glendal~9p california ~ CITY OF GLENDALE, CALIFORNIA REPORT TO THE: Housing Authority ~ Successor Agency ~ Oversight Board ~

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1 Joint D City Council ~ glendal~9p california ~ CITY OF GLENDALE, CALIFORNIA REPORT TO THE: Housing Authority ~ Successor Agency ~ Oversight Board ~ July 17, 2018 AGENDA ITEM Report: Intermountain Power Project: Alternative Repowering and California Energy Commission Emissions Performance Standard Compliance Filing 1) Motion authorizing the General Manager of Glendale Water & Power, or his designee, to vote at the Intermountain Power Project (IPP) Coordinating Committee in favor of an Alternative Repowering that would reduce the size of the IPP Repowering from 1,200 MW to 840 MW and finding that such action is exempt from the California Environmental Quality Act. 2) Resolution approving an Emissions Performance Standard Compliance Filing for Submittal to the California Energy Commission in connection with the Alternative Repowering of the Intermountain Power Project, and Authorizing the General Manager of Glendale Water & Power to submit such filing to the California Energy Commission, and finding that such action is exempt from the California Environmental Quality Act. COUNCIL ACTION Public Hearing fl Ordinance H Consent Calendar ~ Action Item E Report Only fl Approved for ~5ü..b3VTh1 1~\~ calendar ADMINISTRATIVE ACTION Submitted by: Stephen M. Zurn, General Manager - GWP Prepared by: Mark Young, Integrated Resources Planning Administrator - GWP Approved by: Yasmin K. Beers, City Manager Reviewed by: Roubik Golanian, Assistant City Manager Michael J. Garcia, City Attorney Robert P. Elliot, Director of Finance If

2 RECOMMENDATION It is recommended that the City Council take the following actions: (1) Authorize the General Manager of GWP, or his designee, to vote in favor of an Alternative Repowering at the IPP Coordinating Committee and find that such action is exempt from the California Environmental Quality Act. The Alternative Repowering, if approved by the IPP Coordinating Committee, would reduce the size of the IPP gas-fired repowering project from 1,200 MW to 840 MW. (2) Approve Glendale Water & Power s (GWP) Compliance Filing for the proposed Alternative Repowering, attached to this report as Exhibit 1, and authorize the General Manager of GWP to submit such filing to the California Energy Commission (CEC). If the Alternative Repowering is approved by the IPP Coordinating Committee, the Compliance Filing must be filed under California s Emissions Performance Standard regulations. State law requires City Council approval of the Compliance Filing before it is submitted to the CEC. BACKGROUND/ANALYSIS IPP is a 1,800-megawatt net coal-fired power plant located near Delta, Utah owned by the Intermountain Power Agency (IPA), a political subdivision of the State of Utah. In 1980, the City of Glendale executed a long-term agreement with the Intermountain Power Agency ( IPA ), a municipal joint action agency in Utah, for the purchase of coal-fired generation from the Intermountain Power Project (IPP) and associated transmission rights from Delta, Utah, to southern California. The Project is owned by IPA. IPP Renewal Contracts On June 16, 2015, the Glendale City Council authorized Glendale to enter into the Second Amendatory Power Sales Contract which, with the concurrence of all of the IPP participants, provides for the repowering of IPP from its current 1,800 MWs of coal-fired generation to no more than 1,200 MWs of California emissions performance standard (EPS)-àompliant natural gas-fired generation by July 1, The Project will eliminate all coal-fired emissions from IPP. The 1,200 MW Project includes the construction and installation of two natural gas-fired combined cycle units, each with a design capacity of approximately 600 MW and expected CO2 emissions of approximately 800 lbs. CO2/MWh, as compared to coal-fired generation which emits roughly 2,000 lbs. C02/MWh. Los Angeles Department of Water & Power (LADWP), which serves as operating agent for IPP, estimates that with the reduction of the total plant output as well as the conversion to natural gas, the repowering will result in the elimination of approximately 13.9 billion pounds of CO2 each year. On June 16, 2015, the Glendale City Council also authorized Glendale to enter into the Renewal Power Sales Contract and the Agreement for Sale of Renewal Excess Power with IPA (the Renewal Contracts) and to subscribe to up to a 50 MW share of the repowering project. (A copy of the June 16, 2015 City Council Report and the Renewal Contracts is available at: packets/reports /CC 8e pdf) Glendale has subscribed to a 4.166% share of the Project. For the 1,200 MW Project, Glendale s 4.166% subscription would give Glendale approximately 50 MWof generation and 128 MW of transmission. The Renewal Contracts will allow the participants to continue participating in IPP as a repowered EPS-compliant natural gas facility through June 15, IPP generation and transmission rights are bundled together. Therefore, continued participation in the IPP project is necessary in order for Glendale to retain its transmission rights connecting Utah to California. 2

3 The IPP Renewal Contracts allow Glendale and certain other participants an off ramp whereby Glendale would have the option to either (a) withdraw from the new generation project, or (b) reduce its generation entitlement share by up to 20% by providing IPA with written notice by August 3, In light of the high degree of uncertainty associated with environmental regulations and policies, changing customer demand, developing technologies, Glendale s transmission needs, and the City of Glendale s ongoing evaluation of its resources, it is in the City of Glendale s best interest to keep its options open with respect to IPP. Under the IPP Renewal Contracts, Glendale retains the right, but not the obligation, to participate in the IPP renewal project. GWP will seek City Council direction regarding the offramp prior to the off ramp notice deadline. Alternative Repowering The Second Amendatory Power Sales Contract provides that, in lieu of pursuing the 1,200 MW Project, the IPP Coordinating Committee may instead elect to pursue an Alternative Repowering. The IPP members are now considering an Alternative Repowering that would reduce the size of the proposed IPP gas repowering from 1,200 MW to 840 MW. The Alternative Repowering will be subject to a vote by the IPP Coordinating Committee in the fall of GWP recommends that the City Council authorize the General Manager of GWP, or his designee, to vote in favor of the Alternative Repowering at the upcoming IPP Coordinating Committee meeting. The IPP Operating Agent, LADWP, estimates that the Alternative Repowering would reduce greenhouse gas emissions by approximately 83%. If the Alternative Repowering is approved, Glendale would retain its 4.166% share of IPP generation and transmission. An 840 MW Project would mean that Glendale would receive 35 MW of generation and 128 MW of transmission from IPP. The Alternative Repowering is allowed under the terms of the Second Amendatory Power Sales Contract. The Alternative Repowering, if approved, would not be a contract amendment and would not be a new contract to buy a power plant. California Energy Commission Compliance Filing GWP is seeking approval to submit the CEC Compliance Filing for the IPP Alternative Repowering as required by current California State law enacted by Senate Bill (SB) The CEC Compliance Filing would only be submitted in the event that the IPP Coordinating Committee votes in favor of the Alternative Repowering. Per Title 20 Sections 2908 and 2909 of the California Code of Regulations, as adopted by the CECto implement SB 1368, the CEC requires a public notice of deliberation and a subsequent Compliance Filing for entering into a covered procurement, which includes any new or renewed contract for the procurement of electricity from a baseload power plant with a term of five years or more. Glendale already satisfied the requirements for a public notice of deliberation which took place at its June 16, 2015 City Council meeting. In October of 2016, Glendale also submitted, and in November 2016 the CEC has approved, a Compliance Filing finding that Glendale s Second Amendatory Power Sales Contract is compliant with the EPS requirements. However, if the IPP Coordinating Committee votes in favor of the Alternative Repowering, Glendale must submit this subsequent Compliance Filing to the CEC in conjunction with the Alternative Repowering, to establish the Alternative Repowering s compliance with the EPS. Per SB 1368 regulations, the Compliance Filing must be approved by the Glendale City Council prior to its submission to the CEC. The proposed compliance filing is attached to this report as Exhibit 1. In compliance with SB 1368 regulations, GWP is requesting the approval of the attached Compliance Filing documentation for submittal to the CEC if the Alternative Repowering is approved. 3

4 California Environmental Quality Act Because Glendale retains its 2019 off ramp rights, an approval of the Alternative Repowering depends upon the approval of the IPP Coordinating Committee members, the Glendale City Council s decision to allow GWP to vote in favor of the Alternative Repowering does not commit Glendale to a definite course of action and is not a project under CEQA. However, assuming that the City Council s authorization for the General Manager of GWP to vote in favor of the Alternative Repowering is a project under the California Environmental Quality Act (CEQA), the action is exempt from CEQA for the following reasons: 1. The authorization to vote for the proposed Alternative Repowering would not have a significant effect on the environment and is therefore exempt from CEQA under the common sense exemption set forth in CEQA Guidelines section 15601(b)(3). 2. The authorization for the Alternative Repowering is categorically exempt pursuant to CEQA Guidelines section as a minor alternation to an existing facility used to provide electric power. 3. The authorization for the Alternative Repowering is categorically exempt pursuant to CEQA Guidelines section as a replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity. The proposed Alternative Repowering would replace 1,800 MW of coal-fired electric generation units with not more than 840 MW of gas-fired electric generation units. The nature gas units would utilize existing infrastructure, staffing, and transmission assets as much as possible. 4. No unusual circumstances exist and thus the categorical exemptions are not subject to any applicable exceptions. IPA s existing project has been in operation since the 1980s, and the proposed Alternative Repowering would reduce air emissions compared to baseline conditions. There is nothing unusual about the contracts or the proposed repowering. The submittal of the CEC compliance filing is exempt from CEQA pursuant to Section (c)(1) of the CEQA Guidelines. In accordance with this section, an activity is not subject to CEQA if it does not involve the exercise of discretionary powers by a public agency. The submittal of the CEC filing as required by SB 1368 is not an action subject to CEQA. FISCAL IMPACT The Alternative Repowering will reduce the cost of the IPP repowering and Glendale s share thereof. Glendale is obligated under the renewal contracts to pay for its share of studies that are necessary to continue the planning process for the Project or the Alternative Repowering, if elected. Glendale has budgeted funds for its share of the cost of studies to be performed under The total costs to Glendale for the Project or the Alternative Repowering will depend upon the ultimate size and design of the facility. The cost estimates will be determined in greater detail well before construction commences and will be brought back to the City Council for its consideration. The Compliance Filing satisfies a regulatory requirement at no cost to Glendale. 4

5 ALTERNATIVES With regard to the approval of the Alternative Repowering, the City Council may authorize the General Manager of GWP to vote in favor of the Alternative Repowering, or it may decline to do so. If the Alternative Repowering is not approved by the IPP Coordinating Committee members, the IPP repowering project will remain at 1,200 MW. With regard to the CEC Compliance Filing, because this Compliance Filing is a regulatory requirement, no other alternatives were considered. CAMPAIGN DISCLOSURE. Not Applicable. EXHIBIT(S) Exhibit 1: Proposed California Energy Commission Compliance Filing 5

6 MOTION Moved by Council Member, seconded by Council Member,the Council of the City of Glendale hereby authorizes the General Manager of Glendale Water & Power (GWP), or his designee, to vote in favor of the proposed Alternative Repowering for the Intermountain Power Project (IPP) at the IPP Coordinating Committee Meeting. The Alternative Repowering would reduce the size of the proposed repowering from I,200 MW to 840 MW of natural gas fired generation. The City Council further finds that this authorization does not commit Glendale to a definite course of action, and, such, is not a uproject~ under the California Environmental Quality Act ( CEQA ) as defined in Section of the CEQA Guidelines. The City Council further finds that if the authorization to vote in favor of the Alternative Repowering were a project under CEQA, the action is categorically exempt from CEQA because the proposed Alternative Repowering: (i) (N) (in) (iv) is a minor alteration to an existing facility used to provide electric power, in accordance with CEQA Guidelines section 15301; is a replacement or reconstruction of existing utility systems and/or facilities involving negligible or no expansion of capacity, pursuant to CEQA Guidelines section 15302; would not have a significant effect on the environment and would reduce air emissions compared to baseline conditions; and no unusual circumstances exist and thus the categorical exemptions are not subject to any applicable exception under CEQA. Ayes: Noes: Absent: Abstain: /1? 4~J9QVED 4LSTO FORM ~CIPAL AS>STANT CITY ATTØQRNEY DATEJ#~oJ?I -in! 4E1

7 RESOLUTION NO. A RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA APPROVING AN EMISSIONS PERFORMANCE STANDARD COMPLIANCE FILING FOR SUBMITTAL TO THE CALIFORNIA ENERGY COMMISSION IN CONNECTION WITH THE ALTERNATIVE REPOWERING OF THE INTNERMOUNTAIN POWER PROJECT, AND AUTHORIZING THE GENERAL MANAGER OF GLENDALE WATER & POWER TO SUBMIT SUCH FILING TO THE CALIFORNIA ENERGY COMMISSION WHEREAS, in 1980, the City of Glendale entered into a long-term agreement with the Intermountain Power Agency ( IPA ) for the purchase of a share of the coalfired generation from the lntermountain Power Project ( IPP ) and transmission rights from Delta, Utah, to Southern California; and WHEREAS, on February 1, 1983, Glendale and IPA entered into an Amendatory Power Sales Contract as an amendment to the Power Sales Contract; and WHEREAS, pursuant to Resolution No dated June 16, 2015, the City Council authorized the Second Amendatory Power Sales Contract amending the Amendatory Power Sales Contract, and further authorized the City Manager to enter into the Renewal Power Sales Contract and the Agreement for Sale of Renewal Excess Power (Renewal Contracts); and WHEREAS, IPP has been operating as a coal4ired power plant for over 30 years owned by IPA and operated by the Los Angeles Department of Water & Power (LADWP) as Project Manager and Operating Agent on IPA s behalf; and WHEREAS, the Renewal Contracts for IPP generation are subject to the California Energy Commission s (CEC) Emission Performance Standard regulations (EPS; 20 CCR 2900 et seq.), including the requirement in 20 CCR 2909) that a publicly-owned utility submit a compliance filing with the CEC within 10 business days of entering into a covered procurement as therein defined (Compliance Filing); and WHEREAS, the Second Amendatory Power Sales Contract provides for the ability to repower IPP s fuel source from its current 1,800 megawatts (MW) net of gas fired generation to no more than 1,200 MW of EPS-compliant natural gas-fired combined cycle generation; and WHEREAS, on November 9,2016, pursuant to Order No , the CEC found Glendale s October 19, 2016 compliance filing to be complete and concurred that Glendale s Second Amendatory Power Sales Contract with IPA for the proposed 1 4E2

8 repowering of IPP from its current 1,800 MW of coal4ired generation to approximately 1,200 MW of EPS-compliant natural gas-fired combined cycle generation to be EPS compliant; and WHEREAS, the Second Amendatory Power Sales Contract, and Renewal Contracts also allow for an Alternative Repowering to modify or further reduce the 1,200 MW of EPS-compliant natural gas4ired combined cycle generation; and WHEREAS, Glendale and the other IPP participants are considering a future, vote on an Alternative Repowering resulting in EPS-compliant natural gas-fired combined cycle generation with a reduced output of 840 MW; and WHEREAS, the EPS regulations require that a Compliance Filing be first approved by the City Council prior to submitting it to the CEC; and WHEREAS, based upon the City Council s knowledge, information or belief, the Compliance Filing attached as Attachment ito the July 17, 2018 Report to the City Council, and on file with the City Clerk, does not contain a material misstatement or omission of fact and the Alternative Repowering complies with the EPS Regulations. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA: SECTION 1. The Compliance Filing regarding the Alternative Repowering for a reduced output of 840 MW attached as Exhibit Ito the July 17, 2018 Report to the City Council, and on file with the City Clerk, be and the same is hereby approved. SECTION 2. The Council does hereby authorize the General Manager of GWP or such other person as the General Manager shall designate in writing, to execute and submit the Compliance Filing and any all other related documents and instruments to the CEC. SECTION 3. This action is exempt from the requirements of the California Environmental Quality Act ( CEQA ) pursuant to Sections 15060(c)(i) and of the CEQA Guidelines. Adopted this day of, ATTEST: Mayor City Clerk TO FORM 2

9 STATE OF CALIFORNIA COUNTY OF LOS ANGELES CITY OF GLENDALE I, Ardashes Kassakhian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No. was duly adopted by the Council of the City of Glendale, California, at a regular meeting held on the day of 2018 and that the same was adopted by the following vote: Ayes: Noes: Absent: Abstain: City Clerk 3

10 EXITWIT 1 [GWP Letterhead] [DATE], 2018 California Energy Commission EPS Compliance 1516 Ninth Street Sacramento, CA Attn: Compliance Filing Subject: EPS Compliance Filing for the Intermountain Power Project Repowering Project Dear Sir or Madam: Summary The City of Glendale ( Glendale ) hereby submits this attached, updated Compliance Filing package, seeking California Energy Commission (CEC) approval of the Compliance Filing for the Intermountain power Project (IPP) Repowering Project as required by Senate Bill (SB) The Intermountain Power Agency (WA) holds legal title to the IPP, which currently includes two 900 W (net) coal generation units located near Delta, Utah. Glendale, along with other municipal and cooperative entities (Purchasers) buy IPP s energy. Glendale submitted a prior Compliance Filing package for the IPP Repowering Project to the CEC in October of 2016, which was approved by the CEC pursuant to Order No In addition, in October of 2016, LADWP submitted a Compliance Filing package for the IPP Repowering Project which was approved by the CEC pursuant to Order No In that order, the CEC approved replacing IPP s combined 1,800 MW coal generating units with SB 1368 Emission Performance Standard (EPS) complaint Natural Gas Combined Cycle (NGCC) units totaling 1,200 MW. Since then, Glendale, IPA and the other Purchasers have evaluated the needs of the IPP participants and have determined that those needs would be best addressed with an advanced class gas turbine with a reduced total output from the 1,200 MW to 840 MW. The reduction in output will allow for additional capacity on the transmission lines associated with IPP for renewable energy integration, while still maintaining the minimum required dispatchable generation necessary to support the HVDC Transmission System that connects Utah and the Intcrmountain West region with California. Background WA, a political subdivision of the State of Utah, began construction of IPP in October 1981, with commercial operation of Unit 1 commencing in June, 1986 and of Unit 2 in May, Each Purchaser s share of IPP s generation was established by a Power Sales Contract, as entered into between IPA and the Purchasers. The Purchasers include 23 Utah municipalities, six Rural Electric Cooperatives, and six California municipalities as follows:

11 UTAH MUMCIPAL UTAH COOPERATIVE CALIFORNIA PURCAHSERS: PURCHASERS: PURCHASERS: Beaver Bridger Valley REA Anaheim Bountiful Dixie-Escalante REA Burbank Enterprise Flowell Electric Assoc. Glendale Ephraim Garkane Power Assoc. LADWP Fairview Moon Lake Elec. Assoc. Pasadena Fillmore Mt. Wheeler Power, Inc. Riverside Heber Holden Hurricane Hyrum Kanosh Kaysville Lehi Logan Meadow Monroe Morgan Mt. Pleasant Muffay Oak City Parowan Price Spring City Although the Power Sales Contracts will expire on June 15, 2027, those contracts required WA to offer the Purchasers the right to continue participating in an IPP repowering beyond that date by entering into the Renewal Power Sales contracts and the Agreement for Sale of Renewal Excess Power (Renewal Contracts). Subsequent to the CEC s approval of the IPP Repowering Project and Glendale s Second Amendatory Power Sales Contract with IPA pursuant to Order Nos and ; Glendale and the Purchasers entered into the Renewal Contracts in early Alternative Repowering of the IPP Repowering Project Pursuant to the current Power Sales Contracts, which provide for the previously approved EPS-compliant IPP Repowering Project, an Alternative Repowering is also permitted in the event Purchasers choose that course. Accordingly, the Purchasers have exercised the desire for an Alternative Repowering to reduce the previously approved IPP Repowering Project for 1,200 MW of EPS-compliant NGCC to 840 MW of EPS-compliant NGCC. Based upon the generation power blocks currently on the market, there are three (3) options for this generation output and generation type, as summarized in Attachment A. Attachment A is based entirely on information received from LADWP, the operating agent for IPP.

12 Compliance Filing Pursuant to 20 CCR section 2900 et seq., of the California Code of Regulations, adopted by the CEC to implement Senate Bill 1368, Glendale hereby submits the attached Compliance Filing. Glendale respectfully requests that the CEC determine that the Alternative Repowering of the previously-approved JPP Repowering Project is similarly in compliance with the EPS regulations promulgated by the CEC. The CEC Compliance Filing is shown as Attachment A. Attachment B includes Glendale City Council Resolution No., adopted on [DATE], approving the submission of the Compliance Filing to the CEC. Attachment C is the attestation required by 20 CCR If the CEC has any questions or requests additional information regarding this coal divestiture and EPS compliant repowering, please contact Mark Young, Integrated Resource Planning Administrator for Glendale Water & Power, at (818) Sincerely, Stephen M. Zurn General Manager, Glendale Water & Power Attachments

13 Attachment A CALIFORNIA ENERGY COMMISSION EMISSION PERFORMANCE STANDARD COMPLIANCE FILING Name of Facility: Intermountain Power Project DESCRIPTION OF IPP REPOWERING PROJECT Location of Facility: 850 W Brush Weliman Road, Delta Utah ProDosed Technology!FueI: Natural Gas-Fired Combined Cycle Generating Facility Planned Commercial Operation Date: July 1,2025 Generation Configuration Options: Preliminary Rated Capacity and CO2 emission estimates were developed from vendor data with station service loads and long term degradation applied for the IPP Repowering Project at site conditions ot 102 F, 9.7% RH, and an elevation of 4760ff. with evaporative inlet cooling. The combined unit output will be limited to a maximum of 840 MW Net. Prime Mover lxi Combined Cycle lxi Combined Cycle lxi Combined Cycle Quantity Manufacturer GE Siemens Mitsubishi Model 7HA.02 SGT6-9000HL M5OIJAC Rated Capacity (MW), at IPP 435 each, 870 total 430 each, 860 total 451 each, 902 total Fuel Used Natural Gas Natural Gas Natural Gas EPS Compliant Yes Yes Yes Expected Operating Profile See Figure 3 See Figure 3 See Figure 3 Expected energy output (MWh) See Figure 3 See Figure 3 See Figure 3 Expected fuel use profile See Figure 4 See Figure 5 See Figure 6 Estimated CO2 emissions for site conditions, (lbs/mwh) Estimated CO2 emissions after derate Power Purchase Contract Terms Figure 1 - Generation configuration Options. Name of Counter Party: Intermountain Power Agency (IPA) Length of Renewal Power Sales Contract: 50 years Duration: July 1,2027 June 15, 2077 Product: Energy (MWh)

14 Capacity for Project: 840 MW2 Capacity for Participants: Below in Figure 2, is the subscribed generation entitlement for each Participant under the Renewal Power Sales Contracts. SHARE OF 840 MW Burbank 4.167% 35 Glendale 4.167% 35 LADWP % 544 Pasadena 1.667% 14 Riverside 4.167% 35 GROUP TOTAL % 663 GROUP TOTAL % I 118 I PURCHASER TOTAL % I 840 I Expected Deliverables: Please refer to Figure 2 Must Take Provisions: Please refer to Figure 2 Dispatch Provisions: It is assumed that LADWP will continue its responsibilities as the Operating Agent for the repowered IPP units, and will continue to be responsible for the dispatch of the IPP units based on Participant and system demand. Unit Contingency: N/A Expected Operating Profiles: A simulation of the load profile performed by LADWP staff is below in Figure 3 utilizing the GE configuration. The Siemens and Mitsubishi options will follow similar profiles as the heat rates and other characteristics are comparable. The load profile was used to derive the average estimated energy output per year as shown below: Energy Output (MWh): 5,003,712 Figure 2 - Generation Distribution The average annual capacity factor for all manufacturers is 68%. 2 The Project size per the Partnership needs is limited to 840 MW Net The Generation Scenarios listed above are based on the available generation sizes from the 3 respective vendors.

15 Avg Monthly Block Dispatch % <,~ _ _ -. a -iv, Mvt~ ADd May PS. lwv O~X.r Dtcefle. 0 9$ Figure 3 - Average Monthly Block Dispatch ExDected Fuel Use Profile: Below is the preliminary fuel use data received from each respective vendor, conditions. estimated for the IPP site GE - Estimated Combined Cycle Data for IPP Repowering All data estimated for site conditions, no duct firing, cooling towers Evaporative Cooling On Off Off Off Load 100% 100% 80% 60% Net Block Output MW Block Heat Input (HF-PIt) MMBTU/h 2,794 2,484 2,073 1,704 CO2 Emissions lbs/mwh Figure 4 - GE Fuel Use Profile (from vendor data)

16 Siemens - Estimated Combined Cycle Data for PP Repo~ering All data estimated for site conditions, no duct firing, cooling towers Evaporative Cooling On Off Off Off Load 100% 100% 80% 60% Net Block Output MW Block Heat Input (HF-tv) MMBTU/h 2,776 2,475 2,124 1,756 CO2 Emissions Ibs/MWh Figure 5 - Siemens Fuel Use Profile (from vendor data) Mistubishi - Estimated Combined Cycle Data for IPP Repowering All data estimated for site conditions, no duct firing, cooling towers Evaporative Cooling On Off Off Off Load 100% 100% 80% 60% Net Block Output MW Block Heat Input (HH~i) MMBTU/h 2,942 2,720 2,282 1,860 C02 Emissions lbs/mwh Figure 6 - Mitsubishi Fuel Use Profile (from vendor data)

17 Data from Existing Plant Apex Generating Station Below in Figure 7 is average hourly data extracted from LADWP s Apex Generating Station located in Clark County, Nevada. The plant consists of a GE MS7000FA 527 MW 2x1 Combined Cycle generating station. The total energy output for the plant in 2015 was 2,635,293 MW!,, with a resultant capacity factor of 57%. Apex-Data Figure 7 - Apex 2015 Load Profile Load 100% 90% 80% 70% 60% 50% 40% 30% Net PlantOutput MW C02 Emissions lbs/mwh ,031 1,084 Figure 8-Apex 2015 Fuel Use Profile

18 ATTACHMENT B California Energy Commission Emissions Performance Standard Compliance Filing [PLACEHOLDER FOR CITY COUNCIL RESOLUTION APPROVING COMPLIANCE FILING TO BE ATTACHED BEFORE SUBMISSION TO CEC]

19 ATTACHMENT C California Energy Commission Emissions Performance Standard Compliance Filing COMPLIANCE FILING ATTESTATION 1, the official named below, certi& under penalty of perjury, the following: 1. I am an agent of the City of Glendale (Glendale) authorized by the Glendale City Council (Council) to sign this attestation on its behalf; 2. The Council has reviewed and approved in noticed public meetings both the covered procurement (on June 16, 2015) and the Compliance Filing (on [July 17, 2018]), to which this attestation is attached; 3. Based on the Council s knowledge, information, and belief, the Compliance Filing does not contain a material misstatement or omission of fact; 4. Based on the Council s knowledge, information, or belief, the covered procurement complies with Title 20, Division 2, Chapter 11, Article I of the California Code of Regulations; and 5. The covered procurement contains the contractual terms or conditions specif~ ing that the contract or commitment is void and al energy deliveries shall be terminated no later than the effective date of any CEC decision pursuant to 20 CCR section 2910 that the covered procurement fails to comply with 20 CCR section 2900 e seq. Executed this th day of 2018 at Glendale, California. Stephen M. Zurn General Manager, Glendale Water & Power City of Glendale