Consideration of Comments on Operating Personnel Credentials Standard (Project 2007-04) The Certifying System Operators Standard Drafting Team thanks all commenters who submitted comments on the draft Operating Personnel Credentials standard. This standard was posted for a 30-day public comment period from October 21, 2009 through November 20, 2009. The stakeholders were asked to provide feedback on the standard through a special Electronic Comment Form. There were 41 sets of comments, including comments from more than 150 different people from over 65 companies representing 9 of the 10 Industry Segments as shown in the table on the following pages. Based on the comments received the drafting team made the following changes to the proposed Standard: • Modified the Purpose statement to provide additional clarity. • Modified the Effective Date from six months to twelve months. • Modified the body of the Requirements to provide additional clarity on who should be certified and how certification is to be accomplished. • Added a footnote to clarify that a trainee that is not NERC-certified must work under the direct supervision of a NERC-certified System Operator • Modified the Measure to provide additional clarity as to who is being measured. • Modified the VSLs to align with the modifications to the Requirements. There were several minority issues that the team was unable to resolve, including the following: • Several stakeholders object to the reference to “competencies.” The team is required to address the FERC directive from Order 693 that states that the standard must identify the minimum competencies operating personnel must demonstrate to be certified. The team met with FERC staff and confirmed that the directive does intend for competencies to be identified in the standard. • Several stakeholders want the language from PER-003-0 relative to allowing trainees to work without a NERC certificate while under the direct supervision of a NERC certified System Operator to be provided in this standard and the team declined to include this provision. The SDT explained that they believed that the individual responsible for the operation of the BES must be certified. The SDT does not believe that any “trainee” should be left in control of the BES. If an entity has a trainee in an applicable operating position, there must be a Certified System Operator on duty that is in control of the BES. However, the SDT has added a footnote to the standard to address this issue. The footnote reads “Non-NERC certified personnel learning or observing the tasks of a real-time operating position must be under the direct supervision of a NERC Certified System Operator at that operating position; the NERC Certified System Operator at that operating position has ultimate responsibility for the performance of the reliability-related tasks.” • Several stakeholders want the language from PER-003 that allowed a responsible entity to operate the BES with someone other than a NERC certified System Operator during an emergency while transferring from a primary control center to a backup control center and the team declined to include this provision. The SDT explained that it believed that standards should not contain exceptions since including exceptions could allow entities to violate the standard during times that do not warrant straying from the intent of the requirement. The SDT further believes that if
