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2017-02 Modifications to Personnel Performance, Training, and Qualifications Standards | PER-003-2 and Implementation Plan

Description:

Start Date: 01/22/2018
End Date: 03/07/2018

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End
2017-02 Modifications to Performance, Training, and Qualifications Standards PER-003-2 IN 1 ST 2017-02 Modifications to Performance, Training, and Qualifications Standards PER-003-2 01/22/2018 02/20/2018 02/26/2018 03/07/2018
2017-02 Modifications to Performance, Training, and Qualifications Standards Implementation Plan IN 1 OT 2017-02 Modifications to Performance, Training, and Qualifications Standards Implementation Plan 01/22/2018 02/20/2018 02/26/2018 03/07/2018

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Hot Answers

Colleen Campbell, On Behalf of: ACES Power Marketing, NA - Not Applicable, Segments 6

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 3/2/2018

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Other Answers

changes are minor for TOP’s and just add clarification with a new “footnote”

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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The clarification should be made in the NERC Glossary of Terms.  The use of footnotes to define the terminology could result in different Standards being interpreted differently base on footnoting.  Standards may eventually begin to conflict based on how different terms are used in specific context.  Though not a major issue for the current project it sets a precedent that opens the door to problems down the road.

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/8/2018

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, 2/21/2018

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Adding a footnote to PER-003 to reference the certification program is short sightedness from the Standards Drafting Team. The key words in this standard as well as many others is "System Operator". Itwould be better to redo the System Operator definition in the NERC Glossary of Terms to include "a NERC certified individual" and add the reference to the NERC System Operator Certification Program Manual.

Aimee Harris, 2/23/2018

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As stated in our previous comments related to Project 2016-EPR-01, AEP believes the standard as currently written is sufficiently clear in this regard. The current version of the standard states that its purpose is “to ensure that System Operators performing the reliability-related tasks of the Reliability Coordinator, Balancing Authority and Transmission Operator are certified through the NERC System Operator Certification Program when filling a Real-time operating position responsible for control of the Bulk Electric System.” This, coupled with the references to “NERC Reliability Operator certificate” within the requirements themselves, provides a clear and direct correlation to the certification specified within the NERC System Operator Certification Program Manual. As a result, we see no lack of clarity within the standard. While AEP does not entirely object to the concept of explicitly referencing the SOC Program Manual in the requirements of PER-003-1, extreme care should be taken to ensure that additional obligations are not unintentionally implied by generally referring to the entire manual as a whole.

In response to our previously submitted comments, the drafting team states in their July 2017 consideration of comments document that “The intent of the SAR DT is not to expand the standard to reflect anything more than the certifications referenced in the NERC System Operator Certification Program Manual not the manual in its entirety.” While we are sure it is not the drafting team’s intent that additional obligations be implied, that risk nonetheless remains (say perhaps, when read by an auditor). While AEP does not believe that the proposed clarifying language and footnote is needed, if one is indeed pursued, we suggest instead using “The NERC certificates certified credentials referenced in this standard pertain to those certificates identified in the NERC System Operator Certification Program Manual.”

Thomas Foltz, AEP, 5, 2/26/2018

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SRP believes the current standard does not require additional clarification as to the type of certification required. However, SRP does not have concerns with adding the proposed footnote.

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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I support the comments submitted by Salt River Project. 

Robert Kondziolka, 2/28/2018

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Sandra Shaffer, 2/28/2018

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Michelle Amarantos, APS - Arizona Public Service Co., 5, 3/2/2018

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Texas RE does not have comments on this question.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/2/2018

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Minnkota would like to sign on the the NERC Standards Review Forum comments as follows:

The NSRF agrees with the additional foot note but disagrees with the Areas of Competency in R1, R2 and R3.  RCs, BAs and TOPs have no control over the Areas of Competency within a NERC Certificate exam.  The exam is based on other mechanisms (the PCGC) that BAs, TOPs and RCs have no control over.  Is “minimum competency” passing the NERC exam?   Entities cannot prove that a System Operator passed with minimum competency, the components under past 1.1, 2.1, and 3.1.  The written Measures do not indicate what level of “minimum competency” only that NERC certificate (or NERC number) is required.  The Areas of Competency do not support the reliability BES and is a legacy issue from years ago.  The Areas of Competency  are strictly within a test that Registered Entities have no control over.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  The NSRF agrees that no one has been found non-compliant and this is a simple item to satisfy during an audit.  But we are looking to gain efficiencies everywhere we can, and this is some low hanging fruit that can be corrected with a simple stroke of the SDT pen.  The NSRF agrees that NERC Certification is required for RCs, TOPs and BAs and do not wish for this Standard to be retired (PER-003-1).  There is a current NERC Certification survey that asks many questions about NERC Certification.  That is being attributed to the PCGC and not this SDT.  The SDT has the power to gain one more efficiency for the Applicable Entities of PER-003-1.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  If the SDT does not move forward with this request, than time, resources and valuable funding will be wasted on opening another Project to address this simple concern.

Theresa Allard, Minnkota Power Cooperative Inc., 1, 3/2/2018

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DTE Electric, Segment(s) 3, 4, 2/28/2018

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Douglas Johnson, 3/5/2018

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Laura Nelson, 3/5/2018

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Aubrey Short, 3/5/2018

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The footnote does provide clarity in regards to the specfication of what certificates are being addressed. 

However, PGE has concerns regarding the referencing of documents, in this case a manual, in a footnote, that is controlled outside of the Standard Development process. 

PGE - Group 1, Segment(s) 3, 5, 1, 6, 8/5/2016

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Leonard Kula, Independent Electricity System Operator, 2, 3/6/2018

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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ISO/RTO Council Standards Review Committee, Segment(s) 2, 3/6/2018

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Alliant Energy supports the following comments from the MRO NSRF:

The NSRF agrees with the additional foot note but disagrees with the Areas of Competency in R1, R2 and R3.  RCs, BAs and TOPs have no control over the Areas of Competency within a NERC Certificate exam.  The exam is based on other mechanisms (the PCGC) that BAs, TOPs and RCs have no control over.  Is “minimum competency” passing the NERC exam?   Entities cannot prove that a System Operator passed with minimum competency, the components under past 1.1, 2.1, and 3.1.  The written Measures do not indicate what level of “minimum competency” only that NERC certificate (or NERC number) is required.  The Areas of Competency do not support the reliability BES and is a legacy issue from years ago.  The Areas of Competency  are strictly within a test that Registered Entities have no control over.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  The NSRF agrees that no one has been found non-compliant and this is a simple item to satisfy during an audit.  But we are looking to gain efficiencies everywhere we can, and this is some low hanging fruit that can be corrected with a simple stroke of the SDT pen.  The NSRF agrees that NERC Certification is required for RCs, TOPs and BAs and do not wish for this Standard to be retired (PER-003-1).  There is a current NERC Certification survey that asks many questions about NERC Certification.  That is being attributed to the PCGC and not this SDT.  The SDT has the power to gain one more efficiency for the Applicable Entities of PER-003-1.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  If the SDT does not move forward with this request, then time, resources and valuable funding will be wasted on opening another Project to address this simple concern.

Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/6/2018

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The NSRF agrees with the additional foot note but disagrees with the Areas of Competency in R1, R2 and R3.  RCs, BAs and TOPs have no control over the Areas of Competency within a NERC Certificate exam.  The exam is based on other mechanisms (the PCGC) that BAs, TOPs and RCs have no control over.  Is “minimum competency” passing the NERC exam?   Entities cannot prove that a System Operator passed with minimum competency, the components under past 1.1, 2.1, and 3.1.  The written Measures do not indicate what level of “minimum competency” only that NERC certificate (or NERC number) is required.  The Areas of Competency do not support the reliability BES and is a legacy issue from years ago.  The Areas of Competency  are strictly within a test that Registered Entities have no control over.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  The NSRF agrees that no one has been found non-compliant and this is a simple item to satisfy during an audit.  But we are looking to gain efficiencies everywhere we can, and this is some low hanging fruit that can be corrected with a simple stroke of the SDT pen.  The NSRF agrees that NERC Certification is required for RCs, TOPs and BAs and do not wish for this Standard to be retired (PER-003-1).  There is a current NERC Certification survey that asks many questions about NERC Certification.  That is being attributed to the PCGC and not this SDT.  The SDT has the power to gain one more efficiency for the Applicable Entities of PER-003-1.  The NSRF recommends that the Areas of Competency within R1, R2 and R3 be removed since this Project is currently active.  If the SDT does not move forward with this request, than time, resources and valuable funding will be wasted on opening another Project to address this simple concern.

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 6/14/2017

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SPP Standards Review Group, Segment(s) , 3/7/2018

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David Ramkalawan, 3/7/2018

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Hien Ho, Tacoma Public Utilities (Tacoma, WA), 4, 3/7/2018

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Hot Answers

We thank you for the opportunity to comment.

Colleen Campbell, On Behalf of: ACES Power Marketing, NA - Not Applicable, Segments 6

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RSC no ISO-NE, Segment(s) 10, 2, 4, 5, 6, 7, 1, 3, 3/2/2018

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Other Answers

changes are minor for TOP’s and just add clarification with a new “footnote”

Maryanne Darling-Reich, On Behalf of: Black Hills Corporation - WECC - Segments 1, 3, 5, 6

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In reviewing the arguments for retirement of PER-004 we are not sure the issue of 24 hours staffing is adequately addressed in the other cited standards.  Other standards address "Reliability Coordinator" as an entity, not "Reliability Coordinator Operating Personnel".  We believe the drafting team has good reason to retire PER-004-2, and the argument seems intuitive; however, due to enhanced technology, removing the staffing requirements could introduce arguments that 24 X 7 staffing is not required by the standards.  It could be further argued that certain activities do not need Certified Operating Personnel oversight because they are automated.  Since Reliability Standards have been made mandatory there have been continuous arguments over business authority, Entity v. Operating Personnel, who specifically needs to be certified, and who determines staffing. 

Kevin Conway, Public Utility District No. 1 of Pend Oreille County, 1, 2/8/2018

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Kristine Ward, On Behalf of: Seminole Electric Cooperative, Inc., FRCC, Segments 1, 3, 4, 5, 6

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Laurie Williams, 2/21/2018

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Aimee Harris, 2/23/2018

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Thomas Foltz, AEP, 5, 2/26/2018

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SRP believes in order to retire PER-004-2 R2, language should be incorporated into the proposed PER-003-2 requiring each RC to staff their Real-Time operations 24 hrs/day.

Neil Swearingen, On Behalf of: Salt River Project, WECC, Segments 1, 3, 5, 6

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Aaron Cavanaugh, On Behalf of: Bonneville Power Administration, WECC, Segments 1, 3, 5, 6

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I support the comments submitted by Salt River Project. 

Robert Kondziolka, 2/28/2018

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Sandra Shaffer, 2/28/2018

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Michelle Amarantos, APS - Arizona Public Service Co., 5, 3/2/2018

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Texas RE appreciates the Standard Drafting Team’s (SDT) efforts to implement the Enhanced Periodic Review (EPR) team’s recommendations.  Texas RE recognizes that there is significant overlap between PER-004-2 and other training Standards, including PER-003 and PER-005.  However, Texas RE remains concerned that retiring PER-004-2 R1 could introduce unnecessary ambiguity.  Specifically, while other PER and IRO requirements cited by the EPR team as overlapping with PER-004-2 R1 contain similar elements, they do not appear to be as explicit regarding NERC-certification requirements and the adequacy of training in connection with those requirements as existing PER-004-2 R1, which is proposed for retirement. 

 

As noted in its response, the SDT relies on PER-003-1 R1 and PER-005-2 R1 to address training issues.  While both standards address aspects of training, neither provide an unambiguous obligation for applicable entities to provide adequate training to their personnel in all circumstances.  For instance, PER-003-1 R1 provides that “Real-time operating positions performing Reliability Coordinator reliability-related tasks with System Operators who have demonstrated minimum competency in the areas listed by obtaining and maintaining a valid NERC Reliability Operator certificate.”  (emphasis added).  It further specifies Areas of Competency, including “Emergency preparedness and operations.”  (PER-003-1 R1.1.3). 

 

Under PER-003-1 R1, the sole required task appears to be for System Operators to demonstrate “minimum competency” by obtaining a valid NERC Reliability Operator certificate. 

While this requirement overlaps with the “adequate training” requirement set forth in PER-004-2 R1, it does not necessarily cover all training circumstances.  By way of example, Texas RE has encountered at least one instance in which an entity’s operators possessed NERC certifications, but had not received adequate training for properly implementing an emergency electric curtailment plan.  This lack of training exacerbated an emergency condition, prolonging an event.  It is unclear whether the language in PER-003-1 R1, with its focus solely on minimal competency demonstrated through the possession of a NERC certification would be broad enough to address circumstances in which an entity’s training was demonstrably inadequate for a particular circumstance. 

 

In addition to concerns regarding the possible narrowing of the requirement that an entity possess adequately trained operators, Texas RE remains concerned that the elimination of PER-004-2 R1 may introduce unnecessary ambiguity regarding the requirement to staff Reliability Coordinator Control Centers with NERC-certified operators on a continuous basis.  In its Consideration of Comments, the SDT constructs such a requirement by combining the requirement in PER-003-1 R1 that Real-time operating positions by staffed by System Operators with various requirements in the IRO Standard family that the SDT argues requires continuous staffing.  However, it is not clear that all Real-Time operating tasks must themselves be performed by a System Operator.  For instance, the Real-time Assessment (RTA) definition includes a statement that a “Real-time Assessment may be provided through internal systems or through third-party services.”  That is, the definition of an RTA appears to permit third-party services to perform the RTA task.  As such, it is unclear whether the continuous obligation to perform an RTA correspondingly triggers an obligation to staff a Reliability Coordinator Control Center with NERC-certified System Operators.  The SDT should avoid any ambiguity around this requirement by retaining PER-004-2 R1 as currently drafted.

Rachel Coyne, Texas Reliability Entity, Inc., 10, 3/2/2018

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Theresa Allard, Minnkota Power Cooperative Inc., 1, 3/2/2018

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DTE Electric, Segment(s) 3, 4, 2/28/2018

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Douglas Johnson, 3/5/2018

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N/A

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Laura Nelson, 3/5/2018

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Preston Walker, On Behalf of: PJM Interconnection, L.L.C., SERC, RF, Segments 2

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Aubrey Short, 3/5/2018

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PGE - Group 1, Segment(s) 3, 5, 1, 6, 8/5/2016

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Leonard Kula, Independent Electricity System Operator, 2, 3/6/2018

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Duke Energy , Segment(s) 1, 5, 6, 4/10/2014

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ISO/RTO Council Standards Review Committee, Segment(s) 2, 3/6/2018

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Larry Heckert, Alliant Energy Corporation Services, Inc., 4, 3/6/2018

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MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 6/14/2017

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SPP Standards Review Group, Segment(s) , 3/7/2018

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David Ramkalawan, 3/7/2018

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Hien Ho, Tacoma Public Utilities (Tacoma, WA), 4, 3/7/2018

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