AR 26 ATTACHMENT A — Pasadena City Council, December 11, 2023 (part 2 of 2)

Pasadena Water and Power
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Biofuels: New External Fuel
Cells Biofuels WECC
Region PCC1 ‐ ‐ ‐
Biofuels: New Internal Fuel
Cells Biofuels WECC
Region PCC1 ‐ ‐ ‐
Wind: New Offshore Wind Wind WECC
Region PCC1 ‐ ‐ ‐
Total Non‐Grandfathered Owned or Contracted Projects ‐ 2,344,889 2,296,829

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10. Renewable Portfolio Standard Procurement Plan Limitations and Relief Section E of the City’s RPS Enforcement Program notes that PWP will use its best efforts to procure adequate supplies of renewable energy as set forth in this RPS Procurement Plan; however, PWP will at all times maintain system reliability and average procurement costs for retail electric sales in accordance with the approved budget and retail ele ctric rates approved by the City Council. California law recognizes that adverse situations beyond PWP’s control may arise and prevent PWP from fulfilling the RPS Procurement Targets in a timely manner and consistent with such limitations.

In the event PWP discovers that such conditions, as specified in the City of Pasadena’s RPS Enforcemen t Program, may potentially prevent PWP from meeting the RPS Procurement Targets set forth in the RPS Enforcement Program, PWP will notify the City Council of the adverse conditions and apply to the CEC for relief. If appropriate, PWP may submit a revised RPS Procurement Plan for discussion, approval, and implementa tion.

The CEC may reduce a procurement requirement to the extent PWP demonstrates that it cannot comply because of conditions beyond its control.170 However, the CEC may not, under any circumstance, reduce the procurement obligation of PCC 1 below 65%for any compliance period obligation after December 31, 2016. PWP expects to fully comply with the City of Pasadena’s and the State of California’s mandatory RPS requirements. PWP does not recommend taking advantage of this provision or other optional compliance measures detailed in the City of Pasadena’s RPS Enforcement Program at this time.

11. Version History
 Version 1: Initially adopted July 22, 2013
 New mandate to comply with SBX1 2
 Version 2: Amended June 1, 2015
 Include updates on contracts and other processes
 Version 3: Amended January 29, 2018
 Show compliance with SB 350
 Include updates on contracts and other processes
 Version 4: Amende
d December 10, 2018
 Show compliance with SB 100
 Include updates on contracts and other processes, as recommended by the 2018 IRP  Version 5: Amended December 5, 2023
 Show compliance with SB 100
170 PUC Section 399.15(5)

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 Inclu
de updates on contracts and other processes, as recommended by the 2023 IRP

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100 Garfield Avenue, Room N 106
Pasadena, California 91101
626.744.4005

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Renewable Portfolio
Standard
Enforcement Plan
Still Under Development and Review
Appendix 29

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Table of Contents

1. Purpose 283

2. RPS PROCUREMENT PLAN GUIDELINES 283

2.1. Compliance Periods ..................................................................................................................................................... 283

2.2. State RPS Procurement Targets .............................................................................................................................. 283

2.3. PCC Definition and Balance Requirements ......................................................................................................... 285

2.4. Long‐Term Contracts .................................................................................................................................................. 288

2.5. Additional Requirements .......................................................................................................................................... 288

2.6. City Council Discretion ............................................................................................................................................... 288

2.7. Review of the RPS Procurement Plan ................................................................................................................... 289

3. Public Notice for RPS Procurement Plan 289

4. Excess Procurement 289

5. Renewable Energy Procurement in Excess of Statutory P rocurement Targets 290

6. PRS Procurement Plan Limitations and Relief 291

7. Reporting 294

8. Enforcement 294

9. Version History 295

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Table of Figures
Figure 1: Compliance Targets .............................................................................................................................................. 284 Figure 2: Portfolio Content Categories ............................................................................................................................... 285

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28. Purpose
The purpose of this revised Renewable Portfolio Standard (RPS) Enforcement Program171 for the Pasadena Water and Power Department (PWP) is to comply with the California RPS pursuant to California Public Utilities Code (PUC) Section 399.30. Each calendar year, PWP will target California state mandated targets (e.g., 60% by 2030), with reasonable progress towards these goals in the intervening years. Pasadena also has its own carbon‐free policy goal, which is not subject to Stat
e compliance requirements.

29. Renewable Portfolio Standard Procurement Plan Guidelines PWP has developed a RPS Procurement Plan for the City Council to consider for adoption. Going forward, no later than January 1, 2024, PWP will incorporate the RPS Procurement Plan into its broader Integrated Resource Plan (IRP) developed and adopted pursuant to PUC Section 9621(b). The RPS Procurement Plan will at minimum include the elem ents described in the following sections.

29.1. Compliance Periods
Procurement targets in Section 2.2 reflect the minimum quantity of eligible renewable energy resources to be procured by PWP in each of the following RPS Compliance Periods (CP):
 CP 4: January 1, 2021, to December 31, 2024, inclusive  CP 5: January 1, 2025, to December 31, 2027, inclusive  CP 6: January 1, 2028, to Decemb er 31, 2030, inclusive  CPs three years in length beginning January 1 and ending December 31, beginning and after January 1, 2031

29.2. State RPS Procurement Targets172
PWP will procure a minimum quantity of electricity products from eligible renewable energy resources, including renewable energy certificates/credits (REC), as a specified percentage of total retail sales to achieve the targets outlined in Figure 1. In each of the intervening years, PWP must show reasonable progress towards the next goal.

The requirements shown in
171 Pursuant to California Public Utilities Code Section 399.30 as enacted by California Senate Bill (SB) X1‐2 in 2011 (“The California Renewable Energy Resources Act”) and subsequently revised by Assembly Bill (AB) 2227 in 2012, and in 2015 by SB 350 (“The Clean Energy and Pollution Reduction Act of 2015”), and as implemented through the Pre‐Rulemaking Amendments to the Enforcement Procedures for the Renewables Portfolio Standard for Local Publicly Owned Electric Utilities, California Energy Commission Amended Regulations Effective April 12, 2016, CEC‐ 300‐2016‐002‐CMF; the Pre‐Rulemaking Amendments to the Enforcement Procedures for the Renewables Portfolio Standard for Local Publicly Owned Electric Utility (Sections 3200 through 3208), and the California Energy Commission Draft Guidebook, Renewables Portfolio Standard Eligibility, Ninth Edition, July 2016, CEC‐300‐2016‐ 006‐ED9‐SD. 172 PUC Section 399.30(c)(2)

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Figure 1 re
ference the California PUC Section 399.30 and SB 100 requirements, not PWP’s goal of 100% carbon‐free by 2030.

Figure 1: Compliance Targets
CP Dates Minimum % of RPS
1 [complete] By December 31, 2013 Average of 20% retail sales by 2013 2 [complete] By December 31, 2016 25% of 2016 retail sales 3 [complete] By December 31, 2020 The sum of: 27% of 2017 retail sales, 29% of 2018 retail sales, 31% of 2019 retail sales, and 33% of 2020 retail sales 4 By December 31, 2024 44% of 2024 retail sales
5 By December 31, 2027 52% of 2027 retail sales
6 By December 31, 2030 60% of 2030 retail sales
7+ Post 2030
Not less than a 60% of retail sales, post 2030; the California Energy Commission (CEC) will establish appropriate multi‐year
compliance periods at a later time
For
the purpose of this RPS Enforcement Program, retail sales shall be defined as the total volume of energy sold, in Megawatt hours, to all retail end‐use customers taking service under Pasadena Municipal Code (PMC) Sections 13.04.040 to 13.04.090173, and 13.04.177 (Net Energy Metering), inclusive. Retail sales may exclude sales to customers taking service under the optional Green Power Option (PMC 13.04.179) or any shared renewable generation program. Sales to retail customers taking Direct Access Service under PMC 13.04.095, energy consumption by PWP, electricity used by PWP for water pumping, and electr icity produced for onsite consumption under PMC 13.04.178 (self‐generation) that was not sold to the customer by PWP shall not be included in this definition of retail sales.

For a customer participating in the Green Power Option or any shared renewable generation project, if the renewable energy is excluded from the calc ulation of retail sales, the Portfolio Content Category (PCC) 1 RECs associated with the electricity credited to such customer under the program will not be used by PWP for compliance with state mandated RPS procurement requirements. The RECs will be retired on behalf of the participating customer, and may not be further sold, transferred, or otherwise moneti
zed for any purpose. To the extent possible, the electricity products excluded from retail sales will be procured by PWP from eligible renewable energy resources that are located in the PWP service territory and in reasonable proximity to program participants174.
173 PMC Sections 13.04.040 – Residential single‐family service, 13.04.045 – Residential multi‐family service, 13.04.050 – Small commercial and industrial service, 13.04.060 – Medium commercial and industrial service – Secondary,13.04.064 – Medium Commercial and Industrial Service – Primary, 13.04.067 – Large commercial and industrial service – Secondary, 13.04.070 – Large commercial and industrial service – Primary,

13.04.071 – Special load management and conservation service, 13.04.075 – Long‐term contracts, 13.04.080 – Standby Service, 13.04.85 – Unmetered rates – Non‐demand, 13.04.087 – Unmetered rates – Demand, 13.04.090 Street lighting and traffic signal service. 174 PUC Section 399.30(c)(4)

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29.3. Portfolio Content Category Definition and Balance Requirements The categories of renewable resources outlined in
Figure 2 will be used to meet the statutory RPS procurement targets.175 Figure 2: Portfolio Content Categories
PCC PCC Description PCC % Balance Requirements
PCC 0: (“Grandfathered” or
“Count‐in‐Full” resources and
contracts):176
 PCC 0 refers to electricity products
procured pursuant to a contract or
ownership agreement executed
before June 1, 2010, and associated
with generation from an eligible
renewable energy resource that met
the CEC eligibility requirements in
effect when the original procurement
contract or ownership agreement
was executed will be classified as PCC

0.  PCC 0 products will count in full
toward state mandated RPS
procurement requirements177.
“Count‐in‐full” means that such
renewable electricity products
procured prior to June 1, 2010, will
be applied toward (deducted from)
the state RPS procurement target for
each compliance period prior to
determining the portfolio balance
requirement, subject to the
following:
 The associated REC must be
retired within 36 months of the
date the electricity product is
generated.
 The PCC 0 products will not
count toward the portfolio
balancing requirements
 No minimum or maximum
requirements; the PCC 0
amount is subtracted from the
RPS needs and any shortage
must comply with the PCC1,
PCC 2, or PCC 3 balance
requirements
 PCC 0 does not have portfolio
balancing requirements
175 PUC Sections 399.30(c)(3) and 399.16, and California Energy Commission Enforcement Procedures Section 3203 176 CPUC 399.16(d) and (e)
177 California Energy Commission Enforcement Procedures Section 3202

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PCC PCC Description PCC % Balance Requirements
 The PCC 0 electricity projects
associated with contracts of less
than 10 years will not be
subtracted when calculating
excess procurement (See
Section 4)
PCC 1
 PCC 1 are products procured as a
bundle with associated energy from
the eligible renewable resource.
 To be classified as PCC 1, eligible
renewable energy resource electricity
products must meet the requirement
of either of the following:
 Having a first point of
interconnection with a California
balancing authority (BA), having
a first point of interconnection
with distribution facilities used
to serve end users within a
California BA area, or scheduled
from the eligible renewable
energy resource into a California
BA without substituting
electricity from another source
other than to provide real‐time
ancillary services required to
maintain an hourly or sub‐hourly
import schedule into a California
BA. Only the fraction of the
schedule actually generated by
the eligible renewable energy
resource shall count toward this
PCC.178
 Having an agreement between
the BA in which the eligible
renewable energy resource is
 CP2: Minimum of 65%
 CP 3 and thereafter: Minimum
of 75%
178 A balancing authority is the entity responsible for integrating resource plans ahead of time, maintaining balance between loads, energy imports/exports, and generation within its balancing authority area, and supporting interconnection frequency in real‐time. California balancing authorities include: the California Independent System Operator (CAISO), the Los Angeles Department of Water & Power (LADWP), the Imperial Irrigation Distr
ict (IID), the Balancing Authority of Northern California (BANC), PacifiCorp West, Sierra Pacific Power (SPP), Turlock Irrigation District (TID) and the Western Area Lower Colorado Region (WALC). PWP is in the CAISO balancing authority area.

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PCC PCC Description PCC % Balance Requirements
located and a California BA to
dynamically transfer electricity
from the renewable energy
resource to the California BA.179
PCC 2
 PCC 2 refers to electricity products
that must be generated by an eligible
renewable energy resource and be
procured as a bundle (matched) with
incremental energy scheduled into a
California BA from a substitute
resource.180
 The first point of interconnection to
the transmission grid for the eligible
renewable energy resource and the
resource providing the incremental
electricity must be located within the
WECC181 service territory but outside
the metered boundaries of a
California BA area.
 The contract for the incremental
electricity must be executed at the
same time or after the contract for
the renewable electricity product.
 CP 3 and thereafter: Maximum
of 15%
PCC 3
 PCC 3 products may be procured
separately from the energy produced
by the renewable resource
(unbundled).
 Eligible renewable energy resource
electricity products or any fraction of
the electricity generated, including
unbundled RECs that do not qualify
under the criteria of PCC 1 or PCC 2,
fall within PCC 3.182
 CP 3 and thereafter: Maximum
of 10%
179 PUC section 399.16(b)(1)
180 PUC Section 399.16(b)(2)
181 Western Electricity Coordinating Council, the non‐profit regional electric reliability entity in the western interconnection, which includes 14 Western US states, 2 Canadian provinces, and Northern Baja Mexico. 182 PUC Section 399.16(b)(3)

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29.4. Long‐Term Contracts
PWP may enter into a combination of long‐term and short‐term contracts for electricity and associated RECs. Beginning January 1, 2021, at least 65% of the procurement PWP counts toward the California RPS requirement in each compliance period will be from contracts of 10 years or longer in duration, or PWP ownership or owne rship agreements, for eligible renewable energy resources. An electricity product classified as PCC 2 will count toward the long‐term procurement requirement of this subdivision if the electricity product is procured under a contract of at least 10 years in duration or an ownership agreement, even if the matching increm ental electricity is not associated with a contract of at least 10 years in duration or an ownership agreement.183

29.5. Additional Requirements
 RPS procurement requirement deficits incurred by PWP in any compliance period will not be added to the RPS procurement requirements of a future compliance period.  PWP must retire RECs to meet its RPS procurement requirements within 36 months from the initial month of the generation of the associated energy.
 In general, publicly‐
owned utilities (POU) may not use RECs for purposes of the California RPS for any given compliance period if that compliance period begins after the date of REC retirement; however, CEC Resolution No. 16‐0309‐04a (adopted by the CEC March 9, 2016) establishes a process to allow PWP to request that surplus RECs retired and reported to the CEC for a specified
RPS CP (surplus retired RECs) be withdrawn and used for the following RPS CP.
 PWP may not procure or retire a REC to meet its RPS procurement requirements for a compliance period that precedes the date of gener
ation of electricity associated with that REC, or the date the REC was procured by PWP.  For example, PWP may not procure or retire a REC generated in April 2021 to meet its state RPS procurement requirements for the 2017 to 2020 CP, nor retire a REC generated in November 2020 to meet its procurem
ent requirements for the 2017 to 2020 CP if PWP did not procure the REC until February 2021.

29.6. City Council Discretion
The City Council will have the discretion to approve, reject, or modify PWP’s recommendations with respect to the following:
 The mix of eligible renewable energy resources procured by PWP pursuant to the RPS Procurement Plan for meeting the greater of the City’s carbon‐free policy goal  Those additional generation resources procured by PWP for purposes of ensuring resource adequacy and reliability
183 PUC Section 399.13(b)

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 The reasonable
costs to be incurred by PWP for any eligible renewable energy resources that may be procured or owned by the utility

29.7. Review of the Renewable Portfolio Standard Procurement Plan PWP shall provide progress and assessments and/or updates of the approved RPS Procurement Plan for the City Council’s consideration when regulatory mandates modify the RPS requirements and/or significant changes occur to the RPS Procurement Plan as a result of RPS procurement. Going forward, updates to the RPS Procurement Plan will be brought to the City Council on an as needed basis. Th
e RPS Procurement Plan update is included as part of PWP’s 2023 IRP.

30. Public Notice for the Renewable Portfolio Standard Procurement Plan PWP will adhere to the following guidelines related to public notice associated with the RPS Procurement Plan184:
 Post public notice pursuant to the Ralph M. Brown Act185 when the City Council will deliberate in public on the RPS Procurement Plan
 Contemporaneously notify the CEC of the date, time, and location of the meeting and provide an electronic copy of the RPS Procurement Plan and other documents for posting on CEC’s website  This requirement will be satisfied if PWP provides the Uniform Resource Locator (URL) that links to this information
 Upon distribu
tion of information related to its renewable energy resources procurement status and future plans to the City Council for consideration at a noticed public meeting, PWP will make that information available to the public and provide the CEC with an ele ctronic copy of the documents for posting on the CEC's web site  This requirement will be satisfied if PWP provides the URL that links to the documents or information regarding other manners of access to the documents

31. Excess Procurement186
PWP may apply excess procurement in one CP to any future CP, including compliance years following 2020.187 However, there will be no carryover of deficits between compliance periods. Other provisions include:
 PCC 3 products may not be counted as excess procurement 184 PUC Sections 399.30(f)
185 Chapter 9 (commencing with Section 54950) of Part 1 of Division 2 of Title 5 of the Government Code 186 Pre‐Rulemaking Amendments to the Enforcement Procedures for the Renewables Portfolio Standard for Local Publicly Owned Electric Utilities, California Energy Commission Amended Regulations Effective April 12, 2016; CEC‐ 300‐2016‐002‐CMF; Section 3206 – Optional Compliance Measures, Subsection (a)(1) – Excess Procurement 187 Pre‐Rulemaking Amendments to the Enforcement Procedures for the Renewables Portfolio Standard for Local Publicly Owned Electric Utilities, California Energy Commission Amended Regulations Effective April 12, 2016; CEC‐ 300‐2016‐002‐CMF; Section 3206 – Optional Compliance Measures, Subsection (a)(1) – Excess Procurement

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 PCC
0 products that would otherwise be classified as PCC 3 and that exceed the 10% maximum limit for PCC 3 must be subtracted from the calculation of excess procurement  Prior to January 1, 2021, electricity products procured under contracts of less than 10 years in duration will be subtracted from the calc
ulation of excess procurement, unless grandfathered (PCC 0)  If procurement is under a contract that has been amended to extend the term, the duration of the amended contract will be calculated from the original contract execution date to the amended contract end date  If procurement is under a contract that has been amended to a total term of at least 10 years in duration, the electricity products generated as of the month and year in which the contract amendment occurs will be eligible to qualify as excess procurement
 The numerical express of the excess procurement permitted for the CP en ding December 31, 2021, and each annual CP thereafter is as follows:
 Excess Procurement = (EPX) – (RPSX+S2X+ S3X)
 EPX = Electricity products retired and applied toward the RPS procurement target for the compliance period X
 RPSX = The RPS procurement target calculated for compliance period X  S2X = Retired PCC 2 RECs that meet the criteria of Section 3202 (a)(1) or 3202 (a)(3) and that were not applied to the procurement target
 S3X = Retired PCC 3 RECs that meet the criteria of section 3202 (a)(1) in excess of the 10% maximum for compliance period X
 For PCC 1 products, contracts of any duration may count as excess procurement  PCC 2 or PCC 3 products shall not be counted as excess procurement  Contracts of any duration for
PCC 2 or PCC 3 products that are credited toward a CP shall not be deducted from a retail seller's procurement for purposes of calculating excess procurement

32. Renewable Energy Procurement in Excess of Statutory Procurement Targets If the City Council establishes RPS goals for PWP higher than the California Procurement Targets, or procures energy to serve PWP Green Power Option customers taking service under PMC 13.04.179 or a shared renewables program, the eligible renewable resources procured in excess of the statutory minimum shall be deemed voluntary and not subject to188 the following:
 Any mandatory enforcement provisions under California rules or regulations  Any restriction from carry over or banking provisions to subsequent CPs, such as sale, purchase, exchange, or any other use
188 As defined in PUC Section 399.30(c)

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 Any
requirements for or restrictions on portfolio content categorization189  Any
reporting or public notice required by the CEC

33. Renewable Portfolio Standard Enforcement Plan Limitations and Relief PWP will use its best efforts to procure adequate supplies of renewable energy as set forth in this RPS Enforcement Plan and the RPS Procurement Plan; however, PWP will always maintain system reliability and maintain average procurement costs for retail electric sales in accordance with the approved budget and retail electric rates approved by the City Council.

California law recognizes that adverse situations beyond PWP’s control may arise and prevent PWP from fulfilling the RPS
Procurement Targets in a timely manner and consistent with such limitations.

In the event PWP discovers that such conditions may potentially prevent it from meeting the RPS Procurement Targets set forth in this RPS Enforcement Plan, PWP
will notify the City Council of the adverse conditions and apply to the CEC for relief. If appropriate, PWP may submit a revised RPS Procurement Plan for discussion, approval, and implementation.

The CEC may reduce a procurement requirement to the extent PWP demonstrates that it can not comply because of conditions beyond its control.190 However, the CEC may not, under any circumstance, reduce the procurement obligation of PCC 1 below 65% for any compliance period obligation after December 31, 2016.

The below applies:
 Delay of timely compliance
 The City Council may make a finding that conditions exist that are beyond PWP’s control to delay the timely compliance with RPS procurement re
quirements as defined in Section 3204 of the CEC’s Enforcement Procedures, including achieving procurement targets and balancing requirements for each CP. Such a finding shall be limited to one or more of the following causes for delay and shall demonstrate that PWP would have met its RPS procurem ent requirements but for the cause of the delay:
 There is inadequate transmission capacity to allow sufficient electricity to be delivered from eligible renewable energy resources, or proposed eligible renewable energy resource projects, to the extent applicable, using CAISO’s current operational protocols. The City Council may find that:
 PWP has undertake
n all reasonable measures under its control and consistent with its obligation under local, state, and federal laws and regulations to develop and construct new transmission lines or upgrades to existing lines intended to transmit electricity generated by eligible renewable energy resources, considering its expectation for cost recovery.  PWP has tak
en all reasonable operational measures to maximize cost‐effective purchases of electricity from eligible renewable energy resources in advance of transmission availability. 189 PUC Section 399.30(c)(3)
190 PUC Section 399.15(5)

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 Permitti
ng, interconnection, or other circumstances have delayed procured eligible renewable energy resource projects, or there is an insufficient supply of eligible renewable energy resources available to PWP:
 The City Council must also find that PWP prudently managed portfolio risks, including, but not limited to, holding solicitations for RPS‐eligible resources with outreach to market participants and rely
ing on a sufficient number of viable projects to achieve RPS procurement requirements.
 PWP sought to develop either its own eligible renewable energy resources, transmission to interconnect to eligible renewable energy resources, or energy storage used to integrate eligible renewable energy resources.
 PWP procured an appropriate minimum margi
n of procurement above the level necessary to comply
with the RPS to compensate for foreseeable delays or insufficient supply.  PWP had taken reasonable measures to procure cost‐effective distributed generation and allowable unbundled RECs.
 Unanticipated curtailment of eligible renewable energy resources was necessary to address the needs of CAISO or other BA, if the delay of timely compliance would not result in an increase in
greenhouse gases (GHG) emissions.
 Unanticipated increase in retail sales due to electrification. For purposes of this paragraph, electrification refers to electrifying sectors that were either supplied by natural gas or other means.

This includes, but
is not limited to, whole house electrification (moving away from natural gas), heat pump electrification, transportation electrification (which includes, but is not limited to, the direct or indirect use of electricity to power vehicles, trains, ships and other vessels), etc. PWP will demonstrate consideration of the factors specified in the CEC Enforcement Procedures in
determining that this condition prevents timely compliance.  Cost limitations
 The City Council may adopt rules for cost limitations on the procurement expenditures used to comply with its RPS procurement requirements. Such cost limitation rules shall ensure that:
 The limitation is set at a le
vel that prevents disproportionate rate impacts.
 The costs of all procurement credited toward achieving the RPS are counted toward the limitation, but the limitation will not include PWP’s costs to procure eligible renewable energy resources for PWP’s voluntary green pricing or shared renewable generation programs.  In
adopting cost limitation rules, the City Council will rely on all of the following:
 The most recent renewables energy resources RPS Procurement Plan  Procurement expenditures that approximate the expected cost of building, owning, and operating eligible renewable resources
 The potential that some planned resource additions may be delay ed or canceled  When applying procurement expenditures under an adopted cost limitation rule, PWP will apply only those types of procurement expenditures that are permitted under the adopted cost limitation rule.  Adopted cost limitation rules will include planned actions to be taken in the event the projected cost of meeting the RPS procure
ment requirements exceeds the cost limitation.

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 Portfolio balance
requirement reduction
 The City Council will allow for the reduction by PWP of the portfolio balance requirement for PCC 1 for a specific compliance period.191
 The need to r
educe the portfolio balance requirements for PCC 1 must have resulted because of conditions beyond PWP’s control.192
 A
reduction of the portfolio balance requirement for PCC 1 below 65% for any compliance period after December 31, 2016, will not be considered.193
 If PWP
reduces its portfolio balance requirements for PCC 1, these changes must be adopted at a publicly noticed meeting, providing at least 10 calendar days advance notice to the CEC, and must include the appropriate information in an updated renewable energy resources RPS Procurement Plan submitted to the CEC. The notice to consider the portfolio balance requirem ent reduction and the RPS Procurement Plan must include the following information:
 The compliance period for which the reduction may be adopted  The level to which PWP has reduced the requirement
 The reason or reasons PWP has proposed for adopting the reduction  An explanation of how the needed reduction resulted
from conditions beyond PWP’s control194
 For
the period from January 1, 2021, to December 31, 2024, inclusive, PWP may adjust its renewable energy procurement targets to ensure the procurement of additional electricity from eligible renewable energy resources, in combination with the procurement of electricity from unavoidable long‐term contracts and ownership agreements, does not exceed the total retail sales of PWP during that CP. PWP may limit its procurement of eligible renewable energy resources for that CP to the greater of (i) the quantity that would allow PWP’s total procurement of electricity products from eligible renewable energy resources during the compliance period, when combined with its unavoidable long‐term procurem ent of coal‐fired generation during the CP, to not exceed PWP’s total retail sales during the compliance period, or (ii) 33% of its retail sales for the CP.  For purposes of this provision, unavoidable long‐term contracts and ownership agreements means commitments for electricity from a coal‐fired power plant, loca ted outside the state, originally entered into by PWP before June 1, 2010 (e.g., the Intermountain Power Project), that are not subsequently modified to result in an extension of the duration of the agreement or result in an increase in total quantities of energy delivered during any CP.
 PWP shall de
monstrate that any cancellation or divestment of the commitment would result in significant economic harm to its retail customers that cannot be substantially mitigated through resale, transfer to another entity, early closure of the facility, or other feasible measures.  Adjustments may be required if an approved RPS Procurement Plan is subseque ntly projected to adversely affect system reliability or resource adequacy.
191 Consistent with PUC section 399.16(e)
192 Specified in California Energy Commission Enforcement Procedures Section 3206(a)(2) 193 PUC section 399.16(e)
194 As provided in Section 3206(a)(2) of the California Energy Commission Enforcement Procedures

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34. Reporting
PWP will submit reports to the CEC as required.195
 PWP’s reporting of costs to procure electricity products to meet its RPS procurement requirements will not include the costs to procure eligible renewable energy resources for PWP’s Green Power Option or shared renewable generation program.
 PWP’s costs for its Green Power Option or shared renewable generation program will be reported separately from its costs to procure
electricity products to meet PWP’s RPS procurement requirements.  In addition to the applicable reporting requirements in the CEC Enforcement Procedures, if PWP excludes the eligible renewable energy resources procured for PWP’s Green Power Option or shared renewable generation program from its annual retail sales, PWP will report the following information:
 The total nu
mber of MWh of electricity products from eligible renewable energy resources procured for the year that were credited to participating customers pursuant to PWP’s Green Power Option or shared renewable generation program
 Documentation demonstrating that the RECs associated with the electric ity products were retired in WREGIS on behalf of the participating customer196
 The total
number of MWh of electricity products procured that PWP excludes from its annual retail sales  Documentation showing that the RECs excluded from PWP’s annual retail sales meet the criteria for PCC 1  A description of PWP’s efforts to ensure the electricity products were procured from eligible renewable energy resources
located in PWP’s service territory or in reasonable proximity to program participants

35. Enforcement
The City Council directs the City Manager to inform the City Council at a public meeting if PWP will not meet the renewable energy procurement requirements as set forth in this RPS Enforcement Program and the RPS Procurement Plan. The PWP General Manager will notify the CEC of such non‐compliance in the manner and schedule established by th e CEC pursuant to regulations developed by the CEC.197
195 Section 3207 of the California Energy Commission Enforcement Procedures 196 WREGIS is the Western Renewable Energy Generation Information System, an independent, renewable energy tracking system for the region covered by the Western Electricity Coordinating Council (WECC). WREGIS tracks renewable energy generation from units that register in the system by using verifiable data and creating renewable energy certificates (REC) for this generation. 197 PUC Section 399.30

DRAFT
Pasadena Water and Power
Renewable Portfolio Standard Procurement Plan
295 of 297
The CEC has adopted
regulations specifying procedures for enforcement of this article. The regulations include a public process under which the CEC may issue a notice of violation and correction against PWP or any other local POU for failure to comply, and for referral of violations to the California State Air Resources Board for penaltie s.

Any complaint against PWP pertaining to the enforcement of an RPS requirement, or any regulation, order, or decision adopted by the CEC pertaining to the RPS, shall be filed in accordance with Title 20, Section 1240 of the California Code of Regulations.

A complaint may be issued for PWP’s failure to comply with any of the requireme nts in the applicable regulations, including, but not limited to, the following:
 Failure to meet an RPS procurement target for reasons other than PWP’s adopted cost limitations and/or delay of timely compliance rules, which the CEC determines comport with the RPS requirements specified198  Failure
to meet a PCC 1 portfolio balance requirement199 for reasons other than PWP’s adopted cost limitations and/or delay of timely compliance rules, which the CEC determines comport with the RPS requirements as specified200
 Failure to adop
t an RPS Procurement Plan, RPS Enforcement Program or Plan, or provide notice, disclosure, or other information to the CEC and public as specified201  Failure
to submit a complete annual, compliance, or other report, or other documentation or information as specified202
 Beginnin
g January 1, 2021, failure to meet the long‐term contracting requirement as specified203

36. Version History
 Version 1: Initially adopted December 12, 2011
 New mandate to comply with SBX1 2
 Version 2: Amended July 22, 2013
 Include updates on contracts and other processes
 Version 3: Amended January 29, 2018
 Show compliance with SB 350
 Include updates on contracts and other processes
198 Subdivisions (a)(2) and (3) of section 3206 of the California Energy Commission Enforcement Procedures 199 Subdivision (c) of Section 3204 of the California Energy Commission Enforcement Procedures 200 Subdivisions (a)(2) and (3) of Section 3206 of the California Energy Commission Enforcement Procedures 201 Section 3205 of the California Energy Commission Enforcement Procedures 202 Section 3207 of the California Energy Commission Enforcement Procedures 203 Section 3208 of the California Energy Commission Enforcement Procedures

DRAFT
Pasadena Water and Power
Renewable Portfolio Standard Procurement Plan
296 of 297
 Version 4: Am
ended December 10, 2018
 Show compliance with SB 100
 Include updates on contracts and other processes, as recommended by the PWP 2018 Power IRP  Version 5: Amended December 5, 2023
 Include updates on contracts and other processes, as recommended by the PWP 2023 Power IRP

100 Garfield Avenue, Room N 106
Pasadena, California 91101
626.744.4005
324
Supplementa�on Informa�on
2023 Power IRP Addendum
1 Addendum – Supplemental Information
Introduc�on .............................................................................................................................................. 2

1. Addi�on of 2026 Waypoint – Goodrich Transfer Sta�on Updates .................................................... 2

2. 2024 Cost of Service and Rate Design Study ..................................................................................... 5

3. Distributed Energy Resources (DERs) and Demand Response (DR) – Project Plan Considera�ons .. 7

4. Dashboard ......................................................................................................................................... 8 Summary ................................................................................................................................................... 9

Supplementa�on Informa�on
2023 Power IRP Addendum
2 Introduction
This Addendum sa�sﬁes the follow-up documenta�on and commentary requirements directed by the Municipal Services Commitee (MSC) during its November 14, 2023 mee�ng delibera�ons. Staﬀ were directed to return with the following supplemental informa�on for further discussion and considera�on:

1. Create an incremental 2026 Waypoint, allowing for future evalua�on and technical analysis of the planned Goodrich Receiving Sta�on upgrades and the required key system modiﬁca�ons as described in the Power Delivery Master Plan (PDMP).

2. Provide incremental �meline and detail associated with the planned 2024 PWP’s Electric Cost of Service and Rate Design study.

3. Provide incremental DER and DR informa�on and concepts. The Implementa�on Plan paterned a�er Carbon Free Scenario 2 modeling results, iden�ﬁes DER and DR resource types.

4. MSC directed staﬀ to provide commentary of dashboard concepts that could be used to assist in the future monitoring and communica�on.

1. Addi�on of 2026 Waypoint – Goodrich Transfer Sta�on Updates Consisten
t with MSC’s direc�ve, a 2026 Waypoint has been added that will provide a speciﬁc and pointed opportunity to review the Goodrich Transfer Sta�on required upgrades. Per protocol, the PDMP , which is updated every ﬁve years, is a comprehensive 100+ page document that addresses the capital infrastructure, capital investment, and capital replacement planning for the Distribu�on and Sub- transmission system. The PDMP also includes signiﬁcant detail speciﬁc to the Goodrich Receiving Sta�on.

From a technical perspec�ve, the size, capability, design considera�on and megavolt-amperes (MVA) metrics of the power transformers at Goodrich may be of heightened interest, but the overall capabili�es of the Distribu�on and Sub-transmission system capabili�es must be jointly and comprehensively considered.

Supplementa�on Informa�on
2023 Power IRP Addendum
3 The goals of the PDMP are comprehensive and require infrastructure investment not only to the Goodrich power transformers, but also to the balance of the distribu�on and sub-transmission networks, which must electrically accommodate the incremental power ﬂows. Engineering review is needed to assure both con�nued system reliability and ensure electrical protec�on and preserva�on of cri�cal system infrastructure.

The ﬁve primary goals which are inherent to the Goodrich Transfer Upgrade and the PDWP are as follows:

1. Reliability and Safety

2. Resiliency

3. Power Quality

4. Grid Moderniza�on

5. Grid Edge (Technology that is customer facing, installed at the “edge” of the grid) The 2026 Wa
ypoint will be uniquely u�lized to provide updated technical reviews and evalua�ons of the Goodrich Transfer Upgrade, with key considera�ons that are topical in the present day, and account for developments since the 2022 P D M P.

PWP is a Tra
nsmission-Constrained Electric System
Goodrich plays a key role in suppor�ng reliability in this constrained system. It operates constantly and is the sole interconnec�on point to the larger CAISO markets. In the review of Goodrich’s transfer capabili�es, the following key considera�ons are paramount:

Supplementa�on Informa�on
2023 Power IRP Addendum
4 • I mp
roving import capacity up to the 336 MW contractual transmission limit. PWP’s ability to use this addi�onal capacity depends on installing larger transformers at the loca�on as well as incremental changes to the 34.5-kv distribu�on system including upgrading other substa�ons. • Readying, reviewing, and engineering poten�al power delivery system modiﬁca�ons to accommodate future installa�ons of batery storage capabili�es. Engineering studies and associated system impact reviews are required for any signiﬁcant resource implementa�on, and the addi�on of batery storage capaci�es is no excep�on.

The PDMP is updated every ﬁve years and is driven b y the latest IRP . The current plan, which was adopted by the City Council in 2022 and includes the requirements of the 2018 IRP , took 2.5 years to develop and is the culmina�on of 22 studies on various topics. Accordingly, the next update is planned for 2026 and will require signiﬁcant modeling and es�ma�ng to iden�fy the projects, sequencing, capital investment, and resources needed to support the 2023 IRP and its 2030 goals.

Cost Considera�ons – PDMP
Since the adop�on of the 2022 PDMP, the price and availability of infrastructure has been dynamically driven, both by pandemic-related events and the scarcity in key metals that are essen�al to the u�lity industry.

The ini�al es�mate for the overall PDMP was $821 million, to be distributed over a number of years to lessen rate impacts. This refreshed cost review will consider impacts from expedited scheduling, new resource costs, and the inﬂa�onary environment. These characteris�cs will be addressed within the 2026 Waypoint evalua�on.

Supply Chain – Custom Manufacturing
The power transformers at Goodrich will require custom manufacturing. Considering the current transformer backlog that the industry is experiencing, this requirement will be reviewed to assure appropriate ac�ons are taken to include expedi�ng, where might be required, in order to meet carbon- free policy goal requirements. This key logis�cal element will also be speciﬁcally evaluated at the 2026 Waypoint.

Construc�on Schedule: Opportuni�es to Expedite or Defer Projects The actual infrastructure upgrades of the Distribu�on and Sub-transmission system must be carefully coordinated as por�ons of the exis�ng system will likely be out of service for signiﬁcant periods of �me while new infrastructure is being constructed.

The 2026 Waypoint will be an opportunity to refresh construc�on schedule assump�ons, project planning considera�ons, and con�ngency analysis. Moreover, there are coordina�on and approvals required from the CAISO and/or other regulatory en��es, as removing key transmission infrastructure such as Goodrich Receiving Sta�on components may have impact on the surrounding bulk electric system.

Summary
The coordina�on associated with Goodrich Receiving Sta�on will be refreshed in 2026, as part of prudent prepara�ons suppor�ng the 2030 carbon-free policy goal. The dynamic considera�ons noted in

Supplementa�on Informa�on
2023 Power IRP Addendum
5 this document as well as others, will be part of the 2026 Waypoint analysis speciﬁc to the Goodrich Receiving Sta�on Upgrades.

2. 2024 Cost of Service and Rate Design Study
U�lity Cost of Service and Rate Design (COS) studies are long-established founda�onal tools for evalua�ng, reviewing, and establishing u�lity rates. PWP is planning a COS in 2024 which will include a comprehensive review of PWP’s power system costs, alloca�ons, and budgetary categories. The COS will also examine customer usage behaviors, by customer type, to provide a beter understanding of how each would be impacted by various rate structures, while also beter documen�ng how each customer class u�lizes and relies upon the PWP system.

The ﬁndings of the analysis and proposed rate designs will provide the basis for electric rates for a 10- year period and produce a rate model that can be adjusted for changes in energy policy requirements. The model will also help iden�fy rates to support new technologies such as Time of Use (TOU) rates, Net Energy Metering (NEM), Customer Self-Genera�on, Metered EV rates, and low-income assistance programs.

In order to recover and allocate system costs eﬀec�vely, several key factors will be considered in the COS modeling including AMI program implementa�on, DER and DR expansion, U�lity-Side Energy Storage, elimina�on of carbon-based energy supply, stranded investments, expansion of assistance programs, development and implementa�on of the IRP and PDMP , and regulatory compliance requirements.

A Request for Proposals (RFP) for the COS study is planned for early December 2023. As PWP engages further with respondents leading to eventual selec�on, a formal project �meline will be produced.

However, many COS �melines may involve an 18-month execu�on window leading to eventual rate approvals.

Supplementa�on Informa�on
2023 Power IRP Addendum
6 The customer impacts driven by aggressive decarboniza�on of the PWP resource por�olio will be analyzed as part of the COS ini�a�ve. PWP’s goal is to develop and review a series of electric rate designs that are based on cost-of-service principles.

The intent of the COS evalua�on is:

1. To perform a comprehensive review of PWP’s power system costs, alloca�ons, and budgetary categories;

2. To assess customer characteris�cs and customer classiﬁca�ons;

3. To design various rate structures, and to evaluate their impacts on customers; and

4. To develop a ﬂexible, non-proprietary working rate model that will be conveyed to the City of Pasadena.

The working model will be able to accommodate adjustments to factors such as integra�on of renewable energy sources; rising opera�ng, maintenance, and capital needs; stranded investments; normal to extreme weather paterns; overall sales; and customer demands.

Each rate structure op�on will adequately balance PWP’s short- and long-term ﬁnancial sustainability.

The proposed rate structure must meet the electric u�lity’s ongoing opera�ng expenditures, bond covenants, capital improvement needs, and fund reserve requirements. It must also follow accepted industry standards, best prac�ces, and California law. The recommended rate design will align policy goals with pricing strategies to encourage customer behavior that beneﬁts Pasadena’s u�lity system and public policy considera�ons.

The ﬁndings of the analysis and the proposed rate designs will provide the basis for electric rates for a ten-year period and will be conﬁgurable to accommodate evolving energy policy requirements. In developing and upda�ng electric rates, PWP and its consultant will consider the following:
• Time of Use (TOU) rates
• Net Energy Metering (NEM) — with and without Advanced Metering Infrastructure or Time of Use metering
• Customer Self-Genera�on (Non-NEM)
• Metered Rate for Electric Vehicles (EVs) — Residen�al and Public • Recovery Adjustments for new Renewable Energy and Power Purchase Agreements (PPAs) • A Standby Charge for the recovery of ﬁxed costs necessary to make electricity service available to a distributed genera�on facility
• Low-Income Assistance Programs
The following are some of the key factors that PWP and the consultant will incorporate into their rate recommenda�ons:
• Advanced Metering Infrastructure (AMI) program implementa�on and data • Distributed Solar Energy and Storage Resources, and Demand Response • U�lity-Side Energy Storage

Supplementa�on Informa�on
2023 Power IRP Addendum
7 • Value of Good Load Factor (Load Shi�ing Programs)
• Commercial and ins�tu�onal customers achieving energy independence • Stranded investments
• Nonrenewal of carbon-based energy supply contracts
• Expansion of assistance programs, including the Electric U�lity Assistance Program (EUAP) • Power Integrated Resource Plan (IRP)
• Power Delivery Master Plan (PDMP)
• Compliance with applicable California regula�ons such as Proposi�on 26 • Other issues, as appropriate
PWP staﬀ and the consultant will present the ﬁndings of the analysis and proposed rate design to City Council Commitee(s) and the Pasadena City Council for review and approval.

PWP is planning to publish an RFP for this analysis in early December 2023, with proposal evalua�ons slated for the end of January 2024. The dura�on of the project will be approximately 18 months, with quarterly informa�onal items to Council Commitee(s) as well as a Public Par�cipa�on Plan to be developed.

PWP will con�nue to work with government en��es, nonproﬁt organiza�ons, other industry group, and stakeholders to iden�fy areas of support for its goals.

3. Distributed Energy Resources (DERs) and Demand Response (DR) – Project Plan Considera�ons
The i
ncreased penetra�on of variable resources to the electric grid has introduced a greater need for dynamic responsiveness, which in-part can be resolved with the addi�on of DER and DR resources. The modeling results call for a signiﬁcant number of distributed resources to be installed in the PWP service territory.

Resource types of DR and DER’s can vary, to include adjustable smart thermostats for air condi�oning (A/C) and hea�ng, u�lity triggered water hea�ng deferrals, u�lity/commercial/residen�al partnership in limited dura�on load curtailment and managed electric vehicle (EV) charging/discharging as poten�al DR considera�ons, in addi�on to the poten�al levels of commercial/industrial and residen�al DER levels of solar, wind and storage.

PWP will engage in proac�ve approaches such as conduc�ng a detailed distributed resources Market Poten�al Study. This will include both energy eﬃciency and distributed resources. This type of study will help PWP evaluate the incremental capabili�es of demand-side resources on the system, as well as use the results to design cost-eﬀec�ve programs.

PWP will also perform a Hos�ng Analysis, which will help PWP iden�fy the best ﬁt loca�ons of distributed resources with the least impact on the system, as well as iden�fy poten�al distribu�on system improvements that could enhance the amount of distributed resources in its service territory.

In addi�on to the exis�ng Load Curtailment Program, PWP will consider addi�onal approaches for enhancing demand response. For example, when PWP implements advanced metering infrastructure,

Supplementa�on Informa�on
2023 Power IRP Addendum
8 there will be opportuni�es to explore automated demand response for residen�al and commercial customers. In addi�on, the CEC con�nues to expand its demand response program oﬀerings including the Demand Side Grid Support (DSGS) Program as well as the Distributed Electricity Backup Assets (DEBA) Program. DEBA incen�vizes the construc�on of cleaner and more eﬃcient distributed energy assets that would serve as on-call emergency supply and/or load reduc�on for the State’s electrical grid during extreme events.

In addi�on to these ac�on items, PWP will con�nue to evaluate demand-side resources as part of a broader strategy, and further ac�ons will include:

1. Con�nued review and coordina�on of State of California, CAISO, and/or CEC oﬀerings of DER programs that meet the beneﬁt criteria.

2. Con�nued review of exis�ng PWP programs that currently support thermostat control, or other similar devices such as PWP’s Water and Energy Direct Install Program (WeDIP) and its demonstrated Energy Eﬃciency and Demand Response contribu�ons.

3. Review and considera�on of ﬁscal incen�ves that align with principles of equity and cost causa�on as deﬁned in federal, state, and local jurisdic�onal guidance.

4. Review of Public Beneﬁts program.

PWP will leverage its experience in these broad areas to further DR and DER programs, while consulting with industry experts, CEC, and other regulatory bodies and engaging in broad utility industry collaborations.

4. Dashboard
PWP plans
to create future web-based dashboards that will serve to provide status updates similar to other past and present initiatives within the City of Pasadena.

While the exac
t formats of the dashboard(s) are not yet determined, the general components can be generally summarized from the vast amounts of information already presented as part of the 2023 IRP.

Examples
of potential Dashboard topics could include:
• Status upda
tes of executed, but not yet commercial projects
• Commercial Operation Date (COD) projections as well as status of key milestones such as environmental reviews of renewable projects in which PWP may have a commercial interest • CAISO updates on policies that are anticipated to change over time, and which may have material impact upon resource planning activities.
• CAISO transmission projects which may have material impacts upon projects that PWP may have commercial interest
• Rate and/or cost impacts, as they occur dynamically
• PWP reliability statistics
• RPS compliance
• Greenhouse gas emissions reduction performance

Supplementa�on Informa�on
2023 Power IRP Addendum
9 In iti
al considerations could include some of the above topics. The dashboard will be updated and dynamically augmented over time.

Annually
, and with each approval process for a new energy contract or program, PWP will report progress rela�ve to the IRP progress and status. These updates will be made to the MSC and/or as designated by U�lity governance authori�es.

Summary
All IRPs and associated planning documents rely upon informa�on known at the �me or available during the planning horizon, such as energy market condi�ons, an�cipated forward pricing of energy resources, and regulatory and policy requirements of state, local and federal governance.

The electric u�lity industry must also an�cipate, in IRPs, that innova�on in a variety of technologies is also likely -- innova�ons such as storage technology or other carbon-free resources that could present addi�onal opportuni�es for further and faster decarboniza�on across the industry and the bulk electric grid.

During the MSC meeting of October 10, 2023, staff presented the challenges of the condensed timeline, and the requirement to procure a significant amount of resources of all types needed to achieve the policy goal of 100% carbon-free by 2030. This time compression, applied to the resource procurement requirements, was further discussed during the MSC meeting of November 14, 2023, which included focus on procurement of DER and DR resources as modeled in the carbon-free Scenario 2 results.

In addit
ion, during the October 10, 2023 discussion, staff affirmed that energy resources are procured well in advance of when they are needed online. Actual practice affirms that most resource types are procured or contracted years ahead of project COD. PWP has been aggressively proactive in the procurement of resources years in advance of actual COD or energy delivery dates and has already executed contracts for the following:
• Sapphire So
lar and Battery Storage
• Coso Geothermal
• Calpine Geothermal
• RFP for Battery Storage
In the aggregate, over recent years, PWP has proactively added greater than $500 million of renewable procurement, all of which strategically folds and fits into 2023 IRP considerations.

PWP shall
con�nue its external market solicita�ons by engaging with developers for renewable projects that are strategically deliverable to PWP’s region of the CAISO. Compe��on for renewable resources is an�cipated to be more challenging, as increased statewide compliance requirements are enacted by regulatory governance, with progressively increasing renewable and zero carbon compliance requirements:

Supplementa�on Informa�on
2023 Power IRP Addendum
10 • 4 4% r
enewable by 2024
• 60% renewable by 2030
• 100% renewable and zero carbon by 2045
PWP will monito
r poten�al impacts of CAISO policy con�nually, as these are cri�cal enablers to the CEC’s Scoping Plan and to achieving statewide carbon-free goals. These considera�ons include:
• Poten�al changes to Resource Adequacy constructs designed to enhance grid stability and resiliency • The transmission interconnec�on queue, and transmission projects suppor�ng statewide grid buildout, as detailed in the CEC Scoping Plan
• Con�nual monitoring of project deliverability as determined by CAISO transmission analysis Considering t
oday’s extremely compe��ve resource procurement environment, PWP must manage the price vola�lity of resource contracts that are impacted by supply chain and inﬂa�onary challenges, and other raw material impacts. Selec�ng renewable and zero carbon resources that are priced prudently and aligned with best ﬁt, and least cost values while managing risk to retail customers, remains a top priority.

The 2023 IRP process provides con�nuity and informs the future 2028 IRP processes. With the addi�on of both the 2026 and 2028 Waypoints, cri�cal elements such as new and emerging technologies are veted, reviewed and considered, while also providing infrastructure considera�ons for Goodrich Transfer Sta�on and the next PDMP . The synergies that have been strategically embedded in this plan preserve the 2030 Carbon Free policy goal without any opportunity cost from a planning perspec�ve.

As with all IRP’s, the 2023 plan represents a “snapshot in �me” that considers currently available commercial technologies. New innova�on in storage technology or other carbon-free resources could provide addi�onal opportuni�es for further, faster, and more eﬃcient decarboniza�on. PWP will closely monitor and evaluate new technology oﬀerings as a focused eﬀort, and also iden�fy poten�al grants and other funding mechanisms for accelerated deployment.

Pasadena City CouncilDecember 11, 2023

Pasadena City Council
December 11, 2023