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METU

Capacity Market

Capacity Market
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 1

METU

Capacity Market
Operating Reserves

Main Duty of the System Operator


Main duty of the system operator is to keep operating the system always in normal and secure operating state by maintaining supplydemand balance

Basic principle for maintaining supplydemand balance: The system operator must always have a sufficient amount of operating reserve against sudden unexpected contingencies

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 2

METU

Capacity Market
Generation System: Operating reserve in terms of demand;

Supply-Demand Balance and Operating Reserves


Operating reserve is measured in terms of percentage of the overall generating capacity in the system Minimum Limits for Operating Reserve: In Planning: In Operation: 10-30 10 % %
Units in service 300 MW 100 MW Operating reserve

300 MW
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 3

METU

Capacity Market
Types of Operating Reserves
Generation System: Operating reserve in terms of demand

In principle operating reserves may be classified in two groups; Hot operating reserves, those plants, which is kept ready to put in service immediately, Cold operating reserves, those plants, which is kept ready, but can be put in service within 10-60 minutes, following the order Keeping a plant as hot or cold operating reserve is something that incurs a cost to the party who benefits from this service

Units in service 300 MW 100 MW Operating reserve

300 MW

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 4

METU

Capacity Market
Operating Reserve Markets
Units in service 3 x 100 MW 2 x 100 MW Operating reserves

Ordering of Operating Reserves Plants in Operating Reserve Market are ordered with respect to their; Full or partial capacity kept in operating reserve state, Quickness of response: time duration needed for the plant to get into service following the order (fuel type and being in hot or cold states determines quickness), Sureness in availability: Certainity in availability (price will depend upon this certainity)
300 MW

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 5

METU

Capacity Market
Cost of Operation Reserves

Terms in Operating Reserve Cost


In principle, cost of an operating reserve is the same as capacity cost, which comprises of two components; Fixed Capacity Cost, Variable Capacity Cost Varible Capacity Cost here, however, unlike the one that has been described earlier, does not include the fuel cost,

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 6

METU

Capacity Market
Cost of Operation Reserves

Terms in Operating Reserve Cost


In principle, cost of an operating reserve is the same as capacity cost, which comprises of two components; Fixed Capacity Cost, Variable Capacity Cost Varible Capacity Cost here, however, does not include the fuel cost

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 7

METU

Capacity Market
Cost of Operation Reserves
Variable Capacity Cost - VCC

Variable Capacity Cost - VCC of a plant is the same as the Operation and Maintenance Cost, i.e. VCC = OPC + MC = OMC where, VCC is the Variable Capacity Cost, OPC is the Operation Cost, OMC is the total Operation and maintenance Cost, MC is the Maintenance Cost Like Fixed Capacity Cost, VCC is measured in terms of; $ / MWh or $ / kWy
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 8

METU

Capacity Market
Cost of Operation Reserves Average Capacity Cost

Fixed Capacity Cost - FCC and Variable Capacity Cost - VCC of a plant may be combined to yield the average capacity cost of a plant;

ACK = FCC + VCC . c or y = b + ax


where, ACk is the average capacity cost of the plant in $ / MWh or in $ / kWy, FCC is the Fixed Capacity Cost, VCC is the Variable Capacity Cost, cf is the combination coefficient, called the capacity factor

Note that Fuel Cost term -FUC does not exist in VCC
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 9

METU

Capacity Market

The Effect of Operating Reserves on Competition


Minimum Operating Reserve Requirement In principle, a competitive market requires an environment, where the available capacity exceeds demand It is widely accepted practice that when the available capacity exceeds demand by only 10 %, a competitive market will be established and it will be possible to keep the price of the most expensive generation at 100 USD / MW, i.e. 10 Cents / kWh level In that respect, Operating Reserves may be regarded as available excess capacity
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 10

METU

Capacity Market
The Effect of Operating Reserves on Price

Minimum Operating Reserve Requirement


In principle, a competitive market requires an environment, where the available capacity exceeds demand so that the customer has a chance for choice It is widely accepted practice that when the available capacity exceeds demand by only 10 %, a competitive market will be established and it will be possible to keep the prices of the most expensive generations at 100 USD / MW, i.e. 10 Cents / kWh level In that respect, Operating Reserves may be regarded as available excess capacity

Karakaya HPP, 188 MW

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 11

METU

Capacity Market
The Effect of Operating Reserves on Price
Price Spikes
Peak level Total Demand (MW)

As consumption increases with respect to daily load curve, supply becomes tighter System operator then finds himself in a difficult situation that the operating reserves run short and he can no longer maintain 10 % operating reserves The system operator then starts offering higher prices for both the committed plants and reserves, driving up the prices In other words, prices follow a trajectory (not exactly but) similar to the daily loading curve

Winter

Summer

Off-Peak level

Time (Hours)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 12

METU

Capacity Market
The Effect of Operating Reserves on Price
Price Spikes
Peak level Power Demand (MW)

The last alternative is rather severe, and may induce some legal consequences against the customer (utility) Hence the utility must compare the legal consequences and penalties to be arised and the price of electricity Before deciding on load shedding
Price paid by the system operator to operating reserves committed real-time sets an upper limit on price in the market High prices in Forward Agreements (Hedging) induce investment

Winter

Summer

Off-Peak level

Time (Hours)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 13

METU

Capacity Market
The Effect of Operating Reserves on Price
Price Spikes
Peak level Power Demand (MW)

In case the operating reserves run short and prices drive up, customers (utilities) confront with three alternatives; Letting the system operator purchase power for them in real-time in terms of real-time spot prices, Making Forward Agreements (Hedging) with suppliers and purchase power from those suppliers, in order not to be influenced by price spikes, Shedding the load within the period the price is high

Winter

Summer

Off-Peak level

Time (Hours)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 14

METU

Capacity Market
Self-Provision of Operating Reserves
Trakya Natural Gas Plant 477 MW

What is Self-Provision ? Self-provision is condition of providing both energy and operating reserve services by the same plant There are two types of operating reserves in terms of their sources; Independent plants exclusively kept, committed and operated as operating reserves. In this case, commercial operating reserve service is provided only by these plants, Self-providing plants with a certain percantage of their capacity kept and sold as operating reserve to system operator (not to costumers !).
Each self-providing plant participates in operating reserve service by its own percentage

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 15

METU

Capacity Market
The need for Self-Provision
Kdz. Ereli Natural Gas Plant

Why self-provision is preferred ? Plants may not be fully convinced that a commercial operating reserve service will work properly, when needed, They may not be satisfied with the some aspects of the service, such as; quality, price, quickness and readiness, Plants may be in difficulty in selling some part of their production within some operating periods, so that they may prefer to offer the capacity corresponding to this part as operating reserve

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 16

METU

Capacity Market
A Simple Criterion for Self-Provision
Criterion Kemerky
P = 630 MW, Capacity = 2392 GWh (1999), 2922 GWh (2000)

Self provision is to be preferred, when; There is a surplus capacity that can be sold in terms of either; a) energy or b) capacity

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 17

METU

Capacity Market
A Simple Criterion for Self-Provision
Criterion

Self provision is to be preferred, when;


Profite < Profitc where, Profite =Pe (Pc + Penergy + PO&M ) Profitc =Pnl (Pc + PO&M ) or Pe (Pc + Penergy + PO&M ) < Pnl (Pc + PO&M ) or Pe Penergy < Pnl where, Profite and Profitc are profits to be earned by electricity an capacity trading, Pe, Pc, Penergy, Po&m, Pnl, are electricity, capacity, energy, operating and maintenance, and the no-load operating prices, respectively
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 18

METU

Capacity Market
Pricing of Operating Reserves

Factors Determining Price of Operating Reserve Factors determining price of operating reserve service are; Capacity factor (percentage of rated power x duration of allocation), Quickness of response, Certainity of availability, Certainity of order, Early ordering, Start-stop expenditures of the plant Units of operating reserve service is the same as that of energy, i.e. kWh or MWh, as it depends both on capacity allocated (MW) and duration (h)
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 19

METU

Capacity Market
Allocation Factor Defininiton

Allocation Factor is a measure of the percentage of capacity service allocated to customer Allocation Factor is expressed as; = ( P / Pr ) * ( t / T ) (unitless)
where, is the allocation factor, P is the power allocated to customer, Pr is the total rated power of the plant, t is the total duration of service (hours), T is the overall duration of the availability of plant (hours)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 20

METU

Capacity Market
Capacity Factor Defininiton
4000

Capacity Factor is the ratio of the total energy supplied to the total capacity allocated Capacity Factor may be expressed as;
c = total energy supplied/total capacity allocated(a.f. x rated power) = P(t) dt / (a.f. x rated power) = Area under the curve / overall rectangular area = Area under the curve / 4000 x 24 where, energy supplied is the total energy supplied during the allocated service period, total capacity allocated = a.f.xrated power

Total Demand P(t) (MW)

3500

3000

2500

2000

1500

1000

Energy supplied

500 0 0 2 4 6 8 10 12 14 16 18 20 22 24

Time (Hours)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 21

METU

Capacity Market
Capacity Factor
Total Demand P(t) (MW)

Defininiton
Capacity factor is not a concern for the producer at all. The producer simply allocates the ordered and committed portion of the plant and does not concern whether this portion is properly utilized by the consumer or not. Proper utilization of this portion is merely a problem of the consumer. In other words, capacity factor is a problem of the customer, allocation factor is a problem of the supplier.

4000

3500

3000

2500

2000

1500

1000

Energy supplied

500

0 0 2 4 6 8 10 12 14 16 18 20 22 24

Time (Hours)
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 22

METU

Capacity Market
Capacity Factor Example
4000

Capacity Factor of the load shown on the right hand side may be expressed as;
c = total energy supplied / total capacity allocated(a.f. x rated power) = P(t) dt / (a.f. x rated power) = Area under the curve / overall rectangular area = Area under the curve / 4000 x 24 = 65 000 MWh / 96 000 MWh = 0.94

Total Demand P(t) (MW)

3500

3000

2500

2000

1500

1000

Energy supplied

500

0 0 2 4 6 8 10 12 14 16 18 20 22 24

Time (Hours)
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 23

METU

Capacity Market
The Effect of Allocated Capacity
160 150 140 130 120 110 100 90 80 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 Allocated Capacity (%)

Percentage price(*) of operating reserve per MW decreases as the allocated capacity increases
-------------------------------(*) (Price / Nominal Price) . 100 (%)

Plant owner prefers higher allocated capacities, since fixed and variable costs of service decrease with the rating (size) of the plant
Principle of Economies of Scale

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 24

Percentage Price (Cent/kWh)

The Effect of Capacity Factor on Price

METU

Capacity Market
The Effect of Quickness of Response
Percentage Price (Cent/kWh) 150 140 130 120 110 100 90 80 70 0.8 1.2 1.6 2.0 2.4 2.8 3.2

The Effect of Quickness of Response Quickness of response requires high flexibility and readiness of the plant which increases the price

T = 1.6 T = 3.16

101.6 = 40 minutes 103.16 minutes = 1 day

Log (Response Time) (minutes)

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 25

METU

Capacity Market
The Effect of Certainity of Availability
Percentage Price (Cent/kWh) 100 95

The Effect of Certainity of Availability Certainity of availability (Sureness) is a parameter influencing the price of service Price of an operating reserve increases with the certainity of availability

90

85

80

75 70 0.75 0.80 0.85 0.90 0.95 1.00

Certainity of Availability (%)


EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 26

METU

Capacity Market
What is Certainity of Availability ?
Operating Reserve Group
Cascade operating reserve service with 98 % availability (Please note that, Customer-B may not receive full operating reserve service when CustomerA is serviced)

Certainity of Availability Assume that the operating reserve group shown in the figure has made an agreement with Customer-A on the basis of definite availability, i.e. 100 % availability Assume that the contingency risk of this customer needing this operating reserve service is only 2 %, i.e. the probability of not needing this operating service is 98 % Hence, it is possible to make a simultaneous (cascade) agreement with Customer-B on the basis of 98 % availability, at a reduced price
Operating reserve service with 100 % availability

Supplier

Transmission System

Transmission System

R-1 Op. Reserve Market - 1

R-2 Op. Reserve Market - 2

Customer-A

Customer-B

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 27

METU

Capacity Market
The Effect of Certainity of Order
140 Percentage Price (Cent/kWh)

The Effect of Certainity of Order Certainity of order (probability of ordering) is a parameter influencing the price of service Price of an operating reserve decreses as the uncertainity of order is reduced

130

120

110 100

90

80 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1

Certainity of Order (%)


EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 28

METU

Capacity Market
The Effect of Early Ordering
150 Percentage Price (Cent/kWh) 140 130 120 110 100 90 80 70 1.0 1.5 2.0 2.5 3.0 3.5 Log (early ordering period) (minutes)

The Effect of Early Ordering Early ordering provides plant operator chance to make a schedule for plant allocation which reduces the price

T = 1.0 T = 3.25

101 = 10 minutes 103.25 minutes = 29 Hours

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 29

METU

Capacity Market
Superposition of Capacity Services
Total Demand P(t) (MW) 40 35 30 25 20 15 10 5 0 2 4 6 8 10 12 14 16 18 20 22 24 2 4

Superposition of Capacity Services Capacity services supplied to two or more customers may be joined together gaining economy in the installed capacity of the operating reserve

Time (Hours)

Demand (Capacity) requested by the first customer

Demand (Capacity) requested by the second customer

Total Demand = 40 + 40 = 80 MW
EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 30

METU

Capacity Market
Superposition of Capacity Services
Total Demand P(t) (MW) 90 80 70 60 50 40 30 20 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

Superposition of Capacity Services


Please note that, the loads are diversived, hence their total does not make 80 MW, i.e. (P1 + P2) (t)max < P1 (t)max + P2(t)max Implying that the supplier does not need to supply the sum of the maximum demands, but maximum of sum of demands, which is more economical in terms of investments

P1 (t) + P2 (t)

P2 (t)

P1 (t)

Total Demand (Capacity) 76 MW < 80 MW


EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 31

METU

Capacity Market
Linkage among Operating Reserve Markets
Operating Reserve Group -1 Operating Reserve Group -2 Operating Reserve Group -3

If no linkage is established among operating reserve markets, they will function simultaneously, but separately This type of architecture results in higher prices, since unsold services in one market can not flow into the others An unsold operating reserve service is nothing but keeping the plant idle, i.e. just waste of resource

Supplier - 1

Supplier - 2

Supplier - 3

Transmission System
R-1 Op. Reserve Market - 1 R-2 Op. Reserve Market - 2 R-3 Op. Reserve Market - 3

Customer-1

Customer-2

Customer-3

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 32

METU

Capacity Market
Operating Reserve Group -1 Operating Reserve Group -2 Operating Reserve Group -3

Cascade Linkaging of Operating Reserve Markets


Forward Cascading If linkage is established among operating reserve markets, then will function simultaneously, and unsold services will flow from one market to the others, thus lowering the prices In this case, markets are cleared in sequence, starting from the one with the highest quality (price) Any surplus service in one market will flow to the other markets at a reduced price in a sequence

Surplus Service Flow

Surplus Service Flow

Supplier - 1

Supplier - 2

Supplier - 3 Transmission System Linkage Regions

Transmission System Linkage Regions

Transmission System

R-1 Op. Reserve Market - 1

R-2 Op. Reserve Market - 2

R-3 Op. Reserve Market - 3

Customer-1

Customer-2

Customer-3

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 33

METU

Capacity Market
Operating Reserve Group -1 Operating Reserve Group -2 Operating Reserve Group -3

Some Practical Problems in Cascade Linkaging


If there is a shortage in the last reserve market R-3, but not in the others, then price in R-3 may rise to a level above the prices in R-1 and R-2 Markets R-1 and R-2 on the other hand are already cleared at a lower price
Inefficient utilization of operating reserves

Surplus Service Flow

Surplus Service Flow

Supplier - 1 Transmission System Linkage Regions

Supplier - 2 Transmission System Linkage Regions

Supplier - 3 Transmission System

R-1 Op. Reserve Market - 1

R-2 Op. Reserve Market - 2

R-3 Op. Reserve Market - 3

Customer-1

Customer-2

Customer-3

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 34

METU

Capacity Market
Operating Reserve Group -1 Operating Reserve Group -2 Operating Reserve Group -3

Solution: Merger of Operating Reserve Markets


Merger of Op. Reserve Markets The ideal solution is to: increse the strength of internal linkages, merge all operating reserve markets in a single market More efficient, but more complicated and difficult to operate The extreme model is to merge the resulting operating reserve market with the energy market forming a single complicated market

Supplier - 1

Supplier - 2

Supplier - 3

Transmission System
R-1 Op. Reserve Market - 1 R-2 Op. Reserve Market - 2 R-3 Op. Reserve Market - 3

Regions

Regions

Customer-1

Customer-2

Customer-3

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 35

METU

Capacity Market

Can Balancing and Settlement Service be used as Operating Reserves ?


Answer The answer is No In principle, operating reserve services; extend longer-terms, such as few months to few tears, are relatively cheaper, are received on the basis of contracts while, balancing and settlement services; are short term services, are relatively much more expensive, are received from the spot market without any contract
Operating Reserve Group -1 Surplus Service Flow Operating Reserve Group -2 Surplus Service Flow Operating Reserve Group -3

Supplier -1 Transmission System R-1 Op. Reserve Market - 1 Linkage Regions Customer-1

Supplier -2 Transmission System R-2 Op. Reserve Market - 2 Linkage Regions Customer-2

Supplier -3 Transmission System R-3 Op. Reserve Market - 3 Customer-3

TETAS P = Pgen - P load

EUAS
Wholesale Company

Load
Transmission System

Distribution System

Pgen

Pload

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 36

METU

Capacity Market
The Effect of Operating Reserves on Price

Price Spikes (NYISO) (15.01.2005)


As consumption increases with respect to daily load curve, supply becomes tighter System operator then finds himself in a difficult situation that the operating reserves run short and he can no longer maintain 10 % operating reserves The system operator then starts offering higher prices for both the committed plants and reserves, driving up the prices In other words, prices follow a trajectory (not exactly but) similar to the load duration curve

Average Real-Time Prices within one-year Period

Hours

2001

2002

2003

Please note that; Price curves follow a pattern similar to those of the load duration curves, i.e. Prices are lower during night periods and higher during evening periods Prices were higher in 2003 due primarily to higher fuel costs,

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 37

METU

Capacity Market

The Effect of Operating Reserves on Competition


Minimum Operating Reserve In principle, a competitive market requires a an environment, where the available capacity exceeds demand Excess capacity is provided in terms of operating reserves Birecik HPP, 630 MW Spillway

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 38

METU

Capacity Market

The Effect of Operating Reserves on Competition


Minimum Operating Reserve It is a widely accepted practice that when the available capacity exceeds demand by only 10 -15 %, a competitive market will be established and it becomes possible to keep the price of the most expensive generation at 100 USD / MW, i.e. 10 Cents / kWh level In that respect, operating reserves may be regarded as available excess capacity Birecik HPP, 630 MW

EE 710 Electricity Trading, Electrical and Electronics Eng. Dept., METU, Spring 2005, Prof. Dr. Osman SEVAOLU, Page 39

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