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Stakeholder Comment & AESO Replies Matrix Alberta Reliability Standard VAR-001-AB-1a Voltage and Reactive Control November 9, 2012 Date of Request for Comment: 2010-06-11 Stakeholder Consultation Period: 2010-06-11 to 2010-07-09 Definitions – New “aggregated generating facilities” means an aggregation of generating units, including any reactive power resources, which are: (i) designated by the ISO; and (ii) situated in the same proximate location at one or more point of connections. (Note: This definition has been added to the AESO Consolidated Authoritative Document Glossary.) Stakeholder Stakeholder Comment AESO Replies Suncor Energy Inc. Support Support with language suggestions Oppose The AESO appreciates Suncor’s support. This definition has been added to the AESO’s Consolidated Authoritative Document Glossary Definitions – New (cont’) “voltage regulating system” means the equipment that automatically controls the reactive power resources to regulate the voltage level at any collector bus. (Note: The AESO intends to consult on a number of ISO Rules definitions that it considers to be necessary in the Alberta reliability standards, including “voltage regulating system” which will be completed prior to the VAR standards being effective.) Stakeholder Stakeholder Comment AESO Replies TransAlta Comment 1: Reply 1: The AESO agrees with TransAlta that defined The text in the drafted standards and terms should be reflected in bold font and has comment matrix does not show defined reviewed, updated and bolded all defined terms terms in bold and this makes it somewhat in Final Proposed VAR-001-AB-1a. difficult to fully interpret the intention of the AESO in using particular language. Page 1 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Definitions – Removals There are no definition removals being proposed Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies Comment 2: See comments in R1 and R2 below Definitions – Amendments Reply 2: Please see AESO Replies 5 and 9 below. Stakeholder Comment Support Support with language suggestions Oppose Comment 3: See comments in R1 and R2 below Support Support with language suggestions Oppose Comment 4: Applicability: TransAlta believes this standard should only be applicable to TFO’s who operates the transmission systems and provides transmission services in its area (the term of Transmission Operator under the NERC registration criteria. ‘) and not generators that are registered as a TFO’s by AESO because of their generation interconnection facilities. TransAlta requests AESO to re- AESO Replies There are no definition amendments being proposed Stakeholder Suncor Energy Inc. TransAlta Page 2 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 3: Please see AESO Replies 5 and 9 below. Reply 4: The AESO agrees with TransAlta and has modified the applicability section in Final Proposed VAR-001-AB-1a to include the following: “This reliability standard does not apply to the operator of a transmission facility whose transmission facility: - is a radial connection; and - has no controllable reactive power resources.” examine the applicability section of this standard or provide clarity as to how a generator registered as a TFO could comply The definition of a generating unit includes the portion of the switch yard associated with the generating unit. Accordingly, this Final Proposed VAR-001-AB-1a is not applicable to such facilities. Alberta Reliability Standard – Requirements The provisions within the proposed Alberta Reliability Standard VAR-001-AB-1a: Voltage and Reactive Control, are derived from NERC VAR-001-1a with suitable revisions for the responsible entities within Alberta. R1 The ISO must make rules for monitoring and controlling voltage levels and MVar flows within the transmission system, including consulting with TFOs and transmission operators adjacent to Alberta as appropriate in the development of such ISO rules. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies Comment 5: Support keeping rules in existing applicable OPPs Reply 5: The AESO is transitioning all ISO OPPs into the ISO rules. The AESO will complete this transition in a manner that reduces duplication and overlaps between Alberta reliability standards and the ISO rules. Upon doing a complete review of the following Reliability Standard, Suncor has noted that the ISO already has OPPs that address the monitoring and controlling of voltage levels and therefore has satisfied WECC and NERC requirements. Suncor is recommending that the AESO consider keeping the original OPPs in place and modifying them as required, and / or review the duplication of standards. Alberta Reliability Standard – Requirements R2. The ISO and each TFO must develop, maintain, and implement procedures, for monitoring and controlling voltage levels and MVar flows within the transmission system, including consulting with each other, neighbouring TFOs and, as appropriate, transmission operators adjacent to Alberta. Page 3 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Stakeholder EPCOR Distribution & Transmission Inc. Stakeholder Comment AESO Replies Support Support with language suggestions Oppose Comment 6: Smaller TFOs, such as EDTI, do not have the ability to actively control voltage levels and MVar flows without the direction of the ISO. EDTI believes that this requirement should be reworded to separate smaller TFOs without this capability from those with it, or alternatively to eliminate this requirement from TFOs without this capability entirely. Reply 6: The AESO disagrees with EDTI’s comments. Any entity, regardless of size or scope of interconnection, having limited or no ability to control voltage levels and reactive power (MVar) flows, is still capable of meeting this requirement by developing, maintaining, and implementing procedures for monitoring and controlling voltage levels and reactive power (MVar) flows and then consulting on those procedures. The above procedures promote reliable transmission system operation. Accordingly, no changes have been made to Final Proposed VAR-001-AB-1a. Nexen Inc. Support Support with language suggestions Oppose Comment 7: Nexen submits that the requirement to have a TFO develop procedures for monitoring the voltage levels and MVar flows and communicating with other transmission operators may be more applicable to those participants that truly provide transmission service to large group Page 4 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 7: Please see AESO Replies 4 5 above. In addition, the AESO has amended Final Proposed VAR-001-AB-1a to provide clarity around previous references to transmission facility owners. The AESO is now specifying legal owner or operator as applicable. of customers over a wide geographic area. Suggesting other participants, due to the overly generic TFO definition employed by the AESO, must now develop procedures and be capable of performing the duties traditionally performed by a system operator and traditional transmission operator is highly onerous and unreasonable. The AESO along with Alberta’s traditional TFO’s have access to all of the necessary information and procedures to effectively manage voltage and MVar flows on the Alberta Interconnected Electric System (AIES). The AESO and TFO’s size and ability to act on an aggregate basis will also have a much greater and more crucial impact on successfully managing an AIES event than a single market participant. Nexen submits that this requirement inappropriately places accountabilities and risks on market participants (i.e. ISD’s or GFO’s) due to the broad definition for TFO’s currently employed by the AESO. Nexen sees no reason that a market participant should be responsible or be at risk for actions and procedures which are essentially and more effectively managed by the AESO or TFO providing service in the area. Comment 8: Nexen submits the AESO must propose entity definitions that differentiate between Page 5 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 8: Please see AESO Replies and Reply 6 above. Suncor Energy Inc. two distinct types of entities. For instance entity registration and requirement applicability could be split between: a) a “non-traditional” transmission facility owner who may own a limited amount of transmission facilities as defined in EUA, but only owns those facilities to facilitate their interconnection and their on-site requirements and have a very limited impact on the reliability of the AIES; versus b) a traditional transmission facility owner and operator which owns many transmission facilities, over a broad geographic area, provides transmission service to a large number of customers and has a significant impact on the reliability of the AIES. Support Support with language suggestions Oppose Comment 9: Please verify the applicability of these standards to Industrial System Designations who have one point of interconnection to the Transmission grid and have aggregated load and generation facilities that operates behind the point of interconnection. Reply 9: The AESO confirms that industrial system designations that operate transmission facilities are included, unless covered by the exemption in the applicability section. Market participants may apply for an applicability assessment under the AESO’s compliance monitoring program. However, such assessment will not exempt any market participant from its obligation under section 20.8 in the Electric Utilities Act to comply with Alberta reliability standards. Please also see AESO Replies 4 and 6 above. Page 6 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 TransAlta Imperial Oil Resources Support Support with language suggestions Oppose Comment 10: Applicability: TransAlta believes this standard should only be applicable to TFO’s who operates the transmission systems and provides transmission services in its area (the term of Transmission Operator under the NERC registration criteria. ‘) and not generators that are registered as a TFO’s by AESO because of their generation interconnection facilities. TransAlta requests AESO to reexamine the applicability section of this standard or provide clarity as to how a generator registered as a TFO could comply Comment 11: It is the view of IORL, that as an ISD owner, we do not have nor should we have the ability 'for monitoring or controlling the TFO voltage levels and MVar flows within the transmission system' or 'know the status of all reactive resources within its services area'. IORL, as a generator, only has the ability to increase/decrease MVar output based on specific direction from the AESO. Consequently, IORL is not in a position to meet the requirement. Alberta Reliability Standard – Requirements Reply 10: Please see AESO Reply 4 above. Reply 11: Please see AESO Reply 9 above. R3 The ISO must operate with sufficient reactive power resources available within Alberta to protect the voltage levels of the transmission system Page 7 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 under normal and contingency conditions. This includes, without limitation, consideration of the transmission system share of the reactive requirements of interconnections. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies The AESO appreciates Suncor’s support. Alberta Reliability Standard – Requirements R4 The ISO may establish and publish criteria on its website that exempts generating units from compliance with any or all of the directives in requirements R5 and R6.3. R4.1 The ISO must maintain a list of generating units and wind aggregated generating facilities in Alberta that are exempt from following voltage level directives or reactive power requirements in the ISO rules. R4.2. The ISO must inform each GFO when its generating unit(s) is included on the list referred to in requirement R4.1. Stakeholder Suncor Energy Inc. TransAlta Stakeholder Comment Support Support with language suggestions Oppose AESO Replies The AESO appreciates Suncor’s support. Support Support with language suggestions Oppose Comment 12: We think the "may" should be replaced by "must". Transparency and clarity are required for the rationale of any exempted units. Reply 12: The AESO agrees with TransAlta’s comment and has amended requirement R4 in Final Proposed VAR-001-AB-1a. Alberta Reliability Standard – Requirements R5. The ISO must issue directives to the operator of a generating unit that specify the following: a) voltage level on the high voltage side of the transformer at the point of connection between each generating unit and the TFO’s facilities; or Page 8 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 b) the reactive power to be achieved by the generating unit. Stakeholder Nexen Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies Comment 13: As noted in the comments provided above in Requirement No.2 and No. 7 below, Nexen submits the definition for TFO is too broad creating confusion and may conflict with the efficient operation of certain facilities. Reply 13: Please see Replies 4, 7 and 9 above. Legislation notes that consideration must be given to energy produced and consumed onsite, especially within an industrial system. Depending upon the configuration of that industrial system and where the generation is located, directions from the AESO (on power flow or voltage levels to facilities deep with an industrial process – beyond the point of interconnection) could have a serious impact on the operation of that industrial process. Nexen submits entity definitions must take into consideration legislative considerations along with the unique interconnection and operational characteristics of its market participants to ensure equitable treatment and to reduce unreasonable amounts of interference on a participant’s facilities or operations. Page 9 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Please also refer to Alberta requirement R5 that has been amended in Final Proposed VAR-001AB-1a to also include reference to the point of connection between the transmission system and the industrial complex for voltage level adjustments. Suncor Energy Inc. TransAlta Support Support with language suggestions Oppose Comment 14: See comment in R2: Clarification required on applicability to ISDs Support Support with language suggestions Oppose Comment 15: In R4. a) in our opinion “the high voltage side of the transformer at the point of connection” is not appropriate based on the following considerations: It should be the generator terminals for synchronous generators or the LV side of system stepup transformer for the wind power facilities. Our rationale is as follows: The wording suggested in R4.a) does not match the wording in the section 3.2 of OPP 702. The section 3.2 of OPP 702 states that ”….(the “interface” is the generator terminals for synchronous generators and low voltage side of the system step-up transformer for wind power facilities.” To adjust system voltages the SC will direct GFOs to raise or lower their voltage by a specific amount using either the generator transformer OLTC (On-Load Tap Changer) or adjusting the generator interface voltage.” Reply 14: Please see AESO Replies 9 and 13 above. Reply 15: The AESO disagrees with TransAlta’s interpretation regarding directing voltage levels at the interface as described in ISO OPP 702. ISO OPP 702 merely states that adjusting the interface voltage will indirectly result in adjustments to the system voltages. Further, the AESO letter of notice dated June 11, 2010, provided stakeholders with information regarding the removal of ISO OPP 702. In that letter of notice, the AESO provided the rationale for the removal of ISO OPP 702, the linkage to the VAR standards consultation and a forthcoming information document. Please also see amended Alberta requirement R5 in Final Proposed VAR-001-AB-1a. Alberta Reliability Standard – Requirements R6. The ISO must know the status of all transmission reactive power resources, voltage regulators and power system stabilizers. Page 10 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Stakeholder Suncor Energy Inc. Stakeholder Comment AESO Replies Support Support with language suggestions Oppose Reply 16: Comment 16: Please see AESO Reply 9 above. See comment in R2: Clarification required on applicability to ISDs Alberta Reliability Standard – Requirements R7 Each TFO must know the status of all transmission reactive power resources, voltage regulators and power system stabilizers within its service area. Stakeholder EPCOR Distribution & Transmission Inc. Nexen Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies Comment 17: EDTI notes that the measure for this requirement refers to R6.1 which does not exist in the Alberta version of VAR-001-AB1a. Reply 17: The AESO agrees with EDTI and corrected the measure to refer to Alberta requirement R7 in Final Proposed VAR-001-AB-1a. MR7 should refer to R7 not R6.1. Support Support with language suggestions Oppose Comment 18: Similar to the requirements outlined in Requirement No.2 above, the broad definition for TFO employed by the AESO inappropriately captures and imposes obligations on those market participants Page 11 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 18: Please see AESO Replies 4 and 6 above. In addition, the AESO agrees with Nexen that the use of “service area” within this requirement is not appropriate and has amended this term in that this requirement was not really meant for. Market participants with limited transmission ownership do not have a “service area”. The definition of “service area” (as provided in the Hydro and Electric Energy Act) and some of the subsequent definitions provided in the Electric Utilities Act demonstrate how the current definition of TFO being employed by the AESO is flawed and creates an inconsistency between legislative definitions versus the intent of the Alberta Reliability Standards. “service area” means the area in which an electric distribution system may distribute electric energy; “electric distribution system” means the plant, works, equipment, systems necessary to distribute electricity in a service area, but does not include a generating unit or a transmission facility; Individual customers (including generators) do not have a service area in which they distribute electricity. Industrial System Designation (ISD’s) sites, while they may distribute electricity, do so solely on their own property for their own operational needs and not to provide service to other customers over a large geographic area. The current definition of TFO employed by the AESO is too broad. It creates a situation where a number of market Page 12 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Alberta requirement R7 in Final Proposed VAR001-AB-1a. participants now may face compliance obligations, implementation costs and risks that are a result of a definition being applied generically across all market participants. The definition of TFO must be further refined and must delineate which reliability obligations should reasonably belong to the appropriate entity so market participants have some certainty and control in being able to mange their risk and compliance obligations. Suncor Energy Inc. TransAlta As noted in Requirement No. 2 above, Nexen submits the AESO must devise a set of definitions and entities to effectively account for the different entities that operate in the province of Alberta. Support Support with language suggestions Oppose Comment 19: See comment in R2: Clarification required on applicability to ISDs Support Support with language suggestions Oppose Comment 20: Applicability: TransAlta believes this standard should only be applicable to TFO’s who operates the transmission systems and provides the transmission services in its area (the term of TOP ‘s in the states) and not generators that are registered as a TFO’s by AESO because of Page 13 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 19: Please see AESO Reply 9 above. Reply 20: Please see AESO Reply 4 above. their interconnection facilities. TransAlta requests AESO to re-examine the applicability section of this standard or provide Imperial Oil Resources Comment 21: It is the view of IORL, that as an ISD owner, we do not have nor should we have the ability 'for monitoring or controlling the TFO voltage levels and MVar flows within the transmission system' or 'know the status of all reactive resources within its services area'. IORL, as a generator, only has the ability to increase/decrease MVar output based on specific direction from the AESO. Consequently, IORL is not in a position to meet the requirement. Comment 21: Please see AESO Replies 4 and 9 above. Alberta Reliability Standard – Requirements R8 The ISO, when notified by an operator of a generating unit of the loss of automatic voltage regulator control or by an operator of an aggregated generating facility of the loss of voltage regulating system control, must issue a directive to the operator to maintain or change either its voltage or reactive power. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies The AESO appreciates Suncor’s support. Alberta Reliability Standard – Requirements R9 The ISO must, when it determines it is necessary, regulate transmission voltage and reactive power flow by issuing directives to TFOs to operate the devices necessary to do so. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Page 14 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 AESO Replies Support with language suggestions Oppose Comment 22: Reply 22: See comment in R2: Clarification required Please see AESO Reply 9 above. on applicability to ISDs. Alberta Reliability Standard – Requirements R10 The ISO must maintain system operating limits by issuing directives to TFOs and operators of generating units for the operation of capacitive and inductive reactive power resources with respect to, without limitation, the following: reactive power generation voltage transmission line switching reactive power resource switching, load shedding Stakeholder Stakeholder Comment AESO Replies Suncor Energy Inc. Support Support with language suggestions Oppose Reply 23: Comment 23: Please see AESO Reply 9 above. See comment in R2: Clarification required on applicability to ISDs. Alberta Reliability Standard – Requirements R11 The ISO must make arrangements such that there are sufficient reactive power resources to support voltage under first contingency conditions. R11.1 The ISO must make arrangements such that reactive power resources are available in locations within Alberta such that the resources can be applied effectively and as soon as practical when a contingency occurs pursuant to R12. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies The AESO appreciates Suncor’s support. Alberta Reliability Standard – Requirements R12 The ISO must take action to restore system operation within interconnection reliability operating limits or system operating limits established by Page 15 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 the ISO in the event of a violation resulting from reactive power resource deficiencies. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose AESO Replies The AESO appreciates Suncor’s support. Alberta Reliability Standard – Requirements R13 The ISO must, after reviewing with the GFO regarding necessary step-up transformer off-load tap changes, provide documentation to the GFO specifying the required tap changes, a timeframe for making the changes, and technical justification for these changes. Stakeholder Stakeholder Comment AESO Replies Suncor Energy Inc. Support Support with language suggestions Oppose Reply 24: Comment 24: Please see AESO Reply 9 above. See comment in R2: Clarification required on applicability to ISDs Alberta Reliability Standard – Requirements R14 The ISO must issue directives necessary to prevent voltage collapse in the event of reactive power resource deficiencies including without limitation to reduce load. Stakeholder Stakeholder Comment AESO Replies Suncor Energy Inc. Support The AESO appreciates Suncor’s support. Support with language suggestions Oppose Alberta Reliability Standard – Removal of NERC Requirements An Alberta variance is a change from the NERC Reliability Standard that the AESO has determined is material. Specifically, the following provisions are deemed as Alberta variances and have been removed from the existing NERC VAR-001-1a requirements. NERC requirement R5 requires the Purchase-Selling Entity to arrange for reactive resources to satisfy the reactive requirements identified by its Transmission Service Provider. This requirement was deleted as the ISO ensures the reactive power requirements are met in Alberta. Stakeholder Stakeholder Comment AESO Replies Alberta Reliability Standard – Amendments of NERC Requirements Page 16 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 The following revisions have been made throughout this proposed reliability standard: - Identified the responsible entities in Alberta. - Applied a consistent writing style and added clarity. - Changed passive terms such as “shall” to “must”. - Developed measures specific to the requirements. Stakeholder Suncor Energy Inc. Stakeholder Suncor Energy Inc. Stakeholder Comment Support Support with language suggestions Oppose Comment 25: Upon doing a complete review of the following Reliability Standard, Suncor has noted that the ISO already has OPPs that address the monitoring and controlling of voltage levels and therefore has satisfied WECC and NERC requirements. Suncor is recommending that the AESO consider keeping the original OPPs in place and modifying them as required, and / or review the duplication of standards. General Comments Stakeholder Comment Comment 26: As discussed with members of the ARS User Group, we understand that there have been some changes made to these standards since initial review by the ARS Working Group and Committee. We are therefore requesting that these changes be reviewed once again by the ARS Committees to understand the changes. Additionally, as reflected in our comments, as more Alberta reliability standards are Page 17 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 AESO Replies Reply 25: Please see AESO Reply 5 above. AESO Replies Reply 26: The AESO agrees with Suncor that there have been changes to the standard since being reviewed by the ARC workgroups. The AESO gathers information from the workgroup and combines this with internal AESO feedback to prepare a draft of the Alberta reliability standard that goes out for broad stakeholder consultation. This is in accordance with the reliability standard development process which allow for all stakeholders to provide their comments. TransAlta being released it is becoming more necessary to identify which sub requirements and measures of the standards apply to ISDs. Suncor has raised this point as an ARS Committee member and the requirements being prescribed in new standards need to be tested for ISD applicability. With respect to applicability of the reliability standards to industrial system designated complexes please see AESO Reply 9 above. Comment 27: In reviewing VAR-001-AB-1a, VAR-002AB-1.1b it appears that a number of changes have been made to the standards since the last time they were reviewed and approved by the working group and the ARC. Reply 27: Please see AESO Reply 26 above. Comment 28: It appears that a number of the changes are a result of the AESO's proposed removal of OPP 702 and the incorporation of portions of that OPP into these two standards. As a general observation, it appears that the result of this additional OPP language has resulted in standard that is much more specific and far reaching than the NERC version of the standard. Reply 28: The AESO disagrees with TransAlta’s observation. The amendments made to Final Proposed VAR-001-AB-1a were done in accordance with the Transmission Regulation. The requirements specified in the NERC reliability standard correlate with the requirements specified in Final Proposed VAR001-AB-1a, except in a few cases as explained in the Alberta variances. Comment 29: TransAlta's position is that these standards should not be approved until such a time as the AESO can provide a complete package that would show how OPP 702 is to be mapped into any of the VAR Standards and the ISO rules, which portions of the OPP are to be retired, and the draft of the Reply 29: Please see AESO Reply 28 above. Page 18 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 With the exception of one requirement relating to changing automatic voltage regulator set points, the appropriate authoritative content of ISO OPP 702 represented in the VAR reliability standards. The AESO will address changing set points in Information Document dealing with Voltage Control. This is especially critical when the AESO proposes to eliminate an entire document, such as OPP 702. proposed new ISO rules Section 304 Maintaining Network Voltage. The AESO proposes to remove ISO OPP 702 in its entirety when the VAR standards come into effect. Nonauthoritative content of OPP 702 that provides useful information for market participants will be captured in an information document. Comment 30: TransAlta needs to better understand where and how some of the key elements of OPP 702 (17 Feb 2010) will be treated going forward when implementing standard VAR-002-AB-1, Reply 30: The AESO has addressed this matter in the proposed VAR-002-AB-1.1b Stakeholder Comment & AESO Replies Matrix. Some excerpts from OPP-702 Section 3.2 are below: Generators must be capable of operating continuously in automatic voltage regulation mode between the generating unit’s lagging and leading reactive power obligations. Generator automatic voltage regulators must be capable of maintaining voltage at the generator interface as prescribed in the AESO Generation and Load Interconnection Standards.(the “interface” is the generator terminals for synchronous generators and low voltage side of the system step-up transformer for wind power facilities) To adjust system voltages the SC will direct GFOs to raise or lower their voltage by a specific amount using either the generator transformer OLTC (On-Load Tap Changer) or adjusting the generator interface voltage. This action Page 19 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Please also see AESO Reply 29 above. will result in a change in VAr output from the generator. The SC will ensure the desired voltage level is attained. Under normal operating conditions and subject to any operating agreements with the AESO, the SC will direct voltage such that reactive power is within the unit obligation or within 0.9 power factor lagging and 0.95 power factor leading based on gross MW output of generating units. The SC will issue directives for generator voltage adjustments directly to the generator operator. It is preferred that the SC directs generators to adjust their voltage level rather than their VAr output so that confusion about the generator control modes is avoided. Comment 31: The addition of portions of an OPP into Reliability Standards has a number of ramifications that need to be carefully considered. The move from an OPP into a reliability standard means that those sections of the OPP would then be subject to audit. This must be carefully considered from three points of view: 1) Is the OPP worded such that it can be audited against and what are the appropriate measures 2) The additional workload that will result from the need to create an audit trail where one was not previously required. 3) The implications of creating a standard more specific and broader reaching than the NERC standards. Page 20 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 31: The AESO has considered these points. Please see Replies 28 and 29 above. In addition, the AESO will continue to follow the guiding principles in the project charter for Alberta Reliability Standards Implementation. These principles do not consider auditability to be a component of system reliability. Comment 32: At all the applicable places in this standard we recommend that a NERC requirement not be split into a number of AESO subrequirements. We recommend that bullets be used instead to prevent an increase of any penalty coverage, as compared to what was envisaged by NERC. Reply 32: The Alberta reliability standards will contain requirements and sub-requirements that generally align with the NERC standards. Each sub-requirement is to be met. Assignment of penalties for violations is beyond the scope of this initiative and is the Market Surveillance Administrator’s accountability. Comment 33: We understand one of the principles of the TOAD process is to eliminate duplication among authorative documents, however there are additional ramifications when moving into reliability standards that must be considered and we believe it is very important that they are fully vetted at the working group level within the standards development process. For these reasons we believe it is necessary to send both of these standard back to the working group and ARC as part of a complete review of the VAR standards and the associated issues surrounding OPP 702 Reply 33: Please see AESO Replies 5 and 26 above. Supplemental Comment from the ARC Discussion Group (September 2012): ARC Discussion Group Comment 34: Does this reliability standard apply to radial transmission lines connected to a generating unit or an aggregated generating facility with a DVAR connected at the end of a radial transmission line? Page 21 of 22 AESO Replies to Stakeholder Comments: 2012-11-09 Reply 34: Yes, Final Proposed VAR-001-AB-1a applies to the AESO and to an operator of a transmission facility that operates a radial transmission line connected to either a generating unit or an aggregated generating facility. For example, in Alberta requirements R6 and R7 the AESO and each operator of a transmission facility are to monitor the status of automatic voltage regulators, voltage regulating systems and/or power system stabilizers within its service territory. Page 22 of 22 AESO Replies to Stakeholder Comments: 2012-11-09