NERC Petition (without exhibits)

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF
THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD PER-005-2 AND
RETIREMENT OF RELIABILITY STANDARD PER-005-1
Gerald W. Cauley
President and Chief Executive Officer
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560

Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein
Counsel
North American Electric Reliability
Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net
Counsel for the North American Electric
Reliability Corporation

March 7, 2014

TABLE OF CONTENTS
I.

EXECUTIVE SUMMARY .................................................................................................... 2

II.

NOTICES AND COMMUNICATIONS ................................................................................ 6

III. BACKGROUND .................................................................................................................... 6
A.

Regulatory Framework ..................................................................................................... 6

B.

NERC Reliability Standards Development Procedure ..................................................... 7

C.

History of PER Training Reliability Standards ................................................................ 8

D.

1.

PER-002-0 .................................................................................................................... 8

2.

PER-005-1 .................................................................................................................. 10

3.

Outstanding Commission Directives .......................................................................... 12
Procedural History of NERC Project 2010-01 Training ................................................ 17

IV. JUSTIFICATION FOR APPROVAL................................................................................... 18

V.

A.

Basis and Purpose of the Proposed Reliability Standard ............................................... 18

B.

Requirements of Proposed Reliability Standard PER-005-2 ......................................... 20

C.

Enforceability of the Proposed Reliability Standards .................................................... 34

D.

Proposed Modifications to the Definition of “System Operator” .................................. 34
EFFECTIVE DATE .............................................................................................................. 36

VI. CONCLUSION ..................................................................................................................... 37

Exhibit A

Proposed Reliability Standard

Exhibit B

Implementation Plan

Exhibit C

Order No. 672 Criteria

Exhibit D

Mapping Document

Exhibit E

Analysis of Violation Risk Factors and Violation Security Levels

Exhibit F

Summary of Development History and Record of Development

Exhibit G

Standard Drafting Team Roster

i

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

North American Electric Reliability
Corporation

)
)

Docket No. _______

PETITION OF
THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF PROPOSED RELIABILITY STANDARD PER-005-2 AND
RETIREMENT OF RELIABILITY STANDARD PER-005-1
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 of the
regulations of the Federal Energy Regulatory Commission (“FERC” or “Commission”),2 the North
American Electric Reliability Corporation (“NERC”)3 hereby submits for Commission approval
proposed Reliability Standard PER-005-2 – Operations Personnel Training. NERC requests that
the Commission approve proposed Reliability Standard PER-005-2 (Exhibit A) as just, reasonable,
not unduly discriminatory or preferential, and in the public interest.4 NERC also requests approval
of (i) the associated Implementation Plan (Exhibit B), (ii) the associated Violation Risk Factors
(“VRFs”) and Violation Severity Levels (“VSLs”) (Exhibits A and E), (iii) the proposed NERC
Glossary definitions for the terms “System Operator” and “Operations Support Personnel,” and
(iv) the retirement of currently effective Reliability Standard PER-005-1, as detailed in this
Petition.

1

16 U.S.C. § 824o (2006).

2

18 C.F.R. § 39.5 (2013).

The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with
Section 215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006).
3

4

Unless otherwise designated, all capitalized terms shall have the meaning set forth in the Glossary of Terms
Used in NERC Reliability Standards (“NERC Glossary”), available at
http://www.nerc.com/files/Glossary_of_Terms.pdf.

1

As required by Section 39.5(a) of the Commission’s regulations,5 this Petition presents the
technical basis and purpose of proposed Reliability Standard PER-005-2, a summary of the
development history (Exhibit F) and a demonstration that the proposed Reliability Standard meets
the criteria identified by the Commission in Order No. 6726 (Exhibit C). The NERC Board of
Trustees approved proposed Reliability Standard PER-005-2 and the retirement of PER-005-1 on
February 6, 2014.
I.

EXECUTIVE SUMMARY
The Personnel Performance, Training, and Qualifications (“PER”) group of Reliability

Standards is intended to help ensure the safe and reliable operation of the interconnected grid
through the retention of suitably trained and qualified personnel in positions that can impact the
reliable operation of the Bulk-Power System. Commission-approved Reliability Standard PER005-1 requires Reliability Coordinators, Balancing Authorities, and Transmission Operators to:
(1) establish a training program for their System Operators using a systematic approach to training,
(2) verify each of their System Operators’ capability to perform reliability-related tasks, and (3)
provide emergency operations training to every System Operator. As System Operators have
primary responsibility for the Real-time operation of the Bulk Electric System (“BES”), Reliability
Standard PER-005-1 serves the important reliability goal of helping to ensure that System
Operators performing Real-time, reliability-related tasks on the BES are adequately trained to
competently perform those tasks and reliably operate the BES.

5

18 C.F.R. § 39.5(a) (2013).

6

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, FERC Stats. & Regs. ¶
31,204, at P 262, 321-37, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).

2

Consistent with FERC directives from Order Nos. 6937 and Order No. 742,8 the purpose
of proposed Reliability Standard PER-005-2 is to improve upon PER-005-1 by expanding the
scope of the Reliability Standard to include training requirements for the following personnel:
i.

personnel of a Transmission Owner, excluding field switching personnel, who can act
independently to operate or direct the operation of the Transmission Owner’s BES
transmission facilities in Real‐time (i.e., local transmission control center operator
personnel);

ii.

Operations Support Personnel, which are proposed to be defined as “[i]ndividuals who
perform current day or next day outage coordination or assessments, or who determine
[System Operating Limits (“SOLs”), [Interconnection Reliability Operating Limits
(“IROLs”)], or operating nomograms, in direct support of Real‐time operations of the
Bulk Electric System;” and

iii.

Generator Operator dispatch personnel at a centrally located dispatch center who receive
direction from the Generator Operator’s Reliability Coordinator, Balancing Authority,
Transmission Operator, or Transmission Owner, and develop specific dispatch
instructions for plant operators under their control.

As the Commission discussed in Order Nos. 693 and 742, these personnel perform or support Real‐
time operations on the BES and, in turn, could have a direct impact on BES reliability.
Accordingly, it is important to expand the scope of the mandatory training requirements to require
that such personnel receive adequate training to help maintain the reliable operation of the BES.
As is already required for System Operators, proposed Reliability Standard PER-005-2
requires the use of a systematic approach to develop and implement training requirements for local
transmission control center operator personnel, Operations Support Personnel and the applicable
Generator Operator dispatch personnel. As the Commission stated in Order No. 742, “[a]
systematic approach to training is a widely-accepted methodology that ensures training is

7

Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 72 FR 16416 (Apr. 4, 2007),
FERC Stats. & Regs. ¶ 31,242, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).
8

See System Personnel Training Reliability Standards, Order No. 742, 133 FERC ¶ 61,159 (2010).

3

efficiently and effectively conducted.”9 The concept of using a “systematic approach to training”
refers to the use of a systematic method for establishing and maintaining training requirements that
are directly related to the needs of the particular position. There are different models for using a
systematic approach to training but any effective systematic approach to training method will
determine: (1) the skills and knowledge necessary for the position in question; (2) the type of
training needed to provide the trainee the identified skills and/or knowledge; (3) whether the
trainee can competently perform his/her job function; and (4) whether the training is effective or
requires adjustment. 10

Like PER-005-1, proposed Reliability Standard PER-005-2 does not

mandate the use of a particular systematic approach to training model; rather it provides entities
the discretion to determine the manner in which they will apply the principles of a systematic
approach to training to develop and implement training requirements for their applicable
personnel.
The proposed Reliability Standard also addresses the Commission’s directive from Order
No. 742 to develop an implementation period for those entities that may, at some time in the future,
become subject to the requirement to provide emergency operations training using simulation
technology.11 Requirement R4, part 4.1 of the proposed Reliability Standard provides Reliability
Coordinators, Balancing Authorities, Transmission Operators, and Transmission Owners 12
months from the date that they (1) gain operational authority or control over Facilities with
established IROLs, or (2) establish protection systems or operating guides to mitigate IROL
violations, to comply with the requirement to provide emergency operations training to their

9

Order No. 693 at P 1382; Order No. 742 at P 25.

10

Systematic approaches to training are generally characterized by five distinct, yet interrelated phases: (1)
analysis, (2) design, (3) development, (4) implementation, and (5) evaluation.
11

Order No. 742 at P 24.

4

applicable personnel using simulation technology. The 12-month period is designed to provide
such entities sufficient time to acquire the necessary simulation technology and modify their
training programs to account for the use of simulation technology.
Proposed Reliability Standard PER-005-2 also improves upon the prior version of the
Reliability Standard by clarifying language in certain requirements and eliminating redundant or
unnecessary requirements. For instance, PER-005-2 does not retain the obligation in Requirement
R3 of PER-005-1 that Reliability Coordinators, Balancing Authorities, and Transmission
Operators provide their System Operators at least 32 hours of emergency operations training every
12 months. As further explained below, the frequency and amount of emergency operations
training for System Operators is most appropriately determined by each entity’s training program
developed in accordance with Requirement R1, rather than a uniform requirement applied to each
entity regardless of its unique characteristics or reliability risk to the Bulk-Power System.
Finally, NERC proposes modifications to the definition of “System Operators” in the
NERC Glossary. The purpose of the proposed modifications is to properly limit the definition to
those operations personnel that have the independent authority to operate the BES in Real-time.
For the reasons discussed herein, NERC respectfully requests that the Commission approve
proposed Reliability Standard PER-005-2, the proposed new and modified definitions used therein,
and the retirement of PER-005-1.

5

II.

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following:12

Charles A. Berardesco*
Senior Vice President and General Counsel
Holly A. Hawkins*
Assistant General Counsel
S. Shamai Elstein*
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net
III.

Mark G. Lauby*
Vice President and Director of Standards
Valerie Agnew*
Director of Standards Development
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560
mark.lauby@nerc.net
valerie.agnew@nerc.net

BACKGROUND
A.

Regulatory Framework

By enacting the Energy Policy Act of 2005,13 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Nation’s Bulk-Power
System, and with the duty of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1)14
of the FPA states that all users, owners, and operators of the Bulk-Power System in the United
States will be subject to Commission-approved Reliability Standards. Section 215(d)(5)15 of the
FPA authorizes the Commission to order the ERO to submit a new or modified Reliability

Persons to be included on the Commission’s service list are identified by an asterisk. NERC respectfully
requests a waiver of Rule 203 of the Commission’s regulations, 18 C.F.R. § 385.203 (2013), to allow the inclusion
of more than two persons on the service list in this proceeding.
12

13

16 U.S.C. § 824o (2006).

14

Id. § 824(b)(1).

15

Id. § 824o(d)(5).

6

Standard.

Section 39.5(a) 16 of the Commission’s regulations requires the ERO to file for

Commission approval each Reliability Standard that the ERO proposes should become mandatory
and enforceable in the United States, and each modification to a Reliability Standard that the ERO
proposes should be made effective.
The Commission has the regulatory responsibility to approve Reliability Standards that
protect the reliability of the Bulk-Power System and to ensure that such Reliability Standards are
just, reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 17 and Section 39.5(c) 18 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.
B.

NERC Reliability Standards Development Procedure

The proposed Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development process.19 NERC
develops Reliability Standards in accordance with Section 300 (Reliability Standards
Development) of its Rules of Procedure and the NERC Standard Processes Manual.20 In its ERO
Certification Order, the Commission found that NERC’s proposed rules provide for reasonable
notice and opportunity for public comment, due process, openness, and a balance of interests in
developing Reliability Standards and thus satisfies certain of the criteria for approving Reliability

16

18 C.F.R. § 39.5(a) (2012).

17

16 U.S.C. § 824o(d)(2).

18

18 C.F.R. § 39.5(c)(1).

19

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672 at P 334, FERC Stats. &
Regs. ¶ 31,204, order on reh’g, Order No. 672-A, FERC Stats. & Regs. ¶ 31,212 (2006).
20

The NERC Rules of Procedure are available at http://www.nerc.com/AboutNERC/Pages/Rules-ofProcedure.aspx. The NERC Standard Processes Manual is available at
http://www.nerc.com/comm/SC/Documents/Appendix_3A_StandardsProcessesManual.pdf.

7

Standards. The development process is open to any person or entity with a legitimate interest in
the reliability of the Bulk-Power System. NERC considers the comments of all stakeholders, and
a vote of stakeholders and the NERC Board of Trustees is required to approve a Reliability
Standard before the Reliability Standard is submitted for Commission approval.
C.

History of PER Training Reliability Standards
1.

PER-002-0

In Order No. 693, the Commission approved four PER Reliability Standards: PER-001-0,
PER-002-0, PER-003-0, and PER-004-1.21 PER-002-0, which has since been replaced by PER005-1, as explained below, required each Transmission Operator and Balancing Authority to be
staffed with adequately trained operating personnel. Specifically, PER-002-0 (1) directed each
Transmission Operator and Balancing Authority to have a training program for all operating
personnel who occupy positions that either have primary responsibility, directly or indirectly, for
the Real-time operation of the Bulk-Power System or who are directly responsible for complying
with the NERC Reliability Standards; (2) listed criteria that must be met by the training program;
and (3) required that operating personnel receive at least five days of training in emergency
operations each year using realistic simulations.
In Order No. 693, the Commission directed NERC to develop the following modifications
to PER-002-0:

21



identify the expectations of the training for each job function;



develop training programs tailored to each job function with consideration of the individual
training needs of the personnel;



expand the applicability of the training requirements to include: (i) reliability coordinators,
(ii) local transmission control center personnel, (iii) generator operators centrally-located
at a generation control center with a direct impact on the reliable operation of the BulkOrder No. 693 at PP 1330-1417.

8

Power System, and (iv) operations planning and operations support staff who carry out
outage planning and assessments and those who develop SOLs, IROLs, or operating
nomograms for Real-time operations;


use a systematic approach to training methodology for developing new training programs;
and



include the use of simulators by Reliability Coordinators, Transmission Operators, and
Balancing Authorities that have operational control over a significant portion of load and
generation.22
The Commission also directed the ERO to determine whether it is feasible to develop

meaningful performance metrics associated with the effectiveness of a training program required
by currently effective Reliability Standard PER-002-0 and to consider whether personnel who
support Energy Management System (“EMS”) applications should be included in mandatory
training pursuant to the Reliability Standard.23
While PER-002-0 addressed training requirements for Transmission Operators and
Balancing Authorities, PER-004-1 applied to Reliability Coordinators. Specifically, PER-004-1
required:


each Reliability Coordinator to be staffed with adequately trained, NERC-certified
operators, 24 hours a day, seven days a week (Requirement R1); and



Reliability Coordinator operating personnel to: (i) complete a minimum of five days of
training in emergency operations each year using realistic simulations (Requirement R2),
(ii) have a comprehensive understanding of the area of the Bulk-Power System for which
they are responsible (Requirement R3), (iii) have an extensive understanding of the
Balancing Authorities, Transmission Operators, and Generation Operators within their area
(Requirement R4), and (iv) place particular attention on SOLs and IROLs and inter-tie
facility limits (Requirement R5).
In Order No. 693, the Commission directed NERC to include formal training requirements

for Reliability Coordinators similar to those in PER-002-0.24

22

Order No. 693 at P 1393.

23

Id. at P 1394.

24

Id. at P 1415.

9

2.

PER-005-1

In response to the Commission’s directives in Order No. 693, NERC requested approval
of proposed Reliability Standards PER-005-1 (System Personnel Training) and PER-004-2
(Reliability Coordination – Staffing) to replace PER-002-0 and PER-004-1, respectively.
Reliability Standard PER-005-1, which superseded all of PER-002-0 as well as Requirements R2,
R3, and R4 of PER-004-1, was designed to help ensure that System Operators performing
reliability-related tasks on the North American BES are competent to perform those reliabilityrelated tasks.

PER-005-1 applies to Reliability Coordinators, Balancing Authorities, and

Transmission Operators and contains the following three requirements:
1. Requirement R1 mandates that Reliability Coordinators, Balancing Authorities, and
Transmission Operators “use a systematic approach to training to establish a training
program for the BES company-specific reliability-related tasks performed by System
Operators and implement the program.” The requirement further requires applicable
entities to create a list of company-specific, reliability-related tasks performed by their
System Operators (R1.1); update the task list every calendar year (R1.1.1); and design and
develop learning objectives and training materials based on the task list (R1.2). Finally, the
requirement mandates that training be delivered (R1.3) and that the training program be
evaluated on at least an annual basis to assess its effectiveness (R1.4).
2. Requirement R2 requires that Reliability Coordinators, Balancing Authorities, and
Transmission Operators verify each of their System Operator’s ability to perform the tasks
identified in Requirement R1.1. The requirement also mandates that within six months of
a modification to the task list, each System Operator’s ability to perform those new or
modified tasks must be verified.
3. Requirement R3 identifies the number of hours of emergency operations training (at least
32 hours) that a System Operator is required to receive every twelve months. Requirement
R3.1 further requires that applicable entities that have operational authority or control over
Facilities with established IROLs or have established operating guides or protection
systems to mitigate IROL violations provide their System Operators emergency operations
training using simulation technology, such as a simulator, virtual technology, or other
technology that replicates the operational behavior of the BES during normal and
emergency conditions.

10

Reliability Standard PER-004-2 modified PER-004-1 by deleting Requirements R2, R3,
and R4, as these three requirements were incorporated into proposed PER-005-1. PER-004-2
simply carried forward, unchanged, the remaining provisions from PER-004-1.
The Commission approved Reliability Standards PER-005-1 and PER-004-2 in Order No.
742.25 As discussed in that order, while Reliability Standard PER-005-1 addressed most of the
Commission’s directives from Order No. 693, NERC designated certain directives to be addressed
in a subsequent Reliability Standards development project. In particular, Reliability Standard
PER-005-1 did not address FERC’s directives to expand the applicability of the training
requirements to include: (1) local transmission control center operator personnel; 26 (2) certain
Generator Operator dispatch personnel centrally-located at a generation control center;27 and (3)
operations and planning support personnel who carry out outage planning and assessments and
those who develop SOLs, IROLs, or operating nomograms for real-time operations.28 NERC also
had yet to consider whether personnel who support EMS applications should be included in
mandatory training requirements. 29 Consistent with NERC’s commitment to address these
directives in a future development project, FERC directed NERC to satisfy these unaddressed
directives.30 Additionally, the Commission directed NERC to consider the necessity of developing
an implementation period for those entities that may become subject to the requirement to provide
emergency operations training using simulation technology.31

25

Order No. 742 at P 1.

26

Id. at PP 61-64.

27

Id. at PP 74, 81, 83-85.

28

Id. at PP 74, 81-2.

29

Order No. 693 at P 1373.

30

Order No. 742 at PP 64, 81-86.

31

Id. at P 24.

11

The following section provides additional background on these outstanding Commission
directives.
3.

Outstanding Commission Directives
i.

Local Transmission Control Center Operator Personnel

In Order No. 693, the Commission directed NERC to expand the applicability of Reliability
Standard PER-002-0 to include local transmission control center operator personnel. 32 The
Commission noted that decision making and implementation may be performed by separate groups
in an Independent System Operator (“ISO”) or Reliability Transmission Organization (“RTO”)
context, as well as other organizations that pool resources. 33 The Commission stated that the
personnel of control centers and organizations that are necessary for the actual implementation of
the decision or are needed for operation and maintenance made by the ISO, RTO or pooled
resource organization should receive training under the standard.34 Specifically, the Commission
stated:
Clearly, in a region where an RTO or ISO performs the transmission operator
function, its personnel with primary responsibility for real-time operations must
receive formal training pursuant to PER-002-0. In addition, personnel who are
responsible for implementing instructions at a local control center also affect the
reliability of the Bulk Power System. These entities may take independent action
under certain circumstances, for example, to protect assets, personnel safety and
during system restorations. Whether the RTO or the local control center is
ultimately responsible for compliance is a separate issue addressed above, but
regardless of which entity registers for that responsibility, these local control center
employees must receive formal training consistent with their roles, responsibilities
and tasks. Thus, while we direct the ERO to develop modifications to PER-002-0
to include formal training for local control center personnel, that training should be
tailored to the needs of the positions.35

32

Order No. 693 at PP 1342-48.

33

Id. at P 1342.

34

Id. At 1342-43.

35

Id. at P 1343.

12

The Commission further explained which type of control centers and personnel were
subject to the directive. The Commission clarified that where a large utility within an RTO or ISO
footprint has one centrally-located control center whose function is to supervise several distributed
control centers, each with remote monitoring and control capability, the personnel of the centrallylocated control center, not the personnel at the distributed control center, should receive formal
training under the Reliability Standard.36 Similarly, the Commission stated that where smaller
entities have a single control center that implements operating instructions from its Transmission
Operator (e.g., an RTO, ISO or pooled resource), the operators at these control centers should be
trained under the Reliability Standards as they may also may take independent action to protect
assets, safety and system restoration.37 The Commission noted, however, that individuals who
carry out field switching operations and station inspections at the direction of the local control
center operators are not subject to the directive.38 Lastly, the Commission noted that local control
center operators need not be trained in the same manner, or to the same extent as System Operators
at a Transmission Operator, Balancing Authority or Reliability Coordinator. Rather, the training
program should be tailored to the functions of local control center operators.39
In Order No. 742, the Commission reiterated its conclusion that omitting such local
transmission control center operator personnel from mandatory training requirements creates a
reliability gap:
The Commission understands that local transmission control center personnel
exercise control over a significant portion of the Bulk-Power System under the
supervision of the personnel of the registered transmission operator. This
supervision may take the form of directing specific step-by-step instructions and at
36

Order No. 693 at P 1344.

37

Id. at P 1345.

38

Id. at P 1346.

39

Id. at P 1348.

13

other times may take the form of the implementation of predefined operating
procedures. For example, ISO New England, Inc., PJM Interconnection, L.L.C.,
and New York Independent System Operator, Inc., are registered transmission
operators who issue operating instructions that are carried out by local transmission
control centers such as PSE&G, PPL Electric Utilities Corp., PECO Energy
Company, Baltimore Gas and Electric Co., Consolidated Edison of New York, Inc.,
National Grid USA, and Long Island Power Authority, which are not registered
transmission operators. The combined peak load of these three RTOs is in excess
of 200 gigawatts. In all cases, the local transmission control center personnel must
understand what they are required to do in the performance of their duties to
perform them effectively on a timely basis. Thus, omitting such local transmission
control center personnel from the PER-005-1 training requirements creates a
reliability gap. The Commission believes that identifying these entities would be a
valuable step in delineating the magnitude of that gap.40
Accordingly, in Order No. 742 the Commission reiterated its directive to develop training
requirements for, and develop a definition of, local transmission control center operator
personnel.41
ii.

Generator Operator Dispatch Personnel

In Order No. 693, the Commission concluded that because a Generator Operator has the
potential to directly impact the reliable operation of the Bulk-Power System, its personnel should
be trained under NERC’s Reliability Standards. 42 The Commission asserted that although
Generator Operators take directions from Balancing Authorities and others, which limits their
ability to impact reliability, it is essential that Generator Operator personnel have appropriate
training to understand those instructions, particularly in an emergency situation in which
instructions may be succinct and require immediate action.43
The Commission limited the directive to personnel of a Generator Operator that perform
dispatch activities, namely, those dispatch personnel at a “centrally-located dispatch center that
40

Order No. 742 at P 62.

41

Id. at PP 63-64.

42

Order No. 693 at P 1359.

43

Id. at P 1359.

14

receive[] direction and then develop[] specific dispatch instructions for plant operators under their
control.”44 This group of personnel would include a Generator Operator’s dispatch personnel
where a single generator and dispatch center are located at the same site.45 The Commission
clarified that while plant operators located at the generator plant site also need to be trained, the
responsibility for this training is outside the scope of the Reliability Standard.46
The Commission recognized, however, that “the experience and knowledge required by
Transmission Operators about Bulk-Power System operations goes well beyond what is needed by
Generation Operators.” 47 Accordingly, the Commission stated that (1) the training for the
applicable Generator Operator personnel “need not be as extensive as that required for
Transmission Operators;” and (2) “the training requirements developed by the ERO should be
tailored in their scope, content and duration so as to be appropriate to generation operations
personnel and the objective of promoting system reliability.”48
iii.

Operations and Planning Support Personnel

The Commission also directed NERC to extend the training requirements to certain
operations planning and operations support staff.49 The Commission clarified that the applicable
support staff are “those [individuals] who carry out outage coordination and assessments in
accordance with Reliability Standards IRO-004-1 and TOP-002-2, and those who determine SOLs
and IROLs or operating nomograms in accordance with Reliability Standards IRO-005-1 and

44

Order No. 693 at P 1360; Order No. 742 at P 83.

45

Order No. 693 at P 1361; Order No. 742 at P 83.

46

Id. at PP 1360-61.

47

Order No. 693 at P 1363.

48

Id. at P 1363.

49

Id. at P 1372.

15

TOP-004-0.”50 The Commission concluded that the Reliability Standard should apply to these
operations planning and operations support staff because they have a direct impact on the reliable
operation of the Bulk-Power System. The Commission noted, however, that such personnel need
not be trained on the responsibilities of System Operators; rather the training should be tailored to
the needs of their functions, the tasks performed and personnel involved.51
iv.

EMS Personnel

In its discussion of support personnel in Order No. 693, the Commission also stated that it
“is aware that the personnel responsible for ensuring that critical reliability applications of the
EMS, such as state estimator, contingency analysis and alarm processing packages, are available,
up-to-date in terms of system data and produce useable results can also have an impact on the
Reliable Operation of the Bulk-Power System.”52 Because the Commission was uncertain about
the impact of EMS personnel on reliable operations, however, the Commission only directed
NERC to consider whether EMS personnel should be included in a mandatory training
requirement.
v.

Implementation Period for Simulation Training

As noted above, Requirement R3.1 of PER-005-1 identifies the entities that must use
simulation technology when providing emergency operations training. While the implementation
plan for PER-005-1 addressed lead times for compliance based on governmental approval, the
standard does not provide any lead times for compliance when an entity becomes subject to the
requirement after the regulatory effective date of the standard. In Order No. 742, the Commission
directed NERC to consider the necessity of developing an implementation period for those entities

50

Order No. 693 at P 1372; Order No. 742 at P 82.

51

Order No. 693 at P 1375.

52

Id. at 1373.

16

that may become, in the future, subject to the simulator training requirement in Requirement R3.1
of PER-005-1.
D.

Procedural History of NERC Project 2010-01 Training

The proposed Reliability Standard was developed as part of NERC Project 2010-01
Training, which was initiated to address the outstanding Commission directives from Order Nos.
693 and 742 related to Reliability Standard PER-005-1. Project 2010-01 Training arose from an
informal development process that NERC began in February 2013 to review the outstanding
directives. Participants in this informal development process were industry subject matter experts,
NERC staff, and staff from FERC’s Office of Electric Reliability.
The informal group met numerous times between February 2013 and July 2013 to discuss
the outstanding FERC directives and, given their experience with Reliability Standard PER-0051, ways to improve the standard. The informal group also conducted industry outreach to obtain
feedback on approaches for responding to the outstanding directives and improving the standard.
After considering this feedback, the informal participants drafted a revised Reliability Standard,
PER-005-2, to address FERC’s outstanding directives and improve the quality and content of the
standard.
Project 2010-01 Training was formally initiated on July 18, 2013 with the posting of a
Standard Authorization Request along with the draft of proposed PER-005-2 developed by the
informal participants for a 45-day formal comment period and ballot. Following the July 18, 2013
posting, a standard drafting team was formed. As further described in Exhibit F hereto, drafts of
the proposed Reliability Standard were posted for two additional comment periods and ballots.
The third ballot received a quorum of 79.12% and an approval of 74.63%. Following approval of
the proposed standard in a Final Ballot, the NERC Board of Trustees approved proposed PER-

17

005-2, the proposed new and modified definitions used therein, and the retirement of PER-005-1
on February 6, 2014.
IV.

JUSTIFICATION FOR APPROVAL
As discussed below and in Exhibit C, proposed Reliability Standard PER-005-2 satisfies

the Commission’s criteria in Order No. 672 and is just, reasonable, not unduly discriminatory or
preferential, and in the public interest. The following section provides: (1) the basis and purpose
of the proposed Reliability Standard; (2) a discussion of the requirements in the proposed
Reliability Standard, including an explanation of how each requirement improves upon the prior
version of the Reliability Standard and, where applicable, satisfies outstanding Commission
directives; (3) a discussion of the enforceability of the proposed Reliability Standard; and (4) an
explanation of the proposed modifications to the definition of the term “System Operator.”
A.

Basis and Purpose of the Proposed Reliability Standard

The proposed Reliability Standard serves the vital reliability goal of helping to ensure that
personnel who perform or support Real-time operations on the BES are adequately trained to
maintain the reliable operation of the BES. Training individuals that both perform and support
Real-time operations is an integral step in enhancing the reliability of the Bulk-Power System. It
is important to train operators and their support personnel to, among other things, understand what
they are required to do in the performance of their duties, particularly in emergency circumstances,
and to perform those duties effectively and on a timely basis in support of reliable operations.
Proposed Reliability Standard PER-005-2 replaces and improves upon the prior version of
the standard by addressing outstanding Commission directives from Order Nos. 693 and 742,
clarifying language in certain requirements, and eliminating redundant or unnecessary
requirements. First, the proposed Reliability Standard improves upon Reliability Standard PER005-1 by expanding the scope of the Reliability Standard to include training requirements for: (1)
18

local transmission control center operator personnel; (2) Operations Support Personnel; and (3)
certain Generator Operator dispatch personnel centrally-located at a generation control center. As
noted above, currently effective Reliability Standard PER-005-1 is limited to requiring Reliability
Coordinators, Balancing Authorities and Transmission Operators to train and verify the
capabilities of their System Operators. As the Commission recognized in Order No. 693, however,
while System Operators have primary responsibility for Real-time operations, there are other
personnel – namely, local transmission control center operator personnel, certain planning and
operations support personnel, and certain Generator Operator dispatch personnel – that perform or
support Real-time operations on the BES and could directly impact BES reliability.

As such,

including mandatory training requirements for these personnel under NERC’s Reliability Standard
will serve to enhance the reliability of the BES.
As is already required for System Operators, proposed Reliability Standard PER-005-2
requires the use of a systematic approach to develop and implement training requirements for local
transmission control center operator personnel, certain planning and operations support personnel,
and certain Generator Operator dispatch personnel. The proposed Reliability Standard requires,
consistent with the principles of an effective systematic approach to training, that the training for
these personnel be tailored to the needs of the respective positions and their impact to BES
reliability.
As explained further below, however, the standard drafting team determined, based on
research conducted by the NERC Operating Committee’s Event Analysis Subcommittee, that there
was insufficient evidence at this time to warrant an extension of the mandatory training
requirements to personnel that support EMS applications. The ERO will continue to assess the
need for mandatory training of these personnel.

19

The proposed Reliability Standard further modifies the prior version of the standard to
include an implementation period for those entities that may become subject, at some point in the
future, to the requirement to provide emergency operations training using simulation technology.
Consistent with FERC’s directive, the implementation period is designed to provide such entities
sufficient time to acquire the appropriate simulation technology and modify their training
programs before they are required to comply with the requirement to use simulation technology.
In addition to modifying Reliability Standard PER-005-1 to address Commission
directives, the standard drafting team sought to modify the standard to improve the clarity, quality
and content of the Reliability Standard. The most substantive modification was the removal of the
obligation from Requirement R3 of PER-005-1 that Reliability Coordinators, Balancing
Authorities, and Transmission Operators provide their System Operators at least 32 hours of
emergency operations training every 12 months. As further explained below, the frequency and
amount of emergency operations training for System Operators is most appropriately determined
by each entity’s systematic approach to developing and implementing a training program tailored
to the needs of its organization, rather than a uniform requirement applied to each entity regardless
of the entity’s unique characteristics or reliability risk to the Bulk-Power System.
B.

Requirements of Proposed Reliability Standard PER-005-2

The proposed Reliability Standard contains six requirements that comprehensively address
training requirements for System Operators, local transmission control center operators,
Operations Support Personnel and applicable Generator Operator dispatch personnel. With the
exception of removing the 32-hour emergency operations training requirement, the proposed

20

Reliability Standard carries over all of the requirements of Reliability Standard PER-005-1 and
includes three new requirements to address Commission directives, as follows:53


Requirement R1 covers training requirements for System Operators and includes the same
substantive requirements as those provided in PER-005-1, Requirement R1. The only
modifications to Requirement R1 were non-substantive and designed to increase the
clarity of the requirement.



Requirement R2 is a new requirement that covers training requirements for local
transmission controls center operators. The requirements in Requirement R2 mirror those
in Requirement R1 for System Operators.



Requirement R3, which maps to Requirement R2 of PER-005-1, requires the verification
of a System Operator’s and a local transmission control center operator’s ability to perform
Real-time, reliability-related tasks. The only differences between proposed PER-005-2,
Requirement R3 and PER-005-1, Requirement R2 is the inclusion of local transmission
control center operators and certain minor changes to the language to provide additional
clarity.



Requirement R4, which maps to Requirement R3.1 of PER-005-1, identifies those entities
that must provide emergency operations training using simulation technology. In contrast
to Requirement R3.1 of PER-005-1, Requirement R4 of proposed PER-005-2, includes
local transmission control center operators as personnel that may be required to receive
emergency operations training using simulation technology. Additionally, Requirement
R4, part 4.1 includes a 12-month implementation period for those entities that may become
subject to the requirement at some point in the future.



Requirement R5 is a new requirement that requires Reliability Coordinators, Balancing
Authorities and Transmission Operators to use a systematic approach to develop and
implement training for Operations Support Personnel on how their job function(s) impact
the Real-time reliability-related tasks which they support.



Requirement R6 is a new requirement that requires Generator Operators to use a systematic
approach to develop and implement training for dispatch personnel at a centrally located
dispatch center who receive direction from the Generator Operator’s Reliability
Coordinator, Balancing Authority, Transmission Operator or Transmission Owner, and
develop specific dispatch instructions for plant operators under their control.
The following is a more detailed discussion of each requirement in proposed Reliability

Standard PER-005-2, including an explanation of how each requirement improves upon the prior

53

Exhibit D to this Petition is a mapping document showing the translation of PER-005-1 to proposed PER005-2. Additionally, Exhibit A includes a redline of the Reliability Standard comparing PER-005-1 and proposed
PER-005-2.

21

version of the Reliability Standard and, where applicable, satisfies outstanding Commission
directives.
Requirement R1 covers the development and implementation of training programs for
System Operators, as follows:
R1.

Each Reliability Coordinator, Balancing Authority, and Transmission Operator shall use
a systematic approach to develop and implement a training program for its System
Operators as follows:
1.1. Each Reliability Coordinator, Balancing Authority, and Transmission Operator
shall create a list of Bulk Electric System (BES) company-specific Real-time
reliability-related tasks based on a defined and documented methodology.
1.1.1. Each Reliability Coordinator, Balancing Authority, and Transmission
Operator shall review, and update if necessary, its list of BES companyspecific Real-time reliability-related tasks identified in part 1.1 each
calendar year.
1.2. Each Reliability Coordinator, Balancing Authority, and Transmission Operator
shall design and develop training materials according to its training program, based
on the BES company-specific Real-time reliability-related task list created in part
1.1.
1.3. Each Reliability Coordinator, Balancing Authority, and Transmission Operator
shall deliver training to its System Operators according to its training program.
1.4. Each Reliability Coordinator, Balancing Authority, and Transmission Operator
shall conduct an evaluation each calendar year of the training program established
in Requirement R1 to identify any needed changes to the training program and shall
implement the changes identified.
The language and structure of Requirement R1 are virtually the same as Requirement R1

of PER-005-1. There were no substantive changes to the obligations imposed upon Reliability
Coordinators, Balancing Authorities, and Transmission Operators by the prior version of the
requirement. Requirement R1 continues to require the training of System Operators using a
systematic approach to training, which is a proven approach to: identify System Operator tasks
and the associated skills and knowledge necessary to accomplish those tasks; determine the
competency levels of each System Operator to carry-out those tasks; determine the competency
22

gaps; and design, implement and evaluate a training plan to address each System Operator’s
competency.
The standard drafting team, however, sought to modify certain language in the requirement
to provide additional clarity. Among others, the standards drafting team made the following
modifications:


Replacing the phrase “shall use a systematic approach to training to establish a training
program” with “shall use a systematic approach to develop and implement a training
program” to make the provision more readable and clarify the performance obligation
(“develop and implement” vs. establish).



Including the term “Real-time” before the phrase “reliability-related task” to clarify that
the relevant tasks are those performed in Real-time.



Including the phrase “based on a defined and documented methodology” in part 1.1 to
clarify that the task list to be created must, consistent with a systematic approach to
training, be based on a defined and documented methodology.



Clarifying part 1.2 to state that the training material to be developed must be designed and
developed based on the entity’s BES company-specific Real-time reliability-related tasks,
rather than some generic training materials.



Replacing the phrase “an annual evaluation” with “an evaluation every calendar year” in
part 1.4 to clarify the timeline for performing evaluations of the training program.

These modifications are designed to improve the strength and quality of the training delivered to
System Operators in accordance with Requirement R1.
Requirement R2 is a new requirement designed to satisfy the Commission’s directive to
expand the training requirements to include local transmission control center operators.
Requirement R2 mirrors the obligations in Requirement R1, as follows:
R2. Each Transmission Owner shall use a systematic approach to develop and implement a
training program for its personnel identified in Applicability Section 4.1.4.1 of this
standard as follows:
2.1. Each Transmission Owner shall create a list of BES company-specific Real-time
reliability-related tasks based on a defined and documented methodology.

23

2.1.1. Each Transmission Owner shall review, and update if necessary, its list of
BES company-specific Real-time reliability-related tasks identified in part
2.1 each calendar year.
2.2. Each Transmission Owner shall design and develop training materials according
to its training program, based on the BES company-specific Real-time reliabilityrelated task list created in part 2.1.
2.3. Each Transmission Owner shall deliver training to its personnel identified in
Applicability Section 4.1.4.1 of this standard according to its training program.
2.4. Each Transmission Owner shall conduct an evaluation each calendar year of the
training program established in Requirement R2 to identify any needed changes to
the training program and shall implement the changes identified.
Applicability Section 4.1.4.1 identifies Transmission Owner “[p]ersonnel, excluding field
switching personnel, who can act independently to operate or direct the operation of the
Transmission Owner’s Bulk Electric System transmission Facilities in Real-time.” The standard
drafting team identified these personnel as the “local transmission control center operators”
described in Order No. 693 and Order No. 742.54 As provided in Order No. 742, it is Transmission
Owners in RTO/ISO or other pooled resource contexts, “such as PSE&G, PPL Electric Utilities
Corp., PECO Energy Company, Baltimore Gas and Electric Co., Consolidated Edison of New
York, Inc., National Grid USA, and Long Island Power Authority, which are not registered
transmission operators,” that have local transmission control centers whose operators carry out the
instructions issued by RTOs/ISOs or other pooled resource organization.55
As the Commission stated in Order No. 693, these personnel “may take independent action
under certain circumstances, for example, to protect assets, personal safety and during system
restorations.”56 As such, Applicability Section 4.1.4.1 focuses on Transmission Owner personnel

54

Order No. 693 at pp 1342-46; Order No. 742 at p 62.

55

Order No. 742 at P 62.

Order No. 693 at P 1343. See also Order No. 693 at P 1347 (“…these operators maintain authority to act
independently to carry out tasks that require real-time operation of the Bulk-Power System, including protecting
56

24

that may “act independently to operate or direct the operation” of the Transmission Owner’s
transmission facilities in Real-time.

Field switching personnel are properly excluded in

accordance with Order No. 693 as these personnel “are not involved with the transmission operator
at the ISO or RTO or at organizations with pooled resources.”57
Because of their authority to take independent action to carry out tasks that require Realtime operation of the Bulk-Power System, local transmission controls center operators are treated
similarly to System Operators under the proposed Reliability Standard. Specifically, the training
requirements in Requirement R2 mirror those required for System Operators under Requirement
R1. Additionally, like System Operators, Transmission Owners must (i) verify the capabilities of
their local control center operators under Requirement R3 and, (ii) for those Transmission Owners
that meet the criteria specified in Requirement R4, provide emergency operations training to their
local control center operators using simulation technology.
Consistent with the requirement to use a systematic approach to training, however, the
actual training program for local transmission control center operators must be consistent with
their roles, responsibilities and tasks, and would not necessarily cover the same topics, or be
structured in the same manner, as the programs developed for System Operators pursuant to
Requirement R1. As FERC stated in Order No. 742, training local control center operator
personnel will further the reliability goal of helping to ensure that local transmission control center
operators “understand what they are required to do in the performance of their duties to perform
them effectively on a timely basis.”58

assets, protecting personal safety, adhering to regulatory requirements and establishing stable islands during system
restorations.”)
57

Order No. 693 at P 1346.

58

Order No. 742 at P 62.

25

Requirement R3 provides as follows:
R3. Each Reliability Coordinator, Balancing Authority, Transmission Operator, and
Transmission Owner shall verify, at least once, the capabilities of its personnel,
identified in Requirement R1 or Requirement R2, assigned to perform each of the BES
company-specific Real-time reliability-related tasks identified under Requirement R1
part 1.1 or Requirement R2 part 2.1.
3.1. Within six months of a modification or addition of a BES company-specific Realtime reliability-related task, each Reliability Coordinator, Balancing Authority,
Transmission Operator, and Transmission Owner shall verify the capabilities of
each of its personnel identified in Requirement R1 or Requirement R2 to perform
the new or modified BES company-specific Real-time reliability-related tasks
identified in Requirement R1 part 1.1 or Requirement R2 part 2.1.
As noted above, Requirement R3 carries over the obligation from Requirement R2 of PER005-1 that Reliability Coordinators, Balancing Authorities and Transmission Operators verify the
capabilities of each of their System Operators assigned to perform the Real-time reliability-related
tasks identified in accordance with Requirement R1. Requirement R3 improves upon PER-0051, Requirement R2 by requiring that Transmission Owners also verify the capabilities of each of
their local transmission control center operators assigned to perform the Real-time reliabilityrelated tasks identified in accordance with Requirement R2. In addition, the standard drafting team
modified the language from the prior version of the standard to provide clarity.
Part 3.1 of Requirement R3 mirrors Requirement R2.1 of PER-005-1 in that it provides
applicable entities six months to verify their applicable personnel’s capability to perform a new or
modified task added to the Real-time reliability related task list required by Requirement R1 part
1.1 or Requirement R2 part 2.1.
Requirement R4 identifies those entities that must provide emergency operations training
using simulation technology, as follows:
R4. Each Reliability Coordinator, Balancing Authority, Transmission Operator, and
Transmission Owner that (1) has operational authority or control over Facilities with
established Interconnection Reliability Operating Limits (IROLs), or (2) has
established protection systems or operating guides to mitigate IROL violations, shall
26

provide its personnel identified in Requirement R1 or Requirement R2 with emergency
operations training using simulation technology such as a simulator, virtual technology,
or other technology that replicates the operational behavior of the BES.
4.1. A Reliability Coordinator, Balancing Authority, Transmission Operator, or
Transmission Owner that did not previously meet the criteria of Requirement R4,
shall comply with Requirement R4 within 12 months of meeting the criteria.
Requirement R4 carries over the obligation from Requirement R3.1 of PER-005-1 that
Reliability Coordinators, Balancing Authorities, and Transmission Operators that have (1)
operational authority or control over Facilities with established IROLs, or (2) established
protection systems or operating guides to mitigate IROL violations, provide their System
Operators emergency operations training using simulation technology. Requirement R4 improves
upon Requirement R3.1 of PER-005-1 by also requiring that Transmission Owners that meet the
above described criteria also use simulation technology when providing emergency operations
training to their local transmission control center operators. While it is unlikely for a Transmission
Owner to have operational authority or control over Facilities with an IROL, certain applicable
Transmission Owners may have established protection systems or operating guides to mitigate
IROL violations. In addition, the standard drafting team modified the language from the prior
version of the standard to provide clarity.
Consistent with Commission directives, part 4.1 of Requirement R4 includes a 12-month
implementation period for those entities that may, at some future time after the effective date of
the proposed Reliability Standard, meet the criteria for having to comply with Requirement R4.
The 12-month implementation period is necessary to provide such entities sufficient time to
acquire the necessary simulation technology and modify their training programs before they are
required to comply with the requirement to use simulation technology.
The proposed Reliability Standard does not retain the obligation from PER-005-1,
Requirement R3 that Reliability Coordinators, Balancing Authorities, and Transmission Operators
27

provide their System Operators at least 32 hours of emergency operations training every 12
months. The standard drafting team concluded that such a requirement is unnecessary and
inconsistent with the obligation in Requirement R1 to use a systematic approach to develop and
implement a training program for System Operators. As discussed above, inherent in any
systematic approach to training method is an analysis of the skills and knowledge necessary for
the position in question and the design, development and implementation of a training program
based on that analysis. Because emergency operations are a significant component of many of the
BES company-specific Real-time reliability-related tasks performed by System Operators,
emergency operations training must be an integral part of any training program developed in
accordance with Requirement R1.

Specifically, Requirement R1 obligates Reliability

Coordinators, Balancing Authorities, and Transmission Operators to:


include all BES company-specific Real-time reliability-related tasks performed by System
Operators, including those tasks involving emergency operations, in their list of tasks
required by part 1.1;



analyze the skills and knowledge necessary for their System Operators to competently
perform those tasks;



design and develop, in accordance with part 1.2, training materials and requirements for
their System Operators, which must include the frequency and amount of emergency
operations training necessary for System Operators to competently perform the tasks
involving emergency operations.;



provide emergency operations training to their System Operators in accordance with their
training program, as required by part 1.3; and



evaluate the effectiveness of their training program, including their emergency operations
training, every calendar year to identify and implement any necessary changes, as required
by part 1.4.59

59

These same obligations would apply to Transmission Owners in developing training programs for their
local control center operators under Requirement R2. Transmission Owners will be required to identify any Realtime reliability-related tasks involving emergency operations that are performed by their local control center
operators and then design, develop and implement a training program that include emergency operations training.
The frequency and amount of such training would be dictated by the analysis of the skills and knowledge necessary

28

The standard drafting team thus concluded that a generally applicable requirement
mandating a minimum amount of emergency operations training, irrespective of the entity’s unique
characteristics or reliability risk to the Bulk-Power System, is unnecessary and inconsistent with
the Commission-approved requirement to use a systematic approach to training methodology. To
comply with Requirement R1, Reliability Coordinators, Balancing Authorities, and Transmission
Operators will determine the frequency and amount of emergency operations training necessary to
support reliable operation of the Bulk-Power System based on an analysis of the needs and risks
of their particular organization and the position in question. As noted above, using a systematic
approach to training methodology is a widely-accepted approach for developing efficient and
effective training programs tailored to the needs and characteristics of the organization and
personnel in question.
The proposal to remove the obligation to provide 32 hours of emergency operations
training every 12 months does not eliminate the obligation to provide continual emergency
operations training to System Operators. As the Commission recognized in Order No. 742,
continual or repeated training is a fundamental part of any systematic approach to training and an
enforceable requirement of the Reliability Standard:
Based on NERC’s and the majority of commenters’ affirmation that continual
training is a fundamental part of a systematic approach to training and an
enforceable requirement of under PER-005-1, we find that any systematic approach
to training, including the systematic approach to training mandated by Reliability
Standard PER-005-1, would entail continual training to refresh System Operators’
knowledge and to cover any new tasks relevant to the operation of the Bulk-Power
System.60

to help ensure that the local control center operators are competent to perform the tasks involving emergency
operations.
60

Order No. 742 at P 34.

29

The deletion of Requirement R3 of PER-005-1 simply recognizes that the frequency and amount
of emergency operations training is most appropriately determined by an entity as part of its
systematic approach to developing and implementing a training program for its System Operators.
Requirement R5 addresses the Commission’s directive to expand the scope of the
Reliability Standard to include training requirements for “those [individuals] who carry out outage
coordination and assessments in accordance with Reliability Standards IRO-004-1 and TOP-0022, and those who determine SOLs and IROLs or operating nomograms in accordance with
Reliability Standards IRO-005-1 and TOP-004-0.”61 Requirement R5 provides:
R5. Each Reliability Coordinator, Balancing Authority, and Transmission Operator shall
use a systematic approach to develop and implement training for its identified
Operations Support Personnel on how their job function(s) impact those BES
company-specific Real-time reliability-related tasks identified by the entity pursuant to
Requirement R1 part 1.1.
5.1. Each Reliability Coordinator, Balancing Authority, and Transmission Operator
shall conduct an evaluation each calendar year of the training established in
Requirement R5 to identify and implement changes to the training.
The proposed definition for Operations Support Personnel mirrors the Commission’s
description of the type of support personnel that may have a direct impact on reliable operations.
Specifically, the term Operations Support Personnel is proposed to be defined as “[i]ndividuals
who perform current day or next day outage coordination or assessments, or who determine SOLs,
IROLs, or operating nomograms, in direct support of Real-time operations of the Bulk Electric
System.”
Requirement R5 serves the important reliability goal of helping to ensure that individuals
that support the Real-time operation of the Bulk Electric System, even if not directly responsible
for operating any BES Facilities, receive adequate training on how their job functions impact the

61

Order No. 693 at P 1372; Order No. 742 at P 82.

30

Real-time reliability related tasks they support. To be clear, this requirement does not require that
Operations Support Personnel be trained on the System Operator’s responsibilities; rather, the
requirement mandates that training be based on how the roles, responsibilities and tasks of
Operations Support Personnel affect the tasks performed by System Operator. This approach is
consistent with the use of a systematic approach to training because it requires the training to be
directly related to the needs of the position in question.
As noted above, the standard drafting team concluded that it was not necessary, at this time,
to expand the scope of the Reliability Standard to include personnel who support EMS
applications. The standard drafting team relied on a May 2013 report provided by the NERC
Operating Committee’s Event Analysis Subcommittee. The report was issued in response to a
request by NERC’s Standards Committee that the Event Analysis Subcommittee consider which
personnel, including EMS support personnel, should be trained under NERC’s Reliability
Standards. The Event Analysis Subcommittee concluded there was insufficient evidence to
warrant extending mandatory training requirements of PER-005-1 to EMS support personnel.62
Specifically, the Event Analysis Subcommittee reviewed the reportable events in NERC’s
Event Analysis database to determine whether there was any evidence demonstrating a need to
include EMS support personnel in NERC’s mandatory training Reliability Standard. The Event
Analysis database included the reportable events on the Bulk-Power System beginning in October
2010. As of May 2013, when the report was issued, the database included over 263 events, 208
of which were cause-coded to allow for trending and cluster analysis. The Event Analysis
Subcommittee and NERC Event Analysis staff queried the 208 events for cause-codes that

62

The Event Analysis Subcommittee is available at
http://www.nerc.com/pa/Stand/PER%20Informal%20Development/NERC%20Event%20Analysis%20Subcommitte
e%20Response%20to%20Request%20for%20Research%20Updated%2010%20May%202013.pdf.

31

pertained to human error or lack of training. The query produced 44 events that identified human
error or lack of training as a possible contributing factor in the event. A further analysis of those
44 events, however, indicated that human error or lack of training was a contributing factor in only
10 of those events. Six of those 10 events were related to the loss of EMS or Supervisory Control
and Data Acquisition (SCADA) applications. The report also indicates that out of those six events,
only two were deemed to be due to a lack of training. Based on that information, the Event
Analysis Subcommittee concluded that while EMS support personnel should receive training, the
evidence does not support a need for such personnel to be trained under Reliability Standard PER005.
Requirement R6 addresses the Commission’s directive to expand the scope of the
Reliability Standard to include training requirements for certain Generator Operator dispatch
personnel. Requirement R6 provides:
R6. Each Generator Operator shall use a systematic approach to develop and implement
training to its personnel identified in Applicability Section 4.1.5.1 of this standard, on
how their job function(s) impact the reliable operations of the BES during normal and
emergency operations.
6.1. Each Generator Operator shall conduct an evaluation each calendar year of the
training established in Requirement R6 to identify and implement changes to the
training.
Applicability Section 4.1.5.1 identifies Generator Operator “[d]ispatch personnel at a
centrally located dispatch center who receive direction from the Generator Operator’s Reliability
Coordinator, Balancing Authority, Transmission Operator, or Transmission Owner, and may
develop specific dispatch instructions for plant operators under their control.” The description of
the personnel identified in Applicability Section 4.1.5.1 mirrors the Commission’s description of
the type of Generator Operator dispatch personnel that may have a direct impact on reliable

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operations and should be included in the mandatory training Reliability Standard. 63 As the
Commission recognized, although Generator Operators take directions from Balancing Authorities
and others, which limits their ability to impact reliability, it is essential that these Generator
Operator dispatch personnel have appropriate training to understand those instructions,
particularly in an emergency situation in which instructions may be succinct and require immediate
action.64 Applicability Section 4.1.5.1 clarifies that, consistent with FERC’s directive in Order
No. 693, these personnel do not include plant operators located at a generator plant site or
personnel at a centrally located dispatch center who simply relay dispatch instructions without
making any modifications.65
Because of the more limited impact that these Generator Operator dispatch personnel have
on the reliable operation of the BES, Requirement R6 only requires that Generator Operators use
a systematic approach to develop and implement training for its applicable personnel on how their
job function(s) impact the reliable operations of the BES during normal and emergency operations.
While an entity may choose to develop a reliability-related task list and other documents typically
developed as part of a systematic approach to training methodology, proposed Requirement R6
does not explicitly require them to do so. Nevertheless, applicable Generator Operators must be
able to show that their training complies with the principles of a systematic approach to training,
such as whether the entity assessed training needs, provided training based on that assessment, and
evaluated the training activity.

63

Order No. 693 at PP 1360-62; Order No. 742 at P 83.

64

Order No. 693 at P 1359.

65

Id. at PP 1360-61.

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C.

Enforceability of the Proposed Reliability Standards

The proposed Reliability Standard includes VRFs and VSLs. The VRFs and VSLs provide
guidance on the way that NERC will enforce the requirements of the proposed Reliability
Standard. The VRFs and VSLs for the proposed Reliability Standard comport with NERC and
Commission guidelines related to their assignment. Exhibit E provides a detailed review of the
VRFs, the VSLs, and the analysis of how the VRFs and VSLs were determined using these
guidelines.
The proposed Reliability Standard also includes measures that support each requirement
by clearly identifying what is required and how the requirement will be enforced. These measures
help ensure that the requirements will be enforced in a clear, consistent, and non-preferential
manner and without prejudice to any party.66
D.

Proposed Modifications to the Definition of “System Operator”

As part of NERC Project 2010-01 Training, the standard drafting team sought to respond
to industry requests to modify the NERC Glossary definition of “System Operator” to more
accurately describe the personnel the industry generally considers to be System Operators.67 The
current definition of “System Operator is as follows:
An individual at a control center (Balancing Authority, Transmission Operator,
Generator Operator, Reliability Coordinator) whose responsibility it is to monitor
and control that electric system in real time.
NERC is proposing the following definition:

Order No. 672 at P 327 (“There should be a clear criterion or measure of whether an entity is in compliance
with a proposed Reliability Standard. It should contain or be accompanied by an objective measure of compliance
so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential manner.”).
66

67

See Standard Authorization Request submitted by Thomas J. Bradish of RRI Energy on October 5, 2010
and accepted by the NERC Standards Committee on October 13, 2010, available at
http://www.nerc.com/pa/Stand/Project%20201016%20Definition%20of%20System%20Operator%20DL/Project_20
10-16_System_Op_Definition_SAR_approved_by_SC-Clean_UPDATED.pdf.

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An individual at a Control Center of a Balancing Authority, Transmission Operator,
or Reliability Coordinator who operates or directs the operation of the Bulk Electric
System in Real-time.
The purpose of the proposed modification is to properly limit the definition to those operations
personnel that have the independent authority to operate the Bulk Electric System in Real-time.
The following is a discussion of each of the modifications to the definition.
First, the standard drafting team concluded that the phrase “operates or directs the operation
of the Bulk Electric System in Real-time” more accurately depicts the function of a System
Operator than the phrase “whose responsibility it is to monitor and control that electric system in
real time.” Specifically, the duty of a System Operator is to constantly monitor the BES and take
the necessary action to operate the system in a reliable and economic manner based on varying
system conditions. The System Operator is tasked with, among other things, reacting to varying
system conditions by modifying system configurations, generator outputs, and transmission
loadings, and directing field personnel to take various actions. The standard drafting team
considered the words “monitor” and “control” to be too ambiguous and limiting. The standard
drafting team used the phrase “operates or directs the operation” to better capture the duties
performed by the System Operator. The standard drafting team also maintains that the phrase
“operates or directs the operation” sufficiently limits the definition to the personnel in a Control
Center who have the independent authority to operate the BES. Individuals that perform certain
tasks under the direct supervision of the NERC-certified System Operator should not be considered
to be “operating” the BES.68

As noted in footnote 1 to Reliability Standard PER-003-1, “[n]on-NERC certified personnel performing
any reliability-related task of a real-time operating position must be under the direct supervision of a NERC
Certified System Operator stationed at that operating position; the NERC Certified System Operator at that
operating position has ultimate responsibility for the performance of the reliability-related tasks.”
68

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The other significant change to the definition of System Operator was to remove reference
to Generator Operators. The role of a Generator Operator is limited to operating generating units
and performing the function of supplying energy and ancillary services to the grid. A Generator
Operator is limited in the action it could take without instructions from its Reliability Coordinator,
Balancing Authority or Transmission Operator.

For instance, a Generator Operator cannot

perform contingency analyses, institute switching orders, observe Real-time transmission line
flows and status, or issue Transmission Loading Relief requests. Given this limited scope, the
standard drafting team concluded it was not appropriate to categorize Generator Operator
personnel as Systems Operators in the same manner as the operating personnel of a Reliability
Coordinator, Balancing Authority and Transmission Operator. Removing references to Generator
Operators from the definition is consistent with the manner in which the term is used in NERC’s
Reliability Standards. No Reliability Standard uses the NERC Glossary term “System Operator”
to refer to Generator Operator personnel.
Lastly, the definition of System Operator was modified to capitalize the terms “Control
Center” and “Real-time” so as to refer to the FERC-approved definition of these terms. Neither
“Control Center” nor “Real-time” were FERC-approved defined terms when the current definition
of “System Operator” was developed.
V.

EFFECTIVE DATE
As described in the Implementation Plan, attached hereto as Exhibit B, NERC respectfully

requests that the Commission approve the proposed Reliability Standard and new and modified
NERC Glossary Terms effective on the first day of the first calendar quarter that is 24 months after
Commission approval. This 24-month implementation period will provide sufficient time for the
applicable entities to develop or modify their processes to comply with proposed PER-005-2. The

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standard drafting team determined that a 24-month implementation period was appropriate because
proposed Reliability Standard PER-005-2 is applicable to functional entities (Transmission
Owners and Generator Operators) that are not currently subject to PER-005-1. Transmission
Owners and Generator Operators will for the first time be required to develop and implement a
systematic approach to training process for their applicable personnel. The standard drafting team
concluded that a 24-month implementation period is a sufficient amount of time to allow these
entities to develop and implement a systematic approach to training process prior to the
enforceability of the proposed standard. The proposed implementation period is consistent with
the 24-month implementation period provided to Reliability Coordinators, Balancing Authorities
and Transmission Operators under PER-005-1.
The proposed 24-month implementation period is also necessary to provide Reliability
Coordinators, Balancing Authorities and Transmission Operators sufficient time to develop
training for their Operations Support Personnel. Even though these entities are already subject to
PER-005-1, the standard drafting team concluded that these entities will need a 24-month
implementation period to modify their processes and training requirements to account for
Operations Support Personnel. During the implementation period, Reliability Coordinators,
Balancing Authorities and Transmission Operators must continue to comply with the requirements
of PER-005-1 applicable to their System Operators.
As described in the proposed Implementation Plan, NERC also respectfully requests that
the Commission approve the retirement of PER-005-1 effective 11:59:59 pm of the day
immediately prior to the effective date for PER-005-2.
VI.

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve:

37



the proposed Reliability Standard and associated elements included in Exhibit A,
effective as proposed herein;



the proposed Implementation Plan included in Exhibit B;



the proposed definitions for the terms “System Operator” and “Operations Support
Personnel,” effective as proposed herein; and



the retirement of Reliability Standard PER-005-1, effective as proposed herein.
Respectfully submitted,
/s/ S. Shamai Elstein
Charles A. Berardesco
Senior Vice President and General Counsel
Holly A. Hawkins
Assistant General Counsel
S. Shamai Elstein
Counsel
North American Electric Reliability Corporation
1325 G Street, N.W., Suite 600
Washington, D.C. 20005
202-400-3000
charlie.berardesco@nerc.net
holly.hawkins@nerc.net
shamai.elstein@nerc.net
Counsel for the North American Electric
Reliability Corporation

Date: March 7, 2014

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