Electricity Commission

Consultation Paper
(Second Round)

Duplicate Protection Rule Amendment Proposal

December 2006

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Purpose
1.

The Electricity Commission (Commission) is considering recommending

changes to the Electricity Governance Rules 2003 (Rules) in order to
clarify asset owner compliance obligations regarding duplicated main
protection systems on both sides of the grid interface at voltages of 220 kV
or above.

2.

The Commission consulted on several proposed amendments to technical

code A of schedule C3 of part C of the Rules as set out in a formal
statement of proposal published on 25 August 2006. This paper is
available on the Commissions web site at:
http://www.electricitycommission.govt.nz/opdev/comqual/CQconsultation/in
dex.html.

3.

The consultation period expired on 4 October 2006 and submissions were

received from a number of parties. The Commission, having considered
issues raised by submitters, is of the view that further changes are
necessary to the wording of the rule amendment proposal. The purpose of
this paper is to consult with persons that the Commission thinks are
representative of the interests of persons likely to be substantially affected
by the further changes to the rule amendment proposal.

Submissions
4.

The Commission invites submissions on the amended proposal by 5 pm on

21 December 2006.

5.

The Commissions preference is to receive submissions in electronic

format (Microsoft Word). Submissions in electronic version should be
emailed with Duplicate Protection Rule Amendment Proposal in the
subject header to info@electricitycommission.govt.nz.

6.

If submitters do not wish to send their submission electronically, they

should post one hard copy of their submission to the address below.
Jenny Walton
Electricity Commission
Level 7, ASB Bank Tower
2 Hunter Street
P O Box 10041
WELLINGTON
Tel: (04) 460 8860
Fax: (04) 460 8879

7.

The Commission will acknowledge receipt of all submissions electronically.

Please contact Jenny Walton if you do not receive electronic
acknowledgement of your submission within two business days.

8.

Your submission is likely to be made available to the general public on the

Commissions website. Submitters should indicate any documents
attached, in support of the submission, in a covering letter and clearly
indicate any information that is provided to the Commission on a
confidential basis. All information provided to the Commission is subject to
the Official Information Act 1982.

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Abbreviations used in this paper

Abbreviation
Act
Commission
Rules

Description
Electricity Act 1992
Electricity Commission
Electricity Governance Rules 2003

Submissions received
9.

The Commission received submissions from the parties listed in Table 1.

All submissions have been published and are available on the
Commissions website.
Table 1: Submissions received
Generators
/ Retailers

Distributors

Transmission
/ System Operation

Consumers

Contact Energy
Genesis Energy
Meridian Energy

Vector

Transpower

Comalco
MEUG

Key Issues raised in submissions

10.

A summary of the key issues raised by submitters and the Commissions

proposed changes to the original rule amendment proposal in response to
those issues is set out in Table 2. The changes are intended to clarify the
meaning of the proposed amendments and do not introduce additional
obligations on asset owners or any other party.
Table 2: Key issues

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Key Issue

Commissions Response

Use of alpha-numeric rule

numbering.

The proposed alpha-numeric numbering of new

rules was intended to preserve the numbering of
subsequent rules. The numbering of rules has
been revised.

Ordering of clauses

The order of some of the clauses in the proposed

rules has been changed to improve logical flow.

The obligation for asset owners to

provide duplicated main protection
systems on each side of the grid
interface is unclear.

The term grid interface, defined in Part A of the

Rules, relates to assets used to make a
connection to the grid, as well as the interface
between assets forming part of the grid. A grid
interface is not simply the boundary between
assets and in this respect, the obligation to
provide duplicated main protection systems on
each side of the grid interface was not clear to
some submitters. Rule 4.4.2 effectively applies to
all assets connected to or forming part of the grid
at voltages of 220 kV. In view of this, the
proposed wording of rule 4.4.2 has been
simplified to reflect this and to remove the

Key Issue

Commissions Response
confusing reference to each side of the grid
interface. In addition, the wording has been
changed to clarify that each asset owner is
required to provide duplicate protection for its
assets only.

Use of the term good industry

practice

The term good industry practice has been

removed from the proposed duplicate protection
rules to avoid confusion with a similar term good
electrical industry practice as used in the
proposed benchmark agreement. However, the
obligations defined under the term good industry
practice have been retained.

Interpretation of the word separate

The word separate was used in several places

in the proposed rules to mean distinct or
individual, although this usage was unclear to
some submitters. The word has been replaced
with other terms to more specifically state the
necessary requirements.

Busbar protection
11.

Although not directly raised by submitters, the Commission identified an

additional issue relating to busbar protection during the evaluation of
submissions received on the rule amendment proposal published on
25 August 2006.

12.

The proposal included an appendix to technical code A of schedule C3 of

part C of the Rules which required that if any or all parts of one main
protection system fail, the other main protection system will disconnect a
faulted asset before backup protection initiates the disconnection of other
non-faulted assets. In effect, one main protection system must provide full
redundancy for the other main protection system.

13.

The grid owners existing standard for 220 kV busbar protection systems
would not have been fully compliant with this requirement, although would
arguably be compliant with the current duplicate protection rule. The grid
owners standard 220 kV busbar protection consists of:

14.

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single main (discriminating zone) unit protection; plus

back up protection from the remote ends of the transmission lines

connected to the busbar; plus

check zone protection (where circuits can be changed over from one
bus to another).

Check zone protection is used on double, triple, and ring buses where
circuits are able to be changed over from one bus to another (and
therefore changed over from one protected zone to another). Although
check zone protection has the same probability of fault detection as the

single main unit protection, it does not function as a second form of main
protection. Rather, its function is to improve the stability of the busbar
protection system by providing a two-out-of-two operation to trip a bus
zone. In the event that either the grid owners single main unit protection
fails or the check zone protection fails, the grid owners back up protection
must operate to clear a bus fault.
15.

The Commission does not intend to recommend that the grid owner should
be required to invest unnecessarily to duplicate its main unit protection on
all grid 220 kV busbars where the grid owners back up protection can
satisfactorily clear busbar faults if the main busbar unit protection fails.

16.

A modification is proposed to the original rule amendment proposal to

allow 220 kV busbars to be protected by single main protection plus back
up protection. The back up protection must be able to clear a fault quickly
enough to ensure that a busbar fault does not cause instability of the
power system. Accordingly, it is proposed that the grid owner (or any other
future owner of 220 kV busbars) be required to ensure that the
performance of its busbar back up protection is compliant with rule 4.4.1 of
technical code A of schedule C3 of part C, i.e. to ensure it supports the
system operator in planning to comply, and complying, with the principal
performance obligations under the Rules.

17.

Additional changes consistent with the modifications outlined in paragraph

16 are proposed to the wording of the appendix to be added to technical
code A of schedule C3 of part C.

18.

As a precautionary measure, it is proposed to specify a higher standard for

the protection of future grid busbars at voltages above 220 kV by requiring
fully duplicated main protection systems on these busbars. It may be
necessary to update this provision at some point if future industry practice
in the New Zealand context exceeds this standard.

Proposed Rule Amendments

The updated proposed rule amendments are appended as Attachment 1.

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ATTACHMENT 1: DETAILED RULE CHANGE PROPOSAL

This Attachment presents the amendments proposed to the Rules.
i.

Include new definitions in part A of the Rules:

back up protection system means a protection system:
(a)

which disconnects faulted assets from the grid because

either a main protection system or a circuit breaker has
failed to disconnect a faulted asset from the grid in the
allocated time; and

(b)

that may disconnect unfaulted assets as well as a faulted

asset

main protection system means a protection system which

detects one or more types of faults and disconnects a faulted
asset from the grid with the minimum of disruption to the grid
and non-faulted assets
circuit breaker failure protection means a protection system
which:

ii.

(a)

operates because a circuit breaker has failed to

disconnect a faulted asset from the grid in the allocated
time;

(b)

may disconnect unfaulted assets from the grid as well as a

faulted asset; and

(c)

need not be duplicated

Amend rule 4.4 of technical code A of schedule C3 of part

C of the Rules as follows:
4.4

Protection of assets and the grid

Each asset owner will must ensure that it provides
protection systems for its assets that are connected to,
or form part of, the grid. Each asset owner must also
ensure that as a minimum requirement:

4.4.1

Achieve the PPOs

Such protection systems will support the system
operator in planning to comply, and complying, with the
principal performance obligations and must be
designed, commissioned and maintained, and settings
must be applied, to achieve the following performance in
a reliable manner:
4.4.1.1

Disconnect any faulted asset

Disconnect any faulted asset in minimum practical time

(taking into account selectivity margins and industry best
design practice) and minimum disruption to the
operation of the grid or other assets; and

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4.4.1.2

Be selective when operating

Be selective when operating, so that the minimum

amount of assets will be disconnected; and
4.4.1.3

Preserve power system stability

As far as reasonably practicable, preserve power

system stability;
4.4.2

Duplicated main protection systems for assets other

than busbars are provided
It provides duplicated main protection systems for
each of its assets at voltages of 220 kV ac or above,
other than busbars; Main protection systems on both
sides of the grid interface at 220 kV are designed to
follow industry best practice, such that there are either
duplicate protections or two different main protections
which have a similar probability of detection. Circuits
breaker duplication is not required. A circuit-breaker
failure protection system shall be provided for each 220
kV circuit breaker; and

4.4.3

Protection for busbars at 220 kV ac

It provides, for each of its 220 kV ac busbars:

4.4.4

4.4.3.1

a single main protection system and a

back up protection system; or

4.4.3.2

if the performance of its backup protection

system does not meet the requirements of
rule 4.4.1, a duplicated main protection
system;

Protection for busbars above 220 kV ac

It provides duplicated main protection systems for
each of its busbars at voltages above 220 kV ac;

4.4.5

Main protection system requirements

It designs, tests and maintains its main protection
systems at voltages of 220 kV ac or above in
accordance with the requirements set out in appendix A;

4.4.6

Circuit breaker failure protection is provided

A circuit breaker failure protection system is provided
for each circuit breaker at voltages of 220 kV ac or
above. Circuit breaker duplication is not required; and

4.4.73

Similar to existing design practice

Protection system design for a connection of assets to
the grid at lower voltages must be similar to existing
design practice in adjacent connections of assets to
ensure co-ordination of protection systems.

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iii.

Add the following appendix to technical code A of schedule

C3 of part C of the Rules:
Appendix A: Main protection system requirements
1.

General requirements

The asset owner must design, test and maintain all main
protection systems at voltages of 220 kV ac or above to
conform to electricity industry standards and practices as they
are reasonably and ordinarily applied by a skilled and
experienced asset owner to current installations at voltages of
220 kV or above in the New Zealand context.
2.

Specific requirements for main protection systems

Main protection systems at voltages of 220 kV ac or above
must meet the requirements set out below:
2.1

Test blocks
Either test blocks or both test switches and test
terminals must be provided;

2.2

Supervision of fused circuits

The electrical continuity of fused protection circuits,
including dc and voltage transformer circuits must be
supervised; and

2.3

Supervision of trip circuits

The electrical continuity of circuit breaker trip circuits
must be supervised.

3.

Specific requirements for duplicated main protection

systems
Duplicated main protection systems (the two components
of which are referred to in this appendix as main 1 protection
and main 2 protection) at voltages of 220 kV ac or above
must meet the requirements set out below:
3.1

Coverage and probability of detection

Duplicated main protection systems must be
designed with sufficient coverage and probability of
detection that if any or all parts of one main protection
system fail, the other main protection system will
disconnect a faulted asset before a backup
protection system initiates the disconnection of other
non-faulted assets;

3.2

Independent station batteries

The dc supply to duplicated main protection systems
must consist of two independent station batteries, each
with its own charger, supervision, and with a capacity
and carry over duty to cover charger failure until repair
and restoration. Station batteries may only feed a
common primary dc busbar provided that the busbar is
insulated and isolated from earth;

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3.3

dc supply fused independently

The dc supply to each duplicated main protection
system must be independently fused at the primary dc
busbar;

3.4

Different main 1 protection and main 2 protection

The manufacturer of main 1 protection must not be the
same as the manufacturer of main 2 protection, unless
one protection uses different measurement principles
from the other;

3.5

Different current transformer cores

The current transformer core (or an equivalent
instrument) and the cabling associated with that
current transformer core or equivalent instrument (as
the case may be) used for main 1 protection must be
independent from that used for main 2 protection;

3.6

Voltage transformer supplies

Where a voltage transformer supply is required for
main 1 or main 2 protection:
3.6.1

Fused at the voltage transformer

The supply must be fused at the voltage
transformer; and

3.6.2

Different fuse and cable for main 1 and

main 2 protection
The supply for main 1 protection must use an
independent fuse and cable from those used
for main 2 protection;

3.7

Circuit breaker trip coils

Main 1 protection must use, in each of the circuit
breakers tripped by that main 1 protection, an
independent trip coil from that used for main 2
protection;

3.8

Protection signalling
Where protection signalling is used, main 1 protection
must use a signal channel over an independent bearer
on a different route from that used for main 2
protection; and

3.9

Segregation of cabling
Main 1 protection cabling must be segregated from
main 2 protection cabling in a manner that minimises
the risk of common mode failure of main 1 and 2
protection and minimises the number of connections in
any protection circuit.

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Existing equipment
Despite rule1 and 3 of this Appendix:
4.1

Current transformers
A current transformer commissioned prior to [date to be
inserted1], is not required to comply with the
requirements of rule 3.5 until the current transformer is
replaced;

4.2

Circuit breaker trip coils

A circuit breaker commissioned prior to [date to be
inserted1], if not designed to incorporate a second trip
coil, is not required to comply with the requirements of
rule 3.7 until the circuit breaker is replaced; and

4.3

Cabling
Cabling commissioned prior to [date to be inserted1], if
not designed to be segregated, is not required to
comply with the segregation requirements of rule 3.9
until the cabling is replaced.

iv.

Make a minor typographical correction to the defined term,

circuit-breaker2, to remove the hyphen between the words
circuit and breaker in part A of the Rules, and in rule 4.3
of technical code A of schedule C3 of part C of the Rules.

To be the date on which these proposed rule amendments come into effect.
The term circuit-breaker is not used elsewhere in the Rules. It previously occurred in technical
code C of schedule C3 of part C, but those occurrences have been updated under a separate rule
amendment.
2

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