CC_05062025_EXH. 3 (GWP TAP - CLEAN) RV. 4.14 — Glendale City Council, May 6, 2025

Trading Authority Policy
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TRADING AUTHORITY POLICY
TBD, 2025
EXHIBIT 3
Trading Authority Policy
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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 AND OFF PREMISES 5

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 7

4.1 BILATERAL ELECTRIC POWER AND TRANSMISSION
TRANSACTON LIMITS 7

4.2 CAISO TRANSACTION LIMITS 9

4.3 GAS TRANSACTION LIMITS 11

4.4 EMISSION ALLOWANCE AND EMISSION REDUCTION CREDIT
TRANSACTION LIMITS 13

4.5 RENEWABLE ENERGY CREDIT TRANSACTION LIMITS 14

4.6 CARBON ALLOWANCE AND CARBON EMISSION OFFSET
TRANSACTION LIMITS 15

4.7 LOW CARBON FUEL STANDARD TRANSACTION LIMITS 16

5. ACKNOWLEDGEMENTS 17

5.1 CLEAR AUTHORITY 17

5.2 VIOLATIONS AND SANCTIONS 17

5.3 SANCTIONS FOR OPERATIONAL/SCHEDULING/TAGGING/
TRANSMISSION ERRORS 17

5.4 POLICY EFFECTIVE 17

6. APPENDICIES 18

APPENDIX A - ACKNOWLEDGEMENT OF TRADING AUTHORITY 18
APPENDIX B - INSTRUMENT OF TRADING AUTHORITY DELEGATION 19 Trading Authority Policy
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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, where the City Council determines it is in the best interest of the City, it may dispense with competitive bidding 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.

Such wholesale energy transactions include electrical energy and capacity, ancillary services, transmission, renewable energy attributes, carbon allowances Trading Authority Policy
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2 and carbon emission offsets, emission allowances and emission reduction credits, low carbon fuel standard credits, 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.

Under this provision,
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3 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.
(c) For Agreements under previous approval of the agreement format by the City Attorney’s Office:
•Both parties execute a standard Confirmation agreement; the parties have already entered into a base contract that was previously approved as to form by the City Attorney’s Office within the last 3 years; and any modifications are only to the commercial terms of the agreement
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.

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4 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;
•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.);
•If the agreement previously approved as to form by the City Attorney’s office was not within the last 3 years;
•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 Trading Authority 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 Energy Risk Management Committee (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.

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5 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.

3.5Deal Capture
Any transaction(s) executed by GWP employee or agent must be accurately and timely captured in the corresponding Energy Trading Risk Management system 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, Related Products and Offerings, and Approved Transaction Types
The purpose of defining a process for the introduction of a new commodity is to ensure that the associated exposures are thoroughly reviewed and understood by the ERMC, GWP management, and GWP Staff. The ERMC must review and approve the use of all new commodities and recommend any such commodity for approval by City Council before the execution of any such transaction.

Products, methods of purchase or marketplaces that package commodities in commercial offerings such as those that include varied timing, guarantees, and online exchange formats; broker, merchant or commodity services and fees, including “futures commission merchants”; ancillary or related necessary or advisable services; asset management and agency agreements; or otherwise related offerings are permitted under this Trading Authority Policy as long as the underlying commodity itself is authorized and the cost of the offerings are Trading Authority Policy
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6 commercially reasonable as determined by GWP. Such costs may include flat fees, commissions, volumetric or per transaction pricing, cost sharing or any other reasonable pricing methodology.

The following transaction types are not new to GWP and therefore do not require the review and approvals described within this Section 3.8: (1) a physical spot or forward bilateral capacity, energy, ancillary service or transmission transaction; (2) a physical spot or forward gas, including but not limited to natural gas, biogas, and hydrogen that can be used as fuel for gas-fired generation facilities, imbalance, storage or transportation transaction, related gas scheduling services, asset management agreements and agency agreements; (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) a low carbon fuel standard credit transaction; (9) an over-the-counter (OTC) financial transaction; or (10) an exchange-traded transaction, including brokerage and related services for any allowed commodity or product, as well as futures commission merchants and related or similar services. Such transactions may take place on commercially reasonable terms if specific price and other transaction features are not set forth in an applicable commodity matrix, provided that any transaction in the underlying commodity itself is in accordance with this Trading Authority Policy.

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7 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. The product offerings and transaction types set forth in Section 3.8, above, apply to all commodities herein, in addition to the specific examples listed in each commodity matrix.

In addition to the term limits specified in the below commodity matrices, for transactions executed through or utilizing a Southern California Public Power Authority (SCPPA) project competitive bidding process or procurement (inclusive of competitive, sole source or other methods), the term of the transaction under City Manager or GWP General Manager approval authority under all matrices may exceed 5 years to be consistent with the respective SCPPA project related procurement cycle, up to a 7 year maximum.

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.

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8 •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 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
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9 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.

When a transmission purchase is related to a fixed-volume energy 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, Trading Authority Policy
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10 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.

Imports are defined as energy located outside the ISO Controlled Grid that is imported into 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 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.

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11 4.3 GAS TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for gas and gas transportation transactions.

Per Transaction Limits Aggregate Limits
Revenue Share
to Counterparty
Limit
Title Product Term Lead
Time
Daily
MMBtu
Volume
$/
MMBtu
Total
MMBtu Total $ %
Share $ Limit
Gas &
Transport N/A N/A
City
Council Asset
Management
& Agency
Agreements
No Limit No
Limit
No
Max.

No
Max. No Max. No
Max. No
Limit
No
Limit
> 2 Years
< 5 Years 10,000 $10
Gas &
Transport < 2
Years
No
Max.

No
Max.
6,000,000 N/A N/ACity
Manager
and
GWP
General
Manager
Asset
Management
& Agency
Agreements
< 5 Yrs.
< 5
Yrs.

No
Max.

No
Max. No Max.
$24
Million
25% $5
Million

4.3.1 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 gas only and do not include transportation, however, the Term, Lead Time, and Quantity limits do apply to transportation.
•Authorized products include physical gas, including but not limited to natural gas, biogas, and hydrogen, imbalance, transportation, scheduling, and storage, as well as financial gas derivatives, including financial basis transactions, asset management agreements and agency agreements.

Financial gas derivatives may be OTC or exchange traded products.

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12 4.3.2 Authorized Delivery Locations
Physical -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 gas to GWP facilities.

Financial 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 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
The City Manager or GWP General Manager must pre-approve firm gas purchases or sales transported on non-firm transportation.

4.3.5 Asset Management and Agency Agreement Criteria
In situations where GWP has idle capacity or usage rights on owned or contracted gas transmission lines, and it does not have the internal resources or expertise to manage the excess capacity efficiently, GWP may enter into asset management or agency agreements, as applicable, to optimize and manage its share of capacity to generate revenue for GWP
Asset Management and Agency Agreements will only be entered into if it is determined to be in GWP’s best interest to execute such agreements. The income received by GWP may be based on a value/revenue sharing percentage, fixed-rate, or other reasonable methodology and meet the following requirements:
•The terms of the agreement must be commercially reasonable as determined by the City Manager, GWP General Manager or designee; and Trading Authority Policy
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13 •The additional income received by GWP must exceed expenses incurred under the agreement.
•The percentage of revenue sharing (if any) with the counterparties to such agreements may not exceed 25% to such entities; any greater percentage must be approved by the City Council.
•The absolute amount of revenue to be received by such counterparties shall not exceed $5,000,000, unless approved by the City Council.

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.

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.
•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
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15 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 is 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.
•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

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16 •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.

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 Years
< 5 Years 50,000 $1000City
Manager
and
General
Manager
LCFS
< 2 Years
< 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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17 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 Manager or GWP General Manager. In situations where after a review by the City Manager or GWP General Manager has been performed and clear authority is still in question, the matter will be presented to the City Council for authorization.

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 Utility 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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18 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, 2025.

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 Utility Risk Manager, GWP Management, or any member of the ERMC.
_____________________________________
Signature
_____________________________________
Type or Print Name
_____________________________________
Title
_____________________________________
Date
Trading Authority Policy
Glendale Water & Power TBD/2025
19 APPENDIX B

INSTRUMENT OF TRADING AUTHORITY DELEGATION

1. DELEGATION PURPOSE
The purpose of this Trading Authority Delegation is to define the authority granted by the Glendale City Manager and the Glendale Water and Power (GWP) General Manager to GWP Operations staff and to ACES (and/or other City consultant, if not ACES). This Trading Authority Delegation is intended to supplement and complement the GWP Trading Authority Policy.

2. DELEGATION OBJECTIVES
The objective of this Trading Authority Delegation 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, •GWP’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 Delegation.

3.1 Execution Authority
This Trading Authority Delegation identifies the authorized levels for the City Manager and GWP General Manager and the authority delegated by the City Manager and GWP General Manager to GWP Operations staff and to ACES (and/or other City consultant, if not ACES). The City Manager and GWP General Manager have the authority to modify authority levels set within this Trading Authority Delegation at their sole discretion as long as the delegated authority does not exceed their own authority per the Trading Authority Policy.

Execution Authority 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 Trading Authority Policy
Glendale Water & Power TBD/2025
20 Aggregate Limits, as applicable, are applied to gross amounts transacted in total, and not to buys and sells netted together.

3.2 Contract Requirements
Transactions with counterparties shall only be permitted if GWP has:
•An active, valid, and executed agreement enabling such trading activity with that counterparty and 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 in writing by the City Manager or GWP General Manager and approved as to form by the City Attorney, or his or her designee. 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 transactions 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.

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, Trading Authority Policy
Glendale Water & Power TBD/2025
21 current agreement that has been previously approved as to form by the City Attorney’s Office within the last 3 years.
(c) For Agreements under previous approval of the agreement format by the City Attorney’s Office:
•Both parties execute a standard Confirmation agreement; the parties have already entered into a base contract that was previously approved as to form by the City Attorney’s Office within the last 3 years; and any modifications are only to the commercial terms of the agreement
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.

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;
•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.);
•If the agreement previously approved as to form by the City Attorney’s office was not within the last 3 years;
•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 Trading Authority Policy.

Trading Authority Policy
Glendale Water & Power TBD/2025
22 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.

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

Trading Authority Policy
Glendale Water & Power TBD/2025
23 3.8Approval for New Commodities, Related Products and Offerings, and Approved Transaction Types
The purpose of defining a process for the introduction of a new commodity is to ensure that the associated exposures are thoroughly reviewed and understood by the ERMC, GWP management, and GWP Staff. The ERMC must review and approve the use of all new commodities and recommend any such commodity for approval by City Council before the execution of any such transaction.

Products, methods of purchase or marketplaces that package commodities in commercial offerings such as those that include varied timing, guarantees, and online exchange formats; broker, merchant or commodity services and fees, including “futures commission merchants”; ancillary or related necessary or advisable services; asset management and agency agreements; or otherwise related offerings are permitted under this Trading Authority Policy as long as the underlying commodity itself is authorized and the cost of the offerings are commercially reasonable as determined by GWP. Such costs may include flat fees, commissions, volumetric or per transaction pricing, cost sharing or any other reasonable pricing methodology.

The following transaction types are not new to GWP and therefore do not require the review and approvals described within this Section 3.8: (1) a physical spot or forward bilateral capacity, energy, ancillary service or transmission transaction; (2) a physical spot or forward gas, including natural gas, biogas, and hydrogen that can be used as fuel for gas-fired generation facilities, imbalance, storage or transportation transaction, or related gas scheduling services, asset management agreements and agency agreements; (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) a low carbon fuel standard credit transaction; (9) an over-the-counter (OTC) financial transaction; (10) an exchange-traded transaction, including brokerage and related services for any allowed commodity or product, as well as futures commission merchants and related or similar services. Such transactions may take place on commercially reasonable terms if specific price and other transaction features are not set forth in an applicable commodity matrix, provided that any transaction in the underlying commodity itself is in accordance with this Trading Authority Policy.

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 Trading Authority Policy
Glendale Water & Power TBD/2025
24 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. The product offerings and transaction types set forth in Section 3.8, above, apply to all commodities herein, in addition to the specific examples listed in each commodity matrix.

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

No
Max.
2,190,000 $150
Million 4,380,000 $300
Million
> 1 Year
< 2 Years 100 $150
Chief or
Assistant
General
Manager
(Power
Management)
and Integrated
Resource
Planning
Administrator
Electric
Power
and
Trans < 1 Year
< 3
Years No
Max.

No
Max.
876,000 $80
Million 1,752,000 $160
Million
> 1 Week
< 1 Year
< 1
Year 100 $150Energy
Trading
Manager
Electric
Power
and
Trans < 1
Week
< 1
Month 100 $1000
438,000 $40
Million 876,000 $80
Million
Trading Authority Policy
Glendale Water & Power TBD/2025
25 > 1 Week
< 3
Months
< 1
Year 50 $100Energy
Marketer/
Trader
Electric
Power
and
Trans
< 1 Week < 1
Month 75 $250
74,400 $10
Million 219,000 $30
Million
Physical
Electric
Power
and
Trans
< 1 Day < 1
Day
100 $1000
(1) 12,000 $4
Million 24,000 $8
Million
ACES
Financial
Electric
Power
None
(1) The dollar limit may only be exceeded without pre-approval of the GWP Deputy General Manager (Power Management) or the GWP General Manager in order to “Keep the Lights On” (KLO).
(2) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.
“Keep the Lights On” (KLO) Procedure
KLO trades are defined as trades executed during Emergency Alert(s) that exceed approved MWh dollar limits. An Emergency Alert is defined as the BA or ISO taking mitigating actions during a contingency event and may no longer able to supply its expected energy requirements. When a trade is executed to “Keep the Lights On,” the trader must perform and log an event analysis. The analysis must include:
1) Generation assets,
2) Transmission,
3) Ancillaries,
4) Gas Delivery Conditions, and
5) Forecast Methodology (Snapshot of Load and PRT)
The trading staff must log the event within 24 hours of occurrence and notify the GWP Energy Trading Manager for review. If feasible, trading staff should notify GWP that a KLO Procedure may occur, but notification is not required to perform the KLO Procedure.

4.1.1Bilateral Electric Power and Transmission Transaction Limits Matrix Explanations
•Transaction Limits represent the MW volume per hour and dollars/MWH for each transaction executed.

Trading Authority Policy
Glendale Water & Power TBD/2025
26 •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 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.
•The transaction term limit for ACES (and/or other City consultant, if not ACES) of < 1 Day covers individual daily transactions as well as executed transactions for more than one day to accommodate weekends or holidays, which could have terms up to 3 days for a normal weekend and up to 5 days to cover a holiday weekend.
•Energy Marketer/ Trader limits will be delegated to ACES (and/or other City consultant, if not ACES) only while performing Day-ahead services.

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 Trading Authority Policy
Glendale Water & Power TBD/2025
27 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.

When a transmission purchase is related to a fixed-volume energy 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
Title Product Delivery
Lead Time Term MW
Size $/MWh
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
Congestion Revenue Rights As required
by CAISO < 1 Year No Max No Max
City Manager
and General
Manager
All other CAISO Products
(Generation Awards,
Demand Awards, Virtual
Transaction Awards)
None None None None
Chief or
Assistant Imports/Exports As required
by CAISO < 1 Week No Max No Max
Trading Authority Policy
Glendale Water & Power TBD/2025
28 Ancillary Service Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below regarding Inter SC
Energy Transactions
General
Manager
(Power
Management)
and Integrated
Resource
Planning
Administrator
All Other CAISO Products
(Generation Awards,
Demand Awards, Virtual
Transaction Awards,
Congestion Revenue
Rights)
None None None None
Imports/Exports As required
by CAISO < 1 Week 100 CAISO Price
Cap
Ancillary Service Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below regarding Inter SC
Energy TransactionsEnergy Trading
Manager All Other CAISO Products
(Generation Awards,
Demand Awards, Virtual
Transaction Awards,
Congestion Revenue
Rights)
None None None None
Imports/Exports As required
by CAISO < 1 Week 75 CAISO Price
Cap
Ancillary Service Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below regarding Inter SC
Energy TransactionsEnergy
Marketer/
Trader
All Other CAISO Products
(Generation Awards,
Demand Awards, Virtual
Transaction Awards,
Congestion Revenue
Rights)
None None None None
Imports/Exports As required
by CAISO < 1 Week 75 CAISO Price
Cap
Ancillary Service Awards None None None None
Inter SC Energy
Transactions
See matrix explanation below regarding Inter SC
Energy Transactions
ACES All Other CAISO Products
(Generation Awards,
Demand Awards, Virtual
Transaction Awards,
Congestion Revenue
Rights)
None None None None
(1) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.

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, Trading Authority Policy
Glendale Water & Power TBD/2025
29 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.

Imports are defined as energy located outside the ISO Controlled Grid that is imported into 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.
•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.
•Energy Marketer/ Trader limits will be delegated to ACES (and/or other City consultant, if not ACES) only while performing Day-ahead services.

Trading Authority Policy
Glendale Water & Power TBD/2025
30 4.3 GAS TRANSACTION LIMITS
The following sets transaction limits, definitions, and procedural requirements for gas and gas transportation transactions.

Per Transaction Limits Aggregate Limits
Revenue
Share to
Counterparty
Limit
Title Product Term Lead
Time
Daily
MMBtu
Volume
$/
MMBtu
Total
MMBtu
Total
$
%
Share
$
Limit
> 2
Years
< 5
Years
10,000 $10
Gas &
Transport
< 2
Years No Max. No
Max.
6,000,000 $24
Million N/A N/A
City Manager
and General
Manager Asset
Managem
ent &
Agency
Agreemen
ts
< 5
Years
< 5
Yrs.

No Max. No
Max. No Max. No
Max. 25% $5
Million
> 1
Year
< 2
Years
10,000 $10
Chief or
Assistant
General
Manager
(Power
Management)
and Integrated
Resource
Planning
Administrator
Gas &
Transport
< 1
Year
< 3
Yrs.

No Max. No
Max.
3,000,000 $12
Million N/A N/A
> 3
Month
< 1
Year
10,000 $15
> 1
Week
< 3
Month
10,000 $20
Energy
Trading
Manager
Gas &
Transport
< 1
Week
< 1
Yr.
20,000 $25
1,500,000 $8
Million N/A N/A
> 1
Week
< 3
Month
s
10,000 $15Energy
Marketer/
Trader
Gas &
Transport
< 1
Week
< 6
Mo.
20,000 $20
900,000 $6
Million N/A N/A
Trading Authority Policy
Glendale Water & Power TBD/2025
31 ACES Gas &
Transport None None None None None None N/A N/A
(1) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.

Financial gas derivatives may be OTC or exchange traded products. •Energy Marketer/ Trader limits will be delegated to ACES (and/or other City consultant, if not ACES) only while performing Day-ahead services.

4.3.2 Authorized Delivery Locations
Physical 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 gas to GWP facilities.

Trading Authority Policy
Glendale Water & Power TBD/2025
32 4.3.3 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 in writing by the City Manager or GWP General Manager.

4.3.4 Transportation Firmness
The City Manager or GWP General Manager must pre-approve firm gas purchases or sales transported on non-firm transportation.

4.3.5 Asset Management and Agency Agreement Criteria
In situations where GWP has idle capacity or usage rights on owned or contracted gas transmission lines, and it does not have the internal resources or expertise to manage the excess capacity efficiently, GWP intends to enter into asset management or agency agreements, as applicable, to optimize and manage its share of capacity to generate revenue for GWP Asset Management and Agency Agreements will only be entered into if it is determined to be in GWP’s best interest to execute such agreements. The income received by GWP may be based on a value/revenue sharing percentage, fixed-rate, or other reasonable methodology and meet the following requirements:
•The terms of the agreement must be commercially reasonable as determined by the City Manager, GWP General Manager or designee; and •The additional income received by GWP must exceed expenses incurred under the agreement.
•The percentage of revenue sharing (if any) with the counterparties to such agreements may not exceed 25% to such entities; any greater percentage must be approved by the City Council.
•The absolute amount of revenue to be received by such counterparties shall not exceed $5,000,000, unless approved by the City Council.

Trading Authority Policy
Glendale Water & Power TBD/2025
33 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 Market No Max No Max
City Manager
and General
Manager
SO2 and NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required Market
Chief or
Assistant
General
Manager
(Power
Management)
and Integrated
Resource
Planning
Administrator
SO2 and NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required Market
Energy
Trading
Manager
SO2 and NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required Market
Energy
Marketer/
Trader
SO2 and NOx
Emission
Allowances
As
Required
As
Required As Required Market As Required Market
ACES
SO2 and NOx
Emission
Allowances
None None None None None None
Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
Credits $/ Credit Total
Credit Total $
City Council
Emission
Reduction
Credit
No Limit No Limit No Max Market No Max No Max
City Manager
and General
Manager
Emission
Reduction
Credit
As
Required
As
Required As Required Market As Required Market
Trading Authority Policy
Glendale Water & Power TBD/2025
34 Chief or
Assistant
General
Manger
(Power
Management)
and
Integrated
Resource
Planning
Administrator
Emission
Reduction
Credit
As
Required
As
Required As Required Market As Required Market
Energy
Trading
Manager
Emission
Reduction
Credit
As
Required
As
Required As Required Market As Required Market
Energy
Marketer/
Trader
Emission
Reduction
Credit
As
Required
As
Required As Required Market As Required Market
ACES
Emission
Reduction
Credit
None None None None None None
(1) Referrals to “ACES” in the above matrices apply to other City consultants, if not ACES.

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 are 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.
•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).

Trading Authority Policy
Glendale Water & Power TBD/2025
35 •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 Produc
t Term Lead
Time
Total REC
Units
$/
REC Unit
Total REC
Units Total $
> 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
> 1
Years
< 2
Years
438,000 $50
Chief or
Assistant
General
Manager
(Power
Management
) and
Integrated
Resource
Planning
Administrator
RECs
< 1
Year
<3
Years
No Max No Max
876,000 $25 Million
Energy
Trading
Manager
RECs < 1
Year
< 1
Year 219,000 $50 438,000 $10 Million
Energy
Marketer/
Trader
RECs < 3
Month
< 6
Month 74,400 $50 219,000 $5 Million
ACES RECs None None None None None None
(1) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.

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 is unbundled from the price of power. Bilateral power trades with renewable Trading Authority Policy
Glendale Water & Power TBD/2025
36 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 occurs in WREGIS for certified RECs that have been banked or generated.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
CO2e
$/
CO2e
Total
Co2e
Total
$
> 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
> 1
Year
< 2
Years
500,000 $50
Chief or Assistant General
Manager (Power
Management) and Integrated
Resource Planning
Administrator
CO2e
< 1
Year
< 3
Years
No Max No
Max
1,500,000 $25
Million
Energy Trading Manager CO2e < 1
Year
< 1
Year 250,000 $50 750,000 $10
Million
Energy Marketer/ Trader CO2e < 3
Month
< 6
Month 25,000 $50 100,000 $2
Million
ACES CO2e None None None None None None
Trading Authority Policy
Glendale Water & Power TBD/2025
37 (1) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.

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.

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) Credits transactions.

Per Transaction Limits Aggregate Limits
Title Product Term Lead
Time
Total
LCSF
Credits
$ per
LCFS
Credit
Total
LCFS
Credits
Total $
City Council LCFS No
Limit
No
Limit No Max No Max No Max No Max
> 2
Years
< 5
Years
50,000 $1000City Manager and
General Manager LCFS
< 2
Years
< 5
Years
No Max No
Max
300,000 $50
Million
Trading Authority Policy
Glendale Water & Power TBD/2025
38 Chief or Assistant
General Manager
(Power Management)
and Integrated
Resource Planning
Administrator
LCFS < 2
Years
< 3
Years 50,000 $750 150,000 $30
Million
Energy Trading
Manager LCFS < 1 Year < 1
Year 25,000 $500 75,000 $15
Million
Energy Marketer/
Trader LCFS < 3
Month
< 6
Month 10,000 $300 25,000 $5 Million
ACES LCFS None None None None None None
(1) Referrals to “ACES” in the above matrix apply to other City consultants, if not ACES.

4.7.1 Low Carbon Fuel Standard (LCF) 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).

5. ACKNOWLEDGEMENTS

5.2 Violations and Sanctions
Violations of this Trading Authority Delegation must not occur. Should it be deemed that non-compliant incidents did occur; the Risk Manager will report Trading Authority Policy
Glendale Water & Power TBD/2025
39 such incidents to the ERMC for evaluation according to the GWP Trading Sanctions Policy.

5.4 Delegation Effectiveness
This Trading Authority Delegation is in effect upon approval of the City Manager and GWP General Manager and shall remain in effect until a replacement delegation has been approved.

5.5 Authority Delegation Acknowledgement
____________________________ ________________
Roubik Golanian Date
City Manager
City of Glendale
____________________________ ________________
Scott K. Mellon, P.E. Date
Acting General Manager
Glendale Water & Power

Glendale City CouncilMay 6, 2025

Glendale City Council
May 6, 2025