Download Stakeholder Comment and AESO Replies Matrix Recommendation Paper

Stakeholder Comment and AESO Replies Matrix
Recommendation Paper – Proposal for Battery Facility Technical and
Operating Requirements
October 22, 2013
The AESO is asking market participants and interested parties to participate in the AESO’s consultation regarding the development
of sections 502.13 and 502.14 of the ISO rules, which will create technical and operating requirements for battery facilities. The
AESO is seeking comments from stakeholders on the associated recommendation paper.
Recommendation Paper – Executive Summary and Purpose
Do stakeholders have any comments on the Executive Summary and Purpose sections?
Stakeholder
Stakeholder Comment
AESO Replies
AltaLink
1. Are there other forms of ES planned to be considered in future? If
so, then would it be appropriate to prepare a generic document
then prepare technology-dependent documents?
1. The AESO proposes to create
requirements for battery facilities,
because they have unique technical
characteristics and the AESO has
received requests to connect them to the
transmission system.
2. Suggest changing the term “battery facility” to “Battery-Energy
Storage System – BESS” which is more widely recognized.
3. Suggest change AIES to Alberta Transmission System (ATS) since
this document does not cover battery solutions connected to
distribution networks.
Other storage technologies may not
require specific technical requirements
and, therefore, they may be adequately
addressed by existing and proposed ISO
rules for generating units and aggregated
generating facilities.
2. The AESO has chosen to adopt the term
“battery facility”. However, the AESO will
consider other suggestions as it
AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22
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develops sections 502.13 and 502.14 of
the ISO rules.
The term “Battery-Energy Storage
System” was rejected because its
abbreviation (BESS) could be confused
with the abbreviation for “bulk electric
system” (BES).
3. The AESO agrees. As noted in section
4.4 of the recommendation paper, the
proposed technical and operating
requirements for battery facilities will only
apply to transmission connected battery
facilities.
Invenergy
No comment.
Recommendation Paper – Background
Do stakeholders have any comments on the Background section?
Stakeholder
Stakeholder Comment
AESO Replies
AltaLink
1. Include references to other relevant, recent FERC orders including
Order #755 (pay for performance for storage devices offering
speed and accuracy of response) and Order #784 (ancillary
services) addressing the particular advantages of BESS.
4. The recommendation paper describes
the proposed technical and operating
requirements for battery facilities. It was
not the AESO’s intention to discuss the
potential applications for battery facilities,
such as ancillary services.
2. Should refer to other BESS applications, e.g., reactive supply,
voltage control, peak reduction, reliability enhancement, reduction
of GHG, transmission project deferment, etc.
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5. See the AESO’s reply 4, above.
Invenergy
Why does the Recommendation exclude distribution-connected
battery facilities considering interconnecting to high voltage systems
can be cost prohibitive?
6. Section 4.4 of the recommendation
paper explains that the legal owners of
electric distribution systems have their
own technical and operating
requirements for distribution-connected
facilities. While the recommendation
paper does not address distribution
connected battery facilities, they will be
allowed.
Recommendation Paper – Technical Requirements – Introduction
Do stakeholders agree with the introduction to the Technical Requirements section?
Stakeholder
AltaLink
Stakeholder Comment
1. We do not agree with the proposal in the first paragraph of Section
4 that battery facilities have similar connection requirements as
synchronous generating units.
AESO Replies
7. The AESO agrees that there are
differences in the capabilities of
generating units and batteries. However,
most of those differences will not form
i. Batteries dot not have any inertia associated with rotating
part of the proposed sections 502.13 and
mass.
502.14 of the ISO rules. That is why the
first paragraph of section 4 of the
ii. BESS can operate in four quadrants.
recommendation paper proposes that
battery facilities would generally have
iii. BESS do not contribute to the short circuit current in case of
similar requirements as synchronous
faults. The converter will block if the current exceeds the
generating units.
maximum semi-conductor limit, which means that the maximum
output power is limited to the rated power.
The purpose of the recommendation
iv. BESS cannot provide short overload outputs comparable to a
paper is to summarize the issues
generator.
identified by the AESO during its initial
evaluation of battery facilities, including
Thus, we suggest rephrasing this statement to alleviate any ambiguity.
the necessary deviations from the
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2. Figure 1:
i. Figure 1 shows two transformers are used; an inverter
transformer and a transmission transformer. This is probably
the case for smaller energy storage systems. Larger
applications may have only one step-up transformer. It should
be optional to have a separate inverter transformer.
ii. Also figure 1 does not show other potential control capabilities
of BESS – e.g. frequency responsive control.
iii. To get the best voltage/power regulation, the measuring point
should be on the transmission voltage level. Thus, we suggest
indicating that on Figure 1. The main point of measurement is
at the point of connection (High Voltage side of the
Transmission System Step-Up Transformer).
3. The paper did not discuss any dynamic requirements specific to
the BESS. The dynamic performance of batteries and power
converters is very different from those of a machine. Step response
times, ride-through etc. will be different.
requirements for synchronous generating
units. Of particular note is the proposal
for batteries to operate in all four
quadrants.
8. The figures in the recommendation paper
are for explanatory purposes only.
9. The AESO does not intend to require
battery facilities to have a specific
configuration for their connecting
facilities (e.g., one inverter and one stepup transformer). The AESO intends to
have requirements that can apply to a
variety of configurations.
10. Figure 1 of the recommendation paper
does include a real power control, which
would include frequency responsive
controls as discussed in section 4.12 of
the recommendation paper.
In accordance with existing reliability
standards and ISO rules, the AESO does
not allow the control of the transmission
level voltage by either synchronous
generating units or wind aggregated
generating facilities. This is done to
prevent interactions between adjacent
generating facilities. Battery facilities will
not be allowed to control the
AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22
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transmission level voltage either.
11. Section 4.7 of the recommendation
paper proposes that battery facilities will
meet the requirements of the NERC
reliability standard PRC-024-1 for voltage
and frequency ride-through. These are
the same requirements that will apply to
generation.
Step response of real power is discussed
in section 4.13 of the recommendation
paper.
Voltage regulation and reactive power
are discussed in sections 4.8 and 4.9 of
the recommendation paper. For further
information on voltage regulation, the
AESO suggests reviewing the ISO rules,
section 502.1 Wind Aggregated
Generating Facilities Technical
Requirements, subsection 7.
Invenergy
We agree with the language used to refer to batteries as a “source and 12. Thank you for your comment.
sink resource.” (pg. 6)
Recommendation Paper – Technical Requirements – Source and Sink Resource
Do stakeholders agree with the proposal to refer to battery facilities as a “source and sink resource”?
Stakeholder
AltaLink
Stakeholder Comment
Prefer designating the devices as a BESS unit with a charging or
discharging state vs. source or sink.
AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22
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Replies
13. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
Invenergy
No comment.
Recommendation Paper – Technical Requirements – Connection Rule and Operating Rules
Do stakeholders agree with the proposal to develop two separate ISO rules, one relating to battery facility technical requirements for
connection and another for battery facility operating requirements?
Stakeholder
AltaLink
Stakeholder Comment
We agree
Replies
14. Thank you for your comment.
Invenergy
We agree with the requirements.
15. Thank you for your comment.
Recommendation Paper – Technical Requirements – Other Rules
Do stakeholders have any comments on the need to review and possibly make incidental amendments to some existing sections of the
ISO rules?
Stakeholder
AltaLink
Stakeholder Comment
We agree
Invenergy
No comment.
Replies
16. Thank you for your comment.
Recommendation Paper – Technical Requirements – Applicability and Variances
Do stakeholders have any comments on the proposed applicability and variances?
Stakeholder
AltaLink
Stakeholder Comment
Suggest to state what minimum transmission voltage level is.
Replies
17. Please see section 1(bbb) of the Electric
Utilities Act, which provides for minimum
voltage levels.
Invenergy
Is the AESO considering IEEE 1547 compliant systems?
18. No. IEEE 1547 is applicable to small
distribution connected facilities. For more
information, please refer to the AESO’s
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replies 6 and 17, above.
Recommendation Paper – Technical Requirements – Maximum Authorized Real Power
Do stakeholders agree with the proposal to make the legal owner responsible for declaring the maximum authorized real power of a
battery facility?
Stakeholder
AltaLink
Stakeholder Comment
1. Suggest to use two terms i.e. maximum authorized charging power
and maximum authorized discharging power. It is confusing to use
one MARP to include both sourcing and sinking capabilities.
Replies
19. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
2. Where will the power be measured? i.e. at the POC, point of
connection? And how will it be measured? (ie. peak instantaneous,
average?)
20. Energy will be measured in accordance
with the AESO’s Measurement System
Standard.
3. We suggest Adding a term for maximum charged/discharged
ENERGY.
Real power will be measured in
accordance with the ISO rules, section
502.8 SCADA Technical Requirements.
As noted in section 4.3 of the
recommendation paper, those rules may
need to be reviewed and have incidental
amendments in order to accommodate
battery facilities. The exact SCADA
requirements are typically detailed in the
functional specification for the project.
In addition, as noted in section 4.16 of
the recommendation paper, the AESO
proposes that synchrophasor
measurement systems are installed at
battery facilities.
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21. See the AESO’s reply 19, above.
Invenergy
No comment.
Suncor
For an aggregated generating facility, it would seem to be reasonable
to have the MARP (of the battery) to represent the source capability.
As the “MARP” is the measure in which the AESO would be making
performance assessments – another value may need to be used to
represent the sink capability if sinking is not equivalent to a load in
terms of requirements.
22. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
Recommendation Paper – Technical Requirements – Operating Voltage Requirements
Do stakeholders have any comments on the proposed operating voltage requirements?
Stakeholder
AltaLink
Stakeholder Comment
Refer to comments on Figure 1 in introduction of Section 4.
Invenergy
No Comment.
Replies
23. See the AESO’s replies 9 and 10, above.
Recommendation Paper – Technical Requirements – Voltage Ride-Through Requirements
Do stakeholders have any comments on the proposed voltage ride-through requirements?
Stakeholder
AltaLink
Stakeholder Comment
How about the “blocking “capability in BESS inverters? Is it allowed or
not? Blocking means that the converter can block the output
completely during for example low voltage, but without tripping the
breaker. The DC voltage will be maintained and the deblocking time to
normal operation is only tens of milliseconds. This is a major
difference to synchronous machines, and it would be good if the paper
discusses how this is handled. Shall the converter be able to source
current during the entire sequence, or just not trip?
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Replies
24. As with synchronous generating units
and wind aggregated generating
facilities, the AESO is not specific in how
the unit or facility rides through the
disturbance. The unit or facility
breaker(s) must not be tripped and real
power production resumes after the
disturbance has been cleared.
Invenergy
No comment.
Recommendation Paper – Technical Requirements – Voltage Regulation
Do stakeholders have any comments on the proposed voltage regulation requirements?
Stakeholder
AltaLink
Stakeholder Comment
1. Unacceptable voltage flicker is governed by power quality
requirements which are the subject of section 4.14. The last
several paragraphs of this section can be moved to this section (or
omitted). Note that reference to loads is not made (just WAGFs
and synchronous generators)
Replies
25. Thank you for your comment. The
AESO does not intend to revise the
recommendation paper.
26. The AESO does not intend to
differentiate between transmission
2. The last paragraph makes references to batteries located within
connected facilities and bulk electric
WAGFs. Workshop discussions could also include the latest NERC
system connected facilities in sections
discourse on the definition of BES (bulk electric systems) and the
502.13 and 502.14 of the ISO rules. The
multitude of examples provided (including integrated systems).
differentiation between transmission
connected facilities and bulk electric
system connected facilities will be
considered in the Alberta Reliability
Standards, which are separate from
technical rules.
Invenergy
No comment.
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Recommendation Paper – Technical Requirements – Reactive Power Capability
Do stakeholders have any comments on the proposed reactive power capability requirements?
Stakeholder
AltaLink
Stakeholder Comment
1. The reactive power capability requirement is a little bit confusing.
The figure indicates that the battery storage should work within a
range of power factor. But this characteristic will be conflict with the
voltage regulation proposed in the Section 4.8, as the voltage
regulating ability will be very limited.
2. Figure 3 is a bit unclear. It seems as maximum active and reactive
power shall be possible simultaneously, but the figure shows
triangles towards zero. This is the opposite of how the PQ diagram
is usually drawn, where the PQ capability is a circle or a square (if
limited).
3. The figure below shows a vendor-based PQ diagram with a 100
MVA converter, where the reactive power has been limited to +/-50
Mvar (100 MVA base for per-unit system).
Replies
27. Section 4.8 of the recommendation
paper proposes that battery facilities will
have a voltage regulating system that is
in-service and controlling voltage
whether the facility is operating as a
source or a sink.
Section 4.9 of the recommendation
paper does not state that the voltage
regulating system of a battery facility
must be operated using power factor
control. Rather, it states that battery
facilities must have minimum reactive
power capability. This is consistent with
the requirements for synchronous
generating units and wind aggregated
generating facilities.
28. To be consistent with the requirements
for synchronous generating units and
wind aggregated generating facilities, the
AESO proposes that battery facilities will
be required to provide active and
reactive power simultaneously if system
conditions require it. Figure 3 in the
recommendation paper is not intended to
describe the capability of the facility;
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rather, it only describes the minimum
reactive power requirements.
For further information on reactive power
requirements, the AESO suggests
reviewing the ISO rules, section 502.1
Wind Aggregated Generating Facilities
Technical Requirements, subsection 9.
29. See the AESO’s replies 27 and 28,
above.
30. Yes, the requirements will be based on
1.0 per unit voltage as measured at the
low voltage side of the transmission
system step-up transformer.
Comparing this figure to the Figure 3 in the paper, means that the
converter must be rated higher than 1 p.u. to be able to provide
reactive power output at 1 p.u. active power. The corners with
active/reactive power simultaneously will therefore be cost driving.
4. Figure 3 does not mention anything about the voltage (I assume
1.0 p.u.). Full capacitive reactive power output at high continuous
system voltage will also make the converter more expensive.
Invenergy
Further discussion is required. Complying with this proposal may result 31. See the AESO’s replies 27 and 28,
in reduction of real power capacity.
above.
Suncor
Can the AESO please provide some description of the reactive power
requirement shown as dotted lines in Figure 3 of the document.
In the session, this was explained as the inherent capability of the
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32. The triangular sections of Figure 3 in the
recommendation paper are the minimum
requirements for reactive power for given
system which must be offered if it is available. Please provide more
details on the use of this range as to whether this range of reactive
power would always be used in an automatic voltage control scenario
or if the AESO intends to provide a reactive power output setpoint for
the battery facility.
real power output. Consistent with wind
aggregated generating facilities, the
reactive capability cannot be withheld if it
is inherently available by the battery
facility.
For further information on reactive power
requirements, the AESO suggests
reviewing the ISO rules, section 502.1
Wind Aggregated Generating Facilities
Technical Requirements, subsections 9,
10 and 11.
33. The AESO does not intend to set the
voltage regulation system setpoint. For
more information regarding the AESO’s
voltage control methods, the AESO
suggests reviewing:
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
Alberta Reliability Standard VAR001-AB-1a Voltage and Reactive
Control;

Alberta Reliability Standard VAR002-AB-1.1b Generator Operation for
Maintaining Network Voltages;

ISO rules, section 304.4 Maintaining
Network Voltage; and

Information Document # 2010-007RS
General Operating Practice – Voltage
Control.
Recommendation Paper – Technical Requirements – Transmission System Step-Up Transformer
Do stakeholders have any comments on the proposed transmission system step-up transformer requirements?
Stakeholder
AltaLink
Stakeholder Comment
Replies
The reference to WAGFs and synchronous generators can be dropped 34. Thank you for your comment. The
to make the section more succinct. A listing of the bullet points should
AESO does not intend to revise the
suffice.
recommendation paper.
Invenergy
Further discussion is required, as more details are needed to explain
the level of mitigation required for blocking the transmission of
harmonic currents.
35. To be consistent with the requirements
for synchronous generating units and
wind aggregated generating facilities, the
AESO proposes that either the
transmission system step up transformer
or the inverter transformer (if the battery
facility is equipped with one) should have
a delta connection that is adequate to
block the transmission of harmonic
currents.
Recommendation Paper – Technical Requirements – Off Nominal Frequency Requirements
Do stakeholders have any comments on the proposed off nominal frequency requirements?
Stakeholder
AltaLink
Stakeholder Comment
1. When operating at off nominal frequency requirements, the output
of the battery should be allowed at reduced value. The typical
requirement on HVDC operation is around 10% less for the off
nominal frequency operation.
2. We recommend naming this section as Frequency Ride Through
AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22
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Replies
36. In Alberta, HVDC systems do not reduce
operation when operating within the
frequency range applied to battery
facilities. Additionally, reducing output
during off nominal frequency operation
would be contrary to good electrical
operating practice, because under
as it aligns with most vendors’ naming.
3. We recommend activating the FRT capability during discharging
state only, especially during system disturbances.
frequency excursions typically require
generation to increase output up to the
full capability of the unit.
37. Thank you for your comment. The
AESO does not intend to revise the
recommendation paper.
38. System disturbances – in particular, over
frequency events – may result in the
battery facility moving to the charging
state. The loss of resources during these
events would be harmful to the reliability
of the transmission system. Therefore,
FRT capability will be active during both
charging and discharging state.
Invenergy
No comment.
Recommendation Paper – Technical Requirements – Frequency Responsive Control System Requirements
Do stakeholders have any comments on the proposed frequency responsive control system requirements?
Stakeholder
AltaLink
Stakeholder Comment
Section 4.12 includes a requirement for frequency response using a
droop characteristic. This is obviously manageable from a technical
perspective, but for resources providing fast regulation service
wouldn’t there already be a frequency component to the signal?
Assuming the AESO adopts some sort of pay-for-performance
arrangement, this frequency response should be netted out from the
calculation if it causes less-perfect fidelity to the regulation signal. In
other words, Battery Storage normally functions as a peaking unit for
very short period of time. The standard EPRI model has no droop
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Replies
39. The proposed requirements in section
4.12 of the recommendation paper are
minimum requirements for the
connection of battery facilities to the
transmission system. They are not
intended to provide technical
requirements beyond the basic reliability
needs of the transmission system.
control function.
Additional requirements to provide
ancillary services are contained in the
technical requirements for those
services.
Regulating reserves are intended to be
responsive to the automatic generation
control, which is a secondary response
to frequency deviations. The primary
response to frequency deviations is
provided by frequency responsive control
systems (governors) of the facility or
generating unit. For more information,
the AESO suggests reviewing its
Technical Requirements for Provision of
Regulating Reserves Version 2.0.
Invenergy
Further discussion is required. This should not be required of storage
systems. BAL-002 compliance is the responsibility of the RRO and BA
per the NERC standard.
40. To clarify, section 4.12 of the
recommendation paper refers to BAL002-WECC-1, not BAL-002-AB-1. While
it is correct that the standard apply to the
ISO, the AESO does not own any
generation; therefore, it places
obligations on generating facilities to be
frequency responsive.
The key proposal in section 4.12 of the
recommendation paper is that battery
facilities will be required to have a
frequency response that is similar to
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generating units in order to ensure the
safe, reliable and economic operation of
the Alberta interconnected electric
system.
Recommendation Paper – Technical Requirements – Real Power and Ramp Rate Control Requirements
Do stakeholders have any comments on the proposed real power and ramp rate control requirements?
Stakeholder
AltaLink
Stakeholder Comment
1. The maximum ramp up rates should be different for normal and
emergency conditions (such as when batteries are supplying
operating reserves and/or LSSi/GRAS services). The emergency
rate should be much higher than normal rate as during a
contingency, it may be necessary for the storage device to
response immediately.
Replies
41. See the AESO’s reply 39, above.
42. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
2. Maximum Ramp rate should be case specific based on transient
system studies. It can be phrased in the OPP that “Granted
storage resources shouldn’t be allowed to destabilize the
network. System studies can assess transient conditions.”
Invenergy
No comment.
Suncor
As the AESO has indicated in the session, the ramp rate may be
dependent on system characteristics in the local region of the battery
installation.
43. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
Would it be possible for the AESO to provide a range of ramp rates
that is generally accepted for connecting to the AIES.
There will be several factors to consider
in determining the ramp rate, including:
For cases which would warrant a separate study to determine the
ramp rate, can the AESO provide some general guidelines as to what
the technical criteria would be in determining the ramp rates?

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the location of the facility;

the size of the facility; and

the number of facilities in the area.
Recommendation Paper – Technical Requirements – Power Quality
Do stakeholders have any comments on the proposed power quality requirements?
Stakeholder
AltaLink
Stakeholder Comment
1. We recommend listing the rules/standards that apply for each item
in the bullet list.
2. Reference to ‘WAGFs and synchronous generating units’ is
incomplete - if left in, reference to BESS as loads should then be
included to be complete.
Replies
44. As noted in section 4.14 of the
recommendation paper, the proposed
power quality requirements will be similar
to synchronous generating units and
wind aggregated generating units.
For further information on power quality
requirements, the AESO suggests
reviewing the ISO rules, section 502.1
Wind Aggregated Generating Facilities
Technical Requirements, subsection 19.
45. Thank you for your comment. The
AESO does not intend to revise the
recommendation paper.
Note that the proposed power quality
requirements will apply to battery
facilities when operating as either a
source or sink.
Invenergy
No comment.
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Recommendation Paper – Technical Requirements – WECC Stability Control Requirements
Do stakeholders have any comments on the proposed WECC stability control requirements?
Stakeholder
AltaLink
Invenergy
Stakeholder Comment
Energy storage can have frequency control and stability functions
implemented, but the size of the energy storage compared to the
system means that its impact will be very small. It should also be
possible to use islanding mode, but the size may again be very
limiting.
Replies
46. The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
As a stabilizer, we agree with AESOs statement that the converter
based energy storage will not contribute to any oscillations. There is
also a possibility to include power oscillation damping functions (POD)
in energy storage the same way as for an SVC or HVDC. The energy
storage should be able to counteract system power oscillations using
both active and reactive power based on an external input signal. This
might be good to know, but is probably better not to include in this
paper.
No comment.
Recommendation Paper – Technical Requirements – Facilities Synchrophasor Measurement
Do stakeholders have any comments on the proposed facilities synchrophasor measurement requirements?
Stakeholder
AltaLink
Invenergy
Stakeholder Comment
Agree - installing PMUs will serve the purpose of measuring the
performance of the BESS, including model validation. Again, this will
be a cost-driven decision.
Batteries should not have to pay for this as the transmission
operator/grid operator receives the benefit.
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Replies
47. Thank you for your comment.
48. The AESO disagrees that only the
transmission system operator benefits
from synchrophasor measurement
technology. As noted in AltaLink’s
comment immediately above,
synchrophasor measurement technology
can also be used by a market participant
for model validation. Additionally, the
owner of a battery facility can use the
data generated by synchrophasor
measurement technology for testing the
performance of the battery facility.
Synchrophasor measurement technology
will likely be a useful tool, because the
data it generates will allow battery facility
owners, battery system vendors and the
AESO to better understand the
interaction between the transmission
system and battery facilities, which are a
new technology.
Recommendation Paper – Technical Requirements – Facilities Testing Post Connection
Do stakeholders have any comments on the proposed facilities testing post-connection requirements?
Stakeholder
AltaLink
Stakeholder Comment
Battery’s life time is different for different types of batteries. The
suggested battery periodic replacement rate for Li-ion battery is 5
years and for other types are around 7.5 years. So it would be more
beneficial to do the facility testing based on the battery technology.
Replies
49. The AESO does not propose to do
battery facility testing based on the
battery technology, because it is
attempting to make the proposed
requirements technology neutral (e.g. Liion, flow batteries, etc.).
Additionally, as battery technology
advances, the replacement rate will
change. To avoid having to determine
the testing interval on case-by-case
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basis, the AESO proposes that
revalidation must be performed every
five years. This is consistent with the
requirement for synchronous generating
units.
Invenergy
What sets the precedent for revalidation every 5 years? Further
discussion is required.
50. Currently, the AESO and WECC require
that generating units connected to the
transmission system revalidate the unit
models every five years.
As noted in section 4.17 of the
recommendation paper, the proposed
revalidation requirements will be similar
to synchronous generating units.
Recommendation Paper – Technical Requirements – Other Requirements
Do stakeholders have any comments on the proposed other requirements?
Stakeholder
AltaLink
Stakeholder Comment
Replies
It would have been good if AESO also recommended in the paper how 51. The recommendation paper does not
battery energy and life time are to be specified. Should the MWh be
discuss energy requirements (MWh),
specified at beginning-of-life or end-of-life, and how long life time to
because that is typically a market issue,
design for?
not an interconnection issue.
Invenergy
No comment.
Recommendation Paper – Other Comments
Do stakeholders have any other comments on the Recommendation Paper?
Stakeholder
Replies
Stakeholder Comment
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AltaLink
The AESO paper addresses only technical requirements relating to
interconnection, and there will need to be another process for
addressing market issues, such as settlement of net energy
consumption at wholesale levels, and pay-for-performance.
52. As noted in section 1 of the
recommendation paper, the AESO
issued the Energy Storage Initiative
Issue Identification paper in the spring of
2013. It can be found at:
http://www.aeso.ca/downloads/Formatte
d_ES_IS_Paper_Final_20130613.pdf.
Additionally, four workshops were held in
the fall of 2013 and the AESO is
preparing the Energy Storage Integration
Discussion Paper, which is scheduled to
be available in the spring of 2014.
Invenergy
No comment.
Suncor
Suncor is a strong supporter of the AESO’s mandate to operate a Fair, 53. The AESO does not consider any of the
Efficient and Openly Competitive (FEOC) and the deployment of
proposed requirements in the
market based mechanisms whenever possible. Considering the
recommendation paper to be services.
services that are being required for the battery system in its sinking
Rather, the proposed requirements are
mode, Suncor would encourage the AESO consider market
intended to provide the minimum
mechanisms for these services. It is not appropriate to have energy
requirements for the connection of
storage facilities provide services that are not required by other
battery facilities to the transmission
generators and loads.
system in order to ensure the reliability of
the transmission system.
Different technologies have unique
characteristics that need to be
considered when being interconnected to
the transmission system. For example,
the requirements for wind aggregated
AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22
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generating facilities are different than the
requirements for synchronous generating
units.
The AESO will consider this comment as
it develops sections 502.13 and 502.14
of the ISO rules.
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