133 FERC ¶ 61,159 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Part 40 

[Docket No. RM09-25-000; Order No. 742] 

System Personnel Training Reliability Standards 

(Issued November 18, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Final Rule 

SUMMARY: Under section 215 of the Federal Power Act, the Commission approves 

two Personnel Performance, Training and Qualifications (PER) Reliability Standards, 

PER-004-2 (Reliability Coordination – Staffing) and PER-005-1 (System Personnel 

Training), submitted to the Commission for approval by the North American Electric 

Reliability Corporation, the Electric Reliability Organization certified by the 

Commission. The approved Reliability Standards require reliability coordinators, 

balancing authorities, and transmission operators to establish a training program for their 

system operators, verify each of their system operators’ capability to perform tasks, and 

provide emergency operations training to every system operator. The Commission also 

approves NERC’s proposal to retire two existing PER Reliability Standards that are 

replaced by the standards approved in this Final Rule. 

EFFECTIVE DATE: This rule will become effective [Insert_Date that is 60 days after 

publication in the FEDERAL REGISTER]. 
Docket No. RM09-25-000 - 2 - 

FOR FURTHER INFORMATION CONTACT: 

Karin L. Larson (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8236 

Kenneth U. Hubona (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

1800 Dual Highway, Suite 201 

Hagerstown, MD 21740 

(301) 665-1608 

SUPPLEMENTARY INFORMATION:
 

133 FERC ¶ 61,159 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Before Commissioners: Jon Wellinghoff, Chairman; 

 Marc Spitzer, Philip D. Moeller, 

 John R. Norris, and Cheryl A. LaFleur. 

System Personnel Training Reliability Standards Docket No. RM09-25-000 

ORDER NO. 742 

FINAL RULE 

(Issued November 18, 2010) 

1. Under section 215 of the Federal Power Act (FPA),1

 the Commission approves 

two Personnel Performance, Training and Qualifications (PER) Reliability Standards, 

PER-004-2 (Reliability Coordination – Staffing) and PER-005-1 (System Personnel 

Training), submitted to the Commission for approval by the North American Electric 

Reliability Corporation (NERC), the Electric Reliability Organization (ERO) certified by 

the Commission. The approved Reliability Standards require reliability coordinators, 

balancing authorities, and transmission operators to establish a training program for their 

system operators, verify each of their system operators’ capability to perform tasks, and 

provide emergency operations training to every system operator. The Commission also 

1

 16 U.S.C. 824o. 
Docket No. RM09-25-000 - 2 - 

approves NERC’s proposal to retire two existing PER Reliability Standards that are 

replaced by the standards approved in this Final Rule. 

I. Background

2. On March 16, 2007, the Commission issued Order No. 693, approving 83 of the 

107 Reliability Standards filed by NERC,2

 including the four PER Reliability Standards: 

PER-001-0, PER-002-0, PER-003-0, and PER-004-1.3

 In addition, in Order No. 693, 

under section 215(d)(5) of the FPA, the Commission directed NERC to develop 

modifications to the PER Reliability Standards to address certain issues identified by the 

Commission. At issue in the immediate proceeding are two new PER Reliability 

Standards that would replace the currently effective Reliability Standards PER-002-0 

(Operating Personnel Training) and PER-004-1 (Reliability Coordination – Staffing). 

Currently Effective Reliability Standard PER-002-0

3. Currently effective Reliability Standard PER-002-0 requires each transmission 

operator and balancing authority to be staffed with adequately trained operating 

personnel.4

 Specifically, PER-002-0: (1) directs each transmission operator and 

balancing authority to have a training program for all operating personnel who occupy 

 2 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). 

3

 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1330-1417. 

4 Id. P 1331. 
Docket No. RM09-25-000 - 3 - 

 

positions that either have primary responsibility, directly or through communication with 

others, for the real-time operation of the Bulk-Power System or who are directly 

responsible for complying with the NERC Reliability Standards; (2) lists criteria that 

must be met by the training program; and (3) requires that operating personnel receive at 

least five days of training in emergency operations each year using realistic simulations.5

4. In Order No. 693, the Commission directed NERC, pursuant to section 215(d)(5) 

of the FPA, to develop the following modifications to PER-002-0: (1) identify the 

expectations of the training for each job function; (2) develop training programs tailored 

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

(3) expand the applicability of the training requirements to include: reliability 

coordinators, local transmission control center operator personnel, generator operators 

centrally-located at a generation control center with a direct impact on the reliable 

operation of the Bulk-Power System, and operations planning and operations support 

staff who carry out outage planning and assessments and those who develop system 

operating limits (SOL), interconnection reliability operating limits (IROL), or operating 

nomograms for real-time operations; (4) use a systematic approach to training 

methodology for developing new training programs; and (5) include the use of simulators 

5

 Reliability Standard PER-002-0. 
Docket No. RM09-25-000 - 4 - 

by reliability coordinators, transmission operators, and balancing authorities that have 

operational control over a significant portion of load and generation.6

 

5. In Order No. 693, 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.7

 

Currently Effective Reliability Standard PER-004-1

6. In Order No. 693, the Commission also approved Reliability Standard PER-004-

1.8

 This Reliability Standard requires each reliability coordinator to be staffed with 

adequately trained, NERC-certified operators, 24 hours a day, seven days a week. 

Further, PER-004-1 requires reliability coordinator operating personnel to have a 

comprehensive understanding of the area of the Bulk-Power System for which they are 

responsible. 

 6

 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1393. 

7 Id. P 1394. 

8 Id. P 1417. 
Docket No. RM09-25-000 - 5 - 

 NERC Petition

7. In a September 30, 2009 filing (NERC Petition),9

 NERC requests Commission 

approval of proposed Reliability Standards PER-005-1 (System Personnel Training) and 

PER-004-2 (Reliability Coordination – Staffing), which were developed in response to 

the Commission’s directives in Order No. 693 regarding currently effective Reliability 

Standard PER-002-0.10 NERC seeks to concurrently retire currently effective Reliability 

Standards PER-002-0 and PER-004-1 upon the effective date of the two new Reliability 

Standards. 

8. NERC states that the proposed Reliability Standards “are a significant 

improvement over the existing Reliability Standards” and recommends Commission 

approval of the standards as a “significant step in strengthening the quality of operator 

training programs as necessary for the reliability of the [B]ulk-[P]ower [S]ystem.”11 

 9 North American Electric Reliability Corp., Sept. 30, 2009 Petition for Approval 

of Proposed Reliability Standards Regarding System Personnel Training (NERC 

Petition). The two PER Reliability Standards are included as Exhibit A to NERC’s 

Petition. In addition, pursuant to section 40.3 of the Commission’s regulations, all 

Commission-approved Reliability Standards are available on NERC’s website at 

http://www.nerc.com/page.php?cid=2|20. See 18 CFR. 40.3. 

10 NERC’s Petition addresses only the directives in Order No. 693 related to 

existing Reliability Standard PER-002-0, not the directives related to PER-004-1. See

NERC Petition at 27. 

11 NERC Petition at 5. 
Docket No. RM09-25-000 - 6 - 

Reliability Standard PER-005-1

9. The stated purpose of Reliability Standard PER-005-1 is to ensure system 

operators performing real-time, reliability-related tasks on the North American bulk 

electric system are competent to perform those reliability-related tasks.12 Reliability 

Standard PER-005-1 applies to reliability coordinators, balancing authorities, and 

transmission operators.13 Reliability Standard PER-005-1 contains three main 

requirements: 

 Requirement R1 mandates the use of a systematic approach to 

training for both new and existing training programs. The 

requirement further requires applicable entities to create a 

company-specific, reliability-related task list relevant to BulkPower System operation and to design and develop learning 

objectives and training materials based on the task list 

performed by its System Operators each calendar year. 

Finally, the requirement mandates the training be delivered 

and the training program be evaluated on at least an annual 

basis to assess its effectiveness. 

 Requirement R2 requires the verification of a System 

Operator’s ability to perform the tasks identified in 

Requirement R1. The requirement also mandates reverification of a System Operator’s ability to perform the 

tasks within a specified time period when program content is 

modified. 

 12 Reliability Standard PER-005-1, Section A.3 (Purpose). 

13 The responsible entities subject to PER-005-1 include: reliability coordinators, 

balancing authorities and transmission operators as those entities are defined in the 

Glossary of Terms Used in NERC Reliability Standards, April 20, 2010, available at

http://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf.
Docket No. RM09-25-000 - 7 - 

 Requirement R3 identifies the number of hours of emergency 

operations training (at least 32 hours) that a System Operator 

is required to obtain every twelve months. The requirement 

further identifies those entities required to use simulation 

technology such as a simulator, virtual technology, or other 

technology in their emergency operations training programs.14

Proposed Reliability Standard PER-005-1 is a new Reliability Standard that is intended to 

supersede all of currently effective Reliability Standard PER-002-0 as well as 

Requirements R2, R3, and R4 of currently effective Reliability Standard PER-004-1. 

Proposed Reliability Standard PER-004-2

10. Proposed Reliability Standard PER-004-2 modifies PER-004-1 by deleting 

Requirements R2, R3, and R4, as these three Requirements are incorporated into 

proposed PER-005-1. Proposed Reliability Standard PER-004-2 simply carries forward, 

unchanged, the remaining provisions from currently effective PER-004-1, including the 

associated violation risk factor and violation severity level assignments. 

 Notice of Proposed Rulemaking 

11. On June 17, 2010, the Commission issued its Notice of Proposed Rulemaking 

(NOPR) proposing to approve the two proposed PER Reliability Standards, PER-004-2 

 14 NERC Petition at 8-9. 
Docket No. RM09-25-000 - 8 - 

 

and PER-005-1 (and to retire the two superseded standards, PER-002-0 and PER-004-

1).15 With respect to Reliability Standard PER-005-1, the NOPR proposed to direct 

NERC to: (1) modify PER-005-1 to explicitly require training for local transmission 

control center personnel, and (2) to evaluate the feasibility of developing meaningful 

performance metrics to evaluate the effectiveness of PER-005-1. In addition, in the 

NOPR, the Commission sought clarification from NERC and/or industry comments on 

several specific aspects of proposed Reliability Standard PER-005-1, including: 

(1) whether three specific training requirements are carried over from PER-004-1 to 

PER-005-1 and are enforceable as part of the systematic approach to training umbrella; 

(2) whether PER-005-1, R1.2, through the systematic approach to training, adequately 

requires entities to develop training programs tailored to each job function with 

consideration of the individual training needs of the personnel; (3) whether PER-005-1, 

R3.1 requires the use of simulators specific to an operator’s own system and if not, 

whether it is feasible or practical to mandate the use of simulators that are specific to the 

operator’s system; (4) whether the proposed two- and three-year lead time prior to certain 

Requirements in PER-005-1 become effective are necessary and the feasibility of 

staggering the retirement of currently effective Reliability Standards PER-002-0 and 

15 System Personnel Training Reliability Standards, 75 FR 35689 (June 17, 2010), 

FERC Stats. & Regs. ¶ 32,661 (2010) (NOPR). 
Docket No. RM09-25-000 - 9 - 

PER-004-1; and (5) whether it is feasible for NERC to complete the standards 

development project to expand applicability of PER-005 to include certain generator 

operators and operations planning and operations support staff by fourth quarter 2011. 

The Commission also proposed to approve NERC’s proposed retirement of currently 

effective Reliability Standards, PER-002-0 and PER-004-1, which will be superseded by 

the two new standards. 

12. In response to the NOPR, comments were filed by 28 interested parties. These 

comments assisted us in the evaluation of NERC’s proposal. In the discussion below, we 

address the issues raised by these comments. Appendix A to this Final Rule lists the 

entities that filed comments on the NOPR. 

II. Discussion

A. Approval of PER-004-2 and PER-005-1

13. In the NOPR, the Commission proposed to approve the two PER Reliability 

Standards filed by NERC in this proceeding as just, reasonable, not unduly 

discriminatory or preferential, and in the public interest. The Commission stated that 

proposed Reliability Standards PER-005-1 and PER-004-2 represent an improvement in 

training requirements. 
Docket No. RM09-25-000 - 10 - 

Comments

14. Many commenters support approving the two proposed Reliability Standards 

PER-004-2 and PER-005-1.16 NERC reiterates in its comments that implementation of 

Reliability Standards PER-005-1 and PER-004-2 will achieve a significant improvement 

in the reliability of the Bulk-Power System and, therefore, it is supportive of the 

Commission’s proposal to approve the two standards. APPA states that the proposed 

PER standards strike the right balance among costs, flexibility and performance, and that 

PER-005-1 and PER-004-2 should be approved without modification. Dominion notes 

that the implementation of the more stringent requirements of PER-005-1, including the 

adoption of a systematic approach to training for new and existing system operator 

training programs, recognizes the criticality of such training and contains a logical and 

reasonable approach to providing the appropriate personnel with the necessary training. 

15. EEI states that if the Reliability Standards are approved, compliance with both 

PER-004-2 and PER-005-1 will support the reliability of the Bulk-Power System by 

measuring competence against a list of specific task requirements. EEI also comments 

that by implementing training requirements that test specific competencies, the proposed 

Reliability Standard PER-005-1 provides greater clarity, thus improving its 

 16 See comments of APPA, Dominion, EEI, IESO, NERC, NRECA, PG&E, Platte 

River, Wisconsin Electric, and WECC. 
Docket No. RM09-25-000 - 11 - 

enforceability. No commenter objects to the approval of the two training Reliability 

Standards. 

Commission Determination

16. The Commission adopts the NOPR proposal and approves Reliability Standard 

PER-004-2 and PER-005-1 as just, reasonable, not unduly discriminatory or preferential, 

and in the public interest.17 By assigning a significant amount of structure to the training 

programs for the principal operators of the Bulk-Power System, namely reliability 

coordinators, balancing authorities and transmission operators, the two proposed 

Reliability Standards will enhance the reliability of the Bulk-Power System. Moreover, 

the two proposed Reliability Standards represent a step forward in implementing a key 

recommendation from the 2003 Blackout Report18 by addressing an identified gap where 

operations personnel were not adequately trained to maintain reliable operation under 

emergency conditions. 

17. The Commission is not directing any modifications to the substantive 

requirements of the two new Reliability Standards, PER-005-1 or PER-004-2. 

Nevertheless, as discussed in greater detail below, the Commission has several concerns 

 17 16 U.S.C. 824o(d)(2). 

18 U.S.-Canada Power System Outage Task Force, Final Report on the August 14, 

2003 Blackout in the United States and Canada: Causes and Recommendations, (April 

2004) (Blackout Report), available at http://www.ferc.gov/industries/electric/indusact/blackout.asp. 
Docket No. RM09-25-000 - 12 - 

regarding certain training issues. To address these concerns, and as discussed in greater 

detail below, the Commission is issuing directives that the ERO: (1) consider the 

necessity of developing an implementation plan for entities that become subject to PER005-1, Requirement R3.1 after Requirement R3.1 is in effect, and (2) develop a 

Reliability Standard, through the ERO’s Reliability Standards development process, 

conducted pursuant to its Standard Processes Manual, establishing training requirements 

for local transmission control center operator personnel. 

B. Implementation Timeline

18. In the NOPR, the Commission expressed concern about NERC’s proposed use of 

staggered effective dates for the two proposed Reliability Standards, which Reliability 

Standards modify currently effective standards. The Commission questioned whether 

staggered effective dates could create a gap in compliance and enforceability. 

Specifically, NERC proposed to make the various requirements in PER-005-1 mandatory 

and enforceable in three stages over a three-year period. The Commission also 

questioned the need for the proposed two- and three-year lead times before certain 

Requirements in PER-005-1 become mandatory and enforceable. 

Comments

19. NERC’s comments clarify the proposed effective dates for each of the new 

Requirements in PER-005-1 and PER-004-2 as well as the corresponding retirement 

dates of the currently effective Requirements in PER-002-0 and PER-004-1. NERC 
Docket No. RM09-25-000 - 13 - 

included in its comments a table that specifies the retirement and effective date for each 

Requirement in each of the affected Reliability Standards, specifically, currently effective 

PER-002-0 and PER-004-1 and proposed Reliability Standards PER-004-2 and PER-005-

1. This table is reproduced in Appendix B of this Final Rule. Further, NERC provides 

justification for the proposed two- and three-year lead times for the effective date for 

some of the proposed Requirements in PER-005-1. Specifically, NERC states that the 

24-month implementation timeframe of proposed PER-005-1, Requirements R1 and R2 

allows flexibility in developing and implementing the training programs that use a 

systematic approach to training, and is structured and tailored to the functions that each 

entity performs in operating the Bulk-Power System. Additionally, NERC explains that 

the 36-month implementation timeframe for Requirement R3.1 in the proposed standard 

PER-005-1 allows entities with simulation technology sufficient time to integrate the use 

of this technology as a core component of those programs going forward and allows 

entities without simulation technology the needed time to secure and integrate simulation 

technology. Finally, NERC states that it reviewed the staggered effective/retirement 

dates and did not find any overlaps or gaps. 
Docket No. RM09-25-000 - 14 - 

 

20. The majority of the commenters generally support NERC’s proposed effective and 

retirement dates.19 Many of these commenters state that if the Commission rejects the 

use of staggered effective and retirement dates, then in the alternative, the Commission 

should impose a uniform effective date that is the first day of the first calendar quarter, 

36 months after FERC approval.20 BGE, GSOC and GTC, KCP&L, SPP, and Westar 

generally support eliminating the staggered effective dates and instead setting this 

uniform effective/retirement date. 

21. EEI raises a concern regarding the effective date for Reliability Standard 

PER-005-1, Requirement 3.1. Specifically, EEI states that although Reliability Standard 

PER-005-1 addresses lead times for compliance based on regulator approval of the 

standards, it does not address the situation where Requirement 3.1 is not applicable to 

certain entities at the time of the regulatory effective date of the standard, but later 

becomes applicable to those entities. Specifically, with respect to PER-005-1, 

Requirement R3.1, which requires simulator training for entities with established 

19 See comments submitted by BPA, ITC, Minnesota Power, Montana-Dakota, NV 

Energy, NorthWestern, PG&E, Platte River, Portland, and WECC. 

20 See comments submitted by Minnesota Power, Montana-Dakota, PG&E, and 

WECC. 
Docket No. RM09-25-000 - 15 - 

interconnection reliability operating limits (IROLs),21 EEI states that if an entity does not 

have established IROLs when the Reliability Standard PER-005-1 becomes effective, but 

later due to system changes an IROL is invoked, the standard does not specify when the 

requirements for simulation training (Requirement R3.1) would be mandatory and 

enforceable for such an entity. EEI states that because entities with established IROLs 

would initially have 36 months to comply with the provisions of Requirement R3.1; i.e., 

to develop simulation training, that the same 36 month compliance lead time should also 

be afforded to all entities with future established IROLs. EEI requests that the 

Commission direct NERC to modify the effective date specified in Reliability Standard 

PER-005-1, section 5.1 to grant a 36-month lead time for entities with newly established 

IROLs or operating guides to be compliant with Requirement 3.1. 

Commission Determination

22. The Commission finds that the proposed staggered implementation schedule for 

PER-005-1 and PER-004-2 and the corresponding retirement schedule for PER-002-0 

and PER-004-1 strikes a reasonable balance between the need for timely reform and the 

needs of the entities that will be subject to PER-005-1 to develop and implement training 

programs utilizing a systematic approach to training and use of simulators as a training 

 21 See NERC Glossary of Terms at 

http://www.nerc.com/docs/standards/rs/Glossary_of_Terms_2010April20.pdf. 
Docket No. RM09-25-000 - 16 - 

 

tool. The effective and retirement date table provided by NERC in its comments and 

incorporated herein as Appendix B demonstrates that there are no apparent overlaps or 

gaps between the retirement of PER-002-0 and PER-004-1 and the effectiveness of the 

requirements in the new Reliability Standards, PER-005-1 and PER-004-2. 

23. The Commission finds that the commenters that advocate for a uniform effective 

date of 36 months have not adequately justified such a lengthy lead time for a Reliability 

Standard that will not impose entirely new requirements. Rather, PER-005-1 requires 

applicable entities to build upon and improve the existing training programs that are in 

place under currently effective PER-002-0. Accordingly, as approved, PER-004-2 in its 

entirety and PER-005-1, Requirement R3 shall become effective on the first day of the 

first calendar quarter after regulatory approval.22 PER-005-1, Requirements R1, R1.1, 

R1.1.1, R1.2, R1.3, R1.4, R2, and R2.1 shall become effective on the first day of the first 

calendar quarter, twenty-four months after regulatory approval. And, finally, PER-005-1, 

Requirements R3.1 shall become effective on the first day of the first calendar quarter, 

thirty-six months after regulatory approval. 

22 “Regulatory approval” for these two Reliability Standards refers to approval by 

the Commission in a final rule. The date of the Commission’s regulatory approval is not 

the date that the final rule is issued by the Commission, rather, in this case, it is 60 days 

after the date the final rule is published in the Federal Register. 
Docket No. RM09-25-000 - 17 - 

24. With respect to EEI’s comment regarding the effective date for entities that may 

become, in the future, subject to the simulator training requirement in PER-005-1, R3.1, 

the Commission believes that this issue should be considered by the ERO. We note that, 

with respect to the Critical Infrastructure Protection (CIP) Reliability Standards, NERC 

has developed a separate implementation plan that essentially gives responsible entities 

some lead time before newly acquired assets must be in compliance with the effective 

CIP Reliability Standards.23 We direct NERC to consider the necessity of developing a 

similar implementation plan with respect to PER-005-1, Requirement R3.1. 

C. Systematic Approach to Training

25. A systematic approach to training is a widely-accepted methodology that ensures 

training is efficiently and effectively conducted and is directly related to the needs of the 

position in question.24 To achieve training results, the objectives of a systematic 

approach to training include: management and administration of training and 

qualification programs; development and qualification of training staff; trainee entrylevel requirements; determination of training program content; design and development 

of training programs; conduct of training; trainee examinations and evaluations; and 

training program evaluation.

 23 See North American Electric Reliability Corp., 130 FERC ¶ 61,271, at P 15 

(2010) (approving the Implementation Plan for Newly Identified Cyber Assets). 

24 See Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1382. 
Docket No. RM09-25-000 - 18 - 

NOPR 

26. In the NOPR, the Commission agreed with NERC that proposed Reliability 

Standard PER-005-1, Requirement R1 met the Commission’s directive to “develop a 

modification to PER-002-2 (or a new Reliability Standard) that uses the systematic 

approach to training methodology.”25 However, the Commission noted that the generic 

reference to systematic approach to training contained in proposed PER-005-1 

Requirement R1 raised the question of whether certain Order No. 693 directives and 

certain specific training requirements that are explicitly set forth in the currently effective 

Reliability Standards PER-002-0 and PER-004-1, which are to be retired, are fully and 

adequately captured under the systematic approach to training umbrella. The 

Commission questioned whether the following three currently effective training 

requirements from PER-002-0 and PER-004-1 are incorporated in proposed Reliability 

Standard PER-005-1: (i) understanding of reliability coordinator area, (ii) continual 

training, and (iii) training staff identity and competency. In the NOPR, the Commission 

sought comment on its understanding of the carryover of these three currently 

enforceable compliance obligations. 

 25 NOPR, FERC Stats. & Regs ¶ 32,601 at P 25 (citing Order No. 693, 

FERC Stats. & Regs. ¶ 31,242 at P 1380). 
Docket No. RM09-25-000 - 19 - 

1. Understanding of Reliability Coordinator Area

27. Currently effective Reliability Standard PER-004-1, Requirements R3 and R4 

provide that reliability coordinator operating personnel “shall have a comprehensive 

understanding of the Reliability Coordinator Area and interactions with neighboring 

Reliability Coordinator areas” and “shall have an extensive understanding of the 

Balancing Authorities, Transmission Operators, and Generation Operators within the 

Reliability Coordinator Area, including the operating staff, operating practices and 

procedures . . . .”26 NERC states that these two requirements are supplanted by and 

addressed more fully in proposed Reliability Standard PER-005-1, Requirements R1 and 

R2. However, proposed Reliability Standard PER-005-1 does not explicitly require 

reliability coordinator operating personnel to have a comprehensive understanding of the 

reliability coordinator area or an extensive understanding of the balancing authorities, 

transmission operators, and generation operators within the reliability coordinator area. 

In order to clarify that these requirements are clear and enforceable under proposed 

Reliability Standard PER-005-1, the Commission sought an explanation from NERC and 

comments from the general public whether these existing requirements are enforceable 

under the proposed Reliability Standard PER-005-1 and whether these requirements are 

clear or should be more explicit. 

 26 See Reliability Standard PER-004-1, Requirements R3 and R4. 
Docket No. RM09-25-000 - 20 - 

Comments

28. Most commenters agree that comprehensive understanding of the reliability 

coordinator area is fully addressed by PER-005-1, Requirements R1 and R2 through the 

use of a systematic approach to training.27 For example, Dominion supports proposed 

PER-005-1, Requirements R1 and R2 because the requirements are clear, measurable, 

and eliminate the subjectivity of the phrase “comprehensive understanding” that currently 

exists under the current PER-004-1, Requirement R3. Dominion believes that proper 

implementation of a systematic approach to training will address the Commission’s 

concern that operating personnel may not have a proper understanding of their system 

and interactions with neighboring systems without resurrecting the vague language in 

PER-004-1. However, other commenters, including ITC, MidAmerican, and SPP, state 

that because the requirement to have a “comprehensive understanding of the reliability 

coordinator’s area” is not explicitly stated in PER-005-1, it will be difficult to enforce. 

29. NERC states that PER-005-1 implements a defense-in-depth approach to ensure 

that the reliability coordinator’s system operators have a comprehensive understanding of 

their reliability coordinator area. NERC believes this approach ensures that system 

operators have the tools to effectively monitor and direct actions within the reliability 

 27 See comments of BPA, Dominion, GSOC & GTC, IESO, ISO/RTO Council, 

KCP&L, Minnesota Power, Montana Dakota, NV Energy, NERC, PG&E, Portland, 

Westar, and WECC. 
Docket No. RM09-25-000 - 21 - 

coordinator area in support of the Bulk-Power System. NERC provides examples of how 

proposed PER-005-1 ensures that the reliability coordinator’s system operators will have 

detailed knowledge of their reliability coordinator area. 

Commission Determination

30. Based on NERC’s explanation, the Commission agrees that the existing 

requirements contained in PER-004-1, which require reliability coordinators to have a 

comprehensive understanding of the reliability coordinator area and interactions with 

neighboring reliability coordinator areas and an extensive understanding of the balancing 

authorities, transmission operators, and generation operators within the reliability 

coordinator area, are adequately captured and enforceable under proposed Reliability 

Standard PER-005-1. 

2. Continual Training

31. Currently effective Reliability Standard PER-002-0, Requirement R3.2 explicitly 

mandates that “the training program must include a plan for the initial and continuing

training of Transmission Operators and Balancing Authorities operating personnel.” In 

the NOPR, the Commission sought an explanation from NERC, and comment from the 

general public, whether continuing training is an enforceable requirement under proposed 

Reliability Standard PER-005-1 and whether this requirement is clear or should be more 

explicit. 
Docket No. RM09-25-000 - 22 - 

Comments

32. NERC comments that continual training is an enforceable requirement under PER005-1, Requirement R1 as a fundamental aspect of a systematic approach to training. 

Most commenters agree with NERC that continual training is an inherent aspect of the 

systematic approach to training.28 For example, the ISO/RTO Council states that PER005-1 is superior to the previous continual training requirement and will be easily 

measured and enforced and thus does not need to be more explicit. 

33. KCP&L believes continuing training is not necessary for routine tasks, only nonroutine. MidAmerican and NV Energy both argue that explicit language addressing 

continual training is necessary to be an enforceable requirement. 

Commission Determination

34. Based on NERC’s and the majority of the commenters’ affirmation that continual 

training is a fundamental part of a systematic approach to training and an enforceable 

requirement 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. 

 28 See comments of BPA, GSOC & GTC, IESO, ISO/RTO Council, ITC, 

Minnesota Power, Montana-Dakota, NV Energy, NorthWestern, PG&E, Platte River, 

Portland, Westar, and WECC. 
Docket No. RM09-25-000 - 23 - 

3. Training Staff Identity and Competency

35. In the NOPR, the Commission noted that currently effective Reliability Standard 

PER-002-0, Requirement R3.4 requires a training program in which “[t]raining staff must 

be identified, and the staff must be competent in both knowledge of system operations 

and instructional capabilities.” The Commission further noted that this requirement is not 

explicitly provided in PER-005-1. As such, the NOPR sought clarification as to (i) how 

and whether a systematic approach to training requires training staff to be identified, and 

(ii) if not, the mechanism by which training staff will be identified and its competency 

ensured. The Commission also invited comment on whether this clarification should be 

made explicit so that entities clearly understand their compliance obligations. 

Comments

36. NERC agrees with the Commission that PER-002-0, Requirement R3.4, which 

requires a training program in which training staff must be identified and competent in 

system operations and instructional capabilities, is an important requirement and 

proposes to reassess whether this requirement should be made more explicit in a later 

version of PER-005-1 so that entities can understand their compliance obligations. 

37. The majority of commenters agree that training staff identification and 

competency are inherent in a systematic approach to training, and that, as such, no 
Docket No. RM09-25-000 - 24 - 

modification of proposed PER-005-1 is necessary.29 However, some commenters 

disagree and argue that PER-005-1 should have an explicit requirement similar to 

Requirement R3.4 in PER-002-0 mandating training staff to be identified and be 

competent in system operations and instructional capabilities.30 Other commenters state 

that the systematic approach to training does not require training staff to be identified or 

their competency ensured, but argue that such a requirement is not necessary and 

potentially detrimental.31 For example, ITC believes competency of training staff should 

be determined by entities internally during the hiring process and companies should not 

be limited by a prescriptive requirement that does not allow for company discretion 

during the hiring process. 

Commission Determination

38. Based on the comments received, the Commission concludes that the current 

requirement for each training program (that training staff must be identified and that such 

staff must be competent in both knowledge of system operations and instructional 

capabilities) is inherent in any systematic approach to training that a registered entity 

would use to meet this requirement, and thus is an enforceable component of 

 29 See comments of GSOC & GTC, Minnesota Power, Montana Dakota, NRECA, 

NV Energy, PG&E, Platte River, Portland, SPP, and Westar. 

30 See comments of BGE, BPA, and MidAmerican. 

31 See comments of IESO, ISO/RTO Council, ITC, KCP&L, NorthWestern, and 

Wisconsin Electric. 
Docket No. RM09-25-000 - 25 - 

Requirement R1 under the proposed standard. However, given the number of 

commenters that argue that it is necessary for the current training program requirement to 

be explicitly stated in the proposed training standard, we agree that NERC should follow 

through on its proposal in its comments to reassess whether this requirement should be 

made more explicit in a later version of PER-005-1. 

D. Training Expectations for Each Job Function/Tailored Training

NOPR Proposal

39. Proposed Reliability Standard PER-005-1, Requirement R1.2 mandates applicable 

entities to “design and develop learning objectives and training materials based on the 

task list created in R1.1.”32 In the NOPR, the Commission noted that it believes that 

NERC has complied with the directive to require entities to identify the expectations of 

the training for each job function and develop training programs tailored to each job 

function with consideration of the individual training needs of their personnel. The 

Commission took the view in the NOPR that the systematic approach to training used to 

satisfy PER-005-1, Requirement R1 would assess factors such as educational, technical 

experience, and medical requirements that candidates must possess before entering a 

given training program. With the above understanding, the Commission concluded that 

 32 NERC Petition at 27 (quoting proposed Reliability Standard PER-005-1, 

Requirement R1.2). 
Docket No. RM09-25-000 - 26 - 

the systematic approach to training methodology required in Reliability Standard PER005-1, Requirement R1 satisfies the Commission’s directive for Order No. 693 to 

develop a modification that identifies the expectations of the training for each job 

function and develops training programs tailored to each job function with consideration 

of the individual training needs of the personnel. In the NOPR, the Commission sought 

comment on its understanding that PER-005-1, Requirement R1.2 requires that the 

learning objectives and training materials be developed with consideration of the 

individual needs of each operator. 

Comments

40. NERC agrees with the Commission that learning objectives and training materials 

are to be developed for each job function. NERC believes that using a systematic 

approach to training allows each entity to tailor its training program to best meet the 

training needs of the function performed by System Operators. 

41. A number of commenters33 agree with NERC and affirm the Commission’s 

understanding that a systematic approach to training requires development of tailored 

training. NorthWestern concurs that PER-005-1 requires the training materials to be 

tailored to the individual needs of each operator. For example, IESO believes that the 

 33 See comments of BPA, GSOC & GTC, NV Energy, NorthWestern, PG&E, and 

Platte River. 
Docket No. RM09-25-000 - 27 - 

 

systematic approach to training process will ensure that the necessary knowledge, skills 

and abilities are provided in the development of learning objectives and associated 

training materials. The ISO/RTO Council contends that PER-005 addresses 

function/task-specific training and not person-specific training or personal development. 

With respect to Requirement R1.2, the ISO/RTO Council interprets the Commission’s 

statement that “. . . requires that the learning objectives and training materials be 

developed with consideration of the individual needs of each operator. . . .” as requiring 

an entity to address the knowledge and skill gaps of individual system operators with 

respect to the reliability tasks they are expected to perform.34 The ISO/RTO Council 

supports the term “systematic approach to training (in lower case)” as used in the 

Reliability Standard because the lower case term provides registered entities flexibility in 

complying with the standard.35 

42. SPP and Westar did not take a position on the issue; rather, they request that the 

Commission clarify what is meant by “consideration of the individual needs of each 

operator.” BG&E recommends that the Commission make more explicit the requirement 

to implement the Department of Energy Handbook on the systematic approach to 

34 See IRC Comments at 7. 

35 Id.
Docket No. RM09-25-000 - 28 - 

 

training36 as the mandatory standardized methodology industry-wide, and expresses the 

view that the DOE Handbook is the most stringent set of standards available, has the 

longest track record of proven successful results, and is familiar to the industry. BG&E 

identifies the following expectations that training should include: (1) customized, taskbased training; (2) annual assessment of operator needs; and (3) individualized training 

on any task for which the trainee failed to achieve satisfactory standards during the 

annual training. 

43. One commenter, Wisconsin Electric, disagrees with the Commission’s 

“understanding” on this issue. Wisconsin Electric expresses several concerns with the 

following statement in the NOPR:

Based on our review of the Systematic Approach to Training 

methodology used by the Department of Energy, we 

understand that a Systematic Approach to Training would 

assess factors such as educational, technical, experience, and 

medical requirements that candidates must possess before 

entering a given training program. With the above 

understanding, we believe that the Systematic Approach to 

Training methodology, as proposed in Reliability Standard 

PER-005-1, satisfies the Commission directive to develop a 

modification that identifies the expectations of the training for 

each job function and develops training programs tailored to 

36 See U.S. Department of Energy’s Handbook, DOE-HDBK-1078-94, Training 

Program Handbook: A Systematic Approach to Training (August 1994), available at

http://www.hss.energy.gov/nuclearsafety/ns/techstds/standard/hdbk1078/hdbk1078.pdf

(DOE Handbook). 
Docket No. RM09-25-000 - 29 - 

each job function with consideration of the individual training 

needs of the personnel.37 

Specifically, Wisconsin Electric is concerned that this would add a number of elements to 

PER-005 and would create confusion over the scope of the compliance obligation. 

Wisconsin Electric states that this language appears to impose the Department of 

Energy’s Systematic Approach to Training as the only acceptable methodology, which, in 

effect, precludes entities from adopting another approach. Wisconsin Electric is also 

concerned that the factors that a candidate must possess before entering a training 

program create a de facto compliance checklist that would exist apart from the language 

of the Reliability Standard. Wisconsin Electric objects to the expansion of NERC 

requirements to include assessment of medical condition of its personnel. Wisconsin 

Electric believes that the Commission should approve PER-005-1 as written without 

conditioning its approval on additional, unstated requirements. 

Commission Determination

44. Based on NERC’s and other commenters’ affirmation of the Commission’s 

understanding as stated in the NOPR, the Commission confirms that Requirement R1.2 of 

proposed Reliability Standard PER-005-1 requires that the learning objectives and 

training materials be developed with consideration of the individual needs of each 

 37 NOPR, FERC Stats & Regs. ¶ 32,661 at P 32. 
Docket No. RM09-25-000 - 30 - 

 

operator. In response to Wisconsin Electric, BG&E and the ISO/RTO Council, the 

Commission clarifies that it is not mandating the use of the specific Systematic Approach 

to Training methodology used by the Department of Energy. However, we believe that 

the Department of Energy’s Systematic Approach to Training methodology as set forth in 

the DOE Handbook is a particularly good and relevant model to use. 

45. DOE’s Handbook is relevant for two reasons. First, it was designed to assist 

facilities, specifically nuclear facilities, that are within the same general industry as 

electric power facilities.38 Second, the DOE Handbook was written on the assumption 

that the user, a facility, is currently not using the DOE Systematic Approach to Training 

model for their training programs, which is very likely the case with respect to entities 

subject to PER-005-1.39 Thus, the DOE Handbook is particularly relevant to entities that 

transition to a systematic approach to training. We note that the DOE Handbook was 

38 DOE has noted that although its training handbooks related to the Systematic 

Approach to Training were prepared primarily for DOE nuclear facilities, the information 

can be effectively used by any other type of facility. See DOE Handbook, DOE-HDBK1074-95 at Foreword (January 1995) (Alternative Systematic Approach to Training 

Handbook), available at

http://www.hss.energy.gov/nuclearsafety/ns/techstds/standard/hdbk1074/hdb1074a.html. 

39 See DOE Handbook at 1.2. The DOE Handbook acknowledges that many 

nuclear facilities already had effective training programs in place that contain many 

performance-based characteristics. Accordingly, DOE Handbook states that facilities 

with existing training programs should not discard such programs; rather, they should 

validate and supplement the existing training content where necessary using systematic 

methods. Id. 
Docket No. RM09-25-000 - 31 - 

 

compiled from a number of sources including the Institute of Nuclear Power Operations’ 

Principles of Training System Development as well as in collaboration with personnel 

representing DOE contractors and private industry.40 Moreover, the DOE Handbook 

provides reasonable flexibility when implementing a systematic approach to training in 

various settings.41 

46. Finally, SPP and Westar request that the Commission clarify what is meant by 

“consideration of the individual needs of each operator.” The Commission provides the 

following clarification. A training plan is designed to prepare individuals to perform 

their jobs. More specifically, a training plan should address gaps between the skills 

necessary to accomplish a particular job task and an operator’s competency to carry out 

that task. Because of the emphasis on the individual, to be effective, a training plan must 

take into consideration the individual needs of the trainee, which includes the trainee’s 

education level, technical experience, and relevant medical requirements. 

40 See DOE Handbook at 1.1. 

41 See id. at 1.2. In developing the DOE Handbook, DOE noted that the handbook 

describes the more classical concept and approach to systematically establishing training 

programs. However, in some cases this classical approach has proven to be time- and 

labor-intensive, and therefore encourages users of the handbook to consider the variety of 

training options that are available for establishing and maintaining personnel training and 

qualification programs. DOE further found that blending classical and alternative 

systematic approaches to training methods often yields the most effective product. See

DOE Handbook at iii (the Foreword). 
Docket No. RM09-25-000 - 32 - 

E. Simulation Training

47. In Order No. 693, the Commission directed NERC to develop a requirement 

mandating simulator training for reliability coordinators, transmission operators and 

balancing authorities that have operational control over a significant portion of load and 

generation. Recognizing that cost of simulator training is an issue, the Commission 

allowed for the use of simulators to be dependent on an entity’s role and size.42

NOPR Proposal

48. In the NOPR, the Commission found that proposed Reliability Standard PER-005-

1, Requirement R3.1 meets this Order No. 693 directive regarding training using 

simulators. However, the Commission sought comment on the terminology in 

Requirement R3.1 which provides that the emergency operations training should use 

“simulation technology such as a simulator, virtual technology, or other technology that 

replicates the operational behavior of the BES during normal and emergency 

conditions.” Specifically, the NOPR asked NERC to clarify: (i) whether the language in 

R3.1, “replicates the operational behavior of the BES,” requires the use of simulators 

specific to an operator’s own system; (ii) if not, whether operators trained on simulators 

that replicate systems other than their own will be adequately trained to respond to 

emergency conditions on their own system; and (iii) whether it is feasible or practicable 

 42 See Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1390. 
Docket No. RM09-25-000 - 33 - 

(including cost considerations) to require use of simulators that realistically replicate the 

entity’s own topology and operating conditions; i.e., to require “custom” simulators. 

Comments

49. NERC and all others who commented on the simulator training issue agree that 

PER-005-1, Requirement R3.1, does not require the use of custom simulators.43 NERC, 

and other commenters,44 state that Requirement R3.1 requires a simulator to replicate the 

operational behavioral characteristics of the bulk electric system through the use of 

simulation technology. Commenters argue that the purpose of simulators is to train the 

operator in principles that can be applied to any system. Specifically, NRECA explains 

that the intent of PER-005-1, Requirement R3.1 is not to require simulators that replicate 

every aspect of an entity’s own topology and operating conditions. Rather, the intent is 

to replicate the operational behavioral characteristics of the bulk electric system through 

the use of more generalized simulation technology. 

50. All commenters, except for BPA, agree that the simulator training requirement 

should not require custom simulators. Some commenters argue that custom simulators 

 43 See comments of APPA, BPA, EEI, GSOC & GTC, IESO, ISO/RTO Council, 

ITC, KCP&L, MidAmerican, Minnesota Power, Montana-Dakota, NRECA, NV Energy, 

NERC, NorthWestern, PG&E, Platte River, Portland, SPP, and Westar. 

44 See comments of APPA, EEI, IESO, ISO/RTO Council, NRECA, Northwestern, 

PG&E, Platte River, Portland, SPP, and Westar. 
Docket No. RM09-25-000 - 34 - 

 

are not necessary.45 These commenters argue that it is the understanding of situational 

conditions and the response to them that is the hallmark of successful operator training, 

and such training does not require the use of simulators specific to an operator’s own 

system. 

51. For example, NRECA states that it is an understanding of the situational 

conditions and the response to them that is the key to successful operator training, and 

those do not require the use of simulators specific to an operator’s own system. NRECA 

further described that simulation of operational scenarios such as: frequency response of 

generators, VAR flow from high voltage to low voltage, and restoration load pick-up and 

the potential for under-frequency tripping, are concepts common to all systems, noting 

that a simulator can address and train on these issues irrespective of individual system 

characteristics. Minnesota Power and Montana Dakota explain that, in general, elements 

of the bulk electric system exhibit behaviors based upon the characteristics of each 

element, not upon their specific location in a particular system. They posit that it is the 

understanding of the situational conditions and the response to them that is the key to 

successful operator training and that understanding does not require the use of simulators 

specific to an operator’s own system. EEI notes that the issue of custom versus generic 

45 See comments of EEI, IESO, KCP&L, Minnesota Power, Montana-Dakota, 

NRECA, NV Energy, and PG&E. 
Docket No. RM09-25-000 - 35 - 

 

simulators was discussed extensively by the PER-005-1 drafting team and argues that 

custom simulators are not necessary to properly train personnel. EEI urges the 

Commission to approve PER-005-1, R3.1 without change and to allow NERC to monitor 

the effectiveness of the simulator training requirement for possible gaps. 

52. Other commenters argue against mandating custom simulators because the cost of 

custom simulators would far exceed the benefit.46 APPA states that the additional cost of 

developing and maintaining a realistic full-scale, system-specific simulator for a small 

balancing authority or transmission operator would likely exceed the benefits. No 

commenter provided specific estimates of the incremental increase in cost of custom 

simulators. EEI, acknowledging that it does not have specific cost information, noted 

that accurate Bulk-Power System modeling and maintenance would be a significant cost 

driver. ITC states that although it believes that the use of system simulators specific to an 

operator’s own system would better prepare a system operator for emergency conditions, 

the cost of custom simulators could likely outweigh the reliability benefits to small 

operators. Portland General Electric estimates that purchase, implementation and 

maintenance of a system-specific simulator could cost several hundred thousand dollars 

46 See comments of APPA, EEI, ISO/RTO Council, ITC, KCP&L, MidAmerican, 

Minnesota Power, Montana-Dakota, NRECA, NV Energy, NorthWestern, Platte River, 

Portland, and SPP. 
Docket No. RM09-25-000 - 36 - 

 

in up-front costs and would necessitate the addition of engineering personnel for 

programming and ongoing maintenance. 

53. BPA, the sole commenter that endorses modifying PER-005-1 to mandate the use 

of custom simulators, notes that it uses custom simulators. BPA acknowledges that the 

cost of implementing and maintaining a high fidelity simulator is significant, but suggests 

an alternative approach of developing a centralized, high fidelity simulator that 

realistically replicates the entire interconnection that could be remotely accessed by 

entities for training exercises. 

54. NERC notes in its comments that custom simulators could be important in 

ensuring the reliability of the BES. NERC further states that while a high fidelity 

simulator may not be necessary to ensure bulk electric system reliability, NERC agrees 

that simulators used for training that provide a useful representation of the system that the 

operators work with may warrant further consideration in a subsequent version of the 

proposed standard.47 EEI appears to agree with NERC, as EEI urges the Commission to 

allow NERC to implement the new PER-005-1 requirements, gather experience on their 

effectiveness, and monitor results for possible gaps or challenges that arise with 

experience. 

47 NERC Comments at 14. 
Docket No. RM09-25-000 - 37 - 

Commission Determination

55. We affirm NERC’s and the industry’s understanding that PER-005-1, 

Requirement R3.1 does not require the use of simulators specific to an operator’s own 

system. While the Commission continues to feel there is value in using custom 

simulators, we acknowledge that NERC and industry have determined that it is not 

necessary at this time. However, NERC and other commenters state that there may be 

potential reliability benefits of some form of custom simulators. NERC has also 

proposed to consider custom simulators in a subsequent modification of PER-005-1. We 

appreciate NERC’s commitment to continually look at how reliability can be improved 

and encourage NERC and industry to evaluate the gained reliability in requiring the use 

of custom simulators. 

F. Local Transmission Control Center Operator Personnel Training

56. In Order No. 693, the Commission directed NERC to expand the applicability of 

currently effective Reliability Standard PER-002-0 to include local transmission control 

center operator personnel. Order No. 693 provided that the training should be tailored to 

the functions that local transmission control center operators perform that impact the 

reliable operation of the Bulk-Power System for both normal and emergency 

operations.48 Proposed Reliability Standard PER-005-1, which is intended to supersede 

 48 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1348. 
Docket No. RM09-25-000 - 38 - 

existing Reliability Standard PER-002-0, does not include local transmission control 

center operator personnel in the applicability section. Rather, proposed Reliability 

Standard PER-005-1, as drafted, is applicable only to the following three functional 

entities: reliability coordinators, balancing authorities, and transmission operators. 

NERC explained that its functional model lists the functions that a transmission operator 

performs, which includes the functions performed by local transmission control center 

personnel. NERC therefore concluded that, the Order No. 693 directive to include formal 

training for local transmission control center personnel is addressed in proposed 

Reliability Standards PER-005-1 because the transmission operator has the ultimate 

responsibility to ensure that its functional responsibilities are met, even if through other 

entities.49

NOPR Proposal

57. In the NOPR, the Commission rejected NERC’s explanation regarding the failure 

to include local transmission control center operating personnel in the proposed training 

standard. The Commission stated in the NOPR that, contrary to NERC’s suggestion, 

under proposed Reliability Standard PER-005-1, a transmission operator could not 

require a local transmission control center operator to receive training if that operator is 

employed by an entity other than a reliability coordinator, balancing authority, or 

 49 NERC Petition at 30. 
Docket No. RM09-25-000 - 39 - 

transmission operator. The Commission noted that with respect to proposed Reliability 

Standard PER-005-1, the standard requires transmission operators, reliability 

coordinators, and balancing authorities to establish a training program for the companyspecific tasks performed by its System Operators.50 Thus the proposed standard only 

requires implementation of a training program for operators employed by the applicable 

entity’s own company. Accordingly, the NOPR proposed to direct NERC to modify 

proposed Reliability Standard PER-005-1 to include a provision that explicitly addresses 

training for local transmission control centers, consistent with the Commission’s directive 

in Order No. 693. 

Comments

58. NERC, and all other commenters that address this issue, object to the 

Commission’s proposal to direct NERC to expand the applicability of PER-005-1 to 

explicitly include local transmission control center personnel. Some commenters agree 

with NERC’s position, stated in its Petition, that the local transmission control center 

operators will receive the necessary training without explicitly including them as a class 

subject to PER-005-1.51 These commenters are concerned that the Commission’s 

directive will require the creation of a new class of registered entities. 

 50 Reliability Standard PER-005-1, Requirement R1.1 (emphasis added). 

51 See comments of IESO, NRECA, and NV Energy. 
Docket No. RM09-25-000 - 40 - 

 

59. The majority of commenters52 state that the term “local transmission control 

center” is unclear and undefined and, without definition, is subject to broad 

interpretation. These commenters raise the concern that “if local transmission control 

center” is not clearly defined, it could result in training requirements applying to nonNERC jurisdictional persons or entities. Commenters appear generally to support a 

definition that would define local transmission control centers as those which have 

authority to make decisions concerning the real-time operation of the bulk electric 

system. Associated Electric proposes a definition of “local transmission control center.” 

60. NERC and two other commenters53 suggest that training requirements for local 

transmission control center personnel should be developed in a separate project, not as a 

modification to PER-005-1. NERC advocates developing training standards for local 

transmission control center personnel in a separate standard because proposed PER-005-1 

is focused on improving training requirements for system operators who work for the 

reliability coordinator, transmission operator, and balancing authority. Further, NERC 

explains that developing training requirements for these operator personnel in a separate 

standard will allow that future standard to be modeled after PER-005-1. Accordingly, 

NERC proposes in its comments to address training requirements for local transmission 

52 See comments of Associated Electric, Dominion, GSOC & GTC, IESO, 

ISO/RTO Council, Minnesota Power, Montana Dakota, PG&E, Portland, and SPP. 

53 See comments of APPA and EEI. 
Docket No. RM09-25-000 - 41 - 

control center operator personnel through its standards development process as a separate 

standards development project, after the Commission issues a final order on PER-005-1. 

Commission Determination

61. Some commenters question the original directive in Order No. 693 requiring the 

development of training requirements for local transmission control center personnel by 

contending, as IESO does, that if individuals at a local control center are simply 

implementing directives from a transmission operator or a reliability coordinator, then 

such personnel should not be required to undergo the same rigorous training meant only 

for those entities who make independent decisions. Specifically, in Order No. 693, the 

Commission stated: 

The Commission disagrees with those commenters who 

contend that, because operators at local control centers take 

direction from NERC-certified operators at the ISO or RTO, 

they do not need to be addressed by the training requirements 

of PER-002-0. Rather, as discussed above, these operators 

maintain authority to act independently to carry out tasks that 

require real-time operation of the Bulk-Power System 

including protecting assets, protecting personnel safety, 

adhering to regulatory requirements and establishing stable 

islands during system restoration.54

Thus, such comments are a collateral attack on Order No. 693 and will not be readdressed. Issues regarding the rigor or type of training required for operators at local 

 54 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1347. 
Docket No. RM09-25-000 - 42 - 

control centers should be vetted through NERC’s standards development process as part 

of the standards drafting and balloting, and ultimately may be raised in comments in any 

future Commission proceeding in which the proposed standard(s) or modified standard(s) 

are before the Commission. 

62. 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 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 
Docket No. RM09-25-000 - 43 - 

 

reliability gap. The Commission believes that identifying these entities would be a 

valuable step in delineating the magnitude of that gap. 

63. NERC proposes in its comments to address the training of local transmission 

control center operating personnel in a different standard than PER-005-1.55 The 

Commission’s concern in the NOPR was that local control center operating personnel be 

trained. We leave it to NERC’s discretion whether to revise Reliability Standard PER005-1 to accomplish this goal or to require local control center operating personnel to be 

trained in a separate Reliability Standard. The Commission notes that proposed 

Reliability Standard PER-005-1 generally requires the applicable entity to establish and 

implement a training program, verify operators’ capabilities, and provide emergency 

training. The specific training, based on the Systematic Approach to Training 

methodology, is determined by the entity based on company-specific reliability-related 

tasks performed by its operators. As discussed above, the Systematic Approach to 

Training methodology is not job specific and, rather, provides flexibility to meet the 

needs of varying organizations and job skills. In its comments, NERC has said that it 

intends to generally model local control center operating personnel training on PER-005-

1. Thus, we expect that the Reliability Standard that is developed will require training for 

local transmission control center that does not significantly diverge from the training 

55 NERC Comments at 15-16. 
Docket No. RM09-25-000 - 44 - 

requirements set forth in PER-005-1. If the ERO proposes a Reliability Standard that 

differs significantly from the approved PER-005-1 requirements, NERC must provide in 

its petition seeking approval of such future standard, adequate technical analysis 

supporting the different approach. 

64. Accordingly, we adopt our NOPR proposal and direct the ERO to develop through 

a separate Reliability Standards development project formal training requirements for 

local transmission control center operator personnel. Finally, given the numerous 

comments stating that term “local transmission control center” should be defined, we 

direct NERC to develop a definition of “local transmission control center” in the 

standards development project for developing the training requirements for local 

transmission control center operator personnel. We will not evaluate Associated 

Electric’s proposed definition but, rather, leave it to the ERO to develop an appropriate 

definition that reflects the scope of local transmission control centers. The Commission 

will not opine on the appropriate definition of local transmission control center, as this 

definition can be addressed first using NERC’s Reliability Standards Development 

Procedures. 

G. Performance Metrics

65. In Order No. 693, the Commission directed NERC to (1) determine “whether it is 

feasible to develop meaningful performance metrics associated with the effectiveness of a 
Docket No. RM09-25-000 - 45 - 

training program..., and if so, develop such performance metrics,”56 and (2) determine if 

quantifiable performance metrics can be developed to gauge the effectiveness of the 

Reliability Standard itself.57 In its Petition, NERC stated that the systematic approach to 

training methodology, as set forth in proposed Reliability Standard PER-005-1, subrequirement R1.4, requires each reliability coordinator, balancing authority and 

transmission operator to conduct an annual evaluation of the training program and assess 

whether system operators are receiving effective training. NERC concluded that this 

annual evaluation “provides a meaningful assessment of the training program” while 

“[a]n evaluation of how System Operators perform during infrequent, actual events on 

the system would not provide useful metrics on an ongoing basis.”58 NERC also stated 

that proposed Reliability Standard PER-005-1 is a training standard, and is not intended 

to address individual system operator performance apart from the requirements associated 

with the company-specific reliability-related tasks identified in Requirement R1. 

NOPR 

66. In the NOPR the Commission sought comment from NERC on whether it 

considered metrics to evaluate the effectiveness of the Reliability Standard itself, not just 

metrics to evaluate the effectiveness of the applicable entity’s training program under 

 56 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1394. 

57 Id. P 1379. 

58 NERC Petition at 33-34. 
Docket No. RM09-25-000 - 46 - 

PER-005-1. In addition, the Commission sought comment on possible performance 

metrics that could be used to assess whether proposed Reliability Standard PER-005-1 

achieves its stated purpose. As a result, the Commission proposed to direct NERC to 

evaluate the feasibility of developing meaningful performance metrics to evaluate the 

effectiveness of the Reliability Standard related to operator training. 

Comments 

67. NERC notes that it is working to develop performance measures that will address 

Reliability Standards in general. NERC emphasizes that performance measures should 

not be embodied in the Reliability Standard requirements so there is room for flexibility 

in the development, implementation and modification of such measures. Commenters 

APPA, Minnesota Power, and Montana-Dakota agree with NERC that the development 

of metrics to evaluate the effectiveness of a NERC Reliability Standard should uniformly 

apply to all standards, not to individual standards. 

68. Two commenters, BG&E and NorthWestern, generally support the Commission’s 

proposal and request that any action taken to explore the feasibility of developing metrics 

provide for a transparent stakeholder process. NorthWestern identifies three methods for 

measuring performance: (1) use currently monitored operating parameters and incident 

reports; (2) capitalize on the capabilities of certain entities to monitor and evaluate the 

response of subordinate entities; and (3) use simulation to evaluate operator performance 

against a standard set of operating challenges. NorthWestern suggests that metrics to 
Docket No. RM09-25-000 - 47 - 

evaluate system operators performing real-time tasks should focus on reliability-related 

tasks that have the greatest commonality across entities and on characteristics of 

operation that provide insight into the organizational and operational approach to 

reliability. 

69. Most commenters, however, state that performance metrics for this Reliability 

Standard are either not feasible59 or not necessary because of the systematic approach to 

training methodology.60 For example, Platte River believes that the feasibility of 

developing meaningful global performance metrics is low. Platte River also believes it is 

too difficult to establish specific parameters and to monitor trends across entities because 

systems are topologically unique and operational situations differ. Commenters note that 

the systematic approach to training addresses the performance metric because its checks 

and balances verify that a person can perform the task after training. 

Commission Determination 

70. The Commission believes that performance metrics should be developed to gauge 

the effectiveness of a Reliability Standard if it is feasible to do so. We are pleased that 

NERC is working to develop performance measures that will address reliability standards 

in general. Based on the comments, it appears that it may be infeasible or, at a minimum, 

 59 See comments of APPA, IESO, ITC, KCP&L, NV Energy, and Platte River. 

60 See comments of ISO/RTO Council, MidAmerican, Minnesota Power, 

Montana-Dakota, PG&E, Portland, and Westar. 
Docket No. RM09-25-000 - 48 - 

impracticable to develop performance metrics for some individual Reliability Standards; 

e.g., PER-005-1. However, we find that, based on this project, NERC is already in the 

process of evaluating the feasibility of developing meaningful performance metrics to 

evaluate the effectiveness of PER-005-1. The Commission encourages NERC to 

complete its generic performance measures project. 

H. Violation Risk Factors/Violation Severity Levels

NOPR Proposal

71. In the NOPR, the Commission proposed deferring action on the proposed violation 

risk factors (VRF) and violation severity levels (VSL) for both of the proposed 

Reliability Standards until the Commission acts on NERC’s pending petition in Docket 

No. RR08-4-005, in which NERC proposes a “roll-up” approach for VRFs and VSL 

assignments by which NERC would only assign VRFs and VSLs to the main 

Requirements and not to the sub-Requirements.61 

Comments

72. The ISO/RTO Council, the sole commenter on this issue, supports the 

Commission’s proposal to defer action on the proposed violation risk factors and 

 61 Docket No. RR08-4-005 comprises NERC’s March 5, 2010 Violation Severity 

Level Compliance Filing submitted in response to Order No. 722 and an August 10, 2009 

informational filing in which NERC proposes assigning VRFs and VSLs only to the main 

Requirements in each Reliability Standard and not to the sub-requirements. 
Docket No. RM09-25-000 - 49 - 

violation severity levels assignments. No commenter objected to the proposal to defer 

action. 

Commission Determination

73. The Commission will defer discussion on the proposed violation risk factors and 

violation severity levels assigned to PER-005-1 and PER-004-2 until after the 

Commission issues a final order acting on NERC’s petition in Docket No. RR08-4-005. 

I. Unaddressed Directives

NOPR Proposal

74. The Commission noted in the NOPR that NERC, in developing proposed 

Reliability Standard PER-005-1, did not comply with the directive in Order No. 693 to 

expand the applicability of the personnel training Reliability Standard, PER-002-0, to 

include (i) generator operators centrally-located at a generation control center with a 

direct impact on the reliable operation of the Bulk-Power System, and (ii) operations 

planning and operations support staff who carry out outage planning and assessments and 

those who develop System Operating Limits (SOL), Interconnection Reliability 

Operating Limits (IROL) or operating nomograms for real-time operations.62 The 

Commission also directed, in Order No. 693, NERC to consider whether personnel that 

support Energy Management System (EMS) applications should be included in 

 62 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1393. 
Docket No. RM09-25-000 - 50 - 

mandatory operator personnel training requirements.63 Noting NERC’s proposal to 

address the expansion of the applicability of the training standard (PER-005-1) and to 

consider including EMS support personnel in the training standard in a subsequent 

standards development project, Project 2010-01 – Support Personnel Training, the 

Commission sought comment on whether NERC should target completing Project 2010-

01 by the fourth quarter of 2011. 

Comments

75. Twenty-five entities commented on this issue.64 BPA is the only commenter that 

believes Project 2010-01 can be completed by fourth quarter 2011. The other 

commenters, including NERC, state that a fourth quarter 2011 deadline is not reasonable. 

A number of commenters believe that a 24 month deadline would be an appropriate 

timeframe for NERC to comply with the Order No. 693 directives. 

76. NERC states that, with respect to incorporating generator operators into the 

applicability section of PER-005-1, it must interact with the Commission to obtain more 

direction before proceeding with the standards development process. NERC commits in 

its comments to meeting the directive to consider whether personnel who support EMS 

 63 Id. P 1394. 

64 The twenty-five commenters include: APPA, Associated Electric, BGE, BPA, 

Constellation, Dominion, EEI, E.ON, EPSA, GSOC & GTC, ISO/RTO Council, ITC, 

KCP&L, Minnesota Power, Montana-Dakota, NV Energy, NERC, NorthWestern, PG&E, 

Platte River, Portland, SPP, Westar, WECC, and Wisconsin Electric. 
Docket No. RM09-25-000 - 51 - 

 

applications should be included the mandatory training Reliability Standard within 

24 months after August 23, 2010.65

77. Other commenters such as APPA and Dominion encourage the Commission to 

allow Project 2010-01 to follow the natural course of the Reliability Standards 

development procedures without imposing a specific deadline. APPA notes that, in 

NERC’s draft 2011-2013 Reliability Standards Development Plan, Project 2010-01 is 

fourteenth of seventeen projects which will be initiated in numerical order. Further, 

APPA states that NERC’s Reliability Standards development “pipeline” is already full to 

capacity. APPA is concerned that a “hard” deadline for Project 2010-01 might delay 

ongoing projects. APPA encourages the Commission to collaborate with NERC on the 

priority for Reliability Standards projects in conjunction with the Reliability Standards 

Development Plan rather than setting deadlines in individual proceedings. 

78. With respect to the Order No. 693 directive to expand training to include 

operations planning and operations support staff who carry out outage planning and 

assessments and persons who develop SOLs, IROLs or operating nomograms for realtime operations, several commenters raise issues regarding the substance of the original 

directive. These issues are beyond the scope of the timing issue the Commission raises in 

the NOPR. For example, Associated Electric urges the Commission to direct NERC to 

65 NERC Comments at 21. 
Docket No. RM09-25-000 - 52 - 

adopt a definition of operations planning and operations support staff that more narrowly 

identifies those personnel who will be subject to the training standard. GSOC and GTC 

do not support expanding the applicability of the PER-005-1 training requirements to any 

other personnel. GSOC and GTC further argue that time spent expanding training 

requirements to other personnel will take away from their job of supporting their 

operating personnel, a use of time and resources that could actually decrease reliability. 

79. With respect to the Order No. 693 directive to expand training to include generator 

operators centrally-located at a generation control center with a direct impact on the 

reliable operation of the Bulk-Power System, several commenters raise issues regarding 

the substance of the original directive. These issues also are beyond the scope of the 

timing issue the Commission raises in the NOPR. For example, Constellation notes that 

in developing training requirements for generator operators the Reliability Standard 

should not create onerous training obligations or impose training requirements that 

conflict with or make existing programs less effective. E.ON comments that there is no 

sound basis for imposing the same or similar training requirements mandated for 

transmission operations on generator personnel. E.ON urges the Commission to weigh 

the complexity of mandating individual plant-specific training programs against the 

incremental benefit to Bulk-Power System reliability. EPSA seeks clarification regarding 

several aspects of the scope and intent of the Commission’s directive to expand the 

applicability of PER-005-1 to include generator operators. Specifically, EPSA asks the 
Docket No. RM09-25-000 - 53 - 

Commission to reaffirm its finding in Order No. 693 that the training will apply only to 

employees at generator operators’ centrally-located dispatch centers or when a single 

generator and dispatch center are at the same site. EPSA seeks as well Commission 

guidance regarding the sufficiency and consistency of existing Regional Transmission 

Organization/Independent System Operator (RTO/ISO) training programs applicable to 

generator operators with respect to the reliability training needs identified in the NOPR. 

EPSA also objects to the suggestion in the NOPR that, in the event that communication is 

lost with the grid operator, a generator operator would take unilateral action for which its 

personnel would require training. 

80. With respect to the Order No. 693 directive that NERC consider whether EMS 

personnel should be incorporated into the system operator training Reliability Standard, 

BGE comments that no separate training is needed for EMS personnel, as EMS personnel 

already are regularly trained. EEI states that, because the skills and functions of EMS 

personnel are unique, the development of training requirements for EMS support 

personnel should take place as a separate, stand-alone development project. 

Commission Determination

81. GSOC and GTC, E.ON, and Constellation raise issues regarding the substance and 

scope of the original Order No. 693 directives. Such comments are a collateral attack on 

Order No. 693 and will not be re-addressed. Such issues should be vetted through 

NERC’s standards development process as part of the standards drafting and balloting, 
Docket No. RM09-25-000 - 54 - 

 

and ultimately may be raised in comments in a future Commission proceeding in which 

the proposed standard(s) or modified standard(s) are before the Commission. 

82. Associated Electric expressed concern that the NOPR definition of the 

“operations planning and operations support staff” who should receive training pursuant 

to the Order No. 693 directive is “broad and will encompass operations planning and 

operation support staff who engage in tasks that do not directly affect the reliable 

operation of the bulk electric system.”66 The Commission clarifies that the scope of the 

Reliability Standard or modification to a Reliability Standard to address training for 

“operations planning and operations support staff” is limited by the qualifications stated 

in Order No. 693. Specifically, in Order No. 693, the Commission directed the ERO to 

develop a modification to PER-002-0 that extends applicability of the training 

requirements to the operations planning and operations support staff of transmission 

operators and balancing authorities.67 The Commission further clarified that such 

directive applies only to operations planning and operations support personnel 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 

66 Associated Electric’s Comments at 6. Associated Electric states that, in the 

NOPR, the Commission “defines” operations planning and operations support staff as 

persons “who carry out outage planning and assessments and those who develop SOLs 

and IROLs, or operating nomograms for real-time operations.” 

67 Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1393. 
Docket No. RM09-25-000 - 55 - 

 

nomograms in accordance with Reliability Standards IRO-005-1 and TOP-004-0.”68 The 

NOPR did not expand or alter the scope of this directive as set forth in Order No. 693. 

83. EPSA requests clarification of several statements in the NOPR regarding the 

Order No. 693 directive related to expanding the applicability of the system operator 

training Reliability Standard to include certain generator operators. First, EPSA 

expresses concern that the NOPR discussion broadly addresses generator operator 

personnel in a way that could be construed as subjecting all generator operator personnel, 

regardless of the disposition of the generating unit and how it fits into the grid and the 

topology of the grid, to the system operator training requirements. Therefore EPSA 

seeks clarification that the Commission did not intend for the NOPR to expand the Order 

No. 693 directive. We confirm that we have not modified the scope of applicability of 

the Order No. 693 directive regarding generator operator training.69 As described in 

Order No. 693, the directive applies to generator operator personnel at a centrally-located 

dispatch center who receive direction and then develop specific dispatch instructions for 

plant operators under their control. Those generator operator personnel must receive 

formal training of the nature provided to system operators under PER-005-1.70 As 

clarified in Order No. 693, this group of personnel would include a generator operator’s 

68 Id. P 1372. 

69 See id. P 1359-61. 

70 See id. P 1360. 
Docket No. RM09-25-000 - 56 - 

 

dispatch personnel where a single generator and dispatch center are located at the same 

site.71 

84. EPSA also seeks clarification regarding the statement in the NOPR that: “[I]n the 

event communication is lost, the generator operator personnel must have had sufficient 

training to take appropriate action to ensure reliability of the Bulk-Power System.”72 

EPSA expresses concern that this statement suggests that if communication is lost with 

the grid operator, the generator operator must take unilateral action for which it requires 

training. EPSA notes that generator operators do not take such unilateral action nor do 

they have access to information to make such decisions. Therefore, EPSA asks the 

Commission to make clear that while communication should be addressed in training 

requirements for centrally located generator operator dispatch employees, the 

Commission is not extending related responsibilities or training requirements to generator 

operator employees. We grant the requested clarification, and affirm that we are not 

modifying the Order No. 693 directive regarding training for certain generator operator 

dispatch personnel, nor are we expanding a generator operator’s responsibilities.73

71 Id. P 1361. 

72 NOPR, FERC Stats. & Regs. ¶ 32,661 at P 58. 

73 See Order No. 693, FERC Stats. & Regs. ¶ 31,242 at P 1359-65. 
Docket No. RM09-25-000 - 57 - 

 

85. EPSA also raises the issue of potentially overlapping or duplicative training 

programs. EPSA notes that training requirements already exist in organized markets and 

compliance with them is a condition for market participation, citing PJM and CAISO as 

examples, and asserts that new training requirements should either mesh with or build 

upon those already in place. EPSA further notes that regional transmission organizations 

and independent system operators have training programs for generator operators that 

ensure that grid participants are well trained on grid operations and the needs of grid 

operators. EPSA believes that any modified or new Reliability Standard related to 

generator operator training should not conflict with or supplant the organized markets’ 

existing training requirements. Accordingly, EPSA states that the Commission’s 

“acknowledgment of these existing programs and how they might fit with the expansion 

of PER-005-1 would provide useful guidance for Project 2010-01.”74 The Commission 

believes that, in the above-discussion regarding the systematic approach to training, the 

systematic approach to training methodology is flexible enough to build on existing 

training programs by validating and supplementing the existing training content, where 

necessary, using systematic methods.75 It is important that the relevant generator 

operator personnel receive the necessary training. Our determination is not intended to 

74 EPSA Comments at 8. 

75 See supra at P 45 & n.40. 
Docket No. RM09-25-000 - 58 - 

limit the source of that training, provided that it meets the requirements of the Reliability 

Standard. 

86. With respect to the time frame within which NERC should complete the 

unaddressed training directives, the Commission recently issued on order on NERC’s 

three year assessment.76 That order requires NERC to identify and address all Reliability 

Standards prioritization matters when submitting its annual Reliability Standard 

Development plan, beginning with the plan for 2012.77 The Commission recognizes the 

importance of a collaborative approach to setting priorities for Reliability Standard 

projects and NERC’s need for flexibility in setting project priorities in order to efficiently 

utilize the technical expertise available to NERC’s standards drafting teams. We 

anticipate that NERC will include this project in its assessment of its Reliability 

Standards priorities. With respect to the Order No. 693 directive to consider whether 

personnel that support EMS applications should be included in the training Reliability 

Standard, we accept NERC’s commitment to satisfy this directive by August 23, 2012. 

III. Information Collection Statement

87. The following collections of information contained in this proposed rule have 

been submitted to the Office of Management and Budget (OMB) for review under 

 76 North American Electric Reliability Corporation, 132 FERC ¶ 61,217 (2010). 

77 Id. P 102. 
Docket No. RM09-25-000 - 59 - 

 

section 3507(d) of the Paperwork Reduction Act of 1995.78 OMB’s regulations require 

OMB to approve certain information collection requirements imposed by agency rule.79

88. The Commission solicited comments on the need for and the purpose of the 

information contained in these two Personal Performance, Training and Qualification 

Reliability Standards and the corresponding burden to implement them. The Commission 

received comments on specific requirements in the Reliability Standards, which we 

address in this Final Rule. The Commission has not directed any modifications to the 

Requirements in the two Reliability Standards being approved. Thus, the Final Rule does 

not materially or adversely affect the burden estimates provided in the NOPR. 

89. However, the Commission received comments on our reporting burden estimates. 

Of the twenty-eight entities that filed comments on the NOPR, two entities, the ISO/RTO 

Council and Westar, comment on the record keeping burden. Both the ISO/RTO Council 

and Westar note that proposed Reliability Standard PER-005-1 includes a new 

requirement that applicable entities use a systematic approach to training which includes 

78 44 U.S.C. 3507(d). 

79 5 CFR 1320.11. 
Docket No. RM09-25-000 - 60 - 

record-keeping requirements (including a job-task-analysis) that are significantly greater 

than the Commission’s estimates provided in the NOPR. In addition, the ISO/RTO 

Council asserts that Reliability Standard PER-005-1, as submitted, more than adequately 

covers appropriate record keeping requirements. With respect to the estimate of the 

record-keeping requirements, in the NOPR, the Commission considered the inclusion of a 

systematic approach to training requirement when developing the record-keeping 

estimates. Moreover, neither commenter provides an estimate of the record-keeping 

burden. The Commission finds that the two commenters did not provide sufficient 

information to support increasing the record keeping burden estimates. With respect to 

the ISO/RTO Council’s assertion that PER-005-1, as submitted, more than adequately 

covers appropriate record keeping requirements, this issue is moot as this final rule does 

not require NERC to make any modifications to PER-005-1. 

90. Burden Estimate: The public reporting and records retention burdens for the 

proposed reporting requirements and the records retention requirement are as follows: 
Docket No. RM09-25-000 - 61 - 

Data Collection No. of New 

Respondents

No. of 

Responses 

Recordkeeping80

Hours Per 

Respondent 

Total 

Annual 

Recordkeeping 

Hours 

PER-005-1, R1.1: RCs, TOs, 

and BAs must create a list of 

bulk electric system 

reliability-related tasks 

performed by system 

operators. 

781 7 40 280 

PER-005-1, R1.2: RCs, TOs, 

and BAs shall design and 

develop learning objectives 

and training materials based 

on its task list. 

7 7 60 420 

PER-005-1, R2: RCs, TOs, 

and BAs shall verify system 

operators’ ability to perform 

each assigned task from 

applicable task list. 

7 7 80 560 

PER-005-1, M1: RCs, TOs, 

and BAs must have available 

for inspection evidence of 

using a systematic approach 

to training to establish and 

implement a training 

program. 

7 7 50 350 

PER-005-1, M1.1: Each RC, 

TO, and BA must have 

available for inspection its 

company-specific, reliabilityrelated task list. 

7 7 10 70 

 80 The proposed Reliability Standards do not impose any reporting requirements. 

81 Only seven of the 16 registered reliability coordinators are not currently subject 

to training requirements as balancing authorities. 
Docket No. RM09-25-000 - 62 - 

PER-005-1, M1.2: Each RC, 

TO, and BA must have 

available for inspection its 

learning objectives and 

training materials. 

7 7 10 70 

PER-005-1, M1.3: RCs, 

TOs, and BAs must have 

available for inspection 

system operator training 

records. 

7 7 10 70 

PER-005-1, M1.4: Each RC, 

TO, and BA must have 

available for inspection 

evidence that it performed an 

annual training program 

evaluation. 

7 7 25 175 

PER-005-1, M2: Each RC, 

TO, and BA must have 

available for inspection 

evidence that it verified that 

its system operators can 

perform each assigned task 

from the training task list. 

7 7 20 140 

PER-005-1, M3: RCs, TOs, 

and BAs must have available 

for inspection their annual 

training records evidencing 

that each system operator 

received 32 hours of 

emergency operations 

training. 

7 7 20 140 

PER-005-1, M3.1: RCs, 

TOs, and BAs must have 

available for inspection 

training records evidencing 

that each system operator 

received emergency training 

using simulation technology. 

7 7 20 140 

Total 2415 Hours 
Docket No. RM09-25-000 - 63 - 

 Total Annual hours for Collection: Recordkeeping = Total Hours. 

Information Collection Costs: Recordkeeping = 2415 hours @ $120/hour82 = $289,800. 

 Total costs = $289,800. 

 Title: Mandatory Reliability Standards for the Bulk-Power System 

 Action: Proposed Collection of Information 

 OMB Control No: 1902-0244 

 Respondents: Business or other for profit, and/or not for profit institutions. 

 Frequency of Responses: On occasion. 

 Necessity of the Information: This final rule would approve revised Reliability 

Standards that modify the existing requirement for entities to develop training programs 

and train certain personnel. The Reliability Standards require entities to maintain their 

training materials and training records subject to review by the Commission and NERC 

to ensure compliance with the Reliability Standards. 

 Internal review: The Commission has reviewed the requirements pertaining to the 

Reliability Standards for the Bulk-Power System and determined that the Requirements 

are necessary to meet the statutory provisions of the Energy Policy Act of 2005. These 

requirements conform to the Commission’s plan for efficient information collection, 

 82 This hourly rate reflects the hourly rate for engineers based on information 

provided to the Commission in Docket No. RM08-13. See Transmission Relay 

Loadability Reliability Standard, 130 FERC ¶ 61,221, at P 327 (2010) (Final Rule). 
Docket No. RM09-25-000 - 64 - 

communication and management within the energy industry. The Commission has 

assured itself, by means of internal review, that there is specific, objective support for the 

burden estimates associated with the information requirements. 

91. Interested persons may obtain information on the reporting requirements by 

contacting the following: Federal Energy Regulatory Commission, 888 First Street, NE 

Washington, DC [Attention: Ellen Brown, Office of the Executive Director, Phone: 

(202) 502-8663, fax: (202) 273-0873, e-mail: DataClearance@ferc.gov]. Comments on 

the requirements of this order may also be sent to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, Washington, DC 20503 

[Attention: Desk Officer for the Federal Energy Regulatory Commission]. For security 

reasons, comments should be sent by e-mail to OMB at oira_submission@omb.eop.gov. 

Please reference FERC-725A and the docket number of this final rule in your submission. 

IV. Environmental Analysis

92. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

on the human environment.83 The actions taken in this Final Rule fall within the 

categorical exclusion in the Commission's regulations for rules that are clarifying, 

 83 Order No. 486, Regulations Implementing the National Environmental Policy 

Act, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. Preambles 1986-1990 ¶ 30,783 

(1987). 
Docket No. RM09-25-000 - 65 - 

corrective or procedural, for information gathering, analysis, and dissemination.84 

Accordingly, neither an environmental impact statement nor environmental assessment is 

required. 

V. Regulatory Flexibility Act

93. The Regulatory Flexibility Act of 1980 (RFA)85 generally requires a description 

and analysis of final rules that will have significant economic impact on a substantial 

number of small entities. Most of the entities, i.e., reliability coordinators, transmission 

operators, and balancing authorities, to which the requirements of this rule would apply 

do not fall within the definition of small entities.86 Moreover, the proposed Reliability 

Standards reflect a continuation of existing training requirements for transmission 

operators and balancing authorities and are “new” only with respect to reliability 

coordinators. 

94. As indicated above, based on available information regarding NERC’s compliance 

registry, approximately seven entities will be responsible for compliance with proposed 

Reliability Standards PER-004-2 and PER-005-1 that were not already subject to the 

 84 18 CFR 380.4(a)(5). 

85 5 U.S.C. 601-612. 

86 The RFA definition of “small entity” refers to the definition provided in the 

Small Business Act (SBA), which defines a “small business concern” as a business that is 

independently owned and operated and that is not dominant in its field of operation. See

15 U.S.C. 632. According to the SBA, a small electric utility is defined as one that has a 

total electric output of less than four million MWh in the preceding year. 
Docket No. RM09-25-000 - 66 - 

existing Reliability Standards comprising the same base training requirements as 

contained in the new Reliability Standards. The Commission does not consider this a 

substantial number. Further, few if any of the seven reliability coordinators are small 

entities. Based on the foregoing, the Commission certifies that this Final Rule will not 

have a significant impact on a substantial number of small entities. Accordingly, no 

regulatory flexibility analysis is required. 

VI. Document Availability

95. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through FERC's Home Page 

(http://www.ferc.gov) and in FERC's Public Reference Room during normal business 

hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington DC 20426. 

96. From FERC's Home Page on the Internet, this information is available on 

eLibrary. The full text of this document is available on eLibrary in PDF and Microsoft 

Word format for viewing, printing, and/or downloading. To access this document in 

eLibrary, type the docket number excluding the last three digits of this document in the 

docket number field. 

97. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC Online Support at (202) 502-6652 (toll free at 1-866-208-
Docket No. RM09-25-000 - 67 - 

3676) or email at ferconlinesupport@ferc.gov, or the Public Reference Room at 

(202) 502-8371, TTY (202) 502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov. 

VII. Effective Date and Congressional Notification

98. These regulations are effective [insert date that is 60 days from publication in the

FEDERAL REGISTER]. The Commission notes that although the determinations 

made in this Final Rule are effective [insert date that is 60 days from publication in the

FEDERAL REGISTER], Reliability Standard PER-004-2 approved in this final rule 

will not become effective until the first day of the first calendar quarter after regulatory 

approval and that Reliability Standard PER-005-1 approved in this final rule will become 

effective on a staggered basis, as identified in Appendix B, with the earliest effective date 

being first day of the first calendar quarter after regulatory approval for PER-005-1, 

Requirement R3. The Commission has determined, with the concurrence of the 

Administrator of the Office of Information and Regulatory Affairs of OMB, that this Rule 

is not a “major rule” as defined in section 351 of the Small Business Regulatory 

Enforcement Fairness Act of 1996. 

By the Commission. 

( S E A L ) 

Nathaniel J. Davis, Sr., 

Deputy Secretary. 
Docket No. RM09-25-000 - 68 - 

Appendix A: Commenting Party Acronyms 

Abbreviation Commenter

APPA American Public Power Association 

Associated Electric Associated Electric Cooperative, Inc. 

BGE Baltimore Gas and Electric Co. 

BPA Bonneville Power Administration 

Constellation Constellation Power Source Generation, Inc., Constellation Energy 

Commodities Group, Inc., Constellation NewEnergy, Inc., and 

Constellation Energy Nuclear Group, LLC 

Dominion Dominion Resources Services, Inc. on behalf of its affiliates 

EEI Edison Electric Institute 

E.ON E.ON U.S. LLC 

EPSA Electric Power Supply Association 

GSOC & GTC Georgia System Operations Corp. and Georgia Transmission Corp. 

IESO Ontario Independent Electricity System 

ISO/RTO Council ISO/RTO Council 

ITC International Transmission Company d/b/a ITCTransmission, 

Michigan Electric Transmission Company, LLC, ITC Midwest LLC, 

and ITC Great Plains, LLC 

KCP&L Kansas City Power & Light Company and KCP&L Greater 

 Missouri Operations Company 

MidAmerican MidAmerican Energy Holdings Company 

Minnesota Power Minnesota Power 

Montana-Dakota Montana-Dakota Utilities Co. 

NRECA National Rural Electric Cooperative Assoc. 

NV Energy Nevada Power Company and Sierra Pacific Power Co. 

NERC North American Electric Reliability Corporation 

NorthWestern NorthWestern Corp d/b/a/ NorthWestern Energy 

PG&E Pacific Gas and Electric Co. 

Platte River Platte River Power Authority 

Portland Portland General Electric Co. 

SPP Southwest Power Pool, Inc. 

Westar Westar Energy, Inc. and Kansas Gas and Electric Co. 

WECC Western Electricity Coordinating Council 

Wisconsin Electric Wisconsin Electric Power Co. 
Docket No. RM09-25-000 - 69 - 

Appendix B 

Coordination of Retirement and Effective Dates Table Existing

Existing Approved

Standard

Requirement to

be retired or

replaced

Proposed

Standard

New Requirement

to be

implemented

Date for

concurrent

retirement and

implementation

PER‐002‐0  

PER‐004‐1

R1  

R2  

R3  

R3.1  

R3.2  

R3.3  

R3.4  

R3

R4

PER‐005‐1 R1  

R1.1  

R1.1.1  

R1.2  

R1.3  

R1.4  

R2  

R2.1

1st calendar

quarter 24 months

after regulatory

approval

PER‐002‐0  

PER‐004‐1

R4  

R2

PER‐005‐1 R3 1st day of 1st

calendar quarter

after regulatory

approval

PER‐004‐1 R1  

R5

PER‐004‐2 R1  

R2

1st day of 1st

calendar quarter

after regulatory

approval

N/A N/A PER‐005‐1 R3.1 1st day of 1st

calendar quarter

36 months after

regulatory

approval