ATTACHMENT A
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Agenda Report
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June 17, 2024
TO: Honorable Mayor and City Council
THROUGH: Municipal Services Committee (June 11,2024)
FROM: Water and Power Department
SUBJECT: AUTHORIZE THE CITY MANAGER TO ENTER INTO AN ENERGY
STORAGE CONTRACT WITH GLENARM BESS, LLC A SPECIAL
PURPOSE ENTITY CREATED BY EPC ENERGY INC. FOR BATTERY
ENERGY STORAGE FOR AN AMOUNT NOT TO EXCEED $55,310,000
FOR THE WATER AND POWER DEPARTMENT
RECOMMENDATION:
It is recommended that the City Council:
1. Find that the recommended actions do not constitute a "project" subject to the California Environmental Quality Act (CEQA) pursuant to Section 21065 of CEQA and Sections 15004(b)(4) and 15378 of the State CEQA Guidelines and, as such,no environmental document pursuant to CEQA is required;
2. Authorize the City Manager to enter into a contract, as the result of a competitive selection process, as specified by Section 4.08.047 of the Pasadena Municipal Code, with Glenarm BESS, LLC a Special Purpose Entity created by EPC Energy Inc. ("EPCE") for the design and future purchase of 25 megawatts ("MW") of dispatchabte storage capacity for up to four hours at a time, from the Gtenarm Battery Energy Storage System ("Glenarm BESS"), for a service rate of $12.18/kW-month over a 15-year delivery term estimated to begin January 1, 2027, and with a total contract price not to exceed $55,310,000 which includes the base contract amount of $54,810,000 over the 15-year contract term and a $500,000 contingency amount for any necessary change orders. Competitive price bidding is not required pursuant to City Charter Section 1002(F) for contracts for professional or unique services; and
3. Authorize the City Manager to enter into a License Agreement with Glenarm BESS, LLC for its use of the land on which the Glenarm BESS will be installed; the term of the License Agreement would coincide with that of the abovementioned contract.
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MEETING OF.06/17/2024AGENDA ITEM NO..12
Glenarm Battery Energy Storage
June 17, 2024
MUNICIPAL SERVICES COMMITTEE RECOMMENDATION:
On June 11, 2024, with one member absent, the Municipal Services Committee ("MSC") unanimously approved the staff recommendation to the City Council.
EXECUTIVE SUMMARY:
City of Pasadena ("City") Resolution 9977, which was adopted by the City Council on January 30, 2023, sets a goal to source 100% of Pasadena's electricity from carbon-free sources by the end of 2030. This ambitious target, which has been incorporated into Pasadena Water and Power's ("PWP's") recently adopted 2023 Integrated Resource Plan ("IRP"), calls for a complete shift to zero-carbon resources 15 years before the 2045 target year established by Senate Bill ("SB") 100. Pasadena's goal greatly exceeds the requirements of California's Renewables Portfolio Standard ("RPS") program, both in resource qualifications and in timeline. PWP has consistently exceeded State RPS compliance targets, focusing on resources that support ratepayer affordability while meeting Pasadena's unique energy needs.
As the 2030 target quickly approaches, PWP is diversifying its power resource portfolio by planning to add a Battery Energy Storage System ("Glenarm BESS") at the Glenarm Power Plant. The proposed 25 MW, 4-hour BESS, which would connect to the nearby GIenarm Receiving Station, would be designed, constructed, owned, and operated by Glenarm BESS, LLC on behalf of the City. Under an Energy Storage Agreement ("ESA"), Glenarm BESS, LLC would charge the City $12.18/kW-month for energy storage as a service, which amounts to $54,810,000 over the 15-year contractual life of the facility. The ESA would also allow the City to purchase the facility for an estimated $47,131,181 at the time it enters service (approximately January 1, 2027), or for reduced purchase prices at numerous points thereafter. PWP would separately seek City Council approval before exercising any such option, in accordance with City purchasing policy.
The recommended contract and License Agreement with Glenarm BESS LLC are conditioned on compliance with the California Environmental Quality Act ("CEQA"). The contract and License Agreement do not grant any vested development entitlements prior to CEQA compliance; do not bind any party, or commit to any definite course of action, prior to CEQA compliance; do not restrict the lead agency (City) from considering any feasible mitigation measures and alternatives, including the "no project" alternative; and do not restrict the lead agency from denying the project.
BACKGROUND:
In December 2018, the Pasadena City Council approved and adopted the 2018 IRP, which includes a commitment to remove carbon-emitting resources from PWP's energy resource portfolio. A key component of the 2018 IRP is the termination of PWP's 108 MW interest in the Intermountain Power Project ("IPP") effective June 2027. In addition, renewable energy resource contracts representing at least 40 MW are set to expire by the end of 2030 and must be replaced.
Glenarm Battery Energy Storage
June 17, 2024
The 2023 IRP, which was approved and adopted by the City Council in December 2023, expands on the goals of the 2018 IRP and outlines multiple pathways to reach the Resolution 9977 goal to source 100% of Pasadena's electricity from carbon-free sources by the end of 2030. Pasadena's target is considerably more ambitious than the 2045 zero-carbon goal mandated by SB 100 and associated RPS compliance requirements and will take accelerated planning and procurement, in a highly competitive energy resource market, to achieve.
To meet overall procurement and duration requirements, and to replace the capacity represented by the 2027 IPP termination and the other expiring renewable energy contracts, PWP plans to procure a mix of both long- and short-term zero-carbon energy products that support reliability, meet current and future State and local compliance requirements, and limit potential exposure to long-term stranded investments. These products, some of which may come from contracts currently under negotiation, would address a significant portion of the compliance and target-related needs, but would make only small contributions to PWP's still-growing operational reliability needs. This concern is addressed in the 2023 IRP, which calls for special emphasis on power system resources (including energy storage) to be located electrically within the city limits.
The Glenarm BESS Project
The construction of the Glenarm BESS would be accomplished through a separate construction contract awarded by the City using the design supplied by Glenarm BESS, LLC. PWP would be responsible for the construction of the necessary infrastructure from the project site to the Glenarm Receiving Station. The City would enter into a separate License Agreement for Glenarm BESS, LLC to use the underlying land (about
0.7 acres) for this project, and the system would be dispatched by PWP through operating orders.
The BESS interconnection point is electrically downstream from the PWP/Southern California Edison interconnection at the T. M. Goodrich Receiving Station ("TMG"), and the facility would be operating from PWP's 34.5 kV subtransmission system. The operation of the Glenarm BESS would shift PWP's electrical load as seen from TMG, but there are no impacts to TMG outside the bounds of PWP's current interconnection agreement limits with Southern California Edison. The California Independent System Operator ("CAISO"), which is stilt checking this proposed project for impacts on the transmission grid, has, so far, not identified any binding constraints on the deliverability of power from the BESS to the grid.
Operation of the BESS would be limited to PWP and Glenarm BESS, LLC, but Glenarm BESS, LLC would not be allowed to operate the BESS for its own account. The City will have the right to purchase the facility outright at various points during the project's 1 5- year delivery period. However, if this option is not exercised by the end of the 15-year agreement, Glenarm BESS, LLC would be required to remove the BESS from the Glenarm site and bear all of the associated removal costs.
Glenarm Battery Energy Storage
June 17, 2024
Projected RA Impact of the Glenarm BESS on the PWP Resource Adequacy Portfolio
The Glenarm BESS Project would provide considerable Resource Adequacy ("RA") benefits to help PWP meet CAISO's capacity requirements. Figure 1 depicts PWP's RA resources and additional requirements for each calendar year through 2035.
Figure 1: Pasadena's Projected RA Procurement Need by Calendar Year Forecasted Resource Adequacy Position
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Forecasted RA Requirement
This RA helps PWP in two ways. First, it directly replaces some of the RA that PWP will lose through the expiration and/or termination of existing major resource contracts, including IPP. Second, it supplies RA without emitting carbon dioxide - an important feature, considering that other components of PWP's power resource portfolio (primarily solar and wind) contribute very little RA relative to their installed sizes in MW. As renewable and carbon-free resources play an ever-increasing role in PWP's resource portfolio, PWP will need more RA-rich resources (such as battery storage) to provide this essential reliability component.
Other Projected Benefits of the Glenarm BESS
Locating a BESS electrically inside Pasadena's city limits provides powerful operating flexibility. As PWP develops the capability to harness the community's Distributed Energy Resources ("DERs"), as outlined in the 2023 IRP, the Glenarm BESS could be used to absorb surplus output from these systems for redelivery to PWP customers later as a carbon-free energy supply. PWP could re-sell some of the stored energy, energy storage service, and ancillary services (such as upward and downward regulation) to CA1SO to augment PWP's wholesale revenue stream and thereby reduce the fiscal burden on PWP's retail customers. The Glenarm BESS could also serve as a source for "black start" energy to assist in PWP's recovery of service in case of a system-wide blackout. With such multi-role capability, the Glenarm BESS wilt provide strategic value to PWP and its customers.
Glenarm Battery Energy Storage
June 17, 2024
Glenarm BESS Selection Process
On July 6, 2023, PWP issued a Request for Proposals ("RFP") through the OpenGov Procurement portal for the design and supply of the major equipment of a BESS to be installed and operated at PWP's Glenarm Power Plant site. The RFP required that the successful Respondent own and operate the BESS on City property, as directed by PWP, in exchange for a service rate (in $/kW-month), which would be paid by the City for use of the BESS. The RFP also required a fixed-price buyout option that allows the City to purchase the BESS at various points throughout the 15-year agreement.
OpenGov sent notices to 3,598 recipients. A total of 96 vendors downloaded the RFP documents from the procurement portal.
A total of four responsive proposals were received by the RFP closing date of October 18, 2023, none of which were local businesses (see below). PWP Staff from the Power Supply and Power Delivery Divisions evaluated the four responsive proposals, focusing on the proposed solution, project viability/technical strength, and project management.
In addition to PWP's internal evaluation process, PWP engaged Ascend Analytics, a well-known utility-related consulting firm, to assess the overall economic value of each proposal with regard to both the service rate and the buyout price. The combined evaluation found that the proposal from EPC Energy Inc. met the requirements of the RFP at the most competitive price.
A summary of the scoring is shown below in Table 1. The combined evaluation found that the proposal from EPCE met the requirements of the RFP at the most competitive price. Detailed scoring is included in Attachment A
Table 1: Evaluation Summary
CompanyLocationAggregate Score
EPC Energy Inc.San Jose, CA79.5
NextEra Energy ResourcesJuno Beach, FL55.3
Ameresco, Inc.Framingham.MA46.5
174 Power GlobalIrvine, CA43
EPCE is headquartered in San Jose, California, and specializes in integrated energy storage systems powered by automotive-grade lithium-iron-phosphate ("LFP") battery cells. Within the past five years, it has supplied seven complete BESS installations similar in size to the Glenarm BESS, with four of those installations in California. EPCE has established a special purpose entity ("SPE"), Glenarm BESS, LLC, specifically for the Glenarm BESS project; therefore, the ESA would be executed with this named EPCE subsidiary as a matter of contractual propriety. The creation of the SPE is routine in the utility scale industry. An SPE protects the project and the City from any legal ramifications of the parent company.
Upon investigation, PWP is not aware of any local businesses that develop utility-scale battery energy storage systems and, therefore, did not conduct any local outreach.
Glenarm Battery Energy Storage
June 17, 2024
EPCE has not been awarded any purchase orders or contracts by the City in the past five years.
Grant Funding to Offset Costs of the Glenarm BESS Project PWP was recently awarded a $9,660,000 grant from the California Energy Commission ("CEC") for the CEC's Distributed Electricity Backup Assets Program, Bulk Grid Asset Enhancements for Grid Reliability ("DEBA/Bulk Gird Grant"). This effort was supported by the 2023 IRP, which includes the strategy to pursue grant funding to offset decarbonization costs. The City Council authorized the City Manager to enter into the associated grant agreement with the CEC on April 8, 2024.
In addition, PWP submitted a Concept Paper for a Federal Grid Resilience and Innovation Partnerships ("GRIP") Grant. In response to this Concept Paper, the U.S.
Department of Energy's National Energy Technology Laboratory sent PWP a Letter of Encouragement to submit a full application for this grant. The full application was submitted on April 17th, and while waiting for the Department of Energy's award decisions, PWP will seek separate City Council approval similar to that sought for the DEBA/Bulk Grid Grant.
Conclusion
It is respectfully requested that a 15-year contract be approved with Glenarm BESS, LLC for a 25 MW, 4-hour BESS, to be constructed inside PWP's electrical system, with delivery beginning approximately January 1, 2027, and ending approximately December 31, 2041, with an estimated service cost of $54,810,000 over the full 15-yearterm, with a $500,000 contingency allowance for any necessary change orders, and with an estimated purchase price of $47,131,181 or less, depending on when PWP buys the BESS. Should PWP recommend exercising the buyout option, a separate request will be made to the City Council, in accordance with City purchasing policy.
COUNCIL POLICY CONSIDERATION:
The Glenarm BESS Project, which supports PWP's further acquisition of renewable energy resources to reduce GHG emissions, is consistent with the City's Urban Environmental Accords; specifically, Action 1 , Renewable Energy; Action 2, Energy Efficiency; and Action 3, Climate Change, as well as with Resolution 9977, passed by the City Council on January 30, 2023, declaring a climate emergency and setting a goal to source 100% of Pasadena's electricity from carbon-free sources by the end of 2030.
ENVIRONMENTAL ANALYSIS:
The proposed actions to authorize the City to enter into a contract for the design and future purchase of storage capacity and to enter into a License Agreement for the potential use of land do not constitute approval of the potential Glenarm BESS project.
These recommended actions do not grant any vested development entitlements, do not bind any party or commit to any definite course of action, do not restrict the City from Glenarm Battery Energy Storage
June 17,2024
considering any feasible mitigation measures and alternatives, and do not restrict the City from denying a future project on either of the involved sites, and, therefore, do not constitute a project subject to the CEQA pursuant to Section 21065 of CEQA and Sections 15004(b)(4) and 15378 of the State CEQA Guidelines. As such, no environmental document pursuant to CEQA is required. The undertaking of, approval of, and/or approval of any physical improvements is fully contingent on compliance with CEQA. Furthermore, any future BESS project at the Glenarm site would require a discretionary land use entitlement (anticipated to be a Conditional Use Permit) and an agreement with a yet-to-be-identified construction contractor. It is anticipated thatCEQA review will occur concurrent with the design process for a BESS facility and must be completed prior to granting of the land use entitlement and awarding a contract for construction. In addition, the future Glenarm BESS project is also subject to environmental review under the National Environmental Policy Act ("NEPA"), since final, non-appealabte NEPA approval is a condition precedent to PWP's receiving federal grant funding toward this project.
FISCAL IMPACT:
The total cost of this action is $55,310,000 which is based upon the proposed service rate of $12.18/kW-month plus a $500,000 contingency allowance for change orders; the estimated annual cost of the contract is $3,654,000 from Fiscal Years 2027 through 2042. Funding for this action will be addressed by future appropriations in Power Operating Fund 401.
The estimated impact to the electric system average rate is less than half a cent ($0.0032). This reflects the impact of the additional cost for the project. It does not consider the net impact of the Intermountain Power Project exit or other expiring resources and assumes all other rate components are held constant. Other components will be considered in the Electric Rate Study.
If PWP exercises an asset buyout option for the facility, it will cease paying the above ser»/ice rate. The estimated maximum purchase price of $47,131,181 corresponds to the earliest possible buyout (upon Commercial Operation, currently estimated to be January 1, 2027) and decreases thereafter. For example, the estimated purchase price for a January 1, 2032, buyout would be $10,806,949.
In light of the DEBA/Bulk Grid Grant award, staff will seek corresponding increases to the Power Fund budgets in the amount of $9,660,000. This will likely benefit the Fiscal Year 2026 budget. Further grant awards, if they occur, would adjust this figure and the affected Fiscal Year budget(s).
Glenarm Battery Energy Storage
June 17, 2024
As PWP continues to expand its portfolio of zero-carbon resources to meet both regulatory compliance requirements and the goals of Resolution 9977, the net impact to future budgets is currently uncertain. Although no rate adjustments are recommended as part of this action, staff will evaluate the cost impacts and may return to the City Council with rate proposals related to this contract.
Respectfully submitted,
Prepared by:
DAVID M. REYES
Acting General Manager
Water and Power Department
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KellyNgt^en u ff
Assistant General Manager
Approved by:
MIGUETT^ARQUEZ
City Manager
Attachment A: Detailed Evaluation Scoring
Attachment A: Detailed Evaluation Scores
Vendor
Proposed
Solution
Financial Value
Of The
Proposal/Price
Project
Viability/Technic
al Strength
Project
Management,
Implementation
Plan and Project
Schedule
Local Pasadena
Business
Small or Micro-
BusinessTotal Score
174 Power Global
22.751118.250043
Ameresco, Inc.
26011.758.750046.5
EPC Energy Inc
24.753511.258.50079.5
NextEra Energy
Resources24.751011.758.750055.25
Disclosure Pursuant to the
City of Pasadena Taxpayer Protection Amendment
Pasadena City Charter, Article XVII
Contractor/Organization hereby discloses its trustees, directors, partners, officers, and those withmore than 10% equity, participation, or revenue interest in Contractor/Organization, as follows:
(If printing, please print legibly. Use additional sheets as necessary.)
1. Contractor/Organization Name:
EPC Energy Inc
2. Type of Entity:
a non-goveniment D nonprofit 501(c)(3), (4), or (6)
3.Name(s) of trustees, directors, partners, officers ofContractor/Organization:
Kewen Chen, President of EPC Energy Inc
Jack Chen, CEO ofYN Energy Inc
4. Names of those with more than 10% equity, participation or revenue interest in Contractor/Organization:
Kewen C hen
YN Energy Inc
Prepared by: Kewen Chen
Title: President
Phone: 408-728-5487
Date: 10/12/2023
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Disclosure Pursuant to the
City of Pasadena Taxpayer Protection Amendment
Pasadena City Charter, Article XVII
Contractor/Organization hereby discloses its trustees, directors, partners, officers, and those withmore than 10% equity, participation, or revenue interest in Contractor/Organization, as follows:
(If printing, please print legibly. Use additional sheets as necessary.)
1. Contractor/Organization Name:
DG Delevopment & Acquisition, LLC (a wholly-owned subsidiary for NextEra Energy Resources, Inc.)
2. Type of Entity:
^non-govemment a nonprofit 501(c)(3), (4), or (6)
3. Name(s) of trustees, directors, partners, officers of Contractor/Organization:
Gary Morris - Vice President, DG Development & Acquisition. LLC NextEra Energy Resources, Inc. is a publicly traded entity. Information on company executives and board of directors is publicy available at www.nexteraenergy.com/ company/leadership.
4. Names of those with more than 10% equity, participation or revenue interest inContractor/Organization:
See previous response.
Prepared by: John Hubenthal
Title: _Sr._Director, Western Origination
Phone:415-318-5913
Date:October 16, 2023
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Disclosure Pursuant to the
City of Pasadena Taxpayer Protection Amendment
Pasadena City Charter, Article XVII
Contractor/Organization hereby discloses its trustees, directors, partners, officers, and those withmore than 10% equity, participation, or revenue interest in Contractor/Organization, as follows:
(If printing, please print legibly. Use additional sheets as necessary.)
1. Contractor/Organization Name:Ameresco, Inc.
2. Type of Entity:
ix non-govemment D nonprofit 501(c)(3), (4), or (6)
3. Name(s) of trustees, directors, partners, officers ofContractor/Organization:
George P. Sakellaris: David J. Corrsin: Michael T. Bakas: Nicole Bulaarino: Mark Chiplock:
Leila Dillon; Bob Georgeoff; Doran Hole; Britta Macintosh; Louis P. Maltezos; Peter Christakis;Lenka Patten; Claire hlughes Johnson; Jennifer L. Miller; Charles R. Patton; Nickolas Stavropoulios; Joseph W. Sutton; Frank V. Wisneski
4. Names of those with more than 10% equity, participation or revenue interest in Contractor/Organization:
George Sakellaris
Prepared by: Jacqueline DeRosa
Title: Vice President - Battery Energy Storage Systems
Phone: +1 5109823535
Date: 10/16/2023
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Disclosure Pursuant to the
City of Pasadena Taxpayer Protection Amendment
Pasadena City Charter, Article XVII
Contractor/Organization hereby discloses its trustees, directors, partners, officers, and those withmore than 10% equity, participation, or revenue interest in Contractor/Organization, as follows:
(If printing, please print legibly. Use additional sheets as necessary.)1. Contractor/Organization Name:
Hanwha Energy USA Holdings Corporation
2. Type of Entity:
X non-govemment a nonprofit 501(c)(3), (4), or (6)
3. Name(s) of trustees, directors, partners, officers of Contractor/Organization:
Sunghonn KimChief Executive Office fi DirectorDavid KirnChief Financial Officer & Chief Strategy Office & DirectorJi Hwan AhnTreasurer Carolyn ByunSecretary
Henry YunPresident & Director
Jae Kyu LeeDirector
4. Names of those with more than 10% equity, participation or revenue interest inContractor/Organization:
KimberlyJohnson
Title: Paralegal
Phone:
Date:
818/378-5495
October 13, 2023
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Kenebrew. Jerice
From:
Sent:
To:
Cc:
Subject:
Jamie Scott
Monday, June 17, 2024 9:41 AM
PublicComment-AutoResponse
Jamie Scott; Chapman, Justin; Madison, Steve; breden
City Council Public Comment - Agenda Items 11, 12 - Support for Wind Contract and Battery Contract
Dear City Council Members,
Our names are Jamie Scott and Felix Breden.
We are residents of Pasadena District 6.
We urge you to vote in favor of Agenda Items 11 S 12 in an ongoing effort to achieve the goals of Resolution 9977.
However, we also ask that you inquire about the following:
1) Whether there exists a Glenarm Master Plan to ensure that any projects being planned for this highly valuable space are intentionally designed to optimally achieve the carbon free goal; 2) Whether there is any option for recourse from the Special Purpose Entity contracted for the Battery Storage Contract should any issues arise;
3) Whether the Battery Storage Contract will be taking advantage of the Inflation Reduction Act's Production Tax Credit / Investment Tax Credit;
4) Whether the current Cost of Service Study will be considering the reduction/elimination of fixed fees to incentivize conservation and reduce the burden on lower income rate payers.
We appreciate your work on behalf of Pasadena's citizens!! Thank you for considering these requests!
Jamie& Felix
Jamie Scott & Felix Breden
(she/her/hers A hp/him/his)
We gratefully acknowledge that we work, play and live on the traditional lands of the Gabrielino-Tongva peoples. 1 Kenebrew. Jerice
From:
Sent:
To:
Subject:
Jenna Cobb •
Sunday, June 16, 2024 5:52 PM
PublicComment-AutoResponse
City Council Public Comment - Agenda Items 11,12- Support for Wind Contract and Battery Contract
'sSome people who received this message don't often get email fromn. Learn why this is important ^] CAUTION: Thisemail was delivered from the Internet. Do not click links or open attachments unless you frnowthe content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0010263" on the DolT portal, . ; : ,
City Council Members,
My name is Jenna Cobb, I am a resident of Pasadena District 2, and I urge you to vote in favor of Agenda Items 11 & 12 in an ongoing effort to achieve the goals of Resolution 9977. However, I ask that you inquire about the following: 1) Whether there exists a Glenarm Master Plan to ensure that any projects being planned for this highly valuable space are intentionally designed to optimally achieve the carbon free goal; 2) Whether there is any option for recourse from the Special Purpose Entity contracted for the Battery Storage Contract should any issues arise; 3) Whether the Battery Storage Contract will betaking advantage of the Inflation Reduction Act's Production Tax Credit/Investment Tax Credit; 4) Whether the current Cost of Service Study will be considering the reduction/elimination of fixed fees to incentivize conservation and reduce the burden on lower income rate payers. 1 Kenebrew, Jerice
From:
Sent:
To:
Subject:
Mishka Michon -i...-. , •_ . ,.c,,i.^u]i.
Saturday, June 15, 2024 9:24 PM
PublicComment-AutoResponse
City Council Public Comment - Agenda Items 11, 12 - Support for Wind Contract and Battery Contract
Some people who received this message don't often get email from iLearn why this is important [^1 CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content issafe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0010263" on theDolT portal, City Council Members,
My name is Mishka and I am a resident of Pasadena District 6.
I urge you to vote in favor of Agenda Items 11 & 12 in an ongoing effort to achieve the goals of Resolution 9977.
However, I ask that you inquire about the following: 1) Whether there exists a Glenarm Master Plan to ensure that anyprojects being planned for this highly valuable space are intentionally designed to optimally achieve the carbon freegoal; 2) Whether there is any option for recourse from the Special Purpose Entity contracted for the Battery StorageContract should any issues arise; 3) Whether the Battery Storage Contract will be taking advantage of the InflationReduction Act's Production Tax Credit / Investment Tax Credit; 4) Whether the current Cost of Service Study will beconsidering the reduction/elimination of fixed fees to incentivize conservation and reduce the burden on lower income rate payers.
Thank you for your attention,
Mishka
Mishka Michon
1