BONNEVILLE POWER ADMINISTRATION

**HUMAN CAPITAL MANAGEMENT**

**Portland, Oregon**

## PERSONNEL LETTER NO. 511-1 (Revised) DATE: November 1, 2006 {#personnel-letter-no.-511-1-revised-date-november-1-2006 .unnumbered}

## SUBJECT: Position Classification {#subject-position-classification .unnumbered}

**PURPOSE**

[]{#__RefHeading___Toc151435268 .anchor}

This Personnel Letter -

-   Establishes the Bonneville Power Administration's (BPA's) policy on
    classifying positions under the General Schedule (GS) and for
    processing position classification appeals of BPA employees.

-   Revised to describe procedures for final internal adjudication of
    classification actions proposed by line management, make related
    changes, and update nomenclature.

-   Supersedes Personnel Letter 511-1, dated July 28, 2006.

The provisions of this Letter do not apply to the following -

-   Employees in recognized bargaining units who negotiate their wage
    rates with BPA under the provisions of 16 U.S.C. 832, Bonneville
    Project Act of 1937 (as amended).

-   Positions of experts and consultants, and positions above the GS-15
    grade level, including positions in the Senior Executive Service
    (SES).

**POLICY SUMMARY:**[]{#__RefHeading___Toc151435269 .anchor}

To classify GS positions within BPA, in accordance with required Federal
law and regulation, in a manner that best supports BPA's legally
mandated fiduciary, public, technical, and environmental
responsibilities.

[**PURPOSE 1**](#__RefHeading___Toc151435268)

[POLICY 1](#__RefHeading___Toc151435269)

[I. RESPONSIBILITIES 4](#__RefHeading___Toc151435270)

[II. POSITION DESCRIPTION 5](#__RefHeading___Toc151435274)

[*Purpose of Position Descriptions* 5](#__RefHeading___Toc151435275)

[*Responsibility of Management* 5](#__RefHeading___Toc151435276)

[*Standard of Adequacy* 5](#__RefHeading___Toc151435277)

[*Preparation of Position Descriptions* 5](#__RefHeading___Toc151435278)

[*Form* 6](#__RefHeading___Toc151435279)

[*Supervisory Certification* 6](#__RefHeading___Toc151435280)

[*Classification Certification* 6](#__RefHeading___Toc151435281)

[*Guides for Preparing Position Descriptions*
6](#__RefHeading___Toc151435282)

[III. POSITION CLASSIFCATION REQUIRMENTS
6](#__RefHeading___Toc151435283)

[*Standards* 6](#__RefHeading___Toc151435284)

[*Determination of Pay Plan, Series, Title, and Grade*
6](#__RefHeading___Toc151435285)

[*Data Gathering by Servicing HCM Specialists to Determine the
Classification of Position* 7](#__RefHeading___Toc151435286)

[*Conditional or Limited Classifications*
7](#conditional-or-limited-classifications)

[*Use of Evaluation Statements* 8](#use-of-evaluation-statements)

[*Content of Evaluation Statements* 8](#__RefHeading___Toc151435289)

[IV. CLASSIFICTATION PROCESS 9](#classification-process)

[*Review by HCM* 9](#__RefHeading___Toc151435291)

[*Review by the BPA HCM officer* 10](#__RefHeading___Toc151435292)

[*Requests for Desk Audits* 10](#__RefHeading___Toc151435293)

[V. CLASSIFICATION APPEALS 10](#classification-appeals)

[*Coverage* 10](#__RefHeading___Toc151435295)

[*Exclusions* 10](#__RefHeading___Toc151435296)

[*Classification Appeal Rights* 11](#__RefHeading___Toc151435297)

[*Representation and Use of Official Time*
11](#__RefHeading___Toc151435298)

[*Reduction in Grade or Pay* 11](#reduction-in-grade-or-pay)

[*Availability of Position Standards* 12](#__RefHeading___Toc151435300)

[*Classification Appeal Procedure* 12](#__RefHeading___Toc151435301)

[*Requests for Reconsideration* 14](#__RefHeading___Toc151435302)

[VI. POSITION CLASSIFICATIONS 14](#__RefHeading___Toc151435303)

[VII. EFFECTING CLASSIFICATION ACTIONS 14](#__RefHeading___Toc151435304)

[VIII. REFERENCES 14](#__RefHeading___Toc151435305)

[APPENDIX A - GENERIC FACTOR LEVEL DESCRIPTIONS IN POSITION DESCRIPTIONS
FOR BPA ANNUAL POSITIONS 16](#descriptions-for-bpa-annual-positions)

[APPENDIX B - REQUIRED STATEMENTS FOR POSITION DESCRIPTIONS
20](#required-statements-for-position-descriptions)

I.  **RESPONSIBILITIES**[]{#__RefHeading___Toc151435270 .anchor}

    A.  **The BPA Chief Human Capital Officer (CHCO)***:*

> Exercises delegated authority, in accordance with BPAM 21, to make
> final BPA classification determinations on actions that are referred
> for resolution.
>
> Additionally, the CHCO shall:

1.  Develop the position classification program and the personnel
    management aspects of the position management program throughout
    BPA; and

2.  Review and evaluate the position classification program and the
    personnel management aspects of the position management program
    throughout BPA for adequacy, effectiveness, and conformance with
    governing laws, regulations, procedures, and policies.

    A.  **In accordance with BPAM Chapter 21, the CHCO, through
        delegation to subordinate supervisors and servicing Human
        Capital Management (HCM) Specialists, shall:**

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1.  Advise managers, supervisors, and employees of the provisions of
    this Letter and assure its implementation;

2.  Assess the effectiveness of the position classification program and
    the personnel management aspects of the position management program
    and initiate improvement as warranted;

3.  Evaluate and assign an appropriate pay plan, title, series, and
    grade to each position by reference to criteria in published OPM
    position classification standards and guides and in accordance with
    delegated classification authority. In conducting the position
    analysis needed to classify the position, the position's coverage
    under the Fair Labor Standards Act, bargaining unit coverage, and
    Federal Regulatory Commission Standards of Conduct coverage will
    also be determined;

4.  Review proposed new positions, requests to fill vacated positions,
    and changes in the duties or organizational relationships of
    existing positions before final classification action is taken;

5.  Ensure that positions are accurately described;

6.  Apply new position classification standards and guides to covered
    positions in a timely manner and reclassify such positions as
    appropriate;

7.  Ensure that any follow-up audits required by this Letter are tracked
    and conducted;

8.  Assist supervisors and managers in addressing classification issues
    in planning and implementing reorganizations and in establishing new
    positions; and

9.  Develop and implement additional operational policies, guidelines,
    and procedures concerning position classification.

    A.  **Supervisors and Managers shall:**

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1.  Prepare and maintain current descriptions of subordinates' major
    duties and responsibilities, certify the accuracy of such by
    signature on the position descriptions, and adhere to position
    classification and position management principles;

2.  Assist the servicing HCM Specialist in the successful conduct of
    position classification and position management reviews and surveys;

3.  Assign duties to positions and ensure that position structures are
    consistent with the principles of sound position management;

4.  Take corrective action when the results of position management
    reviews indicate a need for improvement in structure;

5.  Describe assigned duties and responsibilities to employees under
    their supervision; and

6.  Ensure that subordinate employees receive adequate information
    regarding classification principles, policies, and rights of appeal.

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II. **POSITION DESCRIPTIONS**[]{#__RefHeading___Toc151435274 .anchor}

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A.  []{#__RefHeading___Toc151435275 .anchor}**Purpose of Position
    Descriptions:** Position descriptions provide official records of
    the duties and responsibilities management has assigned to
    positions. Their main purpose is to ensure that employees are
    properly compensated for the duties they perform, but they are also
    essential for effective staffing, sound organizational planning,
    implementation of reorganizations, position management, budgeting,
    effective employee utilization, performance evaluation, and so
    forth.

B.  []{#__RefHeading___Toc151435276 .anchor}**Responsibility of
    Management:** Management is exclusively responsible for assigning
    duties and responsibilities to each subordinate position and for
    adding, removing, or changing assignments at any time. It is
    management's responsibility to prepare current and accurate position
    descriptions and to ensure that position descriptions are updated as
    soon as possible after permanent changes in individual assignments
    occur.

C.  []{#__RefHeading___Toc151435277 .anchor}**Standard of Adequacy:** A
    position description is adequate if it describes the major duties,
    responsibilities, knowledge, skills, abilities, supervisory
    relationships, and other required job factors of a position clearly
    enough to provide information necessary for classification, position
    management, and placement purposes, when considered by one familiar
    with the occupational fields involved and the application of
    pertinent classification standards, and when supplemented by readily
    available and current information on the organization, functions,
    programs, and procedures concerned. This standard of adequacy is a
    minimum standard established by OPM that BPA's position descriptions
    are required to meet.

D.  []{#__RefHeading___Toc151435278 .anchor}**Preparation of Position
    Descriptions:** Position descriptions shall be prepared by, or under
    the direct supervision of, each employee's immediate supervisor. It
    is advisable to obtain the opinions and comments of the affected
    employee(s). Upon receiving a classification request, the servicing
    HCM Specialist will determine whether the position description is
    adequate for evaluation and will ascertain its accuracy based on
    existing knowledge, readily available information, or data developed
    in considering the request**. (*NOTE*: Employee input is required
    under the BPA-PDL bargaining agreement, except for reorganization
    actions, when the duties in a position description are modified for
    PDL bargaining unit employee's existing position.)**

E.  []{#__RefHeading___Toc151435279 .anchor}**Form:** Position
    descriptions for all positions in grades GS-1 through GS/GM-15 are
    to be typed on plain bond and attached to a properly executed DOE F
    3511.1e, "Position Description," by the initiating office.

F.  []{#__RefHeading___Toc151435280 .anchor}**Supervisory
    Certification:** Immediate supervisors shall certify to the accuracy
    of the position description by signing the following statement,
    which is preprinted on the DOE F 3511.1e, for each position
    description submitted for classification action:

-   "I certify that this is an accurate statement of the major duties
    and responsibilities of this position and its organizational
    relationships, and that the position is necessary to carry out
    Government functions for which I am responsible. This certification
    is made with the knowledge that this information is to be used for
    statutory purposes, relating to appointment and payment of public
    funds, and that false or misleading statements may constitute
    violations of such statutes or their implementing regulations."

> The immediate supervisor shall sign on line 13a of DOE F 3511.1e. A
> higher-level supervisor may also sign line 13b at the discretion of
> the initiating office. In the absence of an immediate supervisor,
> certification by a higher-level supervisor is mandatory. This
> responsibility shall not be delegated.

G.  []{#__RefHeading___Toc151435281 .anchor}**Classification
    Certification:** The servicing HCM Specialist who certifies on line
    14 of DOE F 3511.1e that the position is properly classified by pay
    plan, title, series, and grade shall attempt to resolve any
    identified questions concerning the accuracy of the position
    description. The HCM Specialist will respond to any questions posed
    by the employee.

H.  []{#__RefHeading___Toc151435282 .anchor}**Guides for Preparing
    Position Descriptions:** The duties and responsibilities of
    positions are described in accordance with the instructions
    contained in this Letter and the attached Appendices.

    1.  **Appendix A** - Generic Position Descriptions for BPA Annual
        Positions

    2.  **Appendix B** **-** Required Statements for Position
        Descriptions

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III. **POSITION CLASSIFICATION
     REQUIREMENTS**[]{#__RefHeading___Toc151435283 .anchor}

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A.  []{#__RefHeading___Toc151435284 .anchor}**Standards:** All positions
    must be classified consistently with published OPM standards and/or
    guides. Any evaluation decisions of OPM that have been certified
    ***(i.e., OPM has ordered, in writing, that a particular
    classification be assigned to a particular position or positions)***
    to BPA or to DOE are binding upon all BPA officials. The
    classification of positions to which they apply may not be changed
    while the major duties and responsibilities remain substantially the
    same, unless pertinent new standards are issued.

B.  []{#__RefHeading___Toc151435285 .anchor}**Determination of Pay Plan,
    Series, Title, and Grade:** Proper pay plans, occupational series,
    titles, and grades for all positions will be determined in
    conformance with this Letter and published OPM position
    classification standards/guides.

C.  []{#__RefHeading___Toc151435286 .anchor}**Data Gathering by
    Servicing HCM Specialists to Determine the Classification of a
    Position**

    1.  **Desk Audits** are first-hand inquiries about the work of a
        position through the use of interviews and the observation of
        work operations. The interviews are typically conducted by a
        servicing HCM Specialist with the employees performing the
        duties or occupying the positions being assessed and, when
        appropriate, with the supervisors and subordinates of the
        employees being audited. **It is the position as actually
        performed, not the employee, which is being evaluated.**

    2.  **Supervisory Audits** are conducted with the supervisor of a
        position when the position is not encumbered, the incumbent is
        not familiar with new duties being assigned to the position, or
        the incumbent is not available for a desk audit. The purposes of
        a supervisory audit are the same as those described for a desk
        audit.

    3.  **Other Data Gathering** may be appropriate and advisable in
        developing full position information and understanding. Sources
        of data include, but are not limited to: the use of central
        files; textbooks and monographs; dockets; publications produced
        by or about the organization and functional statements; and
        interviews with employees in related organizations (such as
        personnel in the budget office when evaluating the budget duties
        in an administrative position).

# Conditional or Limited Classifications

1.  **Projected Positions:** When an organization is newly established
    or an existing organization is assigned major new projects,
    functions, or responsibilities, a situation may be created in which
    management must anticipate what duties will be assigned to various
    positions. Post audits of all projected positions will be done
    within 180 days of incumbency, when there is a question about
    whether the anticipated duties have materialized, to ensure the
    accuracy of the position descriptions and the classification
    decisions. This timeframe enables the incumbent to assume the duties
    of the position and is sufficient for the position to stabilize to
    the extent that the projection can be validated or invalidated. In
    the event management makes permanent changes to the position prior
    to the post audit, the position description shall be updated within
    30 days of the permanent changes. The fact that a position's
    duties/responsibilities are projected will be recorded on the DOE F
    3511.1e, Part III, Remarks.

2.  **Impact of the Person in the Position:** Occasionally positions may
    warrant classification at a higher than usual grade because the
    unique abilities of a particular incumbent have significantly
    enhanced the scope, difficulty, and responsibility of the duties
    assigned by comparison with applicable classification standards.
    This type of classification and the name of the incumbent occupying
    the position are to be recorded on the DOE F 3511.1E, Part III. Post
    audits of all such positions will be done every 2 years, when there
    is reason to believe that duties or responsibilities have diminished
    substantially, to ensure that the original classification and
    position description is still valid. When this type of position is
    vacated, it presumptively reverts to the former classification
    unless a new classification review indicates otherwise.

3.  **Others:** Any other limitations on a position, such as temporary
    or part-time status, are to be recorded in Part III of the DOE F
    3511.1E. This will serve as notice to the HCM staff, supervisor, and
    the employee of the conditions or limitations that have been placed
    on the position.

# Use of Evaluation Statements

1.  Evaluation statements are formal, written determinations describing
    the rationale for the classification of a position by analyzing,
    evaluating, and documenting a position factor-by-factor (i.e., in
    terms of the grade level criteria cited in appropriate position
    classification standards and/or guides). This reduces the
    possibility of an incorrect classification.

2.  Evaluation statements must be prepared in the following instances:

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a.  A classification decision is being formally appealed within BPA or
    to OPM;

b.  A proposed classification requires approval outside of BPA (e.g.,
    certain personnel requiring high-level security clearances);

c.  A classification advisory opinion is being requested, either from
    OPM or any entity outside of BPA with authority to make such a
    request (e.g., Merit system Protection Board, a Court, etc.);

d.  A single classification affects a large block of BPA positions
    (i.e., five or more positions);

e.  The classification decision is one: that a prudent journey-level
    classifier would regard as likely to set a precedent; that would not
    be readily apparent to another classifier; that is borderline as to
    grade, series, or pay plan; of for which there is good reason to
    believe that the decision may be questioned later, and;

f.  Instances in which grade levels are based on "Impact of the Person
    on the Position."

g.  Evaluation statements need not be prepared for positions routinely
    classified using familiar standards on a cross-series comparison
    basis, even when a specific standard does not exist, as long as the
    classification is readily apparent and based on established BPA
    classification practices.

h.  Evaluation statements are maintained in Human Capital Management and
    are available to employees, supervisors, and evaluators.

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D.  []{#__RefHeading___Toc151435289 .anchor}**Content of Evaluation
    Statements:** Since the purpose of an evaluation statement is to
    support the series, title, grade, and occasionally pay plan that the
    HCM Specialist assigns to a position, it is important that
    evaluation statements be written so that they reflect all essential
    information particular to the position evaluated. Evaluation
    statements provide any background necessary for a full understanding
    of the position that is not contained in the position description or
    in other readily available documents; discuss the choice of pay
    plan, series, and title to the extent that they are at issue and not
    self-evident; and analyze the major duties in light of the
    grade-level criteria in the classification standards used, to the
    extent that they are at issue and are not self-evident.

#### CLASSIFICATION PROCESS

A.  []{#__RefHeading___Toc151435291 .anchor}**Review by HCM:**

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1.  Upon receipt of a position description, a servicing HCM Specialist
    makes a determination as to whether the action is routine or
    non-routine. Examples of routine actions include those that are vice
    actions for which there is no apparent classification issue, actions
    to establish new positions that are consistent with established BPA
    patterns, etc. Examples of non-routine actions include those that
    set a precedent (i.e., are not consistent with established BPA
    patterns), actions for which the proper classification is not
    readily apparent, actions that may have implications across BPA
    organizational lines, etc.

2.  If the action is routine, there is no requirement for a substantive
    classification review. If the action is non-routine, a servicing
    Human Capital Management Specialist shall complete a substantive
    classification review. The review shall include consultation with
    the initiating manager if there is any question about the
    sustainability of the classification request

3.  If the results of the review sustain the classification request, the
    action is processed.

4.  If the results of the review do not sustain the classification
    request, the servicing HCM Specialist shall consult with the
    initiating manager and present the findings, including any
    alternatives (e.g., additional duties or responsibilities) that
    would sustain the classification requested. Upon receipt of the
    findings and any alternatives, the manager must choose among the
    following alternatives:

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a.  Accept the classification findings and request that the HCM
    Specialist proceeds with the modified request.

b.  Accept any alternatives identified by the HCM Specialist, make any
    needed changes to the position description, and request that the HCM
    Specialist proceed with the modified request.

c.  Prepare a memorandum stating the business need for the original
    classification requested, and forward the memorandum to the
    organization's Senior Vice-President (or Vice-President if there is
    no Senior Vice-President) for concurrence.

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5.  If a Senior Vice-President (or Vice-President) receives a request
    under paragraph "CLASSIFICATION PROCESS\\Review by HCM\\number 4\\c"
    and does not concur, the memorandum is returned to the initiating
    manager who must choose another option under paragraph
    "CLASSIFICATION PROCESS\\Review by HCM\\number 4". If the request is
    concurred with, it is then forwarded to the BPA CHCO for
    consideration.

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B.  []{#__RefHeading___Toc151435292 .anchor}**Review by the BPA Human
    Capital Management Officer:** Upon receipt of a request under
    paragraph "CLASSIFICATION PROCESS\\Review by HCM\\number 5", the
    CHCO will make a final classification determination. In doing so,
    the CHCO will consult, as needed, with line management and will also
    rely, as needed, on classification advice and assistance either from
    BPA HCM Specialists or contract resources with classification
    expertise. If the determination supports the original classification
    request, such determination must be documented in an evaluation
    statement that complies with the requirements in "POSITION
    CLASSIFICATION REQUIEMENTS\\Content of Evaluation Statements". If
    the determination does not support the original classification
    request, the memorandum is returned to the initiating manager who
    must choose another option under "CLASSIFICATION PROCESS\\Review by
    HCM\\number 4".

C.  []{#__RefHeading___Toc151435293 .anchor}**Requests for Desk
    Audits:** HCM will conduct desk audits when requested by the manager
    of a position. HCM may conduct a desk audit when requested by other
    management officials for valid business reasons (e.g., as part of a
    dispute resolution process). Employees who wish to question the
    accuracy of the classification of their positions may do so by
    initiating a classification appeal under "CLASSIFICATION APPEALS".

#### CLASSIFICATION APPEALS

A.  []{#__RefHeading___Toc151435295 .anchor}**Coverage:**

    1.  Procedures in this Letter apply to any BPA GS/GM employee who
        believes the classification of his or her position is incorrect.

    2.  This Letter establishes the procedures under which a GS/GM
        employee may seek adjustment, within BPA, of the pay plan,
        series, title (if one is prescribed), or grade of a position. A
        request for such adjustment will be accepted from the employee
        officially assigned to the position or his/her representative
        that has been designated in writing.

    3.  All levels of management and supervision are responsible for
        protecting and publicizing an employee's right to seek
        adjustment in the pay plan, series, title, or grade of the
        position, and for ensuring that employees may execute this right
        without restraint and without fear of reprisal or any subsequent
        prejudice.

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B.  []{#__RefHeading___Toc151435296 .anchor}**Exclusions:**

    1.  Complaints about the accuracy of position descriptions (separate
        from classification matters such as pay plan, series, title, or
        grade) are not covered by the classification appeals provisions
        of this Letter. However, any doubt concerning the accuracy of
        the position description must be resolved, by desk audit if
        necessary, before the proper classification can be determined.
        This does not in any way diminish the exclusive responsibility
        of management to decide what duties will be assigned and
        performed.

    2.  The correctness of OPM position classification standards,
        guides, or other published classification guidance, although
        employees may appeal the application of those standards and
        guides to their position.

    3.  The classification of a position based on comparison with other
        positions and not published OPM standards.

    4.  The classification of a position that has been certified by OPM
        as a result of a BPA or employee appeal when there has been no
        change in major duties or the standards and/or guides used to
        classify the position.

    5.  The classification of a position to which an employee is
        detailed or temporarily promoted, unless the employee has been
        temporarily promoted to the position for 2 or more years.

C.  []{#__RefHeading___Toc151435297 .anchor}**Classification Appeal
    Rights:** Employees may appeal the classification of their official
    position at any time. GS/GM employees may appeal within BPA under
    the provisions of this Letter or may elect to appeal directly to
    OPM.

D.  []{#__RefHeading___Toc151435298 .anchor}**Representation and Use of
    Official Time:** Employees have a right to the representative of
    their choice in preparing their classification appeal. The employee
    must designate the representative in writing. If the choice will
    result in a conflict of interest or position, unreasonable costs to
    the Government, or undue interruption of the representative's
    official duties as determined by the supervisor, it may be
    disallowed. Official time is authorized only when it is necessary to
    obtain information not available during non-work hours. Designation
    as a representative does not convey a right to the representative to
    be present during fact-finding sessions, except during a session
    with the employee when requested by the employee. Also, a
    representative may not participate in OPM on-site audits unless
    specifically requested to do so by OPM.

# Reduction in Grade or Pay:

1.  **Notice to Employee Not Entitled to Grade Retention:** When a
    position to be downgraded has not been classified at the current or
    higher grade for at least a year, the incumbent is not eligible for
    grade retention and the demotion is an adverse action. It must be
    affected in accordance with 5 CFR, Part 752, and normal procedures
    for adverse actions, including at least 30-days advance written
    notice. The notice must state why the position is being downgraded;
    what efforts have been made to avoid demoting the employee; and why
    the efforts failed. It should not imply that a final decision has
    been made to demote the employee, though it is proper to state that
    it has been decided to downgrade the position. After the notice
    period, if it is decided that demotion cannot be avoided, the
    employee must be given a written notice of that decision. It must
    explain the employee's right to appeal the adverse action or, if
    applicable, to grieve it under a negotiated grievance procedure. It
    must also explain the employee's right to file a classification
    appeal and the time limits for filing in order to preserve any
    retroactive benefits, and it should explain the employee's
    entitlement to pay retention.

2.  **Notice to Employee Entitled to Grade Retention:** When a
    classification decision will result in a loss of grade and the
    affected employee is entitled to grade retention, the downgrading is
    not an adverse action. However, the employee must be notified in
    writing before the action is taken. The notice should specify why
    the position is being downgraded; what efforts have been made to
    reassign the employee; and why the efforts have failed. It must also
    inform the employee of the right to appeal the classification
    decision and of his or her entitlement to grade retention, as
    required by 5 CFR 536.304, Issuance of Employee Letters.

3.  **Time Limits:** In certain circumstances, employees not entitled to
    grade retention may suffer a loss in pay when they are downgraded.
    Such an employee who wins a timely appeal is entitled to back pay
    retroactive to the date of the downgrading. However, in order to be
    timely, the appeal must be filed no later than 15 calendar days
    after the effective date of the downgrading. Any further appeal from
    a final decision within BPA must be filed with OPM no later than 15
    calendar days after receipt of the BPA appeal decision, or 15
    calendar days after the effective date of the action taken as a
    result of the classification decision, whichever is later. Employees
    must be fully informed of all applicable time limits at the time
    that they are given the decision. In certain cases extensions may be
    granted in consideration of extraordinary circumstances beyond the
    control of the employee. Note, however, that nothing in this
    paragraph diminishes an employee's right to file a classification
    appeal at any time.

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E.  []{#__RefHeading___Toc151435300 .anchor}**Availability of Position
    Standards:** Position classification standards, guides, and related
    material are to be available for review by any BPA employee.
    Employees geographically located away from their servicing office
    will have these materials, as far as capability allows, made
    available to them electronically or through the mail.

F.  []{#__RefHeading___Toc151435301 .anchor}**Classification Appeal
    Procedure:** A classification appeal is **a formal request in
    writing** by the employee for a review of the employee's official
    pay plan, series, title, and/or grade, to correct what the employee
    believes is an incorrect classification. Employees and designated
    representatives may request assistance from an HCM Specialists
    regarding regulatory and procedural concerns.

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1.  **Content of Appeal:** Employees must include the following
    information in an appeal:

    a.  Name, BPA mailing address (with appropriate routing), position
        (or organizational) number, and office telephone number;

    b.  Employing office location and the location of the official
        headquarters;

    c.  Exact location of the employee's position in the organization
        structure of the office to which assigned;

    d.  Present series, title, and grade of the position;

    e.  Requested series, title, and grade or other classification
        action;

    f.  A copy of the official position description and, if appropriate,
        a statement that the employee considers the official position
        description to be complete and accurate (whenever possible the
        employee and the supervisor should agree on the description
        before an appeal is filed);

    g.  Reasons for the appeal; and

    h.  Statement of any facts that the employee believes may affect or
        have bearing on the appeal.

2.  **Office to Which Appeals Should be Addressed:**

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a.  Although employees may appeal the classification of GS/GM positions
    directly to OPM, both OPM and BPA prefer that appeals be filed first
    with BPA. This helps to establish a sound factual basis for a fair
    and accurate evaluation, and it provides an opportunity for
    resolution of the problem within BPA.

• Employees electing to appeal within BPA should first request that HCM
reconsider the classification. The request is sent to the CHCO and must
include the information specified in "CLASSIFICATION
APPEALS\\Classification Appeal Procedure\\Content Appeal\". The
classification shall be reviewed by a different HCM Specialist from the
one who made the original decision.

• If the employee is dissatisfied with the result of this review, he or
she may appeal the classification to the CHCO, providing a copy of the
information submitted in the request for review. The CHCO will assure an
HCM Specialist specified by the CHCO promptly considers the appeal
within BPA, or the CHCO may elect to refer the appeal to the appropriate
OPM office within 30 calendar days of its receipt. When BPA elects to
refer an appeal to OPM that was filed by the appellant to be adjudicated
within BPA, the appellant must be notified in writing and must concur in
this determination. If the employee does not want the appeal forwarded
to OPM, BPA will cancel the appeal.

• If the employee is not satisfied with the decision of the CHCO, the
appeal may then be filed with the appropriate office of OPM. (Mail or
telephone contact information is available on request from HCM
Classification and Compensation.)

• Employees electing to appeal directly to OPM are urged, although they
are not required, to file their appeal through HCM. Such appeals should
be addressed to the appropriate OPM office, but transmitted through HCM.
It is mandatory for BPA to forward such appeals to the appropriate OPM
office within 60 calendar days of their receipt from the employee. Upon
request, all information submitted by BPA concerning an employee's
appeal will be made available to the employee.

b.  [Effect of Appeal on Pending Classification Actions]{.underline}:
    Filing an appeal with either BPA or OPM does not automatically stop
    a classification action. Such actions may be taken either by BPA at
    its own volition or under order from OPM.

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G.  []{#__RefHeading___Toc151435302 .anchor}**Requests for
    Reconsideration:** OPM may, at its discretion, reopen and reconsider
    an OPM classification appeal decision when either BPA or the
    affected employee presents written information that establishes a
    reasonable doubt as to the technical accuracy of the decision.
    Requests for reconsideration must be submitted, within 45 days after
    the decision is issued, to the Director, OPM Washington, DC
    Oversight Division, 1900 E Street, NW, Room 7675, Washington, DC
    20415-0001.

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IV. **POSITION CLASSIFICATION
    ACCOUNTABILITY**[]{#__RefHeading___Toc151435303 .anchor}

> BPA staff who have been delegated classification authority are
> responsible for the proper exercise of that authority. Positions must
> be classified in accordance with published OPM standards and guides,
> and established classification policies and principles. Positions must
> be classified by individuals who have had proper training and
> experience.

V.  **EFFECTING CLASSIFICATION ACTIONS**[]{#__RefHeading___Toc151435304
    .anchor}

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A.  All identified classification errors must be corrected by the
    beginning of the fourth pay period form the date the error is
    determined.

B.  New classification standards must be implemented within 12 months
    from the date of receipt.

C.  Vacant positions identified for downgrading or upgrading because of
    classification error, receipt of new standards, or action taken by
    authority outside of BPA may not be refilled prior to correcting the
    classification error.

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VIII. **REFERENCES**[]{#__RefHeading___Toc151435305 .anchor}

• 5 U.S.C., Chapter 51, Classification

• 5 U.S.C., Chapter 53, Pay Rates and Systems

• 5 U.S.C., Chapter 75, Adverse Actions

• 16 U.S.C. 832, Bonneville Project Act of 1937 (as amended)

• Public Law 92-392, Section 9b (August 18, 1972)

• 5 CFR, Part 210, Basic Concepts and Definitions (general)

• 5 CFR, Part 511, Classification under the General Schedule

• 5 CFR, Part 536, Grade and Pay Retention

• 5 CFR, Part 752, Adverse Actions

• "Introduction to the Position Classification Standards," Office of
Personnel Management (OPM), Workforce Compensation and Performance
Service, Office of Classification Programs, December 1997, HRCD-4

• "The Classifiers Handbook," OPM, Workforce Compensation and
Performance Service, Office of Classification Programs, December 1997,
HRCD-4

• General Schedule Classification Standards for specific Guides and
Series descriptions, OPM, Workforce Compensation and Performance
Service, Office of Classification Programs, various publication dates,
HRCD-4

• BPAM Chapter 21: Internal Delegations of Authority

• BPAM Chapter 400/300A, Employment

• BPAM Chapter 400/500A, Compensation, Position, and Organizational
Management

• BPAM Chapter 400/700A, Employee Relations Program

• Personnel Letter 351-1, Reduction in Force

• Personnel Letter 511-2, Accretion of Duties for Annual Employees

###  • Personnel Letter 536-2, Grade and Pay Retention {#personnel-letter-536-2-grade-and-pay-retention .unnumbered}

• Personnel Letter 752-1, Discipline, Adverse Actions, and Alternative
Discipline

Kimberly A. Leathley

Manager, Human Capital Management

Attachments(2)

Appendix A -- Generic Position Descriptions for BPA Annual Positions

Appendix B -- Required Statements for Position Descriptions

#####  {#section .unnumbered}

##### GENERIC FACTOR-LEVEL DESCRIPTIONS IN POSITION  {#generic-factor-level-descriptions-in-position .unnumbered}

##### DESCRIPTIONS FOR BPA ANNUAL POSITIONS {#descriptions-for-bpa-annual-positions .unnumbered}

To streamline procedures, BPA has adopted an approach to preparing
position descriptions that simplifies and expedites the process. Under
this process, the content of the factor-level descriptions in position
descriptions has been standardized to conform to prescribed patterns
within broad occupational groupings. The generic material describes the
common characteristics associated with work of a particular grade level.
Individually prepared statements of the position's tasks/duties and
functional responsibilities, sufficient to describe its unique
characteristics, will supplement the generic factor-level descriptions.
Managers are responsible for preparing these unique descriptions and
combining them with the other required generic statements.

Use of the standard language contained in generic factor-level
descriptions is mandatory. If necessary, in rare or unusual situations,
the Manager, HCM may approve an exception. Please contact the
appropriate servicing HCM Specialist for additional information. This
appendix provides an overview of the appropriate roles and
responsibilities in the application of the generic description models.

#  {#section-1 .unnumbered}

# PURPOSE {#purpose .unnumbered}

-   To simplify a manger's responsibilities in preparing individual
    position descriptions.

-   To only require unique written descriptions of those portions of a
    job that are meaningful for purposes of specifying employee
    responsibilities, identifying qualification requirements relative to
    the knowledge, skills, abilities, and describing the position's role
    in accomplishing the output of the work unit.

-   To provide guidance, instruction, and designated authorities and
    responsibilities for developing accurate position descriptions, and
    using generic factor-level descriptions in accordance with
    regulatory requirements.

-   To expedite administrative processes associated with determining the
    final classification of a position.

-   To update procedures for appropriate position documentation and
    records maintenance.

## SUMMARY {#summary .unnumbered}

-   The intent of the generic factor-level description policy is to
    streamline administrative processes. The position description is the
    official record of the duties and responsibilities assigned to a
    position, or group of positions, by the manager/supervisor.

-   The position description is a tool that facilitates communication
    and understanding between the manager and the employee. It is
    important to discuss descriptions and expectations so that employees
    and managers have a common understanding of work expectations.

-   Specific questions regarding BPA factor-level descriptions should be
    directed to a HCM Specialist.

I.  **RESPONSIBILITIES**

> The following officials share responsibilities in the preparation,
> classification, and implementation of position descriptions:

A.  **Organization Managers:** Assign duties and responsibilities to
    subordinate positions; clearly communicate to each employee their
    assigned duties and responsibilities; and formally describe these
    duties and responsibilities in writing for each position.

B.  **HCM Specialists:** Those with delegated authority classify
    positions in accordance with OPM and BPA requirements review and
    analyze official position descriptions and any other material
    necessary to arrive at a final classification decision.

C.  **Chief Human Capital Officer (CHCO):** Manages BPA's classification
    and compensation programs and formally delegates personnel
    management authority to designated staff.

II. **DEVELOPING POSITION DESCRIPTIONS**

> Managers and staffs work together in completing position descriptions.
> The position description is an essential tool in identifying the
> duties and responsibilities of individual positions. Generic
> factor-level descriptions are based on established OPM guidelines.

#  Human Capital Management Classification and Compensation:

1.  HCM Classification and Compensation staff develops generic factor
    level descriptions for each factor based on pertinent OPM
    classification standards/guidance that describe work at particular
    grade levels. HCM Specialists with delegated authority provide
    guidance and support to managers, and determine final
    classifications in accordance with their individual delegated
    authority.

2.  Specific questions regarding classification concerns should be
    referred directly to the assigned HCM Specialists with delegated
    authority. The initiation of a new position, or description of a
    position outside the scope of the generic descriptions, must be
    reviewed carefully and concurrently by the manager and the servicing
    HCM Specialists.

3.  Generic factor-level descriptions have been developed for the
    following occupational groups:

**• Managers/Supervisors:** This group represents positions that are
officially assigned management direction and oversight responsibility of
employees. (One- or two-grade interval positions)

**• Professional:** Occupations with a positive education requirement,
such as engineer, biologist, environmental scientist. (Two-grade
interval positions)

**• Administrative/Technical Specialist/Analytical:** Positions
providing analytical and/or evaluative support to agency management,
projects, or programs. These positions include, for example, Public
Utilities Specialist, Management Analyst, Administrative Specialist,
Program Manager, Computer Specialist, etc. (Two-grade interval
positions)

**• Engineering and Scientific Technician:** This group represents
positions providing technical expertise in support of professional
engineering and scientific work. (One-grade interval positions)

**• Administrative Assistant/Clerical:** This group represents positions
providing technical assistance in support of Administrative/Technical
Specialist/Analytical positions. (One-grade interval positions)

**• Management Support:** This group includes all Secretarial, Personal
Assistant, Office Manager, and Executive Assistant positions. (One-grade
interval positions)

**• Student Trainees:** (One- or two-grade interval positions.)

#  Organization Managers:

1.  Managers review and apply the appropriate generic factor-level
    descriptions. The factors represented within the description are not
    to be changed. Any concerns regarding the content need to be
    reviewed with the assigned Human Capital Management Specialist with
    delegated authority.

2.  Managers are directly responsible for: (a) The written
    *Introduction* to the generic position description; and (b) an
    accurate *description of the Major duties and Responsibilities* of
    the position. These two elements are mandatory and must be added by
    the managers. Specifically, managers provide:

    a.  **Introduction:** This information must include a brief
        description of the organization's function and the relationship
        of the position to the organization. Managers may add other
        pertinent information. (One or two paragraphs should suffice.)

    b.  **Duties and Responsibilities:** Managers describe the duties
        and responsibilities associated with the position. Duties and
        responsibilities that significantly affect the work unit's
        objectives must be included. Related duties and responsibilities
        should be grouped together and listed in a logical order, such
        as the sequence in which they are performed, order of
        importance, or other pattern, which facilitates description,
        understanding and evaluation of the position.

####  {#section-2 .unnumbered}

#### FORMS

-   DOE F 3511.1e, U.S. Department of Energy, *Position Description
    Cover Sheet,* will remain in use.

#####  {#section-3 .unnumbered}

##### REQUIRED STATEMENTS FOR POSITION DESCRIPTIONS {#required-statements-for-position-descriptions .unnumbered}

Position descriptions must describe the major duties and
responsibilities assigned by management to employees. This includes a
description of supervisory responsibilities for managers/supervisors and
Contracting Officer's Technical Representative (COTR) responsibilities,
if they represent a significant position responsibility. In addition, as
specified below, BPA has determined that certain other statements are
mandatory.

I.  **POSITION DESCRIPTIONS OF COMPUTER AND INFORMATION TECHNOLOGY
    POSITIONS**

> The position descriptions of all positions classified in computer and
> information technology series (both one-grade interval and two-grade
> interval) throughout BPA must state that incumbents have a working
> knowledge of computer security procedures. Positions that are non
> critical-sensitive (level 2) or above, because of the type and level
> of computer access, must also contain a statement that the incumbent
> has a working knowledge of computer security procedures. Each position
> description must state:

• "The incumbent is required to have a working knowledge of BPA's data
processing security procedures. The incumbent must be familiar with and
comply with those parts of the procedures which apply to the assigned
tasks."

> HCM Classification and Compensation staff shall assure that the
> position descriptions for all positions in computer and information
> technology series, or those determined to be non critical-sensitive or
> above in position sensitivity, contain this or a similar statement.
> The specific location of this statement in the position description is
> not mandated; however, it is suggested that it be added to the generic
> statement included under Factor 1, Knowledge Required by the Position.

II. **POSITION DESCRIPTIONS OF MANAGERS AND SUPERVISORS**

> Standardized Equal Employment Opportunity (EEO) duty statements for
> managers and supervisors are to be listed along with other official
> duties in the body of position descriptions for annual managers and
> supervisors, and in job standards for hourly supervisors. The
> standardized EEO duty statements are:

A.  **For Managers:** "As a manager, the incumbent provides
    understanding, support, and leadership in administering BPA's EEO
    program for all applicants and employees. To the full extent of
    his/her authority and responsibility, the incumbent provides and
    ensures fair and equitable treatment for all employees in personnel
    policies and practices including recruitment, selection, placement,
    counseling, training, career development, promotion, and adverse
    actions."

B.  **For Supervisors:** "As a supervisor, the incumbent is actively
    involved in achieving BPA's EEO program commitments for all
    applicants and employees. To the full extent of his/her supervisory
    authority and responsibility, the incumbent must act in a fair and
    equitable manner towards all employees in personnel policies and
    practices including recruitment, selection, placement, counseling,
    training, career development, promotion, and adverse action."

> The statement is applicable to any position/job officially designated
> as supervisory, whether or not the position/job meets position
> classification criteria for titling as supervisory. The phrase "to the
> full extent of his/her supervisory authority and responsibility" takes
> into account those situations where only limited supervisory authority
> and responsibilities are assigned.

####### CONTRACTING OFFICER'S TECHNICAL REPRESENTATIVE

> When responsibility as a COTR represents a significant portion of the
> overall duties and responsibilities, the following standardized
> statement shall be listed along with other duties in the body of the
> position description.

"When delegated authority by a contracting officer (CO), monitors
performance and compliance with the contract to ensure that BPA receives
goods or services that conform to the technical requirements as set
forth in the contract. Such duties include, but are not limited to:
reviewing and evaluating technical progress, financial reports and other
documents; performing production surveillance and status reporting,
timely reporting of inadequacies noted in specifications or performance;
monitoring the use of government property; assuring that modifications
to work to be performed under the contract are not implemented before a
written modification is issued by the CO; informing the CO of situations
that could become a basis for future claims; interpreting technical
specifications; approval of contractor's reports and other materials;
preparation of receiving reports; review and certification of invoices;
and rejection of non conforming services, materials, or equipment."

III. **FOR MANAGERS AND SUPERVISORS WHO'S POSITIONS ARE RESPONSIBLE FOR
     TECHNOLOGY INNOVATION**

> Standardized Technology Innovation duty statements for managers and
> supervisors are to be listed along with other official duties in the
> body of position descriptions. The standardized duty statements are:

A.  **For Managers:** "As a manager, the incumbent provides support and
    leadership in advancing BPA's Technology Innovation program. To the
    full extent of his/her authority and responsibility, the incumbent
    provides and ensures employees assigned technology innovation
    responsibilities have the resources required to fulfill their
    obligations, including strategic direction, and supervisory,
    financial, and administrative support.

B.  **For Supervisors:** "As a supervisor, the incumbent is actively
    involved in achieving BPA's technology innovation commitments. To
    the full extent of his/her supervisory authority and responsibility,
    the incumbent must ensure that employees assigned technology
    innovation responsibilities are able to carry out their duties
    including face-to-face meetings, that projects are meet BPA's
    technology innovation strategy; and that projects include
    appropriate teams, management sponsorship, and controls.

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IV. **FEDERAL ENERGY REGULATORY COMMISSION (FERC) STANDARDS OF CONDUCT
    (SOC) FUNCTIONAL CLASSIFICATION STATEMENTS**

> The position descriptions of all positions throughout BPA must state
> the Standards of Conduct (SOC) functional classification in order to
> ensure that BPA adheres to the SOC rules prescribed by the Federal
> Energy Regulatory Commission (FERC). BPA's goal is to provide open
> access non-discriminatory transmission service and maintain a robust
> wholesale power market. Each position description must include the
> appropriate SOC functional classification for employees in one of the
> three categories: Transmission Function, Power Merchant Function, or
> Shared Function.

A.  **Transmission Function Employee:**

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all transmission
        customers.

    2.  The incumbent of this position is identified by BPA as a
        Transmission Function employee. Transmission Function employees
        conduct transmission system operations and reliability
        functions, including, but not limited to, engaging in day-to-day
        duties and responsibilities for planning, directing, organizing,
        or carrying out transmission-related operations. Under the FERC
        SOC independent functioning principle, the employee may not
        engage in affiliated power merchant functions which include, but
        are not limited to: making wholesale power merchant decisions
        and/or business rules; developing power merchant policy;
        directing, organizing, or executing power merchant activities.

    3.  Further, the FERC SOC non-discrimination rules limit information
        access and prohibit disclosures of certain transmission
        information to Power Merchant Function employees. Specifically,
        the incumbent may not provide access to, or disclose to
        affiliated Power Merchant Function employees any non-public
        information about (1) BPA's transmission system, (2)
        transmission system information of another or (3) transmission
        information about BPA's transmission customers.

    4.  The incumbent is required to immediately report violations of
        the FERC SOC to the Chief Compliance Officer and/or its
        Supervisor or Manager. In addition, the incumbent is required to
        complete BPA's mandatory SOC web based training.

B.  **Transmission Services Supervisor and Manager Duties:**

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all customers.

    2.  The incumbent of this position is identified by BPA as a
        Transmission Function employee. Transmission Function employees
        conduct transmission system operations and reliability
        functions, including, but not limited to, engaging in day-to-day
        duties and responsibilities for planning, directing, organizing,
        or carrying out transmission-related operations. Under the FERC
        SOC independent functioning principle, the employee may not
        engage in affiliated power merchant functions which include, but
        are not limited to: making wholesale power merchant decisions
        and/or business rules; developing power merchant policy;
        directing, organizing, or executing power merchant activities.

    3.  Further, the FERC SOC non-discrimination rules limit information
        access and prohibit disclosures of certain transmission-related
        information to Power Merchant Function employees. Specifically,
        the incumbent may not provide access to, or disclose to
        affiliated Power Merchant Function employees any non-public
        information about (1) BPA's transmission system, (2)
        transmission system information of another or (3) information
        about BPA's transmission customers.

    4.  As a supervisor or manager, the incumbent is required to
        immediately report violations of the FERC SOC to the Chief
        Compliance Officer. In addition, the supervisor or manager is
        required to ensure that employees complete BPA's mandatory SOC
        training.

C.  **Power Merchant Function Employee**:

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all customers.

    2.  The incumbent of this position is identified by BPA as a Power
        Merchant Function employee. Power Merchant Function employees
        are engaged in wholesale power sales, including, but not limited
        to, engaging in day-to-day duties and responsibilities for
        planning, directing, organizing, or carrying out power merchant
        functions. Under the FERC SOC independent functioning principle,
        the employee may not engage in transmission system or
        reliability functions which include, but are not limited to,
        those that are engaged in day-to-day duties and responsibilities
        for planning, directing, organizing or carrying out transmission
        related operations.

    3.  Further, the incumbent is prohibited by the FERC SOC
        non-discrimination rules from obtaining any non-public
        information about (1) BPA's transmission system, (2)
        transmission system information of another or (3) transmission
        information about BPA's transmission customers.

    4.  The incumbent is required to immediately report violations of
        the FERC SOC to the Chief Compliance Officer. In addition, the
        incumbent is required to ensure that employees complete BPA's
        mandatory SOC training.

D.  **Power Merchant Function Supervisors and Managers:**

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all customers.

    2.  The incumbent of this position is identified by BPA as a Power
        Merchant Function employee. Power Merchant Function employees
        are engaged in wholesale power sales, including, but not limited
        to, engaging in day-to-day duties and responsibilities for
        planning, directing, organizing, or carrying out power merchant
        functions. Under the FERC SOC independent functioning principle,
        the employee may not engage in transmission system or
        reliability functions which include, but are not limited to,
        those that are engaged in day-to-day duties and responsibilities
        for planning, directing, organizing or carrying out transmission
        related operations.

    3.  Further, the incumbent is prohibited by the FERC SOC
        non-discrimination rules from obtaining any non-public
        information about (1) BPA's transmission system, (2)
        transmission system information of another or (3) transmission
        information about BPA's transmission customers.

    4.  As a supervisor or manager, the incumbent is required to
        immediately report violations of the FERC SOC to the Chief
        Compliance Officer. In addition, the supervisor or manager is
        required to ensure that employees complete BPA's mandatory SOC
        training.

E.  **Shared Function Employee:**

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all customers.
        Shared Function employees may support but may not engage in
        either Transmission Functions or Power Merchant Functions.
        Shared Function employees may not act as a conduit for sharing
        restricted transmission-related information with the Power
        Merchant Function.

    2.  The incumbent of this position is identified by BPA as a Shared
        Function employee. Shared Function employees may not conduct
        transmission system operations and reliability functions,
        including, but not limited to, engaging in day-to-day duties and
        responsibilities for planning, directing, organizing, or
        carrying out transmission-related operations. In addition,
        Shared Function employees may not engage in wholesale power
        sales functions, including, but not limited to, engaging in
        day-to-day duties and responsibilities for planning, directing,
        organizing, or carrying out power merchant activities. Under the
        FERC SOC independent functioning principle, the Shared Function
        employee may provide support functions for either or both the
        Transmission Function and Power Merchant Function.

    3.  Further, the FERC SOC non-discrimination rules require Shared
        Function employees from acting as a conduit for providing access
        to, or disclosing certain information to Power Merchant Function
        employees. Specifically, the incumbent may not provide access to
        or disclose to affiliated Power Merchant Function employees any
        non-public information about (1) BPA's transmission system, (2)
        transmission system information of another or (3) transmission
        information about BPA's transmission customers.

    4.  The incumbent is required to immediately report violations of
        the FERC SOC to the Chief Compliance Officer and/or its
        Supervisor or Manager. In addition, the incumbent is required to
        complete BPA's mandatory SOC web based training

F.  **Shared Function Manager:**

    1.  The incumbent is required to have a working knowledge of the
        Federal Energy Regulatory Commission (FERC) Standards of Conduct
        (SOC) to ensure fair competition in the open access transmission
        market though compliance with its basic principles. The FERC SOC
        basic principles require BPA's Transmission Function employees
        and its affiliated Power Merchant Function employees to function
        independently and abide by non-discriminatory information access
        and prohibited disclosure regulations for transmission-related
        information that is not equally available to all customers.
        Shared Function employees may support but may not engage in
        either Transmission Functions or Power Merchant Functions.
        Shared Function employees may not act as a conduit for sharing
        restricted information with the Power Merchant Function.

    2.  The incumbent of this position is identified by BPA as a Shared
        Function employee. Shared Function employees may not conduct
        transmission system operations and reliability functions,
        including, but not limited to, engaging in day-to-day duties and
        responsibilities for planning, directing, organizing, or
        carrying out transmission-related operations. In addition,
        Shared Function employees may not engage in wholesale power
        sales functions, including, but not limited to, engaging in
        day-to-day duties and responsibilities for planning, directing,
        organizing, or carrying out power merchant activities. Under the
        FERC SOC independent functioning principle, the Shared Function
        employee may provide support functions for either or both the
        Transmission Function and Power Merchant Function.

    3.  Further, the FERC SOC non-discrimination rules require Shared
        Function employees from acting as a conduit for providing
        access, to or disclosing certain transmission-related
        information to Power Merchant Function employees. Specifically,
        the incumbent may not provide access to, or disclose to
        affiliated Power Merchant Function employees any non-public
        information about (1) BPA's transmission system, (2)
        transmission system information of another, or (3) transmission
        information about BPA's transmission customers.

    4.  As a supervisor or manager, the incumbent is required to
        immediately report violations of the FERC SOC to the Chief
        Compliance Officer. In addition, the supervisor or manager is
        required to ensure that employees complete BPA's mandatory SOC
        training.