Download RE:

November 9, 2012
Dear Market Participants and Interested Parties:
RE:
AESO Reply to Stakeholder Comments on Voltage and Reactive (“VAR”) Reliability
Standard Proposed for Adoption as Alberta Reliability Standard:
a) VAR-002-AB-1.1b Generator Operation for Maintaining Network Voltages (“VAR-002AB-1.1b”); and
b) New Definition for incorporation into AESO Consolidated Authoritative Documents
Glossary.
Section 19 of the Transmission Regulation requires the Alberta Electric System Operator (“AESO”) to consult
with market participants likely to be directly affected by the AESO’s adoption or making of reliability
standards, and also requires the AESO to forward proposed reliability standards to the Alberta Utilities
Commission (“Commission”) for review along with the AESO’s recommendation that the Commission approve
or reject them.
Accordingly, the AESO issued a Stakeholder Consultation Letter on June 11, 2010 providing notice and
seeking comments from market participants on proposed VAR-002-AB-1.1b.
During the AESO’s consultation on proposed VAR-002-AB-1.1b, the North American Electric Reliability
Corporation (“NERC”) Board of Trustees approved NERC standard VAR-002-2b Generator Operation for
Maintaining Network Voltage Schedules replacing NERC VAR-002-1.1b; however the AESO is continuing to
proceed with the consultation of proposed VAR-002-AB-1.1b in order to implement VAR-002-AB-1.1b in
Alberta with the intention of conducting a review of NERC reliability standard VAR-002-2b for adoption in
Alberta at a future date.
The AESO’s reply is set out in the attached AESO Replies document, and a summary of the stakeholder
comments received and the AESO’s reply to these comments is included below.
In addition, the final proposed VAR-002-AB-1.1b (“Final Proposed VAR-002-AB-1.1b”) is attached.
Summary of proposed VAR-002-AB-1.1b
Please see the AESO’s June 11, 2010 Stakeholder Consultation Letter for a summary of proposed VAR-002AB-1.1b.
AESO Reply to Market Participant Comments
The written comments received by the AESO in response to proposed VAR-002-AB-1.1b attached to its June
11, 2010 Stakeholder Consultation Letter and the ARC Discussion Group, and the AESO’s replies to these
comments are summarized below:
1.
Stakeholders were concerned that defined terms were not bolded in proposed VAR-002-AB-1.1b.
In response to these comments, the AESO replied that it agreed that defined terms should be reflected
in bold font and had reviewed and bolded all defined terms in Final Proposed VAR-002-AB-1.1b.
2.
A stakeholder stated that it appeared that a number of changes had been made to proposed VAR-001AB-1a and VAR-002-AB-1.1b since the last time they were reviewed and approved by the working
group and the ARC.
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Public Information
In response to this comment, the AESO replied that it agreed that there had been amendments made to
these standards since being reviewed by the ARC workgroups. The AESO further replied it had
gathered information from the ARC workgroup and combined this with internal AESO feedback to
prepare a draft of the Alberta reliability standard that went out for broad stakeholder consultation, as
was done in this case. This process was in accordance with the Alberta reliability standard development
process. The AESO believed that this process allowed for sufficient opportunity for stakeholders to
provide comments. Furthermore the changes were presented to the ARC Discussion Group and their
comments were considered.
3.
A stakeholder stated that a number of the changes appear to be the result of the AESO's proposed
removal of ISO OPP 702 Voltage Control (“ISO OPP 702”) and the incorporation of portions of that ISO
OPP into this and one other standard, resulting in a more specific and far reaching version than the
NERC version of the standard.
In response to this comment, the AESO replied that it disagrees with this observation and that the
amendments made to Final Proposed VAR-002-AB-1.1b were done in accordance with the
Transmission Regulation. The requirements in the NERC reliability standard correlated with the
requirements in Final Proposed VAR-002-AB-1.1b, except in a few cases as explained in the Alberta
variances.
4.
A stakeholder stated that these standards should not be approved until such a time as the AESO can
provide a complete package that would show how ISO OPP 702 was to be mapped into any of the VAR
Standards and the ISO rules, which portions of the ISO OPP were to be retired, and the draft of the
information document dealing with Voltage Control. This stakeholder also stated that this is especially
critical when the AESO proposes to eliminate an entire document, such as ISO OPP 702.
In response to this comment, the AESO replied that, with the exception of one authoritative provision
relating to changing automatic voltage regulator set points, the authoritative content of ISO OPP 702
was adequately covered by the VAR reliability standards. The AESO proposed to remove ISO OPP 702
in its entirety when the VAR standards come into effect. The AESO would address changing set points
in another appropriate authoritative document currently under development. The non-authoritative
contents of ISO OPP 702 that provides useful information for market participants would be captured in
an information document.
5.
A stakeholder recommended that in all the applicable places in proposed VAR-002-AB-1.1b that a
NERC requirement not be split into a number of AESO sub-requirements and that bullets be used
instead to prevent an increase of any penalty coverage, as compared to what was envisaged by NERC.
In response to this this comment, the AESO replied that the Alberta reliability standards would contain
requirements and sub-requirements that generally aligned with the NERC standards. Each subrequirement was to be met. Assignment of penalties for violations was beyond the scope of this
initiative and is the Market Surveillance Administrator’s accountability.
6.
A stakeholder requested that changes to proposed VAR-002-AB-1.1b be reviewed and vetted by the
ARS Committees.
In response to this comment, the AESO replied that it agreed that there had been amendments to the
standard since being reviewed by the ARC workgroups. The AESO further replied that it gathered
information from the ARC workgroup and combined this with internal AESO feedback to prepare a draft
of the Alberta reliability standard that went out for broad stakeholder consultation, as was done in this
case. This process was in accordance with the Alberta reliability standard development process. The
AESO believed that this process allowed for sufficient opportunity for stakeholders to provide comment.
Furthermore the changes were presented to the ARC Discussion Group and their comments were
considered.
7.
Some stakeholder comments were received about the lack of clarity of how requirements apply to wind
aggregated generating facilities.
In response to these comments, the AESO replied that Final Proposed VAR-002-AB-1.1b applied to all
aggregated generating facilities including wind aggregated generating facilities, except for those that
are identified as exempt.
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8.
A stakeholder had a concern about the increased obligation placed on Alberta market participants to
obtain AESO’s consent to operate without the automatic voltage regulator in service and in voltage
control mode when the NERC version only requires notification.
In response to this comment, the AESO replied that it did not agree that this change is unjustified. The
AESO had made the amendment from “notification” to “consent” for the reliable operation of the Alberta
interconnected electric system, which was also consistent with the AESO’s interconnection
requirements. The Alberta reliability standards would contain requirements and sub-requirements that
generally align with the NERC standards.
9.
A stakeholder asked for verification that the wind farms that are not equipped with voltage regulating
systems (those built prior to applicable standards being in place) can seek an exemption from Alberta
requirement R2.
In response to this comment, the AESO replied that it had amended the applicability section to include
exception criteria and that an information document had been created to identify the wind aggregated
generating facilities that met these criteria.
10.
In reference to Alberta requirement R3, a stakeholder asked for clarification of what was considered “as
soon as practical”.
In response to this comment, the AESO replied that it had amended Alberta requirement R3 to be
completed “as soon as reasonably possible”. In the AESO’s opinion, this provided sufficient clarity.
11.
A stakeholder stated that the AESO currently received information on the operational status of the
automatic voltage regulator or voltage regulating system on a real-time basis, and as such, asked why
there was an additional need to notify the AESO? Were there other parities in which the AESO would
want the market participant to contact? And if so in what form of communication and evidence would be
considered satisfactory by the AESO? The stakeholder recommended that Alberta requirement R3 be
removed from the standard.
In response to this comment, the AESO replied that it disagreed with this assessment. Not all plants
automatically report their automatic voltage regulator status to the AESO on a real-time basis, rather
through other means such as the Energy Trading System. This did not create an additional need to
report status for any generating unit that reported automatic voltage regulator status through SCADA. In
the AESO’s opinion, operator notification was an important step in the non-SCADA processes.
12.
A stakeholder requested Alberta requirement R4.2 (now R6), that addressed not adjusting AVR, VRS or
on-load taps unless instructed by the AESO, be amended to expressly exempt generating units that
were off-line.
In response to this comment, the AESO replied that it agreed that this requirement does not apply to
offline generating units. However, the AESO was not of the opinion that it was necessary to clarify that
off line generating units, or other off line equipment, were exempt from reliability standards.
13.
In reference to Alberta measure MR4.2 (now MR6) a market participant expressed a concern about a
possible gap in data caused by a failure of the logging system that would be indistinguishable from a
gap caused by non-compliance.
In response to this comment, the AESO replied that Alberta measure MR6 had been amended with the
measure now identifying examples of acceptable evidence such as operator logs which could be used
for evidence if the data files are unavailable.
14.
A stakeholder commented that, in Decision 2009-183, issued on June 24, 2010 the Commission
determined that the PPAs were considered enactments and therefore had the force of regulation. As a
result, the AESO could not make ISO rules or standards that were not consistent with the PPA. The
AESO must recognize that the PPAs specified the MVAR limits of the respective generating units and
that these limits were not necessarily those shown on the Generator “D” curve. The AESO must respect
these limits and avoid issuing directives that would cause unnecessary strain on the unit, should these
limits be breached.
In response to this comment, the AESO replied that it disagreed with this assessment. Under normal
system operating conditions, the AESO would not issue directives or instructions that would take the
units beyond the limits of the PPA. However, under abnormal or emergency conditions the AESO would
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issue directives or instructions that were reasonable and appropriate for the circumstances that ensured
the reliable operation of the Alberta interconnected electric system.
15.
A stakeholder expressed that 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 reduce unreasonable amounts of interference on a participant’s
facilities or operations.
In response to this comment, the AESO replied that that market participants may apply for an
applicability assessment under the AESO’s compliance monitoring program; however, such
assessment would not exempt any market participant from its obligation under section 20.8 in the
Electric Utilities Act to comply with Alberta reliability standards.
16.
Stakeholders asked for verification of the applicability of these standards to Industrial Systems.
In response to these comments, the AESO confirmed that Final Proposed VAR-002-AB-1.1b was
applicable to industrial system designated complexes that owned or operated a generating unit, unless
covered by the exemption in the applicability section. Market participants may apply for an applicability
assessment as stated in 15 above.
17.
A number of recommendations were made by stakeholders to revise wording of Alberta requirements
and measures.
In response to these comments, the AESO replied that it had taken these recommendations into
consideration and had amended the Alberta requirements and measures in Final Proposed VAR-002AB-1.1b.
18.
A number of stakeholders disagreed with the use of the term “confirmation” in Alberta measure MR8.
In response to this comment, The AESO replied that Alberta measure MR8 had been replaced with
Alberta measure MR7 in Final Proposed VAR-002-AB-1.1b and that the reference to the term
confirmation had been removed.
19.
A stakeholder suggested that the information referred to in Alberta requirement R8 (now R7) is
generally provided to the AESO as part of the customer interconnection process. This stakeholder also
recommended that the AESO should further review this requirement in relation to the AESO’s existing
interconnection standards and requirements to ensure that there was no duplication of this requirement.
In response to this comment, the AESO replied that it agreed that the AESO’s Customer Connection
Process requires data to be provided to the AESO. While this requirement did not obligate the AESO to
make a request for the data it did create the obligation for the participant to respond to an AESO
request.
20.
Stakeholders suggested that some requirements are specified in other ISO OPPs. It was also
recommended that the AESO consider keeping the original ISO OPPs in place and modifying them as
required, and / or review the duplication of standards.
In response to this comment, the AESO confirmed that Alberta reliability standards would continue to
be recommended to the Commission following consultation with affected stakeholders, while ISO rules,
including ISO OPPs, would continue to be created, amended, consulted on and filed with the
Commission in a manner that reduces duplication and overlaps between reliability standards and ISO
rules. For clarity, Alberta reliability standards would continue to be represented as a separate
authoritative domain from ISO rules and would continue to be drafted in a manner that, as determined
to be applicable and practicable for implementation in Alberta, retained the format and wording
approved by the NERC Board of Trustees. As a result, there may be some occasions where the AESO
determined that it is reasonable and necessary that duplication or overlap occur. Where there were
linkages between reliability standards and other authoritative and non-authoritative documents,
reference would be made to those documents on the AESO website.
21.
A stakeholder stated that only the operator of a generating unit would be able to ensure that the
generating unit was compliant with Alberta requirement R9 (now R8).
In response to this comment, the AESO replied that it disagreed and that it was the AESO’s opinion that
the legal owner of a generating unit or aggregated generating facility was ultimately responsible for
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ensuring that transformer tap positions were changed according to the specifications provided by the
AESO.
22.
A stakeholder commented that by adding an “acceptable explanation” in Alberta measure MR10 that
this added an additional requirement in the measure.
In response to this comment, the AESO replied that it agreed and had revised Alberta measure MR10
(now MR9) in Final Proposed VAR-002-AB-1.1b.
23.
A stakeholder asked what was an appropriate retention period for compliance related documentation
and/or data?
In response to this comment, the AESO replied that it recommended that all stakeholders reference
their own organization’s internal record retention policy with respect to applicable retention periods for
compliance-related documentation. While retention periods for various records may be prescribed by
applicable law, there may also be reasons specific to an organization and its circumstances which
caused it to designate a particular retention period for certain records.
24.
The ARC Discussion Group (ARCDG) stated that a large amount of documentation would be required
to show compliance with Alberta requirement R4.2, which required entities not to adjust their AVR or
VRS set point unless instructed by the AESO. ARCDG members were also concerned about possible
data gaps if computer systems are not recording data 100% of the time and that it is difficult to retain
information for a non-action. ARCDG members were not concerned about the policy and were satisfied
if Alberta requirement R4.2 was captured in an ISO rule instead.
In response to this comment, the AESO replied that it agreed to remove Alberta requirement R4.2 from
Final Proposed VAR-002-AB-1.1b and would relocate this requirement to another authoritative
document. Currently ISO OPP 702 contains a requirement for generation facility owners to “not adjust
their generator voltage without first advising the SC”. The AESO would ensure that this requirement
only appears in one authoritative document.
25.
ARCDG members stated that new Alberta requirement R4(b) (refer to the latest version of this reliability
standard) is not necessary because ISO rules Section 301.2 ISO Directives (“ISO Rules Section 301.2”)
applied and requested the AESO to consider removing Alberta requirement R4(b) from the reliability
standard.
In response to this comment, the AESO replied that it disagreed and had retained new Alberta
requirement R4(b) in Final Proposed VAR-002-AB-1.1b to remain more closely aligned with NERC.
26.
ARCDG members recommended relocating Alberta requirement R5 into Alberta requirement R4.1(c),
and suggested the following wording for R4.1(c): “using an alternative method to control voltage and
reactive power output when the automatic voltage regulator or voltage regulating system is out of
service”.
In response to this comment, the AESO replied that it disagreed and had not relocated Alberta
requirement R5 into Alberta requirement R4.1(c), as Alberta requirement R4 was applicable when the
automatic voltage regulator or the voltage regulating system was in service while Alberta requirement
R5 applied when the automatic voltage regulator or the voltage regulating system was out-of-service
27.
ARCDG members stated that Alberta requirement R6 is not necessary because ISO Rules Section
301.2applied and requested removing Alberta requirement R6 from proposed VAR-002-AB-1.1b.
In response to this comment, the AESO replied that it agreed to remove the thirty (30) minute
requirement specified in Alberta requirement R6 but would retain the rest of the requirement which was
now specified in Alberta requirement R4 in Final Proposed VAR-002-AB-1.1b, to align with NERC.
28.
ARCDG members requested to add to the applicability section the interpretation provided by NERC in
Appendix 2 of VAR-002-1.1b that proposed VAR-002-AB-1.1b did not require generating units to have
an automatic voltage regulator.
In response to this comment, the AESO disagreed was of the opinion that it was not necessary to
include the interpretation provided by NERC in Final Proposed VAR-002-AB-1.1b. The requirement for
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generating units and aggregated generating facilities to have automatic voltage regulators or voltage
regulating systems was covered in other authoritative documents or interconnection standards.
29.
ARCDG members recommended replacing Alberta requirement R7 with the NERC language in NERC
requirement R3 to remove the threshold level in Alberta requirements R7.1 and R7.2 that was used to
identify when a capability change in reactive power as to be reported to the AESO. Support for this
recommendation included the concern of having operators of generating units to be aware this 1%
value (subsequently proposed to the ARC Discussion Group as a 10% value) for each unit and to take
appropriate action accordingly. It would be preferable to adopt a policy for operators to report all
changes in reactive power resource capability or status in accordance with the NERC requirement.
In response to this comment, the AESO replied that it agreed as the AESO had no issue with this
recommendation and had adopted wording in Final Proposed VAR-002-AB-1.1b that was aligned with
NERC requirement R3.
30.
ARCDG members asked why proposed VAR-002-AB-1.1b applied to generating units below the
NERC threshold and requested the reliability reason for doing this.
In response to this comment, the AESO replied that it was applying Final Proposed VAR-002-AB-1.1b
to generating units and aggregated generating facilities directly connected to the transmission system in
order to have these generating resources operate with their automatic voltage regulators and voltage
regulating systems in the automatic voltage control mode. In Alberta, there were in excess of eight
hundred (800) MWs of generating capacity that fall below the NERC threshold. These generating
resources must still provide dynamic reactive capability and be controlled by the automatic voltage
control systems for the reliable operation of the Alberta interconnected electric system. In addition, this
also allowed for the removal of these requirements from ISO OPP 702 which eliminated duplication with
ISO rules.
31.
An ARCDG member requested limiting the application of proposed VAR-002-AB-1.1b to generators 5
MVA and above.
In response to this comment, the AESO replied that it agreed and has amended Final Proposed VAR002-AB-1.1b such that it applied to generating units that have a maximum authorized real power rating
greater than 4.5 MW.
Definitions
The AESO did not receive any comments on the definitions of “aggregated generating facility” and “voltage
regulating system”, which were proposed in the consultation on June 11, 2010. Following the June 11, 2010
consultation, the AESO determined that it was necessary to use these definitions in other Alberta reliability
standards. Therefore, the AESO removed the definitions from the proposed VAR reliability standards
consultation and conducted a separate consultation process. These definitions have subsequently been
finalized and currently reside in the AESO’s Consolidated Authoritative Document Glossary.
Information Document
An Information Document was developed to provide information relevant to Final Proposed VAR-002-AB1.1b. A description of the information document and a link to the same is attached to this Reply Letter.
Additional Changes to the Final Proposed VAR-002-AB-1.1b
The following summarizes additional amendments made to the Final Proposed VAR-002-AB-1.1b as a
result of further AESO Review:
1.
Amended the applicability of Final Proposed VAR-002-AB-1.1b to use the terms adopted through the
AESO’s Transition of Authoritative Documents (“TOAD”) project and applied Final Proposed VAR-002AB-1.1b to generating units and aggregated generating facilities with a real power rating greater than
4.5 MWs;
2.
Amended the effective date to be the first day of the calendar quarter that follows three full calendar
quarters after approval by the Commission;
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3.
Bolded all defined terms ;
4.
Amended Alberta requirement R3 to notify the AESO “as soon as reasonably possible” rather than “as
soon as practical”;
5.
Removed the reference to “confirmation” from Alberta measure MR7;
6.
Amended Alberta requirements R7 and R9 to make it clear that they apply to aggregated generating
facilities;
7.
Removed “acceptable explanation” from Alberta measure MR9;
8.
Removed Alberta requirement R4.2 in the previous version of Final Proposed VAR-002-AB-1.1b in
regards to not adjusting the automatic voltage regulator or voltage regulating system set point unless
instructed by the AESO. This requirement will be transferred to an ISO rule;
9.
Removed the thirty (30) minute requirement in Alberta requirement R4b;
10.
Removed the threshold level in Alberta requirements R6.1 and R6.2 that is used to identify when a
capability change in reactive power is to be reported to the AESO.
Forwarding Final Proposed VAR-002-AB-1.1b to the Commission
Pursuant to section 19 of the Transmission Regulation, the AESO intends to forward Final Proposed VAR002-AB-1.1b to the Commission on November 23, 2012, with the AESO’s recommendation that the
Commission approve Final Proposed VAR-002-AB-1.1b as an Alberta Reliability Standard.
Final Proposed VAR-002-AB-1.1b is proposed to be effective on the first day of the calendar quarter
(January 1, April 1, July 1 or October 1) that follows three full calendar quarters after approval by the
Commission.
Attachments to AESO Reply
1. AESO Replies to the June 11, 2010 Stakeholder Consultation Letter, including stakeholder comments;
2. Blacklined and clean copy of Final Proposed VAR-002-AB-1.1b Generator Operation for Maintaining
Network Voltages; and
3. Copy and description of the draft information document providing information relevant to Final Proposed
VAR-002-AB-1.1b.
Yours sincerely,
Original Signed By
Paul Glatthor
Manager, Authoritative Documents Process
Ph: (403) 539-2464
E-mail: [email protected]
Attachments
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