Download New ISO rules 501.3.1 Wind Generating Facilities Technical Requirements

Stakeholder Comment Form
AESO AUTHORITATIVE DOCUMENT PROCESS
New ISO rules 501.3.1 Wind Generating Facilities Technical Requirements
NOTE: The AESO is asking market participants to give an initial indication of their support for, or opposition to, the specific ISO rule
changes referenced below. Such an initial indication assists in the AESO’s practical understanding of the receptivity of the industry
to the proposed changes, and in that regard the AESO thanks in advance all market participants who choose to respond. With
regard to the specific ISO rule changes and their implications, such responses are without prejudice to the rights of market
participants under the Act, any regulations, or related decisions of the Commission.
Date of Request for
Comment:
December 16, 2009
Period of Consultation:
December 16, 2009
Comments From:
ENERCON GmbH
Date [yyyy/mm/dd]:
2010/01/21
Contact:
Markus Fischer
Phone:
+49-421-2441565
E-mail:
[email protected]
through January 22, 2010
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 1 of 49
G1 Definitions to ISO Rules - New Definitions
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“generating facilities” means an aggregation of generating units, designated by the ISO, situated in the
same proximate location.
Reason for Stakeholder Positions:
- Is one single wind energy converter at the same time a generating facility and a generating unit?
- generating facilities can have one or more collector busses and only one point of connection
(mark with ”x”)
Support
X
Oppose
No Comment
Alternate Proposal:
“generating facilities” means an aggregation of one or more generating units, designated by the ISO, situated in the same
proximate location. A generating facility can have one or more collector busses but only one point of connection.
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“maximum authorized MW” means,
(i)
for a generating unit, the maximum quantity (MW) that the generating unit is authorized by
the ISO to deliver to its generator terminal; or
(mark with ”x”)
Support
X
Oppose
No Comment
for generating facilities with a collector bus, the maximum quantity (MW) that the generating units are
authorized by the ISO to deliver to its collector bus.
Reason for Stakeholder Positions:
A generating facility can have one or more collector busses (please also refer to section 33 (2)).
Alternate Proposal:
“maximum authorized MW” means,
(i)
for a generating unit, the maximum quantity (MW) that the generating unit is authorized by the ISO to deliver to the
low voltage-side of its generating unit step-up transformer; or
for generating facilities, the maximum quantity (MW) that the generating units are authorized by the ISO to deliver to its
collector bus(ses).
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 2 of 49
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“operator” means a person given expressed authority by an owner to operate on the owner’s behalf any
one or more of:
(i)
a generating unit;
(ii)
any generating facilities;
(iii)
a transmission facility;
(iv)
an electric distribution system;
(v)
an industrial system; or
(vi)
a load facility;
(mark with ”x”)
Support
Oppose
X
No Comment
and includes the owner, if no such other person has been so authorized.
Reason for Stakeholder Positions:
Alternate Proposal:
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“person” as defined in the Act includes an individual, unincorporated entity, partnership, association,
corporation, trustee, executor, administrator or legal representative.
(mark with ”x”)
Support
Oppose
X
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 3 of 49
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“point of connection” means a point at which electric energy is transferred between a transmission
facility that is not an industrial system, and:
(i)
the high voltage side of any generating facilities;
(ii)
an electric distribution system;
(iii)
an industrial system; or
(iv)
a load facility owned by a person who has arranged directly for system access service under
Subsection 101(2) of the Act.
(mark with ”x”)
Support
Oppose
X
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 4 of 49
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“transmission system” as defined in the Act means all transmission facilities in Alberta that are a part of
the interconnected electric system.
(mark with ”x”)
Support
Oppose
(X) No Comment
Reason for Stakeholder Positions:
It would be highly appreciated if all terms defined in the Act or in the ISO RULES PART ONE – GENERAL that are used in the
present document would be listed in this section G1, as it is the case for transmission system. This would be a big help for the
reader of the Wind Generating Facilities Technical Requirements.
Alternate Proposal:
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“wind turbine generator” means the electric turbine generator component of a wind powered generating
unit and includes a synchronous or asynchronous generator.
(mark with ”x”)
Support
X
Oppose
No Comment
Reason for Stakeholder Positions:
Please refer to well established definition according to IEC
Alternate Proposal:
replacement of “wind turbine generator” by “wind turbine” and definition according to IEC:
“wind turbine ” means a system which converts mechanical energy to electrical energy.
Further comment: Wind turbines include a generating system which may include a combination of a induction or synchronous
machine and power electronics. The induction machine or synchronous machine may be directly connected with the grid or
decoupled via power electronics
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 5 of 49
G1 Definitions to ISO Rules - New Definitions (cont’)
The following new definition hereby is incorporated in to Section G1 of the ISO rules:
“voltage regulating system” means the equipment that automatically controls the reactive power
devices to regulate the voltage level at the collector bus of wind generating facilities.
(mark with ”x”)
Support
X
Oppose
No Comment
Reason for Stakeholder Positions:
A generating facility can have one or more collector busses (please also refer to section 33 (2)).
There are wind turbines available that can provide reactive power highly dynamically (e. g. from ENERCON). We would appreciate
if the AESO would distinguish between the turbines and reactive power devices.
Alternate Proposal:
“voltage regulating system” means all equipment that automatically controls the wind turbines and/or reactive power devices
to regulate the voltage level at a collector bus of wind generating facilities.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 6 of 49
G1 Definitions to ISO Rules - Revised Definitions
The following definition change hereby is incorporated in to Section G1 of the ISO rules:
The definition of “owner” is deleted and the following is substituted
(mark with ”x”)
Support
Oppose
X
No Comment
“owner”, for the purpose of these ISO rules, means the person who has title to and ownership of any one
or more of:
(i) a generating unit;
(ii) any generating facilities;
(iii) a transmission facility;
(iv) an electric distribution system;
(v) an industrial system; or
(vi) a load facility.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 7 of 49
G1 Definitions to ISO Rules - Revised Definitions (cont’)
The following definition change hereby is incorporated in to Section G1 of the ISO rules:
The definition of “gross MW” is deleted and the following is substituted:
(mark with ”x”)
Support
X
Oppose
No Comment
“gross MW” means a real power instantaneous measurement at a generator terminal or collector bus.
Reason for Stakeholder Positions:
Alternate Proposal:
“gross MW” means
(i)
for a generating unit a real power instantaneous measurement at the low voltage-side of the generating unit step-up
transformer,
(ii)
for generating facilities a real power instantaneous measurement at a collector bus.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 8 of 49
ISO Rule 501.3.1
Wind Generating Facilities Technical Requirements
1.
Applicability
(mark with ”x”)
Applicability
1(1) Section 501.3.1 applies to the ISO, and subject to the provisions of subsections 1(1), (2) and (3) to
any:
X
Support
Oppose
No Comment
(i) new wind generating facilities and to its owner; and
(ii) existing wind generating facilities and to its owner if such facilities connected to the
transmission system under the Wind Power Facility Technical Requirements dated November 15,
2004.
(2) Any wind generating facilities whose owner executed a Construction Commitment Agreement
and completed the approval process of the ISO for connection to the transmission system under
the Technical Requirements for connecting generators (1999) is exempt from this Section 501.3.1
but remains subject to the Technical Requirements for connecting generators (1999).
(3) If any wind generating facilities referred to in subsection (2) undergo a facility addition or
replacement such that the resulting accumulative MW capability is increased by an amount equal to
or greater than five (5) MW, then the new or replaced facility will be subject to and must comply
with the provisions of this Section 501.3.1 in its entirety.
(4) Notwithstanding subsection (2) above, all wind generating facilities must be compliant with the
provisions contained in subsections 32 and 36 below.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 9 of 49
2.
Requirements
Maximum authorized MW for Wind Generating Facilities
2(1) The owner of any wind generating facilities must submit to the ISO the maximum authorized MW
for those facilities, and once approved of by the ISO this value will form part of the functional specifications
for the wind generating facilities.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) In accordance with Appendix 2, the ISO will determine the wind generating facilities’ requirements
associated with reactive power capability of the wind generating facilities, based on the maximum
authorized MW as submitted and approved.
Reason for Stakeholder Positions:
By definition the maximum authorized MW is defined by the ISO (please refer to the definition of maximum authorized MW). It is
not clear why then the owner of a wind generating facility must submit this value to the ISO.
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 10 of 49
2.
Requirements (cont’)
Voltage Ride Through Requirements
3(1) Wind generating facilities with a maximum authorized MW amount equal to or greater than five (5)
MW and connected to the transmission system must meet the voltage ride through requirements
specified in this subsection 3.
X
Support
Oppose
No Comment
(2) Each owner of wind generating facilities must ensure they are capable of continuous operation
between ninety percent (90%) and one hundred and ten percent (110%) of the rated voltage at the point
of connection.
(3) Subject to subsection 3(4) below, wind generating facilities must not trip off line any loaded wind
turbine generator due to voltage dips or post-transient voltage rises described in Appendix 1, resulting
from normally cleared transmission faults on any phase or combination of phases at or beyond the point
of connection.
(4) Notwithstanding any other provision of this subsection 3, wind generating facilities are not required to
ride through:
(a) transmission system faults that cause a forced outage of a radial line to the wind generating
facilities;
(b) faults that occur on the wind generating facilities side of the point of connection, including the lower
voltage network and the substation, or
(c) transmission system faults that result in a transfer trip or anti-islanding protection scheme to activate
at the wind generating facilities.
Reason for Stakeholder Positions: Detailed definition of the term “voltage” avoids misunderstandings.
Alternate Proposal:
(2) Each owner of wind generating facilities must ensure that the generating facilities are capable of continuous operation if the
root mean square values of all three line to line voltages at the point of connection are within the range of ninety percent (90%)
and one hundred and ten percent (110%) of the root mean square value of the rated line to line voltage at the point of
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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connection.
(3) Subject to subsection 3(4) below, wind generating facilities must not trip off line any loaded generating unit if
• the root mean square value of the highest of the three line to line voltages remains above the blue line in Appendix 1 for
voltage dips,
• the lowest of the three line to line voltages remains below the red line in Appendix 1 for post-transient voltage rises,
resulting from normally cleared transmission faults on any phase or combination of phases at or beyond the point of connection.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
Voltage Regulation and Reactive Power
4(1) The ISO must assess voltage regulation and reactive power performance of wind generating
facilities at the collector bus, and all reactive power requirements must be based on the rated voltage at
the collector bus.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) Wind generating facilities must be able to regulate their voltage at the voltage regulation system
point of control under both non-disturbance and disturbance conditions.
Reason for Stakeholder Positions:
As for (1): Wind generating facilities may have multiple collector buses.
As for (2) Does the term “disturbance” include a transmission fault which leads to operation in voltage ride through mode? A more
detailed definition is appreciated. Based on this definition, further comments may apply. According to the definition of the voltage
regulation system, the voltage control point shall be at a collector bus. (see above)
Alternate Proposal:
(1) The ISO must assess voltage regulation and reactive power performance of wind generating facilities at a collector bus, and
all reactive power requirements must be based on the rated voltage at the collector bus.
(2) Wind generating facilities must be able to regulate the voltage at a collector bus
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
Wind Generating Facilities Reactive Power Capability
5(1) The reactive power capability of any wind generating facilities to supply reactive power must meet
or exceed +0.9 power factor based on the gross MW of the wind generating facilities.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The reactive power capability of the wind generating facilities to absorb reactive power must meet
or exceed -0.95 power factor based on the gross MW of the wind generating facilities.
(3) Continuous reactive power capability referred to in subsections 6 and 7 below may be aggregated to
meet the requirements set out in subsection 5(1) and subsection 5(2) above.
(4) All wind turbines and reactive power devices used to vary the wind generating facilities’ output of
reactive power within the requirements set out in subsection 5(1) and subsection 5(2) above must be
under control of a voltage regulation system.
(5) The operator must not intentionally, and the control systems of wind generating facilities must not be
designed, to reduce the reactive power capability from the dynamic reactive devices described in
subsection 6, or the non-dynamic reactive devices described in subsection 7.
Reason for Stakeholder Positions:
As for (1) and (2): This contradictory to the Appendix 2. If a reference to active power would be made, it must be made to the
available installed capacity and not to the gross MW. The reactive capability may be reduced if wind turbines are out of service
(e.g. maintenance).
As for (4): A generator facility can have one or more voltage regulation systems.
Alternate Proposal:
(1) The reactive power capability of any wind generating facilities to supply reactive power must meet or exceed +0.9 power
factor.
(2) The reactive power capability of the wind generating facilities to absorb reactive power must meet or exceed -0.95 power
factor
(4) All wind turbines and reactive power devices used to vary the wind generating facilities’ output of reactive power within the
requirements set out in subsection 5(1) and subsection 5(2) above must be under control of at least one voltage regulation
system.
(5): To be deleted
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 15 of 49
2.
Requirements (cont’)
Dynamic Reactive Power Capability
6(1) The dynamic reactive power capability of any wind generating facilities must meet or exceed plus
zero point nine five (+0.95) power factor to minus zero point nine eight five (-0.985) power factor based
on the gross MW of the wind generating facilities.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) Wind generating facilities must have reactive power devices that are continuously acting and
continuously variable under control of its voltage regulation system, and be able to respond to
transmission system voltage fluctuations.
(3) For the purposes of subsection 6(1), a short term reactive power capability for a period of up to one
(1) second will be deemed to meet the dynamic reactive power capability set out in that subsection 6(1).
(4) The short term reactive power capability referred to in this subsection 6 does not qualify for continuous
reactive power described in subsection 5.
Reason for Stakeholder Positions:
As for (1): see above
As for (3): Does this mean that the reactive power has to be provided with a settling time of up to one (1) second, or does the
reactive power have to be provided for a maximum of one (1) second.
Alternate Proposal:
(1) The dynamic reactive power capability of any wind generating facilities must meet or exceed plus zero point nine five (+0.95)
power factor to minus zero point nine eight five (-0.985) power factor.
(3) For the purposes of subsection 6(1), a short term reactive power capability with a settling time of up to one (1) second will be
deemed to meet the dynamic reactive power capability set out in that subsection 6(1).
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
(mark with ”x”)
Non-Dynamic Reactive Power Capability
7(1) For any wind generating facilities, the MVAr size of the individual shunt reactive power devices
under control of the voltage regulation system must not be larger than the total range of the continuous
capability of dynamic reactive power set forth in subsection 6.
X
Support
Oppose
No Comment
(2) Any shunt reactive power device installed in any wind generating facilities must be capable of being
switched on no later than five (5) minutes after having been switched off.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 17 of 49
2.
Requirements (cont’)
Voltage Regulation System
(mark with ”x”)
Support
8(1) Wind generating facilities must have a continuously variable, continuously acting, closed loop
centralized control voltage regulation system that measures voltage compared to a set point, and will
control reactive devices such as wind turbine generators, static VAr devices, capacitor and reactor
banks, or any or all of them.
(2) The voltage regulation system must be continuously in service and controlling while the wind
generating facilities are connected to the transmission system, and regardless of the quantity of actual
MW output from the wind generating facilities.
(3) The voltage regulation system set point must be adjustable by the operator of the wind generating
facilities to between ninety five percent (95%) and one hundred and five percent (105%) of rated voltage.
(4) The voltage regulation system must operate in a voltage set point control mode to the exclusion of
any other modes.
(5) The voltage regulation system must measure voltage that represents the overall voltage response of
the wind generating facilities.
(6) The voltage regulating system must be capable of:
(a) adjustable gain, or reactive droop compensation adjustable from zero to ten percent (0 to 10%); and
(b) reactive current compensation to compensate for the transmission system step-up transformer.
(7) The combined settings of the voltage regulation system must be able to achieve a steady state
voltage regulation of plus or minus zero point five percent (+/- 0.5%) of the voltage controlled by the
voltage regulation system.
(8) Prior to commissioning of any new wind generating facilities, the ISO will specify whether the
reactive power compensation in the voltage regulation system must be implemented.
(9) The ISO may, upon no less than ninety (90) days notice to the owner of any operational wind
generating facilities, require a change to the setting of the reactive droop compensation gain or the
reactive current compensation settings for those wind generation facilities.
(10) The voltage regulation system must be calibrated such that a change in reactive power will
achieve ninety five percent (95%) of its final value no sooner than zero point one (0.1) seconds and no
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 18 of 49
X
Oppose
No Comment
Reason for Stakeholder Positions:
As for (1): It should be carefully considered, that wind turbines may have a high performance voltage control capability reg. their
terminal voltage.
As for (2): How is the actual MW output defined, is it the gross MW? It should be clear that for low wind speeds, the capability of
the voltage regulation system to control the voltage at a collector bus is not the same as for high wind speeds because the
generating facilities are required to meet or exceed a certain power factor, but not to provide or absorb a certain amount of
reactive power. At periods of no wind, the whole facility stays connected to the transmission system; it is unreasonable to apply a
requirement to provide voltage control even at no wind. The ISO may buy this service / performance as an ancillary service.
Alternate Proposal:
(1) Wind generating facilities must have at least one continuously variable, closed loop centralized control voltage regulation
system that measures voltage at a collector bus of the wind generating facility compared to a set point, and will control reactive
devices such as wind turbines, static VAr devices, capacitor and reactor banks, or any or all of them. For the avoidance of doubt:
wind turbines and static VAr devices may have their own local underlying voltage controls loops, that are obliged to operate under
all operating conditions in a stable way in conjunction with the voltage regulation system.
(2) The voltage regulation system must be continuously in service and controlling while the wind generating facilities are
providing active power to the transmission system, and regardless of the quantity of actual MW output from the wind generating
facilities.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
(mark with ”x”)
External Voltage Regulation
9 No wind generating facilities may use or rely upon any voltage regulation system and reactive
power that are external to the wind generating facilities without first having the ISO review and approve
of the matter in writing.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
Operator Availability
10 The owner of wind generating facilities must have a designated and qualified operator available
twenty four (24) hours a day every day for contact and communication with the ISO, in accordance with
ISO rules and other communication policies and protocols.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
WECC Stability Control Requirements
11 If the ISO is required by any WECC standards or policies to use a power system stabilizer for any
wind generating facilities using a synchronous wind turbine generator and connected directly to the
transmission system, then the ISO in turn may require those wind generating facilities to use a power
system stabilizer.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
Operating Voltage Requirements and Range
(mark with ”x”)
X
12 The owner of any wind generating facilities must submit to the ISO the following information and data
which will form part of the functional specifications for those wind generating facilities:
Support
Oppose
No Comment
(a) a minimum through maximum transmission system voltage operating range; and
(b) the value to be used for rated voltage of the transmission system at the point of connection, based
on the normal operating voltage levels at the specific location of the wind generating facilities.
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
Transmission System Step-Up Transformer
13(1) The voltage ratio, tap changer type, range and step size specifications for any step-up transformer of
any wind generating facilities must be such that the reactive power requirements specified in subsection
4 are fully available throughout the operating voltage range referred to in subsection 12.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The wind turbine generator step-up transformer and transmission system step-up transformer
connection for any wind generating facilities must be designed to provide:
(a) a favorable circuit to block the transmission of harmonic currents, and
(b) isolation of transmission and wind turbine generator side ground fault current contributions.
(3) The wind generating facilities must utilize an effectively and solidly grounded wye connection on the
high side of the transmission system step up transformer.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 21 of 49
2.
Requirements (cont’)
Off Nominal Frequency Requirements
14(1) For wind generating facilities that have a requirement to protect equipment for off-nominal
frequency operation, the owner must install protective relays so as to accommodate operation for the
specified time frames shown in Appendix 3.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The trip setting of the protective relays must either:
(a) be set to the requirements set out in Appendix 3 with respect to the frequency versus time setting; or
(b) automatically trip load to match the anticipated generation loss and at comparable frequency levels.
(3) The owner must only use solid state or microprocessor based frequency relays in wind generating
facilities to provide off-nominal frequency protection.
(4) Frequency relays must use the definite time characteristic and not be disabled for transmission
system voltages that are eighty percent (80%) or higher of the rated voltage
(5) The ISO first must approve in writing if the operator of wind generating facilities intends to permit a
frequency relay to be automatically disabled if transmission system voltages fall below eighty percent
(80%) of nominal.
Reason for Stakeholder Positions:
As for (3): A frequency protection system can not only be a relay, it can also be integrated in the control and monitoring system.
This option should be included.
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
Over Frequency Control Requirements
15(1) Any wind generating facilities must have an over frequency control system that continuously
monitors the frequency of the transmission system at a sample rate of thirty (30) per second and a
resolution of zero point zero zero four (0.004) Hertz, and the frequency control system must automatically
control the real power output of the wind generating facilities at all times.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The frequency control system may have an intentional deadband of up to zero point zero three six
(0.036) Hertz.
(3) The frequency control system must be designed and calibrated to reduce the real power output at the
collector bus based on the real time capacity of all available wind turbine generators, and such
reductions must be;
(a) proportional to the frequency increase by a factor of thirty three percent (33%) per Hertz of the above
capacity;
(b) at a rate of five percent (5%) of the above capacity per second; and
(c) with no intentional time delay added to the control system.
(4) In accordance with subsection 14, for transmission system over frequency events greater than sixty
one point seven (61.7) Hertz, wind generating facilities may trip due to the over frequency, but if the wind
generating facilities remain connected to the transmission system then the frequency response system
must continue to ramp down the active power output in accordance with provision of this subsection 15.
(5) The over frequency control requirements of this subsection 15 must have control priority over the power
limiting control function, and must reduce the real power output for an over frequency condition even
when the requirements of this subsection 18 are in effect.
Reason for Stakeholder Positions:
- How is the real time capacity defined, is it the gross MW?
- It is considered that the deadband is the relevant parameter for the frequency protection system.
Alternate Proposal:
(1) Any wind generating facilities must have an over frequency control system that continuously monitors the frequency of the
transmission system at a sample rate of thirty (30) per second and a resolution of zero point zero one (0.01) Hertz, and the
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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frequency control system must automatically control the real power output of the wind generating facilities at all times.
(2) The frequency control system may have an intentional deadband of up to zero point zero three six (0.036) Hertz.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
(mark with ”x”)
Wind Generating Facilities Disconnection
16(1) Wind generating facilities must have systems, controls and related procedures to electrically
disconnect the wind generating facilities from the transmission system either at:
X
Support
Oppose
No Comment
(a) the point of connection;
(b) the collector bus feeder breakers; or
both of them, as applicable.
(2) Wind generating facilities connecting to a transmission facility must provide the functionality and
remote control capabilities to enable the operator of the transmission facility to open or trip any
interconnecting breaker either at the point of connection or the collector bus feeder breakers, as
applicable.
(3) Once a connecting or feeder breaker of any wind generating facilities has been opened or tripped,
then the operator may only electrically reconnect to the transmission facility after receiving approval
from the ISO.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
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2.
Requirements (cont’)
Wind Generating Facilities Real Power and Ramp Rate Limitations
17(1) Wind generating facilities must have the control capability to limit the real power output at the
point of connection in accordance with any limits or instructions contained in a directive, and in any
event, that real power output must not exceed the tolerances described in this subsection 17.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The real power control limit of the wind generating facilities referred to in subsection 17(1) must be
adjustable from the minimum operating output to the maximum authorized MW at an average resolution
of one (1) MW.
(3) When a real power limit at any wind generating facilities is in effect in accordance with a directive
and wind speed conditions at the wind generating facilities are increasing, then subject to subsection
17(4) below, the power limiting controls of the wind generating facilities must be capable of keeping the
one (1) minute average MW output from exceeding the wind generating facilities limit specified in the
directive by two percent (2%) of the maximum authorized MW.
(4) If a wind gust results in the real power control limit set out in the directive being instantaneously
exceeded, the wind generating facilities will remain in compliance if the real power output at the point of
connection does not exceed the real power control limit by more than five percent (5%) of the maximum
authorized MW.
(5) Wind generating facilities must be equipped with ramp rate limiting controls.
(6) The ramp rate limiting controls must be capable of limiting the ramping up of any wind generating
facilities, and must be adjustable such that the ramp rate does not exceed, in MW per minute, from five
percent (5%) of the maximum authorized MW to twenty percent (20%) of the maximum authorized MW.
(7) The default setting for the ramp rate limiting controls must be set at ten percent (10%) unless
otherwise specified by the ISO.
(8) Any difference in the real power at the point of connection and the collector bus must be
compensated for in the real power limiting and ramp rate limiting controls.
Reason for Stakeholder Positions:
- A generating facility can have one or more collector busses (please also refer to section 33 (2)).
- It is assumed that ramp rate means the rate at which an asset will change its level of supply or demand in MW per minute in
response to an energy market dispatch or directive.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 26 of 49
Alternate Proposal:
(8) Any difference in the real power at the point of connection and a collector bus must be compensated for in the real power
limiting and ramp rate limiting controls
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 27 of 49
2.
Requirements (cont’)
(mark with ”x”)
Wind Generating Facilities Protection Requirements
18(1) The owner of any wind generating facilities must comply with all provisions of the AIES
Protection Standard Rev 0, December 1, 2004.
X
Support
Oppose
No Comment
(2) The protection requirements set out in subsection 18(1) extend to and include the wind turbine
generator, any step-up transformer, collector facilities and any transmission system equipment required to
connect the wind generating facilities to the transmission system.
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
Wind Generating Facilities Power Quality
19 Wind generating facilities must comply with all industry practices, standards and guidelines for
electricity quality not otherwise specifically set out in this Section 501.3.1.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 28 of 49
2.
Requirements (cont’)
Voltage Flicker
20 The flicker for wind generating facilities must comply with either the maximum permissible voltage
flicker limits as defined in Appendix 4, or in International Electrotechnical Commission 61000-3-7,
Electromagnetic compatibility (EMC) – Part 3-7: Limits - Assessment of emission limits for the connection
of fluctuating installations to MV, HV and EHV power systems , whichever is lower.
(mark with ”x”)
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Most wind energy converters are certified in accordance with IEC 61400-21. This international standard has been developed for
measurement and assessment of power quality characteristics of wind energy converters. A corresponding certificate for most type
of wind energy converter is available on request. Based on this certificate, the flicker disturbance factor values can be calculated
and be compared to the maximum permissible values given in IEC 61000-3-7.
Alternate Proposal:
20 The flicker for wind generating facilities must comply with the maximum permissible flicker disturbance factor as defined in
International Electrotechnical Commission 61000-3-7, Electromagnetic compatibility (EMC) – Part 3-7: Limits - Assessment of
emission limits for the connection of fluctuating installations to MV, HV and EHV power system.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 29 of 49
2.
Requirements (cont’)
Harmonics
21(1) Upon request from the owner of any wind generating facilities, the ISO will provide information
describing the specific harmonic-impedance envelope at a proposed point of connection for those wind
generating facilities.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The owner must mitigate any harmonic currents resulting from non-compliance with IEEE Standard
519-1992 Recommended Practices and Requirements for Harmonic Control in Electrical Power Systems.
Reason for Stakeholder Positions:
IEEE Standard 519-1992 is not adapted to wind energy converters. Most wind energy converters are certified in accordance with
IEC 61400-21. This international standard has been developed for measurement and assessment of power quality characteristics
of wind energy converters. A corresponding certificate for any type of most wind energy converter is available on request. Based
on this certificate, the harmonic currents can be compared to the maximum permissible values given in IEC 61000-3-6.
Alternate Proposal:
(2) The owner must mitigate any harmonic currents resulting from non-compliance with International Electrotechnical Commission
61000-3-6, Electromagnetic compatibility (EMC) – Part 3: Limits – Section 6: Assessment of emission limits for distorting loads in
MV and HV power systems – Basic EMC publication.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 30 of 49
2.
Requirements (cont’)
(mark with ”x”)
Voltage Unbalance Avoidance
22(1) Wind generating facilities must not cause any voltage unbalance on the transmission system,
calculated in accordance with subsection 22 (2), in excess of three percent (3%).
X
Support
Oppose
No Comment
(2) The voltage unbalance will be calculated using the following formula:
Unbalance (%) = 100 x (deviation from average)
(average)
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
Avoidance of Undue Resonance
23. Any wind generating facilities must include systems and components designed to avoid introducing
undue resonance into the transmission system, such design specifications to apply to self-excitation of
induction machines, transformer ferroresonance, resonant effects of capacitor additions and the
capacitance of the wind generating facilities’ collector cables.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 31 of 49
2.
Requirements (cont’)
(mark with ”x”)
Grounding
24. Any wind generating facilities must be designed and constructed to take in to account that the
transmission system operates as an effectively and solidly grounded.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
Lightning Surge Protection
25. The lightning surge protection for any substation facilities associated with any wind generating
facilities must be designed to take into account the average isokeraunic level for the site location of the
wind generating facilities, and to be compatible with the connecting transmission facility to ensure
coordination of insulation levels.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 32 of 49
2.
Requirements (cont’)
(mark with ”x”)
Clearance and Access
26(1) All energized facilities and installations of any wind generating facilities must be maintained at safe
vertical and horizontal clearances and otherwise must meet the specifications and requirements set forth in
this subsection 26.
X
Support
Oppose
No Comment
(2) The connecting facilities of any wind generating facilities at a point of connection must be designed
and operate in compliance with the Canadian Electrical Code Part I.
(3) The facilities and installations of any transmission facility connecting with the wind generating
facilities at a point of connection must comply with The Alberta Electrical and Communication Utility
Code.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 33 of 49
2.
Requirements (cont’)
(mark with ”x”)
Wind Power Facility Fault Interrupting Devices
27(1) The design of the connecting facilities of any wind generating facilities must:
X
Support
Oppose
No Comment
(a) account for the fault contributions from both the transmission system and the wind generating
facilities; and
(b) have fault interrupting and momentary withstand ratings that are adequate to meet the maximum
expected fault levels, with a margin for future anticipated fault levels.
(2) The wind generating facilities must not use or apply high voltage fuses at sixty nine (69) kilovolts or
higher due to the risks of reduced reliability, increased outage times, single phasing and the possibility of
ferroresonance.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 34 of 49
2.
Requirements (cont’)
(mark with ”x”)
Wind Generating Facilities Isolating Devices
28(1) Any wind generating facilities must be designed and operate with manually operable isolation
switches at all points of isolation designated by the ISO after consultation with the owner of the applicable
transmission facility.
X
Support
Oppose
No Comment
(2) The isolation switches must permit visual verification of electrical isolation, and have the capability of
being locked open with multiple locks.
(3) All isolating switches of the wind generating facilities must be under the control of either the operator
of the wind generating facilities, or the operator of the transmission facility.
(4) If the wind generating facilities contain isolating switches owned by both the owner of the wind
generating facilities and the owner of the transmission facility, then the owner of the wind generating
facilities must agree in writing with the owner of the transmission facility as to who will control those
isolating switches.
Reason for Stakeholder Positions:
Alternate Proposal:
2.
Requirements (cont’)
(mark with ”x”)
Special Interconnection Protections
29. The ISO, after consultations with the owner of any wind generating facilities, may require in writing
additional, remedial action schemes and other specific protection and controls for the wind generating
facilities at a proposed point of connection to ensure adequate, safe, efficient and reliable protection of
the interconnected electric system and the wind generating facilities.
X
Support
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 35 of 49
2.
Requirements (cont’)
(mark with ”x”)
Revenue Metering
30(1) Any wind generating facilities must have revenue electric meter facilities conforming to the AESO
Measurement System Standard, to measure active energy and reactive energy flowing from the wind
generating facilities to the transmission system, and for submission of the resulting data and records to
the ISO.
X
Support
Oppose
No Comment
(2) The revenue electric metering facilities must include instrument transformers dedicated for metering
purposes only, voltage transformers, current transformers, secondary wiring, test switches, meters and a
communication interface.
(3) All metering data must be submitted to the ISO in the format specified in the standard referenced in
subsection 30(1).
(4) At the point of connection, the meter installation facilities must be capable of measuring real power
imports and exports.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 36 of 49
2.
Requirements (cont’)
Supervisory Control and Data Acquisition Requirements
31 In addition to complying with AESO SCADA Standard Rev 1 September 6, 2005 as amended from time
to time, any wind generating facilities must provide the following additional data:
(mark with ”x”)
(X)
Support
Oppose
No Comment
(a) voltage regulation system set-point;
(b) wind speed and direction, from a single point of measurement at the wind generating facilities;
(c) potential MW capability, the real power that would have been produced at the point of connection
without wind generating facilities curtailment and based on real time meteorological conditions at
each available wind turbine generator;
(d) real power limit, the MW limit used in the power limiting control system at the wind generating
facilities; and
(e) on / off status for the wind power limiting control system at the wind generating facilities.
Reason for Stakeholder Positions:
- As for (b): Does this refer to the “meteorological tower” mentioned in section 32? Is the “wind speed” an average or an
instantaneous value?
- As for (c): Is “potential MW capability” defined as: the real power that would have been produced at the point of connection
without wind generating facilities curtailment and based on real time meteorological conditions at each available wind turbine
generator
- As for (d): Is “real power limit” defined as: the MW limit used in the power limiting control system at the wind generating
facilities;
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 37 of 49
2.
Requirements (cont’)
Wind Power Data Collection Facility Requirements
32(1) Any wind generating facilities must have a data collection tower and related facilities installed in
accordance with the provisions of this subsection 32.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) The meteorological tower referred to in subsection 32(1) must be equipped with two (2) weather
measurement devices, one taking measurements at the wind turbine generator hub height and another
taking measurements at a height specified by the ISO.
(3) The measurement devices must measure, on a ten (10) minute average value;
(a) wind speed in meters per second (m/s), precision for instantaneous measurements to the nearest zero
point one (0.1) meters per second;
(b) wind direction in degrees from true north, precision for instantaneous measurements to the nearest one
(1) degree;
(c) barometric pressure in HectoPascals (HPa), precision for instantaneous measurements to the nearest
six (6)-Pa; and
(d) ambient temperature in degrees celsius (◦C), precision for instantaneous measurements to the nearest
zero point one (0.1) degrees celsius.
(4) The ISO will specify in writing whether the owner must submit the data described in subsection 32 for
the wind generating facilities to the ISO by means of the systems referenced in subsection 31, or an
alternative means or path.
Reason for Stakeholder Positions:
As for (1) and (2): It is assumed that the “data collection tower” is identical to the “meteorological tower”?
Alternate Proposal:
(1) Any wind generating facilities must have a meteorological tower and related facilities installed in accordance with the
provisions of this subsection 32.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 38 of 49
2.
Requirements (cont’)
(mark with ”x”)
Wind Power Facility Monitoring Equipment
33(1) Any wind generating facilities must have a monitor installed that complies with the AESO
Requirements for Phasor Measurement Units.
X
Support
Oppose
No Comment
(2) The monitor must be capable of measuring all three (3) phase to ground voltages and currents at each
collector bus of the wind generating facilities and for each transmission step-up transformer.
(3) The monitor must be capable of measuring all three (3) phase to ground voltages and currents at each
point of connection of the wind generating facilities.
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 39 of 49
2.
Requirements (cont’)
Wind Generating Facilities Testing Post Connection
(mark with ”x”)
Support
34(1) Following connection of any wind generating facilities to the transmission system, those facilities
must be tested by the owner in accordance with the provisions of subsection 34(2) below and the test
results and report must be provided as per the ISO document “Requirements for Model Validation” no later
than thirty (30) days following the date upon which wind speed conditions reasonably will allow for the tests
to be conducted.
(2) The following specific tests must be completed:
(a) A voltage regulation system and reactive power response test, which demonstrates the ability of the
wind generating facilities to control the collector and transmission system voltage in a stable
manner, and which test consists of injecting a test signal to the voltage reference point of the voltage
regulation system;
(b) A reactive power capability test, which demonstrates the ability of the wind generating facilities to
provide continuous reactive power in accordance with the any applicable standards set out in the ISO
rules;
(c) A voltage set-point capability test, which demonstrates the ability of the wind generating facilities to
adjust the voltage set-point of the voltage regulation system to any applicable standards set out in
the ISO rules;
(d) A harmonic test as may be required by the ISO , which will demonstrate that harmonic levels for the
wind generating facilities are within the limits of IEEE 519; and
(e) A flicker test as may be required by the ISO, which will confirm that the flicker levels for the wind
generating facilities are within the specifications set out in subsection 21.
(3) The tests set out in this subsection 34 may be required to be re-conducted upon written request from
the ISO, and in any event, such retests must be done due to a change in any applicable NERC or WECC
policy or standards requirements.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 40 of 49
X
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 41 of 49
2.
Requirements (cont’)
Provision of Modelling Information
35(1) In accordance with the Transmission Technical Modeling Requirements of the ISO, the owner of any
wind generating facilities must provide to the ISO all reasonably requested data and records to allow for
the modeling of the wind turbine generators, transformers, collector systems, control systems and other
installations of the wind generating facilities.
(mark with ”x”)
X
Support
Oppose
No Comment
(2) Where an appropriate model is not available within Siemens’ PSS/E software, the owner must supply a
working user written PSS/E model.
(3) If such a model is supplied to the ISO, then in addition, the owner must provide a written model and
compiled code of the model, and maintain the user written model compatible with current and new
releases of PSS/E until such time as a standard model is provided to the ISO.
(4) Any model submitted by an owner under this section 35 may be resubmitted by the ISO to the WECC
and its members for interconnected system studies.
(5) The owner in addition must provide the ISO with power system studies which demonstrate that the
wind generating facilities are capable of meeting the voltage ride through requirements specified in
subsection 35(3).
(6) The owner must provide the ISO with a wind turbine generator model with validated data
demonstrated by a physical performance test, on a sixty (60) Hertz system, of at least one wind turbine
generator for every type or model used at the wind generating facilities.
(7) The owner in addition must provide a voltage regulation system model with validated data
demonstrated by a physical performance test of at least one (1) voltage regulation system device used
at the wind generating facilities.
(8) The owner in addition must re-validate all model data from time to time as requested by the ISO.
Reason for Stakeholder Positions:
- As for (1): It should be considered that there are types of wind energy converters where the wind turbine generator is
completely decoupled from the grid and hence plays a minor role for the behavior of the generating system on the grid. In this
case the provision of data of the
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 42 of 49
- As for (4): Is this section applicable in case a user written model has been provided?
- As for (6): See comment to (1). A test on a 50Hz system must be accepted. Is there a standard for the validation of the wind
turbine generator model? ENERCON models are validated in accordance with FGW Technische Richtlinie Teil 4: Anforderungen
an Modellierung und Validierung von Simulationsmodellen der elektrischen Eigenschaften von Erzeugungseinheiten und -anlagen
Alternate Proposal:
(1) In accordance with the Transmission Technical Modeling Requirements of the ISO, the owner of any wind generating
facilities must provide to the ISO all reasonably requested data and records to allow for the modeling of the generating unit,
transformers, collector systems, control systems and other installations of the wind generating facilities.
(6) The owner must provide the ISO with a generating unit model with validated data demonstrated by a physical performance
test of at least one wind turbine generator for every type or model used at the wind generating facilities.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 43 of 49
2.
Requirements (cont’)
Wind Power Data Facility Requirements
(mark with ”x”)
Support
36(1) Any wind generating facilities must have equipment and installations so as provide to the service
provider as designated by the ISO forecast data and records, which must include historical ten (10) minute
averaged meteorological data, containing details on wind speed, wind direction, temperature and
barometric pressure and which illustrate the height of the measurements.
(3) Upon written request by the ISO, the owner of the wind generating facilities must provide historical
data and records referenced in subsection 36(1) for up to two (2) calendar years prior to the
commissioning period of the wind generating facilities.
(4) The owner of the wind generating facilities must provide the ISO with wind turbine generator data
and records, including hub height, turbine land coordinates, turbine power curves, high wind speed cut-out,
and any applicable temperature cut-outs.
(5) The ISO will specify in writing how the owner must submit to the ISO the data and records specified in
this subsection 36 for the wind generating facilities.
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 44 of 49
X
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
3.
(mark with ”x”)
Appendix 1 - Voltage Ride Through Requirements
120%
Wind generating facilities may trip above high voltage requirement.
X
Support
Oppose
No Comment
Voltage (Point of Connection) Percent of Rated
100%
Fault incidence at
time = 0 second.
80%
60%
Wind generating facilities may trip below
low voltage requirement.
40%
20%
15%
0%
-1
0
1
2
3
4
5
Time (Seconds)
Low Voltage Requirement
High Voltage Requirement
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 45 of 49
Reason for Stakeholder Positions:
Alternate Proposal:
3.
(mark with ”x”)
Appendix 2 - Reactive Power Capability
-0.985 power
factor
at maximum
authorized MW
+0.95 power
factor
at maximum
authorized MW
Continuous Reactive Power
Capability
Dynamic Reactive Power
Capability
-0.95 power factor
at maximum
authorized MW
X
Support
Oppose
No Comment
+0.9 power
factor
at maximum
authorized MW
1.0
MW per unit
0.8
0.6
0.4
Absorbing MVArs per unit
0.6
0.484
0.4
0.2
0
0.2
0.4
0.328
0.6
0.2
Producing MVArs per unit
Where 1 per unit is the maximum authorized MW
Minimum continuous
reactive capability
Minimum dynamic
reactive capability
Continuous reactive power capability
within the shaded area.
Dynamic reactive power capability
within the shaded area.
Reason for Stakeholder Positions:
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 46 of 49
Alternate Proposal:
3.
Appendix 3 - Trip Settings of Off-Nominal Frequency Protective Relays
Frequency (Hz)
Minimum Time Delay
>61.7 Hz
0 seconds
61.6 Hz to 61.7 Hz
30 seconds
60.6 Hz to <61.6 Hz
3 minutes
>59.4 Hz to <60.6 Hz
Continuous Operation
>58.4 Hz to 59.4 Hz
3 minutes
>57.8 Hz to 58.4 Hz
30 seconds
>57.3 Hz to 57.8 Hz
7.5 seconds
>57.0 Hz to 57.3 Hz
45 cycles
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
(mark with ”x”)
Support
Page 47 of 49
X
Oppose
No Comment
Reason for Stakeholder Positions:
Alternate Proposal:
3.
Appendix 4 - Voltage Flicker Limits
(mark with ”x”)
X
Support
Oppose
No Comment
Reason for Stakeholder Positions: Please refer to remarks in 20 and 21
Alternate Proposal: should be delete
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 48 of 49
Please return this form with your comments by Friday, January 22, 2010 to:
John Kehler, Operations and Reliability, [email protected],
(403) 539-2622 or alternate,
Kevin Wiens, [email protected] (403) 539-2672
Proposed New ISO Rule: 2009-12-16 – Comments from ENERCON
Page 49 of 49