Download Stakeholder Comment and Rationale Form AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

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:
TransCanada Energy Ltd. (TCE)
Date [yyyy/mm/dd]:
2012/01/13
through
2012/02/14
Contact:
Janene Taylor
Phone:
403-920-7682
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).
1. ISO Definitions
(a) New
There are no new ISO rules definitions associated with proposed New ISO Rules
Section 502.5
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position (if
any)
(b) Removals
There are no ISO rules definitions removals associated with proposed New ISO
Rules Section 502.5.
Comment # 2: Insert Comments / Reason for Position (if
any)
(c) Amendments
There are no amendments to ISO rules definitions associated with proposed New
ISO Rules Section 502.5.
Comment # 3: Insert Comments / Reason for Position (if
any)
2. ISO Rules
Issued for Stakeholder Consultation: 2011-12-06
Stakeholder Comments
Page 1
AESO Replies
Alternate Proposal
Public Information
(a) New
Comment # 4: Insert Comments / Reason for Position (if
any)
The AESO’s existing Generator and Load Interconnection Standard (“Technical
Standard”) was adopted in 2006. The Technical Standard has a 5 year term, and
therefore needs to be reviewed and amended during the 2011-12 timeframe.
However, the AESO is transitioning all of its technical requirements including the
Technical Standard into new ISO rules, in accordance with the principles and
procedures under the AESO’s Transition of Authoritative Documents (“TOAD”)
project. The AESO has further determined that it would be most efficient and
practical going forward to split the Technical Standard in to separate new load
and generating unit technical ISO rules. The first stage of this initiative is to redraft
and relocate the applicable generating unit provisions of the Technical Standard
into Proposed New ISO Rules Section 502.5.
The AESO is endeavoring to represent legally binding requirements and
obligations in one of its three authoritative document domains, those being ISO
rules, ISO tariff or the Alberta Reliability Standards. The proposed minimum
technical requirements of a legally binding nature for existing, modified and new
generating units have been set out in the proposed New ISO Rules Section 502.5.
It should be noted that, as provisions have been redrafted and relocated in
proposed New ISO Rules Section 502.5, the AESO has not intended any
essential changes to the policies currently reflected in the Technical Standard for
generating units, with some specific and limited exceptions referred to below.
The rationale for each of the subsections of proposed New ISO Rules Section
502.5 is provided below.
Subsection 1 – Applicability
Comment # 5: Insert Comments / Reason for Position (if
any)
The applicability section of the Technical Standard did not clearly state which
market participant subcategories were responsible for meeting the requirements.
Subsection 1 clarifies that the requirements apply to legal owners of a generating
unit including those in an industrial complex, but excludes wind aggregated
generating facilities.
Issued for Stakeholder Consultation: 2011-12-06
Page 2
Subsection 2 – Requirements – New Generating Unit
Comment # 6:
Proposed Wording
Subsection 2 sets out, with clarity, the provisions that apply to a new generating
unit.
As a general comment TCE finds Sections 2 and 3
difficult to understand and repetitive of one another. In
particular, the term “new generating unit” and “facilities
modification” are not clearly defined. TCE offers the
following comments on Sections 2 and 3 and has
offered alternate proposed wording that in TCE’s view
provides greater clarity.
Requirements
Requirement 2(1) refers to a generating unit that is
“new” as of the effective date of the rule. Requirement
2(5) states that the provisions of the rule do not apply to
a generating unit with a functional specification issued
by the ISO prior to the effective date of the rule.
Requirement 7(3) indicates that the ISO will deem the
Maximum Authorized Real Power (MARP) for an
existing unit to be the Maximum Authorized MW (MAM)
previously approved by the ISO in writing or in the
functional specification. Taken together it appears (for
the purposes of this rule), the AESO considers a
generating unit to be new provided it has not yet
synchronized to the Alberta Interconnected Electric
System (AIES) and has not received an approved
functional specification from the ISO. It then follows that
all other units would be considered existing and would
receive from the AESO a MARP equal to its MAM. If
TCE’s understanding is correct than TCE would
propose for ease of understanding that requirements
2(1), 2(5) and 3(1) be replaced with TCE’s proposed
requirements 2(1) and 2(2) as follows:
2(1) On and after the effective date of this section 502.5
and subject to the provisions of this subsection 2, the
legal owner of an existing generating unit, which for
the purposes of this section 502.5 is defined as a
generating unit which is energized and in commercial
operation as of the effective date of this section 502.5
must comply with the provisions of this section 502.5
and with the functional specification provisions for that
Issued for Stakeholder Consultation: 2011-12-06
Page 3
2(1) On and after the effective date of this
section 502.5 and subject to the provisions of this
subsection 2, the legal owner of an existing
generating unit, which for the purposes of this
section 502.5 is defined as a generating unit
which is energized and in commercial operation
as of the effective date of this section 502.5 must
comply with the provisions of this section 502.5
and with the functional specification provisions
for that generating unit.
(2) On and after the effective date of this section
502.5 and subject to the provisions of this
subsection 2, the legal owner of a new
generating unit, which for the purposes of this
section 502.35 is defined as a generating unit
that has not yet synchronized and does not have
an approved functional specification from the
AESO as of the effective date of this section
502.5 must comply with the provisions of this
section 502.5 prior to the generating unit being
energized.
(3) If after the effective date of this section 502.5
the legal owner of an existing generating unit
subsequently physically alters that generating
unit or the functional specification for an
existing generating unit, such that the
maximum authorized real power for that
generating unit increases by a value greater
than 10%, then subject to subsections 2(2) and
2(3) the legal owner must ensure the
modification is in compliance with the provisions
of this section 502.5.
(4) The testing, reporting and modeling
generating unit.
(2) On and after the effective date of this section 502.5
and subject to the provisions of this subsection 2, the
legal owner of a new generating unit, which for the
purposes of this section 502.35 is defined as a
generating unit that has not yet synchronized and does
not have an approved functional specification from the
AESO as of the effective date of this section 502.5 must
comply with the provisions of this section 502.5 prior to
the generating unit being energized.
In addition, subsections 2(1) and 3(1) indicate that a
generating unit must continue to comply for so long as
the generating unit remains connected to the
transmission system. TCE is of the view that the
inclusion of this requirement is inappropriate as TCE
understood that this rule is intended to only specify the
design requirements and capabilities of a generating
unit and not to place any requirements on the operation
of a generating unit which are already contained in
existing AESO rules and reliability standards. TCE
requests that the AESO clearly delineate the design
specifications from the operational requirements of
generating units in order to avoid redundancy in
requirements and TCE’s proposed wording reflects its
view that the sentence be deleted from the
requirements.
Requirement 2(3) is redundant; the applicability of
subsection 9 is set out in subsection 9. TCE suggests
removing subsection 2(3).
Requirement 2(4) is confusing. TCE’s understanding is
that if a generating unit synchronizes prior to the
effective date of this rule it would have a functional
specification and would be considered an existing
generating unit. As such it appears that requirement
2(4) is intended to deal with generating units that have
not yet synchronized but have an approved functional
Issued for Stakeholder Consultation: 2011-12-06
Page 4
requirements set out in subsections 24 to 28 do
not apply to a generating unit that is connected
to the in-plant distribution of an industrial
complex and with two (2) or more voltage
transformations between the generating unit
terminals and the transmission system.
(5) The synchronized phasor measurement
system provisions set out in subsection 21 apply
only to new generating units as of the effective
date of this section 502.5.
specification and that any changes to an approved
functional specification prior to synchronization must
comply with the requirements of this rule 502.5. TCE
recommends that the requirement be reworded to be
clearer.
Furthermore, it is TCE’s view that the term modification
(or modify) is not sufficiently clear. Given the
importance of the term in triggering changes in
compliance obligations it must be defined for the
purposes of this rule. TCE submits that for the purpose
of this rule a modification should only constitute a
physical alteration to a generating unit that increases
the output of that generating unit by some percentage of
the of maximum authorized real power. TCE suggests
10%. As such TCE recommends that requirements 2(4)
and 3(4) be combined and reworded as the new
requirement 2(3).
(3) If after the effective date of this section 502.5 the
legal owner of an existing generating unit
subsequently physically alters that generating unit or
the functional specification for an existing generating
unit, such that the maximum authorized real power
for that generating unit increases by a value greater
than 10%, then subject to subsections 2(2) and 2(3) the
legal owner must ensure the modification is in
compliance with the provisions of this section 502.5.
Given the proposed changes requirements 2(2) and
3(2) have been combined into a new requirement (2)
and requirement 3(3) has been renumbered as
requirement 2(5).
(4) The testing, reporting and modeling requirements
set out in subsections 24 to 28 do not apply to a
generating unit that is connected to the in-plant
distribution of an industrial complex and with two (2) or
more voltage transformations between the generating
unit terminals and the transmission system.
Issued for Stakeholder Consultation: 2011-12-06
Page 5
(5) The synchronized phasor measurement system
provisions set out in subsection 21 apply only to new
generating units as of the effective date of this section
502.5.
Issued for Stakeholder Consultation: 2011-12-06
Page 6
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.
Comment # 7: Insert Comments / Reason for Position (if
any)
If subsection 2(1) is amended as suggested above then
subsection 3(1) is not required and subsection 2(4) and
3(4) are otherwise redundant. In addition the headings:
New Generating Unit and Existing Generating Unit are
not required.
.
Subsection 4 – Functional Specification
Comment # 8: Insert Comments / Reason for Position (if
any)
Consistent with current practice, subsection 4 enables the AESO to approve of
and issue a functional specification for a generating unit project, which will set out
technical details with regard to design, construction and operation of the
generating unit connection project and any associated transmission system
connection facilities.
Consistent with technical requirements under other ISO rules, Subsection 4(2)
allows for variances in a functional specification under certain conditions.
Subsection 5 – Successor to Prior Requirements
Subsection 5 clarifies that proposed New ISO Rules Section 502.5 succeed the
generating facilities provisions of the Technical Standard.
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:
Comment # 9: Insert Comments / Reason for Position (if
any)
This section could be moved to directly below the
applicability section.
Comment # 10: Insert Comments / Reason for Position
(if any)
The inclusion of the word two (2) in requirement 6(1)
creates confusion. TCE recommends that the word two,
and the words “the first value” and “the second value”
be deleted.
(a) The voltage ride-through requirements;
Issued for Stakeholder Consultation: 2011-12-06
Page 7
Note that the proposed wording below makes
reference to TCE proposed requirement 2(3).
6(1) The legal owner of a new or existing
generating unit that has been modified subject
to subsection 2(3) must submit in writing to the
ISO the root mean square phase-to-phase
operating voltage values the legal owner
proposes to use at the:
a) point of connection…
(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.
TCE does not understand the purpose of Requirement
6(3).
b) terminals of the…
It is unclear as to the circumstances under which the
ISO would provide the owner of an existing generating
unit with written notice requiring the generating unit to
request approval from the AESO of a proposed
operating voltage. It seems that an existing generating
unit should not need approval for a proposed operating
voltage considering the existing generating unit by
definition is already operating (or has a functional
specification) and has had its operating voltage
approved by the AESO.
Perhaps it would be necessary that the ISO would need
to contact an existing generating unit to notify the
generator if there were changes to the voltage in the
area. If this is the intent of requirement 6(3) it should be
reworded to make that clear.
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.
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.
Issued for Stakeholder Consultation: 2011-12-06
TCE recommends that requirement 6(3) either be
deleted or reworded.
Comment # 11: Insert Comments / Reason for Position
(if any)
Subsection 7(2) should be amended for clarity.
Subsection 7(4) should be deleted as it places
requirements on the operation of a generating unit not
on the capability of the unit. Furthermore, ISO Rule 3
requires that a generating unit’s Available Capability be
less than or equal to its Maximum Capability (MC),
which is approved by the ISO, presumably the ISO
would approve an MC for a generating unit greater than
its MARP. In addition, ISO Rule 6.6 requires that a
generating unit operate in compliance with its dispatch;
once again TCE presumes the ISO would not dispatch a
unit above its MARP. As such, this requirement is
addressed in the ISO Rules and should not be repeated
here.
Page 8
7(2) The ISO will not approve a maximum
authorized real power value that is not in
compliance with the reactive power requirements
set out in subsections 8 or 9, as applicable.
Subsection 8 – Reactive Power Requirements for All Generating Units
Subsections 8(4) through 8(6) allow the participant to apply for a reduction in the
reactive power/power factor requirement in the under excited region of the
reactive capability curve.
The AESO is aware of the concerns that depending on the specific location of the
generator unit, operating near the bottom of the D-curve may result in the unit
becoming unstable. In the AESO’s opinion, it would be appropriate to reduce the
reactive power requirement, if provided with technical back up to this concern.
Comment # 12: Insert Comments / Reason for Position
(if any)
As discussed in more detail in the accompanying letter
TCE requests that the AESO have a fulsome
consultation on the reactive power obligations for
generating units. TCE has and continues to express its
view that generators should be compensated for the
reactive power it provides, particularly during
emergency conditions and that reactive power should
be considered an ancillary service.
Subsection 6(5) and 8(1) are redundant.
Subsection 9 – Additional Reactive Power Requirements for a Generating
Unit with a Power Purchase Arrangement
Comment # 13: Insert Comments / Reason for Position
(if any)
This section requires the applicable participant to meet certain requirement in
regards to reactive power obligations under normal and abnormal system
conditions.
It is inappropriate and unnecessary to repeat or refer to
legislative requirements within ISO Rules as it creates
redundancy in the obligations. TCE submits that
subsection 9(4) be deleted.
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:
In TCE’s view requirements 9(8), 9(9) and 9(10) are
also inappropriate. The reactive power requirements
specified in the PPA were chosen based on the
capability of those facilities and may not necessarily
change as a result of a modification and they may not
change upon the expiry of the PPA legislation.
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
Furthermore, the Power Purchase Arrangements (PPA)
are legislation and in TCE’s view it is inappropriate for
the AESO to place more onerous requirements on a
generating unit subject to a PPA because it undergoes
a modification.
Page 9
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: Insert Comments / Reason for Position
(if any)
The previous Generation and Load Interconnection
standard required that generating units be capable of
continuous operation between +/- 5% and generating
units connected under the 2006 standard (or its
predecessors) were designed to meet the +/-5%
requirement.
It is unclear to TCE the exact point where the voltage is
measured. The requirement to be capable of
continuous operation between 90% and 100% of the
operating voltage at the generator terminal exceeds the
standard generator manufacturer design of +/-5% and is
more onerous than the previous standard. If this is the
intent then TCE requests that the AESO undertake a
more fulsome consultation with industry as to why this
requirement must be changed.
TCE is concerned with the language in requirements
10(3) and 10(4) as it is not possible for the legal owner
of a generating facility to ensure that a generating unit
does not trip or go off-line under the conditions listed in
subsection 10(3) or that its protection functions, critical
devices or critical motors will behave as described in
subsection 10(4). The legal owner of a generating
facility can merely confirm that a generating unit has
been designed to behave in certain way and that the
models support these assumptions. The requirements
should be amended to reflect this difference in
responsibility.
Subsections 10(3)(a)(i) and 10(5)(b) refer to the normal
clearing time for a three phase fault, however, the rule
does not define what that is. TCE submits that the
requirements should explicitly state the normal clearing
Issued for Stakeholder Consultation: 2011-12-06
Page 10
(3) Subject to subsection 10(2), the legal owner
of an existing generating unit with a maximum
authorized real power value equal to or greater
than nine (9) MW must confirm that the
generating unit is designed such that it does not
trip or go off-line for a transmission system
disturbance at….
(4) The legal owner of an existing generating
unit must confirm that the generating unit was
designed such that the following does not
occur…
time should not exceed nine cycles as this is consistent
with the NERC Reliability Standard PRC-024.
Alternatively these clearing times could be specified in
the functional specification of a generating unit.
Subsection 11 – Automatic Voltage Regulator
Subsection 10(5) refers to the specific location of the
generating unit. TCE submits that the requirement
should indicate whether this is at the point of
connection, the generator terminals or some other point.
Comment # 15: Insert Comments / Reason for Position
(if any)
Subsection 11 sets out the requirements for the automatic voltage regulator and
the basic approach has been carried over from the existing Technical Standard.
Subsection 12 – Frequency and Speed Governing Requirements
Subsection 12 sets out the requirements for the governor systems and the basic
approach has been carried over from the existing Technical Standard, with the
one exception noted below.
Subsection 12(4) contains the following:
“If the frequency of the generating unit while connected to the transmission
system remains greater than sixty one point seven (61.7) Hz or less than fiftyseven (57) Hz for more than ten (10) minutes, then the generating unit must be
immediately removed from service.”
Comment # 16: Insert Comments / Reason for Position
(if any)
As mentioned previously, this rule should not place
requirements or obligations on the legal owners of
generating units that pertain to the operation of a facility
rather should only specify the design specifications. As
such, subsection 12(3) should be reworded for clarity.
TCE proposes the following wording.
The AESO has discussed this requirement in work group sessions with
generating unit owners and a consensus was reached that this is appropriate to
include this in proposed New ISO Rules Section 502.5. It was, however,
recommended that the AESO seek broader input in particular from distribution
facility owners, industrial system owners, etc.
Subsection 13 – Power System Stabilizer
Comment # 17: Insert Comments / Reason for Position
(if any)
Subsection 13 sets out the requirements to install power system stabilizers and
has been amended to add requirements that had previously existed in WECC
policies, which the AESO has currently been enforcing.
Issued for Stakeholder Consultation: 2011-12-06
Page 11
(3) The generating unit must be designed such
that if the frequency of the generating unit while
connected to the transmission system remains
greater than sixty one point seven (61.7) Hz or
less than fifty seven (57) Hz for more than ten
(10) minutes, then the generating unit will be
immediately removed from service.
Subsection 14 – Transmission System Step-Up Transformer
Comment # 18: Insert Comments / Reason for Position
(if any)
Subsection 14 sets out the requirements for the step-up transformer and the basic
approach has been carried over from the existing Technical Standard.
Section 15 – Auxiliary Systems
Subsection 15 sets out the requirements for the critical auxiliary system to meet
minimum standards so that multiple units will not go off line for single point of
failure and that these auxiliaries must be considered when studying the voltage
ride capability of the facility.
The AESO has experienced issues with facilities where the generating unit may
have been able to ride through disturbances but the critical auxiliary system
caused the generating unit to trip or go offline. As well, Alberta Reliability
Standard TPL-002-AB-0 System Performance Following Loss of a Single BES
Element does not allow for cascading for the loss of a single bulk electric system
element.
Subsection 16 – Generating Unit Disconnection and Interrupting Devices
Comment # 19: Insert Comments / Reason for Position
(if any)
The term “modification” is used in subsection 15(1) and
is not defined. TCE submits that the AESO should only
consider physical modifications to a generating unit that
increases the output of that facility by greater than 10%
of maximum authorized real power to trigger a change
in requirements.
TCE also requests that the AESO confirm that section
12 does not require that co-generation units be capable
of preventing the loss of a steam turbine in the event a
combustion turbine trips.
Comment # 20: Insert Comments / Reason for Position
(if any)
Subsection 16 sets out the requirements for the generating unit breakers and the
basic approach has been carried over from the existing Technical Standard.
Subsection 17 – Isolating Devices
Comment # 21: Insert Comments / Reason for Position
(if any)
Subsection 17 sets out the requirements for the generating unit disconnect
switch(es) and the basic approach has been carried over from the existing
Technical Standard.
Subsection 18 – Power Quality
Subsections 18(6) and (7) amends and clarifies the requirements for generating
units to not introduce excessive voltage unbalances on to the transmission
system and how they are calculated.
The previous requirement in the existing Technical Standard was to related
voltage unbalance at distribution voltages. This new requirement is more
appropriate for transmission systems.
Issued for Stakeholder Consultation: 2011-12-06
Comment # 22: Insert Comments / Reason for Position
(if any)
Section 18 should be reworded to add clarity that the
requirements pertain to the design of the generating unit
not the operation of the generating unit as those
requirements should be or are already contained in
some other AESO rule or reliability standard.
Page 12
Subsection 19 – Grounding
Comment # 23: Insert Comments / Reason for Position
(if any)
Subsection 19 sets out the requirements for the generating unit grounding and the
basic approach has been carried over from the existing Technical Standard.
Subsection 20 – Lightning and Other Surge Protection
Comment # 24: Insert Comments / Reason for Position
(if any)
Subsection 20 sets out the requirements for the generating unit surge protection
and the basic approach has been carried over from the existing Technical
Standard.
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.
Issued for Stakeholder Consultation: 2011-12-06
Comment # 25: Insert Comments / Reason for Position
(if any)
It is not clear to TCE why the AESO is placing an
additional requirement on new or modified existing
generating units to install Phasor Measurement units.
The AESO has not consulted with industry as to why
this should be a requirement. TCE requests further
consultation on this matter.
Subsection 21(3)(a) requires that a generating unit
comply with the requirements set out in the AESO
Requirements for Phasor Measurement Units
document. As a general principle TCE does not support
the notion that the AESO can place requirements to
comply with other authoritative documents within its
rules.
Page 13
Subsection 22 – Internal Sequence of Event Monitoring
Comment # 26: Insert Comments / Reason for Position
(if any)
Subsection 22 adds additional requirements regarding what must be monitored
within the generating unit. The additional requirements only apply to new or
modified generating units.
In the AESO’s opinion, in order to properly analyze the root cause of some
system disturbances, greater detail is required from generating units in regards to
their behaviour during these disturbances.
Subsection 23 – Provision of Data and Modeling Information
Subsection 23 deals with the provision of data for both new and modified
generating units.
This section was added so that the AESO can ensure it has the information
required to properly model the behaviour of the generating unit in relation to the
transmission, and to confirm that the generating unit is in compliance with
sections of proposed New ISO Rules Section 502.5.
Subsection 24 – Testing Intervals
Comment # 27: Insert Comments / Reason for Position
(if any)
TCE notes that sections 23 through 28 require the legal
owner of a generating unit to undergo testing and to
report the results of the testing to the AESO during what
appears to be the commissioning phase or the period
immediately following the commissioning of a
generating unit. It is unclear to TCE if all of these
requirements belong in the Generating Unit Technical
Requirements Rule or if there is the potential for overlap
with other ISO Rules such as OPP 603, 604 and 605
and the MOD Reliability Standards.
Comment # 28: Insert Comments / Reason for Position
(if any)
Subsection 24 sets out requirements to provide a model validation or reactive
power verification report in terms of both format and timing.
Subsection 25 – Reporting
Comment # 29: Insert Comments / Reason for Position
(if any)
Subsection 25 sets out requirements to provide a model validation or reactive
power verification report in terms of both format and timing.
This subsection was added to clarify the reporting requirements to the market
participants.
Issued for Stakeholder Consultation: 2011-12-06
Page 14
Subsection 26 – Baseline Testing
Comment # 30: Insert Comments / Reason for Position
(if any)
Subsection 26 sets out the requirements for the generating unit baseline testing
and the basic approach has been carried over from the existing Technical
Standard.
Subsection 27 – Reactive Power Verification and Re-verification Testing
Comment # 31: Insert Comments / Reason for Position
(if any)
Subsection 27 sets out the requirements to test that the reactive power
requirements of proposed New ISO Rules Section 502.5 have been met.
Reactive power verification has been an existing WECC policy that the AESO has
been enforcing. This subsection has been added to clarify the testing
requirements to the participants.
Subsection 28 – Model Revalidation Testing
Comment # 32: Insert Comments / Reason for Position
(if any)
Subsection 28 sets out the requirements for the generating unit model
revalidation testing and the basic approach has been carried over from the
existing Technical Standard.
The following reference sections in the existing Technical Standard that have not
been included in proposed New ISO Rules Section 502.5:
Comment # 33: Insert Comments / Reason for Position
(if any)
Section 1.1 – Purpose
This section was removed to align with the principals of the TOAD project.
Section 1.3 – Definitions
This section was removed to align with the principals of the TOAD project.
Section 1.4 – Modifications
This section was removed to align with the principals of the TOAD project.
Section 1.5 – Requirement For Review
Issued for Stakeholder Consultation: 2011-12-06
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This section was removed to align with the principals of the TOAD project.
Section 1.6 – Document Change History
This section was removed to align with the principals of the TOAD project.
Section 2.5 – Clearance and Access
This section was removed as it referenced codes that do not fall under the
jurisdiction of the AESO.
Section 4.0 – Load Interconnection Requirements
Proposed New ISO Rules Section 502.5 does not include the requirements for
load facilities. These facilities will be the subject of separate ISO rules and be
consulted on separately as the requirements for generating facilities and load
facilities are significantly different.
(b) Removals
No removal of ISO rules provisions are being proposed for proposed New ISO
Rules Section 502.5.
Comment # 34: Insert Comments / Reason for Position
(if any)
(c) Amendment
No amendments to ISO rules provision are being proposed for proposed New ISO
Rules Section 502.5.
Comment # 35: Insert Comments / Reason for Position
(if any)
(d) Other
(Stakeholders wishing to comment on specific provisions are requested to copy
the provision into this area and provide comments)
Comment # 36: Insert Comments / Reason for Position
(if any)
Issued for Stakeholder Consultation: 2011-12-06
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