AEMO review of

technical
requirements for
connection final
report: Appendix 2
22 December 2023

Stakeholder consultation analysis

and revised recommendations –
NER Schedules 5.2 & 5.3a

1
Important notice
Purpose
This is Appendix 2 to the Final Report published as part of AEMO’s periodic review of the technical requirements for
connection in the National Electricity Market under clause 5.2.6A of the National Electricity Rules.

Disclaimer
This document does not constitute legal or business advice, and should not be relied on as a substitute for obtaining detailed
advice about the National Electricity Law, the National Electricity Rules, or any other applicable laws, procedures or policies.
AEMO has made reasonable efforts to ensure the quality of the information in this document but cannot guarantee its accuracy
or completeness.

Accordingly, to the maximum extent permitted by law, AEMO and its officers, employees and consultants involved in the
preparation of this publication:

• make no representation or warranty, express or implied, as to the currency, accuracy, reliability or completeness of the
information in this publication; and

• are not liable (whether by reason of negligence or otherwise) for any statements, opinions, information or other matters
contained in or derived from this publication, or any omissions from it, or in respect of a person’s use of the information in
this publication.

Copyright
© 2023 Australian Energy Market Operator Limited. The material in this publication may be used in accordance with the
copyright permissions on AEMO’s website.

AEMO acknowledges the Traditional Owners of country throughout Australia and recognises their continuing
connection to land, waters and culture. We pay respect to Elders past and present.
Contents
1 Update report submissions 4

2 General feedback 5

3 Schedule 5.2 feedback 10

4 Schedule 5.3a feedback 80

5 Multiple schedule feedback 82

6 Structural amendments feedback 83

7 Consequential amendments feedback 84

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 3
1 Update report submissions
AEMO received the following submissions on its update report:

1. Akaysha Energy 13. Huawei Australia

2. Amp Power Australia 14. Hydro Tasmania

3. AusNet 15. Marinus Link

4. Bo Yin 16. Neoen

5. Caterpillar 17. Powerlink

6. CEC 18. SA Power Networks

7. CPSA 19. Siemens Gamesa Renewable Energy Pty Ltd

8. CT LAB 20. Solar Turbines Sagl

9. ElectraNet 21. TasNetworks

10. ENA 22. Tesla

11. Energy Queensland 23. Transgrid

12. Goldwind

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 4
2 General feedback
General feedback

General issue Summary of feedback provided – general AEMO response

Negotiation framework and CEC Under NER 5.2.6A, AEMO’s review must consider whether the technical
need to meet AAS AEMO considers this to be out-of-scope for this review, however the framework is resulting in the requirements for connection to the NEM should be amended. AEMO
industry being exposed to higher CapEx and development costs without any system need for has undertaken extensive consultation with a view to recommending
additional capability. We strongly urge AEMO to consider this as part of their review. changes to automatic and minimum access standards, as well as
suitable general requirements for negotiated access standards, that can
We recommend 5.3.4A(b)(1A) be removed as it presents a barrier to upgrading existing plant and/or be expected to maintain the integrity of the power system and be
new capabilities from being implemented to existing assets where there is an overall benefit to the reasonably and efficiently achievable by a broad range of technologies
power system. expected to connect to the grid.
• The need to meet the AAS is resulting in additional CapEx and development costs to projects These recommendations have been developed to work better than the
without there being a substantiated system need. existing requirements within the existing parameters under NER 5.3.4A,
• The requirement to meet the AAS is at odds with the NEO which requires ‘…efficient investment in, including the addition of some flexibility or discretion for some aspects
and efficient operation and use of, electricity services…’. of the MAS. This may help to accommodate cases where a non-material
reduction in performance is acceptable (or potentially even beneficial) at
• We recommend this clause be removed or where the NSP or AEMO rejects a negotiated access,
a given network location.
then the level of performance that will be accepted should be proposed along with a justification
which clearly ties the rejection with an associated network need for additional performance. • While we appreciate that interpreting the ‘no less onerous’ requirement
Furthermore, we recommend there be a carveout of this clause for legacy assets that are not relative to the existing performance standards can present issues for
affected by an alteration. some alteration projects, AEMO remains firmly of the view that the
changes to the NER 5.3.4A/5.3.9 negotiating framework raised in
• This clause has been especially problematic for existing assets looking to retrofit a BESS behind
submissions by the CEC and some of its members are outside the
the existing connection point. Grandfathering of these legacy assets will not discourage plant
scope of this review. The implications of these proposed options,
upgrades and /or modification that can have an overall positive impact on the power system.
together with potential alternative improvements either in drafting or in
• The CEC appreciates that AEMO is running a separate workstream reviewing the 5.3.9 process, application/understanding of the current framework, need to be carefully
however this issue is best managed as part of this workstream. and comprehensively worked through before recommending rule
Goldwind Australia changes. This should continue to progress through separate
workstreams.
We consider it just as important to address some limitations placed by the provisions under clause
5.3.4A as the changes AEMO proposed for all the S5.2.5 clauses. Clause 5.3.4A(b)(1A) specifies
that the performance standard must be no less onerous than the existing performance standard
under a 5.3.9 process. However, our experience has shown that some modifications (e.g. retrofitting
grid forming capabilities) may lead to small reduction in performance for some aspects of the GPS
(e.g. active power recovery time, reactive power and voltage rise/settling times) but with a net
positive effect on the network around them. This clause would preclude and likely discourage such
changes due to the risks associated with a drawn out 5.3.9 process.
Furthermore under clause 5.3.4A(b1) there is a requirement to aim for the AAS even when modifying
existing generators. This presents a sizeable risk for projects considering expansion or addition of
BESS since there is a risk AEMO and/or NSP can request for higher performance standard even for

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 5
 General issue Summary of feedback provided – general AEMO response
existing plant. Not only can this end up in requiring lots of engineering effort to investigate the
headroom to meet AAS which constitutes a time and cost risk to the project but also be forced to
install costly hardware to meet the demands of the AAS. This prevents projects to augment BESS
which can be a net positive contributor the network.
We propose both clauses are removed from the rules.
Neoen
There should be a clear requirement for the NSP and AEMO to justify the need to meet AAS under
any clause. NSPs and AEMO should have to provide evidence to support their decision (e.g. by
presenting results of the studies) when rejecting negotiated standards. The proponents are required
to do so under 5.3.4A(b2) however AEMO and NSPs don’t have the same obligation making the
negotiation process uneven from the start. At the moment typically AEMO and NSPs reject
negotiated standards as a starting point in all negotiations and only agree to them towards the end of
the process if the proponent can show via extensive studies that they can’t in any way or shouldn’t
(e.g. due to a detrimental impact on the network) meet the automatic standard. We don’t think this
was the intent of the framework established under 5.3.4A.
Tesla
Although it has not been specifically considered within the NER clauses proposed to be changed by
AEMO, we would suggest that as this progresses to a Rule Change, AEMO should also update the
language used in rule 5.3.4A(1A), specifically deleting the phrase “no less onerous”. This wording is
currently creating challenges in respect of BESS assets transitioning from grid following inverters to
grid forming inverters.
• Currently there is no special provision or acknowledgment in the NER of the unique operating
characteristics of grid forming assets. They are treated the same, and subject to the same
connection requirements as all asynchronous plant. However, they have different technical
performance characteristics.
• Industry would benefit from an update to rule 5.3.4A(1A) clarifying the intent is not to prevent the
transition from grid following inverters to grid forming.
Fast-track rule change process ElectraNet AEMO acknowledges that some proposed changes are more
ElectraNet shares AEMO’s view on the timeliness for AEMO to review technical requirements for contentious than others. However, the level of consultation undertaken
connection to ensure they are fit for purpose as we see the rapid and ongoing changes to the NEM for this review has been extensive, particularly in relation to schedules
power system. However, ElectraNet has reservations about progressing a number of the proposed 5.2 and 5.3a. There have been multiple opportunities provided for input
rule drafting changes via the fast-tracked process noted in 1.5.4 p10 of the published and AEMO has updated its recommendations based on consideration of
recommendations report. The measure of what could be fast tracked and what may need to go feedback on each occasion. AEMO therefore considers that there is
through the normal Rule change consultation processes is currently unclear, unjustified and it is scope to propose a fast-track process for most recommended rule
noted that some aspects of the proposed changes materially affect the application of the Rules changes. As noted in several submissions, aspects of the current
beyond the negotiation of access standards. standards are causing confusion or unnecessary barriers to connection
and it is particularly important to implement improvements as soon as is
ENA – caution on use of fast-track approach feasible to facilitate the energy transition.
ENA is supportive of improving the access standards, so they are fit for purpose for a future power Ultimately the AEMC will determine whether a fast-track process
system at the earliest opportunity. ENA is also supportive of AEMO’s efforts to involve stakeholders proceeds and the extent of any rule made under that process.
throughout this process. However, we have reservations about progressing the rules drafting as a

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 6
 General issue Summary of feedback provided – general AEMO response
fast-tracked process given the extensive nature of the review. The measure of what could be fast
tracked and what may need to go through normal consultation processes is currently unclear.
Powerlink
Powerlink recommends AEMO not recommend the Rule change is fast-tracked, given two rounds of
consultation would be prudent to ensure all relevant impacts are captured in amendments to the
Rules.
Tesla
While we acknowledge the work done by AEMO in running multiple forms of consultation already, we
would caution against an expedited rule change process. The proposed changes to the NER are
comprehensive and wide-reaching. AEMO’s consultation process has been incredibly engaged,
however this does not mean that industry has not missed potential issues; nor that unforeseen
impacts of some of the proposed changes may not come up. An additional benefit of the AEMC
running a standard rule change process is that the AEMC approach to considering the impacts of a
Rule Change will also differ from the approach taken by AEMO, which may highlight different
perspectives.
Overly prescriptive approach to ENA – cautions on overly specific approach AEMO agrees that an overly prescriptive approach is generally
specification of technical ENA recommends that AEMO avoids an overly prescriptive approach to ensure technical undesirable, and has sought to include flexibility in the technical
requirements requirements for connection remain appropriate throughout the energy system’s transition. Some of requirements.
AEMO’s proposed changes include guidance for engineering judgements and may be inappropriate On the items in Powerlink’s detailed response that it specifically
in the NER. An adaptive approach where market participants, NSPs and AEMO are able to apply considers to be overly prescriptive:
engineering knowledge and make judgements to reflect a connecting plant’s specific circumstances • Powerlink is not supportive of including synchronous condensers in
and attributes better supports a balance of process efficiency and customer outcomes. S5.2, because they may be installed for a specific purpose. AEMO
Powerlink notes that the same argument could be applied to any plant. Common
Powerlink recommends AEMO: purposes of synchronous condensers are to provide fault level for
system strength, inertia to support frequency response, or reactive
• adopt a less prescriptive approach to the specification of technical requirements in the NER to power to support voltage. Each of these requirements is important for
accommodate the evolution of generation technologies and knowledge of power system power system security it is therefore important for synchronous
engineering over time. Some of the proposed changes which we consider inappropriate in the condensers to meet appropriate performance standards.
Rules include guidance for engineering judgements. We consider that improvements to overall
performance of the power system in the interests of consumers is best supported by an adaptive • Powerlink was concerned about AEMO’s drafting describing the rise
approach where market participants, NSPs and AEMO apply engineering knowledge and make time for reactive current injection to be in response to a “steplike”
judgements that can reflect a connecting plant’s specific circumstances and attributes. voltage change. AEMO notes that the concept of rise time cannot be
properly assessed, unless the input to the test is steplike.
• reassess the desirability of increasing the complexity of automatic access standard requirements
for generating systems. We consider this approach may not achieve the intended outcomes and AEMO acknowledges that in some cases it has proposed provisions to
instead favour an approach that encourages proponents to discuss their particular requirements guide the determination of some negotiated standards. In general, there
with NSPs under the negotiated access standards. is a tension between clear unambiguous requirements and flexibility that
permits engineering judgement to be exercised. Clarity and precise
TasNetworks language simplifies decisions, but can also lead to the rejection of
A detailed response to the revised draft recommendations and draft NER amendments solutions that otherwise would have been acceptable, because not all
recommended in the Update Report are provided in the attached template. These responses are circumstances can be considered in the ruled drafting. Flexibility allows
given based on the specific circumstances found in the Tasmanian network. Where there are no for engineering judgement to be exercised, but can be at the expense of
specific concerns or comments raised does not mean we do not support concerns raised by other negotiation time. Guidance has in a few cases been provided to

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 7
 General issue Summary of feedback provided – general AEMO response
network service providers based on their circumstances. We have contributed to and support Energy reconcile these potentially conflicting drivers. For example, a control
Networks Australia’s (ENA’s) submission. objective has been proposed for establishing correct tuning in S5.2.5.5,
Noting these differences, TasNetworks requests AEMO provide the ability for technical requirements which is intended to guide the negotiation around the design and
to vary between networks and parts of networks to allow a fit for purpose set of standards on settings for reactive current injection during faults.
connections to be imposed. In some cases definitions have been provided at the request of
stakeholders (including some NSPs). AEMO has, for example provided
a definition for “adequately controlled” at the request of stakeholders.
In response to TasNetworks, AEMO notes that it has accommodated
different thresholds for Tasmania and the mainland, where relaxations
to standards have been allowed based on size of plant, at TasNetworks’
request, and support from Hydro Tasmania.
Proposal to remove the defined Marinus Link AEMO acknowledges Marinus Link’s comments, but does not intend to
term frequency Given AEMO’s proposal and reasoning to remove the defined term voltage from Chapter 10 and recommend removing the term “frequency” from the glossary at this
noting also that the term “current” is not defined in chapter 10, MLPL proposes that the definition of time, as its removal has not been consulted on.
“frequency” also be deleted. The definition of frequency is:
For alternating current electricity, the number of cycles occurring in each second. The term
Hertz (Hz) corresponds to cycles per second.
MLPL considers that the term frequency is also best understood from an engineering perspective in
the context in which it is used.
Furthermore, if the above definition was to be relied upon it could prove problematic: the definition
implies that one second must elapse in order that the number of cycles occurring is known. In many
instances, however, the quantity of interest is the frequency when measured over a much shorter
timescale, potentially as small as one cycle or one half-cycle. The above definition is therefore
unsuitable for such circumstances.
MLPL acknowledges that, given the stage of the consultation in this technical standards review, it
may be too late to incorporate such a Rules amendment. However, we put the proposal forward for
consideration.
Definition of disconnection CPSA There are 127 instances of the term disconnect in the NER, some of
This term is used throughout and refers to (as defined in the NER) interrupting the flow of electricity which are intended to mean complete disconnection of everything
at the connection point. This term should not be italicised in most clauses to provide flexibility to behind the connection point, and some of which include partial
disconnect units / reactive plant not at the connection point. disconnection – for instance disconnecting a production unit, but not the
balance of plant. Of these, the existing italicisation does not always
correspond with the former meaning.
The word disconnect (without italicising) and the impact should also be
clear to an engineer, in the context of the plant that is referenced.
AEMO would therefore agree that “disconnect” without italics referring to
a production unit or part of a generating system or IRS could be less
ambiguous than the italicised version, in some usages.
AEMO does not intend to examine all uses of the word disconnect, as
that is beyond the scope of the review. However, we agree that in the

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 8
 General issue Summary of feedback provided – general AEMO response
context of Schedules 5.2, 5.3 and 5.3a there could be usages where no
italics would be less ambiguous.
Use of guidelines Neoen AEMO acknowledges Neoen’s comments, noting that the purpose, use
We would like AEMO to consider the use of guidelines in the negotiation process in this review of the and application of informal guidelines are not within scope of this
Rules. AEMO and various NSPs issue guidelines which have no legal standing in the NER, and insist review, but are part of process discussions being conducted in other
these guidelines be met to the letter as soon as they are published and in some cases even before forums.
that with guideline provided in a draft format. This is effectively bypassing the negotiated standard As a general observation, from AEMO’s perspective, the primary
pathway. Only the guidelines referenced by the NER (e.g. Power System Modelling Guideline) objective of guidelines that are not prescribed by the rules should be to
should have any impact on the connection process. promote common understanding and, as a result, improve efficiency via
The process for establishing the guidelines that the Rules currently reference must be reviewed – transparency. They should assist stakeholders to understand how
very little (if any) consultation appears to take place with the wider industry before the guidelines are relevant NER requirements are likely to be interpreted and applied in
issued/revised and there is no time allowed for projects to react to the new requirements. Rules are making assessments and decisions under the NER that involve a
silent on notice that must be given before guidelines are amended, the consultation period and the degree of discretion or judgment, including the balancing of individual
transitional arrangements when updated guidelines are published. The NER should describe the interests and circumstances with broader responsibilities and
consultation and application process in detail. Additionally, many matters for which AEMO has requirements for security, quality and reliability of supply in the interests
applied guidelines are matters for which the Generator has direct and sole responsibility – and bears of all network users.
all risks – under the NER. While we appreciate that AEMO is expressing "care" that other Participants
operate according to AEMO's (perceived) ideal, this is not part of AEMO's role under the NER or the
NEL. We are concerned that these matters hinder the ability of Participants to deliver efficient
outcomes according to the NER and the NEO.

© AEMO 2023 | Appendix 2. Update report stakeholder consultation analysis and revised recommendations 9
3 Schedule 5.2 feedback
Schedule 5.2 Conditions for Connection of Generators

NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
NER S5.2.1 – Outline of requirements
Application of Schedule 5.2 AusNet – Supports Many respondents did not comment on this issue, indicating that the
based on plant type instead of AusNet supports AEMO’s revised recommendation. general support for the principle articulated in responses to the draft
registration category and report still holds. Of those that raised concerns, most were from TNSPs
extension to synchronous Caterpillar – Clarification on classification of generators as Small or Large Generators (ElectraNet, Powerlink and TasNetworks) seeking flexibility to apply
condensers It is proposed to classify synchronous generators (as Small- and Large Generators) based on some but not all requirements of schedule 5.2 to synchronous
their individual unit capacity (MW) instead of the aggregated plant capacity. Synchronous condensers, or exclude synchronous condensers that are network
generators are autonomous units (an indivisible set) which can generate electrical energy such assets.
that the frequency of the generated voltage, the generator speed and the frequency of network The point that NSPs may install synchronous condensers for different
voltage are in a constant ratio and thus in synchronism. These units can be started and stopped purposes could equally be applied to synchronous condensers installed
independently; therefore, should be considered individually in determining the classification as by other parties. AEMO considers it is important for secure and
Small- or Large Generators. predictable system operation for similar types of plant to have
ElectraNet – Opposes the requirement for technical performance obligations for NSP comparable performance, whether they are operated as part of a
owned synchronous condensers network or connected to it. AEMO’s recommendation acknowledges the
While ElectraNet agrees that there are benefits to defining technical performance obligations for NSP’s broader responsibilities for its network and provides flexibility to
synchronous condensers, the effects of including network equipment in schedule 5.2 significantly establish standards within the ranges allowed under schedule 5.2.
changes the obligations of NSPs with material financial and resourcing implications that require In relation to Powerlink’s submission, AEMO has not proposed that all
further justification and consultation. It is not clear why the existing planning, modelling and schedule 5.2 requirements would apply to synchronous condensers
commissioning obligations of NSPs with regard to network augmentations are not sufficient for (rather a subset, with modifications as applicable), and at this stage has
network owned and operated synchronous condensers. not proposed that any schedule 5.2 standards would apply to
Powerlink – Partial support; Alternative proposed standalone SVCs or STATCOMs.
• Powerlink appreciates the intentions and agrees some performance standards should apply to Transgrid considered it is unclear how the requirements would apply to
dynamic plant connecting to the network. However, the whole of Schedule S5.2 should not a synchronous generator that is also able to operate as a synchronous
apply to synchronous condensers, SVC and STATCOMs, particularly for plant that has been condenser. AEMO’s view is that many of the access standards
installed to address a specific purpose. We consider NSPs and AEMO should retain discretion requirements would be common to both operating modes, but if different
to apply relevant subclauses for these classes of plant. there would be scope to describe that difference in the performance
standard, within the range of the negotiated access standards.
• Powerlink does not support the default inclusion of synchronous condensers into the S5.2
standards. Transgrid also queried how NER 5.3 would apply to negotiation of
standards for plant owned by NSPs. In terms of setting appropriate
Solar Turbines standards within the Schedule 5.2 range AEMO does not see that this
It is recommended a classification that as much as possible permits to define requirements should raise particular difficulties, as the NSP would be in a good
associated to components of the unit rather than a complete system. This would help position to understand both the capability of the plant and the needs of
manufacturer in provide and design a suitable product, it would help integrators in complete the the network to propose performance standards within the range of the
access standards. In terms of the ‘negotiating’ process, AEMO’s

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
plant assessment, it would permit to speed up a process which seems to be frequently pretty long indicative drafting recognises that an NSP cannot ‘agree’ access
and complex and it would limit cost associated to compliance verification. standards with itself and the process is one of establishing and
We also consider, as a general comment, that requirement shall not necessarily be technical documenting standards. AEMO acknowledges the clauses relating to
agnostic, but vice versa shall be tailored to best use the specificities of each technology. This the negotiating process (particularly 5.3.4A and 5.3.9) may require
should be valid also for mixed plants (plants with multiple technologies) additional drafting to eliminate any ambiguity about their application to
NSPs as Schedule 5.2 Participants but not Connection Applicants.
• It is difficult to evaluate if the proposed changes would go in such direction. AEMO will clarify this in its rule change proposal.
TasNetworks – Supports in principle; alternative proposed Solar Turbines suggested refocusing the technical standards to unit
• TasNetworks is supportive of the broad principle of applying Schedule 5.2 based on plant type level. This approach has been taken in many overseas standards where
rather that registration category. We remain concerned that there may be situations where the focus is on proving equipment is suitable for use rather than
basing standards solely on the type of technology could be unnecessarily restrictive. The same establishing performance at the connection point. While AEMO
technology could operate in different ways depending on whether it is a load/generation or a acknowledges these benefits, this change could result in a negative
network and therefore the performance expectations may be different and should be reflected level of injection at the connection point, which is not desirable and
in the ability to apply Schedule 5.2. would represent a major shift from the performance standards approach
Transgrid – Supports adopted in Australia in the early 2000s. AEMO is not in a position to
recommend such a significant change at this stage of the Review.
• Transgrid supports applying NER S5.2 to synchronous condensers connected by a participant
Caterpillar suggested that synchronous condensers should be
other than a Generator or Integrated Resource Provider (i.e. an NSP).
considered individually from the perspective of classification as small or
• Considers that the negotiation of performance standards is unclear for synchronous large. However, any MW/MVA ‘thresholds relate to the impact of the
condensers owned by an NSP. While NER S5.2.5.1(b1) sets out how the process differs, NER generating system as a whole, not the impact of individual units. AEMO
5.3 will still apply to a synchronous condenser owned by a NSP (as stated in the modified table does not see benefit in differentiating between synchronous and
under 5.1.2). NER 5.3 is ambiguous when applied to NSP owned synchronous condensers asynchronous plant for these thresholds. The capability to be stopped
where the connection applicant is the NSP. and started independently is not the most relevant characteristic.
• It is unclear how the requirements of NER S5.2 would apply to a synchronous generator that is Final recommendation
also capable of operating as a synchronous condenser. Would: Considering all feedback, AEMO will retain its Update Report
– The negotiated access standard be defined by the lowest performance: or recommendation.
– Separate access standards apply for generator and synchronous condenser modes of
operation.
Siemens Gamesa
• SGRE support these changes.
NER S5.2.5.1 – Reactive power capability

Voltage range for full reactive Ausnet Supports – with addition A majority of stakeholders who responded to the draft report supported
power requirement AusNet supports AEMO’s revised recommendation in principle. However, for S5.2.5.1 NAS c(3), the proposed amendments. Some stakeholders indicated a concern that
it is suggested to change to the following wording including the voltage-dependent reactive power the mid-point selection might lead to a reactive power requirement
requirement: specified for higher than 110% of nominal voltage. AEMO made
clarifications to address this issue in the update report and indicative
“may include negotiate a limit that describes how the reactive power capability varies as a rule drafting.
function of active power level or voltage level due to a design characteristic of the plant”
Bo Yin, AusNet and Caterpillar suggested more restricted reactive
power ranges for weak grids, or to require less oversizing of plant.
However, AEMO notes this access standard has broad scope for

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
AusNet believes that the efficient voltage-dependent reactive power curve should be as follows, negotiation of lower requirements where appropriate. AEMO
which can form a basis for the NAS. It can be provided in the assessment guideline or approach acknowledges the proposed AAS is more onerous than many
paper setting up as a recommenced negotiation principle. international standards, but it should be noted that those are mostly
• For a key voltage bus node where the voltage is meant to be tightly controlled, the UQ profile mandatory standards.
similar to the GB grid code (as mentioned in Bo Yin’s response to the Draft Report) utilises On the other hand, Transgrid preferred the AAS to remain as is, and
plants’ capability more effectively which takes the high 𝑑𝑉/𝑑𝑄 sensitivity into account. Powerlink argues that a reduction in the AAS is not needed as
negotiation is available. Given that the NER negotiation framework
specifies the AAS as the maximum performance that can be required,
and the target level for negotiation, AEMO does not consider it
appropriate for the AAS to require performance that is essentially
unusable (full injection at very high voltage and full absorption at very
low voltage). This translates into unnecessary additional cost for
generators and does not promote efficient investment in electricity
services, as required by the NEO.
Some submissions expressed concerns about the selection of a mid-
point voltage by NSPs. Midpoint voltage is not the same as setpoint or
target voltage, but simply defines, for drafting convenience, the midpoint
of a range. However, AEMO agrees that the value specified for target
voltage should be coordinated with the range of values set for this
standard. AEMO considers that the proposed standard has a sufficiently
wide range (full absorption and injection plus full injection at low
voltages and full absorption at high voltages) to accommodate the range
of operating voltages that could be reasonably expected over the life of
the plant. For example, distribution networks are typically operated
within a few percent of nominal voltage, so a mid-point close to nominal
voltage would be appropriate in most instances, whereas transmission
voltages might be operated a little higher so a mid-point between
nominal voltage and 104% might be suitable. In any case, basic
insulation levels of network equipment would not make it practical to
have a mid-point voltage above 104%, lest the upper band (midpoint
voltage+5%) impinge on the basic insulation level of the network
• For the bus nodes that are not remote from system strength nodes on the transmission level equipment.
and are regularly experiencing bidirectional load flow may require more network voltage control
support. Under such circumstances, the wider-band UQ profile (e.g., strong grid in the image Hydro Tasmania raised a concern about inconsistencies between
above) provides more resilience assuming the Q margin (i.e., away from knee point of QV ranges set for different parties at the same location. The common party
curve) and stability margin (i.e., away from stability limits) are well maintained. is the NSP who is in a position to provide the same range to all relevant
connecting parties.
Bo Yin – Alternative proposal
Hydro Tasmania and Solar Turbines noted the shape of the
Bo Yin’s submission comments that the amount of reactive power required at low SCR to achieve characteristic does not align with the capability characteristic of
voltages in the range 90 -110% is much less than 0.395 pu because of high dV/dQ sensitivity. synchronous machines. AEMO notes that the AAS is an “at least”
BoYin suggests that AEMO should investigate the amount of reactive power actually being requirement, not a requirement to match the shape of the performance.
utilised by power plants. The current AAS also does not match the capability curve of a
Bo Yin suggests that the requirement for reactive power injection at low voltage should be synchronous machine, and it is not necessary for it to do so.
balanced against the cost of providing it. He suggests the following:

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
AEMO agrees with Transgrid that voltage dependent limits matching the
AAS requirement of S5.2.5.1 are neither necessary nor desirable, and
the drafting in S5.2.5.1 does not require such limits.
Energy Queensland suggested simplifying the requirement to be for
voltages in the range 0.95pu to 1.10pu, reactive absorption requirement
of -0.395 x Pmax, and for voltages 0.90-1.05pu, a reactive injection
requirement of 0.395 x Pmax. AEMO acknowledges this is a simpler
approach, but considers it would not necessarily result in better
outcomes and could have shortcomings compared with the current
proposed approach. It would effectively have a mid-point at nominal
voltage, which might not suit some transmission locations, and would
not require injection above 105% or reactive absorption below 95%. If
implemented in this way, there would be a discontinuity of the
requirement at 105% and 95%, which could cause undesirable hunting
of the control system if a plant was set up to provide just this
performance level.
Transgrid identified that the active power capability definition does not
consider the number of units in service, in contrast with the current NER
definition of ‘rated active power’.
The purpose of moving away from the use of rated active power is to
Caterpillar – Alternative proposed recognise that nameplate rating of equipment is not always a useful
• Synchronous generators (alternators) offer a large over-excited operating range, up to +0.75 reference point when seeking to establish the maximum amount of
Q/Pmax at rated active power (Pmax) but are constrained in their under-excited operating active power transfer that can be permitted or required at a connection
range owing to voltage stability and stator heating. On the other hand, inverter capabilities at point. The proposed changes to the existing definition of active power
rated active power (Pmax) in the over-excitation range are constrained owing to over-current capability recognise that the term can apply to both a unit and a system,
capabilities of the inverter switches. and both would be recorded in the performance standards. The draft
It is proposed to limit the Q-requirements from ±0.395 to ±0.33 Q/Pmax (±0.95 power factor) to definition neither prescribed nor limited the relationship between the
avoid over-sizing of alternators and inverters. The NAS can be used to agree on larger Q- capability of a system and the number of its in-service units at any point
ranges. in time. However, AEMO agrees that the access standards themselves
(rather than the active power definition) should clearly establish when it
It proposed to add a figure, with the voltage axis as a percentage of the nominal grid voltage and is relevant for performance to be linked to the combined active power
the required reactive power as a percentage of the unit’s nominal active power, showing the capability of those units currently in operation, instead of the maximum
required voltage-reactive power “U-Q/Pmax” range. This figure would represent that reactive value for a system with all its units operating.
power capability of units is reduced with increase in voltage deviation. In the context of S5.2.5.1, AEMO will modify the drafting to require that
Energy Queensland – partial support; alternative proposed maximum active power and maximum demand consider only those
production units that are in-service (operating), recognising not all units
Ergon Energy and Energex agree that a graph would be useful for interpretation. However, we will necessarily be identical.
note the “centre point” concept could introduce challenges in future due to the dynamic nature of
networks. In our view, it would be simpler to specify that for voltages in the range 0.95pu to
1.10pu, reactive absorption requirement of -0.395 x Pmax, and for voltages 0.90-1.05pu, specify Final recommendation
a reactive injection requirement of 0.395 x Pmax. Considering all update report feedback, in conjunction with the draft
Huawei Australia – clarification requested report consultation feedback, AEMO will retain its update report
What is the rule for NSP to nominate a centre point? recommendation, subject to clarification that the maximum active power

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Hydro Tasmania – partial support; alternative proposed level and maximum demand are only to consider the in-service
Hydro Tasmania (HT) acknowledges that NSP is best placed to identify the expected voltage (operating) units for the purpose of assessing compliance with reactive
profile of a network, however, without basic nomination principles or guidelines, leaving the 10% power requirements.
centre line nomination to a single party alone, could lead to potential issue when inconsistency is
encountered between different participants, e.g. generator A had a centre line nominated at 1
p.u., subsequently generator B is required to have a different centre line at similar location due to
the network shift caused by generator A.
At most, +/-5% consistent with S5.2.5.13 (2B) (iii), should be allowed if the TNSP is able to
nominate the centre line to also avoid conflicts may arise with this clause. Ungoverned TNSP
nomination also releases the possibility of the TNSP biasing the centre line prohibitive of
achieving 0.395*Pmax, and thus negating the intent of this change.
To avoid that, HT suggests that certain principles need to be established. For example, the
nomination should be pre-specified and published, ideally in a regional rather than individual unit.
This also will help generators to manage the specification of the machine reactive capability in
long term.
Additional, in the revised recommendation, an identical reactive capability is required for both
absorption and injection. As previously submitted, the main power transformer reactive power
consumption facilitates the GS leading reactive capability, but being a burden for lagging reactive
capability, hence being challenging to be satisfied. The symmetrical reactive power requirement
in the proposed rule change doesn’t well reflect this fact.
HT notices that the revised recommendation used word ‘linearly’, while it may be ok for the IBRs,
it could be challenging for synchronous machines due to its non-linear characteristic between
voltage and reactive capability.
Neoen – Supports with clarification
There needs to be alignment on the different voltage levels referred to in the NER. To maintain
consistency with the practical operation of the NEM and avoid introducing another extraneous
term, the "target voltage" which should be recorded in the connection agreement should be
utilised here. It is not efficient or effective to introduce another definition such as “voltage centre
point”.
If the new quantity is introduced it should be considered what mechanisms are in place for setting
and potentially revising it. Refer to the provisions in 5.3.13 – similar would be required here.
Proposed change to limit the requirement for full reactive power capability to a 10% voltage band
around a centre point nominated by the NSP (in the range 95% to 105%) could mean that the
capability of the plant needs to be maintained down to the 85% of the nominal voltage, if the
nominated centre point is the lower boundary of the range, i.e. 95%. This could require further
plant oversizing that must be supported by additional funding and considered in design.
Clarification on this expectation is required from AEMO in a guideline or report prior to the Rule
being amended. The nomination of voltage centre point must have a sound basis and be
received from the NSP sufficiently early to enable connection studies to be accurate and
commence in a timely manner. Neoen therefore recommends the voltage centre point, if

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introduced to the NER, to be determined from the connection point’s voltage profile, which the
NSP should be required to share at Connection Enquiry stage.
Powerlink – Opposes
• The negotiation framework already permits the provision of capabilities less than the automatic
levels of full supply (capacitive) of reactive power at high voltages, and capabilities less than
automatic levels of full absorption (inductive) of reactive power at low voltages. The proposed
changes do not add material benefits to the performance required, assuming that appropriate
engineering judgement is made by all parties when negotiating an access standard.
• Powerlink does not support the determination of a mid-point voltage, given this could change
over time.
• The proposed changes could lead to more complex access standards for S5.2.5.1, which
would result in an incrementally more complex task in the assessment of the access standard
itself and more complexity in the network and its operation.
Siemens Gamesa - Supports
• SGRE support these changes.
Solar Turbines
• It is considered that the provided wording is not self-exhaustive without a figure (as the one in
the presentation) which shall be part of the documentation.
• It is not so clear the aim of having a mid point in addition to the nominal/rated voltage which is
floating within the +/-5%. It is expected that requirements will be based on nominal/rated
voltage.
• For synchronous generators (4-pole generators) a symmetrical reactive power limit is unusual
and typical reactive power in underexcitation condition is PF 0.95, corresponding to Q/Pref
0.328 while in overexcitation condition this can range between 0.9 and 0.8 (corresponding to
Q/Pref 0.484 respectively 0.75).
• Such values could be used as a better reference, in particular for requirements on the
underexcitation side since higher Q/P values will lead for bigger generators (longer generator
shaft).
TasNetworks – Supports
• TasNetworks supports this proposed change.
Tesla – Supports
• Tesla is supportive of the final position proposed by AEMO.
Transgrid – Opposes
• Prefers the existing AAS as some plant can provide full reactive power capability of the full
voltage range without additional equipment.
• It is unclear whether the mid-point voltage in S5.2.5.1 is the target voltage mentioned in
S5.2.5.13.

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• The proposed amendment to S5.2.5.13(2B)(iv)(A) requires limiting devices to achieve
S5.2.5.1, which could be interpreted as voltage dependant reactive power limits in the PPC.
This could unnecessarily limit the reactive control in the NEM, meaning that the NSP may
require more FACTS devices than would otherwise be required.
• Considers that the term active power capability does not full consider the impact of reduced
numbers of in-service generating units.
The proposed draft NER amendments replace the term rated active power in the current Rules
with the term active power capability; in Transgrid’s view this term does not fully consider the
impact of reduced number of “in-service generating units”. The definition of the rated active
power in the current rules refers to “in-service generating units”, which is not referenced in the
new definition of active power capability. Therefore, it is unclear what the reactive power
requirement for a generating system or an integrated resource system is when there are
reduced number of generating units are in-service. This would lead to a lack of clarity as to the
expected performance of non-scheduled and semi-scheduled plants when generating units are
switched out of service. Transgrid has also included additional feedback on this item under the
“Definition changes” section below.
Treatment of reactive power Akaysha Energy - Opposes A broad spectrum of views on the proposed change was expressed in
capability considering Akaysha Energy is not in favour of temperature derated reactive power limits stating it is difficult the stakeholder responses.
temperature derating to implement. Supports GPS modelling capturing temperature derating. Scaling of 0.395 x P(T) Goldwind, Huawei, Siemens Gamesa, TasNetworks and Transgrid
artificially reduces reactive capability unnecessarily. generally supported the proposal to reduce active and reactive power
Amp Energy – alternative approach proportionally if a temperature derating applies. Amp Energy generally
supported the proposal, but suggested more flexibility to allow for other
The revised changes are generally welcomed. Regarding the three main variants for treatment of derating options.
temperature derating, our view is that all three options have its own merits and hence the rule
should be flexible to allow the most appropriate choice to be made at each location. Neoen and Powerlink noted that not all plants derate active and reactive
power in the same way. Akaysha Energy also opposes including
AusNet – alternative approach temperature derated reactive power limits in the AAS, as they may be
For weaker systems, Voltage sensitivity to Q and sometimes P (i.e., cross coupling effects) are difficult to implement and artificially reduces reactive capability
prone to be high. Therefore, extension of Q (i.e., prioritization of derating P) would not enhance unnecessarily, and would be difficult to implement for some technology.
the network's voltage stability. Hence, it is not a preferable option. For a distribution network AusNet suggested leaving it to the NSP’s discretion as to whether
where SCR is typically low, which tends to have the characteristics of weak grid connection, reactive power is prioritised or active and reactive power reduced
therefore, the reactive power proportional to active power accounting for any temperature equally when temperature derating applies. Amp Energy suggests that
derating is more preferred. On the other hand, in grid conditions where voltage sensitivity to Q flexibility should be allowed for the most appropriate choice but does not
(i.e., 𝑑𝑉/𝑑𝑄) is less pronounced and grid bus angle is not sensitive to P (i.e., 𝑑𝛿/𝑑𝑃 is low), indicate which party should have the choice of derating mode.
prioritizing derating of P (i.e., option 3) becomes more favourable. There is not one fits all
‘balanced right’ approach. AusNet proposes to leave selection of option 1 or 3 up to the relevant Solar Turbines, by contrast, preferred clarity upfront on the requirement
NSP's discretion considering network regulation needs and plant limitations. The expectation can (which it would be if in the access standard), rather than different
be communicated at the connection enquiry stage or as early as practical. derating options being applied.
Energy Queensland – Alternative proposed Powerlink and Energy Queensland preferred the AAS to require reactive
power to be maintained regardless of any temperature derating. AEMO
Ergon Energy and Energex support option 1 to require the same reactive power regardless of notes that if the plant is derated with temperature, meeting an AAS that
temperature derating. derates active power in preference to reactive power would not
Goldwind Australia

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We support the proposed option 3 seems like a reasonable balance. necessarily create the best outcome for the power system on a hot day,
Huawei Australia - Support when system demand is very high.
We propose Option 3. Both active power and reactive power should be reduced to keep the Tesla did not support recording temperature derating in the GPS as it is
power factor unchanged. commercially sensitive. AEMO notes that the GPS is a confidential
document shared only between the Generator, AEMO, the NSP and the
Neoen – Opposes AER. AEMO considers that if the plant is subject to temperature
Proposal to consider temperature derating is unnecessarily complicating the standard – derating this should be documented in the GPS as it has a significant
temperature impacts on active power capability. Each generating system bids to the market with impact on performance capability that can affect power system security
accordance to their current capability which already takes temperature derating into when the cumulative impact is considered.
consideration. It is unnecessary to add this to the Rules and will only prolong the discussions Considering all the submissions, the best outcome for the power system
related to this standard. Recording additional irrelevant material under the Rule will mean more would be no derating of active or reactive power with temperature.
testing and modelling needs to be conducted initially and through project life to "prove" the
statement extending and complicating the negotiations. Including temperature deratings in the GPS keeps the compliance
requirements in line with actual plant capability. Knowledge of active
Powerlink – Opposes and reactive power deratings at temperature extremes assists AEMO to
• While some inverter-based generating units derate current as a function of temperature, other assess power system security and reliability for those conditions.
generating unit types do not. From our experience, some wind turbines reduce active power as
a function of temperature, but do not necessarily reduce reactive power as a function of
temperature. Additionally, some thermal plants derate active power as a function of Final recommendation
temperature, and do not derate or vary reactive power. Considering all feedback, AEMO will revise its recommendation to have
• The adoption of an automatic standard that reduces the required reactive power as a function no derating of active or reactive power at the AAS level (below 50oC),
and to require any derating of active and reactive power with
of temperature-derated active power could result in that reactive capability that could be
temperature to be documented in the GPS as part of a NAS.
provided by some technologies at no additional cost is no longer provided.
In the NAS, express that, unless otherwise agreed with the NSP and
• Powerlink suggests that the automatic standard for reactive power is retained as being
AEMO, the derating is to be based on a proportional derating of active
invariant to temperature and considers that the S5.2.5.1 negotiated access standard already
power and reactive power at equipment level, projected to the
supports negotiation around temperature derating.
connection point.
• We recommend that if there is any temperature derating of active power at the connection
point, and if there is a requirement to document the reactive power derating in the GPS, then
active power should also be documented within the GPS.
• We consider generating unit-level temperature derating information is not needed within the
GPS and that only the information for temperature derating of the generating system at the
connection point is needed.
Siemens Gamesa - Supports
• SGRE support these changes.
Solar Turbines
It is not clear in which format the derating factor shall be represented (or maybe any
representation is acceptable) or how the requirements is stated.
In the draft recommendation update report dated 26th of July 2023 (see page 14 of the pdf) it is
indicated that the there are three main variants possible.
At present they seems not to be integrated in the draft document.

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For the sake of clarity any specific variant shall be clearly specified by the relevant party to which
the plant shall be connected to. The information shall be made publicly available and it is not
expected to change when applying for connection.
That would permit manufacturer to properly quote a solution that is in line with what is requested.
Later change would lead to unnecessary costs.
Regarding the requirements, reactive power capability is normally defined for a reference power
(for Gas Turbine for example it can be used Prated at ISO condition); reactive power capability
corresponds to such a value and it is valid considering voltage range and operational
temperature.
It has also to be noted that AVR limiters are typically fixed values or characteristic (static);
dynamic characteristic can be found as function of voltage (eg underexcitation limiter) in
advanced AVR, not as function of temperature.
Operational capability may be affected on how limiters can be set for properly protecting the
generators. That is to say that limiters can frequently be considered the operational limits at any
given condition.
TasNetworks – Supports
TasNetworks has applied temperature derating consistent with Option 3 in the past, where we
have maintained the ability to direct generators to reduce their active power output to a level that
meets 0.395*Pmax(T). It remains critical that the maximum temperature at which no derating
occurs must be set in such a way as to prevent inadvertent reduction in reactive power capability
during high temperature events, when cooling load is largest.
Tesla – Does not Support documentation of reactive power derating in GPS
Tesla is not supportive of the second dot point which would require reactive power derating as a
function of temperature to be captured in the GPS. This data is commercially sensitive.
Compensation of reactive Akaysha Energy – Partial support In the update report AEMO proposed a 0.5% threshold: the plant while
power when units are out of Akaysha Energy urges AEMO and NSPs consider on-site measurements of harmonics and filter not otherwise in service except for reactive power compensation, for
service impacts around operating a filter when the IBR is offline. Any reactive plant to meet S5.2.5.2 typical system impedance nominated by the NSP, should not cause a
compliance should not deteriorate the network for other parties in the vicinity and downstream voltage deviation (compared with fully disconnecting the plant) of more
from the POC. The 0.5% threshold should be confirmed with modelling. than 0.5%. AEMO specifically requested feedback on the
appropriateness of the 0.5% threshold. The proposed requirement was
Amp Energy – Partial support with clarification intended to reflect that for multiple small impacts it may be more
The 0.5% requirement or any value should be properly assessed. By having 1 single value in the efficient for the NSP to install a single central solution to compensate
General requirements this may become an unnecessary barrier if it is not necessary for a the voltage compared with many generators installing compensation
particular connection point. Should this be a value but can be increased if an agreement can be devices or operating plant and causing additional losses. A central
reached with the NSP and AEMO? solution is likely to be more cost efficient if the NSP must otherwise
AusNet – Support, with clarification install reactive compensation to account for the voltage impacts related
to line loading.
AusNet agrees with AEMO’s revised recommendation to introduce reasonable impact threshold.
AusNet supports the initially proposed 0.5% threshold to minimize the impacts on network “Not otherwise in service” in this context means the units are not
voltage regulation. Nevertheless, proponents could argue for the adoption of a 3% voltage generating or, for bi-directional units, consuming energy other than
auxiliaries.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
variation tolerance for transmission and 5% for distribution to maintain consistency with S5.2.5.12 Note that this clause is not applicable to a situation where all units are
voltage variation assessment criteria. operational, but the dispatch level or energy source availability is zero. It
Caterpillar – Partial support, with clarification caters for the situation in which the units are switched off (other than
those being used to provide reactive compensation).
This requirement can influence the design of AC filters. A project-specific study (at the plant-
level) is required to confirm the proposed 0.5% voltage variation. It is therefore proposed to move There was a variety of responses on this issue.
this requirement under the AAS standard and allow for relaxation in the NAS/MAS Akaysha Energy, Amp Energy, Caterpillar, Energy Queensland, Hydro
(Negotiated/Minimum Access Standard). Tasmania, SA Power Networks, Transgrid and TasNetworks all argued
CEC – Support with clarifications that a one-size threshold is not appropriate, and different thresholds
might apply at different connection points.
It is not clear how the requirement to limit impact on voltage to [0.5]% will be assessed. Can
AEMO provide an example? Amp Energy and Caterpillar suggested the threshold could be
increased, considering modelling of the impact. AusNet supported 0.5%
• Subject to clarification of the above, the 0.5 % figure seems extremely low and arbitrary. Any but considered proponents could argue for the adoption of 3% voltage
requirements should be determined based on the needs of the power system at a particular variation tolerance for the transmission network and 5% for the
location. The draft report isn’t clear on what is ‘not in service’. Depending on the technology distribution network to maintain consistency with S5.2.5.12 voltage
used, there are three operating scenarios that result in different reactive power capabilities at variation assessment criteria. CEC considers the 0.5% to be extremely
the connection point. Namely, o generating, o not generating (but units electrically connected), low and arbitrary. Siemens Gamesa suggests increasing it to 1% and
and o units disconnected. Tesla suggests it should be 5%. Caterpillar suggested it could be an
• Seldom are all units fully disconnected. Hence some operational flexibility should be exercised automatic access standard, but Powerlink suggested it should be a
to avoid having to over capitalise on solutions for the rare event that all units are disconnected. minimum access standard. Powerlink considered 0.5% would be too
E.g., allow the use of operational solutions such as switching out equipment within (say) 30 high in situations where there are pre-existing high voltages in the
minutes if required by the NSP (to manage voltages) to bring reactive power at the connection network that need to be managed.
point to a small MVAR band. AusNet, Goldwind and TasNetworks considered the 0.5% threshold is
• Recommend de-italicising the word ‘disconnect’ (defined term) such that disconnection does reasonable (or reasonable in most cases). TasNetworks considered it
not have to be via the connection point circuit breaker. might be too onerous in a weak network.
Energy Queensland – alternative proposed Some stakeholders considered the standard should take account of how
often the situation is likely to occur. Wind farms and batteries are not
Ergon Energy and Energex welcome clarity around compliance with clauses. However, we do not
often in the situation of turning off units (some wind farms might turn off
consider that a fixed voltage figure (such as the 0.5% proposed) is universally applicable. We
for too low wind conditions), but for solar farms there is no generation
suggest it should be within the Network Service Provider’s (NSP’s) discretion to determine
every night. Synchronous machines might or might not have balance of
appropriate voltage figures for specific locations in their network.
plant in service with or without auxiliary plant operating. The cost of
Goldwind Australia – Partial support; alternative proposal providing reactive support is also variable with technology, so providing
We think it is important to distinguish two different potential scenarios that AEMO may be trying an exact one-size optimal solution is not feasible. CEC suggested that
to capture as one: where units are seldom fully connected operational flexibility should be
exercised to avoid overcapitalising on solutions e.g. switching out
• All generating units are in service but for intermittent generators, the energy source (e.g. sun
equipment within a certain timeframe if required by the NSP to manage
or wind) is unavailable.
voltages.
• All/some generating units are offline/unavailable Powerlink considered the requirement should be expressed in MVAr.
For case 1, it would be reasonable to have all/some generating units to continue provide voltage AEMO notes this would not be a consistent measure of impact as the
control. It is noted that not all generators have the ability to continue providing voltage support in voltage sensitivity of the power system is different in different parts of
the absence of the energy source, therefore it is important to maintain the flexibility around the the network and the significance of a MVAr threshold would depend on
number of units that can mitigate any voltage impact to a reasonably agreed value – in this case the size of the generating system. On the other hand, converting a
the proposed 0.5% would be reasonable.

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For case 2, this is where we recommend AEMO consider the practicalities around the physical voltage threshold into an equivalent MVAr has the advantage that it
plant being switched in and out without the presence of any mitigation from generating units. For would not vary over time with changes to the power system.
example, this could be energising the transformers and/or overhead lines for a project after a Powerlink commented on the application of performance standards to a
maintenance regime. In such situations sometimes it may not be practical to limit the voltage small subset of units that will be online for reactive power
impact to 0.5% (e.g. due to line charging currents of long transmission lines). Such scenarios in compensation, that all performance standards should apply, other than
our view would be quite rare occurrences, therefore on that basis we propose AEMO consider those specifically associated with active power.
3% voltage impact limit similarly to the specification of “Infrequent events” under “ENA
Engineering Recommendation P28” standard in the UK. AEMO agrees that S5.2.5.9 should be unaffected by the number of units
in service. The fault contribution under S5.2.8 should be much less, and
Hydro Tasmania - Partial support; Alternative proposed the tolerated fault level should not be affected by the number of units in
HT is of the opinion that this clause fundamentally relates to auxiliary load service, so these clauses need not be assessed for compliance but
specification/management, rather than the performance of generating unit, hence putting the should nevertheless comply. Likewise, S5.2.6 should be unaffected by
requirement to auxiliary loads would be more logical, e.g. auxiliary loads power factor. In order to the number of units in service. S5.2.5.12 is also unlikely to be affected,
identify the impact on voltage e.g. [0.5%], obviously, the typical system X/R ratio (as proposed in while S5.2.5.15 should only be considered with all units in service.
the calculation) changes as the network evolving, given that, it is recommended: 1) The AEMO does not agree that it is essential to apply S5.2.5.3, S5.2.5.4 or
requirement is applied to new connection application only. 2) Remain the NSP technical S5.2.5.5 requirements to a small number of units that are in service
judgment in parallel with the threshold, e.g. 0.5%, given the fact that some area in the system solely for the purpose of reactive compensation, as the impact of
could be more robust to voltage variation, whereas some area could be more sensitive. tripping should be minimal.
Powerlink – Opposes; Alternative proposed AEMO does not consider there is a need to apply S5.2.5.6 or S5.2.5.7
• Powerlink notes that if multiple solar farms were connected in to the one bus or to different to these units for similar reasons. S5.2.5.8 over-frequency response is
buses in the same area, then under the proposed standard, the combined effect of those solar not relevant since there will be no active power generated. AEMO
farms at night-time could appreciably increase the voltage by several percent. In some agrees that S5.2.5.11 and S5.2.5.14 are not relevant.
networks, there are pre-existing high voltage challenges to manage, and the proposed Hydro Tasmania is of the opinion that the clause relates to auxiliary load
standard (of 0.5% voltage increase) would not be appropriate. Solar farms spend more than specification and management, and suggests that it be treated as a
50% of the time (i.e. at night-time) with generating units not generating or potentially out of power factor requirement. AEMO notes that the provision is presently
service. written in this form, largely considering synchronous machines. A power
• Powerlink suggests that the 0.5% threshold of the proposed General Requirements should factor specification works for generating systems that have substantial
instead be considered for a Minimum Standard. We recommend the Automatic Standard be auxiliary loads, but not for systems for which the load from the balance
expressed as a requirement for 0 MVAr at the connection point, combined with a nominal of plant is largely inductive or capacitive. For those systems with few
reactive power tolerance. auxiliary losses, the current requirement effectively translates to zero
impact on voltage, which is unnecessarily onerous.
• Powerlink recommends that, by default, all clauses of a GPS apply whenever a plant is
energised. The performance requirement during the day and at night could differ, and some Many of the responses to this proposal depend on the primary type of
clauses may not be relevant or could be negotiated for different performance during the day generation considered by the respondent – solar, wind, battery, hydro or
and at night as agreed by NSP and AEMO. For example, for a solar farm at night with a subset thermal, which present different issues with different impacts on the
of inverters in night-time reactive support mode, S5.2.5.3, S5.2.5.4, S5.2.5.9, S5.2.8, should power system. The NSPs also see different impacts on their networks.
still apply. AEMO considers voltage impact is a more objective assessment
• Powerlink recommends those clauses that specifically related to active power are carved out criterion than a power factor or reactive power value for determining
(e.g. S5.2.5.11, S5.2.5.14). Components of S5.2.5.5 should still be applicable when a solar whether a limit on reactive power is required for the connection point,
farm is operating at night (e.g. the requirement to stay connected). Some flexibility should be although voltage sensitivity can vary over time as well as from location
provided under a Negotiated Access Standard for provision of reactive current under S5.2.5.5 to location.
when a solar farm is operating at night, while other components of S5.2.5.5 (e.g. active power AEMO does agree that the voltage impact could be recorded as a MVAr
recovery) are not relevant. range for the purpose of the GPS, which would also address Hydro
Tasmania’s concerns about changes over time.

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SA Power Networks - alternative proposed The requirement could be specified as an automatic and minimum
We recommend that both active power and reactive power requirement to scale down linearly as access standard, to reflect that different connection points can tolerate
a proportion of the number of generating units still in service and leave freedom for each NSP to different amounts of voltage change.
determine whether the voltage impact on the connection point is acceptable as part of the due Final recommendation
diligence assessment. Given that each NSP applies different planning criteria to meet the unique Considering all these factors AEMO proposes to amend its
requirements of each connection point with different network characteristics, it may not be recommendation to include an AAS based on based on 0% voltage
advisable to develop an automatically accepted voltage impact limit as this could trigger the variation and an MAS of up to 1% voltage variation or greater value
NSPs to invest significant amount of capital to resolve voltage constraints which goes against the agreed with the NSP, in each case considering the system impedance
principles of the NEO. In the scenario where a significant portion of the plant’s reactive power value nominated by the NSP, considering the equivalent impedance for
requirements are met by a pure reactive plant such as SVCs and STATCOMs, the NSP and the the minimum three phase fault level determined declared (under NER
generating system should have the freedom to negotiate on an appropriate active power and 5.20C.1(c)) at the electrically closest system strength node range and
reactive power requirement / limitations when the reactive plant is out of service, and document it the impedance between that point and the connection point. The value
as part of the agreed performance standards for the generating system. is to be converted to an equivalent MVAr for recording in the GPS.
Siemens Gamesa - Supports with clarification; Alternative proposed For performance compliance purposes AEMO proposes that units in
SGRE suggest to increase the voltage deviation from 0.5% to 1% for a typical system impedance service solely for the purpose of reactive compensation should meet
nominated by the Network Service Provider, the higher the voltage deviation is, the less will be protection requirements, requirements under S5.2.5.10, steady state
the costs borne by the consumer. SGRE understand that the typical system impedance is as performance requirements (considering the number of units in service),
extracted form system normal snapshot considering the nearby voltage control by adjacent and the relevant requirements of S5.2.5.13, as if for a secondary
plants. operating mode.
Solar Turbines Additionally, require that for conditions where schedule 5.2 plant is not
There could be multiple reason for which a generating plant is not in operation, but basically this in service, (other than solely for the purpose of reactive compensation):
can be summed in market driven reasons or maintenance/repairing/modifying activities. There • maximum active power consumption of a generating system or
are also multiple plant type (pure generation, mixed pure generation, Combined Heat & Power, integrated resource system in respect of auxiliary load and the range
part of industrial plant) that can drive the requirements and the way this shall be fulfilled. of permitted reactive power at the connection point are to be specified
In case of market driven reasons and for pure generating plant, the system is most probably as steady state values.
completely off or it will be on minimum loads to keep it operational. It is not considered that any
requirement shall be applicable in such condition. In case of reactive power becomes a system
need it is recommended to create an appropriate ad-hoc market for reactive power and inertia.
In case of maintenance/repairing/modifying activities of pure generating plant, where a single unit
is present, then no reactive power requirement has to be considered. When multiple units are
present, then the expectation is that the overall reactive power requirement decreases as a
function of the units connected. Basically the Pref used for calculating the reactive power
contribution is function of the number of units connected, it is not economically viable to install a
compensating system to keep on with such activities and there is merit to used the resources
available instead of having the complete generating plant off.
Different consideration can be made for CHP plant and generating plants embedded in industrial
power plant when the generation is considered a by-product and the target could be the Heat
(steam) production. When generating plant is disconnected from the grid (both for market reason
or for maintenance/repairing/modifying activities, it is likely the plant will still be a generation or
load to the grid. It is still recommended that reactive power requirements remain proportional to
the operational generation when exporting (or when the generation is in operation). In case all
generation is off then the applicable requirement shall be of a load.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
TasNetworks – Support with clarification
While TasNetworks generally supports the change, it is our experience that the fixed limit may
not be appropriate in all cases. While limiting the voltage impact to 0.5% is reasonable in most
cases, this may not be the case in weaker parts of a network. Allowing the Network Service
Providers (NSP) to set the limit to a lower value in limited circumstances should be included in
the rule drafting to allow better management of these parts of the network.
Tesla – Opposes; Alternative proposed
Tesla does not support the revised recommendation to limit the impact on voltage to 0.5% when
the plant is not in service. This should be removed or increased to 5% as a more reasonable
expectation.
Transgrid – does not support – Alternative proposed
• Under the proposed voltage impact threshold of 0.5% plants will be able to operate in a wider
reactive power range and this impact the network thus requiring more reactive power
compensation devices. The cumulative effect of multiple generating systems in an area could
be significant. Transgrid prefers allowing the NSP to specify a voltage threshold appropriate for
its network.
• If a fixed voltage threshold is used then the maximum system impedance should be based to
calculate the steady-state voltage impact. Transgrid suggests that AEMO provide clarification
and supporting data to demonstrate how the proposed 0.5% voltage impact threshold was
determined.
• The term “auxiliary load” is used in the draft NER amendment of S5.2.5.1 (g) is italicised but
not defined. If this refers to the auxiliary load component it is unclear how harmonic filters, the
collector network and other reactive plant are to be managed when the production units are not
in-service.
• Transgrid’s original proposal highlighted two aspects of zero output: the production units are
out of service or in service but not producing. Transgrid still suggests some guidance on
operation of Q-on-demand modes to streamline the requirements across the NEM, as it is
common in solar and wind projects.

S5.2.5.7, S5.2.5.8, S5.2.5.13

Simplifying small connections AusNet – supports proposals on S5.2.5.7, S6.2.5.8 S5.2.5.13 for small connections; Generally, the changes for small connections other than the proposal
Opposes change to AEMO advisory matters. around AEMO advisory matters are well supported by stakeholders.
AusNet supports AEMO’s revised recommendation on S5.2.5.7, S5.2.5.8 and S5.2.5.13 for ElectraNet, SA Power Networks and Energy Queensland, as well as the
smaller connections. ENA, expressed various concerns about the proposal to apply a
AusNet disagrees with the recommendation to exclude AEMO's advisory matters on connections threshold of 30 MW to AEMO advisory matters. Powerlink also
less than 30 MW. This is a significant change from current practice and no justification has been cautioned about the possibility of multiple plants close to 30 MW
provided as to how this recommendation was reached. connecting in the same vicinity.
Additionally, AEMO’s position in this matter contradicts discussions between NSPs and other Electranet suggested this change would have significant unintended
parts of AEMO which have been considering AEMO becoming further involved in setting impact on the application of the NER, noting it is unclear how AEMO

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
performance standards for sub 5 MW connections. AusNet requests AEMO share its analysis would be satisfied that the connection could meet its performance
assessing the merits of excluding AEMO’s advisory matters on connections less than 30 MW, standards under NER 2.2.1(e)(3) without undertaking the advisory role.
compared to the status quo. This should include responding to valid questions and concerns AEMO’s registration functions are considered separate from its advisory
raised by Energy Queensland and AusNet during their first-round response to the review’s draft role in approving negotiated access standards for matters that are
report, which were left unanswered. considered to have a power system security impact. AEMO is required
Caterpillar – alternative proposals to make an assessment under NER 2.2.1(e)(3) for all registered
generating and integrated resource systems, irrespective of size, and
• General comments: It is proposed to simplify and make the MAS (Minimum Access Standard) for all performance standards irrespective of whether AEMO has been
requirements exhaustive for Small Generators. This will help OEMs design and test for the involved in their negotiation. This already extends (and will continue to
base level requirements. Any non-exhaustive requirements or requirements higher than the extend) to standards that are not AEMO advisory matters and automatic
MAS are proposed to be given under the NAS or AAS. standards that may not have been negotiated under NER 5.3.4A at all.
• S5.2.4 - It is proposed to provide relaxation of simulation model requirements (RMS/EMT) for AEMO will continue to require each registration applicant to provide
Small Generators. Block diagram representation of Small Generators, using common satisfactory evidence of capability of the actual plant to meet the
standards (IEEE, IEC, etc.), can be provided on request. performance standards agreed at the connection agreement stage.
• S5.2.5.4 - Please see the comments below for “S5.2.5.4” (MAS proposal: 70% to 80% for 0.7 ElectraNet also suggested that NER 4.14(q) should not be deleted as it
seconds after T(uv)). enables AEMO to reject a change on the grounds of power system
security even if it is not an AEMO advisory matter. However, AEMO
• S5.2.5.5 - It is proposed that the current MAS which states that the fault ride-through
notes that if it is not an AEMO advisory matter, it should not affect
capabilities for synchronous generators are agreed with the system operator, be moved under
power system security.
NAS. MAS of 30% Un (residual voltage) for 150 ms is proposed for Small Generators.
ElectraNet also noted that NER 5.3.4A(f) (unchanged in the proposed
• S5.2.5.5 - Multiple fault ride-through (MFRT) requirements: It proposed to relax the MFRT for drafting) sets out the reasons for an NSP to reject a proposed
Small Generators considering the MAS proposed above. performance standard. AEMO notes that regardless of this clause the
• S5.2.5.5 – NAS: “…the reactive current contribution of a schedule 5.2 plant to the extent it performance standard must be proposed at a level that does not
comprises synchronous production units or synchronous condensers may be limited to 250% adversely affect power system security, under NER 5.3.4A(b)(2). NER
of the maximum continuous current maximum continuous current”. Reactive current 5.3.4(f) sets out conditions where the NSP must reject a performance
contribution of synchronous generators is a natural response which depends on the grid- and standard, but does not prevent an NSP from rejecting it on other
on-site conditions. Restricting the fault current to a lower value for stringent faults requires grounds, including if it considers it not to meet NER 5.3.4A(b)(2
extensive plant-level studies and solutions. It is proposed to relax (remove) this requirement for However, considering the size threshold proposed, it is unlikely that
Small Generators. generating systems in the range 5 to 30 MW would be prevented from
• S5.2.5.13 - It is understood that the voltage and reactive power requirements (settling time, connection on grounds of power system security impact, provided that
PSS, etc.) are for Large Generators and not for Small Generators. If not the case, it is they meet at least the minimum access standards of each requirement
proposed to: in Schedule 5.2. The price sensitivity of generation or otherwise is not a
– Provide a settling time requirement of greater than 10 s for Small Generators, reason for AEMO or an NSP to object to connection of a plant, on power
system security grounds, which meets at least the minimum access
– Provide relaxation of PSS (power system stabiliser) requirements for Small Generators, standards. The price sensitivity for batteries is dealt with through the
Only require reactive power or power factor modes for Small Generators; current NAS: dispatch process. The concern raised by ElectraNet could be addressed
“…Network Service Provider and AEMO will nominate one or more control modes to be by permitting an NSP to refer a matter to AEMO if they believe there
implemented…”. could be an adverse impact on power system security, and if a
CEC – Supports with qualification reference is made the matter would become an AEMO advisory matter.
A provision of this nature is also broadly consistent with the CEC’s
Having less parties to negotiate with is generally welcome, however there could be some benefits suggestion of allowing consultation with AEMO by exception.
in having the ability to consult AEMO (by exception) if a proponent and the NSP cannot agree on
a set of negotiated performance standards. Energy Queensland, SA Power Networks and the ENA opposed
changes to AEMO advisory matters threshold on the grounds that

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
ElectraNet – Opposes changes to AEMO advisory matters AEMO involvement in the negotiation of performance standards helps to
ElectraNet disagrees with the proposed increase to the AEMO advisory threshold for Negotiated provide consistency for performance standards development. While this
Access Standards to 30 MW and considers that this change will have significant and unintended may be true, it is not the reason for AEMO advisory matters. AEMO and
impacts on the application of the National Electricity Rules. It is also noted that 30 MW NSPs could also develop other measures to ensure consistency
connections are clearly material to the operation of Distribution Networks and are material for between them such as revised GPS guidelines to assist common
some areas of Transmission Networks. ElectraNet considers that 30 MW connections are interpretation of technical requirements and assessment methodology
material to system security in South Australia. that need not be in the rules.
ElectraNet notes that the National Electricity Law requires that all Generators be registered Some respondents also noted that AEMO has formed a working group
unless an exemption to registration is granted by AEMO. Based on the published AEMO guide, it to discuss harmonisation of performance requirements for generating
is understood that standing exemptions are available for Generators with rating of less than 5 systems and batteries in the range 200 kW to 5 MW. AEMO
MW; Generators larger than this size are required to apply for exemptions and no exemptions are acknowledges that the proliferation/concentration of smaller IBR does
granted for Battery systems larger than 5 MW. collectively impact power system security, but direct involvement of
AEMO in individual connections of that size would not be an efficient
NER 2.2.1(e)(3) requires that, when registering a Generator, AEMO be satisfied that the way to address this issue.
generating system is capable of meeting or exceeding its performance standards. It is unclear
how AEMO would gain comfort that, for a generator (production system) with capacity above the AEMO’s reason for recommending a size threshold for its involvement
threshold for registration but below the proposed 30 MW AEMO advisory threshold, the agreed in individual connections is to facilitate effective management of
performance standards could be achieved without undertaking a review of the plant performance engineering resources focusing on larger connections that are much
and access standards consistent with what is currently performed under AEMO’s advisory more likely to affect power system security on an individual basis. This
function. is necessary to manage the energy transition efficiently.
The proposed drafting deletes NER 4.14(q) with the justification that AEMO is not required to Caterpillar proposed some additional relaxations of performance
agree to performance standards that are not advisory matters. Contrary to this position, requirements for small plant, above those already consulted on. At this
ElectraNet considers that this clause enables AEMO to intervene in situations where it considers late stage of the review process, AEMO is not in a position to consider
power system security would be adversely affected (regardless the clauses identified as AEMO recommending these proposals as part of this technical standards
advisory matters). Such action is consistent with AEMO responsibility for power system security review, as they would require further detailed consultation with industry.
under NER 4.3. It is unclear what benefits removing this clause brings. Caterpillar may wish to raise them as part of a subsequent rule change
consultation.
NER 5.3.4A(f) sets out the situations where a Network Service Provider must reject proposed
negotiated access standards and are unchanged by the proposed drafting. Importantly, these Hydro Tasmania requested retaining flexibility for plant less than 7 MW
provisions include rejection for reasons of system security only under the advice of AEMO. It is not to be scheduled. AEMO does not intend to change any
considered that the threshold proposed by AEMO will likely result in the inability to reject requirements around dispatch as a part of this review.
negotiated access standards for proposals below 30 MW for security reasons. This presents a AEMO held an additional meeting with NSPs to discuss this matter. The
material risk to the secure operation of the power system in the expected outcome that relatively meeting indicated possible misunderstanding that applying a threshold
large numbers of such production systems connect to distribution systems in relatively close to an AEMO advisory matter meant not registering the plant. This is not
proximity. the intention and registration and classification of plant as scheduled or
ENA – concerns about changes to AEMO advisory matters otherwise would not be affected. The generator will still have to satisfy
AEMO that the plant will be able to meet or exceed its performance
• What is included in the definition of an AEMO advisory matter is being altered in the schedules standards under NER 2.2.1(e) as a condition of registration. NSPs
and the list of clauses that are advisory will be updated later. This lacks clarity of what is an raised concerns about whether AEMO would still be responsible for
AEMO advisory matter and what needs to be considered by the NSPs as part of 2 the models under the proposed changes.
connection process. This has the potential to transfer work to networks regarding the
Performance Standards and compliance. NSPs also raised concerns about the cumulative effect of multiple
connections – for example with respect to frequency response.
• AEMO is proposing that the AEMO advisory matters exclude connections below 30MW or
In the meeting TasNetworks also raised that a 30 MW threshold was too
30MVA in relation to Schedule 5.2 (Connections for generation, integrated resources and
high in Tasmania, and a threshold based on the largest contingency

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
synchronous condensers) and Schedule 5.3 Connection of Loads. ENA has a number of size should apply there. TasNetworks suggests a threshold at the lower
concerns with this approach: of 5% of maximum contingency size and 30 MW. That translates to a
– There is no justification on why or how AEMO arrived at this decision. What analysis was 7.5 MW threshold in Tasmania, and 30 MW elsewhere.
undertaken that resulted in the decision to take this approach? » AEMO is primarily Energy Queensland commented that “If the assessment, monitoring and
responsible for the security of the power system and would be losing visibility in the 5MW- ongoing compliance sits with the DNSP to manage and maintain, then
30MW category, yet is also seeking increased visibility and standards in the 30kW - 5MW there appears to be no value to the proponent or market for any
connections progressed under Chapter 5A. These requirements are inconsistent and appear proponent being registered in the range of 5-30 MW, for any technology,
to conflict with each other. including energy storage”. AEMO notes that if the Schedule 5.2 plant is
– ENA is also concerned that these matters might be considered differently by different registered (irrespective of size), then AEMO and the AER have a role in
networks in the connection process and may create issues down the track. There are compliance - but in no case should the NSP regard itself as not having
already issues being seen on the power system which are created by small connections, any monitoring and enforcement role, since the performance standards
these smaller connections in aggregate have the ability to create larger power system issues are part of the connection agreement with the NSP.
at both transmission and distribution level, including across the interconnectors creating
issues for other states. Final recommendation
– This also doesn’t seem consistent with past amendments where AEMO has required Based on analysis of the feedback, AEMO will retain its update report
batteries above 5MW to be registered because of 10MW swings in load. We will see more recommendation to change S5.2.5.7, S5.2.5.8 and S5.2.5.13 and
price responsive load (virtual currency miners, data centers, H2 production, large bi- amend the update report recommendation to apply a threshold based
directional electric vehicle chargers etc) or generation creating power system issues and on the smaller of 5% of the largest generator contingency size or 30
increased system services cost and we urge AEMO to reconsider their position. MW.
– This also impacts connection alterations where the NSP and the Schedule 2 participant However, considering the strong level of concern expressed by some
need to advise AEMO of connection alterations for agreements that include AEMO advisory NSPs regarding the proposed threshold on AEMO advisory matters,
matters, rule 5.3.9 (h). The changes both to the threshold and to the list of matters included AEMO has decided not to progress this as a rule change proposal
as AEMO advisory matters make it unclear whether the notification will relate to existing immediately, but instead undertake further consultation on efficient
connection agreement/advisory matters or the matters under the new rule. This is also involvement for AEMO in smaller connections.
marked a tier 2 penalty clause.
Energy Queensland – opposes changes to AEMO advisory matters; support changes to
S5.2.5.7 and S5.2.5.8
Ergon Energy and Energex are strongly opposed to the blanket exclusion of all connections
under 30MW from Australian Energy Market Operator (AEMO) Advisory Matters. As referenced
in our April 2023 submission1 to AEMO’s Draft Report, along with technical due diligence, a key
role for AEMO is to ensure consistency and clarity in relation to the technical requirements for
connections across the National Energy Market (NEM), as well as support for ensuring the
negotiating framework is applied where relevant. These ‘small connections’ can still be
incredibility complex and difficult, as such, losing AEMO’s oversight will be significant. Having
DNSPs and connecting applicants to resolve technical requirements, may result in discrepancies
in interpretations and potential commercial pressures in the determination of matters related to
system security. This will not have an immediate impact, but will gradually occur over several
years, meaning that any impacts will be difficult to identify early. This is very similar to the
compliance considerations of small-scale embedded generation.
Given the forecasted impacts of aggregated storage systems in the NEM over the next few years,
it seems short-sighted to exclude these from AEMO oversight. It was stated in AEMO’s Update
Report Forum held on 9 August 2023 that “most connections of this size apply for exemption”.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
We suggest this does not cover battery systems, as these are not eligible for exemption. In our
view, having an exemptions framework would have little strain on AEMO’s resources.
Further, we have seen varied compliance of very small embedded generators, that trying to
resolve compliance or technical matters post construction is complex, difficult and often very
expensive. We do not see any benefit in omitting connections of less from than 30MWs from
AEMO advisory matters, especially based on evidence and AEMOs learnings on a market
segment that is only expected to grow in the distribution network. Notwithstanding, should these
amendments proceed, Ergon Energy and Energex question why these systems/proponents
should need to register with AEMO at all. If the assessment, monitoring and ongoing compliance
sits with the DNSP to manage and maintain, then there appears to be no value to the proponent
or market for any proponent being registered in the range of 5-30MW, for any technology,
including energy storage. Ergon Energy and Energex have no objection to the proposed changes
to S5.2.5.7 or S5.2.5.8.
Hydro Tasmania – partial support; alternative proposed
The facilities for the TNSP to co-ordinate with AEMO as to whether a connection should be
except from a scheduled connection should also be preserved, and in that some flexibility to the
discretion of the TNSP in applying 7MW as a firm limit.
Powerlink – Comment
Careful consideration needs to be made if there are multiple connecting plant with nameplate
capacities close to the 30 MW threshold proposed in the same geographical area.
SA Power Networks – Oppose change to AEMO advisory matters
We strongly advise for AEMO to be involved and provide an advisory role if the technical
requirements in Schedule 5.2 are applied for a ‘Schedule 5.2 plant’ under 30MW/MVA the NSP
considers to have material impact on the wider network.
We strongly oppose AEMO’s recommendation to exclude connections less than 30MW for AEMO
Advisory Matters.
– a. This will have a material impact on the consistency of connection assessments across the
NEM and places the onus solely on the NSPs to ensure appropriate minimum performance
standards are met by 5-30MW Generators to maintain system security without regulatory
oversight from AEMO. Considering the influx of more IBR generators in the network and
distribution network connected BESS proposals with grid-forming capabilities, to
Stakeholder feedback | SA Power Networks | AEMO review of technical requirements for
connection under Schedules 5.2, 5.3 and 5.3a of the NER NER Schedule 5.2 issue
Schedule 5.2 (Generators) – feedback on revised recommendations and relevant draft NER
amendments ensure consistency across the NEM, we strongly believe that it is most
appropriate for AEMO to provide the regulatory oversight to ensure all Registered
Generators have appropriate, consistent level of performance standards.
– b. Aggregated smaller connections on the network can cause a wider power system impact
at both transmission and distribution levels and a working group initiated by AEMO was
formed to increase visibility and a uniformed assessment approach for Chapter 5A
connections. AEMO’s proposed recommendation is inconsistent with that initiative and may

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
hinder their function in maintaining wider power system security. Concerning S5.2.5.7 and
S5.2.5.13, we advise that a re-evaluation of this threshold is necessary, particularly
considering the impending decommissioning of a significant portion of synchronous
generators and increase uptake in Inverter Based Resources (IBR). As a result, the size of
the largest credible contingency event in SA is diminishing. Moreover, the collective impact
of numerous generators below 30MW, lacking thorough investigation into their voltage and
reactive power control, could pose system stability issues.
– c. Majority of Generators under 30MW (above 5MW) in SA are registered Market
Participants (therefore subject to the technical requirements in Schedule 5.2) and have not
applied for exemptions from registration due to financial incentives in participating in AEMO
markets. We have received an increase of applications for BESS with a nameplate rating of
5MW which must be registered as Generators. Assuming AEMO’s function in managing
GPS non-compliances for Registered Generators remain unchanged due to this
recommendation, it may be more resource intensive to deal with potentially increase of non-
compliances from generators due to influx of <30 MW generating systems (e.g. BESS with
grid-forming capabilities).
Siemens Gamesa - Supports
SGRE support these changes.
TasNetworks – Supports
TasNetworks is supportive of setting the threshold to the minimum of 30MW or 5% of any
maximum credible contingency event size specified in the frequency operating standards for the
relevant region.
Tesla – no concerns raised
Tesla has no additional comments on this revised recommendation.
Transgrid – partially supports
• Does not consider there is an issue with current NER S5.2.5.7, even for small connections.
• Does not have any concerns with the proposed amendments for small connections for NER
S5.2.5.8.
• Does not have any concerns with the proposed amendments for small connections for NER
S5.2.5.13.
• AEMO advisory matter input helps provide a level of consistency across jurisdictions and adds
value to the connection process and need not necessitate significant due diligence by AEMO.
NER S5.2.5.2 – Quality of electricity generated
Reference to plant standard AusNet There has been general support for the proposal to remove reference to
AusNet supports AEMO’s revised recommendation. AS1359.101. Hydro Tasmania indicated another plant standard should
be substituted, but did not propose an alternative. AEMO notes that the
Energy Queensland NER already allows a registered participant or other interested person
Ergon Energy and Energex have no objection to the removal of the reference to AS1359.101. to propose a plant standard to the Reliability Panel under NER
5.3.3(b2).

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
Hydro Tasmania – Supports; alternative proposed Final recommendation
The proposed change, while maintaining reference to a plant standard, is acceptable. Considering all feedback, AEMO will retain its update report
TasNetworks – Supports recommendation.
TasNetworks supports this proposed change.
Tesla - Supports
Tesla remains supportive of this change.
Transgrid - Supports
Supports the draft recommendation to remove reference to the superseded standard.
NER S5.2.5.4 – Generating system response to voltage disturbances

Overvoltage requirements for AusNet - Supports There was a range of views on this proposed change. It was supported
medium voltage and lower AusNet supports AEMO’s revised recommendation. by AusNet, Siemens Gamesa, TasNetworks, Tesla and Transgrid.
connections Powerlink considered that it might be more practically dealt with by
Caterpillar -alternative proposal (on a different aspect of the clause) modifying the negotiated access standard or negotiating process for
Currently both the AAS and MAS require "continuous uninterrupted operation where a power S5.2.5.4. ElectraNet, Energy Queensland and SA Power Networks
system disturbance causes the voltage to vary within 70% to 80% of normal voltage nominal opposed the change.
voltage at the connection point for a period of at least 2 seconds after T(uv)." As noted by ElectraNet, AEMO agrees the change could have the effect
It is proposed to relax the MAS requirement as "continuous uninterrupted operation where a of introducing impedance between the location of the overvoltage and
power system disturbance causes the voltage to vary within 70% to 80% of normal voltage the connection point. The current rule effectively makes the
nominal voltage at the connection point for a period of less than or equal to 0.7 seconds after requirements at the voltage ride through requirements at unit level much
T(uv). " more onerous for distribution-connected plant, particularly those without
ElectraNet – Opposes the use of point of application for distribution-connected plant tap-changing transformers, than for transmission-connected plant. The
The proposed drafting for S5.2.5.4 includes a definition for point of application. In the case of purpose of the changes made to this standard in 2018 was to increase
connection points at or below 66 kV, the proposed definition defines the location of voltage power system resilience to high transmission level overvoltages, with
disturbances at the nearest electrical location with a nominal voltage above 66 kV. For some the intent of improving the performance of transmission connected
DNSP connection points this location will be on the transmission system and may be significantly generation.
remote from the actual PoC. This can have the effect of introducing significant impedance ElectraNet and Energy Queensland suggested that an alternative way
between the generating system and the location of the defined voltage disturbance and therefore to deal with the issue would be to allow negotiation on the assessment
reduce the effective ride through obligation of these connections. It is suggested that while such point. Powerlink also suggested the issue might be better dealt with by
consideration may be appropriate for the Negotiated Access Standard, the Automatic Access modifying the negotiation of this standard.
Standard should be maintained with the disturbance assessed at the PoC. AEMO agrees with the suggestion, instead of applying the point of
Energy Queensland – Opposes use of point of application for distribution-connected plant application to the AAS and MAS, of modifying the negotiation provisions
Ergon Energy and Energex consider that there are few cases where this would be appropriate, to allow agreement by the NSP and AEMO to a point of application for
and the reason for changing the automatic access standard is unclear, instead of allowing this overvoltage application at a location with nominal voltage higher than
nomination under the Negotiated Access Standard. Removal to the nearest bus over 66kV may the connection point, where the plant is connected at nominal voltage
represent two or three transformations, and significant network – masking the potential impact less than 66 kV with no automatic tap-changing transformer between its
where the voltage excursion occurs in the distribution network. Given that this clause relates to production units and the connection point. AEMO considers this would
power system resilience, it appears to be making a change to accommodate a minority of cases address the technical issues while providing more flexibility than the
where this would be appropriate, rather than the whole system. We instead recommend that original proposal in appropriate locations.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
AEMO consider, with the NSP’s and AEMO’s approval, the ability to negotiate on the assessment SA Power Networks raised a concern that this requirement could mean
point. that the overvoltage requirements could be applied a long distance from
Powerlink – Partial support; alternative proposed the connection point. However, AEMO considers that if the connection
point was a long way from the transmission, a transformer with
• Powerlink considers it more practical to deal with plant connecting to a voltage level below 66 tapchanging would be needed to keep the voltages within an
kV by modifying the negotiated access standard or negotiating process for S5.2.5.4. appropriate operating range, but agrees that this might be between the
• Powerlink supports the removal of the limit on negotiation based on the size of the plant. connection point and 66 kV level, not the 132 kV. The proposed
amendment below should address this scenario. SA PowerNetworks
• Minor drafting note: The Rules mark-ups refer to the electrically closest location exceeding 66
also raised that requiring them to consider overvoltages at transmission
kV. The revised recommendation in the Update Report refers to the nearest high-voltage
level would be more complex for them, as they typically do not model
transmission location, even though some DNSPs have lines operate at 132 kV. Powerlink
the power system to the transmission network. The proposed
assumes the Rules mark-up is the intended change, even though it does not exactly align with
amendment below should limit the need for this additional modelling to
the description in AEMO’s Update Report.
only circumstances where it provides value as a negotiation position.
SA Power Network - Opposes
Final recommendation
• The revised approach would imply that the point of application of overvoltage for S5.2.5.4
Considering stakeholder feedback, AEMO proposes to modify the
would be at the nearest 132kV or 275kV transmission connection point which could be very
update report recommendation to:
electrically distant, potentially up to 100 kms away from the connection point for a Chapter 5
connected Generator connected to a DNSP’s distribution system. Has AEMO completed any • allow agreement by the NSP and AEMO to a point of application for
studies or publish evidence to confirm overvoltage conditions are non-credible in the sub- overvoltage application at a location with nominal voltage higher than
transmission and distribution networks and HVRT capabilities from DNSP connected the connection point, where the plant is connected at nominal voltage
generation are not required for overvoltage conditions in the sub-transmission and distribution less than 66 kV with no automatic tap-changing transformer between
networks? This would also imply that S5.2.5.4 for distribution connected generation would its production units and the connection point.
need to be assessed on a SMIB model up to the nearest 132kV/275kV connection points
through sub-transmission mesh networks, adding unnecessary complexities to the SMIB
modelling. In our experience, S5.2.5.4 compliance has not been an issue for distribution or
sub-transmission connected Chapter 5 Generators and therefore we suggest re-considering
the proposal.
Siemens Gamesa – Supports
SGRE support these changes.
Solar Turbines – No objection; clarification
Additional note to stated requirements:
(2), (3) are unlikely to be field testable for generating units for generating units that shall be field
tested. Therefore that would be based on manufacturer declaration from manufacturer. It is
recommended to have this clearly stated.
TasNetworks - Supports
TasNetworks supports this proposed change.
Tesla – Supports
Tesla remains supportive of this change.
Transgrid Supports

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
Supports making the point of application of over voltages at the nearest HV transmission location
for connections below 66kV. This is consistent with approach proposed for the NSW REZ access
standards.
Requirements for overvoltages AusNet Support with clarification The specific proposed change was not consulted on in the draft report,
above 130% In AEMO's revised recommendation, it is aimed to clarify the power frequency root mean square but the report sought feedback on how this issue should be addressed.
voltages outlined in S5.2.5.4(a)(2) to (8) and (b)(1) to (5). However, this crucial clarification has The proposed drafting and the discussion in the update report
not been addressed in the draft NER amendments. represents the outcome of AEMO’s consideration of that feedback and
further analysis of this issue.
Caterpillar – clarification sought
There was a range of stakeholder feedback on this issue.
The current set of requirements are understood as the peak voltages seen from network surges
and is given for the purpose of insulation coordination. It is requested to clarify if there are Several respondents questioned the reference to peak voltages and
specific unit level requirements. non-power frequency waveforms. The main reason for these references
is that phenomena causing voltages exceeding 130% are likely caused
CEC – Opposes Alternative proposed by switching surges or lightning.
Reference to peak voltage of 184 % is likely to cause confusion with RMS voltage. It is unclear as AusNet, Energy Queensland and Hydro Tasmania requested
to why reference to peak voltage and non-power frequency voltage is required. clarification of which voltages are RMS. AEMO expects that the
• Subject to agreement by the OEM, blocking may be considered an appropriate response which voltages above 130% are not power frequency voltages, but are more
is less disruptive than a protection trip. correctly characterised as slow front overvoltages or fast front
• It is unclear why non-power frequency voltages have been introduced into this clause. overvoltages as described in IEC 60071-1.
Reference to insulation coordination in this clause is not appropriate and is a design matter. This standard, which applies for equipment designed for operating
voltages above 1 kV (not low voltage up to 1kV as suggested by Solar
• We are concerned that referring to IEC 60071-1 and insulation coordination will require
Turbines) describes:
proponents to undertaken insulation coordination studies in order to demonstrate compliance
with this clause. • Slow front overvoltages: transient overvoltages usually unidirectional
with time to peak 20 µs <Tp ≤ 5000 µs and tail duration less than T2
• The root cause of the issues of this clause is that the upper limit is unbounded. Hence the
≤ 20 ms.
correct approach to updating this clause should be to specify an upper limit for high power
frequency voltages. These are typically what result in equipment tripping (based on a • Fast front overvoltages: transient over voltage, usually unidirectional,
protection setting). with time to peak 0.1 µs < T1 ≤ 20 µs and tail duration T2 <300 µs.
CPSA – Opposes, Alternative proposed The standard describes standard shapes for these voltages profiles for
The problematic aspect of this clause in relation to over voltages has been the unbounded >130 testing. For slow front overvoltages which are representative of
% requirement. Introduction of reference to peak voltage and non- -power frequency voltages switching surges, Tp – 250 µs and T2 – 2500 µs. For fast front
and IEC 60071-1 will only complicate things. The focus should be on providing an upper limit to overvoltages, which are representative of lightning impulses, T1 = 1.2
over voltages. µs and T2 = 50 µs.
ElectraNet – Partial support, but concern about Rules drafting The value specified in the access standard was intended to provide the
value of the peak voltage (not RMS) for use in specify in ride through.
The proposed inclusion of new clause S5.1.4(a1) relates to transient voltages and is not
considered to be consistent with the existing intent of NER S5.1.4 that relates to power frequency
voltages. It is considered that this proposed clause is not appropriate in its current location in the Neoen suggested that the existing limit is derived from the system
draft Rules. Additionally, while the proposed Rule is understood to be intended to require the standard of S5.1a.4, which relates to a power frequency voltage across
design of the network to manage transient voltages resulting from switching of network elements, a 20 ms cycle. AEMO notes that the current wording of “over 130% of
the current drafting is not sufficiently clear. The specified standard is focused on determining the normal voltage for a period of at least 0.02 seconds after T(ov)”
maximum withstand voltages of plant and the selection of standard insulation levels, yet it is provides an unbounded requirement whereas the proposed drafting

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
understood that the intent of this clause is to ensure the effective management of peak over- specifies “at least” would be satisfied provided the plant can remain in
voltages due to plant switching. The current drafting does not achieve this intent. CUO for a small amount above 184% peak for at least 20ms.
ENA – switching surges (NER S5.1.4 and NER 5.7.2) – needs further consultation Transgrid was concerned about relating a peak voltage of 130% rms
Appendix A2, S5.1.4 (a1) includes new obligations on NSPs regarding network design to ensure power frequency to 184% used for a peak voltage for a different type of
switching of network elements does not cause connected plant to experience slow front transient waveform. The conversion was simply to ensure that the value was
overvoltage above a certain level. Clauses S5.1.4 and S5.1a.4 are applicable to power frequency higher than the peak of the voltage specified in S5.2.5.4(a)(2).
voltages and hence it is not appropriate to include transient overvoltage requirements under CEC and CPSA suggested instead imposing an upper bound on the
S5.1.4. It is also worth noting that the proposed requirement to manage switching surges that voltage. Tesla would prefer to remove the requirement above 130%
cause overvoltages outside of the system standard at the connected plant, relies on the switching altogether (as would Siemens Gamesa), but Tesla would also support
surge and the resulting transient overvoltage at the connected plant being directly related, which an upper bound of 140%. AEMO notes that it initially proposed an upper
is not the case. The transient overvoltage at the connected plant is highly dependent on the bound of 140% in the 2018 rule change, but this was not accepted
design of the connected plant, and in particular, surge arrester specification and placement at the based on stakeholder opposition. Neoen questioned whether the plant
connected plant. It is also worth noting that this issue is already handled by the existing rules and should be required to remain in CUO for these types of voltages.
relevant international standards to which both network elements and connected plant must be Neoen suggested recording the peak voltage for which the generator
designed to. will disconnect to protect its plant. AEMO notes that feedback from OEM
Energy Queensland – clarification discussions suggests that there may be multiple different levels at which
The amended rule wording should provide clarification as to whether these voltages are root disconnection could occur (above 184% peak), so this may not be
mean squared voltages. practical. Transgrid suggested the use of IEC 60071-1 to define ride
through requirements for generators. However, IEC 60071-1 is related
Ergon Energy and Energex note that under IEC60071.1, switching impulses are not considered to the voltage withstand of insulation and does not translate naturally to
for voltages under 275kV, only lightning impulse withstand and short-duration power-frequency this application. Insulation is required to withstand conditions that
withstand voltages. We would appreciate AEMO’s views on whether our assessment aligns with generators should not be expected to ride though.
AEMO’s intended changes.
Powerlink did not comment on the proposed inclusion of the reference
Hydro Tasmania – Support, with clarification to switching surges in S5.2.5.4, but suggested that any insulation
The clarifications in terms of clearly identifying which voltages are RMS and which relate to coordination obligations be placed on all technically relevant parties.
switching surges are acceptable. The explicit capping of the TOV in the 20 ms period is a sound AEMO notes that there are existing obligations on the generator within
extension of the rule. The related changes to clauses outside of NER S5.2 are also acceptable. S5.2.3(a) and S5.2.3(b) to agree on relevant technical matters including
The issue of >V/Hz should also be considered here. insulation coordination and protection, and that the insulation levels of
Neoen – Partial support with clarifications the plant are coordinated with the insulation levels of the network to
which the generator is connected, and that the plant is capable of
This standard needs to introduce a RMS voltage limit for remaining connected to the network. withstanding without damage the voltage impulse levels specified in the
The way the existing standard and recent proposal from AEMO are worded implies there is no connection agreement.
RMS voltage limit for remaining connected to the network (voltage “greater than 130%”). Further
changes proposed to this standard should avoid specifying values “above” or “greater than” The proposed drafting places an obligation on NSPs not to cause
without introducing the limit – it leads to ambiguity and implies there is no limit of voltage for switching surges that would adversely affect other network users. It
which the plant must be connected. would be possible to include a corresponding obligation for generators.
Note that the existing limit is derived from the system standard of S5.1a.4 which relates to power TasNetworks was concerned it would be costly to ensure that its
frequency voltage - I.e. voltage across a 20 ms cycle. Introducing limits for voltage of less than equipment would be able to meet an obligation not to cause connected
20ms duration relates to transients or impulse voltages. It is essential to ensure that any changes plant to experience slow front over-voltages of the type contemplated in
with respect to this requirement are consistent with the agreements made between a Generator IEC 60071-1.
and an NSP under S5.2.3(a) and according to the design of S5.2.3(b). These include matters AEMO agrees that only repeated over-voltages of this type should be
regarding insulation coordination and voltage impulse levels. The requirement for CUO during targeted with any requirement, considering that lightning strikes (fast-
impulse events needs to be justified and defined. What is being sought with respect to this

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
provision. Certainly, remaining connected for the duration of a transient event is essential, front overvoltages) are highly random. This would limit the scope of
however, it needs to be recognised that plant must protect itself from externally induced events work (if any) needed to comply with the clause.
and continuing to operate under such conditions must be managed within the reasonable Transgrid and ENA raised concerns about the location of the
capability of plant. The correct coordination of insulation including operation of surge arrestor requirement within S5.1.4, as this relates to power frequency, not
devices during such transient events will impact what might be considered “CUO”. Need to voltages that are other than power frequency. AEMO acknowledges this
ensure that in this context merely not disconnecting is sufficient. concern.
The peak voltage of 184% must be well defined within the Rules and the OEMs should be well Regarding Energy Queensland’s comment on switching surges, the
consulted on selection of this level – high voltages will damage IBR’s equipment and different standard provides some indicative values for test levels for voltages up
technologies will require a different level of protection. Defining unreasonably high voltage to 245 kV for lightning impulses and short-duration power frequency
withstand level is not beneficial to operation of the network as damaged generation will not be overvoltages. However, AEMO does not find anything to indicate that
able to return to service after fault clearance. Suggestion to record the peak voltage for which the switching surges are not to be considered at those voltages.
generator will disconnect to protect its equipment instead of imposing an arbitrary level.
“Blocking” should also be defined within the Rules – many inverters must disconnect within Transgrid preferred the rule to have the form at least 130%, which
milliseconds (e.g. 3 ms) to protect equipment from physical and irreversible damage and the use would be consistent with the voltage representation rest of the clause,
of external devices diverting or “blocking” the voltage or current in any way will not provide and is consistent with their suggestion to use the IEC term “temporary
sufficient level of protection. overvoltage”. AEMO acknowledges that switching between types of
voltage representation does seem to be causing confusion, even though
General comments: the standard defines the types of voltage described in the clause.
• Proposal refers to matters that are related to primary plant design (e.g. protection and AEMO also agrees with TasNetworks that for the 184% formulation, the
insulation coordination) and are already agreed between the connecting plant and the NSP rule would need to specify whether the value is phase to ground or
and recorded in the Connection Agreement. Addition of these in the standard will again further phase to phase.
complicate and prolong GPS negotiations without a tangible benefit to network operator/owner.
AEMO notes that the rest of the clause does not specify whether the
• When NER refers to an AS or IEC document it places an obligation on a potential participant to values refer to phase to phase or phase to neutral or phase to ground
purchase that standard – these are not open documents accessible to everyone the same way voltages either.
as the NER. With numerous references, it can become expensive to maintain a library.
Powerlink suggested including a requirement that protection settings not
Powerlink – Alternative proposed be timed to trip earlier than 20 ms. Transgrid supported the requirement
• The proposed change puts an explicit obligation on the NSP to design its network and for temporary overvoltage at least 130% for at least 20 ms.
insulation coordination in a particular manner. In the electrical vicinity of a given connection AEMO raised Powerlink’s suggestion with OEMs and developers to
point, there can be NSP equipment (for which an insulation coordination obligation would be gauge their response. Some OEMs raised concerns, for example, how a
made) as well as equipment that is part of other generating systems. Therefore, we protection based on energy would be treated for such a clause. Other
recommend that any insulation coordination obligations are placed on all technically relevant stakeholders considered there would always be a need for some
parties. This would include an obligation on each generating system to ensure their equipment instantaneous protection to protect a plant from damage. In light of this
has been designed so that switching of their elements does not expose other parties to feedback AEMO proposes to incorporate the requirement only in the
switching surge voltages. AAS for NER S5.2.5.8.
• Powerlink recommends there should be a requirement for no protection elements with trip Transgrid said that AEMO has not provided evidence as to why slow
timer settings <= 20 ms front overvoltages are more of a concern at these levels of voltages.
Siemens Gamesa – Alternative proposed The reason that switching surges are more of a concern than fast front
overvoltages (lightning flashes) is that there is usually more energy
SGRE suggest to remove the requirement for a voltage at the connection point above 1.30pu as
associated with them typically, because of the longer duration, as
Network users are incentivised to ensure their plant is capable of withstanding the required
described above. Of course, this is not absolute as there is a distribution
switching and lightning surges to maintain the integrity of their equipment. of durations and magnitudes for switching surges and lightning strikes.
Solar Turbines – Partial support with clarification Also, because switching surges can be repeatable, as they are affected
by the design of the power system, there is higher probability that they

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
In reference to “AAS peak voltage of at least 184% of nominal voltage… and a fast overvoltage will cause damage to equipment, as surge arresters have limits on
(lightning impulse) at the connection point”: operations.
• This should correspond to a lightning event and associated protection and capabilities shall be Tesla raised a query on the meaning of blocking. The intent was to
addressed as part of the design of an electrical installation, correspondent AS or IEC std shall allow some relaxation of the CUO requirement for very short durations
be used to define protection against overvoltages in such installation. The reference std for the plant to protect itself from damage. Following further OEM
provide much more detailed information associated to component capabilities than the discussions AEMO understands that there may be a variety of
indicated std measures that IBR plant takes to protect itself from extreme voltages
which are more complex than simply suspending the supply or
• This has not to be addressed in a Grid Connection requirement except for introducing a
absorption of active power and reactive power, and that the transition
reference to such std and the fact such protection shall be installed in the plant (other than the
back from the protected state to full operation might also need to be
mentioned IEC 60071-1)
considered. Considering the potential to misinterpret this proposed
• (Note that IEC 60071-1 refers to low voltage system up to 1 kV; point of connection is 66kV or change, and that it is not simple to describe the range of acceptable
above) behaviour, AEMO has decided not to progress it further.
TasNetworks – Partial Support
TasNetworks agrees with the principle of points 1, 4 and 5. We would like to confirm that the first Final recommendation
point should read “Require CUO for peak voltages less than 184 %” so as to be consistent with
Considering the above feedback, AEMO recommends modifications to
the fourth dot point. The draft rule should clarify whether the waveform measurement is phase-to-
the Update Report recommendation to:
ground or phase-to-phase. NSPs should use good electrical industry practice when designing the
insulation coordination of the network. This does not mean that every switching surge events will • apply an obligation on NSPs not to cause switching surges for
not lead to a peak voltage increase above 184%. Indeed, there is no way to guarantee this connected plant, and amend the requirement to be for “repeated”
exceedance will never occur. Furthermore, with appropriately sized surge arrestors, spark gaps, slow front overvoltages.
etc, the risk to equipment can be acceptably reduced. TasNetworks does not believe NSPs will
be able to meet this obligation under S5.1.4(a1), without significant investment. • rely on the requirements of S5.2.3 for insulation coordination and
impulse withstand, but add a requirement (in that clause) on the
Tesla – Opposes Schedule 5.2 Participant not to cause repeated slow front
Tesla has some serious concerns with this recommendation. overvoltages that would affect the NSP’s equipment (complementary
It is unclear to us how the 184% requirement was calculated based on IEC 60071.1) to the previous dot point)
We are also unclear as to the implementation risks of including this requirement. Will this result in • require the plant remain in CUO for voltages at least 130% for at least
additional testing and compliance certifications? 20 ms in S5.2.5.4 AAS.
We are unclear what is meant by permitting the plant to “block” for transient overvoltages. Does • specify that the voltages in S5.2.5.4 refer to rms power frequency
this effectively require plant to ride through these peak voltage requirements. Noting these quantities.
concerns above, we do not support the revised change and remain supportive of our initial • omit the previously proposed NER S5.2.5.4(e4).
position provided in our previous submission to AEMO and extracted below:
• In S5.2.5.8 AAS, add a requirement for no voltage-related protection
“Tesla would suggest an alternative that could be considered is to delete S5.2.5.4(a)(1) which settings less than 20 ms.
would effectively create an upper bound of 130%. Alternatively we would be supportive of Option
4 which would see the introduction of an upper-voltage limit of 140%”
Transgrid – further consultation is required
• There are two very different types of over-voltages to be considered:
– Temporary overvoltage for power frequency overvoltage
– Transient overvoltage as defined in IEC 60071-1
• Temporary overvoltage:

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
– S5.2.5.4 should only be for temporary power frequency overvoltages only.
– Supports the inclusion of “at least” in defining the upper limit for temporary overvoltage limit
up to 130% rms for one cycle. This aligns with the system standards in NER S5.1a.4.
• Transient overvoltage:
– This should be limited to gathering information from OEMs, including protection and inverter
behaviour. This would be in addition to the temporary power frequency overvoltage over one
cycle.
– Additional consultation is required as AEMO did not make recommendations in its Draft
Report.
– There is insufficient basis for parts of the draft recommendation, including:
▪ Using a transient overvoltage limit of 130% of the temporary overvoltage limit
multiplied by √2 is not related to the transient overvoltage, and is inconsistent with IEC
60071-1.
▪ The assertion that switching surges are of most concern is not substantiated.
▪ The use of IEC 60071-1 to define ride through requirements for generators. IEC
60071-1 is related to the voltage withstand of insulation and does not translate
naturally to this application. Insulation is required to withstand conditions that
generators should not be expected to ride though.
▪ PSCAD modelling of transient overvoltages - for accurate results that include the
whole of the generation system, including surge arrestors and transformers, the setup
of PSCAD models will need consideration of Balance of Plant details more commonly
applicable to insulation coordination type studies. This exceeds current modelling
requirements.
▪ Simulations to demonstrate compliance will involve applying representative transient
overvoltage waveforms at the point of application (e.g. the connection point) and
modelling surge transference down to the production unit level. While transformer
models have been proposed in the literature for this type of assessment, they are
complex and rely on input information pertaining to the physical construction of the
transformer (e.g. detailed knowledge of the core and winding geometry). This
information is not readily available, and modelling of this nature is not practical for
generator connections.
▪ As per draft NER amendment proposed in Appendix A2, S5.1.4 (a1) includes new
obligations on NSPs regarding network design to ensure switching of network
elements does not cause connected plant to experience slow front (transient)
overvoltage above a certain level. Issues with this requirement include:
▪ It has been included under “S5.1.4 Magnitude of power frequency voltage”. The title of
S5.1.4 clearly states that the clause is applicable to power frequency voltage. It is not
appropriate to include transient overvoltage requirements under S5.1.4.
▪ The wording of S5.1.4 (a1) sets the requirement for “voltages above those described
in clause S5.1a.4 of the system standards”. S5.1a.4 of the system standards is valid

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
only for power frequency voltages and does not define voltage limits for transient
overvoltage.
▪ The requirement relies on the switching surge (a traveling wave) and the resulting
transient overvoltage at the connected plant being directly related. This is not the
case, the transient overvoltage at the connected plant is highly dependent on the
design of the connected plant, most notably surge arrester specification and
placement at the connected plant.
– Transgrid designs network elements in accordance with the relevant international standards
(including the IEC 60071 series of standards for insulation coordination). Connected plant
must also be designed to IEC 60071 to meet the requirements of S5.2.3. In Transgrid’s
opinion, this issue is adequately handled by the existing rules and relevant international
standards. Nothing further needs to be included in the NER regarding transient overvoltage.
Clarification of continuous Akaysha Energy – supports The proposal to address this issue was generally well received.
uninterrupted operation (CUO) AusNet Supports with clarification Powerlink suggests that there could be some level of reduction in
in the range 90% to 110% of reactive and active power permitted as part of the negotiation. AEMO
normal voltage AusNet notes voltage variations greater than 10% within the range 90% to 110% of nominal notes that the proposed wording allows for some reduction in active
voltage, temporary active power output reduction and temporary reduction in reactive power power including “other factors that the Network Service Provider and
capability, corrected by tap-changing transformer action is acceptable when assessing CUO AEMO consider reasonable in the circumstances”.
performance.
TasNetworks suggested that S5.2.5.4(e3) should read for voltage
However, the response time of OLTC in transmission and distribution can differ significantly. In reductions greater than 10% within the range of 90 -110% of nominal
distribution networks, the response time of OLTC can be as high as 1 to 2 minutes, which may voltage, temporary active power reduction and temporary reduction in
not be genuinely classified as a temporary response. To ensure a more precise definition of reactive power capability corrected by tap-changing transformer action
temporary response, AusNet suggests specifying the acceptable response time limits (e.g.,7.5s) are permitted. AEMO has described the requirement as variation rather
rather than accepting performance to be corrected by OLTC. than reduction to account for scenarios in which the voltage rises, for
Bo Yin - Opposes example, from 0.99 to 1.1 pu.
The CUO requirement assumes the dynamic reactive power which is obtained without reliance In its response on S5.2.5.1, Transgrid commented that the rule should
on OLTC action. This is inconsistent with S5.2.5.1. not encourage Schedule 5.2 participants to enable limits that restrict the
Caterpillar – Support with clarification reactive capability of the plant. AEMO agrees with this sentiment, and
will consider whether any minor changes to S5.2.5.4(e1)(2) drafting and
A linear reduction in the corners of the U-Q/Pmax (voltage-reactive power) profile is allowed as S5.2.5.13 (2B)(iv) are required to make this clear.
mentioned in NER S5.2.5.1. It is therefore proposed to consider NER S5.2.5.1 conditions as part
of this CUO range. AusNet suggested that OLTC response in the distribution network may
be as long as 1 to 2 minutes, and proposes that response should be
CEC – no concerns raised corrected within 7.5 s rather than by OLTC action. AEMO understands
No comments on what is proposed in principle. that distribution networks are typically obliged to keep voltages within
Energy Queensland - no concerns raised 5% and variations in excess of 10% should be rare. Voltages in
distribution networks are more likely to be operated close to nominal
Ergon Energy and Energex make no comment voltage, so a voltage drop of more than 10% is more likely to go below
Goldwind Australia 90%, in which case the requirement does not apply. In addition, mostly
We are supportive of the proposed changes. We consider these changes to be important to small plant is likely to be impacted, and the effect may be offset by
enable efficient connection of newer technologies such as grid forming. some reduction in load affected by the same voltage disturbance.
Considering all these factors, AEMO considers the previously proposed
Powerlink – Supports with clarification rule is sufficient for the purpose.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
• We support the limitation of the assessment of maintaining active or reactive power to a Final recommendation
maximum voltage change of 10%. Considering the assessment above AEMO will retain its update report
• While not considered in AEMO’s Update Report, Powerlink suggests that some level of recommendation, and will review its proposed drafting for
reduction of active and reactive power at the connection point can be accepted as part of CUO S5.2.5.4(e1)(2) and S5.2.5.13 (2B)(iv) to confirm it does not promote
and form part of a negotiated access standard, if agreed to by the NSP and AEMO. unnecessary limits on reactive power capability.
Siemens Gamesa – Supports
• SGRE support these changes.
Solar Turbines – Support with clarification
Looking at Draft Recommendation, there is mention to reactive power capability within the normal
voltage range (and outside it).
It seems this is covered in S5.2.5.1.
• Makes sense to have reference to S5.2.5.1 when it comes to voltage deviation.
TasNetworks – Supports, with clarification
• TasNetworks supports this proposed change. We believe the statement in the second dot point
should read “voltage reductions greater than 10%…” rather than “voltage variations greater
than 10% …”
Tesla – Supports
• Tesla is supportive of the revised AEMO recommendation.
Transgrid - Supports
• Transgrid supports the revised recommendation on the CUO that require plant to maintain
reactive power capability, and active power output (with the exception of active power
reduction due to transient response, losses, energy source availability and any other
reasonable factors) for voltage variations of ±10% in the range of 90% to 110% nominal
voltage.
• Transgrid is in favour of removal of the ramp time requirement and the associated assessment
methodology requirement in the Rules.
• While Transgrid support the revised recommendation for voltage variations greater than 10%
within the range 90% to 110% of nominal voltage, that allows the tap-changer response to
occur, the term ‘temporary’ should be better qualified.
Combined frequency and Hydro Tasmania – Alternative proposal Hydro Tasmania raised a concern about the requirement for CUO for
voltage disturbances Hydro Tasmania acknowledges that AEMO recognises HT concerns of simultaneous >V and <f combinations of voltage and frequency deviation for synchronous
and that whilst a possibility would be rare, however there is no proposal to address this. AEMO machines for which over-fluxing is an issue.
notes “This means that technically a plant must be able to remain in CUO for combinations of AEMO notes that S5.2.5.3 MAS has a carve out in the MAS for V/f
abnormal voltage and frequency within the levels and durations of S5.2.5.3 and S5.2.5.4 if they limitations. In addition it may be possible to specify a specific limitation
occur simultaneously. “ under S5.2.5.5 MAS to cover off this issue, at least so far as the
combination relates to multiple simultaneous contingencies.
Another possible avenue open to a Schedule 5.2 Participant is that the
they can propose to the AEMC under NER 5.3.3(b2) a plant standard

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However, HT proposes that upon inspection of protection settings, few, or no synchronous that covers the capability and could be accepted as an alternative to
generators in the NEM would be able to comply with this requirement, nor would be willing to part of an existing technical requirement.
comply with this requirement based on resulting plant damage. Final recommendation
In terms of streamlining the connection process, the specific limitations for multiple contingency No changes are proposed.
events causing high V/f ratios should be clear performance standards of a generator can be
clearly documented. The typical fluxing capability as per AS/IEC 60034 or IEEE C57 could be
referred for new generators.
NER S5.2.5.5 – Generating system response to disturbances following contingency events

Definition of end of a AusNet – partial support Most respondents supported the proposed change to add a definition of
disturbance for multiple fault AusNet believes that end of a disturbance for MFRT should be the first instance where voltage at the end of a disturbance.
ride through point of connection reaches a level between 90% and 110% of the normal point of connection AusNet preferred the simpler formulation of the clause, without the
voltage. reference to 20 ms.
This approach differs from AEMO’s draft recommendation, where end of a disturbance means Tesla suggested adding “and frequency recovers to the PFR deadband
voltage return within the range 90 to 110% of normal voltage at the connection point for at least for at least 20 ms” to this definition. AEMO notes that the effect of
20ms. Implementing this proposed change would eliminate any ambiguity related to performance frequency deviation is allowed for in the proposed changes for the CUO
expectations, particularly in scenarios involving multiple voltage fluctuations within and outside definition, and MFRT as presented in this clause is mostly about
the specified range. multiple faults.
Caterpillar – alternative proposed (not related to this issue) Caterpillar requested relaxing the fault ride through clearance time for
It is proposed to relax the fault ride through (FRT) requirement, from 430 ms to 150 ms, for MFRT to be 150ms instead of 430 ms, to allow for the risk of pole
synchronous generators to consider the multiple fault ride through (MFRT) scenarios. There is a slipping. AEMO notes that in the proposed rule it has allowed Schedule
high risk of pole-slipping for synchronous generators as the fault clearing time increases. The 5.2. Participants to declare specific limitations which could include
proposed 150 ms is the fault clearance time for medium- and high voltage grids as given in most conditions that could lead to pole slipping.
European grid code documents (Ref: EU 2016/631 alias NC-RfG and EN 50549). Solar Turbines commented that 20 ms seems too short, and
CEC – No concerns raised recommends that the end of the disturbance be considered when the
plant stops oscillating. However, AEMO considers that definition would
No comments on what is proposed apart from the fact that these studies have become mostly an tend to incentivise poor tuning, because the more oscillatory the
academic exercise with no real-world context considered. response, the further apart the faults could be, which does not seem an
Energy Queensland – No concerns raised appropriate outcome.
Ergon Energy and Energex make no comment Transgrid considered that overlapping or simultaneous faults should still
Powerlink – Support be considered under this clause. AEMO considered this possibility as
part of the draft report, but has not identified anything that would result
Powerlink supports this proposed change. in a different position.
Siemens Gamesa – Supports Final recommendation
SGRE support these changes. Considering all feedback, AEMO will retain its update report
Solar Turbines – Alternative proposed recommendation.
20ms when voltage is within +/-10%Un seems too short, but also not consistent in defining the
system in stable condition for active power recovery (most probably the voltage is still oscillating
leading to associated power measurement oscillation). That would allow to consider the end of
the disturbance when the voltage happens to just recover to 90% Un.

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It is recommended that the end of the disturbance is normally considered when the voltage is
considered back to stable condition (eg not oscillating and within +/-5%Un from nominal). This
definition is needed to apply for any associated requirements.
TasNetworks – Supports
TasNetworks supports this proposed change.
Tesla – Partial Support with clarification
Tesla would suggest an additional change to the definition to refer to both voltage and frequency
recovery. This would change the definition to “…following fault clearance, the voltage recovers to
and remains within the range of 90 to 110% of normal voltage at the connection point for at least
20ms, and frequency recovers to the PFR deadband for at least 20ms”
Transgrid – General support
• In general, Transgrid supports AEMO’s intent in providing clarity on “end of a disturbance”.
• In regard to AEMO’s assertion that multiple faults occurring at the same time or with 0 ms
delay being a technically possible but highly unlikely event, Transgrid notes that a series of 15
disturbances occurring within a five-minute period (as currently assessed under the AAS) is a
low probability event in itself. Nevertheless, given the material impact of such an event to
system security, it has been recognised that it is important to understand and record the plant
capability to ride-through a multiple disturbance event. Therefore, in the same vein for the AAS
requirement, at least two consecutive faults–where the second fault commences immediately
after the clearance of the previous fault (i.e., minimum clearance between the two faults is zero
milliseconds)–within the 15-disturbance sequence should be included.
• Transgrid also notes that, the post fault voltage recovery behaviour in some instances may be
heavily impacted by the generator response. For example, post-fault voltage dips spikes or
oscillatory behaviour may be caused or exacerbated due to poorly tuned controllers causing
the voltage to move beyond the specified 90%-110% range (i.e., prolonging the disturbance or
causing subsequent disturbances), even though the original disturbance has been cleared.
Transgrid’s understanding is that if a disturbance is prolonged or exacerbated due to poorly
tuned plant response, that will be considered as a non-compliance to the CUO requirement.
Form of multiple fault ride AusNet – Supports with clarification There are two parts to this change:
through clause AusNet supports AEMO’s revised recommendation concerning NSPs developing extra • An allowance for specific limitations to be declared and carved out as
connection-specific non-credible contingencies events that align with historical faults. part of a negotiated access standard, supported by evidence, and
Nonetheless, AusNet extends an invitation to AEMO to provide clarity regarding the specific
• Consideration of what studies should be done to support the
criteria that qualify as “reasonable grounds” for an NSP to identify an inadequately disclosed
proposed performance standard.
limitation. Furthermore, AusNet holds the perspective that defining a baseline common suite of
tests encompassing the MFRT requirements under the AAS and MAS would significantly The former was well supported in the draft report consultation. In the
enhance the value of AEMO’s initiative. The evidence can be provided in the form of type testing update report consultation it was also supported, though most
or a hardware in the loop (HIL) report. respondents did not comment on it at that stage.
CEC – Partial support, partial opposition Consideration of what studies should be done to support the proposed
standard is more difficult, as the nature of the MFRT requirement is
• The presumption that an NSP requesting additional studies when there are reasonable such that one cannot prove compliance.
grounds to believe there is inadequately disclosed information is unlikely to yield the desired

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outcome. For example, if a protection system which limits MFRT capability is not modelled, Some stakeholders supported the proposed drafting, others opposed
undertaking additional studies will yield the same results as previous studies. Hence the part or all of it.
outcome would be an endless loop of studies being undertaken. AEMO considers it is impractical to do exhaustive studies for this
• The focus should instead be on having a carveout to MFRT requirements by documenting performance requirement, as there are too many possible combinations
specific technology limitations in the performance standards to avoid an endless loop of to consider, and compliance cannot be proven by studies.
studies. • One option previously considered was to provide a test suite. The main
• In assessing this clause the NSP and /or AEMO should provide guidance on the nature of advantage of this approach is simplicity and limited work. However,
multiple fault expected based on previous events and /or considering the actual power system. stakeholders pointed out that the lack of location-specific contingencies
made this less useful. Some NSPs requested that they either be
CPSA – Partial support
permitted to add or substitute studies relevant to the connection. Some
• We are concerned that these studies have almost become an academic exercise to run as stakeholders still prefer the test suite option, but AEMO considers that a
many simulations & combinations as possible. smaller set of more targeted studies could provide better outcomes to
• Where studies are required, the focus should be to consider actual power system operating identify the performance of the plant and its limitations in the
conditions / limitations when assessing this clause. surrounding network.
• The focus should be on having carveouts to CUO based on equipment limitations within the AEMO agrees with CPSA, Powerlink and other stakeholders that the
GPS and have the OEM declare these limitations (eg auxiliary supply limitations, dump resistor key value of this clause is to identify plant limitations. These may be
thermal limitations etc revealed by studies, but only if the limitation is one that is modelled.
Otherwise they will need to be identified by other means (such as
ElectraNet – Clarification sought information from the OEM).
• Further clarity is required from AEMO on the following proposed revisions: In the draft report AEMO proposed to give participants the option to
• [Link](d)(1) requires that the NSP advise the “minimum three phase fault level at the seek guidance from the NSP on what contingencies they should
connection” for tuning of the plant. This fault level is then applied as a threshold below which consider. The rationale here is that the NSP has detailed understanding
further disturbance ride through is not required. Noting that S5.2.5.13 refers to “apparent of their network, and the combinations contingency events that might
system impedance” and that the definition of this impedance is different from a fault level, it is cause a limitation to be revealed in the modelling. These do not need to
considered important that the requirements in these two clauses be aligned. be 15 faults, but could be, for example, a combination of contingency
• S5.2.5.5(r2) requires that the NSP specify all combinations of multiple contingency events to events known to lead to a large phase angle jump.
be assessed by the proponent for the purposes of a Negotiated Access Standard. Clause (r3) There is no requirement for the advised studies to be complete or
then restricts the NSP from requiring the assessing any other events. Further clarity on this is comprehensive, as that would also be impractical.
required, specifically whether there is any restriction on the NSP undertaking their own On the other hand, AEMO proposed that the NSP could propose studies
assessments that may vary the sequence or combination of events in review of the proposed if there was something specific that they thought might show up as a
Negotiated Access Standard. limitation in a study or a limitation was not adequately described. While
ENA – Opposes limiting NSP capability to add studies for MFRT to “reasonable grounds” AEMO agrees with CEC that not all limitations will be revealed in
A fundamental principle of the current access standards and rules made by the AEMC is that studies, there are some limitations that can be observed that way.
proponents need to meet the automatic access standard or prove why a minimum or negotiated If the limitation is not in the model there is clearly no value in requesting
access standard is more reasonable. Given the power system is transitioning to lower emissions, a study. AEMO does not agree that the outcome would be an endless
there will be far more connections generating larger swings between minimum and maximum loop of studies being undertaken, as suggested by CEC.
operational demand and delivery and commissioning of new network infrastructure. CEC suggested that past history should form the basis for identifying
NSPs should have flexibility to request for additional studies for multiple fault ride through if likely faults in the future. There is no correlation between historical and
deemed necessary, as per the negotiation framework, without requiring ‘reasonable grounds’. 3 future faults. At best historical faults might be considered examples of
As such ENA does not support the inclusion of S5.2.5.5 r3) and suggest it is removed. The what could happen. The proposal that if requested, an NSP could
suggest faults that might be onerous, is in line with the considering the
actual power system, as CEC proposes.

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clause, including the provisions for “reasonable grounds” is likely to be problematic and create In response to clarification requested by ElectraNet regarding NSPs
subsequent issues. undertaking their own assessments, there is no limitation in the rules
Energy Queensland – No concerns raised preventing that.
• Ergon Energy and Energex make no comment. In response to ENA’s comments, it would not be in any NSP’s interests
to make requests that reduce the efficiency of the connection process or
Huawei Australia – Alternative proposal unnecessarily divert the NSP’s own resources for no good reason.
We recommend that AEMO publish a test specification for MFRT so that OEMs can provide lab AEMO notes that there is nothing to preclude an NSP from undertaking
test reports and apply them to different projects. their own studies should they consider it necessary.
Neoen – Opposes Powerlink also did not support (r2) and (r3), saying they are not aligned
Allowing the NSP to require additional MFRT studies – the introduction of MFRT requirement was with the intent of the MFRT capabilities of a plant. AEMO notes that the
to ensure that the generating plants have clear obligation in terms of remaining connected should intent of these clauses in combination is to focus on studies targeted to
multiple, consecutive faults occur. Increasing number of MFRT studies provides no clear benefits those conditions likely to be arduous for the plant, so as to reveal or
to the network owner. Comment from AEMO in the recent presentation that the NSP will only better define specific limitations – where they are capable of being
have a right to require additional studies if they suspect the proponent did not disclose all revealed in studies.
information about performance of their facility – if the information has not been made available it Transgrid questioned what constitutes “reasonable grounds” and argued
will also not be included in the models. Additional studies will not increase clarity. Regardless the that they should have additional flexibility to request studies during the
standard should not introduce ambiguity – if the requirements are expanded for MFRT it should connection phase. As Transgrid notes, limitations are often not
be clearly stated under what conditions NSPs can request additional studies. represented in models, so it would not be ‘reasonable grounds’ to
Powerlink – Opposes request additional studies related to something that is not represented in
the model. However, if the NSP knows, for example, of a firmware
• We do not support this change. Powerlink understands the MFRT requirements were added to limitation that is likely to be exposed through the model (because the
the technical standards to identify if there were any plant-level limitations (e.g. protection control is represented in the model) then there would be reasonable
settings, auxiliaries, breaking register/chopper) that would force a plant to trip under MFRT grounds to ask for studies to examine that point. AEMO suggest that the
when a power system could sustain those MFRT in the absence of the plant under appropriate action in that case would be to discuss the possible
consideration for connection. limitation with the Schedule 5.2 Participant, so that they can design
• Powerlink recommends that for multiple faults, AEMO, the NSP and connection applicant studies to identify if there is a limitation and it can either be resolved,
should check that the model can ride through multiple faults (which can be assessed in DMAT worked around or documented appropriately.
studies), with plant compliance assessed via OEM statements on capabilities (e.g. of auxiliary In summary, AEMO notes the lack of support for (r2) and (r3) from
system ride through capability). Auxiliary systems may be the most limiting element of a parties who are concerned these will lead to excessive studies or
generating system for compliance purposes, but may not be modelled. parties who consider it will limit their ability to require studies,
• Powerlink does not support S5.2.5.5 (r2-3), as this is not aligned with the intent of the multiple
ride through capabilities of a plant.
Final recommendation
Siemens Gamesa – Support with clarification
Considering stakeholder feedback, AEMO recommends modifying the
• SGRE Support these changes, with the understanding that the NSP will have the power to update report recommendation to remove (r2) and (r3) provisions.
request additional studies (i.e. power system studies) to assess any potential limitation. AEMO will retain other aspects of the update report recommendation,
However, that defining any hardware or prototype test specification in order to demonstrate a including relating to the declaration of specific limitations.
platforms capability will remain the responsibility of the OEM.
• SGRE believe that the best approach would be for AEMO to release an assessment guideline
showing a list of possible onerous multiple faults based on historical faults in NEM not
specifically in a state, for example, incidents like in SA in 2016 or in QLD in 2021 could be
good candidates for studying multiple fault ride through capability of a technology. The current

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issue that most OEMs are suffering because it is difficult to test the technology’s
performance/robustness for the totality of scenarios that fall under the AAS.
Solar Turbines – Alternative Proposed (on a different issue)
• See above comments to the disturbances requirements described in S5.2.5.5(c).
• 3-phase automatic reclosure shall be as part of the credible contingency event scenario,
however they shall not separate (and reconnect) the generating plant to the grid
• (4) the requirements in S5.2.5.4(a)(7) and a(8) foresees both voltage ranges (eg a(7) voltage
between 80%Un and 90%Un and 10sec and a(8) voltage between 70%Un and 80%Un and
2sec) it is not clear if only one event shall be tested (ed 78%, 2sec) or two events need to be
triggered. It seems the requirement is for a single event
• It is possible to get a recommendation of the event to be tested, but as indicated above, it is
recommended a credible contingency event scenario (single line diagram with grid
representation) to be provided with the correspondent event and grid characteristic
information. It is recommended involvement of manufacturers in defining such requirements.
• It is recommended also to define a credible list of events pre defined sequence, however
system information shall be as well properly defined. It is recommended involvement of
manufacturers in defining such requirements.
• S5.5.2.5 (l) (9) There is reference to a fault level for which the generating plant has been
tuned.
– It is recommended to better specify what “tuned” means (primary control mode vs secondary
control mode? Protection settings?)..
– Note also that normally fault level is considered the Scc or Icc (eg fault level specified for MV
distribution), however it is not clear if this is the intention here.
Whereas fault level is expected with a different meaning, it is recommended to replace “a three-
phase fault level at the connection point” with “a 3-phase fault causing the voltage to drop at the
connection point…
TasNetworks – Supports
TasNetworks supports this proposed change. The first dot point provides TasNetworks with the
flexibility required to adequately assess multiple fault ride through in Tasmania.
Tesla – Opposes
As noted in our previous response, Tesla is not supportive of site-specific tests as we believe this
will add cost and lengthy delays to projects. AEMO’s revised recommendations will likely result in
the NSP asking for multiple studies to be undertaken which would yield the same results. As an
alternative we would suggest an allowance for NSPs to stage faults during commissioning in
reference to site specific concerns. Otherwise, we believe that all MFRT requirements can be
verified through modelling.
Transgrid – Supports
• Transgrid is in favour of AEMO’s recommendation on disclosure of MFRT limitations,
supported by evidence (preferably supported by laboratory tests or HIL tests).

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• Transgrid supports AEMO’s intent in allowing NSPs to nominate alternative/additional
combinations for MFRT if deemed necessary due to connecting location. However, Transgrid
believes that AEMO should consider defining a common suite of tests that would exercise the
models for MFRT requirement as proposed in Option 5 of the Draft Recommendation. While
this suite of tests must not be considered as an exhaustive list, it will provide the OEMs and
the developers a set of testing conditions that the plant should be designed to ride-through.
This can be supplemented with additional combination of MFRT test scenarios if deemed
necessary by the connecting NSP, due to the connecting location.
• In circumstances where NSP and/or AEMO reasonably believe there is an inadequately
disclosed limitation–that may be uncovered by specific multiple contingency conditions–both
AEMO and NSP should have the flexibility to request for these additional studies to be
considered. However, Transgrid notes that it is not clear on what is required to be provided as
‘reasonable grounds’ for the additional studies. If there are in fact inadequately disclosed
limitations, those limitations will be only known by the relevant OEM. If the limitations are
incorporated to the modelling (in most instances this is not the case), they may be uncovered
by specific multiple contingency events. NSP’s should have flexibility to request for additional
combinations for MFRT at the Connection Application stage if deemed necessary.
Number of faults and time AusNet – supports Most respondents supported the proposed changes, which allowed for 6
between them AusNet supports AEMO’s revised recommendation. faults within 5 minutes, with the potential for specific limitations which
might impact of timing between faults.
CEC – no concerns raised
Solar Turbines suggested that 6 faults each within 200 ms does not
No comments on what is proposed subject to review of rule drafting. seem applicable for a system based on reliable design. However,
Energy Queensland – no concerns raised AEMO notes that the power system in Australia does have records of
Ergon Energy and Energex make no comment occurrences with multiple faults in the same area within a short time of
each other, particularly associated with bush fire activity.
Hydro Tasmania – support with clarification
Hydro Tasmania asks for better guidelines and carve outs for physical
AEMO notes Hydro Tasmania’s previous comments on multiple fault impacts on synchronous constraints.
machines and that “this is an example of a type of issue that the amendment is intended to
address”. HT is however still unclear on how this may be addressed given proposed MAS will Considering the carve out for specific limitations, AEMO notes there is
require up to 6 disturbances. significant flexibility built into the proposed MAS despite the underlying
requirement to ride through at least six faults.
I.e There should be better guidelines and carve-outs in the MAS to allow for physical constraints
governing the ability for synchronous machine multiple faults ride through where the effort is not Final recommendation
in trying to demonstrate academic compliance, but moreover maximising plant capability within its Considering all feedback, AEMO will retain its update report
physical limitations without concern of not realising an academic MAS (which may not even recommendation.
present a credible fault ride-thought [sic] scenario).
Siemens Gamesa – Supports
SGRE support these changes.
Solar Turbines – Alternative proposed
S5.2.5.5(c) calls for faults that belong to credible contingency events. Is this a realistic credible
scenario?

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6 consecutive faults each withing 200ms do not seem applicable for a system based on reliable
design. In addition no further detail regarding such events is provided.
In general all events (faults) as they are described in S5.2.5.5(d) are expected to happen in a
very short time in the proximity of the generating unit, which seems unusual.
A different and more realistic approach is recommended. See comments above on event
proposal and grid scenario proposal.
Tesla – Supports
Tesla remains supportive of AEMO’s recommendation.
TasNetworks Supports
TasNetworks supports this proposed change.
Transgrid – Supports
Transgrid supports AEMO’s revised recommendation to retain the MAS requirement, while
allowing specific limitations to be carved out provided that the number of disturbances remains at
six.
Reduction of fault level below AusNet – partial support The proposed change considered that tuning of plant controls is
minimum level for which the AusNet supports AEMO’s revised recommendation on recording the range of fault levels for affected by the fault level under which the plant is designed to operate.
plant has been tuned tuning be advised by the NSP and recorded, in the RUG. However, to carve out the CUO for AEMO’s proposal is to:
MFRT in AAS and MAS may not be consistent with the objective on streamlining the connection • Assess the MFRT requirements considering the range of fault level
process. Given the rapid change occurring in the power system, to maintain the CUO for MFRT for which the plant has been tuned, and
beyond N-1 and extending it to at least N-1-1, thereby accommodating crucial planned [outages],
• Document the relevant fault levels so that these can be compared
remains a paramount consideration due to the magnitude of concurrent projects being executed
against the actual fault levels on the power system to identify when
on the network.
the tuning might need to be re-examined for different fault level range.
CEC – Support, with clarification requested Some respondents requested clarity on what AEMO means by making
No comments on what is proposed. the fault level more transparent. The proposed drafting includes a
It is unclear what the changes to S5.2.2 are in relation to making retuning requests ‘more requirement for the range of fault levels for tuning purposes to be
transparent’. Could AEMO advise? recorded in the releasable user guide (RUG). As the RUG is always
available to NSPs and Schedule 5.2 Participants the tuning range can
Energy Queensland – No concerns raised
be referred back to after connection to flag the potential requirement for
Ergon Energy and Energex make no comment retuning due to changes in the power system. Having the fault levels
Hydro Tasmania – Partial support, clarification recorded in the RUG avoids any need to change the GPS where
settings need to be updated, but GPS performance requirements are
• HT agrees that during and after multiple faults, the network condition could change
not impacted.
significantly, including fault levels. However, since 6 faults within 200ms assessment is rather
academic, it is unclear how this specification is going to be implemented to prove generating Settings changes can be undertaken through a request under S5.2.2.
system compliance in reality. Note that a Schedule 5.2 Participant must comply with its performance
standards regardless of the fault level, so it is the Participant’s
• HT is aware this clause was introduced in 2018 with supporting evidence based on simulation responsibility to update its settings through this process if needed to
results and historical data, however, very limited information can be found since then. HT meet its GPS. Nevertheless, if there is a change to the power system
would encourage AEMO to put some effort in a guideline, including technical objectives, that necessitates settings changes across multiple plants, it might be
performance expectations, compliance evaluation practicality based on genuine system events more efficient for the NSP to coordinate the changes.
(e.g. Callide event), to facilitate the technical understanding of this clause.

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Neoen – No change required This change was supported by AusNet and Powerlink explicitly and
This should be covered by S5.2.5.5(d)(7) and S5.2.5.5(l)(6) “provided that none of the events other respondents did not object to it. Transgrid suggested recording the
would result in: … the islanding of the generating system or cause a material reduction in power lowest fault level at which the plant can remain connected and stable
transfer capability by removing network elements from service”. (even if GPS compliance across other performance standards are not
achievable at this fault level).
Powerlink – Partial support; Alternative proposed
Neoen suggested that a lower fault level should be covered by
• For S5.2.5.5 (d) (10), Powerlink considers the plant should be expected to remain connected reference to reduced power transfer or islanding. While those conditions
and stable (not necessarily providing full compliance) for fault levels that are below the are associated with reduced fault level, the underlying fault level prior to
minimum expected fault level for a single contingency (i.e. minimum fault level used for tuning disconnection of any line element may also change over time, and a
purposes), down to the technical capability of the equipment (withstand SCR at the settings contingency event can also include trip of a generator, which may not of
that are used for compliance tuning). itself affect the power transfer capability but will reduce fault level.
• Powerlink supports the changes in S5.2.5.5 to make the conditions that might require retuning Powerlink considered the plant should be expected to remain connected
more transparent. and stable (not necessarily providing full compliance) for fault levels
Siemens Gamesa – Supports below the minimum expected fault level for a single contingency event,
SGRE support these changes. down to the technical capability of the equipment (withstand SCR at the
settings used for compliance testing).
Solar Turbines – Opposes
TasNetworks suggested the plant should nominate the level down to
This requirement is not clear not the draft wording or in the Draft Recommendation Update which it is stable and can stay connected and Transgrid made a similar
Report comment. AusNet suggested that the plant should maintain CUO for
Specifically, it is not clear what is the lower range for which the plant had been tuned (primary MFRT beyond N-1 extending it to at least N-1-1. AEMO notes that the
control mode vs secondary control mode? Protection settings?). fault level is very much influenced by the generation pattern, as well as
It is recommended to remove the requirement or better define the expectation or at least better the number of network outages. Considering Powerlink’s comment,
define what is the expected tuning. AEMO notes that the compliance testing for SCR under S5.2.5.15 does
not require the plant to use the same settings as for normal operation.
TasNetworks – Partial Support; alternative proposed Considering TasNetworks’ comment, there might be some value in
Generators should be required to nominate a minimum guaranteed floor for stable operation knowing the fault level down to which a plant is stable. However,
(down to a short circuit ratio of 3) and a level where they would be permitted to disconnect. determining this for combinations of multiple contingencies might be an
Tesla – Support arduous task requiring many studies, as the minimum fault level could
be different for different combinations of contingencies.
Tesla is supportive of the carveout provisions and the resulting inference that a retuning would
not trigger a full 5.3.9. We would suggest that more detail is needed by the final comment that This raises the issue of how NSPs determine and specify the range of
“the changes in S5.2.5.5 make the conditions that might require retuning more transparent fault levels for which plant is expected to remain in CUO, and for which
they are tuned. The rules do not make this requirement explicit, at
Transgrid – Supports with clarification present. There is benefit to transparency and consistency of approach
Transgrid suggests recording the lowest fault level (lower than the lower bound of the fault level across all NSPs in setting the range. AEMO discussed the
range for which the plant has been tuned to achieve GPS compliance) the plant can operate methodology applied by NSPs in a meeting with them, and use of the
stably and remain connected (even if GPS compliance across others performance standards are minimum fault level at the nearest fault level node in conjunction with a
not achievable at this fault level). single network outage was identified as a way to apply a consistent
approach.
Hydro Tasmania said it is unclear how the specification of 6 faults with
200 ms between them could be implemented for compliance
assessment. AEMO notes that 200 ms is the minimum time between
faults. In practice, auto-reclosure is common within 5-10s of the fault
clearance, so 6 faults within five minutes (e.g. associated with a severe

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
storm or bushfire), where fault level remains within the specified range
for tuning, is not infeasible. Ongoing compliance against ride through
clauses is assessed based on a review of actual power system
incidents, in this case multiple contingency events.
Final recommendation
Considering all feedback, AEMO proposes to define the minimum fault
level as the higher of the value equivalent to the SCR recorded for
S5.2.5.15, and the level that would be achieved at the connection point
considering the minimum three phase fault level at the nearest system
strength node, in conjunction with a network outage that most reduces
the fault level at the connection point.
This value should also be consistent with the level for tuning of the
controls, for which CUO is required.
AEMO proposes to retain the requirement to document the range of
fault levels for tuning in the RUG as previously proposed, to facilitate
review of tuning ranges in the future, with a view to the possible need
for settings changes over the life of the plant.
Active power recovery after a Akaysha Energy – Supports Most respondents supported the proposed change. Transgrid proposed
fault The submission supports the consistent conditions for active power recovery post fault with a a minor amendment changing “return” to “reaches”.
synchronous machine where GFM technology emulates synchronous and inertial responses. The AEMO supports this amendment, and will include it in the drafting.
submission also suggests that AEMO incorporate GFM voluntary specification details into the Powerlink noted there is a difference between an actual frequency
NER clause update, and references PFR. change and a measured frequency change. Measurement of frequency
AusNet – Supports, with clarification at the inception or during a fault can be challenging, and in general
AusNet supports AEMO’s revised recommendation on amending the MAS to include reference to control actions based on those measurements should not occur. AEMO
clause 4.4.2(c1) for primary frequency response (PFR) where S5.2.5.11 has been referenced notes that it is difficult to distinguish between a response to angle
regarding a frequency disturbance and include frequency response in the AAS. However, AusNet change and frequency and there is a level of greyness as to whether
suggests allowing active power recovery should start at the first instance when voltage reaches a response of virtual synchronous machines are controlled actions or not.
level to between 90% and 110% of point of connection normal voltage, instead of that voltage It is difficult to be definitive about interpretation of results in the rules, so
return stably into that range. AEMO prefers to leave this as flexible as possible. As is often the case,
AEMO recognises there is a balance to be achieved between specificity
CEC – No concerns raised and flexibility.
No comments on what is proposed. Akaysha Energy suggested that AEMO incorporate GFM voluntary
Energy Queensland – No concerns raised specification details into the NER. AEMO would like to clarify that
Ergon Energy and Energex make no comment consideration of including the Voluntary Technical Specification
requirements into the NER would be a subsequent piece of work,
Powerlink Support, with clarification beyond this review.
Powerlink supports this change in principle, noting the following caveats: Final recommendation
There is difference between an actual frequency change compared to a measured frequency AEMO will retain its update report recommendation, with a minor
change. Measurement of frequency at the inception of a fault, during a fault, or at or immediately modification to change “return” to “reaches”.
after fault clearance, can be extremely challenging. In general, controlled actions based on those
measurements should not occur.

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
Siemens Gamesa – Supports
SGRE support these changes.
Solar Turbin–s - Opposes
See comments above. Active power recovery shall be expected after transient condition which do
not corresponds necessarily to voltage within +/-10%Un and +20ms and +100ms. That’s
particularly true for system with inertia.
TasNetworks – Supports
TasNetworks supports this proposed change.
Tesla – Supports with clarifications
As noted above, we suggest that the MFRT end of disturbance definition refers to frequency as
well as voltage. This definitional change should also flow through to active power recovery.
Transgrid – Supports with clarification
• Transgrid support amend the MAS to include reference to clause 4.4.2(c1) for primary
frequency response where S5.2.5.11 has been referenced in regard to a frequency
disturbance response in the AAS.
• The ambiguity of the te‘m 'return’ is not addressed nor removed by the new “end of
disturbance” definition. The definition of “end of disturbance” affects the start time of the active
power recovery measurement (as mentioned above) but does not provide any clarity on the
end time of the active power recovery measurement, hence the potential misinterpretation of
‘return’ remains. In Transgrid’s experience, proponents have misinterpreted the end of active
power recovery measurement to be when active power ‘settles to 95%, not when it first
reaches 95% of pre-disturbance value. Hence Transgrid suggested including definition of
“recovery” to be the “first instance at which the active power reaches 95% of the pre-fault level”
for instead of the ambiguous term “return”. This is especially important to remove ambiguity of
the performance requirements if the active power has overshoot/undershoot/oscillations while
the voltage is stabilising in the 90% - 110% range.
Rise time, settling time and Akaysha Energy – Partial support More stakeholders supported this proposal than opposed it, but there
commencement time for strongly supports recommendations based on recent reactive current MAS change. was less support from NSPs and more support from generators and
reactive current injection developers.
Positive/Negative sequence ratios are difficult to obtain. The submission recommends further
consultation with OEMs on what to capture for unbalanced faults. There are several aspects to the change proposed:
AusNet – Partial support • Omission of settling time, consistent with the recent changes to the
MAS
AusNet supports the draft recommendation on omitting the settling time requirement in AAS,
which is further supported by changing the tuning objective to “adequately controlled” instead of • Inclusion of “step-like response” for rise time
“adequately damped”. However, AusNet still has concerns that without some general criteria • Addition of a “commencement time” requirement
being defined in the AAS around damping, there may be protracted negotiations or the potential
• Addition of a definition of “adequately controlled” at the request of
for degraded performance being deemed acceptable.
stakeholders from the draft report consultation.
CEC - Comment
Powerlink objected to the changes, with specific reference to “step-like”,
on the basis that they can be dealt with by negotiation. AEMO is

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
No comments on what is proposed. We note that the term ‘adequately controlled’ is more cognisant that, in many cases, a black and white interpretation of rules
qualitative in nature. As a general principle, the control transients should be assessed on what is wording rather than reliance on engineering judgement has been a
required and/or desirable to maintain system security and reliability of supply. more common approach in access standards assessment in the NEM
Energy Queensland – No concerns raised over the past 10 years. In reality each situation is nuanced and flexibility
in the rules allows for an NSP and AEMO to agree results that are
Ergon Energy and Energex make no comment acceptable using engineering judgement, but without that flexibility
Neoen – Clarification on commencement time application and definition of adequately would be rejected.
controlled AEMO does not agree that adding “step-like” to the description of the
The benefit of shortening the response commencement time to 10 ms and how will this be input adds complexity. The NER framework for compliance applies over
assessed is unclear. The current injection is measured in response to % voltage reduction – the the life of the plant and irrespective of voltage profile of the fault. It is
NER specification of voltage refers to power frequency voltage, which must be measured across unrealistic to expect an outcome from a test to be within defined bounds
a 20 ms cycle. How will the voltage reduction be measured under this clause to allow a response without also specifying the inputs to a similar level of detail. The addition
within half the cycle? of “step like” applies a common-sense measure to the input of the test,
For similar reasons it is also questionable whether existing technologies can meet this so that engineering judgement can be exercised within the rules
requirement. Currently network wide studies can only be run in PSS/e which is not suitable to framework to decide if it is a proper test for measurement of rise time. If
analyse transient phenomena that occurs in very short timeframes – the 10 ms requirement will the inputs are specified too rigidly, there will be no room for compliance
not be possible to verify prolonging and complicating discussions under this clause without a assessment based on actual faults. On the other hand, if the test
clear benefit to the network. The proposed definition for “adequately controlled” is required. applies to an unspecified fault voltage profile, compliance cannot be
demonstrated reliably because the input is not suitable in all cases.
Powerlink – Opposes “step like”
An alternative approach followed by many other jurisdictions
Powerlink notes that this section of the Rules was recently updated by the AEMC. We consider internationally is to fully specify a test, and undertake it in a test facility.
the proposed changes are not required and these issues can instead be managed through the Ongoing compliance assessment is then not required. However, at
negotiated access standard. Being more prescriptive about the current injection response (e.g. present the NER does not have the concept of separate design and
“step like” function) risk bringing more complexity into the assessment of compliance on site and ongoing compliance requirements.
in simulations (e.g. no fault results in a step-like response).
TasNetworks objected to the removal of settling time for reasons similar
Siemens Gamesa – Supports in nature to the above, that with a passive single machine infinite bus
SGRE support these changes system a simulation environment can be established to provide a step-
Solar Turbines – Comment (regarding synchronous machines) like input suitable for assessing a settling time. However, AEMO notes
that the application of this clause is not limited to well-behaved single-
• During fault and for synchronous generating unit, the initial generator reaction is based on the machine infinite bus systems.
behaviour of a rotating machine, then the AVR reacts to a voltage input error by increasing the
excitation current to support the voltage. Transgrid also preferred to keep the settling time requirement, with
similar amendments as proposed by AEMO for the definition of rise time
• AVR dynamic behaviour can be assessed as step voltage response, however this behaviour (with specific test conditions), as it provides a quantifiable assessment
does not consider the initial reaction of the synchronous generator during an event. criteria for steplike responses. AEMO could make the proviso of a “step-
• The reactive current injected is not a controlled variable, but a by product of the AVR reaction like input” apply to settling time as well, but the recent AEMC review of
reading an input voltage error. AVR performance is not normally evaluated based on reactive reactive current injection for the MAS demonstrated how problematic
current injection, but by measuring the voltage behaviour against a voltage setpoint step the calculation of settling time can be in a fault context, where longer-
variation. term dynamics can affect the results (and that was just in simulations
using SMIB models). The material presented by the AEMC was
TasNetworks – Opposes the removal of settling time
focussed on wind farms, but similar observations can be made for grid-
As per our previous submission, the standard definitions from control theory for “rise time” and forming inverters. There is practically nothing wrong with changes
“settling time” should remain. The Dynamic Model Acceptance Test (DMAT) use a passive single above 10% of the fault response over the course of a fault, provided the
machine infinite bus (SMIB) arrangement when assessing performance. Under this arrangement,

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
any dynamic response observed can only be due to the equipment under test and in this setting, response is adequately controlled, and meets other aspects of the
the control theory terms are appropriate. For on-site “R2” testing, and in full model verification requirements.
when other voltage regulation devices can impact the voltage profile, there is justification to relax In addition, the proposed changes restore consistency in approach
the wording. between the minimum and automatic access standards, which can
Tesla – Supports assist in the negotiation of performance standards.
Tesla is supportive of AEMO’s revised recommendations. Several stakeholders commented on the definition of ‘adequately
Transgrid – Supports with clarification controlled’, which speaks to the tension between flexibility and
specificity, as described above. CEC commented that the definition is
• Acknowledge that the settling time is not a comprehensive measure as to the adequacy and qualitative, but this is necessary to maintain flexibility. It is attempting to
stability of the reactive current response for complex disturbances. However, the settling time document the principles that should be considered when assessing this
requirement provides good generalised and quantifiable assessment criteria for stability when clause. Nevertheless, AEMO observes that the proposed definition
applied to step-like voltage disturbances. Transgrid prefers to retain the performance criterion could reference the system standards, when considering the over
for settling time in the AAS with similar amendments as proposed by AEMO for the definition of voltage excursions caused by the plant. For under-voltages the system
rise time (with specific test conditions). Transgrid also notes that with the removal of the standards are silent, so the reference would need to be to S5.2.5.4
settling time requirement from the MAS, the rules are more flexible to negotiating this ranges and durations. The advantage of that would be that it would
performance. address a loophole that could allow a plant to cause a voltage excursion
• Transgrid supports the inclusion of the commencement time of no greater than 10ms in the that then causes the voltage at its connection point to be outside the
AAS; however, it notes there is ambiguity regarding the response initiating condition in the range under S5.2.5.4 for CUO.
proposed AAS. The current MAS under S5.2.5.5 (O)(2A) allows for the response initiating Defining such terms as “step-like” and “adequately controlled” is of
conditions to be agreed with the NSP and AEMO. Further comments on this are included limited value where all parties are equally able to exercise engineering
under ‘Commencement of reactive current injection’ section. judgement. However, AEMO does recognise that there is a range of
• Transgrid supports the inclusion of “adequately controlled” definition in the NER. However, engineering experience and capability in the NEM and that the energy
Transgrid notes that proposed amendment S5.2.5.5 (a00) refers to plant response for transient transition will continue to provide resourcing challenges. In light of that
over-voltage and transient under-voltage in defining “adequately controlled” response. As AEMO proposes to define adequately controlled at stakeholder request,
noted in our response under clause S5.2.5.4, transient overvoltage is defined in IEC 60071-1 but does not intend to define “step-like”, which should be understood in
as “short-duration overvoltage of few milliseconds or less, oscillatory or non-oscillatory, usually the context.
highly damped”. The requirement under clause S5.2.5.5 is for the plants to provide an Transgrid noted that the term “transient over-voltage” is not used in a
adequately controlled stable response for power frequency overvoltage or undervoltage manner consistent with the definition in the IEC standard. The wording
disturbances that are typically cleared within 80ms to few seconds and is not limited to could be expanded to transient or temporary over-voltage or under-
transient events. Further consideration needs to be given to consistent use of terminology, voltage to be consistent with IEC 60050-614, which is also referenced in
considering defined terms in relevant IEC standards. 610071-1. AEMO acknowledges that the IEC standards do have a
definition of transient. However, the term “transient” is not used by
reference to the IEC standard in this clause, so AEMO does not agree
that it should conform to that definition, which is more prescriptive than
intended by its use here.
The addition of a “commencement time” criterion was made in the
recent rule change on this clause for the MAS. The proposed change
adds the criterion to the AAS.
Stakeholders expressed support for the change, other than Neoen who
questioned the value of setting 10 ms as the commencement time and
indicated it cannot be tested in an RMS wide are model. AEMO
suggests that, unlike rise time and settling time, this measure can
generally be calculated in an EMT SMIB model without much difficulty,

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
and could also be demonstrated in hardware-in-loop tests. It reflects the
benefit of rapid commencement of reactive current injection in response
to a voltage drop, in arresting or opposing the voltage deviation. In
AEMO’s recent publication of a voluntary grid forming technical
specification1, grid forming inverters from various manufacturers
demonstrated (in simulations) commencement times of around 3 ms,
opposing a voltage deviation.
Final recommendation
Considering stakeholder feedback, AEMO recommends modifying the
update report recommendation, by amending the “adequately
controlled” definition to include not causing or exacerbating voltages
beyond:
• the more restrictive of the system standards and levels and durations
agreed under S5.2.5.4 for overvoltages, and
• levels and durations agreed under S5.2.5.4 for undervoltages and
• not causing or exacerbating voltage oscillations that could adversely
affect the ability of other schedule 5.2 plant to remain in operation
during the disturbance.
Commencement of reactive AusNet Transgrid noted that there is some ambiguity in the location at which the
current injection AusNet supports AEMO’s revised recommendation reactive current commencement and rise time are to be measured. The
and clarity on reactive current current NER provides some flexibility around the measurement location
Powerlink – Supports for reactive current contribution. AEMO does not propose to modify this.
injection location
Powerlink supports this proposed change. Typically, fault ride through current response is AEMO agrees with Transgrid that reactive current commencement time
implemented at the generating unit level, as distinct from at the connection point. and its measurement location should also be recorded in the
Siemens Gamesa – Supports performance standards.
SGRE support these changes. Final recommendation
Solar Turbines Considering stakeholder feedback AEMO will retain its update report
It is recommended to indicate that the AVR shall be set to react above 85%Un in case of recommendation with two minor amendments to:
undervoltage and below 115%Un in case of overvoltage. • Amend NER S5.2.5.5(u)(2) to clarify that reactive current rise time
TasNetworks – Supports and commencement time can be measured at a location other than
the connection point.
TasNetworks supports this proposed change.
• Amend NER S5.2.5.5(o1) to require all the elements of reactive
• Tesla – Supports current response to be recorded including the location for
• Tesla remains supportive of this recommendation measurement of reactive current injection level as a function of
Transgrid – supports with clarification voltage, the location of measurement of commencement time and rise

1
At [Link]

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
• Under the proposed AAS, there is some ambiguity in regard to the location at which the time and the response initiating condition including the location at
reactive current commencement and rise time is to be measured. Noting that S5.2.5.5 (g)(2) which it is measured, noting that rise time and commencement time
specifies the reactive current response requirements for a step-like voltage profile at the might be measured at a different location.
connection point, is the expectation that the reactive current commencement time and rise time
is to be measured at the Connection Point for the AAS? Suggest providing further clarity on the
location at which the reactive current commencement and rise time is to be measured for the
AAS.
• S5.2.5.5 (o1) MAS provides the ability for the reactive current commencement conditions to be
agreed with NSP and AEMO and recorded in the performance standards. However, there is no
such equivalent requirement under the AAS to explicitly record the reactive current
commencement conditions such as response initiating condition or the location. Transgrid
suggests adding an equivalent of subclause (o1) to the AAS to remove ambiguity.
Consideration of unbalanced AusNet – support, with clarification The proposed drafting retained the requirement for the plant to have
voltages and clarity on reactive AusNet supports AEMO’s revised recommendation on requiring the control strategy to minimise facilities for 4%/% reactive current injection and 6%/% reactive current
current injection volume voltage deviation on each phase from pre disturbance levels, for unbalanced faults. AusNet absorption, but specified this for balanced voltages.
would like to stress that the negative sequence current control should not be overly prescriptive The drafting also proposes a control objective to optimise the overall
due to the X/R ratio being dictated by angle of the fault impedance. To have a constant negative settings.
sequence current injection objective might not be aligned with the objective of maximizing post Caterpillar suggested inclusion of example graphs in the NER, but as
fault voltage stability. the solution is likely to be different from one model/type of plant to
Caterpillar - clarification sought another, this is not feasible.
It is requested to add (example) graphs showing the response of asynchronous units (inverters) Huawei asked if AEMO has specific requirements for negative phase
for changes in positive- and negative sequence component of the grid voltage respectively. sequence (NPS) in unbalanced faults. Powerlink also noted that the
Energy Queensland – no concerns raised control objective could be interpreted as not requiring the plant to have
NPS or phase imbalance correction. Transgrid noted that there is no
Ergon Energy and Energex make no comment quantifiable assessment criterion for unbalanced faults.
Huawei Australia AEMO acknowledges the omission identified by Transgrid, Powerlink
Do AEMO and the NSP have specific requirements for negative sequence current in unbalanced and Huawei, and proposes to expand its recommended AAS to include
faults? a requirement for either inherent response or control response that
Powerlink Support with clarification opposes voltage unbalance during faults or temporary over-voltages.
The control objective includes requirement to “minimise” deviation of voltage, which can be Transgrid suggested that the 4% and 6% apply to positive sequence
interpreted in different ways. For example, a plant that only has the ability to inject positive injection for unbalanced faults as well. AEMO considers these levels as
sequence current may consider that they minimise over-voltages by reducing positive sequence design criteria affecting the range of injection levels that can be
injection to a very low level; however, this may be at a level that still can’t be accepted. considered for the optimisation. However, AEMO agrees that the
requirement for positive sequence injection should also apply in
We recommend that the term “minimise” is framed as “minimise subject to NSP requirements”, unbalanced faults.
because it is the NSP that is affected by high voltages.
Transgrid also noted an inconsistency in the draft S5.2.5.5(f) and
Some generating unit types inject current per phase (i.e. no particular negative sequence S5.2.5.5(n) (i.e., between the AAS and the MAS for reactive current
injection), and that those standards could be expressed on that basis (i.e. without reference to response). The AAS refers to positive sequence voltage deviations,
negative sequence voltage or negative sequence current). while the MAS refers to voltage. This will be addressed by the
Siemens Gamesa – Partial support; Alternative proposed amendment above.

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SGRE support the recommended revisions to record unbalance fault in GPS. However, the The control objective should be considered the overarching requirement
assessment of volume of negative current injection in accordance with the negative voltage that sets the level of reactive power response for both balanced and
deviation could be difficult depending on the technology and may require significant additional unbalanced faults. Flexibility in how the response is described in the
effort during all connection stages. For example, with DFIG (similarly to synchronous machines) GPS needs to be retained as different algorithms and inherent
negative sequence current may be absorbed by the machine itself rather than as defined by a responses can apply.
software control system so codifying the performance may not be clear and straightforward. Siemens Gamesa suggested that DFIGs may not be able to control
SGRE also suggest to limit the matter of priority only to the positive sequence and active current negative sequence because they have an inherent response rather than
vs reactive current a control response. AEMO notes that whether a response is inherent or
Solar Turbines – Alternative proposed control-based should not prevent describing a response characteristic,
Note that synchronous generators and AVRs do not control reactive current injection on the even if heuristic.
single phases (unless the generator is 1-phase). Transgrid also noted that NER S5.2.5.5(o)(1)(ii) refers to 115% instead
It is recommended to define appropriate requirements considering synchronous generators of 120%. AEMO agrees that this is a drafting error, which will be
technology. corrected in AEMO’s rule proposal.
Tesla – Support Final recommendation
Tesla is supportive of AEMO’s revised recommendations. Considering the stakeholder feedback, AEMO proposes to amend its
update report recommendation as follows:
TasNetworks – Supports
• Retain the 4%/% and 6%/% as facility requirements in the AAS
TasNetworks supports this proposed change. (unchanged intent, but minor redrafting is required).
Transgrid – support with clarification
• In the AAS, amend the requirement for facilities to achieve 4%/%
• Supports retaining in the AAS 4% and 6% levels for injection and absorption. Suggest this is injection and 6%/% absorption of positive sequence reactive current
clarified to apply for each 1% positive sequence voltage deviation for both balanced and for balanced and unbalanced faults, by removing “for balanced
unbalanced faults and overvoltage disturbances.
voltages”.
• Welcomes the S5.2.5.5 (u)(3) amendment requiring the response to unbalanced faults and
• Apply the control objective to both balanced and unbalanced faults
overvoltage disturbances to be recorded in the GPS. However, there is no quantifiable
and overvoltages (for establishing the settings, rather than as a
assessment criterion for unbalanced faults proposed in the amended AAS (since
facility)
S5.2.5.5(f)(1)(i) and (ii) are limited to balanced faults). While the proposed amendment under
S5.2.5.5(f)(1)(iii) to minimise the deviation of voltage on each phase provides the broader • Expand the AAS to include a requirement for either inherent response
intent and guidance for the required positive and the negative sequence reactive current or control response that opposes voltage unbalance during faults or
response, it is ambiguous and open to interpretation. In Transgrid’s experience, lack of clarity temporary over-voltages.
on unbalanced fault response requirements has resulted in prolonged plant tuning and • In NER S5.2.5.5(o)(1)(ii) correct 115% to 120% (drafting error).
negotiations so it is crucial that clear technical requirements are set in the AAS. Transgrid
suggest applying clause S5.2.5.5(f)(1)(i) and (ii) requirement to both unbalanced and balanced
faults (based on each 1% voltage deviation of positive sequence voltage) supplemented by
proposed S5.2.5.5(f)(1)(iii) requirement to minimise voltage deviation on each phase. This
should allow for the balancing of the voltages by providing appropriate level/s of positive and
negative sequence current.
• Inconsistency in the draft S5.2.5.5(f) and S5.2.5.5(n) (i.e., between the AAS and the MAS for
reactive current response). The AAS refers to positive sequence voltage deviations, while the
MAS refers to voltage.
• Draft S5.2.5.5(o)(ii) specifies an overvoltage threshold of 115% of nominal voltage for the MAS
which is the same as the overvoltage threshold specified under S5.2.5.5(g)(ii) for AAS. Given

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that AEMO has not specified this MAS amendment in the recommendation report, it is
assumed to be a typographical error.
Metallic conducting path AusNet – oppose The proposal to remove the metallic conducting path reference received
As per the previous AusNet submission, AusNet's view is that this wording served a purpose, and support (or no objection) from four respondents. It was opposed by
that rather than omission entirely, an appropriate, clearer substitute should be included. three stakeholders who considered that it continues to serve a purpose
or that its existence is not creating problems.
CEC – Oppose
Neoen suggested that it is intended to indicate a low impedance fault
Strongly recommend the wording remain as removal of it could require additional studies to may practically evolve. AEMO does not agree that the clause speaks to
assess high impedance faults (including faults with varying impedance). AEMO’s draft report the evolution of faults, although it certainly doesn’t preclude low
states that the ‘existing wording does not appear to add anything useful’. We strongly disagreed impedance faults. However, including or removing the clause would not
and the fact that the wording exists, yet is not creating problems for the industry is a testament to change this understanding.
the value that the wording provides.
AEMO considers that removing this clause would make no practical
Energy Queensland – No objection difference to the studies that would be needed. Practically, very high
Ergon Energy and Energex have no objection to the removal of this statement. impedance faults are unlikely to trouble a generating system, and the
Neoen – Oppose clause already refers to the clearance of faults by protection, so it is
clear that the faults referred to in the clause are sufficient to be cleared
The original reason for including this term must be considered. It was originally intended to by protection systems.
indicate a low impedance fault may practically evolve.
Whereas the description makes it clear that a fault for the purpose of
Powerlink – Support this clause includes something that has a metallic path, it does not
Powerlink supports this change. preclude a fault including something that is not a metallic path. Noting
TasNetworks – Support that a power system engineer would automatically interpret that a fault
covered by this clause could have a metallic conducting path, the
TasNetworks supports the removal of this clause. addition of this clause (a) does not limit or refine the application of
Transgrid – supports S5.2.5.5 in any useful way.
Transgrid supports the deletion of this subclause. Further explanation of what faults apply for this clause could be
provided in a guideline.
AEMO considers that a substitute clause is not appropriate, because
the original drafting of the clause simply states that faults considered by
the clause included (effectively for the avoidance of doubt) a fault
having a metallic conducting path. AEMO considers that there is no
residual uncertainty that might otherwise lead such faults to be
excluded, and therefore NER S5.2.5.5(a) can safely be deleted.
Final recommendation
Considering the stakeholder feedback, AEMO will retain its update
report recommendation.
Reclassified contingency AusNet – comment Most respondents agreed with the proposal in principle. Neoen objected
events AusNet notes AEMO's response and suggests that if there are undocumented principles in use, on the grounds that uncertainty on credible contingency events at the
that they should be formalised so that parties have clear and fair expectations of future design stage adds risk to the project.
compliance and changes. AEMO notes that under the current NER there is no limitation on the
CEC credible contingency events for which the plant must remain in CUO,
and this would include reclassified events as well as credible

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Additional study cases may be required however no further comments given the proposed contingencies that change in size or nature over time. The proposed
wording incorporates those contingencies that are commonly reclassified and are ones that are amendment therefore de-risks the project, when compared with the
likely to affect the connection point. status quo.
Energy Queensland – no concerns raised Another mitigating factor is that the power system is always
Ergon Energy and Energex make no comment. reconfigured for a reclassification of a non-credible contingency. This
typically involves one or more network constraints that, if binding, will
Huawei Australia - Support with clarification reduce the flow on the affected element so that the impact on the power
We recommend that the NSP can provide detailed credible contingency events system is less onerous.
Neoen – Oppose Identifying and checking the commonly reclassified contingency events
Generating systems can’t be re-designed as network events are re-classified – the Rules must be would allow the Schedule 5.2 Participant to identify and remedy any
clear what events are credible before the design is underway. NSP should provide a list of potential non-compliance, considered that these identified events have
credible contingencies in the response to the connection enquiry, credible contingency events a higher likelihood of occurring than others. AEMO reports every 6
must be consistent with the rule definitions and the planning and design of the NSP network. The months on reclassification decisions. Considering Solar Turbines and
project can’t respond to re-classification once the work on application package preparation Huawei’s comments, it is not possible to define a one size fits all
commences – this would introduce significant re-design and re-work which would have direct scenario for testing credible contingency events, under the
impact on level of funding required for the project. Should this change be introduced there needs “performance standards” approach adopted in the NEM, which applies
to be a clear obligation on NSP/AEMO to outline the events that may be re-classified in near site-specific conditions for the assessment. The connection applicant
future and the risk this may introduce to the project. Note that a reclassified credible contingency and NSP should discuss which reclassifications (and credible
event is a non-credible contingency event that AEMO has determined is now reasonable possible contingency events more generally) should be considered, as part of
given abnormal system conditions. The system cannot be designed to always operate such that scoping their studies for connection application submission. AEMO
potentially reclassified events are always possible and the same goes for generating plant. notes that there are existing obligations on NSPs (for example in NER
5.3.2(f)) to provide technical information to Schedule 5.2 Participants.
Note that the event types defined in S5.2.5.5 already cover a number of non-credible contingency
events there is no need to expand these conditions. The cost of doing so would be prohibitive Final recommendation
and must be understood that a non-defined list of event withstand conditions imposes inefficient Considering the stakeholder feedback, AEMO will retain its update
costs onto new connections that are passed on to consumers, with no benefit. report recommendation.
Solar Turbines
Solar Turbines comments include some general comments on credible contingency event
assessment:
• The requirement identifies fault condition, but it does not provide detailed information regarding
clearing times and typical grid set-up and therefore it is not possible to assess generating unit
capability in advance. The requirement is pretty generic so it is difficult to provide any answer,
less a statement of compliance for manufacturers.
• The requirements provide no obligation to look for an optimization on the protection settings by
the relevant parties (including system operator) which is desirable for lifecycle of the
generating unit and for the safety (availability) of the system. It is recommended to add a note
in such respect (worst case scenario shall in any case be based on best achievable protection
scenario for the generating unit, protection settings shall be set with the best possible
configuration from generating unit perspective).
• It is recommended to create a pre-defined grid system to be used as reference for proving
compliance and correspondent system characteristics and clearing times. This shall be based
on the list of events as described in the definition of credible contingency event in S5.1.2.

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TasNetworks – Supports
TasNetworks supports this proposed change.
Tesla – Support with clarification
Tesla would suggest additional wording in this clause that would also require the NSP to publish
these additional commonly reclassified contingencies. If they are considered by NSPs, but not
visible to developers and OEMs, it is unhelpful.
Transgrid – Supports
Agrees with the amendment rule in S5.2.5.5 (t1) to expand the term credible contingency by
reference to specify credible contingency events selected by the NSP for the purpose of NER
S5.1.2.1.
NER S5.2.5.7 – Partial load rejection

Application of minimum AusNet – support Stakeholder responses generally supported the proposed change.
generation to energy storage AusNet supports AEMO’s revised recommendation Transgrid’s suggested applying (a0) to bi-directional units so that they
systems would be required to remain in CUO for system load reduction
CEC – clarification sought
conditions when absorbing active power from the power system.
Note that the NER wording amendments do not seem to have been made in Appendix A2.
AEMO agrees that battery systems are unlikely to have a minimum
To be revisited – members raised a concern that this may affect the serviceable life of Battery generation level. Note that the definition of bidirectional unit indicates
storage systems depending on how it is drafted. that only those units capable of smooth transition between generating
ElectraNet – seeks clarification of need and consuming power are considered as bidirectional under Schedule
S5.2.5.7 – It is not clear why this Clause has been specified for synchronous condensers. The 5.2. This means that they do not have a minimum generation, although
original intent of this clause is understood to be requiring generators to remain online for loads they may still have a maximum load constraint. For example batteries
down to Pmin for a large frequency disturbance. It is noted that the proposed drafting already may have a maximum charge level, where they cannot continue
obliges synchronous condensers to ride through frequency, voltage and power system charging. Therefore it may be necessary to allow for constraints on load
disturbances (S5.2.5.3, S5.2.5.4 and S5.2.5.5 respectively), and it is unclear what additional level for some types of bidirectional units, under some conditions (e.g.
performance is gained from this clause. based on charge level).
Energy Queensland – no concerns raised CEC expressed concern that the requirement may affect the serviceable
life of a battery storage system. AEMO interprets this as a concern
Ergon Energy and Energex make no comment. about a requirement to reduce output and begin absorbing energy.
TasNetworks – Supports However, AEMO notes that the requirement in this clause is related to
TasNetworks supports this proposed change. continuous uninterrupted operation rather than frequency response.
Transgrid – support with clarification ElectraNet questioned the application of S5.2.5.7 to synchronous
condensers since they are required to ride through frequency, voltage
Note the amendment to minimum generation “the minimum sent out generation for continuous and power system disturbances.
stable operation of a production system including each of its operating production units”. The
term “sent out generation” is defined in the NER as “In relation to a generating unit, the amount of The clause was originally drafted for synchronous generation,
electricity supplied to the transmission network or distribution network at its connection point”. As considering that some synchronous machines may have difficulty in
AEMO asserted in the Approach paper, bi-directional units are not likely to have minimum maintaining their plant prime mover in stable operation for a load
generation for continuous stable operation; therefore, the proposed amendment in S5.2.5.7 (a0) rejection event.
should also apply to bi-directional systems. The clause was extended to all types of generation in 2018, and more
recently was modified under the IESS rule change to cover IRS.

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Nevertheless, experience of the assessment of this rule over the past 5
years since it was extended to asynchronous plant, indicates that there
has been little gained from the extension to asynchronous plant, and by
the same logic there is little to be gained from applying it to synchronous
condensers, noting that both types of plant must comply with voltage
and frequency disturbances and contingencies.
Noting the suggestions for changes needed to apply this requirement
effectively to batteries, AEMO has revisited the provisions subsequent
to the update report and concluded the most efficient outcome is to
apply the clause only to synchronous generation, which is most likely to
be affected by load rejection. AEMO has discussed this option with
NSPs and received no in-principle objections. For developers, this
change will reduce the time and resource requirements for compliance
assessment..
Final recommendation
AEMO recommends the application of s5.2.5.7 only to synchronous
generation. On this basis it is not necessary to consider the operating
conditions other than minimum generation level for stable operation that
might need to be exempted from the ride through requirement.
Clarification of meaning of CUO AusNet – support Respondents to the consultation were either supportive or silent on the
for NER S5.2.5.7 AusNet supports AEMO’s revised recommendation proposed changes.
CEC – clarification sought AEMO notes Transgrid’s comment on drafting and confirms its intent to
make the change from “be capable of” to “remain in” in this clause.
Note that the NER wording amendments do not seem to have been made in Appendix A2.
Final recommendation
To be revisited – members raised a concern that this may affect the serviceable life of Battery
storage systems depending on how it is drafted. Considering the stakeholder feedback, AEMO will retain its update
report recommendation (permitting active and reactive power changes
Energy Queensland – no concerns raised within the concept of remaining in CUO).
Ergon Energy and Energex make no comment.
TasNetworks – Supports
TasNetworks supports this proposed change.
Transgrid – supports with clarification
• Support the addition of paragraph (h) “A relevant system is permitted to vary its active power
and reactive power to the extent required to oppose a voltage variation or frequency variation”
as it makes the performance requirement clearer.
• Transgrid notes that AEMO has not incorporated the revised recommendation to replace the
term “be capable of” with “remain in” in Appendix A2 Draft NER amendments for clause
S5.2.5.7 (c) and (d).
NER S5.2.5.8 – Protection of generating systems from power system disturbances

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
Emergency over-frequency AusNet – support Most respondents supported the proposed changes to the over-
response AusNet supports AEMO’s revised recommendation frequency response requirements which clarify the preferred approach
being a droop response, and retain tripping as the least preferred option
Caterpillar – Support with clarifications as a minimum access standard.
• The revised recommendations include: Caterpillar requested clarification of the words “proportional reduction”.
• “A–S - reflecting a proportional response”: Further clarification on the term “proportional This is used in (b1)(1) in relation to the negotiated standard. It is
response” is requested. Also, certain prime movers of synchronous generators (genset, intended to be a reference to droop response. However, AEMO
turbines) are constrained in their speed of active power response. Therefore, it is proposed to acknowledges that the wording could be more precise – eg “a reduction
specify a droop range for the response as 16.67% – 100% rated power (Pmax) per Hertz and proportional to frequency deviation”
a maximum ramp rate as 20% Pmax/minute. Caterpillar suggested specifying a specific droop setting in the AAS,
“NAS - ...specifically including rapid reduction by 50% by means other than tripping”: It is because of plant limitations. AEMO considers that a proponent whose
requested to clarify that the response can saturate (settle) at the minimum operating level before plant has such a limitation can seek to negotiate an appropriate access
a 50% Pmax reduction is achieved. Also, a maximum ramp rate of 20% Pmax/minute is proposed standard. There appears to be no benefit in specifying either maximum
here. ramp rate or a specific droop setting, as all technologies are covered by
CEC – support with clarifications these requirements, and different technologies and plants have different
capabilities.
We note that AEMO has accepted our proposal to establish an AAS, NAS and MAS which is
welcome, and the new wording provides flexibility for different plant types. Caterpillar also sought clarification of the interaction with the minimum
operating level. AEMO agrees that a reference to minimum operating
• Recommend removing the capitalising of ‘disconnect’ for the NAS and MAS to allow level needs to be added, to clarify that the 50% reduction in output is
disconnection other than at the connection point. subject to the plant output remaining above the minimum stable
• Reference to vector shift protection not operating for less than 20 degrees is questionable as operating level if any.
desensitising vector shift protection to such an extent would likely negate its use as an anti- CEC recommended that ‘disconnect’ not be italicised to allow a plant to
islanding scheme. Reliance on Vector shift protection for anti-islanding is questionable (there disconnect other than at the connection point, while keeping ancillary
are better alternatives such as topology-based schemes). plant in service
• Recommend clarification of ‘disconnect’ under the General Requirements. Use of ‘disconnect’ The NER defines disconnect as the operation of switching equipment or
(italicised) requires opening the connection point circuit breaker and there should be flexibility other action so as to prevent the flow of electricity at a connection point.
for the generator to disconnect other than at the connection point (which would allow auxiliary The definition does not specify the location of switching, but does
supplies to be maintained and allow for faster restoration). specify the outcome ie “so as to prevent flow of electricity at a
CPSA – Supports over-frequency treatment; opposes vector shift connection point”.
• We welcome AEMO’s inclusion of a new AAS and NAS as per CPSAs recommendation in our There may be, in some circumstances, some ambiguity in the definition
previous submission to capture different levels of performance for different plant types. as to whether it requires preventing all flow of electricity (including
• The use of / reference to Vector Shift protection is a pointless exercise given that setting this reactive power) through the connection point. However, in the context
protection to >20 degrees effectively desensitises it and renders it ineffective for detecting “disconnect” is combined with “the operating production units” so the
islanding conditions. If anything, the use of Vector shift protection should not be allowed as it intent should be clear. Nevertheless AEMO agrees that removing the
difficult to reliably set it. Topology based schemes are the most dependable anti-islanding italicising from the term here may improve clarity. AEMO prefers not to
schemes. change the definition because it is used in many locations in the NER
that are outside the scope of this review.
Energy Queensland – no concerns raised
Hydro Tasmania suggested it would be helpful to accommodate
Ergon Energy and Energex make no comment. exemptions for plant that cannot achieve a 50% reduction due to safety
Hydro Tasmania – Support with clarification or stability reasons. AEMO considers that the range of options for
negotiation should accommodate more modest reductions and could

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Would be helpful to accommodate exemptions in the NAS. In case the generating unit ’an't possibly be combined with tripping as a last resort. However, the NAS
achieve rapid reduction by 50% due to stability or safety reasons (e.g. hydraulic limitations), provision could possibly also include reduction of less than 50%.
subject to NSP assessment and agreement. Solar Turbines suggested a power reduction of 50% Pref in 3 seconds
In addition, HT notes that the mandatory PFR implementation was applied for units >30MW (e.g. is not realistic for large synchronous machines. AEMO notes that the
dispatchable units), while Hydro Tasmania understands the new threshold e.g. 7MW proposed access standards are not just for synchronous machines but apply to a
due to the Tasmania system size, there are handful units (between 7MW and 30MW) in the range of technologies, and the negotiation framework allows for a longer
Hydro fleet will not automatically satisfy the over frequency response requirement based on PFR response time where required.
settings. HT would like to open a separated discussion to find a best practice to accommodate. Solar Turbines also raised concerns that operating with such high ramp
Solar Turbines – Alternative proposed rates might lead to unstable operation. Once again AEMO notes that the
• Some comments to the drafted requirement negotiation framework for this clause takes account of plant limitations,
which would include stability limits.
• The AAS requesting a power reduction of 50%Pref in 3s is not realistic for synchronous
Solar Turbines considered Australia’s approach of technology agnostic
generators with inertia of size of more than 4 MW (most probably even less), much less
requirements to result in unnecessarily slow responses from some
applicable for bigger power units.
inverter-based technologies that can achieve faster responses as well
• Power reduction with such fast ramp rates does not necessary lead to stable operating as being difficult to achieve for some technologies such as gas turbines.
condition and in general has consistent power undershoot. They can result in very nervous AEMO considers that the range of possible negotiated access
behaviour of the generating unit that will tend to initiate large power reduction also for limited standards adequately covers the range of technologies, without
frequency deviation ad associated instability. unnecessarily complicating the access standard. Not also that the
• The requirement as it is stated seems to be targeting only the Pmax and 3s scenario. It is performance standards should not be viewed as limiting plant
recommended to re adapt the requirement (at least for synchronous generators) so that the capabilities – they are to be met or exceeded.
generating unit/generating plant shall reduce its active output power as fast as technically Transgrid suggested that the NAS statement that a reduction in active
feasible and such capabilities shall be documented and recorded, as also suggested in the power output should generally be achieved by fast ramping in
presentation slides. preference to disconnection of production units.” does not make it clear
• It is also strange that AAS specifies such a fast requirements that seems non practical for that droop response is the preferred response. However, AEMO
synchronous generators and other technologies, but almost slow for inverter based technology considers that the proposed drafting is clear as to the order of
(eg in Germany inverter technology are expected to reduce power of 50%Pref in 2s, wind units preference, expressed within the AAS-MAS-NAS framework.
are expected to reduce 20%Pref in 5s, while synchronous generator 45%Pref in 8s, but with Final recommendation
the exception of Gas Turbine and reciprocating engine for which is requested a ramp rate of Considering all feedback, AEMO will retain its update report
20%Pref per minute). recommendations with the following amendments:
Note that the requirements does not describe any other condition different from power reduction • Make the 50% reduction subject to the plant remaining above
in overfrequency, therefore std ramp rates are expected for any other behaviour. minimum operating level for stable operation.
TasNetworks – Supports
• Modify the wording of “proportional response” to clarify that response
TasNetworks supports this proposed change. proportional to frequency deviation is intended.
Tesla – Supports • Allow the 50% reduction and 3s requirements to be relaxed where
Tesla remains supportive of this change. AEMO and the NSP agree a relaxation is necessary for safe
Transgrid – generally supports operation of the plant and preferable to tripping., but in any case, not
unnecessarily delaying the commencement of the response
• Support the prioritisation of response being: 1) continuous frequency droop control, 2) fast
ramping, 3) disconnection, as well as changes to the wording on protection settings. • Remove the italics from “disconnect” or otherwise modify the
definition to allow for disconnection somewhere other than the
• The Negotiated clause states that “A reduction in active power output should generally be connection point.
achieved by fast ramping in preference to disconnection of production units.” This does not

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make it clear that that “frequency droop” response is preferred over “fast ramping”. Transgrid
recommend including “frequency droop” in (b4) of the Negotiated standard to make this clear.

NER S5.2.5.10 – Protection to trip plant for unstable operation

Requirements for stability Akaysha Energy – supports with clarification The general nature of the feedback received suggests that earlier
protection on asynchronous Submission supports the clarification of the S5.2.5.10 requirements, and the detection of concerns around this clause are getting close to resolution.
generating systems instability based off POC measurements. Recommends the generator only disconnects on Most of the residual issues raised in responses on this issue focus on
receiving a disconnect signal from AEMO or the NSP, as sudden disconnection may have the following topics:
broader risks for the power system. The submission recommends that minor instabilities should • Generator disconnection because of unstable operation leading to
not trigger automatic disconnection of very large generation assets. broader problems for the power system
Amp Energy – concerns about contribution
• Concerns about the types of stability that are to be covered, and
Based on our experience, there is no proven commercially available product which can incomplete understanding of the mechanisms
automatically accurately detect oscillations and work out if a plant is contributing to the instability
Some respondents also raised concerns about:
or not. A common technique which has been used in some produces (most still in trial phase) is

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comparing Q and V phase differences but that technique has been shown to be less accurate or • Concerns that the technology to identify whether a plant is
even completely unreliable with medium to high sub-synchronous oscillation frequency range contributing to an instability is not well developed
(above 10-15Hz). Therefore, the revised requirement should be further reviewed.
• Whether protection grade tripping (~100 ms) is required
AusNet – support
• Whether the detection and protection could be implemented in
AusNet supports AEMO’s revised recommendation separate devices
Caterpillar – Support with clarification • The requirement to install PMUs for plant greater than 100 MW.
• The given set of AAS and MAS are non-exhaustive, and it is requested to add tables or flow- Generator disconnection
charts showing the requirements. For the MAS, an exhaustive set of requirements including
In relation to disconnection of generation, CEC and its members raised
tables with the min/max configuration settings and default thresholds are requested.
issues around automatically disconnecting via a system that has not
• It is also proposed to allow for additional development time where there are project-specific been proven. Alternatives proposed were to raise an alarm but initiate
protection requirements. manual tripping, or initiate tripping on a disconnect signal from AEMO or
CEC – Partial support, partial opposition the NSP. Neoen considered that automatic disconnection for IBRs
should not be required in any conditions as this could lead to unwanted
AAS:
and unexpected loss of generation/load leading to unnecessary network
• Members had concerns around automatically disconnecting via a system that has not yet events. Neoen also suggested clear definitions of “unstable” and
been proven and the impact this can have on power system security and / or non-compliant “oscillation” should be provided. Hydro Tasmania was concerned that
with its performance standards. disconnection of generating plant through a protection response always
• Computing contributions to oscillations in real time is not a proven concept and this area is risks amplifying the issue, and supported a response hierarchy starting
evolving. Hence mandating requirements in the Rules is not appropriate at this stage. with control/blocking mechanisms, backed up by coordinated protection
with reasonable time delay.
• Requirements for production systems >100 MW to install a PMU and receive information from
AEMO. It is unclear what information is provided, how often and what needs to be done with Considering this feedback, AEMO proposes to clarify that in addition to
this information provided by AEMO. 6 • AEMO considering the need for a system-based the plant contributing to the oscillation, tripping should be restricted to
approach to assessing control interactions which is generally welcome and is the most suitable oscillations at a level that would have an adverse impact on power
way to identify control interactions. system security.
MAS: CT LAB proposed a multi-level strategy that includes alarming at lower
levels and tripping at higher levels to be defined by NSPs, with a
• If required by the NSP & AEMO, requirements for production systems <100 MW to install a process for refining the settings for control and further refinement in the
PMU and receive information from AEMO. It is unclear what information is provided, how often case of non-related contingency events.
and what needs to be done with this information provided by AEMO. It is also unclear what
triggers would require an NSP/AEMO to request this hence the requirement should be on AEMO notes that whereas the AAS requires plant to have a protection
reasonable technical grounds. system with disconnection capability, there is flexibility about whether it
is enabled and the trigger for disconnection. This is more flexible than
Generally: the current NER S5.2.5.10.
• There are concerns that a solution is being designed without truly understanding the nature of Clarity on whether disconnection means protection grade tripping
the problem or the symptoms. There are various failure modes that may result in unstable
Powerlink considered that “disconnection” in the context of a protection
operation, all of which have different frequencies, magnitudes and variations in output
system should be made clear in any Rules amendment.
quantities. For example, FRT re-triggering, PPC-INV communications loss, interactions
between PV inverter MPPT & active power controllers, low SCR instability etc. Without AEMO notes that there is sufficient flexibility in the proposed rule to
understanding the nature of these issues and the resultant plant output, designing a scheme to allow for ramp back of active power and generation unit disconnection.
detect this is at best a guess. • It is recommended that these proposed changes be omitted The hierarchy of actions could also include sending alarms to NSPs, so
until a proven solution is agreed upon. there is sufficient flexibility to require SCADA to do this as part of this
clause.

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• The need to communicate information from the detection system to the NSP/AEMO control AEMO notes there might be some circumstances where instability
centre (if required by the NSP/AEMO). Clarity should be provided on the type, number of and warrants a fast protection grade response. For example, the instability
refresh frequency for these signals. The proposed changes to this clause raised many might be associated with overvoltages or overcurrents, in which case
concerns from our members. In particular, was the concern that mandating the need to trip for protection might need to trip the plant rapidly to prevent damage.
an unproven scheme would present a risk to system security and compliance with Separate devices for monitoring and protection
performance standards. A safer solution would be to raise an alarm but initiate manual tripping.
Some OEMs advised that the setting of threshold and/or delays should be determined by the CTLAB proposed that the monitoring system be separate from the
OEM as the technology provider. protection system, providing both system operator alarming and a
control signal to a protection relay to initiate a trip action. Powerlink also
CPSA – partial support – concern about tripping asks if the protection and detection systems are separate devices.
• There is a lack of understanding of the various failure modes and the type of instability they AEMO notes that the proposed rule does not link the requirements of a
create. It is recommended that this be understood and quantified prior to trying to apply a protection system and a detection system to the same device to retain
suitable protection system to detect instability. Some of the failure modes or control instabilities flexibility in the solution. AEMO does not intend that the rules should
include, FRT re-triggering, loss of PPC to unit comms, MPPT / active power control specify the devices to be used for protection system and detection
interactions etc. systems, only that both capabilities should be features of S5.2.5.10
arrangements.
• Automatic tripping of this protection function should be avoided until it has been proven. If the
oscillations are not large, the issues is most likely a power quality issue and manual Contribution to oscillations
intervention in the short term would suffice. CEC said that computing contributions to instability in real time is not a
CTLab – partial support proven concept so mandating in Rules requirements is not appropriate.
Neoen suggested the Rules should only require capabilities which are
• A clear definition and preferably a standard defining instability and describing the
proven sufficiently reliable and readily available on the market from a
measurement methods and its test protocols is required. range of suppliers. However, AEMO’s recommendation does not
• CT LAB propose the monitoring system be separate from the protection system, providing both mandate assessing the contribution to oscillations, which is only
system operator alarming and a control signal to a protection relay to initiate a trip action referenced in the automatic access standard, and only in the context of
• CT LAB propose a multi-level strategy that includes alarming at lower levels and tripping at not tripping unless a contribution to the oscillations is established.
higher levels as defined by NSPs. In the early stages tripping should be disabled until the NSP There are two mechanisms for establishing contributions in AEMO’s
has agreed upon practical tripping values and strategies. This will assist in refining the settings proposal. One is a detection system within the plant. A second
for control and further refinement in the case of non-related contingency events. possibility is for AEMO to employ a PMU based centralised system2 that
• CT LAB propose a multi-level strategy that includes alarming at lower levels and tripping at identifies the source of an oscillation, and feeds the information back to
higher levels as defined by NSPs. In the early stages tripping should be disabled until the NSP the plant, with the plant responding based on the trigger conditions and
has agreed upon practical tripping values and strategies. This will assist in refining the settings actions recorded in the performance standard. Either of these systems
for control and further refinement in the case of non-related contingency events. could provide confirmation of contribution to an oscillation.
Nevertheless, AEMO agrees that there may be situations in which there
• CT LAB propose the use of reprogrammable measurement platforms that can adapt and grow is no available information about the contribution for the type of stability.
with ever changing system needs and not to specifically call for PMU devices – rather call for
Requirements for PMUs
the ability to stream PMU data to meet AEMO’s need for synchrophasor data.
Powerlink indicated that the reason for requiring PMUs was unclear. As
Energy Queensland - Support
described above and in the referenced paper, AEMO is trialling a central
• Ergon Energy and Energex are supportive of the hierarchy of actions and agree that system to collect information about the instabilities and locate the
technology maturity of these detection systems is a challenge. We note that the definition of source of an oscillation. Powerlink is concerned that the system might

2
See also James Guest, Daniel Lavis “Widespread PMU Installation: Australian Experience” presented at the Cairns 2023 International Symposium 4-7 September 2023. SC-C2 Paper 1280. This paper describes a
method of identifying the source of controller-based interactions using PMUs and its application in the NEM to identify the source of a 17 Hz oscillation.

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‘instability’ must be clear for the NSP, the proponent and AEMO to effectively facilitate be expensive to implement. Hydro Tasmania also argued against
performance standard negotiation and design works. We support further clarification be making the PMU a requirement for synchronous machines. AEMO
provided in guidelines or in updates to the Power System Stability Guidelines. agrees that the cost of PMU requirements should be justified by the
Goldwind Australia – Support with clarification need, and proposed PMU installation in the AAS only for plant of 100
MW or greater, and in the MAS only if required by AEMO or the NSP for
No objections to the proposed changes to the rules, however it would be important to define a plant of that size. CTLab suggested that AEMO allow for a device that
oscillation assessment methodology/methodologies that are acceptable considering the limited streams PMU data. AEMO expects that its proposed wording would
number of options available at this time. allow for the measurement unit to stream PMU data (noting that it would
Hydro Tasmania – Partial Support; Opposes requirement for PMU and Opposes protection need to conform to the appropriate PMU standards).
disconnecting plant Some respondents sought more clarity on oscillations and stability
Protection response by disconnecting the generating plant from the network always has a risk to covered by this clause. SGRE requested definition of “the plant’s
amplify the issue, particularly the instability is identified by multiple IRSs in a region. It is HT’s contribution to instability”. Goldwind suggested defining acceptable
view that a reasonable execute hierarchy should be start with control/blocking mechanisms, then oscillation assessment, considering the limited options available at
backed up by coordinated protection with reasonable time delay. HT strongly opposes the AAS present.
requirement for PMU. At this stage, without detailed technical specifications and verification, this The proposed drafting makes reference to the power system stability
requirement appears premature to be implemented in the rule change. In contrast, there is a guidelines under NER 4.3.4(h), for the requirements and capabilities in
dedicated document MASS to specify the technical requirement of FCAS, including logger this clause (including specific PMU requirements). AEMO’s intent is to
specification to data requirement. incorporate more detail into these guidelines which should address
It is HT’s view that unless there is an absolute system security concern due to generating system various issues raised by respondents.
performance, a PMU installation should be a negotiated outcome between the generator and AEMO also notes that limitations on disconnecting should not preclude
NSP with the MAS requirement only, otherwise there should be no other obligation on the SG to the plant disconnecting itself to protect it from damage due to the
install a PMU and/or any of the associated infrastructure without some form of reimbursement for instability more generally (irrespective of causing it).
installation and ongoing management and maintenance costs (this is very different from the
FCAS infrastructure which essentially is recovered through FCAS markets). Or with the MAS Final recommendation
requirement only to the extent of the SG to facilitate access and connection for a PMU to be Considering all feedback, AEMO will retain its update report
installed by the NSP. recommendation, with amendments to the AAS requirement around
Neoen – Opposes automatic disconnection; guideline required; contribution identification disconnection and contribution as follows:
not available from commercial systems • Amend “ must have a protection system capable of disconnecting
Coordinated and consistent approach to oscillation monitoring and detection is needed. Clear units for unstable behaviour…” to “must have a facility capable of
definition on what should be classified as an “oscillation” and how it should be detected and disconnecting the plant automatically for oscillatory behaviour”
flagged is needed from AEMO – with the introduction of the detection mechanism in the MAS and On detection of oscillations, execute a hierarchy of actions based on
lack of definitions on monitoring and detection algorithms for oscillations there is a potential for configurable trigger conditions, thresholds and timeframes, agreed with
many different systems to operate in the future network. Variety of different mechanisms will the NSP and AEMO, having regard to the power system security impact
provide information on a state of the network that will be difficult to interpret and will not aid in of the oscillations or instability, where:
operation of the network. Comment from AEMO that it is impossible to establish a single • any hierarchy of actions that includes a requirement to trip plant must
definition of “oscillations” – if AEMO with full access to network information is unable to do so
take account of available automated information on the plant’s
how can this be established and designed by others? Without a clear guideline this has a high
contribution to the oscillations or instability, and
potential for implementation of systems that will not provide any benefits. Under no conditions
should automatic disconnection for IBRs be required as this could lead to unwanted and • actions are automatically and promptly actioned.
unexpected loss of generation/load leading to unnecessary network events. Neoen therefore
recommends removing from this standard any requirement for this capability, and to change the
name of the standard from “Protection to trip plant for unstable operation” to “Unstable plant
operation” or similar, provided that clear definitions of “unstable” and “oscillation” are also

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provided in the Rules. Furthermore, our understanding is that there will be a requirement for the
plant to automatically establish its contribution to the oscillations – we are not aware of any
technology that would be capable of doing that and suggest the Rules should only require
capabilities which are proven sufficiently reliable and readily available on the market from a range
of suppliers.
Powerlink – Partial Support (Opposes reference to contribution to oscillations in AAS)
Powerlink considers that “disconnection” in the context of a protection system could be
interpreted to mean a fast protection grade ~100ms trip of circuit breakers, or a slower (say 1 or 2
seconds) ramp back of active power and generating unit disconnection. We recommend the
meaning of disconnection is made clear in any Rules amendment.
We consider the Rules should clarify if the intent is to have separate devices to detect an
instability in voltage, active power and/or reactive power; and a protection system that is capable
of disconnection.
We recommend the automatic standard should include provision for SCADA signals and/or
alarms as agreed with the NSP and/or AEMO.
We do not support any reference to ‘contribution to the oscillations’ in AAS, as the methods to
prove contribution from a given plant are still not mature and can create confusion for generator,
NSP and AEMO. Furthermore, there are cases in the NEM where instabilities in one plant can be
caused by another nearby plant. It can become a matter for debate as to which plant is the
contributor to the oscillations.
In relation to PMUs and the need for AEMO to receive PMU data, Powerlink considers the intent
behind this requirement is not clear. Furthermore, meeting this requirement could become
extremely costly for generators. For example, this could include a solution for the generator to
provide high speed [non-SCADA] data directly to AEMO.
Siemens Gamesa – Support with clarification
SGRE request to define “the plant’s contribution to instability” in the draft rule to avoid any
dispute for an unnecessary disconnection of a plant. This statement should define what “the
plant’s contribution to instability” means regarding the duration, the deviation magnitude of
voltage/active power/reactive power and etc. The current draft rule is vague and triggered
conditions, thresholds and timeframes are immensely subjective.
TasNetworks – Support with clarification
TasNetworks agrees that actions to mitigate oscillatory behaviour should be agreed on by the
NSP and AEMO, and agrees with the proposed structure of the minimum and automatic access
standards (MAS and AAS). The meaning of “promptly” is vague and should be avoided. It is
crucial that concurrent tripping of asynchronous generators with the ability to detect these
oscillations does not occur, and while the NSP and AEMO are involved in the determination of
the hierarchy, this issue should be avoidable. Additionally, the connecting plant’s ability to
determine whether it is contributing to an oscillation would be difficult for it to determine with
certainty. Currently TasNetworks requires installation of phasor measurement unit (PMU)
facilities for any asynchronous generator connection, regardless of size. PMUs are not just used
for network monitoring, but also for anti-islanding schemes, and TasNetworks has required their

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use for both purposes previously. The proposed change to the AAS to only make this a
requirement for plant with an active power capability of 100 MW is problematic in Tasmania.
Using the same reasoning used to set the threshold for small connections TasNetworks requests
the threshold is set to the minimum of 100MW or 5% of any maximum credible contingency event
size specified in the frequency operating standards for the relevant region).
Tesla – does not support automatic disconnection; alternative proposed
Tesla would suggest additional changes to the third dot point to confirm that the disconnection
follows a signal from AEMO and is not automatic. We remain concerned that the revised AEMO
recommendation does not go far enough in confirming that the disconnection will not be
automatic.
Transgrid - Supports
• The proposed NER amendment under S5.2.5.10 (a)(2)(i) ‘have the capability to detect
instability in voltage, reactive power or active power at the connection point’ is a deviation from
the draft recommendation which states ‘Must have system that can detect an instability in
voltage, reactive power and active power. The latter is a mandatory requirement to be
implemented, while the former is ambiguous on the implementation requirement. Transgrid
suggests that the AAS requirement be clear in the rules and for removing any doubt, replacing
‘have the capability to detect’ with ‘must have systems that can detect’.
• Suggest including a clear definition of “instability” or a clear reference to types of instability that
is defined under the Power System Stability Guideline.
• Suggest adding ‘as per agreed configuration’ at the end of (2) (iii)(A) to address any future
disputes on ‘contribution’. The agreed configuration is expected to be considered in the design
phase based on R1 data.
• Further clarity is required on what actions to be taken by the plant on receipt of the information
from AEMO as per AAS (a)(3)(ii) and MAS (b)(2)(ii). Additionally, it would need more clarity on
what ‘form nominated by AEMO’ in AAS (a)(3)(ii) and MAS (b)(2)(ii) would be.
• Draft refers to pole slipping condition of synchronous condenser. Considering synchronous
condensers do not a have prime mover, can AEMO clarify the conditions that pole slipping
becomes relevant to syncon technology.
• Recommend General Requirement (f) to include “remote enablement and disablement signals”
in addition to the remote tripping signal.
NER S5.2.5.13 – Voltage and reactive power control
Voltage control at unit level and AusNet – Support Stakeholders who responded to this recommendation generally
slow setpoint change AusNet supports AEMO’s revised recommendation supported the proposed change, other than Powerlink, which did not
see the need for it.
CEC – Support with clarification
Since the rules require a 5 second settling time for a setpoint change of
• No major comments on what is proposed. 5% and settings are not permitted to be changed without agreement of
• Propose more specific wording that implementation of rate limited setpoint control is solely at AEMO and the NSP, it is unclear that ramp rate limiters are permitted
the discretion of the generator. (even though historically this was common practice for synchronous

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Powerlink – Does not see the need for a change machines). AEMO therefore sees some value in making the allowance
• Powerlink considers that rate limitations on a setpoint are an operational measure. We do not clear, so as to encourage the practice, which is also consistent with
see the need to include this in the GPS or Rules. desired operation of plant voltage controls under the AEMO Voltage
Dispatch System.
Siemens Gamesa – Support
Transgrid suggested specifically allowing the ramp limiter to be disabled
• SGRE support these changes. for testing purposes. However, AEMO notes that changing settings
Solar Turbines – Comment specifically for testing particular aspects of controls is not unusual, and
Voltage Control response time is compatible with 2.5 sed for a 5%Un variation. does not normally require special reference in the rules.
However fine tuning of gains could be needed. Final recommendation
TasNetworks – Support Considering all feedback, AEMO will retain its update report
recommendation.
TasNetworks supports this proposed change.
Transgrid - Support
• Recommended updating to make it clearer that the setpoint rate-limiter can be
bypassed/disabled during testing and compliance assessments.
• Acknowledge AEMO’s legal advice that the current drafting does not preclude unit level
voltage control.
Optimise power system AusNet – Opposes The intent of the proposed changes was to reorient the clause to focus
performance over expected Considering the rapid transformations occurring within the National Electricity Market, AusNet more on low system strength conditions, to ensure plant is stable for
fault level (system impedance) acknowledges the intention on the introduction of a connection point-dependent performance those conditions, where the power system is more likely to be under
range – Voltage control index (i.e., dV/dQ and dV/dP) is to improve representation of network characteristics. While stress, and less on the speed of response for conditions under which
AusNet embraces the concept of capturing potential cross coupling effect of the grid, we also the system is likely to be less stressed.
recognise the potential burden it could place on Network Service Providers. The practicality of Several parts to the proposed amendments relate to this issue,
calculating the minimum, maximum, and typical values of apparent system impedance, while repeated here so that they can be separately considered:
factoring in generator dispatching patterns when setting up the study cases, raises questions. As In the AAS:
a result, AusNet is of the opinion that the challenges presented by this change initiative outweigh
the benefits it offers. This perspective contradicts the primary objective of this rule change, which • Require a 2 second rise time of reactive power for system voltage
seeks to streamline the connection process by eliminating obstacles that are not aligned with the change up to 5% for the highest system impedance and typical
Net Zero target. system impedance level nominated by the NSP.
Caterpillar – Alternative proposal • Retain a 5 second settling time (5% step not into a limit) and 7.5 s
settling time (5% step into a limit).
MAS: It is proposed to allow a settling time of greater than 10 s for reactive power (Q) and power
factor changes. Q-response of synchronous generators are influenced by grid- and onsite For a negotiated access standard:
conditions/components, which include the grid- strength, harmonics, asymmetry and OLTCs. • Require that controls are tuned to achieve the lowest reasonably
CEC – Clarification sought achievable settling time for the highest apparent system impedance
level, prioritising the primary operating mode.
AEMO’s proposal is understood in principle in relation to an apparent system impedance.
• If a settling time of 5 seconds cannot be met for the full range of
It is recommended that an example of calculation of apparent system impedance’ be provided to
apparent system impedances, then target achieving it for the range
ensure it is clear to all, else it may be interpreted differently by various stakeholders.
highest to typical apparent system impedance.
ENA – Apparent impedance requires justification
In the MAS:

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It is not clear that the proposed concept of apparent system impedance will provide any benefit • Allow a higher settling time longer than 7.5s to be agreed with the
over the established method of using three-phase fault levels. The introduction of a new concept NSP for a voltage disturbance up to 5% (for both synchronous and
should be treated with caution, especially when it becomes a required performance standard and asynchronous plant)
significantly deviates from the standard methodology carried out by both NSPs and proponents. General requirements
AEMO has not provided clear and sufficient evidence to the industry that these changes to
S5.2.5.13 are going to meet the 65onsidtives of the NEO or provide a material improvement to • Include an explanation of the concept of apparent system
the process of tuning plant control systems. impedance (see note below) and require the minimum, maximum
and typical values to be recorded in the RUG.
Energy Queensland – clarification sought and propose alternative approach to apparent
system impedance The typical system impedance level should be reflective of typical unit
commitment.
In our view, is not clear what a “step-like change” is. Ergon Energy and Energex seek clarity from
AEMO on what this means. Use of apparent system impedance and the range of system
impedances to be considered
While Ergon Energy and Energex acknowledge the power system is dynamic, in that the pattern
of generation and load operating at any particular time can change how the settling time of the The majority of comments related to the proposed concept of apparent
generating system presents, this change may introduce additional complexity in terms of system impedance, for which AEMO sought specific feedback from
assessment and ongoing compliance. Rather than assessment on the basis of an ‘apparent stakeholders in the update report.
impedance’, we consider that it may be more appropriate to refine the way that compliance with AusNet opposed the concept of considering highest, lowest and typical
this clause is assessed. For example, a simple 5% step may no longer be appropriate, given the impedances on the grounds of the burden on NSPs to determine these
volume of generation in the system. Rather, we suggest this should be tested in a similar way to values.
compliance with S5.2.5.5 and matching the model performance to actual network conditions to CEC requested an example of the calculation of apparent impedance to
demonstrate compliance. assist interpretation. ENA indicated that AEMO has not provided
Goldwind Australia enough evidence that the changes have material benefit. SA Power
The concept of having flexibility on writing the GPS to cover a wide range of SCR operation is Networks also requested more clarity on how apparent impedance
welcome. We think that the introduction of “apparent system impedance” is more representative should be calculated and what is ‘electrically close’ to the connection
of the actual small signal response of the network. However, we believe it would be important to point.
limit the assessment only to the “apparent system impedance” range rather than traditional short Energy Queensland acknowledged the issue of different generation
circuit range. We recommend this is made explicit in the rules as lack of clarity on this will patterns introducing complexity in assessment and ongoing compliance,
introduce grey areas where AEMO/NSPs can request additional studies based on the traditional but rather than assessment on the basis of apparent impedance
short circuit range which just adds more unnecessary work to the industry. suggested compliance should instead be demonstrated by matching
Neoen – comment model performance to actual network conditions.
It should be considered how rise time and settling time integrate together. The speed of response Goldwind welcomed the flexibility to write the GPS to cover a range of
should be tuned with consideration of nearby machines and the state (e.g. strength) of the SCR operation, and considers the apparent impedance is more
network. Much like the tuning of PI controllers – fast tuning of control systems in weak network representative of the actual small signal conditions. They consider it
can increase network instability. The rise time of reactive power should be matched with the important to limit the assessment to the apparent impedance range
system’s strength not tuned to be as fast as possible or compliant with an arbitrary number of rather than the traditional short circuit range.
seconds. The response of all plant connected in proximity needs to be coordinated to ensure Powerlink did not support the proposed changes, as it considered the
correct, stable and appropriate sharing of response. There should be no hunting due to concept of apparent system impedance will devalue the core purpose of
significantly different response characteristics. control system tuning and further complicate plant tuning for no material
Powerlink – Partial Support: Supports >7.5s MAS settling time; opposes apparent gain. Powerlink agreed with the concept of tuning to achieve stability at
impedance; Alternative proposed lower fault levels, but proposed that the tuning should be set to achieve
stability for a 5% voltage disturbance at an SCR of 3.
• We strongly support inclusion of a longer settling time than 7.5s, to be agreed with the NSP,
for a voltage disturbance up to 5% (for both synchronous and asynchronous plant) in MAS. TasNetworks supported the concept.

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• We do not support the proposed changes to S5.2.5.13. We consider that the concept of Transgrid opposed it on several grounds:
apparent system impedance for S5.2.5.13 will devalue the clause’s core purpose of control • It doesn’t provide enough benefit compared with using an OPDMS
system tuning and further complicate the plant tuning exercise for no material gain. For the snapshot
power system, the main need from each generating system is to oppose the voltage change
caused by external disturbances. Therefore, compliance assessment should, in plant • It is a lot of work for NSPs
operation, be able to be demonstrated in the context of multiple other dynamic plant operating, • Using lower fault levels would be more robust (to achieve tuning
as distinct from assessing or calculating what the apparent system impedance is in the field. stable for low system strength conditions)
Powerlink considers that priorities are: • Transgrid opposes the use of apparent system impedance in a
(1) settling time (either into a limiter or not) requirements, to a 5% external disturbance (i.e. performance standard as
in the field and in a NEM model); – The variability of nearby generation can have a significant impact
(2) stability of the plant (either into a limiter or not), to a 5% external disturbance, at SCR = on the “voltage stiffness” of the network for a given plant. The
3; concept of what a typical network scenario would be for these
surrounding generators is too vague, especially when the
(3) rise time (either into a limiter or not) requirements, to a 5% external disturbance (i.e. in
surrounding plant consist of different fuel sources.
the field or in a NEM model);
– The proposal in the draft wording that a plant would need to be
(4) stable (adequately damped) performance for a 5% voltage reference change in a NEM
compliant between the nominated highest and typical system
model and in the field;
impedance, is effectively the current negotiated access standard
(5) documentation of the settling and rise time of a 5% voltage reference change. For without the specification of what that typical system impedance is.
simplicity, this can be performed in a SMIB file, for a range of fault levels from
AEMO has conducted some testing on the apparent impedance
synchronous sources (as agreed with the NSP, and documented in the GPS); and
concept, and the study will be made available with this report. AEMO
(6) a reasonability on voltage reference change for settling and rise time should be present found that, while using apparent impedance instead of impedance
as part of good tuning process. In the field operation outside of plant testing, most based on fault level does lead to response times more closely aligned to
plants are not subject to 5% Vref changes, and even if they are, there are SCADA / the impact considering all plant in service, the effect of changing
EMS delays that result in delays in seeing any reactive power change. controls on a nearby plant significantly outweighs the difference from
Powerlink agrees with focusing performance objectives on the lower fault level scenario. Stable using apparent impedance compared with impedance based on fault
plant operation (as distinct from full compliance) at fault levels below a N-1 minimum dispatch level. This is because the dynamics of nearby plant has a significant
scenario, but bounded to a reasonable level (e.g. SCR = 3 / the technical limit of the equipment), effect on the response of the plant under test. This is consistent with
can be an important tuning criteria for a plant. Transgrid’s observation about the variability of nearby generation having
a significant impact. AEMO’s conclusion from the study is that while the
SA Power Networks – Clarification sought
concept is valid, the benefits of using apparent impedance are not
• It is unclear how “apparent system impedance” is to be practically calculated under what sufficient to justify the additional complexity.
dispatch conditions as this differs from the standard calculation of fault levels and Thevenin
Range of impedance levels to be considered
equivalents. We would like to also understand what constitutes as “electrically close to the
connection point”. AEMO still considers there are benefits to considering a range of
system impedances for the assessment, and for it to focus on the lowest
Solar Turbines – Alternative proposed
system strength cases.
Reactive power and Power Factor response time is normally expected longer being a secondary
AEMO agrees with Powerlink’s comments that the most important
loop control.
considerations for tuning are:
The requirements proposed in the Draft Recommendation Update Response of 2s seems to be
• settling time for voltage disturbances,
unrealistic being faster than the requirement of the core loop (some AVR provide reactive power
control as input to the voltage loop). • stability at low fault level (low system strength) conditions
• rise time for a voltage disturbance of 5% (determined through
modelling)

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Typically fast response time is around 5s (eg typical value in Germany); shortest response time Powerlink also suggested documenting settling time and rise time for a
of 3s associated to Q(U) control could lead to system voltage oscillation (reactive power deviation 5% voltage setpoint change for a range of fault levels from synchronous
on big units is able to modify the voltage inducing a counter reaction etc.). sources performed in a SMIB model. However, AEMO notes that the
Not clear reference to impedance value in the Presentation slides (to be possibly explained) same issue as observed in AEMO’s study of apparent impedance will
occur here: i.e. the real power system will not match the rise time in the
TasNetworks – Support SMIB, because the response is significantly affected by the dynamics of
TasNetworks supports this proposed change. nearby plant. Settling time may also be affected by nearby plant.
Transgrid – opposes use of apparent system impedance, and removal of reactive rise for In terms of complexity from having to assess typical impedance, AEMO
setpoint suggests that a system normal snapshot can be used for a typical
• It is unclear from AEMO’s proposal that introducing the concept of apparent system impedance impedance case. To account for the impact of local plant, the
will provide any benefit over the established method of using three-phase fault levels: considered projects would need to be integrated with the snapshot,
especially anything nearby.
– Both methods result in the tuning/assessment of the plant using a network equivalent series
impedance connected to a voltage source. The only difference in outcome appears to be AEMO does not agree with Transgrid’s view that focusing the
that the resultant impedance calculated to represent the system would be different. It is performance requirements on lower system strength cases is just the
difficult to see how the use of the apparent system impedance is going to add value to this same as the negotiation process at present. The intent is to focus the
process. – AAS on the low to typical range of system strength (highest to typical
system impedances). The current rules are silent as to the range or the
– AEMO notes that “AEMO is not convinced that fault level would give a suitable measure focus for tuning and tend to favour fast response to achieve the AAS’ 2
here that IBR plant tends to have limited fault level contribution, but capable of injecting second rise time for low system impedance conditions.
reactive power up AAS level around target voltage level”. Transgrid acknowledges the
transient response of IBR plant and their contribution to the “voltage stiffness”, but it is Targeting stable operation at an SCR of three as proposed by Powerlink
unclear how this is going to be adequately captured through the use of a static series in the AAS would certainly focus tuning more towards the low system
impedance in a SMIB model. This comment implies that the calculated fault level is resulting strength cases, but might not be suitable for plant connected in strong
in a lower level of “voltage stiffness” to which a plant is being tuned for. Transgrid believes parts of the network, as the impedance range might be impractical for
this is a more robust approach, as the plant would be tuned to consider lower fault levels tuning.
(higher system impedance conditions). Noting several stakeholders thought that a requirement to consider high,
– The proposal by AEMO is also likely to result in a significant amount of additional work for low and typical system impedances was too much work, AEMO
NSPs to calculate apparent system impedance quantities for proponents (in addition to the proposes that the range of system impedances to be assessed is based
fault level quantities that are currently supplied). Transgrid doesn’t believe sufficient on typical impedance (represented by a system normal snapshot) and a
supporting evidence has been provided by AEMO to demonstrate the benefit of using this maximum system impedance (discussed below). AEMO intends the
method or adequate consultation has been carried out on this matter. “typical” conditions to cover the types of conditions that would be found
during commissioning of the plant.
• Disagree with the concept of a typical apparent system impedance for the purposes of
specifying a performance standard: Transgrid commented that it is unclear whether the RUG can be
updated at some later time to reflect a different range for tuning. AEMO
– The variability of nearby generation can have a significant impact on the “voltage stiffness” considers that if the plant is later retuned for different range of system
of the network for a given plant. The concept of what a typical network scenario would be for impedance, because of changes to the system, then it would be
these surrounding generators is too vague, especially when the surrounding plant consist of appropriate to update the RUG with the new values of system
different fuel sources. impedance. The goal would be to change the tuning settings to achieve
– The proposal in the draft wording that a plant would need to be compliant between the the GPS requirements considering the changed power system
nominated highest and typical system impedance, is effectively the current negotiated conditions. This would, of course also mean updating the settings in the
access standard without the specification of what that typical system impedance is. For a RUG to reflect their amended values at the same time.
negotiated access standard, at some point along the range of fault levels between low to AAS 2 second rise time for a power system disturbance of up to
high, a plant would exceed the AAS requirement of a 2 second rise time. The current rules 5%
requirement is that the negotiated rise time is specified in the performance standards, rather

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than retaining the 2 second requirement and carving out a fault level (or system impedance) Transgrid suggested including a rise time requirement for a 5% step in
range for which the 2 second requirement is applicable. system voltage and also retaining the rise time for a voltage setpoint
• Agree with AEMO that the response of nearby plant can have a significant impact on a plant’s change (as a testable parameter). Transgrid also proposed that a
own response to both setpoints and disturbances: different rise time could be set for disturbances and setpoint changes,
as a negotiated access standard.
– Recommends the use of full network models such as AEMO’s OPDMS snapshots and the
Connections Simulation Tool, as these are much better placed to capture the interactions Transgrid also argued that this setpoint change requirement would
with surrounding plant. As noted above, it is unclear how the concept apparent system accommodate unit level voltage control by having different plant and
impedance is going to provide significant benefit over using the calculated fault levels. unit level objective (slower setpoint change and faster disturbance
response). This would add another compliance assessment
– Considers that these tools are likely underutilised by proponents for the purposes S5.2.5.13 requirement. Not having a setpoint related rise time requirement would
plant/unit level voltage control tuning. be better aligned with unit level voltage control.
• Disagrees with the removal of the reactive power rise time requirement for a change in voltage Transgrid also objected to a rise time requirement for a disturbance of
setpoint: less than 5% on the grounds that the signal to noise level may be too
– It is understood that for some plant, all else being equal, the existing AAS objective for a small. AEMO acknowledges that this can be a problem for field testing,
voltage setpoint can negatively impact the stability of the plant due to aggressive tuning. and proposes to change this to 2-5%, to avoid the measurement
– Proposes that the reactive power rise time requirement be applicable for a change in voltage difficulties around small changes.
setpoint or a step change in the voltage at the specified location. That is, retain the existing Powerlink agreed with the rise time requirement for a 5% system
requirement, but introduce the requirement for a step change in the voltage. This would then voltage step in a model or in the field, as a compliance requirement.
align with the requirements for settling time. Solar Turbines suggested that a response time of 2s is too fast, 3s is
– This proposal allows for the plant performance to remain readily testable during likely to cause voltage oscillations and 5s is a typical time in Germany.
commissioning whilst also facilitating the possibility of a negotiated access standard, where Energy Queensland suggested that rather than applying a voltage step
a different rise time can be agreed to for setpoints and disturbances. in the field the compliance could be assessed like S5.2.5.5 (by means of
– The above proposal also better accommodates unit level voltage control, as the plant level assessment of actual disturbances over the life of the plant, rather than
and unit level responses can therefore be tuned for different objectives (slower setpoint specific tests) matching the model performance to actual network
change and faster disturbance response). conditions to demonstrate compliance.
• The magnitude of the voltage step should not be specified as any voltage less than 5%: AEMO agrees that achieving a 5% voltage step in field testing is usually
not possible. However, a 2 second rise time for a setpoint change is not
– Not including a limit on the minimum size of the disturbance is not recommended to avoid
aligned to best performance for the power system, notwithstanding that
compliance testing and requirements for very small step changes in the voltage which would
it is testable.
have a low signal to noise ratio.
AEMO agrees with Powerlink that it is the response to voltage
– The removal of the requirement for setpoint changes, as outlined above, also make this
disturbances that matters. AEMO also agrees with Energy Queensland
performance criterion difficult to test onsite.
that the response to a disturbance can be considered over the life of the
• It is unclear from AEMO’s proposal whether the intention of the rules is to allow the NSP to plant.
provide updated minimum, typical and apparent system impedance advice to a proponent,
As illustrated by AEMO’s study, a neighbouring plant can significantly
after the performance standards have been agreed, to which the plant is then potentially
affect the rise time for a setpoint change. This is because a
required to retune their plant for:
neighbouring plant in voltage control opposes the change in voltage.
– It is unclear if AEMO’s intent is that the RUG can be updated with revised system Therefore, this metric is not a good measure for compliance
impedance values for which the plant will be required to remain compliant with, or whether assessment as it is adversely affected by external factors outside the
the reference to the RUG in the GPS refers only to that version at the time of GPS control of the generator. Nevertheless, AEMO acknowledges that it is
agreement. important to assess stability of the plant during commissioning.

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• As noted in the previous submission, Transgrid believes that amendments to these aspects of AEMO agrees that a 2 second rise time is not generally suitable for
S5.2.5.13 are much better suited as general guidelines for a negotiated access standard: typical conditions, as suggested by Solar Turbines, as the plant will
– The introduction of a new concept should be treated with caution, especially when it become faster and less stable for lower SCR conditions.
becomes a required performance standard and significantly deviates from the standard AEMO notes that the rise time for voltage disturbance is likely to be
methodology carried out by both NSPs and proponents. faster if new plant connects nearby or if the system impedance
– AEMO has not provided clear and sufficient evidence to the industry that these changes to decreases (for example, due to the retirement of synchronous plant).
S5.2.5.13 are going to meet the objectives of the NEO or provide a material improvement to Therefore, the risk of non-compliance over time to a rise time
the process of tuning plant control systems. requirement based on a system disturbance is lower than for one based
on a setpoint change.
– The current rules already provide flexibility for a negotiated access standard to be agreed
upon, though the rules should be updated to provide much clearer guidance for such a Since the rise time is affected by changes in generation and network
negotiated standard. over time, and because a SMIB model is unlikely to result in rise times
the same as measurements for the same system impedance, AEMO
– The current rules are not overly complicated as they don’t carve out system conditions for does not see value in recording in the GPS rise time (or settling time) for
when the plant is considered compliant. It is recommended that the rules be updated to based on 5% setpoint change a range of fault levels based on SMIB
provided better guidance for a negotiated access standard and better guidance as to how to model results, as suggested by Powerlink.
appropriately tune the plant when the plant’s connection point might experience a wide
range of fault levels (or system impedances). Maximum impedance condition
The power system will in general tend to be less stable at system
strength conditions than for high system strength. Powerlink has
suggested that the tuning should give a stable response down to an
SCR of 3. While AEMO supports targeting stability for weak grids, a
blanket requirement for compliance assessment at SCR of 3 might not
be workable for plant (especially small plant, since SCR is a function of
plant size) that is connected in parts of the grid that have high fault level
for typical conditions. In particular the plant may not be able to achieve
the required settling time at typical levels while also achieving stable
operation at SCR of 3.
Therefore, AEMO does not propose to link the requirement for stable
operation down to SCR of 3.
For the AAS AEMO considers that a reasonable compromise might be
to consider for the low system strength case, the fault level at the
connection point based on the minimum fault level associated with the
electrically closest system strength node, in combination with the
network outage that most reduces the fault level at the connection point.
The minimum fault level condition would usually be higher than the
equivalent fault level agreed under S5.2.5.15 for minimum SCR, but
there may be some cases where it would be lower, in which case the
value under S5.2.5.15 should be considered, as this is a design limit of
the plant. Note that the minimum SCR agreed under S5.2.5.15 might
also be less than 3 in some cases.
For this maximum system impedance condition, AEMO suggests the
plant should have a settling time of 5 seconds/7.5 seconds for a 5%
voltage disturbance for operation not into a limiter and into a limiter

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respectively. Since this condition is unlikely to occur in normal
conditions on the power system, the assessment would necessarily be
by simulation, rather than testing.
Operation out of limiters
In addition, AEMO proposes to extend the settling time requirements to
conditions where the plant response is starting from a limited condition
and the voltage or setpoint step causes it to exit the limit. This aims to
test for whether wind-up of the controller is occurring. Wind-up of a
controller is an undesirable behaviour, which in the context of a voltage
controller, can cause a voltage excursion to be prolonged, by delaying
the reactive power response.
Summary
In summary, the modified proposed rise time and settling time
requirements for the AAS and voltage control are:
• 3 second rise time for a steplike 2-5% voltage disturbance not into a
limit for typical system impedance to maximum system impedance
conditions
• 5 second settling time (not into a limiter) and 7.5 s settling time (into
and out of a limiter) for a 5% voltage setpoint change considering
typical power system impedance conditions at the connection point
• 5 second settling time (not into a limiter) and 7.5 s settling time (into
and out of a limiter) for a steplike 2 to 5% voltage disturbance for
typical to maximum system impedance conditions at the connection
point
• Maximum system impedance conditions at the connection point are
defined with reference to the higher of the fault level corresponding to
the performance standard agreed under S5.2.5.15 and the fault level
at the connection point considering the fault level required to be
maintained at the electrically closest system strength node, in
conjunction with the network outage which most reduces the fault
level at the connection point.
In addition, AEMO proposes to make consistent impedance ranges for
synchronous plant for the settling time criteria for synchronised
operation (S5.25.13 (3) (B) and (C)), to address an omission in the
indicative drafting provided with the update report.
Note that the assessment conditions are based on the same criteria as
for the minimum fault level in S5.2.5.5 for tuning and for MFRT
requirements.
AEMO can issue guidance to describe more fully what typical
impedance conditions comprise, and the concept of steplike in this
context. Use of a wide-area model (such as an OPDMS snapshot) is

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more likely to capture the dynamics of nearby plant than a SMIB model
for the typical case, which should enable comparison with model
behaviour for testing. Typical impedance can change over time, so
tuning settings might eventually need to change if the power system
impedance characteristics change significantly. Referencing the values
of fault level in the RUG (as discussed in S5.2.5.5) will assist future
identification of when tuning might need to be reviewed.
Final recommendation
Considering all feedback, AEMO will modify the update report
recommendations to:
• change “apparent system impedance” to system impedance
• change the rise time requirement from 2 to 3 seconds and not into a
limiter
• change to a 2-5% voltage disturbance performance requirement,
rather an “up to 5%” requirement
• add the requirement for settling time for steps out of a limit
• omit reference to minimum (apparent) system impedance conditions
(i.e. the range to be considered is from “typical” to maximum
impedance conditions)
• define maximum system impedance conditions, consistent with that
proposed for S5.2.5.5 tuning range
• apply the same range of impedances to synchronous machine
settling time for voltage setpoint step and voltage disturbance into/out
of and not into limiters.
The MAS requirement for settling time is discussed below.
The full list of rise time and settling time requirements considering these
and other changes is provided in Appendix 4.
Minimum access standard for CEC – partial support, alternative proposed The update report proposed an allowance for a system voltage
settling time Member feedback was received where the 7.5 second settling time could not be met due to a disturbance of 5%, a settling time of 7.5s or greater number agreed with
network asset that had a very slow settling time, hence voltage would not settle within 7.5 the NSP.
seconds resulting in the generator being non-compliant. This was based on a request from Transgrid in feedback to an earlier
The MAS for settling time is 7.5 seconds for non-limiter operation. Recommend that the round of consultation.
requirement for settling time in the MAS be removed to account for the above scenario. This change received some specific feedback. It was supported by
Energy Queensland – Do not see a need Powerlink. The CEC requested removing the requirement altogether,
but the specific condition described would be manageable with the
Ergon Energy and Energex do not support an open-ended settling time ‘limit’. Ergon Energy and change proposed in the update report.
Energex are not aware of any technical reason why a 7.5s settling time cannot be achieved by
new plant. Energy Queensland did not see the need for the change. However, an
NSP does not need to use the provision if they do not have the need, for
Powerlink – Supports

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• We strongly support inclusion of a longer settling time than 7.5s, to be agreed with the NSP, this provision which is intended to provide additional flexibility for
for a voltage disturbance up to 5% (for both synchronous and asynchronous plant) in MAS. unusual situations.
Final recommendation
Considering all feedback, AEMO will retain the update report
recommendation, for typical impedance and specifying the voltage
disturbance to be “step-like”.
The full list of rise time and settling time requirements considering these
and other changes is provided in Appendix 4.
Clarification of when multiple Akaysha Energy – Support The intent of the proposed changes is to reduce the AAS requirement
modes of operation are required The submission supports the simplification of reactive power control modes into primary and for three modes of operation down to two, and to place more
secondary modes. compliance emphasis on the mode of operation under which the plant
will operate most of the time.
AusNet – support
The proposed changes seek to require, in the AAS a primary and
• AusNet supports AEMO’s revised recommendation secondary mode of operation. The primary mode is the mode that will
CEC – Support with clarifications be used most of the time, and the secondary mode occasionally.
• The concept of a primary and alternate control mode is welcome. This would reduce time and Conditions for use of the secondary mode might include testing or
effort required for modelling as well as during commissioning where presently three modes are operation under planned network outages. The proposed changes
assessed. contemplate reduced compliance requirements for the secondary mode.
Additional considerations for this clause have been to focus the
• The codifying of voltage control as the primary mode may preclude using other modes as the
compliance requirements on measures that are appropriate for the
primary mode (eg power factor). Both for existing and well as legacy plant that may be
desired outcomes on the power system and ensuring the outputs
currently operating in power factor mode that go through the 5.3.9 process.
assessed for compliance are suitable for the characteristic that is being
• Alternatively, propose that only two modes are required, a primary and alternate mode. tested.
• Unclear why settling time compliance for setpoint changes is carved out but for voltage As an example, the proposed drafting removes a requirement to assess
disturbances it is retained. A generator would need to apply setpoint changes to confirm voltage settling time for a reactive power setpoint step change, as
compliance rather than wait for a network event. voltage is not a controlled parameter for reactive power control.
Energy Queensland – Partial support Reducing the number of operating modes to two, and the concept of a
Ergon Energy and Energex consider that if a secondary mode is required, that adequate tuning primary and secondary mode has received strong support from
of that mode should be demonstrated. stakeholders over the draft report and in the update report and drafting
consultation.
Powerlink – Supports with clarification
Some stakeholders expressed different opinions on some detailed
Powerlink considers the NSP should be specifying the primary and secondary control modes. We implementation issues, which are considered further below.
agree that the secondary control mode should have reduced assessment requirements.
However, secondary control mode assessment should include that the required reactive power Specification of the primary mode
target (or power factor) is met within a given tolerance. Powerlink and Transgrid suggest that the NSP should have the flexibility
Solar Turbines – Support with clarification to specify different primary control modes, whereas the proposed rule
has voltage control as the primary mode. Powerlink and Transgrid did
Signal leading to control mode switching shall be defined. not say why this would be preferred other than if the proponent
This shall include how the switching shall happens. proposes voltage as a primary mode, then the NSP cannot require an
TasNetworks – Supports alternative mode as primary mode. AEMO agrees that if a proponent
proposes voltage control as a primary mode, the NSP cannot object to
TasNetworks supports this proposed change.
it. CEC suggests that codifying voltage control as primary mode may

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Transgrid – Support with clarification prevent another mode from being primary mode, which might affect
• Suggests retaining the existing rules requirement for the settling time for a step change in current and legacy plant that is going through a NER 5.3.9 process.
reactive power (or power factor) setpoint for the secondary control mode. The secondary AEMO notes that the proposed drafting does not preclude having power
control model should be appropriately tested during commissioning. Reference setpoint tests factor or reactive power mode as a primary mode as a negotiated
are important to verify that the plant has been turned appropriately for the mode. access standard.
AEMO considers power factor or reactive power mode would only be
• Recommends that the rules have flexibility to allow for a different primary control mode, at the
preferable where necessary to work around a technical limitation that
discretion of the NSP. The reason why this flexibility is important for the AAS, is because if a
cannot be otherwise resolved with voltage control mode. Note that there
proponent proposes voltage control mode as the primary control and it is the AAS, then the
would be an option to limit the range of reactive power for voltage
NSP must accept that, as per the requirements of the NER.
control purposes should it be desirable to have something closer to
reactive power control. However, there may be some rare cases where,
to resolve a network issue, specification of a mode other than voltage
control for a primary control might be necessary. Therefore, AEMO
proposes to permit the NSP, in consultation with AEMO, to specify a
different primary and secondary mode to cater to special circumstances
on the power system, but in that case to require voltage control as a
secondary mode of operation.
Requirements for compliance assessment
There is a tension between demonstrating adequate tuning and the
burden of time and resource from compliance assessment, validation
during the connection phase, at commissioning and throughout the life
of the plant. AEMO agrees with Energy Queensland that adequate
tuning must be demonstrated both for primary and secondary modes.
Transgrid suggested retaining the existing rules requirement for settling
time for a step change in reactive power setpoint for the secondary
control mode, and that the secondary control mode should be
appropriately tested during commissioning. Transgrid preferred setpoint
testing because it is something that can be done during testing. CEC
commented that it is unclear why settling time compliance for setpoint
changes has been carved out of the requirements for power factor and
reactive power, and suggested that setpoint step settling time
compliance can be assessed at commissioning rather than waiting for a
voltage disturbance. Considering the last comment AEMO notes that
having a setpoint step settling time requirement would not make any
difference to the time required to confirm compliance with a voltage
disturbance (which requirement AEMO proposes to retain).
AEMO acknowledges that it is useful to be able to validate responses
through testing.
The concern with setpoint step testing is that a large setpoint step
change of power factor or reactive power of the type described in the
current rule is neither necessary nor desirable on the power system and
is therefore not a suitable measure for compliance: A slower
overdamped response to a setpoint change may have a long settling

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time but this would be suitable for a reactive power or power factor
mode of operation, so a 5 second settling time is not a suitable measure
of a “good” response. As Powerlink indicated, the important control
performance characteristic is the response to voltage disturbances, for
which a shorter settling time is desirable. As a compromise, and to
verify that the power factor and reactive power modes are stable, a
requirement for the controls to be adequately damped could be
substituted.
Powerlink agrees that the secondary mode should have reduced
assessment requirements but suggests that the secondary control mode
assessment should include that the required reactive power target or
power factor target is met within a given tolerance. AEMO agrees that
tracking a target level to within a reasonable tolerance is an important
performance characteristic, but notes that AEMO has not proposed any
changes to the existing rules, which include regulation requirements,
irrespective of primary or secondary mode operation.
Final recommendation
In the AAS:
• Require two operating modes, a primary and secondary mode with
the ability to switch between them
• By default, the primary mode is voltage control, but permit the NSP
under the AAS to require a primary operating mode other than
voltage control, with voltage as the secondary control mode.
• Where voltage is the secondary mode, omit the reactive risetime
requirement.
• For power factor and reactive power modes:
– Remove the requirement to assess voltage settling time
– Retain the requirement to assess reactive power settling time, and
for power factor mode, active power settling time, for voltage
disturbances, and
– For a setpoint step not into a limit equivalent to at least half the
range of reactive power agreed in S5.2.5.1 require that reactive
power, if response overshoots or exhibits oscillatory behaviour, has
a settling time of 5 seconds or less.
• Where power factor mode or reactive power mode is the primary
operating mode, require the same range of system impedances for
each assessment listed above as for the voltage control assessment
(described above).

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• Otherwise, for a secondary mode, require the voltage disturbance
step responses for that mode to be assessed for typical impedance
that would occur in normal operation of the grid.
• A ramp-limit on a setpoint change may be applied, where agreed with
the NSP and AEMO (apply this to all three modes).
Full detail of how AEMO’s proposal would apply for risetime and settling
time requirements across voltage, power factor and reactive power
control, AAS and MAS and primary and secondary modes, is provided
in Appendix 4.
Materiality threshold on Transgrid – Partial Support; Alternative proposed AEMO agrees with Transgrid that there is often a deadband for active
settling time error band • Transgrid agrees with the introduction of a materiality threshold for active power settling time in power, particularly within the power plant controller of a distributed
response to a voltage step or voltage setpoint. generating system (eg wind or solar farm), but also on some other types
of plant, in which the active power controller will not seek to control the
• Transgrid agrees with AEMO’s intent to “avoid the calculation where it is not meaningful...”, yet active power. This means that active power variations due to internal
AEMO doesn’t appear to have considered that a fixed 3 MW materiality threshold can still lead (eg energy source) or external factors (eg voltage fluctuations on the
to relatively small error bands being calculated for large plant, thus leading to potential power system) within the deadband will not be corrected. The rules do
calculations which are not deemed meaningful. Furthermore: not specify an accuracy requirement for active power within the
– For a large plant, a 3 MW materiality threshold can result in an extremely small tolerance to technical standards but rely on conformance with dispatch measures
which AEMO is expecting the plant to regulate active power within. For example, if a 500 instead.
MW plant exhibited a maximum change of 5 MW in response to the step, then this would AEMO notes that +/-0.5 MW is the smallest error band under this
require the plant to regulate active power to back within ±0.5 MW, or ±0.1% of the rated materiality threshold, (unless the active power output changed as a
active power. This tolerance for the settling error band is not considered reasonable, cannot result of the voltage setpoint step, noting that a large active power
be readily verified through on-site testing and does not appear to serve a useful purpose as change for a voltage disturbance step would most likely be non-
a performance standard. compliant with S5.2.5.4).
– If the induced change in active power is relatively small compared to the size of the plant The proposed change was intended to address situations where the
but above the materiality threshold of 3 MW, then a plant controller’s integral gain would small change in active power in combination with background changes
need to be tuned relatively aggressively to regulate the active power to within such a small in active power or voltage mean that the settling time cannot be
tolerance. Even with the added flexibility of the updated MAS for settling time, this is not reasonably determined.
deemed to be a reasonable incentive to speed up the active power controller’s response
Transgrid’s concern is around the relative size of the plant to the
time.
threshold.
– Such a small tolerance bands for large plant would also prohibit plant controllers from setting
Alternative formulation
reasonable deadbands around the target setpoint or only allow setting dead them to be so
small as to be of no value. An alternative formulation would apply a an error band of:
• Transgrid recommends using the rated active power when determining the materiality • ±0.5 MW;
threshold, potentially with an upper limit the maximum magnitude of the threshold. In addition, • ±2% of the maximum active power (or maximum demand, as
consideration should be given to an allowable deadband for the active power control response relevant) agreed under a performance standard for clause S5.2.5.1;
to a change in voltage setpoint. This would be in line with the setpoint accuracy requirement or
for reactive power control in S5.2.5.13, where the rules require that the plant only need to be
able to regulate reactive power to within 2% of the rating (in MVA; expressed in MVAr). • the value of error band calculated using the definition of settling time.
Settling time would need to be calculated for larger deviations, but with
error band thresholds modified to be at least ±0.5 MW for plant sized

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up to 25MW, linearly increasing to be at least 2MW for a 100 MW
plant, ±20 MW for a plant of 1000 MW.
Materiality thresholds more generally
ElectraNet and Neoen observed, under responses to the proposed
settling time definition change that this change made the error bands
smaller for settling time generally.
AEMO notes that that proposed change aligns the settling time for the
two parts of the definition, but agrees that error band size can be too
small for sustained changes of reactive power and voltage under
S5.2.5.13 as well as active power.
On consideration of ElectraNet and Neoen’s comments, AEMO
proposes to extend the consideration of error band threshold to all uses
of this clause (voltage, reactive power and active power), and to make
consistent error band allowances.
Final recommendation
Amend the NER as follows, for active power settling time:
• Apply a settling time error band that is the largest of:
– ±0.5 MW
– 2% of the maximum active power (or maximum demand, where
relevant) agreed under a performance standard for clause
S5.2.5.1, and
– the value calculated under the settling time definition.
Amend the NER as follows, for reactive power settling time
• Apply a settling time error band that is the largest of:
– ±0.5 MVAr
– 2% of the maximum reactive power agreed under a performance
standard for clause S5.2.5.1, and
– the value calculated under the settling time definition.
Amend the NER as follows for voltage settling time:
• Apply a settling time error band that is the larger of:
– ±0.5% of nominal voltage and
– the value calculated under the settling time definition.
Impact of a generating system Akaysha Energy – Support with clarification The proposed amendments in the update report were to:
on power system oscillation Akaysha Energy would like to understand the assessments required to support the MAS in the • Modify the MAS to require the plant not to reduce the damping of any
modes “do not harm” in the existing network damping. The submission supports the “call out” of the oscillation that is not adequately damped.
system strength framework, for IBR that pays for service to mitigate instabilities. The submitter is

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concerned that reference to oscillation modes relates to SSAT models, which may be difficult for • Where a Schedule 5.2 Participant has elected to pay the system
new OEMs to produce. The submitter suggests the clause could be relaxed to reduce the barrier strength charge (under NER 5.4.3B(b1)), require that assessments
to entry of new OEMS. take into account the performance required to be provided by the
AusNet – supports SSSP at the relevant system strength node.
AusNet supports AEMO’s revised recommendation AEMO’s response below analyses these issues in turn:
CEC – No concerns raised Modification of MAS to require the plant not reduce the damping of
any mode that is adequately damped
No major comments on what is proposed
AusNet, CEC, TasNetworks, Tesla, and Transgrid supported this
Energy Queensland - Partial Support; Alternative proposed recommendation. Transgrid suggested reformatting the requirement to
Ergon Energy and Energex agree it is reasonable to include the performance of the system be clearer.
strength service provider, where relevant. We consider that plant should not reduce the damping However, after further consideration of the proposed change, and
of any oscillations and are supportive of removal of the reference to “is not adequately damped”. recognising that the current MAS includes a requirement not to degrade
Hydro Tasmania – comment any mode of oscillation that is within 0.3 nepers per second of being
HT is aware that the acceleration of the IBR has been one of the key drivers of the NER change, unstable by more than 0.01 nepers per second, the existing rule seems
unfortunately, synchronous generator doesn’t [sic] necessarily across in the issue, such as the to cover the proposed change sufficiently well.
unique 7-10Hz oscillation mode associated with the GFL inverter tuning experienced in the NEM Therefore, AEMO does not intend to progress part of the proposed rule
as mentioned in the consultation draft report, despite synch condenser operation provides fault change.
level support to mitigate the issue. Accounting for remediation by the SSSP in the assessment
So as big take away, HT would suggest that rather than relying on a consultation process to Akaysha Energy, AusNet, CEC, Energy Queensland, TasNetworks,
educate, update and discuss the emerging matters with the participants, can AEMO create a Tesla and Transgrid supported this change. Transgrid noted that paying
platform, so that the emerging issues, concerns, insights, rule change supporting evidence and system strength charge should not preclude the connecting plant from a
discussion outcomes etc. can be shared and recorded in public, timely and traceable manner. As requirement to optimise the plant design and control settings if stability
a result, to better engage with the participants and support the 3-5 years once NER change, issues are identified. Powerlink suggested that the nature of a system
ultimately, underpin the NEN transformation. strength solution might change between planning and implementations
Powerlink – Support with clarification phases. Powerlink suggested that this might lead to tuning and
In relation to: ‘where a Schedule 5.2 Participant has elected to pay the system strength charge assessments that may not be real. Powerlink suggested the wording be
(under NER 5.4.3B(b1)), require that assessments take into account the performance required to changed so that it may (instead of must) take account of the
be provided by the SSSP at the relevant system strength node’, Powerlink considers that the performance to be required by the SSSP at the relevant system strength
nature of a system strength solution planned by an SSSP to meet S5.1.14 can change between node.
the planning and implementation phases. Mandating this approach in MAS could lead to However, AEMO does not see that this would resolve the issue faced by
tuning/assessment that may not be real. We therefore recommend this is included as an optional the proponent, if the SSSP were to change its mitigation strategy. In any
(i.e. may) instead of a mandatory (i.e. must) requirement, based on the NSP’s requirements. case, it would be anticipated that the level of support for system
Solar Turbines – Comment strength that the proponent is paying for should not be reduced to the
extent that the plant becomes non-compliant with this clause.
• The proposed modification/addition is not clear.
AEMO also acknowledges some more general comments made in
Better clarification is needed to provide feedback. response to this clause, but these are not specific to the issues under
TasNetworks – Supports examination.
TasNetworks supports this proposed change. Final recommendation
Tesla – Support Considering the stakeholder feedback, AEMO will:
Tesla is supportive of this revised recommendation.

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Transgrid – supports with clarification • omit the additional requirement on oscillations not adequately
• Supports AEMO’s intent in modifying the MAS to require the plant not to reduce the damping damped
of any oscillation that is not adequately damped. • retain its update report recommendation on accounting for
• Combining this requirement with the current S5.2.5.13(d)(ii)(A) as per the proposed drafting in remediation by the SSSP when the Schedule 5.2 Participant has
Appendix A2 makes application of this requirement ambiguous. For clarity Transgrid suggests elected to pay the system strength charge (under NER 5.4B(b1),
S5.2.5.13(d)(ii) to be amended to: other than to reformat the clause S5.2.5.13(d)(ii)(A) for improved
clarity.
“(ii) operation of the schedule 5.2 plant production unit does not degrade:
(A) damping of any oscillation mode not adequately damped;
(B) any mode of oscillation that is within 0.3 nepers per second of being unstable, by
more than 0.01 nepers per second; and
(C) any other mode of oscillation to within 0.29 nepers per second of being unstable;
and”
• Supports the revised recommendation requiring the assessments to consider the required
performance from the system strength service provider at the relevant system strength node,
noting that paying system strength charge should not preclude the connecting plant from being
required to optimise plant design and control system tuning if stability issues are noted at the
connecting location.
Definition – continuous uninterrupted operation

Recognition of frequency Akaysha Energy – Commentary; supportive of allowing for phase jump and fast frequency The proposed change sought to recognise frequency response mode,
response mode, inertial response) inertial response and active power response opposing an angle jump as
response and active power The submission highlights that GFM responds to phase angle jumps, regardless of whether the legitimate behaviours, within the definition of CUO.
response to an angle jump inverter enters FRT and in transient timeframes and that Very Fast FCAS contingency response Akaysha Energy, AusNet, CEC, Energy Queensland, TasNetworks,
is likely to be provided by GFM. The submitter strongly believes that requirements in CUO should Tesla and Transgrid supported this proposed change. Powerlink did not
not disincentivise fast frequency and virtual synchronous control features. see the need for it, commenting that the existing rules have been used
AusNet supports to manage these issues. However, AEMO notes that clearer recognition
of these behaviours as positive for the power system reduces the
AusNet supports AEMO’s revised recommendation perception that they are not consistent with CUO. As previously noted,
CEC Support inertial response is programmed in IBR GFM technology not inherent.
No major comments on what is proposed. AEMO is seeking to remove impediments to their connection and speed
up the process for connection. It is difficult to ensure that engineering
Energy Queensland – Support judgement is always applied, when the rules can be literally read as
Ergon Energy and Energex are supportive of inclusion of provisions for inertial response preventing desirable behaviours.
Neoen – clarification sought Neoen sought clarification as to whether inertial response is covered by
1. Is inertial response not adequately addressed in S5.2.5.11? S5.2.5.11. AEMO considers that S5.2.5.11 refers to frequency droop
response, rather than inertial response.
2. How is active power response and voltage phase angle response assessed in practi–e - i.e.
for an operational facility? It is important to understand the difference between models and Neoen also queried how active power response to a phase angle jump
physical plant when looking at sub-cycle performance. can be practically measured. AEMO considers this could be observed in
assessment of power system incidents, considering the phase shift
Powerlink – Does not consider this change necessary

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 NER Schedule 5.2 issue Summary of feedback provided – Schedule 5.2 AEMO response
We do not see the need for this change. The current definition of CUO can be used to manage measured at the connection point, and the response of the plant. This
the issues raised in the Discussion Paper. The proposed changes appear to focus on ‘how to type of response can also be observed in simulations.
apply engineering’, which we do not consider a primary role of the Rules. Transgrid also raised a separate issue about application of CUO
Solar Turbines – Supports / Comment paragraph (d) when considering inadvertent disconnection scenarios for
Natural behaviour for synchronous generating expected to be already in line with requirements. assessing the feasibility of inadvertent disconnection scenarios.
TasNetworks – Supports However, this issue is not one that AEMO proposes to address in the
current review. We suggest that Transgrid might consider raising it as a
TasNetworks supports this proposed change. separate rule change request.
Tesla – Supports Other changes to the CUO definition
Tesla remains supportive of this recommendation. The current drafting of the CUO definition is very focused on S5.2.5.5,
Transgrid – supports whereas the other clauses also use this definition. AEMO has proposed
• Transgrid supports the amendments proposed to the CUO definition. some minor amendments that make the drafting more appropriate for
other clauses.
• Transgrid has seen issues with application of CUO requirement in paragraph (d), when
considering inadvertent disconnection scenarios (classified as credible contingency events The drafting changes were reflected in the rules drafting provided for
under S5.1.2.1) for assessing feasibility of transfer trip schemes under clause S5.2.5.8(d). This comment with the Update Report. No comments on these changes were
issue is exacerbated by the lack of clarity in the system standards under clause S5.1a.4 on the received.
allowable reduction in voltage of supply at a connection point due to a contingency event. Final recommendation
There should be flexibility for the NSP to allow transient voltage variations below 90% of Considering all feedback, AEMO will retain its update report
normal voltage for a limited period due to inadvertent disconnection of transmission plant, recommendation, noting also the minor drafting improvements to make
provided that there are no material adverse impacts to other connected plant the clause more general.

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4 Schedule 5.3a feedback
Schedule 5.3a Conditions for connection of MNSPs

Issue Summary of feedback provided – Schedule 5.3a AEMO response

NER S5.3a.1a Introduction to the schedule

Alignment of schedule with Marinus Link supports AEMO notes the support from Marinus Link for removing the NER S5.1 obligations
plant-type rather than • Marinus are supportive of the proposal to remove NER S5.1 obligations from HVDC from HVDC network elements that are covered by NER S5.3a.
registration category network elements that are covered by NER S5.3a. AEMO agrees that there is an inconsistency between the policy and drafting of
NER 5.3.4B in regard to the payment of system strength charges by a regulated
• Marinus notes an unintended consequence of the proposed drafting where NER 5.3.4B
NSP that owns an HVDC link. AEMO considers that a NSP that owns and operates
replaces Market Network Service Providers with Schedule 5.3a Participant, thus requiring
an HVDC link should not pay system strength charges on the basis that:
all HVDC elements to pay system strength charges rather than only non-regulated HVDC
elements. This is inconsistent with the text of the update report. Marinus suggest that the • the HVDC project would be developed using the NER joint planning process:
NER include an explicit statement in 5.3.4B that system strength mitigation requirements and
for HVDC systems owned by regulated NSPs should be addressed by means of the joint • any system strength mitigation costs are included in the associated RIT-T.
planning process.
AEMO will review the drafting to be consistent with its policy.
TasNetworks support
AEMO agrees that “voltage transformer” in NER S5.3.3(c)(1) and S5.3a.6(c)(1)
TasNetworks supports this proposed change. should be italicised.
AEMO notes the support from TasNetworks.
Final recommendation
Considering the stakeholder feedback, AEMO will retain its update report
recommendation.

NER S5.3a.8 – Reactive power capability

Reactive power Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.
Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

NER S5.3a.13 – Market network service response to disturbances in the power system

Voltage disturbances Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.

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 Issue Summary of feedback provided – Schedule 5.3a AEMO response
Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

Frequency disturbances Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.
Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

Fault ride through Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.
requirements Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

NER S5.3a.4 – Monitoring and control requirements

Remote monitoring and CTLab support AEMO notes the support from CTLab, Marinus link and TasNetworks.
protection against instability Supports alignment with S5.2.5.10. Final recommendation
Marinus Link supports Considering the stakeholder feedback, AEMO will retain its update report
Marinus is generally supportive. recommendation.
TasNetworks support
TasNetworks supports this proposed change.

New standards
Voltage control Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.
Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

Active power dispatch Marinus Link supports AEMO notes the support from Marinus link and TasNetworks.
Marinus is generally supportive. Final recommendation
TasNetworks support Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

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5 Multiple schedule feedback
Multiple Schedules

Issue Summary of feedback provided – Multiple Schedules AEMO response

NER Multiple clauses

References to superseded Powerlink - Supports AEMO notes support from Powerlink and TasNetworks.
standards Powerlink supports this proposed change. Final recommendation
TasNetworks – Supports Considering the stakeholder feedback, AEMO will retain its update report
TasNetworks supports this proposed change. recommendation.

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6 Structural amendments feedback
NER structural amendments

Issue Summary of feedback provided – NER structural amendments AEMO response

NER structural amendments

Drafting principles Powerlink – Opposes; Alternative proposed See comments under S5.2.1 regarding Powerlink’s comments on inclusion of
Flexibility to include components of S5.2 should be available at NSPs and AEMO at their synchronous condensers in schedule 5.2.
discretion. (As noted above) AEMO acknowledges TasNetworks’ support of the proposed changes. No further
TasNetworks – Supports feedback was provided by Transgrid.
TasNetworks supports this proposed change.
Transgrid – additional comment pending
Intending to provide further feedback on the NER structural amendments.
Proposed approach TasNetworks – Supports AEMO acknowledges TasNetworks’ support of the proposed changes. No further
TasNetworks supports this proposed change. feedback was provided by Transgrid.
Transgrid – additional comment pending
Intending to provide further feedback on the NER structural amendments.

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7 Consequential amendments feedback
Consequential amendments

Issue Summary of feedback provided – Consequential amendments AEMO response

Definitions

production system N/A

Schedule 5.2 plant, Schedule N/A

5.3 plant and Schedule 5.3a
plant
Schedule 5.2 Participant, N/A
Schedule 5.3 Participant and
Schedule 5.3a Participant
synchronous condenser N/A

synchronous condenser N/A

system
active power capability Neoen – alternative proposed The term is proposed to replace ‘rated active power’ for the purposes of the
Need to careful that the definition does not become circular. Consider using the term technical requirements for connection, because equipment nameplate rating is
“maximum operating level” as defined in S5.2.5.11 rather than introduce another term. often not a helpful indication of the level at which plant can operate while meeting
all its performance standards. Individual access standards
Transgrid – changes proposed
The draft recommendation was to redefine the existing term ‘active power
• Active power capability: The definition refers to the term “bid-validation data” for capability’ as: ‘the maximum amount of active power that is permitted to be
scheduled plants. Transgrid suggests to use a term that refers to the physical status of transferred to a connection point from a production unit, generating system or
the plant, for example the number of “in-service generating units”. Bid validation data is integrated resource system (as the case may be), specified or proposed to be
also not available to plants that are in the connection process, and not yet connected. specified in a performance standard or connection agreement.
This term has been referred in multiple clauses such as S5.2.5.1, S5.2.5.10, S5.2.5.11, For a production unit that is a scheduled resource, the active power capability is
S5.2.5.13 and S5.2.5.15. Further consideration should be given to how this term is used equal to the maximum generation quantity specified in the bid validation data.‘
across various clauses; it appears that in some clauses the term is used as a reference to
the maximum amount of active power at the connection point with all generating units in- In:
service, while in other clauses it appear to refer to a level of active power below the • S5.2.5.1 it refers to the maximum amount of power permitted to be transferred
maximum active power. from the connection point, from a generating system or integrated resource
system
• S5.2.5.10 it refers to the maximum amount of power permitted to be transferred
through the connection point, from a generating system or integrated resource
system

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 Issue Summary of feedback provided – Consequential amendments AEMO response
• S5.2.5.11 in regard to droop it refers to the maximum amount of power permitted
to be transferred to the connection point, from a production unit.
• S5.2.5.13 in regard to operation of the stator it refers to the maximum amount of
power permitted to be transferred from the connection point, from a production
unit.S5.2.5.15 it refers to the maximum amount of power permitted to be
transferred through the connection point, from a generating system or integrated
resource system.(with all units in service).
As discussed in AEMO’s response on the S5.2.5.1 issues, where the term is used
in relation to a production system, AEMO will propose clarifications to ensure that,
where relevant to the technical requirement, only the capability of the in-service
(operating) production units is considered.
In relation to Transgrid’s concern regarding bid validation data, AEMO notes that a
resource can only be scheduled (and hence this part of the proposed definition
would only apply) once it has been registered and classified as such. The purpose
of this provision is that bid validation data should match the recorded active power
capability, not that the bid validation data dictates the active power capability.
Final recommendation
Considering the stakeholder feedback, AEMO will retain its update report
recommendation, subject to:
• Clarification that the maximum value in the bid validation data should reflect the
recorded active power capability in the performance standards, rather than the
bid validation data defining the active power capability.
• Including any necessary drafting adjustments in the proposed access standards
to confirm the relationship of performance capability with the number of in-
service (operating) units where relevant.
nameplate rating N/A

negotiated access standard N/A

normal voltage – definition Powerlink – Support on normal voltage deletion AEMO acknowledges Powerlink’s support of the proposed changes.
removed Powerlink generally supports the proposed changes (e.g. to rise time and deletion of normal
voltage), noting our comments on CUO above.
performance standard N/A

plant N/A

rated active power - deleted See ‘active power capability’

rated maximum demand - N/A

deleted

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 Issue Summary of feedback provided – Consequential amendments AEMO response
reactive power capability N/A

rise time Powerlink – Support on risetime The reference to external influence in the rise time definition is intended to mean
Powerlink generally supports the proposed changes (e.g. to rise time and deletion of normal external to the generating system.
voltage), noting our comments on CUO above. Final recommendation
TasNetworks – opposes change to rise time definition AEMO will clarify this in the definition to say:
TasNetworks disagrees with changing the definition of “rise time”. The proposed definition is In relation to a control system, the time taken for an output quantity to rise from
open to different interpretations on how to calculate the mean sustained change. Unless the 10% to 90% of the mean sustained change induced in that quantity by a step
definition can be modified to remove this ambiguity TasNetworks recommends the definition change of an input quantity, disregarding longer-term dynamics and influences
is left unchanged. external to the generating system, following the step change.
Transgrid – supports in principle changes to the risetime definition
Rise time: As per commentary for S5.2.5.13 above, AEMO has proposed to amend the
definition of rise time, such that longer-term dynamics and external influences following the
step change are disregarded. Transgrid agrees with this in principle noting that there is
ambiguity in what constitutes ‘longer term dynamics’. In addition, AEMO should clarify
whether an ‘external influence’ is separate to the Schedule 5.2 plant entirely or can be a
separate control system within the Schedule 5.2 plant (separate to the main control system
controlling the change output quantity). For example, the unit level voltage control response
might be subject to slower dynamics of the plant controller.
settling time ElectraNet – opposes change in error band calculation in Settling time definition AEMO recognises that the change materially affects the tolerances for settling time
Chapter 10, definition of Settling time - This change in definition has the effect of requiring when the maximum change is large relative to the sustained change.
much tighter tolerances for settling when the maximum change is large relative to the AEMO has considered this difference with the change to add a threshold to error
sustained change. It is unclear why this change is proposed. The new drafting materially band in S5.2.5.13 settling time assessment for active power, reactive power and
affects the interpretation of performance standards under s5.2.5.13 and presents a risk to voltage deviation during voltage steps. (See the section on materiality of settling
5.3.9 proposals for existing generators. time error bands under S5.2.5.13 above.)
Neoen – on settling time error band change In conjunction with the proposed changes in S5.2.5.13, which provide wider error
The proposed change appears to be halving the band for settling time. What is the benefit of bands for small changes, a more standard settling time definition can be used.
tightening this band by so much and how will it be assessed? This is typically assessed in Final recommendation
PSS/e which cannot provide this level of accuracy. The accuracy of the models (PSS/e or AEMO proposes to amend its final recommendation as follows:
PSCAD) has its limits as well – halving the band will again prolong and complicate the
S5.2.5.13 discussions without a clear benefit to network operation. In relation to a control system, the time measured from initiation of a step change
in an input quantity to the time when the magnitude of error between the output
quantity and its final settling value remains less than 10% of the sustained change
induced in that output quantity.
Note that this change needs to be made in conjunction with associated
modifications of error bands for active power, reactive power and voltage (as
described under S5.2.5.13).
short circuit ratio N/A

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 Issue Summary of feedback provided – Consequential amendments AEMO response

voltage – definition deleted Marinus Link – supports un-italicising of voltage; flags drafting errors AEMO thanks MLPL for its review of the drafting and acknowledges the oversights,
MLPL supports AEMO’s proposal to remove the definition of the term voltage on the basis which AEMO will correct in its rule change proposal.
that this term is best understood from an engineering perspective in the context where it is Final recommendation
used. Considering the stakeholder feedback, AEMO will retain its update report
MLPL notes two instances in which the word voltage has been incorrectly un-italicised when recommendation with minor modifications to retain italicisation when part of the
part of the composite defined term voltage transformer. These are in proposed amendments composite defined term voltage transformer (proposed amendments in
S5.3.3.(c)(1) and S5.3a.6(c)(1). S5.3.3.(c)(1) and S5.3a.6(c)(1)).
Technical changes

Incorporating synchronous Powerlink – Partial support; Alternative proposed See comments under S5.2.1
condensers We consider there should be discretion, as agreed by the NSP and AEMO, as to which
clauses are applicable. Please refer to comments above.
TasNetworks – Supports
TasNetworks supports this proposed change.
Transgrid – additional comment coming
Intending to provide further feedback on the consequential amendments.
Additions to information Powerlink Powerlink’s comments have been considered under the relevant clauses.
provision Final recommendation
We highlight our comments (with more detail) above, relating to:
• S5.2.5.1 – mid-point voltage: This change does not appear to be required. S5.2.5.5 – AEMO will retain its update report recommendation.
lowest / highest single phase and three phase fault level and X/R: It is not clear how a
NSP providing this information will add value to the compliance process.
• Tuning for S5.2.5.5 should be based on minimum fault level/withstand capability level. An
outage on the system with non-minimal fault level could have the worst-case X/R value,
which may significantly differ from the X/R value at the minimum fault level.
• S5.2.5.13 – lowest, highest and typical apparent system impedance: We do not consider
these appropriate for compliance assessment purposes and therefore does not support
their addition as requirements.
TasNetworks – Supports
TasNetworks supports this proposed change.

Relevant system – in relation TasNetworks – Supports Final recommendation

to small plants exempt from TasNetworks supports this proposed change. AEMO will retain its update report recommendation.
some requirements
S5.2.5.8 Protection settings Solar Turbines – Comment While AEMO notes Solar Turbines comments, review of schedule 5.1 for Network
and relationship to ride Enlarging protection setting does not necessarily reinforce system resilience, but it could Service Provider is not within the scope of this review.
through clauses rather limit generating unit lifecycle and availability.

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 Issue Summary of feedback provided – Consequential amendments AEMO response
In the document it seems there is not much emphasis in appropriate grid system design Final recommendation
optimization or protection scheme optimization in order to limit the event and protect AEMO will retain its update report recommendation.
important assets as generating units.
Some examples of possible improvements:
• Optimization on fault clearing delay times associated to contingency event;
• System optimization to reduce the occurrence of almost contemporary multiple events
(protection scheme definition), if the requirements of so many multiple events in such a
short time shall be considered credible)
TasNetworks - Supports
• TasNetworks supports the redrafting of S5.2.5.8
S5.2.5.8 Conditions for which Powerlink – Support Final recommendation
the plant may trip and Powerlink supports this proposed change. AEMO will retain its update report recommendation.
recording of conditions
TasNetworks – Supports
TasNetworks supports this proposed change.
S5.2.5.8 Network Service TasNetworks – Supports Final recommendation
Provider liability TasNetworks supports this proposed change. AEMO will retain its update report recommendation.
S5.2.5.11 Minimum operating Powerlink – Support
level Powerlink supports this proposed change.
TasNetworks – Supports
TasNetworks supports this proposed change.
S5.2.5.11 Response direction TasNetworks – Supports Final recommendation
for bidirectional units taking TasNetworks supports this proposed change. AEMO will retain its update report recommendation.
power from the system
Drafting changes

Drafting changes No specific additional feedback was received on other drafting changes

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