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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 Page 1 of 5 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 Page 2 of 5 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 Page 3 of 5 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 Page 4 of 5 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 Page 5 of 5