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HEC supports the structure of the standards proposed for Tasmania, as it is consistent with the five-frequency band structure used in the National Electricity Market (NEM) HEC believes it is important to apply the defined principles used in NEM to determine the value of the frequency bands for Tasmania. The proposed Tasmanian frequency bands closely reflect the existing frequency control limits used by the HEC in the past.
HEC supports the structure of the standards proposed for Tasmania, as it is consistent with the five-frequency band structure used in the National Electricity Market (NEM) HEC believes it is important to apply the defined principles used in NEM to determine the value of the frequency bands for Tasmania. The proposed Tasmanian frequency bands closely reflect the existing frequency control limits used by the HEC in the past.
HEC supports the structure of the standards proposed for Tasmania, as it is consistent with the five-frequency band structure used in the National Electricity Market (NEM) HEC believes it is important to apply the defined principles used in NEM to determine the value of the frequency bands for Tasmania. The proposed Tasmanian frequency bands closely reflect the existing frequency control limits used by the HEC in the past.
HEC response to Consultation Paper 6 October 1999 1 Overview The HEC supports the structure of the standards proposed for Tasmania, as it is consistent with the five-frequency band structure used in the National Electricity Market. HEC believes it is important to apply the defined principles used in NEM to determine the value of the frequency bands for Tasmania. The application of NEM principles in Tasmania results in frequency bands similar to those currently being used. HEC proposes the following values based on NEM principles. Frequency band Frequency Band (Hz) Normal band 49.9 50.1 Load changes 49.0 51.0 Single generator contingency 47.0 51.0 Other credible contingency 47.0 53.0 Multiple contingency band 44.8 55.0 2 Methodology It is noted that the proposed Tasmanian frequency bands have been benchmarked against three other standards as follows: i. National Electricity Market, which is a much larger and interconnected system. ii. Queensland, which is predominantly thermal, larger than the Tasmanian system and is also an isolated system with different dynamic response. iii. New Zealand, which is a larger system containing of two islands connected by bi-polar HVDC link, and therefore offering different dynamic characteristics. It is also noted that the proposed Tasmanian frequency bands closely reflect the existing frequency control limits used by the HEC in the past and HEC supports the comment that any changes from existing frequency limits may result in additional costs. Page 2 3 Response to Specific Issues Issue 1: Customers Frequency Requirements HEC agrees with the statements in the Issues Paper. Present experience indicates that the existing customers do not specifically complain on the frequency variations and they are much more sensitive to voltage changes. This may be influenced by the technology used at present in Tasmania and the electromagnetic compatibility of current equipment. However, there are mixed signals as far as future expectations are concern. In the future, customers may have much higher expectations of quality of power supply. As an example Malaysia established dedicated load centres (information super highway centres and technology parks) offering customers very high reliability and quality of power supply. These developments are market driven with specific customers paying higher prices for higher quality. This will be manifested by higher demand for frequency control ancillary services. Issues 2 - 8: Customers Frequency Requirements HEC endorses the issues paper comments. Issue 9 - Generic Factors HEC agrees that the 5 frequency bands documented in the National Electricity Code (NEC) and their corresponding description as shown below should be adopted in Tasmania. These should be regarded as the recognised standard and the actual numerical frequency bands should be seen as a consequence of the application of the standard. Frequency band Definition of Band Normal band Defines the range of frequency control for load fluctuations resulting from the continuous process of switching. Load changes Defines the maximum size of the load that is subject to a regular switching. The size depends on the capacity of generation in service, and is time of day dependent. Single generator contingency Defines frequency excursions upon loss of largest generating unit. Other credible contingency Defines largest load connected on a single circuit. Multiple contingency band Defines the largest frequency excursion where system equipment should remain in service. Page 3 The following additional factors, if not already considered, need to be taken into account by the Panel for each of the bands. Frequency band Influencing factors Normal band Capability for secondary frequency regulation, available fast response reserve and AGC. Load changes Capability of primary frequency regulation. System inertia Largest units in service Spinning reserve Load frequency dependence Single generator contingency Size of the largest generating unit Capability of primary frequency regulation Interaction between primary and secondary frequency control Load frequency dependence Other credible contingency Transmission plant maintenance Largest size of load or generation centre connected on a single transmission element Capability of primary frequency regulation Load frequency dependence Multiple contingency band Extreme weather conditions increasing probability of multiple contingencies Capability of primary frequency regulation Load frequency dependence Issue 10- Specific Factors Factors to be considered in setting particular frequency bands should include: i. Practicality of achieving specified bands ii. Cost of achieving specified band iii. Public benefit to be gained iv. Who pays for improved frequency performance, impact on existing business To keep the frequency within the National Electricity Market bands would significantly increase requirements for ancillary services and the associated cost of providing these services. Issue 11- Evidence for Different Bands Differences between existing and proposed frequency bands are noted. However the HEC considers that they are totally acceptable, as they are the result of applying the frequency definitions as specified in Table A of the Consultation Paper to the Tasmanian environment. The differences are caused by the different: size of our system, sizes and composition of generating units affecting control ability, and load/frequency characteristics. Page 4 Normal band: i. The existing band of 49.9 to 50.1Hz is equivalent to that of the National Electricity Market. ii. Proposed normal band is wider than the band currently adhered to by HEC. iii. New Zealand applies wider normal band and their system is larger than Tasmania. This seams to indicate that NZ target is soft or Tasmania is adopting unnecessarily onerous target. We do not see the need to depart from the current frequency band of 49.9 to 50.1Hz as there is no constraint imposed on the size of standard deviation applied to this particular frequency band. While this makes it difficult to assess the system performance, it makes the need for a wider normal band unnecessary. We agree that the present band does not impose any known adverse impacts on Code Participants. Retention of this band may also better facilitate Tasmanias submission for entry to the National Electricity Market as it aligns with the NEM standard. HEC proposes: 49.9 50.1Hz Load change contingency band: At present the band is 0.5Hz and allows for switching of a 35MW block of load (depending on system generation in service). This band is violated on occasions by the actions of one or two customers. The consultation paper is proposing to increase the band to 1.0Hz in order to satisfy the requirements of these customers. We believe that this frequency band is acceptable for Tasmania as it is the result of applying the defined criteria (Table A of the Consultation Document). The application of a narrower band may result in increased cost of ancillary services, which should be born by the Customer as the causer HEC proposes: 49.0 51.0 Hz Single generator contingency band The consultation paper does not recommend a band but puts forward a choice of three proposed options for the single generator contingency band. As a Generator we recommend that option 3 be adopted in Tasmania as we believe that this is the frequency band which corresponds to the defined criteria, ie. frequency excursions upon loss of largest generating unit(Table A of the Consultation Document). The size of largest generating unit can not be modified. Running these units partially loaded is not an economic solution. Page 5 However this frequency band, 47-51Hz, is wider than that proposed in the issues paper for the (other) credible contingency band, 47.5-53Hz. The size of these two bands will to be coordinated as the other credible contingency band is intended to capture frequency changes under possibly transmission maintenance condition. If not coordinated, under frequency load shedding may result. We note that the report by Sinclair Knight Merz indicates that special design considerations for new thermal and gas turbine generation may be required for operation at frequencies below 47Hz and this would result in additional capital cost. These additional costs to enable other generation technologies to operate in the Tasmanian environment should not be considered as a barrier to entry and should only be regarded as part of the normal investment required to enter the Tasmanian environment. HEC proposes: 47.0 51.0 Hz Other credible contingency band The concern is about frequency in cases where customer loads are connected to a power station at an HV terminal and the system connection is lost. This may include locations such as Gordon, Catagunya, Rowallan and others (Butlers Gorge, West Coast). Loss of transmission element(s) may cause a significant frequency rise beyond the limit postulated in the standard. There will be additional cost to install over frequency protection to disconnect generating units or customers to protect against equipment damage. Similar issues apply to embedded generation, which may need to be disconnected from the system. The system needs to have controlled islanding protection to avoid very low frequencies or generator stalling. One example where this can happen is at Trevallyn with a loss of transmission causing local load to exceed the capacity of local generation. HEC proposes: 47.0 53.0 Hz Multiple contingency band We agree with the proposal to adopt the current frequency band of 44.8 to 55.0Hz. The limits of this band are constrained by present setting of UFLS. All the HECs generating units are robust enough to operate below 47Hz and the present band does not impose any known adverse impacts on Code Participants. HEC proposes: 44.8 55.0 Hz Issue 12 Barrier to entry The HEC considers that the application of tighter frequency bands may result in a barrier to entry to new HEC schemes due to the costs of improving their normally slow governing response which is associated with long water column Page 6 and large plant inertia. The formation of barriers to entry of new renewables is also contrary to the Federal Governments Mandated Renewables program. With respect to barrier to entry see our comments on the Single Generator Contingency Band under Issue 11 above. Issue 13 Generation to protect customer owned plant Current experience indicates that there is no adverse impact of occasional operation of hydro machines at low frequencies down to 44Hz. However, at frequencies below 47Hz it is most likely that thermal generation plant would become disconnected from the system. Issue 16 Level of ancillary services Tighter frequency regulation will require more ancillary services to be made available. Frequency control ancillary service is provided by: i. Generators (spinning, rapidly unloading and tripping) ii. Loads (natural load frequency characteristic not considered as FCAS) iii. Loads (on/off control) Tighter frequency regulation has the following impact on generators: i. For fast primary control resulting in wear and tear of governing equipment and possible operation at non optimal output level requiring compensation for loss of efficiency. ii. For secondary control (response to AGC pulses) increased wear and tear of governing equipment with increased cost of maintenance, loss of efficiency and possibly reduced asset life cycle. Issue 19 - Single generator contingency band HEC Generation does not believe that there is a need to shed the load on occurrence of a single generator outage. We are not aware of any customer complaints on frequency excursion. Tightening the frequency standard and load shedding will incur additional cost of production losses or inconvenience which will need to be covered by a customer requiring higher quality of frequency. Issue 22 Customer sensitivity The design of Gordon connection is such that in case of loss of transmission to Chapel Street it is virtually impossible to keep frequency within the required 53Hz. The best solution for a small load at Gordon may be a direct trip on over-frequency to avoid possible damage on over voltages. Page 7 4 Additional Comments The timing of this paper coincides with the process of the selection of Basslink developer. As the of maximum size of acceptable power frequency excursions influences the cost of developing the Basslink project, it is very important that the panel approve frequency standards, which represent a compromise between: i. Cost of developing Basslink project ii. Amount of ancillary services to be contracted by Basslink iii. Acceptable quality of power supplies to existing and future customers. Once Basslink design is adopted it may be extremely expensive to tighten up the standard without impacting the economic viability of the project. An early decision on frequency standards will have a positive impact on the Basslink project.
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