Meeting Minutes Resource Subcommittee July 23-24, 2014 Northwest Power Pool 7505 N.E. Ambassador Place Portland, Oregon Administrative

A meeting of the Resources Subcommittee (RS) was held on July 23–24, 2014 in Portland, Oregon. The agenda and attendance list are attached as Exhibits A and B, respectively.

Resources Subcommittee Chair Gerry Beckerle presided and Larry Kezele announced that a quorum was present, read the applicable Notice of Public Meeting and acknowledged the NERC Antitrust Compliance Guidelines. The subcommittee reviewed and revised the RS Organization and Assignments, the RS Roster, and the RS Survey Contacts. April 23–24, 2014 Meeting Minutes

The subcommittee approved the April 23–24, 2014 meeting minutes. Resources Subcommittee Action Item List

The RS reviewed, revised and updated the action item list, which is affixed as Exhibit C. Resources Subcommittee Confidentiality Agreement

Larry Kezele reviewed the list of those individuals that have signed the RS confidentiality agreement. Working Group and Task Force Reports

1. Frequency Working Group Chair Sydney Niemeyer reported that the FWG met on July 23, 2014 and reviewed the master frequency event list for March, April and May 2014 for the Eastern, Quebec, Western and ERCOT Interconnections. The working group also reviewed Bonneville Power Administration’s use of variable bias with regard to the reporting requirements of BAL-003-1, Form 1.9a.

2. Inadvertent Interchange Working Group Chair Tabitha Hernandez reported that the IIWG met on July 23, 2014 and discussed the following: 1) Area Interchange Error Training Document and 2) Inadvertent Interchange Accounting Training Document. Frank Carrera reported that Electric Power Group is updating the Inadvertent Interchange application user guide, which is expected to be completed by August 15, 2014 (Presentation 1 (slides 45-52)). Chair Hernandez will also continue her efforts to work with the Eastern Interconnection regional survey contacts to verify on-peak and off-peak inadvertent interchange accumulations and resolve outstanding imbalances.

3. Operating Reserve Working Group Chair Beckerle reported that the ORWG has not met.

Meeting Minutes – Resources Subcommittee Meeting –July 23-24, 2014 2

NERC Related Activity

1. Reliability Guideline: Generating Unit Operations during Complete Loss of Communications Vice Chair Troy Blalock reported that the Operating Committee approved the draft Reliability Guideline: Generating Unit Operations during Complete Loss of Communications, at its June 10-11, 2014 meeting (Presentation 2). However, during its debate of the reliability guideline, the OC noted the following concerns:

a. Individuals in substations (personnel safety)

b. Transmission element overloads (SOLs or IROLs)

c. Conflict with EOP-002 (Requirement R5)

d. Generators controlling to voltage

The RS discussed each of the above concerns and noted that implementation of the guideline was voluntary. Chair Beckerle will provide an overview of subcommittee’s discussion to the OC at its September 2014 meeting.

2. Eastern Interconnection Frequency Response Initiative Vice Chair Blalock reported that he provided a status report of the Eastern Interconnection Frequency Response Initiative to the Operating Committee at its June 2014 meeting. He expanded on his status report for this meeting (Presentation 4).

3. Field Test to Reduce the Number and Depth of Time Error Corrections Chair Beckerle summarized the discussion of this topic at the subcommittee’s last meeting. The Eastern Interconnection may pursue ERCOT’s and WECC’s initiative with the North American Energy Standards Board (NAESB). Don Badley reported that WECC petitioned the NAESB to broaden its time error correction window from 5 seconds to 30 seconds. NAESB approved WECC’s petition and WECC implemented the new time error window on June 9, 2014. Chair Beckerle suggested tabling further discussion of this agenda item, especially given the BAL-004-0 is currently being reviewed by a standard drafting team that is considering the elimination of time error corrections.

4. 2014 Interconnection Frequency Response Obligation Report Bob Cummings discussed the schedule for developing the 2014 Interconnection Frequency Response Obligation Report. He anticipates developing the report in late summer 2014, following which he will seek endorsement from the Frequency Working Group and the Resources Subcommittee. Mr. Cummings anticipates presenting the report to the Operating Committee in September 2014 for acceptance. The 2014 report will include the frequency response obligations for all balancing authorities.

5. Essential Reliability Services Task Force and Frequency Response Subgroup Chair Beckerle provided an overview of Essential Reliability Services Task Force activities (Presentation 6). The ERSTF formed four subgroups to address its assigned tasks: 1) Load and Resource Balance subgroup, 2) Voltage Support subgroup, 3) Frequency Response subgroup and 4) Policy and Advisory subgroup.

Meeting Minutes – Resources Subcommittee Meeting –July 23-24, 2014 3

NERC Reliability Standards and Reliability Related Documents

1. Project 2007-12 (Frequency Response and Frequency Bias Setting) Implementation Larry Kezele reported that BAL-003-1 (Frequency Response and Frequency Bias Setting) was approved by FERC on January 16, 2014.

Compliance Enforcement Dates

a. Bob Cummings reported (Presentation 3) that the compliance enforcement dates for BAL-003-1 are:

i. April 1, 2015 for Requirements 2, 3 and 4

ii. April 1, 2016 for Requirement 1

Technical Considerations of Implementing BAL-003-1

a. BAL-003-1 Webcast – The BAL-003-1 webcast is currently scheduled for September 12, 2014.

b. FERC Form 714 Data – NERC will be collecting FERC Form 714 data. Non-jurisdictional entities will also be asked to provide similar data.

c. Balancing Authority Data Submittal Website – Bob Cummings provided an overview of the balancing authority data submittal website (Presentation 5). The site will be used to collect and store BAL-003-1 Form 1 and Form 2 data. The site is expected to be available on September 1, 2014.

d. Test/Transition to the 0.9% Bias – The RS believes that the current timeline of implementation of BAL-003-1 does not allow for a field trial to analyze the transition from 1.0% bias to 0.9% bias.

2. Five-Year Review of Reliability Standards Don Badley reported that the Standards Committee approved the development of a standard authorization request (SAR) to move forward with a project to review and revise BAL-005 and BAL-006. The SAR is now out for informal comment until August 14, 2014. The initial drafting team is considering the retirement of BAL-004.

Frequency Response Analysis Tool

Dmitry Kosterev, Bonneville Power Administration, and Pavel Etingov, Pacific Northwest National Laboratory, provided an overview of the Frequency Response Analysis Tool (FRAT) developed for WECC by Pacific Northwest National Laboratory (Presentation 7). BPA is using FRAT to analyze the frequency response characteristics of the BPA balancing authority. BPA is also considering using FRAT to determine compliance with BAL-003-1.

Resources Subcommittee Software Applications

Frank Carrera, representing Electric Power Group (EPG), provided a status report of CERTS/NERC applications (Presentation 1 (slides 1-6)). Maps in the Resource Adequacy application are being updated for release in August 2014 and the Inadvertent Interchange web site is being updated to include management functionality. Mr. Carrera provided an overview of a recent outage of the Automated Reliability reporting function. EPG is working to create the missing reports. EPG is also working with each Interconnection to secure a source of time error correction data.

Meeting Minutes – Resources Subcommittee Meeting –July 23-24, 2014 4

2013 Frequency Event Characteristics and Observations for each Interconnection

Carlos Martinez reviewed each Interconnection’s candidate frequency events, by month, from 2009 to 2014 and each Interconnection’s 2013 generation event observations for event frequency point A, B and C (Presentation 8). Frequency and Control Performance and Time Error

1. Frequency Performance, Trends and Events and Time Error

a. Second Quarter Frequency and Time Error Performance Reports – Frank Carrera, EPG, reviewed the preliminary Western, Eastern, ERCOT and Quebec Interconnection frequency, control and time error correction performance reports (Presentation 1 (slides 7-44)). Time error correction performance reports were only available from ERCOT and Western.

b. Western Interconnection Trends and Events

John Tolo noted there were minor discrepancies in the time error correction data captured by the Western Interconnection and by EPG. The data is being reviewed to determine the source of these discrepancies.

c. Eastern Interconnection Trends and Events

Brad Gordon reviewed the EI time error report (Presentation 9).

d. ERCOT Interconnection Trends and Events

Sydney Niemeyer stated that EPG’s report captured ERCOT’s frequency, control and time error correction performance statistics.

e. Quebec Interconnection Trends and Events

Francis Monette reviewed the Hydro Quebec Interconnection frequency and control performance and time error report (Exhibit D).

2. CPS1 and CPS2 Data Trends In closed session, the subcommittee discussed CPS1 and CPS2 data trends.

3. DCS Data Trends In closed session, the subcommittee discussed DCS data trends.

Dates and Locations of Future Meetings

Wednesday, October 29, 2014 (FWG) Wednesday, October 29, 2014 (IIWG) Wednesday, October 29, 2014 (RS) Thursday, October 30, 2014 (RS)

8:00 – 10:00 a.m. 10:00 a.m. – Noon 1:00 – 5:00 p.m. 8:00 a.m. – 5:00 p.m.

Las Vegas, NV: WECC RS Members

Wednesday, January 28, 2015 (FWG) Wednesday, January 28, 2015 (IIWG) Wednesday, January 28, 2015 (RS) Thursday, January 29, 2015 (RS)

8:00 – 10:00 a.m. 10:00 a.m. – Noon 1:00 – 5:00 p.m. 8:00 a.m. – 5:00 p.m.

Miami, FL: FRCC RS Members

Meeting Minutes – Resources Subcommittee Meeting –July 23-24, 2014 5

Wednesday, April 22, 2015 (FWG) Wednesday, April 22, 2015 (IIWG) Wednesday, April 22, 2015 (RS) Thursday, April 23, 2015 (RS)

8:00 – 10:00 a.m. 10:00 a.m. – Noon 1:00 – 5:00 p.m. 8:00 a.m. – 5:00 p.m.

San Diego, CA: WECC RS Members or New Orleans, LA: SERC RS Members

Wednesday, July 22, 2015 (FWG) Wednesday, July 22, 2015 (IIWG) Wednesday, July 22, 2015 (RS) Thursday, July 23, 2015 (RS)

8:00 – 10:00 a.m. 10:00 a.m. – Noon 1:00 – 5:00 p.m. 8:00 a.m. – 5:00 p.m.

Montreal, QC: NPCC RS Members or Vancouver, BC: WECC RS Members

Adjourn

The subcommittee meeting adjourned at 3:03 p.m. PDT on July 24, 2014. Respectfully submitted,

Larry Kezele Larry Kezele Resources Subcommittee Secretary

Agenda Resources Subcommittee July 23, 2014 | 1:00–5:00 p.m. PDT July 24, 2014 | 8:00 a.m.–5:00 p.m. PDT

Northwest Power Pool 7505 N.E. Ambassador Place Portland, Oregon (503) 445-1075

Conference: 1-866-740-1260 | Pass code: 5247004 | Security code: 679232

Introductions and Chair’s Remarks

NERC Antitrust Compliance Guidelines and Public Announcement

Agenda Items

1. Administrative

a. Membership and Guests* — Chair Beckerle

i. Resource Subcommittee (RS) Organization and Assignments

ii. RS Roster

iii. RS Survey Contacts

b. Arrangements — Don Badley

c. Parliamentary Procedures* — Larry Kezele

d. Approve — Meeting Agenda — Chair Beckerle

e. Approve — April 23–24, 2014 Meeting Minutes* — Chair Beckerle

f. Resources Subcommittee Action Items List*— Chair Beckerle

g. NERC–RS Confidentiality Agreement* — Chair Beckerle

2. Working Groups and Task Force Reports

a. Frequency Work Group — Sydney Niemeyer

b. Inadvertent Interchange Work Group — Tabitha Hernandez

c. Reserve Work Group — Bob Klueber

Exhibit A

3. NERC Related Activity

a. NERC Operating Committee Action Items Assigned to RS — Chair Beckerle

i. Reliability Guideline: Generating Unit Operations During Complete Loss of Communications — Vice Chair Blalock

1) Operating Committee Concerns with Initial Version of the Reliability Guideline:

• Individuals in substations (personnel safety)

• Transmission element overloads (SOLs or IROLs)

• Conflict with EOP-002 (Requirement R5)

• Generators controlling to voltage

b. Eastern Interconnection Frequency Initiative Status Report — Vice Chair Blalock

i. Status – NERC Data Repository

c. Time Error Correction – Field Test to Reduce the Number and Depth of Time Error Corrections – Chair Beckerle

4. NERC Reliability Standards and Reliability Related Documents

a. Information – Project 2007-12 (Frequency Response) – Time Line of Implementation Activities Prior to the Compliance Enforcement Dates — Tom Pruitt and Bob Cummings

Background – BAL-003-1 (Frequency Response and Frequency Bias Setting) was adopted by the NERC Board of Trustees on February 7, 2013 and was filed at FERC on March 29, 2013. On July 18, 2013, FERC issued a notice of proposed rulemaking wherein FERC proposes to approve Reliability Standard BAL-003-1. On January 16, 2014, FERC approved BAL-003-1.

Regulatory Considerations:

i. Determination of compliance enforcement dates

Technical Considerations:

i. Fixed and Variable Bias and Forms 1 and 2

ii. BAL-003-1 Webcast

iii. FERC Form 714 data

iv. Field trial to test the transition from 1.0 % Bias to 0.9% Bias

b. Project 2010-14.2 Periodic Review of BAL Standards— Don Badley

i. BAL-004-0 (Time Error Correction)

ii. BAL-005-0.2b (Automatic Generation Control)

RS Agenda – July 23-24, 2014 2

iii. BAL-006-2 (Inadvertent Interchange)

5. RS Software Applications — Frank Carrera

6. 2013 Frequency Event Characteristics and Observations for each Interconnection — Carlos Martinez

7. Frequency and Control Performance and Time Error

a. Second Quarter Frequency Performance Report for all Four Interconnections — Song Xue

b. Frequency Performance, Trends, and Events and Time Error

i. Western Interconnection — John Tolo

ii. Eastern Interconnection — Brad Gordon, Terry Bilke

iii. ERCOT Interconnection — Sydney Niemeyer

iv. Hydro Québec Interconnection — Francis Monette

CLOSED SESSION (NDA required)

a. CPS1, CPS2, BAAL Data Trends — Chair Beckerle

b. DCS Data Trends — Chair Beckerle

END CLOSED SESSION

8. Future Meetings

a. October 29–30, 2014 – Las Vegas, NV (WECC RS Members Coordinating) or Austin, TX (ERCOT RS Members Coordinating)

b. January 28–29, 2015 – Miami, FL (FRCC RS Members Coordinating)

c. April 22–23, 2015 – TBD

d. Schedule future meetings *Background materials included.

RS Agenda – July 23-24, 2014 3

Resources Subcommittee Meeting Attendance July 23-24, 2014 Northwest Power Pool Portland, Oregon Attendance: Name Attendance Gerry Beckerle, Chair Y Troy Blalock, Vice Chair Y Don Badley Y Sydney Niemeyer Y Mike Potishnak Y Robert Rhodes N John Tolo Y Terry Bilke Y (Proxy Tabitha Hernandez) Francis Monette Y Brad Gordon Y Tony Nguyen Y Tom Pruitt Y Bill Kunkel Y (Speakerphone) Larry Kezele Y Bob Cummings Y Antonio Franco Y Frank Carrera Y (Speakerphone) Ajay Das Y (Speakerphone) Danielle Martini Y Tim Reynolds Y Carlos Martinez Y Mike Oatts Y (Speakerphone) Eddy Lim Y Dmitry Kosterev Y Pavel Etingov Y

Exhibit B

Resources Subcommittee July 23–24, 2014 Meeting Open Action Items List

Action Figure

Subject Action Item/Assignment Due Date Completion Date

Tabitha Hernandez

Inadvertent Interchange Balances Determination

102810, Bill will draft a letter on behalf of the RS to the Balancing Authorities (BAs) in the Eastern Interconnection stating their inadvertent interchange balances prior to January, 2007 with a request to the BAs to identify any disputes with evidence to correct and establish a definitive historic and accurate inadvertent interchange balance.

012711 RS reviewed draft letter. Terry Bilke will issue the revised letter.

042011 Letter issued, with responses due from BAs by 041511. Discuss later in the agenda.

072711 Chair Bilke asked the Inadvertent Working Group seek additional resources to help in tracking inadvertent. He suggested that the working group generate a quarterly report for RS review. Gil Tam noted that EPG sends out two inadvertent reports each month that identifies what BAs have submitted data and the accuracy of the data.

10/26/11 Vice Chair Badley reported on his progress to resolve EI inadvertent balances.

012512. Data discrepancies still being addressed. Finalize at April 2012 meeting.

072512. Don Badley looking for historical Inadvertent Interchange data. Data may be available from CERTS. Data discrepancies still being addressed. Finalize at October 2012 meeting.

102412 The RS addressed data discrepancies. However, root causes have yet to be determined.

012313 Efforts continue to address EI inadvertent interchange mismatches.

021111 042612

Agenda Item 1.f Exhibit C

Action Figure

Subject Action Item/Assignment Due Date Completion Date

042413 Mike Potishnak reported the following:

1. By June 1 2013, get FRCC fully validated and entered into the CERTS tool (Badley, Hernandez, Tam, Carrera)

2. By June 20 2013, update and reach closure on data base, particularly handing of atypical BAs (Badley, Hernandez)

3. By June 1 20913, get legal opinion on NAESB involvement (Kezele)

4. Get allocation algorithm to Larry by yesterday (Potishnak)

5. Facilitate NERC IT coordination with this effort – ongoing (Kezele)

6. All EI BAs agree on carry forward values for a recent common month by 7-15-13 (Potishnak, Badley, Hernandez)

7. By July 27 2013, allocate mismatches (Badley, Hernandez)

072413 Completed number 4 in the list above.

102913 No status change.

012214 Don McInnis will bring to the FRCC’s attention either using the CERTS tool or assigning another person to enter the data from the FRCC tool into the CERTS tool.

042314 Ongoing, with update to be provided at the July 2014 meeting.

07/23/14 Ongoing, with update to be provided at the October 2014 meeting.

Resources Subcommittee

NERC OC Operating Manual Docs

073108, RS members on each open BAL-related standard drafting team are to request that the SDT write or plan to write a modules for each SDT specific requirement and how to achieve technical results for the PSRD.

102908, Resources Subcommittee recommended to the OC that the RS documents that are found in the OC Operating Manual be kept in the manual.

102908, RS Working Groups and RBCSDT, BACSDT, and FRSDT are to revise the documents for accuracy. RS will then submit the revised documents to the RFWG to update the manual. SDTs can develop the documents as standards reference documents to support their respective standards.

012909, John Swez to review the Performance Standard Reference Document for accuracy. Ongoing action item.

RS Operating Manual documents are:

Ongoing

Action Figure

Subject Action Item/Assignment Due Date Completion Date

Performance Standard Reference Guidelines (PSRG) – John Swez – Note the OC approved the PSRG on June 15, 2010, new PSRG inserted into the NERC Operating Manual

Area Interchange Error Survey Training Document – Don Badley and Inadvertent Interchange WG

Frequency Response Training Document – Sydney Niemeyer and Frequency WG

Inadvertent Interchange Accounting Training Document – Don Badley and Inadvertent Interchange WG – Expect update by next meeting.

121609, NERC posted the Performance Standard Reference Document for 45 day comment period which ends on Feb 12, 2010.

102710, The OC approved the PSRG on June 15, 2010. The RS anticipates the remaining OC Operating Manual documents to be revised during the SDT standards revision process.

072711 Chair Bilke reported that is an ongoing task.

10/26/11 No change in status.

012512. No change in status.

042512 No changes in status

072512 No changes in status

102412 IIWG beginning to address changes required in the Area Interchange Error Survey and Inadvertent Interchange Accounting Training Documents.

012313 No changes in status.

042413 No changes in status.

072413 Mike Potishnak proposed changes to II Accounting Training Document.

102913 No changes in status.

012214 No changes in status. Need to begin development of a frequency response training document. The RS discussed the existing AIE training document, which needs to be updated to include screen shots from the CERTS tool.

042314 No changes in status. PSRG – Hold off any work until BAL-001 and BAL-002 are completed. Perhaps create a new CPS and BAAL training document. Review again at the July 2014 meeting. AIE Survey Training Document – Needs to be updated to reflect use of the EPG AIE application. Tabitha will further investigate.

Action Figure

Subject Action Item/Assignment Due Date Completion Date

Frequency Response Training Document – Sydney suggested archiving the FR training document and relying instead on the technical documentation for BAL-003-1. Larry Kezele will remove the FR training document from the Operating Manual and archive it to the RS related files website and add the FR Information document to the RS related files website. Don Badley will review and make a recommendation regarding the FR training document. II Accounting Training Document – Tabitha will review.

072314 AIE Training Document. Tabitha reviewed and concluded that changes are not required. Inadvertent Interchange Accounting Training Document. CERTS is updating the application user guide, which is scheduled to be completed by August 2014.

Larry Kezele CPS Data 102810, During the CPS data review, it was pointed out that not all Canadian entities are included in the CPS Summary. Tom to visit with Chris Scheetz to include future Canadian entities into the CPS Summary.

012711 Review data later in today’s meeting

072711 Some Canadian entities are still missing from the CPS1, CPS2, and DCS reports. Don Badley contacted Chris Scheetz regarding this issue.

10/26/11 Don Badley working with WECC staff to resolve.

012612 Chair Badley continues to address with Alberta and BC Hydro.

042512 Chair Badley will advise AESO and BC Hydro to send their CPS data directly to Chris Scheetz.

072512 Chair Badley will advise AESO and BC Hydro to send the CPS data directly to NERC (Chris Scheetz).

102412 Don Badley will review with Chris Scheetz and AESO and BC Hydro.

012313 NERC is willing to accept CPS data directly from Canadian BAs; however, WECC is internally reviewing.

042413 Don Badley will arrange a conference call with BC Hydro and AESO to further discuss.

072413 BC Hydro will be submitting its data through WECC Compliance. No progress on AESO.

102913 No change in status.

012214 BC Hydro has been sending data to WECC for two years. Data is still not being received by NERC. Chair Badley will discuss this with AESO.

012611

Action Figure

Subject Action Item/Assignment Due Date Completion Date

042314 In process. Not yet complete. Don and Tony will provide an update at the July 2014 RS meeting.

072314 AESO wants to submit their data directly to NERC. BC Hydro may soon be sending its data to WECC.

Larry Kezele EPG Software Application Users

072512. The subcommittee decided to annually review the list of those having access to the Resource Adequacy, Intelligent Alarm, Frequency Analysis and Monitoring, Automatic Reliability Report, and Inadvertent Interchange software applications.

072413 Completed for this year. Will conduct review again in July 2014.

072314 L. Kezele will send out the list of registered users.

July 2014

Tabitha Hernandez

Transferring Inadvertent Balancing

072413 Tabitha to write a white paper on how dissolving BA’s would transfer their inadvertent balance to the “new BA.”

102913 In progress.

012214 Draft reviewed and changes will be incorporated.

042314 Tabitha reported that the document is near final. She will resend it to the RS.

072314 This document is now posted under the RS’s website under related files. This item is now complete.

Tabitha Hernandez

Contact Regional Entity Administrators

072413 Tabitha to contact each Regional Administrator to discuss the locking and unlocking of NERC tool. The plan is for one person to lock the system for the Eastern Interconnect. This will ensure the function is getting completed.

102913 In progress.

012214 In progress. EPG provided the list of names.

042314 In progress.

072314 In progress.

Chair Beckerle

Fixed and Variable Bias

042314 The RS will consider sending a letter to the survey contacts regarding use of fixed versus variable bias along with potential FR reserve sharing group plans.

072314 Tony Nguyen and Don Badley will discuss variable bias implementation issues at the RS’s October 2014 meeting. The decision to issue a survey will be postponed until the RS’s October 2014 meeting.

Action Figure

Subject Action Item/Assignment Due Date Completion Date

Tabitha Hernandez

Accumulated Inadvertent Balances

042314 Ms. Hernandez to write up a letter to Regional Administrators to work with their regional BA’s on confirming Accumulated Inadvertent Balances as of 12/31/2008.

072314 Ongoing. To be further discussed at the IIWG’s October 2014 meeting.

Tabitha Hernandez

Training document for Regional Administrators

042314 Create a training document for Regional Administrators addressing the RS’s expectations of them.

072314 Ongoing. To be further discussed at the IIWG’s October 2014 meeting.

Sydney Niemeyer, Tom Pruitt, Francis Monette, Tony Nguyen

Review of Form 1 and Form 2 in regard to Variable Bias

042314 Review of Form 1 and Form 2 in regard to Variable Bias and BA load dampening estimation.

072314 Ongoing. Expectation is to complete by October 2014 meeting.

Hydro-Québec TransÉnergie

Frequency and Time Error Report

Second Quarter 2014

The following data was computed from HQT archives.

2014 April May June

Average Frequency 60,000469 Hz 60,000471 Hz 60,000459 Hz

Standard Deviation from average frequency

0,0190 Hz 0,0239 Hz 0,0241 Hz

Most negative Time Error -0,68 sec. -0,54 sec. -0,66 sec.

Most positive Time Error 0,56 sec. 0,87 sec. 0,89 sec.

Average Time Error -0,036 sec. 0,002 sec. -0,045 sec.

Note: All data was computed from 3-sec. samples.

From: Fresh Mbuangi Muakassa, ing. jr Direction Contrôle des mouvements d'énergie

HQT 514-879-4100 ext. 3623 mbuangimuakassa.fresh@hydro.qc.ca

Exhibit D