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Direct Testimony of Charles Simmons for Highland Citizens, Va.

Direct Testimony of Charles Simmons for Highland Citizens, regarding the application of Highland New Wind Development, LLC, to construct a facility in Highland County, Virginia – September 1, 2006

p. 8: “The principals of economic dispatch result in starting with the lowest cost units being dispatched first and proceeding to load units in order of their cost. Similarly, the higher cost units are the first units to be reduced as load requirements are decreased. The very high cost oil units would be the first units to be affected but they are presently being dispatched at very low levels. A major impact of additional wind generation would be to further reduce the operation of the gas fired plants (combustion turbines or combined cycle units) since they represent the bulk of the higher cost generation.”

p. 9: “There is very little contribution from wind generation during the critical summer peak season. Since generation as well as transmission and distribution facilities are limited in their capacity by thermal constraints, the summer peak loads are the most critical. Wind generation is generally at its lowest level during the warmest periods of the warmest days in the year.”

p. 10: “Loads are projected on a day ahead and on an hour ahead basis within the control area (PJM in this case) in order to schedule sufficient units in service to meet the expected load and to provide the necessary spinning reserve. The spinning reserve provides the margin for the units to respond to the minute-by-minute load changes as well as to absorb the impact of an unexpected loss of generation. The units respond to load changes within their pre-set bandwidth by sensing any deviations from 60 Hz frequency and automatically opening or closing control valves to maintain frequency. Bandwidths are altered by an automated system to maintain economic dispatch as loads change. The variation in wind generation would make it very difficult to incorporate any specific capacity from that source in the day ahead planning which is an essential part of maintaining a reliable system.”

p. 18: “The only way to even approximate the extent of any emission reduction would be to carry out a series of simulations using actual values with injection of various levels of wind generation to determine which units responded. You can make no rational judgment as to the extent of any emission reduction without knowing which units will be affected. The grouping of units as coal, gas or oil is far too simplistic to produce meaninghl results. The variation in heat rate between units and the variation over the load range on the same unit, the presence or absence of pollution controls and their effectiveness, the fuel characteristics and transmission constraints all will have an effect that can be determined only by knowing the units affected. As pointed out earlier, the largest plant in the AEP system was ignored in the RSG report. The 1300MW unit 3 at this plant will have scrubbers installed in 2007 with an expected 98% efficiency. The two remaining 800MW units will have scrubbers installed following completion of the 1300 MW unit. Improvements of this type are being made at many locations with huge impacts on emissions. These impacts, however, can only be considered with a unit by unit study and not by grouping by fuel type.”

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