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




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НазваниеMaterially Affected Party Comments to awea draft Standard 1 – 2009, “Small Wind Turbine Performance and Safety Standard”
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No. 10: Alex Murley, British Wind Energy Association (BWEA)

Number

Comment

Recommended Response

Rcmd. Action

10.1

General – The document makes direct reference to the IEC 61400 standards suite, specifically parts 2, 11, and 12, however the clause references indicated are now incorrect. This appears to be due to the references relating to the previous versions of the IEC standards, and therefore needs to be updated to reflect the current issue of each. For reference the current issues are 61400-2:2006, 61400-11:2003, and 61400-12-1:2006.


Specifically the references need to be amended as follows;


Points 2.1.1, 2.1.3, 2.1.4, 2.1.7 refer to section 2.1, when it should be 5.1

Point 2.1.8 should refer to section 5.2.1.

Point 2.1.9 should refer to section 6.1

Point 2.1.10 should refer to section 6

Point 2.1.11 should refer to section 6.4

Point 2.1.12 should refer to section 6.6

Point 2.1.13 should refer to sections 7.3 and 7.4 instead of 4.3 and 4.4 respectively

Point 2.1.14 should refer to section 7.6

Point 2.1.15 should refer to section 8.1. Also Equation 5 should be Equation 3, and Equation 6 should be Equation 2

Point 2.1.16 should refer to section 8.3

Point 2.1.17 should refer to section 9 and clause 6 should be clause 9

Agreed – Thank you

The references will be updated.

10.2

With regard to point 2.1.7 concerning battery voltage, we’d suggest that this be amended in line with the BWEA standard point 2.1.7 i.e. that the manufacturer declares a nominal voltage between 2.1 and 2.5 volts per cell, and that the regulator maintains the voltage within 10% of nominal. This then allows manufacturers to use batteries other than 2.1 volts per cell. Equally 1 minute average load should be within 5% of nominal.

The BWEA provision would allow a manufacturer to charge a lead-acid battery to abnormally high voltages. 2.4 volts per cell is an equalization charge on a lead-acid battery, which is only used for maintenance on an occasional basis (under 5% of the time). Testing at these “extreme” battery voltages would not fairly characterize the performance a customer could expect since they will not operate their systems with such high regulation set-points. The power curve would, therefore, be optimistic. The use of other types of batteries with higher regulation points (eg, NiCad) is extremely rare. It is more valuable to consumers to standardize the test conditions than it is to accommodate a rare application.

Keep the current language and discuss this problem with the BWEA.

10.3

With regard to point 2.1.8 concerning the minimum distance between turbine and met mast, we’d suggest that this should be amended to be between 2 – 4 rotor diameters subject to a minimum of 3m.

This is a good clarification.

Make recommended clarification

10.4

With regard to section 3 on acoustic noise testing, we’d suggest that the same noise mapping methodology is adopted as that within section 3 of the BWEA document. Whilst inherently there is no issue with the approach of the AWEA document (it effectively follows the IEC standard), we feel that noise emissions are something little understood by planning authorities and the public at large, and that a more easily understood or graphical representation of what can be expected is beneficial. This is the major area of difference between the BWEA standard and the AWEA standard and the BWEA standard gives clients, manufacturers, planning authorities, and installers a very easily understood outcome. In this respect we suggest that the BWEA document’s use of red/yellow/green sectors is replaced by a contour map. Using a contour map will make it easier to relate to local planning (zoning) regulations in various locations.

The BWEA approach is tailored to the market needs in the UK, but would cause great confusion and real problems in the U.S. Noise contour maps are not in common use and noise restrictions (red zone) vary by jurisdiction. The simplicity of the AWEA approach (one number, comparable between products) is more valuable than the greater “fidelity” of the BWEA approach. The underlying (IEC 61400-11) data is the same.

None

10.5

With regard to acoustic averaging periods, we’d suggest that the wording be amended to be a minimum averaging period of 10 seconds, so that 1 minute averages are still valid. In that way the data logger setup used for power performance measurement, can also use the same data for noise.

Seems reasonable, but would like to discuss with members of the committee with more experience with acoustic testing

Discuss with committee at Windpower 2009

10.6

Regarding the duration test referenced in section 5, we’d suggest that both AWEA and BWEA standards should amend section 9.4.1 of 61400-2 so that the sample period is 1Hz and the averaging period remains at 10 minutes. It seems odd to suggest a sample period of 0.5Hz for durability, when 1Hz is used for power performance measurement. Equally it seems sensible to average over 10 minute durations for durability due to the quantity of data collected.

0.5 Hz is half the frequency of 1 Hz, so the sampling rate is lower. This is appropriate for the duration test. The averaging needs to stay at 1 min so that the ability to fill the high wind speed bins is not degraded.

None

10.7

The references shown in section 9 would need to be amended to reflect these changes.

Section 5 of the AWEA standard?

TBD

No. 10: Sven Ruin, Flexenclosure, Sweden (manufacturer)

Number

Comment

Recommended Response

Rcmd. Action

11.1

It would be better to enforce the use of IEC 61400-2 Ed. 2 than to create national standards. This IEC standard has to be fulfilled anyway for export from the US to some other countries.

The decision to create a new standard based on the IEC standard was made ~ 6 years ago for substantive reasons relating to costs and consumer value. Those reasons remain valid today.

None

11.2

One problem with the AWEA draft SWT standard is that the support structure (tower etc) is not seen as part of the wind turbine. We have at least one example from a Swedish SWT manufacturer, which shows that such an approach has led to total failure of the SWT.

See response to Comment 6.5

None

11.3

If the AWEA draft SWT standard would be taken further that the draft stage, it is important to first harmonize it better with related international activities. It would be of particular advantage, if the labeling part is harmonized with IEA Wind Task 27 and BWEA.

We are satisfied that our labeling scheme is appropriate for the U.S. market and we respect other counties differing views for their own citizens. Recognizing these differences it is probably better to not try to harmonize the presentation parts of the standards.

None

No. 12: Rem Pacheco, State of New Mexico (Electrical Bureau Chief)

Number

Comment

Recommended Response

Rcmd. Action

12.1

Upon reviewing the proposed AWEA Small Wind Turbine Performance and Safety Standard 9.1-2009 I find that it is devoid of meaningful electrical safety standards. While it may cover acoustic, strength & safety, labeling and duration tests the proposed standard does not adequately include, or make reference to electrical safety standards, for electrical components, such as generators, inverters, disconnects, overcurrent protection, grounding, etc. The National Electrical Code NFPA 70 contains electrical safety provisions that address these electrical components. Also, the electrical wiring system between the turbine and the load falls under the provisions of the National Electrical Code.   

See response to Comment 8.1

Discuss with committee at Windpower 2009

12.2

In addition, UL 1741 and IEEE 1547 are safety standards for inverters, converters, controllers and interconnection system equipment for use with distributed energy resources and compliance with these standards is not included nor are these safety standards referenced in the proposed standard.  The only referenced standards are the International Electrotechnical Commission (IEC) 61400.

See response to Comment 8.1

Discuss with committee at Windpower 2009

12.3

It is my opinion that in order to make this proposed standard a comprehensive safety standard a new section should be added that would include electrical components, or add electrical provisions to the existing sections.

See response to Comment 8.1

Discuss with committee at Windpower 2009

No. 13: Jeremy Lewis, State of New Mexico (Energy Conservation and Management Div.)

Number

Comment

Recommended Response

Rcmd. Action

13.1

One concern refers to Section 8.2 below:

For the first two years after turbine certification the manufacturer is required to notify the certifying agency of all changes to the product, including hardware and software. The certifying agency will determine whether the need for retesting and additional review under the guidelines provided in Section 8.1.

Since the changes made to any product could significantly reduce or increase their Rating, turbine manufacturers should be obligated to alert the certifying agency of changes to their products for as long as their products are manufactured.

The committee’s intent was to cover the product’s “teething period”, during which operation problems would be addressed by the manufacturer. It was assumed that after that any product changes would be beneficial. But, in light of some Asian products that have entered the market in the last few years it may be prudent to require reporting over the entire validity of the certification.

Discuss with committee at Windpower 2009

No. 14: Gerald LeBow, Zephyr Corporation (Japan) (manufacturer)

Number

Comment

Recommended Response

Rcmd. Action

14.1

The draft of the proposed standard calls for a reference turbine output measurement to be made at a wind speed of 11 meters per second ( Section 1.5.2.1 et.al.). We understand the history of the Committee’s desire to offer the consumers a comparable standard reference so they can evaluate different small wind turbines in a similar light. We also understand some committee members’ desire for this lower speed even though it is not in compliance with the IEC and ANSI standards.


That said, we believe that the consumer would be better served if they were presented with the full power curve over a wide range of wind speeds, as tested by a sanctioned testing laboratory. Consumers could look for the wind speed appropriate to their location and then see which small wind turbine(s) is (are) the most appropriate.


Picking any reference value, especially a low value like 11 meters per second, may prejudice State subsidies some of which are based on turbine power rating. This could possibly result in higher subsidies to wind turbines, which are optimized, for 11 meters per second and lower subsidies for those, which are not.


If the committee feels compelled to pick a single reference wind speed, we would suggest compliance with current IEC and ANSI standards, which use 12.5 meters per second as their reference. Manufacturers should still be required to report their entire power curve so relevant data for the consumer is available for a wide range of wind conditions.

The committee views “Rated Power” as a necessary evil and they expect the “AWEA Rated Annual Energy” parameter to largely replace it. But they also recognize that Rated Power is a seductively simple parameter that will continue to be used. There is an overwhelming consensus for 11 m/s in spite of any resulting problems with subsidy programs based on capacity. The committee specifically turned down a proposal from the Chair at its meeting at Windpower 2008. Manufacturer’s are free to provide the entire power curve, but we cannot move from the 11 m/s requirement for the “AWEA Rated Power”

None

14.2

Regarding passive power control, we believe that fluttering of blades ( Section 2.1.15 et.al.) should be avoided in all instances. It causes increased stress on blades and may cause them to fail prematurely. In addition, increased noise is generated when blades are fluttering. Fluttering should not be used to slow or retard a small wind turbine in heavy wind as a means of power control. We suggest that an active braking means be employed when the turbine needs to be controlled or stopped.

When the AWEA standard was first drafted there was a major small wind turbine product that did use flutter. That product no longer relies on flutter and I am not aware of a commercial product that still does. Therefore, it is appropriate to remove the reference to flutter in this section. However, furling is still an oft used passive overspeed control method and it would not be appropriate to disallow its use.

Remove reference to fluttering
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