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. 19: Arlinda Huskey, NREL

Number

Comment

Recommended Response

Rcmd. Action

19.1

Overall document: Generally agree that duplicate sections may be deleted since they are included in the most current versions of the standard.

What duplicate sections?

TBD

19.2

1.5.2.6: The definition for maximum voltage should state if an average or instantaneous.

It’s a good point. Since the effects of voltage that exceeds the ratings of devices connected to it can be instantaneous, this voltage should be based upon instantaneous values. It’s Section 1.5.2.7 though.

Add “instantaneous” to the definition.

19.3

1.5.2.8: The definition for maximum current should state if an average or instantaneous.

See response to Comment 19.2 – same principle.

Add “instantaneous” to the definition.

19.4

1.5.2.12: The definition of turbulence intensity is confusing. The standard deviation of wind speed divided by the mean wind speed based on 1-minute averaged data that is sampled at 1 Hz.

It comes down to whether “1-second wind speed data” or “that is sampled at 1 Hz” is less confusing. The substance is unchanged. I think Husky’s phrasing is clearer.

Reword 1.5.2.12

19.5

2.1: Include reference to Annex H for small wind turbines.

Need clarification on how Appendix H exists in the latest version of IEC 61400-12 (which I don’t have)

Seek guidance at Windpower 2009

19.6

2.1.5: This section may be in conflict with Annex H section e) of the standard. The standard states, “In order to minimize differences in results due to wiring between the turbine and the load, the connection to the load shall be no closer than the base of the turbine tower and no farther than three times the tower height.”

See response to Comment 17.4. Annex H will not sufficiently account for realistic wire run losses.

None

19.7

2.1.14.3: Very confusing wording and some turbines do not have sustained output.

It is confusing, but it is a difficult concept to describe. The committee’s intent to ensure that the reviewers can ascertain whether the turbine is regulating its speed and power. To do that they need to see field data on the behavior of the turbine beyond its regulation point.

None

19.8

4.1: This section states, “A quick check of the rest of the structure for obvious flaws or hazards shall be done and if judged needed, additional analysis may be required.” What is a “quick check”? Is it an analytical or observational check?

This is guidance to the technical reviewers, essentially allowing them to identify design aspects beyond the nominal load path that concern them. The phrase “quick check” is meant to convey that detailed analyses of all aspects of the turbine structure are not to be required.

None

19.9

6.1.7: What is the strength and safety report? Is this the simple equations or aeroelastic modeling results from section 4.1? Or is it the safety and function report?

It is the manufacturer’s documentation responding to all of Section 4

None

19.10

8.1.3: This section requires the manufacturer to be familiar with duration testing and that is not always the case. I do not think manufacturers will always know how changes to a turbine will affect the duration test results.

It’s a moot point for the first two years since all changes must be reported. But, it’s a good point once it becomes the manufacturer’s call and it probably could use some further clarification. That clarification may take some time to craft and it may best be disseminated in a technical note. We can add this after adoption since we do have some time.

Ask committee and/or SWCC to recommend further guidance

No. 20: Jeff Gigoux , Mariah Power (manufacturer)

Number

Comment

Recommended Response

Rcmd. Action

20.1

… to ensure the current standards do not preclude a vertical axis wind turbine (VAWT) from being certified under this proposal.


In order to alleviate this potential issue, we propose building a primary standards set that all turbines must meet (performance at a standard wind speed, for example) and then have segmented sub-standards that are specifically applicable to a HAWT and VAWT type of technology. By doing so, this will help alleviate many of the objectionable requirements we have identified as not applicable or different for a VAWT in an urban wind environment. Our goal is to ensure the standards requirements

are appropriate, sustainable and still meet the stated objective in the foreword regardless of axis orientation:


“The goal of this standard is to provide meaningful criteria upon which to assess the

quality of the engineering that has gone into a small wind turbine meeting this

standard, and to provide consumers with performance data that will help them make

informed purchasing decisions. The standard is intended to be written to ensure the

quality of the product can be assessed while imposing only reasonable costs and

difficulty on the manufacturer to comply with the standard.”

The committee has always intended the standard to be “axis neutral”

N/A

20.2

Page iii, Table: There are currently 7 HAWT manufacturers listed as participants. With no VAWT manufacturers included, this tends to create a document that is biased towards only a single technology, and even more so when considering that it is chaired by a HAWT manufacturer. We would like to recommend that Sandia National Laboratory be asked to review this document as well, since they are experts in VAWT. This will help ensure the document is representative of the small wind turbine industry, and not just small propeller turbine manufacturers.

There were no VAWT manufacturers active during the period that the committee did most of its work (2004-2006), but we were mindful that there would be VAWT’s to be certified. We deny that there is bias and state ready to address any specific discrimination identified. A review by Sandia is not warranted.

N/A

20.3

Also, Tracy Twist of Mariah Power participated vocally in a number of meetings, and would ask for acknowledgement on the list of participants.

According to my meeting records those were SWCC meetings not AWEA committee meetings, but it’s entirely possible that the record is incomplete.

Ms. Twist will be added

20.4

Page 1 – section 1.3.2: Please add “In a VAWT this equates to the rotor width times the rotor length of 200 m2 or less.”

The definition of “swept area” in Section 1.5.2.11 covers VAWT’s more accurately than the requested language. For example, consider a tropiskien Darrieus.

None

20.5

Page 2 – section 1.4.1: Can you please add in information on how an agency becomes licensed to provide AWEA certification and a web address that will provide links to licensed agencies when they become available?

AWEA will not license certifying agencies. SWCC is the one specifically established to certify small wind turbines to the AWEA standard. UL is rumored to be interested as well.

None

20.6

Page 2 – section 1.5.2.2: Why is wind speed of 5 m/s used instead of 5.35 m/s for class 3?

That was the wind speed the committee accepted after I proposed it in 2004. I chose it because it is a round number representative of the residential market. The DOE wind classes were not a consideration.

None

20.7

Page 2 – section 1.5.2.3: One of the biggest issues our industry faces is noise. It is important that we create a standard that will make noise levels clear to consumers. We fear that the 95% rule to pass the standard will allow noisy turbines to receive a passing grade which, as written, does not assist consumers in making decisions. This is especially true for urban and suburban areas, the largest projected growth markets for small wind turbines. We feel this section needs to be expanded to protect these customers, as explained below.


People do not complain about wind turbine noise from their operation when the wind is low. People object to the noise that some turbines make during higher wind periods. A turbine that is quiet 95% of the time, but sounds like a chainsaw the other 5% when the neighbors are trying to sleep, is not a

quiet turbine. Under the standard as written, all turbines, would get a good rating, even though many people currently are or will be unhappy with the noise they make. A case in point is the recent study

of roof-mounted turbines in England. There were several turbines with very good performance, that were removed due to noise and excluded from the study, yielding a virtually worthless study of only those that were poorly sited. One of the main conclusions is that noise can be an issue in urban environments, even if wind conditions are adequate. If the new standard is going to the trouble of measuring noise, it should at least make it a useful measurement that is meaningful to consumers.


We recommend that the wind speed for noise measurement should include the actual measurement at 11 m/s, or rated power. In other words, that a rated noise be declared, not just a rated power. This gives consumers tools to understand the differences between turbines along every measure that is important during the turbine’s performance.

I believe the Warwick Trials turbines referenced were shut down due to structural noise in the buildings they were mounted on. That has more to do with vibration than acoustic noise. But, the point about peak noise is valid and it was a hot topic at the committee. The consensus that emerged was that many noise ordinances are crafted along the lines of exceedence thresholds and that we should adopt a similar approach. We also wanted the noise levels to be weighted by their likelihood of occurrence. We believe that is more important than reporting the peak. The sound level at 11 m/s would not be the peak for many turbines anyway. The Summary Report, Section 6.1.1, requires manufacturer’s to make the complete sound curve available to the public and this should help alleviate your concern

None

20.8

The second part of the problem with this standardization is that the sound measurement is taken from a distance of 60 meters. While this distance will certainly cut down on the perceived noise of the

turbine, this assumes that only rural applications are under consideration, and if written into the standard as such, it will make it very difficult to improve local zoning laws in suburban or urban areas when the reference distance for noise is well out of the scale with most property sizes. We

recommend a sound rating should also be added that is recorded at the base of the tower, or very close to the base – say 1 or 2 meters away. This also gives a more true reading of noise from the turbine itself, versus other background noise factors.


At a minimum, both the noise at 11 m/s or rated power, and average noise from 5 m/s wind speed distribution should be included. Likewise, measurement at or right next to the base of the tower should be added in addition to the 60 meters, for both wind speeds.

It is very valuable to consumers to have a comparable sound rating for all certified small wind turbines. Creating two reference distances would greatly diminish this value. It is fairly easy to calculate sound pressure levels for different slant distances and there is nothing to stop a manufacturer from presenting additional ratings at shorter distances.

None

20.9

Page 4 – section 2.1.4: We are concerned that this section may be misinterpreted to mean a 10 m hub height is required for all turbines. Please expand the first sentence to read:


“The wind turbine shall be installed using the manufacturer's specified mounting system with the rotor installed at the manufacturer’s recommended hub height on that mounting system.”

This recommendation seems redundant and leaves out the possibility that the manufacturer has no recommended mounting system.


See related response to Comment 5.1.

None

20.10

Page 6 – section 3.1.2: This should be the required, not preferred method for taking acoustic measurements. It is required for power data, it should be required for other data too.

See response to Comment 17.8

None

20.11

Page 6 – add section 3.1.7: The acoustic measurement shall include acoustic measures at 2 meters from the base of the wind turbine, in addition to 60 meters from the base. This will provide consumers

with meaningful data and a basis for extrapolation to points between 2 meters and 60 meters from the turbine, should shorter distances be used in their particular property or setting.

See response to Comment 20.8

None

20.12

Page 6 – section 4.1: Include minimum strength and safety evaluation for VAWT components (airfoil, struts, main shaft), not just HAWT.

The intent here is clear as written. The strength will be reviewed along the primary load path(s). On a VAWT with struts, the struts will no doubt be reviewed.

None

20.13

Page 6 – section 4.2: See comment below: Page 7, Section 5.2.6: “Some wind turbines are designed to operate supercritically (rotating above resonance) the same as a jet engine. Add - “Supercritical operation shall not be reported as a problem if it is part of the turbine-pole design, and has not been proven to cause a structural failure.”

This is unnecessary. While the industry does not use the term “supercritical”, it has been common practice for a long time for turbines to operate above the lower natural frequencies of the system.

None

20.14

Page 7 – section 5.2.2: We do not believe the duration test of a minimum of 25 hours at 15 m/s or greater is applicable to wind turbines designed specifically for low wind conditions, that will employ braking measures at wind speeds equal to or greater than 15 m/s. We recommend the high wind

operation (duration testing) be based upon the operating range of the turbine and the declared survival speed for the wind turbine, so that the data is meaningful in the conditions the turbine is intended to operate in.

The committee wants to see that turbines can handle themselves in high winds because that had been a problem with some popular products in the past. The committee specifically increased the high wind speed data requirement over IEC 61400-2 for that reason. All certified turbines should pass the same duration test.

None

20.15

Page 7 – section 5.2.6: Some wind turbines are designed to operate supercritically (rotating above resonance) the same as a jet engine. Add - “Supercritical operation shall not be reported as a problem if it is part of the turbine-pole design, and has not been proven to cause a structural failure.”

See response to Comment 20.13

None

20.16

Page 7 – section 6.1: Add that the reports for each section may be released independently, specifically that the report for the Duration Test may be released following the release of other report sections.

All reports can be released by the manufacturer. Only the Summary Report, Section 6.1.1, is essentially required to be made public.

None
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