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Transcript
EE379K/EE394V Smart Grids:
Renewable Integration Hurdles
Brad Bell,
Ross Baldick,
Director of Customer Solutions
Smart Wires, Inc
Department of
Electrical and
Computer
Engineering
Spring 2017
Copyright © 2017
1
Outline

Utility Scale Renewable Project Development Overview

Generation Interconnection Overview



Generation Interconnection Cost Allocation Overview


Existing Barriers in Transmission
Steady State Case Studies
ERCOT Model vs. Load Flow Cost Allocation Model
Future Integration – Environmental Regulations


Clean Power Plan
State Level Legislation
Copyright © 2017
2
Renewable Project
Development Overview
Copyright © 2017
3
Renewable Project Development Overview
Copyright © 2017
4
Renewable Project Development Overview

Key inputs for siting new projects/
project selection







Transmission Availability
Real Estate Availability
Local Permitting Requirements
Wind/Solar Resource Strength
Regulatory Environment
Energy/Capacity Market Health
Renewable Energy Incentive Programs
Copyright © 2017
5
Generation Interconnection
Overview
Copyright © 2017
6
Interconnection Study Overview


Every Transmission Owner in the U.S. requires a set of
interconnection studies to be performed for utility scale generation
to interconnect to the grid.
The primary intent of the interconnection study process is to allow
for the reliable interconnection of resources attempting to site
within the existing Transmission Owner’s service region.




The interconnection studies will verify that the proposed generation
asset will be able to meet the reliability and operating criteria for an
asset in the region.
The interconnection studies will identify the Transmission
Interconnection Facilities necessary to physically interconnect the
generation resource.
The interconnection studies will identify any Network Upgrades
necessary to interconnect the generation resource and assign a cost
allocation methodology for procuring the Network Upgrades.
Upon completion of an Interconnection Study the generation unit
looking to interconnect to the grid may do so based upon the terms of
a negotiated Interconnection Agreement (IA).
Copyright © 2017
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Interconnection Study Overview



Feasibility Study- Informs the generation asset developer of
transmission system constraints that could limit the ability of the
unit to generate.
System Impact Study- In depth evaluation of the impact of
inserting the generation asset onto the transmission system.
Performed to identify Network Upgrades and Transmission
Interconnection Facilities necessary to physically and electrically
interconnect the proposed generation asset to the transmission
system.
Facilities Study- Determine the final cost and time estimates to
construct the Network Upgrades and Transmission Interconnection
Facilities necessary to physically and electrically interconnect the
proposed generation asset to the transmission system.
Copyright © 2017
8
Feasibility Study Overview



The Feasibility Study informs the generation asset developer of
transmission system constraints that could limit the ability of the
unit to generate
Transmission constraints are determined by either a DC or AC
contingency analysis on an expected future case.
The Feasibility Study will present to the project developer(s) the
following information




List of system binding constraints (Overloaded Element & Binding
Contingencies) which can limit the output of the generator(s) in the study.
Transmission upgrades and costs necessary to mitigate the constraints to
obtain full power output.
Performed in ~3 months.
Generally performed in PSS/E, PSLF, PowerWorld, Tara,
DIgSILENT
Copyright © 2017
9
System Impact Study Overview

System Impact Study- In depth evaluation of the impact of
inserting the generation asset onto the transmission system.
Performed to identify Network Upgrades and Transmission
Interconnection Facilities necessary to physically and electrically
interconnect the proposed generation asset to the transmission
system.




Steady State- Evaluation of the transmission system under both
normal and contingency conditions in accordance with NERC TPL
Standards.
Short Circuit- Identify the increased level of fault duty on the
transmission system as a result of the addition of the generator(s)
Stability/Reactive Power Requirement – Will determine the impact
of the generation asset on transient stability performance of the
transmission system due to system disturbances
Performed in ~9-18 months
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10
Steady State Study Overview



The Steady State Study will include the evaluation of the
transmission system under both normal and contingency
conditions in accordance with NERC TPL Standards. The analysis
will include both steady state thermal and voltage analysis.
The Steady State Study is a more in depth version of the
Feasibility Study.
The Steady State Study will present to the project developer(s)
the following information





Maximum output where no constraints exist.
List of system binding constraints (Overloaded Element & Binding Contingencies)
which can limit the output of the generator(s) in the study.
Maximum output under constraint scenarios
Transmission upgrades and costs necessary to mitigate the constraints to obtain full
power output.
Generally performed in PSS/E, PSLF, PowerWorld, Tara,
DIgSILENT
Copyright © 2017
11
Steady State Study Overview

The Steady State Study Analysis will follow the following steps
a) Formulation of Basecase scenario(s) to be studied
a)
b)
c)
Minimum of a peak loading case along with one sensitivity non-peak case
Wind Integration Sensitivity: High Wind / Low Load case
Solar Integration Sensitivity: Fall/Spring/Winter Peaking case.
b) Evaluation of Basecase scenario(s) to be studied
a)
b)
Run complete N-1 contingency analysis
Identify most limiting constraints on the system
c) Insert Interconnecting Generator(s) into the basecase to create the final
study case
a)
b)
c)
Run complete N-1 contingency analysis
Identify the Maximum output where no constraint exists
Identify acceptable measures to relieve any identified constraints
- New Transmission Line Build
- Transmission Line Reconductor
- Transformer Replacement
- Powerflow Control Devices (Series Reactor, Series Capacitor, Phase Shifting Transformer, Distributed Control Devices)
- Unit Deration
- Unit Relocation
- Special Protection Scheme (SPS) / Remedial Action Scheme (RAS)
d) Create Study Report
a)
Report upgrades and necessary costs required to mitigate any system constraints identified during analysis
Copyright © 2017
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Steady State Case Study #1
Base Case N-1 Analysis
244 MVA/292 MVA
Sidney
Cabo
Graham
122 MVA/122 MVA
Powel
Copyright © 2017
13
Steady State Case Study #1
Interconnection Customer N-1 Analysis
Cabo
Sidney
Graham
Powel
Copyright © 2017
14
Steady State Case Study #2
Base Case N-1 Analysis
244 MVA/292 MVA
Sidney
Cabo
Graham
122 MVA/122 MVA
Powel
Copyright © 2017
15
Steady State Case Study #2
Interconnection Customer N-1 Analysis
Cabo
Sidney
Graham
Powel
Copyright © 2017
16
Steady State Case Study #2
T-Line Reconductor Solution
Cabo
Sidney
Graham
Powel
* Example Reconductor Cost = $1-1.2M/mile
* Project Cost @ 22.6 miles = $22.6M-27.12M
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17
Steady State Case Study #2
Special Protection System (SPS) /
Remedial Action Scheme (RAS)
Cabo
Sidney
Graham
Generation Ramp Back Info
• The Sidney – Powell 138 kV line
overloads to 124% of its
122 MVA /122 MVA rating.
• 151 MVA loading on Sidney – Powell
138 kV line post contingency.
• Each unit has a post contingency 34%
shift factor on the constrained
Sidney – Powel line.
• A common SPS/RAS strategy is to
have a generator back its generation
down automatically post contingency
to protect existing transmission
equipment
Powel
Copyright © 2017
18
Steady State Case Study #2
Special Protection System (SPS) /
Remedial Action Scheme (RAS)
45 MW
Cabo
Sidney
Graham
Generation Ramp Back Strategy
• For every MW reduced at Gen A 0.34
MW will be reduced from the
Sidney – Powel 138 kV facility
• Gen A will create an automatic ramp
back scheme that will back its
generation down to 45 MW after
receiving signal from the Transmission
Owner that the Graham – Cabo 138
kV line is out of service.
• The Transmission Owner will have the
right to disconnect Gen A if it fails to
achieve ramping in agreed upon
timeline
Powel
Copyright © 2017
19
Steady State Case Study #2
Powerflow Control / Series Reactor Solution
Cabo
Sidney
Graham
Powel
* 4.05 ohm/phase series reactor may lower
line loading to 95% of rated value.
* No other lines in area can be overloaded
with powerflow control insertion
Copyright © 2017
20
Powerflow Control – Series Reactor




Main purpose is to increase line reactance. Thus diverting flow
away from circuit where the reactor is applied.
Often used in highly meshed networks with available capacity
on existing circuits.
Often seen as a “last resort” as the devices do not create
additional capacity on the system. Fixed device that allows for
access to existing underutilized circuits.
Increasing line reactance lowers system stability, thus in
stability constrained regions series reactors are not often utilized
Copyright © 2017
21
Smart Wires Guardian –
Distributed Series Reactor DSR
• Distributed series reactors serve the
same core function as traditional
devices, increase line reactance
• Each device has a fixed reactance
injection
• As a fleet allows for variable
reactance injection
• Three methods of operation:
1. Static, no backhaul comms required
2. Manual Control, controlled by grid
operator
3. Set Point Control, operated via setpoint with central override
• Embedded sensing technology and
fleet level communications
Copyright © 2017
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Steady State Case Study #2
Powerflow Control / Smart Wires Solution
Cabo
Sidney
Graham
• 4.05 ohm/phase DSR can eliminate the
overload condition
• At 600A Smart Wires DSR device can
deliver 0.0253Ω reactance per device.
Powel
• 4.05Ω / 0.026Ω per device =
• 160 devices per phase
• 480 devices total
* No other lines in area can be overloaded
with powerflow control insertion
Copyright © 2017
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Series Capacitors




Series capacitors are primarily installed in systems with
extremely long transmission lines as a way to electrically
shorten the lines and reduce system instabilities
Typically applied on 230kV lines and above
Alleviate thermal and voltage constraints
Introduce Subsynchronous Resonance risks
Copyright © 2017
24
Smart Wires Router– Distributed Static
Synchronous Series Compensator (SSSC)
• Connected in series to the
transmission line.
• Controls effective reactance of a
transmission line through voltage
injection
• Operates in both inductive and
capacitive mode of operation
• Does not introduce Subsynchronous
Resonance (SSR) Issues
Power Line
XM
Current
Feedback
• Three methods of operation:
Power
Supply
SM
S2
Cf
1. Static, no backhaul comms required
Control
2. Manual Control, controlled by grid
operator
Comms
3. Set Point Control, operated via setpoint with central override
Lf
CDC
•
Copyright © 2017
Embedded sensing technology and fleet
level communications
25
Short Circuit Study


The goal of the short circuit study is to assess and identify the
increased level of fault duty on the transmission system as a result of
the addition of the generator(s) in the study.
The short circuit study will identify and address the circuit breakers and
transmission buses overdutied by the addition of the generator(s) in
the study.


The short circuit study will be performed with and without the
proposed generation assets. This allows the Transmission Owner to
assess the impact of the proposed generator(s) on fault duty level for
various fault locations.



Identified circuit breakers and transmission busses overdutied will be
included in the Interconnection Facilities Study
Analysis performed on 3-phase and Single Line – to Ground faults
Analysis performed on faults within 3-5 busses from point of
interconnection
Generally performed in PSS/E, Aspen, Cape
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Stability Study

Transient Stability – The capability of the system to return to a
stable operating point after the occurrence of a disturbance.






Tripping of a Generator Or Line
Load dropping
Occurrence of a fault
When a disturbance does occur the system is no longer in a
steady state and you will see changes in rotor speeds and node
voltages will deviate from the steady state values
The system is stable if the fluctuation in system quantities damp
out and the system settles to a steady operating point
The system is considered unstable when the deviation in system
quantities continue to grow and can lead to tripping of facilities
and eventually system collapse
Copyright © 2017
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Stability Study
Stable Response
Copyright © 2017
28
Stability Study
Poorly Damped
Copyright © 2017
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Stability Study
Unstable Response
Copyright © 2017
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Stability Study


Wind and Solar projects tend to be sited in remote areas of power
systems where the fuel resource is most prevalent. These areas are
generally remote from synchronous generation and load centers and
under certain scenarios can be considered “weak grids”
System characteristics and challenges that occur in a “weak grid” can
be [1]




Highly compensated weak grids can see voltage collapse with in the normal operating
voltage range. Static Capacitors or Static Var Compensators contribute to this issue
and have limited effectiveness to increasing transfer flows.
Renewable projects are essentially connected to a common POI in many instances.
The close connection creates a condition such that each plant interacts with each
other.
A grid with low short circuit ratios and high voltage sensitivity of dV/dQ requires
special coordination of various control systems. Normal voltage control settings can
result in too much voltage support, in a weak system this can lead to undamped
oscillations. Detailed control system modeling is required to study this phenomenon.
Voltage Ride Through Capability (HVRT & LVRT). Post contingency bus voltages in a
weak grid system tend to deviate higher than in a strong grid scenario. Additional
HVRT capability is necessary to maintain a stable response.
[1] http://www.ercot.com/content/news/presentations/2014/Panhandle%20Renewable%20Energy%20Zone%20Study%20Report.pdf
Copyright © 2017
31
Stability Study

Steps considered to alleviate “weak grid” conditions caused by addition of
asynchronous generation





Increase connectivity to rest of grid with additional transmission lines
Synchronous Condensor addition
Reactor insertion
Implementation of Generic Transmission Limits (GTLs)
Increased Voltage Ride Through (VRT) requirements for Intermittent Renewable
Resources (IRR)
Copyright © 2017
32
Facilities Study





The Facility Study determine the final cost and time estimates to
construct the Network Upgrades and Transmission
Interconnection Facilities necessary to physically and electrically
interconnect the proposed Generation asset to the transmission
system.
Results of the System Impact Study are the main inputs to the
Facilities Study.
The study develops a detailed cost estimate that includes
equipment, engineering, procurement and construction costs to
the most accurate accuracy possible based on in-service dates
provided by the generation asset developer.
Results of the Facilities study are included in a deliverable to the
generation asset developer. The results are often included in
the Generation Interconnection Agreement.
Performed in 3-4 months
Copyright © 2017
33
Generation Interconnection
Cost Allocation Methods
Copyright © 2017
34
Definitions




Generator Interconnection Facilities (GIF) – Generator owned
transmission facilities necessary to interconnect the unit
Transmission Interconnection Facilities (TIF) – Transmission
Owner owned transmission facilities necessary for the physical
interconnection of the unit
Point Of Interconnection (POI) – Location where the Generation
Interconnection Facilities Interconnect to the Transmission
Interconnection Faciliites. “Change of ownership point.”
Network Upgrades – Transmission system upgrades necessary
to prevent unreliable operating conditions on the grid under
prior outage conditions.
Copyright © 2017
35
Gen. Interconnection Cost Allocation
Copyright © 2017
36
Gen. Interconnection Cost Allocation:
ERCOT Method

PUCT Substantive Rule §25.195.(c).1 – Terms and Condition of
Transmission Service – Construction of New Facilities.

When an eligible transmission service customer requests transmission
service for a new generating source that is planned to be
interconnected with a TSP's transmission network, the transmission
service customer shall be responsible for the cost of installing
step-up transformers to transform the output of the
generator to a transmission voltage level and protective
devices at the point of interconnection capable of electrically
isolating the generating source owned by the transmission service
customer. The TSP shall be responsible, pursuant to paragraph
(2) of this subsection, for the cost of installing any other
interconnection facilities that are designed to operate at a
transmission voltage level and any other upgrades on its
transmission system that may be necessary to accommodate
the requested transmission service
Copyright © 2017
37
Gen. Interconnection Cost Allocation:
ERCOT Method

Generator Interconnection Facilities (GIF) are physically
constructed and financially funded by Generation Owner.
GIF include





Generator Collector Substation
Generator Step-Up (GSU) Transformer
Circuit Breaker on high side of GSU
Generation Tie Line (Gen can decide ownership)
Transmission Interconnection Facilities(TIF) will be
physically constructed by the Transmission Owner (TO).
Transmission Owner will finance the TIF through their
rate base.



New substation bay if interconnecting to an existing substation
New substation if interconnecting to an existing line
Generation Tie Line (Gen can decide ownership)
Copyright © 2017
38
Gen. Interconnection Cost Allocation:
ERCOT Method





Network Upgrades will NOT be constructed.
Network Upgrades are NOT required for reliability in
ERCOT
ERCOT does not have a Generation Deliverability
Reliability Standard
Transmission Owner is not responsible for
guaranteeing any deliverability of an interconnecting
Generator to the market.
Interconnection Policies were put in service to create
greatest amount of competition in ERCOT’s energy
only market
Copyright © 2017
39
Gen. Interconnection Cost Allocation:
Load Flow Cost Allocation Method

Generator Interconnection Facilities (GIF) are
physically constructed and financially funded by
Generation Owner. GIF include





Generator Collector Substation
Generator Step-Up (GSU) Transformer
Circuit Breaker on high side of GSU
Generation Tie Line
Transmission Interconnection Facilities(TIF) will be
physically constructed by the Transmission Owner
(TO). Generation Owner will financially fund TIF. TIF
include.


New substation bay if interconnecting to an existing substation
New substation if interconnecting to an existing line
Copyright © 2017
40
Gen. Interconnection Cost Allocation:
Load Flow Cost Allocation Method



Network Upgrades will be physically constructed by
the Transmission Owner (TO). Network Upgrades will
be financially funded by the Generation Owner.
Network Upgrades are deemed necessary for system
reliability.
Network Upgrades are deemed necessary for
Capacity Market operation
Copyright © 2017
41
Gen. Interconnection Cost Allocation:
Load Flow Cost Allocation Method

Transmission Credits/Rights are assigned to
Generation Owner in order to offset Network
Upgrade Costs


Transmission Credits are granted to the Generation Owner
to allow the asset owner access their transmission
investment.
Load Flow Cost Allocation methods are commonly
used in regions that utilize a Generation Deliverability
Reliability standard.
Copyright © 2017
42
Gen. Interconnection Cost Allocation:
Load Flow Cost Allocation Method


Network Upgrades for a set of projects (one or more
identified Network Upgrades) is allocated based on
the MW impact from each project on the constrained
facilities in the Post Contingency Case.
Cost is allocated based on the pro rata share of the
MW contribution on all constraints from each project.
Copyright © 2017
43
Gen. Interconnection Cost Allocation:
Load Flow Cost Allocation Method





Total MW Contribution on constrained facilities from
generators X, Y, and Z
Total MW flowing on all constraints from Steady State
Study = X+Y+Z
Generator X’s share of the Network Upgrade Costs = X/(X+Y+Z)
Generator Y’s share of the Network Upgrade Costs = Y/(X+Y+Z)
Generator Z’s share of the Network Upgrade Costs = Z/(X+Y+Z)
Copyright © 2017
44
Steady State Case Study #2
Interconnection Customer N-1 Analysis
Cabo
Sidney
Graham
Powel
Copyright © 2017
45
Steady State Case Study #2
T-Line Reconductor Solution
Cabo
Sidney
Graham
Powel
* Example Reconductor Cost = $1-1.2M/mile
* Project Cost @ 22.6 miles = $22.6M-27.12M
Copyright © 2017
46
ERCOT Cost Allocation Ex.



Generator A – 150 MW

Generator Owner ($)
 Gen Collector Station- $4M
 GSU - $2M
 High Side Breaker - $1M
 TOTAL = $7M
Transmission Owner ($)
 Gen Tie Line - $5M
 Substation Bay - $2.5M
 Total = $7.5M


Generator B – 100 MW
Generator Owner ($)
 Gen Collector Station- $4M
 GSU - $2M
 High Side Breaker - $1M
 TOTAL = $7M
Transmission Owner ($)
 Gen Tie Line - $5M
 Substation Bay - $2.5M
 Total = $7.5M
Copyright © 2017
47
Load Flow Cost Allocation Ex.

Cost is allocated based on the pro rata share of the MW
contribution on all constraints from each project.

Total MW Contribution on constraints from Gens A and B

X = x1 + x2 = 51 + 34 = 85
Total MW constraints from System Impact Study =
X = 85 MW
Copyright © 2017
48
Load Flow Cost Allocation EX.


Generator A’s share of the Network Upgrade costs =
51/(51+34) = 60% (x) $27.1M = $16.26M
Generator B’s share of the Network Upgrade Costs =
34/(51+34) = 40% (x) $27.1M = $10.84M
Copyright © 2017
49
Load Flow Cost Allocation Ex.



Generator A – 150 MW

Generator Owner ($)
 Gen Collector Station- $4M
 GSU - $2M
 High Side Breaker - $1M
 Gen Tie Line - $5M
 Substation Bay - $2.5M
 Network Upgrades - $16.26M
 TOTAL = $30.76M
Transmission Owner ($)
 TOTAL = $0M


Generator A – 100 MW
Generator Owner ($)
 Gen Collector Station- $4M
 GSU - $2M
 High Side Breaker - $1M
 Gen Tie Line - $5M
 Substation Bay - $2.5M
 Network Upgrades - $10.84M
 TOTAL = $25.34M
Transmission Owner ($)
 TOTAL = $0M
Copyright © 2017
50
Future Integration –
Environmental Regulations
Copyright © 2017
51
Clean Power Plan Overview



“Announced August 3, 2015, The Clean Power Plan (CPP) will
reduce carbon pollution from power plants while maintaining
energy reliability and affordability.”
The final Clean Power Plan relies on a federal-state
partnership to reduce carbon pollution from the biggest
sources – power plants.
States develop and implement plans that ensure that the
power plants in their state – either individually, together or in
combination with other measures – achieve the interim
CO2 emissions performance rates over the period of 2022 to
2029 and the final CO2 emission performance rates, ratebased goals or mass-based goals by 2030.
Copyright © 2017
52
Clean Power Plan Overview

In the final Clean Power Plan, EPA determined that the Best System
of Emission Reduction “BSER” consists of three building blocks:






Building Block 1 – Reducing the carbon intensity of electricity generation by
improving the heat rate of existing coal-fired power plants.
Building Block 2 – Substituting increased electricity generation from loweremitting existing natural gas plants for reduced generation from higheremitting coal-fired power plants.
Building Block 3 - Substituting increased electricity generation from new
zeroemitting renewable energy sources (like wind and solar) for reduced
generation from existing coal-fired power plants.
State plans must be submitted by September 2016.
States could submit an initial plan with an extension to September
2018
Final state submissions must demonstrate that their plan will meet
the CO2 emissions requirements by 2030.
Copyright © 2017
53
CPP, ERCOT Impacts


In 2015 ERCOT performed a study to evaluate the potential
reliability implications of CPP compliance; the analysis does not
indicate any assessment of the policy merits or legal
permissibility of either compliance approach.
ERCOT modeled four scenarios over the timeframe 2016 to
2030 to evaluate the implications of the CPP on reliability in the
ERCOT region:

Baseline – This scenario estimates a baseline of the ERCOT system under current
market trends against which anticipated CPP changes are compared.

CO2 Limit – This scenario applies the limits in the CPP to the ERCOT system to
determine the least-cost way to comply with the limits. This scenario does not place a
price on CO2 emissions.

CO2 Price – This scenario applies a CO2 emissions price that causes the ERCOT
system to achieve compliance with the limits.

CO2 Price & Regional Haze – This scenario adds the impacts of compliance
with the proposed Regional Haze FIP to the CO2 price scenario.
http://www.ercot.com/content/news/presentations/2015/ERCOT_Analysis_of_the_Impacts_of_the_Clean_Power_Plan-Final_.pdf
Copyright © 2017
54
CPP, ERCOT Impacts

The ERCOT Analysis indicated that the following generation
retirements and generation additions would be necessary for
the four scenarios.

The Baseline case indicates the changes in times due to economics,
not compliance with any environmental regulations
Unit Retirements by 2030
Capacity Additions by 2030
http://www.ercot.com/content/news/presentations/2015/ERCOT_Analysis_of_the_Impacts_of_the_Clean_Power_Plan-Final_.pdf
Copyright © 2017
55
CPP, ERCOT Impacts

The following charts provide insight into the magnitude of
generation mix change due to varying scenarios
Generation by Fuel Year 2022
Generation by Fuel Year 2030
Copyright © 2017
56
CPP, ERCOT Impacts
Copyright © 2017
57
CPP, ERCOT Impacts

Impact on LMPs and Retail Rates
Copyright © 2017
58
State Level Legislation

Currently 29 states have enacted Renewable Portfolio Standard
(RPS) / Renewable Energy Standard (RES) - Regulatory mandates
set to increase production of energy from renewable generation
resources.



Most often a percentage of renewable energy date
May require installed capacity of requirement by date
Can have percentage based cost caps which limit increases to
ratepayers bills.
Copyright © 2017
59
Summary

Utility Scale Renewable Project Development Overview

Generation Interconnection Overview



Generation Interconnection Cost Allocation Overview


Existing Barriers in Transmission
Steady State Case Studies
ERCOT Model vs. Load Flow Cost Allocation
Future Integration – Environmental Regulations


Clean Power Plan
State Level Legislation
Copyright © 2017
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Homework Exercises:
Due Thurs Feb, 9th
(1)
Utilize the PowerWorld Case on the course website titled
13BusSystem_Basecase.PWB to complete the following Steady
State Study example.
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Homework Exercises:
Due Thurs Feb, 9th
2.
The Clean Power Plan allows states to achieve their CO2
emissions performance by Rate-Based or Mass-Based
Compliance Pathways.


Define Rate-Based and Mass-Based Compliance Pathways
What are the units for emissions measured under Rate-Based
Compliance? Under Mass-Based Compliance?
The following is a link to the PJM Clean Power Plan
Compliance Assessment.

In a few paragraphs discuss the effects of Mass-Based
Compliance and Rate-Based Compliance on the PJM Region.
http://www.pjm.com/~/media/library/reports-notices/clean-power-plan/20160901-cpp-compliance-assessment.ashx
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