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.
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.
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.
Draft for Comments
July 28, 2004
Page 2 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Submitted by:
John Compton
PECO
john.compton@pecoenergy.com
Walker, Blake R
MidAmerican
BRWalker@midamerican.com
Bill Bell
Training Coordinator
ISO New England
wbell@iso-ne.com
Comments:
If NERC is implementing a knowledge growth and performance improvement
program to maintain NERC certification, will I be given ample time to
accumulate the required 120 CEH to keep my certification valid? My present 5
year certification will expire in October 2004. I strongly agree with NERC's
stand on this matter.
Retaking the examination for the same classification will not be an option.
Taking an examination for the same Specialty Classification will not be
allowed until the suspension period has expied.
The total hours over 3 years is probably too much for many of the companies
without a total overhaul of the operating shifts. Each area would need to
ensure mandatory training weeks with no vacation time allowed during
training periods, and many areas will resist that, even though it is a very
good idea. I think that the CEH total should be reduced to one third of this
proposal at first with verbiage attached that 240 hours is desirable for all
credential areas. We need for everyone to buy into this program now that it
has started, and I think that this might make quite a few opt out.
We were also that testing would always be an option, and that option has
been completely removed from the table here. Some smaller utilities may not
be able to afford to send their people to receive 240 hours of accredited
training with the available contractors, and have it be a viable economic
option.
Draft for Comments
July 28, 2004
Page 3 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
A one-year suspension for a person whose certification has lapsed is too
restrictive. What that does is basically removes a person's ability to work,
and therefore that person's employability, for what might be something as
innocent as scheduling problems. Is there going to be a mechanism to
ensure that the certified operator receives a reminder that their certification is
about to expire, much like the states issuing a reminder that one's
automobile license is about to expire. This needs to be rethought, in my
opinion.
Macom, Todd
Todd.Macom@PacifiCorp.com
Everett M. Stallcop
Supervisor - Transmission
System Operations
AEP - Public Service Company
of Oklahoma
office: (918) 610 – 3601
emstallcop@aep.com
Godiksen, Dan
Electric System Dispatcher
CWLP DGodiksen@cwlp.com
I believe that this is a step in the right direction, but I also think that quite a
few people will consider the requirement of 80 hours every year of
mandatory NERC Accredited training, while not a bad thing, but a very
expensive, and prohibitive, proposition.
Although I am in agreement that CE is a viable alternative to a System
Operator's exam, I believe the number of hours required to maintain the
certification is excessive. It is my understanding that a portion of time
allotted to specific training will be disallowed by NERC even if designed to
comply with the requirements. An example of this would be simulator
training. Since it is not cost effective for each utility to possess a training
simulator, system operators may need to be trained on how to use a
neighboring company's leased/rented simulator. The time needed to explain
the simulator as well as time allotted for breaks, lunch and other class
discussions, which do not fall under appendix A category, would not count for
CE. In addition to the fact that the electrical system for each entity is of
unique nature, it is speculated that training which does not qualify for NERC
certification must also be provided to the system operators. These factors put
each utility, as well as each system operator in a position of being
overburdened in attempting to comply with the NERC proposed standards.
The 180 required CE training hours in addition to the job specific and
disallowed training could easily approach 300 hours in a 3-year period. To be
competitive in today’s energy market, most utilities cannot maintain the
necessary manpower to provide for this additional requirement. It would not
be cost effective to staff an additional employee to cover the mandated
training, so this burden would fall on the employee’s requirement to gain
NERC CE on their time off.
This is a great way to track the continuing education hours earned
1) Will there be an appeals process in which a company can submit a request
for testing instead of the CEH program (on a case-by-case basis)? 2) Having
reviewed your list of topics, I am concerned with redundancy over a several
year period, what steps are in place to expand those topic areas? 3) Having
the general topics available, will there be a process in which a company can
develop their own (NERC approved) training specific to their needs and
certifications? 4) Is there a process in which company employees can
become NERC certified to teach the NERC courses? To company employees
and those from other companies? 5) Would the fees be adjusted to reflect
an in-house effort instead of commercially purchased training? 6) Is it
NERC's intention to eventually asses fees for suspended / revoked
credentials? I hope that this feedback will be helpful in developing a
Draft for Comments
July 28, 2004
Page 4 of 42
NERC System Operator Certification Phase II
Cummings, John M
John.Cummings@northwestern
.com
Knarreborg, Renee
RKNARREB@ci.tacoma.wa.us
Chuck Weaver
WAPA-RMR Operations Switching
(970 )461-7463
weaver@wapa.gov
Administrative Guidelines
successful CE program. I also hope that these issues will be addressed, or if
they have already been addressed could you please provide me with the
information or location in which I can retrieve that information.
I commend NERC for their excellent effort to get this program in place ASAP.
CEU's will help grid reliability. I believe the draft System Operator
Certification Program Administrative Guidelines needs to allow topics NOT
covered in Appendix A to gain CEU approval through the existing CEU
certification program. My reason for this is that many control areas have
unique equipment or features or problems and time spent addressing these
unique, local issues is one of the biggest advantages CEU's have over
standardized testing. I suspect the authors of the draft System Operator
Certification Program Administrative Guidelines meant any Certified CEU
course directly related to operator tasks, but the words "See Appendix A for
recognized training topics" may discourage people from getting CEU
Certification on topics other than those listed in Appendix A. Certainly
Appendix A covers most every topic, but I think it is best not to be too
prescriptive.
Why have the required number of CEH increased so dramatically from what
previous discussions have been proposing? Our System Dispatchers are
currently certified as Reliability Operators. It will be nearly impossible to staff
our control center to meet 240 hours in three years plus an additional 40
hours per year for the Recommendation #6 requirement and the WECC
requirement of 10 CEH in two years. In addition we have to meet training
requirements for our own utility. This is at minimum 4 weeks of training per
person, per year, per Dispatcher. With 13 System Dispatchers in our utility
that are required to be certified, we will need to hire another 2 or 3 full time
bodies to provide stafing and administration to meet this training
requirement.
That is a major expense and resourse drain for a small publicly owned utility.
Recomendations,
* Total NERC required training hours should not exceed 180 hours/ per three
years
* These 180 hours should include the 40 hours for recomendarion #6
* There should be only two "buckets" 1 for Area of Certificate (and /or NERC
policies/ professionally related) and 1 for Emergency Operations
* The division of hours should be 20 hours for Area of Certification (etc) and
40 hours for Emergency Operations
* If rec. #6 has to be maintained separately from the NERC CEH program,
then the required number of CEH should be 20 per year or 60 per three years
* The rec. #6 should be based on the calendar year starting Jan. 1 instead of
starting from the middle of the year. (In the west we now have three training
time lines to meet!)
* There should be a requirement for all Regional councils to provide
additional CEH training specific to each individual region for example the
10/per two year requirement that the WECC requires is about right.
The number of hours required by this proposal exceed the amount of
dispatcher training that is available in this country and exceeds the amount
that is necessary for a well trained dispatcher. Continuing education and
exams are part of the training necessary for a dispatcher but too little (none
in this proposal) weight is given to "desk time". We get good at our jobs by
doing our jobs and learning from our experiences and those of others we
work with. Where does that get accounted for? I suggest using a sliding scale
with inexeperienced dispatchers requiring more CEHs per 3 year period and
more experienced dispatchers(measured by number years of satisfactory job
Draft for Comments
July 28, 2004
Page 5 of 42
NERC System Operator Certification Phase II
Tim Hattaway
Energy Control Center
Manager
Alabama Electric Cooperative
John Mason
Supervisor-Transmission
System Operations
Missouri Public Service/Aquila
Mason,
John.Mason@aquila.com
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric
Cooperative, Inc.
JNeagle@AECI.org
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.co
m
Administrative Guidelines
performance) requiring fewer CEHs.
System Operators should be allowed to select the method for re-certification.
Since the testing program is in place and is currently working to some
degree, an option or combination of re-testing and or CEH certification should
be allowed. The intial "promotion" of a CEH program seemed to have an
"either / or" framework which now appears to no longer be the case.
Comments in general:
- The hourly requirement to maintain certification had to begin somewhere
but the CEH requirements stated above are excessive. Why such a large
difference in hours for the 4 certifications? About 1/2 of the hourly
requirements stated for each should be adequate.
- The escalation towards increasing levels of "specialization" in system
operations is unsettling. This began with the separation generation and
transmission functions. Marketing companies hired out experienced
operators and these were replaced with less experienced staff. Five-year
single-level certifications were added (good thing) but then were changed
recently to further specialize in balancing, transmission and reliability. Now,
add to this the proposed large CEH hourly maintenance for the certifications
and you have a situation where you have such intense specialization that you
eventually will have few or no operators that have "broad" experience that
cover all 3 areas. The holders of "reliability" certificates (should) have this
big picture knowledge but these people won't be in-house and don't
intimately know your system. They will be at "RTO headquarters". With
such large reliability CEH requirements, companies that want to maintain that
high-level certification to keep their operators well-rounded will be forced into
an economic decision to take a lesser certificate because they can't afford the
off-time for training and the 4-5 weeks vacation that operators often carry.
All operators (gen, trans and marketing) need to have some
training/knowledge in ALL areas of operations.
Some smaller shops may be forced to 'give up' transmission altogether due to
the regulatory loads being place upon them. A further push to move all
transmission under RTO control more quickly?
Agree with overall concept of the program.
Is it the intent that for every CE period (each three years) the courses taken
by the System Operators must always be different than those previously
completed. If so, development of these courses will be very burdensome and
probably of not much value as there will be too much information. It would
be much better to be able to retake courses periodically. At least in this
fashion the point can be emphasized and more readily available (in terms of
memory/recall) in times of crisis.
Associated Electric Cooperative Inc. agrees with the concept of mandatory
continuing education for system operators. Associated objects, however, to
some of the details of the plan as stated in additional comments below.
I agree that operators recognize that replacing the certification exam with
continuing education is more beneficial, but they will also agree that the
amount that the PCGC is proposing is excessive. Considering the continued
need for region specific and system specific training. The requirement in the
pilot program went from 32 hours for 2 years to 240, 180 and 120 hours for
3 years. Does this include the 5 day training requirement on black start
restoration and emergency operation or is it separate?
Draft for Comments
July 28, 2004
Page 6 of 42
NERC System Operator Certification Phase II
Cintron, Walter
CINTRONW@coned.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
Why is retaking the exam not an option in lieu of not accumulation the
required CEU's. This does not make sense.
The System Operator Certification Continuing Education Program is a good
idea. The System Operators will be kept current with all of the policies and
procedures in the industry as well as their own company. The problem here is
the number of CEH that are proposed to maintain their credentials.
The July 2003 proposal to maintain a valid NERC certificate, system operators
will be offered a choice of either: 1) completing and passing the NERC
certification exam again, or 2) earning 32 CE hours within the two-year
period preceding the expiration date of their certificate. This is the proposal
that our System Operators were enthusiastic about.
The 240 credit hours and no choice in writing an exam you are now
proposing will kill most of that System Operators enthusiasm. Operators
through their daily tasks gain experience throughout their career. With this
many CEH there seems to be no recognition for that experience.
With this many CEH’s to maintain it puts a great burden on resources and
finances. Training may have to be done at overtime rates.
Draft for Comments
July 28, 2004
Page 7 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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.
1.1.
2.
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.
3.
Establish criteria for NERC-certified system operators to maintain a credential
through the use of continuing education credit hours.
The process of registering continuing education credit hours will be done
electronically. System operators and training providers may continuously update
their information.
Establish a mandatory process to maintain the credential of NERC-certified system
operators by meeting continuing education credit hour requirements established by NERC.
Comments:
Bill Bell
Training Coordinator
ISO New England
wbell@iso-ne.com
phenimp@selectenergy.com
Godiksen, Dan
Electric System Dispatcher
CWLP
DGodiksen@cwlp.com
Knarreborg, Renee
RKNARREB@ci.tacoma.wa.us
Tim Hattaway
Energy Control Center
Manager
Alabama Electric
Cooperative
Kevin Conway
Grant County PUD
Good.
Only comment. Would like to see a list of NERC approved training courses
with web links to providers of classes.
1) Do you have a process in which Reservists who are re-called for active
duty (up to 2 years) can have their time stopped and then re-instated upon
their return? If not and they do fall into a suspended or revoked status,
potentially causing them to loose their position, would this violate their
rights and job protection guaranteed by law?
I like the idea of the electronic data base however, there is no mention of
Training Coordinators and/or Supervisors having access to view the training
records of our own employees. This is a must.
What is the certification requirement for CEH providers? supervisors?
trainers? marketers?
It seems that one of the stated goals of any program relating to NERC
System Operators should be the reliability of the electrical grid. System
reliability is not mentioned in any of the 3 goals listed above.
For the smaller companies that do not have a large staff of training
personnel and a large staff with "extra" system operators, they will be faced
with decisions to send people to workshops and conferences to gain the
required CEH. The smaller company may well have to staff their operations
centers with less than a full staff while other operators are sent off for
training. In such situations, reliability suffers in the name of training.
There needs to be some way for company management to verify and track
individual operator progress towards maintaining certification. Since the host
company is held responsible for certifing that NERC Certified operators are
operating the electrical grid then they should have some means of tracking
the operators that they employ.
How can NERC manage this manditory process? It will be difficult to verify,
and the honor system of reporting can become abused very easily. Who will
Draft for Comments
July 28, 2004
Page 8 of 42
NERC System Operator Certification Phase II
John Mason
Supervisor-Transmission
System Operations
Missouri Public
Service/Aquila
John.Mason@aquila.com
Administrative Guidelines
bear the cost? This proposal will cause the utilities to increase their current
spending dramatically. I don't believe there will be enough support from the
voting members due to the anticipated increased costs.
No comments. Does NERC realistically think they have this in place by next
year and have it be meaningful and it not be a looked upon as a rushed
over-reaction?
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
Agree with this process
John Neagle
Associated Electric
The order in which the goals are listed implies a lesser importance for
establishing the process for maintaining NERC-certification creditials than for
You cannot continually increase their knowledge, there is a limit. We would
be better to emphasize the materil by repeating periodically.
Why does NERC have to approve the training? The Control Area has a direct
interest in training their staff. Do not need NERC to approve our material. If
any particular Control Area is satisfied that the material is relevent for their
operation, then so be it. Self declaration is used in other associations
(Engineers, Doctor's etc.) See website
http://www.apegs.sk.ca/default.aspx?DN=28,11,2,documents
At the above website the program is CPE - Continuing Professional Excellence
NERC already has an audit process for compliance with Operating
Policies/Standards which is directly linked to operator training. Surely, a
better proposal would be to include Operator Certification within the audits.
In this way the training must be completed but it is training the Control Area
administers to the requirement of the standard. Getting NERC approval of a
training course add no value, but rather adds costs.
Also credit has to be given for the type of operation in Saskatchewan. Our
operators are responsible for Generation, Transmission, Distribution and
Tagging. We have numerous types of Generation and two separate power
systems to operate. We have the unique Island Falls dynamic schedules. We
have to be knowledgeable about the operation of the McNeil Converter
station and B10T Phase shifting transformer. Our Operators also have to
complete and pass examinations in the following technical areas:
Communication
Computers
Economics
Substations
Protective relaying
Power transmission
Power pool operations
Emergency analysis& Response
Power Dynamics
Steady state Power Flow
Distribution
Standard Protection Code
Along with these courses, restoration classes, DTS classes and Power
Dynamics courses are continually provided each year. I don't think we
should be lumped together with every utility in the USA, as we are probably
some of the most qualified and trained operators on the continent.
Draft for Comments
July 28, 2004
Page 9 of 42
NERC System Operator Certification Phase II
Cooperative, Inc.
JNeagle@AECI.org
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
establishing an electronic registration and documentation process.
Associated Electric Cooperative Inc. concurs with the goals as stated, but
believes the order in which they are listed should be revised.
Agree with these concepts
Draft for Comments
July 28, 2004
Page 10 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Kevin Conway
Grant County PUD
John Mason
Supervisor-Transmission
System Operations
Missouri Public Service/Aquila
John.Mason@aquila.com
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
Cintron, Walter
CINTRONW@coned.com
The idea has merit in recognizing CEHs, but it doesn't seem to reflect the
move to the Functional Model. I tend to agree with the concept, but not
the methodology.
Continuing education is needed but should cover all operational areas and
not be so specific in the balancing/transmision/reliability areas.
Agree with this process.
Why do we not recognize employment as a factor in accumulating CH's.
This is not unusual, and actually performing the System Operator function
is a tremendous learning experience. Lets recognize that doing the job is
significant.
The large number of CH's required appears to be a knee jerk reaction to
August 14/03, when in fact it was not a System Operator knowledge or
qualification problem. System Operators are already well trained, the
additional 40hrs/yr training as required from the Aug 14 recommendations
document should form part of the CE hours and should not have to be
registered with NERC (who better know the training requirements than the
Control Area). This seems to be a money grab to fund a ineffective and
inefficient program.
I think that before you start making certification hinge on accumulated
CEH credits you make a provision for those that do not complete them to
be able to retest. Removing an operator from performing a function is not
realistic and penalizes the company . This will place a human resource
issue for a company as well as a potential for decreased reliablity on a
reliability authority's system by removing experienced operators.
Draft for Comments
July 28, 2004
Page 11 of 42
NERC System Operator Certification Phase II
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
Agree with these concepts
Draft for Comments
July 28, 2004
Page 12 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Kevin Conway
Grant County PUD
Joe Knight
MAPPCOR
je.knight@mapp.org
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
This seems to make the process sound easier that I think it will be. I don't
have confidence that NERC currently has the needed resources to handle
monitoring at this level, and at the proposed timeframes. NERC has
recently demonstrated to my organization that it is under performing
simple administrative responsibilities in the current monitoring of Certified
Operators. NERC has shown poor perfomance in simply notifying
individuals that their certification anniversary date is within a year to
expire. I agree that some of this responsibility falls on the individuals
maintaining their certifications, but with the organization being financially
responsible for the sanctions, NERC should keep the employer informed as
well. If this can't be effectively managed now, how can the proposed
program have much success, or more importantly, support from the voting
members?
Will physical attendance be required or is electronic attendance going to be
an option. If 100% physical attendance is required, there will be a
potential problem due to the cost of travel. If some classes can be
attended electronically, it will benefit those who live in areas where travel
to other parts of the country requires bearing a signigficant cost burden.
Agree with these concepts
Draft for Comments
July 28, 2004
Page 13 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Tim Hattaway
Energy Control Center
Manager
Alabama Electric Cooperative
The committee should provide some type of estimated dollars for Phase II
of the program.
Kevin Conway
Grant County PUD
This will result in even greater costs that small utlities can not afford.
Training is expensive enough now. Shifting additional overheads on
training will make it very difficult for entities trying to comply with limited
budgets. Cost based fee structures work in the beginning, but tend to
sprial out of control after a while.
Agree with the concepts as presented.
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Agree with these concepts
Draft for Comments
July 28, 2004
Page 14 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Kevin Conway
Grant County PUD
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Those who have a current 5 year certification should be grandfathered
with a 5 year certificate. How will NERC deal with an operator who is in
the third year of their certification when the program is started? Would
they have to take the exam again, because it is only good for three years
now? There are still some outstanding questions on how this certification
will fit into the proposed move to the Functional Model.
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.
Again, I don't believe that NERC knows best what training a Control Area
should complete. It should be acceptable for the Control Area to
determine what training is required and train their operators. The training
should then be counted for CH's (see APEGS website). The completion of
the required training should be included in the NERC Compliance audits.
Agree with these concepts
Draft for Comments
July 28, 2004
Page 15 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Jim Eckels
Senior Transmission Specialist
Transmission Operations Support
- Training Dept.
First Energy - SCC Wadsworth,
Ohio
(330) 336-9049
jleckels@firstenergycorp.com
Does this mean that now where only going to be required to have 10
hours of emergency training per year instead of 40 hour "required"
emergency training per year? After the blackout, NERC required 40
hours of emergency training per year.
Steve Rainwater
Steve.Rainwater@lcra.org
Training Coordinator
Lower Colorado River Authority
120 is a rather large number. Smaller utilities such as my own (the
Lower Colorado River Authority-LCRA, with small training staffs will be
forced to go outside the company for training. This can be a very
expensive proposition. 40 hour courses on system protection for example
can cost $21,000 to train 18 Transmission Operators. Less complex
courses are cheaper, but how much does a senior operator gain from
being repeatedly exposed to the same basic concepts such as voltage
control or reactive power? In the market we find ourselves today it
would be difficult for me to get funding for anything of any significant
technical complexity. This says nothing about those utilities that do not
even employ training staff or utilize simulators. This number should be
revised downwards to a number in the 60-90 range. Doing so would
allow much more flexibilty in the type and content of training, with the
number as high as 120 I'm afraid utilities would simply go for the less is
more approach and just load up on low-cost, technically unchallenging
matrial in order to make a number.
The 90 CEH should be broken out into so many hours for Area of
Credential and Professionally Related. It seems like Professionally
Related CEH is missing from this.
The 30 CEH for Emergency Operations Training should be dropped as
Blackout Recommendation #6 takes care of this each year, and that
training could be certified as CEH.
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
I'm afraid that if you don't break this down per year that you might get
some who decide that they will try to complete all the training in a few
months prior to their expiration date.
Can we count OSHA required safety training anywhere?
Draft for Comments
July 28, 2004
Page 16 of 42
NERC System Operator Certification Phase II
Chuck Weaver
WAPA-RMR Operations Switching
(970 )461-7463
weaver@wapa.gov
Tim Hattaway
Energy Control Center Manager
Alabama Electric Cooperative
Kevin Conway
Grant County PUD
John Mason
Supervisor-Transmission System
Operations
Missouri Public Service/Aquila
John.Mason@aquila.com
Jeff Boltz
System Operator / Trainer
First Energy, Reading Control
Center
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric Cooperative,
Inc.
JNeagle@AECI.org
Administrative Guidelines
Are CEHs strictly counted? Most training classes start at 0800, break for
an hour lunch then end around 1600 with a morning and afternoon
break also. That is at most 6 1/2 hr per day of training. So in this case
120 CEH =18.46 days of training not 15 days, right? As far as simulators
go, you are right in thinking that they are very useful in dispatcher
training; however, I would guess that 98% of this country's dispatchers
do not have access to one, so right now it is a pipe dream.
This comment will apply the all areas of certification. An explanation
should be given as to how the number of required hours was chosen
along with the make-up for these hours (ie. 30 of the 90 hours must
utilize simulations etc). Also, some explanation should be given as to
how CE hours relate to the 40-hours of annual emergency training that
NERC instituted in the spring of 2004.
On-the-job-training (OJT) should be allowed in some fashion to account
for some of the CEH. Some of the most realistic training in system
operations can come from actually performing a task in a real-time
situation under the guidance and instruction from a veteran system
operator.
How will NERC help small companies provide proper training in these
areas? Simulations will be great if they are on the system that the
operator is expected to use. Learning a foreign system, because that is
the one that has CEH accreditation, accomplishes very little other than
meeting CEH requirements.
Hours excessive. (same for BIOCE, BITOC and RAOCE)
What happened to the "professional related are" credits as stated in the
FAQ dated July 19, 2004 and would you apply theses credits to the
"transmission operator tasks"?
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. Also proposes 30
hours of simulations/restoration requirement is over 3 years -- goes
against recommendation 6 of 5 days a year. Can the 30 hour Policy
training include Regional & Local Policies? Need to define per year. Is it
Jan-Dec or July-June? .
Of the 90 CEH related to Transmision Operator tasks, some should be
awarded for the learning that occurs just working the desk from shift to
sihft.
Associated Electric Cooperative Inc. believes requiring 120 CEH of NERC
approved learning activity, delivered by NERC approved providers, is
excessive. Associated has historically and continues to advocate and
provide continuing education for its system operators through in-house
instruction, self-study and, to a lesser extent, off-site learning
opportunities. With an authorized staff of seven system operators to
cover a 24/7 desk and an 8/5 desk, only one operator is available for
training at any given time. To obtain NERC approval for in-house
instructors and learning activities would probably not be feasible for a
small utility such as Associated. For each operator to obtain 120 CEH at
Draft for Comments
July 28, 2004
Page 17 of 42
NERC System Operator Certification Phase II
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.com
Cintron, Walter
CINTRONW@coned.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
off-site facilities would require substantial budget increases and possibly
additional staff. The Personnel Certification Governance Committee
should consider reducing the number of CEH required and relaxing the
requirements to allow recognition of documented, on-going, in-house
training on recognized topics.
Will these 30 hours of the 90 be counted as part of the NERC 5-day
requirement?
This requirement seems unrealistic expecially if the operator cannot
complete the requirements , he should be allowed the option of
retesting. The same comment goes for all 4 tests.Agai.
Agree with these concepts
Draft for Comments
July 28, 2004
Page 18 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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.
The 120 CEH must include:

30 CEH on NERC operating policies and standards.

90 CEH related directly to balancing and interchange 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:
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric Cooperative,
Inc.
JNeagle@AECI.org
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
The 90 CEH should be broken out into so many hours for Area of
Credential and Professionally Related. It seems like Professionally Related
CEH is missing from this.
The 30 CEH for Emergency Operations Training should be dropped as
Blackout Recommendation #6 takes care of this each year, and that
training could be certified as CEH.
Same here, operating the desk should account for some of the training
CEH's
Associated Electric Cooperative Inc. believes requiring 120 CEH of NERC
approved learning activity, delivered by NERC approved providers, is
excessive. Associated has historically and continues to advocate and
provide continuing education for its system operators through in-house
instruction, self-study and, to a lesser extent, off-site learning
opportunities. With an authorized staff of seven system operators to
cover a 24/7 desk and an 8/5 desk, only one operator is available for
training at any given time. To obtain NERC approval for in-house
instructors and learning activities would probably not be feasible for a
small utility such as Associated. For each operator to obtain 120 CEH at
off-site facilities would require substantial budget increases and possibly
additional staff. The PCGC should consider reducing the number of CEH
required and relaxing the requirements to allow recognition of
documented, on-going, in-house training on recognized topics.
Will these 30 hours of the 90 be counted as part of the NERC 5-day
requirement?
Agree with these concepts
Draft for Comments
July 28, 2004
Page 19 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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.
The 180 CEH must include:

30 CEH on NERC operating policies and standards.

150 CEH related directly to Balancing and Interchange/Transmission Operator tasks.
(See Appendix A for recognized training topics.)
 As a minimum, 30 of these 150 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:
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric
Cooperative, Inc.
JNeagle@AECI.org
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.co
m
Keep hours the same for all certificate categories. You don't need more
Emergency Operations Training hours per Blackout Recommendation #6
based on what certificate you hold so why have more hours for this?
Reduce 180 CEH to 120 CEH. Change 150 CEH to 90 CEH and should be
broken out into so many hours for Area of Credential and Professionally
Related. It seems like Professionally Related CEH is missing from this.
The 30 CEH for Emergency Operations Training should be dropped as
Blackout Recommendation #6 takes care of this each year, and that
training could be certified as CEH.
Same here, working the desk should account for some of the CEH's
Associated Electric Cooperative Inc. believes requiring 180 CEH of NERC
approved learning activity, delivered by NERC approved providers, is
excessive. Associated has historically and continues to advocate and
provide continuing education for its system operators through in-house
instruction, self-study and, to a lesser extent, off-site learning
opportunities. With an authorized staff of seven system operators to cover
a 24/7 desk and an 8/5 desk, only one operator is available for training at
any given time. To obtain NERC approval for in-house instructors and
learning activities would probably not be feasible for a small utility such as
Associated. For each operator to obtain 180 CEH at off-site facilities would
require substantial budget increases and possibly additional staff. The
PCGC should consider reducing the number of CEH required and relaxing
the requirements to allow recognition of documented, on-going, in-house
training on recognized topics.
Will these 30 hours of the 90 be counted as part of the NERC 5-day
requirement?
Draft for Comments
July 28, 2004
Page 20 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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.
The 240 CEH must include:

30 CEH on NERC operating policies and standards.

210 CEH related directly to Reliability Coordinator Operator tasks. (See Appendix A
for recognized training topics.)
 As a minimum, 30 of these 210 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:
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
Kevin Conway
Grant County PUD
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Joe Knight
MAPPCOR
je.knight@mapp.org
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric Cooperative,
Inc.
JNeagle@AECI.org
Keep hours the same for all certificate categories. You don't need more
Emergency Operations Training hours per Blackout Recommendation #6
based on what certificate you hold so why have more hours for this?
Reduce 240 CEH to 120 CEH. Change 210 CEH to 90 CEH and should be
broken out into so many hours for Area of Credential and Professionally
Related. It seems like Professionally Related CEH is missing from this.
The 30 CEH for Emergency Operations Training should be dropped as
Blackout Recommendation #6 takes care of this each year, and that
training could be certified as CEH.
See Transmission Operator comments. This is where CEHs are getting
excessive. Anyone who operates a Control Area will most likely fall under
this catogory. Most small Contol Areas will not be able to afford training
at this level. Unless it is the intent to do away with small control areas,
this issue needs to be reevaluated. This will be a major issue in the
Pacific Northwest.
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?
How many in-class hours constitute 1 CEH?
Again, working the function should account for a portion of the CEH's.
Associated Electric Cooperative Inc. believes requiring 240 CEH of NERC
approved learning activity, delivered by NERC approved providers, is
excessive. Associated has historically and continues to advocate and
provide continuing education for its system operators through in-house
instruction, self-study and, to a lesser extent, off-site learning
opportunities. With an authorized staff of seven system operators to
cover a 24/7 desk and an 8/5 desk, only one operator is available for
Draft for Comments
July 28, 2004
Page 21 of 42
NERC System Operator Certification Phase II
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
training at any given time. To obtain NERC approval for in-house
instructors and learning activities would probably not be feasible for a
small utility such as Associated. For each operator to obtain 240 CEH at
off-site facilities would require substantial budget increases and possibly
additional staff. The PCGC should consider reducing the number of CEH
required and relaxing the requirements to allow recognition of
documented, on-going, in-house training on recognized topics.
Will these 30 hours of the 210 be counted as part of the NERC 5-day
requirement?
The percentage breakdown is fine but there is still a problem with total
amount of hours required as was stated in the comments for the
Executive Summary.
Draft for Comments
July 28, 2004
Page 22 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
Kevin Conway
Grant County PUD
John Mason
Supervisor-Transmission
System Operations
Missouri Public Service/Aquila
John.Mason@aquila.com
Jeff Boltz
System Operator / Trainer
Can someone with a suspended certificate work in a non-independent
postion under the direct authority of a certified system operator?
This brings up a point of how much will NERC allow the employer to know.
Currently, privacy is maintained to the extent that the employer has little
control of the certification process. The employer, for the most part, pays
for the training and the testing, but has to rely on the operator to give him
the correct information on if he passed. If there was a failure, the
employer may get no notification. How will the employer monitor any of
this, if he is the one who may have to pay the sanctions? The current
process for the employer is not reasonable right now. The Region and the
individual's employer should have immediate notification of the individual's
certification status from NERC.
Not allowing an experienced operator that was currently certified to
operate a desk just because he hasn't attained X hours of CEH's is drastic.
It also puts a company into a more undesireable situation of not having
enough operators to cover shift. Also, a new operator with no experience
that passes a test with no CEH's and no 5-day emergency training can
operate a desk? I can imagine a shop ignoring this and keep this operator
on duty in spite of that deficit.
What provisions will be made for Operators who fail to complete their
required hours thru no-fault of their own, several examples would be
Draft for Comments
July 28, 2004
Page 23 of 42
NERC System Operator Certification Phase II
First Energy, Reading Control
Center
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
Cintron, Walter
CINTRONW@coned.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
callup to active duty of reserves, a medical condition which would prevent
them from attending class (heart attack or such) or callup for jury duty for
an extended period of time, or requirements from their employer to man
extra shifts due to reduction in work force to maintain minimum manning.
Will these Operators be disciminated against and suspended?
If an Operator has trouble maintaining his credentials during a three year
period, and is suspended, placing a requirement on them to complete the
required hours within two years is undue burden.
"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.
New operators will enter the control room. We have a 3 year training
period that occurs and after this period the operators are completely
trained. During this period they will be operating but may not have taken
the Certification Exam, as they are still in training.
Conversely, an operator may be deficient in CEH's at the end of their
certification period. They have a year to accumulate the required CEH's,
during this period it is stated that they cannot peform any task that
requires an operator to be NERC certified.
In both of the scenarios above, can the operator perform these functions
under the direction of a NERC certified operator? Without this flexibility
the cost in terms of manpower would be prohibitive.
Why are we making this so stringent with respect to accreditation? It
appears that you are penalizing the operators .What is the bottom line with
respect to this?
Going back to the Executive Summary comments, there should be a choice
to rewrite an exam in lieu of the CEP. This would allow the Operator to
write an exam without being suspended for a year.
Draft for Comments
July 28, 2004
Page 24 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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.
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.
2.
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).
3.
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:
Jim Eckels
Senior Transmission
Specialist
Transmission Operations
Support - Training Dept.
First Energy - SCC
Wadsworth, Ohio
(330) 336-9049
jleckels@firstenergycorp.com
Should show an example of what the web site will look like to submit CEH on
and view current CEH's. Also, don't forget training will be needed to explain
how to do this (both for the student and the provider).
Brian Nolan
Manager - Projects
North American Electric
Reliability Council
Brian.Nolan@nerc.net
609-452-8060
Steve Rainwater
Steve.Rainwater@lcra.org
Training Coordinator
Lower Colorado River
Authority
Mike Clime
Ameren
Energy Supply Operaions
Will it be allowed to gain all CEH's from one provider, such as an internal
education program? It does not sound reasonable to allow a company to be
the single source of education, even if they are a NERC certified provider.
The method b which these CE hours will be submitted needs to be clearly
delineated.
NERC will have to do a better job of getting people their certificate # in a
more timely manner. It currently takes 6-8 weeks to receive a certificate
after passing the exam. Under the proposed new program an operator
Draft for Comments
July 28, 2004
Page 25 of 42
NERC System Operator Certification Phase II
Technical Training
Supervisor
Tim Hattaway
Energy Control Center
Manager
Alabama Electric Cooperative
Kevin Conway
Grant County PUD
Jeff Boltz
System Operator / Trainer
First Energy, Reading
Control Center
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric
Cooperative, Inc.
JNeagle@AECI.org
Cintron, Walter
CINTRONW@coned.com
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Administrative Guidelines
would be unable to do CEH training during this 6-8 week period because they
would not have a valid NERC certificate #. The operator will need to be able
to immedately start accumlating CEH once their exam is passed or they have
successfully renewed their certificate.
Any training in the operator receives above and beyond the required number
of CEH should be allowed to carry over to the next period.
The employer, as well, should be able to monitor and track where an
employee is in respect to meeting NERC requirments. I do not feel it is
unreasonable to allow some level of carry over of additional credits in
situations where training is within a month or two of the end of the year.
Perhaps an individual only needed a few credits for compliance, but a difficult
to get in class becomes available in December that will give the individual 30
extra credits. The employer may forgo allowing the individual from taking
the class, because the full benefit of the training is not going to be realized.
What provisions will be made for a discrepancy between the Operator
records and the Providers databases? Will the Operator be penalized for
inaccurate records from the Provider? Especially if the Operator is finishing
his CEH requirement just prior to suspension. I refer to FEQ dated July 19,
2004, Question 121, If the provider status is revoked, there is no incentive
for them to report CEH hours, in turn the Operator could be "suspended" for
no fault of his own, hence "being unfair to the student" as stated in Question
123.
CEH hours in excess should be allowed to be carried over to next period
within a reasonable amount, example 33% of their requirement. Example if
an Operator is suspended for a deficit of 1 credit, and takes a 20 hour course
prior to his suspension, he should not be penalized for the initiative for
acquiring CEH hours, this is especially true for an individual that is
suspended.
Agree with concepts
Again, this section talks about submitting proof that the operator has
accumulated the necessary CEH's to extend their certification. To do this is
intensely administrative, I would suggest that the confirmation of this
necessary CEH's be done by audit. Operating the System according to NERC
Policies/Standards is left to audit, this is no different.
What will the PCGC/NERC accept as "proof of having acquired the necessary
CEH"? Acceptable proof should be defined.
If proof of having aquired the necessary CEH must be submitted not less
than 30 days prior to the expiration date of the operator's credential, any
CEH completed within that 30 day period should be allowed to carry forward
and apply to the next three year period requirements.
Again, lets penalize the operators.
This is called a three-year program. It actually is a 35-month program with
the requirement to have all of the sufficient proof to NERC 30 days before
the system operator’s certificate expiration date.
The CEH in excess of the required amount should be allowed to be carried
over. One of your primary purposes of CE is that it promotes ongoing
development of an operator’s knowledge. Why can’t the individual, once the
Draft for Comments
July 28, 2004
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NERC System Operator Certification Phase II
Administrative Guidelines
number of CEH for their chosen field have been attained, have their
certificate’s expiration date extended for the 3 years from that date rather
than lose any CEH’s?
Draft for Comments
July 28, 2004
Page 27 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Jim Eckels
Senior Transmission
Specialist
Transmission Operations
Support - Training Dept.
First Energy - SCC
Wadsworth, Ohio
(330) 336-9049
jleckels@firstenergycorp.com
Show example of credential maintenance application. Is this something we
will need to submit/update every year?
Mike Clime
Ameren
Energy Supply Operaions
Technical Training
Supervisor
Kevin Conway
Grant County PUD
If all hours for renewal were kept the same for each certificate there would
be no need for the last two bullets.
Jeff Boltz
System Operator / Trainer
First Energy, Reading
Control Center
Leo St. Hilaire
Program Development
Perhaps this would be much easier to manage if there was only one test
again, and the certification level depended on meeting the proper amount of
training hours. Everyone could then test as a
Reliability Coordinator an train for what their current jobs are. It is my feeling
that using one test would be easier to manage, and since there is a target
threshold for CEHs, NERC would then allow the certified individual to
maintain the proper certification level through training.
Show example of credential maintenance application.
If you send in a maintenece form for a TO, and job resposibilities require an
upgrade to RC status, will a new form suffice? (Assume that the person has
passed and RC exam)
What is requirment for submission of this form?? Once during 3 year period,
yearly?
Agree with concepts
Draft for Comments
July 28, 2004
Page 28 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
Coordinator
Manitoba Hydro
Draft for Comments
July 28, 2004
Page 29 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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:
Brian Nolan
Manager - Projects
North American Electric
Reliability Council
Brian.Nolan@nerc.net
609-452-8060
Steve Rainwater
Steve.Rainwater@lcra.org
Training Coordinator
Lower Colorado River
Authority
Kevin Conway
Grant County PUD
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
Cintron, Walter
CINTRONW@coned.com
To prevent the attempt to use both the exam and CEH's acquired for those
with exams expiring prior to the third year, it would be best to state that the
CEH's acquired prior to taking the exam cannot be applied to the next three
year period.
What about those CE hours already earned during 2004? Will they be
grandfathered in? Also, why not allow those Operators already in their three
year window to pro-rate their hours based upon the date of their certification.
Some operators at LCRA have as little as 18 months to go before they will
require re-certification and it would be difficult to get them 120 hours of NERC
CE hours in that time frame without significant added cost. That does not even
consider the fact that this policy isn't in place yet and more time will go by
before it takes effect. This would force most operators to take the test for recertification.
This will be very confusing, putting many people in jeopordy of loosing their
certifications during the transition. Will this mean that if this program is put in
place, if I am on my fifth year, I now will be extended three more years
making a total of eight? If I am on my first year, will I only get three years
allowed on my five year certification? I understand that you cannot satisfy
everyone, but if there is no sense of equity, you will not have good acceptance
of the program.
Agree with concept
Does this mean if an operator has one year remaining (on his five year
certificate) after implementation of the CE program they must complete the
CH's in one year or write the exam again? This doesn't seem to make sense
given that the admission in this paper is that System Operators who re-write
the certification exam still know the information they knew when they
originally wrote the certification exam. This then should permit the System
Operator with one year remaining to commence their 3 year CE Program and
their original certification will span the additional two years to accomodate
participation in the CE Program.
Are you saying that an operator who has allowed his 5 year certification expire
now can accumulate CEH credits and allow him to be recertified?
Draft for Comments
July 28, 2004
Page 30 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
Section II — Program Rules
Rules for NERC-Certified System Personnel
1.
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.
2.
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.
3.
Provider access to database — Rules for providers to input information concerning CEH
delivered when database is developed and process is determined.
4.
System Operator access to database — Rules for system operators to input information
concerning CEH received when database is developed and process is determined.
5.
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.
5.6.
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.
In the absence of legal or other requirements, documentation must be retained until
credential extension is granted.
6.
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.
7.
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
July 28, 2004
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NERC System Operator Certification Phase II
Administrative Guidelines
maintaining a credential, will still be recognized if, subsequent to the course or learning
activity taking place, the approved status is revoked.
8.
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:
Jim Eckels
Senior Transmission Specialist
Transmission Operations
Support - Training Dept.
First Energy - SCC Wadsworth,
Ohio
(330) 336-9049 - Outside
number
jleckels@firstenergycorp.com
Brian Nolan
Manager - Projects
North American Electric
Reliability Council
Brian.Nolan@nerc.net
609-452-8060
Steve Rainwater
Steve.Rainwater@lcra.org
Training Coordinator
Lower Colorado River Authority
Mike Clime
Ameren
Energy Supply Operaions
Technical Training Supervisor
Chuck Weaver
WAPA-RMR Operations Switching
(970 )461-7463
weaver@wapa.gov
2 - what's "applicable credential maintenance program requirements"?
(too wordy)
5 - define timely
5.6 Most dispatchers don't know what their NERC Certification number is.
Doesn't NERC have a master database available so people can just enter
there name & company and the DB can match up the cert #? Also, titles
can change a lot depending on the company.
8 - Instructors should at least get a 2:1 ratio on CEH's. There is a lot of
preparation that the instructors do to get ready to teach the material.
Will the CEH be required to be spread across the training topic in some
way? Or could, say a RC take all of their hours in Interconnected Power
System Operations with each course focusing on a different sub element?
The reason being is that since they will need to communicate with others
in times of crisis and non-crisis, they should have to take at least on
course in communication, likewise they should need to address the other
aspects of training topics.
Re: #3 Cannot comment on something that is not defined.
Re #5: Can the employer maintain these records for the employee?
Re #6: I believe what you are trying to say that a given course on a
specific topic relating to emergency operations can only be given for
credit twice per year. needs clarification.
Re #8: If an operator can get credit for an emergency operations course
twice per year why then can the instructor only get credit once? Also, the
documentation requirements are not given. This needs to be made very
clear.
If the instructor only gets 1 CE as it reads above and they have to deliver
the training multiple times to get their staff certifed, when will the
instructor have time to obtain their CEH?
Instructors should be given at a minimum, the number of CEH hours for a
couse that they developed, and in reality they should probably be given
double the CEH hours, considering the time necessary to develop and
implement a CEH course.
Why not give credit to the instructor for all of the CEH courses that they
are currently maintaining. I think the instructor is being snubbed, as they
are probably the ones who are the best trained, of all the system
operators.
Instructor credits are not lenient enough. Anyone who has done training
knows that the preparation time for a training sesssion is much more that
the time it takes to present the session. I suggest 3.0 CEH for each CE
credit hour of a learning activity presented not the proposed 1.0.
Draft for Comments
July 28, 2004
Page 32 of 42
NERC System Operator Certification Phase II
Tim Hattaway
Energy Control Center Manager
Alabama Electric Cooperative
Kevin Conway
Grant County PUD
Jeff Boltz
System Operator / Trainer
First Energy, Reading Control
Center
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
Dennis F. Felgate, P. Eng.
Sask Power
dfelgate@saskpower.com
John Neagle
Associated Electric Cooperative,
Inc.
JNeagle@AECI.org
Administrative Guidelines
It seems that having the learning activites too closely tied to a particular
certificate will discourage people who are not required to become NERC
Certified such as marketers, planners and back-office personnel from
attempting to get certified. The smaller companies may be forced to
increase their training dollars in order to comply with this CEH program
may elect to disreguard certification for non-essential personnel such as
marketers, planners and back-office personnel. Even though the CEH
program is designed around the system operator, those that have
acquired NERC certification has expanded well beyond just the system
operator to include others that now at least have an understanding of
basic principles of system operations.
There is a lot of information contained in the above paragraph. It is
important for us to understand that even though the Operator is the one
being certified, it is the employer who is being sanctioned. We need to
allow the employer more latitude in what classes are selected and,
against current privacy concerns, how well the Operator is doing in these
classes. Secondly, we have created a large hurdle for the companies by
limiting them to classes that may only be available in difficult (possibly
expensive) locations, and may not deal specifically with the direct
responsibilities of the Operator being certified. This may be the only
training that fits in the time frame to keep an operator certified under the
program.
7, I s a calendar year start on January 1, or is it 12 months from their
certification date?
8, Stated here is 1 for 1, however in FAQ dated July 19, 2004 Question 79
states 1.5 for each 1 CEH, which is correct? I would assume 1 to 1 for
reception, and 1.5 to 1 for developing and delivery.
Also how much credit does an instructor get for developing the course but
not delivery?
General comment, per FAQ dated July 19, 2004 Answer 122 states that
"providers" may not wish to be posted on the website. This should be
amended to require all providers and sponsors should be posted. If the
provider or sponsor only delivers to his or her own respected utility that
should be mentioned. This would ensure that students signing up for CEH
credits with an outside provider or sponsor is NERC approved, preventing
them from contacting NERC evertime they sign up for a course to verify
the providers staus as stated in Answer 122.
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.
Instructor Credits - must be referring to a certified system operator
leading the instruction of a training course? I am hoping it is not
referring to instructors accumulating CEH's!
As stated above, Associated Electric Cooperative Inc. believes the level of
CEH required to maintain a credential and the stipulation that CEH will be
recognized only from NERC approved providers and for NERC approved
learning activities is excessive. The PCGC should consider reducing the
number of CEH required and relaxing the requirements to allow
recognition of documented, on-going, in-house training on recognized
topics.
Draft for Comments
July 28, 2004
Page 33 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
Williams, Robert
PacifiCorp
Robert.Williams@PacifiCorp.com
Given the time and efforts required to develop and present a learning
activity, there should be more credit given to the instructors.
Terry Banks
Senior System Operator
(Training)
NB Power
tbanks@nbpower.com
Our operation have Monthly Operators Meetings where operational topics
are discussed, there are topics on lessons learned and reviews of proper
operating procedures. Can a NERC Provider approve those topics? After
the meetings been held? Is a test/evaluation required for those topics to
be approved?
Our operation has always used field exposure in conjunction with training
courses. Could this field training quailify for CE credits?
NERC Recommendation #6 requires 5 days of emergency training and
drills each year. Is this emergency training in addition to other training?
Can this be included for CEH hours? Can they be included as the NERC
operating policies and standards requirements?
Draft for Comments
July 28, 2004
Page 34 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
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
July 28, 2004
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NERC System Operator Certification Phase II
Administrative Guidelines

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.

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, 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
July 28, 2004
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NERC System Operator Certification Phase II
Administrative Guidelines
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.

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, 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:
Truman S. Buffington
1071 Emerald Drive
Brandon, FL 33511-6521
scottybcoder@esosoftware.com
Your “System Operator Certification Program Administrative Guidelines” is
an excellent document in that it provides a good cookbook of training
subjects in which a System Operator should demonstrate proficiency.
However, though it mentions NERC-approved providers, it mentions no
texts. Consequently, the time frames for continuing education hours seem
to be somewhat arbitrary.
June 2001 I retired from Tampa Electric Company as a NERC Certified
System Operator,
Certificate # N19981204.
Since that date I have been a training consultant to Tampa Electric. I
have trained six neophytes to be NERC Certified System Operators for
Tampa Electric. Some had power plant experience; some had marketing
experience; most had limited math skills.
I found that using the “NERC Operating Manual” and the Second Edition of
the EPRI manual, “Interconnected Power System Dynamics Tutorial”, I
Draft for Comments
July 28, 2004
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NERC System Operator Certification Phase II
Administrative Guidelines
could teach these trainees the fundamentals of operating the power
system according to NERC’s mandate for Reliability Coordinators using 160
hours of classroom time. In addition, these trainees have spent or will
spend the remainder of either 10 or 12 months on the job training,
according to demonstrated proficiency. This training includes
approximately 40 hours of advanced applications and operations
simulations.
I strongly believe that seasoned System Operators could complete the
same classroom program in 120 hours.
Thirty hours for advanced applications and operations simulations, while
better than no mandate at all, seems to me to be inadequate. I believe
that 40 hours would be more appropriate.
The first edition of the EPRI manual, mentioned above, was written by
PTI. It was copyrighted in 1989. The second edition was prepared by
KEMA-ECC, Inc., in 1998. It was re-written using input from users of the
first edition.
Since 1978 I have reviewed many texts pertaining to operating the power
system. The Section Edition of the EPRI manual is the best I’ve seen.
The abstract for the text states that the text is meant to be a tutorial and
a REFERENCE RESOURCE for both System Operators and Operations
Engineers.
I strongly feel that every control room on the continent should have copies
of this text lying around for reference.
Though the text was copyrighted in 1998, it is entirely appropriate for
today’s congested transmission grid.
I urge the committee to review this text and consider adopting it for all
NERC-approved providers of System Operator continuing education
program. In addition, you should consider making it a mandatory
companion to the NERC Operating Manual for System Operations
reference resource.
In the world of System Operator training material, the EPRI text is nothing
short of a TREASURE, possibly worth more than all the rest put together.
Brad Calhoun
Training Coordinator
CenterPoint Energy
Real Time Operations
(713) 207-2744
I am reviewing the Continuing Education White Paper and have a
question.
Will CE hours an operator earns toward his certificate also count as a
hours for the annual system emergency training requirement? In other
words, will a TO have to earn 40 hours annually for certification and an
additional 40 hours for system emergency training for a total of 80 hours?
Thanks.
Jim Eckels
1 - Can the "30 CEH on NERC operating policies and standards" include
Draft for Comments
July 28, 2004
Page 38 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
Senior Transmission Specialist
Transmission Operations
Support - Training Dept.
First Energy - SCC Wadsworth,
Ohio
(330) 336-9049
jleckels@firstenergycorp.com
King, Scott
Scott.King@XCELENERGY.COM
Regional policies and standards?
2 - Need to define per year as July 1 - June 30
Mark
FRCC
My comments amount to a blanket NO. The requirements for CEH's that
NERC is proposing is unreasonable for each of the authorities. They are
asking/commanding utilities to provide education to their operators
enough ceh's to earn a Bachelors degree every three years. I don't agree
with this at all. 240 cehs every three years is absolutely ridiculous. That's
80 a year for the three years. The committee that came up with this
should rethink their recommendations .
1. The continuing education requirement for recertication is a great idea.
I think that a certain amount of continuing
education/training should
become mandatory regardless of recertification. If an individual is from a
small company unwilling to spend the necessary CEH dollars, will he/she
be able to take a test every three years in lieu of continuing education?
Will this individual be as qualified or remain as qualified/trained as their
counterparts by merely passing a test? (Most likely - NOT)
KULT, KENNETH D
kkult@oppd.com
I feel the testing change would add to the stress of all operators. My
thoughts are to go to a monthly mini test, over each policy with a needed
passing grade. A copy of the passed policy and score could be sent the
manager to insure they are being done. There could be a charge for this
program so funds would be lost. A yearly test could be given on the
updated policies. Each operator could be given a code number and
password for your records. The reason for the test - is to make sure the
operators are staying up with the needed information. The mini test would
assure this is taking place. This testing should be to keep all trained and
informed - not - to add to the stress of the job.
2. The number of required CEH's for the upper two levels require 180
and 240 CEH's. With the average week of training currently yeilding only
20 plus CEH's, an individual will have to attend the equivalent of 9-12
weeks of certified training to maintain their certification over a 3 year
period. Many companies are marginally staffed making it very difficult to
allow each operator 3-4 weeks of certified training
per year, not to mention the training costs. I don't think my company will
send our marginal staff to this much training unless it is mandatory.
3. The cost of evaluating and certifying each organization's simulator
training program and/or inhouse training plus continued evaluation and
monitoring could become quite costly.
Steve Rainwater
Steve.Rainwater@lcra.org
Training Coordinator
Lower Colorado River Authority
Kenneth Parker
tpkbp@tecoenergy.com
4. I didn't see any proposed date for implementation of the proposed
program.
How is purchased training material handled vis-a-a vis this proposal? For
example if a contractor develops a course of instruction that is submitted
to NERC and approved as a learning activity and then sold to a utility for it
to provide to its' employeees how is that documented? Does the approval
cross from the seller to the buyer? It needs to be defined.
Congratulations on a job well done, the program content looks good to
me. Will the NERC Training Courses count toward CEH's? Will there be
Draft for Comments
July 28, 2004
Page 39 of 42
NERC System Operator Certification Phase II
Dan Godiksen
Electric System Dispatcher
CWLP
Mike
phenimp@selectenergy.com
Al Parsons
NCPA Manager, System
Operations
Tim Hattaway
Energy Control Center Manager
Alabama Electric Cooperative
Kevin Conway
Grant County PUD
Ray Gross, PJM
610-630-7208
610-666-8890
grossrc@pjm.com
Administrative Guidelines
a listing of approved courses and their providers?
1) Do you have a process in which Reservists who are re-called for active
duty (up to 2 years) can have their time stopped and then re-instated
upon
their return? If not and they do fall into a suspended or revoked status,
potentially causing them to loose their position, would this violate their
rights and job protection guaranteed by law?
Would like to see a list of NERC approved training courses with web links
to providers of classes.
I have a System Operator who has her certification expiring in December
2004. Is there going to be an extension for those folks to have time
enough to get CE hours?
I suggest that NERC grant operators certain amount of time to achieve the
120 CE hours before they are put on the expiration list. If you were to
divide the 120 hours up into 40 hours per year, then as long as the
operator completes 40 CEH they could keep their certification. I would
suggest at lease a 6-month extension of their certification to pass this
hurdle.
Some method of OJT should be allowed.
Is this a definitive list of subjects? Perhaps it would be better to establish
a point based system of each category. Instead of adding up hours
needed, have each Operator meet a certain point goal for each
certification.
Again, I am concerned that there is a huge burden put on employers to
maintain a properly certified group of Operators, yet not giving them the
proper mechanisms to police the individuals. Further, I am concerned of
the financial burdens that will be placed on the employers. Due to the
mature workforce ( high levels of accured leave, increased illness
experianced, etc) it will be very difficult for the employer to arrange for
training needs without increasing staffing, and costs. It is my opinion that
this will lead to low acceptance.
PJM Dispatcher Training Task Force Comments on the NERC
Recertification Whitepaper
1. The state of the NERC Continuing Education Program is just starting out
having been launched on 3/1/04. There are not an adequate number
NERC approved providers (< 50) nor CEH approved courses to ensure all
operators in all NERC Regions have reasonable access to appropriate NERC
approved continuing education opportunities.
2. The operator is dependent on enough CEP approved training activities
to satisfy the requirements for re-certification. What signposts will the
PCGC use to determine if and when adequate training resources are
available to satisfy the needs of all operators?
3. Categories of Continuing Education Hours are not adequately detailed
to ensure that an operator maintains currency on all relevant NERC
Policies and related tasks required for the respective credential. For
instance, for the RO or TO there is no assurance that training completed
reflects all critical tasks the operator performs.
Draft for Comments
July 28, 2004
Page 40 of 42
NERC System Operator Certification Phase II
Administrative Guidelines
An alternate approach combining retesting and completion of NERC CEHs
would provide greater assurance that an operator remains current.
4. There are no provisions to address instances where differences exist
between the amount of training reported to NERC by a sponsors and a
system operator. For instance, is the operator penalized if the sponsor
fails to report training completed by one or more system operators. Similar
situations may occur if the sponsor ceased operations due to bankruptcy
or if the sponsor suffered a major computer systems failure.
5. There needs to be more detail regarding what qualifies for the CEP
training categories of NERC Policy and Related to Credential. For instance
for the first category, NERC operating policy and standards, does it include
training on regional and/or operating company policy, or is it strictly
limited to NERC policy and standards? There is no explanation in either
the CEP admin Manual or the PCGC Whitepaper.
6. Currently there are no provisions in the NERC CEP to recognize or
report simulations as a distinct sub-category of credential related training.
7. The provisions for the operator who does not satisfy the three year
CEH requirement results in putting additional challenges on the individual
who is put on suspension, then gets re-instated which could result in
having only two years to satisfy the subsequent 3 year CEH quota.
8. There are no provisions to allow an operator with extenuating
circumstances to submit a request for an extension or exception to
provisions laid out in the White Paper. The PCGC may be exposed to legal
challenge by an operator who is denied employment due to suspension of
the credential due to circumstances beyond the individual’s control.
9. What are the implications for an operator with a record of a suspended
NERC credential? Is the record permanent, or is it expunged after a
certain period? Does the penalty escalate if a second suspension were to
occur?
10. The provisions of “Changing Certification Levels” may permit B/I, and
Transmission operators to take an alternate exam to maintain a valid
credential rather than earning the stipulated number of CEHs. There
appears to be nothing stopping someone with a BI/TO credential from
taking the TO exam, and then 3 years later take the BI/TO exam, etc.
11. Provisions of the Whitepaper conflict with the NERC CEP program in
terms of granting a trainer CEHs for course development efforts. Also,
trainers of system operators are handicapped if they deliver repeated
sessions of the same course, in contrast to trainers who deliver single
sessions of a variety of courses.
12. It would be informative if the authors of the whitepaper (PCGC) were
to provide in the preamble their “vision” of the NERC Certification Program
and the rationale for functionally barring the recertification of a number of
individuals through re-examination who voluntarily hold a NERC credential.
Draft for Comments
July 28, 2004
Page 41 of 42
NERC System Operator Certification Phase II
Maki, Ron
Ron.Maki@aquila.com
Administrative Guidelines
Is the next step to establish prerequisites for candidates which may
restrict access to NERC exams?
1.
The number of hours for all credentials is excessive. The CEH
program is a good idea but the numbers should be ½ of the proposed
amount or extend the certificate to 5 years. The 5 days of EM training
should be incorporated as part of the hours required.
2.
All credentials need a certain amount of general knowledge, getting
too specialized in these areas. Operators will be missing out on the big
picture.
3.
Time frame for all training requirements needs to be specific. Is the
calendar year for the 5 days EM training the same as CEH?
4.
Why the 3 year requirement versus the 5 year certificate?
5.
NERC needs to publish a list of approved CEH providers.
6.
Have an extension process in place where an experienced Operator
may apply for additional time due to company or personal emergencies.
Leo St. Hilaire
Program Development
Coordinator
Manitoba Hydro
John Neagle
Associated Electric Cooperative
Inc.
jneagle@aeci.org
7.
Clarify transition and time frame into the new program.
8.
Clarify who will keep track of the hours and who will pay for them.
9.
A test out process in place in lieu of CEH.
Agree with concepts but would have liked to seen professional
development addressed.
Several topics are recognized for either Transmission Operator or
Balancing and Interchange Operator CEH but are not included on the
combination Balancing and Interchange / Transmission Operator list. It
would seem that a topic recognized for either of the individual credentials
should be recognized for the combination credential.
These comments are submitted by:
Draft for Comments
July 28, 2004
Page 42 of 42