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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. Date of Request for Comment: Period of Consultation: 2013-12-11 2013-10-22 Comments From: Suncor Energy Inc. Date [yyyy/mm/dd]: 2013-12-11 through 2013-12-11 Contact: Ben Hui Phone: 403-296-8440 E-mail: [email protected] Recommendation Paper – Executive Summary and Purpose Do stakeholders have any comments on the Executive Summary and Purpose sections? Stakeholder Stakeholder Comment AESO Replies Recommendation Paper – Background Do stakeholders have any comments on the Background section? Stakeholder Stakeholder Comment AESO Replies Recommendation Paper – Technical Requirements – Introduction AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 1 Do stakeholders agree with the introduction to the Technical Requirements section? Stakeholder Stakeholder Comment AESO Replies 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 Stakeholder Comment Replies 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 Stakeholder Comment Replies 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 Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Applicability and Variances Do stakeholders have any comments on the proposed applicability and variances? Stakeholder Stakeholder Comment Replies 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? AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 2 Stakeholder Stakeholder Comment For an aggregated generating facility, it would seem to be reasonable to have the MARP (of the battery) to represent the source capability. Replies 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. Recommendation Paper – Technical Requirements – Operating Voltage Requirements Do stakeholders have any comments on the proposed operating voltage requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Voltage Ride-Through Requirements Do stakeholders have any comments on the proposed voltage ride-through requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Voltage Regulation Do stakeholders have any comments on the proposed voltage regulation requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Reactive Power Capability Do stakeholders have any comments on the proposed reactive power capability requirements? Stakeholder Stakeholder Comment AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 3 Replies 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 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. Recommendation Paper – Technical Requirements – Transmission System Step-Up Transformer Do stakeholders have any comments on the proposed transmission system step-up transformer requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Off Nominal Frequency Requirements Do stakeholders have any comments on the proposed off nominal frequency requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Frequency Responsive Control System Requirements Do stakeholders have any comments on the proposed frequency responsive control system requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Real Power and Ramp Rate Control Requirements AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 4 Do stakeholders have any comments on the proposed real power and ramp rate control requirements? Stakeholder Stakeholder Comment Replies 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. Would it be possible for the AESO to provide a range of ramp rates that is generally accepted for connecting to the AIES. 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? Recommendation Paper – Technical Requirements – Power Quality Do stakeholders have any comments on the proposed power quality requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – WECC Stability Control Requirements Do stakeholders have any comments on the proposed WECC stability control requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Facilities Synchrophasor Measurement Do stakeholders have any comments on the proposed facilities synchrophasor measurement requirements? Stakeholder Stakeholder Comment AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 5 Replies Recommendation Paper – Technical Requirements – Facilities Testing Post Connection Do stakeholders have any comments on the proposed facilities testing post-connection requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Technical Requirements – Other Requirements Do stakeholders have any comments on the proposed other requirements? Stakeholder Stakeholder Comment Replies Recommendation Paper – Other Comments Do stakeholders have any other comments on the Recommendation Paper? Stakeholder Stakeholder Comment Suncor is a strong supporter of the AESO’s mandate to operate a Fair, Efficient and Openly Competitive (FEOC) and the deployment of market based mechanisms whenever possible. Considering the services that are being required for the battery system in its sinking mode, Suncor would encourage the AESO consider market mechanisms for these services. It is not appropriate to have energy storage facilities provide services that are not required by other generators and loads. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 6 Replies