Stakeholder Comment and Reply Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Proposed New ISO rules 502.15 Reporting Facility Modification Modeling Data (“New ISO Rules Section 502.15”)
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2012/04/24
2012/04/24
through 2012/05/25
1. ISO Rules Definitions
(a) New
There are no new ISO rules definitions being associated with the proposed New ISO
Rules Section 502.15.
Stakeholder Comments and/or Alternate Proposal
TransAlta
AESO Replies
(b) Removals
There are no ISO rules definition removals associated with the proposed New ISO
Rules Section 502.15.
(c) Amendments
There are no ISO rules definition amendments associated with the proposed New
ISO Rules Section 502.15.
2. ISO Rules
Stakeholder Comments and/or Alternate Proposal
AESO Replies
(a) New
In developing proposed New ISO rules Section 502.15 the AESO reviewed existing
ISO OPP 003.4 Power System Data Sharing (“ISO OPP 003.4”), ISO OPP 003.5
Equipment Ratings (“ISO OPP 003.5”) and ISO OPP 1306 Reporting Facility
Changes (“ISO OPP 1306”). Through this review the AESO identified the
authoritative requirements and obligations in ISO OPPs 003.4, 003.5 and 1306, and
relocated those authoritative requirements and obligations into proposed New ISO
Rules Section 502.15 while recognizing and addressing the duplication that currently
exists between these ISO OPPs. In the AESO’s opinion, proposed New ISO Rules
Section 502.15 represents the collective set of authoritative requirements and
obligations from OPPs 003.4, 003.5 and 1306.
AESO Replies to Stakeholder Comments: 2012-08-02
Page 1 of 18
Subsection 1 – Applicability
AltaLink Management Ltd
The AESO proposes that New ISO rules Section 502.15 is applicable to:
1.
(a)
the legal owner of a transmission facility;
(b)
the legal owner of an aggregated generating facility capable of a
maximum output equal to or greater than five (5) MVA;
(c)
the legal owner of a generating unit capable of a maximum output equal to
or greater than five (5) MVA;
(d)
the legal owner of an industrial complex with an electric motor that:
(e)
(f)
(i)
connects at a voltage equal to or greater than six hundred (600)
volts;
(ii)
is capable of a maximum consumption equal to or greater than one
(1) MVA; and
(iii)
aggregates to being capable of a maximum consumption at the
facility equal to or greater than five (5) MVA;
the legal owner of an electric distribution system:
(i)
who provides a form of connection service to one or more electric
distribution system connected generating units and aggregated
generating facilities; and
(ii)
where the sum total of nameplate rated capacity for all facilities
referred to in subsection 1(e)(i) is equal to or greater than ten (10)
MVA at each point of delivery; and
the AESO.
In the AESO’s opinion, this subsection is consistent with the applicability specified in
existing ISO OPP 1306 which states that “TFOs, GFOs, DFOs, ISDs and direct
connect customers, collectively, are referred to as facility owners in this OPP” and
that “all facility owners must report to the AESO, changes in…”.
AltaLink believes further clarity on the purpose and
applicability of this Rule is needed. AltaLink recommends
that a section be added to define the purpose and intent
of this Rule and to clarify and highlight that this Rule
applies to facility modifications only and not to system
additions or facility modifications related to system
additions.
1. In 2009, the AESO worked with a group of
stakeholders to develop a standard template for ISO
rules. The outcome of that work was that the
template should only have sections for “applicability”,
“requirements” and any “appendices” required. In
essence the ISO rules stakeholders felt that the
content of ISO rules should be focused on the binding
requirements and not contain any informational
content. The AESO has been using this template for
all documents transitioned to date and will continue to
use this template such that there is consistency
across the ISO rules. Therefore, no changes have
been made to final proposed ISO rules 502.15
Reporting Facility Modification Modeling Data (“final
proposed ISO rules 502.15”) to include the purpose
and intent of ISO rules 502.15. However, the AESO
will update the Transmission Modeling Information
Document (“Information Document”) to clarify the
purpose and intent of the rule; which is, in summary,
obtaining the necessary facility modification modeling
data such that the AESO can maintain a complete
and accurate transmission model.
With regard to applicability comment, the AESO
wishes to clarify the following:
a. If a market participant is seeking a transmission
connection the relevant data will be collected
through the AESO’s Connection Process or the
AESO’s System Projects Process. For clarity, the
AESO collects the facility modeling data it
requires, pre energization, in the AESO’s
Connection Process or the AESO’s System
Projects Process and therefore a market
participant is not required to submit data under
proposed ISO rules Section 502.15.
b. If after the facilities are energized, post
energization, any market participant who modifies
AESO Replies to Stakeholder Comments: 2012-08-02
Page 2 of 18
its facilities must submit data to the AESO in
accordance with proposed new ISO rules 502.15.
For clarity, this includes a legal owner of a
transmission facility who modifies its facilities.
2.
AltaLink suggests that the minimum electric motor
voltage and capacity characteristics outlined in (d) are too
low and electric motors at these levels will not have a
significant effect on system fault levels. AltaLink
recommends that six hundred (600) volts be increased to
one thousand (1000) volts in (i) and five (5) MVA be
increased to ten (10) MVA in (iii).
2. a. The AESO considered AltaLink’s suggestion with
regard to changing the six hundred (600) volts to
one thousand (1000) volts and the AESO agrees
that the threshold can be increased. Therefore, the
AESO has modified the threshold from six hundred
(600) volts to one thousand (1000) volts in final
proposed ISO rules 502.15.
b.The AESO considered AltaLink’s suggestion with
regard to increasing the five (5) MVA to ten (10)
MVA and the AESO is aware of multiple sites in
close proximity where motors aggregating to more
than 5 MVA and less than 10MVA, in their
cumulative effect, may impact system
performance. In addition to system fault levels,
system performance issues includes voltage
stability and voltage recovery which can be
affected by motor load behaviour. Therefore, the
AESO has not modified the threshold from five (5)
MVA to ten (10) MVA in final proposed ISO rules
502.15.
ATCO Electric Ltd
4. ATCO submits that “an industrial complex” as indicated in
subsection 1(d) should be clearly defined and should not
apply to DFOs. DFOs do not own the motors and therefore
do not have any motor information that may be requested.
AESO Replies to Stakeholder Comments: 2012-08-02
4. The term industrial complex can have a variety of
meanings. It can refer to:
a) A facility with an industrial system designation;
b) A facility without an industrial system designation;
c) A facility with load and generation;
d) A facility with just load;
e) Or many other configurations.
Page 3 of 18
Depending on the context of an ISO rule the term
industrial complex may be targeted at specific
configurations or specific equipment/facilities within an
industrial complex.
If the use of the term industrial complex requires
further description or examples, then this is content
that the AESO incorporates in an Information
Document.
5.
AESO Replies to Stakeholder Comments: 2012-08-02
ATCO submits that “the legal owner of an electric
distribution system” as specified under subsection 1(e)
should be excluded from this Applicability section. ATCO
as a DFO does not own any of the distribution connected
generators and therefore can not authenticate or take
responsibility/liability for the data required for these
generators. Detailed technical reasons are also provided
in the comments for subsection 2.
With regard to ISO rules 502.15 the “Applicability”
subsection is targeted at “electric motors” within an
industrial complex. In the AESO’s opinion, legal
owners will know if they own an industrial complex or
not, and if that industrial complex has an electric
motor within it. Therefore, the AESO will not be
proposing a definition for the term industrial complex.
The Alberta Electric Utilities act gives the right to provide
electric distribution service solely to the owner of the
electric distribution system in whose service area the
property is located. Electric distribution service includes
the connection of distributed generation. It is the DFO who
contracts with the distributed generator to provide service,
at which time the DFO is in a position to obtain the
required information. The DFO can choose which Point of
Interconnection to extend when a distributed generator
requires a connection, and determines any switching that
might move a portion of the distribution system from one
point of interconnection to another. The DFO is the sole
party who can determine on an ongoing basis, which
distribution-connected generators are aggregated behind
which Point of Interconnection with the transmission
system. Therefore, the AESO has not modified the
“applicability” section in proposed ISO rules Section
502.15 to exclude “the legal owner of an electric
distribution system”. However, as ATCO Electric Ltd
indicated, if it does not own or have any generators
connected to its system then ATCO Electric Ltd does not
need to submit any facility modeling data for distribution
connected generators.
Page 4 of 18
TransAlta
6. TransAlta would like to understand the reasoning behind
the applicability of this rule for (b) and (c) to facilities
capable of a maximum output equal to or greater than
five (5) MVA. We would suggest that a threshold of 10
MVA would be more appropriate.
Subsection 2 – Submission and Approval of Data Related to a Facility
Modification
AltaLink Management Ltd
7.
In this subsection the AESO proposes:
(1)
that the legal owner must provide transmission modeling data to the AESO
with respect to a modification no later than ninety (90) days prior to the
proposed energization date such that the AESO can maintain an accurate
transmission model;
(2)
that the AESO review the data submission received within sixty (60) days of
receiving the data submission and provide notification to the legal owner if the
data submission is deficient;
(3)
that the legal owner resubmit the data submission addressing the
deficiency(ies) identified by the AESO within thirty (30) days of receiving
notice of the deficiency(ies); and
(4)
that the AESO publish the transmission data modeling requirements such that
legal owners understand the specific data that the AESO requires.
In addition, this subsection references Appendix 1 which contains a list of
equipment, machinery and other facility components on which the AESO requires
transmission modeling data should those facility components be modified.
Furthermore, the list in Appendix 1 is supported by Information Document #2010001R Transmission Modeling Data Requirements (“ID# 2010-001R”) that sets out
the data submission details and data submission forms.
6. Please refer to AESO Reply 2(b) above.
Without delaying in-service dates, it will not be possible
for AltaLink to meet the 90 day requirement for all data
presently identified in the Transmission Modeling Data
Requirements (TMDR)” document. This will especially be
true of the smaller and fast paced facility modification
projects. In many instances the entire project duration is
less than 90 days and thus the required data is not even
available in that timeframe. Since this Rule only applies
to facility modifications and these modifications are
typically equipment replacements with relatively similar
modeling characteristics, AltaLink recommends that the
Rule be revised such that the transmission modeling data
must be provided to the AESO within ninety (90) days
after the energization date.
7.
Firstly, the AESO wishes to clarify that the ninety (90)
day requirement is not targeted at urgent or
unplanned equipment modifications. ISO rules
502.15, subsection 3, accommodates urgent or
unplanned equipment modifications and allows the
market participant to provide the modeling data within
seventy two (72) hours of implementing the
modification.
Secondly, if the modification is not urgent or
unplanned then the market participant is doing some
level of planning for the modification and in the
AESO’s opinion, ninety (90) days is a reasonable
target. However, the AESO understands that the
specific data for the modification may not be known
ninety (90) days in advance and therefore the AESO
will accept data submissions based on
manufacturer’s type data for the purposes of meeting
the ninety (90) day requirement. The AESO has
clarified this in final proposed New ISO rules 502.15
and will update the detailed data submission forms in
the Information Document accordingly.
For clarity, the AESO has not changed the ninety
(90) day requirement in final proposed ISO rules
502.15.
In the AESO’s opinion, the requirement to submit data with respect to a modification
AESO Replies to Stakeholder Comments: 2012-08-02
Page 5 of 18
no later than ninety (90) days prior to the proposed energization date is consistent
with the requirements currently set forth in existing ISO OPP 1306.
The AESO has added obligations for the AESO to review the data submitted within
sixty (60) days of its receipt and such to provide notice to the legal owner if the data
submitted is deficient the legal owner must address the deficiency identified by the
AESO within thirty (30) days of receiving notice of same from the AESO. In the
AESO’s opinion, these additional requirements add clarity and certainty for both the
legal owners and the AESO.
8.
Subsection 2(1) of the Rule refers to “Transmission
Modeling Data Requirements (TMDR)” information
document for the required data. It is mentioned in its
“Section 1: Purpose - This document is subject to revision
periodically as the system grows…..” To ensure asset
owners are able to comply, it is necessary to fix the
requirements. Thus, AltaLink recommends that the final
Rule identify the date and version of the TMDR
document.
ID# 2010-001R has supported existing ISO OPP 1306 for some time. While existing
ISO OPP 1306 does not require the AESO to publish the transmission data
modeling requirements, in the AESO’s opinion, it is appropriate to place this
obligation up on the AESO, and accordingly, proposed New ISO Rules Section
502.15 sets out this requirement.
8.
The Information Document sets out the detailed data
submission forms and these may change from time
to time. However, a change to the Information
Document is discussed and agreed upon with the
Transmission Data Committee prior to the change
being implemented. Following implementation of a
change to the Information Document, a market
participant should include the new data submission
and information as required resulting from the
change.
The AESO wishes to point out to stakeholders that the
Information Document does have a revision history
section at the end of the document so it should be
relatively easy to understand the date the Information
Document was changed and the specific change that
was made.
In addition to the above, the AESO is currently
reviewing its Information Document process (“ID
process”) and will be posting information with
regards to the ID process on the AESO website in
the fall of 2012.
9. The requirements do not indicate a time period of
when the AESO will update the transmission system
object model once it has received the data from the
asset owners. AltaLink recommends that a time
period be specified for this activity so that asset
owners know when the transmission system object
model will be updated.
AESO Replies to Stakeholder Comments: 2012-08-02
For these reasons, the AESO has not indicated a
date and version for the Information Document in
final proposed ISO rules 502.15.
9. The AESO agrees that a time period for updating the
transmission system object model should be
indicated. Therefore, final proposed ISO rules 502.15
has been amended to indicate a 30 day time period
for the AESO to update the transmission system
object model once a data submission has been
received from a market participant.
Page 6 of 18
ATCO Electric Ltd
10. Subsection 2(2) of the proposed Rule 502.15 and the
Letter of Notice indicate that the Transmission Modeling
Data Requirements (TMDR) information document sets
out details on what’s required for a submission. However,
the current TMDR document does not include what
technical information is required for aggregated motors or
aggregated distribution connected generators. This makes
it very difficult to comment on the reasonableness of the
proposed Rule 502.15 as it relates to the aggregated
machines. As a result, ATCO submits that a meaningful
consultation can only happen after the current TMDR
document is revised to clearly indicate what information is
required for the aggregated machines. Stakeholders
should be given an opportunity to review any changes to
the TMDR document at the time of or prior to the Rule
consultation.
11. ATCO, through its participation in the Transmission
Data Committee, became aware of the following
proposed changes that may be introduced to the
TMDR document for aggregated machines:
“Aggregated machines are a totaled MVA equivalent for induction
motors, synchronous motors, and generators located in sites where the
site is fed from transformers that connect to voltages greater than 60
kV”
Required information:
 ½-cycle and 3-cycle fault contributions
 Aggregate MVA for
- low- and medium-voltage induction motors;
- medium-voltage synchronous motors
- synchronous and induction generators
½-cycle and 3-cycle fault contribution are the symmetrical fault
current in amperes coming from the site system for a fault on the
Transmission-system side of each of the supply transformers. Where
multiple transformers supply a site, the faults shall be applied
AESO Replies to Stakeholder Comments: 2012-08-02
10. Prior to issuing ISO rules 502.15 for consultation the
AESO has discussed the changes ATCO Electric Ltd.
is referring to with the Transmission Data Committee
and ATCO Electric Ltd participated in those
discussions and therefore, in the AESO’s opinion,
ATCO Electric Ltd is in a position to understand the
data submission changes that will be reflected in the
Information Document as is evidenced in its
comments below. The AESO commits to updating
the Information Document with the changes discussed
and confirmed with the Transmission Data Committee
by August 31, 2012.
11. The obligation to provide aggregated machine models
for motors and for industrial-site generators falls on
the owner of the industrial site where the motors are
installed. During site design the owner’s engineers will
have selected equipment and designed plant
distribution and grounding taking into account the
electrical effects of the equipment installed in the
plant, including fault contributions of the motors and
industrial-plant generators. The obligation to provide
aggregated machine models for distributionconnected generators falls on the distribution
company who entered into connection agreements
with the generator owners. The distribution company
in the course of fulfilling their responsibility to operate
a safe distribution system will have evaluated the
effect of the distribution-connected generators on their
distribution equipment, including the fault
contributions from those generators. In both cases
therefore, the party responsible for submitting the
aggregated machine model will have already
calculated the fault levels being requested or, if not,
will have already compiled the software models from
Page 7 of 18
simultaneously to all supplying transformers.”
Gathering the above-mentioned additional data and
submitting to the AESO require extra resources and costs that
can not be underestimated.
12. ATCO as a TFO is responsible for the safe and
reliable operation of the interconnected DFO and also
has the obligation to ensure monies expended on
studies and data gathering/modeling are prudent.
ATCO submits that any changes or additional data
requirements currently being contemplated by the
AESO may be imposed to the stakeholders only if
they add clear value to the AESO’s transmission data
model. In that regard, AESO should clearly explain:
- How does the AESO plan to use the above data? What
studies would use the data?
- Why are the additional data essential to fulfill the
AESO’s mandate in transmission planning and
operation?
- What are the specific examples that demonstrate the
additional data would make a material difference in
transmission planning, operation or design?
ATCO is of the view that no additional data should be required
unless the above questions can be answered to satisfy the
stakeholders that there is clear value and well-defined use for
those additional data.
With respect to the requirements for the specific fault
contribution information listed above for aggregated
generators, ATCO offers the following comments learned
through years of experience:
It is recognized that proper selection of any electrical
equipment installed in a power system must be mechanically
AESO Replies to Stakeholder Comments: 2012-08-02
which the fault levels can be obtained without undue
expense. Based on the above explanation, it is the
AESO’s opinion that no additional and significant
costs should be incurred and therefore the AESO has
not made any changes to final proposed New ISO
rules Section 502.15.
12. AESO’s mandate is defined in the Electric Utilities
Act section 17 and goes beyond transmission
planning and operation. In particular the AESO has a
duty to “to collect, store and disseminate information
relating to the current and future electricity needs of
Alberta and the capacity of the interconnected
electric system to meet those needs, and make that
information available to the public;”.
Aggregated machines of sufficient size, when
connected at intermediate voltages, can affect the
capacity of the system to meet Alberta’s needs by
contributing to voltage collapse during voltage
excursions, by providing load relief during frequency
excursions, by contributing to fault levels, and by
changing the net equivalent source impedance at
the point of interconnection with industrial plants. The
total MVA of different classes of motor load informs
complex load models during dynamic simulation.
AESO will incorporate the aggregate machine data
into the TASMo model, include them in the AESO
planning base cases, and use them to create the
complex-load models. AESO is also submits this
data to WECC, and makes them available to Alberta
stakeholders for use in their own studies.
Stakeholder studies include plant design and safetyequipment specification studies performed at
industrial sites. The presentation Assumptions And
Source Data For Short Circuit And Arc Flash
Calculations In Industrial Facilities given at the March
2012 IEEE Electrical Safety, Technical and
Megaprojects Workshop presented specific
examples of calculations affected by fault
calculations from adjacent and near-by industrial
Page 8 of 18
braced for and withstand the higher magnitude fault currents
where the equipment is installed until the upstream protection
devices clear the fault. However, for transmission substation
equipment, the peak withstand and the ‘close and latch’
capabilities are ensured through the quoting and use of the
appropriate IEEE/ANSI standards. For example ANSI C37.062009 specifies that the minimum close and latch rating is 82
kA pk based upon 31.5 kA interrupting rating, a value unlikely
to be ever reached at typical industrial/mixed load substations,
and less likely as the AESO prefers the use of 40 kA
interrupting ratings at 145 kV (Similar recommendations exist
for other voltage levels). Furthermore, any fault contribution
from aggregated distribution connected generators becomes
immaterial when it reaches the substation due to the
impedances of transformer and distribution line between the
generator and the substation. Substation equipment selection
based on system fault levels combined with safety margin
proves to be adequate. Therefore ½-cycle and 3-cycle fault
contributions from aggregated motors or distribution
connected generators are not needed for transmission
substation equipment selection.
plant aggregate machines.
Based on the above explanation, it is the AESO’s
opinion that the data related to aggregated machines
is necessary and as such no changes have been
made to final proposed ISO rules 502.15.
For distribution connected customers, local influences within
the same industrial site, surrounding distribution topology and
impedances from the transmission point of common coupling
will be the overriding factors that influence customer selection
of equipment and protection. The manufacturing and
protection industry for low and medium voltage fuses and
circuit breakers have well established practices set out to
determine the momentary duty and interrupting duty for
specifying such downstream equipment. Expenditure of TFO
or DFO resources to reflect this back upon the transmission
facility will not benefit either these distribution customers or
the transmission network in what understanding or impact this
will have on current practices in equipment selection.
As per industry knowledge for induction machines, the inertia
of the loads act as a prime mover and thereby deliver fault
current for a few cycles. Furthermore the magnetic field in the
motor is collapsing due to the voltage sag during the fault.
This fault contribution is important when considering medium
AESO Replies to Stakeholder Comments: 2012-08-02
Page 9 of 18
voltage switchgear, fuse clearing and interrupting/withstand
ratings of low voltage equipment where this component is
added to obtain the total fault current. However, this
information can be and should be provided to the customer by
the DFO directly because the DFO is most familiar with the
adjacent system. In fact, for distributed generator connections
or new load additions to the distribution system, ATCO as a
DFO has process in place to provide customers short circuit
information at the point of common coupling, which would
have included the contributions from any adjacent
synchronous machines.
13. Should the AESO choose to expend monies through
such data gathering, it is suggested that the distribution
connecting customers with synchronous machines be
required to provide the information directly to the AESO
(not through the DFO or TFO) to avoid additional costs to
the ratepayers.
14. 90 days requirement:
13. Please refer to AESO Reply #5 above.
14. Please refer to AESO Reply #7 above.
There are circumstances that manufacture test reports or
design data are not available 90 days before the planned
modification. ATCO is of the position that the facility owner
should be given the option to submit modelling data based on
best available information at the time of the required
submission, and then submit amendment when more accurate
information becomes available.
15. ATCO also submits that no impedance submission should
be required if the change in impedances after planned or
emergency modifications are within 5% (typical safety
margin built in design).
AESO Replies to Stakeholder Comments: 2012-08-02
15. The AESO agrees that negligible changes to
equipment can be made where the engineer, using
his or her good electric industry practice judgment
has assessed that the changes are unlikely to have a
measureable effect on the impedance of the
equipment. In the case of transformers and
machines, the impedances are tested and provided
by the manufacturer and as such there should be no
concern or issue. In the case of transmission lines,
Page 10 of 18
the type and extent of the change will determine if an
impedance submission is required or not, and if an
engineer is unable to determine this, the AESO
strongly encourages that person to contact the
AESO for direction. In the AESO’s opinion,
engineers should be using good electric industry
practice judgment and as such the AESO has not
amended final proposed ISO rules 502.15 to set out
all the permutations for impedance submissions
related to transmission lines.
EDTI
16. EDTI does not agree with the inclusion of the information
document titled, “Transmission Modeling Data
Requirements” with this rule. The rule should explicitly list
all equipment for which modifications require the legal
owner to act according to the rule. Referencing an
external document that is not authoritative allows the
authoritative document (ISO Rule 502.15) to change when
the external document is modified. The ISO is obligated
to consult with market participants when modifications are
proposed to existing ISO rules as per AUC Rule 017.
Information documents are not subject to a similar
consultation process when they are modified. Situations
may arise when modifications to the information document
alter the ISO rule in which it is referenced. This should
not be permitted as it would violate AUC Rule 017. To
avoid this possibility, EDTI recommends removing the
reference to the information document, “Transmission
Modeling Data Requirements” within Rule 502.15.
AESO Replies to Stakeholder Comments: 2012-08-02
16. ISO rules 502.15 requires market participant to submit
facility modification modeling data. The Information
Document contains a series of forms supporting the
detailed data submissions.
EDTI is correct that Information Documents are not
subject to the process and procedures outlined in
AUC Rule 017. However, as mentioned in AESO
Reply #8 above, the AESO is currently reviewing its
ID process and will be posting information with
regards to the ID process on the AESO website in
the fall of 2012.
In the AESO’s opinion, a modification to the detailed
submission forms in the Information Document would
not impact or alter the categories set out in Appendix
1 of proposed ISO rules 502.15. For clarity, the
AESO would not be modifying the data submission
forms to include data that was not contemplated in
one of the categories in Appendix 1 of proposed ISO
rules 502.15. Therefore, the AESO has not amended
ISO rules 502.15 to remove the reference to the
Information Document.
Page 11 of 18
17. EDTI’s understands that the purpose of ISO Rule
502.15 is to maintain various transmission system
models (TASMo, EMS, and the GIS Model). This is
accomplished by facility owners notifying the ISO of
changes to certain characteristics of equipment listed
in the information document, “Transmission Modeling
Data Requirements”. The current draft of Rule 502.15
is unclear as to which characteristics of which types of
equipment trigger the ISO notification requirement.
EDTI believes the appendix referenced in the rule
should include all equipment characteristics and
parameters that the rule applies to. EDTI believes
that the inclusion of a checklist similar to section 4.1
of the Transmission Modeling Data Requirements
document would generate more information than
would the appendix included in the current draft of
Rule 502.15.
17. Stakeholders appear to have opposing views with
regard to retaining or removing Appendix 1 from
proposed ISO rules 502.15.
In the AESO’s opinion, it is important to provide a
level of certainty to market participants with regard to
the type of data the AESO is interested in. To
achieve this level of certainty the AESO has listed
the categories in Appendix 1. If, in the future the
AESO wishes to change those categories then it is
required to formally consult with market participants
in accordance with Alberta Utilities Commission Rule
017 Procedures and Process for Development of
ISO Rules and Filing of ISO Rules with the Alberta
Utilities Commission. In the AESO’s opinion, if it
seeks to change the categories it should be formally
consulting with market participants and therefore, the
AESO has left Appendix 1 in final proposed ISO
rules 502.15.
The Information Document supporting ISO rules
502.15 contains a series of detailed submission
forms supporting the categories set out in Appendix
1 of proposed ISO rules 502.15. As mentioned
above, AESO would not be modifying the data
submission forms to include data that was not
contemplated in one of the categories in Appendix 1
of proposed ISO rules 502.15. In the AESO’s
opinion, setting out the categories in Appendix 1 of
proposed ISO rules 502.15 and having the detailed
submission forms in an Information Document is
appropriate.
While the AESO has not removed Appendix 1 in final
proposed ISO rules 502.15, it has amended the
appendix. It has removed the following from
Appendix 1 as these items do not represent specific
types of equipment:
(a) electrical and physical parameters for
transmission system objects;
AESO Replies to Stakeholder Comments: 2012-08-02
Page 12 of 18
(b) load and generation measurement and forecast;
(e) transmission facilities;
(i) elements;
In summary, Appendix 1 remains in final proposed
ISO rules 502.15 but it has been amended for the
removal of the four items above.
18. EDTI believe that Rule 502.15 should not include load
and generation forecast data. This data was not required
as part of OPP 003.4, OPP 003.5 or OPP 1306. Another
authoritative document, the ISO Tariff Application
(Section 7 - 3(1) of the Terms and Conditions), requires
market participants to provide forecast data to the ISO.
EDTI is also concerned that if the load forecast remains
part of ISO Rule 502.15, TFOs will be required to
formally submit a new forecast to the ISO after every
iteration. Sometimes this occurs on a monthly or weekly
basis. Currently, TFOs provide load forecasts to the ISO
approximately once per year.
19. EDTI notes that the wording in the stakeholder
consultation document does not match the wording of the
drafted rule. Subsection 2(4) of the drafted rule states
that after the ISO receives a submission under subsection
2(1), it will “notify the legal owner in writing of the decision
no later than sixty (60) days prior to the date of
energization of the modified equipment, machinery or
other facility components.” This timeframe is not the
same as “within sixty (60) days of receiving the data
submission”, as stated in the consultation document.
EDTI agrees with the wording in the drafted rule
document
AESO Replies to Stakeholder Comments: 2012-08-02
18. It is not the AESO’s intent to include all forecast
information. The AESO will amend the detailed
submission forms in the Information Document to
clarify the specific forecast information needed.
19. Subsection 2(4) of proposed ISO rules 502.15 is the
correct language.
Page 13 of 18
TransAlta
20. TransAlta would like further clarification of (1):
According to Stage 5 of the PDUP outlined in the PDUP-IM,
modelling data must be received by the AESO 100 days prior
to energization; however, OPP1306/ISO Rule 502.15
indicates that the data must be submitted no later than 90
days prior to energization. Why is there a 10 day difference
between the two? Is there a difference between the PDUP
submission and the OPP1306/ISO Rule 502.15 submission?
Could the AESO clarify and identify the difference(s)?
20. The AESO recognizes that the Project Data Update
Package Instruction Manual (“PDUP-IM”) states that
modeling data is required 100 days prior to
energization.
Firstly, the AESO wishes to point out that the PDIPIM is focused on connection projects and not on
facility modifications once facilities are modified.
Secondly, the AESO recognizes that all parties are
diligently working towards the target in-service date
when connecting new facilities and as such a delay
in the in-service date can have significant impacts on
several parties and not just on the market participant
connecting the facilities. The 100 days stated in the
AESO’s Connection Process and in the PDUP-IM is
a target to ensure that the in-service date is not
delayed. With every connection project the AESO
issues an Energization Package Deliverables
Requirement Letter (“letter”) and within that letter
there is a provision that states:
“Timelines presented may have been adjusted by the
AESO Project Manager/Coordinator in conjunction
with AESO Operations in consideration of project
complexity or other project factors that may impact or
influence a deliverable(s).”
Not every new connection is the same and larger
more complex projects may actually require a longer
lead time; something greater than 100 days.
Lastly, the AESO does need 90 days lead time to
appropriately process and model the data whether
that data is a result of a new connection or a facility
modification.
Therefore, based on the above explanation the
AESO has not amended the 90 day requirement in
final proposed ISO rules 502.15.
AESO Replies to Stakeholder Comments: 2012-08-02
Page 14 of 18
As a note, stakeholders can always suggest that the
100 day reference in the AESO’s Connection
Process and the PDUP-IM document be changed to
align with the 90 days in ISO rules 502.15 if
necessary and appropriate.
21. TransAlta would like to suggest the following changes:
21.
(1) that the legal owner must provide transmission
modeling data they have available to the AESO with
respect to a modification no later than ninety (90)
days prior to the proposed energization date such that
the AESO can maintain an accurate transmission
model;
(We would like to point out that equipment data is not
always available 90 days prior to target energization
date.)
(1) Please refer to AESO Reply #7 above.
(2) No changes suggested.
(2) No replies required.
(3) that the legal owner resubmit the data submission
addressing the deficiency(ies) identified by the AESO
within sixty (60) days of receiving notice of the
deficiency(ies);
(We believe that 30 days will be too short of a
timeframe to respond to the AESO.
(3) If a market participant identifies a discrepancy
then it has essentially confirmed that the model is
deficient; the model is different from the actual
facilities. In the AESO’s opinion, the market
participant already has the correct data which was
the reason for triggering the discrepancy and as
such the 30 days referenced in ISO rules 502.15
should not be problematic for the submission of
that data . Therefore, the AESO has not
amended final proposed ISO rules 502.15 with
respect to the 30 day requirement referenced in
Section 5(1).
(4) No changes suggested.
(4) No replies required.
Subsection 3 – Operational Modification
AltaLink Management Ltd
This subsection recognizes that a legal owner may need to make a modification on
an unplanned or urgent basis and when this occurs, the legal owner must notify the
21. As per AltaLink’s comments in Section 2, since this Rule
only applies to facility modifications and these
AESO Replies to Stakeholder Comments: 2012-08-02
In accordance with AESO Reply #7 and 20(1) above the
AESO has amended the language in final proposed ISO
rules 502.15 such that manufacturer’s type data is
Page 15 of 18
AESO within twenty-four (24) hours of making the modification and, submit the
transmission modeling data regarding the modification within seventy-two (72) hours
of making the modification.
Existing ISO OPP 1306 contemplates the need for transmission modeling data for
“emergency replacements” and recognizes that this data cannot be submitted ninety
(90) days prior to the proposed energization date. However, existing ISO OPP 1306
does not specify the timeframe for such data submission. In the AESO’s opinion,
specifying the timeframes regarding when data must be submitted provides clarity
and certainty for both the AESO and market participants.
modifications are typically equipment replacements with
relatively similar modeling characteristics, AltaLink
recommends that the Rule be revised such that the
transmission modeling data must be provided to the
AESO within ninety (90) days after the energization date.
acceptable.
The AESO does require data that is representative of the
facilities prior to energization such that the transmission
model and energy management system model include
some level of information on all facilities connected to the
transmission system. Therefore, in the AESO’s opinion it
is essential to obtain data prior to energization and as
such the AESO has not amended the language in final
proposed ISO rules 502.15 to allow for the submission of
data after energization.
ATCO Electric Ltd
22. ATCO submits that replacements on a temporary basis
should be exempted from this requirement if there is a
plan to place a permanent unit back to service. Such
exemption should include the use of mobile substation for
planned maintenance or under emergency circumstances,
which only require short durations (can be as short as 72
hours). Any emergency spare used during the repair of a
failed POD transformer or regulator should also be
exempted from this data submission requirement because
it has negligible impact on the transmission system.
22. The AESO disagrees that emergency circumstances
should be exempt from ISO rules 502.15. The AESO
recognizes that a market participant will not be able to
submit data for unplanned and urgent changes prior
to energization and as such the AESO has allowed for
the submission of data post energization in ISO rules
502.15 subsection 3 if the circumstances were
unplanned or of an urgent nature.
With regard to mobile substations referenced by
ATCO Electric Ltd. The AESO agrees that the AESO
does not need modeling data from mobile substations
if those mobile substations are set up for a short
period of time. Therefore, the AESO has amended
final proposed ISO rules 502.15 such that modeling
data is not required if the mobile substation is set up
for a period of 7 calendar days or less. For clarity, if
a mobile substation is in set up for a period of more
than 7 calendar days then the AESO will require
modeling data for the mobile substation 90 days in
advance of energizing the mobile substation.
TransAlta
23. TransAlta would like further clarification regarding the
interpretation of the statement: “making the modification”.
At what point in time would the 24 hours start? Would this
be at the time of implementation of the modification itself
AESO Replies to Stakeholder Comments: 2012-08-02
23. The reference to 24 hours in ISO rules 502.15
subsection 3(c) means within 24 hours of energizing
the modification.
Page 16 of 18
or at the time of energizing after the modifications have
been completed?
TransAlta would like to suggest the following changes:
The legal owner must notify the AESO within twenty-four
(24) hours of completing the modification and, submit the
transmission modeling data regarding the modification
within seven (7) days of completing the modification.
Subsection 4 - Reporting by the Legal Owner of Transmission System Object
Model Discrepancies
This subsection sets out obligations regarding discrepancies identified by the legal
owner with respect to transmission modeling data.
Existing ISO OPP 1306 contemplates periodic reviews for the purpose of identifying
and explaining any variances, however existing ISO OPP 1306 does not specify any
reporting timeframes.
In the AESO’s opinion, specifying the timeframe for reporting any discrepancies
identified provides additional clarity and certainty for legal owners.
The AESO has amended the language in final
proposed ISO rules 502.15 to clarify this.
TransAlta also suggests that the 72 hours in ISO rules
502.15 subsection 3(d) be changed to 7 days. In the
AESO’s view, after making the modification the
market participant will have the data and as such the
72 hours submission timeframe should not be difficult
to achieve. Therefore, the AESO has not amended
the language in final proposed ISO rules 502.15 to
reflect the suggested change.
EDTI
24. EDTI notes there is inconsistency between subsection 4
(Reporting by the Legal owner of Transmission System
Object Model Discrepancies) and subsection 5
(Reporting by the ISO of Transmission System Object
Model Discrepancies). Subsection 5 allows the ISO to
confirm suspected discrepancies prior to providing the
legal owner with written notice of the discrepancy.
However, subsection 4 does not provide this same
freedom to the legal owner to confirm the suspected
discrepancy. Legal owners must report all suspected
discrepancies, whether they are confirmed, not
confirmed, or found invalid. EDTI proposes that
subsection 4(1) end with the phrase, “unless the
suspected discrepancy was found to be invalid.”
24. The AESO agrees that the market participant should
confirm a suspected discrepancy prior to reporting it.
Therefore, the AESO has amended the language in
final proposed ISO rules 502.15 to allow for this
confirmation.
Subsection 5 - Reporting by the AESO of Transmission System Object Model
Discrepancies
This subsection sets out obligations regarding discrepancies identified by the AESO
with respect to transmission modeling data.
Existing ISO OPP 1306 contemplates periodic reviews for the purpose of identifying
and explaining any variances, however existing ISO OPP 1306 does not specify any
reporting timeframes.
In the AESO’s opinion, specifying the timeframe for reporting any discrepancies
identified provides clarity and certainty for legal owners.
AESO Replies to Stakeholder Comments: 2012-08-02
Page 17 of 18
Additional Changes
Stakeholders may notice that existing ISO OPP 1306 contains requirements
regarding generator model validation reporting and that these requirements were not
transitioned to proposed New ISO Rules Section 502.15.
The generator model validation reporting requirements are now contained in ISO
rules Section 502.1 Wind Aggregated Generating Facilities Technical Requirements
and proposed ISO rules Section 502.5 Generating Unit Technical Requirements.
Therefore, to prevent duplication, the AESO has not transitioned these requirements
from existing ISO OPP 1306 to proposed New ISO Rules Section 502.15.
(b) Amendments
There are no amendments to ISO rules provisions associated with the proposed
New ISO Rules Section 502.15.
(c) Removals
No removal of ISO rules provisions are being proposed for proposed New ISO Rules
Section 502.15.
(d) Other
Stakeholders wishing to comment on specific provisions are requested to copy the
provision into this area and provide comments.
AltaLink Management Ltd
25. AltaLink recommends that Appendix 1 be removed from
this Rule as the equipment categories contained therein
are already included in the Transmission Modeling Data
Requirements document.
25. Please refer to AESO Reply #17 above.
ATCO Electric Ltd
26. ATCO finds that Appendix 1 as specified in the proposed
Rule does not provide clarify, rather it adds confusion and
can create inconsistency with the TMDR document.
AESO Replies to Stakeholder Comments: 2012-08-02
26. Please refer to AESO Reply #17 above.
Page 18 of 18