Download Stakeholder Comment & AESO Replies Matrix

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