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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: 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 Page 15 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 Page 16