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1092 IEEE Transactions on Power Systems, Vol. 14, NO.

3, August 1999

NERC’S NEW CONTROL PERFORMANCE STAND


Nasser Jaleelit and Louis S. VanSlyckt
Priority-based Control Engineering (PCE)
Dublin, Ohio
t Senior Member, IEEE 4 Life Fellow, IEEE
Abstract: For several decades, control area performance in 11. INTERCONNECTED SYSTEM CONTROL
normal interconnected power system operation has been as- Interconnected operation requires reasonable control of
sessed by Criteria A1 and Az. On February 1, 1997, the North frequency and transmission network power flows. Fre-
American Electric &liability Council (NERC) replaced A1 quency control is assisted by an interconnection’s natural
and with control performance standards CPSl and CPSS. regulation. This regulation is provided by governor action
These criteria, or standards, assess characteristics of an area’s and load sensitivity to frequency. Both are in such direc-
“area control error”. Their purpose is to indicate whether an
tion as to oppose and halt frequency changes. This per-
area’s generation is adequately controlled to make interchange petually ongoing natural regulation (a.k.a., primary fre-
meet its schedule and interconnection frequency support obli- quency response) constantly restores a balance between
gation. After January 1998, control areas are expected to be total interconnection generation and total load plus losses.
at least 100% in compliance with CPSl and 90% with CPSZ. The repeatedly restored balance, however, is fleeting and
There will be sanctions for areas failing to meet these stan- seldom at scheduled frequency, and it is only momentarily
dards. This paper briefly describes the new control perfor- that generation in any area exactly balances the area obli-
mance standard:;, their technical foundations and the research gation. Consequently, primary control does not maintain
leading to them. a satisfactory match between the trends of area obligation
Keywords: AGC, Control Area, Control Criteria, Frequency and area generation. Matching the trends of obligation
Bias, Funnel Control,LFC, Inadvertent, Interchange,Intercon- and generation within areas is the function of secondary
nection, Priority-based Control, Time Error, Wedge Control. (centrally directed) contro1.l
I. INTRODUCTION In an interconnected system “control areas” are vested
with the responsibility of secondary control, i.e., to set
Since the 1060’s, control area performance in normal scheduled interchange (biased by the area’s frequency s u p
interconnected power system operation has been moni- port obligation) and to control generation so that the con-
tored and assessed by Criteria A1 and Az. Over the years, trol area’s boundary flow will reasonably match the area’s
however, many power system engineers have felt there was biased interchange schedule. Thus, each control area must
little correspondence between good interconnected system maneuver area generation to acceptably match its own
operation and good A1 and A2 control area performance. obligation trend. Area obligation, for this purpose, is de-
It is hoped that the new control performance standards, fined as:
CPS1 and CPS2, with their solid technical foundation, Obligation = area native scheduled
will not elicit such criticism. {load and lasses}’ {interchange}
Criterion A I specified that area control error, “ACE”,
defined in (2) and (3) below, should cross zero at least share of support for
once every ten minutes. Criterion A:! specified that ten + {interconnection frequency
minute average ACE should be less than an area specific
parameter, L d . CPSl is a limit on the average of a func-
Change in obligation is constantly occurring because of
tion. combining ACE and interconnection frequency error
changes in load and scheduled interchange (and somewhat
from schedule. CPS2 is similar to Az, but with a techni-
t o variation of frequency.) Obligation typically changes
cally defensible specification for the limit on ten minute
much faster than generation can be controlled, hence prac-
average ACE.
tical (secondary) generation control can only attempt to
match the trend of obligation. The mismatch is measured
PE-261-PWRS-0-12-1997 A paper recommended and approved by
the IEEE Power System Operations Committee of the IEEE Power by ACE, a fundamental signal for control area operation.
EngineeringSociety for publication in the IEEE Transactions on Power Its variation is due to the arbitrary nature of changes in
Systems. Manuscript submitted July 31, 1997; made available for obligation and generation.
printing December 12, 1997.
Mismatch = Generation - Obligation
= Area Control Error (ACE). (2)
The mismatch is obtained from measurements of net
control area interchange (T,) and interconnection frequen-
cy (Fa)-not from measurements of generation and load.

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1093
That is: rapidly changing obligation, as well as episodic mismatch
events (such as unexpected loss of generation.) Thus, if it
ACE Ta-Ts-lOB(Fa-Fs), (3) is not too large for too long, ACE is acceptable, provided
an area can make no accurate forecast of its future ACE
where the subscripts “a” and “s” refer to actual (mea-
trend.
sured) and scheduled (manually set) values, respectively.
When ensuing ACE averages are non-predictable, a
T, is the area’s net scheduled interchange and F, is sched-
control area is using the interconnection’s power exchange
uled frequency. The interconnection frequency error from
only on a random basis. On such basis, interconnection
schedule is A F = Fa - F,. The area’s share of support for
assistance becomes judicious and mutually beneficial for
interconnection frequency is lOBAF, where B is the area’s
all areas. When an area’s ACE is typically off-zero in the
defined frequency bias coefficient in MW per tenth Hz (a
same direction for the same hours of the day, the area has
negative number, not necessarily constant.) Changes of
a predictable ACE structure. The daily cycle of time error
scheduled interchange (except dynamic) are normally fil-
which exists in all NERC interconnections is evidence of
tered (ramped) over ten minutes so that they can be ac-
repetitious structure in ACEs. For interconnected opera-
commodated at practical rates of generation adjustment.
tion to be fair, performance standards should be sensitive
Dynamic schedules are sometimes used to “electroni-
to non-random ACE averages. This point is an important
cally transfer” load from one area to another, the second
consideration in the new performance standards.
area becoming responsible for matching the trend of the
Compared to A1 and A2, the new performance stan-
transferred load. Areas without native generation may
dards will allow larger average ACE for a few minutes,
use a dynamic interchange schedule to serve their entire
provided that sub-hourly ACE averages are maintained
load.
within reasonable bounds.
For areas with no native load, the first term in (1)
Consider average obligation over the next T minutes:
can be zero if the area has no transmission losses. The
a If T is small, less than 5 to 10 minutes, or so, change in
new performance standards are applicable to areas with-
out load or generation. All control areas, however, will average obligation is difficult to accurately predict, and
have some interconnection frequency support responsibil- very difficult, or impossible, to match with generation
ity given by a defined frequency bias coefficient B. changes.
0 As T becomes larger, change in average obligation be-
Throughout an interconnection, ACEs measure what-
ever mismatches exist in the presence of primary control. comes less difficult to predict, and more easily matched
Performance standards, or criteria, assess the overall con- by generation maneuvering.
trol process-the aggregate result of primary, AGC (au- Beyond some value of T , call it T,, average ACE should
tomatic generation control) and manual unit maneuver- be essentially unpredictable (even in sign), otherwise it in-
ing. Standards are needed to specify how closely each dicates anticipated off-schedule operation. Thus, T-min-
area should match generation with the trend of its obliga- Ute average ACE should be random for any averaging in-
tion. Through performance auditing, standards also help terval greater than T,. When this randomness is reason-
with the timely detection of metering errors and sched- ably achieved, AVG,{ACE}, for T > T,, will be reason-
ule setting mistakes. Standards should, of course, allow ably non-coincident with its counterpart AVG,{ACE} in
maximum and fairly shared benefits of interconnected o p other areas of the interconnection. (The authors believe
eration without compromise of reliability. that T, would be less than 30 minutes for most areas, de-
At a control area’s discretion, modifications of the sig- pending on an area’s load and generation characteristics.)
nal given by (3) may be used to develop a signal for control
IV. BASES FOR PERFORMANCE STANDARDS
intended to correct for past error accumulations, e.g., in-
advertent. It should be noted, however, that (3) is the Based on the foregoing observations, strategic design of
only ACE definition on which performance is to be re- performance criteria should consider that:
ported to NERC.5 Thereby, all control areas will be re- * To realize interconnection benefits, neglecting to mat-
porting performance on a common basis. ch rapid obligation changes must be permitted to some
practical extent.
111. STRATEGY FOR PERFORMANCE STANDARDS * The allowed 2’-minute average ACE should decrease
Too tight control of ACE would be impractical and as a function of T .
costly. When tolerated at a reasonable extent, ACE ex- * Area performance over 5 minutes, 20 minutes, or an
cursions allow bulk electricity suppliers to obtain mas- hour, is not as meaningful as performance over a long
sive benefits from interconnected operation. However, it sequence of 5 minute, or 20 minute, etc., intervals.
is necessary to establish operating performance standards Therefore, the new criteria have been designed to con-
for this toleration so that all parties may fairly share the sider long duration statistics of various T-minute in-
benefits of interconnected operation. tervals. NERC’s Performance Subcommittee selected
Spontaneous power exchange is highly beneficial be- 12 months as a practical choice of duration.
cause it allows the interconnection to help serve an area’s These strategies lead to the conclusion that ACE should

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1094

satisfy a decreasing function of T : obey (4), then AF will obey a function similar to (4)-
another decreasing function of T . That is:
RMS{AVC:,{ACE}} = a ( T ) , (4)
RMS{AVG,{AF}} = cp(T). (5)
where a ( T ) is the root-mean-square (RMS) of all the T
minute average ACE values over the past 12 months. The similarity between a ( T ) and v ( T )depends highly
It is shown in [2] that if ACE were a random signal, on the coincidence of ACEs in the interconnection. When
a(T) would be proportional to 1/@. Of course ACE it- AW,{ACE} is random for T > T,, cp(T) will decrease
self can not be made to meet this condition because its for T > T,. When this condition is typical for a MW
next data cycle value is far more likely to be close to the majority of areas, frequency error will have small hourly
preyent value than to be random. However, a good con- average (assuming Tc < 60 minutes and ACE magnitudes
trol algorithm can make AVG,{ACE} nearly random for do not greatly exceed their past levels.)
T T,. Moreover, this can be accomplished with far less
a:
Average frequency error (or average ACE) over On-
generation maneuvering than that of many present AGC Peak, Off-peak, any given hour of the day, or even a few
schemes. minutes, indicates a level of operational error over the
corresponding time frame. Nevertheless, frequency error
V. INADVERTENT needs to be tolerated up to some practical level to realize
Operating to zero inadvertent for an hour, or group of benefits of interconnected operation via randomly occur-
hours, is not good area performance unless there happened ring off-zero ACEs. But the longer the *timeframe, the
to be zero average frequency error for the same interval. smaller the average operational error should be. Small
In that event (and only in that event) the area managed hourly average frequency error allows a larger peak-to-
a zero average ACE for the interval. When operating to peak variation about its hourly average. This translates
zero average ACE, an area will, or will not, incur inadver- directly to an allowance of larger peak-tGpeak ACE vari-
tenl; depending on average frequency error. When an area ation about its hourly average, with accompanying re-
inciirs inadvercent while operating at zero average ACE it duction of control costs and greater benefits of intercon-
deserves to ha,ve its inadvertent account corrected while nected operation. That is, for control practice to allow
continuing to operate at zero average ACE. To be mean- the largest practical RMS{ACE}, AVG,{ACE} must be
ingful, coordinating inadvertent balances should always be appropriately bounded for larger values of T .
per formed by giving proper consideration to lAFl hourly
averages. These facts should be axiomatic for anyone as- VII. CPSl
sociated with interconnected power system operation. A limit condition on AF may be written as:
With small hourly average IAFI, inadvertent energy
accounts would become more appropriate (as an opera-
tional performance assessment), and in fact, would be-
come tightly bounded for good performing areas3 As per- where A F , is the one minute average of A F , and el is a
formance indicators, inadvertent accounts are presently target bound for the 12 month RMS of one minute average
rather meaningless because time error corrections do not interconnection frequency error (set by NERC).
separately correct for frequency error from schedule in the Mathematical relationships between frequency and in-
On-Peak and Off-peak accounting intervals. One con- terconnection ACEs show that ACE coincidence with fre-
sequence of this time error correction practice is t o fre- quency error is a measure of the non-randomness of ACE.
quently trap On-Peak and Off-peak inadvertent accounts That is, non-randomness of ACE can be measured by its
so there is little opportunity for payback. The longstand- coincidence with A F . (The “coincidence” of signal z with
ing lack of any criteria incentive to control ACE averages signal y, is AVG{z x y}.) Analyses also show that coin-
over intervals longer than ten minutes could be partly to cidence among ACEs are significant contributors to AF
blame for this situation. This subject is fully explained in magnitudes. These studies lead to basing CPSl on the
[2] by theory <andwith examples. dimensionless compliance factor:

VI. FREQUENCY CONSIDERATIONS CF1 = -{-}


1 ACE
€; -lOB 1 xAF1, (7)
Bounding average frequency error reduces unscheduled
energy exchange, enhances the benefits of interconnected
operation and helps to balance these benefits among ar-
where {s}l is the average of ACE t (-10B) over the
AGC cycles of a minute. This form was chosen so that
eas. It also enhances reliability by reducing the average CF1 is applicable t o areas using non-constant bias. For ar-
frequency error from 60 Hz. Further, controlling hourly eas using constant B, the -lOB factor need not be within
time error makes inadvertent energy metering more mean- the one minute average computation.
ingful. The ACE x AF product in (7) is instrumental in in-
Additional mathematical relationships between inter- corporating sensitivity to ACE non-randomness and its
connection ACEs and frequency error show that if ACEs coincidence with other ACEs. Using this compliance fac-

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1095
tor, CPSl is a percentage defined as: month condition to be met 90% of the time. The CPS2
standard is based on the dimensionless compliance factor:
cpsl= 100 (2 -AW={CFI}), (8) 1 -
CF2 = -IACEio 1, (10)
L 10
where the average (AVG) is taken over one month for re- -
where, ACE10 is 10-minute average ACE and
porting purposes, but is a twelve month rolling average for
compliance measure. Note that when AVG{CFl} is less
or greater than 1, CPSl is correspondingly greater or less
than 100%. An area fails compliance if CPSl is less than The number Blo is the area’s average B over the ten
100%. minute interval of assessment. The multiplier 1.65 is the
All one minute average data values are to be obtained statistical conversion factor from a 68.3% confidence limit
from topof-minute to topof-minute, and time stamped (1 standard deviation) to a 90% confidence limit. The
with this “clock minute”. Only a few numbers need to be parameter v relates the size of the area to that of the
retained hourly, or daily, monthly, etc., to compute the interconnection.
12 month average. However, NERC has required that one A derivation of v based on fair considerations for elec-
minute data be retained for possible further study and tric interconnection is given in [2]. If all areas use constant
analysis. B , then v = B/B,. Thus, if all B values are constant, (11)
Alternative to defining CF1 with one minute averaged simplifies to:
data, AGC cycle rate data might have been used. How- Llo = 1.65~10 J(10B)(1oB,). (12)
ever, it is practical to perform computations only as of-
ten as necessary to provide acceptable accuracy. One For most areas, Llo values given by ( l l ) , using NERC’s
minute averaging also has other advantages because of recommended €10 target for each of the NERC Intercon-
time stamping facility, and effacing the range of AGC cy- nections, are larger than those used in the A2 criterion.
cle rates among areas. After some study and considera- They are much larger for many areas. Appendix B, of [2],
tion, the NERC Performance Subcommittee chose the one lists these limits as well as all other control area parame-
minute rate.4 Control area processes, however, will still re- ters related to CPSl and CPS2.
quire ACE data acquisition at their typical 2 to 4 second To measure compliance with CPS2, one first computes
rates. the ratio of ten minute interval counts:
NERC Standards include rules for defining an area’s Number of intervals that CF2 > 1
frequency bias coefficient, B, which establishes an area’s R = (13)
Total number of intervals ’
share of secondary frequency support. One may note,
however, that a small IBI makes (7) more sensitive to then CPS2 is the percentage measure:
ACE magnitudes. Alternatively, via (3), a large IBI com-
CPS2 = 100 (1 - R). (14)
mits the area to more interconnection frequency support
responsibility. The interval counts in (13), (6 per hour), are over
In regard to CF1, note that under the hypothetical con- one month for reporting purposes, and over rolling twelve
dition that ACEs in all other areas add to zero, AF = month durations for compliance measure. An area fails
ACE + (-lolls), where B, is the sum of B values for all compliance if CPS2 is less than 90%.
control areas. In this event, CF1 is directly proportional It should be noted that CPS2 is insensitive to ACE non-
to ACE2. Indeed however, sensitivity of CPSl to magni- randomness or its coincidence with other ACEs. Hence,
tudes of ACE exists whether or not all other ACEs add to the chosen Llo values are appropriate only if the coinci-
zero. This fact depreciates the need for CPS2. dence among ACEs does not significantly increase.

VIII. CPS2 IX. A RECOMMENDED STANDARD

Since (7) allows areas to benefit from a large [ACE1 NERC’s function is to set performance standards, not
when ACE x AF is negative, a second performance stan- to specify control practices to meet them. Each control
dard, CPSP, is applied to ten minute average ACE. This area has the opportunity to find methods best suited to
standard is derived from an interconnection objective: its particular situation. Because CPSl considers only one
minute averages of AF and ACE, the benefits of control-
ling so that AVG,{ACE} becomes more tightly bounded
for larger values of T may not be obvious. For this reason
where AFIO is the ten minute average of AF, and €10 is a the NERC Performance Subcommittee gave serious con-
target bound for the 12 month RMS of ten minute average sideration to adapting a performance standard based on
interconnection frequency error. a compliance factor:
This standard is similar to the A2 criterion, but with
a technically defensible “ L d ” . Like A2, it is a rolling 12
CFh = -
1 ACE
E:
{ -}
-lOB h
xAFh,

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1096

where AFh and {s}h are the respective averages of


* Operating
XI. CONCLUSIONS
performance standards are necessary to
A&, and {%} over the clock hour h, and Eh is a
clock hour frequency target for the interconnection. assure reliable and fair interconnected operation
If a standard based on (15) were adopted it could re- * Average ACE should decrease as the averaging base
place CPS2, which is a simple limit on 10-minute aver- increases
age ACE that is blind to ACE coincidence. Mathemati- * Standards should relate to area performance over a
cal analysis developed in [2] strongly suggests that CPS1, statistically representative interval, e.g., 12 months
combined with a CPS based on (15), would achieve the *
Standards must recognize and be sensitive to the C+
desired interarea power flow control and interconnection incidence among ACES
frequency performance. * The new standards accomplish their design functions,
although an hourly based standard would be far less s u b
A concern of the authors is that if operating perfor- tle in stressing the benefits of controlling subhourly ACE
mance is not satisfactory under CPSl and CPS2, there
averages.
could be recommendations to reduce €1 or €10. Adoption
of a, performance standard based on (15) would be far
* A standard based on hourly energy data would be
beneficially redundant with ACE based standards. There
better in the authors’ opinion. Maneuvering generation to
fore, among other attributes, it would be valuable in pro-
comply with (15) would be far more practical than requir-
mptly detecting errors or mistakes.
ing more rapid and costly maneuvering to meet reduced
one or ten minute E targets. XII. ACKNOWLEDGEMENTS
A CPS based on (15) has an additional attribute. CFh Since 1991 the authors have been fortunate to have col-
can be directly applied to hourly energy data and thereby laborated with many power system engineers on research
provide a redundancy check on power data (AGC cycle) leading to the new performance standards and to this pa-
based performance. An infrastructure to acquire and au- per. The new standards are a result of the combined ef-
dit hourly energy data has been in place in the industry for forts of all these power system engineers.6 Most of these
decades, although the audit process needs to be improved individuals are listed in [2]. Most of them have served
and streamlined. For this reason, the authors, in [2], rec- on NERC’s Performance Subcommittee, or Control Cri-
omrnended that NERC establish a data clearing house for teria Task Force, sometime between 1991 and 1997. The
each interconnection. The clearing house functions would PCE research performed after mid-1994, was sponsored
inclxde auditing hourly MWh and frequency error data, as by NERC, and partially funded by the Electric Power
well as interchange schedules between areas. It is recom- Research Institute under contract RP3555-10. The full
mended that following any transaction change the areas report is published as [2].
party to the transaction should verify through the clear- XIII. REFERENCES
ing house that they indicate the same new interarea net [l]N. Jaleeli, L. S. VanSlyck, D. N. Ewart, L. H. Fink, and
schedule. A. G. Hoffmann, “Understanding Automatic Generation
Control”, IEEE T-PWRS,Vol. 7, No. 3, Aug. 92, pp
X. OBSERVATIONS 1106-1122.
[2] Nasser Jaleeli and Louis S. VanSlyck, Principle Investi-
0 The new performance criteria have a technically de-
gators, CONTROL PERFORMANCE STANDARDS
fensible basis developed from mathematical relations be-
AND PROCEDURES FOR INTERCONNECTED OP-
tween interconnection ACES and frequency error.
ERATION, EPRI TR-107813, April ’97.
0 The new criteria can be applied fairly to all types [3] Nathan Cohn, “Auditing Control Performance of Inter-
of areas, e.g., small areas, large areas, areas using non- connected Areas Utilizing the Components Concept and
constant B , areas having no native load, or, no native its Decomposition Techniques, Part I: Audit Technology
generation, etc. and Field Tests”, IEEE T-PWRS May 88, pp 581-603.
[4] Hoffman, S. and Illian, H., “EasternInterconnection Fre-
0 By allowing less unit maneuvering, the new criteria
quency Study”, Presented to the NERC Performance
provide opportunity to realize significant savings in fuel Subcommittee, See [6], July 1997.
costs, and unit wear and tear. [5] NERC Operating Manual
0 The new criteria are practical and not unreasonably [6] NERC Performance Subcommittee, & Control Criteria
dem.anding in data volume or processing requirements, Task Force meeting minutes 1991 to date.
etc. XIV. THE AUTHORS
Nasser Jaleeli and Louis S. VanSlyck are President and Vice
0 As with A1 and Az, area performance measured by
President, respectively, of Priority-based Control Engineering
CPSl and CPS2 is dependent on ACE data accuracy. (PCE). PCE was founded by the authors in 1994. See IEEE
However, a standby criterion is available. It could be T-PWRS, Vol. 4, No. 2, May 1989, pp 779 for the authors
based on hourly energy data rather than MW data and pictures and biographies, or [l]for biographies only.
could replace CPS2.

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1097

Discussion not been fully identified, it is suspected that CPS2 may


have to be re-examined. To date, several control areas have
Donald E. Badley (Northwest Power Pool, Portland, OR): taken advantage of this new concept in control performance
As Chairman of NERC’s Control Criteria Task Force evaluation and have indeed realized worthwhile efficiency
(CCTF) during the years of research which culminated gains. More are expected to do the same in the near future.
in the EPRI Project, NERC’s new Control Performance
Standards, and this paper, I would like t o offer a few
comments on that effort.
Drs. Jaleeli and VanSlyck are owed a debt of gratitude WARREN L. MCREYNOLDS, Bonneville Power Administration,
for their inventiveness, insight, and perseverance to accom- Vancouver, WA. The authors have worked long and hard
producing a workable control performance standard. Their efforts
plish this worthy work. The operations function of the are just now becoming reality in control areas throughout North
electric industry benefits by having standards that are reli- America. The authors are asked to comment on some of the
ability based, the marketing function benefits by standards implementation problems encountered in the Western
that are uniformly applied, and the customer benefits from Interconnection.
significant efficiency gains.
Prior t o the development of these Control Performance Beginning in October, 1997, all WSCC control areas removed
Standards (CPS1 and CPS2), the Control Performance automatic time error control from AGC. The WSCC Performance
Work Group recommended this action rather than implement on-
Criteria (A1 and A2) were established in the late 1960’s peak and off-peak accumulated time error accounting procedures
as guides for control area operation to meet interchange and new control parameters required to make time error control
schedules and share support for interconnection frequency. transparent to CPSl tracking, There were several reasons, FERC
Although, A1 and A2 were criticized as not having a does not define time error control as an ancillary service for which
uniform correspondence with good interconnection perfor- a control area could receive compensation. Also, several control
mance, given the technology of the times they reasonably areas doubted that they could implement new control parameters
accomplished their purpose. The CCTF was formed in and accounting procedures in a timely manner.
mid-1980 to address the criticisms of A1 and A2 by tech- The non-random nature of ACE averages became apparent
nical justification, modification, or replacement with new immediately, Approximately 30 manual time error corrections
criteria. The standards are the result of the analytical occur each month, most of them for slow time. A few control
studies reported in this paper, and more fully in [2]. areas have implemented control strategies that are quite similar.
The new standards are designed to evaluate control They suspend AGC action anytime their ACE and frequency error,
performance without prescribing how control is to be are the same sign. This completely ignores the tolerance band
accomplished. This allows control areas to tailor their own allowed by E{, for some acceptable level of so-called “harmful”
control.
algorithms to maintain the necessary control of area inter-
change flows and interconnection frequency while mini- The Western Interconnection’s target frequency error was
mizing non-productive adjustments of generation. The established using historical information over averaging intervals
resultant reduced maneuvering of unit output should from 2 seconds to one hour. The ten-minute averaging interval
realize considerable opportunities for generators to be was used to establish EIO. The I / fiprinciple was used to establish
operated more efficiently and with less maintenance due ~ 1 .WSCC is not meeting these targets. This tells us that q(T) is
to reduced wear and tear. not decreasing enough as T > T,. The authors recommend against
These Standards also provide a means of controlling the lowering the ~1 and ~ 1 0 . But, NERC requires that frequency error
frequency characteristic; such that, if it appears that the be no worse than historical averages. There is no Eh available to
tighten bounds for larger values of T. Do the authors have an
frequency characteristic can be relaxed without threat- alternative recommendation?
ening reliability then factors may be changed which will
allow control performance to change to the point that the We also see the liberal CPS2 criteria leading to problems.
desired frequency characteristic is achieved. Governor action that is sustained by bias response after a
As the electric utility industry heads toward a market- disturbance can lead to constrained path overloads when
based economy, it is essential that standards established contingency reserves and governor action are not uniformly
t o preserve the reliability of the system are technically responsive on both sides of constrained paths. A control area with
good control will show a beneficial CPS1, they might show a
defensible-the CPSl Standard accomplishes this goal. compliance violation for CPS2, and be required to reduce the
However, the intended natural mate to CPSl was rejected constrained path operational rating due to the support they provide
in favor of the present CPS2. The authors warned that to an area with inadequate contingency reserves.
since the target curve would not be anchored in two
places the achievement of a specific frequency performance There is more work beyond establishing the standards. Several
could no longer be guaranteed. On February 1, 1998, attempts to provide operator displays of CPS compliance have
control areas in NERC began control performance evalu- been suggested. NERC Performance Subcommittee reports of
ation under CPS. For the most part, acceptable frequency CPSl compliance sometimes exceed 200%. This suggests the
computation of CPSl is wrong. A benchmark data set is essential
performance has been achieved. However, frequency to validate a control area’s arithmetic.
performance in the Western Interconnection has deterie
rated. Although the reasons for this deterioration have Manuscript received February 25, 1998.

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s. p. Hoffman, H. F. Illian (ComEd, Lombard, IL): The of Cps2. Clearly, any issue of performance should be
authors should be recognized and commended for their thoroughly answerable by examination of acquired and
contributions to the development of the New Control retained data. Needed data should be on hand whenever
Performance Standards. We generally agree with their its review seems worthwhile. Thus, we again call out the
analysis and discussion. We have only one substantive importance of establishing an interchange data clearing
comment. house for ongoing reconciliation of schedules and inter-
The authors have suggested that CPS2 be replaced with changes to aid in the timely identification of operating
an hourly limit that could be represented by a frequency practice deficiencies or metering malfunctions when they
profile value called Eh, epsilon sub h. By setting E,,, at a value occur. This function would also provide the benchmark
less than E,, they would be able to control the shape of the data set mentioned in Mr. McReynolds last paragraph.
profile of frequency variation versus measured period length. NERC’s new transaction tagging procedure addresses the
This would force the reduction in the RMS of the frequency schedule side of the clearing house function. Equal dili-
error as the measurement period increases from one minute to gence should be given to the metered interchange side.
one liour, thus assuring that undesirable coincidence between Messrs. Hoffman and Illian provide an excellent
ACES is eliminated. We agree with this goal of having description of points we have made in the paper and in the
smaller average frequency variations as the measurement EPRI report [2],and what they say is technically accurate.
period increases. However, for the operator who is not statistically astute,
However, we do not agree that an additional standard for CPSl (with or without CPS2) might suggest coordination
frequency that nieasures the hourly variation is necessary at of control with interconnection frequency, and might not
this time. The reason for this can be seen if one considers the suggest controlling sub-hourly ACE averages. The first
nature of the measurements. The one-minute measures used could be counterproductive while the second would be a
for CPS1 include the RMS values of the coincident variation missed opportunity.
for all periods greater than one-minute, including the RMS An hourly CPS, (call it CPSh), based on an Eh objective,
values for the hourly measure. Since the hourly measure is sends a clear message that avoids both these subtleties.
included within the one-minute measure, anytime control All this being true, there is a still more significant benefit
alternatives are considered for meeting the one-minute limit, in establishing CPSh. It can be defined in terms of energy
those alternatives will include both the reduction of the and time error data (as described in [2]), thereby providing
variation for periods between one-minute and one-hour and an auditing check on power and frequency data. All these
the reduction of the variation for periods greater than one- benefits would be secured by establishing CPSh and the
hour. Our expectation is that the economic cost of reducing clearing house function. In regard to the historical eh data
the variations for periods greater than one-hour will be needed for a CPSh target-it should be directly obtainable
significantly less than the economic cost of reducing from records of hourly time error.
variations for periods between one-minute and one-hour. Mr. McReynolds notes that the WSCC abandoned
Therefore, the wedge shape that the authors have described as automatic time error control in October 1997 for prac-
being desirable will occur naturally as the result of the tical reasons. To continue would have necessitated new
economic decisions that will be made with respect to the infrastructure development. The WSCC has needed to
control actions implemented. If the economic drivers invoke several manual time error corrections in the past
assoc iated with control cause the appropriate characteristic, few months. Time error is a direct indication of non-
there will be no need for the additional measure. random ACE averages and the coincidence of ACES.
If one takes the view that less is usually better, then the CPSl is designed to be sensitive to such control defi-
prudent approach would be to wait and see if the economics ciency and reasonably meeting CPSl by most areas will
associated with control will achieve the goal without reasonably achieve €1, .the targeted value of R M S { A F } .
implementing an additional measure within the Control This achievement, however, does not limit the integral of
Performance Standard: AF, and hence, long-term accumulations of time error
Manuscript received June 29, 1998. are unbounded by CPSl. Indeed no combination of
CPS1, CPS2 and/or CPSh can force the integral of A F
to converge. A practical method t o establish such an
Nasser Jaleeli and Louis S. VanSlyck: We would first like objective is described in Section 4 of [2].
to thank all the discussers for their comments. During the Inadvertent accounts are only meaningful if accumula-
years we worked with the NERC committees on this devel- tions of long-term On-Peak and Off-peak time errors are
opment they were all active participants in the research individually limited. Moreover, as accurate and timely
effor::. We particularly thank Mr. Badley who adminis interchange accounting is crucial to the business process,
tered the work so effectively as chairman of the CCTF. reconciled energy and time error data should be considered
Mr. Badley mentions likely benefits of the new stan- as the basis for judging not only the accuracy of power and
dards in the marketing function. Indeed, Messrs. Illian frequency data but the quality of areas’ performance as
and Hoffman have published a method for this in [7] and well. The EPRI report [2] suggests that only those areas
[8]. Mr. Badley also mentioned deterioration of WSCC causing imbalance should be responsible for its correction.
frequency performance as a possible call for re-examination These business objectives would require little new infras-

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tructure, only a strengthening of what exists-namely the and the coincidence of ACES. Our recommendation is to
clearing house function and a suitable control criterion like implement the suggested CPSh.
that presented on page 7-3 of 121. Mr. McReynolds worries about a scenario where there
Mr. McReynolds mentions a stopgap practice of is a constrained flow path between a region with good
suspending AGC action when the correction of ACE would control taking advantage of the “liberal” limits of CPSl
worsen frequency (i.e., when ACE x AF is negative). This and CPS2 and a region with inadequate contingency
will be effective only if the AGC action is realized before reserves. Where a flow path is so weak as to be endangered
AF changes sign. Although not recommended, implemen- by normal condition ACE excursions the path must be
tation of this practice may be acceptable as a temporary severely endangered by disturbance possibilities. It seems
scheme. As future improvements are made, however, the to the authors that such a condition should be addressed
objective should be to control with the largest RMS{ACE} by shoring up the network rather than tightening bounds
that meets NERC CPS Standards (while maintaining on performance standards.
transmission flows within reliability constraints, whenever
they are more stringent). This concept is described in [2] REFERENCES
as priority-based control. [7]Illian, Howard F., Hoffman, Stephen P., “Real Energy
Mr. McReynolds notes that p(T) is not decreasing Interconnected Operations Services”, Proceedings of
satisfactorily as T increases. As noted in the paper, the American Power Conference, April 1998, Vol. 60-11,
RMS{AVGT{X)}only decreases as 1/@ if x is a random Pages 1070-1085.
signal. Clearly, the result that p(T) is not decreasing [S] Illian, Howard F., Hoffman, Stephen P., “Enabling
enough is directly related to non-random ACE averages Market Managed Reliability”, ibid, Pages 1089-1097.

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