131 FERC ¶ 61,254 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 C.F.R. Part 40 

Docket No. RM09-25-000 

System Personnel Training Reliability Standards 

(Issued June 17, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Proposed Rulemaking. 

SUMMARY: Pursuant to section 215 of the Federal Power Act, the Federal Energy 

Regulatory Commission (Commission) proposes to approve Reliability Standards PER005-1 (System Personnel Training) and PER-004-2 (Reliability Coordination – Staffing) 

submitted to the Commission for approval by the North American Electric Reliability 

Corporation, the Electric Reliability Organization (ERO) certified by the Commission. In 

addition, pursuant to section 215(d)(5) of the FPA, and section 39.5(f) of the 

Commission’s regulations the Commission proposes to direct the ERO to develop 

modifications to proposed Reliability Standard PER-005-1 to address certain issues 

identified by the Commission. The proposed Reliability Standards require reliability 

coordinators, balancing authorities, and transmission operators to establish a training 

program for their system operators, verify each of their system operator’s capability to 

perform tasks, and provide emergency operations training to every system operator. 

DATES: Comments are due [insert date that is 60 days after publication in the

FEDERAL REGISTER]. 
Docket No. RM09-25-000 - 2 - 

ADDRESSES: Interested persons may submit comments, identified by Docket 

No. RM09-25-000, by any of the following methods: 

 Agency Web Site: http://www.ferc.gov. Documents created electronically using 

word processing software should be filed in native applications or print-to-PDF 

format and not in a scanned format. 

 Mail/Hand Delivery. Commenters unable to file comments electronically must 

mail or hand deliver an original and 14 copies of their comments to: Federal 

Energy Regulatory Commission, Secretary of the Commission, 888 First Street, 

NE, Washington, D.C. 20426. 

FOR FURTHER INFORMATION CONTACT: 

Karin L. Larson (Legal Information) 

Office of the General Counsel 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, D.C. 20426 

(202) 502-8236 

Kenneth U. Hubona (Technical Information) 

Office of Electric Reliability 

Division of Reliability Standards 

Federal Energy Regulatory Commission 

13511 Label Lane, Suite 203 

Hagerstown, MD 21740 

(301) 665-1608 

SUPPLEMENTARY INFORMATION: 
131 FERC ¶ 61,254 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

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

NOTICE OF PROPOSED RULEMAKING 

(Issued June 17, 2010) 

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

 the Commission 

proposes to approve Reliability Standards PER-005-1 (System Personnel Training) and 

PER-004-2 (Reliability Coordination – Staffing), developed by the North American 

Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability 

Organization (ERO). The Commission proposes to direct the ERO to develop 

modifications to proposed Reliability Standard PER-005-1 to address certain issues 

identified by the Commission. The proposed Reliability Standards require reliability 

coordinators, balancing authorities, and transmission operators to establish a training 

program for their system operators, verify each of their system operator’s capability to 

perform tasks, and provide emergency operations training to each system operator. The 

Commission also proposes to approve the retirement of the currently effective Reliability 

Standards PER-002-0 (Operating Personnel Training) and PER-004-1 (Reliability 

Coordination), which are superseded by the proposed Reliability Standards PER-005-1 

and PER-004-2. 

 

1

 16 U.S.C. § 824o (2006). 
Docket No. RM09-25-000 - 2 - 

I. Background 

A. System Personnel Training and the August 14, 2003 Blackout 

2. On August 14, 2003, a blackout that began in Ohio affected significant portions of 

the Midwest and Northeast United States, and Ontario, Canada (August 14 Blackout). 

This blackout affected an area with an estimated 50 million people and 61,800 megawatts 

of electric load.2

 The subsequent investigation and report completed by the U.S.-Canada 

Power System Outage Task Force (Task Force) reviewed several previous major North 

American outages and concluded that “inadequate training of operating personnel” was 

among the factors that the August 14 Blackout had in common with previous outages.3

 

3. Specifically, the Task Force summarized that previous outage analyses 

recommended “enhanced procedures and training for operating personnel.”4

 This 

included: 

• Thorough programs and schedules for operator training and 

retraining should be vigorously administered. 

• A full-scale simulator should be made available to provide operating 

personnel with “hands-on” experience in dealing with possible 

emergency or other system conditions. 

 2 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. 

3 See Blackout Report at 107. 

4 Id. at 110. 
Docket No. RM09-25-000 - 3 - 

• Procedures and training programs for system operators should 

include anticipation, recognition, and definition of emergency 

situations. 

• Written procedures and training materials should include criteria 

that system operators can use to recognize signs of system stress and 

mitigating measures to be taken before conditions degrade into 

emergencies....5

4. The Blackout Report stated that some reliability coordinators and control area 

operators, i.e., balancing authorities, did not receive adequate training in recognizing and 

responding to system emergencies and this “training deficiency contributed to the lack of 

situational awareness and failure to declare an emergency on August 14 while operator 

intervention was still possible (before events began to occur at a speed beyond human 

control).”6

 The Blackout Report recommended “[i]mprov[ing] near-term and long-term 

training and certification requirements for operators, reliability coordinators, and operator 

support staff.”7

 The Task Force suggested that NERC require training for planning staff 

at control areas and reliability coordinators concerning power system characteristics and 

load, VAR, and voltage limits to enable them to develop rules for operating staff to 

follow.8

 In addition, the Task Force urged NERC to “require control areas and reliability 

 5 Id.

6 Id. at 157. 

7 Id. at 156, Task Force Recommendation 19. 

8 Id. at 156-157, Task Force Recommendation 19.A. 
Docket No. RM09-25-000 - 4 - 

coordinators to train grid operators, IT support personnel, and their supervisors to 

recognize and respond to abnormal automation system activity.”9

B. Section 215 of the FPA and Mandatory Reliability Standards

1. Section 215 of the FPA

5. Section 215 of the FPA requires a Commission-certified ERO to develop 

mandatory and enforceable Reliability Standards, which are subject to Commission 

review and approval. If approved, the Reliability Standards are enforced by the ERO, 

subject to Commission oversight, or by the Commission independently. 

6. In July 2006, the Commission certified NERC as the ERO.10 Concurrent with its 

2006 ERO Application, NERC submitted to the Commission a petition seeking approval 

of 107 proposed Reliability Standards, including four Personnel Performance, Training 

and Qualifications (PER) Reliability Standards. The PER group of Reliability Standards 

is intended to ensure the safe and reliable operation of the interconnected grid through the 

retention of suitably trained and qualified personnel in positions that can impact the 

reliable operation of the Bulk-Power System. 

 9 Id. at 157, Task Force Recommendation 19.B. 

10 North American Electric Reliability Corp., 116 FERC ¶ 61,062 (ERO 

Certification Order), order on reh’g & compliance, 117 FERC ¶ 61,126 (2006), aff’d sub 

nom., Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009). 
Docket No. RM09-25-000 - 5 - 

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

107 Reliability Standards filed by NERC,11 including the four PER Reliability Standards: 

PER-001-0, PER-002-0, PER-003-0, and PER-004-1.12 In addition, 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 standards that would replace the 

currently effective Reliability Standards PER-002-0 (Operating Personnel Training) and 

PER-004-1 (Reliability Coordination – Staffing). 

2. Reliability Standard PER-002-0

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

operator and balancing authority to be staffed with adequately trained operating 

personnel.13 Specifically, PER-002-0: (1) directs each transmission operator and 

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

positions that either have primary responsibility, directly or 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 

 11 Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 

Federal Register 72 Fed. Reg. 16,416 (Apr. 4, 2007), FERC Stats. & Regs. ¶ 31,242, 

order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007). 

12 Order No. 693 at P 1330-1417. 

13 Id. P 1331. 
Docket No. RM09-25-000 - 6 - 

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.14

9. 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 (SOLs), interconnection reliability operating limits (IROLs), 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 

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

operational control over a significant portion of load and generation.15 

10. 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 

 14 Reliability Standard PER-002-0. 

15 Order No. 693 at P 1393. 
Docket No. RM09-25-000 - 7 - 

of a training program required by currently effective Reliability Standard PER-002-0 and 

to consider whether personnel that support Energy Management System (EMS) 

applications should be included in mandatory training pursuant to the Reliability 

Standard.16 

3. Reliability Standard PER-004-1

11. In Order No. 693, the Commission also approved Reliability Standard 

PER-004-1.17 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. 

12. Under section 215(d)(5) of the FPA, the Commission directed NERC to develop 

modifications to currently effective Reliability Standard PER-004-1 through the 

Reliability Standards development process to: (1) include formal training requirements 

for reliability coordinators similar to those addressed under the personnel training 

Reliability Standard PER-002-0 and (2) include requirements pertaining to personnel 

credentials for reliability coordinators similar to those in PER-003-0.18 

 

(continued...) 

16 Id. P 1394. 

17 Id. P 1417. 

18 Id. P 1415, 1417. Currently effective Reliability Standard PER-003-0 requires 

transmission operators, balancing authorities and reliability coordinators to have NERC-
Docket No. RM09-25-000 - 8 - 

II. NERC Petition for Proposed Reliability Standards PER-005-1 and PER-004-2

13. In a September 30, 2009 filing (NERC Petition),19 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-002-0.20 NERC seeks to concurrently retire currently effective Reliability 

Standards PER-002-0 and PER-004-1 upon the effective date PER-004-2 and PER-005-1. 

14. 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.”21 

A. Reliability Standard PER-005-1

15. Proposed Reliability Standard PER-005-1 has the stated purpose of ensuring that 

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

 

certified staff for all operating positions that have a primary responsibility for real-time 

operations or are directly responsible for complying with the Reliability Standards. Id. at 

1395.

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

of Proposed Reliability Standards Regarding System Personnel Training (NERC 

Petition). 

20 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. 

21 NERC Petition at 5. 
Docket No. RM09-25-000 - 9 - 

bulk electric system are competent to perform those reliability-related tasks.22 The 

proposed Reliability Standard applies to reliability coordinators, balancing authorities and 

transmission operators. Reliability Standard PER-005-1 contains three requirements, 

which NERC describes as follows: 

 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. 

 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.23

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

23 NERC Petition at 8-9. 
Docket No. RM09-25-000 - 10 - 

NERC states that PER-005-1 is a new Reliability Standard that supersedes all of currently 

effective Reliability Standard PER-002-0 and supersedes Requirements R2, R3, and R4 

of currently effective Reliability Standard PER-004-1. 

16. According to NERC, proposed Reliability Standard PER-005-1 “marks a 

significant milestone toward achieving FERC priorities as articulated in Order No. 693,” 

but acknowledges that it does not satisfy all of the directives set forth in Order No. 693.24 

Specifically, NERC recognizes that proposed Reliability Standard PER-005-1 does not 

establish training obligations for generator operators and various operations support 

personnel as required by Order No. 693, stating that “these will be addressed in a 

subsequent development effort as described in the Reliability Standards Development 

Plan: 2009-2011.”25

B. Reliability Standard PER-004-2

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

Requirements R2, R3, and R4. According to NERC, more detailed and less ambiguous 

requirements addressing the same issues set forth in currently effective Reliability 

Standard PER-004-1 Requirements R2, R3, and R4 are now included in proposed PER005-1. Proposed Reliability Standard PER-004-2 simply carries forward, unchanged, the 

remaining requirements from currently effective PER-004-1, including the associated 

 24 Id. at 7. 

25 Id.
Docket No. RM09-25-000 - 11 - 

violation risk factor and violation severity level assignments. NERC states that 

Requirement R2 of currently effective PER-004-1, which requires reliability coordinator 

operating personnel to complete a minimum of five days per year of training and drills 

using realistic simulations of system emergencies, is now addressed in proposed 

Reliability Standards PER-005-1, Requirement R3. According to NERC, Requirements 

R3 and R4 of currently effective PER-004-1, which mandate reliability coordinator 

operating personnel to have an extensive understanding of its reliability coordinator area 

and other operators within that area, are now addressed in proposed Reliability Standard 

PER-005-1, Requirements R1 and R2. 

III. Discussion

18. We agree with NERC that the proposed Reliability Standards PER-005-1 and 

PER-004-2 comply with many of the requirements in Order No. 693 and represent an 

improvement in training requirements. Accordingly, pursuant to section 215(d)(2) of the 

FPA, the Commission proposes to approve Reliability Standards PER-005-1 and PER004-2, as just, reasonable, not unduly discriminatory or preferential, and in the public 

interest. In addition, pursuant to section 215(d)(5) of the FPA, the Commission proposes 

to direct the ERO to develop modifications to proposed Reliability Standard PER-005-1 

to address certain issues identified by the Commission. 

19. It appears that the proposed Reliability Standards adequately address a number of 

the directed modifications set forth in Order No. 693 regarding the PER Reliability 

Standards. For example, it appears that proposed Reliability Standard PER-005-1 

adequately addresses the following Order No. 693 directives: (1) identify the 
Docket No. RM09-25-000 - 12 - 

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 section to include reliability coordinators; (4) incorporate a 

Systematic Approach to Training methodology in the development of training programs; 

and (5) incorporate simulator training into the standard. 

20. Personnel training is important to ensuring the reliability of the Bulk-Power 

System, as recognized in Order No. 693 and the Blackout Report.26 The ERO has 

proposed changes to the training standard on many issues, including: (1) the Systematic 

Approach to Training, (2) tailoring training for each job function, and (3) simulation 

training. In several of these areas, the Commission is seeking clarification from the ERO 

or industry comment on specific matters and proposes improvements that can be made to 

further enhance operator training. Further, we propose to direct the ERO to modify PER005-1 to explicitly address training for local control center personnel, as required by 

Order No. 693. Each of these matters is discussed below. 

21. The Commission also seeks comment on the feasibility of the proposed effective 

dates and retirement dates proposed by NERC. Additionally, the Commission proposes 

to defer review of the violation risk factor and violation severity level assignments for 

proposed Reliability Standards PER-005-1 and PER-004-2. 

 26 Blackout Report at 156. 
Docket No. RM09-25-000 - 13 - 

22. Finally, as acknowledged by NERC, certain of the directives from Order No. 693 

related to the currently effective Reliability Standard PER-002-0 are not addressed in 

proposed Reliability Standard PER-005-1. Thus, the Commission seeks comment on the 

timeframe for the ERO to modify PER-005-1 to fully respond to the Commission’s 

directives in Order No. 693 regarding expanding the applicability of the training 

requirements. 

A. Systematic Approach to Training

23. In Order No. 693, the Commission directed NERC to develop modifications to 

currently effective Reliability Standard PER-002-0 to use a Systematic Approach to 

Training methodology for developing new training programs.27 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. To 

achieve training results, Systematic Approach to Training objectives include: 

management and administration of training and qualification programs; development and 

qualification of training staff; trainee entry-level requirements; determination of training 

program content; design and development of training programs; conduct of training; 

trainee examinations and evaluations; and training program evaluation.

24. NERC states that proposed Reliability Standard PER-005-1, Requirement R1 

satisfies this directive as it requires each reliability coordinator, balancing authority, and 

 27 Order No. 693 at P 1382. 
Docket No. RM09-25-000 - 14 - 

transmission operator to use a Systematic Approach to Training to establish companyspecific, reliability-related tasks performed by its system operators. Specifically, 

Requirement R1 provides that “each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall use a systematic approach to training to establish a training 

program. . . .”28 

Commission Proposal

25. Based on the Commission’s understanding of Systematic Approach to Training, 

we agree with NERC that proposed Reliability Standard PER-005-1, Requirement R1 

meets the Commission’s directive to “develop a modification to PER-002-2 (or a new 

Reliability Standard) that uses the SAT methodology.” 29 Requirement R1 and the 

corresponding sub-requirements mandate that each reliability coordinator, balancing 

authority, and transmission operator use a Systematic Approach to Training to establish 

its training program. Thus, NERC appears to have complied with the Order No. 693 

directive to adopt a Systematic Approach to Training. 

26. However, the generic reference to Systematic Approach to Training contained in 

proposed PER-005-1, Requirement R1 raises the question whether certain Order No. 693 

directives and whether 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 

 28 See NERC Petition at Exhibit A, PER-005-1, R1. 

29 See Order No. 693 at P 1380. 
Docket No. RM09-25-000 - 15 - 

be retired, are fully and adequately captured under the Systematic Approach to Training 

umbrella. The Commission questions whether the following three, currently effective 

training requirements 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. As discussed in detail below, we seek comment on our 

understanding of the carryover of these three currently enforceable compliance 

obligations. 

1. Understanding of Reliability Coordinator Area

27. Requirements R3 and R4 of currently effective PER-004-1 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 . . . .”30 NERC 

states that these two requirements are supplanted by and are addressed more fully in 

proposed Reliability Standard PER-005-1, Requirements R1 and R2.31 Requirements R1 

and R2 of proposed Reliability Standard PER-005-1 state: 

 30 Currently effective Reliability Standard PER-004-1, available at 

http://www.nerc.com/files/PER-004-1.pdf. 

31 NERC Petition at 26 (stating that PER-004-001, Requirements R3 and R4 

are removed because they are more fully addressed by Requirements R1 and R2 of 

PER-005-1). 
Docket No. RM09-25-000 - 16 - 

R1. Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall use a systematic approach to 

training to establish a training program for the BES companyspecific reliability-related tasks performed by its System 

Operators and shall implement the program. 

R1.1. Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall create a list of BES companyspecific reliability-related tasks performed by its System 

Operators. 

R1.1.1. Each Reliability Coordinator, Balancing Authority 

and Transmission Operator shall update its list of BES 

company-specific reliability-related tasks performed by its 

System Operators each calendar year to identify new or 

modified tasks for inclusion in training. 

R1.2. Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall design and develop learning 

objectives and training materials based on the task list created 

in R1.1. 

R1.3 Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall deliver the training established in 

R1.2. 

R1.4. Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall conduct an annual evaluation of 

the training program established in R1, to identify any needed 

changes to the training program and shall implement the 

changes identified. 

R2. Each Reliability Coordinator, Balancing Authority and 

Transmission Operator shall verify each of its System 

Operator’s capabilities to perform each assigned task 

identified in R1.1 at least one time. 

28. The text from currently effective Reliability Standard PER-004-1, Requirements 

R3 and R4 requiring reliability coordinator operating personnel to have a comprehensive 

understanding of the reliability coordinator area, is not explicitly restated in proposed 

PER-005-1, Requirements R1 and R2. NERC states that Requirements R3 and R4 of 
Docket No. RM09-25-000 - 17 - 

currently effective Reliability Standard PER-004-1 are removed “because they are more 

fully addressed by Requirements R1 and R2 of PER-005-1.”32 NERC’s statement 

implies that Requirements R1 and R2 of proposed Reliability Standard PER-005-1 retain 

an obligation for reliability coordinator operating personnel to have a comprehensive 

understanding of the reliability coordinator area and interactions with neighboring 

reliability coordinator areas, and entities that fail to do so could be subject to an 

enforcement action. However, this is not clear from either the proposed Reliability 

Standard or from NERC’s petition. Thus, the Commission seeks an explanation from 

NERC, and comment from the general public, whether “a comprehensive understanding 

of the reliability coordinator area” is an enforceable requirement under proposed 

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

explicit. 

2. Continual Training

29. The 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.” NERC states that the requirements of PER-002-0 “have been completely 

replaced and supplanted by the specific provision of proposed new Reliability Standard 

 32 Id.
Docket No. RM09-25-000 - 18 - 

PER-005-1.”33 NERC’s statement implies that the Systematic Approach to Training 

requirements set forth in proposed PER-005-1 retains an obligation of continuing 

training, and entities that fail to do so could be subject to an enforcement action. The 

Commission seeks 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. 

3. Training Staff Identity and Competency

30. Similarly, 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.” Since this requirement is not explicitly provided in PER-005-1, we seek 

clarification as to how and whether the Systematic Approach to Training requires training 

staff to be identified, and, if not, the mechanism by which training staff will be identified 

and its competency ensured. The Commission also seeks comment whether this should 

be made explicit so that entities clearly understand their compliance obligations. 

B. Training Expectations for Each Job Function/ Tailored Training

31. In Order No. 693, the Commission directed NERC to develop a modification to 

currently effective Reliability Standard PER-002-0 that identifies the expectations of the 

training for each job function and develops training programs tailored to each job 

 33 Id. at 27. 
Docket No. RM09-25-000 - 19 - 

function with consideration of the individual training needs of the personnel. 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.”34 

Commission Proposal

32. The Commission believes that NERC has complied with our 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 the personnel. 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.35 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 each job function with consideration of the individual training needs of the personnel. 

 34 Id. at 27 (quoting proposed Reliability Standard PER-005-1, Requirement R1.2). 

35 U.S. Department of Energy’s Standard, DOE-STD-1070, Guidelines for 

Evaluation of Nuclear Facility Training Programs at Appendix – Objectives and Criteria, 

Objective 3 (June 1994), available at 

http://www.hss.energy.gov/nuclearsafety/ns/techstds/standard/std1070/std1070.html. 
Docket No. RM09-25-000 - 20 - 

We also understand 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 operator. We seek comment on this 

understanding. 

C. Simulation Training 

33. 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.36 The Commission acknowledged concerns regarding the high cost to 

develop and maintain full-scale simulators, and took them into consideration. We stated 

that we did not require that entities must develop and maintain full-scale simulators, but 

rather they should have access to training on simulators. Further, because the cost is 

likely to outweigh the reliability benefits for small entities, the Commission stated that 

small entities should continue to use training aids such as generic operator training 

simulators and realistic table-top exercises. Therefore, the Commission directed the ERO 

to develop a requirement for the use of simulators dependent on an entity’s role and size. 

34. NERC explains that because “the implementation cost of a full-fledged systemspecific simulator can be significant . . . the use of a simulator is only required for entities 

managing facilities having a significant impact on the bulk power system (Requirement 

 36 Order No. 693 at P 1390-91. 
Docket No. RM09-25-000 - 21 - 

R3.1). . . .”37 Thus, NERC states that proposed PER-005-1, Requirement R3.1 satisfies 

this directive as it requires: 

Each Reliability Coordinator, Balancing Authority and 

Transmission Operator that has operational authority or 

control over Facilities with established IROLs or has 

established operating guides or protection systems to mitigate 

IROL violations shall provide each System Operator with 

emergency operations training using simulation technology 

such as a simulator, virtual technology, or other technology 

that replicates the operational behavior of the BES during 

normal and emergency conditions.38

Commission Proposal

35. As required in Order No. 693, proposed Reliability Standard PER-005-1 requires 

the use of simulator training. It appears that proposed PER-005-1, Requirement R3.1 

would enhance the existing requirements governing simulation training by providing 

operating personnel with hands-on simulation training experience in dealing with 

possible emergencies or other system conditions. In addition, the proposed Reliability 

Standard appears to take into account the size of the entity, as allowed by Order No. 693, 

by requiring such training only for entities which have operational authority or control 

over facilities with established IROLs or have established operating guides or protection 

systems to mitigate IROL violations. 

 37 NERC Petition at 17. 

38 Id. at 32. 
Docket No. RM09-25-000 - 22 - 

36. However, we ask for clarification from NERC concerning the simulation 

requirement. The Blackout Report found that some reliability coordinators and control 

area operators had not received adequate system emergency training, that “[m]ost notable 

was the lack of realistic simulations and drills to train and verify the capabilities of 

operating personnel,” and that this training deficiency contributed to the lack of 

situational awareness and failure to declare an emergency while operator intervention 

was still possible.39 Requirement R3.1 requires the simulation technology to “replicate[] 

the operational behavior of the [bulk electric system] during normal and emergency 

conditions.” By requiring the technology to replicate the operational behavior of the 

Bulk-Power System, it appears that this provision requires the use of simulators specific 

to an operator’s own system. We ask NERC for clarification on this issue. We also ask 

for comments on this provision from other interested persons. 

37. The Commission believes that system-customized simulator training would further 

the Blackout Report goal of providing “realistic simulations.” Because each system is 

topologically unique,40 training on a simulator specific to one’s own system (“custom 

simulation”) would necessarily better prepare an operator on that system than generic 

 39 Blackout Report at 157 (emphasis added). 

40 The properties of each system are unique, properties such as the location and 

capabilities of generator units and capacitor banks, typical transmission line loadings, 

location and function of special protection systems, if any, normal substation 

configuration, and other elements. The interaction of these elements impact an operator’s 

options in an emergency. 
Docket No. RM09-25-000 - 23 - 

simulation training. Custom simulation is considered to be highly effective because it 

provides trainees with realistic and relevant contexts in which to test and develop their 

understanding, knowledge and competence. An advantage of custom simulation is that it 

trains operators on specific control strategies for their own system. In other words, it 

would allow the system operator to better understand how his actions and reactions will 

affect the particular assets and environment in which the operator works. In short, 

simulation training that utilizes an environment that resembles the expected system 

conditions during emergency, results in more effective troubleshooting during 

emergencies as it better prepares the operators to identify changes and symptoms, 

correctly locate the problem, and take necessary action to fix the problem. While a more 

generic simulator can teach the skills needed for operating a power system and 

responding to emergency conditions, it does not familiarize the operator with the 

specifics of his system and how that system responds to specific events that give rise to 

emergencies. Greater knowledge of and experience in dealing with the specific system 

give the operator a more solid grasp of the behavior of that system and a feel for its 

response to various conditions and, therefore, better prepare the operator to deal with 

emergencies on that system. 

38. Some entities may currently use vendor-provided emergency system simulator 

training to provide operating personnel with “hands-on” training experience. In some 

instances the emergency conditions embedded in the vendor training programs may not 

be specific to the entity’s own system and operations. In Order No. 693, the 

Commission, citing commenters’ concerns regarding the high cost to develop and 
Docket No. RM09-25-000 - 24 - 

maintain full-scale simulators, concluded that the directive does not mean that entities 

subject to the simulation training requirement must develop and maintain full-scale 

simulators but rather they should have access to training on simulators.41 As such, we 

would not expect an entity to necessarily use a simulator that replicates its own hardware, 

but we believe that there may be other tools that would allow an entity to input its own 

system files to a vendor simulator so the vendor simulator would run that entity’s 

system’s power flows over a range of operating conditions and test operator response. 

39. Therefore, we seek comment on whether the Reliability Standard should require 

the simulation technology to realistically replicate an entity’s own topology and operating 

conditions. If the proposed language, “replicates the operational behavior of the [bulk 

electric system],” contemplates use of simulators not specific to one’s own system, we 

ask 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. For 

example, we seek comment on whether training on simulators that replicate a different 

system provide operating personnel emergency system training with sufficiently realistic 

simulations to enable them to act in an actual emergency. We seek comment on the 

feasibility and practicality (including cost considerations) of requiring use of simulation 

technology that realistically replicates the entity’s own topology and operating 

conditions. 

 41 Order No. 693 at P 1390-91. 
Docket No. RM09-25-000 - 25 - 

D. Local Transmission Control Center Operator Personnel 

40. In Order No. 693, the Commission directed NERC to modify currently effective 

Reliability Standard PER-002-0 to include formal training for local transmission control 

center operating personnel.42 Specifically, the Commission concluded that “[w]hile 

PER-002-0 applies to transmission operators, it is important for reliability that personnel 

involved in decision making and implementation receive proper training.”43 Because 

local transmission control center personnel are responsible for implementing instructions 

that affect the reliability of the Bulk-Power System, we directed the ERO to modify 

PER-002-0 to include training for such personnel tailored to the needs of the positions. 

41. Proposed Reliability Standard PER-005-1 does not explicitly include a 

requirement that covers formal training for local transmission control center operator 

personnel. NERC’s Petition states that the NERC Reliability Functional Model 

accurately captures the list of functions that a Transmission Operator performs, and 

therefore includes those performed by local control center personnel. NERC concludes 

that, if all entities are properly registered in the NERC Compliance Registry, the 

Commission’s directive to include formal training for local transmission control center 

operator personnel “will be appropriately addressed because the Transmission Operator 

 42 Id. P 1343. 

43 Id. P 1342. 
Docket No. RM09-25-000 - 26 - 

has the ultimate responsibility to ensure that its functional responsibilities are met, even if 

through other entities.”44 

Commission Proposal

42. The Commission is concerned with NERC’s conclusion that local transmission 

control center personnel will receive training because this conclusion relies on the 

transmission operator requiring training for another entity’s personnel. Moreover, 

NERC’s response to this directive reasserts the same arguments we rejected in Order 

No. 693: 

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.45 

Thus the Commission concluded: 

Whether the RTO or the local control center is ultimately 

responsible for compliance is a separate issue . . ., regardless 

of which entity registers for that responsibility, these local 

control center employees must receive formal training 

consistent with their roles, responsibilities and tasks.46 

 44 NERC Petition at 30. 

45 Order No. 693 at P 1347. 

46 Id. P 1343 (emphasis added). 
Docket No. RM09-25-000 - 27 - 

Simply put, the Commission already rejected the concept of relying on the transmission 

operator’s obligation to train its personnel to ensure that local transmission control center 

operator personnel receive training. The Commission’s objective, as stated in Order 

No. 693, is to ensure that there are no gaps in responsibility for providing formal training 

to local transmission control center employees. Sub-requirement R1.1 of the proposed 

Reliability Standard PER-005-1 states that each “Transmission Operator shall ... 

establish a training program for the BES company-specific ... tasks performed by its 

System Operators and shall implement the program.”47 The language of this subrequirement provides that the Transmission Operator is only required to implement a 

training program for operators within its company. It is unclear to the Commission how 

the Transmission Operator could then require a local control center operator to receive 

training, particularly if that operator is within another entity, as suggested by NERC. A 

clear statement in the proposed Reliability Standard that incorporates local transmission 

control center operator personnel would satisfy the Commission’s directive. We propose 

to direct NERC to modify proposed Reliability Standard PER-005-1 to include a 

provision that explicitly addresses training for local transmission control center 

personnel, consistent with the Commission’s directive in Order No. 693. 

 47 Proposed Reliability Standard PER-005-1, Requirement R1.1 (emphasis added). 
Docket No. RM09-25-000 - 28 - 

E. Performance Metrics

43. In Order No. 693, the Commission directed NERC to determine “whether it is 

feasible to develop meaningful performance metrics associated with the effectiveness of a 

training program..., and if so, develop such performance metrics.”48 In response, NERC 

states that the Systematic Approach to Training methodology, as set forth in proposed 

Reliability Standard PER-005-1, sub-requirement 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 concludes that this “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.”49 NERC also states 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. 

 48 Order No. 693 at P 1394. Generally, performance metrics are a system of 

parameters or means of quantitative and periodic assessment of a process that is to be 

measured. See e.g., NERC Staff White Paper, Toward Ensuring Reliability: Reliability 

Performance Metrics (December 2007). 

49 NERC Petition at 33-34. 
Docket No. RM09-25-000 - 29 - 

Commission Proposal

44. Order No. 693 did not specifically require NERC to provide metrics for the 

training standard, but required NERC to explore the feasibility of developing meaningful 

metrics for assessing the effectiveness of training programs. As a part of this directive, 

we stated that metrics could be used to “continually improve an applicable entity’s 

performance and the Reliability Standard itself.”50 The Commission is encouraged that 

the proposed Reliability Standard includes a requirement for each applicable entity to 

annually evaluate its training program to identify and implement needed changes. This is 

an important part of keeping each individual training programs current, and an 

improvement over the currently effective reliability standard. We agree with NERC that 

this provides a meaningful assessment of the training program. 

45. However, the Commission also stated that “if quantifiable performance metrics 

can be developed to gauge the effectiveness of a Reliability Standard, these performance 

metrics should be developed.”51 While NERC evaluated whether metrics were needed to 

assess each individual program, we are not satisfied that NERC evaluated whether 

performance metrics could be devised to evaluate the Reliability Standard. While NERC 

states that “[a]n evaluation of how System Operators perform during infrequent, actual 

 50 Order No. 693 at P 1379. 

51 Id. (emphasis added). 
Docket No. RM09-25-000 - 30 - 

events on the system would not provide useful metrics on an ongoing basis,”52 it provides 

no explanation of this statement. The Commission questions whether metrics could be 

developed to establish specific parameters and measurements that would allow, among 

other things, the monitoring of trends and the comparison of performance across entities. 

Further, the Commission believes that meaningful performance metrics could include a 

global metric that could be used to compare the competency of system operators to 

perform reliability-related tasks from one entity to another in order to assess whether a 

particular entity’s training program is producing adequately trained personnel. In 

addition, the results from such a metric could be used to identify areas in which a 

particular reliability requirement may need to be improved. These objectives go beyond 

the annual evaluation set forth in proposed Reliability Standard PER-005-1, subrequirement R1.4, and NERC has not provided an explanation of whether it has evaluated 

whether such metrics are feasible. 

46. NERC suggests that an evaluation of how system operators perform during 

infrequent, actual events on the system would not provide a useful metric. While actual 

system disturbances that result in significant operating events such as IROL violations or 

loss of load may not be frequent, contingencies, frequency decline, overloaded 

transmission lines and voltage excursions, among other operating events, occur regularly 

and actions to mitigate these circumstances are what prevent more significant 

 52 NERC Petition at 33-34. 
Docket No. RM09-25-000 - 31 - 

disturbances. Operator actions with regard to these more regular events seem noteworthy 

and may provide indicators of the effectiveness of training programs. 

47. We seek comment from NERC on whether it considered metrics to evaluate the 

effectiveness of the Reliability Standard, in addition to its consideration of metrics to 

evaluate the effectiveness of an individual entity’s training program. In addition, we seek 

comment on possible performance metrics that could be used to assess whether proposed 

Reliability Standard PER-005-1 achieves its stated purpose “[t]o ensure that System 

Operators performing real-time, reliability-related tasks on the North American Bulk 

Electric System ... are competent to perform those reliability-related tasks.” 

Accordingly, we propose to direct that the ERO evaluate the feasibility of developing 

meaningful performance metrics to evaluate the effectiveness of the Reliability Standard 

related to operator training. 

F. Effective and Retirement Dates

48. With respect to proposed Reliability Standard PER-005-1, NERC proposes 

staggered effective dates, i.e., the mandatory compliance date after an allotted 

implementation period, for each of the standard’s requirements and sub-requirements. 

Specifically, NERC proposes: compliance with PER-005-1, Requirements R1 and R2 

would be mandatory on the first day of the first calendar quarter, 24 months after 

regulatory approval; compliance with Requirement R3 would be mandatory on the first 

day of the first calendar quarter after regulatory approval; and compliance with subrequirement R3.1 would be mandatory on the first day of the first calendar quarter 

36 months after regulatory approval. NERC proposes to retire currently effective 
Docket No. RM09-25-000 - 32 - 

PER-002-0 because the PER-002-0 requirements will be superseded by proposed 

PER-005-1. Thus NERC states that retirement of PER-002-0 is necessary to avoid 

redundancy, conflict, and confusion regarding the mandatory training standards. 

Notwithstanding the proposed staggered effective dates of the requirements in 

PER-005-1, NERC proposes to retire PER-002-0 upon the “effective date of 

PER-005-1.”53 

49. With respect to proposed Reliability Standard PER-004-2, the proposed effective 

date section set forth in proposed Reliability Standard PER-004-2 states: 

Effective Date: 

● Retire Requirement 2 when PER-005-1 Requirement 3 

becomes effective. 

● Retire Requirements 3 and 4 when PER-005-1 

Requirements 1 and 2 become effective. 

NERC’s Petition states that it seeks Commission approval to retire existing Reliability 

Standard PER-004-1 upon the effective date of proposed Reliability Standard PER-004-2 

and PER-005-1.54

 Commission Proposal 

50. The Commission is concerned that the proposed effective and retirement dates 

may not be appropriate. The Commission previously has approved the use of staggered 

effective dates in conjunction with new Reliability Standards. However, in this case, 

 53 Id. at 27 and 42. 

54 Id. at 1 and 42. 
Docket No. RM09-25-000 - 33 - 

where the proposed Reliability Standards modify currently effective standards, we are 

concerned that a staggered effective date may create a gap in compliance and 

enforceability. 

51. NERC states that proposed Reliability Standard PER-005-1 is intended to 

supersede existing Reliability Standard PER-002-0 “upon the effective date of 

PER-005-1.” First, it is not clear whether NERC intended that PER-002-0 be retired 

when the first requirement in PER-005-1 becomes effective, or when all requirements in 

PER-005-1 become effective. If PER-002-0 is retired when only certain requirements are 

effective in PER-005-1, the Commission is concerned that this may create a gap in 

training requirements as NERC proposes to make the various requirements in PER-005-1 

mandatory and enforceable in three stages over a three year period. We seek an 

explanation from NERC on whether its proposed effective date for PER-005-1 and 

retirement date for PER-002-0 will create a gap in compliance and further seek comment 

on alternative approaches to avoid any such gap. If NERC intends for PER-002-0 to be 

retired after all of PER-005-1’s requirements are in effect, the Commission is concerned 

that this may result in overlapping and potentially conflicting requirements that could 

unintentionally introduce confusion in compliance expectations during certain 

timeframes. We also request industry comment on the length of the lead-time before the 

various requirements in PER-005-1 become mandatory and enforceable, which, as 

currently proposed, is as long as three years and, more specifically, comment on the need 

for the proposed two- and three- year lead-times. 
Docket No. RM09-25-000 - 34 - 

52. With respect to proposed Reliability Standard PER-004-2 and the retirement of 

currently effective PER-004-1, as the Commission understands the text in proposed 

Reliability Standard PER-004-2, NERC proposes to retire Requirements R2, R3, and R4 

of currently effective Reliability Standard PER-004-1 concurrent with the dates the 

related requirements in proposed PER-005-1 become effective.55 In other words, NERC 

proposes to stagger the retirement of currently effective PER-004-1. The Commission 

seeks comment on the feasibility of using a staggered retirement date as well as possible 

alternative approaches. 

G. Violation Risk Factors/Violation Severity Levels

53. To determine a base penalty amount for a violation of a requirement within a 

Reliability Standard, NERC must first determine an initial range for the base penalty 

amount. To do so, NERC assigns a violation risk factor to each requirement and subrequirement of a Reliability Standard that relates to the expected or potential impact of a 

violation of the requirement on the reliability of the Bulk-Power System. NERC may 

propose either a lower, medium or high violation risk factor for each mandatory 

 55 The effective date language in proposed PER-004-2 is not clear. The 

Commission read the language with the assumption that the reference to “Requirement 2” 

in the text “Retire Requirement 2 upon the effective date of PER-005-1 Requirement 3” 

refers to Requirement 2 of PER-004-1. 
Docket No. RM09-25-000 - 35 - 

Reliability Standard requirement.56 The Commission has established guidelines for 

evaluating the validity of each violation risk factor assignment.57 

54. NERC also will assign each requirement and sub-requirement one of four 

violation severity levels – low, moderate, high, and severe – as measurements for the 

degree to which the requirement was violated in a specific circumstance. On June 19, 

2008, the Commission issued an order establishing four guidelines for the development 

of violation severity levels.58 

55. With respect to proposed Reliability Standard PER-005-1, NERC proposes to 

assign violation risk factors only to the main requirements and did not propose violation 

risk factors for any of the sub-requirements.59 NERC assigns Requirement R1 a 

 

(continued...) 

56 The specific definitions of high, medium and lower are provided in North 

American Electric Reliability Corp., 119 FERC ¶ 61,145, at P 9 (2007), order on reh’g, 

120 FERC ¶ 61,145 (2007) (Violation Risk Factor Rehearing Order). 

57 See Violation Risk Factor Rehearing Order, 120 FERC ¶ 61,145 at P 8-13. 

The guidelines are: (1) consistency with the conclusions of the Blackout Report; 

(2) consistency within a Reliability Standard; (3) consistency among Reliability 

Standards; (4) consistency with NERC’s definition of the violation risk factor level; and 

(5) treatment of requirements that co-mingle more than one obligation. 

58 North American Electric Reliability Corp., 123 FERC ¶ 61,284, at P 20-35 

(2008) (Violation Severity Level Order), order on reh’g & compliance, 125 FERC 

¶ 61,212 (2008). The guidelines provide that violation severity level assignments should: 

(1) not lower the current level of compliance; (2) ensure uniformity and consistency in 

the determination of penalties; (3) be consistent with the corresponding requirement; and 

(4) be based on a single violation. 

59 We note that in Version Two Facilities Design, Connections and Maintenance 

Reliability Standards, Order No. 722, 126 FERC ¶ 61,255, at P 45 (2009), the ERO 

proposed to develop violation risk factors and violation severity levels for Requirements 
Docket No. RM09-25-000 - 36 - 

“medium” violation risk factor, Requirement R2 a “high” violation risk factor, and 

Requirement R3 a “medium” violation risk factor. The NERC Petition proposes 

violation severity levels for Requirements R1, R2, and R3 of proposed Reliability 

Standard PER-005-1. NERC did not propose violation severity levels for any of the subrequirements. With respect to proposed Reliability Standard PER-004-2, NERC proposes 

to carry forward the violation risk factors and violation severity levels currently assigned 

to the existing Reliability Standard PER-004-1. NERC requests approval for the 

proposed violation risk factors and violation severity levels subject to the outcome of the 

proceedings in Docket Nos. RR08-4-000 and related sub-dockets.60 

Commission Proposal 

56. In its March 5, 2010 filing in Docket No. RR08-4-005, NERC incorporated by 

reference its informational filing submitted in response to Version Two Facilities Design, 

Connections and Maintenance Reliability Standards, Order No. 722, 126 FERC ¶ 61,255, 

at P 45 (2009), in which NERC proposed the novel approach of assigning violation risk 

factors and violation severity levels only to a Reliability Standard’s Requirements, but 

not the sub-requirements. Because the violation risk factors and violation severity levels 

 

but not sub-requirements. The Commission denied the proposal as “premature” and, 

instead, encouraged the ERO to “develop a new and comprehensive approach that would 

better facilitate the assignment of violation severity levels and violation risk factors.” As 

directed, on March 5, 2010, NERC submitted a comprehensive approach that is currently 

pending with the Commission in Docket No. RR08-4-005. 

60 NERC Petition at 42. 
Docket No. RM09-25-000 - 37 - 

for both proposed Reliability Standard PER-005-1 and PER-004-2 are impacted by the 

NERC’s pending petition, we propose to defer discussion on the proposed violation risk 

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

act on the ERO’s petition in Docket No. RR08-4-005. 

H. Unaddressed Directives 

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

currently effective 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 SOLs, 

IROLs or operating nomograms for real-time operations.61 The Commission also 

directed the ERO, in part, to consider “whether personnel that support [Energy 

Management System] applications ... should be included in mandatory training”62

requirements set forth in Reliability Standard PER-002-0. 

58. In Order No. 693, with regard to the directive to expand the applicability of the 

training requirements in currently effective PER-002-0 to include generator operators, the 

Commission stated, “it is essential that generator operator personnel have appropriate 

 61 Order No. 693 at P 1393. 

62 Id. P 1394. 
Docket No. RM09-25-000 - 38 - 

training.”63 The Commission further noted that in 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. Thus, we directed the ERO to modify 

currently effective Reliability Standard PER-002-0 to apply to generator operators.64 

59. With regard to the directive to expand the applicability of the training 

requirements in currently effective PER-002-0 to include operations planning and 

operations support staff, the Commission directed the ERO to modify currently effective 

Reliability Standard PER-002-0 to apply to operations planning and support staff 

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 nomograms in accordance with Reliability Standards IRO-005-1 and 

TOP-004-0.65

60. With regard to the directive to consider Energy Management System (EMS) 

support personnel, the Commission noted that EMS support personnel can also have an 

impact on the reliable operation of the Bulk-Power System. These are the personnel 

responsible for ensuring that critical EMS reliability applications, such as state 

estimation, contingency analysis and alarm processing packages, are available, contain 

 63 Id. P 1359. 

64 Id. 

65 Id. P 1372 (citations omitted). 
Docket No. RM09-25-000 - 39 - 

up-to-date system data and produce useable results. Because the impact of these 

employees upon Reliable Operation is not as clear, we directed the ERO to consider, 

through the Reliability Standards development process, whether personnel that perform 

these additional functions should be included in mandatory training pursuant to 

PER-002-0.66

61. In response to these Order No. 693 directives, NERC acknowledges that proposed 

Reliability Standard PER-005-1 does not establish training obligations for generator 

operators and operations planning and operations support staff.67 Also, NERC 

recognizes that it did not address the Order No. 693 directives related to EMS support 

personnel.68 

62. NERC states that it omitted generator operators,69 operations planning, and 

operations support staff from the scope of the development of proposed Reliability 

Standard PER-005-1 because the inclusion of those personnel would have required an 

expansion of the standard drafting team roster to ensure that those disciplines were fair

represented on the drafting team.

ly 

 

70 NERC states that it instead chose to complete the 

66 Id. P 1373. 

67 NERC Petition at 30. 

68 Id. at 34. 

69 NERC’s Petition actually references generator “owners” which appears to be a 

typographical error. 

70 NERC Petition at 30. 
Docket No. RM09-25-000 - 40 - 

core activities it identified in the project scope rather than delay the completion with an 

enlarged scope. Accordingly, NERC states that it plans to address the expansion of

training standard (PER-005-1) in a subsequent drafting project, Project 2010-01

Support Personnel Training.

 the 

 – 

t 

personnel into the tra t 2010-01 – Support Personnel Training. 

71 Likewise, NERC also states that it has deferred 

compliance with the Commission’s directives to consider the inclusion of EMS suppor

ining standard to Projec

Commission Proposal

63. NERC is continuing to work to expand applicability of proposed Reliabilit

Standard PER-005-1 to include generator operators and operations planning and 

operations support staff, as required in Order No. 693. We appreciate that NERC felt that 

the inclusion of generator owners, operations planning, and operations support staff in

standards proposed here would have necessitated expansion of the Standard Drafting 

Team roster to ensure these disciplines were fairly represente

y 

 the 

d and that this would have 

rt staff 

 

 

delayed the completion of this important set of standards. 

64. With respect to operations planning and operations support staff, the Commission

stated that PER-002-0 should apply to operations planning and operations suppo

that have a direct impact on the reliable operation of the Bulk-Power System.72

71 Id. (identifying NERC Project 2010-01 – Support Personnel Training, which is 

part of NERC’s Reliability Standards Development Plan: 2009-2011, to address these 

directives). 

72 Order No. 693 at P 1372. 
Docket No. RM09-25-000 - 41 - 

Recommendation 19 of the Blackout Report identified training deficiencies as 

contributing to the August 14, 2003 blackout and states that NERC should require 

n stated 

n 

ient 

ebsite 

 there have been disturbances caused by human errors at generating 

ff. 

pplicability to support personnel for EMS applications as 

directed in Order No. 693. 

 

training for the planning staff at control areas and IT support personnel.73 

65. Regarding generator operator personnel, in Order No. 693, the Commissio

that it is essential that generator operator personnel have appropriate training to 

understand instructions from a balancing authority, particularly in an emergency situatio

in which instructions may be succinct and require immediate action. Further, we noted 

that if communication is lost, the generator operator personnel should have had suffic

training to take appropriate action to ensure reliability of the Bulk-Power System.74 

Since the issuance of Order No. 693, System Disturbance reports from NERC’s w

indicate that

stations.75 

66. For the reasons enumerated in Order No. 693, we continue to believe that 

requiring a comprehensive training program is important, specifically one that includes 

training for generator operators and for operations planning and operations support sta

NERC must also consider a

73 Blackout Report at 157. 

74 Order No. 693 at P 1359. 

75 See e.g., NERC System Disturbance Reports dated May 21, 2007 and August 

13, 2007, available at http://www.nerc.com/files/disturb07.pdf. 
Docket No. RM09-25-000 - 42 - 

67. NERC indicates that it intends to address the expansion of the training standard in 

Project 2010-01 – Support Personnel Training, which is slated to be initiated in 2010.76 

In the Reliability Standards Development Plan: 2010-2012, NERC states that the 

Support Personnel Training standard “is a priority project as it was proposed in support of 

a 2003 blackout recommendation.”77 NERC previously targeted a completion date of the 

fourth quarter of 2011 for the expansion of the training standard.78 More recently, NERC 

has stated that the completion date for this standard is “to be determined.”79 Given the 

continuing need to require training for generator operators and operations support and 

operations planning personnel the Commission believes the previously announced 

targeted date (i.e., fourth quarter of 2011) is a reasonable deadline for completion of this 

work. We seek comments from NERC and other interested persons on whether 

 76 NERC Petition at 30.. (identifying NERC Project 2010-01 – Support Personnel 

Training, to address these directives). See also, NERC Standards Under Development 

Anticipated Posting Schedule (updated 3/3/2010), available at 

www.nerc.com/docs/standards/sar/Project Summary Calendar.xls-2010-04-07. 

77 Reliability Standards Development Plan: 2010-2012, Volume I – Overview at 9 

(filed with the Commission at North American Electric Reliability Corporation 

Informational Filing of 2010 Development Plan, Docket Nos. RM05-17-000, RM05-25-

000, and RM06-16-000 (Dec. 2, 2009)). 

78 Reliability Standards Development Plan: 2009-2011, Volume II, List of Projects 

at 202 (dated Sept. 22, 2008). 

79 Reliability Standards Development Plan: 2010-2012, Volume II, List of 

Projects at 136 (dated Oct. 7, 2009). 
Docket No. RM09-25-000 - 43 - 

completion of this work by the fourth quarter of 2011 is reasonable, or whether, for good 

cause, another timeline for completion of this work would be necessary. 

68. In Order No. 693, the Commission also directed NERC to consider in the 

Reliability Standards Development Process certain issues regarding personnel that 

support EMS applications. NERC deferred consideration of this matter to Project 2010-

1. In their comments regarding the timeline for completing the expansion of the 

personnel training standard, NERC and other interested persons should also discuss 

whether the issues identified in Order No. 693 regarding personnel that support EMS 

applications should be addressed on the same timeline (i.e., completed by the fourth 

quarter of 2011). 

I. Summary

69. We propose to approve proposed Reliability Standards PER-005-1 and PER-004-2 

as just, reasonable, not unduly discriminatory or preferential, and in the public interest. 

Under section 215(d)(5) of the FPA, the Commission proposes to direct the ERO to 

develop modifications to proposed Reliability Standard PER-005-1 to address certain 

issues identified by the Commission. We also seek comment from the ERO and other 

interested entities regarding the Commission’s specific concerns discussed above. The 

Commission may determine after considering such comments that it is appropriate to 

direct the ERO to develop additional modifications to PER-005-1. 

70. In addition, the Commission proposes to defer review of the violation risk factor 

and violation severity level assignments for proposed Reliability Standards PER-005-1 
Docket No. RM09-25-000 - 44 - 

and PER-004-2 until the Commission acts on NERC’s March 5, 2010 filing pending in 

Docket No. RR08-4-005. 

IV. Information Collection Statement 

71. The Office of Management and Budget (OMB) regulations require approval of 

certain information collection requirements imposed by agency rules.80 Upon approval 

of a collection(s) of information, OMB will assign an OMB control number and a

expiration date. Respondents subject to the filing requirements of this rule will not be 

penalized for failing to respond to these collections of information unless the collections 

of information display a valid OMB control number. The Paperwork Reduction Act 

(PRA)

n 

 

81 requires each federal agency to seek and obtain OMB approval before 

undertaking a collection of information directed to ten or more persons, or continuing a 

collection for which OMB approval and validity of the control number are about to 

expire.82

72. The Commission is submitting these reporting and recordkeeping requirements to 

OMB for its review and approval under section 3507(d) of the PRA. Comments are 

solicited on the Commission’s need for this information, whether the information will 

have practical utility, the accuracy of provided burden estimates, ways to enhance the 

quality, utility, and clarity of the information to be collected, and any suggested methods 

80 5 CFR § 1320.11 (2009). 

81 44 USC § 3501-20 (2006). 

82 44 USC § 3502(3)(A)(i) (2006), 44 USC § 3507(a)(3) (2006). 
Docket No. RM09-25-000 - 45 - 

for minimizing the respondent’s burden, including the use of automated information 

techniques.

73. This Notice of Proposed Rulemaking (NOPR) proposes to approve two new 

Reliability Standards, PER-004-2 and PER-005-1 governing training, which standards 

will replace currently effective Reliability Standards PER-002-0 and PER-004-1 

approved by the Commission in Order No. 693. Rather than creating entirely new 

training requirements, the proposed Reliability Standard PER-005-1 instead modifies and 

improves the existing Reliability Standards governing personnel training.83 Thus this 

proposed rulemaking does not impose entirely new burdens on the effected entities. For 

example, the currently effective training Reliability Standard, PER-002-0, requires 

transmission operators and balancing authorities to create training program objectives, 

develop a plan for the initial and continued training, and maintain training records. 

Similarly, proposed training Reliability Standard, PER-005-1, which supersedes PER002-0, requires transmission operators, balancing authorities and reliability coordinators 

to establish a training program (using a systematic approach to training), verify the 

trainee’s capabilities to perform task for which they receive training, and maintain 

training records. Accordingly, the recordkeeping requirements imposed by proposed 

Reliability Standard PER-005-1, are more specific but not necessarily more expansive 

 83 Proposed Reliability Standard PER-004-2 does not add any new requirements, 

rather it restates and carries forward the two remaining requirements from PER-004-1 

that are not superseded by proposed Reliability Standard PER-005-1. 
Docket No. RM09-25-000 - 46 - 

than currently effective Reliability Standard PER-002-0’s recordkeeping requirements. 

However, proposed Reliability Standard PER-005-1 does enlarge the scope of the 

affected entities to include reliability coordinators. 

74. Like the currently effective training Reliability Standards, PER-002-0 and 

PER-004-1, proposed Reliability Standards PER-004-2 and PER-005-1 do not require 

responsible entities to file information with the Commission. However, these Reliability 

Standards do require applicable entities to develop and maintain certain information, 

subject to audit by a Regional Entity such as documentation to show a development and 

delivery of a training program for system operators, verification of system operator 

capabilities to perform tasks, and training records to show compliance with requirements. 

75. Public Reporting Burden: Our estimate below regarding the number of 

respondents is based on the NERC compliance registry as of May 12, 2010. Because 

under the proposed Reliability Standards the scope of applicability is enlarged to include 

reliability coordinators, but otherwise continue to impose training requirements on 

transmission operators and balancing authorities, the Commission considers the reporting 

burden only with respect to reliability coordinators. According to the NERC compliance 

registry, there are sixteen entities registered as reliability coordinators. However, under 

NERC’s compliance registration program, entities may be registered for multiple 

functions. Thus, of the sixteen entities registered as reliability coordinators, nine are also 

registered as balancing authorities and, as such, must comply with currently effective 

Reliability Standards governing system operator training. Given these additional 
Docket No. RM09-25-000 - 47 - 

parameters, the Commission estimates that the Public Reporting burden for the 

requirements contained in the NOPR is as follows: 

Data Collection No. of New 

Respondents

No. of 

Responses 

Recordkeeping84

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. 

785 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: RCs, 

TOs, and BAs must have 

available for inspection its 

7 7 10 70 

 84 The proposed Reliability Standards do not impose any reporting requirements. 

85 Only seven of the 16 registered reliability coordinators are not currently subject 

to training requirements as balancing authorities. 
Docket No. RM09-25-000 - 48 - 

company-specific, reliabilityrelated task list. 

PER-005-1, M1.2: RCs, 

TOs, and BAs 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: RCs, 

TOs, and BAs must have 

available for inspection 

evidence that it performed an 

annual training program 

evaluation. 

7 7 25 175 

PER-005-1, M2: RCs, TOs, 

and BAs 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 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 - 49 - 

 Total Annual hours for Collection: (Reporting + recordkeeping ) = hours. 

Information Collection Costs: The Commission seeks comments on the costs to 

comply with the reporting and recordkeeping burden associated with the proposed 

Reliability Standards. It has projected the average annualized cost to be the total annual 

hours 

Recordkeeping = 2415 hours @ $120/hour = $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 proposed rule would approve revised 

Reliability Standards that modify the existing requirement for entities to develop training 

programs and train certain personnel. The proposed 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 

proposed Reliability Standards for the Bulk-Power System and determined that the 

proposed 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, communication and management within the energy industry. The 
Docket No. RM09-25-000 - 50 - 

Commission has assured itself, by means of internal review, that there is specific, 

objective support for the burden estimates associated with the information requirements. 

76. Interested persons may obtain information on the reporting requirements by 

contacting: Federal Energy Regulatory Commission, 888 First Street, NE, Washington, 

DC 20426 [Attention: Michael Miller, Office of the Executive Director, Phone: 

(202) 502-8415, fax: (202) 273-0873, e-mail: DataClearance@ferc.gov]. Comments on 

the requirements of the proposed rule may also be sent to the Office of Information and 

Regulatory Affairs, Office of Management and Budget, Washington, D.C. 20503 

[Attention: Desk Officer for the Federal Energy Regulatory Commission], e-mail: 

oira_submission@omb.eop.gov. Please reference OMB Control No. 1902-0244 and the 

docket number of this proposed rulemaking in your submission. 

V. Environmental Analysis

77. 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.86 The actions proposed here fall within the categorical 

exclusion in the Commission's regulations for rules that are clarifying, corrective or 

procedural, for information gathering, analysis, and dissemination.87 Accordingly, 

neither an environmental impact statement nor environmental assessment is required. 

 86 Order No. 486, Regulations Implementing the National Environmental Policy 

Act, 52 FR 47897 (Dec. 17, 1987), FERC Stats. & Regs. ¶ 30,783 (1987). 

87 18 CFR § 380.4(a)(5) (2009). 
Docket No. RM09-25-000 - 51 - 

VI. Regulatory Flexibility Act Analysis 

78. The Regulatory Flexibility Act of 1980 (RFA)88 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.89 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. 

79. 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 

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 Rule will not have a 

 88 5 USC § 601-12 (2006). 

89 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 USC § 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 - 52 - 

significant impact on a substantial number of small entities. Accordingly, no regulatory 

flexibility analysis is required. 

VII. Comment Procedures

80. The Commission invites interested persons to submit comments on the matters and 

issues proposed in this notice to be adopted, including any related matters or alternative 

proposals that commenters may wish to discuss. Comments are due [Insert 60 days 

from publication in the FEDERAL REGISTER]. Comments must refer to Docket 

No. RM09-25-000, and must include the commenter’s name, the organization they 

represent, if applicable, and their address in their comments. 

81. The Commission encourages comments to be filed electronically via the eFiling 

link on the Commission’s web site at http://www.ferc.gov. The Commission accepts 

most standard word processing formats. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format and not 

in a scanned format. Commenters filing electronically do not need to make a paper 

filing. 

82. Commenters that are not able to file comments electronically must send an 

original and 14 copies of their comments to: Federal Energy Regulatory Commission, 

Secretary of the Commission, 888 First Street NE, Washington, DC 20426. 

83. All comments will be placed in the Commission’s public files and may be viewed, 

printed, or downloaded remotely as described in the Document Availability section 

below. Commenters on this proposal are not required to serve copies of their comments 

on other commenters. 
Docket No. RM09-25-000 - 53 - 

VIII. Document Availability

84. 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, D.C. 20426. 

85. 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. 

86. 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 1-866-208-3676) 

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. 

By direction of the Commission. 

( S E A L ) 

Kimberly D. Bose, 

Secretary. 
Docket No. RM09-25-000 - 54 -