount, it will be difficult to meet the required training hours.

> It should not be the responsibility of the system operator to submit credit for CEHs, it is the responsibility of the provider. The operator should only verify proper credit of CEHs.

> Retaking the exam should be an option. Under extenuating circumstances/situations and individual should be able to petition NERC

(PCGC) to take a certification exam in lieu making up the continuing training hours; e.g., an operator is off due to extended illness or retirement with the individual re-entering the workforce, it would be better to have the individual to retake the exam instead of making up the hours.

Preamble:

We agree that the certification exam content is geared to system

Draft for Comments

Page 13 of 110

July 28, 2004


Katie Duncan on behalf of

SPP OTWG

KDuncan@spp.org

Keith Comeaux

CLECO

Keith.Comeaux@cleco.com

Robert D. Vargus

Muscatine Power & Water bvargus@mpw.org operators acquiring certification by demonstraing a basic understanding of NERC Policies/Standards and fundamental system operations. The system operator's employer must provide the necessary on-site training on position specific responsibilities and tasks prior to allowing that sytem operator to independently assume shift responsibilities. This ensures understanding of the operating entitie's policies and procedures for both normal and offnormal/ememgency conditions.

1. NERC should consider re-testing as an option in some cases, especially for support personnel who may be discouraged from recertifying without a retest option. The more options NERC can provide for re-certification the better. The program needs to address hardship cases where retesting would be appropriate. The document does not address or allow relief for System Operators who do not attain the required CE hours due to circumstances beyond their control, such as long-term illness, military duty, or other uncontrollable absence from the job. Should the program provide a method to request extension related to such circumstances? Loss of employment or other penalties as a result of Certification suspension/revoke may offer legal challenge to the program.

We support recognition of CE as a means of maintaining SO

Certification.. Long overdue.

BC Transmission Corporation

Rod MacNeill

Manager, Operator Training

Rod.MacNeill@bctc.com

Gary L. Condict

Aquila Inc.

System Operations Supervisor gary.condict@aquila.com

Sanjay Dutta

CAISO

Manager of Operations Training

Draft for Comments

240 hours required for RA is excessive. This will force operators to down grade their certificates because companies will not pay for the additional training. Shouldn't we promote obtaining the highest certificate possible?

I recommend that all certificates require the same number of CE hours

(15 hours per year). For instance, a professional engineering license only requires 30 hours every two years. I think we have to be realistic, shifts still have to be covered!

Agreed that a training program administered on an on-going basis is an excellent method for continued growth . Would rather see this program introduced as an option as opposed to the only method of maintaining credentials.

"The industry in general, and system operators in particular, reconize that this is not enough." What industry and system operators were you talking to? I have not talked to 1 system operator or industry that agrees with that sentence at any meeting (APDA or

MAPP/MISO meetings). We agree the numbers are too too high and the length of time is too constricted (3 yrs or less to be re-certified).

I have been in the power industry since 1976 and as a system operator since 1982. I received a BBA in 1985 and a MBA in 1995 (as you can see I am not adverse to taking CEH class work). I firmly believe that in the long run your requirements are over the top. 120 hours of CEHs over a 3 to 5 year period is more than plenty of training for most anyone. Keep the testing, but require 40 hours of CEHs per year. You can modify it from there. As in the "White Paper" the jump is just extremely large without the CEH classes organized to cover it yet.

CAISO will abide by requirement of 240 hrs/three years for RA level.

CAISO recommends that each category (Reliability Coordinator,

Balancing and Interchange/Transmission Operator, Balancing Operator

July 28, 2004

Page 14 of 110


SDutta@caiso.com

Thomas V Pruitt

Duke Energy tvpruitt@duke-energy.com

Michael S. Wenzinger

Senior Load Dispatcher

City of Los Angeles, Department of

Water & Power

Michael.Wenzinger@ladwp.com and Transmission Operator) should require the same number of

Continuing Education hours, in this case they should all require 240 hrs/three years.

As mentioned above, CAISO will abide by the 240-hrs/three years requirement; however, we would like to know how PCGC arrived at this number. Is this number based on amount of continuing education being required in other industries? If yes, what industries? What are the CE requirements for Nuclear Operators and Air Traffic Controllers, since these jobs seem to be closely related to the System Operators in the Power industry?

The mandatory CEH program described in this white paper is a dramatic turnaround on the matter of using CEH for recertification. The original concept was to offer a CEH based option to the testing approach. Moving forward after initial testing based certification, the

System Operator would have a choice to maintain certification via CEH or via testing. Clarification is needed on why this approach, at least as a transitional step, has been discarded in favor of a mandatory CEH program.

The requirements in this white paper affect much more than the individual operator. Control Areas, Reliability Coordinators, and other entities charged with performing control and coordination functions in the industry are affected. The requirements portion of this whitepaper should be subjected to an open development process with balloting representative of the entire industry.

This program is directionally right, but it is a huge step forward that may leave some of the smaller entities behind. The program and the non-compliance aspect of this program will drive Control Areas and

Reliability Coordinators to increase staffing levels for System

Operators. If one falls behind in CEHs, it will be very difficult to catch up. Without a bench of certified operators, a single suspension could put an entire organization at risk of non-compliance. A progressive, phased-in approach would allow adequate time to increase staffing.

This puts additional pressure on everyone (NERC, CEH Providers & utilities) to ensure that quality training is being delivered. This will have a significant impact on resources required to produce and deliver training, and, depending on the implementation date, demand for quality training may exceed the industry's ability to supply it.

System Operators need to be included in the process of developing the direction which NERC moves regarding certification. Numerous websites and bulletin boards of and for System Operators echo a frustration that they have for NOT being included in the process.

While NERC has its structure, its committees and subcommittees, it has NOT included the System Operators in the structure. NERC's committees tend to be staffed by engineers and high level managers who have never worked a shift as a System Operator. While their technical expertise in either the theory of power system operation, or in the practices of managing a large corporation are exceptional, they do not understand the problems faced by operations personnel on a moment to moment basis.

Draft for Comments

Page 15 of 110

July 28, 2004



Western operates four controls areas, one in the Eastern

Interconnection and three in the

Western Interconnection, plus an addition dispatch office within the

CAISO. These comments are a consolidation of the thoughts and opinions of the personnel working at these facilities.

Mark Meyer

MMEYER@wapa.gov

NERC must include a panel, or panels, of System Operators in its decision making processes relating to System Operator certification.

These experts can provide direction in System Operator needs as regards training subject matter, policy development and revision, training methodology and improvement in tools for monitoring system operations.

Such inclusion could lead to standardized tools and terminology that should reduce outages. In example the term CLEARANCE is not uniformly recognized across power systems to mean the same thing.

This industry MUST standardize its terminology if it intends to move from individual Control Area control to regional Security Coordinator or

RTO control.

The 3 year validity for a credential is too short of a time period. The 5 year is a good time period. With the CEH program in its infancy, a graduated scale of CEH's per year required would be a good scale to follow. At the end of the 5 year period the proposed number of CEH's would be acceptable.

Retaking taking the test should always be an option as long as participating utilities/entities have an ongoing training program.

The statements related to the credential suspension is vague. It indicates that the suspension can be up to one year. The initial indication is that there is no way to renew the credential with out accumulating the CEH's. A retest should be an option.

Once the suspension time period has expired an operator should be able to retake the exam. If the individual is off for a medical situation they could be off for a time period long enough not to be able to accumulate the CEH's.

1. The proposed three year certification period is too short. NERC should retain the five year certification period.

2. The proposed continuing education hours recommended for the subject areas seem to be excessive and unreasonable. This number could place an adverse burden on companies to complete due to work schedules, limited personnel, etc. We offer the following recommendations:

-96 CEH for Reliability Coordinators (versus 240)

-96 CEH for Balancing and Interchange/Transmission

Operators (versus 180)

-96 CEH for Balancing Operators (versus 120), and

-96 CEH for Transmission Operators (versus 120)

Note: These recommendations are for a 5 year period, not a 3 year period.

Note: The recommended 96 hours is a multiple of 32----32 is the maximum reasonable amount a training that can be accomplished in a one week session given some travel time at each end of the week.

Note: We recommend that the number of CEHs required for the four certification specialties be the same, i.e, 96 CEHs for RC, BI, TO and BI/TO. We believe each of these specialties equally share the burden of operating a reliable system. Also, many smaller companies routinely rotate personnel through various duties.

Draft for Comments

Page 16 of 110

July 28, 2004


3. The NERC Technical Analysis of the August 14, 2003 Blackout report recommendation #6 requires 5 days of training on emergency operations per year for system operators. This places an exceptional burden on companies and system operators to accomplish this each and every year, particularly if the continuing education program is adopted and CEH requirements are in addition to the 5 days. At a minimum, CEHs should be earned for the "5 days of training" and be accumulated to meet the certification requirements. However, if the topic is always "emergency operations" this will conflict with other topics that should be covered. This issue must be resolved.

4. We are concerned about the proposal to eliminate retesting as a normal means of recertification. Especially troublesome is the provision whereby if certification is under suspension for a one year period and then the certication is revoked, testing is once again appropriate. This almost seems like a reward. We suggest development of a system whereby an appropriate number of CEHs must once again be earned to allow recertification.

5. Consideration should be given to an alternate category of certification that would be earned through testing for individuals who wish to be certified or are required to be certified by their companies, but who are not actually (on the desk) system operators. Examples would be operations engineers, and supervisors who are not in the immediate chain of command but still involved in systems operations.

It is highly unlikely these personnel will have the time or the scheduling flexibility to obtain the required CEHs, but the would like to demonstrate their knowledge of NERC policies and associated electrical principles by testing out.

6. The transition from the current program to a continuing education program must be carefully developed with respect to the expiration dates of system operators that are currently certified. If the testing option is not available, the certified system operator may not have adequate time to acquire the necessary CEHs if his/her anniversary date is within a few months or a year of when the new program becomes effective. A prorated number of hours may be necessary during the initial few years of the continuing education program.

7. What does it mean that “…the system operator’s employer will complete the necessary on-site training before allowing that system operator to hold a shift…..? What does NERC consider to be “necessary on-site training”? Companies will ensure this is completed prior to assigning the operator to shift work. Recommend deletion of this sentence or clarify NERC's expectations.

Draft for Comments

Page 17 of 110

July 28, 2004


Goals

In light of the foregoing, the following goals have been set in place:

1.

Establish mandatory continuing education criteria to maintain certification with the goal to improve system operator performance by increasing their knowledge in their job tasks.

2.

1.1.

Establish criteria for NERC-certified system operators to maintain a credential through the use of continuing education credit hours.

Establish an electronic process to register and document continuing education credit hours earned by certified system operators through NERC CE Program approved learning activities.

2.1.

The process of registering continuing education credit hours will be done electronically. System operators and training providers may continuously update their information.

3.

Establish a mandatory process to maintain the credential of NERC-certified system operators by meeting continuing education credit hour requirements established by NERC.

Comments:

Alan Gale



Mark Klohonatz


Operations


Karl Tammar

NYISO

KTAMMAR@nyiso.com

Why is 1.1 a subset of Goal #1? They appear to be stating the same thing. A possible alternative: "Establish a mandatory criteria to maintain system operator certification through the use of continuing education credit hours."

Why is 2.1 a subset of Goal #2? They are very similar, and 2.1 does not contain a goal, it states how it will be implemented. A possible alternative: "Establish a user friendly electronic process to register and document continuing education credit hours earned through NERC CE approved learning activitites."

In 1.1 above, what does 'criteria' here really refer to? Does this mean it will be a requirement to maintain certification credential through the use of CE hours? Does it mean "X" hours per year per credential type?

Is the goal to establish the program or establish the quantity of hours? a. AP would recommend that retaking the exam remain as an option for re-certification.


We support the development of an electronic repository for CE hours.

IRC members suggest that re-testing be retained, at a minimum, as an available option fro re-certification under extraordinary circumstances.

Re-certification exams of this nature should cover a greater breath than only NERC policy and fundamentals.

For example, the whitepaper does not provide a safeguard for those situations where an operator's personal situation precludes pursuing

CE toward the end of their 3-year cycle and they therefore could lose their employment. Examples where this could happen are extended callups in the military reserves, jury duty or illness.

Add option to enable the operator to retake a test.

Draft for Comments

Page 18 of 110

July 28, 2004


Hannah Peterson

Training Specialist

Midwest ISO, Inc.


A. Glazner

AGlazner@fmtn.org

Matthew Sadinsky

System Operations Success, Intl.

Matt@sosintl.com

Anita Lee, P. Eng.


Procedures

Alberta Electrical System Operator anita.lee@aeso.ca

Linda Campbell

FRCC

LCampbell@frcc.com

Gordon Pietsch



The goal of all preceding methods of attaining a NERC Certification always provide operators an incentive to try to attain the highest rating. With the CEH's, as proposed, companies will only certify to the minimum required to, GET BY, and meet a standard, not to advance their operators knowledge.

Specific timing requirements must be in place to support consistent, timely reporting by both the Continuing Education Provider and the student seeking the CEHs.

An additional capability to allow supervisory staff or designated contacts at each participating company the ability to access their employee's records (via read-only or report functionality) will allow participating companies to lend greater support to the CEH program by providing a direct, local level of oversight.

Need to allow flexibility by retaining the potential to recertify by taking the exam. To ensure that continuing education occurs if a participant opts to recertify by taking an exam, the exam option could be coupled with a minimum CEH requirement geared toward supporting on-going learning regarding NERC policy.

This electronic process and documentation should be established prior to requiring the CE hours and should be accessible to the system operators' company trainer for planning/budgeting future education needs.

As soon as a format for electronically managing and transmitting information is available we would very much like to see it.

Please address the issue of whether the tracking of Emergency

Operations training contemplated by NERC Recommendation #6 will be considered as a separate "bucket". Also please seek and provide clarification that 5 days = 40 hours. Lastly, please clarify that the relevent period for training to satisfy the Rec #6 EO requirement will be cycled from June 30th - July 1st to coincide with the planned NERC

CE calendar year without creating a "dead period" where EO training received could not be counted.

AESO support the development of an electronic repository for CE hours.

NERC should maintain the re-test option to preserve flexibility for those individuals whose situation precludes meeting the CEH requirements.

In 1.1 above, what does criteria here really refer to? Does this mean it will be a requirement to maintain certification credential through the use of CE hours? Does it mean "X" hours per year per credential type?

Depending on the clarification of "criteria", need to review 1.1 and 3 to see how they are really different.

Will this be considered a training standard? If it is to be a training standard, it would need to be developed through the NERC Reliability

Standards Proces

We do agree with the MISO SOTWG comments that before implementing any program a working data base/online tracking system should be in place. The data base needs to have close NERC oversite, timely entry of data by the CEH providers, access by the entity employing the operator and reporting capabilities. If this system is not fully operational system operators could be at risk of loosing their credentials through no fault of their own.

Draft for Comments

Page 19 of 110

July 28, 2004


Page 20 of 110






Mark Meyer

MMEYER@wapa.gov

1. There are numerous references in the document concerning electronic record keeping. Here are our comments concerning the record keeping database management:

a. The training providers should be responsible entering the earned

CEHs

b. Certified personnel/personnel seeking certification should be able to access/review the data for concurrence checks to ensure it is correct. The process for correcting discrepancies should be detailed.

c. The record keeping system should be able to generate status reports/notifications for both certified personnel/personnel seeking certification and employers on some periodic basis. This is particularly important in the period immediately preceding the expiration date of a certification.

d. The record keeping system should be able to keep track of what training counts for each type of certification and to issue automatic updates for changes of status for the various specialties.

2. In paragraph 3 above, the statement seems to imply that the

"process" will be mandatory when, in fact, the intent is to state that the mandatory refers to the fact that this will be the only choice once the program is approved? See our comments on retesting for an alternate type of certification.

Each utility or company management should have the right to decide if the competency of one system operator can be demonstrate by CEH or the exam…

Gratien Charest






Will Behnke


1.) There needs to be a goal added to keep the cost that the utility companies might be exposed to when setting up the criteria, timeline for startup.

Jule W. Tate


Operations Training

Progress Energy jule.tate@pgnmail.com amoore@txued.com



Before implementing any program a working data base/online tracking system should be in place. The data base needs to have close NERC oversite, timely entry of data by the CEH providers, access by the entity employing the operator and reporting capabilities. If this system is not fully operational system operators could be at risk of loosing their credentials through no fault of their own.

Will this be become a requirement of the NERC Reliability Standards?

If so, when will it be introduced into the NERC Reliability Standards

Process?


What is the method of measuring improved performance?

The electronic tracking system must be implemented prior to starting this program. This program must be available to providers and credential holders.

TRWG does support continuing education for system personnel

Add option to enable the operator to retake a test.


Draft for Comments July 28, 2004


Kathy Bauer

NorthWestern Energy


Dale Wadding

Coordinator, System Operations

Center

Dairyland Power Cooperative ddw@dairynet.com

Herbert Ezzell

WAPA

EZZELLH@wapa.gov


MISO SOTWG

American Transmission Company psteinberger@atcllc.com

John Taylor

SPP

JTaylor@spp.org

Clarify the system operators required to have certification, any operator involved with the interconnected system, voltage level, something other than "responsible for", that could just mean the foreman, lead operator, chief dispatcher, department manager, or vice president, ceo etc.

Just as the CEH program was developed and initiated before recertification by CEH is implemented, the electronic registration and documentation of CEH's should be developed and tested in advance of any recertification program. This electronic system should be in place, tested, used, and proven for a significant period of time (6-12 months) before being used for recertification purposes. This time would allow for debugging and improvement of the system, but most importantly it would allow time for CEH providers and system operators to become acquainted with its use.

The operator's organization must be able to audit and enter necessary training data into the NERC web site. The organization must be able to protect it's investment through monitoring of the operator's training and ensuring accuracy of the information provided to NERC.

Before implementing any program a working data base/online tracking system should be in place. The data base needs to have close NERC oversite, timely entry of data by the CEH providers, access by the entity employing the operator and reporting capabilities. If this system is not fully operational system operators could be at risk of loosing their credentials through no fault of their own.

Item 1. and 3. seem to be the same. I suggest replacing item three with the following:

Establish the requirement for training and education to be ongoing as changes occur by requiring recertification to be dependent upon a continuing education process

I think this would be great. I especially like the idea of an electronic process to keep up with credit hours.

Lisa Carter


LCarter@spp.org

Mike Wells on behalf of

WECC OTS

WECC Staff mike@wecc.biz

Jane Cocker

System Operations

The WECC OTS supports the concept of making continuing education a requirement rather than simply an option.

There is concern the cost of the NERC database and web interface could become excessive and all options that will satisfy the data retention needs should be explored. The process of using CEH to maintain a credential must avoid unnecessary complexities that may add little to the quality of the program and increase the complexities of recording data and adversely affect the cost of the database.

OTS can support the concept that the operator tracks status/progress towards maintaining their credential, and supports the concept that the training provider be responsible to enter required data from the delivery of approved learning activities.

This paper does not mention the company's training representative. It is the company that will be sanctioned if it uses an uncertified operator on shift, not the operator. In almost all cases, it is the company that will plan and pay for the operator's CEH training. Provision must be made for a company training representative to have full write/change/delete access to the database record of each operator employed by the company. The scenario where only the operator can view and update the training record is not acceptable.

The electronic documentation process needs to be in place and thoroughly tested before any implementaion of a CEH program. It

Draft for Comments

Page 21 of 110

July 28, 2004



JCocker@RPU.ORG

Pat Budler

Energy Delivery


Robert D. Eubank

Power Operations Specialist

Tri-State G&T reubank@tristategt.org

Kathy Davis



SPP OTWG

KDuncan@spp.org


Rod MacNeill



Administrative Guidelines must be reliable and easy to use.

There also needs to be a list of CE providers and courses offered. At this time there is not enough accesable CE training available. Most training is given at a specific time and location that may not coincide with an operators training shift. Options such as on-line training need to be established.

Remember operators are also shift workers. Traveling and switching shifts around to be able to go to available training creates hardships on the operators and their companies.

Well defined, user friendly electronic tracking system is a requirement before this program can go live. The data base needs to have strong

NERC oversite,near real-time data entry by the CEH providers, and access and reporting capabilities by the utilities. A less than perfect system could result in system operators losing their certification through no fault of their own.

I support the concept of making continiuing education a requirement rather than an option that be can be chosen by an individual operator or a individual company.

I have a concern regarding the cost of the NERC database and web interface not become excessive and that all options that will satisfy the retention of data be utilized. The CEH's must avoid unecessary complexities that will hinder or confuse the individual operator or the trainers responsible for System Operator training.

This paper does not mention the company's training representative. It will be the company that will be sanctioned in the event failure to meet the training requirements established. In most every case it is the company who will plan and pay for the Operator's CEH training.

Provision must be made to allow a company training representative to have full write/change/delete access to the database record of all operator's employed by said company. The above reference to where only the certified operator can have access to the database to update trainig records is not acceptable.

Goals - 2.1

Training providers, training department for the operating entity or independent contrators, must be responsible for updating continuing training information, input of CEHs to NERC database. The system operator should only have to update if the provider fails to do so.

TVA believes that NERC should provide a method for a prospective employer to gain access to an applicant's training records.

2. It would be helpful to see a more complete and specific list of what training can count towards continuing education. Certification program criteria should address how the certification program and the emergency training mandate are expected to complement each other.

3. Access to input electronic information updates by more than one person seems prone to mistakes. The providers should input information and System Operators and company administrators should be able to check the information to review and monitor. Before going live with this initiative, a clearly defined resolution process needs to be in place

We supports the concept of making continuing education a requirement rather than simply an option.Would like to see an option for using an exam to maintain certifcation in some cases such as long term illness or circumstances that might not allow a System Operator the ability to get all the hours required. Not clear why an examination

Draft for Comments

Page 22 of 110

July 28, 2004


Keith Comeaux

CLECO


Thomas V Pruitt





Water & Power

Michael.Wenzinger@ladwp.com was not allowed as an option every 3 years with maybe less hours for

CE in between? No recognition for the time spent studying for an exam.

It is not clear how the interface and database would allow the automatice acceptance of CE credits. Right now NERC uses volunteers to match requirements to applications for CE credits. The cost of the

NERC database and web interface could become excessive and other options that will satisfy the data retention needs to be explored.

Suggest this process be offered as an alternative to retaking the certification test and not a mandatory program.

The whitepaper provides very detailed specifications for goals 1 and 3, but details for goal 2 are absent.

Again, System Operators not engineers and managers must be included in the process of identifying important job tasks and critcal skills, knowledges, and abilities required to perform their jobs.

Draft for Comments

Page 23 of 110

July 28, 2004


Section I — Introduction

Recognizing Continuing Education

The NERC system operator certification process recognizes the interest and the responsibility of system operators to continue their educational and professional development throughout their career. Phase I of the System Operator Certification Program provided the framework for the initial exams used to obtain certification in one of four NERC credentials: Transmission Operator,

Balancing and Interchange Operator, Balancing and Interchange/Transmission Operator, and

Reliability Coordinator. Phase II of the system operator certification program provides the framework for the use and tracking of continuing education credit hours for the purpose of maintaining the credential over time that was initially earned by passing an exam.

The purpose of allowing system operators to maintain a credential through the accumulation of continuing education credit hours is to actively promote the use of NERC-approved continuing education learning activities for maintaining proficiency and professional development. The

NERC-approved learning activities are monitored by the Personnel Subcommittee to ensure that they are well developed and delivered consistent with the objectives of the NERC CE Program.

Comments:

Alan Gale




Hannah Peterson

Training Specialist

Midwest ISO, Inc.


A. Glazner

AGlazner@fmtn.org


Interconnection and three in the Western Interconnection, plus an addition dispatch office within the CAISO. These comments are a consolidation of the thoughts and opinions of

The purpose stated in paragraph 2 above is not stated as a goal of the program.

This is an example of the PCGC trying to address other training requirements within the certification program. There is currently no requirement to utilize Continuing Education in a company's training plan.

There have been numerous quality training programs in the past, and will be in the future as we forge ahead. But to "actively promote" its use appears to say that the PCGC does not believe that quality training can occur without it being accredited as Continuing Education.


It will be important to ensure that all training requirements - be it the

CEH program, Recommendation 6, or other industry requirements - act as one overall program in which the requirements support the overall, single program objectives rather than introduce competing requirements. If this is not done, the certification program could become onerous and dilute the effectiveness of the intent of the program as operators are placed in a position of determining which requirement has priority.

Maybe NERC should take a more active role in providing training and/or training materials to aid the individual trainers in setting up continuing education programs

In the paragraph above the use of continuing education hours for professional development is identified as one of the benefits of this program but no where else in the document is the topic of professional development addressed. Is this another category of hours or was it intended to be an implied but not a measurable realized benefit?

Draft for Comments

Page 24 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines the personnel working at these facilities.

Mark Meyer

MMEYER@wapa.gov

Will Behnke


-Concern CEH opportunities won’t be plentiful enough.

-Concern CEH opportunities won’t “mesh up” with shift work schedule.

-Even with the 3 year method, taking into account limited opportunities and shift work, concern that

a serious injury or illness, family injury, illness, surgery, death, etc. will make CEH total

unattainable.

-Proposed CEH based system discourages movement between

Certification levels.

-Proposed CEH based system encourages operators to only know they’re function, eliminating the

robustness of having all or the majority of operators understanding the

“big picture”, thus lowering

the average operator knowledge level.

-Organizations may not bear the additional cost of holding a certificate

“in excess” of what is

necessary.

-Proposed CEH based system may discourage organizations from filling a position with an

individual at a different Certification level.

-The CEH Certificate Levels should represent a “minimum level” for operators new in thei

respective functions. The CEH policy should then state that it is expected operators not at the R.C.

level will continue to increase and maintain CEH’s till they’re at the R.C. level.

- The amount of CEH may seem somewhat excessive as especially at the

RC level of certification.

- There may be a need for on-line NERC approved Training courses that could help allow operators

to fulfill the CEH requirements.

Establishing the number of required continuing education hours for any credential was based on PCGC committee agrement but it would be more prudent to base it on job analysis. What level of achieved CEH's transulates into ensuring the requirement is valid? Using a job task analysis to establish a requirement for each credential is recommended.

The total CEH requirment is comprised of operating policy, standards, job tasks related to a specific credential and emergency focused training.

There is no approved list of training topics with detailed content descriptions that could be helpful to be referenced to assure quality delivered training content addressing the CEH requirement. Appendix A is attached to this whitepaper but how does this list relate to Appendix 8B1 of the NERC Operating Manual.

The purpose of this whitepaper is to solicit comments for the NERC PS and the PCGC but there are conflicting statements and policies between these committees and other NERC initiatives and directives. An example would be the mixed information in the training community concerning the

Draft for Comments

Page 25 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines amoore@txued.com

John Theotonio on behalf of

TRWG



Heather M. Boykin


System Operations Center -

Pine Bluff hboykin@entergy.com

Dale Wadding


Center


5 day emergency training and the cycle by which it reoccurrs. Will the emergency training requirement add to the training burden in maintaining

NERC Certification? Later in this whitepaper it is proposed the CEH requirement include emergency training hours but are the other NERC committees in agreement? There is also a conflict between the PCGC and

NERC Recommendation #6. This whitepaper states a minimum of 30 CEH hours must be simulations (as specified for NERC Recommendation #6) while Recommendation #6 specifies 5 days per year that can total near

120 hours.

Since the origional intent of the NERC exam was to verify a minimum level of knowledge regarding NERC Policy it might be wise to breakdown the types of required training to two specific training types. One type to maintain certification and the other for job related, emergency and professionally related training. The whitepaper addresses the type of training that will be tracked through the NERC CEH program and used to maintain system operator certification credentials but does not make it clear that the NERC Recommendation training can be tracked.

As the PGCG considers options and sets minimum CEH training hours it needs to seriously consider operator shift rotations and its impact on available training hours. Most shift rotations include time for training but this can quickly evaporate when a shift partner suffers an illness or other personal problem and leaves the shift for an extended time. This problem can be addressed by allowing re-examination in some form. Also the

PCGC must consider other current NERC training requirements and possible future training requirments.

The NERC program for individual utilites to become an Approved CE

Provider is a very good program to have the individual utilities design special programs intermally to respond to special operating practicies and policies which will also increase reliability for the entire electric system.

Can the relationship between CEH/Certification and Version 0 Standard

031 be clarified?

TRWG does support continuing education. TRWG believes that system personnel should have multiple methods to maintain certification, such as testing (using an alternate exam) or continuing education., and that this program should direrctly link to trainging standards such as those found in the NERC CE program


I think that the continuing education credit hours is a good idea overal. I think that there should be some consideration and comparison between the original five year program and this new program. I think that the continuing education hours for rel. coor. of 240 would be acceptable, IF

THIS WAS STILL A FIVE YEAR PROGRAM.

This program would not be "allowing" system operators to maintain credentials through CEH accumulation, it would "require" them to do so.

And is the purpose of the program "to actively promote the use of CEH activities" as stated in this section, or is it "to increase system operator knowledge and performance" as stated in the goals. Granted, these are

Draft for Comments

Page 26 of 110

July 28, 2004


Herbert Ezzell

WAPA

EZZELLH@wapa.gov


MISO SOTWG

American Transmission

Company psteinberger@atcllc.com similar objectives but increased use of CEH activities should simply be a result of the program, not a purpose or goal.

The employing organizations' responsibility to the operator must be spelled out. This document places all of the responsibility for meeting the

CEH requirements on the operator.

The purpose of this white paper is to solicit comments for the NERC PS and the PCGC but there are conflicting statements and policies between these committees and other NERC initiatives and directives. An example would be the mixed information in the training community concerning the

5-day emergency training and the cycle by which it reoccurs. Will the emergency training requirement add to the training burden in maintaining

NERC Certification? Later in this white paper it is proposed the CEH requirement include emergency training hours but are the other NERC committees in agreement? There is also a conflict between the PCGC and

NERC Recommendation #6. This white paper states a minimum of 30

CEH hours must be simulations (as specified for NERC Recommendation

#6) while Recommendation #6 specifies 5 days per year that can total near 120 hours.

Since the original intent of the NERC exam was to verify a minimum level of knowledge regarding NERC Policy it might be wise to breakdown the types of required training to two specific training types. One type to maintain certification and the other for job related, emergency and professionally related training. Thse whitepaper addresses the type of training that will be tracked through the NERC CEH program and used to maintain system operator certification credentials but does not make it clear that the NERC Recommendation #6 training can be tracked. Also see the comment for Continuing Education Credit Hours to Maintain a

Valid Credential

The current CEH course approval procedure allows for professionally related credits but there is no mention of this type of CEH credit being applicable to the CEH requirement.

Currently it not possible to study NERC Policies knowing exactly what credential applies to any given policy. This is a problem that would lead a operator having to study all policies in detail to have all bases covered when preparing for an exam.

As the PGCG considers options and sets minimum CEH training hours it needs to seriously consider operator shift rotations and its impact on available training hours. Most shift rotations include time for training but this can quickly evaporate when a shift partner suffers an illness or other personal problem and leaves the shift for an extended time.

Consideration should also be given to the costs associated with this amount of training. It will be necessary for operators to attend qualifiying program outside their companies or companies will have to hire additional staff to do CEH training. Either way it will increase training costs so the

CEH re-certification program needs to carefully stuctured to be fair for the small and large utility companies. This problem can be addressed by allowing re-examination in some form. Also the PCGC must consider other current NERC training requirements and possible future training requirments.

There should be a yearly minimum rather than just total recertification

Draft for Comments

Page 27 of 110

July 28, 2004


John Taylor

SPP

JTaylor@spp.org

Lisa Carter


LCarter@spp.org

Jane Cocker

System Operations


JCocker@RPU.ORG amount to help promote on going and consistent training programs to avoid training jam sessions.

Add to the last paragraph:

The Personnel Subcommittee defines a continuing education hour in its

NERC CE Program Administrative Manual.

Each operating entity in the indusrty must ultimatley regulate the content of contiuning education provided to it's respective system operators to make sure that it is relevant and supports performance. This paper recognises that obligation by proposing that the majority of the continuing education hours be spent in job-related training.

The ability to participate in a continuing education progroam provides the operator with training on a more consistant basis. I believe this will be more beneficial to operators overall rather than having to re-familiarize themselves (over a short time) with all the necessary information required to pass the NERC exam. It's like anything else, the more you are exposed to something the easier it is to retain and recall. This too would instill the operator with greater confidence in their abilities to make the necessary and important decisions they are faced with on a daily basis.

The proposed number of CEH's to maintain credentials needs to be reviewed and how those numbers were arrived at need to be explained.

Again they seem excessive compared to other professions requiring

CEH's.

NERC needs to establish specific requirements and detailed content descriptions. How does Appendix A of this whitepaper relate to Appendix

8B1 of the NERC Operating Manual? What about the emergency training requirements recommended after the August 14th blackout?

At this point there are conflicting statements between these policies.

Conflicts need to be resolved and clear instructions for meeting the requirements need to be established.

Strongly suggest that taking the exam be retained as a recertification method.

Pat Budler

Energy Delivery



SPP OTWG

KDuncan@spp.org


Rod MacNeill



Gary L. Condict

Aquila Inc.


4. See comments under NERC System Operator Certification Phase II

Preamble

The NERC System Operator Certification and CE program wants to recognize professional development but the ability to allow counting

Professionally related education has been removed from phase II of CE.

Suggest that Professional Development hours form a part of phase II and be recognized as CE credits as it was in phase I. Training in areas that are not directly related to specific credentials but related to other areas of system operations should be counted for CE hours in some way.

The maintaining of credentials should be through continuing education hours or a combination of continuing education hours and examination

(less CE hours required).

There are a lot of vendors that claim their hours count for CE. Don't leave this up to the interpretation of the vendor or the student.

I recommend NERC should publish a list of the vendors and course titles that they will count as CE.

Draft for Comments

Page 28 of 110

July 28, 2004


Keith Comeaux

CLECO


Sanjay Dutta

CAISO


SDutta@caiso.com



City of Los Angeles, Department of Water & Power

Michael.Wenzinger@ladwp.com

Opposed to this concept as the only means to maintain an operators credentials.

A person who does not work in the control room as an operator but happens to be NERC certified and wishes to keep his or her certification

(i.e., Manager (not shift manager), Director, VP, etc.) should be allowed to re-certify by retesting, because it is difficult for people in such positions to complete 240 hrs or training in three years.

How many qualified System Operators are on the Personnel

Subcommittee? How many of those System Operators have stood shift during a major system disturbance?

You wouldn't have a group of machinists setting the training standards for doctors. Would you? Conversely, you wouldn't have a group of doctors setting training standards for machinists. The point is that only System

Operators can be considered as experts for the training of System

Operators, or for the certification that a System Operator has attained some level of knowledge and/or expertise in system operations.

Both the WECC and NERC exams I took had very little to do with verifying that I knew how to properly and reliably operate a power system. Both exams did demonstrate that I could memorize and recite information in policies.

Consider the ACE equation. The ten before beta is not a ten, it is a one ( ten over ten ) used to convert the frequency bias stated per tenth of a hertz, to a frequency bias stated per hertz. Since most System Operators have mathematics educations well beyond algebra, this ten becomes a source of confusion. Additionally, since the meter error component was added to the ACE equation it should have been added to the ACE equation for Flat Tie-line Control ( leaving it out merely allows the error to exist in this mode ).

These are issues that System Operators would bring to the table.

Draft for Comments

Page 29 of 110

July 28, 2004


Governance and Administration of the System Operator Certification CE

Program

Governance:

The NERC Personnel Certification Governance Committee (PCGC) is the governing body that establishes the policies, sets fees, and monitors the performance of the system operator certification program.

Administration:

NERC administers the certification program. As program administrator, NERC maintains databases, records, and applications, collects fees, and provides reports on the certification related activities. NERC also maintains master files containing certification records, program audits and CEH awarded.

Comments:

Alan Gale



Hannah Peterson

Training Specialist

Midwest ISO, Inc.


Gratien Charest






Will Behnke


Heather M. Boykin




Dale Wadding


Center

Dairyland Power Cooperative

I believe some mention of the heiarchy of the NERC Personnel

Subcommitte reporting to the NERC Operating Committee should be mentioned here. Who does the PCGC report to? To the OC? Directly to the Board of Trustees?

Need to put into place a mechanism to share data back to providers to ensure accurate reporting. Many training attendees come unprepared to

CEH eligible sessions and providers have to spend time "tracking down" the certificate information in order to grant CEHs and report hours to

NERC. Implementing a data sharing mechanism will expedite the reporting and administrative procedure.

It is requested that accommodations be made to allow those who are recently certified be provided with a means to acquire CEHs as they wait for the receipt of their certificate number. It currently takes 6-8 weeks to receive a certificate after passing the exam. Under the proposed CEH program an operator would be unable to receive CEH training during this

6-8 week period because they would not have a valid NERC certificate number. The operator will need to be able to immedately start accumlating CEHs once their exam is passed or they have successfully renewed their certificate.

NERC should present and manage Competency Standards instead of the ways to achieve competency; all the utilities or company would have to confirm the achievement. A demonstration of the training process could be acceptable…

1.) Will NERC also maintain a list of all possible CE classes that are avalible?

See the comment for Goals concerning a working tracking system and data base.

I think that our instructors should be able to teach some of these courses.

They know more about our floor applications and our operations here at the SOC than any outsider could possibly know.

NERC may have databases, but they are not developed to the point needed for use in a CEH recertification program. Any such database needs to be available online with information input by CEH providers and information access available to system operators and their employers. As

Draft for Comments

Page 30 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines ddw@dairynet.com


MISO SOTWG


Company psteinberger@atcllc.com

Pat Budler

Energy Delivery



Rod MacNeill


Rod.MacNeill@bctc.com mentioned above, this process needs to be tested for a significant amount of time before being used in a recertification program.

See the comment for Goals concerning a working tracking system and data base.

Database must be functional and reliable for this program to succeed.

Keith Comeaux

CLECO


Thomas V Pruitt






Companies need to have access to records for administration of their

System Operator records. The company is usually paying for the

Certification and CE training, but has not had access to records. The company must have access to records. It has been our experience that individual System Operators have no interest in maintaining and accessing their records. Maintenance should be done by company admin staff and / or training departments. Suggest allowing System Operator access to their employees records to keep them up to date. This would allow designated person(s) to input data and to ensure the Certification records match company records. Our company will have to manage 28 - 30 certified employees whose certificates will expire at different times and who will have access to various amounts of training at very different times. We will want to ensure System Operator Certifications do not lapse and that records at NERC will match what we have (no differences).

You may consider readjusting expiry dates so that certified employees of a System Operator all expire at the same time. This makes scheduling training to ensure we meet the requirements much easier.

Favor this structure with the PCGC in the governamce role. Agree that

NERC should administer the certification program as opposed to another entity..

NERC currently has training requirements in effect (Item 6 from the

Blackout Report and the P8T3 Compliance Template) that are not or do not appear to be coordinated with the requirements specified in this document. Because the training in these other requirements are directly related to the requirements of this document, the requirements should be aligned and coordinated, and, where appropriate, consolidated. In addition, since NERC is charged with administration and enforcement of the requirements, it is recommended that the requirements portion of this whitepaper be subjected to an open development process with balloting representative of the entire industry.

Administration of the certification program will be significantly more complex than it has been in the past, especially with the subcategorical requirements. Implementing the program on a trial basis for the first two or three years (with continued requirement for recertification by examination - consistent with the transition plan) may be a more prudent course to insure that the mechanics of the program are workable.

How many System Operators are on the NERC Personnel Certification

Governance Committee?

Draft for Comments

Page 31 of 110

July 28, 2004


Draft for Comments

Page 32 of 110

July 28, 2004


Funding the System Operator Certification CE Program

The PCGC shall ensure the program is financially sound. The program shall be reviewed periodically to ensure NERC administrative fees are adequately recovered through program fees.

Phase I

— the exam program. The cost of governing, developing, and administering the exams is paid by the fees collected to take an exam.

Phase II

— maintaining a credential through accumulating continuing education credit hours. The cost of governing, developing, and administering Phase II must be paid by the fees collected to participate in the certification program. The cost to provide Phase II has yet to be determined. The fees will be set according to the cost.

Comments:

Alan Gale



Mark Klohonatz


Operations


This section states, “the program shall be reviewed periodically”. For the accurate development of annual training budgets, an actual schedule for fee review is necessary.

Why are only the fees subject to "periodic review"? Shouldn't the entire program be reviewed? I do not recall seeing any words that would indicate a review is scheduled or planned. Of particular interest would be to review the quantity of CEH's required after a short period of operations under this program. Especially after the full impact is realized.

The NERC website states that 5,500 people have been certified since

1998. The industry turnover numbers will fluctuate, resulting in the fees for exams (Phase I) being inconsistant from one review period to another.

Will funding be separate for Phase I and Phase II? Will Phase II end up supporting Phase I as the quantity of exams drops?

We have serious concerns for proposing a program such as this without addressing some of the logistical issues as outlined in the comments offered in the Phase II Preamble section, and, at the same time, suggest that the fees would be determined after the the program is implemented as is stated here for Phase II. There are too many details left to be answered for at this point to be comforatble with allowing language as appears above to stand without question.

This approach seems reasonable. Karl Tammar

NYISO

KTAMMAR@nyiso.com

Anita Lee, P. Eng.


Procedures

Alberta Electrical System

Operator anita.lee@aeso.ca

Linda Campbell

FRCC

LCampbell@frcc.com


Interconnection and three in

Are there more Phases to this program… If so what are they?.

This section states, “the program shall be reviewed periodically”. For the accurate development of annual training budgets, an actual schedule for fee review is necessary. In addition, the purpose of Phase I and Phase II is unclear. As written, it appears that when Phase I ends, Phase 2 begins.

Funding of the Certification Program can and should be as simple as possible. At the present time an individual submits $350 to apply for and take an exam. The continuing funding requirements should be the same.

Draft for Comments

Page 33 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines the Western Interconnection, plus an addition dispatch office within the CAISO. These comments are a consolidation of the thoughts and opinions of the personnel working at these facilities.

Mark Meyer

MMEYER@wapa.gov




An individual submits an application to exchange the required number of accumulated CEHs and a check for $350. Realizing that there may be fixed costs associated with maintaining an exam for the initial certification of an individual, all others will not need to sit for an exam so some costs can be avoided. Again, keep it simple.

Jule W. Tate


Operations Training


Heather M. Boykin





WECC OTS


1.) When will Phase II costs be known? NERC needs to finalize costing and include the costing method to any approval process before Phase II moves forward.

2.) Needs more explanation. Who pays for the fees to participate in the program? Operators?

This section states, “the program shall be reviewed periodically”. For the accurate development of annual training budgets, an actual schedule for fee review is necessary. In addition, the purpose of Phase I and Phase II it is unclear. As written, it appears that when Phase I ends, Phase 2 begins.

I will know more about whether I am for or against this program when I see the associated "costs". I would also like to know what is to be done with the people that are NERC certified here at the SOC that are NOT reliability coordinators? Are we also going to have to take these 80 hours/ year??

There is concern the cost of the NERC database and web interface could become excessive and all options that will satisfy the data retention needs should be explored. The process of using CEH to maintain a credential must avoid unnecessary complexities that may add little to the quality of the program and increase the complexities of recording data and adversely affect the cost of the database.

OTS feels the final proposal should include language indicating the principle of cost containment will receive appropriate priority in all phases of this program.

Fee structure must be easily understood and consistent. Pat Budler

Energy Delivery


Robert D. Eubank



Kathy Davis



Rod MacNeill



Again I have a concern that the cost of the NERC database and web interface could become excessive and not have all of the options needed to properly record all the training records. We need to make sure the final proposal addresses this concern and acts appropriately.

Phase II:

NERC CE Admin Program Manual has established the fees for processing continuing education learning acitivities, $8.00 per course hour. This conflicts with the statement "…cost to provide the Phase II is yet to be detemined."

We agree that both Phase I and Phase II should be self-funded but we have a concern the cost of the NERC database and web interface could become excessive. Right now the cost to our company is about $3000.00 per year (per System Operator) for Certification and CE for 28 - 30 people. The cost to NERC for each person to use CE to maintain

Draft for Comments

Page 34 of 110

July 28, 2004


Keith Comeaux

CLECO


Sanjay Dutta

CAISO


SDutta@caiso.com

Certification seems like it will be much more that $100.00 per year, plus the cost of the additional training.

We are concerned that CE hours earned between the date of Phase II approval and the implementation date will not count. CE hours earned between approval and implementation must count.

The program should be cost neutral to all parties. As stated above the cost of the test covers the current cost. Divide the cost of the test divided by the three (three year cycle) and add that to the cost of the CE programs annual fee to be paid by those choosing that option.

What will be the start-up costs for this program and how would these costs be allocated?

Draft for Comments

Page 35 of 110

July 28, 2004


Continuing Education Credit Hours to Maintain a Valid Credential

The current NERC system operator certification examinations focus on verification of the basic competence of system operators. The certification exams address basic principles of interconnected operations and system operator tasks as they relate to NERC operating policies and power system operations. Those who pass an exam are granted a five-year credential associated with that exam.

As proposed, upon passing the exam, the successful candidate will receive a three-year credential associated with that exam: Transmission Operator, Balancing and Interchange Operator, Balancing and Interchange/Transmission Operator, and Reliability Coordinator. NERC-certified system operators will then have to accumulate a specific amount of credit hours in NERC-approved CE learning activities in specific subjects within a specific time period in order to maintain their NERC credential. This process is described below for each of the four credentials:

Comments:

Karl Tammar

NYISO

KTAMMAR@nyiso.com


Hannah Peterson

Training Specialist

Midwest ISO, Inc.


See our earlier comments on differing opinions on elimination of retesting.

It will be more difficult to handle the administration of a 3-year program, particularly for those organizations with many system operators. It's unclear why the credential needs to be shortened.

Several of the NERC V0 standards require operator training in various topics. The hours and subjects mandated in the standards should apply to the required hours in the CE program.

The 5 - year credential perios should be maintained with the proposed

CEH's hours over 5 years. As proposed companies will always train to the minimum requirement to perform a position not to try to have their operators attain a higher certification.

CEH training certainly should require NERC Policy/Standard training to maintain certification credentials. This whitepaper requires 30 CEH hours over a 3 year period. This works out to 10 hours per year. Currently many operators attend 32 hours of NERC Policy training every 5 years in preparation for the exam. In preparation for the exam, operators may study old versions of NERC Policy rather than current Policies.

Consideration should be given to increase this requirement to assure adequate training on NERC Policy and that system operators are kept informed and proficient on policies/standards.

The NERC PSC and the PCGC should focus on policy/manual content as their primary concern for maintaining a valid NERC Certification.

Additional technical training might best be left to the organizations who employ the operator and are currently held accountable through compliance requirements

To avoid the potential of "just in time" CEH training, it is requested that consideration be given to including a minimum number of CEHs per year, to total the desired number of CEHs in the multi-year period (example - if

240 hours are required over a three year period, "level" the number of hours by implementing a minimum of 80 hours per year). This will ensure continual training is occurring.

Draft for Comments

Page 36 of 110

July 28, 2004


A. Glazner

AGlazner@fmtn.org

Matthew Sadinsky

System Operations Success,

Intl.

Matt@sosintl.com

Burrows Gerry

KCPL

Gerry.Burrows@kcpl.com

Need to define "per year." Is it Jan-Dec or July-June? This year should also be the same as the 5 day emergency training requirement.

Are there enough providers and CEH available for credit to cover the number of hours needed by all the operators in the industry (based on the required number of hours outlined in this whitepaper)? no comments except the CE hour should be equal among the specific certificates.

Each of the four credentials below outline a 3 year period preceding the date of certificate expiration. Please consider permitting students to count all training during their five year certificate towards meeting the minimum required amount of hours for the transition period.

An apparently unintentional consequence of the approach as it is strictly interpreted and contemplated here would be to create a disincentive to take relevant training in the first 1-2 years of a recently received new 5 year NERC certification.

Specifically, it is our suggestion that for the first five years following the enactment of this program, all CE hours earned could be counted. This will help student and utility companies in the transition.

Switching from a five year program to a three year program introduces many problems as indicated by this proposal. It is suggested that each system operator be allowed to maintain his/her certification until its current expiration date with the requirement of the proposed number of

CEH hours per year. At that time the credential period can be switched to three years as proposed. This would make for a smoother transition and would be less impact to companies on manpower to meet these requirements.

AESO would like to have the credential period maintained at five years, or at mimimum four years, in order that the system operator schedule can be managed.

Anita Lee, P. Eng.


Procedures



Linda Campbell

FRCC

LCampbell@frcc.com

The first sentence of the second paragraph above sounds like everyone will start "fresh" with a new exam. We thought there was to be a transition plan for those individuals who already have the credential to renewing it using CEH's.

Consideration should be given to reduce the administrative burden in all the proposed process

Gratien Charest






Will Behnke


1.) Will a current certificate holder that has recently completed a

Reliability Coordinator test be grandfathered or be required to declare any one of the newer qualifications or, will this occur only when it is time to renew the current certificate?

CEH training certainly should require NERC Policy/Standard training to maintain certification credentials. This whitepaper requires 30 CEH hours over a 3 year period. This works out to 10 hours per year. Currently many operators attend 32 hours of NERC Policy training every 5 years in preparation for the exam. This works out to be 6.4 hours per year. In preparation for the exam operators study old versions of NERC Policy rather than current Policies. Consideration should be given to increase this requirement to assure adequate training on NERC Policy.. Also, as

Draft for Comments

Page 37 of 110

July 28, 2004


Herbert Ezzell

WAPA

EZZELLH@wapa.gov policy and standards change the system operators would be kept informed and proficient on those policies/standards.

The NERC PSC and the PCGC should focused on policy/manual content as their primary concern for maintaining a valid NERC Certification.

Additional technical training might best be left to the organizations who employ the operator and are currently held accountable through compliance requirements.

I feel that the option to test out (with a predetermined minimum amount of appropriate CE hours) should remain available, and the required hours should be lowered slightly.

Debra L. Yinger




TRWG



Cochran, Bob

Xcel Energy


Heather M. Boykin




Dale Wadding


Center


TRWG believes that continuing education should include an annual minimum requirement. Continuing education as stated in this paper can allow someone to obtain all CE hours in a single year, so there could be periods where system personnel will receive no training.

The 5 - year credential perios should be maintained with the proposed

CEH's hours over 5 years. As proposed companies will always train to the minimum requirement to perform a position not to try to have their operators attain a higher certification. what's wrong with a 5 year credential? what's driving the desire to go to three years?

I think that everyone HOLDING a certification should have three years from the start should be able to START the program with everyone else.

Establishing requirements for different numbers of CEH required for various credentials could cause these results:

1. "Dumbing down" of the system operator workforce. Since it would be easier/cheaper to maintain the lowest credential required to do their current job, operators would have no incentive to learn the knowledge necessary to perform tasks of other credentials. This could create a disconnect between operators during the execution of normal job tasks, since they wouldn't have the understanding of what knowledge is required to do each other's job.

2. Operators who assume new positions could be less prepared since they have had no incentive (in fact, a disincentive) to gain the knowledge required in their new credential.

3. Since employers typically provide the training required for their system operators to maintain certification, there would be an incentive for these companies to only provide the minimum training required. If they provided more, the companies would run the risk of their operators obtaining a higher credential which would make them more attractive in the job market, thus exposing their employer to higher system operator attrition.

There is one segment of the electrical industry that has been left out of the certification process. This segment is the Marketers who control generation facilities. The effect of their generation on system reliability and stability has been demonstrated repeatedly during system disturbances and transmission loading relief events. The impact of

Marketers buying and selling of generation and scheduling of energy transactions demonstrates the need for marketers to meet a minimum

Draft for Comments

Page 38 of 110

July 28, 2004


Page 39 of 110



MISO SOTWG



John Taylor

SPP

JTaylor@spp.org elm@dairynet.com

Jane Cocker

System Operations


JCocker@RPU.ORG

Snodgrass,Theodore M tmsnodgrass@bpa.gov

Kathy Davis

TVA Electric System Operations adavis@tva.go level of training. I have spent an inordinant amount of time on the phone training and retraining Marketers on the requirements for energy tagging and scheduling.

CEH training certainly should require NERC Policy/Standard training to maintain certification credentials. This whitepaper requires 30 CEH hours over a 3 year period. This works out to 10 hours per year. Currently many operators attend 32 hours of NERC Policy training every 5 years in preparation for the exam. This works out to be 6.4 hours per year. In preparation for the exam operators study old versions of NERC Policy rather than current Policies. Consideration should be given to increase this requirement to assure adequate training on NERC Policy.. Also, as policy and standards change the system operators would be kept informed and proficient on those policies/standards.

The NERC PSC and the PCGC should focused on policy/manual content as their primary concern for maintaining a valid NERC Certification.

Additional technical training might best be left to the organizations who employ the operator and are currently held accountable through compliance requirements.

This is the only way for recertification to have any meaning. Re-testing should mean starting from ground zero, which is the way you have it described here. I have seen several coments wanting retesting to be an option for recertifying. Don't allow retesting to recertify.

For all 4 credentials , why are the # of CEH's required somuch greater

(more than double most) than other professions requirements? ie Police,

LPN, RN, Physician, Engineer.

Various areas of subject training may be best addressed by companies that employ the operators. These are already held accountable through compliance requirements.

NERC CEH should focus on policy/manual content.

The five year credential term should be retained. This period provides the flexibility needed to keep up with the realities of needing an experienced and consequently aging and therefore retiring and 'needs to be replaced' staff. It may not be feasible to meet whatever the final requirements are in the three year time period. I need as much time as I can get to insinuate enough training into the mele that is a control center manager's job.

We agree that the purpose of the operator certification examination is to verify competence of system operators in basic principles of interconnected system operations and system operator tasks as they relate to NERC operting policies and power system operations.

This concept should also be applied to maintaining NERC certification.

The system operator should demonstrate competance by completion of a continuing training program that specifically addresses basic principles of interconnected system operations and system operator tasks as they relate to NERC operting policies and power system operations.

Completion of the minimum required hours by individual system operators in this area should be all that is required to maintain certification. The operating entity (e.g., utlity, RTO, ISO, PSE) is responsible for continuing training on shift specific tasks/responsibilities. This should be a requirement of the operating entity specified in NERC policies/standards, not an individual system operator responsibility. It should be separate from operator certification requirements.

Draft for Comments July 28, 2004



SPP OTWG

KDuncan@spp.org


Rod MacNeill



Gary L. Condict

Aquila Inc.


Keith Comeaux

5. The SPP OTWG has concerns regarding overall number of hours and the different hour requirements for the various certification types. The number of hours required is excessive for a new program and should be reduced to half of the current proposed numbers. For example, a transmission operator requirement would be more practical at around 60 hours over the 3 years to start the program (not the 120 hours presently proposed in the draft). This would be more practical and feasible for the initiation of the program. The hours could be adjusted in the future as the extension program seasons and operating entities have had time to increase their operator staff to handle the training. Maybe a provision clause or clauses could be specified in the document to transition the CE hour requirement to a higher number of hours after a logical period of program operation.

6. If there is better justification for varying the hours for each certification type, that would be acceptable, but the overall hours should still be reduced. It's not clear why there is a difference in hours required.

7. Please provide a reason for shifting from 5 to 3 years.

8. The proposal, as it is now, would provide less incentive to certify at the highest level due to cost and time. Also, specialization discourages "big picture" understanding and may alienate positions that need to rely on each other in critical situations. We encourage NERC to support more robust understanding.

9. The basic concept and goal of this plan needs to be better described.

Is certification tield to NERC Operating Policies and Standards only or is it more robust? If so it needs to be better documented. One consideration would be to enforce continuing training through compliance templates for the entities required to have certified operators as this works in other areas. Do not hold an operator responsible (or revoke certificate) if a company fails to provide training, hold the company responsible. The company should be held responsible for real time system operator CE requirements. Organizations should not be held responsible through NERC for certification of other support personnel or others whose job functions do not require certification.

10. We believe continuing education is important, but are not sure how the amount in this proposal is justified. NERC should consider conducting a study to understand how many hours it takes to keep Operators up to date as we all realize the need to train operators on appropriate changes.

We support maintaining Certification with CE.

The maintaining of credentials should be through continuing eductaion hours or a combination of continuing education hours and examination

(less CE hours required).

What about exceptions to the rule in regards to sickness, call to active duty, etc. There are any number of situations that an operator might be short of the required number of hours that are out of their control.

Sometimes these situations may not only affect the operator in question, but the ones that have to fill their shifts. A longer certification period should ease the burden and not require an exception.

I recommend extending the certification period to five years.

Offer options for the operator such as this method or retake the test on a

Draft for Comments

Page 40 of 110

July 28, 2004


CLECO


Thomas V Pruitt





Michael.Wenzinger@ladwp.com three year cycle. I agree that the test only verifies the basic competence for operators and until recently there was no assurance that training was being conducted. Now the template will provide the compliance auditors a means to verify that it is being provided.

The recent Readiness Audits performed by NERC have specifically queried entities regarding certification of first level management and support staff, and audit reports have commended those entities which have certified all or part of the individuals in those groups. Given that it is clearly desireable by NERC that these groups have a demonstrated, detailed understanding of NERC operating policies and standards and that the credentials outlined below are predominantly focused on specific operator tasks, should there be an additional credential created (with more emphasis on policies and standards and less on specific tasks) for which these ancillary groups would certify?

I disagree. The current examination process has little to do with the real core competancies required to be a good System Operator. The current examination process merely tests a System Operators' ability to memorize and recite existing NERC policy.

Draft for Comments

Page 41 of 110

July 28, 2004


Transmission Operator Certification

After completing and passing an initial NERC Transmission Operator certification exam, the candidate is awarded a NERC credential as a Transmission Operator. A certificate will be issued that is valid for three years. To maintain a valid Transmission Operator credential, system operators must earn 120 CEH within the 3-year period preceding the expiration date of their certificate.

The 120 CEH must include:



30 CEH on NERC operating policies and standards.



90 CEH related directly to transmission operator tasks. (See Appendix A for recognized training topics.)



As a minimum, 30 of these 90 CEH must utilize simulations (i.e., table-top exercises, dispatcher/operator training simulators, emergency drills, or practice emergency procedures, restoration, blackstart or other reliability based scenarios).

Comments:

Alan Gale



Mark Klohonatz


Operations

Allegheny Power

I think that 120HRS of CEH is a completely un-reasonable quantity. Many that I have talked to believe that just because we have to do the 40 hours a year of Emergency Training, which was instituted with NO industry input, that 120 hours every 3 years isn't any more.

The difference between "company" training and Certified Credit Hours training is immense! While it is possible to become a Certified Training

Facility and perform your own training, many entities are too small to take on this challenge without busting the bank. Not all training has to be

Continuing Education Training to be of good quality and of benefit to the operator behind the desk. The ability to talk about a recent mishap or near-miss without having to create learning objectives, a lesson plan, and measure that learning should count towards training and DOES today. If the requirement of 120 Hours becomes the standard, too many companies will be unable to afford to pay for training, or even to pay for the overtime to perform training. These operators are still quite capable operators and are meeting all compliance issues. While it would be easier to budget training as a fixed amount, it would negate any flexibility of the entity to have a responsive training program.

Each individual entity must have the flexibility to decide how the hours should be distributed per Appendix A and NERC policy. By the breakdown stated above, the PCGC is admitting the tie between the certification program and the 40 hours of Emergency Training. The breakdown above will FORCE every entity to obtain or contract simulator time.

Certified Plant Engineers only require 8 hours per year, and only 4 of them have to be technical in nature. Medical Doctors only require 10 per year. I would suggest a quantity of 10 hours per year, resulting in 30 hours every 3 years. This would be consistent with these two widely accepted continuing education users.

The individual entity must have the flexibility to decide how the hours should be distributed per Appendix A and NERC policy.

How will the required annual 40 hours of emergency operations training be recognized for CEH?

Will the annual average of 40 hours of CEH training be in addition to the

40 hours of emergency operations training?

Draft for Comments

Page 42 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines mklohon@alleghenypower.com

Karl Tammar

NYISO

KTAMMAR@nyiso.com

There were differing opinions with the IRC on the mandatory hours for each occupation. Some felt the hours should be the same for all occupations. Others agreed with a tiered approach.

In general, the requirements should not be overly prescriptive as it will become difficult to judge which category a particular training event will fit and it will be more dfficult for operator to meet the requirements. We suggest leaving some flexibility, (such as 150 CEH total, 30 related to policy and standards, 60 job-related, the remainder can be from any area in an approved industry list. Of the 150 hours, 30 hours should be simulation or drill based).

One option would have a set of core courses common to all functions

(RC,TO, BA/IA) so if an operator who was a RC has to re-qualify due to an absence which caused a deficit in the required # of CEH then he may quickly be able to qualify for say an TO while regaining the credits to become a RC again

A 5 - year period should be adopted for all exams. Thomas W Farr twfarr@cmsenergy.com

Hannah Peterson

Training Specialist

Midwest ISO, Inc.


Linda Campbell

FRCC

LCampbell@frcc.com

Gordon Pietsch




Interconnection and three in the Western Interconnection, plus an addition dispatch office within the CAISO. These comments are a consolidation of the thoughts and opinions of the personnel working at these facilities.

For all Certification types, there is concern that the above specified training does not take into account other training that must occur. This training can include OSHA Safety training, professional-related training, etc

This proposal calls for 30 hours of simulation training over a three year period. This is in conflict with Recommendation 6, which calls for five days of realistic simulations each year. These requirements need to complement each other.

We agree that 120HRS of CEH is a reasonable quantity, but believe that the individual entity must have the flexibility to decide how the hours should be distributed per Appendix A and NERC policy. The following is a suggestion for sentence structure in the last bullet: "..or practice emergency procedures) on restoration, blackstart or other reliability based scenarios.

We feel all four specialties should have equal requirements of 180 hours of CEH's over a period of 3 years. 30 of these CEH's would be on NERC policies. We believe there should be an alternative method of recertification that would allow all four of the specialties to accumulate

50% of the required CEH's plus retest every three years. With these two alternatives avaliable it would allow for choice, flexability and unforseen situations that may occur at a company or for an individual system operator that would not allow them the time to accumulate the 180 hours. 30 of these hours would still be required on NERC policies.


1. See comments under the "Preamble" section. Note that our recommendation for the number of CEHs is for a 5 year period, not a 3 year period. (same for BIOCE, BITOC, and RAOCE.

Draft for Comments

Page 43 of 110

July 28, 2004


Mark Meyer

MMEYER@wapa.gov




Jule W. Tate


Operations Training


1.) The number of education hours is excessive especially since each CEH must be certified by the NERC process. If Simulation Hours or other Drill based hours fell outside the NERC certified training the number would be more in line. Getting new Drills qualified in the accounting process will prohibit useful renewal of training as system conditions change with addition of new resources or loads. The process will or could limit updates that should be made for the operators.

We agree that 120HRS of CEH is a reasonable quantity, but believe that the individual entity must have the flexibility to decide how the hours should be distributed per Appendix and NERC policy

Debra L. Yinger



What is the rational for the CEHs proposed and the differences in required CEH hours for the 3 levels of certifications?

Is there a conflict with the Version 0 - Standard 031 - R2? Ten hours a year of the 5 days (40 hrs) required in the standard will be CEH format.

There should be a minimum yearly requirement instead of just a three year requirement for all topic groups.

I feel that the hour requirements are slightly high. As it is very difficult to allot time to train a person working shifts under normal conditions, this puts a limitation on the Operator especially if the work location is under staffed. The Operator could then be penalized due to limitations beyond his/her control. If there is not an in-house NERC approved trainer, the

Operator may have to travel frequently to obtain the necessay CEh's. The option for testing out should also be incorpated as an option with a lower amount of CE hours.

TRWG believes that the number of CE hours should be equal across all credentials. TRWG believes that training shold be based on performance gap analysis.

A 5 - year period should be adopted.


TRWG







Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov

If NERC truly wishes to get the maximum benefit from continuing education, it should set some minimum amount of CEH which must be completed in the first two years of the 3-year period. This would help ensure a continuous process of education instead of a once every three year "cram" to meet the education requirement. too many hours for certification. If NERC wants entities to provide training for operators, enforce that against entities's. Don't take it out on operator seeking to keep his job.

All credential requirements should include some professionally related

CEH's. These increase the knowledge level of the operators and improve their performance. These professionally related CEH's could be detailed as a separate number or included in the non-NERC policy requirement.

The 3 year requirement should be levelized to assure that learning is distributed over the entire period. For instance, if the requirement is 120

CEH in a 3 year period, a minimum of 30 CEH should be earned in each calendar year.

The amount of CEH required appears excessive and arbitrary. What facts support this level of commitment? Currently in my organization the minimum requirements are 80 hours per three year period of relevant structured classroom training and 32 hours per year of relevant self study.

This level of training has been challenging to meet because of personnel

Draft for Comments

Page 44 of 110

July 28, 2004


John Taylor

SPP

JTaylor@spp.org

Mark R. Henry, P.E.

Manager, ERCOT Compliance mhenry@ercot.com

Pat Budler

Energy Delivery


Robert D. Eubank



Kathy Davis



SPP OTWG

KDuncan@spp.org


Rod MacNeill shortages, vacations and operating commitments.

I believe the logic in requiring a different number of hours for each certification class was probably based on the breadth of knowledge each classification msut have compared to the others. I don't belive that is a valid basis for determining the number of CEHs required. Each certification area should be equally competent in their respective job, therefor each certificate should require the same number of CEHs.

The CEHs related directly to transmission operator tasks, other than it being one of the topics listed in Appendix A, how do you determine if it is related directly to the area of credentialing? Jo Task Analysis? Supervisor decision? Employee decision?

The 30 CEHs of simulations appears to be emergency operations training.

Is that correct? If so, probably should call it such, and clarify whether or not that is in addition to the 5 days required in compliance template

P8T3.

The CEH requirements should be per year, not for three years. Making for three years means that a person can go to a one-time three week class and be done. Even requiring 30 CEHs per year would still mean that a person could go to traiing one week per year, which doesn't really meet the intentr of continuing education. To meet the intent the training should be done on an ongoing basis when needed for the job. Our industry changes too fast to train once every three years, even if it is for three weeks at the time. Some will say that ongoing is not practical due to illnesses and vacations, but a standard should be set based on what should be, with allowance for exceptions, not the other way around.

Suggest 100 hours, 20 on NERC or Regional policies and the rest on tasks.

Same simulation requirement for all levels of certification - is this equitable?

I think the amount of hours are appropriate considering the level in which we are training to bring the industry training standards to. However, these hours may be difficult to obtain without having the dollars funded to allow this amout of training. Companies may be reluctant to part with the funding necessary to obtain these CEH's.

120 CEH must include:

* 60 CEH on basic principles of interconnected system operations and system operator tasks as

they relate to NERC operating policies and power system operations. {Completion will

satisify requirement to maintain certification}.

* 60 CEH related directly to transmission operator tasks {not tied to maintaining certification,

employer responsbility to ensure completion}.

> As a minimum, 30 of these 60 CEH must utilize simulations.

11. These hours are excessive for a new program. What is the basis for these hours?

See "Additional Comments".

In this case 120 CEH = 120/7.5 = 16 man days * 28 employees = 448

Draft for Comments

Page 45 of 110

July 28, 2004




Keith Comeaux

CLECO


Marc M. Butts

Southern Company Services mmbutts@southernco.com

Sanjay Dutta

CAISO


SDutta@caiso.com man days of CE over a three year period. In order to reduce the CEH required I would recommend 60 CEH over three years plus the successful completion of the Qualifying Exam.

If an operator chooses this path the number of hours and the subject content in Appendix A for this certification look reasonable .

General comment for all four credentials: Why are the hours not proposed per year instead of "within the 3-year period" to prevent the cram course style of training?

Some language needs to be added to the white paper that addresses hardships. For example, for smaller companies, illness of one or two operators can affect the ability of all operators to complete training.

Language needs to be added in the white paper that says that NERC will address hardships on a case-by-case basis.

120 hours of training over the 3 year period ought to be sufficient to obtain any level of certification. Differences in the amount of training required to hold various certifications or requirements over 120 hours creates a barrier that discourages operators from wanting to get a bigger picture view and learning more than their current job.

Professionally related hrs should be incorporated into the Continuing

Education program, otherwise PCGC should suggest what should an operator do for professional development and personal growth.

Draft for Comments

Page 46 of 110

July 28, 2004


Balancing & Interchange Operator Certification

After completing and passing an initial NERC Balancing and Interchange Operator certification exam, the candidate is awarded a NERC credential as a Balancing and Interchange Operator. A certificate will be issued that is valid for three years. To maintain a valid Balancing and

Interchange Operator credential, system operators must earn 120 CEH within the 3-year period preceding the expiration date of their certificate.







90 CEH related directly to balancing and interchange operator tasks. (See Appendix A for recognized training topics.)




Comments:

Linda Campbell

FRCC

LCampbell@frcc.com

We agree that 120HRS of CEH is a reasonable quantity, but believe that the individual entity must have the flexibility to decide how the hours should be distributed per Appendix A and NERC policy. Same suggestion as above on sentence structure in the last paragraph.

We agree that 120HRS of CEH is a reasonable quantity, but believe that the individual entity must have the flexibility to decide how the hours should be distributed per Appendix A and NERC policy

Jule W. Tate


Operations Training



TRWG







Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov

TRWG believes that the number of CE hours should be equal across all credentials. TRWG believes that training shold be based on performance gap analysis.

A 5 - year period should be adopted.

If NERC truly wishes to get the maximum benefit from continuing education, it should set some minimum amount of CEH which must be completed in the first two years of the 3-year period. This would help ensure a continuous process of education instead of a once every three year "cram" to meet the education requirement. too many hours for certification. If NERC wants entities to provide training for operators, enforce that against entities's. Don't take it out on operator seeking to keep his job.



The amount of CEH required appears excessive and arbitrary. What facts support this level of commitment? Currently in my organization the minimum requirements are 80 hours per three year period of relevant structured classroom training and 32 hours per year of relevant self study.

This level of training has been challenging to meet because of personnel shortages, vacations and operating commitments.

Draft for Comments

Page 47 of 110

July 28, 2004


John Taylor

SPP

JTaylor@spp.org

Mark R. Henry, P.E.


Pat Budler

Energy Delivery


Robert D. Eubank



Kathy Davis


Make the number of CEHs trhe same for all certification areas.

Suggest 100 hours, at least 20 on NERC or Regional policies and the rest on tasks.


I think the amount of hours are appropriate considering the level in which we are training to bring the industry training standards to. However, these hours may be difficult to obtain without having the dollars funded to allow this amout of training. Companies may be reluctant to part with the funding necessary to obtain these CEH's.





* 60 CEH related directly to Balancing & Interchange operator tasks

{not tied to maintaining

certification, employer responsbility to ensure completion}.




SPP OTWG

KDuncan@spp.org


Rod MacNeill



Keith Comeaux

CLECO


Sanjay Dutta

CAISO


SDutta@caiso.com

Thomas V Pruitt


See "Additional Comments".

In this case 120 CEH = 120/7.5 = 16 man days * 28 employees = 448 man days of CE over a three year period. In order to reduce the CEH required I would recommend 60 CEH over three years plus the successful completion of the Qualifying Exam.

If an operator choses this path the number of hours and the subject content in Appendix A for this certification look reasonable .



Why does the Balancing and Interchange Operator have training requirements related to Market Operations (see Appendix A)? This seems to send mixed priority signals and could create more complex standards of conduct and data/info confidentiality issues.

Draft for Comments

Page 48 of 110

July 28, 2004


Draft for Comments

Page 49 of 110

July 28, 2004


Balancing, Interchange & Transmission Operator Certification

After completing and passing an initial NERC Balancing and Interchange/Transmission Operator certification exam, the candidate is awarded a NERC credential as a Balancing and

Interchange/Transmission Operator. A certificate will be issued that is valid for three years. To maintain a valid Balancing and Interchange/Transmission Operator credential, system operators must earn 180 CEH within the 3-year period preceding the expiration date of their certificate.







150 CEH related directly to Balancing and Interchange/Transmission Operator tasks.

(See Appendix A for recognized training topics.)




Comments:

Alan Gale



Linda Campbell

FRCC

LCampbell@frcc.com

Jule W. Tate


Operations Training




Same comment as above. Recommend 30 hours every 3 years.

Additionally, if "One of the primary purposes of continuing education is that it promotes ongoing development of an operator's knowledge...",

I believe we should allow CEHs from the RC syllabis be allowed to count for the BITO certificate. I can understand not overlapping with the BIO and TO since they are somewhat specialized, but the combined operators would benefit from allowing the "higher" level

CEHs count. This would improve their overall understanding, improve their knowledge and "hopefully" improve their performance.

We believe that 180 HRS of CEH is excessive. The criteria should be

120HRS of CEH with the hours accumulated from NERC policy and the training topics provided in Appendix A for this type of certification. See previous suggestion on sentence structure in the last bullet.


120HRS of CEH with the hours accumulated from NERC policy and the training topics provided in Appendix A for this type of certification.




Water & Power


TRWG believes that the number of CE hours should be equal across all credentials. TRWG believes that training should be based on performance gap analysis.

Since this certification is a combination of the previous two certifications, I believe the training requirement should include all of the elements of the two previous training requirements. Hence, I believe the requirement should be:


90 CEH related directly to Transmission Operator tasks.

90 CEH related directly to Balancing and Interchange Operator tasks.

This results in a total of 210 CEH. This would prevent a System

Operator from only choosing training that related only to Transmission

Operations, or only to Balancing and Interchange operations, while holding a certification for the combined operations.

Draft for Comments

Page 50 of 110

July 28, 2004


Kathy Bauer

NorthWestern Energy


Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov

Additionally, if NERC truly wishes to get the maximum benefit from continuing education, it should set some minimum amount of CEH which must be completed in the first two years of the 3-year period.

This would help ensure a continuous process of education instead of a once every three year "cram" to meet the education requirement.

60 hours a year is too difficult to arrange classroom/training time with

24x7x365 operation, canned training is not effective training, just meeting the rules does not make a better operator. Minimum staffing requirements & maximum 12 hour shifts in a row established and staff accordingly. too many hours for certification. If NERC wants entities to provide training for operators, enforce that against entities's. Don't take it out on operator seeking to keep his job. all four certifications should require same number of CE hours.



The amount of CEH required appears excessive and arbitrary. What facts support this level of commitment? Currently in my organization the minimum requirements are 80 hours per three year period of relevant structured classroom training and 32 hours per year of relevant self study. This level of training has been challenging to meet because of personnel shortages, vacations and operating commitments.

Make the number of CEHs trhe same for all certification areas John Taylor

SPP

JTaylor@spp.org

Mark R. Henry, P.E.


Pat Budler

Energy Delivery


Suggest 100 hours, at least 20 on NERC or Regional policies and the rest on tasks.

Robert D. Eubank



Kathy Davis


There should be a minimum number of CEH in the Balancing and

Interchange area and a minimum number of hours in the Transmission

Operator area to maintain this certification. It also seems there should be more hours requiring simulations to meet this requirement. A starting point might be 20 hours of simulation training in each area .


I think the amount of hours are appropriate considering the level in which we are training to bring the industry training standards to.

However, these hours may be difficult to obtain without having the dollars funded to allow this amout of training. Companies may be reluctant to part with the funding necessary to obtain these CEH's.





* 120 CEH related directly to Balancing, Interchange, &

Transmission Operator tasks {not tied

Draft for Comments

Page 51 of 110

July 28, 2004



SPP OTWG

KDuncan@spp.org


Rod MacNeill



Keith Comeaux

CLECO


Sanjay Dutta

CAISO


SDutta@caiso.com


to maintaining certification, employer responsbility to ensure completion}.



RDB: See "Additional Comments".

GPR: In this case 180 CEH = 180/7.5 = 24 man days * 28 employees

= 672 man-days of CE over a three year period, this equals one additional employee. In order to reduce the CEH required I would recommend 90 CEH over three years plus the successful completion of the Qualifying Exam.

If an operator chooses this path the number of hours seem excessive.

How was this number arrived at? This NERC test contains twenty percent more questions than the T/O and B/I test so why would it require fifty percent more training hours to maintain this certification.



Draft for Comments

Page 52 of 110

July 28, 2004


Reliability Coordinator Operator Certification

After completing and passing an initial NERC Reliability Coordinator Operator certification exam, the candidate is awarded a NERC credential as a Reliability Coordinator Operator. A certificate will be issued that is valid for three years. To maintain a valid Reliability Coordinator Operator credential, system operators must earn 240 CEH within the 3-year period preceding the expiration date of their certificate.







210 CEH related directly to Reliability Coordinator Operator tasks. (See Appendix A for recognized training topics.)




Comments:

Alan Gale



Hannah Peterson

Training Specialist

Midwest ISO, Inc.


Linda Campbell

FRCC

LCampbell@frcc.com

Jule W. Tate

Manager, Power System Operations

Training


Same comment as above. I can see increasing the hours by a small number for the RC, perhaps 40 hours every 3 years.

On the surface 240 hours appears to be six weeks of training per three year period, which implies 2 weeks training each year.

However, while 2 weeks each year is implied, in fact more training time may well be needed to achieve 80 CEH hours in a year. A full day of accredited training, factoring in lunch and breaks taken during the training day equates to less than 8 CEH units achieved in one day. For example, if only 6 1/2 hours were achieved in a full training day, it will take in excess of 12 full training days, not 10 full training days, to achieve 80 CEH units in a year. That comes out to approx. 37 full days of training per 3 year period instead of 30.

Understanding that a full day's training may not typically achieve 8

CEH units, it is requested that this requirement either be "levelled" to match requirements for other certifications or be changed to a

200 hour CEH target over three years to respect a typical full training day' realities. A concern would be that without retaking the

NERC test as an option going forward, organizations may be put in a position where there may not be enough time availability to meet high CEH requirements, which could result in an unexpected amount of suspended and or revoked certifications.


120HRS of CEH with the hours accumulated from NERC policy and the training topics provided in Appendix A for this type of certification. Even though the RC has more responsibility, proper choice of training topics should make 120 hours very adequate to get the necessary training. Also, see previous suggestion on sentence structure for last bullet.


120HRS of CEH with the hours accumulated from NERC policy and the training topics provided in Appendix A for this type of certification.

Draft for Comments

Page 53 of 110

July 28, 2004


Debra L. Yinger








Water & Power


Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov

Downing, Staci

Avista Energy

I feel that the hour requirements are slightly high. As it is very difficult to allot time to train a person working shifts under normal conditions, this puts a limitation on the Operator especially if the work location is under staffed. The Operator could then be penalized due to limitations beyond his/her control. If there is not an in-house NERC approved trainer, the Operator may have to travel frequently to obtain the necessay CEh's. The option for testing out should also be incorpated as an option with a lower amount of CE hours.

TRWG believes that the number of CE hours should be equal across all credentials. TRWG believes that training should be based on performance gap analysis.

Since this is the "senior" certification, allowing operation in any of the NERC certified specialties the training requirement must also exceed those for the lower certifications. Hence, I believe the training requirement should be:


90 CEH related directly to Transmission Operator tasks.

90 CEH related directly to Balancing and Interchange Operator tasks.

60 CEH relating directly to Reliability Coordinator tasks and responsibilities.

This results in a total of 270 CEH. This would prevent a System

Operator from only choosing training that related only to

Transmission Operations, or only to Balancing and Interchange operations, while holding a certification for the Reliability Cordinator position. Breadth of knowledge is crucial in these positions.

Additionally, if NERC truly wishes to get the maximum benefit from continuing education, it should set some minimum amount of CEH which must be completed in the first two years of the 3-year period.

This would help ensure a continuous process of education istead of a once every three year "cram" to meet the education requirement. too many hours for certification. If NERC wants entities to provide training for operators, enforce that against entities's. Don't take it out on operator seeking to keep his job. all four certifications should require same number of CE hours.

All credential requirements should include some professionally related CEH's. These increase the knowledge level of the operators and improve their performance. These professionally related CEH's could be detailed as a separate number or included in the non-NERC policy requirement.

The amount of CEH required appears excessive and arbitrary. What facts support this level of commitment? Currently in my organization the minimum requirements are 80 hours per three year period of relevant structured classroom training and 32 hours per year of relevant self study. This level of training has been challenging to meet because of personnel shortages, vacations and operating commitments.

Requiring 240 Continuing Ed credits in a 3 yr period is more than they require to earn some degrees and this is just to maintain the

Draft for Comments

Page 54 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines sdowning@avistaenergy.com

John Taylor

SPP

JTaylor@spp.org

Mark R. Henry, P.E.


Begalman, Buppha

Buppha.Begalman@AvistaEnergy.com certification. It seems this is a bit on the high side for CEH and should be reduced to a more reasonable number, as most employees with the Certification are full-time and other are also attending education courses in other areas. Too many hours could lead to a large number of employees who may not be able to renew the certification as they did not fully meet the required hours. Other meetings have suggested continuing education courses in the range of 16-20 to maintain the certification. This would be more attainable by most individuals and ensure many could recertify.

Make the number of CEHs trhe same for all certification areas.

Suggest 100 hours, at least 20 on NERC or Regional policies and the rest on tasks. 2 weeks of annual training with CEH credits arranged seems excessive to several ERCOT members.

I support the continue edution program. The 240 ceh is unrealistic for us to do. We are working 40 hours plus a week. This is a stressful job and to add 80 hours ceh a year is not possible. We have family wa also need to take care of too. Less ceh is more desireble.

It also seems there should be more hours requiring simulations to meet this requirement. Same simulation requirement for all levels of certification - is this equitable?

Pat Budler

Energy Delivery


Robert D. Eubank



Kathy Davis


I think the amount of hours are appropriate considering the level in which we are training to bring the industry training standards to.

However, these hours may be difficult to obtain without having the dollars funded to allow this amout of training. Companies may be reluctant to part with the funding necessary to obtain these CEH's.





* 180 CEH related directly to Reliability Coordinator Operator tasks {not tied to maintaining

certification, employer responsbility to ensure completion}.




SPP OTWG

KDuncan@spp.org


Rod MacNeill



RDB: See "Additional Comments".

GPR: In this case 240 CEH = 240/7.5 = 32 man days * 28 employees = 896 man days of CE over a three year period. In order to reduce the CEH required I would recommend 120 CEH over three years plus the successful completion of the Qualifying Exam.

The number of CEH required puts a large financial burden on the employer, the goal can be met with a combination of CEH and certification examinations.

Draft for Comments

Page 55 of 110

July 28, 2004


Keith Comeaux

CLECO


Robert D. Vargus

Muscatine Power & Water bvargus@mpw.org

Sanjay Dutta

CAISO


SDutta@caiso.com

Thomas V Pruitt



If an operator choses this path the number of hours seem excessive.

How was this number arrived at? This NERC test contains twenty percent more questions than the T/O and B/I and the same number as the BIT test so why would it require one-hundred percent more training hours to maintain the certification than the T/O and B/I.

The hour requirements for a Reliability Coordinator is much too high over a three year period (240 CEHs). It is also true for the 180

CEHs for the Balancing & Interchange/Transmission Operator. I don't feel that you are being realistic with these numbers. My family physician only has to take 40 hours of class a year (scheduled for one week) and pass a test over it, to keep his full credentials. The school teachers in our area are required to take 120 hours over 3 years to keep up with their certificates (one class a year, usually one-two weeks during their summer). I cannot believe that we are going to be required to do 180-240 CEHs over 3 years.



This requirement, coupled with other training requirements (e.g.,

P8T3, FERC Standard of Conduct, etc.) is too much to require initially. A progressive, phased-in approach, especially while this requirement is being coordinated with other requirements, is better.

Draft for Comments

Page 56 of 110

July 28, 2004


Deficits of CEH for Credential Holders

An individual holding a NERC credential who does not accumulate the required number and balance of CEH within the three-year period will be deemed deficient and their credential will be suspended on the date they become deficient. The credential holder will be given up to 12 months to acquire the necessary CEH, during which time their credential will remain suspended. (An operator with a suspended credential cannot perform any task that requires an operator to be NERCcertified.) If more than 12 months elapse, the credential will be revoked. The operator will be required to take an exam to become certified again. During the time of suspension, the original anniversary date will be maintained. Therefore, should the system operator accumulate the required number of credit hours within the 12-month suspension period, the system operator will, again, be required to accumulate the required number of credit hours prior to the original 3-year anniversary date.

 For example: a system operator’s credential expires on July 31, 2007, but does not accumulate the required number of credit hours prior to that date:



The credential will be suspended on July 31, 2007.



If the system operator then accumulates the required number of credit hours by

March 1, 2008, the credential will be reinstated on March 1, 2008, and will be valid until July 31, 2010.



The system operator will have to accumulate the required number of credit hours prior to

July 31, 2010, or the credential will be suspended again. Those CEH previously used to maintain the credential cannot be reused in the current period.



A record of the suspension between July 31, 2007, and March 1, 2008, will be maintained.

Comments:

Alan Gale



Karl Tammar

NYISO

KTAMMAR@nyiso.com

Suggest adding a “hardship clause” to these guidelines for extended medical problems or military duty. One approach may be to "just stopping the clock" while in this status. If he is on 6 month medical leave, he would have 3 years and 6 months to complete the necessary

CEHs. (You could include a 5 year maximum since that was the satndard previously.) Each scenario should require review by the

PCGC.

If an individual does not acquire the required CEH for the RC credential, but does acquire the CEH for a lower level certification, can he work as the lower credential and then complete the requirements within the next 12 months and then go back to the RC function?

Waiting an entire 12 months to allow testing is excessive. I would suggeest a six (6) month maximum. Even this will be a burden to many smaller entities. And in the case of my particular entity, would probably result in termination of the individual.

See the earlier comments. As a minimum, NERC must have some safeguard for those operators whose situation legitimately does not allow them to complete requirments.

Draft for Comments

Page 57 of 110

July 28, 2004



Hannah Peterson

Training Specialist

Midwest ISO, Inc.


Linda Campbell

FRCC

LCampbell@frcc.com

Gordon Pietsch






Will Behnke


While IRC membes thought that if there was a shortend cycle and no retest option, there needed to be safegard in the process (a reduced credential, a probationary period, etc.).

There should be a 5 - year creditation period. They should be allowed to work under direction of a NERC Certified controller of the proper requirement, until the CEH requirement is acquired.

Can someone with a suspended certificate work in a non-independent postion under the direct authority of a certified system operator?

Deficits of CEH for credential holders and resultant suspension action need to be shared with the entity that is responsible for maintaining and reporting operator certification. The utility that any suspended individual is working for needs to have accurate and current information on the status of operators for NERC Complaince, Readiness

Audits and other management and reporting purposes. This requirement again, emphasizes the need for a working NERC tracking system that provides a reporting system so that accumulated training hours, suspensions, revocation, and NERC granted extensions are readily known to the individual and his/her employer..

We suggest adding a “hardship clause” to these guidelines for extended medical and military duty. One approach to consider is to suspend an individual’s certification without losing the CEH already accumulated before the extended leave. Each scenario will require review by the PCGC.

In reviewing the sections regarding suspension of credentials and the changing of Certification Levels, there appears to be an opportunity for an individual to change certification levels if the individual does not acquire the required number of CEH for the higher level, but does acquire the CEH for a lower level certification. In addition, there should be a retest option included in the 12-month suspension period.

Waiting an entire 12 months to allow testing is excessive.

We feel there should be a means of appealing a ruling that a system operator's certification has been suspended or revoked. In the current white paper there is no process or means to appeal.

The operator should not have credentials suspended during the appeal process.

1.) The training is extremely important and the needs are not questioned but this requirement is too excessive. The three year period in most cases will likely be plenty of time to acquire the hours needed but, conditions in any given company due to retirements, job changes, corporate changes, etc., could hamper ones ability to finish their training in the prescribed time. To compensate for unexpected circumstances NERC needs to consider a grace period after the initial expiration date in which the person has a final chance to collect the hours needed for certification. Something that might work could be a situation where a person within 10 hours of certification could work their position on an automatic temporary extension. NERC could also consider a one time request for an extension in order to finish the required hours.

If taking the NERC certification test is adequate to determine a basic level of competency for power system operators on initial certification, it seems inconsistant that an exam is not considered adequate for recertification after certification is revoked. See the comment for

Draft for Comments

Page 58 of 110

July 28, 2004


Jule W. Tate


Operations Training


Phase II Preamble.


Audits and other management and reporting purposes. This requirement again, emphasizes the need for a working NERC tracking system that provides a reporting system so that accumulated training hours, suspensions, revocation, and NERC granted extensions are readily know to the individual and his/her employer.

Extentions should be granted for certified operators which are somewhat deficit CEHs if a mitigation plan is supplied by the company for which the individual works and is approved by NERC. The opertor to keep an active certification during the mitigation period.

Companies would rather have a seasoned operator with a few CEHs short of recertification then having a totally new individual monitoring reliability.

Should their be a section here to adress CEH decifits due to long term illness, unpridictable staffing issues, military obligations, ect.?

We suggest adding a “hardship clause” to these guidelines for extended medical and military duty. One approach to consider is to suspend an individual’s certification without losing the CEH already accumulated before the extended leave. Each scenario will require review by the PCGC.

In reviewing the sections regarding suspension of credentials and the changing of Certification Levels, there appears to be an opportunity for an individual to change certification levels if the individual does not acquire the required number of CEH for the higher level, but does acquire the CEH for a lower level certification. In addition, there should be a retest option included in the 12-month suspension period.

Waiting an entire 12 months to allow testing is excessive.

Compliance with the Continuing Education Program should be identified as in the other proposed standards. Four levels with associated penalties.

Compliance should allow the operator to take an exam to stay certified.

Possible appeal for extension if unusual circumstances as extended illness?

Debra L. Yinger







Water & Power


There should be a 5 - year creditation period. They should be allowed to work under direction of a NERC Certified controller of the proper requirement, until the CEH requirement is acquired.

Before NERC can assess penalties ( suspension or revocation of credentials ) it must guarantee that sufficient training is readily available at sufficient locations and times to allow the education process to take place.

Additionally, NERC should consider assessing some penalty on the

Draft for Comments

Page 59 of 110

July 28, 2004


Kathy Bauer

NorthWestern Energy


Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov utilities so that they are motivated to allow System Operators the time necessary to acquire the required training. In making this determination, NERC might review how many Control Areas were deficient in the "continuing training" requiremnt over the past few years compliance audits. nerc failed to notify any of our operators that their certification was to expire, Nerc was supposed to have notified a year in advance that your certificate was expiring

If you can recover certification by taking a test after suspension, then taking a test must be good enough. Why not keep the test as an option for anyone wanting to renew?

Some type of hardship exemption should be allowed for individual operators and also for employing companies to accommodate health, accident, weather, and other catastrophic issues that could prevent accumulation of required CEH.


MISO SOTWGAmerican

Transmission Company psteinberger@atcllc.com


WECC OTS

WECC Staff mike@wecc.biz elm@dairynet.com

Jane Cocker

System Operations


JCocker@RPU.ORG

Pat Budler

Energy Delivery


Retaining record of suspension infers a potential punitive use of the record. If this is the intent then potrntial punitive actions must be spelled out to prevent misunderstanding and misinterpretations. This will prevent blindsiding of an operator at a future point in time.

If taking the NERC certification test is adequate to determine a basic level of competency for power system operators on initial certification, it seems inconsistant that an exam is not considered adequate for recertification after certification is revoked. See the comment for

Phase II Preamble.


Audits and other management and reporting purposes. This requirement again, emphasizes the need for a working NERC tracking system that provides a reporting system so that accumulated training hours, suspensions, revocation, and NERC granted extensions are readily know to the individual and his/her employer..

OTS supports the concepts presented.

At 90-days before the expiration date of an operator's credential, an email notification should be sent to the company an operator is employed by, notifying them of the operator's status in maintaining the credential. And, the company should be notified anytime an operator's credential is either suspended or revoked.

30 day buffer before suspension of credentials after expiration date.

As stated before, it is inconsistent that testing is acceptable at one point, then unacceptable later on.

How will deficient CEHs be communicated to the system operator?

If taking the NERC certification test is adequate to determine a basic level of competency for power system operators on initial certification, why would it not be acceptable for recertification - after certification is revoked or prior to going deficient?

Re-emphasizes the need for a working NERC tracking system that

Draft for Comments

Page 60 of 110

July 28, 2004


Robert D. Eubank




SPP OTWG

KDuncan@spp.org


Rod MacNeill



Administrative Guidelines provides a near real-time reporting system so that accumulated training hours, suspensions, revocation, are readily available to the individual and his/her employer.

How many suspensions are permitted? Or is this left to the discretion of the employer?

I support this concept.

At 120 days before expiration of an operator's credential, a notice should be sent to both the operator and the company's training representative for the company in which the operator is employed notifying them of the operator's status in maintaining the credential.

Also the company's training representative should be notified when the operator's credential is either suspended or revoked.

15. The proposed plan to suspend the credential if the number of CEH have not been accumulated should be changed to provide for a notice of pending suspension. The notice should be for 6 months during which time the operator can still work, then if the CEH's aren't accumulated by the end of the 6 month period, suspension could occur until appropriate hours are accumulated. Also, when training is conducted and CEH earned during the last year of the credential that causes the number of accumulated hours to exceed the required amount, the extra hours should be allowed to carry over to the next 3 year period. There will be occasions that an organization cannot manage all hours to the exact requirement and to disallow additional hours is too severe.

We support the concept but not clear why an exam could not be used

(in some cases) to maintain Certification prior to lapsing. Suggest that an exam be allowed to maintain Certification in the case of long term illnesses and other circumstances beyond the control of a System

Operator. We believe there is value in studying for the exam and that should be recognized for CE credits.

A method must be found for notifying the SO and the Company that

Certification will lapse at least 90 days prior to expiration of the credential. Company should not have to rely on a System Operator tracking their own expiration of Certification. Company must be notified whenever a System Operator's credential is suspended or revoked.

A system operator that fails to accumulate the required number of credit hours will have their credentials suspended. Their credentials will be reinstated if the system operator has a minimum of 50% of the required hours and completes the Qualification Exam (no waiting period). Should the system operator have less than 50% of the required CEH and reaches the 50 % level within a year following the suspension the system operator will be allowed to write the Qualifying

Exam With less than 50% of the required hours the above would apply.

The credential should be reinstated with an expiry date 3 years from the date of reinstatement. To do otherwise is to be unnecessarily punative to an operator who may have become suspended due to job loss or long-term illness. For example, if an operator looses his job just before accumulating enough CEH to recertify is out of work for 2 years, is reemployed and rewrites the certifcation exam, he is required to complete 3 years of CEH in 1 year. If he cannot do this, he is back

Draft for Comments

Page 61 of 110

July 28, 2004


Keith Comeaux

CLECO


Marc M. Butts

Southern Company Services mmbutts@southernco.com

Administrative Guidelines where he started from--being required to rewrite the certification exam. What is the rationale for this policy?

The obligation for maintaining the credential falls on the operator to aquire this training. This program holds the operator accountable while the template names the Operating Authority responsible which seems like a disconnect. As explained above we now have an opportunity of retaking the test but only after the worst case scenario has taken place. Suggest a hardship case in the event an operator finds himself/herself without an entity to sponsor them for a period of time to re-take the test to maintain their credential.

The white paper needs to address a method of NERC notifying organizations when an individual's certification is suspended, revoked or expires.

Draft for Comments

Page 62 of 110

July 28, 2004


CEH Earned by Operators for Maintaining a Credential

1.

The NERC-certified system operator seeking to maintain the credential must submit proof of having acquired the necessary CEH from a NERC-approved provider or a NERC approved learning activity. These submittals will be made electronically into the NERC certification database.

1.1.

Operators will be able to track their status/progress towards maintaining their credential continuously.

2.

3.

1.2.

Certified system operators must review their CE credit hour records at least 90 days before their credential expiration date to allow sufficient time to acquire, and apply

CEH prior to the operator’s certificate expiration date.

1.3.

To ensure their credential does not get suspended, the system operator must submit proof of sufficient CEH to NERC 30 days before the system operator’s certificate expiration date. Submissions received at NERC within the 30-day window may not be credited to the system operator’s account in time to prevent the credential being suspended.

For system operators who meet the CE credit hour requirements, NERC will extend their certificate’s expiration date for three years (a new certificate will be mailed to the address on record).

System operators whose CE credit hour submittal is found to be incomplete will be deemed to be deficient and their credential will be suspended.

4.

CEH in excess of the required amount cannot be carried over from one three-year period to the next.

Comments:

Alan Gale



30 days may not be enough time to complete the "paperwork" at NERC.

Although this will be done primarily electronically, the potential exists for a large number of operators to be "renewing" at the same time. recommend extending the window to 90 days, although this really results in only having 2.5 years to complete the training requirements.

Some provision must be made to notify the individual's employer that a credential has been suspended. We have placed the burden of maintaining the certification on the individual, but the employer is the one that will be in violation of Policy 8 (Version 0 Standard #32). I would extend that reporting to be of all credentials that were extended also.

That would remove the "he didn't tell me" excuse.

Should not the CE provider and/or local trainer be primarily responsible for inputting CEH information into the NERC database?

Karl Tammar

NYISO

KTAMMAR@nyiso.com


A. Glazner

AGlazner@fmtn.org

Anita Lee, P. Eng.


The certification should be for a 5 - year period.

The 30 day requirement is too long. The CEH's should be able to be submitted up to the date that the certificate expires. If this an on-line type database the result should be updated immediately. the proof of the creditials should lie with the training administrators, not with the system operators.

The CEH provider should be responsible for inputting CEH information into the NERC database within a strict timeframe.

Draft for Comments

Page 63 of 110

July 28, 2004


Procedures



Linda Campbell

FRCC

LCampbell@frcc.com

Gordon Pietsch





Mark Meyer

MMEYER@wapa.gov

Gratien Charest



Donnie Harrell

Sr. Analyst





To provide clarity, the following revised wording is provided for 1.3; If the record of the system operator has not been updated by 90 days prior to certificate expiration; the system operator must submit a copy of the course certificate, which is issued in accordance with NERC CEH requirements after each learning Activity, at least 30 days before the system operators certificate expires.

If a system operator accumulates more than the required hours over a three year period any CEH's over the required amount that had been accumulated in the last six months prior to expiration should apply to the next three year period.

1. See our comments on database management in the "Goals" section.

2. Care must be taken to ensure that credit is received for CEHs earned right up to the last day of the certified period to avoid suspension or revocation, rather than a potentially shortened period described in #1.3 above. There are times that scheduling conflicts will result in a person not being able to obtain the required training until the very end of the period. As mentioned in our database comments, the record keeping system should be able to generate warning messages to both the system operator and the employer as the anniversary date approaches.

3. Provision should be made for a reasonable amount of excess earned

CEHs to be carried over to the next certification period. Often scheduling of personnel is an important factor into what training a person can achieve in a given period and earning some additional CEH should not be discouraged. Carry over should not be excessive because the goal is

"continuing" education. We suggest a maximum carry over of 32 CEH.

Each utility or company management should be responsible to demonstrate the fulfilment of the determined CEH in the computing system. In other words, system operators should not be permitted to fill in their own data…

.2.1. Certified system operators (or the operators designated training administrator) must review CE credit hours at least 90 days before their credential expiration date to allow sufficient time to acquire, and apply

CEH prior to the operators expiration date.

I think it is a good idea to have the Training Admin. to be able to monitor

System Operator progress on CEH, as a back up plan anyway. Also I don not think it is necessary to have the Operator and the training provider to register all training, it should be sufficient for the training provider to register all information for that training session and the Operator only allowed to monitor his or her progress.

40 to 80 hours of "certified" training per year seems excessive to me.

1.) If companies are expected to pay NERC to be the record keeper then the system that will be developed should have the capability to know when a person has the required amount of hours and should automatically renew the certificate. This approach places all the responsibility on the operators to make sure NERC systems for record keeping are up to date. The time window is also constraining. A person

Draft for Comments

Page 64 of 110

July 28, 2004


Will Behnke


Jule W. Tate


Operations Training







Cochran, Bob

Xcel Energy


Dale Wadding

Coordinator, System Operations could acquire the remainder of the hours needed inside the 30 day window which would also be inside the 3-year certificate period and could have their certificate expire and not be allowed to work their position, even though technically they are qualified. The system should be designed to allow any hours accumulated entered up to the expiration date for the certificate to be renewed. If this is not attainable then prior comments pertaining to a grace period should be considered.

2.) The overlapping dates of certificate expiration will make it extremely dificult to manage the hours needed with the number of certificates held within a company. How do we structure a training program for up to fifty people with fifty different expiration dates? How do we insure that the 30

CEH for Policy Training falls within everyones windows? The thirty day window adds to the difficulity of companies being successful in keeping programs on tract for each certified employee.

The CEH provider should be responsible for entering CEH information into the NERC database in a strict timeframe. Failure of a CEH provider to quickly update operators records could become critical as an operator nears a cerficate expiration date. The operators should be able to review the data along with his/her employer. An operator needs to submit proof the required training is complete. What constitutes "proof." Is the CEH

Provider Certificate proof enough or is there a requirement for cross checks and other records? Also see the comments in the Goals section.

Application of previously earned CEHs (earned during the development of this White paper) which the operators have accumulated should be able to apply to the CEHs needed in the future as these were accumulated in good faith to support the NERC directive.

To provide clarity, the following revised wording is provided for 1.3; If the record of the system operator has not been updated by 90 days prior to certificate expiration; the system operator must submit a copy of the course certificate, which is issued in accordance with NERC CEH requirements after each learning Activity, at least 30 days before the system operators certificate expires.

The certification should be for a 5 - year period.

The 30 day requirement is too long. The CEH's should be able to be submitted up to the date that the certificate expires. If this an on-line type database the result should be updated immediately.

Item 1.3 above in essence reduces the training window from 3-years to

35-months. Why should a System Operator be penalized for NERC's inability to perform its task in a timely manner? System Operations is a real-time profession, NERC should be able to perform in a real-time manner.

I do not believe a NERC certified System Operator should be penalized if he completes the CEHs prior to the end of the 3-year period.

Even the Uniform Commercial Code recognizes the date of postmark as the date of payment of an obligation, not the date of receipt.

Need methodology for operator's employer to track operator's progress.

Employer is paying for it after all and she has to have some way of managing operator's training.

The requirement to submit proof of CEH at least 30 days before expiration of current certification essentially creates a 35 month

Draft for Comments

Page 65 of 110

July 28, 2004


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov


MISO SOTWGAmerican

Transmission Company psteinberger@atcllc.com

Downing, Staci

Avista Energy sdowning@avistaenergy.com


WECC OTS

WECC Staff mike@wecc.biz extension, not the 3 years as stated elsewhere in the white paper.

Operators should be able to earn CEH's up until the last day of their certification, then enter a 30 day grace period which would allow for

NERC database entry, verification, submittal of proof, and certification extension.

This identified process prevents the employing organization's protection of its' investment in the operators. The employing organization must be able to access the NERC data base to ensure that each of their operators' have every opportunity to meet the CEH requirements as well as verifing the accuracy of the information entered in the database.

The policy must state the employing organization's responsibility to the operator in reference to providing the opportunity for meeting the CEH goals as a normal part of the operator position and not in outside of the operator's employment.

The CEH provider should be responsible for inputting CEH information into the NERC database in a strict timeframe. Failure of a CEH provider to quickly update operators records could become critical as an operator nears a cerficate expiration date. The operators should be able to review the data along with his/her employer. An operator needs to submit proof the required training is complete. What constitutes "proof." Is the CEH

Provider Certificate proof enough or is there a requirement for cross checks and other records? Also see the comments in the Goals section.

This is why reducing the required number of hours would benefit all companies, because not many would be able to operate if employees were put on probation and had to make the hours in order to recertify.

This would put additional stress on co-workers as well as the company, by trying to cover for those who did not meet the required hours. Reducing the hours would reduce the potential for suspension of ceritfication and further problems.

OTS can support the concept that the operator tracks status/progress towards maintaining their credential, and supports the concept that the training provider be responsible to enter required data from the deliver of approved training activities.


The development and testing of the database and web interface, and subsequent user training, may take several months. When a version of this proposal is approved by the NERC Board, will implementation of this requirement begin then, or be delayed until the database is fully implemented? If a proposal for this program is presented to the NERC

Board in February, then the program needs to begin at that time.

Alternate methods of record keeping can be employed until the database is ready for implementation.

With record keeping being done electronically, why the 30-days to submit

CEH prior to credential expiration? Is it simply to cover scheduled or

Draft for Comments

Page 66 of 110

July 28, 2004


Mark R. Henry, P.E.

Manager, ERCOT Compliance mhenry@ercot.com elm@dairynet.com forced outages of the database?

Item #3 states "System operators whose CE credit hour submittal is found to be incomplete will be deemed to be deficient and their credential will be suspended." It is expected this refers to the total of all CEH submittals results in a deficit in the number of CEH required by the expiration date of the credential.

Item 1.2 is a suggestion, not a requirement - use "should" instead of

"must", unless it will be enforced. Why not have NERC send out an automatic letter indicating what is on-file 90 days before expiration instead?

#1.3 For an electronically based system 30 days is an inordinately long period of time. Not flexible enough, give the 30 days on the other side, ie past his expiration date, loss of certification will not occur until after this

30 day buffer, loss of certification not only impacts the holder but also other certified opertors who will have to fill that position. #4 Not cost effective, if we are paying for CEH's they should be just as valuable for one period as for the next, or do we get up and leave the class when we've earned "just the right number" of CEH's ? Make the excess CEH's earned in the year preceeding may be carried over. Knowledge is knowledge regardless of when learned.

What constitutes 'proof'? What about the CE providers responsibilty?

These items need to be further clarified.

Jane Cocker

System Operations


JCocker@RPU.ORG

Pat Budler

Energy Delivery


Robert D. Eubank



The 30 day window in section 1.3 should be shortened to 7 days.

Electronic tracking should permit faster turn around of the training records. The CEH provider shall be responsible for timely data entry into the NERC database. The operators should be able to review the data along with his/her employer.

I can support the concept that the operator tracks status/progress towards maintaining their credential, and supports the concept that the training provider be responsible to enter required data from the deliver of approved training activities.


The development and testing of the database and web interface, and subsequent user training, may take several months. When a version of this proposal is approved by the NERC Board, will implementation of this requirement begin then, or be delayed until the database is fully implemented? If a proposal for this program is presented to the NERC

Board in February, then the program needs to begin at that time.

Alternate methods of record keeping can be employed until the database is ready for implementation.

With record keeping being done electronically, why the 30-days to submit

CEH prior to credential expiration? Is it simply to cover scheduled or

Draft for Comments

Page 67 of 110

July 28, 2004


Snodgrass,Theodore M tmsnodgrass@bpa.gov

Kathy Davis



SPP OTWG

KDuncan@spp.org


Rod MacNeill


Rod.MacNeill@bctc.com forced outages of the database?

Item #3 states "System operators whose CE credit hour submittal is found to be incomplete will be deemed to be deficient and their credential will be suspended." It is expected this refers to the total of all CEH submittals results in a deficit in the number of CEH required by the expiration date of the credential.

This seems fraught with opportunity to pull someone's ticket w/o warning.

You need to have a tickler file that sends an E-Mail or other notice to people whose ticket is peceived, by NERC to be about to expire else you're going to be held hostage to the reliability of your database, not a position I envy. There needs to be time for dispute and resolution.

1. It should not be the responsibility of the system operator to input proof of acquisition of the CEH, it is the responsibility of the provider.

The Admin Guideline for CEHs already requires the provider to submit data on CEHs issued.

3. How will the system operator be notified that their credential is suspended? Also, how will an operating be able to determine if an individual has a valid certification, i.e., not suspended?

16. While it is commendable that system operators have some responsibility in the process, their management staff should be an integral part of this process. After all, management will be responsible for providing the staffing, payment, and work schedule manipulation to accommodate the training. Having operators manage the process may lead to schedule conflicts. Management may also have specific training a particular operator needs to enhance skills. It is important that both the

Operator and a system administrator from an organization have access to

CEH records.

17. In the event an operator's credentials are suspended will the entity and the operator be notified by NERC? In such a case the entity could be at risk of violating a NERC requirement for certified operators working shift? Who would be responsible for making this notification, the operator or NERC?

We support the concept that the System Operator tracks their status and progress towards maintain their credential. We also support the concept that a Training Provider enters their data/records into the database. We have a concern that the company's training manager or admin staff cannot review the status and progress of a System Operator in the NERC databse. Each company will have System Operator 's progressing through

CE at different rates and with different expiration dates. This is going to be a challenge for developing a yearly training plan that fit the needs of each System Operator. The System Operator must be able to authorize an additional person(s) to access to enter and view that System Operator's training records.

We are concerned that the development and testing of the database and web interface may take several months. Required training and CE has been in place since 2003. This program should not be delayed by technology reasons.

If CE records are kept electronically, why will NERC require 30-days to submit CEH prior to credential expiration? If a database is developed CE

Draft for Comments

Page 68 of 110

July 28, 2004


Keith Comeaux

CLECO


Thomas V Pruitt


Administrative Guidelines records should be able to entered up to Certification expiry date and a 30 day period after that date be used to deal with expired certifications.

WE are not clear what item 3 means? "System operators whose CE credit hour submittal is found to be incomplete will be deemed to be deficient and their credential will be suspended." Does this refer insufficient hours within three years or does this refer to a wrong entry of information, i.e., a clerical error? If this refers to clerical errors, it is another reason to allow more than the operator to enter and checks records.

The employer must have access to an employees CEH in order to ensure the employee receives the required hours. Maintaining two sets of records (Employer and NERC) only leads to confusion.

Being unable to carryover CEH in excess of those required to recertify bumps into the issue of all our operators having different expiry dates and the company's attempt to provide the required CEH during the three year period in a cost-effective manner. The company needs either consistent expiry dates for all operators or operators need to be able to carryover excess CEH's.

In the event an operator's credentials are suspended will the entity and the operator be notified by NERC? In such a case the entity could be at risk of violating a NERC requirement with suspended operators working shift? Who would be responsible for making this notification, the operator or NERC?

What is the resolution process for discrepancies between an operator's records and those maintained by NERC?

Draft for Comments

Page 69 of 110

July 28, 2004


Changing Certification Levels

A certified system operator can change the type of the credential they hold by indicating this change on their credential maintenance application. A system operator has the following options:

To change a credential from:



Balancing and Interchange Operator to any other NERC credential: the system operator must pass the exam for that credential.



Transmission Operator to any other NERC credential: the system operator must pass the exam for that credential.



Balancing and Interchange/Transmission to Reliability Coordinator: the system operator must pass the exam for that credential.



Reliability Coordinator to any other NERC credential: the system operator must submit the proper number and type of hours for the new credential.



Balancing and Interchange/Transmission to Transmission Operator or Balancing and

Interchange Operator: the system operator must submit proper number and type of hours for the new credential.

Comments:

Alan Gale



This is the first mention of the "credential maintenance application".

Some clarification of it, it's use and functions is necessary.

If an individual does not acquire the required CEH for the RC credential, but does acquire the CEH for a lower level credential, can he work as the lower credential and then complete the requirements within the next 12 months and then go back to the RC function?

What is a "credential maintenance application" and when will we know more about the process and methods for changing our certification level?

Art Feeney

Salt River Project



Operations

Phone: (602) 236-3839

Fax: (602) 236-3808 aefeeney@srpnet.com

Linda Campbell

FRCC

LCampbell@frcc.com

See comments provided in the “Deficits of CEH for Credential Holders” section of the guidelines. Also, the first sentence mentions "credential maintenance application". Is this part of the electronic database? How often does it get filled out? Would it be once during the 3 years, or every time they want to apply hours? This may need some clarification.

Western operates four controls areas, one in the

Eastern

Interconnection and three in the Western Interconnection, plus an addition dispatch office within the CAISO.

These comments are a consolidation of the thoughts

1. The "Credential maintenance application" appears to be undefined with no requirements stated.

2. See our comments on database management under the "Goals" section.

3. Recommend adding a sentence stating that a new anniversay date will be awarded to Operators on the day they pass the exam for the new credential.

Draft for Comments

Page 70 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines and opinions of the personnel working at these facilities.

Mark Meyer

MMEYER@wapa.gov

On behalf of Doug Hils

(industry segment 1) and

Walt Yeager (industry segment 6)


Will Behnke


1.) Starting at a lower level certification and then slowly working to the more difficult would allow some to skirt the CEH requirement and to only retest until the end of their careers. Starting at a Transmission Operator and never changing job requirements or responsibilities one could move to the Balancing and Interchange/Transmission Operator class at the end of three years. At the end of the three years of Balancing and interchange/Transmission Operator one could then take the RC test and another three years of time without any CEH's. So if an operator just passed the TO certification they could work the system for 11 years without taking any additional CEH's.

It is not recommended that there be levels of credentials. As mentioned in the Phase II Preamble comment. This type of system provides incentive for operators and their companies to maintain minimum credentials. There does, however, need to be a system for changing credentials due to changing job assignments.

Jule W. Tate


Operations Training


Dale Wadding

Coordinator, System

Operations Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov

If a certified system operator holds a Reliabilty Coordinator credential but fails to submit the required number of CEH's, change to another certification level if he has earned the required CEH's for that credential?

If this is the case then their should be a statement for the Balance and

Interchange/Transmission Operator to Balance and Interchange Opertrator or Transmission Operator must submit the proper number of and type of hours for that credential.

See comments provided in the “Deficits of CEH for Credential Holders” section of the guidelines.

Some operators want to obtain the highest level certification to provide for future flexibility. If a person passes the Reliability Operator exam, they receive a RO Certificate and have demonstrated adequate knowledge of the subject matter. If, however, they work for a Transmission Operator, this proposal indicates they can obtain enough CEHs to be recertified as a TO without taking the TO exam. If the person later accepts a job with an organization that requires a RO certificate, the RO certificate should be reinstated for 3 years while the person accumulates the required number of hours towards their RO Certification extension.

If passing an exam to move up to another credential results in a 3 year extension of a system operator's expiration date, this may create a loophole by which an operator who is approaching their expiration date but doesn't have sufficient CEH for renewal of their current credential could take an exam to move to another credential. In this way, the operator could avoid entering a suspension period.

Is the credential maintenance application form available?

The process for changing certification levels needs to provide for an exam process to minimize the time needed to change Certification levels, otherwise the operator could be unable to operate in the new credential capacity for up to three years due to the length of time needed to attain the

Draft for Comments

Page 71 of 110

July 28, 2004



MISO SOTWG



John Taylor

SPP

JTaylor@spp.org


WECC OTS


Jane Cocker

System Operations


JCocker@RPU.ORG

Pat Budler

Energy Delivery


Robert D. Eubank



Snodgrass,Theodore M tmsnodgrass@bpa.gov necessary CEH for the new credential.

It is not recommended that there be levels of credentials, as mentioned in the Phase II Preamble comment. This type of system provides incentive for operators and their company’s to maintain minimum credentials. There does, however, need to be a system for changing credentials due to changing job assignments.

Changing credentials should be the same for each category. Even if a reliability coordinator does have a broader knowledge than a balance and interchange coordinator, each should be equaly qualified in their respective fields.

The section is acceptable as written. It indicates a certified operator "can" change the type of credential they hold and that "a system operator has the following options" to change a credential.

The WECC OTS agrees with this position and wishes to state that operators

(and others) must be allowed to earn and maintain a credential that covers their specific area of responsibility, or above. For example, a Transmission

Operator must be allowed to earn and maintain a Reliability Operator credential if the operator so desires. Also, persons not working as a BI, TO,

BIT, or RO, must be allowed to earn and maintain a certification credential.

This includes persons such as supervisors, managers, trainers, planners, reliability council staff, etc.

Once again, the test/no test, options are confusing and inconsistent. Job duties change. One credential on NERC policy should be issued to all, then the same number of CEH's required for maintenance. Other training should be addressed by individual companies under established compliance requirements.

The system as proposed is designed to force operators into limited credentials and in my opinion that is not helpful to higher operation standards.

There are opportunities to utilize an exam to extend certification by going to a separate level of credential. Ideally there would be separate training requirements that would permit an operator to recertify without any additional training so using CEU's would be the obvious choice. It should not be necessary to prohibit restesting as a means to recertify. If testing is good enough for the first three years, why isn't it good enough for subsequent cycles? From a certification standpoint, the important point is that the operator has an adequate understanding of NERC policies and how the power system operates.

The section is acceptable as written. It indicates a certified operator "can" change the type of credential they hold and that "a system operator has the following options" to change a credential.

I agree with this position and wish to state that operators (and others) must be allowed to earn and maintain a credential that covers their specific area of responsibility, or above. For example, a Transmission Operator must be allowed to earn and maintain a Reliability Operator credential if the operator so desires. Also, persons not working as a BI, TO, BIT, or RO, must be allowed to earn and maintain a certification credential. This includes persons such as supervisors, managers, trainers, planners, reliability council staff, etc.

Just what is envisioned as the period of certification when an operator changes jobs and therefore credentials? Does the operator get a full three years by virtue of taking a different test? It appears that a full three years

Draft for Comments

Page 72 of 110

July 28, 2004


Kathy Davis

TVA Electric System

Operations adavis@tva.go


SPP OTWG

KDuncan@spp.org


Rod MacNeill


Rod.MacNeill@bctc.com need to be alotted.

What is the credential maintenance application? It is not described anywhere in this document. Where is a copy of the form available at? Can the operator submit this electronically online?

18. The program doesn't seem to encourage everyone to achieve the highest level of certification. It's in the best interest of the industry to find a way to make it more realistic to achieve the highest level of knowledge to promote coordination and understanding of different roles. This proposal discourages participants (or at least their employers) from maintaining the highest level. This is bad for the industry.

Is the intent to force System Operators to maintain only their base credentials? It is not clear if this allows maintenance of a Certification above the credentials actually required for the job the System Operator is doing.

Suggest that operators (and others) must be allowed to earn and maintain a credential that covers their specific area of responsibility, or above. For example, a Transmission Operator must be allowed to earn and maintain a

Reliability Operator credential if the operator so desires. Also, persons not working as a BI, TO, BIT, or RO, must be allowed to earn and maintain a certification credential. This includes persons such as supervisors, managers, trainers, planners, reliability council staff, etc.

If the hours required for maintaining a credential are not equal I see a possible need for an operator to elect to change their status from RC or from B&I/T to a lesser credential.

Keith Comeaux

CLECO


Draft for Comments

Page 73 of 110

July 28, 2004


Transition Plan — From a 5-year Program to a 3-year Program

An individual whose credential expires during the first three years after implementation of this

System Operator Certification Continuing Education Program has the option to either accumulate the required number of CEH for extension of their credential expiration date or pass the exam for the desired credential; either way, they will receive a three-year extension of their certificate’s expiration date. Individuals whose credential expires after the third anniversary of the implementation of this program must accumulate the required number CEH prior to the expiration date of the certificate.

Comments:

Alan Gale



Karl Tammar

NYISO

KTAMMAR@nyiso.com


Some credit should be given for the vast quantity of CEHs obtained in support of the effort to get the Continuing Education program up and running. I do not believe that many smaller entities would have spent the time and money for Continuing Education classes if they knew they were going to get no credit for them. It was explained in several venues that we needed to get the CE program up and running, to prove that we could get quality training, before we could approach the certification side of

CEH's. To callously disregard that tremendous effort, and expense, is a terrible injustice and could be a financial burden to many. It is certainly a poor choice of spending taxpayer dollars if there is no credit given for it.

I would suggest that CEH's earned within 1 year of the implementation of this program be counted towards the final tally, especially if the higher quantities prevail.

See the earlier comments. The shorter cycle could be problematic and the reasoning for shortening the cycle has not been explained.

Hannah Peterson

Training Specialist

Midwest ISO, Inc.


Matthew Sadinsky


Intl.

Matt@sosintl.com

Anita Lee, P. Eng.


Procedures



Linda Campbell

FRCC

LCampbell@frcc.com

Those who are on the current 5 - year plan should be allowed to retake the exam within 5 - years to maintain their current level. After that a 5 year plan should be maintained with CEH's at the currently proposed CEH numbers.

If retaking of the exam for recertification is retained as an option this will minimimize some or the recordkeeping burden associated with NERC granted extensions, suspensions and revocations without having a lapse in certification credentials. This will allow some flexibility if an operator is unable to meet the three year CEH requirement.

See above. During the transition period care should be taken not to create a disincentive for taking training. The look back period for the first five years should, we think, contemplate and count all training earned since the last certificate.

The 5-year cycle should be maintained. A 3-year cycle is a very short period of time to get every System Controllers Off Shift to get his CEH hours. .

For the transition from the 5YR to 3YR certification program, we suggest allowing credit for the CEH received one year before the implementation of the new guidelines. In addtion, there should be an inclusion of a prorated number of hours for a System Operaotor whose certification

Draft for Comments

Page 74 of 110

July 28, 2004


Gordon Pietsch


Great River Energy gpietsch@GREnergy.com expires in the first three years of these guidelines. A more detailed transition plan is required to understand the impact of changing from the existing 5-YR program to the proposed 3-YR program.

We do agree with the transition plan with the following requirements. We feel all four specialties should have equal requirements of 180 hours of

CEH's over a period of 3 years. 30 of these CEH's would be on NERC policies. We believe there should be an alternative method of recertification that would allow all four of the specialties to accumulate

50% of the required CEH's plus retest every three years. With these two alternatives avaliable it would allow for choice, flexability and unforseen situations that may occur at a company or for an individual system operator that would not allow them the time to accumulate the 180 hours. 30 of these hours would still be required on NERC policies.


1. See our comments on the transition period under the "Preamble" section. The transition period rules must be carefully thought out because of staggered expiration dates of current certificates. Personnel with dates expiring within a few months or a year of the transition date must be treated fairly, and consideration must be given to the difficulties in scheduling training for on-shift personnel.



Mark Meyer

MMEYER@wapa.gov




Will Behnke


Jule W. Tate


Operations Training

Progress Energy

1.) A NERC certified operator should have 3 years from the implementation of this program to accumulate the required CEH regardless of the expiration date of their certificate.

2.) When this is implemented will operators be allowed to claim CEHs already accumulated?

If retaking of the exam for recertification was retained as an option this would minimimize some of the record keeping burden associated with

NERC granted extensions, suspensions and revocations without having a lapse in certification credentials. If for what ever reason a person doesn’t meet the training requirements they have the option to recertify. Again a suggestion would be to have a re-examination test

A suggestion has been made to to have NERC honor the 5 year cerification as originally awarded for taking the test (prior to white paper approval) and have these individuals which fall under this "grandfathered clause" have the remainder of the time to accumulate the total required amount of CEHs to remain certified for the following three years after certificate expiration. Those with less then three years prior to renewal would have an option to retest or fulfill the CEHs requirements within the time remaining before recertification Individuals will still need to test to intially begin the CEH program..

Can CEHs earned before renewal process is approved be counted towards recertification? Example, CEHs earned this year be counted?

Can those who still have old certificates (those certificates that start with

Draft for Comments

Page 75 of 110

July 28, 2004

NERC System Operator Certification Phase II Administrative Guidelines jule.tate@pgnmail.com

Cochran, Bob

Xcel Energy


Heather M. Boykin





MISO SOTWG



"N" that were issued before the 4 exams were created) still use CEHs to recertify at the RA level? If not, are they required to take one of the new exams, or does the "N" certificate equate to one of the new certificates?

For Certified System Operators that have more than 3 years till their certification expires when the CEH program starts, be required to accumulate the specified CEH's by their certification expiration date or three years from the start of the CEH program? Also will Certified System

Operators that have less than 3 years till their certification expires when the CEH program starts, be required to accumulate the specified CEH's by their certification expiration date or three years from the start of the CEH program?

For the transition from the 5YR to 3YR certification program, we suggest allowing credit for the CEH received one year before the implementation of the new guidelines. In addtion, there should be an inclusion of a prorated number of hours for aSystem Operaotor whose certification expires in the forst three years of these guidelines. A more detailed transition plan is required to understand the impact of changing from the existing 5-YR program to the proposed 3-YR program.

I feel the option should always be available. Debra L. Yinger




Those who are on the current 5 - year plan should be allowed to retake the exam within 5 - years to maintain their current level. After that a 5 year plan should be maintained with CEH's at the currently proposed CEH numbers.

Please make the effective date of this new way of doing things some day in the future; rather than retroactive. Pleae make the effective date,

January 1. Please make effective date far enough out that entities can plan orderly transition.

I think that everyone HOLDING a current certification should be able to begin the program together. That would help to keep things simple and it would be more fair.

John Taylor

SPP

JTaylor@spp.org elm@dairynet.com

If retaking of the exam for recertification was retained as an option this would minimimize some or the recordkeeping burden associated with

NERC granted extensions, suspensions and revocations without having a laps in certification credentials. If for what ever reason a person doesn’t meet the training requirements they have the option to recertify. Again a suggestion would be to have a re-examination test.

Need to include some provision to prevent last minute recertifyting for 5 years by exam just prior to the implemantion of recertification by continuing education. Many operators are talking about timing a recertification exam such that take it just before this continuing education requirement goes into effect to avoid continuing education requirements for at least two years.

Keep testing as a means of maintaining certification, upgrade tests as necessary to keep pace with changes. For the last certification exam we had to study year old superceded guidelines to be "prepared" for the test.

That points to the test and maintenance of it as the problem, not the level

Draft for Comments

Page 76 of 110

July 28, 2004


Jane Cocker

System Operations


JCocker@RPU.ORG

Pat Budler

Energy Delivery


Robert D. Eubank



Snodgrass,Theodore M tmsnodgrass@bpa.gov of knowledge of the test takers.

More options need to be available and several points need to be clarified before implementation of this plan.

If the program is designed properly, taking the exam should always be an option, but one that doesn't make sense in most cases. If taking an exam is acceptable for the transition, why wouldn't it be acceptable to extend/recertify?

No additional comments. Support the concept.


SPP OTWG

KDuncan@spp.org


Rod MacNeill



Keith Comeaux

CLECO


Robert D. Vargus

Muscatine Power & Water bvargus@mpw.org

Seems as good as any except let'sa keep the 5 year term. This isn't punishment it's an attempt to increase the base familiarity and understanding of the folks who are system operators. If you don't set up something that is manageable without quadrupling training budgets you're creating a revolution not an enhancement.

19. Once approved, CEH requirements should go into effect on a future date (not retroactively) and preferably on a calendar year with a 6 months lead time. This would help companies plan resources and budgets. So following this recommendation a note would go out no later than July of 2005 that the program would be in place beginning January

1, 2006.

We support the transition plan. However, we suggest that on the date that NERC CE is implemented, all System Operators be provided that start date for their three year credential. The credential expiration date would then be three years later from this implementation date. This would allow companies and System Oprators to better co-ordinate training for staff within the same three year window for the majority of their System

Operators.

Keep the options descibed above, CEH's or retake the test for the foreseeable future not just as a transitional period. Present options.

I believe that changing from 5-year to 3-year Certificaton is going to cause a huge mess in paper work, undo hardships on a System

Operator to receive the continuing credit hours, and a substantial monetary hardship to most Companies that require Certified System Operators. I believe that over the long run this will drive personnel away from becoming a System

Operator when you combine this with the abnormality of working swing shift.

At this time, we are experiencing a shortage of experienced System

Operators due to retirements, marketing opportunities, and many other market driven factors that are leaving many control centers short handed.

In the short run, we can adapt to this. Over the long run it is much to taxing physically and mentally to run shorthanded. Do a spot check yourself and see how many Power Companies in the midwest are short

System

Operators (Certified).

Draft for Comments

Page 77 of 110

July 28, 2004


Section II — Program Rules

Rules for NERC-Certified System Personnel

1.

2.

3.

4.

5.

6.

7.

Selection of learning activities —

System operators must select appropriate learning activities for the credit hours to be applied to maintain their credential. Learning activities chosen must address knowledge and skills to meet tasks performed by that function.

(For example: a learning activity approved for maintaining a Balancing and Interchange

Operator credential will not be recognized for maintaining a Transmission Operator credential unless that learning activity has also been approved for Transmission Operators.)

1.1.

CEH will be recognized from NERC-approved providers and from NERC-approved learning activities only.

1.2.

General areas of study are: NERC and regional standards, policies and procedures; technical concepts; and the associated systems, processes and business rules related to balancing and interchange, transmission operations, and reliability coordinator functions. See Appendix A for recognized training topics.

Recognized learning activities only —

System operators must comply with all applicable credential maintenance program requirements, and CEH will be recognized only for learning activities where the CE Program sponsors have complied with the standards for NERC approval for issuance of CE hour credits.

Provider access to database —

Rules for providers to input information concerning CEH delivered when database is developed and process is determined.

System Operator access to database —

Rules for system operators to input information concerning CEH received when database is developed and process is determined.

Retain documentation

— The credentialed individual is responsible for the accurate and timely reporting of the appropriate number of CEH earned and must retain adequate documentation of their participation in approved CE learning activities including:

5.1.

5.2.

5.3.

5.4.

5.5.

Name and contact information of the learning activity sponsor,

Title of the learning activity and description of its content,

Date(s) of the learning activity,

Location (if applicable),

Number and type of CE hour credits, all of which must be included in documentation provided by the sponsor, and

NERC certificate number. 5.6.

In the absence of legal or other requirements, documentation must be retained until credential extension is granted.

Learning activity credit only once per year

— CEH for a particular course or learning activity will not be recognized for maintaining a credential more than once during a calendar year.

Exception: Courses dealing with emergency operations will be recognized no more than two times during a calendar year.

Providers whose approved status is revoked after granting CEH

— CEH granted by a

NERC-approved provider for a course or learning activity that had been approved for

Draft for Comments

Page 78 of 110

July 28, 2004


8.

maintaining a credential, will still be recognized if, subsequent to the course or learning activity taking place, the approved status is revoked.

Instructor credits

— 1.0 CE credit hour for each CE credit hour of a learning activity will be recognized towards maintaining the instructor’s credential. CEH will be recognized one time per year for a learning activity, regardless of the number of times the learning activity is given.

Comments:

Alan Gale



Mark Klohonatz


Operations


Karl Tammar

NYISO

KTAMMAR@nyiso.com

In item 6, what if an individual was to take 3 courses, all on different aspects of emergency operations? Would one of them not count? I can understand if they are IDENTICAL courses, and by the same provider, but the same learning activity should be allowed.

The exception should state "The same course dealing with emergency operations will be recognized no more than two times a calender year."

This same exception should be given to the instructor in item 8.

Paragraph 1.1 - CEH will be recognized from NERC-approved providers and from NERC-approved learning activities only. a.What will be considered NERC approved learning activities? b.How will the “learning activities” be approved by NERC? c.What are the requirements for providing a NERC approved learning activity? d.What will be required to become a NERC-Approved Provider?

Paragraph 2 - CEH will be recognized only for learning activities where the

CE Program sponsors have complied with the standards for NERC approval for issuance of CE hour credits. a.What are the standards for NERC approval? b.Will the standards be made available for comment?

Paragraph 6 - CEH for a particular course or learning activity will not be recognized for maintaining a credential more than once during a calendar year. a. What criteria will be used to determine if it is the same course or learning activity (ex. same course and same provider)? b. If the course has the same title but is conducted by a different provider will both count as CEH credit? c. If a particular learning activity is spread over multiple days during the year, will the hours involved in each day be considered as CEH credit?

Paragraph 6, Exception – Courses dealing with emergency operations will be recognized no more than two times during a calendar year. a.Does this refer to taking the same course from the same provider? b.To what degree will the required annual 40 hours of emergency operations training be applicable toward CEH credit?

The “Exception” noted in item 6 should be re-worded. It appears to say that an operator cannot participate in more than two training events related to emergency operations. The wording should be changed to say that "Emergency operations training (with the same learning objectives)

Draft for Comments

Page 79 of 110

July 28, 2004


Hannah Peterson

Training Specialist

Midwest ISO, Inc.


A. Glazner

AGlazner@fmtn.org

Matthew Sadinsky


Intl.

Matt@sosintl.com

Anita Lee, P. Eng.


Procedures


Operator anita.lee@aeso.ca may be recognized no more than two times during a calendar year.".

Instructors spend significant time preparing for training events. There should be some additional credit offered to acknowledge this.

There is concern about instructors who are currently NERC certified. Due to the potential to increase the number of training sessions provided, instructors may be placed in a difficult position to acquire the required number of CEHs to recertify. At a minimum, instructors should be given the number of CEH hours for a course that they developed and CEHs should be applied toward a percentage of the time spent researching and developing course material.

Support staff (people not on the desk like management staff, technical trainers, etc.) should have different training requirements to ensure they are qualified and up to date to provide the necessary training/support

I agree with awarding CE hours to training administrators for designing and implementing training activities.

Consider giving 1.5 hours CE credit to instructors teaching a course one time a year.

Linda Campbell

FRCC

LCampbell@frcc.com



Mark Meyer

MMEYER@wapa.gov

The CE provider should be responsible for the submission of data into the

NERC database.

Instructors spend significant time preparing for training events. There should be some additional credit offered to acknowledge this. We would suggest two hours credit for one hour of training.

AESO intend to implement Simulation Training on a regular basis on different emergency procedures. These training programs are valuable in system operator training and focus on different aspects of emergency operation. They should be recognized and accepted in the CE program and not limited to twice per year.

We are not sure how item 2 is different from what is stated in item 1. In items 3 and 4 we recommend removing the phrase "..when database is developed and process is determined." The whole document is based on there being a database and process. In item 6, what if an individual was to take 3 courses, all on different aspects of emergency operations?

Would one of them not count? We are not sure we understand what the exception means.

1. Section II, #6 refers to courses dealing with emergency operations. If emergency operations courses deal with independent information or scenarios, numerous courses should apply to continuing education.

Please clarify this.

2. Section II, #8 refers to instructor credential. Does this mean that all instructors will be certified? If this is a reference to maintenance of a

NERC operator credential (Transmission Operator, Balancing and

Interchange Operator, etc.) that the instructor may have, than this statement should be clarified.

3. Also concerning Section II, #8 the 1 CEH earned for each CEH taught by an instructor trying to maintain certification seems to be very conservative. Research indicates that it takes anywhere from 5 hours to

Draft for Comments

Page 80 of 110

July 28, 2004





Will Behnke

Alliant Energy willbehnke@alliantenergy.com amoore@txued.com

20 hours of work to prepare each hour of instruction. We suggest revising the number substantially upwards to recognize that instructors are becoming truly expert in certain aspects of system operation.

1.) Item 5 again places the burden on the individual to maintain documents pertaining to their training which is understood. There are other places in this document that also place the burden on the operator to submit or check to be sure hours are accounted for properly in the proposed NERC data base. Given all the responsibility placed on the operators to maintain their documents, check hours etc. there does not seem to be a need for an expensive data base which will ultimately be funded by users and/or companies where its use is not fully identified.

Individuals who are CEH providers and are NERC Certified System

Operators should be exempt from the training and certifications requirements for a least 2 years after their NERC credential expires, as is done with the NERC test committee members who receive a new NERC credential valid for 2 years. This options would be an incentive for CEH

Providers to become a NERC Certified System Operator. For a trainer to develop a training program and deliver it, it takes many hours for each hour of training delivered. If PCGC decides to only give it will be difficult for the trainers maintain their certification credentials. As mentioned above this would reduce the incentive for CEH providers to be NERC certified system operators. Currently there is no requirement for a CEH provider to be a Certified System Operator but only that the program they offer meet the NERC CE program criteria

A major concern of industry trainers revolves around having enough CEH providers with approved courses that qualify for the CEH requirement.

Using the above mentioned suggestion would help address this concern.

Personnel involved in instruction as a primary job task should always have the option to retake an exam as method of recertification.

TRWG believes that a person who is involved in the design and development of a training class should receive additional credit.


TRWG


Cochran, Bob

Xcel Energy


Dale Wadding


Center


Herbert Ezzell

WAPA

EZZELLH@wapa.gov


MISO SOTWG

Need clarification of relationship of certification CEH to mandatory emergency training. What constitutes a training hour needs careful definiton.

Companies need access to the CEH information for the operators they employ so they can monitor and plan the training needed to maintain their operator's certification. Otherwise, operators could allow their certification to lapse and a company could become non-compliant because they were not able to access the data.

Instructor credits should be allowed at a higher rate to recognize the preparation time required. Also, if the learning activity is related to emergency operations the instructor credit should be allowed twice annually to correspond with the allowance for operators.

CEH providers who administer and structure learning activities but don't act as instructors should be allowed CE credits in recognition of the time and knowledge required to perform their duties.

The record keeping process must allow the employing organization acces to audit the operators files to verify accuracy and to ensure the operator has every opportunity to meet the CEH requirements.

Utility trainers who provide CEH training and who are also NERC Certified

System Operators should possibly be exempt from the training and

Draft for Comments

Page 81 of 110

July 28, 2004




John Taylor

SPP

JTaylor@spp.org


WECC OTS


Pat Budler

Energy Delivery


Administrative Guidelines certifications requirements for a least 2 years after their NERC credential expires, as is done with the NERC test committee members who receive a new NERC credential valid for 2 years.

Another approach would be to grant utility trainers CEH credits for preparing a program. It can take many hours to develop and deliver any program for CEH credit. If the PCGC decides to follow its plan as described it will be difficult for the trainers maintain their certification credentials.



Item 8 - "maitianing the instructor's credential" should say maintaining the instructor's system operator credential, in case we require certification of training programs in the near future.

Item #2 states ". . . and CEH will be recognized only for learning activities where the CE Program sponsors have complied with the standards for

NERC approval for issuance of CE hour credits". This can be read that to be assured of getting credit for the CEH the operator is responsible to make sure the provider adheres to the requirements of the CE Program.

That obligation resides with the provider only. Item #7 recognizes if an operator successfully completes a course from an approved provider, that is later determined to have failed to comply with the program, the CEH for the operator remains valid Consider a rewording of Item #2.

Item #6 indicates that a particular learning activity will not be recognized for maintaining a credential more than once during a calendar year (twice for emergency operations). Since the purpose of training operators is to give them the understanding, skills, and ability to safely and reliably operate the bulk power system, it seems unnecessarily restrictive to limit credit for multiple deliveries of the same course, especially in the area of emergency operations. Any concern that entities will provide (and pay for), ineffective repeat training, just to fill the CEH requirements, is unfounded and would constitute gaming of the process. Training records reviewed during NERC Reliability Readiness Audits would reveal this type of gaming and if found could be dealt with.

Item #8 awards 1 CEH for each CE credit hour of a learning activity (once per year) toward maintaining the instructor's credential. Credit should also be given for the time and experience obtained when developing a

CE-approved learning activity. For example, if a CE-approved learning activity awards 8 CEH to the successful student, then 8 CEH should be available (one time only), to be divided among those who developed the learning activity.

The section on Instructor credits seems out of place. Nowhere in the white paper are instructor requirements discussed. It confuses more than clarifies and should be moved to a separate document.

The database should be set up so that if a provider enters attendance for an operator, the record will be applied to the operators credential. The operator should have the ability to add other courses where the provider doesn't enter the data or an error occurs. All subject to audit of course.

Utility trainers should earn CEH credits for developing a program. The

Draft for Comments

Page 82 of 110

July 28, 2004


Robert D. Eubank



Kathy Davis

TVA Electric System Operations adavis@tva.go normal ratio of development to delivery time is 8 to 1. If the PCGC decides to follow its plan as described it will be difficult for the trainers maintain their certification credentials.




NERC approval for issuance of CE hour credits". This can be read that to be assured of getting credit for the CEH the operator is responsible to make sure the provider adheres to the requirements of the CE Program.

That obligation resides with the provider only. Item #7 recognizes if an operator successfully completes a course from an approved provider, that is later determined to have failed to comply with the program, the CEH for the operator remains valid Consider a rewording of Item #2.

Item #6 indicates that a particular learning activity will not be recognized for maintaining a credential more than once during a calendar year (twice for emergency operations). Since the purpose of training operators is to give them the understanding, skills, and ability to safely and reliably operate the bulk power system, it seems unnecessarily restrictive to limit credit for multiple deliveries of the same course, especially in the area of emergency operations. Any concern that entities will provide (and pay for), ineffective repeat training, just to fill the CEH requirements, is unfounded and would constitute gaming of the process. Training records reviewed during NERC Reliability Readiness Audits would reveal this type of gaming and if found could be dealt with.

Item #8 awards 1 CEH for each CE credit hour of a learning activity (once per year) toward maintaining the instructor's credential. The once per year award to the instructor should be expanded to at least a minimum of twice per year. The certified instructor is going to have very little to to maintain his/her own credentials given the amount of time necessary to develop and present the programs. Credit should also be given for the time and experience obtained when developing a CE-approved learning activity. For example, if a CE-approved learning activity awards 8 CEH to the successful student, then 8 CEH should be available (one time only), to be divided among those who developed the learning activity.

1.2 Suggest developing a list of areas of study by group, 1) basic principles of interconnected system operations and system operator tasks as they relate to NERC operating policies and power system operations and 2) tasks/responsibilities associated with the operator's position/certification.

3. & 4. - intent is stated to provide provider and user access to CEH database, however no mention is made regarding access by operator's employer, unless employer is also provider. Employer needs to have access to determine continuing training requirements are being met.

5. This is in conflict with the Admin Guidance on CEHs. The provider is required to maintain documentation of completed CEH learning activities and must notify NERC of completion of activities by system operators.

The system operator should not be required to report CEHs, the provider should. Why should the individual system operator be required to

Draft for Comments

Page 83 of 110

July 28, 2004



SPP OTWG

KDuncan@spp.org


Rod MacNeill


Rod.MacNeill@bctc.com maintain documentation.

8. Needs clarification. Is this stating that when a certified individual teaches a class they will receive credit for the class they teach (one time only for year, regardless of how many times they present it)? Does it also imply that if a certified individual develops a training presentation, learning activity, but does not teach it they will receive training credit because they developed it?

20. Training development and delivery requires a large amount of time and should be given more credit. One rule of thumb often used is that it takes 25 hours of development to deliver 1 hour of face to face training.

We agree that credit should not be granted each time a class is taught, but trainers need more than a 1 for 1 because of the time involved.


NERC approval for issuance of CE hour credits". Does this mean that to get credit for the CEH the operator is responsible to make sure the provider adheres to the requirements of the CE Program? Item #7 recognizes if an operator successfully completes a course from an approved provider, that is later determined to have failed to comply with the program, the CEH for the operator remains valid. The obligation should reside with the provider only and be audited by NERC if required.

System Operator's should not be required to determine if a learning activity that is being provided is recognized. What is a CE Sponsor? We suggest that all terms be defined upfront.

Item #4 states tha company personnel assigned by the System Operator must be given access to database for entry and reviewing CEH's for planning and maintaining training requirements.

Item #6 states an exception, "Courses dealing with emergency operations will be recognized no more than two times during a calendar year." We are not clear on the intent of these words? If the intent is that "courses" dealing with emergency operations are limited to two per year - this is not supported. Multiple courses dealing with emergency operations should be encouraged, especially Restoration training. Restoration Plans should not change much from year to year and practice should be encouraged multiple times a year if possible but at least once per year. This type of training should be accepted for NERC CE hours as many times as they are completed each year. Also, other courses should be recognized more than once per year. Audits can be used to deal with courses that are seen by

NERC as being taken multiple times by the same person. The audit can determine if the course should not be accepted multiple times. Emergency training should be accpeted as many times as practiced as we want each

System Operator to be ready for this if required. Emergency operations cannot be praticed enough.

Item #8 awards 1 CEH for each CE credit hour of a learning activity toward maintaining the instructor's credential. Consideration should be given to award CEH's for the time developing the course in the amount of

CEH approved to provide the course. At least 1.5 CE credit hour should be allowed by instructors for developing and delivering a course. If an instructor is delivering a course more than once they should be allowed

CE hour credits each time they deliver it, not just once. Instructors learn new information each time they deliver a course. Each class is different.

Draft for Comments

Page 84 of 110

July 28, 2004


Keith Comeaux

CLECO


Thomas V Pruitt



Item #6 requires a better definition of what "a particulat course or learning activity" is. This seems to indicate that courses covering restoration case-studies or real-time response training, for example, will have to cover different topics and each be individually recognized as distinct courses if they are provided several times a year. I believe this is overly onerours on the training provider. I suggest the "exceptions" list should be expanded to include courses that deal with scenarios/case studies/contingency analysis that could cover a variety of scenarios, to avoid having to register new courses for each scenario presented.

A one-to-one ratio does not give the instructor any consideration for the time spent developing the learning activity. Suggest increasing this to 1.5 or 2.0 credits for each hour of instruction.

It is routine in other certification organizations for instructors to receive from 1.5 to 2 times the hours credit for a course they teach. Instructors learn far more and in more depth than the students they teach and it is reasonable to award them more credit.

Draft for Comments

Page 85 of 110

July 28, 2004


Appendix A

Recognized Operating Training Topics for Maintaining NERC System

Operator Credentials

Reliability Coordinator



Interconnected Power System Operations — basic electricity, production and transfer of energy, reactive power flow, MW and Mvar reserves, ACE components and concept, CPS and DCS components and concepts, formulating operational plans, concept of frequency control, evaluating interchange schedules, evaluate operating plans of balancing authority, evaluate operating plans of transmission operator, system control, telemetry, system protection, and system stability.



EHV Operations — system protection schemes, power system operations, power system component interaction, effect of generator injection on power flow, surge impedance loading, transformer saturation, and solar magnetic disturbance.



Emergency Operations — NERC, ISO/RTO, regional, and local policies and procedures, line loading relief procedures, load shedding, and emergency operating plans.



Power System Restoration — restoration philosophies, determining extent of outage, determining islands, synchronizing philosophies, black-start, and restoration plans.



Tools — SCADA, advanced applications, load forecasting, system state estimator, evaluating power flow, real-time contingency analysis, voltage stability analysis, transient stability analysis.



Communications — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, ability to write brief, concise reports of a system event or action.



Congestion Management



Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, and physical and cyber sabotage.

Balancing and Interchange/Transmission Operator



Interconnected Power System Operations — basic electricity, production and transfer of energy, MW and Mvar reserves, economic operation, system control, energy accounting, telemetry, confirm interchange schedules, and operate the integrated generation and transmission system.



Generation — monitor on-line generator performance, track dynamic Mvar capability, respond to frequency deviations, understand and respond to CPS and DCS, coordinate operational plans and unit commit/decommit schedules from generation operators.



Communication — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, and ability to write brief, concise reports of a system event or action.

Draft for Comments

Page 86 of 110

July 28, 2004




EHV Operations — system protection, system stability; monitor, implement and coordinate operating procedures, assess the reliability impact of planned and forced transmission outages.

 Emergency Operations — NERC, ISO/RTO, regional, and local policies and procedures, line loading relief procedures, load shedding, emergency operating plans, and implement emergency operation procedures.



Power System Restoration — restoration philosophies, black-start, and restoration.



Tools — EMS, SCADA, advanced applications (state estimation, real-time contingency analysis), load forecasting, and energy accounting.



Congestion Management



Outage Procedures — planning, switching procedures, protective card procedures, reporting, and communications.



Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, physical and cyber sabotage.



Market Operations — market rules, OASIS, NERC tagging, tariffs, transmission rights, and market tools.

Transmission Operator



Interconnected Power System Operations — basic electricity, production and transfer of energy, Mvar reserves and reactive power flow, economic operation, transmission system control, energy accounting, telemetry, system protection, and system stability.



EHV Operations — purpose and limitations of system protection schemes, understand power system operations, power operations and limitations of system components (breakers

[oil, gas], disconnects [manual, motor operated, air blast, whip], fuses), power system component interaction, effect of generator injection on power flow, surge impedance loading, transformer saturation, and solar magnetic disturbance.



Communications — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, and ability to write brief, concise reports of a system event or action.






Power System Restoration — restoration philosophies, black-start, and restoration.



Tools — SCADA, state estimator, real-time contingency analysis, and operator load flow.



Outage Procedures — planning, switching procedures, protective card procedures, reporting, and communications.



Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, physical and cyber sabotage.

Draft for Comments

Page 87 of 110

July 28, 2004


Balancing and Interchange Operator



Interconnected Power System Operations — basic electricity, production and transfer of energy, Mw reserves, understand ACE components and concept, formulating operational plans, understand concept of frequency control, evaluating interchange schedules, system control, and telemetry.



Generation — monitor on-line generator performance, track dynamic Mvar capability, respond to frequency deviations, understand CPS and DCS components and concepts, coordinate operational plans and unit commit/decommit schedules from generation operators, capabilities of different types of generators (peakers, combined cycle, coal, oil, gas, nuclear, hydro, geothermal), frequency response characteristics.






Power System Restoration — restoration philosophies, and black-start.

 Tools — EMS, load forecasting, and energy accounting.



Communications — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, and ability to write brief, concise reports of a system event or action.



Congestion Management — Understand concept.



Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, and physical and cyber sabotage.



Market Operations — market rules, OASIS, NERC tagging, tariffs, transmission rights, and market tools.

Additional Comments:




Water & Power


William Price

Transmission Group Leader

LGE Energy Services

The content appears good, except that the Reliability Coordinator topics should include all of the topics allowed for the Balancing and

Interchange/Transmission Operator.

The three topics that were not included, Generation, Outage Procedures, and Market Operations may not directly relate to the Reliability

Coordinator position. However, since NERC intends to allow persons holding a Reliability Coordinator certification the right to operate in any of the other positions it is prudent to include all of the knowledges required for those positions in the training required for a Reliability Coordinator.

On a different note, this policy does NOT address retirement. When a

System Operator retires his certification continues until expiration. At that point, not having completed the required CEHs the certification is suspended, and the suspension recorded. A System Operator should be able to notify NERC of their intent to not renew their credential. This way, if the System Operator decides to return to the profession they can renew their certification without the documentation of a suspension on their credential.

I personally do not like the continuing actions toward dispatchers. I would like to know how many blackouts dispatches have caused in the USA? It seem to me that NERC is picking on dispatchers because they are an easy

Draft for Comments

Page 88 of 110

July 28, 2004


William.Price@lgeenergy.com

Cummings, John M

NWMT

John.Cummings@northwestern.com

Herbert Ezzell

WAPA

EZZELLH@wapa.gov

Paul Steinberger on behalf of MISO

SOTWG

American Transmission Company psteinberger@atcllc.com

John Taylor

SPP

JTaylor@spp.org target. The MISO was setup to coordinate outages, power flows, and generator outages in their footprint. What happened on 08/14/03? How many certified operators where working? What good did it do? Since then

NERC has come down on the dispatch people group very hard.

Dispatcher just put the systems back together.

I think getting training is good but put the pressure where it truly belongs.

Put in on the companies who do poor maintenance, who do not have enough people, and are worried about the bottom line.

Thanks for the input,

I believe the 60 CEU (hours) per year is too much. You are causing folks with many years of experience operating transmission and generation to look for early retirement; this hurts grid reliability.

Many of us are responsible to get our own CEU's without much assistance from our employer. The 60 hours proposed in the white paper could demand quite a bit of financial commitment by the operator, especially if there is travel involved. This makes early retirement a viable option.

I don't think it would be wise to encourage them to leave.

A reasonable annual CEU requirement is 4 days per year for 32 hours annually.

I also believe that whoever put the Physical and Cyber security chapter in the final August 14, 2003 report may have done so with good intentions, but disastrous affects. By making companies spend money on physical and cyber security (which had nothing to do with the blackout), that money is not available for training or mapboards or any number of things that would actually help grid reliability.

Good Luck in your efforts.

The training topics for Reliability Coordinator must include all areas of responsibility outlined by NERC Policy 9. The Reliability Coordinator

Credential is the senior (umbrella) certification, therefore, the certifications must cover all training required for all subordinate certifications.

Utility trainers who provide CEH training and who are also NERC Certified

System Operators should possibly be exempt from the training and certifications requirements for a least 2 years after their NERC credential expires, as is done with the NERC test committee members who receive a new NERC credential valid for 2 years.

Another approach would be to grant utility trainers CEH credits for preparing a program. It can take many hours to develop and deliver any program for CEH credit. If the PCGC decides to follow its plan as described it will be difficult for the trainers maintain their certification credentials.


Many companies may have to depend on contractor services to provide the necessary training. Will vendors and other contractors find the NERC

CEH training lucrative enough to enter the business thus providing adequate opportunity for the industry?

Need to make sure we are not too prescriptive. Suggest adding words that clarify that these are partial lists, other more job-specific topics may be appropriate.

Draft for Comments

Page 89 of 110

July 28, 2004


Alexander Brinis abrinis@bellsouth.net

John P Arcuri

Edison Mission Energy Marketing and Trading

JArcuri@edisonmission.com

Deacon, Robert P rpdeacon@pplweb.com

Robert A Damico

System Operations, Manager

Allegheny Power

RDAMICO@alleghenypower.com

I believe that there should be an option for the SO whose certificate is about to expire to forgo the continuing education credits and just retake the examination. Additionally, the imposition of a revokation period of one year may infringe on the individuals ability to find a job since he can't retake the test until after the revokation period of one year is over. For example, if you happen to be out of a job just after your certification expires and you don't have enough credits, then whatever company intends on hiring you, will have to provide you with the credits through training instead of just paying for the exam fee. In short, if an individual can prove that he or she is qualified by passing the test, then the revokation period makes no sense. The other point I would make is that if an individual's certificate is valid for 5 years from now, then the certificate should expire 5 years from now like it says on the certificate and not 3 years from now. That doesn't make much sense either.

My perspective is that of a former plant operator and generation dispatcher in a merchant environment. The level of knowledge of interconnected operation by merchant dispatchers is typically not on par with their utility dispatch counterparts. Their background, training and experience is completely different. Merchant dispatchers can impact system reliability through their direction of the plant or lack of understanding of RTO instructions. It is important that you encourage these folks to improve in these area. PJM is taking the lead on this with their new exams.

I work for a merchant power gen company, where NERC certification is not required. Both my current and previous employers encourage maintaining professional certifications, even when they are not a direct requirement for the job, as in my case. However, you need to consider that there is a limit to the resources we can devote. This will discourage those who don't have the cert from obtaining it, while causing others to have to drop the cert because they are unable to complete the requirements. In the end, a process that was intended to raise the reliability of the system will actually jeopardize it, since level of knowledge will drop in some areas. Please consider either providing a generation only option for people to qualify, or reduce the continuous training requirements to make the other options fit the budgets of smaller participants.

I appreciate any feedback you can provide.

I think NERC is missing a major point of reality in many energy companies today. Until your recent announcement, my management has supported my personal efforts to remain current and certified in all areas related to my operational responsibilities (current NERC Reliability Coordinator, PJM

Generation & Transmission certifications), but will NOT support the future required time and expense (time away from the job) required to recertify based on CEU's. I think the testing/exam option or an online CEU option should be considered for Power Dispatchers (like myself) that actively remain current on the NERC and PJM principles and policies, but cannot take time away from the job to remain certified under the proposed CEU requirement.

I think this is a great idea. I'm sorry it took so long to get started as I'm currently studying for my test. The employer should cover all costs associated with this and give the operators time to complete this training.

Draft for Comments

Page 90 of 110

July 28, 2004


Colleen Frosch

ERCOT Shift Supervisor cfrosch@ercot.com

Gary Markwart

Control Room Supervisor

Montana-Dakota Utilities Co. gary.markwart@mdu.com

Ronald D. Green

American Electric Power

Transmission Operations

Manager Training & Development rdgreen@aep.com

I think the System Operator Certification Continuing Education Program will be a great program. I agree that System Operator's will get more out of CE classes, which we enable us to build on our skills and knowledge much more so than re-taking a test every 5 years.

1. I believe the required hours are an over kill compared to other licensed professionals. Typically, this does vary by states, most requirements for

Architects, Lawyers, Accountants, Nurses, Teachers, Dentists, emergency medical technicians, paramedics are 20 - 30 hours per yr when figured out no matter if there recertification is 2 - 5 year span.

2. There is no mention of clock hours versus contact hours or CEU's

Typically 1/4 college credit = 10 clock hours, 1 semester hr = 15 clock hours.

3. I think there should be a time period you need to work before taking the test (1 Year). That would give more validity to job knowledge then just passing a test.

4. There should be a yearly minimum rather than just total recertification amount to help promote on going and consistent training programs rather than a few jam sessions.

5. If you do not meet the required hours to become recertified and your certification is suspended, I think reinstatement by presenting evidence of having completed the needed hourly requirement within the time period prior to the date of applying for reinstatement. I don't like the idea of retesting because that is not what we are trying to achieve. There is no revoking just suspension. The original expiration date is maintained. I can't believe any company can afford to keep their operators in suspension very long. Once they are in suspension and can't work the desk I guess they can spend all their time training.

6. I don't like the large difference in CEH's between the different credentials. I don't feel that reliability coordinators have much more responsibility as Control Area operators.

1. The number of CE hours required for each of the 4 System

Operator Categories seems too great for initiation of a new program. The hours should start at a lesser requirement (about half of that proposed for each system operator classification) until staffing and NERC approved providers and training activities are adequate to support greater hour requirements. For example, a transmission operator requirement would be more practical at around 60 hours over the 3 years to start the program (not the 120 hours presently proposed in the draft). This would be more practical and feasible for the initiation of the program. The hours could be adjusted in the future (if deemed necessary) as the extension program seasons and operating entities have had time to increase their operator staff to handle the training.

Alternate approach – Why test based on 5 years and CE train based on 3 years. Make the CE Certification program also based on 5 years and keep the hours as proposed (120/5 = 24 hrs average per year for a

Transmission Operator). 24 CE hours per year is a much more practical figure for the hours than the proposed 40 hours per year specified in the white paper. This hour requirement would be large enough to hold as the

Draft for Comments

Page 91 of 110

July 28, 2004



WECC OTS


Administrative Guidelines permanent requirement.

2. Suppose there is a difference in the hours reported to NERC by a

System Operator and the hours reported by a provider, or a provider fails to report hours for any reason (such as a contracted provider).

What is the resolution process?

3. In Appendix A – Recognized Operating Training Topics, NERC,

RTO/ISO, Regional, and local policies and procedures are listed as CE subtopics of training under other other topics such as Emergency Procedures.

NERC Policies and Requirements along with corresponding RTO/ISO,

Regional and Local policies and procedures should be listed as separate CE training topics so all such training can be specifically counted toward the

CE requirement and toward the 30 CE hours of NERC Policy training required in the white paper for all system operators over the 3 year period.

4. The document does not address or allow relief for System

Operators who do not attain the required CE hours due to circumstances beyond their control, such as long term illness, military duty, or other uncontrollable absence from the job. Should the program provide a method to request extension related to such circumstances? Loss of employment or other penalties as a result of Certification suspension/revoke may offer legal challenge to the program.

5. Trainers may be disadvantaged when delivering repeated sessions of the same learning activity, in contrast to trainers who deliver only one session of multiple courses, as the trainer who delivers repeated sessions can only count the hours toward their own certification once, whereas delivery of multiple courses allows a trainer CE hour credit for each. Also, no CE hours credit is given to a trainer for training development.

6. Should there still be the option to re-test for recertification every 5 years? The white paper states "retaking the exam will not be an option".

Some professionals voluntarily hold a NERC certification (such as engineers and managers) who the Certification Program Guidelines bar from re-examination for recertification. Many of these individuals, whose intent was to retest every 5 years, may be discouraged from pursuing their voluntary recertification due to CE time requirements to attend proctored CE training.

Categories:

The proposal requires a specified number of CEH in the categories of

NERC Policy and Area of Credential (with a subgroup of Utilization of

Simulations), in addition to an overall total number of CEH. The overall total number represents the minimum number of CEH necessary to fill the categories. Depending on how the training is planned it is possible to exceed the 240 CEH for the RO (for example) without filling all of the category requirements and being deemed deficient. The two categories to earn CEH should be in the Area of Credential and in Professionally Related.

Singling out NERC Policy implies that a training program wouldn't include enough time on the NERC Policies that form the basis of how we operate the system. This is an unfounded assumption and ignores requirements to study regional or company specific policies or procedures. The proposal ignores the category of Professionally Related that is part of the current

CE Program. For example, if a BI operator takes a course on system

Draft for Comments

Page 92 of 110

July 28, 2004


Mark R. Henry, P.E.

Manager, ERCOT Compliance mhenry@ercot.com elm@dairynet.com

Timothy Hird

Senior Transmission Coordinator

MidAmerican Energy

Chairman DETC UMW APDA

TEHird@midamerican.com dyanmics that is not part of the BI credential, the CEH do not count toward this requirement. If the number of required CEH (and other training requirements) remains onerous, courses like this would not be attended, leaving out the benefits that a breadth of understanding gives as each operator understands other aspects of system operations.

Hours

We should require the number of CEH necessary to provide sufficient, quality training to keep the system operator up-to-date and refreshed in the knowledge and skills necessary to safely and reliably operate the system. An examination of how many hours are appropriate to justify maintaining of the credential requires knowing whether the NERC 5-day training requirement (which states it "is in addition to other training requirements") is in addition to this proposal, or can be part of the proposal (if the 5-days are CE approved). OTS is aware the NERC 5-day requirement isn't a PCGC requirement, but this determination must be known to fully evaluate the appropriate number of CEH to maintain the credential.

Regardless, it appears that the CEH required are excessive - the goal of having trained and prepared operators can be accomplished with fewer hours. The OTS recommends the 5-day training on emergencies be allowed to count toward maintaining a credential (if CE-approved). Even then, the number of hours required seems excessive.

The PCGC needs to clearly state in the document the NERC Board approves, whether CEH earned between the date of Board approval and the subsequent program implementation date, will count toward maintaining a credential. In other words, state that if the program doesn't start until a database is implemented, whether CEH earned between BOT approval and implementation will count. OTS believes the CEH should count.

Appendix A - shouldn't there be "Recommended Operating Training

Topics" list for the BI and for the TO, then BIT is the two lists combined, and the RO is the two lists combined, plus some specifics to the RO?

As long as the list is conceptual, and additions are possible, it is okay. I suggest that the topics be put in a table and check which topics can be applied to each type of certification, since the material covered is very similar, if not identical (same text for "emergency operations" appears in all categories).

This system completely overlooks/negates the best training operators in all

4 certifications undergo on a daily basis, OJT, on the job training. You are certifying trainers to simulate & signoff on what we do daily, and not

"crediting" us with having learned anything from dealing with the real thing, real time. The 'simulations' would be sadly lacking in authenticity without the information gathered in realtime yet no means of accrediting those involved.

Not enough company/control area specific training recognized.

The Dispatcher Education and Training Committee (DETC) of the Upper

Midwest American Power Dispatchers Association (UMW APDA) has looked at the System Operator Certification Program Administrative Guideline and have made the following comments:

CEH’s should fall more into line with other professions. Here is the actual

Draft for Comments

Page 93 of 110

July 28, 2004


Jane Cocker

System Operations


Administrative Guidelines number of hours required for other professions in Minnesota:

Police officer 48 Credits/3 years

LPN 12 hours/2 years

RN 24 hours/2 years

Physician 75 hours/3 years

Prof. Engineer 24 professional development hours/2 years

In the case of nurses, the conversion of college credits to hours is 1 semester is equivalent to 15 hours; 1 quarter is equal to 10 hours. We place our lives in the hands of these individuals on a daily basis, yet their

Continuing education requirements are quite less than those proposed in the CEH white paper.

Companies may not have the option to send operators to training. A test out option may be needed if operators are short on CEH’s. An operator is responsible for obtaining the required number of CEH credits within the three year certificate period. If the operator is unable to accumulate the proper number of credits, might the operator "test out" of a topic prior to the certification expiration to keep the certification.

CEH requirements should be an equal amount for all levels, Transmission

Operator, Balancing and Interchange Operator, Balancing, Interchange and Transmission Operator, and Reliability Coordinator Operator. Why is

NERC trying to “pigeon hole” operators into certain credentials?

Specifically, why is NERC trying to transition operators out of the

Reliability Coordinator Operator credential? Isn’t a broader knowledge base more desirable in any operator position?

NERC should concentrate on policy training as they do now. There should be 30 hours of policy training over 3 years.

There is not enough time in the year to cover all shifts/trainings and not only is there not enough time, but also there are not enough CEH offerings.

The company costs associated with meeting the proposed requirements will be prohibitive. (Travel, lodging, meals, overtime, etc.)

Does Appendix A of the white paper supersede Appendix 8B1 of the NERC

Operating Manual? They are similar in scope, but 8B1 is more detailed.

Goal 1: “Establish mandatory continuing education criteria to maintain certification with the goal to improve system operator performance by increasing their knowledge in their job tasks” has not been met by this program as currently written.

NERC needs to project the administrative costs associated with the CE program.

The 5 year certification period associated with testing should remain in place for those entering a new position which requires certification, or for those entering a position requiring an upgrade in certification.

I think continuing education to maintane certification is the way to go, however it should not be rushed into before everything is in place. It should also be set up so it can realistically be accomplished without

Draft for Comments

Page 94 of 110

July 28, 2004


JCocker@RPU.ORG

Robert D. Eubank



Nuno, Enrique D ednuno@pplweb.com

Administrative Guidelines putting even more pressure on operators than there already is.

Categories:



Simulations), in addition to an overall total number of CEH. The overall total number represents the minimum number of CEH necessary to fill the categories. Depending on how the training is planned it is possible to exceed the 240 CEH for the RO (for example) without filling all of the category requirements and being deemed deficient. The two categories to earn CEH should be in the Area of Credential and in Professionally Related.

Singling out NERC Policy implies that a training program wouldn't include enough time on the NERC Policies that form the basis of how we operate the system. This is an unfounded assumption and ignores requirements to study regional or company specific policies or procedures. The proposal ignores the category of Professionally Related that is part of the current

CE Program. For example, if a BI operator takes a course on system dyanmics that is not part of the BI credential, the CEH do not count toward this requirement. If the number of required CEH (and other training requirements) remains onerous, courses like this would not be attended, leaving out the benefits that a breadth of understanding gives as each operator understands other aspects of system operations.

Hours

We should require the number of CEH necessary to provide sufficient, quality training to keep the system operator up-to-date and refreshed in the knowledge and skills necessary to safely and reliably operate the system. An examination of how many hours are appropriate to justify maintaining of the credential requires knowing whether the NERC 5-day training requirement (which states it "is in addition to other training requirements") is in addition to this proposal, or can be part of the proposal (if the 5-days are CE approved). OTS is aware the NERC 5-day requirement isn't a PCGC requirement, but this determination must be known to fully evaluate the appropriate number of CEH to maintain the credential.

I would like to recommend the 5-day training on emergencies be allowed to count toward maintaining a credential (if CE-approved). Even then, the number of hours required seems excessive.

The PCGC needs to clearly state in the document the NERC Board approves, whether CEH earned between the date of Board approval and the subsequent program implementation date, will count toward maintaining a credential. In other words, state that if the program doesn't start until a database is implemented, whether CEH earned between BOT approval and implementation will count. OTS believes the CEH should count.

Appendix A - shouldn't there be "Recommended Operating Training

Topics" list for the BI and for the TO, then BIT is the two lists

This is a joke you should be ashamed of yourselves! I have RO authority which even with the PJM accredited seminar I will not be able to meet. I only get 22CEU's off the seminar each year how on God's green earth am

I gonna maintain my certication? Ive taken this test 2x over the last 5 yrs

(Initial & recert) & now if I meet the CEU's I'm gonna lose my

Draft for Comments

Page 95 of 110

July 28, 2004


Joe Rion rrgjrion@midwest.net

Kathy Davis



Administrative Guidelines certification? What a joke! As it is NERC certification is a joke in the industry with these new mandates it will continue to be a laughingstock.

How you can have training that does not meet the mandates for minimum

CEU's each year is beyond me. Get with the program!

It looks like you have an idea where you want to head.

I don't think you have thought out everything.

Each company is different, some have just enough people to cover the shifts, some have more than enough. Some companies have union system operators and some don't.

Over the last four years where has NERC been, I haven't seen or heard from anyone. I would think that you would have checked to see if I was getting the training I needed. I would have thought that the systems operators working on this project would have asked for advice of ideas from the working system operators.

I worked all June with 4 days off, I worked all July with 2 days off, where would I have stuck a day or two to go somewhere and train. It would have been hard enough to work an extra two hours on computer time. If

I get hurt or injured and need an hour or two to complete continuing education credit I may not be able to go get them on time. At my place of work I can't come in if I have a cast on, so any training time would be lost to me till I get approved to come back to work.

Allot of system operators aren't going to reply to this so I think you need to contact them by mail to solicit their opinions. The NERC manual has grown by leaps and bounds, looks like you have added pages to justify your existence.

The NERC manual should have less pages than before, lots of stuff in there not needed.

I will notify my legeslators what I think of this program and NERC. Nerc has failed to justify it's existance to me.

Operator Training Topics - training topic listing is incomplete. For example:

> No listing of ACE, CPS, or DCS under Balancing Operator Certifications

> Voltage stability analysis for Transmission Operators

> Synchronizing philosophies under Balancing and Transmission

Operators

RECOMMENDATION:

Based on the fact that the initial certification exam verifies competence of system operators in basic principles of interconnected system operations and system operator tasks as they relate to NERC operting policies and power system operations, the continuing training requirements to get a certification renewed should be based on the same. This would hold the individual system operator responsible to maintain his professional certification.

The system operator's employer must provide the necessary on-site training on position specific responsibilities and tasks prior to allowing that sytem operator to independently assume shift responsibilities. This ensures understanding of the operating entitie's policies and procedures for both normal and offnormal/ememgency conditions. NERC

Policies/Standards should place the responsibility for continuing training in position specific responsibilities and tasks on the utility. This continuing training should ensure operators remain competent in the position specific responsibilities and tasks.

21. In Appendix A – Recognized Operating Training Topics, NERC,

Draft for Comments

Page 96 of 110

July 28, 2004


SPP OTWG

KDuncan@spp.org


Rod MacNeill




RTO/ISO, Regional, and local policies and procedures are listed as CE subtopics of training under other other topics such as Emergency Procedures.

NERC Policies and Requirements along with corresponding RTO/ISO,

Regional and Local policies and procedures should be listed as separate CE training topics so all such training can be specifically counted toward the

CE requirement and toward the 30 CE hours of NERC Policy training required in the white paper for all system operators over the 3 year period.

22. We recgonize that numerous industry volunteers have committed a tremendous amount of work and effort in the development of this concept. The intent behind this effort is appreciated and we are in agreement that operators deserve the best training.

Comments on the categories and number of hours:

Categories:



Simulations), in addition to an overall total number of CEH. The total number represents the minimum number of CEH necessary to fill the categories. Depending on how exactly the training is planned, it is possible to exceed the CE hours without filling all of the category requirements. We believe that Professionally Related should also be allowed and cross-training between Certifications be encouraged. The two categories to earn CEH should be in the Area of Credential and in

Professionally Related learning. Professionally Related learning should be allowed as it was in Phase I.

Singling out NERC Policy implies that a training program wouldn't include enough time on the NERC Policies to form the basis of how we operate the system. This ignores any requirements to study regional or company specific policies or procedures. As an example WECC policy training as a sub-region of NERC is not clearly recognized and WECC policy training should be. The proposal ignores the category of Professionally Related that is part of the current CE Program. For example, if a BI operator takes a course on system dynamics or EHV operations that is not part of the BI credential, the CEH do not count toward this requirement. Courses like this may not be attended by all System Operators in a company leaving out the benefits that provides each System Operator other aspects and understanding of all system operations. Also, company specific training is not specifically recognized and this often forms a basis for learning that is built on.

Hours:

The number of hours of required training for each System Operator

Credential is too high. Not clear where the number of hours came from.

This could be expensive and there is not enough recognition for training already being done for system operators. There does not appear to be any recognition for NERC required training (5 days per year), regional training

(WECC annual requirements), company required training, including initial and ongoing training. Suggest that CEH's include and recognize all of this training. CE has been good so far, as it has formalized training that has already been developed and is already being delivered. We do not want to lose that by making the required hours too high that training gets watered down as we move to meet a requirement for hours that is too high.

We suggest that five days of required Emergency training be considered along with a Certification exam on NERC Policies be an option to maintain a Credential.

Appendix - There is duplication in the lists of BI, TO, BIT and the RO. It is

Draft for Comments

Page 97 of 110

July 28, 2004


Gary L. Condict

Aquila Inc.


Keith Comeaux

CLECO


Allan George

Sunflower Electric Power

Corporation ageorge@sunflower.net

Richard Lindner

Senior Power Dispatcher

Puget Sound rick.lindner@pse.com

Administrative Guidelines not clear what the recognized training topic lists are meant to do? Suggest a list of what every System Operator is required to be trained on and a separate list of what each Credential is required to separately train on and for. Recognize cross training between credentials as either

Professionally related or as directly related to system operations training.

It is still unclear to me if these new requirements will replace the directive for 5 days of emergency training each year. This needs to be spelled out in clear terms with no room for interpretation, including what the meaning of a "DAY" is!

I recommend that the emergency training to be included in the NERC CE requirements.

Is it a calendar year or June 30 to July 1? Will courses we take in the fall of 2004 count toward the CE when the new rules go into affect.

I recommend NERC to be very specific in spelling out the requirements.

Again, do not leave it up to the interpretation of the operator or company.

I do not want my insistence for offering options to take away from this project. Numerous industry volunteers have committed a tremendous amount of work and effort in the development of this concept. The intent behind this effort is appreciated and we are in agreement that operators deserve the best training methods available. We do not oppose this approach as an option but do not support it as a mandated method.

I feel that the Certificate should remain effective for 5 years. I certified first with the SWPP in 1995, then obtained a Balancing, Interchange and

Transmission Certificate with NERC in 1999, and recertified my Balancing,

Interchange and Transmission Certificate with NERC in 2003. I strive to stay abreast of current education and training opportunities as much as possible. Our industry demands continuous education. I don’t feel that 3 years provides enough time to acquire all CEH, actually 2 years and 9 months since 90 days are required to apply CEH prior to the operators certificate expiration date. If an operator does go into suspension and is successful in completing that certificates CEH he will be forced into an even shorter time period to acquire the next CEH’s.

I also do not think it is appropriate to require that an operator who is suspended not be able to perform any task that requires an operator to be

NERC certified. If the operator held a certificate and was obtaining CEH, he is still knowledgeable and has the skills to be an operator. It seems appropriate to ‘label’ him as suspended and allow the one year to complete the necessary CEH needed to recertify him all the while he continues to work. We all realize this industry is one that “on the job training” is the best learned lesson.

It also seems bias to say that to become a certified operator you must pass the NERC test which certifies you for 3 years, and to recertify you must complete the necessary CEH and if you don’t you will be suspended for one year at which time will be the first opportunity to retake the test.

If the test is the means to verify you have the basic knowledge to be certified, why is it not an option to recertify? I understand the added educational benefits of continued education .

I would first like to commend the PCGC for bringing up the issue of mandatory training for those of us in the Power System Operations field. I believe that it is critical that annual training takes place to ensure the competency and professionalism in this ever-changing industry.

My concern, however, is the amount of training required, and the ridged

Draft for Comments

Page 98 of 110

July 28, 2004


Earl Cass cass@wapa.gov

Administrative Guidelines timeline in which to accomplish this task. I am currently certified as a

Reliability Coordinator and understand that to maintain this certification I need 80 hours of Continuing Education, 40 hours of Emergency Training, and 5 hours of WECC training applicable MORC. It is also my understanding that these hours can not overlap, so in essence, I need to receive 125 hours of training each year.

Much of the training being offered will require us spending a portion of our time traveling. Again if I may use myself as an example, by attending the

Training-the-Trainer Workshop held in St. Louis last week, I was able to receive 10 CEH's. However in order to receive those CEH's, I was required to attend 16 hours of classroom training and spend an additional two days traveling. So in reality, and for budgetary purposes, I was away from the office for 32 hours and in return, received 10 CEH's. Roughly a 3:1 ratio.

On top of that, I still need to receive training specific to my duties and responsibilities for the utility I work for. This year alone, I will have received training on our new EMS, OATI, webSAS, our new energy scheduling accounting system, and our company Standards of Conduct.

Unfortunately, I don't believe that this "internal" training falls under the

NERC and WECC training specified above.

Puget Sound Energy currently employs 13 dispatchers and 1 manager requiring certification. In all honesty, with our current staffing levels and other requirements facing our department I fail to see how we can accomplish this task. This year alone we will have worked on our NERC

Readiness Audit, RMS, USF, CA Certification, newly acquired Wind

Generation, Reserve Sharing issues, and obtaining the classification of a

NERC Continuing Education Provider. The list goes on and on.

I am concerned that the proposed Certification Training as it currently stands will be too great of an obstacle for many utilities to overcome and may result in sanctions against those utilities for non-compliance.

However, what may even be worse is that some System Operators/Power

Dispatchers may lose their certification through no fault of their own.

Even with the best of intentions, a department's training plan can be derailed by retirement, STD/LTD, or simply by staff turnover.

I fully support the concept of Certification through Continuing Education.

However, I believe that the proposed requirements and the time-line set forth to achieve those requirements are, for the most part, unobtainable for a large portion of the industry. I would hope that initially, the hours required can be reduced, the course requirements modified to allow overlapping of certain classes, and the time frame for implementation to be brought in phases over a more realistic time period.

Thank you for the opportunity to express my thoughts and concerns.

The bulk of my comments were submitted in a composite reply from

Western Area Power Administration . The following comments are general in nature and are mine .

The intent of the PCGC is to strengthen and improve the present

Personnel Certification Program through the mandatory accumulation of

Continuing Education Hours and I applaud that effort. However there

Draft for Comments

Page 99 of 110

July 28, 2004


Sanjay Dutta

CAISO


SDutta@caiso.com

Thomas V Pruitt


Administrative Guidelines should remain options of utilizing these accumulated hours or reexamination or both. There could be any number of individuals with varying circumstances where this would be a better option than what is being proposed. For instance, many support engineers, trainers, first line supervisors, second tier managers and in fact individuals at the Vice president level have chosen or are required by their companies to achieve and maintain NERC Certified status. This status is required of them by their companies because of the direct influence these individuals have on the day-to-day operation of the bulk electric power system. In order to satisfactorily perform their responsibilities they must receive training on a very broad spectrum of topics not included in your program.

While it is certainly understandable that the PCGC wishes to promote further training and accumulation of knowledge through the continuing education program, it is not clear why limitations appear to have been placed on the program. As with the present Certification Program, one of the most significant shortcomings is the fact that the present tests do not have questions on all aspects of the NERC Policies. If there are differences with respect to regional or interconnection practices or requirements related to the NERC Policies then there can be no questions on the exams regarding these policies.

As we move to a more diverse and defined hierarchy within the electric utility industry as the NERC Functional model proposes, individuals will become more specialized and less broad in their knowledge of the entire power system. First, we don’t allow exam questions concerning neighboring regions or interconnections, next we have exams that only focus on specific tasks and functions an individual may perform and now the proposal is to allow accumulation of CEHs only for those topics which directly apply to the certification an individual is holding.

I believe this will place an extraordinarily high and unachievable burden on the individuals tasked to provide and ensure reliability of the bulk power system. The emphasis is placed on the Reliability Coordinators to perform this function yet the tools and processes are not keeping pace with the demands and requirements. The last blackout pointedly emphasized the need for additional tools and training and the dangers of not providing these items to the system operators. The bottom line here is “Do not discourage an individual from broadening their perspective by acquiring or receiving increased knowledge and skills on a wide variety of power system topics just to satisfy a small minority that wish to have a narrow perspective.

CAISO would support a quick implementation of this program, so that operators through out industry could benefit from this program immediately.

This program spells out a certification and certification maintenance program that is well defined. This is not a bad approach, but very different from prior approaches to CEH based programs. It is necessary that the reasons for this approach be clearly explained.

The requirements portion of this whitepaper should be subjected to an open development process with balloting representative of the entire industry. Other training requirements should be consolidated with these, or at the very least coordinated with them.

Details on adminsitration (including a resolution/appeal process) need to

Draft for Comments

Page 100 of 110

July 28, 2004



Administrative Guidelines be as well defined as the requirements for the various credentials. In addition, support staff and other ancillary functions, which need to be fully cognizant of the requirements of operators, should have an avenue for maintaining certification.

Entities will be extremely challenged to meet the requirements of this new program: NERC will need to construct the administrative tools to track and audit not only individuals' records but also the increased number of approved courses and training providers, utilities will need to increase operator staffing levels, and training providers (both in-house and third party) will need to expand their capabilities to provide a number of new courses and serve a much greater volume of students. It is very likely that demand will outstrip supply. A progressive, phased-in approach would allow adequate time to increase staffing.

RECOMMENDATIONS

NERC should be focused on policy/manual content for certification training

- set minimum (e.g. 60/3 years) of policy hours for maintaining certification, across all credentials. Additional technical training, for example the 5 days of emergency training, and other training as needed, would be managed by the organizations who would be held accountable through compliance requirements. By setting up certification hours in this way, the certification standards would transfer easily to other groups as well, who aren't on the desk but who are working with operators on daily basis (e.g. Operations Engineers).

Need to have more options for re-certification than just continuing education. There are some shops that are just too small to maintain CE credit.

NERC's requirements should include the same number of hours for all the credential types otherwise makes for a logistics nightmare. If you need

120 to be a certified then why need set a separate limit for each credential type? If an organization has its operators certified as a RO (the highest level), regardless of their position, they have a better baseline of knowledge - generateion, transmission, etc. Why would an organization want to pigeon hole it's operators into one of the 4 credentials? It might end up "dumbing down" the industry.

The whitepaper doesn't address trainers that are CE providers, who develop the training. Trainers don't get credit for creative development.

Recommend a way for a Provider to identify a fulltime trainer who gets credit for development.


COMMENTS

It looks like the "Professionally Related" hours have been wrapped into the credential specific category. Please confirm. If so, will the Professionally

Related option go away on learning activity applications? CE is about maintaining level of knowledge needed to do job; not necessarily the training to move operators ahead.

"Level" the number of hours by implementing a minimum per-year basis

(e.g. 20/year) to avoid operators waiting until year 3 to get it all done.

Whitepaper proposes 30 hours of simulations/restoration requirement is over 3 years -- goes against Recommendation 6 of 5 days a year.

The procedures outlined in this whitepaper are cost prohibitive and time intensive. Record keeping will take development time away from Training staff.

How will record keeping be reviewed by NERC?

Draft for Comments

Page 101 of 110

July 28, 2004




Debra L. Yinger



Jule W. Tate

Manager, Power System Operations

Training


NERC Policies are not split out clearly by TO, BO, BIO and RO. As a result,

Operators will study all of the policies to be on the "safe side" - the RO level of knowledge. Therefore, why have different hour requirements between credential types?

Are there enough providers and CEH available for credit to cover the number of hours needed by all the operators in the industry (based on the required number of hours outlined in this whitepaper)?

What were the hour requirements based on? They should be based on job analysis of what is needed per job type to ensure the requirements are valid.

What do organizations do with the operators who don't have the required number of CEH within the 3 years and their certification is suspended?

They can't work and what is the organization to do?

TRWG believes that a statement should be included that this list of topics is not all inclusive, as there could be other appropriate topics that would be beneficial to system operators.

The above subjects are more than sufficient and cover a wide variety of appropriate material.

Walter Lorber

Director of Core Services


WLorber@RPU.ORG

Can training material approved for CEH's also be used to satisfy the five days per year of training and drills in system emergencies, using realistic simulations required for NERC Compliance, or is this a completely separate compliance issue?

We are very pleased the PCGC is working toward adopting a Continuing

Education option for extending System Operator Certification credentials.

It is important that this option be an opportunity to enhance a System

Operator’s job knowledge without placing a financial and scheduling burden on the individual entities to provide the CEH required for extending certification.

With the expected adoption of Version 0 in early 2005, the proposed implementation plan applies to the entities included in the NERC

Functional Model. Because of this, the guidelines should reflect the entities included in the NERC Functional Model. Since there is no Reliability

Coordinator in the Functional Model, the most apparent equivalent is the

Reliability Authority. If the Reliability Coordinator is a job function that remains, we suggest adding to the NERC Functional Model to eliminate confusion and provide consistency between Version 0, the draft entity

Certification Standards and the System Operator Certification

Requirements. In addition, if the Reliability Coordinator Operator

Certification remains as a separate certification level, we also recommend adding Reliability Authority as a level of Operator certification.

Although the NERC System Operator Certification Program is a separate program from the existing 40 HRS of System Operator training required by

NERC Blackout Recommendation 6a, we suggest that those responsible for developing training requirements at NERC work together when implementing these guidelines to eliminate duplicate training needs and adopt one training requirement for NERC Certified System Operators.

The PCGC is to be commended for seeking to improve the NERC system operator certification program. The proposed System Operator

Certification Program Administrative Guidelines is in itself a recognition of the role and importance of the SOs and the important job they do. Their expertise is critical to the operations of electric utility systems.

Draft for Comments

Page 102 of 110

July 28, 2004


Will Behnke


Howard Rulf

Manager Compliance and Training

We Energies

Howard.Rulf@we-energies.com

As a director having accountability for the system operations function of a small municipal utility, I have some concerns about the resource requirements of the proposed program. While we try to staff appropriately to allow time for training, retirements and other turnover sometimes leave us stretched. A three-year recertification cycle should accommodate some of that variability; however, it is not clear at this juncture when and how the recognized training will be made available. If significant travel time must be added to the required class time, the proposed training requirements impose a significant part of an FTE.

The number of CEHs proposed (120 - 240) appears significantly higher than for most professions. As a professional engineer in Minnesota, I’m required to obtain 24 personal development hours over two years. That’s a significant difference. Also, I don’t see a definition of CEH. My PDH requirement is simply classroom hours. Even if the CEH is classroom time, the 3 – 6 weeks in the classroom must potentially be doubled (6 – 12 weeks) for associated travel.

The difference in CEH requirements and subject matter for different credentials reduces the universality of the SOs and would seem to have the effect of limiting the recruiting pool of available operators for a given situation. Which, when tied to the increased expense of training, has the potential to significantly increase the cost of operating a control room.

I would encourage you to implement the program with:

Lower CEH requirements. Regularly review and assess training needs and options, and as training opportunities become better defined and more widely and economically available, adjust the hours as appropriate.

Less difference in the credential requirements for each specialty. A larger portion of the required CEHs for each specialty should be standard, with fewer specialized CEHs. This would allow operators to maintain multiple credentials.

Thank you for soliciting input. I encourage you to take time to digest the comments.

Supervisors, planning engineers and operations support personnel who currently hold a NERC Certified System Operator credentials are not addressed but should be. There are many support personnel who have taken the exam and maintain certification to become more familiar with

NERC policy and standards in order to better understand their jobs and job tasks of system operators. Some of these individuals work closely with reliability organizations and NERC to set policy and administer operating guides. There should be some criteria for them to use the time they spend on committees or work groups of reliability organizations to maintain their certification credentials.

We Energies Comments on Maintaining NERC System Operator Credential

Through the Use of Continuing Education Credit Hours

1. Is continued System Operator Training now the NERC CEH program?

2. All of NERC needs to coordinate what is being required for training.

There needs to be one document that states all training requirements, not willy-nilly throughout NERC policies and documents.

Draft for Comments

Page 103 of 110

July 28, 2004





Donnie Harrell

Sr. Analyst



3. The number of required CE hours is encouraging the industry to take the lowest cost option and lower certification levels rather than increase broad System Operator knowledge.

4. The number of required CE hours for recertification is too large. It should he half of what is stated. The other half could be documented discretionary training that may or may not have CE hours associated with it. We Energies has an annual system emergency training day for System

Operators and others related to how we will respond to challenges and problems during the peak load summer days. We are going to spend more total hours struggling with paperwork to continually recertify a yearly changing program than the total number of System Operator training hours that might be credited.

5. Even though the CE program states that the planned training activity segment of drills may qualify for CE hours, that does not appear likely to happen. Say, for example, that MISO sponsors a system recovery drill, how does MISO certify that a specific individual at a remote location really did participate and successfully completed some required evaluation?

They can’t. The drill that can be counted toward the five days of system emergency training won’t be counted in the CEH program. If an individual has five days of system emergency training in a year that is mainly drills, they will really need five days plus 10 hours of system emergency training for that year.

6. There do not appear to be training requirements for currently certified system operators who are going to raise their certification. All they have to do is pass the test for the higher level. The way it looks, I could get

120 CE hours in three years and lower my certification to Balancing and

Interchange Operator, have no CE hours for three years, then take the

Balancing and Interchange/Transmission test and be certified for another three years.

7. There still should be a testing option for certification renewal, possibly a different or more comprehensive test than the original certification test.

1.) Transmission Operator, Bullet item 1 "energy accounting" needs to be removed as this is a Balancing and Interchange Operator function.

2.) Balancing and Interchange Operator In bullet 1, the "production and transfer of power" are not needed in this category. This should be contained in Transmission Operator. Again in bullet 1, "formulating operational plans" is too broad of a statement. This needs to be defined.

In bullet 2, "tracking dynamic Mvar capability" is not needed in this category and should be included in Transmission Operator. Bullet item 4 is not needed in this category as this is a Transmission Operator function..

If the 40 hours of emergency training can be counted toward the required

120-240 CEH then I do not believe this is enough mandatory training. The

40 hours of emergency training required each year for your last three of certification would satisfy the requirement of 120 hours.

Will there be enough CE providers when this is implemented?

To insure current, up-to-date training we should look at having a two year certification program not a three.

Draft for Comments

Page 104 of 110

July 28, 2004






Mark Meyer

MMEYER@wapa.gov

Gordon Pietsch



Linda Campbell

FRCC

LCampbell@frcc.com

It is possible to take your required training the first year and not having any additional training for 2 to 2 years 10 months.

The instructor, developer should be rewarded by 1.5 or 2 time the CEH value.

What will the process for the instructor to receive the CEHs? Will he just be added to the roster?

1. The listing of topics in Appendix A is too restrictive and is incomplete.

The ability to add additional pertinent topics to each bullet in Appendix A is necessary. The review team should be able to discern whether a specific topic meets the categorization in Appendix A. For example, here are two reccomended additional topics:

a. Add Outage Procedures under Reliability Coordinator Training Topics

b. Add Congestion Management under the Transmission Operator

Training Topics

2. Consideration should be given to a broad expansion of training topics to be applicable to any of the certification specialties. The expansion would include all sorts of topics related the the electric power industry, electric power system operation and electric power engineering. For example, a person who is certified as a TO, and who has been in this job for many, many years, is going to find very little training that will expand his expertise in this particular area. However, if continuing education and profesional development in our profession is the desired goal, this person should have the option to study in related areas and accummulate CEHs for the effort. In our comment #5 under the "Preamble" section we suggested an alternate certfication for those personnel other than actual system operators. Should this suggestion be adopted, this expanded list of topics would be particularly appropriate.

We believe that NERC and the white paper over looked a large group of

NERC certified people that are not control room operators. These would include supervisors, engineers, and operations support personnel that are currently NERC Certified. We feel this group should be able to recertify every three years by taking only the test. Many of these people have other types of training that they are required to attend as part of their job that would not fall into the category of NERC certified CEH's.

We are very pleased the PCGC is working toward adopting a Continuing

Education option for extending System Operator Certification credentials.

It is important that this option be an opportunity to enhance a System

Operator’s job knowledge without placing a financial and scheduling burden on the individual entities to provide the CEH required for extending certification.

With the expected adoption of Version 0 in early 2005, the proposed implementation plan applies to the entities included in the NERC

Functional Model. Because of this, the guidelines should reflect the entities included in the NERC Functional Model. Since there is no Reliability

Coordinator in the Functional Model, the most apparent equivalent is the

Reliability Authority. If the Reliability Coordinator is a job function that remains, we suggest adding to the NERC Functional Model to eliminate confusion and provide consistency between Version 0, the draft entity

Certification Standards and the System Operator Certification

Requirements. In addition, if the Reliability Coordinator Operator

Certification remains as a separate certification level, we also recommend

Draft for Comments

Page 105 of 110

July 28, 2004


Anita Lee, P. Eng.


Procedures

Alberta Electrical System Operator anita.lee@aeso.ca

Bob Low

Director, System Operations

AltaLink Management Ltd.

Bob.Low@AltaLink.ca adding Reliability Authority as a level of Operator certification.

Although the NERC System Operator Certification Program is a separate program from the existing 40 HRS of System Operator training required by

NERC Blackout Recommendation 6a, we suggest that those responsible for developing training requirements at NERC work together when implementing these guidelines to eliminate duplicate training needs and adopt one training requirement for NERC Certified System Operators.

The lists provided in this appendix appear very limited and constraining compared to the current Appendix 8 B and the previous attempts at a system operator Job Task Analysis.

AltaLink has reviewed the White Paper on Continuing Education fro

Maintaining Operator Certificate, and we are not convinced that the desired outcomes of improving operator performance will be achieved through the Continuing Education process as described. As stated in the

White Paper Preamble, "It is hoped that by increasing a system operator's knowledge, the performance of the system operator will improve as well.", and we see nothing in the Continuing Education program that would change "hope" to "ensure" that the performance of the operators reaches and maintains a certain level of competence.

The White Paper does not provide a strong rationale or evidence that continuing education hours can replace a competency based examination for demonstrating the desired performance of an operator. Much adult education and learning literature and studies describe how the delivery and receipt of content does not necessarily lead to changes in performance. And yet, the program states that the continuing education hours must be accumulated and the option of demonstrating competence is not available (except if the certification has been suspended for a year).

Content approved for continuing education may be of little practical value in terms of operator performance improvement or even in terms of new knowledge. Depending on where an individual is in their development, content may be redundant. If an operator can repeat the same content every 3 year period, or if they have learned and performed on-the-job what is beyond the content of approved continuing education, there is no new learning derived from the continuing education and the only purpose of the continuing education may be to meet the required hours in order to maintain certification. The continuing education hours are to cover recognized training topics given in Appendix A. Most of these topics, with the exception of NERC, regional, local, etc. policies and procedures are very static in their nature, and there will be little benefit for a skilled operator to dedicate time to learning the information that he knows and uses on-the-job.

Simulation training focused on the roles and responsibilities of the operator is a valid way of ensuring that the operator is prepared to deal with situations that may arise, and operators should require evidence of this training for certification to be maintained.

Although continuing education credits may be accumulated and applied towards maintaining certification, we feel that the option of taking an exam in order to maintain certification should not be taken away.

Draft for Comments

Page 106 of 110

July 28, 2004


Rob Fuglesten

Power System Operator

Otter Tail Power Company

RFuglesten@otpco.com



My input for re-certification is that CEH's would be great, but I think retesting should also be an option. I think the Certificate holder should be required to have 10 to 20 hours a year of CEH's on NERC Policy changes and Standards updates. NERC should also have the Companies responsible for CEH's training the PSO's in their respective areas.

If yearly CEH's are met by the Certificate Holder, why should the

Certificate expire at all?

RECOMMENDATIONS

NERC should be focused on policy/manual content for certification training

- set minimum (e.g. 60/3 years) of policy hours for maintaining certification, across all credentials. Additional technical training, for example the 5 days of emergency training, and other training as needed, would be managed by the organizations who would be held accountable through compliance requirements. By setting up certification hours in this way, the certification standards would transfer easily to other groups as well, who aren't on the desk but who are working with operators on daily basis (e.g. Operations Engineers).

Need to have more options for re-certification than just continuing education. There are some shops that are just too small to maintain CE credit.

NERC's requirements should include the same number of hours for all the credential types otherwise makes for a logistics nightmare. If you need

120 to be a certified then why need set a separate limit for each credential type? If an organization has its operators certified as a RO (the highest level), regardless of their position, they have a better baseline of knowledge - generateion, transmission, etc. Why would an organization want to pigeon hole it's operators into one of the 4 credentials? It might end up "dumbing down" the industry.

The whitepaper doesn't address trainers that are CE providers, who develop the training. Trainers don't get credit for creative development.

Recommend a way for a Provider to identify a fulltime trainer who gets credit for development.


COMMENTS

It looks like the "Professionally Related" hours have been wrapped into the credential specific category. Please confirm. If so, will the Professionally

Related option go away on learning activity applications? CE is about maintaining level of knowledge needed to do job; not necessarily the training to move operators ahead.

"Level" the number of hours by implementing a minimum per-year basis

(e.g. 20/year) to avoid operators waiting until year 3 to get it all done.

Whitepaper proposes 30 hours of simulations/restoration requirement is over 3 years -- goes against Recommendation 6 of 5 days a year.

The procedures outlined in this whitepaper are cost prohibitive and time intensive. Record keeping will take development time away from Training staff.

How will record keeping be reviewed by NERC?

NERC Policies are not split out clearly by TO, BO, BIO and RO. As a result,

Operators will study all of the policies to be on the "safe side" - the RO level of knowledge. Therefore, why have different hour requirements between credential types?

Draft for Comments

Page 107 of 110

July 28, 2004


Karl Tammar

NYISO

KTAMMAR@nyiso.com

Art Feeney

Salt River Project



Operations

Phone: (602) 236-3839 Fax:



Are there enough providers and CEH available for credit to cover the number of hours needed by all the operators in the industry (based on the required number of hours outlined in this whitepaper)?

What were the hour requirements based on? They should be based on job analysis of what is needed per job type to ensure the requirements are valid.

What do organizations do with the operators who don't have the required number of CEH within the 3 years and their certification is suspended?

They can't work and what is the organization to do?

The lists provided are a good start. They should be expanded to something that approximates the current Appendix 8 B and NERC’s previous attempts at an operator Job Task Analysis.

ALL OPERATOR CERTIFICATION EXAMPLES

The proposed number of Continuing Education hours is too large. It is

SRP's opinion that NERC Continuing Education should focus on significant changes in Policy and re-address the most important reliability skills and knowledge needed by System Operators. It should not be a wholesale reeducation of basics. Therefore, SRP suggests that no more than 15 hours per year, or 45 hours every three years, is a more appropriate level for a

Continuing Education program. SRP believes this is sound for reasons of practicality and compatibility with other industry's CE programs. At 15 hours per year, there is ample time to stay current on issues such as

NERC policy changes, changes in system conditions, and other topical subjects. Together with the NERC Policy 6 Emergency Training requirement, this affords each dispatcher the opportunity to remain up to date on industry-related issues as well as practice their skills under abnormal or emergency conditions.

After conducting an informal survey (below) of various professions, including a few that are considered similar to system operations, it became apparent that the number of CE hours proposed for System

Operators far exceeded the requirements of other professions.

Profession Requirement

Nuclear Power Plant Operator Licensehttp://www.nrc.gov/reading-rm/doccollections/cfr/part055/part055-0059.html

Air Traffic

No CE

Controllerhttp://www.calmis.cahwnet.gov/file/occguide/AIRCONTR.HTM

No CE

Electrical and Electronic

Engineerhttp://www.calmis.cahwnet.gov/file/occguide/ENGELEC.HTM

No CE

Aircraft Pilot and Flight

Engineerhttp://64.57.102.78/CALGOLD2/calcareer/pilot.html per year

10 hours

Architecthttp://www.aia.org/conted/faq/1-5.asp 18 hours per year

Other Professions

Registered Nurses And Nurse

Practitionershttp://www.calmis.cahwnet.gov/file/occguide/NURSEREG.HTM

15 hours per year

Occupational Therapist http://www.doh.state.fl.us/mqa/occupational/ot_ceu.html per year

13 hours

Secondary School

Teacherhttp://www.calmis.cahwnet.gov/file/occguide/teachsec.pdf

(document) 30 hours per year

Draft for Comments

Page 108 of 110

July 28, 2004


Alan Gale




Comment 5:

ALL OPERATOR CERTIFICATION EXAMPLES

It appears the Continuing Education category of "Professionally Related" is absent from the White Paper. Does this indicate that this category of training is being removed from the CE program or is it training that doesn't count? If "Professionally Related" training is a valid Continuing

Education type it should be included in any re-certification requirement.

Comment 6:

APPENDIX A - RECOGNIZED OPERATING TRAINING TOPICS FOR

MAINTAINING NERC SYSTEM OPERATOR CREDENTIALS

Training content for the NERC Continuing Education Program should not be determined by the entity overseeing the Program. SRP believes that it is the responsibility of the NERC Personnel Subcommittee to identify and prescribe training that is appropriate for a System Operator. Therefore, any reference to training content should be removed.

Comment 7:

CEH EARNED BY OPERATORS FOR MAINTAINING A CREDENTIAL

Item 1.3: The 30-day window for proof of sufficient CEH to NERC seems too stringent. It should be sufficient to submit proof of training by the day prior to the deadline.

Item 4: "CEH in excess of the required amount cannot be carried over from one three-year period to the next". It seems reasonable that a specified number of excess hours earned in the last year of a credential, after satisfying the CE requirement, should be carried forward. Effort and expense are expended to earn these hours and they should remain with the individual who earned them.

APPENDIX A Comments:

Transmission Operator (TO):

Interconnected Power System Operations (IPSO)-

Why does 'economic operation' apply to the TO but not the BIO?

The TO does not get credit for "formulate operational plans" but the BIO does and the RC gets credit to "evaluate" them.

What is meant by the "system control" bullet? This term is pretty broad, which is good from the trainer side, but not from the "clear and concise direction" side.

TOOLS- Why aren't real-time contingency analysis and operator load flow considered advanced applications since they are for the BITO?

Outage Procedures - What is intended with "protective card procedures"?

The TO has no training credit for congestion management, interchange schedules, or market operations, while the BIO does.

Balancing and Interchange Operator (BIO):

TOOLS - Why does it list EMS but not SCADA?

Generation - Contains items that are not in the combined TO/BIO sylabis.

What is meant by the "system control" bullet (in IPSO)?

Balancing and Interchange/Transmission Operator (BITO):

Draft for Comments

Page 109 of 110

July 28, 2004


What is meant by the "system control" bullet?

This portion should contain all the requirements from both the BIO and the TO individually. There are some 'minor' diffrences that lead to misinterpretation or raises questions as to what is creditable for CEHs and what may not be. Some examples:

IPSO - 'confirm' vs. 'evaluate' interchange schedules, no mention of system protection or system stability.

Generation - capabilities of different types of generators from BIO, no mention of ACE, no mention of frequency control.

EHV Operations - big difference in the level of detail allowable,

Why is "assess the reliability impact of planned and forced transmission outages" a function of the BITO but not a function of the RC?

Congestion Management - To what detail is he creditable? The BIO only has to "understand concept", but no level of detail is provided for the

BITO or the RC.

Reliability Coordinator (RC):

IPSO - What is meant by the "system control" bullet?

TOOLS - No mention of EMS.

Congestion Management - To what detail is he creditable? The BIO only has to "understand concept", but no level of detail is provided for the

BITO or the RC.

No Generation subset.

No Market Operations subset. This should also include the Standard of

Conduct.

No Outage Procedures subset.

Emergency Operations - BITO has "implement emergency operations procedures but the RC does not?

Draft for Comments

Page 110 of 110

July 28, 2004

System Operator Certification Program Administrative

System Operator Certification Program

Administrative Guidelines

Maintaining

NERC System Operator Credential

Through the Use of

Continuing Education Credit Hours

North American Electric Reliability Council

Executive Summary

Details

Transition

NERC System Operator Certification Phase II Preamble

Goals

Section I — Introduction

Recognizing Continuing Education

Governance and Administration of the System Operator Certification CE

Program

Governance:

Administration:

Funding the System Operator Certification CE Program

Phase I

Phase II

Continuing Education Credit Hours to Maintain a Valid Credential

Transmission Operator Certification

Balancing & Interchange Operator Certification

Balancing, Interchange & Transmission Operator Certification

Reliability Coordinator Operator Certification

Deficits of CEH for Credential Holders

CEH Earned by Operators for Maintaining a Credential

Changing Certification Levels

Transition Plan — From a 5-year Program to a 3-year Program

Section II — Program Rules

Rules for NERC-Certified System Personnel

Selection of learning activities —

Recognized learning activities only —

Provider access to database —

System Operator access to database —

Retain documentation

Learning activity credit only once per year

Exception: Courses dealing with emergency operations will be recognized no more than two times during a calendar year.

Providers whose approved status is revoked after granting CEH

Instructor credits

Appendix A

Recognized Operating Training Topics for Maintaining NERC System

Operator Credentials

Reliability Coordinator

Balancing and Interchange/Transmission Operator

Transmission Operator

Balancing and Interchange Operator

Related documents

Add this document to collection(s)

Add this document to saved

Suggest us how to improve StudyLib