408

IEEE TRANSACTIONS ON POWER SYSTEMS, VOL. 18, NO. 1, FEBRUARY 2003

Discussion of: Statistical and Dynamic Analysis of Generation Control Performance Standards1
Robert Blohm

Robert Blohm [economist]: The paper is a deep contribution to organizing the concepts in control performance, analytically comparing the CPS1, CPS2, and MAC standards in scope and effectiveness, and testing the CPS1 and ACE standards for primary and secondary control effectiveness in a realistic simulation, and for dependence of the comparative effectivenesses on deviation of an areas response from the areas obligation. CPS2 is found to be no different than ACE , and therefore, not technically superior to ACE the way CPS1 is (because CPS2 does not incorporate covariance). CF1 compliance is proven to make standard deviation of ACE better than the reference standard. CF1 and ACE are both found able to evaluate secondary control well, while one circumstance is found where ACE does not evaluate primary control. However, the basic concepts of the paper are obscured because presented from the implicit perspective of the bundled integrated utility beginning with the following of four hidden assumptions

the control decomposition work of the late Nathan Cohn [1], but with any noncompliance of response A f with bias obligation BA f 0 removed. But the minus sign in (1) makes RA 0UA d f d f 0UA BA 0 A f . Likewise, RA is not exactly ACEA . Because of the sign reversal in (1), RA df 0ACEA BA 0 A f . This definition is never explicitly stated in the paper but is exactly what occurs in (41) and (42). Equation (40) [KP KA PA KB PB ] is crucial and fundamental here but is stated only much later, on page 480. Equation (40) extracts capacity P from bias B and from responsiveness  in order to identify the capacity-unweighted frequency bias K and the capacity-unweighted responsiveness [frequency-response characteristic] KA as control variables. Equation (40) incorporates the deepest, and third, unstated assumption of the paper

+(

)1

1 1 1 = +

= +(

1 = )1

The interconnection always just meets bias obligation:

(III)

Loads mismatch or mis-schedule; and generation corrects the mismatch; not vice-versa:

(I)

From this follows the explicit part of the papers title: Generation control of [the implicit part:] load behavior, in other words: frequency control of load by generation. While such inexplicit asymmetry reduces the papers clarity, the results in the paper do not require such asymmetry, which is weakened by price-mediated functional unbundling. Indeed, the asymmetry gets expressed by a minus sign in equation (1), page 476, which, with equation (2), drives the paper. Given that KP 0 B is assumed, as stated only much later on page 479, the minus sign assigns load mismatch a positive polarity if load is overscheduled and, so, the mismatch moves frequency in the same positive direction; the minus sign assigns load mismatch a negative polarity if load is underscheduled and the mismatch moves frequency in the same negative direction. This suggests a deeper hidden asymmetry, namely that

= 10

Overscheduled load is\better" (economically?) than underscheduled load:

(II)

These hidden assumptions make the exact relationship between the papers fundamental behavioral variable RA and either scheduling error UA or ACEA , and between PT and tieline error TA , confusing in the absence of explicit definitions for RA and PT . The definitions are only implicit in (2). The paper calls RA in (1) and (2) real control error. This is what I 0 would want to call net scheduling error UA f. d f UA 0 BA 0A This is scheduling error UA , or what is called primary inadvertent in

)1

Manuscript received May 4, 2002; revised November 13, 2001. R. Blohm is on the Joint Inadvertent Interchange Taskforce, North American Electric Reliability Council, Princeton, NJ 08540-5731 USA (e-mail: rb112@columbia.edu). Digital Object Identifier 10.1109/TPWRS.2002.807056
1T.

In other words, interconnection  B always. That is, 0KP is both ten times aggregate bias B of the interconnection and ten times aggregate frequency responsiveness  of the interconnection. Accordingly, definitions (41) and (42) of ACEA and ACEB , respectively, state that 0K is the same capacity-unweighted frequency bias for everyone, making 0KPA ten times area As bias BA , and 0KA PA ten times area As actual frequency response A . Assuming (40), equation (2) is equivalent to setting deviation of interchange to be PT df 0 RA 0 KA PA f UA 0 KPA f , which we get by substituting (1) for RB in (2). 0KA PA f is what Nate Cohn [1] defined as secondary inadvertent and is defined as response (determined by speed droop or speed regulation) scheduled in order to meet the requirement by the ACE equation that you offset KPA f in addition to your own deviation of interchange PT , in other words, that you offset your own scheduling error UA . This makes the definition of ACEA PT KPA f 0 RA 0 KA PA f KPA f UA and, therefore, by (40) Ui KP f U , or aggregate scheduling ACE A; B; ... error. Tieline error TA  PT is determined by how the interconnection response 0KP f to scheduling error U is allocated among the control areas. While the paper allows for individual control area discretion in that allocation, especially in the concluding experimental section V of the paper (pages 480481), (40) along with (41) and (42), assume that generators in aggregate are ever compliant, unlike loads, and will always in aggregate schedule response as required. The challenge in a market where generators can no longer be assumed to be any more compliant in aggregate than individually is to create proper definition and price signaling to ensure that Ki Pi KP 0 0B holds, as may not currently be A; B; ... the case in the Texas ERCOT interconnection. The very definition of RA suggests that CPS1 should be supplemented by a substandard addressing getting BA 0 A f near enough to zero, so that CPS1 is not allowing secondary control to make up for lapses in primary control and, therefore, effectively controlling only secondary response. Already (1) and (2) each assumes (40) and the definition of KP , stated much later in the paper. Postponed statement or nonstatement of assumptions occurs two more times while one of those times, also an assumption is stated but not used. To derive (4), you need (40). Equation (44) is impossible to derive without the assumption stated nowhere in the paper that

1 =

1 =

1 + =

1 1

1 = 1 =

= 1

1 1 =

)1

Sasaki and K. Enomoto, Dynamic analysis of generation control performance standards, IEEE Trans. Power Syst., vol. 17, pp. 806-811, Aug. 2002.

2 R and 1 2 R are proportional to each other 1 (IV) in the same ratio as capacity P B =2P A A:

0885-8950/03$17.00 2003 IEEE

IEEE TRANSACTIONS ON POWER SYSTEMS, VOL. 18, NO. 1, FEBRUARY 2003

409

Such a strict relation between average size of control error and capacity is based on normal distribution of short-cycle load fluctuations but may not hold in all interconnected control areas. Finally, the condition mentioned that the interconnections frequency response is 10% MW/Hz seems nowhere used in the proof. There seems to be an equation error but it is minor. The right-hand side of mapping (5) and (6) should be multiplied by the absolute value =j hj KP where the Jacobian is the of the Jacobian jJ j determinant of the inverse h01 of matrix h expressed in (4). This affects only the scale of the bivariate normal distribution and has no impact on the analytic results. Thanks to the transformation of coordinates by (4), three kinds of share are interrelated in Fig. 4: Bias share [or load share (when response is the same across areas)] and variability share. There is bias share greater or less than 0, and there is bias share related to variability share, with a tradeoff between variability share and bias share. In other words, variability share above bias share is bad and happens when bias share is greater than 0. Variability share at bias share means random, no correlation, but it would be nice to derive that conclusion mathematically, maybe from the fact that, in area coordinates, bias share is 0. Two typos are inconvenient. The diagonal zero-mean line should intercept the origin in the middle drawing of Fig. 3, and the fifth line of the adjacent column on page 477 should refer to Fig. 4 instead of Fig. 1. For clarity, the figures should label whose performance and whose PT is being depicted. In Fig. 4 it is area As, whereupon we can derive that 0 PT is area Bs deviation of interchange or tie-line error. Figure 5 should accordingly be labeled as depicting the performance of the rest of Western Japan, while Kansai Electrics deviation of interchange is 0 PT . In Figures 10 and 11, the roles are switched: area A is Kansai, while area B is the rest of Western Japan, and the figures should be labeled as depicting area As performance. Furthermore, the term interconnection should be used instead of whole area. For clarity, 1f "1 in Figures 10 and 11 should be rewritten as  f1 "1 , noting that this "1 is calculated during the three hours of the simulation and used for calculating CF1. The choice of normalizing denominator in (14) is not explained. It would be to keep MAC within a good enough range of variability. A denominator seems to have been chosen that normalizes the integral by the maximum possible value expressed by the root of the product of sums of squares. A product of sums of squares is always greater than a sum of products of squares

= 1 det =

(1 ) =

( )

(a2 + b2 )(c2 + d2 ) > a2 c2 + b2 d2 a2 d2 + b2 c2 > 0:

It is not mentioned that MACs sum to 0 across areas since PT and MAC of the interconnection is the sum A!; B !; ... of products, each one equal to zero. At one point in the paper it states that CF1 is equivalent to MAC and they can evaluate the effects of correlation between ACEs. But they are equivalent only in that sense, for right after (18) it is specified that only when there is no correlation between the ACEs, the evaluation by MAC becomes the same as the evaluation by the standard deviation of ACE. However, as there is no reference value to evaluate a generation control in MAC, the evaluation by MAC becomes a relative one between control areas. So CF1 is not equivalent to MAC. Economically speaking, MAC is a percentage allocation mechanism but does not evaluate the amount of what is allocated. It is therefore similar in concept to the frequency-control contribution I have helped develop on NERCs Joint Inadvertent Interchange Taskforce to allocate to each control areas inadvertent interchange whatever is determined

1 =0

to be the value of that inadvertents contribution to helping or hurting frequency. The amount of aggregate scheduling error or ACE determines the price of inadvertent, and that price gets discovered by encouraging trading of CF1 rights the way pollution rights are traded, provided there is a CF1 penalty set high enough to make it worthwhile to avoid the penalty by trading. In that way, CF1 winds up making FCC an absolute, not just relative, standard based on a unit of value. The papers conclusion that ACE can evaluate secondary control results from ACE s getting worse when area A stops using secondary control, from case 4 to case 6 or from case 5 to case 6 in Fig. 11. Similarly, ACE gets worse from case 6 to case 5, or from case 4 to case 5, when area B stops using secondary control. But the conclusion that ACE cannot evaluate primary control is supported by the single counterexample that ACE does not get worse when area A cuts primary control in half from case 2 to case 1 in Fig. 10, although ACE does get worse when area A cuts primary control enough, to a fifth from case 2 to case 3, or to two fifths from case 1 to case 3. Moreover, no such counterexample exists for ACE which deteriorates when area B reduces primary control from case 3 to case 1, from case 3 to case 2, and from case 1 to case 2. Note that it is deviation of actual governor responsiveness 0KA PA from bias 0KPA , coordinated so as to keep interconnection bias and interconnection responsiveness the same ( 0KP ), that is being performed here. Uncoordinated change, such that the entire interconnection deviates from its obligation to be 0KP responsive is not explored but is very interesting. What the results do show is that, provided the interconnections response does not deviate from its obligation, correlation between ACEs of different control areas occurs once a control areas response differs from its obligation and, when that happens, control measures such as CPS1, MAC, and ACE are differentiated in their effectiveness. A shortcoming that the ERCOT interconnections recent failure of CPS1 has suggested that those measures allow for rectifying the deviation by resorting to secondary control only, and do not therefore directly address the primary control shortfall as a shortfall of primary control. Does the perverse primary control result have anything to do with the smaller size of area A, to the extent that area As (reduction in) response needs to have a big enough impact on the system to deteriorate ACE enough, and that primary (frequency) response is response to a share of the entire systems scheduling error, while secondary response is reversal of the areas own scheduling error which it directly increases 1-for-1 by failing to respond? If a bunch of smaller areas have lots of error, they can have a bigger effect in secondary control of their own error than in primary response to system error, and vice versa for the bigger, better-behaved control area. A bunch of smaller control areas with lots of error can have a disproportionate effect in secondary control and thereby in deviation of interchange because their amount of primary control through interchange is greater than secondary only on condition that their total amount of schedule mismatch is less than their share of (primary) obligation. The paper is a very carefully crafted piece of work.

REFERENCES
[1] Nathan Cohn, Decomposition of the Time Deviation and Inadvertent Interchange on Interconnected Systems, Part I: Identification, Separation and Measurement of Components, IEEE Trans. Power Apparat. Syst., vol. PAS-101, pp. 11521169, May 1982.