One of the reliability concerns presented by higher precentages of VERs on-line is the

displacing resources that have the ability to arrest and stabilize system frequency after a grid
disturbance or the sudden loss of a large generating source.
Currently, photovoltaic solar generation offers no inertia and provides no frequency response,
and wind generation offers virtually no recovery support unless specifically designed to do so.
The ISO is concerned that during periods of light load and high renewable production, the
system may require subeconomic operation to meet its frequency response obligation, as
proposed under NERCs Frequency Response and Frequency Bias Setting Standard.
An additional concern is having less inertia because VERs displace conventional resources
with rotating mass and governor response.
The ISO must closely monitor this displacement in real-time because the ability to arrest
system frequnecy and meet its FRO depends on the following; the system condition just
before the fault, the size of the outage, the headroom available on governor responsive
resources, and the number and speed of governors providing frequency response.
Conventional resource displacement creates opportunities for renewable resources, demand
responce, storage, and smart technologies to help a Balancing Authority meet its FRO.
The ISO and General Electric INternational (GE) jointly conucte a frequency response study
to investiagte the loss of large-generation events under conditions with wind and solar
generation levels.
Four extreme base cases with lighter loads and high VERs were created for the studies.
They are winter low load with high ISO wind, weekend morning with high ISO wind and
solar production, winter off peak with high wind production, and spring peak with high hydro
and wind production.
The study focused on Californias frequency response for the loss of two Palo
Verde(2690MW) generating units and the loss of two Diablo Canyon units(2400MW).
These operating conditions were selected because more resources woud be decommitted
because of the low loads and high VER production levels.
For the contingencies studied, three system equivalent frequencies were moduled based on the
weighted speed of all the synchronous machines in the system.
The winter low load with high ISO win base case in comprised of WECC load level of 91300
MW and 15890 MW of win and solar generation, of which 10960 MW was located within
California.
Headroom on governor responsive resources in the base case was 13740 of which 3974 was
locted within California.

As shown in Figure 5, for the loss of two Palo Verde units, the frequency nadir (point C)
occurred at 9.8 s at a frequency of 59.67 Hz, and the settling frequency (point B) was 59.78
Hz.
Figure 6 shows the electrical and mechanical power output of the governor responsive
resources within California.
At the time of the nadir (point Cp), the resources within California were delivering
approximately an extra 524 MW or 24% of the overall WECC frequency response obligation.
The GE-ISO settling-based frequency response shows that California contributed 234
MW/0.1 Hz, which includes a 25% safety margin.
Based on the WECC obligation, if California was assigned 30% or 205MW/0.1 Hz (based on
load ratio), the response of 234 MW/0.1 Hz was adequate.
The NERC propoesd FRO for the WECC is being reviewed and may change after the review
process.

7.
Several sensitivities were conducted to evaluate the adequacy of the committed resources to
avoid unintentional load tripping.
First, hourly deterministic production simulation studies were conducted for each hour of
2020.
Hourly time series for wind and solar resources were developed, and resources were
committed by the model to meet the hourly loads.
Second, the unit commitment patterns from the production simulation studies were chosen
based on low loads and high VER penetration for specific hours or potential overgeneration
conditions.
These generation commitment patterns and corresponding loads were then modeled in the GE
stability model.
The following sensitivities and results are summarized in Table 1.
The system was futher stressed by reducing the practical minimum headroom on governor
responsive resources in the Western Interconnection to 8000 MW and further reducing the
headroom to an extreme minimum level of 3000 MW.
The 3000-MW was based on the WECC only carrying required spinning reserve for the
interconnection as a whole.
Although this is not an actual acceptable operation condition, it is a test case for
determinining that maintaininig a minimum of the spinning reserve requirement as available
headroom is not adequate to reliably operate the system.
As shown in FIgure 7, the higher renewable penetration case (red line) with more wind has
better frequency response than the base case (blue line) because the higher wind generation
increased resource Kt headroom.
For the practical headroom of 8000 MW, the frequency nadir reached 59.55 Hz, which only
gives 50 mHz of margin before the first block of underfrequency load shedding relys are set
to pick up at 59.5 Hz
For the extreme minimum headroom case, the frequency nadir was 59.42 Hz, which would
have resulted in underfrequency load shedding picking up and unintentionally tripping load.
These sensitivities indicate that extremely depleted headroom will result in unacceptable
system preformance.
The radio between resources providing governor response and the other resources Kt is a
good primary metric for determining the amount of governor resources that should committed
in real time [9,10].

These studies provide evidence that as high levels of wind and solar generation are integrated
into the existing resource mix in the WEstern Interconnection, it is necessary to maintain
adequate headroom on governor responsive resources to meet a required frequency response
obligation.
The system must also maintain a minimum amount of synchronize resources to arrest
frequency decline after a disturbance.
The speed of frequency responsive resources needs to be considered because the frequency
nadir after a major loss of generation event typically occurs within 10 s after the event.
For the practical minimum headroom case, the frequency response unti secondary frequency
response or automatic generation control ispatches resourcs on regulatio an contingency
reserve could be dispatched.
The studies also concluded that withdrawal of primary response quickly contributes to
degraded frequency performance of approximately 20%.
Inertial control from wind generation provides fast transient support, via controlled inertial
response from wind turbines, and can siginficantly improve the system frequency nadir.
Based on the previously described finding, the ISO collaborated with NERC to issue a joint
report in which inertial response was recommended as a charasteristic that asynchronous
resources should provide, similar to sychronous resources, to maintain system reliability as
more renewable resources are integrated into the grid.