Download Market Participant Comment and Replies Matrix AESO AUTHORITATIVE DOCUMENT PROCESS

Market Participant Comment and Replies Matrix
AESO AUTHORITATIVE DOCUMENT PROCESS
Consultation Letter on Proposed New Alberta Reliability Standard VAR-002-AB-3 (“VAR-002-AB-3”), Generator Operation for Maintaining Network Voltages
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
June 4, 2015
June 4, 2015
through
July 6, 2015
1. Alberta Reliability Standard
Market Participant Comments and/or Alternative
Proposal
AESO Replies
a) New
TransAlta
TransAlta
1. Version of this standard:
1. Response to Comment #1
The AESO is proposing to implement new Alberta reliability standard VAR-002-AB-3
and to retire existing VAR-002-AB-1.1b.
The AESO is seeking comments from market participants with regard to the
following matters:
1. Do you agree or disagree with the proposed new VAR-002-AB-3? 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.
The NERC currently enforceable versoin is the
version 4. The difference between the version 4
from the version 3 (the version that the AESO
proposes to adopt here) is to clarify applicability of
requirements to BES dispersed power producing
resources, such as wind farms. There are a lot of
wind farms in Alberta. Thus, it is recommended
AESO adopt the version 4 to clarify how the
requirements are applicable to the wind farms. The
recommendation based on the NERC version 4 are
detailed below in Comment #5 and #6.
2. Applicability section.
This draft applies to the generator at the threshold
lower than the NERC version. It is recommended
the draft align with the NERC with a threshold
established based on the reliability. Can AESO
AESO Replies to Market Participant Comments: 2015-10-05
In the AESO’s view, it is not necessary to adopt
NERC VAR-002-4 at this time to clarify how the
requirements apply to wind farms. The reference
to “aggregated generating facilities” in VAR-002AB-3 is equivalent to NERC’s “dispersed power
producing resources”, which includes wind
farms. The extent to which VAR-002-AB-3
applies to aggregated generating facilities is
described in the Applicability section of VAR002-AB-3.
Response to Comment #2
The threshold was established through the
adoption of the previous Alberta version of this
standard, VAR-002-AB-1.1b. After the
consultation period for VAR-002-AB-1.1b closed,
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explain the relaiblity rationale of lower threshold in
Alberta?
the AESO Replies Matrix was published on
November 9, 2012. The AESO responded to a
similar comment, in its reply to comment 85 on
VAR-002-AB-1.1b, as outlined below.
In the AESO’s view, the reasons for establishing
the threshold have not changed since 2012.
Comment 85:
Why was the Alberta reliability standard
applied to generating units below the NERC
threshold? Please provide the reliability
reason for doing this.
Reply:
The AESO is applying Final Proposed VAR002-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 is in excess of eight hundred
(800) MWs of generating capacity that falls
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
interconnected electric system. In addition,
this also allows for the removal of these
requirements from ISO OPP 702 which
eliminates duplication with ISO rules.
AESO Replies to Market Participant Comments: 2015-10-05
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3. Requirement R1.
a. The Alberta version should not include the
voltage regulating system for the aggregated
generating facility. The NERC version only deals
with the generator with AVR. We do not believes
the NERC version expands this requirement to
the voltage regulating system in the aggregated
generating facility. This can be shown from the
R3 in the NERC version. R3 says “ a status
change on the AVR, power system stabilizer, or
alternative voltage controlling device”. It is clear
that the AVR and alternative voltage controlling
device are two different terms. The voltage
regulating system in the aggregated generating
facility is an alternative voltage controlling device.
Thus, we request the AESO provide the reliability
rationale why the voltage regulating system is in
the scope of R1. If the AESO interprest the AVR
in the NERC version includes the voltage
regulating system, we request the AESO provide
the rationale.
b. We would like to seek the clarification of
“receives the ISO’s consent” in the R1 (b).
Please define “consent”. Does this mean the
ISO’s explicit approval to allow the generating
unit or aggregated generating facility in operation
when the AVR or voltage regulating system is not
in service and in voltage control mode? In this
case, for example, the ISO system controller
would say “yes, it is approved”. Or does this
mean the ISO acknowledgemet of generating
unit or aggregated generating facility in operation
when the AVR or voltage regulating system is not
in service and in voltage control mode? In this
case, for example, the ISO system controller
would say “thank you for the update”.
Response to Comment #3
a. The AESO included aggregated generating
facilities and voltage regulating systems in
the previous Alberta version of this standard,
VAR-002-AB-1.1b.
The AESO has determined that this standard
should apply to aggregated generating
facilities in Alberta (please refer to the
AESO’s Response to Comment #1, above).
To date, all aggregated generating facilities
have voltage regulating systems as opposed
to automatic voltage regulators. The AESO
views voltage regulating systems as
equivalent to automatic voltage regulators
from an operational reliability perspective.
b. The intent of requirement R1(b) is to ensure
the AESO receives notification of the
unavailability of automatic voltage regulators
and voltage regulating systems.The AESO
takes this information into account in making
operational decisions.
Therefore, the AESO will remove the phrase
“and receives the ISO’s consent” from R1(b).
If the AESO interpretation is the first case, we
AESO Replies to Market Participant Comments: 2015-10-05
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would like the AESO provides the reliability
rationale to make the Alberta version more
stringent than the NERC version. The R1 in the
NERC version requires the notification only, not
the approval when the AVR is not in service and
in voltage control mode.
4. Requirement R2.
a. We understand this requirement is about to comply
with the ISO directive or instruction related to the
voltage/reactive power control. However, the AESO
market rule 301.2 and 304.4 have already covered this
topic. We would like the AESO provides the reliability
rationale to include this in the reliability standard.
Response to Comment #4
a. Section 304.4 of the ISO rules was developed
in conjunction with the previous Alberta version
of this standard, VAR-002-AB-1.1b. The
changes in the proposed VAR-002-AB-3 have
not created any overlap between Section 304.4
and VAR-002-AB-3.
The AESO agrees that Section 301.2 of the ISO
rules overlaps with the proposed VAR-002-AB-3.
The AESO will remove the requirement to
comply with ISO directives from VAR-002-AB-3,
as this requirement is covered in Section 301.2.
b. We would like the AESO provides the defintion of
the the wording of “instruction” in R2 “receiving
directive or instruction”.” Directive” is a defined term
while “instruction’ is not. If is imperative for the control
room operator of generating unit or aggregated
generating facility to understand what is an “instruction”
in the conversation with the ISO system controller.
What kind of wordings used by the ISO system
controller would be treated as “instruction” ? What kind
of wordings would not be treated as “instruction”?.
AESO Replies to Market Participant Comments: 2015-10-05
b.The AESO does not intend to define
instruction. A directive given by the AESO will
explicitly state that it is a “directive”. An
instruction is any other request for a change in
voltage or reactive power that does not state that
it is a directive.
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5. Requirement R4
In the NERC version 4, it states” Reporting of status
or capability changes as stated in Requirement R4
is not applicable to the individual generating units of
dispersed power producing resources identified
through Inclusion I4 of the Bulk Electric System
definition.” The rationale is mentioned in the
Guidelines and Technical Basis section of the
NERC version 4 - Rationale for Exclusion in R4. We
believe this is a valid argument and should be
adopted in Alberta.
6. Requirement R5.
In the NERC version 4, Footnote 5 states “For
dispersed power producing resources identified
through Inclusion I4 of the Bulk Electric System
definition, this requirement applies only to those
transformers that have at least one winding at a
voltage of 100 kV or above.” The rationale is
mentioned in “Guidelines and Technical Basis” of
the NERC version 4 - Rationale for Exclusion in R5.
We believe this is a valid argument and should be
adopted in Alberta.
AESO Replies to Market Participant Comments: 2015-10-05
Response to Comment #5
The applicability section and requirement R4 of
VAR-002-AB-3 refer to “aggregated generating
facilities” (which is equivalent to NERC’s term
“dispersed power producing resources”), rather
than to the individual generating units that make
up an aggregated generating facility. As such,
the operator is required under requirement R4 to
notify the AESO of changes in the reactive
capability of the aggregated generating facility as
a whole. This may include the loss of dynamic
reactive resources or capacitor banks, or
individual wind turbine generators in cases
where the wind turbine generators contribute to
the reactive capability of the facility.
Response to Comment #6
The voltage threshold was established through
the adoption of the previous Alberta version of
this standard, VAR-002-AB-1.1b. In the AESO’s
view, the reasons for establishing the threshold
have not changed since 2012. Please refer to the
AESO’s Response to Comment #2.
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