Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
Date: 2011-12-06
Proposed New ISO Rules Section 502.5 Generating Unit Technical Requirements (“New ISO Rules Section 502.5”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
Comments From:
2011/12/06
2011/12/06
through
2012/01/31
Company Name
Contact:
Company Contact
Phone:
Contact Phone Number
E-mail:
Date [yyyy/mm/dd]:
Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO Rules. Please refer back to the Letter of Notice under the “Attachments to Letter of
Notice” section to view the actual proposed content changes to the ISO Rules. Please place your comments / reasons for position underneath (if any).
1. ISO Definitions
(a) New
There are no new ISO rules definitions associated with proposed New ISO Rules
Section 502.5
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position (if
any)
(b) Removals
There are no ISO rules definitions removals associated with proposed New ISO
Rules Section 502.5.
Comment # 2: Insert Comments / Reason for Position (if
any)
(c) Amendments
There are no amendments to ISO rules definitions associated with proposed New
ISO Rules Section 502.5.
Comment # 3: Insert Comments / Reason for Position (if
any)
2. ISO Rules
Issued for Stakeholder Consultation: 2011-12-06
Stakeholder Comments and/or Alternate Proposal
Page 1
AESO Replies
AESO Replies
Public Information
(a) New
Comment # 4: Insert Comments / Reason for Position (if
any)
The AESO’s existing Generator and Load Interconnection Standard (“Technical
Standard”) was adopted in 2006. The Technical Standard has a 5 year term, and
therefore needs to be reviewed and amended during the 2011-12 timeframe.
However, the AESO is transitioning all of its technical requirements including the
Technical Standard into new ISO rules, in accordance with the principles and
procedures under the AESO’s Transition of Authoritative Documents (“TOAD”)
project. The AESO has further determined that it would be most efficient and
practical going forward to split the Technical Standard in to separate new load
and generating unit technical ISO rules. The first stage of this initiative is to redraft
and relocate the applicable generating unit provisions of the Technical Standard
into Proposed New ISO Rules Section 502.5.
The AESO is endeavoring to represent legally binding requirements and
obligations in one of its three authoritative document domains, those being ISO
rules, ISO tariff or the Alberta Reliability Standards. The proposed minimum
technical requirements of a legally binding nature for existing, modified and new
generating units have been set out in the proposed New ISO Rules Section 502.5.
It should be noted that, as provisions have been redrafted and relocated in
proposed New ISO Rules Section 502.5, the AESO has not intended any
essential changes to the policies currently reflected in the Technical Standard for
generating units, with some specific and limited exceptions referred to below.
The rationale for each of the subsections of proposed New ISO Rules Section
502.5 is provided below.
Subsection 1 – Applicability
Comment # 5: Insert Comments / Reason for Position (if
any)
The applicability section of the Technical Standard did not clearly state which
market participant subcategories were responsible for meeting the requirements.
Subsection 1 clarifies that the requirements apply to legal owners of a generating
unit including those in an industrial complex, but excludes wind aggregated
generating facilities.
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Subsection 2 – Requirements – New Generating Unit
Comment # 6: Insert Comments / Reason for Position (if
any)
Subsection 2 sets out, with clarity, the provisions that apply to a new generating
unit.
Subsection 3 – Requirements – Existing Generating Unit
Comment # 7: Insert Comments / Reason for Position (if
any)
Subsection 3 sets out the provisions that apply to an existing generating unit,
including clarifications as to what subsections of proposed New ISO Rules
Section 502.5 are not applicable.
Subsection 4 – Functional Specification
Comment # 8: Insert Comments / Reason for Position (if
any)
Consistent with current practice, subsection 4 enables the AESO to approve of
and issue a functional specification for a generating unit project, which will set out
technical details with regard to design, construction and operation of the
generating unit connection project and any associated transmission system
connection facilities.
Consistent with technical requirements under other ISO rules, Subsection 4(2)
allows for variances in a functional specification under certain conditions.
Subsection 5 – Successor to Prior Requirements
Comment # 9: Insert Comments / Reason for Position (if
any)
Subsection 5 clarifies that proposed New ISO Rules Section 502.5 succeed the
generating facilities provisions of the Technical Standard.
Subsection 6 – Operating Voltage Requirements
Comment # 10: Insert Comments / Reason for Position
(if any)
Subsection 6 requires the market participant to clearly state the voltages to which
the generating unit will be designed at both the point of connection and the
generator terminals.
In Alberta, the voltage levels may vary considerably from the nominal voltage,
therefore, having the legal owner clearly stating the values to be voltages at the
point of connection and the generating unit terminals allows the AESO to fairly
ensure the compliance of all legal owners with regard to:
(a) The voltage ride-through requirements;
(b) Voltage regulation; and
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(c) The reactive power requirements of the generating unit.
This subsection also makes the legal owner aware of the voltage range at that
facility so that they may properly specify, design and purchase the appropriate
equipment.
Subsection 7 – Maximum Authorized Real Power
Comment # 11: Insert Comments / Reason for Position
(if any)
Subsection 7 requires the participant to submit in writing the maximum value that
the generating unit can ever be operated at, under ideal circumstances while
meeting other requirements of proposed New ISO Rules Section 502.5.
Many generating units can operate above nameplate values under the proper
conditions, so to properly study the behaviour of the generating units in respect to
the transmission system, this maximum value needs to be clearly stated. This
value is also required to properly design the transmission system.
Subsection 8 – Reactive Power Requirements for All Generating Units
Comment # 12: Insert Comments / Reason for Position
(if any)
Subsections 8(4) through 8(6) allow the participant to apply for a reduction in the
reactive power/power factor requirement in the under excited region of the
reactive capability curve.
The AESO is aware of the concerns that depending on the specific location of the
generator unit, operating near the bottom of the D-curve may result in the unit
becoming unstable. In the AESO’s opinion, it would be appropriate to reduce the
reactive power requirement, if provided with technical back up to this concern.
Subsection 9 – Additional Reactive Power Requirements for a Generating
Unit with a Power Purchase Arrangement
Comment # 13: Insert Comments / Reason for Position
(if any)
This section requires the applicable participant to meet certain requirement in
regards to reactive power obligations under normal and abnormal system
conditions.
Most of this section covers policies already in place by the AESO, however for
clarity, these requirements have been incorporated into proposed New ISO Rules
Section 502.5 to allow participants to find all requirements to design, build,
maintain and/or modify facilities under dedicated ISO rules. For background
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information please refer to the document Application Guideline Generator
Interconnection Requirements – Reactive Power available at:
http://www.aeso.ca/downloads/AESO_PPA_Reactive_Power_Guidelines.pdf
Of particular note, subsection 9(10) specifies the requirements that will be
applicable to generating units that are currently the subject of a power purchase
arrangement once that power purchase arrangement ends.
Subsection 10 – Voltage Ride-Through Requirements
Comment # 14: Insert Comments / Reason for Position
(if any)
All generating unit must have the capability to support the transmission system
during system disturbances. Therefore, each generating unit must have some
capability for voltage ride through.
The basic approach to the requirements for existing generating units has been
carried over from the existing Technical.
Subsection 10 allows new generating units to be able to ride through system
disturbances that result in voltages as low as 0% and as high 120% for specified
periods of time. This requirement has been amended to align with the direction
that the industry is taking for new generating units. Please refer to FERC orders
661 and 693.
Subsection 11 – Automatic Voltage Regulator
Comment # 15: Insert Comments / Reason for Position
(if any)
Subsection 11 sets out the requirements for the automatic voltage regulator and
the basic approach has been carried over from the existing Technical Standard.
Subsection 12 – Frequency and Speed Governing Requirements
Comment # 16: Insert Comments / Reason for Position
(if any)
Subsection 12 sets out the requirements for the governor systems and the basic
approach has been carried over from the existing Technical Standard, with the
one exception noted below.
Subsection 12(4) contains the following:
“If the frequency of the generating unit while connected to the transmission
system remains greater than sixty one point seven (61.7) Hz or less than fifty-
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seven (57) Hz for more than ten (10) minutes, then the generating unit must be
immediately removed from service.”
The AESO has discussed this requirement in work group sessions with
generating unit owners and a consensus was reached that this is appropriate to
include this in proposed New ISO Rules Section 502.5. It was, however,
recommended that the AESO seek broader input in particular from distribution
facility owners, industrial system owners, etc.
Subsection 13 – Power System Stabilizer
Comment # 17: Insert Comments / Reason for Position
(if any)
Subsection 13 sets out the requirements to install power system stabilizers and
has been amended to add requirements that had previously existed in WECC
policies, which the AESO has currently been enforcing.
Subsection 14 – Transmission System Step-Up Transformer
Comment # 18: Insert Comments / Reason for Position
(if any)
Subsection 14 sets out the requirements for the step-up transformer and the basic
approach has been carried over from the existing Technical Standard.
Section 15 – Auxiliary Systems
Comment # 19: Insert Comments / Reason for Position
(if any)
Subsection 15 sets out the requirements for the critical auxiliary system to meet
minimum standards so that multiple units will not go off line for single point of
failure and that these auxiliaries must be considered when studying the voltage
ride capability of the facility.
The AESO has experienced issues with facilities where the generating unit may
have been able to ride through disturbances but the critical auxiliary system
caused the generating unit to trip or go offline. As well, Alberta Reliability
Standard TPL-002-AB-0 System Performance Following Loss of a Single BES
Element does not allow for cascading for the loss of a single bulk electric system
element.
Subsection 16 – Generating Unit Disconnection and Interrupting Devices
Comment # 20: Insert Comments / Reason for Position
(if any)
Subsection 16 sets out the requirements for the generating unit breakers and the
basic approach has been carried over from the existing Technical Standard.
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Subsection 17 – Isolating Devices
Comment # 21: Insert Comments / Reason for Position
(if any)
Subsection 17 sets out the requirements for the generating unit disconnect
switch(es) and the basic approach has been carried over from the existing
Technical Standard.
Subsection 18 – Power Quality
Comment # 22: Insert Comments / Reason for Position
(if any)
Subsections 18(6) and (7) amends and clarifies the requirements for generating
units to not introduce excessive voltage unbalances on to the transmission
system and how they are calculated.
The previous requirement in the existing Technical Standard was to related
voltage unbalance at distribution voltages. This new requirement is more
appropriate for transmission systems.
Subsection 19 – Grounding
Comment # 23: Insert Comments / Reason for Position
(if any)
Subsection 19 sets out the requirements for the generating unit grounding and the
basic approach has been carried over from the existing Technical Standard.
Subsection 20 – Lightning and Other Surge Protection
Comment # 24: Insert Comments / Reason for Position
(if any)
Subsection 20 sets out the requirements for the generating unit surge protection
and the basic approach has been carried over from the existing Technical
Standard.
Subsection 21 – Synchrophasor Measurement System
Comment # 25: Insert Comments / Reason for Position
(if any)
Subsection 21 requires new or existing units with an upgraded protection system
to install a synchrophasor measurement system.
The application of synchrophasor measurement systems on generating units will
allow the AESO to better analyze the response of the generating units to system
disturbances, which assist the AESO in developing mitigating requirements for the
reliability of the transmission system. It will also allow the AESO to better monitor
compliance to the ISO rules and requirements.
The generating unit owners and operators will also be able to use this data to
analyze the behaviour of the generating unit for the model revalidation
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requirements and determine if the generating unit is operating as designed.
Subsection 22 – Internal Sequence of Event Monitoring
Comment # 26: Insert Comments / Reason for Position
(if any)
Subsection 22 adds additional requirements regarding what must be monitored
within the generating unit. The additional requirements only apply to new or
modified generating units.
In the AESO’s opinion, in order to properly analyze the root cause of some
system disturbances, greater detail is required from generating units in regards to
their behaviour during these disturbances.
Subsection 23 – Provision of Data and Modeling Information
Comment # 27: Insert Comments / Reason for Position
(if any)
Subsection 23 deals with the provision of data for both new and modified
generating units.
This section was added so that the AESO can ensure it has the information
required to properly model the behaviour of the generating unit in relation to the
transmission, and to confirm that the generating unit is in compliance with
sections of proposed New ISO Rules Section 502.5.
Subsection 24 – Testing Intervals
Comment # 28: Insert Comments / Reason for Position
(if any)
Subsection 24 sets out requirements to provide a model validation or reactive
power verification report in terms of both format and timing.
Subsection 25 – Reporting
Comment # 29: Insert Comments / Reason for Position
(if any)
Subsection 25 sets out requirements to provide a model validation or reactive
power verification report in terms of both format and timing.
This subsection was added to clarify the reporting requirements to the market
participants.
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Subsection 26 – Baseline Testing
Comment # 30: Insert Comments / Reason for Position
(if any)
Subsection 26 sets out the requirements for the generating unit baseline testing
and the basic approach has been carried over from the existing Technical
Standard.
Subsection 27 – Reactive Power Verification and Re-verification Testing
Comment # 31: Insert Comments / Reason for Position
(if any)
Subsection 27 sets out the requirements to test that the reactive power
requirements of proposed New ISO Rules Section 502.5 have been met.
Reactive power verification has been an existing WECC policy that the AESO has
been enforcing. This subsection has been added to clarify the testing
requirements to the participants.
Subsection 28 – Model Revalidation Testing
Comment # 32: Insert Comments / Reason for Position
(if any)
Subsection 28 sets out the requirements for the generating unit model
revalidation testing and the basic approach has been carried over from the
existing Technical Standard.
The following reference sections in the existing Technical Standard that have not
been included in proposed New ISO Rules Section 502.5:
Comment # 33: Insert Comments / Reason for Position
(if any)
Section 1.1 – Purpose
This section was removed to align with the principals of the TOAD project.
Section 1.3 – Definitions
This section was removed to align with the principals of the TOAD project.
Section 1.4 – Modifications
This section was removed to align with the principals of the TOAD project.
Section 1.5 – Requirement For Review
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This section was removed to align with the principals of the TOAD project.
Section 1.6 – Document Change History
This section was removed to align with the principals of the TOAD project.
Section 2.5 – Clearance and Access
This section was removed as it referenced codes that do not fall under the
jurisdiction of the AESO.
Section 4.0 – Load Interconnection Requirements
Proposed New ISO Rules Section 502.5 does not include the requirements for
load facilities. These facilities will be the subject of separate ISO rules and be
consulted on separately as the requirements for generating facilities and load
facilities are significantly different.
(b) Removals
No removal of ISO rules provisions are being proposed for proposed New ISO
Rules Section 502.5.
Comment # 34: Insert Comments / Reason for Position
(if any)
(c) Amendment
No amendments to ISO rules provision are being proposed for proposed New ISO
Rules Section 502.5.
Comment # 35: Insert Comments / Reason for Position
(if any)
(d) Other
(Stakeholders wishing to comment on specific provisions are requested to copy
the provision into this area and provide comments)
Comment # 36: Insert Comments / Reason for Position
(if any)
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