Stakeholder Comment and AESO Replies Matrix Recommendation Paper
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Stakeholder Comment and AESO Replies Matrix Recommendation Paper
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 through Comments From: Company NameInvenergy LLC Date [yyyy/mm/dd]: 2013-12MM-11DD Contact: Stakeholder RepresentativeChris Orzel Phone: +1 312 582 1430 E-mail: [email protected] 2013-12-11 Recommendation Paper – Executive Summary and Purpose Do stakeholders have any comments on the Executive Summary and Purpose sections? Stakeholder Stakeholder Comment Invenergy Why does the Recommendation exclude distribution-connected battery facilities considering interconnecting to high voltage systems can be cost prohibitive? Recommendation Paper – Background AESO Replies Do stakeholders have any comments on the Background section? Stakeholder Stakeholder Comment Invenergy No comment. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 1 AESO Replies Recommendation Paper – Technical Requirements – Introduction Do stakeholders agree with the introduction to the Technical Requirements section? Stakeholder Invenergy Stakeholder Comment No 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 Invenergy Stakeholder Comment Replies We agree with the language used to refer to batteries as a “source and sink resource.” (pg. 6) 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 Invenergy Stakeholder Comment We agree with the requirements. 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 Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Applicability and Variances Do stakeholders have any comments on the proposed applicability and variances? Stakeholder Invenergy Stakeholder Comment Is the AESO considering IEEE 1547 compliant systems? AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 2 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? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Operating Voltage Requirements Do stakeholders have any comments on the proposed operating voltage requirements? Stakeholder Invenergy Stakeholder Comment No Comment. Replies Recommendation Paper – Technical Requirements – Voltage Ride-Through Requirements Do stakeholders have any comments on the proposed voltage ride-through requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Voltage Regulation Do stakeholders have any comments on the proposed voltage regulation requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Reactive Power Capability Do stakeholders have any comments on the proposed reactive power capability requirements? Stakeholder Invenergy Stakeholder Comment Replies Further discussion is required. Complying with this proposal may result in reduction of real power capacity. Recommendation Paper – Technical Requirements – Transmission System Step-Up Transformer AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 3 Do stakeholders have any comments on the proposed transmission system step-up transformer requirements? Stakeholder Invenergy Stakeholder Comment Replies Further discussion is required, as more details are needed to explain the level of mitigation required for blocking the transmission of harmonic currents. Recommendation Paper – Technical Requirements – Off Nominal Frequency Requirements Do stakeholders have any comments on the proposed off nominal frequency requirements? Stakeholder Invenergy Stakeholder Comment No 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 Invenergy Stakeholder Comment Replies Further discussion is required. This should not be required of storage systems. BAL002 compliance is the responsibility of the RRO and BA per the NERC standard. Recommendation Paper – Technical Requirements – Real Power and Ramp Rate Control Requirements Do stakeholders have any comments on the proposed real power and ramp rate control requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Power Quality Do stakeholders have any comments on the proposed power quality requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – WECC Stability Control Requirements AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 4 Do stakeholders have any comments on the proposed WECC stability control requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Technical Requirements – Facilities Synchrophasor Measurement Do stakeholders have any comments on the proposed facilities synchrophasor measurement requirements? Stakeholder Invenergy Stakeholder Comment Replies Batteries should not have to pay for this as the transmission operator/grid operator receives the benefit. Recommendation Paper – Technical Requirements – Facilities Testing Post Connection Do stakeholders have any comments on the proposed facilities testing post-connection requirements? Stakeholder Invenergy Stakeholder Comment Replies What sets the precedent for revalidation every 5 years? Further discussion is required. Recommendation Paper – Technical Requirements – Other Requirements Do stakeholders have any comments on the proposed other requirements? Stakeholder Invenergy Stakeholder Comment No comment. Replies Recommendation Paper – Other Comments Do stakeholders have any other comments on the Recommendation Paper? Stakeholder Invenergy Stakeholder Comment No comment. AESO Stakeholder Comment and AESO Replies Matrix: 2013-10-22 5 Replies