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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 Page 11 of 49 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 Page 12 of 49 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 Page 13 of 49 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 Page 14 of 49 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 Page 16 of 49 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 Page 19 of 49 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 Page 20 of 49 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 Page 22 of 49 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 Page 23 of 49 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 Page 24 of 49 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 Page 25 of 49 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