System Operator Certification Program - NERC File… · Web view · 2012-12-19Administrative...

System Operator Certification ProgramAdministrative Guidelines

DRAFT for COMMENTS

MaintainingNERC System Operator Credential

Through the Use ofContinuing Education Credit Hours

NERC System Operator Certification Phase II Administrative Guidelines

North American Electric Reliability Council

Draft for Comments July 28, 2004 of 44


Executive SummaryThe 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.

DetailsThe 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.

TransitionA transition process has been designed so that people with current 5-year certificates can transition to the 3-year 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.



NERC System Operator Certification Phase II PreambleThe 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: Comments:John [email protected]

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.

Walker, Blake [email protected]

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.

Bill Bell Training Coordinator ISO New England [email protected]

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.

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.

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.

Macom, Todd [email protected]

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.

Everett M. StallcopSupervisor - Transmission System OperationsAEP - Public Service Company of Oklahomaoffice: (918) 610 – [email protected]

This is a great way to track the continuing education hours earned

Godiksen, Dan Electric System DispatcherCWLP [email protected]

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 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.

Cummings, John M [email protected]

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.

Knarreborg, Renee [email protected]

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.

Chuck Weaver The number of hours required by this proposal exceed the amount



WAPA-RMR Operations - Switching (970 )[email protected]

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 performance) requiring fewer CEHs.

Tim Hattaway Energy Control Center Manager Alabama Electric Cooperative

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.

John MasonSupervisor-Transmission System OperationsMissouri Public Service/AquilaMason, [email protected]

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?

Leo St. Hilaire Program Development Coordinator Manitoba Hydro

Agree with overall concept of the program.

Dennis F. Felgate, P. Eng.Sask [email protected]

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.John NeagleAssociated Electric Cooperative, [email protected]

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.

Williams, Robert [email protected]

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?

Cintron, Walter [email protected]

Why is retaking the exam not an option in lieu of not accumulation the required CEU's. This does not make sense.

Terry BanksSenior System Operator (Training)NB [email protected]

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.



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

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

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

Comments:Bill Bell Training Coordinator ISO New England [email protected]

Good.

[email protected]

Only comment. Would like to see a list of NERC approved training courses with web links to providers of classes.

Godiksen, Dan Electric System [email protected]

1) Do you have a process in which Reservists who are re-called for activeduty (up to 2 years) can have their time stopped and then re-instated upontheir return? If not and they do fall into a suspended or revoked status,potentially causing them to loose their position, would this violate theirrights and job protection guaranteed by law?

Knarreborg, Renee [email protected]

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.

Kevin Conway Grant County PUD

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 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.

John MasonSupervisor-Transmission System OperationsMissouri Public Service/[email protected]

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?


Agree with this process


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,documentsAt the above website the program is CPE - Continuing Professional ExcellenceNERC 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:CommunicationComputersEconomicsSubstationsProtective relayingPower transmissionPower pool operationsEmergency analysis& ResponsePower DynamicsSteady state Power Flow



DistributionStandard Protection CodeAlong 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.

John NeagleAssociated Electric Cooperative, [email protected]

The order in which the goals are listed implies a lesser importance for establishing the process for maintaining NERC-certification creditials than for 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



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

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.





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.


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?

Joe [email protected]

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.





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.


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.





Continuing Education Credit Hours to Maintain a Valid CredentialThe 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:


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.





Transmission Operator CertificationAfter 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 EckelsSenior Transmission SpecialistTransmission Operations Support - Training Dept.First Energy - SCC Wadsworth, Ohio(330) [email protected]

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.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?

Steve Rainwater [email protected] CoordinatorLower 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.

Mike ClimeAmerenEnergy Supply OperaionsTechnical Training Supervisor

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.

Chuck WeaverWAPA-RMR Operations - Switching (970 )[email protected]

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)

Jeff BoltzSystem Operator / TrainerFirst Energy, Reading Control Center

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 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.





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



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


Comments:Mike ClimeAmerenEnergy Supply OperaionsTechnical Training Supervisor

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.







Balancing, Interchange & Transmission Operator CertificationAfter completing and passing an initial NERC Balancing and Interchange/Transmission Operator certification exam, the candidate is awarded a NERC credential as a Balancing and Interchange/Transmission Operator. A certificate will be issued that is valid for three years. To maintain a valid Balancing and Interchange/Transmission Operator credential, system operators must earn 180 CEH within the 3-year period preceding the expiration date of their certificate.



150 CEH related directly to Balancing and Interchange/Transmission Operator tasks. (See Appendix A for recognized training topics.)



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.



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.

Williams, Robert PacifiCorpRobert.Williams@PacifiCor



mailto:[email protected]


p.com

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



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



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.



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?

Joe [email protected]

How many in-class hours constitute 1 CEH?


Again, working the function should account for a portion of the CEH's.

John NeagleAssociated Electric Cooperative, Inc.

Associated Electric Cooperative Inc. believes requiring 240 CEH of NERC approved learning activity, delivered by NERC approved providers, is excessive. Associated has historically and



[email protected] 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 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.




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.



Deficits of CEH for Credential HoldersAn 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 NERC-certified.) 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.


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. Jeff BoltzSystem Operator / TrainerFirst Energy, Reading Control Center

What provisions will be made for Operators who fail to complete their required hours thru no-fault of their own, several examples would be 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.



CEH Earned by Operators for Maintaining a Credential1. 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 EckelsSenior Transmission SpecialistTransmission Operations Support - Training Dept.First Energy - SCC Wadsworth, Ohio(330) [email protected]

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 NolanManager - ProjectsNorth American Electric Reliability [email protected]

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.

Mike ClimeAmeren

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



Energy Supply OperaionsTechnical Training Supervisor

a certificate after passing the exam. Under the proposed new program an operator 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.

Terry BanksSenior System Operator

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



(Training)NB [email protected]

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 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?



Changing Certification LevelsA 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 EckelsSenior Transmission SpecialistTransmission Operations Support - Training Dept.First Energy - SCC Wadsworth, Ohio(330) 336-9049 [email protected]

Show example of credential maintenance application. Is this something we will need to submit/update every year?


If all hours for renewal were kept the same for each certificate there would be no need for the last two bullets.


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?

Leo St. Hilaire Program Development

Agree with concepts



Coordinator Manitoba Hydro



Transition Plan — From a 5-year Program to a 3-year ProgramAn 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 NolanManager - ProjectsNorth American Electric Reliability [email protected]

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 re-certification.


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?



Section II — Program Rules

Rules for NERC-Certified System Personnel1. 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. Name and contact information of the learning activity sponsor, 5.2. Title of the learning activity and description of its content, 5.3. Date(s) of the learning activity, 5.4. Location (if applicable), 5.5. Number and type of CE hour credits, all of which must be included in documentation

provided by the sponsor, and 5.6. 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



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 EckelsSenior Transmission SpecialistTransmission Operations Support - Training Dept.First Energy - SCC Wadsworth, Ohio(330) 336-9049 - Outside [email protected]

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.

Brian NolanManager - ProjectsNorth American Electric Reliability [email protected]

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.

Chuck WeaverWAPA-RMR Operations - Switching

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



(970 )[email protected]

suggest 3.0 CEH for each CE credit hour of a learning activity presented not the proposed 1.0.


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.


Given the time and efforts required to develop and present a learning activity, there should be more credit given to the instructors.


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?



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.

EHV Operations — system protection, system stability; monitor, implement and coordinate operating procedures, assess the reliability impact of planned and forced transmission



outages.

Emergency Operations — NERC, ISO/RTO, regional, and local policies and procedures, line loading relief procedures, load shedding, emergency operating plans, and implement emergency operation procedures.

Power System Restoration — restoration philosophies, black-start, and restoration.

Tools — EMS, SCADA, advanced applications (state estimation, real-time contingency analysis), load forecasting, and energy accounting.

Congestion Management

Outage Procedures — planning, switching procedures, protective card procedures, reporting, and communications.

Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, physical and cyber sabotage.

Market Operations — market rules, OASIS, NERC tagging, tariffs, transmission rights, and market tools.

Transmission Operator Interconnected Power System Operations — basic electricity, production and transfer of

energy, Mvar reserves and reactive power flow, economic operation, transmission system control, energy accounting, telemetry, system protection, and system stability.

EHV Operations — purpose and limitations of system protection schemes, understand power system operations, power operations and limitations of system components (breakers [oil, gas], disconnects [manual, motor operated, air blast, whip], fuses), power system component interaction, effect of generator injection on power flow, surge impedance loading, transformer saturation, and solar magnetic disturbance.

Communications — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, and ability to write brief, concise reports of a system event or action.


Power System Restoration — restoration philosophies, black-start, and restoration.

Tools — SCADA, state estimator, real-time contingency analysis, and operator load flow.

Outage Procedures — planning, switching procedures, protective card procedures, reporting, and communications.

Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, physical and cyber sabotage.

Balancing and Interchange Operator Interconnected Power System Operations — basic electricity, production and transfer of

energy, Mw reserves, understand ACE components and concept, formulating operational



plans, understand concept of frequency control, evaluating interchange schedules, system control, and telemetry.

Generation — monitor on-line generator performance, track dynamic Mvar capability, respond to frequency deviations, understand CPS and DCS components and concepts, coordinate operational plans and unit commit/decommit schedules from generation operators, capabilities of different types of generators (peakers, combined cycle, coal, oil, gas, nuclear, hydro, geothermal), frequency response characteristics.


Power System Restoration — restoration philosophies, and black-start.

Tools — EMS, load forecasting, and energy accounting.

Communications — effective communication skills (how to give orders, communicate in emergency conditions, effective listening skills, etc.), dispute/disagreement resolution, and ability to write brief, concise reports of a system event or action.

Congestion Management — Understand concept.

Recognize and Operate during System Emergencies — loss of facilities, communications, and system tools, generation deficiencies, transmission contingencies, and physical and cyber sabotage.

Market Operations — market rules, OASIS, NERC tagging, tariffs, transmission rights, and market tools.

Additional Comments:

Truman S. Buffington1071 Emerald DriveBrandon, FL [email protected]

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 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 CalhounTraining CoordinatorCenterPoint EnergyReal 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 ahours for the annual system emergency training requirement? In otherwords, will a TO have to earn 40 hours annually for certification and anadditional 40 hours for system emergency training for a total of 80 hours?Thanks.



Jim EckelsSenior Transmission SpecialistTransmission Operations Support - Training Dept.First Energy - SCC Wadsworth, Ohio(330) [email protected]

1 - Can the "30 CEH on NERC operating policies and standards" includeRegional policies and standards?2 - Need to define per year as July 1 - June 30

King, Scott [email protected]

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.

MarkFRCC

My comments amount to a blanket NO. The requirements for CEH's that NERC is proposing is unreasonable for each of the authorities. They areasking/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 .

KULT, KENNETH D [email protected]

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) 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 trainingper 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. 4. I didn't see any proposed date for implementation of the



proposed program.Steve Rainwater [email protected] CoordinatorLower Colorado River Authority

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.

Kenneth Parker [email protected]

Congratulations on a job well done, the program content looks good tome. Will the NERC Training Courses count toward CEH's? Will there bea listing of approved courses and their providers?

Dan GodiksenElectric System DispatcherCWLP

1) Do you have a process in which Reservists who are re-called for activeduty (up to 2 years) can have their time stopped and then re-instated upontheir return? If not and they do fall into a suspended or revoked status,potentially causing them to loose their position, would this violate theirrights and job protection guaranteed by law?

[email protected]

Would like to see a list of NERC approved training courses with web links to providers of classes.

Al Parsons

NCPA Manager, System Operations

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.



Ray Gross, [email protected]

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.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. Is the next step to establish prerequisites for candidates which may restrict access to NERC exams?

Maki, Ron [email protected]

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.

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.Leo St. Hilaire Program Development Coordinator Manitoba Hydro

Agree with concepts but would have liked to seen professional development addressed.

John NeagleAssociated Electric Cooperative [email protected]

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:


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