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2016-EPR-01 Enhanced Periodic Review of PER Standards | Templates for PER-003-1 and PER-004-2

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Start Date: 01/10/2017
End Date: 02/23/2017

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For PER-003-1, it is unclear as to where this footnote will be added, i.e., is it under R1, R2 or R3, or all of the above. This needs to be clarified but the SRC questions whether it is worth the effort in creating a SAR given that there is significant effort involved in creating a SAR, forming a drafting team and processing the proposed changes through the NERC and FERC regulatory processes.  SRC is of the opinion that the proposed footnote addition does not provide enough of a justification for the amount of effort needed for the industry to put out a SAR, form a drafting team, recommend changes and get the proposed changes through the NERC and regulatory process.

ISO/RTO Council Standards Review Committee, Segment(s) 2, 2/23/2017

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(1)   We agree that a footnote should be added to NERC Reliability Standard PER-003-1 that clarifies its dependency on the NERC System Operator Certification Program.  However, we feel the Periodic Review Team (PRT) has neglected to address an urgent compliance gap present following recent changes to the NERC System Operator Certification Program, and urge the PRT to revise its recommendation to identify that a revision to the standard is necessary.

(2)   We observe no complementary mechanism that ties the NERC System Operator Certification Program back to this reliability standard.  At a minimum, we expect direct, one-for-one alignment between the areas of competencies and the content domains identified as the framework used to ensure the content validity of each NERC certification exam.  From what we observe, these content domains were updated recently in the 2017 NERC Exam Resource Materials posted on the NERC web site (http://www.nerc.com/pa/Train/SysOpCert/Pages/default.aspx).  For comparison, we attached a similar list of content domains from 2012.  Without this alignment and when the requirements within this standard are taken verbatim, then industry is burdened to demonstrate that a minimum competency has been obtained for applicable staff performing Real-time, company-specific, reliability-related tasks.

(3)   The current approach to the interdependencies between this reliability standard and the NERC Continuing Education Program relies on the assumption that all registered entities are also NERC Continuing Education Providers.  We find this is not always the case.  We believe the minimum set of competencies System Operators must maintain are already addressed by the systematic training approach required by their employers in NERC Reliability Standard PER-005-2.  At a minimum, we ask the PRT to document in its recommendations that further coordination with the NERC Personnel Certification Governance Committee is necessary to update the list of Recognized Operator Training Topics, as identified in Appendix A of the NERC System Operator Certification Program Manual.  We feel this list needs to be revised with current industry concerns, situation awareness and human performance-centric themes, and available technologies.

(4)   We ask the PRT to expand its recommendation to include a footnote reference to the NERC Personnel Certification Governance Committee (PCGC) and the importance of its role in monitoring the performance of the NERC System Operator Certification Program.

ACES Standards Collaborators, Segment(s) 1, 5, 4, 3, 2/23/2017

NERC 2012 Exam Study Guide.pdf

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Other Answers

John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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Daniel Herring, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Jeffrey DePriest, On Behalf of: Jeffrey DePriest, , Segments 3, 4, 5

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BPA has no objections to this proposed edit for clarification.

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

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Rick Applegate, On Behalf of: Rick Applegate, , Segments 1, 3, 4, 5, 6

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Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Santee Cooper , Segment(s) 1, 2/7/2017

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

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This recommendation may be suitable if the standard was being revised for a substantive reason, but to make a change to the standard to implement this recommendation is unwarranted. The footnote is unnecessary for any RC, TOP, and/or BA stakeholder worthy of performing functions to which this standard applies.

The purpose statement in PER-003-1 specifically states the standard 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."

In addition, requirement 1 specifically references a "...valid NERC Reliability Operator certificate...", while requirements 2 and 3 specifically references "...obtaining and maintaining one of the following valid NERC certificates..." and specifically lists applicable NERC certifications for each requirement.

Further, the PER-003 RSAW has auditor guidance that the "...Audit Team may contact NERC to confirm the certification information is valid." This guidance points to the NERC Syystem Operator Certification Program and associated manual. It would require a tortured argument to point these references to certifications or a certification program other than NERC.

Considering the above references, coupled with historic precedent from previous audits, there should be no need to include a footnote to ensure BAs, TOPs, and RCs "understand (i) the connection between the Standard and the NERC System Operator Certification Program Manual; and (ii) that the certifications referenced under PER-003-1 are those under the NERC System Operator Certification Program."

LeRoy Patterson, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Entergy Agrees with adding a footnote to PER-003-1 Standard.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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Lauren Price, On Behalf of: Lauren Price, , Segments 1

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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AEP believes the standard is sufficiently clear in this regard as currently written. The current version of these requirements all specify NERC certificates, so a direct correlation to the NERC System Operator Certification Program Manual should already be clear. While AEP does not entirely object to the concept of explicitly referencing the SOC Program Manual in PER-003-1, care should taken to ensure that additional obligations aren’t unintentionally implied (say, from the content of the manual itself) by doing so.

 

Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Scott Downey, On Behalf of: Scott Downey, , Segments 1

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We don't think this has been an issue in the past, however we do not object to the clarifying footnote being added.

Quintin Lee, On Behalf of: Eversource Energy, , Segments 1, 3, 5

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The suggested clarification to highlight that certifications required under PER-003-1 must be NERC certifications appears reasonable, particularly in light of the proposed retirement of PER-004-2.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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The SPP Standards Review Group agrees with the Periodic Review Team’s (PRT) recommendation for adding a footnote to provide more clarity in the Standard. Additionally, we suggest the drafting team add a Guideline and Technical Basis (GTB) Section to the Standard to help provide clarity in reference to the Requirements. Also, we suggest reformatting the Measurements in the current Standard. We feel this will help provide consistency with the current formatting of newly developed and revised Standards in reference to the Requirement and Measurement Process. The best example of the current formatting process would be demonstrated in the IRO-002-4 Standard.

SPP Standards Review Group, Segment(s) , 2/23/2017

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While we do not feel strongly one way or the other with the proposed addition of a clarifying footnote, we are unclear on where that footnote will be added, i.e., is it under R1, R2 or R3 or all of the above. We wonder if a seemingly minor change would provide sufficient reliability improvement to warrant the effort needed to effect the change (e.g., forming a drafting team, going through the approval process, etc.).  Also, the PER-003-1 EPR template indicates sub-parts (a) to (g), which are not found in the PER-003 standard. This needs to be clarified in the SAR.

There is already a footnote related to each requirement R1, R2 and R3 in PER-003-1 which ties to the NERC Operator Certification Program.

FN1 of PER-003-1 Non-NERC certified personnel performing any reliability-related task of a real-time operating position must be under the direct supervision of a NERC Certified System Operator stationed at that operating position; the NERC Certified System Operator at that operating position has ultimate responsibility for the performance of the reliability related tasks.

RSC no Dominion and Eversource, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 2/23/2017

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Hot Answers

ISO/RTO Council Standards Review Committee, Segment(s) 2, 2/23/2017

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Thank you for the opportunity to comment.

ACES Standards Collaborators, Segment(s) 1, 5, 4, 3, 2/23/2017

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Other Answers

John Williams, On Behalf of: John Williams, , Segments 1, 3, 5

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Karen Webb, On Behalf of: Karen Webb, , Segments 1, 3, 5

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Daniel Herring, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Karie Barczak, On Behalf of: DTE Energy - Detroit Edison Company, , Segments 3, 4, 5

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Jeffrey DePriest, On Behalf of: Jeffrey DePriest, , Segments 3, 4, 5

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BPA believes that this Standard is for Reliability Coordinators and does not apply to BPA, therefore BPA has no objections to this proposed recommendation.

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

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Rick Applegate, On Behalf of: Rick Applegate, , Segments 1, 3, 4, 5, 6

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Glen Farmer, On Behalf of: Avista - Avista Corporation, , Segments 1, 3, 5

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Santee Cooper , Segment(s) 1, 2/7/2017

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

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However, this organization is not a Reliability Coordinator so PER-004 does not apply to us.

LeRoy Patterson, On Behalf of: Public Utility District No. 2 of Grant County, Washington, , Segments 1, 4, 5, 6

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Michelle Amarantos, On Behalf of: APS - Arizona Public Service Co., , Segments 1, 3, 5, 6

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Southern Company, Segment(s) 1, 6, 3, 5, 9/1/2016

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Douglas Webb, On Behalf of: Great Plains Energy - Kansas City Power and Light Co., SPP RE, Segments 1, 3, 5, 6

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Entergy agrees on the retirement of the PER-004 Standard.

Oliver Burke, On Behalf of: Entergy - Entergy Services, Inc., , Segments 1, 5

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Lauren Price, On Behalf of: Lauren Price, , Segments 1

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Sean Bodkin, On Behalf of: Dominion - Dominion Resources, Inc., , Segments 3, 5, 6

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Laura Nelson, On Behalf of: Laura Nelson, , Segments 1

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

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sean erickson, On Behalf of: Western Area Power Administration, , Segments 1, 6

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Thomas Foltz, On Behalf of: AEP, , Segments 3, 5

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Peak respectfully disagrees with the recommendation that PER-004-2 be retired. PER-004-2 R1 states that each Reliability Coordinator shall be staffed 24 hours per day, seven days per week. This requirement is not adequately captured in other standards outlined in the PER-004-2 EPR template. Peak suggests consideration be given to incorporating the 24x7 staffing language into PER-003-1 R1.

Scott Downey, On Behalf of: Scott Downey, , Segments 1

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We agree that the requirements of PER-004-2 are duplicative and that it can be retired

Quintin Lee, On Behalf of: Eversource Energy, , Segments 1, 3, 5

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Both PER-004-2 requirements do appear to be substantially addressed by other reliability requirements.

Rachel Coyne, On Behalf of: Texas Reliability Entity, Inc., , Segments 10

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We truly appreciate the efforts of the Periodic Review Team (PRT) on identifying the Paragraph 81 Criteria associated with this particular Standard. The SPP Standards Review Group is in agreeance with the recommendation of retirement of this Standard.

SPP Standards Review Group, Segment(s) , 2/23/2017

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RSC no Dominion and Eversource, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 2/23/2017

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