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2017-02 Modifications to Personnel Performance, Training, and Qualification Standards

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Start Date: 06/21/2017
End Date: 07/24/2017

Associated Ballots:

Ballot Name Project Standard Pool Open Pool Close Voting Start Voting End

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Hot Answers

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

No comment.

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

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Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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Alex Ybarra, On Behalf of: Alex Ybarra, , Segments 1, 4, 5, 6

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

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The footnote provides necessary clarity.

Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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

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

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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 taken to ensure that additional obligations aren’t unintentionally implied by generally referring to the entire manual as a whole.

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

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We agree that the proposed footnote will provide the necessary clarification, but suggest to change “certifications” to certificates” to conform with the language used in the requirements.

Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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

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

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

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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No Comments

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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

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CenterPoint Energy does not believe any clarification is needed. The Purpose states, “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.” No revisions are warranted.

Michael Cruz-Montes, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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No comment

ISO/RTO Council Standards Review Committee, Segment(s) 2, 7/19/2017

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MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 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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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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SPP Standards Review Group, Segment(s) , 7/24/2017

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  1. The language listed within this question does not currently align with what is listed within the SAR.  We want to confirm that the language proposed does not identify a specific standard revision (i.e. PER-003-1).  Furthermore, we propose the footnote references the NERC Personnel Certification Program, as identified within the NERC Rules of Procedure.  We propose using this language instead for the footnote, “The NERC certificates referenced in this standard pertain to those identified under the NERC Personnel Certification Program (i.e. NERC System Operator Certification Program).”
  2. We feel the SDT has misunderstood our previous comments regarding the Enhanced Periodic Review of the PER Reliability Standards.  The scope of PER-003 is to require registered entities to staff Real-time operating positions with NERC-certified System Operators performing reliability-related tasks.  Personnel are certified through an examination process that is dictated by the NERC System Operator Certification Program and governed by the NERC Personnel Certification Governance Committee (PCGC).  However, with recent changes to the exam, as identified on the NERC web site (http://www.nerc.com/pa/Train/SysOpCert/Pages/default.aspx), we no longer see a one-to-one set of minimum competencies necessary for eligible candidates to possess in order to take the NERC System Operator Certification exam. This places a compliance burden on applicable entities to demonstrate a reasonable assurance that their NERC-certified System Operators have obtained the necessary competencies, as identified within the PER-003-1 standard.  We feel this “chicken-and-egg” problem could be entirely avoided by removing the minimum set of competencies from the standard and only requiring applicable entities to staff Real-time operating positions with NERC-certified System Operators performing reliability-related tasks.  This would also provide the NERC PCGC more control over the NERC System Operator Certification Program and not conflict with examination and continuing education requirements posted on the NERC web site.
  3. We thank you for this opportunity to provide these comments.

 

ACES Standards Collaborators, Segment(s) 1, 3, 4, 6, 5, 7/24/2017

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Hot Answers

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

PER-004-2 does not apply to BPA as BPA is not registered as a Reliability Coordinator.

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

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We are not an RC.

Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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Alex Ybarra, On Behalf of: Alex Ybarra, , Segments 1, 4, 5, 6

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

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Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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

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

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

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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

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

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

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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No Comments

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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

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Michael Cruz-Montes, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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No comment

ISO/RTO Council Standards Review Committee, Segment(s) 2, 7/19/2017

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The NSRF agrees with the PRT recommendation for retirement of PER-004-2.   

MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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This Standard is not applicable to Manitoba Hydro.

Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 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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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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Texas RE is concerned there could be a potential reliability gap in retiring PER-004-2 R1.  The SAR argues PER-004-2 is duplicative and all requirements are covered in other reliability standards.  Texas RE is concerned that without an explicit requirement to be staffed with NERC-certified operators 24/7 the RCs’ control centers may not be staffed with adequately trained personnel. Is the SDT’s position that without the explicit obligation in PER-004-2 R1 that there would be a continuing explicit obligation for RCs to be staffed with NERC-certified operators 24/7? If so, please explain and indicate the specific standard requirements including such compliance responsibility.

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

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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We would like to thank the drafting team for their efforts of pointing out the redundancy associated with this standard.

SPP Standards Review Group, Segment(s) , 7/24/2017

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 6, 5, 7/24/2017

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Hot Answers

Elizabeth Axson, On Behalf of: Elizabeth Axson, , Segments 2

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John Merrell, On Behalf of: Tacoma Public Utilities (Tacoma, WA), , Segments 1, 3, 4, 5, 6

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Other Answers

PER-004-2 does not apply to BPA as BPA is not registered as a Reliability Coordinator.

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

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We are not an RC.

Jamie Monette, On Behalf of: Allete - Minnesota Power, Inc., , Segments 1

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Alex Ybarra, On Behalf of: Alex Ybarra, , Segments 1, 4, 5, 6

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

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Daniel Grinkevich, On Behalf of: Daniel Grinkevich, , Segments 1, 3, 5, 6

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

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

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

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Leonard Kula, On Behalf of: Independent Electricity System Operator, , Segments 2

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

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

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

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Amy Casuscelli, On Behalf of: Xcel Energy, Inc. - MRO, WECC, SPP RE - Segments 1, 3, 5, 6

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No Comments

Seattle City Light Ballot Body, Segment(s) 1, 4, 6, 5, 3, 12/2/2016

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

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Michael Cruz-Montes, On Behalf of: CenterPoint Energy Houston Electric, LLC, Texas RE, Segments 1

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No comment

ISO/RTO Council Standards Review Committee, Segment(s) 2, 7/19/2017

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MRO NSRF, Segment(s) 3, 4, 5, 6, 1, 2, 7/19/2017

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This Standard is not applicable to Manitoba Hydro.

Mike Smith, On Behalf of: Mike Smith, , Segments 1, 3, 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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DTE Energy - DTE Electric, Segment(s) 5, 4, 3, 2/27/2017

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

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

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Stephanie Burns, On Behalf of: International Transmission Company Holdings Corporation - MRO, SPP RE, RF - Segments 1

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RSC, Segment(s) 1, 0, 2, 4, 5, 6, 7, 3, 7/18/2017

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SPP Standards Review Group, Segment(s) , 7/24/2017

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ACES Standards Collaborators, Segment(s) 1, 3, 4, 6, 5, 7/24/2017

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