2011-04-28 ENMAX Comments (Bulk Tx Line Rule 3rd Consult)

Stakeholder Comment and Rationale Form
AESO AUTHORITATIVE DOCUMENT PROCESS
Stakeholder Consultation Draft
Date: 2011-04-28
Proposed New ISO Rules Section 502.2 Bulk Transmission Line Technical Requirements Version 3.0
Date of Request for Comment [yyyy/mm/dd]:
Period of Consultation [yyyy/mm/dd]:
2011/04/28
2011/04/28
Comments From:
ENMAX Corporation
Date [yyyy/mm/dd]:
2011/05/16
through
2011/05/13
Contact:
Penny Haldane
Phone:
403 514 1506
E-mail:
Listed below is the summary description of changes for the proposed new, removed or amended sections of the ISO Rules. 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 Definitions
(a) New
“bulk transmission line”
Stakeholder Comments and/or Alternate Proposal
Comment # 1: Insert Comments / Reason for Position (if
any)
AESO Replies
Comments
AESO Replies
The proposed new ISO rules definition has been amended to expand the
exclusions to include the reference to the newly defined term ‘aggregated
generating facility’.
2. ISO Rules
Issued for Stakeholder Consultation: 2011-04-28
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(a) New
Comment # 2: Insert Comments / Reason for Position (if
any)
The proposed New ISO Rules Section 502.2 Version 3.0 replace the AESO’s
Technical Requirements for Connecting to the Alberta Interconnected Electric
System (IES) Transmission System, Part 3: Technical Requirements for
Connecting Transmission Facilities (“Technical Requirements”) and set out the
minimum set of technical requirements for any new bulk transmission line with a
voltage equal to or greater than 100 kV planned to be connected to the IES.
The following outlines the key differences and rationale for each of the amended
subsections between the previously consulted on December 17, 2010 New ISO
Rules 502.2 Version 2.0 and proposed New ISO Rules Section 502.2 Version 3.0.
Subsection 1 – Applicability
Comment # 3: Insert Comments / Reason for Position (if
any)
Subsection 1 has been amended to clarify and align the drafting format and
content with that used for other new ISO rules drafted in the AESO’s new
authoritative document format. As well, the obligation has been amended to only
apply to the ‘legal owner’ of a facility instead of the previous application to both
the ‘legal owner’ of a facility and the facility.
Subsection 2 – New and Existing Transmission Lines
Based on recent project experience and stakeholder comments, the requirements
of subsection 2(3) have been amended and will apply to projects with greater than
1500 meters of circuit length rather than 300 meters. This will provide additional
flexibility regarding minor additions.
Subsection 2(5) has been amended to clarify that any required changes to
existing and commissioned bulk transmission line, if required for reasons outlined
in this subsection, will only be addressed through either an amendment to the
original functional specification or the issuance of a new functional specification.
As well, other incidental clarifying amendments have been made to this
subsection to specifically differentiate between new and existing transmission
Issued for Stakeholder Consultation: 2011-04-28
Comment # 4: Insert Comments / Reason for Position (if
any)
ENMAX is concerned that the proposed rule is already
being applied to the ENMAX SEC interconnection
functional specification (ECTP/Shepard). The AESO
has contemplated not applying the rule until it is
approved by the AUC and becomes effective on the
suggested date of 2012-01-01. This understanding is
reflected in the April 26, 2011 reconsultation notice,
which stated that, “the AESO has made amendments to
subsection 2 to clarify that proposed NEW ISO Rules
Section 502.2 will not apply to any new connection
project prior to the effective date of New ISO Rules
Section 502.2 Version 3.0.., However, the April 28, 2011
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lines.
Subsection 3 – Functional Specifications
Letter of Notice did not contain a similar comment, it
only addressed the change from 300m to 1500m.
ENMAX respectfully requests that the AESO remove,
from the functional specifications attached to “in
progress” ENMAX projects, the draft rule 502.2 as it
would not be appropriate or fair to apply an unapproved
rule to an existing project.
Comment # 5: Insert Comments / Reason for Position (if
any)
Subsection 3(1) has been amended to require the AESO to issue functional
specifications for all bulk transmission line connection projects and associated
connection facilities.
Subsection 5 – Other Code Requirements
Comment # 6: Insert Comments / Reason for Position (if
any)
Subsection 5(1)(c) has been amended to clarify that the reference to the
Canadian Standards Association (“CSA”) Overhead Systems Standard is
contemporary version of this CSA standard when referenced in the Alberta
Electrical Utilities Code (“AEUC”).
Subsection 5(1)(e) has been amended to remove requirements regarding radio
interference that unnecessarily duplicate those found in federal government
regulations.
Subsection 6 – Weather Loading Return Periods
Comment # 7: Insert Comments / Reason for Position (if
any)
Subsection 6(4) has been amended to be consistent with other amendments
reflected in proposed new ISO rules Section 502.2 Version 3.0 such that any
required changes to existing and commissioned bulk transmission line, if required,
will only be addressed through either an amendment to the original functional
specification or the issuance of a new functional specification.
Issued for Stakeholder Consultation: 2011-04-28
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Subsection 9 – Weather Loading for Vertical Loading Alone
Comment # 8: Insert Comments / Reason for Position (if
any)
Subsection 9 has been amended to remove the probability based requirement for
vertical loading.
Subsection 10 – Failure Containment Loading
Comment # 9: Insert Comments / Reason for Position (if
any)
Subsection 10 has been amended to remove the tower modeling requirements.
The AESO has decided to make the tower modeling less prescriptive so the
information has been provided in the updated Information Document 2010-005R
Bulk Transmission Line Technical Requirements (“ID 2010-005R”) to provide
general guidance.
As well, subsection 10 has been amended to accommodate the use of wood
laminate poles.
Subsection 12 – Conductor Selection
Comment # 10: Insert Comments / Reason for Position
(if any)
Subsection 12 has been amended to clarify that any change to a conductor type
other than the standard conductor types set out is this subsection will be made in
the project functional specification.
Issued for Stakeholder Consultation: 2011-04-28
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Subsection 13 – Sequence of Failures
Comment # 11: Insert Comments / Reason for Position
(if any)
Subsection 13 has been amended to clarify that sequence of failure analysis is
not required for a bulk transmission line using wood structures given the relatively
high strength variation of wood structures.
Subsection 14 – Overhead Shieldwire
Comment # 12: Insert Comments / Reason for Position
(if any)
Subsection 14 has been amended to require that 3/8” Gr. 220 galvanized steel
strand is the minimum shieldwire size for average span lengths in excess of one
hundred and fifty (150) meters, and that the shieldwire is sized to address the
expected weather loading.
Subsection 17 – Basic Design Clearances
Comment # 13: Insert Comments / Reason for Position
(if any)
Subsection 17(4) has been removed and relocated to the updated ID 2010-005R
as the minimum clearance requirements under maximum design loading is more
safety related than a reliability concern and do not need to be a requirement in
proposed new ISO rules Section 502.2. Safety related clearance requirements are
addressed in the AEUC.
Table 4 – “Switching Surge Electrical Clearances” has been removed and
replaced with new subsections 17(5) and (6) to reference IEEE standards for the
calculation of air gap distances, as the actual value will vary due to system
voltage, elevation, etc, making it problematic to declare a “minimum value”.
Subsection 19 – Clearance to Edge of Right of Way
Comment # 14: Insert Comments / Reason for Position
(if any)
Subsection 19 has been amended to allow 138/144kV lines to utilize road
allowance as this exclusion in previous versions of proposed new ISO rules
Section 502.2 was an oversight. Further, the requirement for right of way width to
meet conductor swing out under five (5) year wind gust has been moved to
updated ID 2010-005R, as this is considered to be more safety related than a
Issued for Stakeholder Consultation: 2011-04-28
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reliability concern. Minimum requirements now reference CSA 22.3 No.1.
Previous Subsection 25 – Radio Interference
Comment # 15: Insert Comments / Reason for Position
(if any)
Previous subsection 25 has been removed and relocated to the updated ID 2010005R as this is not a direct reliability concern and is more appropriately located in
this information document.
Previous Subsection 26 – Documentation of Design Criteria
Comment # 16: Insert Comments / Reason for Position
(if any)
Previous subsection 26 has been moved to the updated ID 2010-005R as this is
not a direct reliability concern concern and is more appropriately located in this
information document.
(b) Other
(Stakeholders wishing to comment on specific provisions are requested to copy
the provision into this area and provide comments)
Issued for Stakeholder Consultation: 2011-04-28
Comment # 17: Insert Comments / Reason for Position
(if any)
ENMAX has identified technical issues with clauses
6(4), 15(1), 15(5), 21(5), 21(7), and 24(5) that will
require further study to determine the impact to ENMAX
when this rule is approved by the AUC and becomes
effective. Additional detail will be provided to the AESO
on the nature of these issues when the subject matter
expert returns from emergency family leave.
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