Memorandum

Date: September 13th, 2017

To: ACERA A.G.

Subject: Preliminary Wind Energy Industry Impact Statement - Proposed Update to Chilean Standard NCh2369

SUMMARY
The public consultation period associated with a proposed update to the Chilean seismic design standard for
industrial installations (NCh2369) is expected to begin soon through the Instituto Nacional de Normalizacion
(INN). The proposed update to NCh2369 includes a new subsection applicable to seismic design and
verification of Wind Farms (Parques Eólicos). The subsection would impose numerous new design
requirements on wind turbines that extend far beyond current standard wind energy industry practice in high-
seismic regions. The combination of several of these proposed requirements would result in a chilling effect to
future utility-scale wind energy development, permitting and financing in Chile due to arguably
overconservative and/or unnecessarily restrictive technical and commercial burdens imposed on turbine
equipment manufacturers and developers.

Active participation from ACERA A.G. and other Chilean wind industry stakeholders during the upcoming public
consultation phase will be required to advise and advocate for reasonable modifications to some proposed
design provisions of NCh2369 in order to mitigate detrimental impacts to the national wind industry. This can
be accomplished while still assuring safe and robust turbine designs that align with Chile’s legacy of robust and
forward-thinking building code requirements.

BACKGROUND
The Chilean Instituto de la Construcción, under a collaboration agreement with the Chilean Ministerio de
Vivienda y Urbanismo (MINVU), convened a Technical Committee to develop the document, “Anteproyecto de
Norma: Actualización de la NCh2369 - Diseño Sísmico de Estructuras e Instalaciones Industriales.” It is
anticipated that the document will soon be submitted for review and approval to the Instituto Nacional de
Normalizacion (INN). The requisite public consultation phase is thus expected to begin soon as well.

The current proposed update to NCh2369 includes a new chapter entitled, “Sistemas de Generación y
Transmisión de Energía Eléctrica,” as well as a new subsection dedicated to Wind Farms (Parques Eólicos) that
includes many specific provisions applicable to the design of Wind Turbines (Aerogeneradores). Many of these
design provisions describe requirements that extend far beyond standard wind energy industry practice, even
in high-seismic hazard regions of nations with established wind infrastructure. Numerous provisions appear to
reflect compounded conservative approaches and/or unnecessarily restrictive requirements that will add cost,
time and uncertainty to future wind development projects in Chile.

Vestas-American Wind Technology, Inc. 1417 NW Everett St., Portland, OR 97209, USA
Tel: +1 503 327 2000, Fax: +1 503 327 2001, vestas-americas@vestas.com, www.vestas.com
CURRENT SEISMIC DESIGN PRACTICE FOR WIND TURBINES IN CHILE

There is currently no officially sanctioned seismic design standard explicitly applicable to wind turbines in Chile.

• General consensus from most local engineering practitioners in Chile is that Endesa ETG 1.015 is the
appropriate contemporary wind turbine design reference considering that Chilean Norma Tecnica de
seguridad y calidad de servicio (NTSyCS, Jan. 2016) indicates that ETG 1.015 should be applied to
seismic design of power generation facilities when no current national standard exists.

• Currently active Norma Chilena Oficial NCh2369.Of2003 is occasionally cited by wind industry
stakeholders as a relevant design standard. Although the standard explicitly excludes “electric power
plants” from scope of application, this concept is often associated with large-scale power generation
facilities required for post-disaster operation. Standard industry practice and most governing
jurisdictions around the globe distinguish wind turbines from such post-disaster facilities.

It is important to note that current standard wind industry practice both in Chile and around the globe is to
assess the wind turbine support structure (tower and foundation) for seismic loads, consistent with the scope
of typical national building/seismic design codes. Seismic design verification of mechanical components and
machinery (e.g. wind turbine rotor and nacelle) are typically excluded from the scope of most national building
codes, including those in Japan, Mexico and the United States.

PROPOSED NCh2369 – KEY ATTRIBUTES OF CONCERN TO THE CHILEAN WIND INDUSTRY

The proposed update to NCh2369 emphasizes wind turbine design requirements consistent with “continuity of
operation,” rather than typical building code objectives of “life safety” and “collapse prevention.” This
attribute not only corresponds to more severe design criteria, but it invokes the unprecedented application of
conservative seismic design and verification requirements to all components of the wind turbine, including
those considered mechanical or machinery.

One consequence of this philosophy as applied to wind turbines would be the elimination the industry-
standard approach of evaluating risk associated with hypothetical loss of replaceable components in the
context of commercial insurance. Instead, the requirement that all wind turbine component designs must
comply with stringent seismic criteria will increase the likelihood that standardized components designed by
international turbine manufacturers and certified in accordance with international wind standard IEC 61400-1
might not comply with local Chilean seismic requirements. Unlike tower and foundation support structure
designs, which can often be customized for local site seismic conditions and requirements, designs of other
turbine components are typically standardized and fixed. This is generally an inflexible manufacturing and
logistics feature of turbine development that has contributed to substantial reductions in the overall cost of
wind energy in recent years. Mandatory compliance of all turbine components with unusually stringent and
idiosyncratic local seismic requirements will not lead to more reliable designs. Instead, it will lead to less
manufacturer competition in the marketplace and increased cost of energy.

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Other specific examples of proposed NCh2369 seismic provisions applicable to wind turbines that will add
design cost and uncertainty:

• 25% increase in maximum effective design soil accelerations over Endesa ETG 1.015 for the same
Group B structural classification

• An expanded definition of operational loads (beyond those of industry-standard design reference IEC
61400-1) expected to occur simultaneously with earthquake event. This can add up to 30% to the
results of the associated seismic load combination.

• Partial load factors of up to 1.2 on operational loads assumed to occur simultaneously with
earthquake event. Industry-standard convention (IEC 61400-1) is partial load factor = 1.0. This
corresponds to another 20% increase in load for operational seismic load case.

• An explicit requirement to combine concurrent operational turbine loads and earthquake loads with
full 100% absolute sum. Industry-standard convention recognizes extremely high improbability that
peak load responses from operation and strong ground motions occur at exactly the same time and in
the same direction. Accordingly, standard published convention is to combine these load components
with either square-root-sum-of-squares (SRSS) or a 0.75 factor applied to the sum.

• Introduction of a conservative combination of orthogonal earthquake load components unnecessary

for a regular and symmetric tubular steel tower cross section increases seismic loads on towers and
foundations by 30%

• Prescriptive requirements that mandate the use of frequency-domain modal analysis for seismic
assessment of entire turbine, with significant restrictions imposed on use of time-history simulations
commonly employed by utility-scale wind turbine manufacturers

Finally, proposed NCh2369 requires local “Specialist Professional” review and approval of seismic design
conditions, assessment methodologies and overall compliance conclusions for all wind farm projects in Chile.
While this is not unprecedented, as similar requirements apply to several other national wind markets, the
wind industry must be prepared to incorporate this new cost and risk into the Chilean wind farm development
process.

CONCLUSION
In order to assure the successful future development of the wind energy industry in Chile, it is essential that
ACERA and other wind industry stakeholders participate in the upcoming INN public consultation for the
proposed NCh2369 seismic design standard in order to advise on realistic wind turbine design expectations
and to best align standard wind industry practices with the unique seismic design concerns of Chile.

Regards,

Trevor Taylor, PE (Oregon & Washington)

Senior Specialist – Global Seismic and Structural Code Compliance
Vestas Wind Systems A/S
trtay@vestas.com

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