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Agenda packet, first session

Glendale City Council
August 9, 2022

Document
Agenda packet, first session
Meeting
August 9, 2022
Body
Glendale City Council
Original file
3.2 MB
Text extracted from the city's file for reading and search. Open the original on glendaleca.primegov.com. That file is the official record.

A G E N D A

GLENDALE CITY COUNCIL

COUNCIL CHAMBERS
613 E. Broadway, 2nd Floor
Glendale, CA 91206
Meetings are broadcast live on Glendale TV, viewable on Spectrum Cable, channel 6, and AT&T U- verse, channel 99. Meetings are also streamed live in high definition (HD) on the city's webpage, glendaleca.gov/live , on YouTube.com/myglendale , and on Apple TV, Roku, and Amazon Fire devices using a free app called Screenweave and choosing “Glendale TV” from the menu. Meetings are also archived on the City Website for viewing anytime at glendaleca.gov/agendas . Call (818) 548-4013 for program schedules. DVDs of the proceedings are available for purchase in the City Clerk's Office.

For public comments and questions during the meeting, call (818) 937-8100. Public comments on a specific agenda item will be taken when that agenda item is discussed. If you have any question about matters on the agenda, or requests for assistance, please contact the City Clerk at (818) 548-2090 during regular business hours.

PLEASE TURN OFF CELLULAR PHONES WHILE INSIDE THE MEETING LOCATION In compliance with the Americans with Disabilities Act (ADA) of 1990, auxiliary hearing aids, sign language translation, and Braille transcripts are available upon request. Assisted listening devices are available same-day upon request. At least 48 hours (or two business days) notice is required for requests regarding sign language translation and Braille transcription services. All documents related to open session items on this agenda that are received less than 72 hours prior to this meeting, and are public records, will be available for review in the Office of the City Clerk, 613 E. Broadway, RM 110, Glendale, CA 91206.

Translation services are provided for meetings through the use of bilingual staff for speakers who wish to utilize the service as available. Speakers should state their request by contacting the City Clerk’s office at (818) 548-2090, at least 24 hours prior to the scheduled meeting. Please specify the language for which you require translation. The exclusive use of City provided interpreters is not required and persons are welcome to use their own interpreter or speak in their native language.

AUGUST 9, 2022

REVISED
- Closed Session start time was revised
- Item 4b was removed
- Item 8c was added

ROLL CALL
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1. CLOSED SESSION – 1:00 PM (To Commence at 2:00 PM )
a. Conference with Legal Counsel – Pending Litigation: Dickinson v. City of Glendale, L.A.S.C. Case No. 21STCV08281
b. Public Employee Performance Evaluation – City Manager and City Attorney c. Conference with Legal Counsel – Anticipated Litigation: Significant exposure litigation pursuant to paragraph subdivisions (d)(2) and (e)(2) of Section 54956.9:

One (1) potential case
d. Conference with real property negotiators: Property location – Real property generally located at the terminus of New York Avenue near Park Vista Drive, commonly referred to as “Mountain Oaks.” Negotiating parties: F.E. & M. Inc.

Employee’s Defined Contribution Plan Trust dated July 10, 1984. Agency negotiators attending the closed session are: Roubik Golanian, Michael J. Garcia, Gillian van Muyden, John Takhtalian, Silvio Lanzas, Jason Bradford, Christine Powers and Onnig Bulanikian. Instructions to the negotiator(s) will concern the price and terms for the acquisition of property
e. Conference with Legal Counsel - Pending Litigation: F.E. & M. Inc. Employee’s Defined Contribution Plan Trust dated July 10, 1984 v. City of Glendale et al., L.A.S.C.

Case No. BS16989

2. REGULAR BUSINESS AGENDA – 6:00 PM
Roll Call
a. Flag Salute: Mayor Kassakhian
b. Invocation: Suzie Abajian, City Clerk
c. Report of City Clerk, re: Posting of Agenda. The Agenda for the August 9, 2022 Regular Meeting of the Glendale City Council was Posted on August 2, 2022 on the Bulletin Board Outside City Hall.

3. PRESENTATIONS AND APPOINTMENTS
a. Agenda Preview for the Meetings of Tuesday, August 16, 2022

4. CONSENT ITEMS (Including Minutes)
The following are Routine and May be Acted Upon by One Motion. Any Member of Council or the Audience Requesting Separate Consideration May do so by Making Such Request Before Motion is Proposed.
a. Police Department, re: California Governor’s Office of Emergency Services Paul Coverdell Forensic Science Improvement Program, Request for Authorization to Accept Grant Funds in the amount of $57,622 to be used for equipment and training for the Verdugo Regional Crime Laboratory

1. Motion authorizing acceptance of the 2021 Paul Coverdell Forensic Science Improvement Grant and authorizing the City Manager, or a designee, to execute the necessary agreements, certification, and other documents required to accept the Grant

2. Resolution of Appropriation in the amount of $57,622 in 2021 Paul Coverdell Forensic Science Improvement Grant funds
b. Libraries, Arts, and Culture, re: Acceptance of grant funds for Public Librarian Diversity Residency Program from the California State Library

1. Motion accepting $100,000 in Library Services and Technology Act (LSTA) grant program funds from the California State Library to enable Glendale Library, Arts & Culture (GLAC) to add two new unclassified Librarian positions under GLAC’s Public 2 TYPED 8/3/2022 5:57:14 PM
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Librarian Diversity Residency Program, and authorizing the City Manager or a designee to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding

2. Resolution appropriating $100,000 from the California State Library, Library Services and Technology Act (LSTA) grant program and $100,000 in matching funds to be appropriated from the Library Mitigation Fee Fund
c. Libraries, Arts, and Culture, re: Acceptance of Grant Funds for Community Connections Collaborative grant from the California State Library

1. Motion accepting $71,257 in Community Connections Collaborative grant funds from the California State Library, which are being provided and administered by Califa Group, to enable the Director of Library, Arts and Culture to carry out the Community Connections Collaborative project and to add a part-time Community Resource Specialist to connect the public with available social services; and authorizing the City Manager or a designee to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding

2. Resolution appropriating $71,257 from the California State Library d. Management Services, re: Audit Committee Annual Report and Internal Audit Work Plan

1. Motion to note and file Fiscal Year 2021-22 Audit Committee Annual Report for the period of July 1, 2021 to June 30, 2022

2. Motion to note and file Fiscal Year 2022-23 Internal Audit Work Plan for the period of July 1, 2022 to June 30, 2023

5. CITY COUNCIL/STAFF COMMENTS

6. COMMUNITY EVENT ANNOUNCEMENTS (3-Minutes)

7. ADOPTION OF ORDINANCES

8. ACTION ITEMS
a. Glendale Water and Power, re: Glendale Water & Power (GWP) Energy Risk Management Policy and Trading Authority Policy

1. Motion approving amendments to the GWP Energy Risk Management Policy

2. Motion approving amendments to the GWP Trading Authority Policy. b. City Attorney, re: Review and Reconsideration of Temporary Cap on Fees Charged by Third-Party Food Delivery Applications

1. Motion to Note and File

2. Resolution Repealing Resolution No 20-63 and Terminating the Emergency Public Order Imposing a Temporary Limit on Commission Fees Charged by Third-Party Delivery Applications on Businesses in Glendale

3. Motion Providing Direction to Staff
c. Police Department, re: Request regarding the acceptance of grant funding from the United States Department of Homeland Security 2021 Urban Area Security Initiatives (UASI) Grant Program

1. Resolution to accept grant funds in the amount of $1,454,709 and authorize the City Manager, or his designee, to execute an agreement with the City of Los Angeles for the award of funds under the FY21 UASI grant program

2. Resolution to dispense with competitive bidding and authorize the Deputy Director of Finance-Purchasing to issue a purchase order with Platinum Simulators Inc. for (1) the 3 TYPED 8/3/2022 5:57:14 PM
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procurement of flight simulator equipment in an amount not to exceed $209,000 for the initial purchase; and (2) thereafter, for the life of the equipment, if the funds for the continued maintenance, support, updates, upgrades, and licensing of the simulator are appropriated within the Police Department’s budget and approved by the City Council as part of the annual citywide budget process

3. Resolution to appropriate $1,454,709 from the Urban Area Security Initiatives (UASI) Grant Program grant revenue and $34,150 from Asset Forfeiture Public Safety

9. HEARINGS

10. REPORTS - INFORMATION

11. WRITTEN COMMUNICATIONS

12. ORAL COMMUNICATIONS
Discussion is Limited to Items NOT a Part of this Agenda. Each Speaker is Allowed 5 minutes. Council May Question or Respond to The Speaker But There Will be no Debate or Decision. The City Manager May Refer the Matter to the Appropriate Department for Investigation and Report.

13. NEW BUSINESS

14. ADJOURNMENT
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4a

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: California Governor’s Office of Emergency Services Paul Coverdell Forensic Science Improvement Program, Request for Authorization to Accept Grant Funds in the amount of $57,622 to be used for equipment and training for the Verdugo Regional Crime Laboratory.

1. Motion authorizing acceptance of the 2021 Paul Coverdell Forensic Science Improvement Grant and authorizing the City Manager, or a designee, to execute the necessary agreements, certification, and other documents required to accept the Grant.

2. Resolution of Appropriation in the amount of $57,622 in 2021 Paul Coverdell Forensic Science Improvement Grant funds.

COUNCIL ACTION
Item Type: Consent Calendar
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
The Glendale Police Department requests acceptance of $57,622 in grant funds from the California Governor’s Office of Emergency Services (Cal OES) for the grant period of April 1, 2022 to June 30, 2023, to be used for equipment, laboratory supplies and training in the Verdugo Regional Crime Laboratory (VRCL).
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COUNCIL PRIORITIES
N/A

RECOMMENDATION
Accept the 2021 Paul Coverdell Forensic Science Improvement Grant funds in the amount of $57,622, authorize the City Manager to execute the necessary agreements, certification, and other documents required to implement the Grant, and adopt a resolution to appropriate the funds for equipment, laboratory supplies, and training.

BACKGROUND
In June 2021, an application seeking grant funds was submitted to the California Governor’s Office of Emergency Services to improve the quality and timeliness of the case processing provided by the Police Department’s Verdugo Regional Crime Laboratory (“Laboratory”). The Police Department was recently notified that its application was approved in the amount of $57,622 as part of the Paul Coverdell Forensic Science Improvement Program. Grant funds will be used to outfit additional examination workstations, replace aging equipment, and provide training to ensure that the laboratory is meeting forensic quality standards.

ANALYSIS
In applying for the grant, the Laboratory conducted a needs assessment and identified equipment, materials and training required to fulfill the grant objectives of improved forensic testing services.

The Laboratory recently remodeled existing office and miscellaneous space to expand laboratory examination space. The new examination space included expanded DNA testing facilities, an additional room for logging crime scene evidence, and a new computer forensic examination laboratory. All renovations have been completed, but some examination spaces are lacking laboratory grade furnishings and equipment. Grant funds will be used to purchase laboratory furniture and equipment in order to enable multiple concurrent examinations. In addition, the Laboratory will replace aging equipment/computer tablets utilized for crime scene documentation.

Grant funds will also be utilized to provide training that will improve the quality of forensic testing services. Continuous self-evaluation and updates improve overall laboratory quality and timeliness of forensic services.

STAKEHOLDERS/OUTREACH
Grant funds will be used to improve the quality of forensic testing services provided to customer agencies and the public.

FISCAL IMPACT
The 2021 Paul Coverdell Forensic Science Improvement Grant funds in the amount of $57,622, were not included as part of the FY2022-23 approved budget. Therefore, staff 6 of 161
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requests an appropriation of $57,622 from grant revenue. The appropriation request is outlined below:

Requesting Appropriation
Amount From (Account
String)
To (Account String) Funding Source
$57,622 GL: 31240-2610-
GPD-0020
PL: GPD00801AG
Police Special Grant
Fund – Federal
Funding
$1,345 GL: 44650-2610-
GPD-0020
PL: GPD00801AG
Police Special Grant
Fund – Training
$26,850 GL: 45150-2610-
GPD-0020
PL: GPD00801AG
Police Special Grant
Fund –
Furniture/Equipment
$6,900 GL: 45350-2610-
GPD-0020
PL: GPD00801AG
Police Special Grant
Fund – General
Supplies
$22,527 GL: 51000-2610-
GPD-0020
PL: GPD00801AG
Police Special Grant
Fund – Capital
Outlay

ENVIRONMENTAL REVIEW (CEQA/NEPA)
This item is considered a ministerial activity and therefore, not subjected to CEQA/NEPA review. There is no possibility that the acceptance of this award may have a significant effect on the environment. (14 Cal. Code Regs. § 15061(b)(3)).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES
Alternative 1: Approve as requested by the Police Department.

Alternative 2: Deny the Police Department’s request. Expenses for capital outlay, furniture, equipment and training would be absorbed by the Police Department budget.

Alternative 3: The City Council may consider any other alternative not proposed by staff. 7 of 161
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ADMINISTRATIVE ACTION
Prepared by:

Catherine Nguyen, Lab Director
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
None.
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M O T I O N
Moved by Council Member ________________________________, seconded by Council Member ___________________________________, that the City of Glendale hereby approves participation in the Paul Coverdell Forensic Science Improvement Program offered by the California Governor’s Office of Emergency Services and accepts grant funds in the sum of $57,622 to be used for the purchase of equipment, furniture, and training for the Verdugo Regional Crime Laboratory, as set forth in the Report to the City Council dated August 9, 2022. The City Manager, or a designee, is hereby authorized to execute the necessary agreements, certification, and other documents required to accept and implement the grant.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION NO. ___________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE

MAKING AN APPROPRIATION
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $57,622 is hereby appropriated and/or transferred from the following accounts to the following accounts:

ACCOUNTS DESCRIPTION FROM TO
31240-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00801AG
44650-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00801AG
45150-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00801AG
45350-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00801AG
51000-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00801AG
Federal Grants, Police Special Grant Fund,
Glendale Police, Projects,
FY2021 Coverdell Forensic Grant
Training, Police Special Grant Fund,
Glendale Police, Projects,
FY2021 Coverdell Forensic Grant
Furniture & Equipment, Police Special Grant
Fund, Glendale Police, Projects,
FY2021 Coverdell Forensic Grant
General Supplies, Police Special Grant Fund,
Glendale Police, Projects,
FY2021 Coverdell Forensic Grant
Capital Outlay, Police Special Grant Fund,
Glendale Police, Projects,
FY2021 Coverdell Forensic Grant
$57,622
$1,345
$26,850
$6,900
$22,527

To appropriate funds for the FY21 Paul Coverdell Forensic Science Improvement Grant for equipment and training for the Verdugo Regional Crime Laboratory.

SECTION 2: The Director of Finance / Information Technology is authorized to make such other revisions, individual appropriation line-items, changes in summaries, fund totals, grand totals, and other portions of the budget document as necessary to reflect and implement the changes specified in this resolution.

SECTION 3: The City Clerk shall certify to the adoption of this Resolution.

Adopted this________day of _______________, 2022.
_______________________________
Mayor
ATTEST:
07/18/2022
_____________________________________
City Clerk 57,622
Director of Finance / Information Technology
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STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF GLENDALE )
I, Suzie Abajian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No._________was adopted by the Council of the City of Glendale, California, at a regular meeting held on the__________ day of _______________, 2022, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
________________________________
City Clerk
/
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4b

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Acceptance of grant funds for Public Librarian Diversity Residency Program from the California State Library.

1. Motion accepting $100,000 in Library Services and Technology Act (LSTA) grant program funds from the California State Library to enable Glendale Library, Arts & Culture (GLAC) to add two new unclassified Librarian positions under GLAC’s Public Librarian Diversity Residency Program, and authorizing the City Manager or a designee to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding.

2. Resolution appropriating $100,000 from the California State Library, Library Services and Technology Act (LSTA) grant program and $100,000 in matching funds to be appropriated from the Library Mitigation Fee Fund.

COUNCIL ACTION
Item Type: Consent Calendar
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
The Public Librarian Diversity Residency Program will allow Glendale Library, Arts & Culture to create two Residency positions for post-graduate Black, Indigenous, and/or People of Color (BIPOC) librarians. The Public Librarian Diversity Residency will provide first professional job experiences that prepare BIPOC Residents for long term career success as public librarians.

The $100,000 award will be used to fund one unclassified Librarian position and $100,000 in matching funds for a second Librarian position will be drawn from the Library Mitigation Fee Fund.

COUNCIL PRIORITIES
Housing: The Public Librarian Diversity Residency Program will increase Library workforce which will help assist community members with a variety of needs, including directing them to available social services and housing resources. 12 of 161
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RECOMMENDATION
Glendale Library, Arts & Culture recommends that the City Council approve (1) a Motion accepting grant funds in the amount of $100,000 from the California State Library to enable the department to add two new unclassified Librarian positions under its Public Librarian Diversity Residency Program, and (2) a Resolution appropriating funds for the Public Librarian Diversity Residency Program.

BACKGROUND
Glendale Library, Arts & Culture and the library profession as a whole struggle to recruit and retain non-White librarians. Additionally, attrition rates for BIPOC librarians is greater than the overall attrition rate for the profession (Diversity Counts, ALA, 2007). To counter this trend, Glendale Library, Arts & Culture have developed a Public Librarian Diversity Residency program. It will rely on the Association of College & Research Libraries Diversity Residency Toolkit, which was created by BIPOC librarians with experience in diversity-focused residencies. The Toolkit recommends a “resident centered framework” that makes the resident the primary audience and benefactor of the program; therefore, our primary goal is to provide first librarian-level job experiences that support and prepare BIPOC Residents for long term success as public librarians. This goal will ensure that equity, diversity, inclusion and belonging guide planning, implementation and evaluation of the program.

Glendale Library, Arts & Culture’s mission is: “We Rise2 Meet Our Communities Challenges.” The Public Librarian Diversity Residency program aligns with multiple aspects of the Glendale Library, Arts & Culture Strategic Plan:

Remember & Reflect: “Reflect our community’s diversity” Inform & Inspire: “Nurture staff to be proud library ambassadors” and “Provide meaningful and quality training for staff”
Sustain & Support: “Create a learning organization”
Empower & Engage: “Be champions of social justice and anti-racism" The City of Glendale passed a Sundown Town Resolution in 2020, acknowledging and apologizing for Glendale’s racist past, and pledging to work towards an anti-racist future.

The resolution solidified the City’s aspiration to become an antiracist organization.

Glendale Library, Arts & Culture has been a leader in the City in this regard and the Public Librarian Diversity Residency program would continue to further this work.

ANALYSIS
The Public Librarian Diversity Residency is based on a successful model developed in academic libraries. It will consist of two (2) residency Librarian positions, which will be supported by mentoring, training, and professional development opportunities. 13 of 161
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The Public Librarian Diversity Residency will build on the lessons learned in academic diversity residency programs and focus on engaging and retaining BIPOC librarians in public librarianship. The Residency Interest Group of the Association of College and Research Libraries developed a Diversity Residency Toolkit that GLAC will use as a model.

The Public Librarian Diversity Residency will have a robust support system for Residents, including:
A Residency Coordinator managing the program,
A Residency Steering Committee giving input on program design and improvements and serving as resources to the Residents, Direct Supervisors co-creating Resident’s goals and managing work, and Mentors providing individual support on an on-going basis.

To ensure buy-in and to enable any manager to serve as a mentor or supervisor, all management staff will engage in training on mentoring, managing BIPOC staff, understanding microaggressions and managing conflict in the workplace. This training plan is based on the Diversity Residency Toolkit Pre-residency Checklist for Institutions.

The Steering Committee will administer and analyze surveys for Residents, Supervisors and Mentors that will drive constant program improvement. Residents will have responsibilities that align with the current GLAC Librarian job description. Residents will receive additional opportunities and funding for training and conference attendance. The Public Librarian Diversity Residency in FY22-23 will conclude with the creation of a “lessons learned” document that can be shared with other public libraries.

Budget Adjustments
Library, Arts & Culture
The Library, Arts & Culture Department is requesting the approval of two new unclassified positions: Librarian. As a result, the impact to the salaried position head count is two positions. The two new Librarians would assist patrons in every aspect of utilizing the library as well as collection management, event programming, financial transactions and other duties as assigned.

The table below summarizes the salaried FTE count:

Adopted
FY 2022-23
Proposed
FY 2022-23
All Funds 48.00 50.00
General Fund 48.00 48.00
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STAKEHOLDERS/OUTREACH
The Public Librarian Diversity Residency program will provide early professional job experiences that prepare Black, Indigenous, and/or People of Color Librarians for long term career success in public librarianship. This program will help Glendale Library, Arts & Culture to make progress on the goals of Inclusion Diversity Equity and Access (IDEA) which will help us to better serve the community.

Glendale Library, Arts & Culture is partnering with the San Jose State University School of Information (iSchool) in order to promote the program to BIPOC graduating students and recent graduates who may be interested in the Residency. The iSchool will also review the Public Librarian Diversity Residency program design and give program feedback, which is a valuable contribution since they know in detail what knowledge, skills and abilities their graduates have, and where development and support will be needed.

The iSchool plans to offer as-needed support to Residents as well and provided input and review on the grant.

FISCAL IMPACT
The Public Librarian Diversity Residency program will cost $200,000 which was not included as a part of the FY 2022-23 approved budget. Therefore, staff is requesting for an appropriation of $100,000 from Federal Grant Revenue and $100,000 in matching funds from Library Mitigation Fee Fund. The fully loaded annual cost (salaries and benefits) of the two unclassified Librarian positions in the amount of $200,000, was not included as a part of the FY2022-23 adopted budget. The appropriation requests are outlined below:

Requesting Appropriation
Amount From (Account
String)
To (Account String) Funding Source
$100,000 GL: 31240-2750-
LAC-0020-P0000
PL:LAC00861AG
GL: 41100-2750-
LAC-0020-P0000
PL: LAC00861AG
Federal Grant
Revenue
$100,000 GL: 43110-4070-
LAC-0020-P0000
PL: LAC00635AN
GL: 41100-4070-
LAC-0020-P0000
PL: LAC00635AN
Library Mitigation
Fee Fund

ENVIRONMENTAL REVIEW (CEQA/NEPA)
Because no possibility exists that the activity in question (adding two residency Librarian positions under the Public Librarian Diversity Residency Program) may have a significant effect on the environment, the activity is not subject to CEQA review under the common sense exemption set forth in 14 Cal. Code Regs. § 15061(b)(3).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements. 15 of 161
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ALTERNATIVES
Alternative 1: The City Council may adopt:
A Motion accepting California State Library grant funds to enable Glendale Library, Arts & Culture to add two new unclassified Librarian positions under its Public Librarian Diversity Residency Program, and authorizing the City Manager or a designee to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding.
A Resolution appropriating $100,000 from the California State Library, Library Services and Technology Act (LSTA) grant program with $100,000 in matching funds to be appropriated from the Library Mitigation fee fund.

Alternative 2: The City Council may decline to adopt a Motion and Resolution of Appropriation and, thus, forfeit the grant funding.

Alternative 3: The City Council may consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Prepared by:

Kristina Gerber, Library, Arts & Culture Administrative Manager Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
None
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C:\INETPUB\WWWROOT\GLENDALE\TEMP\CC_08092022_MOTION_4B1.PDF MOTION
Moved by Council Member , seconded by Council Member , that the Council of the City of Glendale hereby:

1. Accepts $100,000 in Library Services and Technology Act (LSTA) grant program funds from the California State Library to enable Glendale Library, Arts & Culture (GLAC) to add two new unclassified Librarian positions under GLAC’s Public Librarian Diversity Residency Program, as more fully outlined in the Director’s August 9, 2022 Report to the City Council; and

2. Authorizes the City Manager, or a designee, to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION NO. ___________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE

MAKING AN APPROPRIATION
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $200,000 of which $100,000 is a net increase in appropriation, is hereby appropriated and/or transferred from the following accounts to the following accounts:

ACCOUNTS DESCRIPTION FROM TO
31240-2750-LAC-0020-P0000-
LAC00861AG
41100-2750-LAC-0020-P0000-
LAC00861AG
43110-4070-LAC-0020-P0000-
LAC00635AN
41100-4070-LAC-0020-P0000-
LAC00635AN
Federal Grants, Library Fund, Library,
Arts & Culture, Projects, Public Librarian
Diversity Residency Program
Salaries, Library Fund, Library, Arts &
Culture, Projects, Public Librarian
Diversity Residency Program
Contractual Services, Library Mitigation
Fee Fund, Library, Arts & Culture,
Projects, Central Library Improvements
Salaries, Library Mitigation Fee Fund,
Library, Arts & Culture, Projects, Central
Library Improvements
$100,000
$100,000
$100,000
$100,000
To appropriate funds for the Public Librarian Diversity Residency Program to fund two unclassified Librarian positions.

SECTION 2: The Director of Finance / Information Technology is authorized to make such other revisions, individual appropriation line-items, changes in summaries, fund totals, grand totals, and other portions of the budget document as necessary to reflect and implement the changes specified in this resolution.

SECTION 3: The City Clerk shall certify to the adoption of this Resolution.

Adopted this________day of _______________, 2022.
_______________________________
Mayor
ATTEST:
7/19/22
_____________________________________
City Clerk 200,000
Director of Finance / Information Technology
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STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF GLENDALE )
I, Suzie Abajian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No._________was adopted by the Council of the City of Glendale, California, at a regular meeting held on the__________ day of _______________, 2022, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
________________________________
City Clerk
/
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4c

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Acceptance of Grant Funds for Community Connections Collaborative grant from the California State Library.

1. Motion accepting $71,257 in Community Connections Collaborative grant funds from the California State Library, which are being provided and administered by Califa Group, to enable the Director of Library, Arts and Culture to carry out the Community Connections Collaborative project and to add a part-time Community Resource Specialist to connect the public with available social services; and authorizing the City Manager or a designee to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding.

2. Resolution appropriating $71,257 from the California State Library.

COUNCIL ACTION
Item Type: Consent Calendar
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
The Community Collaborative grant will allow the Glendale Library, Arts & Culture to expand its role as a social services connector by adding a part-time Community Resource Specialist, who will work with the Library’s existing Social Service Liaison.

Library, Arts and Culture will receive $71,257 and will contract with Ascencia to provide a Community Resource Specialist to work at the Library for one year. 20 of 161
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COUNCIL PRIORITIES
Housing: The Community Connections Collaborative Project will provide social services referrals to community members with a variety of needs, including housing.

RECOMMENDATION
Staff recommend that the City Council approve the motion accepting grant funds in the amount of $71,257 from the California State Library, which will be administered by Califa Group, and a resolution appropriating the funds for the Community Connections Collaborative Project.

BACKGROUND
Library, Arts & Culture (LAC) has been successful in securing a grant from the California State Library (CSL) to support the Community Connections Collaborative project, which is a partnership between Madera County Library, Oceanside Public Library and Glendale Library, Arts and Culture, with Califa Group, a nonprofit library membership consortium, administering the grant.

In 2017, through the support of the CSL’s Mental Health Initiative grant, GLAC brought on a part-time Social Service Liaison (SSL), who connects with people experiencing homelessness and/or mental health issues at the Library and refers them to needed resources. LAC has continued the position using general fund support. The SSL assists patrons who are struggling to navigate the various programs and systems available to them and acts as a critical point of de-escalation when patrons violate the Library’s Rules of Behavior. In 2019, the SSL assessed 221 unique patrons for services, made 173 referrals to other community agencies for services, and made 878 total patron contacts.

That same year, staff completed 155 hours of mental health training and, as a result, documented 53% fewer patron behavior incidents at the Central Library than in the prior year.

In FY21-22, LAC received a six-month long Community Connections grant from CSL, allowing LAC to:
- Extend the SSL’s hours and contract with Ascencia to staff a Community Resource Specialist (CRS) at the Library, resulting in LAC connecting with 187 individuals through 751 total interactions and 97 referrals to community partners over six months. - Expand access to social services by giving community partners space to do outreach visits, providing support to more than 40 community members. - Host a Mental Health Fair with over 50 community members connecting with 15 community organizations.
- Develop a needs assessment, establish a Library-based community resource center, and participate in a community of practice with libraries throughout the state offering social services support.

The new CSL Community Connections Collaborative grant will allow the partner libraries to extend and deepen the work of the FY2021-22 CSL Community Connections grant. 21 of 161
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ANALYSIS
LAC, Madera County Library, and Oceanside Public Library will partner to extend the work initiated by the FY2021-22 Community Connections grant and create the Community Connections Collaborative project, with Califa Group administering the grant.

As part of the Community Connections Collaborative project, LAC will:
• Contract with Ascencia to provide a Community Resource Specialist (CRS) to provide referrals to needed social service assistance to Library patrons, and maintain a community resource center in the Library.
• Generate more formalized tracking and reporting on local outcomes through surveys conducted in referral consultations provided by the CRS. • Create a report evaluating the Community Connections Collaborative work. • Participate in online monthly meetings to create a Community of Practice and strengthen the efforts of the Community Connections Collaborative. • Identify new, grow existing, and formalize project partnerships with local community agencies offering critical services.
• Offer joint training with partner libraries for Library staff to build awareness of social services resources, bolster staff capacity to handle referrals and embed the work more fully into each organization.
• Host an informational webinar on implementing the Community Connections work so that other public library systems can learn from the experience.

The Community Connections Collaborative project aims to improve the quality of life of individuals and families by providing warmer hand-offs and direct referrals to vital social services. Additionally, Library staff will be more knowledgeable, confident and better equipped in being able to address the needs of the customers that they serve.

STAKEHOLDERS/OUTREACH
A key piece of the FY22-23 Community Connections grant project included LAC staff connecting with local social services organizations and providing them the opportunity to do outreach at the Central Library’s community resource office. Community Resource Center for Aging, at USC Verdugo Hills Hospital, and the Veteran Peer Access Network have both held regular outreach at Central Library, enabling them to better connect with and support community members in need. The Verdugo Jobs Center will be providing onsite outreach in September.

LAC also participates with CSP in regular Continuum of Care meetings and will include the new CRS in those meetings in order to connect with stakeholders. By continuing to work with these organizations, and extending the offer of space for regular outreach at Central Library, LAC will improve its ability to be a social services connector for community members in need.
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FISCAL IMPACT
The Community Connections Collaborative project will cost $71,257 which was not included as a part of the FY 2022-23 approved budget. Therefore, staff is requesting for an appropriation of $71,257 from the Federal Grant Revenue. The appropriation request is outlined below:

Requesting Appropriation
Amount From (Account
String)
To (Account String) Funding Source
$71,257 GL: 31240-2750-
LAC-0020-P0000-
PL: LAC00860AG
GL: 43110-2750-
LAC-0020-P0000-
PL: LAC00860AG
Federal Grant
Revenue

ENVIRONMENTAL REVIEW (CEQA/NEPA)
Because no possibility exists that the activity in question (carrying out the Community Connections Collaborative project services and adding a part-time Community Resource Specialist to connect the public with social services) may have a significant effect on the environment, the activity is not subject to CEQA review under the common sense exemption set forth in 14 Cal. Code Regs. § 15061(b)(3).

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES
Alternative 1: The City Council may elect to approve a motion to accept grant funds in the amount of $71,257 from the California State Library, along with a resolution appropriating funds.

Alternative 2: The City Council may decline to adopt a Motion and Resolution of Appropriation and, thus, forfeit the grant funding.

Alternative 3: The City Council may consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION

Prepared by:

Kristina Gerber, Library, Arts & Culture Administrative Manager Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
None
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C:\INETPUB\WWWROOT\GLENDALE\TEMP\CC_08092022_MOTION_4C1.PDF MOTION
Moved by Council Member , seconded by Council Member , that the Council of the City of Glendale hereby:

1. Accepts $71,257 in Community Connections Collaborative grant funds from the California State Library, which are being provided and administered by Califa Group, to enable the Director of Library, Arts and Culture to carry out the Community Connections Collaborative project and to add a part-time Community Resource Specialist to connect the public with available social services, as more fully outlined in the Director’s August 9, 2022 Report to the City Council; and

2. Authorizes the City Manager, or a designee, to execute all agreements, amendments, certifications, and documents necessary to accept and implement the funding.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION NO. ___________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE

MAKING AN APPROPRIATION
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $71,257 is hereby appropriated and/or transferred from the following accounts to the following accounts:

ACCOUNTS DESCRIPTION FROM TO
31240-2750-LAC-0020-P0000-
LAC00860AG
43110-2750-LAC-0020-P0000-
LAC00860AG
Federal Grants, Library Fund, Library,
Arts & Culture, Projects, Community
Collections Collaborative Project
Contractual Services, Library Fund,
Library, Arts & Culture, Projects,
Community Collections Collaborative
Project
$71,257
$71,257
To appropriate funds for the Community Connections Collaborative Project.

SECTION 2: The Director of Finance / Information Technology is authorized to make such other revisions, individual appropriation line-items, changes in summaries, fund totals, grand totals, and other portions of the budget document as necessary to reflect and implement the changes specified in this resolution.

SECTION 3: The City Clerk shall certify to the adoption of this Resolution.

Adopted this________day of _______________, 2022.
_______________________________
Mayor
ATTEST:
7/19/22
_____________________________________
City Clerk 71,257

STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF GLENDALE )
I, Suzie Abajian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No._________was adopted by the Council of the City of Glendale, California, at a regular meeting held on the__________ day of _______________, 2022, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
________________________________
City Clerk
/
Director of Finance / Information Technology
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4d

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Audit Committee Annual Report and Internal Audit Work Plan

1. Motion to note and file Fiscal Year 2021-22 Audit Committee Annual Report for the period of July 1, 2021 to June 30, 2022.

2. Motion to note and file Fiscal Year 2022-23 Internal Audit Work Plan for the period of July 1, 2022 to June 30, 2023.

COUNCIL ACTION
Item Type: Consent Calendar
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
Each year, the Audit Committee must report its actions and activities to the City Council per Glendale Municipal Code Section 2.82.100 (D). The Audit Committee met four times during Fiscal Year 2021-22 where they were provided with financial and budget updates and internal audit activity reports.

Each year, Internal Audit must prepare an audit work plan based on a risk assessment per Glendale Municipal Code section 2.08.130 (A). This risk-based work plan is used to identify and prioritize high risk areas in order to select and schedule audits. The Fiscal Year 2022-23 Internal Audit Work Plan was reviewed by the Audit Committee at its July 28, 2022 meeting as required by Glendale Municipal Code section 2.82.100 (B). This work plan is comprised of 25 projects.
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COUNCIL PRIORITIES
N/A

RECOMMENDATION
Staff recommends that the City Council note and file the Fiscal Year 2021-22 Audit Committee Annual Report and the Fiscal Year 2022-23 Internal Audit Work Plan.

BACKGROUND
Fiscal Year 2021-22 Audit Committee Annual Report
Each year, the Audit Committee must report its actions and activities to the City Council per Glendale Municipal Code Section 2.82.100 (D). At its July 28, 2022 meeting, the Audit Committee approved its Fiscal Year 2021-22 Report (Exhibit 1), which covers the actions and activities of the Audit Committee for the period of July 1, 2021 through June 30, 2022. At this time, the Audit Committee is presenting this report to the City Council to satisfy the requirements of the Glendale Municipal Code. The Audit Committee met four times during Fiscal Year 2021-22 where they were provided with financial and budget updates and internal audit activity reports:
• The financial activities completed by the Audit Committee include review of the City’s financial statement audit as of and for the year ending June 30, 2021, examination of the external auditor’s communication on significant audit findings, and review of other financial and budget reports provided by Finance staff. • The internal audit activities completed by the Audit Committee include review of Fiscal Year 2021-22 Internal Audit Work Plan, review of issued internal audit reports, review of the status of audit follow-up activities including discussion of any audit recommendations not being implemented within 2 and 3 years of audit report issuance and the decision of not implementing an audit recommendation by management.

Fiscal Year 2022-23 Internal Audit Work Plan
Each year, Internal Audit must prepare an audit work plan based on a risk assessment per Glendale Municipal Code section 2.08.130 (A). Internal Audit’s plan of engagements is developed following a risk-based model that includes an annual risk assessment process and a quantitative methodology that assigns a weighted risk value to each potential audit subject area in the City. This risk-based work plan is used to identify and prioritize high risk areas in order to select and schedule audits. This work plan is a flexible and dynamic document that will be amended throughout the year in response to the ever-changing environment and risk landscape. The ongoing risk assessment will be performed through a periodic express risk survey on emerging risks and regular communications with management and the Audit Committee.

The risk assessment process includes reviewing and updating potential audit topics through discussions with key management personnel by gathering information on the 27 of 161
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operating environment. These potential audit topics are evaluated and rated for impact and likelihood in the four risk categories of financial, compliance, strategic and operational. The final risk ranking considers factors such as the City’s strategic goals and objectives, executive management’s specific concerns, explicit management requests, significant changes in operations, key areas not previously audited, and available staff resources. The plan is reviewed with the City Manager and Audit Committee prior to being presented to City Council. This year staff continued a data- driven approach in the annual risk assessment process to identify higher risk areas for audit in the coming year. Staff provided department’s third-party data along with a short risk questionnaire to help departments identify higher risk purchase orders and contracts to be audited. Staff tailored the risk assessment questionnaire to the current environment and used a survey tool to gather the assessment results.

The Fiscal Year 2022-23 Internal Audit Work Plan (Exhibit 2) was reviewed by the Audit Committee at its July 28, 2022 meeting as required by Glendale Municipal Code section

2.82.100 (B). The Fiscal Year 2022-23 Internal Audit Work Plan is comprised of 25 projects, including two carried over projects, 10 new and re-selected projects, three recurring projects, and 10 continuous auditing/on-going advisory assignments. In addition, a list of nine potential projects is included within this work plan and may be performed due to changes in risks and priorities or if all the planned audits are completed prior to the end of the fiscal year.

ANALYSIS
N/A

STAKEHOLDERS/OUTREACH
N/A

FISCAL IMPACT
There is no fiscal impact associated with this report.

ENVIRONMENTAL REVIEW (CEQA/NEPA)
N/A

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES
Alternative 1: The City Council note and file Fiscal Year 2021-22 Audit Committee Annual Report and Fiscal Year 2022-23 Internal Audit Work Plan as presented.

Alternative 2: The City Council note and file Fiscal Year 2021-22 Audit Committee Annual Report and provide input on the Fiscal Year 2022-23 Internal Audit Work Plan.

Alternative 3: The City Council may consider any other alternative not proposed by staff. 28 of 161
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ADMINISTRATIVE ACTION
Prepared by:

Jessie Zhang, Internal Audit Manager
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS

1. Fiscal Year 2021-22 Audit Committee Annual Report

2. Fiscal Year 2022-23 Internal Audit Work Plan
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C:\inetpub\wwwroot\Glendale\temp\CC_08092022_Motion_4d1.pdf

M O T I O N
Moved by Council Member ________________________________, seconded by Council Member ___________________________________, that the Annual Internal Audit Work Plan prepared by the Audit Committee be hereby approved and accepted and is ordered filed in the office of the City Clerk.

Vote as follows:

Ayes:

Noes:

Absent:
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C:\inetpub\wwwroot\Glendale\temp\CC_08092022_Motion_4d2.pdf

M O T I O N
Moved by Council Member ________________________________, seconded by Council Member ___________________________________, that the Annual Report prepared by the Audit Committee be hereby approved and accepted and is ordered filed in the office of the City Clerk.

Vote as follows:

Ayes:

Noes:

Absent:
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1 CITY OF GLENDALE, CALIFORNIA
Internal Audit

141 N. Glendale Ave., Suite 346
Glendale, CA 91206-4975
Tel. (818) 548-2085 Fax (818) 956-3286
[email protected] | www.glendaleca.gov
City of Glendale Audit Committee
141 North Glendale Avenue, Room #346
Glendale, California 91206
Ju
ly 28, 2022
H
onorable Mayor Ardy Kassakhian and Members of the City Council City of Glendale
613 E. Broadway, Room 200
Glendale, CA 91206
R
e: Audit Committee Annual Report for Fiscal Year 2021-22 D
ear Mayor Kassakhian and City Council Members:

E
ach year, the Audit Committee must report our actions and activities to the City Council per Glendale Municipal Code Section 2.82.100. The purpose of this memo is to communicate our activities for the period of July 1, 2021, to June 30, 2022.

T
he Audit Committee met four times during Fiscal Year 2021-22 where we were provided with financial updates and internal audit activity reports. In 2018, the Audit Committee started to conduct paperless meetings in keeping with the City Council’s priorities of fiscal responsibility and sustainability. I am pleased to report that the paperless meeting methodology enabled seamless transitions between conducting the audio/video conference and in-person public meetings. Two of these four meetings were conducted with a combination of in-person and call-in methods due to COVID-19 social distancing requirements, one meeting was 100% virtual, and one meeting was 100% in-person at the City Council Chambers. Besides these regular meetings, I have also worked with City staff regularly via email sharing my thoughts on emerging risks and concerns and receiving clarification from staff on questions.

T
he Audit Committee assists the City Council by reviewing financial information and management reports, and by providing independent recommendations regarding the scope, priority, and methods of audit related activities within the City. Despite the evolving situation with the COVID-19 pandemic, the Audit Committee continued to carry-out its responsibilities during this unprecedented time.

Exhibit 1
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City of Glendale
Internal Audit
Fiscal Year 2022-2023 Audit Work Plan
Exhibit 2
Ref.# Audit Subject Area Department Audit Type
1 Public Record Request CCD Performance
2 Tree Trimming Contract Audit PWD Contract Compliance
1 Insight Public Sector Contract Audit ITD Contract Compliance 2 Workers' Compensation Disability Settlement Process Audit HRD Performance 3 Data Center Security Assessment ITD Performance
4 Landfill JPA with Sanitation District Audit PWD Contract Compliance 5 Water System Pipeline Management Program Audit GWP Contract Compliance 6 Vehicle Towing Contract Audit GPD Contract Compliance 7 Parking Citations Contract Audit PWD Contract Compliance 8 Business Registration Certificate Audit CDD Performance 9 Fuel Purchase Contract Audit PWD Contract Compliance
10 Fleet Operations Audit - Vendor Management PWD Performance 11 PCI Compliance Audit (3) CTD Compliance
CA1 User Access Control (AD and Munis) ITD Periodic
CA2 Duplicate Payments FIN Periodic
CA3 Procurement Cards FIN Periodic
CA4 Double Dipping between Procurement Cards and Employee Expense Claims FIN Periodic CA5 Procurement Card Usage with Existing PO FIN Periodic CA6 Vendor Risk Assessment FIN Periodic
CA7 GASB 87 Leases FIN Periodic
T1 Energy Risk Management Committee GWP Advisory
T2 Investment Policy Advisory Committee CTD Advisory
T3 PCI Compliance Team CTD Advisory
O1 Basic Life Support (BLS) Program Analysis GFD Performance O2 Traffic Signal Maintenance Contract Audit PWD Contract Compliance O3 IT Asset Management - LTE Services ITD Performance
O4 Medical Services - Vital Contract Audit GPD Contract Compliance O5 Credit Card Refund Process Audit CTD Performance
O6 Building Permit Process Audit CDD Performance
O7 Western Reservoir Project Audit GWP Contract Compliance O8 Special Event Permits Audit MSD Performance
O9 Multi-Project Affordable Housing Lottery Audit/Advisory CDD Performance Carried-Over Projects from FY 2021-2022 to FY 2022-2023 New Projects Planned for FY 2022-2023
Continuous and On-Going Advisory Projects
Total Planned Projects for FY 2022-2023: 25
Other Potential Projects:
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8a

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Glendale Water & Power (GWP) Energy Risk Management Policy and Trading Authority Policy.

1. Motion approving amendments to the GWP Energy Risk Management Policy.

2. Motion approving amendments to the GWP Trading Authority Policy.

COUNCIL ACTION
Item Type: Action
Approved for August 9, 2022 Calendar

EXECUTIVE SUMMARY
The GWP Energy Risk Management Policy is the framework for GWP to manage the risks that are inherent from participating in the wholesale energy markets. The purpose of this Policy is to formally establish an energy risk management program and document the organizational structure, utilized by GWP, to meet the energy needs of its customers, and provide guidelines for GWP to plan, execute, and control the management of a variety of risks associated with energy portfolio activities. In addition, this Policy establishes supporting risk policies for managing all of GWP’s energy risks.

The purpose of the GWP Trading Authority Policy is to define the authority granted by City Council, to the City Manager and the GWP General Manager, to execute energy- related transactions and the ability to delegate trading authority within the limits defined in the GWP Trading Authority Delegation.

COUNCIL PRIORITIES
Environmental Stewardship: By approving the amended GWP Energy Risk Management Policy and GWP Trading Authority Policy, GWP will be able to continue to act in accordance to the renewable and clean energy objectives within the Policies and allow for successful strategic planning so that reliable and cost-effective renewable and clean energy can be provided to commercial, business, and residential customers. 35 of 161
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RECOMMENDATION
Approve amendments to the GWP Energy Risk Management Policy and GWP Trading Authority Policy.

BACKGROUND
Energy Risk Management Policy
The most recent updates to the GWP Energy Risk Management Policy were approved by the City Council in June 2021, which included recommended modifications that would better align GWP’s energy risk management processes, procedures, and protocols to best practices in the industry. As part of its responsibilities as stated in the GWP Energy Risk Management Policy, the GWP Energy Risk Management Committee (ERMC) has undertaken its annual review of the Policy and has approved modifications recommended by the GWP Energy Risk Manager and staff.

Trading Authority Policy
The most recent updates to the GWP Trading Authority Policy were approved by the City Council in June 2021. The Trading Authority Policy authorizes the City Manager and GWP General Manager to establish transaction authority levels for positions below the GWP General Manager level via the GWP Trading Authority Delegation.

ANALYSIS
GWP Energy Risk Management Policy
The proposed, amended GWP Energy Risk Management Policy is attached to this report as Exhibit 1. A redline draft showing the proposed changes from the current GWP Energy Risk Management Policy is attached to this report as Exhibit 2.

The major updates to the GWP Energy Risk Management Policy are:
3. Assignment of Responsibilities:

The organizational chart was revised to mirror the updates made to the GWP ERMC member titles.
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3.4.1 GWP Energy Risk Management Committee Structure:

The GWP ERMC Structure was updated by adding the role of “Chief Assistant General Manager (Power Management)” as a voting member in conjunction with the GWP Assistant General Manager. The section designation (Supply) for GWP Chief Assistant General Manager and GWP Assistant General Manager is replaced with (Power Management) through the policy. The change is in response to additional roles within GWP. The titles for the GWP Utility Finance Manager and City of Glendale Director of Finance/Information Technology are also corrected in the GWP ERMC Structure and throughout the policy. 37 of 161
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3.5 GWP Chief or Assistant General Manager (Power Management):

The role of Chief Assistant General Manager is added to the responsibilities of the GWP Assistant General Manager as it pertains to Energy Risk Management. The reason for this addition is due to present and future staffing changes. 3.12 GWP Utility Finance Manager:

The responsibilities of the GWP Finance Manager were expanded to include managing the counterparty approval, credit, and collateral management processes. This responsibility was previously held by the GWP Power Contracts Manager due to an unfilled GWP Utility Finance Manager position.

GWP Trading Authority Policy
The proposed, amended GWP Trading Authority Policy is attached to this report as Exhibit 3. A redline draft showing the proposed changes from the current Trading Authority Policy is attached to this report as Exhibit 4.

The major updates to the GWP Trading Authority Policy are:
3.4 Trading On and Off Premises:

The amended Policy allows for off-premise trading while maintaining continued business operations and reliability. This change is in response to the City of Glendale hybrid work policy. All trades must be executed through an approved recorded communication method.
4.2 CAISO Transaction Limits:

The amended Policy removes authority limits for Ancillary Service Awards due to GWP’s owned generation being located outside of the CAISO. The authority limits are also removed for Inter Scheduling Coordinator (SC) Energy Transactions.

Inter SC Energy Transactions, though transacted through the CAISO, are considered bilateral transactions and will be monitored in accordance with the Bilateral Electric Power and Transmission Matrix.
4.3.4 Transportation Firmness:

The amended policy provides firmness requirements for natural gas sales. Firm natural gas sales must be transported on firm pipeline transportation. The City Manager or GWP General Manager can pre-approve exceptions to this policy. 4.6.1 Carbon Allowance and Carbon Emission Offsets Transaction Limits Matrix Explanations:

The amended policy identifies the Carbon Allowance and Emission Offset product types of CCA, GCCO, CCO3 and CCO8. Each of these product types are applied differently based on California Air and Resource Board regulations.

5.3 Sanctions for Operational/Scheduling/Tagging/Transmission Errors:

The amended policy includes acknowledgement for errors made while performing operational, scheduling or transmission responsibilities that may result in disciplinary action according to the guidelines outlined in the GWP Trading Sanctions Policy.
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CONTRACT DASHBOARDS
Not Applicable.

STAKEHOLDERS/OUTREACH
Not Applicable.

FISCAL IMPACT
The adoption of the amended GWP Energy Risk Management Policy and GWP Trading Authority Policy will not have a fiscal impact.

ENVIRONMENTAL REVIEW
The proposed action is exempt from the requirements of the California Environmental Quality Act (CEQA) pursuant to 14 California Code of Regulations Section 15378 as it is not a “project” as defined in CEQA.

CAMPAIGN DISCLOSURE
Not Applicable.

ALTERNATIVES
Alternative 1: Approve amendments to the GWP Energy Risk Management Policy and GWP Trading Authority Policy.

Alternative 2: Choose not to approve the amendments to the GWP Energy Risk Management Policy and GWP Trading Authority Policy. In this case, the existing GWP Energy Risk Management Policy will remain in place. GWP will not be able to benefit from the proposed amendments to the policy which enable GWP to successfully act and strategically plan in accordance with energy risk objectives within the Policies in order to meet regulatory requirements, and to provide reliable and cost-effective energy to customers utilizing all available industry resources.

Alternative 3: Consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Prepared by:

Chie Valdez, Integrated Resource Planning Administrator Howard Wong, Energy Risk Manager - GWP
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS / ATTACHMENTS
Exhibit 1: Proposed Energy Risk Management Policy
Exhibit 2: Redline of Energy Risk Management Policy (showing changes from current Policy)
Exhibit 3: Proposed GWP Trading Authority Policy
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Exhibit 4: Redline of Trading Authority Policy (showing changes from current Policy) 40 of 161
MOTION
Moved by Council Member ____________________________, seconded by Council Member ___________________________, that the Council hereby approves the revised Glendale Water & Power (GWP) Energy Risk Management Policy, as set forth as Exhibit 1 to the Report to City Council, dated August 9, 2022, which policy replaces the GWP Energy Risk Management Policy approved by Council on June 29,2021.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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MOTION
Moved by Council Member ____________________________, seconded by Council Member ___________________________, that the Council hereby approves the revised Glendale Water & Power (GWP) Trading Authority Policy, as set forth as Exhibit 3 to the August 9, 2022 Report to City Council, which policy replaces the GWP Trading Authority Policy approved by Council on June 29, 2021.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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Energy Risk Management Policy
Glendale Water & Power TBD/2022

ENERGY RISK MANAGEMENT POLICY
TBD, 2022
EXHIBIT 1
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i

TABLE OF CONTENTS

1. POLICY PURPOSE 1

2. RISK MANAGEMENT OBJECTIVES 2

2.1 GWP Business Objectives 2

2.2 GWP Risk Management Objectives 2

3. ORGANIZATION & GOVERNANCE 3

3.1 City Council 5

3.2 City Manager 5

3.3 GWP General Manager 6

3.4 GWP Energy Risk Management Committee (ERMC) 7

3.4.1 Energy Risk Management Committee Structure

3.4.2 Meeting Timing,Frequency, and Voting Procedures

3.4.3 Member Vacancies

3.4.4 Energy Risk Committee Responsibilities

3.5 GWP Chief or Assistant General Manager (Power Management) 10

3.6 GWP Assistant General Manager (Business Services) 10

3.7 GWP Integrated Resources Planning Administrator 11

3.8 GWP Energy Trading Manager 12

3.9 GWP Power Planning Manager 13

3.10 GWP Energy Risk Manager 14

3.11 GWP Power Contracts Manager 16

3.12 GWP Utility Finance Manager 17

3.13 GWP Utility Business System Support Administrator 18

3.14 City of Glendale Finance 18

3.15 City of Glendale Legal 19

3.16 City of Glendale Audit 19

3.17 Conflict of Interest and Compliance 20

4. SCOPE OF BUSINESS ACTIVITIES GOVERNED BY THIS 20
POLICY

5. RELATED POLICIES 20

6. REPORTING 21

6.1 Reporting Requirements 21
Table 6.1 Reporting Requirements 21
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ii

7. POLICY REVIEW 22

8. PROCEDURES 22
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Energy Risk Management Policy
Glendale Water & Power TBD/2022
1 1. POLICY PURPOSE
Glendale Water & Power (GWP) is in the business of generation, transmission, and distribution of electricity for the benefit of the City of Glendale. One of GWP’s main objectives is to procure reliable and sustainable power for its customers at stable and predictable rates while optimizing existing and local resources. This Energy Risk Management Policy (the Policy) is designed to establish the framework for GWP to manage the risks that are inherent in the wholesale energy operations and markets it participates in.

The purpose of this Policy is to formally establish an energy risk management program and document the organizational structure (Figure 3.1) utilized by GWP to meet the electricity needs of its customers and provide approved guidelines for GWP to plan, execute, and control the management of a variety of risks associated with energy portfolio activities. The purpose of this Policy is also to formalize the policies of GWP regarding managing its energy risks. Accordingly, this Policy will set forth GWP’s:
risk management objectives;
risk governance structure and responsibilities;
scope of business activities governed by this Policy; and list of associated guidelines, policy documents, and registry.

GWP intends that energy risk management will support the advancement of its strategic business plan and will properly manage its business and financial risks through:
prudent oversight;
adequate mitigation of energy risks consistent with GWP’s defined risk registry and tolerance; and
sufficient internal controls and procedures.

Managing the energy risks of GWP entails the coordination of resources and activities among all departments within GWP and within the City of Glendale (CoG) governance structure.
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2 2. RISK MANAGEMENT OBJECTIVES

2.1GWP BUSINESS OBJECTIVES
An effective energy risk management policy better equips a utility to achieve its energy portfolio objectives. This Policy is focused on helping GWP achieve these business objectives:
Provide reliable, sustainable power to retail customers; Manage the energy portfolio to stabilize rates;
Comply with mandatory renewable and clean energy standards and other regulatory requirements;
Provide renewable and clean energy while reducing carbon and other emissions;
Allow for hedging to protect against adverse changes in energy market prices and mitigate the risk to customers of significant rate increases and budget shortfalls;
Allow for providing price and risk differentiated energy products to customers as appropriate;
Optimize GWP’s existing energy portfolio resources; and Protect GWP’s systems, communications, and data against risks associated with cybersecurity.

2.2GWP RISK MANAGEMENT OBJECTIVES
The primary goal of this Policy and resulting risk management activities is to strengthen GWP’s ability to provide reliable, sustainable power to its retail customers at stable, predictable rates while managing risks and complying with mandatory regulatory requirements. This goal is best achieved by enabling GWP to transact in different energy commodity markets while monitoring, minimizing, and mitigating associated risks.

Other goals of risk management activities are to:
Maintain risks within desired tolerances for a defined period in the future; Enhance the value of GWP’s assets/resources;
Participate in commodity markets and derivative instruments for hedging and not speculative purposes;
Develop a risk management culture and support GWP’s ongoing strategic planning process;
Manage a portfolio of physical and financial positions to help stabilize the cost of energy with associated risks while maintaining reliable energy supplies for customers and meeting regulatory requirements; Identify, quantify, and monitor market and regulatory risks; 48 of 161
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3 Monitor trading activity to identify and report if policy violations occur and if authority limits are exceeded without proper approval;
Work within the existing organizational structure to implement the Policy; Remain flexible to accommodate changing needs of GWP’s energy portfolio while maintaining control of the overall risk position; and Operate a disciplined program to manage budget, cash flows, margining, and transaction execution.

3. ORGANIZATION & GOVERNANCE
Risk governance will follow a top-down approach whereby the GWP Energy Risk Management Committee (ERMC) identifies GWP’s energy risk management objectives and provides energy risk management oversight, consistent with the rates, annual budget, policies, and transaction authorities that are all periodically adopted by the City Council. Supporting controls, policies, and procedures will be implemented and aligned throughout the risk governance structure, with distinct roles and responsibilities that result in an energy risk controlled environment. Governance and controls include the organizational structure, policies, reporting processes, and procedures that support GWP’s business models, risk tolerances, energy supply objectives, and appropriately segregate responsibilities.

The following sections identify and describe the levels within the organization with oversight and direct responsibility for the implementation of this Policy and the resulting program.

ASSIGNMENT OF RESPONSIBILITIES
The following organizational chart illustrates the roles and functions responsible for the implementation of risk management activities within this Policy. Also, it identifies the appropriate segregation of duties within GWP for the primary functions that manage energy commodities:
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5 3.1CITY COUNCIL
The City of Glendale City Council shall:
Adopt an electric utility annual budget;
Review and approve retail electric customer rate changes; Review and approve changes to the GWP Electric System Cash Reserve Policy;
Approve transaction authorities for the City Manager and the GWP General Manager established according to the Trading Authority Policy; Approve recommended changes to the Energy Risk Management Policy that establishes an overall framework for evaluation, management, and control of energy risk for GWP.

3.2CITY MANAGER
The City Manager is responsible for providing the oversight of and support for GWP’s energy risk management philosophies and principles. The City Manager shall:
Establish scope and frequency of any GWP management reporting to the City Council;
Periodically review energy risk exposures and compliance with policies and procedures;
Discuss GWP’s energy risk exposures and the steps GWP management has taken or will take to mitigate, control, and monitor such exposures, as documented in GWP’s Risk Registry;
Require adequate management involvement, financial controls, and systems to monitor, report, and ensure the integrity of this Policy at all levels;
Periodically review this Policy and the related policies as defined in Section 5, and recommend changes proposed by the GWP ERMC to the City Council and/or such other changes as the City Manager deems advisable; and
Approve a Trading Authority Delegation reflecting delegation of trading authority and limits. Periodically review the Trading Authority Delegation and recommend proposed revisions, as needed; and
Serve on the ERMC.
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6 3.3GWP GENERAL MANAGER
The GWP General Manager is responsible for the overall direction, structure, conduct, control, mitigation, reporting, and enforcement of GWP’s risk management activities. The GWP General Manager shall:
Establish a risk management culture throughout the organization; Periodically assess the adequacy and functioning of the system of controls over market, credit, and operational risks;
Ensure that all energy risk control activities (e.g., position monitoring, portfolio assessment, credit) are independent of energy purchases and sales;
Approve a Trading Authority Delegation reflecting delegation of trading authority and limits. At a minimum, annually review the Trading Authority Delegation and revise, as needed;
Report to the City Manager on GWP’s energy risk management activities, achievements, and goals;
Annually review with the ERMC and assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; Review with the GWP ERMC on GWP’s compliance with its energy risk policies and energy risk management in accordance with the policies; Periodically report, to the City Manager, the risk profile of GWP’s energy portfolio and on the results of energy risk management activities; Have authority to transact within the limits set by the City Council in the Trading Authority Policy;
Approve proper organization, separation, or consolidation of functional activities;
Ensure that the identification and quantification of energy risks and related energy risk mitigation strategies, as documented in GWP’s Risk Registry, are integrated into the GWP strategic planning process; and Establish and maintain an effective working relationship with associated energy service providers; and
Serve on the ERMC.
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7 3.4GWP ENERGY RISK MANAGEMENT COMMITTEE (ERMC)
The GWP ERMC has the responsibility for managing the target energy risk profiles and leading GWP’s energy risk management efforts on a path of continuous improvement. The GWP ERMC will provide direction and oversight to GWP concerning power supply planning, transacting, hedging, reporting, and related internal controls; and the development and implementation of policies and procedures consistent with this Policy.

The GWP ERMC establishes a forum for discussion of GWP’s significant energy risks and must develop guidelines required to implement an appropriate energy risk management control infrastructure; this includes implementation and monitoring of compliance with GWP’s energy risk management-related policies, as defined in Section 5. The GWP ERMC executes its energy risk management responsibilities through direct oversight and prudent delegation of its responsibilities to the independent energy risk management function, as well as to other GWP and City of Glendale (CoG) personnel.

3.4.1GWP Energy Risk Management Committee Structure
Voting Membership:

The GWP ERMC shall be comprised of six voting members and seven non-voting members.

The six voting members are:

1. City Manager;

2. GWP General Manager (Chair);

3. GWP Chief or Assistant General Manager (Power Management), or as designated by the GWP General Manager;

4. GWP Assistant General Manager (Business Services) or as designated by the GWP General Manager;

5. GWP Energy Risk Manager; and

6. CoG Director of Finance/Information Technology.

Non-voting participants shall include, but not limited to:

1. GWP Integrated Resources Planning Administrator;

2. GWP Trading Manager;

3. GWP Utility Business System Support Administrator;

4. GWP Utility Finance Manager;

5. CoG Attorney;

6. Power Planning Manager; and

7. CoG Internal Audit Manager.
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8 3.4.2Meeting Timing, Frequency, and Voting Procedures The GWP ERMC shall meet no less than once per calendar quarter.

Member attendance shall be recorded in the GWP ERMC meeting minutes.

Any voting member of the GWP ERMC can request an emergency meeting of the GWP ERMC to address circumstances or issues that may require immediate attention. In the event any member or participant is unable to attend a GWP ERMC meeting, that member or participant may designate an alternate to attend and vote in his or her absence.

The six voting members shall each have a single vote on matters that come before the GWP ERMC and a voting member, or designee, must participate in the GWP ERMC meeting in order to vote and approve a proposed action. If any three of the voting members, or their designees, are not present at a GWP ERMC meeting, a vote on a proposed action cannot take place. The GWP ERMC will make decisions and take actions by a simple majority vote. If the GWP ERMC reaches an impasse that cannot be addressed through a vote or if a tie vote occurs, the GWP General Manager will make a final decision.

3.4.3Member Vacancies
In cases where a committee member vacates the GWP ERMC, the GWP General Manager will resolve the GWP ERMC vacancy by making a discretionary interim appointment.

The GWP General Manager will designate a Secretary to the GWP ERMC to document all meetings and actions taken by the GWP ERMC in meeting minutes that will be distributed to GWP ERMC members for their review and approval. The Secretary need not be a member of the GWP ERMC.

Approved meeting minutes will be distributed by the Secretary to the GWP ERMC members.

3.4.4GWP Energy Risk Management Committee Responsibilities The GWP ERMC is responsible for:
Aligning energy risk management with City Council approved budgets, rates, policies and transaction authorities;
Setting a clear strategy and goals for hedging market price risk via the Hedge Policy; reviewing and approving risk management strategies and hedging plans to be implemented by GWP;
Establishing the scope of energy portfolio and risk management activities, the purpose for engaging in transactions, and the appropriate risk tolerances consistent with strategic direction;
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9 proposed energy risk management strategies for strategic fit, evaluate risk exposure consistent with energy risk tolerances, and reporting and control requirements. The GWP ERMC shall ensure that approved strategies are consistent with GWP’s approved strategic business plan, energy risk management objectives, approved energy risk tolerance guidelines, and compliance with energy risk policies;
Reviewing reports by the independent energy risk management function concerning policy and procedural compliance and taking appropriate action to mitigate losses or increased risks, if any, as necessary; Providing oversight and direction for specific projects including new markets, RFP development and review of RFP responses for physical and financial energy, fuel, related transportation transactions, and tools and systems needed to manage the risks of participation in energy markets;
Discussing elements of energy risk management best practices and developing an GWP ERMC opinion of their specific practicality; Overseeing the implementation and review of related Standard Operating Procedures and changes to them;
Conducting other activities relevant to the implementation and oversight of this Policy and related policies, as defined in Section 5, and procedures;
Recommending to the GWP General Manager the proper organizational structure, separation or consolidation of functional risk management activities;
At least, annually, review GWP’s energy risk management program and Risk Registry due to changes in business practices, improved procedures, GWP’s philosophy and strategy, or market changes; and ensuring continued compliance with its established guidelines; Reviewing this Policy and related policies as defined in Section 5, on an annual basis and recommending changes to this Policy to the City Manager for submittal to the City Council for approval; and Approving and periodically reviewing the related policies defined in Section 5.
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10 3.5GWP CHIEF OR ASSISTANT GENERAL MANAGER (POWER MANAGEMENT) The GWP Assistant General Manager or designee, as relates to Power Management Services, oversees the “front office,” reports directly to the GWP General Manager, and responsible for GWP’s overall energy supply. The GWP Assistant General Manager (Supply) shall:
Develop and maintain retail load forecasts and retail fuel and purchase power budgets;
Assure compliance with this Policy and related policies, as defined in Section 5, by the Energy Trading Manager and Marketers, Analysts and Schedulers, Real-time Traders or Authorized Agents, and the GWP Power Contacts Manager involved in energy risk management activities; Establish a review and approval process to provide timely responses to issues arising from day-to-day operations;
Oversee the development of hedge strategies to manage GWP’s energy exposure;
Recommend hedge strategies to the GWP ERMC that address GWP’s plans to manage its energy exposure;
Oversee the development of procedures for Energy Marketers, Schedulers, and Real-time Traders as needed;
Support and assist in the preparation of reports listed in Section 6.1, Reporting Requirements; and
Serve on the GWP ERMC.

3.6GWP ASSISTANT GENERAL MANAGER (BUSINESS SERVICES)
The GWP Assistant General Manager or designee, as relates to Business Services, oversees the “back office,” reports directly to the GWP General Manager, and responsible for GWP’s marketing development and operations activities. The GWP Assistant General Manager (Business Services) shall:
Oversee the responsibilities of the GWP Utility Manager (Financial) and GWP Business Systems Support Manager;
Provide management oversight for the direction and coordination of customer service activities with other sections of the utility; Direct marketing and public information activities of the utility. Oversee the development, implementation, promotion, evaluation, and modification of GWP customer relations, marketing, demand-side management, utility conservation, renewable energy, and revenue enhancing programs across all customer segments;
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11 Lead the utility wide change management effort with respect to smart grid and related innovation. Responsible for the development and implementation of strategic and technology work plans;
Direct personnel and activities in the development of distributed resources, dynamic rates, including time of use, critical peak, and real time pricing, demand response, smart appliance, consumer device, advanced storage, peak-shaving, new web based services, and other smart grid program options for empowering consumers;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Serve on the GWP ERMC.

3.7GWP INTEGRATED RESOURCES PLANNING ADMINISTRATOR
The GWP Integrated Resources Planning Administrator reports directly to the authority under section 3.5 and plans, directs, supervises, and reviews the development, identification, and administration of power resources; plans, directs, supervises and reviews the development, negotiation, monitoring, administration, and settlement of transactions related to power resource contracts; and plans, directs and supervises participation in regulatory, legal and project administration efforts. The GWP Integrated Resources Planning Administrator shall:
Direct activities related to the preparation of forecasts of energy requirements and peak demands;
Direct the development of analytical studies related to power supply economics, generation, forecasting, regulatory and legislative impacts; Direct the City's power supply projects including generation, transmission and marginal costing studies;
Direct the preparation of utility data to assist in negotiating power marketing agreements and power purchases;
Direct contract negotiations to fill power supply requirements and to resolve power supply issues;
Direct the preparation of reports for regulatory agencies; Direct the development and maintenance of forward wholesale market information systems;
Direct the development and implementation of forward strategies; Negotiate and administer joint power resource development projects, regional transmission and power generating projects;
Analyze proposed litigation settlements and negotiate the settlement of disputes;
Coordinate the legal review of proposed contractual arrangements; Evaluate and report performance and compliance of existing power contracts;
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12 Responsible for the development of the annual budget and long-term power cost forecasts;
Assist in the development of overall policies, plans, and objectives; and Prepare comprehensive written and oral reports and presentation recommendations; and
Participate on the GWP ERMC.

3.8GWP ENERGY TRADING MANAGER
The GWP Energy Trading Manager reports directly to the authority under section

3.5 and exercises technical, administrative, and management responsibility over staff performing energy trading. The GWP Energy Trading Manager shall:
Represent the “front office” in GWP’s energy risk management organization; The “front office” is responsible for energy trading, operations, portfolio optimization, load forecasting, transaction and scheduling, generating resource optimization, and hedging;
Assure daily compliance with the Energy Risk Management Policy and related policies, as defined in Section 5, and timely responses to issues arising from day-to-day operations;
Execute and manage energy transactions (purchases, sales, and hedges) in accordance with approved hedge strategies and within the requirements specified in the Trading Authority Delegation;
Understand the types of transactions individuals may engage in to manage the energy portfolio;
Adhere to the transaction approval process;
Actively acquire and analyze market intelligence and assist in developing hedge strategies;
Prepare transaction analyses and reports;
Communicate market intelligence within GWP’s risk management organization; and
Participate on the GWP ERMC.
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13 3.9GWP POWER PLANNING MANAGER
The GWP Power Planning Manager reports directly to the authority under section

3.5 and supervises the analysis, forecasting and planning activities for the electric utility's integrated resources established by GWP management. The GWP Power Planning Manager represents the “front office” in GWP’s energy risk management organization. The GWP Power Planning Manager shall:
Evaluate resource needs to meet forecasted loads and load patterns and performs technical and economic analysis of resource options; Perform modeling, analysis, and forecasting of load patterns and resource utilization;
Interpret and evaluate economic analyses, planning data, and study results;
Assist in evaluating opportunities for power supply acquisition and power project participation;
Assist in negotiating contracts to fill power supply requirements and to resolve power supply issues;
Evaluate market data and opportunities for power supply acquisition and power project participation;
Prepare and supervise preparation of technical and administrative reports and recommendations including the annual long-range power supply plan (integrated resource plan) and reports to regulatory bodies; Develop and recommend policies and procedures to ensure that power planning/marketing activities comply with NERC/WECC requirements and contractual provisions;
Develop and recommend procedures to effectively carry out optimization of the City's resource, transmission, and load portfolio; Assist with development of the annual budget;
Prepare and supervise preparation of reports and graphic displays for use in presentation of study results and recommendations; and Participate on the GWP ERMC.
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14 3.10GWP ENERGY RISK MANAGER
GWP’s Independent Risk Management Function is led by the GWP Energy Risk Manager. The GWP Energy Risk Manager represents the “middle office” in GWP’s energy risk management organization. The responsibilities of the GWP Energy Risk Manager include ensuring reports covering GWP’s energy portfolio position and credit exposures are prepared and reporting compliance with energy risk management policies and procedures. The GWP Energy Risk Manager also leads the development and review of business processes and internal control improvements throughout the energy transaction lifecycle. The GWP Energy Risk Manager will provide risk assessment input to the hedge planning and transacting activity, but will maintain a strict separation of duties. The GWP Energy Risk Manager will brief the GWP General Manager, as requested, regarding recent GWP energy risk management activities.

The GWP Energy Risk Manager will serve as facilitator of the GWP ERMC and reports directly to the GWP General Manager. In addition, the GWP Energy Risk Manager shall:
Perform responsibilities delegated by the GWP ERMC;
Serve, organize and conduct the GWP ERMC meetings;
Engage the EMRC in discussions regarding emerging risks, events and developments that could expose GWP to potential losses; Develop, recommend, and administer risk management processes and procedures, including best practice procedures;
Provide and administer energy risk management education/training to GWP management and staff;
Review energy risk management activities and risk controls, and recommend modifications of controls to meet changing business needs; Review adequacy and accuracy of reports, and report any deficiencies to the GWP ERMC. Recommend actions to address deficiencies; Assess energy risks to GWP in aggregate, by business unit, and by material business activity;
Ensure compliance, review, and recommend changes to the Energy Risk Management Policy and related policies, as defined in Section 5, and energy risk management procedures, as appropriate;
Monitor compliance of transactions with GWP’s Trading Authority Policy and Trading Authority Delegation and monitor GWP’s portfolio for compliance with GWP’s Hedge Policy;
Report to the GWP ERMC and GWP General Manager on GWP’s compliance with its energy risk policies and energy risk management in accordance with policies;
Manage credit exposure in compliance with the GWP Credit Policy; Report mark-to-market forward energy transactions for credit exposure purposes;
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15 Review and evaluate proposed longer-term transactions to be executed by GWP and ensure adequate analysis has been performed with proper assessment and mitigation of any such risk consistent with energy risk management objectives, risk tolerance guidelines, and energy risk management policies, including the financial, legal, credit, regulatory, reliability, and operational impacts;
Ensure the responsibilities of the GWP ERMC, as outlined in the Policy, are fulfilled;
Provide advice regarding the effectiveness of tools used or evaluated to assist in energy risk management for measuring, monitoring, and reporting performance;
Validate the tools and data used throughout GWP to measure, monitor, and report risk;
Support periodic internal audits of GWP risk control policies, processes and procedures with CoG Internal Audit to ensure overall operational compliance;
Conduct periodic review and update of the GWP Risk Registry, including status of mitigation plans and risk prioritization, and ensure effective strategies are in place to mitigate the top energy risks; Review and advise the GWP ERMC and the GWP General Manager of risk exposures in the GWP Risk Registry;
Ensure Standard Operating Procedures and Allegro Business Process Documents for each of the functional areas that fall under the Policy umbrella are maintained and updated, as necessary;
Be responsible for the oversight and effectiveness of GWP’s energy risk management policies, procedures, and trading control environment; Review and recommend, to the GWP ERMC, changes to functional activities, as appropriate, to ensure proper segregation of duties; Provide a timely summary of GWP ERMC accomplishments for the past year and goals for the upcoming year to the GWP ERMC and GWP General Manager;
Lead and assist in the preparation of reports listed in Section 6.1, Reporting Requirements;
Participate, as required, on committees and working groups such as risk management, legislative, regulatory, and cybersecurity; and Report regularly to the GWP ERMC, the following information, at a minimum, but not limited to:
oPortfolio modeling risk measures (1-60 months);
oPower cost projections and confidence intervals;
oProduction output and operational concerns;
oCredit and contract risk exposures;
oHedging strategies;
oEnergy policy and procedural violations;
oRegulatory and reliability compliance;
oBusiness continuity;
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16 oPhysical and cyber security in coordination with the City’s Information Systems Department;
oUpdates to the GWP Risk Registry; and
oOther Key Performance Indicators that support effective energy risk management

3.11GWP POWER CONTRACTS MANAGER
The GWP Power Contracts Manager reports directly to the authority under section 3.5 and recommends, negotiates, and prepares the City's power resource contracts and agreements in accordance with the direction and goals established by GWP management. The GWP Power Contracts Manager represents the “middle office” in GWP’s energy risk management organization. The GWP Power Contracts Manager shall:
Actively participate in regulatory, legal, and project administration efforts. Identify and assist in the negotiation and evaluation of contracts, including resource purchases and sales, transmission, natural gas, transportation, renewables and emissions, settlement, interconnection, interchange, development, participation, operation, and agreements;
Monitor and support the GWP’s participation in utility industry’s federal, state, and local regulatory authority activities;
Review, evaluate, revise, and author contracts, regulatory filings, and legal filings related to the GWP's energy resource operations; Review and ensure the GWP is in compliance with contractual terms and is receiving similar compliance from contracting parties in accordance with prepared task lists, schedules and loss calculations, procedures, and guidelines for administering and evaluating all energy resource related agreements;
Evaluate existing and proposed contractual arrangements and recommend desirable modifications for the purpose of optimizing the GWP's benefits;
Analyze and recommend resource-operating strategies and assist in the creation of contractual guidelines for related resource functions; and Support strategies related to legal disputes.
Assign appropriate funding based on contract terms and budget; and Notify GWP Management if it is anticipated that there will be inadequate funds available in the budget to transact;
Adhere to confirmation process by confirming trades executed under enabling agreements;
Manage the counterparty approval, credit, and collateral management processes;
Develop and manage Power Management’s budget for bulk power, gas, transmission, transportation, environmental commodities, and related contractual services;
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17 Oversee trade capture and validation activities including actualization of trades, etags, generation resource data, and review accuracy, completeness, and timeliness of data in the trading system; Monitor and manage Renewable Energy Credits as it relates to creation, transfer, and retirement for RPS Compliance;
Carbon Allowance allocations, offsets, and mandatory greenhouse gas emissions reporting and verification;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5;
Serve as “Energy Risk Manager” back-up; and
Participate on the GWP ERMC.

3.12GWP UTILITY FINANCE MANAGER
The GWP Utility Manager reports directly to the authority under section 3.6 and manages the “back office” in GWP’s energy risk management organization. The Back Office, as part as the GWP Finance, provides settlement services; documents the required accounting treatment of forward transactions; and provides the related valuation of these transactions to enable the preparation of invoices and reporting of forward transactions in GWP’s financial statements in accordance with prevailing accounting rules. The GWP Utility Manager shall:
Oversee and monitor the back office for transactional analysis and accuracy;
Develop and apply accounting policies to financial transactions; Oversee the settlement of transactions (verification, accounts payable/receivable process);
Manage the counterparty approval, credit, and collateral management processes;
Correctly classify and report transactions. (Certain transactions may differ in their reporting requirements, depending on whether they qualify as “existing assets, liabilities, and firm commitments” or “anticipated transactions” for hedge accounting. CoG Finance shall determine how transactions are classified for reporting purposes and ensure that hedges are accounted for in accordance with generally accepted accounting principles.);
Be responsible for Dodd-Frank compliance;
Provide appropriate funding. (CoG Finance shall maintain control procedures over electronic funds transfer for payments and collections.

This is intended to ensure that cash payments are properly disbursed and authorized trades are independently confirmed and processed.); and Notify GWP Management and the Power Contracts Manager if GWP Finance anticipates there will be inadequate funds available in the budget to transact.
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18 Supports CoG Finance in preparing the Comprehensive Annual Financial Report that complies with the accounting requirements promulgated by the Governmental Accounting Standards Board (GASB);
Participate, as required, on finance committees and working groups; Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC.

Under no circumstances will members of the GWP Finance be given the authority to enter into any energy transactions on behalf of the utility.

3.13GWP UTILITY BUSINESS SYSTEM SUPPORT ADMINISTRATOR
The GWP Business Systems Support Manager reports directly to the authority under section 3.6 and has the responsibility of managing, directing, and coordinating the planning and implementation of major utility technology projects.

GWP’s Business Systems Support Manager shall:
Manage, support, and maintain the Energy Trading and Risk Management (ETRM) applications, databases, backups, and redundancies; Conduct quarterly audits of ETRM users access and provide reporting to management as needed;
Maintain OATI security and certificate management;
Administer all aspects of IT security with firewall monitoring; Develops and maintains GWP cybersecurity training, procedures, and policies;
Participate, as required, on cybersecurity committees and working groups. Coordinate information technology activities with City’s Information Services;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC

3.14CITY OF GLENDALE FINANCE
The Finance Department provides timely, accurate, clear and concise information to the City Council, City Manager, GWP General Manager, GWP ERMC, and various City Departments and is dedicated to managing the City’s resources in a fiscally conservative manner. City of Glendale’s Director of Finance/Information Technology shall:
Provide support and assistance on GWP financial and budgetary issues; Provide long range financial planning functions including revenue and operational expense projections;
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19 Provide recommendations on operations effectiveness measures, and revenue strategies;
Review existing and proposed ordinances, statues, resolutions, and other documents;
Direct the City’s energy risk management functions including litigation, insurance, and external auditors;
Confer on financial policies and procedures;
Assure compliance with this Policy and related policies, as defined in Section 5; and
Serve on the GWP ERMC.

3.15CITY OF GLENDALE LEGAL
The City Attorney's Office is committed to providing professional, quality legal services that ultimately protect the interests of the City of Glendale, its departments, and the City Council. City of Glendale’s City Attorney shall:
Review the Policy and the related policies, as defined in Section 5, and recommend updates as appropriate in compliance with the City Charter and applicable law;
Negotiate master/enabling agreements with counter-parties as directed by the authority under section 3.5 and GWP Power Contracts Manager; Assess legal enforceability of contracts with applicable laws and regulations;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC.

3.16CITY OF GLENDALE AUDIT
The City of Glendale Internal Audit assists the City in improving operations by providing independent audits and consulting services designed to add value and promote transparency, accountability, efficiency and effectiveness. The City of Glendale’s Internal Audit Manager shall:
Verify proper segregation of external and internal reporting, energy risk management, accounting, treasury, and trading duties and maintenance of files;
Sample and review activities for compliance with related policies and procedures;
Document and report audit findings to GWP ERMC, including compliance with and discrepancies from this Policy and the related policies, as defined in Section 5, as well as any other irregularity which could expose GWP to financial or operational risk; and
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20 Participate on the GWP ERMC.

3.17CONFLICT OF INTEREST AND COMPLIANCE
Potential conflict of interest by persons directly affected by this Policy is covered by State law and City of Glendale’s citywide Conflict of Interest Charter Code.

All City of Glendale employees who hold positions mentioned in this Policy or perform functions described herein shall not enter into, or direct others to enter into, any energy transactions or other related transactions other than on behalf of GWP, the City of Glendale, or its authorized agents.

4. SCOPE OF BUSINESS ACTIVITIES GOVERNED BY THIS
POLICY
The scope of this Policy is designed to address the management of the energy risks associated with GWP, as documented in GWP’s Risk Registry. The GWP Risk Registry is a comprehensive list of risks that affect GWP’s short-term business operations and long-term strategic planning and is maintained by the GWP Energy Risk Manager. The GWP Risk Registry is comprised of Tier1, Tier 2, and Tier 3 risks distinguished by business category and prioritized by impact and likelihood. GWP and CoG personnel have been identified as the owners of each risk and are responsible for developing strategies to mitigate each risk. The number of risks may vary dictated by business and market changes. The GWP Risk Registry reporting requirement is outlined in Section 6.1.

5. RELATED POLICIES AND REGISTRY
Supporting related policies and registry are identified below. Responsibility for their approval, modification, oversight, and compliance shall be consistent with the organization and governance of this Policy (Section 3). * Denoted CoG City Council responsibility for final approval.
GWP Trading Authority Policy*
GWP Trading Sanctions Policy
GWP Credit Policy
GWP Hedge Policy
GWP Business Continuity Policy
GWP Cyber Security Policy
GWP Risk Registry
GWP Electric Cash Reserves Policy*
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21 6. REPORTING
Reports required by this Policy communicate the operational, market, and credit risks assumed by GWP, and provide information to evaluate the portfolio performance and the effectiveness of the energy risk management program. The reports should be used as a basis for management discussions to determine future energy transactions and strategy.

6.1REPORTING REQUIREMENTS
Management reporting will act as a formal means of communicating the performance of energy transactions and management decisions. On an ongoing basis, management and staff must also establish sufficient communications among parties with responsibilities relative to this Policy.

The following table identifies the reports that must be generated, their normal frequency, report access or distribution, and the originator of the report:

Table 6.1 – Reporting Requirements
Report Report Access
Normal
Frequency Originator
Load/Resource
Balance
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly GWP Energy Risk
Manager
Trade Data Report GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
Mark-to-Market
Report
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
Counterparty Credit
Exposure Report
GWP ERMC Members and
Participants
All Transaction
Implementation Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
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22 Risk Registry and
Risk Mitigation
Activities (1)
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
T1- Monthly
T2- Quarterly
T3 - Annually
GWP Energy Risk
Manager
Portfolio Modeling
Report
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly GWP Energy Risk
Management Section
(1) As required in Section 3.3, GWP General Manager Responsibilities, the GWP General Manager shall report to the City Manager, annually, on the risk profile of the energy portfolio and on the results of energy risk management activities.

7. POLICY REVIEW
Following approval of this Policy, the GWP ERMC shall periodically, no less than annually, review the Policy and the related policies, as defined in Section 5, and recommend updates as appropriate in coordination with the GWP General Manger. Examples of events prompting updates to this Policy and related policies and reviews are changes in regulatory requirements, significant changes in the resource portfolio, significant changes in variable energy prices of alternative resources, changes in regulations, and reliability concerns.

8. PROCEDURES
Standard Operating Procedures (SOP) and Desk Procedures shall be developed for each functional area to provide specific operating criteria and parameters for day-to-day energy risk management activities as needed. The operating criteria and parameters shall be updated as frequently as appropriate to reflect changes in market conditions and staffing levels. All procedures shall be reviewed approved by management and monitored and reviewed by the GWP ERMC. 68 of 161
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ENERGY RISK MANAGEMENT POLICY
TBDJuly 1, 20221
EXHIBIT 2
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i

TABLE OF CONTENTS

1. POLICY PURPOSE 1

2. RISK MANAGEMENT OBJECTIVES 2

2.1 GWP Business Objectives 2

2.2 GWP Risk Management Objectives 2

3. ORGANIZATION & GOVERNANCE 3

3.1 City Council 5

3.2 City Manager 5

3.3 GWP General Manager 6

3.4 GWP Energy Risk Management Committee (ERMC) 7

3.4.1 Energy Risk Management Committee Structure

3.4.2 Meeting Timing,Frequency, and Voting Procedures

3.4.3 Member Vacancies

3.4.4 Energy Risk Committee Responsibilities

3.5 GWP Chief or Assistant General Manager (Power ManagementSupply) 10

3.6 GWP Assistant General Manager (Business Services) 10

3.7 GWP Integrated Resources Planning Administrator 11

3.8 GWP Energy Trading Manager 12

3.9 GWP Power Planning Manager 13

3.10 GWP Energy Risk Manager 14

3.11 GWP Power Contracts Manager 16

3.12 GWP Utility Finance Manager 17

3.13 GWP Utility Business System Support Administrator 18

3.14 City of Glendale Finance 18

3.15 City of Glendale Legal 19

3.16 City of Glendale Audit 19

3.17 Conflict of Interest and Compliance 20

4. SCOPE OF BUSINESS ACTIVITIES GOVERNED BY THIS 20
POLICY

5. RELATED POLICIES 20

6. REPORTING 21

6.1 Reporting Requirements 21
Table 6.1 Reporting Requirements 21
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7. POLICY REVIEW 22

8. PROCEDURES 22
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1 1. POLICY PURPOSE
Glendale Water & Power (GWP) is in the business of generation, transmission, and distribution of electricity for the benefit of the City of Glendale. One of GWP’s main objectives is to procure reliable and sustainable power for its customers at stable and predictable rates while optimizing existing and local resources. This Energy Risk Management Policy (the Policy) is designed to establish the framework for GWP to manage the risks that are inherent in the wholesale energy operations and markets it participates in.

The purpose of this Policy is to formally establish an energy risk management program and document the organizational structure (Figure 3.1) utilized by GWP to meet the electricity needs of its customers and provide approved guidelines for GWP to plan, execute, and control the management of a variety of risks associated with energy portfolio activities. The purpose of this Policy is also to formalize the policies of GWP regarding managing its energy risks. Accordingly, this Policy will set forth GWP’s:
risk management objectives;
risk governance structure and responsibilities;
scope of business activities governed by this Policy; and list of associated guidelines, policy documents, and registry.

GWP intends that energy risk management will support the advancement of its strategic business plan and will properly manage its business and financial risks through:
prudent oversight;
adequate mitigation of energy risks consistent with GWP’s defined risk registry and tolerance; and
sufficient internal controls and procedures.

Managing the energy risks of GWP entails the coordination of resources and activities among all departments within GWP and within the City of Glendale (CoG) governance structure.
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2 2. RISK MANAGEMENT OBJECTIVES

2.1GWP BUSINESS OBJECTIVES
An effective energy risk management policy better equips a utility to achieve its energy portfolio objectives. This Policy is focused on helping GWP achieve these business objectives:
Provide reliable, sustainable power to retail customers; Manage the energy portfolio to stabilize rates;
Comply with mandatory renewable and clean energy standards and other regulatory requirements;
Provide renewable and clean energy while reducing carbon and other emissions;
Allow for hedging to protect against adverse changes in energy market prices and mitigate the risk to customers of significant rate increases and budget shortfalls;
Allow for providing price and risk differentiated energy products to customers as appropriate;
Optimize GWP’s existing energy portfolio resources; and Protect GWP’s systems, communications, and data against risks associated with cybersecurity.

2.2GWP RISK MANAGEMENT OBJECTIVES
The primary goal of this Policy and resulting risk management activities is to strengthen GWP’s ability to provide reliable, sustainable power to its retail customers at stable, predictable rates while managing risks and complying with mandatory regulatory requirements. This goal is best achieved by enabling GWP to transact in different energy commodity markets while monitoring, minimizing, and mitigating associated risks.

Other goals of risk management activities are to:
Maintain risks within desired tolerances for a defined period in the future; Enhance the value of GWP’s assets/resources;
Participate in commodity markets and derivative instruments for hedging and not speculative purposes;
Develop a risk management culture and support GWP’s ongoing strategic planning process;
Manage a portfolio of physical and financial positions to help stabilize the cost of energy with associated risks while maintaining reliable energy supplies for customers and meeting regulatory requirements; Identify, quantify, and monitor market and regulatory risks; 73 of 161
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Work within the existing organizational structure to implement the Policy; Remain flexible to accommodate changing needs of GWP’s energy portfolio while maintaining control of the overall risk position; and Operate a disciplined program to manage budget, cash flows, margining, and transaction execution.

3. ORGANIZATION & GOVERNANCE
Risk governance will follow a top-down approach whereby the GWP Energy Risk Management Committee (ERMC) identifies GWP’s energy risk management objectives and provides energy risk management oversight, consistent with the rates, annual budget, policies, and transaction authorities that are all periodically adopted by the City Council. Supporting controls, policies, and procedures will be implemented and aligned throughout the risk governance structure, with distinct roles and responsibilities that result in an energy risk controlled environment. Governance and controls include the organizational structure, policies, reporting processes, and procedures that support GWP’s business models, risk tolerances, energy supply objectives, and appropriately segregate responsibilities.

The following sections identify and describe the levels within the organization with oversight and direct responsibility for the implementation of this Policy and the resulting program.

ASSIGNMENT OF RESPONSIBILITIES
The following organizational chart illustrates the roles and functions responsible for the implementation of risk management activities within this Policy. Also, it identifies the appropriate segregation of duties within GWP for the primary functions that manage energy commodities:
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5 3.1CITY COUNCIL
The City of Glendale City Council shall:
Adopt an electric utility annual budget;
Review and approve retail electric customer rate changes; Review and approve changes to the GWP Electric System Cash Reserve Policy;
Approve transaction authorities for the City Manager and the GWP General Manager established according to the Trading Authority Policy; Approve recommended changes to the Energy Risk Management Policy that establishes an overall framework for evaluation, management, and control of energy risk for GWP.

3.2CITY MANAGER
The City Manager is responsible for providing the oversight of and support for GWP’s energy risk management philosophies and principles. The City Manager shall:
Establish scope and frequency of any GWP management reporting to the City Council;
Periodically review energy risk exposures and compliance with policies and procedures;
Discuss GWP’s energy risk exposures and the steps GWP management has taken or will take to mitigate, control, and monitor such exposures, as documented in GWP’s Risk Registry;
Require adequate management involvement, financial controls, and systems to monitor, report, and ensure the integrity of this Policy at all levels;
Periodically review this Policy and the related policies as defined in Section 5, and recommend changes proposed by the GWP ERMC to the City Council and/or such other changes as the City Manager deems advisable; and
Approve a Trading Authority Delegation reflecting delegation of trading authority and limits. Periodically review the Trading Authority Delegation and recommend proposed revisions, as needed; and
Serve on the ERMC.
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6 3.3GWP GENERAL MANAGER
The GWP General Manager is responsible for the overall direction, structure, conduct, control, mitigation, reporting, and enforcement of GWP’s risk management activities. The GWP General Manager shall:
Establish a risk management culture throughout the organization; Periodically assess the adequacy and functioning of the system of controls over market, credit, and operational risks;
Ensure that all energy risk control activities (e.g., position monitoring, portfolio assessment, credit) are independent of energy purchases and sales;
Approve a Trading Authority Delegation reflecting delegation of trading authority and limits. At a minimum, annually review the Trading Authority Delegation and revise, as needed;
Report to the City Manager on GWP’s energy risk management activities, achievements, and goals;
Annually review with the ERMC and assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; Review with the GWP ERMC on GWP’s compliance with its energy risk policies and energy risk management in accordance with the policies; Periodically report, to the City Manager, the risk profile of GWP’s energy portfolio and on the results of energy risk management activities; Have authority to transact within the limits set by the City Council in the Trading Authority Policy;
Approve proper organization, separation, or consolidation of functional activities;
Ensure that the identification and quantification of energy risks and related energy risk mitigation strategies, as documented in GWP’s Risk Registry, are integrated into the GWP strategic planning process; and Establish and maintain an effective working relationship with associated energy service providers; and
Serve on the ERMC.
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7 3.4GWP ENERGY RISK MANAGEMENT COMMITTEE (ERMC)
The GWP ERMC has the responsibility for managing the target energy risk profiles and leading GWP’s energy risk management efforts on a path of continuous improvement. The GWP ERMC will provide direction and oversight to GWP concerning power supply planning, transacting, hedging, reporting, and related internal controls; and the development and implementation of policies and procedures consistent with this Policy.

The GWP ERMC establishes a forum for discussion of GWP’s significant energy risks and must develop guidelines required to implement an appropriate energy risk management control infrastructure; this includes implementation and monitoring of compliance with GWP’s energy risk management-related policies, as defined in Section 5. The GWP ERMC executes its energy risk management responsibilities through direct oversight and prudent delegation of its responsibilities to the independent energy risk management function, as well as to other GWP and City of Glendale (CoG) personnel.

3.4.1GWP Energy Risk Management Committee Structure
Voting Membership:

The GWP ERMC shall be comprised of six voting members and seven non-voting members.

The six voting members are:

1. City Manager;

2. GWP General Manager (Chair);

3. GWP Chief or Assistant General Manager (Power ManagementSupply), or as designated by the GWP General Manager;

4. GWP Assistant General Manager (Business Services) or as designated by the GWP General Manager;

5. GWP Energy Risk Manager; and

6. CoG Director of Finance/Information Technology.

Non-voting participants shall include, but not limited to:

1. GWP Integrated Resources Planning Administrator;

2. GWP Trading Manager;

3. GWP Utility Business System Support Administrator;

4. GWP Utility Finance Manager;

5. CoG Attorney;

6. Power Planning Manager; and

7. CoG Internal Audit Manager.
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8 3.4.2Meeting Timing, Frequency, and Voting Procedures The GWP ERMC shall meet no less than once per calendar quarter.

Member attendance shall be recorded in the GWP ERMC meeting minutes.

Any voting member of the GWP ERMC can request an emergency meeting of the GWP ERMC to address circumstances or issues that may require immediate attention. In the event any member or participant is unable to attend a GWP ERMC meeting, that member or participant may designate an alternate to attend and vote in his or her absence.

The six voting members shall each have a single vote on matters that come before the GWP ERMC and a voting member, or designee, must participate in the GWP ERMC meeting in order to vote and approve a proposed action. If any three of the voting members, or their designees, are not present at a GWP ERMC meeting, a vote on a proposed action cannot take place. The GWP ERMC will make decisions and take actions by a simple majority vote. If the GWP ERMC reaches an impasse that cannot be addressed through a vote or if a tie vote occurs, the GWP General Manager will make a final decision.

3.4.3Member Vacancies
In cases where a committee member vacates the GWP ERMC, the GWP General Manager will resolve the GWP ERMC vacancy by making a discretionary interim appointment.

The GWP General Manager will designate a Secretary to the GWP ERMC to document all meetings and actions taken by the GWP ERMC in meeting minutes that will be distributed to GWP ERMC members for their review and approval. The Secretary need not be a member of the GWP ERMC.

Approved meeting minutes will be distributed by the Secretary to the GWP ERMC members.

3.4.4GWP Energy Risk Management Committee Responsibilities The GWP ERMC is responsible for:
Aligning energy risk management with City Council approved budgets, rates, policies and transaction authorities;
Setting a clear strategy and goals for hedging market price risk via the Hedge Policy; reviewing and approving risk management strategies and hedging plans to be implemented by GWP;
Establishing the scope of energy portfolio and risk management activities, the purpose for engaging in transactions, and the appropriate risk tolerances consistent with strategic direction;
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9 proposed energy risk management strategies for strategic fit, evaluate risk exposure consistent with energy risk tolerances, and reporting and control requirements. The GWP ERMC shall ensure that approved strategies are consistent with GWP’s approved strategic business plan, energy risk management objectives, approved energy risk tolerance guidelines, and compliance with energy risk policies;
Reviewing reports by the independent energy risk management function concerning policy and procedural compliance and taking appropriate action to mitigate losses or increased risks, if any, as necessary; Providing oversight and direction for specific projects including new markets, RFP development and review of RFP responses for physical and financial energy, fuel, related transportation transactions, and tools and systems needed to manage the risks of participation in energy markets;
Discussing elements of energy risk management best practices and developing an GWP ERMC opinion of their specific practicality; Overseeing the implementation and review of related Standard Operating Procedures and changes to them;
Conducting other activities relevant to the implementation and oversight of this Policy and related policies, as defined in Section 5, and procedures;
Recommending to the GWP General Manager the proper organizational structure, separation or consolidation of functional risk management activities;
At least, annually, review GWP’s energy risk management program and Risk Registry due to changes in business practices, improved procedures, GWP’s philosophy and strategy, or market changes; and ensuring continued compliance with its established guidelines; Reviewing this Policy and related policies as defined in Section 5, on an annual basis and recommending changes to this Policy to the City Manager for submittal to the City Council for approval; and Approving and periodically reviewing the related policies defined in Section 5.
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10 3.5GWP CHIEF OR ASSISTANT GENERAL MANAGER (POWER

MANAGEMENTSUPPLY)
The GWP Assistant General Manager or designee, as relates to Power Management Services, oversees the “front office,” reports directly to the GWP General Manager, and responsible for GWP’s overall energy supply. The GWP Assistant General Manager (Supply) shall:
Develop and maintain retail load forecasts and retail fuel and purchase power budgets;
Assure compliance with this Policy and related policies, as defined in Section 5, by the Energy Trading Manager and Marketers, Analysts and Schedulers, Real-time Traders or Authorized Agents, and the GWP Power Contacts Manager involved in energy risk management activities; Establish a review and approval process to provide timely responses to issues arising from day-to-day operations;
Oversee the development of hedge strategies to manage GWP’s energy exposure;
Recommend hedge strategies to the GWP ERMC that address GWP’s plans to manage its energy exposure;
Oversee the development of procedures for Energy Marketers, Schedulers, and Real-time Traders as needed;
Support and assist in the preparation of reports listed in Section 6.1, Reporting Requirements; and
Serve on the GWP ERMC.

3.6GWP ASSISTANT GENERAL MANAGER (BUSINESS SERVICES)
The GWP Assistant General Manager or designee, as relates to Business Services, oversees the “back office,” reports directly to the GWP General Manager, and responsible for GWP’s marketing development and operations activities. The GWP Assistant General Manager (Business Services) shall:
Oversee the responsibilities of the GWP Utility Manager (Financial) and GWP Business Systems Support Manager;
Provide management oversight for the direction and coordination of customer service activities with other sections of the utility; Direct marketing and public information activities of the utility. Oversee the development, implementation, promotion, evaluation, and modification of GWP customer relations, marketing, demand-side management, utility conservation, renewable energy, and revenue enhancing programs across all customer segments;
Direct the activities of support service functions for the utility; Prepare written reports and correspondence, and recommend procedural changes to improve efficient operation of the section;
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11 Prepare and monitor GWP budget and overall financial health of the utility; Lead the utility wide change management effort with respect to smart grid and related innovation. Responsible for the development and implementation of strategic and technology work plans;
Direct personnel and activities in the development of distributed resources, dynamic rates, including time of use, critical peak, and real time pricing, demand response, smart appliance, consumer device, advanced storage, peak-shaving, new web based services, and other smart grid program options for empowering consumers;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Serve on the GWP ERMC.

3.7GWP INTEGRATED RESOURCES PLANNING ADMINISTRATOR
The GWP Integrated Resources Planning Administrator reports directly to the authority under section 3.5 and plans, directs, supervises, and reviews the development, identification, and administration of power resources; plans, directs, supervises and reviews the development, negotiation, monitoring, administration, and settlement of transactions related to power resource contracts; and plans, directs and supervises participation in regulatory, legal and project administration efforts. The GWP Integrated Resources Planning Administrator shall:
Direct activities related to the preparation of forecasts of energy requirements and peak demands;
Direct the development of analytical studies related to power supply economics, generation, forecasting, regulatory and legislative impacts; Direct the City's power supply projects including generation, transmission and marginal costing studies;
Direct the preparation of utility data to assist in negotiating power marketing agreements and power purchases;
Direct contract negotiations to fill power supply requirements and to resolve power supply issues;
Direct the preparation of reports for regulatory agencies; Direct the development and maintenance of forward wholesale market information systems;
Direct the development and implementation of forward strategies; Negotiate and administer joint power resource development projects, regional transmission and power generating projects;
Analyze proposed litigation settlements and negotiate the settlement of disputes;
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12 Evaluate and report performance and compliance of existing power contracts;
Responsible for the development of the annual budget and long-term power cost forecasts;
Assist in the development of overall policies, plans, and objectives; and Prepare comprehensive written and oral reports and presentation recommendations; and
Participate on the GWP ERMC.

3.8GWP ENERGY TRADING MANAGER
The GWP Energy Trading Manager reports directly to the authority under section

3.5 and exercises technical, administrative, and management responsibility over staff performing energy trading. The GWP Energy Trading Manager shall:
Represent the “front office” in GWP’s energy risk management organization; The “front office” is responsible for energy trading, operations, portfolio optimization, load forecasting, transaction and scheduling, generating resource optimization, and hedging;
Assure daily compliance with the Energy Risk Management Policy and related policies, as defined in Section 5, and timely responses to issues arising from day-to-day operations;
Execute and manage energy transactions (purchases, sales, and hedges) in accordance with approved hedge strategies and within the requirements specified in the Trading Authority Delegation;
Understand the types of transactions individuals may engage in to manage the energy portfolio;
Adhere to the transaction approval process;
Actively acquire and analyze market intelligence and assist in developing hedge strategies;
Prepare transaction analyses and reports;
Communicate market intelligence within GWP’s risk management organization; and
Participate on the GWP ERMC.
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13 3.9GWP POWER PLANNING MANAGER
The GWP Power Planning Manager reports directly to the authority under section

3.5 and supervises the analysis, forecasting and planning activities for the electric utility's integrated resources established by GWP management. The GWP Power Planning Manager represents the “front office” in GWP’s energy risk management organization. The GWP Power Planning Manager shall:
Evaluate resource needs to meet forecasted loads and load patterns and performs technical and economic analysis of resource options; Perform modeling, analysis, and forecasting of load patterns and resource utilization;
Interpret and evaluate economic analyses, planning data, and study results;
Assist in evaluating opportunities for power supply acquisition and power project participation;
Assist in negotiating contracts to fill power supply requirements and to resolve power supply issues;
Evaluate market data and opportunities for power supply acquisition and power project participation;
Prepare and supervise preparation of technical and administrative reports and recommendations including the annual long-range power supply plan (integrated resource plan) and reports to regulatory bodies; Develop and recommend policies and procedures to ensure that power planning/marketing activities comply with NERC/WECC requirements and contractual provisions;
Develop and recommend procedures to effectively carry out optimization of the City's resource, transmission, and load portfolio; Assist with development of the annual budget;
Prepare and supervise preparation of reports and graphic displays for use in presentation of study results and recommendations; and Participate on the GWP ERMC.
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14 3.10GWP ENERGY RISK MANAGER
GWP’s Independent Risk Management Function is led by the GWP Energy Risk Manager. The GWP Energy Risk Manager represents the “middle office” in GWP’s energy risk management organization. The responsibilities of the GWP Energy Risk Manager include ensuring reports covering GWP’s energy portfolio position and credit exposures are prepared and reporting compliance with energy risk management policies and procedures. The GWP Energy Risk Manager also leads the development and review of business processes and internal control improvements throughout the energy transaction lifecycle. The GWP Energy Risk Manager will provide risk assessment input to the hedge planning and transacting activity, but will maintain a strict separation of duties. The GWP Energy Risk Manager will brief the GWP General Manager, as requested, regarding recent GWP energy risk management activities.

The GWP Energy Risk Manager will serve as facilitator of the GWP ERMC and reports directly to the GWP General Manager. In addition, the GWP Energy Risk Manager shall:
Perform responsibilities delegated by the GWP ERMC;
Serve, organize and conduct the GWP ERMC meetings;
Engage the EMRC in discussions regarding emerging risks, events and developments that could expose GWP to potential losses; Develop, recommend, and administer risk management processes and procedures, including best practice procedures;
Provide and administer energy risk management education/training to GWP management and staff;
Review energy risk management activities and risk controls, and recommend modifications of controls to meet changing business needs; Review adequacy and accuracy of reports, and report any deficiencies to the GWP ERMC. Recommend actions to address deficiencies; Assess energy risks to GWP in aggregate, by business unit, and by material business activity;
Ensure compliance, review, and recommend changes to the Energy Risk Management Policy and related policies, as defined in Section 5, and energy risk management procedures, as appropriate;
Monitor compliance of transactions with GWP’s Trading Authority Policy and Trading Authority Delegation and monitor GWP’s portfolio for compliance with GWP’s Hedge Policy;
Report to the GWP ERMC and GWP General Manager on GWP’s compliance with its energy risk policies and energy risk management in accordance with policies;
Manage credit exposure in compliance with the GWP Credit Policy; Report mark-to-market forward energy transactions for credit exposure purposes;
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15 Review and evaluate proposed longer-term transactions to be executed by GWP and ensure adequate analysis has been performed with proper assessment and mitigation of any such risk consistent with energy risk management objectives, risk tolerance guidelines, and energy risk management policies, including the financial, legal, credit, regulatory, reliability, and operational impacts;
Ensure the responsibilities of the GWP ERMC, as outlined in the Policy, are fulfilled;
Provide advice regarding the effectiveness of tools used or evaluated to assist in energy risk management for measuring, monitoring, and reporting performance;
Validate the tools and data used throughout GWP to measure, monitor, and report risk;
Support periodic internal audits of GWP risk control policies, processes and procedures with CoG Internal Audit to ensure overall operational compliance;
Conduct periodic review and update of the GWP Risk Registry, including status of mitigation plans and risk prioritization, and ensure effective strategies are in place to mitigate the top energy risks; Review and advise the GWP ERMC and the GWP General Manager of risk exposures in the GWP Risk Registry;
Ensure Standard Operating Procedures and Allegro Business Process Documents for each of the functional areas that fall under the Policy umbrella are maintained and updated, as necessary;
Be responsible for the oversight and effectiveness of GWP’s energy risk management policies, procedures, and trading control environment; Review and recommend, to the GWP ERMC, changes to functional activities, as appropriate, to ensure proper segregation of duties; Provide a timely summary of GWP ERMC accomplishments for the past year and goals for the upcoming year to the GWP ERMC and GWP General Manager;
Lead and assist in the preparation of reports listed in Section 6.1, Reporting Requirements;
Participate, as required, on committees and working groups such as risk management, legislative, regulatory, and cybersecurity; and Report regularly to the GWP ERMC, the following information, at a minimum, but not limited to:
oPortfolio modeling risk measures (1-60 months);
oPower cost projections and confidence intervals;
oProduction output and operational concerns;
oCredit and contract risk exposures;
oHedging strategies;
oEnergy policy and procedural violations;
oRegulatory and reliability compliance;
oBusiness continuity;
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16 oPhysical and cyber security in coordination with the City’s Information Systems Department;
oUpdates to the GWP Risk Registry; and
oOther Key Performance Indicators that support effective energy risk management

3.11GWP POWER CONTRACTS MANAGER
The GWP Power Contracts Manager reports directly to the authority under section 3.5 and recommends, negotiates, and prepares the City's power resource contracts and agreements in accordance with the direction and goals established by GWP management. The GWP Power Contracts Manager represents the “middle office” in GWP’s energy risk management organization. The GWP Power Contracts Manager shall:
Actively participate in regulatory, legal, and project administration efforts. Identify and assist in the negotiation and evaluation of contracts, including resource purchases and sales, transmission, natural gas, transportation, renewables and emissions, settlement, interconnection, interchange, development, participation, operation, and agreements;
Monitor and support the GWP’s participation in utility industry’s federal, state, and local regulatory authority activities;
Review, evaluate, revise, and author contracts, regulatory filings, and legal filings related to the GWP's energy resource operations; Review and ensure the GWP is in compliance with contractual terms and is receiving similar compliance from contracting parties in accordance with prepared task lists, schedules and loss calculations, procedures, and guidelines for administering and evaluating all energy resource related agreements;
Evaluate existing and proposed contractual arrangements and recommend desirable modifications for the purpose of optimizing the GWP's benefits;
Analyze and recommend resource-operating strategies and assist in the creation of contractual guidelines for related resource functions; and Support strategies related to legal disputes.
Assign appropriate funding based on contract terms and budget; and Notify GWP Management if it is anticipated that there will be inadequate funds available in the budget to transact;
Adhere to confirmation process by confirming trades executed under enabling agreements;
Manage the counterparty approval, credit, and collateral management processes;
Develop and manage Power Management’s budget for bulk power, gas, transmission, transportation, environmental commodities, and related contractual services;
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17 Oversee trade capture and validation activities including actualization of trades, etags, generation resource data, and review accuracy, completeness, and timeliness of data in the trading system; Monitor and manage Renewable Energy Credits as it relates to creation, transfer, and retirement for RPS Compliance;
Carbon Allowance allocations, offsets, and mandatory greenhouse gas emissions reporting and verification;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5;
Serve as “Energy Risk Manager” back-up; and
Participate on the GWP ERMC.

3.12GWP UTILITY FINANCE MANAGER
The GWP Utility Manager reports directly to the authority under section 3.6 and manages the “back office” in GWP’s energy risk management organization. The Back Office, as part as the GWP Finance, provides settlement services; documents the required accounting treatment of forward transactions; and provides the related valuation of these transactions to enable the preparation of invoices and reporting of forward transactions in GWP’s financial statements in accordance with prevailing accounting rules. The GWP Utility Manager shall:
Oversee and monitor the back office for transactional analysis and accuracy;
Develop and apply accounting policies to financial transactions; Oversee the settlement of transactions (verification, accounts payable/receivable process);
Manage the counterparty approval, credit, and collateral management processes;
Correctly classify and report transactions. (Certain transactions may differ in their reporting requirements, depending on whether they qualify as “existing assets, liabilities, and firm commitments” or “anticipated transactions” for hedge accounting. CoG Finance shall determine how transactions are classified for reporting purposes and ensure that hedges are accounted for in accordance with generally accepted accounting principles.);
Be responsible for Dodd-Frank compliance;
Provide appropriate funding. (CoG Finance shall maintain control procedures over electronic funds transfer for payments and collections.

This is intended to ensure that cash payments are properly disbursed and authorized trades are independently confirmed and processed.); and Notify GWP Management and the Power Contracts Manager if GWP Finance anticipates there will be inadequate funds available in the budget to transact.
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18 Supports CoG Finance in preparing the Comprehensive Annual Financial Report that complies with the accounting requirements promulgated by the Governmental Accounting Standards Board (GASB);
Participate, as required, on finance committees and working groups; Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC.

Under no circumstances will members of the GWP Finance be given the authority to enter into any energy transactions on behalf of the utility.

3.13GWP UTILITY BUSINESS SYSTEM SUPPORT ADMINISTRATOR
The GWP Business Systems Support Manager reports directly to the authority under section 3.6 and has the responsibility of managing, directing, and coordinating the planning and implementation of major utility technology projects.

GWP’s Business Systems Support Manager shall:
Manage, support, and maintain the Energy Trading and Risk Management (ETRM) applications, databases, backups, and redundancies; Conduct quarterly audits of ETRM users access and provide reporting to management as needed;
Maintain OATI security and certificate management;
Administer all aspects of IT security with firewall monitoring; Develops and maintains GWP cybersecurity training, procedures, and policies;
Participate, as required, on cybersecurity committees and working groups. Coordinate information technology activities with City’s Information Services;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC

3.14CITY OF GLENDALE FINANCE
The Finance Department provides timely, accurate, clear and concise information to the City Council, City Manager, GWP General Manager, GWP ERMC, and various City Departments and is dedicated to managing the City’s resources in a fiscally conservative manner. City of Glendale’s Director of Finance/Information Technology shall:
Provide support and assistance on GWP financial and budgetary issues; Provide long range financial planning functions including revenue and operational expense projections;
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19 Provide recommendations on operations effectiveness measures, and revenue strategies;
Review existing and proposed ordinances, statues, resolutions, and other documents;
Direct the City’s energy risk management functions including litigation, insurance, and external auditors;
Confer on financial policies and procedures;
Assure compliance with this Policy and related policies, as defined in Section 5; and
Serve on the GWP ERMC.

3.15CITY OF GLENDALE LEGAL
The City Attorney's Office is committed to providing professional, quality legal services that ultimately protect the interests of the City of Glendale, its departments, and the City Council. City of Glendale’s City Attorney shall:
Review the Policy and the related policies, as defined in Section 5, and recommend updates as appropriate in compliance with the City Charter and applicable law;
Negotiate master/enabling agreements with counter-parties as directed by the authority under section 3.5 and GWP Power Contracts Manager; Assess legal enforceability of contracts with applicable laws and regulations;
Assure compliance with the Energy Risk Management Policy and related policies, as defined in Section 5; and
Participate on the GWP ERMC.

3.16CITY OF GLENDALE AUDIT
The City of Glendale Internal Audit assists the City in improving operations by providing independent audits and consulting services designed to add value and promote transparency, accountability, efficiency and effectiveness. The City of Glendale’s Internal Audit Manager shall:
Verify proper segregation of external and internal reporting, energy risk management, accounting, treasury, and trading duties and maintenance of files;
Sample and review activities for compliance with related policies and procedures;
Document and report audit findings to GWP ERMC, including compliance with and discrepancies from this Policy and the related policies, as defined in Section 5, as well as any other irregularity which could expose GWP to financial or operational risk; and
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20 Participate on the GWP ERMC.

3.17CONFLICT OF INTEREST AND COMPLIANCE
Potential conflict of interest by persons directly affected by this Policy is covered by State law and City of Glendale’s citywide Conflict of Interest Charter Code.

All City of Glendale employees who hold positions mentioned in this Policy or perform functions described herein shall not enter into, or direct others to enter into, any energy transactions or other related transactions other than on behalf of GWP, the City of Glendale, or its authorized agents.

4. SCOPE OF BUSINESS ACTIVITIES GOVERNED BY THIS
POLICY
The scope of this Policy is designed to address the management of the energy risks associated with GWP, as documented in GWP’s Risk Registry. The GWP Risk Registry is a comprehensive list of risks that affect GWP’s short-term business operations and long-term strategic planning and is maintained by the GWP Energy Risk Manager. The GWP Risk Registry is comprised of Tier1, Tier 2, and Tier 3 risks distinguished by business category and prioritized by impact and likelihood. GWP and CoG personnel have been identified as the owners of each risk and are responsible for developing strategies to mitigate each risk. The number of risks may vary dictated by business and market changes. The GWP Risk Registry reporting requirement is outlined in Section 6.1.

5. RELATED POLICIES AND REGISTRY
Supporting related policies and registry are identified below. Responsibility for their approval, modification, oversight, and compliance shall be consistent with the organization and governance of this Policy (Section 3). * Denoted CoG City Council responsibility for final approval.
GWP Trading Authority Policy*
GWP Trading Sanctions Policy
GWP Credit Policy
GWP Hedge Policy
GWP Business Continuity Policy
GWP Cyber Security Policy
GWP Risk Registry
GWP Electric Cash Reserves Policy*
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21 6. REPORTING
Reports required by this Policy communicate the operational, market, and credit risks assumed by GWP, and provide information to evaluate the portfolio performance and the effectiveness of the energy risk management program. The reports should be used as a basis for management discussions to determine future energy transactions and strategy.

6.1REPORTING REQUIREMENTS
Management reporting will act as a formal means of communicating the performance of energy transactions and management decisions. On an ongoing basis, management and staff must also establish sufficient communications among parties with responsibilities relative to this Policy.

The following table identifies the reports that must be generated, their normal frequency, report access or distribution, and the originator of the report:

Table 6.1 – Reporting Requirements
Report Report Access
Normal
Frequency Originator
Load/Resource
Balance
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly GWP Energy Risk
Manager
Trade Data Report GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
Mark-to-Market
Report
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
Counterparty Credit
Exposure Report
GWP ERMC Members and
Participants
All Transaction
Implementation Staff
Monthly
(Updated
Daily)
GWP Energy Risk
Management Section
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22 Risk Registry and
Risk Mitigation
Activities (1)
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
T1- Monthly
T2- Quarterly
T3 - Annually
GWP Energy Risk
Manager
Portfolio Modeling
Report
GWP ERMC Members and
Participants
All Transaction Implementation
Staff
Monthly GWP Energy Risk
Management Section
(1) As required in Section 3.3, GWP General Manager Responsibilities, the GWP General Manager shall report to the City Manager, annually, on the risk profile of the energy portfolio and on the results of energy risk management activities.

7. POLICY REVIEW
Following approval of this Policy, the GWP ERMC shall periodically, no less than annually, review the Policy and the related policies, as defined in Section 5, and recommend updates as appropriate in coordination with the GWP General Manger. Examples of events prompting updates to this Policy and related policies and reviews are changes in regulatory requirements, significant changes in the resource portfolio, significant changes in variable energy prices of alternative resources, changes in regulations, and reliability concerns.

8. PROCEDURES
Standard Operating Procedures (SOP) and Desk Procedures shall be developed for each functional area to provide specific operating criteria and parameters for day-to-day energy risk management activities as needed. The operating criteria and parameters shall be updated as frequently as appropriate to reflect changes in market conditions and staffing levels. All procedures shall be reviewed approved by management and monitored and reviewed by the GWP ERMC. 93 of 161
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TRADING AUTHORITY POLICY
TBD, 2022
EXHIBIT 3
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i

TABLE OF CONTENTS

1. POLICY PURPOSE 1

2. TRADING AUTHORITY POLICY OBJECTIVES 1

3. PROCEDURAL REQUIREMENTS 1

3.1 EXECUTION AUTHORITY 1

3.2 CONTRACT REQUIREMENTS 2

3.3 CREDIT REQUIREMENTS 4

3.4 TRADING ON PREMISES 4

3.5 DEAL CAPTURE 5

3.6 SPECULATION 5

3.7 NON-STANDARD COMMODITIES 5

3.8 APPROVAL FOR NEW COMMODITIES, NEW PRODUCTS AND
NEW MARKETS 5

4. TRADING AUTHORITY MATRICES 6

4.1 BILATERAL ELECTRIC POWER AND TRANSMISSION
TRANSACTON LIMITS 6

4.2 CAISO TRANSACTION LIMITS 8

4.3 NATURAL GAS TRANSACTION LIMITS 9

4.4 EMISSION ALLOWANCE AND EMISSION REDUCTION CREDIT
TRANSACTION LIMITS 11

4.5 RENEWABLE ENERGY CREDIT TRANSACTION LIMITS 12

4.6 CARBON ALLOWANCE AND CARBON EMISSION OFFSET
TRANSACTION LIMITS 13

4.7 LOW CARBON FUEL STANDARD TRANSACTION LIMITS 14

5. ACKNOWLEDGEMENTS 15

5.1 CLEAR AUTHORITY 15

5.2 VIOLATIONS AND SANCTIONS 15

5.3 SANCTIONS FOR OPERATIONAL/SCHEDULING/TAGGING/
TRANSMISSION ERRORS 15

5.4 POLICY EFFECTIVE 15

6. APPENDICIES 16

APPENDIX A - ACKNOWLEDGEMENT OF TRADING AUTHORITY 16
APPENDIX B - INSTRUMENT OF TRADING AUTHORITY DELEGATION 17 95 of 161
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1 1. POLICY PURPOSE
The purpose of this Trading Authority Policy is to define the authority granted by the Glendale City Council to the City Manager and the Glendale Water and Power (GWP) General Manager to execute energy related transactions and to delegate trading functions to Glendale Water and Power staff within the limits defined in this policy. This Authority Policy is intended to supplement and complement the GWP Energy Risk Management Policy.

2. TRADING AUTHORITY POLICY OBJECTIVES
The objective of this Trading Authority Policy is to define:
The commodities and products that can be transacted,
The authorized lead time and term for each transaction, The authorized maximum price and volume,
Counterparty contract and credit requirements,
The process for approving new commodities, products or locations, The City Council’s intentions regarding hedging and speculating, and Other relevant factors associated with due diligence in authorizing transactions to be executed.

3. PROCEDURAL REQUIREMENTS
The following defines procedural requirements that apply to all commodities and products transacted upon this Trading Authority Policy.

3.1Execution Authority
The Glendale City Charter (the Charter), Article VI, Section 9, generally requires competitive bidding for contracts for the purchase of materials or products equal to or greater than $50,000. However, Article VI, Section 9 of the Charter authorizes the City to dispense with competitive bidding where the City Council determines it is in the best interest of the City to do so and acts by resolution setting forth the reason for such action. It is in the City's best interest to dispense with competitive bidding for wholesale energy transactions as they must be completed in a rapidly changing market that is not structured to accommodate public entity bidding requirements. Wholesale energy transactions are related to energy supplied by one producer/marketer/utility to another for eventual resale to consumers.

On an annual basis, the General Manager requests that the City Council authorize the City Manager, or designee, to dispense with competitive bidding for wholesale energy transactions on the grounds that it is in the City’s best interest in accordance with Article VI, Section 9 of the Charter. Such wholesale energy 96 of 161
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2 transactions include electrical energy and capacity, ancillary services, transmission, renewable energy attributes, carbon allowances and carbon emission offsets, emission allowances and emission reduction credits, low carbon fuel standard credits, natural gas, transportation, imbalance and storage.

This resolution includes any GWP gas scheduling services managed for GWP by a third party(ies).

This policy identifies the City Council authorized levels for the City Manager and GWP General Manager and explicitly gives the City Manager and GWP General Manager the authority to delegate authority levels to others. This will be done via a Trading Authority Delegation. The City Manager and GWP General Manager have the authority to modify authority levels set within the Trading Authority Delegation at their sole discretion as long as the delegated authority does not exceed their own authority per this Trading Authority Policy. A form of Trading Authority Delegation is attached to this Policy as Appendix B.

Execution Authority of the City Manager and the GWP General Manager is outlined by commodity in the authority matrix sections found below. The trading limits, with the exception of pricing, apply to both purchases and sales. Price limits apply to only purchases. Per Trading Day and Aggregate Limits, as applicable, are applied to gross amounts transacted in total, and not to buys and sells netted together.

Glendale Municipal Code Section 1.04.080 states: “Whenever a power is granted to or a duty is imposed upon a city officer by this code or any other ordinance of the city, the power may be exercised or the duty performed by an assistant or a deputy of the officer or by a person authorized pursuant to law by the officer, unless this code expressly provides otherwise.”

3.2Contract Requirements
Transactions with counterparties shall only be permitted if GWP has:
An active, valid, and executed agreement enabling such trading activity with that counterparty approved as to form by the City Attorney, or his or her designee.
Long-form confirmations may be used as a valid agreement in lieu of a permanent agreement, when necessary, if approved by the City Manager or GWP General Manager and approved as to form by the City Attorney. A long-form confirmation is a confirmation that is used to confirm a transaction when no underlying enabling agreement exists between the parties. In addition to confirming the transaction details, the long-form confirmation may incorporate by reference the terms and conditions of the underlying enabling agreement to be executed. For example, a long-form confirmation for a physical power transaction may incorporate by reference the terms and conditions of the WSPP agreement.
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3 Under this provision,
City Attorney review/ stamp/ approval as to form is NOT required where:
(1) the transaction is less than 5 years in duration; and (2) the transaction is not one that requires City Manager or City Council approval under the Energy Risk Management Policy, Trading Authority Policy and Trading Authority Delegation; and
(3) one or more of the following situations applies:
(a)For Agreements under the WSPP:
Both parties are WSPP members, the parties execute a standard Confirmation agreement, and no modifications to the WSPP are made; or
Both parties are WSPP members, the parties execute a standard Confirmation agreement, and any modifications to the WSPP are set forth in a valid, active, current agreement that has been previously approved as to form by the City Attorney’s Office within the last 3 years;
(b) For Agreements under the NAESB:
Both parties execute a standard Confirmation agreement; the parties have already entered into a NAESB Base Contract that was previously approved as to form by the City Attorney’s Office; and any modifications to the NAESB are set forth in a valid, active, current agreement that has been previously approved as to form by the City Attorney’s Office within the last 3 years.

Because the WSPP Agreement and NAESB Agreement are posted, FERC- approved, industry standard agreements, the WSPP and NAESB form agreements do not require approval as to form by the City Attorney’s Office.

However, the WSPP and NAESB cover sheet and any modifications to the WSPP and NAESB terms and conditions must be reviewed and approved as to form by the City Attorney’s Office. If the enabling agreement, other than the standard form WSPP or NAESB, has not been reviewed in over 3 years, the City Attorney’s Office must review the agreement to ensure the provisions are still valid/ active/ enforceable.

City Attorney review/ stamp/ approval as to form IS required in any one of the following situations:
The agreement does not fall under the WSPP or NAESB;
In the case of a WSPP Agreement, one of the parties is not WSPP- enabled;
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4 If the agreement is a WSPP Agreement, the agreement includes modifications to WSPP standard form agreement. These modifications could be included in a long-form confirmation, a “Master Confirmation” document, a “Special Conditions” document, exhibits, addendums, amendments, and such;
If the agreement is a NAESB Contract, the agreement includes modifications to the NAESB standard form contracts. These modifications could be included in a long-form confirmation, a “Master Confirmation” document, a “Special Conditions” document, exhibits, addendums, amendments, and such; The confirmation adds legal terms and conditions (beyond the confirm standard form, which would typically only include the specifics of the deal such as counterparties, price, product, delivery point, term, etc.);
There are questions or concerns regarding the legal terms and conditions, signatory or levels of authority required, or any questions whether the deal falls within the Risk Management Policy.

3.3Credit Requirements
Counterparty trading credit limits, trading restrictions, and other Credit Policy provisions shall not be intentionally exceeded or violated. (Note: Since credit exposures are a function of not only positions traded, but also a function of market pricing and volatility, credit exposure to a counterparty may unintentionally exceed a credit limit purely due to changes in the forward market.) Entering into transactions with a counterparty that has total credit exposure greater than or equal to its open line of credit and the total of any security currently provided will not be allowed unless approved by the City Manager, the GWP General Manager, or the ERMC.

Entering into transactions with a counterparty that violate current trading restrictions will not be allowed unless approved by the City Manager, the GWP General Manager, or the ERMC.

3.4Trading On and Off Premises
All bilateral trades must be executed via a recorded communication method such as a voice recorded communication line, instant messaging (IM) application, or an online broker account that is maintained and controlled by personnel who are independent of the trading function. Email confirmations can serve as a permitted communication recording method. Off-premise bilateral trading is permitted, following the City of Glendale hybrid work policy, but trades must be executed through an approved recorded communication method. 99 of 161
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5 3.5Deal Capture
Any transaction(s) executed by GWP employee or agent must be accurately captured in the corresponding Allegro system, the same working day or shift, to facilitate the nightly import and export process. Excessive deal capture violations will be reported to the ERMC.

3.6Speculation
No speculative trading activities shall be permitted, and no speculative trading positions shall be initiated. Speculation is the opposite of hedging. A speculator holds no offsetting position(s) in the spot market and deliberately initiates price risk in order to reap potential rewards.

3.7Non-Standard Commodities
The City Council must approve any transaction that involves commodities not listed in this Trading Authority Policy.

3.8Approval for New Commodities, New Products and New Markets The purpose of defining a process for the introduction of a new commodity, new product, or new market is to ensure that the associated exposures are thoroughly reviewed and understood by the ERMC, GWP management, and GWP Staff.

Within the commodities that have been approved by City Council, the ERMC must approve the use of all new products or the entry into new commodity markets (e.g. trading venues) before the execution of any such transaction. For new commodities, the ERMC must recommend any such commodity for approval by City Council before the execution of any such transaction.

The following transaction types are not new to GWP and therefore do not require the review and approvals described within this Section 3.8 if they are bilateral or within previously used trading venues: (1) a physical spot or forward bilateral capacity, energy, ancillary service or transmission transaction; (2) a physical spot or forward natural gas, imbalance, storage or transportation transaction, or related gas scheduling services; (3) an over-the-counter (OTC) physical option (calls or puts); (4) a CAISO authorized pool transaction, as noted in Section 4.2; (5) emission allowance and emission reduction credit transaction, as noted in Section 4.4; (6) a renewable energy credit transaction; (7) a carbon allowance or carbon emission offset transaction; (8) an over-the-counter (OTC) financial transaction; (9) an exchange-traded transaction; or (10) a low carbon fuel standard credit transaction.
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6 4. TRADING AUTHORITY MATRICES
A vital control element in the management of risk is the development of and adherence to transaction limits. Limits ensure that trading and hedging activity is appropriate and controlled at various levels of position aggregation and duration of transactions. The limits are established in consideration of overall portfolio strategies, market conditions, and risk tolerance levels.

4.1 BILATERAL ELECTRIC POWER AND TRANSMISSION TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for power and transmission transactions.

Per Transaction Limits Per Trading Day
Limits Aggregate Limits
Title Product Term Lead
Time
MW
Size
$/
MWH
Total
MWH
Total
$
Total
MWH Total $
City
Council
Electric
Power
and
Trans
No
Limit
No
Limit
No
Max.

No
Max. No Max. No
Max. No Max. No
Max.
> 2
Years
< 5
Years
100 $100City
Manager
and GWP
General
Manager
Electric
Power
and
Trans < 2
Years
< 5
Years
No
Max.

No
Max.
2,190,000 $150
Million 4,380,000 $300
Million

4.1.1 Bilateral Electric Power and Transmission Transaction Limits Matrix Explanations
Transaction Limits represent the MW volume per hour and dollars/MWH for each transaction executed.
Per Trading Day Limits represent the total MWh volume and dollars for all transactions executed in a trading day.
Aggregate Limits represent the sum total MWh volume and dollars for all open forward transactions with all counterparties.
Lead time represents the time period from the date a trade is executed to the start of the trade.
The dollar limits are based upon electric power only and do not include transmission, however, the Term, Lead Time, and Quantity limits do apply to transmission.
To the extent the transaction price can be identified separately for energy and renewable energy attributes, the energy portion of any bundled (energy and renewable energy attribute) transaction must be monitored against the limits above, while the renewable energy attribute portion of 101 of 161
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7 any bundled transaction must be monitored against the renewable energy credits authority matrix.
Authorized products include spot and forward electric power and transmission, including both physical and financial derivatives, as well as bilateral capacity and bilateral ancillary services. Financial derivatives may be OTC or exchange traded products.

4.1.2 Authorized Delivery Locations
Trading at delivery locations that are normal to the daily course of business for GWP to the extent transmission is available, is authorized as follows:

Unrestricted Delivery Locations
WECC including CAISO
Trading at any other delivery locations shall be prohibited unless approved by the City Manager, GWP General Manager, or GWP ERMC.

4.1.3 Firmness of Power
The product firmness of all transactions must be provided for in an executed agreement between GWP and the appropriate counterparty. Sales commitments must never be more “firm” than the supply source, including the purchase side of back-to-back sales, swaps or spreads, unless the sale can be resupplied by GWP generating resources or sufficient and timely reserves that are exclusive of reserves for the single largest contingency. Transaction(s) cannot reduce system reliability and must be logged in detail including specific resupply resource(s). The City Manager or GWP General Manager can provide pre- approved authority to sell power that is more “firm” than the supply source without sufficient and timely reserves.

4.1.4 Transmission Service Firmness and Volume
Transmission purchase(s) must be at least of “equal” firmness to the energy component of the associated transmission purchase(s). If firm transmission is unavailable, less-firm transmission can be used as long as there are sufficient reserve resources to supplement curtailed schedule(s) caused by transmission priority. Utilization of less-firm transmission cannot reduce system reliability and must be logged in detail including specific reserve resource(s). The City Manager or GWP General Manager can provide pre- approved authority to purchase power that is more “firm” than the associated transmission without sufficient reserve resources.

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8 transaction, the volume of the transmission purchase shall not exceed the energy component of the associated transmission purchase.

4.2 CAISO Transaction Limits
The following sets transaction limits, definitions, and procedural requirements for CAISO transactions.

CAISO Per Transaction Limits (up to)
Title Product Delivery
Lead Time Term MW
Size $/MWh
City
Council All CAISO Products No Limit No Limit No
Max No Max
Imports/Exports
As required
by CAISO < 1 Week No
Max No Max
Ancillary Service Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below regarding Inter SC Energy
Transactions
Generation Awards
Demand Awards
Virtual Transaction
Awards
None None None None
City
Manager
and
General
Manager
Congestion Revenue
Rights
As required
by CAISO < 1 Year No
Max No Max

4.2.1 CAISO Transaction Limits Matrix Explanations
Generation Award Limits are per generating unit. A Generation Award is defined as the amount of energy a market participant is required to generate within the market after submitting a generation offer for the supply of Energy and/or Ancillary Services, including Self Schedules, submitted by Scheduling Coordinators for generating resources, conveyed through a three part offer to either the DA or RT CAISO Markets. Demand Award Limits are per each load location. A Demand Award is defined as the energy awarded to a market participant according to the amount submitted in the DA market via a demand bid that indicates the MWh of Energy the Scheduling Coordinator is willing to purchase, the price at which it is willing to purchase the specified Energy, and the applicable Trading Hours for which the energy will be purchased. Import and Exports are by location and are each monitored separately.

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9 electronic tag. Exports are defined as energy located within the ISO Controlled Grid that is exported out of the CAISO Controlled Grid via an energy award and electronic tag.
An Inter SC Energy Transaction is an energy quantity traded from one SC to another SC for a specific hour and location. Inter SC Trades may be submitted to the ISO but are not monitored as they are a direct result of the bilateral trade executed between the SC’s. The bilateral transaction will only be monitored in accordance with the Bilateral Electric Power and Transmission Matrix.
Limits for Ancillary Service Awards apply to the Regulation and Operating (Spinning and Non-Spinning) Reserve Market. Ancillary Services are defined as Regulation, Spinning Reserve, Non-Spinning Reserve, Replacement Reserve, Voltage Support and Black Start together with such other interconnected operation services as the ISO may develop in cooperation with Market Participants to support the transmission of Energy from Generation resources to Loads while maintaining reliable operation of the ISO Controlled Grid in accordance with Good Utility Practice. Only Congestion Revenue Rights that are bought and sold via the long- term, annual and monthly auctions or in the secondary market are monitored per the limits above. This excludes congestion revenue rights allocated in the Annual Allocation.

4.3 NATURAL GAS TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for natural gas and gas transportation transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Daily
MMBtu
Volume
$/
MMBtu Total MMBtu Total $
City Council Natural Gas
& Transport No Limit No
Limit No Max. No Max. No Max. No Max.
> 2 Years
< 5 Years 10,000 $10City Manager
and GWP
General
Manager
Natural Gas
& Transport
< 2 Years
< 5 Yrs.

No Max. No Max.
6,000,000 $24
Million

4.3.1 Natural Gas Transaction Limits Matrix Explanations Transaction Limits represent the MMBtu volume per day and dollars/MMBtu for each transaction executed.
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10 Aggregate Limits represent the total MMBtu volume and dollars for all forward transactions.
Lead time represents the time period from the date a trade is executed to the start of the trade.
The dollar limits are based upon natural gas only and do not include transportation, however, the Term, Lead Time, and Quantity limits do apply to transportation.
Authorized products include physical natural gas, imbalance, transportation and storage as well as financial natural gas derivatives, including financial basis transactions. Financial natural gas derivatives may be OTC or exchange traded products.

4.3.2 Authorized Delivery Locations
Physical natural gas transactions may only be executed for delivery at GWP facilities or at delivery locations in which an approved transportation agreement is in place to transport the natural gas to GWP facilities.

Financial natural gas transactions may only be executed at the following locations:
Henry Hub
SoCal Border
San Juan Basin
Permian Basin
AECO
SoCal Citygate
PG&E Citygate
Trading at any other locations shall be prohibited unless transportation is available in the event physical delivery is deemed necessary.

4.3.3 Natural Gas Firmness
The product firmness of all trades must be provided for in an executed agreement between GWP and the appropriate counterparty. Sales commitments must never be more firm than the supply source unless pre-approved by the City Manager or GWP General Manager.

4.3.4 Transportation Firmness
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11 4.4 EMISSION ALLOWANCE AND EMISSION REDUCTION CREDIT TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for Emission Allowance and Emission Reduction Credit (ERC) transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
Allowances $/Allowance Total
Allowances
Total $
City
Council
SO2 and
NOx
Emission
Allowances
No Limit No Limit No Max No Max No Max No Max
City
Manager
and
General
Manager
SO2 and
NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required As
Required
Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
Credits $/Credit Total
Credits
Total $
City
Council
Emission
Reduction
Credits
No Limit No Limit No Max No Max No Max No Max
City
Manager
and
General
Manager
Emission
Reduction
Credits
As
Required
As
Required
As
Required Market As
Required
As
Required

4.4.1 Emission Allowance and Emission Reduction Credit Transaction Limits Matrix Explanations
Under the Acid Rain Program, one allowance is equivalent to one ton of SO2 or NOx. Under the ERC, one credit can be equivalent to one pound of pollutant reduction per day or one ton of pollutant reduction per year.

Under SCAQMD Reclaim program, SO2 or NOx may be purchased and sold by dollars per pound.
Per Transaction represent the total quantity in allowances or credits and dollars/allowance or dollars/credit for each transaction executed. Aggregate Limits represent the sum total quantity in allowances or credits and dollars for all forward transactions.
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12 Lead time represents the time period from the date a trade is executed until actual transfer of the certified emission allowance(s) or credit(s) confirmed in the Allowance Management System (AMS).
Maximum trading limits (As Required) and market execution prices (Market) will be based on meeting emission compliance requirements for the Grayson Power Plant or other GWP emitting resources as reflected in the Transaction Limits Matrix.
Authorized emission allowances and credits include Particles Oxidation Catalysts (POC), Volcano Smog (VOG), Volatile Organic Compound (VOC)Reactive Organic Gas (ROG), Particulate Matter (PM2.5 & PM10), Sulfur Dioxide (SO2), and Nitrogen Oxide (NOx).
Participation in the Emission Auction is not governed or limited by the Trading Authority Policy. Due to varying compliance needs and market complexities, auction strategies will be reviewed by the ERMC and approved in writing by GWP management.

4.5 RENEWABLE ENERGY CREDIT TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for renewable energy credit (REC) transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
REC
Units
$/
REC
Unit
Total
REC
Units
Total $
City
Council RECs No
Limit
No
Limit No Max. No Max. No
Max. No Max.
> 2
Years
< 5
Years
876,000 $50City
Manager
and
General
Manager
RECs
< 2
Years
< 5
Years
No Max No Max
2,190,000 $50 Million

4.5.1 Renewable Energy Credits Transaction Limits Matrix Explanations The matrix above addresses authority for REC transactions that are stand- alone transactions (from power), or where the price of such RECs are unbundled from the price of power. Bilateral power trades with renewable energy attributes bundled in the power price will be monitored against the bilateral power matrix.
Per Transaction Limits represent the total units and dollars/unit for each REC transaction executed.
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13 Aggregate Limits represent the sum total units and dollars for all open forward transactions with all counterparties and on all trading venues. Lead time represents the time period from the date a trade is executed until:
othe start of the delivery obligation in the case of forward RECs to be generated, or
othe actual transfer of standalone RECs occurs in WREGIS for certified RECs that have been banked or generated.

4.6 CARBON ALLOWANCE AND CARBON EMISSION OFFSET TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for carbon (CO2e) allowances and carbon emission offsets.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
CO2e
$/
CO2e
Total
CO2e Total $
City
Council CO2e No
Limit
No
Limit No Max. No Max. No Max. No Max.
> 2
Years
< 5
Years
1,000,000 $50City
Manager
and
General
Manager
CO2e
< 2
Years
< 5
Years
No Max No Max
3,000,000 $50 Million

4.6.1 Carbon Allowances and Carbon Emission Offsets Transaction Limits Matrix Explanations
The matrix above addresses authority for Carbon Allowances and Carbon Emission Offsets such as CCA, GCCO, CCO3, and CCO8.
Per Transaction Limits represent the total allowance/offset volume and dollars/CO2e for each Carbon Allowance or Carbon Emission Offset transaction executed.
Aggregate Limits represent the total allowance/offset volume and dollars for all forward Carbon Allowance or Carbon Emission Offset transactions. Lead time represents the time period from the date a trade is executed until the actual transfer of the certified Carbon Allowances or Carbon Emission Offsets occur in CITSS.
Participation in the Carbon Auction is not governed or limited by the Trading Authority Policy. Due to varying compliance needs and market complexities, auction strategies will be reviewed by the ERMC and approved in writing by GWP management.
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14 4.7 LOW CARBON FUEL STANDARD (LCFS) CREDIT TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for Low Carbon Fuel Standard (LCFS) Credit transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
LCFS
Credits
$/
LCFS
Credit
Total
LCFS
Credits
Total $
City
Council LCFS No
Limit No Limit No Max No Max No Max No Max
> 2
Year
s < 5
Year
s
50,000 $1000City
Manager
and
General
Manager
LCFS
< 2
Year
s
< 5
Years
No Max No Max
300,000 $100
Million

4.7.1 Low Carbon Fuel Standard (LCFS) Credit Transaction Limits Matrix Explanations
The matrix above addresses authority for Low Carbon Fuel Standard Credits
Per Transaction Limits represent the total credits and dollars/credit for each Low Carbon Fuel Standard Credit transaction executed. Aggregate Limits represent the total credits and dollars for all forward transactions.
Lead time represents the time period from the date a trade is executed until actual transfer of the certified LCFS credit(s) confirmed in the LCFS Reporting Tool (LRT).
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15 5. ACKNOWLEDGEMENTS

5.1 Clear Authority
Any situation where authority is in question from a “clearly authorized” standpoint should be reviewed and authorized by the City Council.

5.2 Violations and Sanctions
Violations of this Trading Authority Policy must not occur. Should it be deemed that non-compliant incidents did occur; the Energy Risk Manager will report such incidents to the Energy Risk Management Committee. Should the Energy Risk Management Committee deem that a violation has occurred, the GWP General Manager, at his or her discretion, will report incident(s) and responsible party(ies) according to the GWP Trading Sanctions Policy.

5.3 Sanctions for Operational/Scheduling/Tagging/Transmission Errors Errors made while performing operational, scheduling or transmission responsibilities may result in disciplinary action according to the guidelines outlined in the GWP Trading Sanctions Policy.

5.4 Policy Effectiveness
This Trading Authority Policy is in effect upon the City Council’s approval and shall remain in effect until a replacement policy has been approved by the City Council superseding this Trading Authority Policy.
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16 APPENDIX A

ACKNOWLEDGEMENT OF TRADING AUTHORITY POLICY
Compliance Statement
I hereby acknowledge receipt and review of GWP’s Trading Authority Policy and Appendix B: Instrument of Trading Authority Delegation dated TBD, 2022.

I further acknowledge that this Trading Authority Policy defines the standards of GWP’s energy risk management efforts that I am required to comply with.

If I become aware of non-compliance with the Trading Authority Policy, I will report such non-compliance to the Energy Risk Manager, GWP Management, or any member of the ERMC.
_____________________________________
Signature
_____________________________________
Type or Print Name
_____________________________________
Title
_____________________________________
Date
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17 APPENDIX B

INSTRUMENT OF TRADING AUTHORITY DELEGATION
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TRADING AUTHORITY POLICY
July 1, 2021
TBD, 2022
EXHIBIT 4
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TABLE OF CONTENTS

1. POLICY PURPOSE 1

2. TRADING AUTHORITY POLICY OBJECTIVES 1

3. PROCEDURAL REQUIREMENTS 1

3.1 EXECUTION AUTHORITY 1

3.2 CONTRACT REQUIREMENTS 2

3.3 CREDIT REQUIREMENTS 4

3.4 TRADING ON PREMISES 4

3.5 DEAL CAPTURE 5

3.6 SPECULATION 5

3.7 NON-STANDARD COMMODITIES 5

3.8 APPROVAL FOR NEW COMMODITIES, NEW PRODUCTS AND
NEW MARKETS 5

4. TRADING AUTHORITY MATRICES 6

4.1 BILATERAL ELECTRIC POWER AND TRANSMISSION
TRANSACTON LIMITS 6

4.2 CAISO TRANSACTION LIMITS 8

4.3 NATURAL GAS TRANSACTION LIMITS 9

4.4 EMISSION ALLOWANCE AND EMISSION REDUCTION CREDIT
TRANSACTION LIMITS 11

4.5 RENEWABLE ENERGY CREDIT TRANSACTION LIMITS 12

4.6 CARBON ALLOWANCE AND CARBON EMISSION OFFSET
TRANSACTION LIMITS 13

4.7 LOW CARBON FUEL STANDARD TRANSACTION LIMITS 14

5. ACKNOWLEDGEMENTS 15

5.1 CLEAR AUTHORITY 15

5.2 VIOLATIONS AND SANCTIONS 15

5.35.3 SANCTIONS FOR OPERATIONAL/SCHEDULING/TAGGING/
TRANSMISSION ERRORS 15

5.4 POLICY EFFECTIVE 15

6. APPENDICIES 16

APPENDIX A - ACKNOWLEDGEMENT OF TRADING AUTHORITY 16
APPENDIX B - INSTRUMENT OF TRADING AUTHORITY DELEGATION 17 114 of 161
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1 1. POLICY PURPOSE
The purpose of this Trading Authority Policy is to define the authority granted by the Glendale City Council to the City Manager and the Glendale Water and Power (GWP) General Manager to execute energy related transactions and to delegate trading functions to Glendale Water and Power staff within the limits defined in this policy. This Authority Policy is intended to supplement and complement the GWP Energy Risk Management Policy.

2. TRADING AUTHORITY POLICY OBJECTIVES
The objective of this Trading Authority Policy is to define:
The commodities and products that can be transacted,
The authorized lead time and term for each transaction, The authorized maximum price and volume,
Counterparty contract and credit requirements,
The process for approving new commodities, products or locations, The City Council’s intentions regarding hedging and speculating, and Other relevant factors associated with due diligence in authorizing transactions to be executed.

3. PROCEDURAL REQUIREMENTS
The following defines procedural requirements that apply to all commodities and products transacted upon this Trading Authority Policy.

3.1Execution Authority
The Glendale City Charter (the Charter), Article VI, Section 9, generally requires competitive bidding for contracts for the purchase of materials or products equal to or greater than $50,000. However, Article VI, Section 9 of the Charter authorizes the City to dispense with competitive bidding where the City Council determines it is in the best interest of the City to do so and acts by resolution setting forth the reason for such action. It is in the City's best interest to dispense with competitive bidding for wholesale energy transactions as they must be completed in a rapidly changing market that is not structured to accommodate public entity bidding requirements. Wholesale energy transactions are related to energy supplied by one producer/marketer/utility to another for eventual resale to consumers.

On an annual basis, the General Manager requests that the City Council authorize the City Manager, or designee, to dispense with competitive bidding for wholesale energy transactions on the grounds that it is in the City’s best interest in accordance with Article VI, Section 9 of the Charter. Such wholesale energy 116 of 161
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2 transactions include electrical energy and capacity, ancillary services, transmission, renewable energy attributes, carbon allowances and carbon emission offsets, emission allowances and emission reduction credits, low carbon fuel standard credits, natural gas, transportation, imbalance and storage.

This resolution includes any GWP gas scheduling services managed for GWP by a third party(ies).

This policy identifies the City Council authorized levels for the City Manager and GWP General Manager and explicitly gives the City Manager and GWP General Manager the authority to delegate authority levels to others. This will be done via a Trading Authority Delegation. The City Manager and GWP General Manager have the authority to modify authority levels set within the Trading Authority Delegation at their sole discretion as long as the delegated authority does not exceed their own authority per this Trading Authority Policy. A form of Trading Authority Delegation is attached to this Policy as Appendix B.

Execution Authority of the City Manager and the GWP General Manager is outlined by commodity in the authority matrix sections found below. The trading limits, with the exception of pricing, apply to both purchases and sales. Price limits apply to only purchases. Per Trading Day and Aggregate Limits, as applicable, are applied to gross amounts transacted in total, and not to buys and sells netted together.

Glendale Municipal Code Section 1.04.080 states: “Whenever a power is granted to or a duty is imposed upon a city officer by this code or any other ordinance of the city, the power may be exercised or the duty performed by an assistant or a deputy of the officer or by a person authorized pursuant to law by the officer, unless this code expressly provides otherwise.”

3.2Contract Requirements
Transactions with counterparties shall only be permitted if GWP has:
An active, valid, and executed agreement enabling such trading activity with that counterparty approved as to form by the City Attorney, or his or her designee.
Long-form confirmations may be used as a valid agreement in lieu of a permanent agreement, when necessary, if approved by the City Manager or GWP General Manager and approved as to form by the City Attorney. A long-form confirmation is a confirmation that is used to confirm a transaction when no underlying enabling agreement exists between the parties. In addition to confirming the transaction details, the long-form confirmation may incorporate by reference the terms and conditions of the underlying enabling agreement to be executed. For example, a long-form confirmation for a physical power transaction may incorporate by reference the terms and conditions of the WSPP agreement.
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3 Under this provision,
City Attorney review/ stamp/ approval as to form is NOT required where:
(1) the transaction is less than 5 years in duration; and (2) the transaction is not one that requires City Manager or City Council approval under the Energy Risk Management Policy, Trading Authority Policy and Trading Authority Delegation; and
(3) one or more of the following situations applies:
(a)For Agreements under the WSPP:
Both parties are WSPP members, the parties execute a standard Confirmation agreement, and no modifications to the WSPP are made; or
Both parties are WSPP members, the parties execute a standard Confirmation agreement, and any modifications to the WSPP are set forth in a valid, active, current agreement that has been previously approved as to form by the City Attorney’s Office within the last 3 years;
(b) For Agreements under the NAESB:
Both parties execute a standard Confirmation agreement; the parties have already entered into a NAESB Base Contract that was previously approved as to form by the City Attorney’s Office; and any modifications to the NAESB are set forth in a valid, active, current agreement that has been previously approved as to form by the City Attorney’s Office within the last 3 years.

Because the WSPP Agreement and NAESB Agreement are posted, FERC- approved, industry standard agreements, the WSPP and NAESB form agreements do not require approval as to form by the City Attorney’s Office.

However, the WSPP and NAESB cover sheet and any modifications to the WSPP and NAESB terms and conditions must be reviewed and approved as to form by the City Attorney’s Office. If the enabling agreement, other than the standard form WSPP or NAESB, has not been reviewed in over 3 years, the City Attorney’s Office must review the agreement to ensure the provisions are still valid/ active/ enforceable.

City Attorney review/ stamp/ approval as to form IS required in any one of the following situations:
The agreement does not fall under the WSPP or NAESB;
In the case of a WSPP Agreement, one of the parties is not WSPP- enabled;
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4 If the agreement is a WSPP Agreement, the agreement includes modifications to WSPP standard form agreement. These modifications could be included in a long-form confirmation, a “Master Confirmation” document, a “Special Conditions” document, exhibits, addendums, amendments, and such;
If the agreement is a NAESB Contract, the agreement includes modifications to the NAESB standard form contracts. These modifications could be included in a long-form confirmation, a “Master Confirmation” document, a “Special Conditions” document, exhibits, addendums, amendments, and such; The confirmation adds legal terms and conditions (beyond the confirm standard form, which would typically only include the specifics of the deal such as counterparties, price, product, delivery point, term, etc.);
There are questions or concerns regarding the legal terms and conditions, signatory or levels of authority required, or any questions whether the deal falls within the Risk Management Policy.

3.3Credit Requirements
Counterparty trading credit limits, trading restrictions, and other Credit Policy provisions shall not be intentionally exceeded or violated. (Note: Since credit exposures are a function of not only positions traded, but also a function of market pricing and volatility, credit exposure to a counterparty may unintentionally exceed a credit limit purely due to changes in the forward market.) Entering into transactions with a counterparty that has total credit exposure greater than or equal to its open line of credit and the total of any security currently provided will not be allowed unless approved by the City Manager, the GWP General Manager, or the ERMC.

Entering into transactions with a counterparty that violate current trading restrictions will not be allowed unless approved by the City Manager, the GWP General Manager, or the ERMC.

3.4Trading onOn and Off Premises
All bilateral trades must be executed via a recorded communication method such as a voice recorded communication line, instant messaging (IM) application, or an online broker account that is maintained and controlled by personnel who are independent of the trading function. Off-premise trading may be authorized by the City Manager or GWP General Manager, but should be via a recorded communication method, if possible. Email confirmations can serve as a permitted communication recording method. Off-premise bilateral trading is permitted, following the City of Glendale hybrid work policy, but trades must be executed through an approved recorded communication method. 119 of 161
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5 3.5Deal Capture
Any transaction(s) executed by GWP employee or agent must be accurately captured in the corresponding Allegro system, the same working day or shift, to facilitate the nightly import and export process. Excessive deal capture violations will be reported to the ERMC.

3.6Speculation
No speculative trading activities shall be permitted, and no speculative trading positions shall be initiated. Speculation is the opposite of hedging. A speculator holds no offsetting position(s) in the spot market and deliberately initiates price risk in order to reap potential rewards.

3.7Non-Standard Commodities
The City Council must approve any transaction that involves commodities not listed in this Trading Authority Policy.

3.8Approval for New Commodities, New Products and New Markets The purpose of defining a process for the introduction of a new commodity, new product, or new market is to ensure that the associated exposures are thoroughly reviewed and understood by the ERMC, GWP management, and GWP Staff.

Within the commodities that have been approved by City Council, the ERMC must approve the use of all new products or the entry into new commodity markets (e.g. trading venues) before the execution of any such transaction. For new commodities, the ERMC must recommend any such commodity for approval by City Council before the execution of any such transaction.

The following transaction types are not new to GWP and therefore do not require the review and approvals described within this Section 3.8 if they are bilateral or within previously used trading venues: (1) a physical spot or forward bilateral capacity, energy, ancillary service or transmission transaction; (2) a physical spot or forward natural gas, imbalance, storage or transportation transaction, or related gas scheduling services; (3) an over-the-counter (OTC) physical option (calls or puts); (4) a CAISO authorized pool transaction, as noted in Section 4.2; (5) emission allowance and emission reduction credit transaction, as noted in Section 4.4; (6) a renewable energy credit transaction; (7) a carbon allowance or carbon emission offset transaction; (8) an over-the-counter (OTC) financial transaction; (9) an exchange-traded transaction; or (10) a low carbon fuel standard credit transaction.
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6 4. TRADING AUTHORITY MATRICES
A vital control element in the management of risk is the development of and adherence to transaction limits. Limits ensure that trading and hedging activity is appropriate and controlled at various levels of position aggregation and duration of transactions. The limits are established in consideration of overall portfolio strategies, market conditions, and risk tolerance levels.

4.1 BILATERAL ELECTRIC POWER AND TRANSMISSION TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for power and transmission transactions.

Per Transaction Limits Per Trading Day
Limits Aggregate Limits
Title Product Term Lead
Time
MW
Size
$/
MWH
Total
MWH
Total
$
Total
MWH Total $
City
Council
Electric
Power
and
Trans
No
Limit
No
Limit
No
Max.

No
Max. No Max. No
Max. No Max. No
Max.
> 2
Years
< 5
Years
100 $100City
Manager
and GWP
General
Manager
Electric
Power
and
Trans < 2
Years
< 5
Years
No
Max.

No
Max.
2,190,000 $150
Million 4,380,000 $300
Million

4.1.1 Bilateral Electric Power and Transmission Transaction Limits Matrix Explanations
Transaction Limits represent the MW volume per hour and dollars/MWH for each transaction executed.
Per Trading Day Limits represent the total MWh volume and dollars for all transactions executed in a trading day.
Aggregate Limits represent the sum total MWh volume and dollars for all open forward transactions with all counterparties.
Lead time represents the time period from the date a trade is executed to the start of the trade.
The dollar limits are based upon electric power only and do not include transmission, however, the Term, Lead Time, and Quantity limits do apply to transmission.
To the extent the transaction price can be identified separately for energy and renewable energy attributes, the energy portion of any bundled (energy and renewable energy attribute) transaction must be monitored against the limits above, while the renewable energy attribute portion of 121 of 161
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Authorized products include spot and forward electric power and transmission, including both physical and financial derivatives, as well as bilateral capacity and bilateral ancillary services. Financial derivatives may be OTC or exchange traded products.

4.1.2 Authorized Delivery Locations
Trading at delivery locations that are normal to the daily course of business for GWP to the extent transmission is available, is authorized as follows:

Unrestricted Delivery Locations
WECC including CAISO
Trading at any other delivery locations shall be prohibited unless approved by the City Manager, GWP General Manager, or GWP ERMC.

4.1.3 Firmness of Power
The product firmness of all transactions must be provided for in an executed agreement between GWP and the appropriate counterparty. Sales commitments must never be more “firm” than the supply source, including the purchase side of back-to-back sales, swaps or spreads, unless the sale can be resupplied by GWP generating resources or sufficient and timely reserves that are exclusive of reserves for the single largest contingency. Transaction(s) cannot reduce system reliability and must be logged in detail including specific resupply resource(s). The City Manager or GWP General Manager can provide pre- approved authority to sell power that is more “firm” than the supply source without sufficient and timely reserves.

4.1.4 Transmission Service Firmness and Volume
Transmission purchase(s) must be at least of “equal” firmness to the energy component of the associated transmission purchase(s). If firm transmission is unavailable, less-firm transmission can be used as long as there are sufficient reserve resources to supplement curtailed schedule(s) caused by transmission priority. Utilization of less-firm transmission cannot reduce system reliability and must be logged in detail including specific reserve resource(s). The City Manager or GWP General Manager can provide pre- approved authority to purchase power that is more “firm” than the associated transmission without sufficient reserve resources.

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4.2 CAISO Transaction Limits
The following sets transaction limits, definitions, and procedural requirements for CAISO transactions.

CAISO Per Transaction Limits (up to)
Title Product Delivery
Lead Time Term MW
Size $/MWh
City
Council All CAISO Products No Limit No Limit No
Max No Max
Imports/Exports As required by CAISO < 1 Week No
Max No MaxCity
Manager
and
General
Manager
Ancillary Service
Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below
regarding Inter SC Energy
Transactions
Generation Awards
Demand Awards
Virtual Transaction
Awards
None None None None
Congestion
Revenue Rights As required by CAISO < 1 Year No
Max No Max

4.2.1 CAISO Transaction Limits Matrix Explanations
Generation Award Limits are per generating unit. A Generation Award is defined as the amount of energy a market participant is required to generate within the market after submitting a generation offer for the supply of Energy and/or Ancillary Services, including Self Schedules, submitted by Scheduling Coordinators for generating resources, conveyed through a three part offer to either the DA or RT CAISO Markets. Demand Award Limits are per each load location. A Demand Award is defined as the energy awarded to a market participant according to the amount submitted in the DA market via a demand bid that indicates the MWh of Energy the Scheduling Coordinator is willing to purchase, the price at which it is willing to purchase the specified Energy, and the applicable Trading Hours for which the energy will be purchased. Import and Exports are by location and are each monitored separately.

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9 is imported in to the CAISO Controlled Grid via an energy award and electronic tag. Exports are defined as energy located within the ISO Controlled Grid that is exported out of the CAISO Controlled Grid via an energy award and electronic tag.
An Inter SC Energy TransactionsTransaction is an energy quantity traded from one SC to another SC for a specific hour and location. Inter SC Trades may be submitted to the ISO but are eachnot monitored separately. Inter SC Transactionsas they are defined as transactions occurring between a direct result of the bilateral counterparties to accommodatetrade executed between the SC’s. The bilateral transactions within the CAISOtransaction will only be monitored in accordance with the Bilateral Electric Power and Transmission Matrix.
Limits for Ancillary Service Awards apply to the Regulation and Operating (Spinning and Non-Spinning) Reserve Market. Ancillary Services are defined as Regulation, Spinning Reserve, Non-Spinning Reserve, Replacement Reserve, Voltage Support and Black Start together with such other interconnected operation services as the ISO may develop in cooperation with Market Participants to support the transmission of Energy from Generation resources to Loads while maintaining reliable operation of the ISO Controlled Grid in accordance with Good Utility Practice. Only Congestion Revenue Rights that are bought and sold via the long- term, annual and monthly auctions or in the secondary market are monitored per the limits above. This excludes congestion revenue rights allocated in the Annual Allocation.

4.3 NATURAL GAS TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for natural gas and gas transportation transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Daily
MMBtu
Volume
$/
MMBtu Total MMBtu Total $
City Council Natural Gas
& Transport No Limit No
Limit No Max. No Max. No Max. No Max.
> 2 Years
< 5 Years 10,000 $10City Manager
and GWP
General
Manager
Natural Gas
& Transport
< 2 Years
< 5 Yrs.

No Max. No Max.
6,000,000 $24
Million
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10 4.3.1 Natural Gas Transaction Limits Matrix Explanations Transaction Limits represent the MMBtu volume per day and dollars/MMBtu for each transaction executed.
Aggregate Limits represent the total MMBtu volume and dollars for all forward transactions.
Lead time represents the time period from the date a trade is executed to the start of the trade.
The dollar limits are based upon natural gas only and do not include transportation, however, the Term, Lead Time, and Quantity limits do apply to transportation.
Authorized products include physical natural gas, imbalance, transportation and storage as well as financial natural gas derivatives, including financial basis transactions. Financial natural gas derivatives may be OTC or exchange traded products.

4.3.2 Authorized Delivery Locations
Physical natural gas transactions may only be executed for delivery at GWP facilities or at delivery locations in which an approved transportation agreement is in place to transport the natural gas to GWP facilities.

Financial natural gas transactions may only be executed at the following locations:
Henry Hub
SoCal Border
San Juan Basin
Permian Basin
AECO
SoCal Citygate
PG&E Citygate
Trading at any other locations shall be prohibited unless transportation is available in the event physical delivery is deemed necessary.

4.3.3 Natural Gas Firmness
The product firmness of all trades must be provided for in an executed agreement between GWP and the appropriate counterparty. Sales commitments must never be more firm than the supply source unless pre-approved by the City Manager or GWP General Manager.

4.3.4 Transportation Firmness
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12 must pre-approve firm natural gas purchases or sales transported on non-firm transportation.

4.4 EMISSION ALLOWANCE AND EMISSION REDUCTION CREDIT TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for Emission Allowance and Emission Reduction Credit (ERC) transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
Allowances $/Allowance Total
Allowances
Total $
City
Council
SO2 and
NOx
Emission
Allowances
No Limit No Limit No Max No Max No Max No Max
City
Manager
and
General
Manager
SO2 and
NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required As
Required
Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
Credits $/Credit Total
Credits
Total $
City
Council
Emission
Reduction
Credits
No Limit No Limit No Max No Max No Max No Max
City
Manager
and
General
Manager
Emission
Reduction
Credits
As
Required
As
Required
As
Required Market As
Required
As
Required

4.4.1 Emission Allowance and Emission Reduction Credit Transaction Limits Matrix Explanations
Under the Acid Rain Program, one allowance is equivalent to one ton of SO2 or NOx. Under the ERC, one credit can be equivalent to one pound of pollutant reduction per day or one ton of pollutant reduction per year.

Under SCAQMD Reclaim program, SO2 or NOx may be purchased and sold by dollars per pound.
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13 Per Transaction represent the total quantity in allowances or credits and dollars/allowance or dollars/credit for each transaction executed. Aggregate Limits represent the sum total quantity in allowances or credits and dollars for all forward transactions.
Lead time represents the time period from the date a trade is executed until actual transfer of the certified emission allowance(s) or credit(s) confirmed in the Allowance Management System (AMS).
Maximum trading limits (As Required) and market execution prices (Market) will be based on meeting emission compliance requirements for the Grayson Power Plant or other GWP emitting resources as reflected in the Transaction Limits Matrix.
Authorized emission allowances and credits include Particles Oxidation Catalysts (POC), Volcano Smog (VOG), Volatile Organic Compound (VOC)Reactive Organic Gas (ROG), Particulate Matter (PM2.5 & PM10), Sulfur Dioxide (SO2), and Nitrogen Oxide (NOx).
Participation in the Emission Auction is not governed or limited by the Trading Authority Policy. Due to varying compliance needs and market complexities, auction strategies will be reviewed by the ERMC and approved in writing by GWP management.

4.5 RENEWABLE ENERGY CREDIT TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for renewable energy credit (REC) transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
REC
Units
$/
REC
Unit
Total
REC
Units
Total $
City
Council RECs No
Limit
No
Limit No Max. No Max. No
Max. No Max.
> 2
Years
< 5
Years
876,000 $50City
Manager
and
General
Manager
RECs
< 2
Years
< 5
Years
No Max No Max
2,190,000 $50 Million

4.5.1 Renewable Energy Credits Transaction Limits Matrix Explanations The matrix above addresses authority for REC transactions that are stand- alone transactions (from power), or where the price of such RECs are unbundled from the price of power. Bilateral power trades with renewable 128 of 161
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14 energy attributes bundled in the power price will be monitored against the bilateral power matrix.
Per Transaction Limits represent the total units and dollars/unit for each REC transaction executed.
Aggregate Limits represent the sum total units and dollars for all open forward transactions with all counterparties and on all trading venues. Lead time represents the time period from the date a trade is executed until:
othe start of the delivery obligation in the case of forward RECs to be generated, or
othe actual transfer of standalone RECs occuroccurs in WREGIS for certified RECs that have been banked or generated.

4.6 CARBON ALLOWANCE AND CARBON EMISSION OFFSET TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for carbon (CO2e) allowances and carbon emission offsets.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
CO2e
$/
CO2e
Total
CO2e Total $
City
Council CO2e No
Limit
No
Limit No Max. No Max. No Max. No Max.
> 2
Years
< 5
Years
1,000,000 $50City
Manager
and
General
Manager
CO2e
< 2
Years
< 5
Years
No Max No Max
3,000,000 $50 Million

4.6.1 Carbon Allowances and Carbon Emission Offsets Transaction Limits Matrix Explanations
The matrix above addresses authority for Carbon Allowances and Carbon Emission Offsets such as CCA, GCCO, CCO3, and CCO8..
Per Transaction Limits represent the total allowance/offset volume and dollars/CO2e for each Carbon Allowance or Carbon Emission Offset transaction executed.
Aggregate Limits represent the total allowance/offset volume and dollars for all forward Carbon Allowance or Carbon Emission Offset transactions. Lead time represents the time period from the date a trade is executed until the actual transfer of the certified Carbon Allowances or Carbon Emission Offsets occur in CITSS.
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15 Participation in the Carbon Auction is not governed or limited by the Trading Authority Policy. Due to varying compliance needs and market complexities, auction strategies will be reviewed by the ERMC and approved in writing by GWP management.

4.7 LOW CARBON FUEL STANDARD (LCFS) CREDIT TRANSACTION LIMITS The following sets transaction limits, definitions, and procedural requirements for Low Carbon Fuel Standard (LCFS) Credit transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
LCFS
Credits
$/
LCFS
Credit
Total
LCFS
Credits
Total $
City
Council LCFS No
Limit No Limit No Max No Max No Max No Max
> 2
Year
s < 5
Year
s
50,000 $1000City
Manager
and
General
Manager
LCFS
< 2
Year
s
< 5
Years
No Max No Max
300,000 $100
Million

4.7.1 Low Carbon Fuel Standard (LCFS) Credit Transaction Limits Matrix Explanations
The matrix above addresses authority for Low Carbon Fuel Standard Credits
Per Transaction Limits represent the total credits and dollars/credit for each Low Carbon Fuel Standard Credit transaction executed. Aggregate Limits represent the total credits and dollars for all forward transactions.
Lead time represents the time period from the date a trade is executed until actual transfer of the certified LCFS credit(s) confirmed in the LCFS Reporting Tool (LRT).
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16 5. ACKNOWLEDGEMENTS

5.1 Clear Authority
Any situation where authority is in question from a “clearly authorized” standpoint should be reviewed and authorized by the City Council.

5.2 Violations and Sanctions
Violations of this Trading Authority Policy must not occur. Should it be deemed that non-compliant incidents did occur; the Energy Risk Manager will report such incidents to the Energy Risk Management Committee. Should the Energy Risk Management Committee deem that a violation has occurred, the GWP General Manager, at his or her discretion, will report incident(s) and responsible party(ies) according to the GWP Trading Sanctions Policy.

5.35.3 Sanctions for Operational/Scheduling/Tagging/Transmission Errors Errors made while performing operational, scheduling or transmission responsibilities may result in disciplinary action according to the guidelines outlined in the GWP Trading Sanctions Policy.

5.4 Policy Effectiveness
This Trading Authority Policy is in effect upon the City Council’s approval and shall remain in effect until a replacement policy has been approved by the City Council superseding this Trading Authority Policy.
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17 APPENDIX A

ACKNOWLEDGEMENT OF TRADING AUTHORITY POLICY
Compliance Statement
I hereby acknowledge receipt and review of GWP’s Trading Authority Policy and Appendix B: Instrument of Trading Authority Delegation dated July 1, 2021TBD, 2022.

I further acknowledge that this Trading Authority Policy defines the standards of GWP’s energy risk management efforts that I am required to comply with.

If I become aware of non-compliance with the Trading Authority Policy, I will report such non-compliance to the Energy Risk Manager, GWP Management, or any member of the ERMC.
_____________________________________
Signature
_____________________________________
Type or Print Name
_____________________________________
Title
_____________________________________
Date
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18 APPENDIX B

INSTRUMENT OF TRADING AUTHORITY DELEGATION
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8b

CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Review and Reconsideration of Temporary Cap on Fees Charged by Third-Party Food Delivery Applications

1. Motion to Note and File

2. Resolution Repealing Resolution No 20-63 and Terminating the Emergency Public Order Imposing a Temporary Limit on Commission Fees Charged by Third-Party Delivery Applications on Businesses in Glendale

3. Motion Providing Direction to Staff

COUNCIL ACTION
Item Type: Action Item
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
The Council has been asked to consider whether to terminate the cap on delivery fees charged by third party delivery platforms for the delivery of food from restaurants to customers who make an online order.
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3 4
9 6

COUNCIL PRIORITIES
N/A

RECOMMENDATION
It is recommended that the Council decide whether to terminate the temporary limit on commission fees charged by third-party delivery platforms.

BACKGROUND
The Council adopted a resolution on June 2, 2020 establishing a “temporary” limit of commissions charged by third party food delivery companies (“Fee Cap”). The resolution was adopted under the City’s emergency authority pertaining to the COVID-19 State of Emergency. It was enacted during the period of time that Los Angeles County was operating under the Safer at Home Order which prohibited restaurants in Los Angeles County from offering dine-in service, limiting restaurants to delivery and take out offerings only. At the time the Fee Cap was enacted, the City determined that third-party delivery platforms, e.g. Grubhub, DoorDash, etc., were charging fees ranging from 12% to 30%.

Given utilization of delivery platforms’ predominance during the period of the Safer at Home Order, the Council determined that the local restaurants had limited bargaining power to negotiate lower fees with third-party platforms, and were therefore overly burdened with excessive fees imposed by third-party platforms.

The Fee Cap applies to any restaurant in Glendale that offers, via the internet, the sale and same-day delivery of food to customers from one or more restaurant locations in the City, excluding formula or chain restaurants (a restaurant chain with eleven or more locations anywhere in the world). It caps all fees, including delivery fees and processing fees, at 15% of the purchase price of the online order. The resolution establishing the Fee Cap under the City’s emergency order provides that it will remain in effect while the City’s state of emergency remains in effect.

ANALYSIS
Starting in March 2021, the County of Los Angeles relaxed its in-person dining restrictions with a partial reopening, with in-person dining allowed at 100% capacity in June 2021.

With restaurants fully re-opened and, in some cases, additional capacity available due to outdoor dining, the question has been raised whether it is still necessary to cap delivery fees whereby restaurants now have the capacity to operate at full capacity.

After enacting temporary caps on fees, some cities have allowed them to continue or extended them, while others allowed them to expire:
Burbank (15% cap) – expired 90 days after public health orders allowed 100% capacity at restaurants (September 30, 2021).
Long Beach (15% cap) – ordinance required City Manager to report on cap every 90 days, with Council to determine necessity based on reports. Los Angeles (15% cap) – provided that whenever a federal, state or local health order keeps restaurants from operating at less than 100% capacity, the cap shall remain in place.
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Pasadena (20% cap) – written to expire 90 days after County health order allowed 100% capacity at restaurants (September 2021)
Santa Monica (15% cap) - issued as part of the City’s 16th supplement to its declaration of a local emergency.

Conversely, the cities of San Francisco, New York, Philadelphia and Minneapolis have made their fee caps permanent. A number of the prominent third party delivery platforms have challenged San Francisco’s and New York’s permanent bans in court. Those cases are pending.

Staff seeks Council’s direction on whether to terminate the Fee Cap in light of the lifting of County restrictions limiting indoor seating at restaurants. While the Fee Cap is currently tied to the City’s state of emergency, which remains in effect, the Council can decouple the Fee Cap and provide for an immediate or earlier termination. Those in favor of letting third party platform fee caps expire or terminate contend that restaurants are in the same position now as before COVID, and thus the unfair bargaining position created by COVID and restrictions on in-person dining no longer exists. Additionally, the Fee Cap applies to all fees associated with an online order including service fees and online processing fees, which may have the unintended effect of limiting charges that may be assessed for other services provided by third party platforms.

Arguments for maintaining the fee cap include the fact that third party delivery platforms still maintain an economic advantage over small, local restaurants still recovering from the economic losses suffering during COVID. Additionally, populations vulnerable to COVID may still need to utilize the third party platforms to order restaurant food.

A resolution to terminate the Fee Cap is provided as one of the options available for Council action.

STAKEHOLDERS/OUTREACH
No additional stakeholder outreach, including discussion with local restaurants, has been conducted at this point. If it desires, Council can decide to direct staff to conduct stakeholder outreach prior to considering whether to terminate the Fee Cap.

FISCAL IMPACT
There is no fiscal impact associated with this report.

ENVIRONMENTAL REVIEW (CEQA/NEPA)
This item is exempt from the CEQA because there is no reasonable possibility that terminating the Delivery Fee Cap will have a significant effect on the environment. 136 of 161
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CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements.

ALTERNATIVES

1. The Council can adopt the resolution terminating the Fee Cap.

2. The Council can note and file this Report.

3. The Council can provide direction to staff.

4. The Council can choose an alternative not identified by staff.

ADMINISTRATIVE ACTION
Prepared by:

Michael J. Garcia, City Attorney
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS

1. Resolution No. 20-63.
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C:\inetpub\wwwroot\Glendale\temp\CC_08092022_Motion_8b1.pdf

M O T I O N
Moved by Council Member _________________________, seconded by Council Member ___________________________, that the Council hereby notes and files the Report to Council, dated August 9, 2022, pertaining to the Review and Reconsideration of the Temporary Cap on Fees Charged by Third-Party Food Delivery Applications.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION NO.

A RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE,
CALIFORNIA REPEALING RESOLUTION NO. 20-63 AND TERMINATING

THE TEMPORARY LIMIT ON FEES CHARGED BY THIRD- PARTY FOOD

DELIVERY COMPANIES UNDER THE CITY OF GLENDALE EMERGENCY AUTHORITY REGARDING COVID-19; AND FOR OTHER RELATED AND

LAWFUL PURPOSES
Whereas, international, national, state, and local health and governmental authorities are responding to an outbreak of respiratory disease caused by the Coronavirus Disease 2019 (COVID-19), a severe acute respiratory illness caused by a novel (new) coronavirus. Symptoms of the virus include fever, cough, and shortness of breath, and infected individuals have experienced a range of outcomes, from mild sickness to severe illness and death; and Whereas, on March 4, 2020, the Governor of the State of California declared a state of emergency to make additional resources available, formalize emergency actions already underway across multiple state agencies and departments, and help the State prepare for broader spread of COVID-19; and Whereas, on March 4, 2020, the Los Angeles County Board of Supervisors and the Department of Public Health declared a local and public health emergency in response to increased spread of coronavirus across the country; and
Whereas, on March 16, 2020, the City Council of the City of Glendale, pursuant to Glendale Municipal Code Chapter 2.84, declared the existence of a local emergency and ordered the closure of and limitation of access to certain public establishments; and
Whereas, the County of Los Angeles Department of Public Health issued a Safer at Home Order, which was revised on May 13, 2020, which required people to remain in their homes subject to certain exceptions including obtaining essential goods such as food and necessary supplies, and requiring the closure of non-essential businesses, until further notice; and
Whereas, to reduce the spread of the virus and protect the public health, the Safer at Home Order prohibited restaurants in the City from offering dine-in service, limiting restaurant delivery and takeout offerings only; and Whereas, the Council of the City of Glendale adopted Resolution No. 20- 63 on June 2, 2020, placing a cap, in the amount of 15% of the amount of an online orders, on all fees charged by third party delivery platforms to restaurants associated with the delivery of food from restaurants to customers, including delivery fees, service fees, and processing fees (“Fee Cap”); and 139 of 161
Whereas, in adopting Resolution No. 20-63, the Council further found that capping the per-order fees at 15% would accomplish the legitimate public purpose of easing the financial burden on struggling restaurants during the COVID-19 emergency while not unduly burdening third-party platforms; and
Whereas, starting in March 2021 and through June 2021, the health orders of Los Angeles County lifted the restrictions on dine-in service, such that in June 2021, restaurants were able to have dine-in service at 100% capacity; and Whereas, with restaurants in Glendale operating at full capacity, the Council finds that it is no longer necessary to impose a cap on fees that may be charged by third party food delivery service platforms.

NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA that:

1. Council Resolution No. 20-63 is repealed and shall have no further force or effect; and

2. This Resolution shall take effect immediately upon adoption.

Adopted this 9th day of August, 2022.
_____________________________
Mayor
_____________________________________
City Clerk
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STATE OF CALIFORNIA )
)

COUNTY OF LOS ANGELES )
I, Dr. Suzie Abajian, City Clerk of the City of Glendale, certify that the foregoing resolution was adopted by the Council of the City of Glendale, California, at a regular meeting held on the _________________ day of _________________________, 2022 and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
________________________________
City Clerk
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C:\inetpub\wwwroot\Glendale\temp\CC_08092022_Motion_8b3.pdf

M O T I O N
Moved by Council Member _________________________, seconded by Council Member ___________________________, that with respect to the Report to Council, dated August 9, 2022, pertaining to the Review and Reconsideration of the Temporary Cap on Fees Charged by Third-Party Food Delivery Applications, the Council hereby directs staff as follows:

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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RESOLUTION NO. ______

A RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA

ESTABLISHING A TEMPORARY LIMIT OF COMMISSIONS CHARGED BY THIRD-

PARTY FOOD DELIVERY COMPANIES UNDER THE CITY OF GLENDALE EMERGENCY AUTHORITY REGARDING COVID-19; AND FOR OTHER RELATED

AND LAWFUL PURPOSES

Whereas, international, national, state, and local health and governmental authorities are responding to an outbreak of respiratory disease caused by the Coronavirus Disease 2019 (COVID -19), a severe acute respiratory illness caused by a novel (new) coronavirus. Symptoms of the virus include fever, cough, and shortness of breath, and infected individuals have experienced a range of outcomes, from mild sickness to severe illness and death; and

Whereas, on March 4, 2020, the Governor of the State of California decl ared a state of emergency to make additional resources available, formalize emergency actions already underway across multiple state agencies and departments, and help the State prepare for broader spread of COVID-19; and

Whereas, on March 4, 2020, the Los Angeles County Board of Supervisors and the Department of Public Health declared a local and public health emergency in response to increased spread of coronavirus across the country; and

Whereas, on March 13, 2020, the President of the United States o f America declared a national emergency and announced that the federal government would make emergency funding available to assist state and local governments in preventing the spread of and addressing the effects of COVID-19; and

Whereas, on March 16, 2020, the City Council of the City of Glendale, pursuant to Glendale Municipal Code Chapter 2.84, declared the existence of a local emergency and ordered the closure of and limitation of access to certain public establishments; and

Whereas, on March 19, 2020, the Governor issued Executive Order N-33-20 and the California Public Health Officer issued a corresponding order requiring people to stay home except as needed subject certain exceptions; and

Whereas, the County of Los Angeles Department of Public Health issued a Safer at Home Order, which was revised on May 13, 2020, which requires people to remain in their homes subject to certain exceptions including obtaining essential goods such as food and necessary supplies, and requiring the closure of non -essential businesses, until further notice; and

Whereas, to reduce the spread of the virus and protect the public health, the Safer at Home Order prohibits restaurants in the City from offering dine -in service, limiting restaurant delivery and takeout offerings only; and

Whereas, restricting restaurants to takeout and delivery offerings only has placed a sudden and severe financial strain on many restaurants, particularly those that are small DocuSign Envelope ID: A10C12C0-E73D-47F2-902D-A2F8CEF5871C 143 of 161
businesses that already operate on thin margins, adding to financial pressures in the industry that predate the COVID-19 crisis; and

Whereas, it is in the public interest to take action to maximize restaurant revenue from the takeout and delivery orders that are currently the sole source of revenue for these small businesses to enable restaurant to survive this crisis and remain as sources of employment and neighborhood vitality in the City; and

Whereas, many consumers use third -party applications and websites to place orders with restaurants for delivery and takeout, and these third -party platforms charge restaurants fees that range between 12% to 30% of the purchase price per order and other transaction fees;

Whereas, the cost of acquiring ingredients and supplies has also increased, because of the COVID-19 crisis; and

Whereas, restaurants, and particularly restaurants that are small businesses with few locations, have limited bargaining power to ne gotiate lower fees with third -party platforms, given the high market saturation of third-party platforms, and the dire financial straits small business restaurants are facing in the COVID-19 crisis; and

Whereas capping the per -order fees in the amounts set forth herein will accomplish the legitimate public purpose of easing the financial burden on struggling restaurants during this emergency while not unduly burdening third-party platforms, as this fee is recognized as reasonable, and third-party platforms will continue to be profitable.

Whereas, such conditions of peril continue to exist, and necessitate extending the expiration deadlines of prior resolutions and public orders and adopt additional protections for the preservation of public health and safety.

BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE that the Council hereby adopts the following Public Order (“Order”):

SECTION 1.

A. Definitions. For purposes of this order, the following definitions apply:

1. “Covered establishment” means a restaurant that offers, in a single commercial transaction over the internet, whether directly or through a third party food delivery services, the sale and same -day delivery of food to customers from one or more retail locations wit hin the City. Covered establishment shall not include any restaurant that meets the definition of a formula restaurant set forth below.

2. “Delivery fee” means a fee charged by a third -party food delivery service for providing a food service establishment with a service that delivers food from such establishment to customers. The term does not include any other fee that may be charged by a thir d-party food delivery service to a food service establishment, such as fees for listing or advertising the food DocuSign Envelope ID: A10C12C0-E73D-47F2-902D-A2F8CEF5871C 144 of 161
service establishment on the third -party food delivery service platform or fees related to processing the online order.

3. “Formula restaurant” means a type of restaurant that has eleven or more other locations in operation, or with local land use or permit entitlements already approved, located anywhere in the world. In addition to the eleven establishments either in operation or with local land use or permit entitlements approved for operation, the business maintains two or more the following features: a standardized array of merchandise, a standardized façade, a standardized décor and color scheme, uniform apparel, standardized signage, a trademark or a service mark.

4. “Online order” means any order placed by a customer through or with the assistance of a platform provided by a third -party food delivery service, including a telephone order.

5. “Purchase price” means the total price of the items con tained in an online order that are listed on the menu of the food service establishment where such order is placed. Such term does not include taxes, gratuities and any other fees that may make up the total cost to the customer of an online order.

6. “Restaurant” means and includes any “Restaurant, full service,” “Restaurant, fast food,” and “Restaurant, counter service with limited seating.” as those terms are defined in Glendale Municipal Code Section

30.70.190. “Restaurant” also means and includes any other eating establishment with dine-in eating service that is prohibited or restricted from providing dine -in eating by Los Angeles Count y Department of Public Health’s Safer at Home Orders.

7. “Third-party food delivery service” means any website, mobile application or other internet service that offers or arranges for the sale of food and beverages prepared by, and the same-day delivery or same-day pickup of food and beverages from, no fewer than 20 food service establishments located in the city that are owned and operated by different persons.

B. Fee limits during declared emergency . It shall be unlawful , during the Effective Period (as d efined below), for a third -party delivery service to charge a covered establishment fees, including a delivery fee, service fee s, and other processing fees, that total more than 15% of the purchase price of an online order.

C. Reporting of Fees. Each receipt generated by the third -party delivery service for either the customer or the covered establishment shall clearly state the fees charged, the gratuities paid, and any discounts offered by the covered establishment.

D. Direct Gratuities to Covered Establishments . At the discretion o f the covered establishment, third-party food delivery services shall provide on their platform a mechanism for customers to provide gratuities to covered establishments. Those payments shall be provided to the covered establishment in full and at the same DocuSign Envelope ID: A10C12C0-E73D-47F2-902D-A2F8CEF5871C 145 of 161
time as the third party food delivery service provides other payments to the covered establishment.

E. Effective Period. This Order shall take effect on June 3, 2020, and shall terminate at such time as the City of Glendale state of emergency related to COV ID-19 terminates (“Effective Period”).

F. Grace Period. A third-party food delivery service shall not be found in violation of this order if between June 3, 2020, and June 10, 2020, it imposes a fee per online order for the use of its services that totals more than 15% of the purchase price of such online order, provided it refunds the portion of the fee that exceeds 15% of the purchase price to the covered establishment prior to June17, 2020.

G. Penalties and Enforcement.

1. If a third-party food delivery service charges a covered establishment fees that violate this O rder, the covered establishment shall provide written notice to the third -party food delivery service requesting a refund within seven days. If the third -party food delivery service does not provide the refund requested after seven days or the third -party food delivery service continues to charge fees in violation of this Order after the initial notice and seven-day cure period, a covered establishment may enforce this Order by means of a civi l action seeking damages and injunctive relief. The prevailing party in any such action shall be entitled to an award of reasonable attorney fees.

2. Violations under this Order shall accrue on a daily basis for each day and for each covered establishment charged a fee in violation of this order. A proceeding to recover any civil penalty authorized pursuant to this order is subject to the administrative hearing process of the City. Any violation of this order may be referred to the Office of the City Attorney for prosecution under Glendale Municipal Code Chapter 1.20, which provides for fines not to exceed $1,000 or imprisonment not to exceed six months. Violations may also be enforced by the provisions of Glendale Municipal Code Chapter 1.24, which shall p rovide, along with other enforcement mechanisms set forth therein, for fines of $400 for the first citation, $1,000 for the second citation, and $2,000 for the third citation.

SECTION 2. If any provision of this order or its application is held invalid by a court of competent jurisdiction, such invalidity shall not affect other provisions, sections, or applications of the Orders or this Resolution which can be given effect without the invalid provision or application, and to this end each phrase, section, sentence, or word is declared to be severable.

SECTION 3. This Order does not supersede any stricter limitation imposed by the County of Los Angeles or the State of California.

DocuSign Envelope ID: A10C12C0-E73D-47F2-902D-A2F8CEF5871C 146 of 161
Adopted by the Council of the City of Glendale on this 2nd day of June, 2020.

_______________________________
Mayor
ATTEST:

_________________________________
City Clerk

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS.

CITY OF GLENDALE )

I, Aram Adjemian, City Clerk of the City of Glendale, hereby certify that the foregoing Resolution No. _______ was adopted by the Council of the City of Glendale, California, at a special meeting held on the 2nd day of June, 2020, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:

____________________
City Clerk

APPROVED AS TO FORM

NAME: __________________________
TITLE: __________________________
SIGNATURE: _____________________
DATE: __________________________

DocuSign Envelope ID: A10C12C0-E73D-47F2-902D-A2F8CEF5871C Michael J. Garcia
City Attorney
June 3, 2020
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CITY OF GLENDALE, CALIFORNIA

REPORT TO THE CITY COUNCIL

AGENDA ITEM
Report: Request regarding the acceptance of grant funding from the United States Department of Homeland Security 2021 Urban Area Security Initiatives (UASI) Grant Program

1. Resolution to accept grant funds in the amount of $1,454,709 and authorize the City Manager, or his designee, to execute an agreement with the City of Los Angeles for the award of funds under the FY21 UASI grant program.

2. Resolution to dispense with competitive bidding and authorize the Deputy Director of Finance-Purchasing to issue a purchase order with Platinum Simulators Inc. for (1) the procurement of flight simulator equipment in an amount not to exceed $209,000 for the initial purchase; and (2) thereafter, for the life of the equipment, if the funds for the continued maintenance, support, updates, upgrades, and licensing of the simulator are appropriated within the Police Department’s budget and approved by the City Council as part of the annual citywide budget process.

3. Resolution to appropriate $1,454,709 from the Urban Area Security Initiatives (UASI) Grant Program grant revenue and $34,150 from Asset Forfeiture Public Safety.

COUNCIL ACTION
Item Type: Consent Calendar
Approved for August 9, 2022 calendar

EXECUTIVE SUMMARY
To accept $1,454,709 in grant funding from the from the United States Department of Homeland Security 2021 Urban Area Security Initiatives (UASI) Grant Program for the grant period of September 1, 2021 to May 31, 2024 to be used for equipment, licensing, and training by the Fire and Police Departments.
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COUNCIL PRIORITIES
N/A

RECOMMENDATION
The Glendale Fire and Police Departments recommend City Council approve a resolution authorizing the City Manager, or his designee, to execute an agreement with the City of Los Angeles for the acceptance of grant funds in the amount of $1,454,709 from the 2021 Urban Area Security Initiatives (UASI) Grant Program, and adopt a Resolution of Appropriation in the amount of $1,454,709 for the 2021 Urban Area Security Initiatives (UASI) Grant Program and $34,150 from Asset Forfeiture Public Safety. In addition, it is recommended City Council adopt the attached Resolution dispensing with competitive bidding and authorizing the Deputy Director of Finance-Purchasing to issue a purchase order (1) to procure a flight simulator equipment in an amount not to exceed $209,000 for the initial purchase; and (2) thereafter, for the life of the equipment, if the funds for the continued maintenance, support, updates, upgrades, and licensing of the simulator are appropriated within the Police Department’s budget and approved by the City Council as part of the annual citywide budget process.

BACKGROUND
The City of Glendale has been successful in obtaining $1,454,709 under the 2021 Urban Area Securities Initiative (UASI) Grant Program. These grant funds are allocated between the City of Los Angeles and those cities recognized by the County of Los Angeles Operational Area (OA), which includes Glendale. The grant is administered by the City of Los Angeles. Management of the grant is the responsibility of the Fire and Police Departments. These funds are available for purchases of approved equipment and training of first responders which meet identified national, state, county and local priorities.

The projects associated with the FY21 UASI grant program are for the purposes of continuing efforts to enhance public safety efforts within Glendale and the region. These projects are part of the Los Angeles Operational Area’s regional funding priorities and have been vetted through the Los Angeles area fire and police regional coordination agencies and the City of Los Angeles Office of Homeland Security and Public Safety. All projects have been approved by the State of California Office of Emergency Services Homeland Security authorizing branch.

ANALYSIS
In October 2020, the City of Glendale Fire and Police Departments submitted a grant request for the United States Department of Homeland Security 2021 Urban Area Security Initiatives (UASI) Grant Program to the City of Los Angeles, and was awarded $1,454,709 in grant funding. The agreement between the City of Glendale and the City of Los Angeles authorizes these funds for the following projects:
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Department Project Name Project Funding
CBRNE Equipment $ 25,000
Hazardous Materials Equipment $ 35,000
Hazardous Materials Training $ 40,000 Fire Urban Search and Rescue Equipment $ 100,000 TDMA Licensing $ 1,000,000
Flight Simulator $ 174,850
Temporary Fencing System $ 22,095 Police
LACPCA Vehicle Barriers $ 57,764
Total Awarded Project Funding $ 1,454,709
UASI 2021 Fire Department Projects:

The grant will support an increase in core capabilities for both our Hazardous Materials (HazMat) and Urban Search and Rescue (US&R) response teams through the purchase of new equipment and for required training. The Glendale Fire Department has maintained the California Office of Emergency Services designation as an officially recognized Type-1 Hazardous Materials response team and is part of the State HazMat Mutual Aid Roster. A high level of training and equipment capabilities are required for the Type-1 HazMat team, which provides advanced Hazardous Materials and Weapons of Mass Destruction (WMD) response capabilities to the region. The Glendale US&R is a Type-1 Heavy and part of California Regional Task Force 4 and is also part of the State Mutual Aid system to provide technical rescue operations for structure collapse, high angle rope rescue, confined space, and mass transportation rescue.

The approved funding will replace and improve detection and response equipment and provide specialized training for new and existing members of both teams.

Approved training for this grant is limited to courses that fulfill the requirements of the State Homeland Security Program guidelines under UASI. The HazMat and US&R training courses include subjects such as responding to terrorist bombing incidents, hazardous materials technician and specialist, assistant safety officer, confined space rescue, and trench rescue. The funds will allow several members to receive the training and the materials and supplies required to deliver the training.

UASI 2021 Police Department Projects:

TDMA LICENSING
The TDMA licensing project upgrades the capabilities of the ICI System core and two of our radio sites, resulting in increased call-carrying capacity in the Santa Clarita and Antelope valleys. By expanding, and up to doubling, the number of voice paths available to radio system users in these areas, the likelihood of circumstances where a user must wait to talk after pushing the button will be reduced or even eliminated. 150 of 161
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Flight Simulator:

The Police Department received approval to procure a flight simulator. A flight simulator would provide the Air Support Unit the ability to replicate critical flight conditions and configurations from which accidents typically occur without the expense and/or risk associated with replicating those conditions in actual flight. Examples of conditions for which crewmembers would not otherwise train with realism include inadvertent instrument meteorological conditions (IIMC – a leading cause of accidents), simulated engine failures in precarious phases of flight, tail rotor failures, vortex ring state/settling with power, and various other critical systems failures. The opportunity for such repetitive training would provide crew members invaluable experience in critical decision making and help build instinctive reactions often required to deal with an in-flight emergency.

The “PHS” simulator from Platinum Simulators Inc. is the only option found to match our current model aircraft (MD500 series), as well as our current avionics configuration (Garmin G500/GTN650). Additionally, the “PHS” is the only model simulator to come standard with multiple preprogrammed helicopter platforms, including our current initial training aircraft (Robinson R-22) and potential future aircraft (Airbus H-125). Because the “PHS” is an FAA Approved Aviation Training Device (AATD), pilots would be able to log simulated flight time toward certifications and/or ratings.

Temporary Fencing System
A temporary fencing system addresses current deficiencies in critical equipment needed to protect soft targets, crowded places, infrastructure, and key resources. Tangle tape provides first responders with the equipment necessary to control pedestrian and vehicle traffic and to protect critical infrastructure and key resources by placing temporary barriers along perimeters at any location during violent protests and civil unrest events.

Los Angeles County Police Chiefs’ Association (LACPCA) Vehicle Barriers The acquisition of LACPCA vehicle barriers addresses current deficiencies in critical equipment needed to protect soft targets and crowded places. Anti-vehicle barrier and trailer equipment provides temporary barriers to offer first responders the ability to set up perimeters at any location for crowd control and restrict vehicle access in the event of peaceful demonstrations, protests or civil unrest. They provide first responders the ability to allow for authorized vehicles to enter restricted access areas and the protection of pedestrians against unauthorized vehicles that may try to enter areas of crowded places.

STAKEHOLDERS/OUTREACH
The grant funds will be used to enhance public safety for the community within Glendale and the region.
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FISCAL IMPACT
The UASI 2021 funding received is $1,454,709 and the flight simulator equipment will cost $209,000, of which neither were included as part of the FY2022-23 approved budget. As the flight simulator equipment costs more than what was approved by the UASI grant for that specific project, $174,850 will be funded by the grant and $34,150 will be funded by Police’s Asset Forfeiture Public Safety. Therefore, staff is requesting for an appropriation of 1,454,709 from the Federal Grant revenue and $34,150 from the Police Department’s Asset Forfeiture Public Safety. In addition, future costs for the continued maintenance, support, updates, upgrades, and licensing of the simulator will be requested by the Police Department in its budget and approved by the City Council as part of the annual citywide budget process. This is a reimbursement grant and requires no matching funds. The appropriation request is outlined below:

Requesting Appropriation:

Amount From (Account String) To (Account String) Funding Source $200,000 GL: 31240-2650-GFD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GFD00792AG
Fire Grant Fund –
Fire Federal
Funding
$160,000 GL: 45150-2650-GFD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GFD00792AG
Fire Grant Fund –
Fire Furniture &
Equipment
$40,000 GL: 44650-2650-GFD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GFD00792AG
Fire Grant Fund –
Fire Training
$1,000,000 GL: 31240-6600-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GPD00793AG
GPD Wireless
Fund – Police
Federal Funding
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$1,000,000 GL: 51000-6600-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GPD00793AG
GPD Wireless
Fund – Police
Capital Outlay
$254,709 GL: 31240-2610-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GPD00794AG
Police Special
Grant Fund –
Police Federal
Funding
$22,095 GL: 45150-2610-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GPD00794AG
Police Special
Grant Fund
Furniture &
Equipment
$232,614 GL: 51000-2610-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: GPD00794AG
Police Special
Grant Fund –
Police Capital
Outlay
$34,150 GL: 24211-2600-GPD-
0000-P0000-T0000-
F0000-0000-0000-
PL: N/A
Asset Forfeiture
Fund – Public
Safety
$34,150 GL: 51000-2600-GPD-
0020-P0000-T0000-
F0000-0000-0000-
PL: G65008
Asset Forfeiture
Fund – Police
Capital Outlay

ENVIRONMENTAL REVIEW (CEQA/NEPA)
There is no possibility that the acceptance of this grant may have a significant effect on the environment. (14 Cal. Code Regs. § 15061(b)(3)).

CAMPAIGN DISCLOSURE
In accordance with the City Campaign Finance Ordinance No. 5744, the following are the names and business addresses of the members of the board of directors, the chairperson, 153 of 161
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CEO, COO, CFO, Subcontractors, and any person or entity with more than 10% interest in the company proposed for contract in this Agenda Item Report:

Officers of Platinum Simulators Inc.:

Full Name Title Business
Address
City State Zip
Pedro Gonzalez Owner 1945 Camino
Vida Roble Ste. L
Carlsbad CA 92008
Terry Simpkins CEO 1945 Camino
Vida Roble Ste. L
Carlsbad CA 92008
Ownership Interest in more than 10% in Platinum Simulators Inc.:

Full Name Title Business Address City State Zip
Pedro
Gonzalez
Owner 1945 Camino Vida
Roble Ste. L
Carlsbad CA 92008

ALTERNATIVES
Alternative 1: Approve as requested by the Fire and Police Departments.

Alternative 2: Deny the Fire and Police Department’s request. If the request is denied, the City will not be able to utilize the grant funding for the approved projects.

Alternative 3: The City Council may consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Prepared by:

Alison Finch, Public Safety Business Administrator
Gor Galstyan, Public Safety Business Specialist
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
None.
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RESOLUTION NO. ___________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE

MAKING AN APPROPRIATION
BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $1,488,859 is hereby appropriated and/or transferred from the following accounts to the following accounts:

ACCOUNTS DESCRIPTION FROM TO
31240-2650-GFD-0020-P0000-
T0000-F0000-0000-0000
GFD00792AG
45150-2650-GFD-0020-P0000-
T0000-F0000-0000-0000
GFD00792AG
44650-2650-GFD-0020-P0000-
T0000-F0000-0000-0000
GFD00792AG
31240-6600-GPD-0020-P0000-
T0000-0000-0000-
GPD00793AG
51000-6600-GPD-0020-P0000-
T0000-0000-0000-
GPD00793AG
31240-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00794AG
45150-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00794AG
51000-2610-GPD-0020-P0000-
T0000-0000-0000-
GPD00794AG
24211-2600-GPD-0000-P0000-
T0000-F0000-0000-0000-
51000-2600-GPD-0020-P0000-
T0000-F0000-0000-0000-
G65008
Federal Grants, Fire Grant Fund,
Glendale Fire, Projects,
UASI 2021
Furniture & Equipment, Fire Grant Fund,
Glendale Fire, Projects,
UASI 2021
Training, Fire Grant Fund,
Glendale Fire, Projects,
UASI 2021
Federal Grants, GPD Wireless Fund,
Glendale Police, Projects,
UASI 2021
Capital Outlay, GPD Wireless Fund,
Glendale Police, Projects,
UASI 2021
Federal Grants, Police Special Grant Fund,
Glendale Police, Projects,
UASI 2021
Furniture & Equipment, Police Special Grant
Fund, Glendale Police, Projects,
UASI 2021
Capital Outlay, Police Special Grant Fund,
Glendale Police, Projects,
UASI 2021
Public Safety, Asset Forfeiture Fund,
Glendale Police, Projects,
Capital Outlay, Asset Forfeiture Fund,
Glendale Police, Projects,
DOJ Asset Forfeiture Expense
$200,000
$1,000,000
$254,709
$34,150
$160,000
$ 40,000

$1,000,000

$22,095

$232,614
$34,150

To appropriate funds for the FY21 Urban Area Security Initiatives (UASI) Grant Program and Flight Simulator Equipment.

SECTION 2: The Director of Finance / Information Technology is authorized to make such other revisions, individual appropriation line-items, changes in summaries, fund totals, grand totals, and other portions of the budget document as necessary to reflect and implement the changes specified in this resolution. 155 of 161
SECTION 3: The City Clerk shall certify to the adoption of this Resolution.

Adopted this________day of _______________, 2022.
_______________________________
Mayor
ATTEST:
07/19/2022
_____________________________________
City Clerk 1,488,859

STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF GLENDALE )
I, Suzie Abajian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No._________was adopted by the Council of the City of Glendale, California, at a regular meeting held on the__________ day of _______________, 2022, and that the same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
________________________________
City Clerk
/
Director of Finance / Information Technology
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1 RESOLUTION NO. ______________

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA

AUTHORIZING THE CITY MANAGER OR A DESIGNEE TO EXECUTE ALL NECESSARY DOCUMENTS ASSOCIATED WITH THE 2021 URBAN AREA

SECURITY INITIATIVES GRANT PROGRAM
WHEREAS, the City of Glendale has been successful in obtaining $1,454,709 in grant funds under the 2021 Urban Area Security Initiatives (UASI) Grant Program for use by the Glendale Fire and Police Departments;
WHEREAS, these grant funds are allocated between City of Los Angeles and those cities recognized by the County of Los Angeles Operational Area which includes the City of Glendale;
WHEREAS, the grant funding is administered by the City of Los Angeles and provided to the City of Glendale under a Subaward Agreement (“Agreement”) between the City of Los Angeles and the City of Glendale;
WHEREAS, the projects associated with the FY21 UASI grant program are for the purpose of continuing efforts to enhance public safety efforts within Glendale and the region;
WHEREAS, the projects associated with the FY21 UASI grant program are part of the Los Angeles Operational Area’s regional funding priorities and have been vetted through Los Angeles area fire and police regional coordination agencies, as well as the City of Los Angeles Office of Homeland Security and Public Safety; WHEREAS, the projects associated with the FY21 UASI grant program have been approved by the State of California Office of Emergency Services Homeland Security authorizing branch;
WHEREAS, the projects associated with the FY21 UASI grant program are set forth in the Report to the City Council dated August 9, 2022, and have been approved by the State of California Office of Emergency Services Homeland Security authorizing branch;
WHEREAS, any liability arising out of the performance of the Agreement related to this grant shall be the responsibility of the City of Glendale; and WHEREAS, the grant funds provided under the FY21 UASI grant program shall not be used to supplant expenditures controlled by the City Council. 157 of 161
2 NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA AS FOLLOWS:

The City Council hereby:

SECTION 1. Finds the above recitals to be true and correct.

SECTION 2. Approves participation in the United States Department of Homeland Security 2021 UASI Grant Program and accepts the grant funds under this program in the amount of $1,454,709.

SECTION 2. Authorizes the City Manager, or a designee, to execute all necessary agreements, certifications, and documents to accept and implement the United States Department of Homeland Security 2021 UASI Grant Program.

Adopted this day of , 2022.
____________________
Mayor
ATTEST:
________________________
City Clerk

STATE OF CALIFORNIA )
) SS

COUNTY OF LOS ANGELES )
I, SUZIE ABAJIAN, Ph.D, City Clerk of the City of Glendale, certify that the foregoing Resolution No. was adopted by the Council of the City of Glendale, California, at a regular meeting held on the day of , 2022, and that same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
_____________________
City Clerk
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1 RESOLUTION NO. ______________

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GLENDALE,

CALIFORNIA, DISPENSING WITH COMPETITIVE BIDDING AND AUTHORIZING THE

DEPUTY DIRECTOR OF FINANCE - PURCHASING TO ISSUE A PURCHASE ORDER

FOR PROCUREMENT OF A FLIGHT SIMULATOR FROM PLATINUM SIMULATORS INC.

WHEREAS, the City of Glendale has been successful in obtaining $1,454,709 in grant funds under the 2021 Urban Area Security Initiatives (UASI) Grant Program for use by the Glendale Fire and Police Departments;
WHEREAS, these grant funds are allocated between City of Los Angeles and those cities recognized by the County of Los Angeles Operational Area which includes the City of Glendale;
WHEREAS, the grant funding is administered by the City of Los Angeles and provided to the City of Glendale under a Subaward Agreement (“Agreement”) between the City of Los Angeles and the City of Glendale;
WHEREAS, the projects associated with the FY21 UASI grant program are set forth in the Report to the City Council dated August 9, 2022, and have been approved by the State of California Office of Emergency Services Homeland Security authorizing branch;
WHEREAS, the approved projects include the procurement of a flight simulator to support the Police Department’s Air Support Unit;
WHEREAS, a flight simulator would provide the Police Department’s Air Support Unit the ability to replicate critical flight conditions and configurations from which accidents typically occur, such as inadvertent instrument meteorological conditions, simulated engine failures in precarious phases of flight, tail rotor failures, vortex ring state/settling with power, and various other critical systems failures, without the expense and/or risk associated with replicating those conditions in actual flight; WHEREAS, flight simulator training would provide Air Support Unit members invaluable experience in critical decision making and help build instinctive reactions often required to deal with an in-flight emergency;
WHEREAS, the “PHS” simulator from Platinum Simulators Inc. is the only simulator option found to match the City’s current model aircraft (MD500 series) and avionics configuration (Garmin G500/GTN650);
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2 WHEREAS, the “PHS” simulator is also the only model simulator to come standard with multiple preprogrammed helicopter platforms, including platforms for the City’s current initial training aircraft (Robinson R-22) and potential future aircraft (Airbus H-125);
WHEREAS, the “PHS” is an FAA approved Aviation Training Device and thus Air Support Unit pilots would be able to log simulated flight time toward certifications and/or ratings;
WHEREAS, the City of Glendale Charter, Article VI, Section 9, provides an exemption to competitive bidding where the Council determines it is in the best interest of the City; and
WHEREAS, it is in the City of Glendale’s best interest to dispense with competitive bidding and authorize the Deputy Director of Finance – Purchasing to issue a purchase order for the procurement of the “PHS” from Platinum Simulators Inc.

NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA AS FOLLOWS:

SECTION 1. That the foregoing facts are deemed to be a true and correct basis for dispensing with competitive bidding, and authorizing the Deputy Director of Finance – Purchasing to issue a purchase order with Platinum Simulators Inc. for the procurement of flight simulator equipment in an amount not to exceed $209,000 for the initial purchase.

SECTION 2. That after the initial procurement, the Police Department is authorized to purchase, for the life of the equipment, continued maintenance, support, updates, upgrades, and licensing for the simulator if the funds are appropriated within the Police Department’s budget and approved by the City Council as part of the annual citywide budget process.

Adopted this day of , 2022.
____________________
Mayor
ATTEST:
________________________
City Clerk

STATE OF CALIFORNIA )
) SS

COUNTY OF LOS ANGELES )
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3 I, SUZIE ABAJIAN, Ph.D, City Clerk of the City of Glendale, certify that the foregoing Resolution No. was adopted by the Council of the City of Glendale, California, at a regular meeting held on the day of , 2022, and that same was adopted by the following vote:

Ayes:

Noes:

Absent:

Abstain:
_____________________
City Clerk
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