To recommend approval of OGRR218 as amended by CenterPoint comments and as revised by OWG
Background
Status:
Approved
Date Posted:
Jan 30, 2009
Sponsor:
Shell Energy North America (US), L. P.
Urgent:
No
Sections:
1.8.2
Description:
This Operating Guide Revision Request (OGRR) changes the five (5) day (40 hours) emergency training requirements to one (1) day (8 hours) for Qualified Scheduling Entities (QSEs) that do not operate the Generation Resource(s) they are scheduling. This OGRR also allows the actual time operating in real emergencies, such as working from a backup office during a hurricane, to satisfy the emergency training requirements.
Reason:
The existing five (5) days of emergency training that is in the Operating Guides is reasonable for Transmission Operators (TOs), Control Area Authorities (CAAs) and QSEs that operate the generation they represent. However, this requirement is excessive and unnecessary for QSEs that do not operate the Generation Resource(s) they schedule. The role of these QSEs is generally limited to acting as a conduit for emergency information between the QSE and the generator. This role is important, but forty (40) hours of annual training is simply not needed for the QSEs to ensure they are capable of meeting their emergency-related responsibilities. Thus reducing the emergency training to one (1) day (8 hours) per year for QSEs that do not operate the generation they schedule is more appropriate and consistent with the need to have operators that are properly trained.
If a Market Participant spends time operating in an actual emergency, such as working from a backup office during a hurricane, this time should be considered acceptable to satisfy the emergency training requirements. There is no better training than working in an actual emergency.