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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, Page 1 of 5 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 Page 2 of 5 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 Page 3 of 5 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. Page 4 of 5 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. Page 5 of 5