Comments on the abovementioned subject.

Application issues

1. The process of application of an RE applicant may consider to include guarantee or

deposits in a projects that an RE applicant applying. This will avoid many RE applicant
just submitting application for purpose of securing a site then later on they will not
pursue the project due to problems with financial closure.  The guarantee or deposit will
serve as a bond to these RE applicant that they will and are committed to undertake
such projects.
2. We can also do qualification of RE Applicant to avoid ‘fly-by-night” RE applicant. This will avoid
too many RE applicant submitting intent to develop project where we could see later on that
they are not  committed to pursue it or just still waiting for their investor to financed their
project. Technical, legal and financial requirements could be a way to see if these applicant
really a qualified RE applicant.
3. Submission of Application of self RE Power Producer I assume is thru first-come-first-serve basis.
However, in the future where there will an aggressive installation of RE in the kingdom, there
might be two RE applicant that will apply for a wind or solar project in a same area or a two RE
applicant have an over-lapping area or block in the map that they submitted. There shall  be a
holding period/time frame for every RE Applicant to complete the study of the site so that a
next interested RE applicant of the same site could do his assessment in the area and could
proceed to implementation should he find it viable to him.

Operational Issues.
 
1. The proposed procedure mentioned that RE applicant may offer their surplus electricity
export for sale to the SEC network. Our SCADA system shall be able to remotely access
facilities throughout the Kingdom, and where we could access alarms and event
conditions, data collection and reporting capabilities. For example in case where there is
too much wind production in a day where the demand is at low point, we could do some
curtailments and RE Applicant shall be aware of such capability of our Control System.
2. In case of wind integration to power grids, our SCADA system shall be a turbine supplier neutral.
In the future where many RE Applicant will install wind turbine of different type and of various
PLCs, our SCADA system shall not be dedicated to any one PLC vendor so that we could be free
to provide data reporting format and analysis report irrespective of turbine type.
3. Is it possible for the Grid Impact Studies (GIS) to cover Operating Issues in integrating a
percentage of RE generation in the power system?  Operating Issues such as ramping
requirements, load following capacity, regulation capacity, over-generation issues and potential
solutions shall be considered to be studied in relation to the target percentage of renewables in
the power system.  Some integration studies concluded that 20% of renewables in the power
systems is expected to increase regulation ramping requirements by plus/minus 15 to 25
MW/min, morning ramp and regulation capacity requirements also increased, and among
others.  
4. If the GIS cold not include the above studies on Operating Issues, Does the Network Planning of
the NGSA could do studies on transmission and operational impacts of interconnecting
a percentage of renewables in the power grid. Such study will be helpful to ISO.
 Reference Draft Procedure Comments
page
Page 5 Step 1. Submission 1. The process of
of Application by application of an RE
self RE Power applicant may
Producer consider to include
guarantee or deposits
for projects/sites that
an RE applicant
applying.
Explanation
The guarantee or deposit
will serve as a bond to these
RE applicant that they will
and are committed to
undertake such projects.
This will avoid many RE
applicant just submitting
application for purpose of
securing a site then later on
they will not pursue the
project due to problems
with financial closure.

2. Technical and financial - An RE Applicant must

capabilities shall be possess technical and
included as a financial capabilities to
requirement for undertake his obligations
application. in putting up and
- Technical capabilities operating an RE project.
could be evaluated by - The qualifications will
the IPP&RE thru the avoid ‘fly-by-night” RE
track record of the applicant. This will avoid
company or expertise too many RE applicant
of the personnel submitting intent to
within the company develop project where we
- Audited Financial could see later on that
requirements, banks they are not  committed to
certifications are pursue it or just still
among documents to waiting for their investor
measure the financial to financed their project.
capacity of an RE
Applicant

Page 2 Process flow of 1. What if the IPP&RE of - RE projects requires

Application SEC receives two
“ IPP&RE receives RE applicant for the same
Applicant site? Or the area being
application applied for a wind
projects overlaps with
another on-going sites.
feasibility studies before
you decide the viability of
a site and apply it for
implementation. The
process flow mentioned a
capacity therefore, an FS
has been undertaken or
even the construction
because the process flow
indicated a grid impact
 study for connection after
endorsement by the
IPP&RE.
- It is not clear in the
process flow how an RE
applicant will able to verify
if the site he like to
explore is “cleared” or has
no other parties already
undertaking a
study/construction.