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Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft Date: 2011-12-06 Proposed New ISO Rules Section 502.5 Generating Unit Technical Requirements (“New ISO Rules Section 502.5”) Date of Request for Comment [yyyy/mm/dd]: Period of Consultation [yyyy/mm/dd]: 2011/12/06 2011/12/06 Comments From: Capital Power Corporation Date [yyyy/mm/dd]: 2012/02/14 through 2012/01/31 Contact: Amber Kirby Phone: 403-717-4677 E-mail: [email protected] Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO Rules. Please refer back to the Letter of Notice under the “Attachments to Letter of Notice” section to view the actual proposed content changes to the ISO Rules. Please place your comments / reasons for position underneath (if any). 2. ISO Rules Subsection 2 – Requirements – New Generating Unit Subsection 2 sets out, with clarity, the provisions that apply to a new generating unit. Stakeholder Comments and/or Alternate Proposal Comment # 6: Capital Power thanks the AESO for the opportunity to comment on the proposed ISO Rule 502.5 Generating Unit Technical Requirements. Capital Power appreciates the AESO’s and specifically the TOAD initiative’s efforts to review the authoritative documents and redraft where necessary to improve clarity and eliminate any duplication of obligations. AESO Replies Capital Power believes that the list of exceptions listed in subsection 2(2) and 2(3) should be exhaustive or would be better included in the individual sections to which the exemptions apply. If only some of the exemptions are listed, market participants will not be able to rely on this subsection to determine applicability and may not refer back to this subsection when reviewing the specific requirements. Therefore, the individual subsections from which some units may be exempt should be stated within those subsections for clarity and ease of reference. For example, rather than Issued for Stakeholder Consultation: 2011-12-06 Page 1 Public Information stating in Subsection 2(2) that a new unit connected to the in-plant distribution of an industrial complex with 2 or more voltage transformers is exempt from subsections 24-28, subsection 24-28 should state that those units are exempt from that subsection. Subsection 2(3) should also be removed and subsection 9 should state that it does not apply to new generating units for the same reasons explained above. Subsection 2(4) states that if any of the facilities of an existing generating unit are “subsequently modified” then the unit will be required to comply with ISO rule 502.5. It is not clear what is meant by “subsequently modified”. Capital Power suggests the AESO establish a clearer threshold for determining what would be considered “subsequently modified” in this context. Subsection 9(8) specifies a capacity increase amount as a threshold. Although increased capacity may not be the only modification to be considered but equipment changes that are required for standard operations and maintenance should not require existing generators to comply with all subsections applicable to new generating units. Is it the intent of subsection 2(5) to imply that new generating units that have not been energized but were issued a functional specification from the AESO before the effective date of the proposed rule 502.5 are not required to comply with the standard but only with the unit specific functional specification? This seems contradictory to subsection 3 Existing Generating Unit as existing units are required to comply with certain subsections within the new proposed rule as well as their unit specific functional specifications. If that is not the intent of subsection 2(5) it should be moved to be included in subsection 3(1). Issued for Stakeholder Consultation: 2011-12-06 Page 2 Subsection 3 – Requirements – Existing Generating Unit Subsection 3 sets out the provisions that apply to an existing generating unit, including clarifications as to what subsections of proposed New ISO Rules Section 502.5 are not applicable. Subsection 6 – Operating Voltage Requirements Subsection 6 requires the market participant to clearly state the voltages to which the generating unit will be designed at both the point of connection and the generator terminals. In Alberta, the voltage levels may vary considerably from the nominal voltage, therefore, having the legal owner clearly stating the values to be voltages at the point of connection and the generating unit terminals allows the AESO to fairly ensure the compliance of all legal owners with regard to: (a) The voltage ride-through requirements; (b) Voltage regulation; and (c) The reactive power requirements of the generating unit. This subsection also makes the legal owner aware of the voltage range at that facility so that they may properly specify, design and purchase the appropriate equipment. Subsection 7 – Maximum Authorized Real Power Subsection 7 requires the participant to submit in writing the maximum value that the generating unit can ever be operated at, under ideal circumstances while meeting other requirements of proposed New ISO Rules Section 502.5. Issued for Stakeholder Consultation: 2011-12-06 Comment # 7: The same comments provided for subsection 2(2)-(4) apply to subsections 3(2)-(4). Please see above. Comment # 10: Subsection 6(1) applies to “new or modified existing generating units”. It is not clear what qualifies as a modification to an existing generating unit from the AESO’s perspective and when that modification would have taken effect. It is not clear from subsection 6(1) which units will be required to submit their proposed operating values without being specifically requested to do so by the AESO as described in subsection 6(3). It is unclear what the intent of Subsection 6(3) is. Subsection 6(3) requires existing generating units to submit a proposed operating voltage value if requested to do so by the AESO. The operating voltage levels of each generating unit are defined within the functional specifications provided by the AESO so the AESO should already have copies of voltage information. Therefore, it is not clear why the AESO would request voltage information to be submitted again. Capital Power understands that new generation connecting to existing lines or general transmission degradation may require additional operating voltage support in some areas but existing generators should not be required to upgrade equipment when the existing generator has not been modified. Existing generating units should also not be required to adjust their technical characteristics at the AESO’s discretion. Comment # 11: Subsection 7(2) requires market participants to be “in compliance with….. subsections 8 and 9 as applicable”. Cross referencing within or across rules should be avoided as a single incident of non-compliance would result in a violation of several ISO rules. Avoiding Page 3 Many generating units can operate above nameplate values under the proper conditions, so to properly study the behaviour of the generating units in respect to the transmission system, this maximum value needs to be clearly stated. This value is also required to properly design the transmission system. duplication of requirements is one of the fundamental principles of the TOAD process and should be maintained wherever possible. Therefore, subsection 7(2) should be removed as it is already covered by subsections 8 and 9 and therefore redundant. The Generating Unit Technical Requirements rule is intended to describe the operational characteristics a generating unit is required to satisfy in order to connect to the AIES. Subsection 7(4) describes how a generating unit should be operated. Rules regarding unit operation should instead be covered in reliability standards or ISO Rules 3 and 6. Subsection 9 – Additional Reactive Power Requirements for a Generating Unit with a Power Purchase Arrangement This section requires the applicable participant to meet certain requirement in regards to reactive power obligations under normal and abnormal system conditions. Most of this section covers policies already in place by the AESO, however for clarity, these requirements have been incorporated into proposed New ISO Rules Section 502.5 to allow participants to find all requirements to design, build, maintain and/or modify facilities under dedicated ISO rules. For background information please refer to the document Application Guideline Generator Interconnection Requirements – Reactive Power available at: http://www.aeso.ca/downloads/AESO_PPA_Reactive_Power_Guidelines.pdf Of particular note, subsection 9(10) specifies the requirements that will be applicable to generating units that are currently the subject of a power purchase arrangement once that power purchase arrangement ends. Issued for Stakeholder Consultation: 2011-12-06 Comment # 13: Subsection 9(5) and 9(6) require generating units that are subject to the reactive power requirements of a power purchase arrangement (PPA) to operate outside established power factor range under abnormal conditions. Providing additional reactive power often presents an opportunity cost in terms of forgone real power production. Due to the necessity of reactive power production and consumption to ensure the reliable operation of the transmission system, the rules for reactive power should encourage efficient and reliable investment in the infrastructure needed and should provide incentives for existing infrastructure to provide reliable and efficient reactive power. Reactive power can be supplied by transmission facilities or generators. Since in Alberta, reactive power is typically supplied by generators, opportunities for cost recovery should be available as they would be if transmission facilities were satisfying reactive power requirements. The FERC Generation Interconnection Rule, Order No. 2003 stated that generators should not be compensated for providing reactive power within the established power factor range but should be compensated for providing excess reactive power in the case of an emergency. Many countries around the world compensate generators for providing and consuming Page 4 reactive power so it is unclear why Alberta has not elected to do so thus far. Capital Power encourages the AESO to investigate compensation options for reactive power providers to ensure that sufficient incentives are available to maintain the reliable operation of the AIES. Subsection 9(8) explains that the AESO will consider a generating unit operating under a PPA to be modified if the real power output exceeds the committed capacity specified in the PPA by 2%. Although Capital Power appreciates the additional clarity the AESO provided regarding the threshold for determining a modification, a 2% increase is insufficient. For example, for a 300MW generating unit, 2% would only allow for an increase of 6MW. ISO Rule 6.6 permits generating units greater than 200MW to vary output by 10MW so it does not make sense than output that is still considered reasonable under dispatch variance rules would result in a generating unit being considered modified under the Generating Unit Technical Requirements. Capital Power suggests that a 10% increase would be more reasonable as the effect on the system operation would be more significant. Subsection 10 – Voltage Ride-Through Requirements All generating unit must have the capability to support the transmission system during system disturbances. Therefore, each generating unit must have some capability for voltage ride through. The basic approach to the requirements for existing generating units has been carried over from the existing Technical. Subsection 10 allows new generating units to be able to ride through system disturbances that result in voltages as low as 0% and as high 120% for specified periods of time. This requirement has been amended to align with the direction that the industry is taking for new generating units. Please refer to FERC orders 661 and 693. Comment # 14: The level of detail provided in Subsection 10(4) is unnecessary and does not clearly indicate the intent of this provision. The provision stated in Subsection 10(4)(a) should be sufficiently clear that the generating unit and any other critical device must remain online during the inception or post-fault transient period following a transmission system disturbance. For example, subsection 10(4)(b) is unnecessary as some contactors may drop out but auxiliary equipment can compensate automatically to prevent the generating unit from tripping. This should be considered sufficient to satisfy the intent of the voltage ride through requirements. Could the AESO provide an example of a synchronous Issued for Stakeholder Consultation: 2011-12-06 Page 5 generating unit that has been able to comply with the 0.0% voltage ride through requirement specified in Subsection 10(5)? Capital Power understands that Subsection 10(5) has been included in anticipation of Reliability Standard “PRC-024 - Generator Performance During Frequency and Voltage Excursions” being approved, first by NERC and subsequently by WECC and Alberta. Capital Power does not support Alberta implementing more onerous reliability requirements than the rest of North America unless it is clearly necessary to maintain the reliability of the AIES. PRC-024 has not been approved by NERC and is not even listed on the Alberta Reliability Standards implementation plan. It has not been clearly communicated why new synchronous generators in Alberta will be required to comply with a more stringent requirement from a system reliability perspective. Therefore, Subsection 10(5) should be removed and new generators should be subject to Subsection 10(3) instead. It is also not clear what the AESO deems “critical” in this context. The Critical Infrastructure Protection (CIP) Alberta Reliability Standards (ARS) describe a very specific definition of “critical” infrastructure. One of the main principles of the TOAD initiative is to ensure that defined terms are used consistently across all AESO authoritative documents. If the term “critical” in this context does not have the same meaning as it does in the CIP ARS, another AESO authoritative document, then it would not be appropriate to use it here. Further, since the intent of the voltage ride through requirements is to ensure the generating unit will not trip offline as a direct result of a transmission disturbance, references to other “critical devices” is unnecessary and should be removed. Issued for Stakeholder Consultation: 2011-12-06 Page 6 Subsection 21 – Synchrophasor Measurement System Subsection 21 requires new or existing units with an upgraded protection system to install a synchrophasor measurement system. The application of synchrophasor measurement systems on generating units will allow the AESO to better analyze the response of the generating units to system disturbances, which assist the AESO in developing mitigating requirements for the reliability of the transmission system. It will also allow the AESO to better monitor compliance to the ISO rules and requirements. The generating unit owners and operators will also be able to use this data to analyze the behaviour of the generating unit for the model revalidation requirements and determine if the generating unit is operating as designed. Comment # 25: Capital Power does not support the inclusion of this provision within the Generating Unit Technical Requirements for multiple reasons. Capital Power understands that the AESO and various transmission facility owners installed synchrophasor measurement systems at various generating units several years ago and that the technical capabilities of these units is such that one phasor measurement unit (PMU) can monitor several generating units and transmission facilities simultaneously. Therefore, it is unnecessary to install equipment of this complexity on each individual new generating unit. Some, if not all PMUs currently in operation are managed by transmission facility owners that have cost recovery capabilities. If the AESO intends to require all new generating units to install synchrophasor measurement systems to support the reliable operation of the AIES, cost recovery mechanisms should also be made available. Subsections 21(1) requires that a new generating unit or existing generating unit that replaces its protections system must have a synchronized phasor measurement system that complies with the “AESO Requirements for Phasor Measurement Units”. Subsection 21(3) also requires generating units to comply with the reporting requirements specified in the “AESO Requirements for Phasor Measurement Units”. Cross referencing within or across rules should be avoided as failure to comply with subsection 21(1) or 21(3) would result in a violation of the “AESO’s Requirements for Phasor Measurement Units” rule as well. A single act should not result in multiple fines for non-compliance. Avoiding duplication of requirements is one of the fundamental principles of the TOAD process and should be maintained wherever possible. Therefore, subsection 21 should be removed as it is already covered by a separate ISO rule and Issued for Stakeholder Consultation: 2011-12-06 Page 7 should not be the responsibility of new generators. Subsection 24 – Testing Intervals Subsection 24 sets out requirements to provide a model validation or reactive power verification report in terms of both format and timing. Issued for Stakeholder Consultation: 2011-12-06 Comment # 28: Subsection 24(4) explains what the AESO considers a modification to an existing generating unit that will require testing. Replacement of existing equipment that is required for standard operations and maintenance should not be considered a modification and therefore subject to the testing requirements specified in subsections 24, 24 and 27. Subsection 24(4)(e) describes any other modification that changes the behavior of the generating unit. This is the more appropriate threshold. Equipment replacements that have the same capabilities and operate in the same manner should not require additional testing. Page 8