Download Stakeholder Comment Matrix AESO AUTHORITATIVE DOCUMENT PROCESS Stakeholder Consultation Draft

Stakeholder Comment Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
September 28, 2015
Proposed New ISO Rules Part 500 Facilities, Division 502 Technical Requirements, Section 502.13 Battery Energy Storage Facility Technical Requirements (“New Section 502.13”)
Date of Request for Comment:
Period of Consultation:
Comments From:
September 28, 2015
September 28, 2015
through
October 26, 2015
NextEra Energy Canada
Contact:
Jennifer Tuck
Phone:
647-200-6945
Email:
[email protected]
2015/10/26
Listed below is the summary description of changes for the proposed New Section 502.13. Please refer back to the Letter of Notice under the “Attachments to Letter of Notice” section to view the
actual proposed content changes to the ISO rules. Please place your comments/reasons for position underneath (if any).
1. ISO Rules
Stakeholder Comments and/or Alternate Proposal
a) New
The AESO is seeking comments from stakeholders with regard to the following
matters:
NextEra Energy Canada (“NextEra”) would like to
offer the following comments on the definitions of
“Maximum authorized charging power” and
“Maximum authorized discharging power” for
the AESO’s consideration. Both definitions state
that they are measured at the low side of the
transmission system step-up transformer. For sites
in which the battery energy storage facility is colocated with another generating facility (e.g. wind
facility), and utilizes the same step-up transformer
will the ISO allow an exception and consider this
measurement point to be at the battery energy
storage terminals (i.e. inverter terminals) so the
wind facility and battery facility metering are not
co-mingled for this purpose? Otherwise, please
consider redefining to say “…as measured at the
1. Do you agree or disagree with the proposed new Section 502.13? If you
disagree, please provide comments.
2. Are there any subsections where the language does not clearly articulate the
requirement for either the AESO or a market participant? If yes, please indicate
the subsections and suggest language that would improve the clarity.
Issued for Stakeholder Consultation: September 28, 2015
AESO Replies
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low voltage side of the transmission system stepup transformer, or at the energy storage facility
terminals if co-located with other generating
facilities and utilizing common step-up
transformers.”
Technical Requirements
- Section 2(1): The ISO will likely receive a
wide variance in the format and content of
the “functional specifications” that must be
submitted here, dependent on the
submitting entity. The AESO should
consider developing a template for this to
ensure the ISO receives the level of detail
that they require to perform and analysis
and approve.
Issued for Stakeholder Consultation: September 28, 2015
-
Section 2(3): “maximum charging power”
could include auxiliary loads (lighting,
HVAC, etc.) which are required for the
facility to operate but not directly
associated with the charging of the
batteries (this is dependent on where the
auxiliary load transformers are tapped
relative to the metering location). Next
Era would like to suggest adding a
sentence stating “This maximum charging
power is not inclusive of any auxiliary
power utilized in the operation of the
facility”.
-
Section 4(1): NextEra would like to
suggest adding language to clarify that for
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ULTC transformers, the 1.00 per unit
voltage should be calculated with the
ULTC at neutral tap, or the normal
operating tap if not at neutral.
Issued for Stakeholder Consultation: September 28, 2015
-
Section 4(2): it is feasible that if a battery
energy storage facility is co-located with
an existing generation resource such as
wind, they may share a common
voltage/reactive control system if they
share a common point of
interconnection. If this is the case, it may
not be desirable to have a separate
manually controllable setpoint of the
battery energy storage facility that is
separate from the control for the aggregate
facility. NextEra would like the AESO to
please consider this scenario in
determining the requirements in section 4,
as to whether you may include an
exception process to exclude certain
battery energy storage facilities from these
requirements in certain scenarios.
-
Section 7(1, 8(1) and 8(2): although
capable of simulating a typical generators
governor response, inverter based
technologies such as battery energy storage
facilities provide a unique capability not
available with traditional generation in
their ability to respond very quickly
(within cycles) to either an input signal or
a fluctuation in a transmission system
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parameter such as voltage or
frequency. These capabilities can be
utilized to more quickly arrest frequency
declines or loss of large loads more
efficiently than the slower typical governor
response. A number of ISO’s have seen
value in this type of response and have
established markets for this type of
service. If AESO is considering this
direction now or in the future, the
governor requirements as well as the ramp
rate limitations in these sections would
prohibit implementing a market design or
ancillary service such as this.
Issued for Stakeholder Consultation: September 28, 2015
-
Section 12(1) and 12(2): our interpretation
is that these breaker controls, remote
functionality, etc can be shared if the
battery energy storage facility is co-located
with an existing generating site and shares
a common point of interconnection. Could
the AESO verify that our interpretation is
accurate?
-
Section 17: It is not clear in section 17 as
to whether or not continuous syncrophasor
measurement data must be kept for at least
one calendar year, or if the intent is that
this data is available for any event that
results in a trip of the battery energy
storage facility (similar to the SER
requirements in section 18). If the intent of
the requirement is to store the
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syncrohphasor measurements only during
the events in which the battery energy
storage facility experiences a trip, and to
then keep each of these trip event records
for a duration of one calendar year, the
language might be modified to state “17(1)
A battery energy storage facility must be
equipped with a syncrhophasor
measurement system that triggers and
event record for every event that results
in a trip of the battery energy storage
facility.” If the intent is to have
continuous PMU data stored for the entire
calendar year, we would like the AESO to
explain the value that this provides.
Issued for Stakeholder Consultation: September 28, 2015
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