Materially Affected Party Comments to awea draft Standard 1 – 2009, “Small Wind Turbine Performance and Safety Standard”




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Materially Affected Party Comments to AWEA Draft Standard 9.1 – 2009, “Small Wind Turbine Performance and Safety Standard”

Compiled by Mike Bergey, Chair, AWEA Small Wind Turbine Standards Subcommittee

May 3, 2009



No. 1: Marc Normandin, Energie PGE (manufacturer)

Number

Comment

Recommended Response

Rcmd. Action

1.1

“… we are highly concerned with the 200m² Swept Area proposed in Scope 1.3.2.”

The 200m2 limitation is in the scope of IEC 61400-2 and relates to the applicability of the simplified equations for loads in the safety analysis. The issue is under review at the IEC , where there seems to be a consensus that larger turbines should be covered. The IEC has tasked several members with developing a plan for the inclusion of larger turbines. The IEC’s goal is to have a draft international small wind standard by the end of 2009. We should not delay the current standard this improvement.

Defer issue for next edition or IEC

No. 2: David Sweetman

Number

Comment

Recommended Response

Rcmd. Action

2.1

There is no provision for the manufacturer to provide the equation for the power output of the wind generator.  The equation must be experimentally derived from the actual equipment, using a range of wind velocities from cut-in to cut-out.

This is not how the wind industry characterizes performance.

None

2.2

The test conditions must be clearly stated, i.e., temperature, air density (elevation).

These are required in the underlying IEC standard and are used to normalize data

None

2.3

While laminar flow should be assumed, at least the conditions to achieve laminar flow should be identified, e.g., tower height, distance to obstructions.

Site requirements to minimize site affects are part of the underlying IEC standard

None

2.4

Correction coefficients should be supplied for temperature and elevation, i.e., how much air density affects performance, especially if not linear.

These are required in the underlying IEC standard and are used to normalize data

None

2.5

Clarification is required depending if the output is AC or DC, e.g., if rectifiers are integral to the generator or a subsequent conversion unit.  Given that many small (< 10 kW) wind generators are primarily DC output, the lack of a commercially available DC kWh meter is a problem in actually quantifying output power.  Some acknowledgement is required for the efficiency loss in conversion of DC to usable AC.

Rectification losses and other normal losses are included. The testing agent will use a calibrated DC watt-meter per the IEC standard. Power data is taken as instantaneous values that are averaged and then binned. This method is well vetted.

None

2.6

The specifications for the wind generator should clearly identify the range of operation for RPM, voltage, current, and frequency.

This requirement is contained in Sections 7.4.7 and 1.5.2.10

None

2.7

While providing an estimated annual production for some standardized environment is useful, there needs to be the methodology to predict performance in the “at use” environment.  The first part is the equation for power output, then include what other efficiency or other correction factors are required.  A sample spread sheet would be useful.

Such spreadsheets exist, although they are based on binned power curves, not power equations. The wind speed probability density used in these performance models is, on the other hand, based on the Weibull equation.

None

2.8

To be wide acceptable and used, any standard must be free to download from a web site.  Is that your intention???

We do not know what policy AWEA will follow on this. There is typically a fee for obtaining standards documents.

None

No. 3: Rich Barbarics, The Energy Advisor

Number

Comment

Recommended Response

Rcmd. Action

3.1

On proposed AWEA performance standard, why is rated power at 11 m/s (25mph) and not something more realistic. PV rates modules on an ill conceived set of conditions (STC) and I thought the wind effort might be closer to reality for small turbines.

That is the intent. Current industry practice has turbines rated at wind speeds ranging from 9 m/s (20 mph) to 14 m/s (31 mph). There is ~ 3.8 times the energy density at 14 m/s compared to 9 m/s. 11 m/s was the consensus middle ground.

None

No. 4: Brian Kramak, Intertek

Number

Comment

Recommended Response

Rcmd. Action

4.1

Not sure if this is worth commenting on or not. Is there a reason that the standard doesn’t mention any US or Canadian standards for the major components?
 
IE, for the generator, I would recommend UL 1004-1 and 1004-4 for the generator for the US and CSA C22.2 No 100 for Canada. Also, if would seem reasonable to mention UL 1741 for the US and CSA C22.2 No 107.1 for Canada for the inverter.

This standard does not address electrical safety issues directly. In 2004 when this standard was proposed and scoped there was essentially no demand from electrical inspectors for safety certification of the turbine itself. That demand, though rare, has been raised now in a few States. Some of the other commenter’s specifically raise this issue.




4.2

Also, we have seen some pretty poor wiring practices. Reference to NEC article 705 shows that it does not have the same coverage as we have for PV systems, so it would seem reasonable to have the wind turbine system standard cover wiring from the wind generator to the inverter/point of connection to the electrical system.

A new section for the 2011 NEC that specifically covers small wind turbines is underdevelopment. It is beyond the scope of this standard.

None

No. 5: David Bernell, Think Energy (writing on behalf of Aerovironment)

Number

Comment

Recommended Response

Rcmd. Action

5.1

In section 2.1.4 of the draft, it states, "The wind turbine shall be installed using the manufacturer's specified mounting system. If a wind turbine is not supplied with a specific mounting system, the generator should be mounted at a hub height of at least 10 meters."  We would like to request that the end of the paragraph be modified to read, "…mounted at a hub height of at least 10 meters from the ground."  This change would provide greater specificity, avoiding misinterpretation of the standard for turbines that are mounted on buildings.

Although we would expect building-mounted turbines to be supplied with standard mounts in most cases, this does seem like a reasonable clarification.

Accept recommendation

No. 6: Paul Migliore, AnemErgonics LLC

Number

Comment

Recommended Response

Rcmd. Action

6.1

I suggest the use of “Small Wind Turbine Certification Council” instead of “Small Wind Certification Council” so that the name of the Council coincides with the name of the Standard. Those in the wind energy industry often use the term “small wind” to refer to the area of interest – energy from small wind turbines. But really, it’s a silly term. After all, what is a “small wind” in comparison to a “large wind” for example? Admittedly, it’s a semantics issue, but good grammar reflects well on AWEA and the SWCC. If this change were made, it would seem to me still acceptable to use SWCC as the acronym.

This is beyond AWEA’s scope and the SWCC Board has settled on their name.

None

6.2

Page (i), paragraph (1), line (3): “AWEA” not “AWES.”

Typo – Thank you

Will correct

6.3

Page (v), Section (3): Use “Acoustic Testing” instead of “Acoustic Sound Testing”, which is redundant.

Yes, it is redundant. However, it is more understandable by technical and non-technical readers. The BWEA has continued this redundancy even though they have adopted a more extensive treatment of acoustics.

None

6.4

Page (2), Section (1.3.5), line (1)

  1. There is no Section 6.1.7.1 in the document.

Correct

Remove reference

6.5

Page (2), Section (1.3.5), line (1)

2. While it is convenient to exclude towers and foundations from the standard, it is also very risky. We may assume that conformance of the tower structure to the International Building Code, Uniform Building Code or their local equivalent will be required for a building permit, but in many cases this is not true. Permits are often issued without engineering review of the tower, except for noting that it is recommended or approved by the manufacturer. In some cases, foundation designs and / or the underlying soil conditions are not checked. When permitting authorities require that foundation drawings be approved by a professional engineer, there is reasonable assurance that the foundation will be robust. However, it does not follow that a review of the tower will be required, or that if such a review is required it will ensure the integrity of the tower. Why is that? Because most structural engineering standards are based on static-strength analysis with the inclusion of robust safety factors for unknown and unpredictable effects. The design of small wind turbines, on the other hand, is dictated primarily by fatigue considerations. And there is nothing in the Standard that requires a fatigue analysis. Thus, there is a non-trivial probability that towers might be grossly under- or over-designed, thereby violating the goal of the Standard (Section 1.1) “…to provide consumers with … confidence in the quality of small wind turbine products…” In view of this situation, and realizing that it would increase the wind turbine manufacturer’s burden for certification, I urge the committee to consider requiring a tower fatigue analysis such as that described by the American Institute of Steel Construction, Specification for Structural Steel Buildings (AISC) 360-05, Appendix 3, Design for Fatigue or that of the Germanischer Lloyd certification agency.

Unlike large wind turbines, small wind turbines are typically offered with numerous tower options and customers are often allowed to supply their own towers. It is too much of a burden to require the “system certification” approach to every tower option. Local permitting will almost always require a PE-stamped structural analysis to the local IBC or equivalent code for their specific wind load requirements and they will not likely accept an AWEA substitute. Also, tower collapses are rare and injuries are extremely rare because people are not around the turbines during severe storms. Including towers and fatigue analyses would carry a high price, limit innovation and consumer choice, and deliver minimal actual consumer benefits.

None

6.6

Page (5), Section (2.1.13): In this part of the Standard, each sub-subsection deals with a unique topic. Therefore, the statement “In Section 4.4, Data Reduction: Select data …” should be contained in a separate sub-subsection, namely, Sub-subsection 2.1.14, and all subsequent sub-subsections should be renumbered.

True. However, there is some value in treating the shorter averaging periods in the same section. The BWEA did not change this section.

None

6.7

Page (6), Section (3) Heading: Delete the word “Sound.” It is redundant.

As previously noted, there is some communication value in this redundancy

None

6.8

Page (6), Section (3.1.4): Delete the word “an” after “cover.”

Typo – Thank you

Will correct

6.9

Page (6), Section (4.2): This requirement of the Standard is necessary, but may not be sufficient. For example, it might be shown during a test period that potentially harmful dynamic interactions are avoided. However, dynamic interactions that are not obvious might reduce the life of a wind turbine from 20 years to six, for example. See my comments above.

This is really the role of the manufacturer’s warranty. There is no way a turbine certification standard can provide comprehensive durability and longevity assurance due to shear number of potential weaknesses and component interactions.

None
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