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IESO Comment Form - Frequency Response Standard
8 pages
English

IESO Comment Form - Frequency Response Standard

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8 pages
English
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Comment Form – Proposed Frequency Response Standard COMMENT FORM Proposed Frequency Response Standard This form is to be used to submit comments on the proposed Frequency Response Standard Authorization Request. Comments must be submitted by February 17, 2005. You may submit the completed form by emailing it to: sarcomm@nerc.com with the words “Frequency Response SAR Comments” in the subject line. If you have questions please contact Mark Ladrow at mark.ladrow@nerc.net or by telephone at 609-452-8060. ALL DATA ON THIS FORM WILL BE TRANSFERRED AUTOMATICALLY TO A DATABASE AND IT IS THEREFORE IMPORTANT TO ADHERE TO THE FOLLOWING REQUIREMENTS: DO: Do enter text only, with no formatting or styles added. Do use punctuation and capitalization as needed (except quotations). Do use more than one form if responses do not fit in the spaces provided. Do submit any formatted text or markups in a separate WORD file. DO NOT: Do not insert tabs or paragraph returns in any data field. use numbering or bullets in any data field. Do not use quotation marks in any data field. submit a response in an unprotected copy of this form. Individual Commenter Information (Complete this page for comments from one organization or individual.) Name: P.D. Henderson Organization: Independent Electricity System Operator Telephone: 905 855-6258 Email: peter.henderson@ieso.ca NERC Region Registered Ballot Body Segment ERCOT 1 - Transmission Owners ECAR ...

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Nombre de lectures 49
Langue English

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Comment Form – Proposed Frequency Response Standard
Page 1 of 8
C
OMMENT
F
ORM
Proposed Frequency Response Standard
This form is to be used to submit comments on the proposed Frequency Response Standard
Authorization Request.
Comments must be submitted by
February 17, 2005
.
You may submit the
completed form by emailing it to:
sarcomm@nerc.com
with the words “Frequency Response SAR
Comments” in the subject line.
If you have questions please contact Mark Ladrow at
mark.ladrow@nerc.net
or by telephone at 609-452-8060.
ALL DATA ON THIS FORM WILL BE TRANSFERRED AUTOMATICALLY TO
A DATABASE AND IT IS THEREFORE IMPORTANT TO ADHERE TO THE
FOLLOWING REQUIREMENTS:
DO:
Do
enter text only, with no formatting or styles added.
Do
use punctuation and capitalization as needed (except quotations).
Do
use more than one form if responses do not fit in the spaces provided.
Do
submit any formatted text or markups in a separate WORD file.
DO NOT:
Do not
insert tabs or paragraph returns in any data field.
Do not
use numbering or bullets in any data field.
Do not
use quotation marks in any data field.
Do not
submit a response in an unprotected copy of this form.
Individual Commenter Information
(Complete this page for comments from one organization or individual.)
Name:
P.D. Henderson
Organization:
Independent Electricity System Operator
Telephone:
905 855-6258
Email:
peter.henderson@ieso.ca
NERC Region
Registered Ballot Body Segment
1 - Transmission Owners
2 - RTOs, ISOs, Regional Reliability Councils
3 - Load-serving Entities
4 - Transmission-dependent Utilities
5 - Electric Generators
6 - Electricity Brokers, Aggregators, and Marketers
7 - Large Electricity End Users
8 - Small Electricity End Users
ERCOT
ECAR
FRCC
MAAC
MAIN
MAPP
NPCC
SERC
SPP
WECC
NA - Not
Applicable
9 - Federal, State, Provincial Regulatory or other Government Entities
Comment Form – Proposed Frequency Response Standard
Page 2 of 8
Group Comments (Complete this page if comments are from a group.)
Group Name:
Lead Contact:
Contact Organization:
Contact Segment:
Contact Telephone:
C
o
n
t
a
c
t
E
m
a
i
l
:
Additional Member Name
Additional Member Organization
Region*
Segment*
* If more than one Region or Segment applies, indicate the best fit for the purpose of these
comments.
Regional acronyms and segment numbers are shown on prior page.
Comment Form – Proposed Frequency Response Standard
Page 3 of 8
Background Information:
Posted for comments is the first posting of the Frequency Response SAR.
The Frequency Task
Force of the NERC Resources Subcommittee has identified the transient frequency response
characteristics as degrading over time and potentially threatening the reliability of the bulk electric
system.
This Standard Authorization Request was initiated to address this concern by developing a
standard to specify a measuring convention for frequency response and by specifying a minimum
required response to system disturbances based on the convention.
The requestor would like to receive industry comments on this SAR and to obtain the input of the
industry prior to determining the final scope and requirements of the SAR.
Accordingly, we
request your comments included on this form, emailed with the subject “Frequency Response SAR
Comments” by February 17, 2005.
Comment Form – Proposed Frequency Response Standard
Page 4 of 8
Question 1: Do you agree there is a reliability need for a specifying the quality and quantity
of frequency response?
Yes
No
If no, please explain in the space provided below.
Comments
We agree in general that there is a reliability need to have frequency response, in order to maintain
interconnection frequency and particularly during disturbances, islanding and restoration.
The
standard need to address both the system needs as well as island requirements for frequency
response.
The standard should provide the process for a technically sound calculation of frequency response
and bias.
The standard should acknowledge that some units might not provide response under normal
operations (e.g. nuclear units operating at full load) and that load response is highly variable event
based on time of day or year.
The standard should acknowledge smaller areas need greater response.
Where BA areas are deficient in meeting the interconnection requirement , they should be allowed
a reasonable period of time to take appropriate steps to make corrections before being assessed as
non compliant.
The standard should also track area response over time (years) and be reevaluated as performance
changes.
Quality should be defined. For generators it should include dead-band, droop characteristics, etc.
Comment Form – Proposed Frequency Response Standard
Page 5 of 8
Question 2: Do you agree with the scope and applicability of the proposed standard?
Yes
No
If no, please explain in the space provided below.
While we agree that the standard should not preclude market solutions (e.g. allow purchasing of
response as long as deliverability and restoration criteria can be met), we have concerns with the
statement
There must be a means for sale/purchase of frequency response as for any other
quantity.
The scope should exclude any reference to a means for sale/purchase of frequency
response as it should only address reliability requirements.
It is not clear what is meant by
A method of allocation must be developed.
Is this an allocation of
Interconnection response to BAs, BA allocation to generators or something different?
The requirements should recognize the capabilities and limitations of generators (e.g. nuclear units
operating at full load).
Comments
Comment Form – Proposed Frequency Response Standard
Page 6 of 8
Question 3: Do you believe these standards are more appropriately additions to existing
standards as opposed to creating new standards?
Yes
No
If yes, please identify the location you believe would be the most appropriate for the proposed
standard
.
Comments
If
the existing Frequency Response and Bias Standard Version 0 (Bal-003-0) can not be clarified
and brought in line with this proposed standard, it should be
standalone .
Comment Form – Proposed Frequency Response Standard
Page 7 of 8
Question 4: Do you have any additional comments regarding the SAR that you believe should
be addressed?
Yes
No
If yes, please share those comments in the space provided below.
We appreciate the opportunity to comment and believe there is a need for such a standard.
It needs to be recognized that there are two objectives for governor response, namely, to provide
response
on an interconnection wide basis to maintain an acceptable frequency and secondly to
control frequency in island situations. The former may allow for averaging over an area of the
response requirement but the latter may limit the extent of averaging.
Published studies show frequency response is declining when it should be increasing with load.
The main concerns with this decreasing performance are:
There may be areas unable to withstand severe disturbances.
Following a grid separation or collapse, control areas may be unable to fulfill their blackstart
and restoration responsibilities, thereby becoming a burden to neighbors.
Because engineering models use theoretical frequency response, they are likely over optimistic
and may misstate grid stability limits.
This standard would allow the industry to determine whether the decline is local or global.
Rather than implementing a complicated infrastructure or process, we would suggest that NERC
automate the calculation of frequency response by either:
Asking BAs to save their CPS-source data in a common format so a common tool can be
used (MAPP BAs and some others use a common tool that can calculate frequency
response with CPS-source data).
Embed the calculation in the NERC ACE-monitoring application.
The standard should employ a methodology that not only captures initial response (first few
seconds after the event) but also the sustained response until AGC action takes over
Comment Form – Proposed Frequency Response Standard
Page 8 of 8
Providing visibility on where and when performance is substandard will likely initiate sufficient
action to arrest the decline in performance.
Minimum performance standards could be
implemented after the industry has identified what is reasonably achievable and technically
justified.
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