NERC System Operator Certification Phase IIAdministrative Guidelines
System Operator Certification Program
Administrative Guidelines
DRAFT for COMMENTS
Maintaining
NERC System Operator Credential
Through the Use of
Continuing Education Credit Hours
North American Electric Reliability Council
Executive Summary
The 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.
Details
The 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:
- 240 CEH for Reliability Coordinator,
- 180 CEH for Balancing and Interchange/Transmission Operator,
- 120 CEH for Balancing Operators, and
- 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.
Transition
A 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 Preamble
The 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 Compton
PECO
/ 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 R
MidAmerican
/ 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
/ 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 / 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. Stallcop
Supervisor - Transmission System Operations
AEP - Public Service Company of Oklahoma
office: (918) 610 – 3601
/ This is a great way to track the continuing education hours earned
Godiksen, Dan
Electric System Dispatcher
CWLP / 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 / 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 / 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
WAPA-RMR Operations - Switching
(970 )461-7463
/ The number of hours required by this proposal exceed the amount 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 Mason
Supervisor-Transmission System Operations
Missouri Public Service/Aquila
Mason, / 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 Power
/ 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 Neagle
Associated Electric Cooperative, Inc.
/ 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
PacifiCorp
/ 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 / Why is retaking the exam not an option in lieu of not accumulation the required CEU's. This does not make sense.
Terry Banks
Senior System Operator (Training)
NB Power
/ 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.
Goals
In light of the foregoing, the following goals have been set in place: