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Stakeholder Comment and AESO Replies Matrix Recommendation Paper – Proposal for Battery Facility Technical and Operating Requirements October 22, 2013 The AESO is asking market participants and interested parties to participate in the AESO’s consultation regarding the development of sections 502.13 and 502.14 of the ISO rules, which will create technical and operating requirements for battery facilities. The AESO is seeking comments from stakeholders on the associated recommendation paper. Recommendation Paper – Executive Summary and Purpose Do stakeholders have any comments on the Executive Summary and Purpose sections? Stakeholder Stakeholder Comment AESO Replies AltaLink 1. Are there other forms of ES planned to be considered in future? If so, then would it be appropriate to prepare a generic document then prepare technology-dependent documents? 1. The AESO proposes to create requirements for battery facilities, because they have unique technical characteristics and the AESO has received requests to connect them to the transmission system. 2. Suggest changing the term “battery facility” to “Battery-Energy Storage System – BESS” which is more widely recognized. 3. Suggest change AIES to Alberta Transmission System (ATS) since this document does not cover battery solutions connected to distribution networks. Other storage technologies may not require specific technical requirements and, therefore, they may be adequately addressed by existing and proposed ISO rules for generating units and aggregated generating facilities. 2. The AESO has chosen to adopt the term “battery facility”. However, the AESO will consider other suggestions as it AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 1 develops sections 502.13 and 502.14 of the ISO rules. The term “Battery-Energy Storage System” was rejected because its abbreviation (BESS) could be confused with the abbreviation for “bulk electric system” (BES). 3. The AESO agrees. As noted in section 4.4 of the recommendation paper, the proposed technical and operating requirements for battery facilities will only apply to transmission connected battery facilities. Invenergy No comment. Recommendation Paper – Background Do stakeholders have any comments on the Background section? Stakeholder Stakeholder Comment AESO Replies AltaLink 1. Include references to other relevant, recent FERC orders including Order #755 (pay for performance for storage devices offering speed and accuracy of response) and Order #784 (ancillary services) addressing the particular advantages of BESS. 4. The recommendation paper describes the proposed technical and operating requirements for battery facilities. It was not the AESO’s intention to discuss the potential applications for battery facilities, such as ancillary services. 2. Should refer to other BESS applications, e.g., reactive supply, voltage control, peak reduction, reliability enhancement, reduction of GHG, transmission project deferment, etc. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 2 5. See the AESO’s reply 4, above. Invenergy Why does the Recommendation exclude distribution-connected battery facilities considering interconnecting to high voltage systems can be cost prohibitive? 6. Section 4.4 of the recommendation paper explains that the legal owners of electric distribution systems have their own technical and operating requirements for distribution-connected facilities. While the recommendation paper does not address distribution connected battery facilities, they will be allowed. Recommendation Paper – Technical Requirements – Introduction Do stakeholders agree with the introduction to the Technical Requirements section? Stakeholder AltaLink Stakeholder Comment 1. We do not agree with the proposal in the first paragraph of Section 4 that battery facilities have similar connection requirements as synchronous generating units. AESO Replies 7. The AESO agrees that there are differences in the capabilities of generating units and batteries. However, most of those differences will not form i. Batteries dot not have any inertia associated with rotating part of the proposed sections 502.13 and mass. 502.14 of the ISO rules. That is why the first paragraph of section 4 of the ii. BESS can operate in four quadrants. recommendation paper proposes that battery facilities would generally have iii. BESS do not contribute to the short circuit current in case of similar requirements as synchronous faults. The converter will block if the current exceeds the generating units. maximum semi-conductor limit, which means that the maximum output power is limited to the rated power. The purpose of the recommendation iv. BESS cannot provide short overload outputs comparable to a paper is to summarize the issues generator. identified by the AESO during its initial evaluation of battery facilities, including Thus, we suggest rephrasing this statement to alleviate any ambiguity. the necessary deviations from the AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 3 2. Figure 1: i. Figure 1 shows two transformers are used; an inverter transformer and a transmission transformer. This is probably the case for smaller energy storage systems. Larger applications may have only one step-up transformer. It should be optional to have a separate inverter transformer. ii. Also figure 1 does not show other potential control capabilities of BESS – e.g. frequency responsive control. iii. To get the best voltage/power regulation, the measuring point should be on the transmission voltage level. Thus, we suggest indicating that on Figure 1. The main point of measurement is at the point of connection (High Voltage side of the Transmission System Step-Up Transformer). 3. The paper did not discuss any dynamic requirements specific to the BESS. The dynamic performance of batteries and power converters is very different from those of a machine. Step response times, ride-through etc. will be different. requirements for synchronous generating units. Of particular note is the proposal for batteries to operate in all four quadrants. 8. The figures in the recommendation paper are for explanatory purposes only. 9. The AESO does not intend to require battery facilities to have a specific configuration for their connecting facilities (e.g., one inverter and one stepup transformer). The AESO intends to have requirements that can apply to a variety of configurations. 10. Figure 1 of the recommendation paper does include a real power control, which would include frequency responsive controls as discussed in section 4.12 of the recommendation paper. In accordance with existing reliability standards and ISO rules, the AESO does not allow the control of the transmission level voltage by either synchronous generating units or wind aggregated generating facilities. This is done to prevent interactions between adjacent generating facilities. Battery facilities will not be allowed to control the AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 4 transmission level voltage either. 11. Section 4.7 of the recommendation paper proposes that battery facilities will meet the requirements of the NERC reliability standard PRC-024-1 for voltage and frequency ride-through. These are the same requirements that will apply to generation. Step response of real power is discussed in section 4.13 of the recommendation paper. Voltage regulation and reactive power are discussed in sections 4.8 and 4.9 of the recommendation paper. For further information on voltage regulation, the AESO suggests reviewing the ISO rules, section 502.1 Wind Aggregated Generating Facilities Technical Requirements, subsection 7. Invenergy We agree with the language used to refer to batteries as a “source and 12. Thank you for your comment. sink resource.” (pg. 6) Recommendation Paper – Technical Requirements – Source and Sink Resource Do stakeholders agree with the proposal to refer to battery facilities as a “source and sink resource”? Stakeholder AltaLink Stakeholder Comment Prefer designating the devices as a BESS unit with a charging or discharging state vs. source or sink. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 5 Replies 13. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. Invenergy No comment. Recommendation Paper – Technical Requirements – Connection Rule and Operating Rules Do stakeholders agree with the proposal to develop two separate ISO rules, one relating to battery facility technical requirements for connection and another for battery facility operating requirements? Stakeholder AltaLink Stakeholder Comment We agree Replies 14. Thank you for your comment. Invenergy We agree with the requirements. 15. Thank you for your comment. Recommendation Paper – Technical Requirements – Other Rules Do stakeholders have any comments on the need to review and possibly make incidental amendments to some existing sections of the ISO rules? Stakeholder AltaLink Stakeholder Comment We agree Invenergy No comment. Replies 16. Thank you for your comment. Recommendation Paper – Technical Requirements – Applicability and Variances Do stakeholders have any comments on the proposed applicability and variances? Stakeholder AltaLink Stakeholder Comment Suggest to state what minimum transmission voltage level is. Replies 17. Please see section 1(bbb) of the Electric Utilities Act, which provides for minimum voltage levels. Invenergy Is the AESO considering IEEE 1547 compliant systems? 18. No. IEEE 1547 is applicable to small distribution connected facilities. For more information, please refer to the AESO’s AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 6 replies 6 and 17, above. Recommendation Paper – Technical Requirements – Maximum Authorized Real Power Do stakeholders agree with the proposal to make the legal owner responsible for declaring the maximum authorized real power of a battery facility? Stakeholder AltaLink Stakeholder Comment 1. Suggest to use two terms i.e. maximum authorized charging power and maximum authorized discharging power. It is confusing to use one MARP to include both sourcing and sinking capabilities. Replies 19. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. 2. Where will the power be measured? i.e. at the POC, point of connection? And how will it be measured? (ie. peak instantaneous, average?) 20. Energy will be measured in accordance with the AESO’s Measurement System Standard. 3. We suggest Adding a term for maximum charged/discharged ENERGY. Real power will be measured in accordance with the ISO rules, section 502.8 SCADA Technical Requirements. As noted in section 4.3 of the recommendation paper, those rules may need to be reviewed and have incidental amendments in order to accommodate battery facilities. The exact SCADA requirements are typically detailed in the functional specification for the project. In addition, as noted in section 4.16 of the recommendation paper, the AESO proposes that synchrophasor measurement systems are installed at battery facilities. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 7 21. See the AESO’s reply 19, above. Invenergy No comment. Suncor For an aggregated generating facility, it would seem to be reasonable to have the MARP (of the battery) to represent the source capability. As the “MARP” is the measure in which the AESO would be making performance assessments – another value may need to be used to represent the sink capability if sinking is not equivalent to a load in terms of requirements. 22. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. Recommendation Paper – Technical Requirements – Operating Voltage Requirements Do stakeholders have any comments on the proposed operating voltage requirements? Stakeholder AltaLink Stakeholder Comment Refer to comments on Figure 1 in introduction of Section 4. Invenergy No Comment. Replies 23. See the AESO’s replies 9 and 10, above. Recommendation Paper – Technical Requirements – Voltage Ride-Through Requirements Do stakeholders have any comments on the proposed voltage ride-through requirements? Stakeholder AltaLink Stakeholder Comment How about the “blocking “capability in BESS inverters? Is it allowed or not? Blocking means that the converter can block the output completely during for example low voltage, but without tripping the breaker. The DC voltage will be maintained and the deblocking time to normal operation is only tens of milliseconds. This is a major difference to synchronous machines, and it would be good if the paper discusses how this is handled. Shall the converter be able to source current during the entire sequence, or just not trip? AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 8 Replies 24. As with synchronous generating units and wind aggregated generating facilities, the AESO is not specific in how the unit or facility rides through the disturbance. The unit or facility breaker(s) must not be tripped and real power production resumes after the disturbance has been cleared. Invenergy No comment. Recommendation Paper – Technical Requirements – Voltage Regulation Do stakeholders have any comments on the proposed voltage regulation requirements? Stakeholder AltaLink Stakeholder Comment 1. Unacceptable voltage flicker is governed by power quality requirements which are the subject of section 4.14. The last several paragraphs of this section can be moved to this section (or omitted). Note that reference to loads is not made (just WAGFs and synchronous generators) Replies 25. Thank you for your comment. The AESO does not intend to revise the recommendation paper. 26. The AESO does not intend to differentiate between transmission 2. The last paragraph makes references to batteries located within connected facilities and bulk electric WAGFs. Workshop discussions could also include the latest NERC system connected facilities in sections discourse on the definition of BES (bulk electric systems) and the 502.13 and 502.14 of the ISO rules. The multitude of examples provided (including integrated systems). differentiation between transmission connected facilities and bulk electric system connected facilities will be considered in the Alberta Reliability Standards, which are separate from technical rules. Invenergy No comment. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 9 Recommendation Paper – Technical Requirements – Reactive Power Capability Do stakeholders have any comments on the proposed reactive power capability requirements? Stakeholder AltaLink Stakeholder Comment 1. The reactive power capability requirement is a little bit confusing. The figure indicates that the battery storage should work within a range of power factor. But this characteristic will be conflict with the voltage regulation proposed in the Section 4.8, as the voltage regulating ability will be very limited. 2. Figure 3 is a bit unclear. It seems as maximum active and reactive power shall be possible simultaneously, but the figure shows triangles towards zero. This is the opposite of how the PQ diagram is usually drawn, where the PQ capability is a circle or a square (if limited). 3. The figure below shows a vendor-based PQ diagram with a 100 MVA converter, where the reactive power has been limited to +/-50 Mvar (100 MVA base for per-unit system). Replies 27. Section 4.8 of the recommendation paper proposes that battery facilities will have a voltage regulating system that is in-service and controlling voltage whether the facility is operating as a source or a sink. Section 4.9 of the recommendation paper does not state that the voltage regulating system of a battery facility must be operated using power factor control. Rather, it states that battery facilities must have minimum reactive power capability. This is consistent with the requirements for synchronous generating units and wind aggregated generating facilities. 28. To be consistent with the requirements for synchronous generating units and wind aggregated generating facilities, the AESO proposes that battery facilities will be required to provide active and reactive power simultaneously if system conditions require it. Figure 3 in the recommendation paper is not intended to describe the capability of the facility; AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 10 rather, it only describes the minimum reactive power requirements. For further information on reactive power requirements, the AESO suggests reviewing the ISO rules, section 502.1 Wind Aggregated Generating Facilities Technical Requirements, subsection 9. 29. See the AESO’s replies 27 and 28, above. 30. Yes, the requirements will be based on 1.0 per unit voltage as measured at the low voltage side of the transmission system step-up transformer. Comparing this figure to the Figure 3 in the paper, means that the converter must be rated higher than 1 p.u. to be able to provide reactive power output at 1 p.u. active power. The corners with active/reactive power simultaneously will therefore be cost driving. 4. Figure 3 does not mention anything about the voltage (I assume 1.0 p.u.). Full capacitive reactive power output at high continuous system voltage will also make the converter more expensive. Invenergy Further discussion is required. Complying with this proposal may result 31. See the AESO’s replies 27 and 28, in reduction of real power capacity. above. Suncor Can the AESO please provide some description of the reactive power requirement shown as dotted lines in Figure 3 of the document. In the session, this was explained as the inherent capability of the AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 11 32. The triangular sections of Figure 3 in the recommendation paper are the minimum requirements for reactive power for given system which must be offered if it is available. Please provide more details on the use of this range as to whether this range of reactive power would always be used in an automatic voltage control scenario or if the AESO intends to provide a reactive power output setpoint for the battery facility. real power output. Consistent with wind aggregated generating facilities, the reactive capability cannot be withheld if it is inherently available by the battery facility. For further information on reactive power requirements, the AESO suggests reviewing the ISO rules, section 502.1 Wind Aggregated Generating Facilities Technical Requirements, subsections 9, 10 and 11. 33. The AESO does not intend to set the voltage regulation system setpoint. For more information regarding the AESO’s voltage control methods, the AESO suggests reviewing: AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 12 Alberta Reliability Standard VAR001-AB-1a Voltage and Reactive Control; Alberta Reliability Standard VAR002-AB-1.1b Generator Operation for Maintaining Network Voltages; ISO rules, section 304.4 Maintaining Network Voltage; and Information Document # 2010-007RS General Operating Practice – Voltage Control. Recommendation Paper – Technical Requirements – Transmission System Step-Up Transformer Do stakeholders have any comments on the proposed transmission system step-up transformer requirements? Stakeholder AltaLink Stakeholder Comment Replies The reference to WAGFs and synchronous generators can be dropped 34. Thank you for your comment. The to make the section more succinct. A listing of the bullet points should AESO does not intend to revise the suffice. recommendation paper. Invenergy Further discussion is required, as more details are needed to explain the level of mitigation required for blocking the transmission of harmonic currents. 35. To be consistent with the requirements for synchronous generating units and wind aggregated generating facilities, the AESO proposes that either the transmission system step up transformer or the inverter transformer (if the battery facility is equipped with one) should have a delta connection that is adequate to block the transmission of harmonic currents. Recommendation Paper – Technical Requirements – Off Nominal Frequency Requirements Do stakeholders have any comments on the proposed off nominal frequency requirements? Stakeholder AltaLink Stakeholder Comment 1. When operating at off nominal frequency requirements, the output of the battery should be allowed at reduced value. The typical requirement on HVDC operation is around 10% less for the off nominal frequency operation. 2. We recommend naming this section as Frequency Ride Through AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 13 Replies 36. In Alberta, HVDC systems do not reduce operation when operating within the frequency range applied to battery facilities. Additionally, reducing output during off nominal frequency operation would be contrary to good electrical operating practice, because under as it aligns with most vendors’ naming. 3. We recommend activating the FRT capability during discharging state only, especially during system disturbances. frequency excursions typically require generation to increase output up to the full capability of the unit. 37. Thank you for your comment. The AESO does not intend to revise the recommendation paper. 38. System disturbances – in particular, over frequency events – may result in the battery facility moving to the charging state. The loss of resources during these events would be harmful to the reliability of the transmission system. Therefore, FRT capability will be active during both charging and discharging state. Invenergy No comment. Recommendation Paper – Technical Requirements – Frequency Responsive Control System Requirements Do stakeholders have any comments on the proposed frequency responsive control system requirements? Stakeholder AltaLink Stakeholder Comment Section 4.12 includes a requirement for frequency response using a droop characteristic. This is obviously manageable from a technical perspective, but for resources providing fast regulation service wouldn’t there already be a frequency component to the signal? Assuming the AESO adopts some sort of pay-for-performance arrangement, this frequency response should be netted out from the calculation if it causes less-perfect fidelity to the regulation signal. In other words, Battery Storage normally functions as a peaking unit for very short period of time. The standard EPRI model has no droop AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 14 Replies 39. The proposed requirements in section 4.12 of the recommendation paper are minimum requirements for the connection of battery facilities to the transmission system. They are not intended to provide technical requirements beyond the basic reliability needs of the transmission system. control function. Additional requirements to provide ancillary services are contained in the technical requirements for those services. Regulating reserves are intended to be responsive to the automatic generation control, which is a secondary response to frequency deviations. The primary response to frequency deviations is provided by frequency responsive control systems (governors) of the facility or generating unit. For more information, the AESO suggests reviewing its Technical Requirements for Provision of Regulating Reserves Version 2.0. Invenergy Further discussion is required. This should not be required of storage systems. BAL-002 compliance is the responsibility of the RRO and BA per the NERC standard. 40. To clarify, section 4.12 of the recommendation paper refers to BAL002-WECC-1, not BAL-002-AB-1. While it is correct that the standard apply to the ISO, the AESO does not own any generation; therefore, it places obligations on generating facilities to be frequency responsive. The key proposal in section 4.12 of the recommendation paper is that battery facilities will be required to have a frequency response that is similar to AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 15 generating units in order to ensure the safe, reliable and economic operation of the Alberta interconnected electric system. Recommendation Paper – Technical Requirements – Real Power and Ramp Rate Control Requirements Do stakeholders have any comments on the proposed real power and ramp rate control requirements? Stakeholder AltaLink Stakeholder Comment 1. The maximum ramp up rates should be different for normal and emergency conditions (such as when batteries are supplying operating reserves and/or LSSi/GRAS services). The emergency rate should be much higher than normal rate as during a contingency, it may be necessary for the storage device to response immediately. Replies 41. See the AESO’s reply 39, above. 42. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. 2. Maximum Ramp rate should be case specific based on transient system studies. It can be phrased in the OPP that “Granted storage resources shouldn’t be allowed to destabilize the network. System studies can assess transient conditions.” Invenergy No comment. Suncor As the AESO has indicated in the session, the ramp rate may be dependent on system characteristics in the local region of the battery installation. 43. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. Would it be possible for the AESO to provide a range of ramp rates that is generally accepted for connecting to the AIES. There will be several factors to consider in determining the ramp rate, including: For cases which would warrant a separate study to determine the ramp rate, can the AESO provide some general guidelines as to what the technical criteria would be in determining the ramp rates? AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 16 the location of the facility; the size of the facility; and the number of facilities in the area. Recommendation Paper – Technical Requirements – Power Quality Do stakeholders have any comments on the proposed power quality requirements? Stakeholder AltaLink Stakeholder Comment 1. We recommend listing the rules/standards that apply for each item in the bullet list. 2. Reference to ‘WAGFs and synchronous generating units’ is incomplete - if left in, reference to BESS as loads should then be included to be complete. Replies 44. As noted in section 4.14 of the recommendation paper, the proposed power quality requirements will be similar to synchronous generating units and wind aggregated generating units. For further information on power quality requirements, the AESO suggests reviewing the ISO rules, section 502.1 Wind Aggregated Generating Facilities Technical Requirements, subsection 19. 45. Thank you for your comment. The AESO does not intend to revise the recommendation paper. Note that the proposed power quality requirements will apply to battery facilities when operating as either a source or sink. Invenergy No comment. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 17 Recommendation Paper – Technical Requirements – WECC Stability Control Requirements Do stakeholders have any comments on the proposed WECC stability control requirements? Stakeholder AltaLink Invenergy Stakeholder Comment Energy storage can have frequency control and stability functions implemented, but the size of the energy storage compared to the system means that its impact will be very small. It should also be possible to use islanding mode, but the size may again be very limiting. Replies 46. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. As a stabilizer, we agree with AESOs statement that the converter based energy storage will not contribute to any oscillations. There is also a possibility to include power oscillation damping functions (POD) in energy storage the same way as for an SVC or HVDC. The energy storage should be able to counteract system power oscillations using both active and reactive power based on an external input signal. This might be good to know, but is probably better not to include in this paper. No comment. Recommendation Paper – Technical Requirements – Facilities Synchrophasor Measurement Do stakeholders have any comments on the proposed facilities synchrophasor measurement requirements? Stakeholder AltaLink Invenergy Stakeholder Comment Agree - installing PMUs will serve the purpose of measuring the performance of the BESS, including model validation. Again, this will be a cost-driven decision. Batteries should not have to pay for this as the transmission operator/grid operator receives the benefit. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 18 Replies 47. Thank you for your comment. 48. The AESO disagrees that only the transmission system operator benefits from synchrophasor measurement technology. As noted in AltaLink’s comment immediately above, synchrophasor measurement technology can also be used by a market participant for model validation. Additionally, the owner of a battery facility can use the data generated by synchrophasor measurement technology for testing the performance of the battery facility. Synchrophasor measurement technology will likely be a useful tool, because the data it generates will allow battery facility owners, battery system vendors and the AESO to better understand the interaction between the transmission system and battery facilities, which are a new technology. Recommendation Paper – Technical Requirements – Facilities Testing Post Connection Do stakeholders have any comments on the proposed facilities testing post-connection requirements? Stakeholder AltaLink Stakeholder Comment Battery’s life time is different for different types of batteries. The suggested battery periodic replacement rate for Li-ion battery is 5 years and for other types are around 7.5 years. So it would be more beneficial to do the facility testing based on the battery technology. Replies 49. The AESO does not propose to do battery facility testing based on the battery technology, because it is attempting to make the proposed requirements technology neutral (e.g. Liion, flow batteries, etc.). Additionally, as battery technology advances, the replacement rate will change. To avoid having to determine the testing interval on case-by-case AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 19 basis, the AESO proposes that revalidation must be performed every five years. This is consistent with the requirement for synchronous generating units. Invenergy What sets the precedent for revalidation every 5 years? Further discussion is required. 50. Currently, the AESO and WECC require that generating units connected to the transmission system revalidate the unit models every five years. As noted in section 4.17 of the recommendation paper, the proposed revalidation requirements will be similar to synchronous generating units. Recommendation Paper – Technical Requirements – Other Requirements Do stakeholders have any comments on the proposed other requirements? Stakeholder AltaLink Stakeholder Comment Replies It would have been good if AESO also recommended in the paper how 51. The recommendation paper does not battery energy and life time are to be specified. Should the MWh be discuss energy requirements (MWh), specified at beginning-of-life or end-of-life, and how long life time to because that is typically a market issue, design for? not an interconnection issue. Invenergy No comment. Recommendation Paper – Other Comments Do stakeholders have any other comments on the Recommendation Paper? Stakeholder Replies Stakeholder Comment AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 20 AltaLink The AESO paper addresses only technical requirements relating to interconnection, and there will need to be another process for addressing market issues, such as settlement of net energy consumption at wholesale levels, and pay-for-performance. 52. As noted in section 1 of the recommendation paper, the AESO issued the Energy Storage Initiative Issue Identification paper in the spring of 2013. It can be found at: http://www.aeso.ca/downloads/Formatte d_ES_IS_Paper_Final_20130613.pdf. Additionally, four workshops were held in the fall of 2013 and the AESO is preparing the Energy Storage Integration Discussion Paper, which is scheduled to be available in the spring of 2014. Invenergy No comment. Suncor Suncor is a strong supporter of the AESO’s mandate to operate a Fair, 53. The AESO does not consider any of the Efficient and Openly Competitive (FEOC) and the deployment of proposed requirements in the market based mechanisms whenever possible. Considering the recommendation paper to be services. services that are being required for the battery system in its sinking Rather, the proposed requirements are mode, Suncor would encourage the AESO consider market intended to provide the minimum mechanisms for these services. It is not appropriate to have energy requirements for the connection of storage facilities provide services that are not required by other battery facilities to the transmission generators and loads. system in order to ensure the reliability of the transmission system. Different technologies have unique characteristics that need to be considered when being interconnected to the transmission system. For example, the requirements for wind aggregated AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 21 generating facilities are different than the requirements for synchronous generating units. The AESO will consider this comment as it develops sections 502.13 and 502.14 of the ISO rules. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 22