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Stakeholder Comment and Replies Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Consultation on Phase 2 Wind Integration Recommendation Paper Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: 2012/12/11 2012/12/11 1. Recommendations 7.1 Investigate Options to Make Wind Dispatchable through 2013/02/28 Stakeholder Comments - - - - AESO Comments Matrix AESO Replies CanWEA supports investigating mechanisms to make wind dispatchable in the AESO EMMO. A significant benefit of more wind offering into the Alberta electricity market is an overall drop in energy price for consumers and rate payers. CanWEA is interested in understanding mechanisms which would incent wind to sell services such as a downward dispatch service, and how this would be broadly implemented to maintain the FEOC principles enshrined in the regulations. CanWEA is interested in better understanding what other ancillary services AESO envisions wind can offer Benefits such as Low Voltage Ride Through, frequency response, VAR support, etc., and other benefits associated with wind energy to help re-stabilize the electricity system after a system fault is a key benefit that wind energy holds. These benefits need to be brought forward and considered in a broadly speaking manner. CanWEA encourages the AESO to continue to seek mechanisms to improve short term forecasts to ensure under and/or over supply conditions are minimized. Page 1 of 6 - AESO Comments Matrix CanWEA is encouraged to see the acknowledgement that lack of wind will be considered an AOR for loss of supply. Page 2 of 6 7.2 System Ramping Service - - - - . AESO Comments Matrix Given that wind is not the only cause of system ramping events in the electricity system, this service should not be solely borne by the wind industry itself rather, should be socialized across the entire rate base, and paid for by the market. Inflexibility of baseload in Alberta contributes to reliability issues during significant ramp events, whether these are caused by wind alone, or in combination with sudden/unexpected changes in demand/generation capacity While CanWEA recognizes that significant ramp events can result in reliability issues, as well as result in undesirable price events, it is noted that these can be minimized through additional mechanisms, and not just ramp rate limitations through implementation of WPM – these include: o Continued and increased investment in transmission, both internal and inter-tie with neighbouring jurisdictions with more flexible generation assets o Continued improvement in short and mid-term wind forecast o Overall increase in flexibility of other system components, both in demand side management and generation technologies CanWEA would like to better understand what the impacts to ramp rate limitations would be on wind assets in Alberta, and does not believe that this analysis has been sufficiently completed by AESO in support of this recommendation. This should include a broader analysis of the frequency of occurrence, the amount (and manner) of generation assets that would be curtailed, how AESO will impose curtailment, what the economic impact is expected to be, and any mechanisms to provide a financial incentive/instrument to ensure economic dispatch of wind resources in Alberta. Page 3 of 6 7.3 Alter Regulating Reserve Technical Requirements - CanWEA supports broadening the requirements to increase the type of products and approaches that can be used in the regulating reserve market, and considers it an overall benefit to Albertans if other technologies, such as DSM and/or storage can be incorporated into this service. . AESO Comments Matrix Page 4 of 6 2. ISO Rules 7.4 Investigate ‘Pay For Performance’ Element in Regulating Reserve Market Comments - - AESO Comments Matrix AESO Replies CanWEA agrees that as new technologies become available, including increased use of variable sources of renewable power, faster and more flexible sources of regulating reserve will be needed. This is in part driven by the increased recognition that the lack of flexibility of many existing thermal sources of baseload power may be limiting the modernization of the power grid, and reducing the ability of system operators to procure more sustainable sources of variable renewable power. This is therefore (and as appropriately noted by AESO), what is in part driving the FERC review of regulating reserves. CanWEA looks forward to continued consultation on the development of this initiative by AESO. Page 5 of 6 Others Others CanWEA wishes to thank AESO for investigating mechanisms to improve the operational and economic integration of wind energy in Alberta. CanWEA looks forward to continued consultation on some the details of the recommendations, as the recommendations become more refined, and additional information is made public. AESO Comments Matrix Page 6 of 6