Please Turn Off Cellular Phones While Inside the Council Chamber

A G E N D A GLENDALE CITY COUNCIL

COUNCIL CHAMBER, City Hall – 613 E Broadway, 2nd Floor Glendale, CA 91206

Welcome to Glendale City Hall. Meetings are broadcast live on cable channel 6 (GTV6) and rebroadcast throughout the week. Call (818) 548-4013 for program schedules. DVDs of the proceedings are available for purchase in the City Clerk’s Office. Meetings are also archived on the City Website for viewing anytime at http://www.glendaleca.gov/government/agendas-minutes. If you have any question about matters on the agenda, or requests for assistance, please contact the City Clerk at (818) 548-2090 during regular business hours.

PLEASE TURN OFF CELLULAR PHONES WHILE INSIDE THE COUNCIL CHAMBER.

In compliance with the Americans with Disabilities Act (ADA) of 1990, auxiliary hearing aids, sign language translation, and Braille transcripts are available upon request. Assisted listening devices are available same-day upon request. At least 48 hours (or two business days) notice is required for requests regarding sign language translation and Braille transcription services. All documents related to open session items on this agenda that are received less than 72 hours prior to this meeting, and are public records, will be available for review in the

Office of the City Clerk, 613 E. Broadway, RM 110, Glendale, CA 91206.

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

APRIL 10, 2018

ROLL CALL 1. CLOSED SESSION – 1:00 p.m. (To Commence at 3:00 p.m.) a. Conference with Legal Counsel, Pending Litigation: Hambaryan v. City of Glendale, L.A.S.C. Case No. BC611707. b. Conference with Legal Counsel, Pending Litigation: Bardakjian v. City of Glendale, L.A.S.C. Case No. BC604654.

2. REGULAR BUSINESS AGENDA – 6:00 p.m. Roll Call a. Flag Salute: Council Member Devine b. Invocation: Ardy Kassakhian, City Clerk c. Report of City Clerk, re: Posting of Agenda. The Agenda for the April 10, 2018 Regular Meeting of the Glendale City Council was Posted on Friday, April 6, 2018, on the Bulletin Board Outside City Hall.

3. PRESENTATIONS AND APPOINTMENTS a. Agenda Preview for the Meetings of Tuesday, April 17, 2018

4. CONSENT ITEMS (Including Minutes) The following are Routine and May be Acted Upon by One Motion. Any Member of Council or the Audience Requesting Separate Consideration May do so by Making Such Request Before Motion is Proposed. a. Director of Public Works, re: Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway 1. Resolution Appropriating $600,000 TYPED 4/3/2018 8:42 AM 4 10 18 CC 1

b. Directors of Public Works and Community Development, re: Glendale Train Station and Transportation Center 1st/Last Mile Regional Improvements Projects Phase I and II 1. Resolution Appropriating Funds c. Director of Public Works, re: Healthy Vending Services Program 1. Motion Awarding a Contract to Intellivend Inc. for Five Years with One Optional Five Year Extension and Authorizing the City Manager to Execute the Contract d. Director of Community Services and Parks, re: Santa Monica Mountains Conservancy Grant Proposition 1 Grant Application 1. Motion Approving the Submittal of a Grant Application to the Santa Monica Mountains Conservancy Under the Water Quality, Supply, and Infrastructure Improvement Act of 2014 (Proposition 1) for $1,875,000, and Authorizing the City Manager to Execute All Necessary Agreements, Certificates, and Documents

5. CITY COUNCIL/STAFF COMMENTS

6. COMMUNITY EVENT ANNOUNCEMENTS (3-Minutes)

7. ADOPTION OF ORDINANCES

8. ACTION ITEMS

9. HEARINGS a. General Manager of Glendale Water and Power, re: Grayson Repowering Project – Final Environmental Impact Report and Consideration of Project Approval or Approval of a Project Option (Final Environmental Impact Report) 1. Resolution Certifying the Environmental Impact Report as Lead Agency 2. Resolution Making Certain Findings and Determinations Regarding the Environmental Effects of the Grayson Repowering Project and Approving a Mitigation Monitoring and Reporting Program 3. Resolution Approving the Project or Project Options and Directing Staff to Take Actions in Furtherance Thereof 4. Motion Providing Direction to Staff

10. REPORTS – INFORMATION

11. WRITTEN COMMUNICATIONS

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

13. NEW BUSINESS

14. ADJOURNMENT

TYPED 4/3/2018 8:42 AM 4 10 18 CC 2

gLendaL~°%9 california ~

CITY OF GLENDALE, CALIFORNIA REPORT TO THE:

Joint H City Council ~ Housing Authority H Successor Agency H Oversight Board H

April 10, 2018 AGENDA ITEM

Report: Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway

1) Resolution of Appropriation to appropriate $600,000 from Local Grants, Measure R Regional Return Fund, Account No. 34301-255 to the Construction, Measure R Regional Return Fund, Public Works Projects, Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway Off-Ramp, Account No. 52100-255-501 -G51 986.

COUNCIL ACTION Public Hearing H Ordinance H Consent Calendar ~ Action Item H Report Only H

Approved for April 10. 2018 calendar

ADMINISTRATIVE ACTION

Submitted by: Roubik R. Golanian, P.E., Director of Public Works

Prepared by: Sarkis Oganesyan, P.E., Senior Civil Engineer

Approved by: Yasmin K. Beers, City Manager C~J%~’âD

Reviewed by: Dennis H. Ambayec, P.E., Dep. Director of Public Works/City Engineer~~~

Michael J. Garcia, City Attorney

Robert P. Elliot, Director of Finance ______RECOMMENDATION

Staff respectfully recommends that City Council approve a Resolution of Appropriation to appropriate $600,000 from Local Grants, Measure R Regional Return Fund, Account No. 34301-255 to the Construction, Measure R Regional Return Fund, Public Works Projects, Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway Off-Ramp, Account No. 52100-255-501-G51986.

BACKGROUND/ANALYSIS

The rehabilitation of Verdugo Boulevard between Verdugo Road and the easterly City limit is part of Public Works Engineering’s ongoing effort to improve the condition of the City’s streets.

Street intersections are potential points of conflict in any roadway system. Motorized and non- motorized users are crossing paths as they travel through or turn from one route to another. Therefore, a major part of road safety challenges involve addressing intersections. Intersections can also become congested when traffic volumes are high, creating inefficiencies that result in user delay and frustration. The benefits of modified and upgraded signalized intersections include: • Enhanced traffic flow along surface streets in the vicinity of the subject intersections; • Enhanced operational, and pedestrian safety; and • Reduced traffic delays, improved mobilization and travel time, and consequently reduce fuel consumption and vehicle emissions.

Project Locations:

• Verdugo Boulevard and Valihi Way • Verdugo Boulevard and SR-2 Freeway Off-Ramp

The above intersections scheduled for signal modifications will be modified and upgraded to improve traffic progression and enhance traffic safety.

The project scope of work includes the following:

• Modification of existing traffic signals; • Installation of new curb ramps to meet current Federal Americans with Disabilities Act (ADA) requirements; and • Installation of new striping and pavement markings.

Measure R

Measure R is a half-cent sales tax for Los Angeles County that finances new transportation projects and programs. In November 2008, Measure P was approved by two-thirds majority, committing a projected $40 billion to traffic relief and transportation upgrades throughout the County over its 30 years life span. The City’s share of Measure R funds for Highway Operational Improvements in the first ten years is approximately $34 million.

The City is required to execute a Funding Agreement (FA) for each of our Measure R funded projects. The FA must be executed in the first year that funds are available and prior to starting

2 any work on the project. They include a general description of the project, the specific work elements to be completed, and the source of all funds.

City staff was able to secure Measure R funds to fund the design, construction, and construction management of the traffic signal modifications on Verdugo Boulevard at Valihi Way and SR-2 Freeway Off-Ramp, and will use Gas Tax funds to fund the street improvement portion of Verdugo Boulevard.

Project S hedule and Milestones

The Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway Off-Ramp are included in Los Angeles County Metro Board’s approved project list in the amount of $600,000. Staff is currently working on the design phase of the project, with project advertisement anticipated in mid-2019, and construction anticipated to begin four months after advertisement.

FISCAL IMPACT

Upon Council’s approval, $600,000 will be appropriated from Local Grants, Measure R Regional Return Fund, Account No. 34301-255 to the Construction, Measure R Regional Return Fund, Public Works Projects, Verdugo Boulevard Traffic Signal Modifications at Valihi Way and SR-2 Freeway Off-Ramp, Account No. 521 00-255-501 -G51 986.

Additional Gas Tax funds will be requested for the street improvement portion of Verdugo Boulevard as part of the FY 2018-2019 budget request.

ALTERNATIVES

Alternative 1: Approve the attached Resolutions. Staff can proceed with the preliminary engineering phase of the project.

Alternative 2: Do not approve the attached Resolutions. The project cannot be designed and consequently cannot be constructed.

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

EXH I BITS

Exhibit 1: Project Location Map

3 RESOLUTION NO.

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE MAKING AN APPROPRIATION

BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $600,000 is hereby appropriated and/or transferred from the following accounts to the following accounts:

ACCOUNTS DESCRIPTION FROM TO 34301-255 Local Grants, Measure R-Regional Return Fund $600,000

52100-255-501-G51986 Construction, Measure R-Regional Return Fund, Public $600,000 Works Projects, Traffic Signal Modifications at Valihi Way and SR-2 Freeway Off-Ramp

To appropriate funding for Verdugo Boulevard traffic signal modifications at Valihi Way and SR-2 Freeway

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

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

Adopted this day of .2018.

Mayor ATTEST: CITY OF GLENDALE DATE 03/26/2018 APPROVED AS TO FiNANCIAL City Clerk PROVISION FOR $ 600,000.00

STATE OF CALIFORNIA) COUNTY OF LOS ANGELES) SS CITY OF GLENDALE) / Director of Finance “

I, Ardashes Kassakhian, City Clerk of the City of Glendale, do hereby certify that the foregoing Resolution No. was adopted by the Council of the City of Glendale, California, at a regular meeting held on the______day of ______,2018 and that the same was adopted by the following vote:

Ayes: Noes: Absent: Abstain:

City Clerk APPROVED AS TO FORM

CIfl4rrORrqEy kAt DATh______EXHIBIT I TRAFFIC SIGNAL MODIFICATIONS ON VERDUGO BLVD AT VALIHI WAY AND SR-2 FREEWAY OFF-RAMP

LEGEND

PROJECT LOCATION MAP gLendaL~° Public Works CITY OF GLENDALE, CALIFORNIA REPORT TO THE:

Joint LI City Council N Housing Authority E Successor Agency fl Oversight Board fl

April10, 2018

AGENDA ITEM

Report: Glendale Train Station and Transportation Center 1st/Last Mile Regional Improvements Projects Phase I and II

1) Resolution: of Appropriation to appropriate funds

COUNCIL ACTION Public Hearing H Ordinance H Consent Calendar ~ Action Item Report Only LI

Approved for April 101 2018 calendar

ADMINISTRATIVE ACTION

Submitted by: )Lc. Roubik R. Golanian, P.E., Director of Public Works

Philip Lanzafame, Director of Community Development

Prepared by: Fred Zohrehvand, Senior Planner

Sarkis Oganesyan, P.E., Senior Civil Engineer

Approved by: Yasmin K. Beers, City Manager

Reviewed by: Kathryn Engel, Transit Manager Ai41

Michael J. Garcia, City Attorney

Robert P. Elliot, Director of Finance Wtuc /~‘ 48 I RECOMMENDATION

Staff respectfully recommends that the City Council approve the following:

1) Resolution of Appropriation to appropriate funds in the following accounts and amounts:

a. Appropriate $1,556,438 from the Local Grants, CIP Reimbursement Fund (34301-409) to Construction, CIP Reimbursement Fund, Public Works Projects, CFP: Train Station Vt/Last Mile Project (521 00-409-501-G521 04) b. Appropriate $1,101,000 from the Federal Grants, Cl P Reimbursement Fund (31240-409) to Construction, CIP Reimbursement Fund, Public Works Projects, Vt/Last Mile Phase II Project (521 00-409-501-G52176) c. Appropriate $200,000 from County Grants, CIP Reimbursement Fund (34050-409) to Construction, CIP Reimbursement Fund, Public Works Projects, TDA3-Bicycle and Pedestrian Fund (52100-409-501-G52050)

BACKGROUND/ANALYSIS

Glendale Train Station Vt/Last Mile Regional Improvements Phase I

The Community Development Department secured funds from the competitive Metro 2015 Call for Projects grant program. The award provides $1,556,438 to improve conditions for transit riders in and around the Glendale Transportation Center (GTC), contingent on meeting Metro’s Project Readiness requirements.

The recommended action will allow the City to meet these requirements by agreeing to the following:

1) Appropriately staff the project; 2) Complete work by the Project Lapse Date; 3) Allocate Metro 2015 Call for Projects grant funds in the amount of $1,556,438; and 4) Utilize $711,100 of local matchfunds from Measure M Local Return.

A funding agreement has been executed by Metro and the City for this grant.

Throughout the ongoing outreach process for the South Glendale Community Plan, beginning in October 2013 and last presented to the City Council on December 6,2016, Tropico stakehoiders have provided numerous comments regarding their desire for mobility and safety improvements in their neighborhood. This project’s initial outreach effort received the 2014 Public Outreach

Award of Merit from the American Planning Association - Los Angeles Chapter. In that same year, 2014, the Metro Board adopted both the First Last Mile Strategic Plan & Planning Guidelines and the Metro Complete Streets Policy. The Community Development Department recognized an opportunity to implement some of the community plan’s draft recommendations consistent with Metro’s new policies through the 2015 Metro Call for Projects, a competitive grant program that distributes discretionary funds to regionally significant projects.

The project will help make Cerritos Avenue a true gateway to the GTC by providing new shade trees, pedestrian lighting, and stormwater infiltration parkways along widened sidewalks. Improvements at GTC include new shelters for rail and bus patrons above existing benches that

2 will be illuminated using sustainable solar power; and an information kiosk for commuters. Other area improvements will bring new LED pedestrian lighting to San Fernando Road between Los Feliz Road and Brand Boulevard, and new full-featured bus shelters with benches, information kiosks, and trash receptacles. The project will implement a comprehensive neighborhood wayfinding program for drivers, bicyclists, and pedestrians noting distances to transit resources, bikeways, parks, schools, libraries, post offices, and other points of interest. Finally, pedestrians will see upgrades to existing crosswalks from standard to high-visibility markings along San Fernando Road between Los Feliz Road and Brand Boulevard; and the addition of new, high- visibility crosswalks at Gardena Avenue and Cerritos Avenue. (See Exhibit 1)

Glendale Transportation Center istILast Mile Regional Improvements Phase II

The Community Development Department secured funds from the competitive 2017 Active Transportation Program (ATP) Augmentation fund program. The award provides $1,101,000 to improve conditions around the GTC, connecting the disadvantaged Tropico neighborhood in Glendale with regional employment, medical, and retail destinations via new active transportation facilities, Metro Rapid/Local and Glendale Beeline transit systems, and Metrolink/Amtrak rail service.

The recommended action will allow the City to meet these requirements by agreeing to the following:

1) Appropriately staff the project; 2) Complete work by the Project Lapse Date; and 3) Allocate 2017 ATP Augmentation fund program funds in the amount of $1,101,000, as well as $200,000 of local match funds from the City’s Transportation Development Act (TDA), Article Ill.

A funding allocation was submitted to California Transportation Commission (CTC) for this project.

The disadvantaged neighborhood around the GTC is vehicle-oriented and lacks adequate active transportation facilities. The project area includes a major regional hospital/health center; Metro rapid transit routes; 11,888 residents/square mile; nearly 8,000 jobs; and multiple modes of transportation, including bicycling and walking, despite the existing conditions.

Phase Il of comprehensive “first/last mile” improvements around GTC includes Glendale’s first protected bikeway, LED pedestrian lighting, wayfinding, shade trees, high-visibility crosswalks, accessibility features, and pedestrian signal improvements. GTC services include Metrolink/Amtrak rail, Metro and Glendale Beeline transit systems.

The GTC is at the heart of the transit oriented development (TOD) - focused Tropico Center Plan. The station is approximately 1/4 mile from a rapid transit hub at Los Feliz Road and San Fernando Road, with direct connectivity to Downtown Glendale and growing commercial/industrial/medical employment centers. These proposed improvements will implement the draft plan’s recommendations to provide critical access for residents and regional commuters between residential and commercial destinations, and to improve facilities and wayfinding for bicyclists, pedestrians, and disabled persons in one of Glendale’s highest-need and highest-potential neighborhoods.

3 This phase is located in the disadvantaged Tropico neighborhood around the Glendale Transportation Center (400 W Cerritos Ave.) in the southern portion of Glendale. The full project area is bounded by Los Feliz Road, San Fernando Road, Brand Boulevard, and westerly City Limits. (See Exhibit 2)

PROJECT SCHEDULE

Phase I:

Milestone Begin End Duration Design Engineering/PS&E May 1,2018 September 1, 2Ol9l6months

. ~dvertise/Award Contract/Certification January 22, 2020 May 22, 2020 t months Construction July 1.2020 March 29, 2021 8 months

Phase II:

Milestone Begin End Duration Proiect Approval & Environmental Document (PAED) May 1, 2018 September 1, 2018 t months Design Engineering/Plans, Specs, & Estimate (PS&E) October 1, 2018 )ctoberl. 2019 12 months \dvertise/Award Contract/Certification January 22, 2020 May 22, 2020 ~ months Construction July 1,2020 March 29, 2021 3 months

FISCAL IMPACT Glendale Train Station 1st/last Mile Regional Improvements Phase I will be funded by Metro Call for Projects in the amount of $1,556,438 with $71.1 ,1 00 from Measure M Local Return ~s a local match.

Project Funding Phase I

Grant funds Match Funds PROJECT ITEM TOTAL (LACMTA) (LOCAL AGENCY) Planning, Design, Engineering $129,578 $59,31 1 $188,889 Project Management/Contract Administration $65,385 $29,929 $95,314 Construction $1,295,779 $593,111 $1,888,890 Construction Engineering $65,696 $28,749 $94,445 TOTAL BUDGET COST $1,556,438 $711,100 $2,267,538

Glendale Transportation Center 1st/last Mile Regional Improvements Phase II will be funded by the 2017 ATP Augmentation Program for Project in the amount of $1,101,000 and $200,000 from Transportation Development Act (TDA) as a local match.

Project Funding Phase II:

Grant funds Match Funds PROJECT ITEM TOTAL (ATP Funds) (LOCAL AGENCY) E&P (PA&ED) $43,000 $4,000 $47,000 PS&E $129,000 $13,000 $142,000 Construction 929,000 $183,000 $1,112,000 TOTAL BUDGET COST $1,101,000 $200,000 $1,301,000

4 Fér the local agency match funds portion of Phase I, $711,100 is currently appropriated in the Measure M Local Return Fund, CDD Projects, CFP: Train Station Vt/Last Mile Project (51200- 222-1 80-521 04).

Upon Council’s approval, the following amounts will be appropriated as follows:

a. Appropriate $1,556,438 from the Local Grants, CIP Reimbursement Fund (34301-409) to Construction, CIP Reimbursement Fund, Public Works Projects, CFP: Train Station Vt/Last Mile Project (52100-409-501-G52104) b. Appropriate $1,101 ,000 from the Federal Grants, CIP Reimbursement Fund (31 240-409) to Construction, C1P Reimbursement Fund, Public Works Projects, Vt/Last Mile Phase II Project (52100-409-501 -G52176) c. Appropriate $200,000 from County Grants, CIP Reimbursement Fund (34050-409) to Construction, CIP Reimbursement Fund, Public Works Projects, TDA3-Bicycle and Pedestrian Fund (52100-409-501 -G52050)

ALTERNATIVES

Alternative 1: Approve the attached Resolutions. Phase I and II of the VYLast Mile Regional Improvements Project will help improve all modes of transportation.

Alternative 2: Do not approve the attached Resolutions. Staff will relinquish funding received for improving all modes of transportation for Phase I and Phase II of the ?YLast Mile Regional Improvements Project.

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

EXHIBITS Exhibit 1: Phase I Project Location Map Exhibit 2: Phase II Project Location Map

5 RESOLUTION NO. ______

RESOLUTION OF THE COUNCIL OF THE CITY OF GLENDALE MAKING AN APPROPRIATION

BE IT RESOLVED BY THE COUNCIL OF THE CITY OF GLENDALE:

SECTION 1: That the sum of $2,857,438 is hereby appropriated and/or transferred from the following accounts to the following accounts: ~

ACCOUNTS DESCRIPTION FROM TO 34301-409 Local Grants, CIP Reimbursement Fund $1,556,438

52100-409-501-G52104 Construction, CIP Reimbursement Fund, Public Works $1,556,438

. Projects, CFP: Train Station 1st/Last Mile Project

31 240-409 Federal Grants, CIP Reimbursement Fund $1,101,000

521 00-409-501 -G521 76 Construction, CI P Reimbursement Fund, Public Works $1,101,000 Projects, 1st/Last Mile Phase II Project

34050-409 County Grants, CIP Reimbursement Fund $200,000

52100-409-501-G52050 Construction, CIP Reimbursement Fund, Public Works $200,000 Projects, TDA3 Project

To appropriate funding for the Glendale 1st/Last Mile Regional Improvements Phase I and Phase II projects

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

Adopted this day of 2018.

Mayor ATTEST: CITY OF GLENDALE DATE 3/26/2018 APPROVED AS TO FINANCIAL City Clerk PROVISION FOR $ 2,857,438

STATE OF CALIFORNIA) COUNTY OF LOS ANGELES) SS $ftV CITY OF GLENDALE) irector of fluance

the______day of ______, 2018, and that the same was adopted by the following vote:

Ayes: ARPROVEe Noes: Absent: Abstain ërrv / ORNEY k-B 1~ DATh ____ City Clerk EXHIBIT 1 - PROJECT LOCATION MAP Glendale Train Station 1st/Last Mile Regional Improvements Revised Project Scope (Phase I) \~

• CYPRESS I 3 -J

,~tV° LOSFELIZ ROADS END

LAUREL £ MIsS f 41$ EULALIA ~ 8 ‘7t~ C.)

a CERRITOS cATHEDRAL

o EORES~

0 r C It

C r~n.:~ir 7RAh~qTAT~ rnr~ 4 fl~p:~P.s~,a~ .‘afltn ‘9 0 Y.,t~.,Vaft,d~q

rAI3TIsn,n.p~It.a~t, ~. Tn~C.n /- ItDF,d.1Pi1 -t ~ik Prntnjl .‘dt.rw nIr~.nrt, F~~wfl, J~~tn1 r~ Ot~b flr~:bP~:, II~’-t.~.n,y (itt. tn ltYe .,%*Tn~. Ra

______C.’it I~b,iifl A C7 14 I ICtptOa~,at ~l *JTh N

The locations of pro~esed rnpiaverneots 0 005 01 02 ale appto~cIinaIeaml ate nGt tc) 34:ale EXHIBIT 2- PROJECT LOCATION MAP

Glendale Train Station Regional 1st/Last Mile Improvements - Phase II Phase II of a package of Glendale Train Station First/Last Mile improvements connecting Glendale to Los Angeles City, including new bicycle facilities, pedestrian lighting, wayfinding, landscaping, sidewalk widening and high-visibility crosswalks.

0~J~ ‘—‘—“A—

North to BURBANK

South-west to ATWATER VILLAGE (City of Los Angeles)

Bicycle/Pedestrian Wayfinding

Glendale Train Station

MetrolinkiAmtrak Route

— LED Pedestrian-Scale Lighling i:~ Gateway Tunnel Improvements CITY OF [Jflfl All-Way Zebra Crosswalks GLENDALE Parkway/Median Landscape Improvements Prepesed Bike Facilities CITY OF Class 2 Bike Lanes LOS ANGELES Class 3 Bike Route (Sharrows) Class 4 Cycle Tracks Metro Rapid Bus Route 150 300 Feet A THE LOCATIONS OF PROPOSED IMPROVEMENTS ARE ILLUSTRATIVE AND ARE NOT TO SCALE gLen

CITY OF GLENDALE, CALIFORNIA REPORT TO THE: Joint U City Council ~ Housing Authority U Successor Agency fl Oversight Board U April 10, 2018

AGENDA ITEM Report: Healthy Vending Services Program

1) Motion awarding a contract for the Healthy Vending Services Program, Specifications No. 3664 to Intellivend, Inc. for five years with one optional five year extension and authorizing the City Manager to execute the contract.

COUNCIL ACTION Public Hearing U Ordinance U Consent Calendar ~ Action Item U Report Only U

Approved for April 10, 2018 calendar

ADMINISTRATIVE ACTION

Submitted by: Roubik Golanian, Director of Public Works Prepared by: Jeremy Bates, Hourly City Worker 72Mt~Uç~( Approved by: Yasmin K. Beers, City Manager

Reviewed by: Michael J. Garcia, City Attorney

• Bob Elliot, Director of Finance and Administrative Services

Shea Eccleston-Banwer, Public Works Manager RECOMMENDATION - Staff respectfully recommends that the City Council approve a Motion awarding a contract for the Healthy Vending Services Program, Specifications No. 3664, to Intellivend, Inc. for five years with an option to extend the contract for one additional five year term.

BACKGROUNDIANALYSIS The City Council approved Resolution 16-58 (“Adopting a Healthy Snack and Beverage Policy for Vending Machines on City Property”) on March 29, 2016, which put in place nutritional requirements for products offered through all new contracts for vending machines on City property. Since Resolution 16-58 was passed, a previous contract has remained in place for vending machines on all City properties except for the Police Building. This contract is set to expire on April 30, 2018, necessitating a new contract.

On December 12, 2017, City Council authorized the Director of Public Works to release a request for proposals (RFP) for a new vending contract for vending machines on City property. The new healthy vending requirements were included in this RFP. The Public Works Department released this RFP on January 24, 2018, and accepted proposals through February 23, 2018.

Evaluation Results Three companies submitted proposals in response to the REP. These proposers were Vending One, Inc.; Vending and Amusements, Inc. (DBA First Choice Vending and Amusements); and Intellivend, Inc. After the submittal deadline, the Evaluation Committee, composed of City staff from Public Works, Community Services and Parks and Finance, as well as a representative from the City of Pasadena’s Department of Public Health in charge of their Healthy Vending Program, met to evaluate and score the proposals based on the below criteria.

Criterion Weighting Percentage Revenue: The commission percentage proposed by 40% VENDOR and potential revenue the Agreement could deliver to GLENDALE. Qualifications: VENDOR’s capacity to adequately handle 20% the workload requirements of the Agreement as stipulated in this RFP. Healthy Vending Experience: VENDOR’s experience with 20% implementing healthy vending programs. References: The level to which outside agencies can 10% attest to VENDOR’s satisfactory provision of services. Energy Savings: The extent to which VENDOR can 10% demonstrate that their technology could provide energy savings or other environmental benefits.

Upon the initial review of the proposals by the Evaluation Cohimittee, Vending One’s proposal was deemed not to have met the requirements of the REP as it would not comply with the City’s healthy vending guidelines. Additionally its commission proposal for the City was vastly less competitive than the other two proposals. Accordingly, the Evaluation Committee scheduled interviews with First Choice Vending and Intellivend as finalists. The commission proposals from the two vendors were as follows:

2 Vendor Commission Proposal ____ First Choice Vending 23% on monthly gross revenue up to $4,000 25% on monthly gross revenue from $4,001 to $8,000 28% on monthly gross revenue above $8,000 Intellivend I 30% on monthly gross revenue

Both vendors propose to calculate monthly gross revenue to be all revenues minus applicable sales taxes and California Redemption Value (CF1V). The interview process helped the Evaluation Committee to clarify the two vendors’ qualifications on the other evaluation criteria. Both companies were similarly qualified on all criteria, but due to its more advantageous revenue proposition for the City, Intellivend was selected by the committee as the vendor of choice for this program.

Staff proposes entering into a five year contract with Intellivend, Inc. to provide vending machines and products in compliance with Resolution 16-58 on all City properties except for the Police Building. The contract would have one optional five year extension to be exercised by the City if the City deems it in its best interest to extend the contract. The five-year length of the contract is appropriate given the significant capital investment required on the part of the vendor to purchase, install, and maintain the vending machines. Additionally, the optional extension provision will give the City the flexibility to extend or not extend the contract based on the vendor’s performance.

FISCAL IMPACT Historically, the annual commission for the Glendale vending machine program has totaled between $10,000 and $12,000. As part of research for the development of the City’s Healthy Vending Policy in 2016, staff concluded that the new policy would likely decrease City vending revenues by 30-40%, based on other public agencies that implemented similar healthy vending programs. However, the 30% commission on monthly gross revenue proposed by Intellivend is higher than the 25% commission rate of the expiring contract.

ALTERNATIVES Alternative 1: Approve the attached Motion awarding a contract for the Healthy Vending Services Program, Specifiàations No. 3664 to Intellivend, Inc. for five years with one optional five year extension and authorizing the City Manager to execute the contract.

Alternative 2: Direct staff to reconsider proposals or re-solicit proposals for this project.

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

EXHIBITS None.

3 MOTION

Moved by Council Member ______, seconded by

Council Member , that the proposal submitted by Intellivend, Inc., for the Healthy Vending Services Program, Specifications No. 3664, is hereby approved and accepted. The City Manager or her designee is hereby authorized to execute a 5-year contract with the option to extend the contract for one additional 5-year term, subject to approval by the City Attorney.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:

APPROVED AS TO FORM

Clp.’~’rrORNEY DATE Y/57/d

4 gLendaL california CITY OF GLENDALE, CALIFORNIA REPORT TO THE:

Joint fl City Council ~ Housing Authority U Successor Agency LI Oversight Board U

April10, 2018

AGENDA ITEM

Report: Regarding Santa Monica Mountains Conservancy Proposition 1 Grant Application.

1) Motion approving the submittal of a grant application to the Santa Monica Mountains Conservancy under the Water Quality, Supply, and Infrastructure Improvement Act of 2014 (Proposition 1) for $1,875,000, to convert the natural turf baseball field at Pacific Park to artificial turf; and authorizing the City Manager or a designee to execute all necessary agreements, certifications, and documents to apply for, accept, and implement the funding. COUNCILACTION Public Hearing LI Ordinance U Consent Calendar ~ Action Item ~ Report Only U Approved for Of/aD (07 ZIg calendar

ADMINISTRATIVE ACTION gnature Submitted by: Onnig Bulanikian, Director of Community Services and Parks

Prepared by: Arsine lsayan, Sr. Administrative Analyst

Approved by: Yasmin K. Beers, City Manager

Reviewed by:

Michael J. Garcia, City Attorney

Robert P. Elliot, Director of Finance ~-(

40! RECOMMENDATION Staff respectfully recommends that the City Council approve the attached Motion authorizing submission of a grant application to the Santa Monica Mountains Conservancy under the Water Quality, Supply, and Infrastructure Improvement Act of 2014 (Proposition 1) for $1,875,000, to convert the natural turf baseball field at Pacific Park to artificial turf; and authorizing the City Manager or a designee to execute all necessary agreements, certifications, and documents necessary to apply for, accept, and implement the funding.

BACKGROUND/ANALYSIS The Santa Monica Mountains Conservancy’s Proposition 1 Competitive Grant Program is a result of the Water Quality and Infrastructure Improvement Act of 2014, codified as Division 26.7 of the Water Code. Proposition 1 authorizes $7.545 billion in general obligation bonds for state water projects, including surface and groundwater storage, ecosystem and watershed protection and restoration, and drinking water protection.

The purpose of this program is to assist cities, counties and districts with multi-benefit ecosystem and watershed protection and restoration projects pursuant to Water Code Section 79731(h), and for projects to protect and enhance an urban creek pursuant to Water Code Section 79735(a). Projects funded by Proposition 1 must carry out at least one of the three objectives of the California Water Action Plan (‘Water Action Plan”) and meet at least one of the purposes of Proposition 1 as stated in Water Code Section 79732(a). Priority will be given to projects that meet the current challenges posed by drought and create a sustainable strategy for managing its water resources and supply.

After reviewing the criteria for the program and consulting with the Santa Monica Mountains Conservancy (SMMC), staff is requesting $2.5 million in Proposition 1 grant funds to convert the natural turf baseball field at Pacific Park to artificial turf. The field is currently used for both baseball and soccer, but is closed three months each year for renovation. By converting the field to artificial turf, the City will not only remove the need for over one million gallons of irrigation water per year, but also add an additional 1,380 hours of field availability each year. Conversion of the playing field to artificial turf will also eliminate the need to fertilize the field or to apply herbicides and pesticides to maintain the turf, which will reduce pollution and contamination of the county storm water system and restore natural system functions that contribute to water supply and water quality. Funding from the grant will also be used to add bio swales around the perimeter of the playing field, eliminating even more turf and need for irrigation, fertilizers and pesticides. The bio-swales will be tied into the existing site drainage system to intercept water from the playing field, adjacent picnic area, paved parkways and the adjacent fire lane. The addition of bio-swales to Pacific Park will capture the first flush of storm water, reducing the amount of pollutants leaving the site and entering the county storm water system. Finally, the new bio-swales will be planted with native plants approved for local use by the Landscape Guidelines of the Los Angeles River Master Plan, creating habitat for birds and insects at a site where none has existed for decades.

The need for additional soccer fields is well documented and was repeatedly voiced by the community at the three Development Impact Fee meetings held in southern Glendale in late 2015, as well as at the Los Angeles County Parks Needs Assessment meeting held at Pacific Park in February 2016.

The estimated total project cost is $2,500,000. The grant request is for $1,875,000 and City’s match will be $625,000. Once funds have been awarded, staff will return to council to request appropriation of grant funds. This project is consistent with the City Council’s priority, which is to develop and maintain facilities to enhance the quality of life for the residents of Glendale.

2 FISCAL IMPACT Upon successful award of grant funds, staff will return to council to request a Resolution of Appropriation of $2,500,000, of which $1,875,000 is the grant portion, and the remaining $625,000 is the City match. The City match component will be appropriated from the Recreation Fund 501-601 and DIF Funds 405-601.

ALTERNATIVES Alternative 1: The City Council may approve the attached Motion authorizing the submittal of the SMCC Proposition 1 grant application.

Alternative 2: The City Council may choose not to approve the attached Motion authorizing the submittal of the SMCC Proposition 1 grant application.

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

CAMPAIGN DISCLOSURE This report does not require Campaign Finance Disclosure.

EXHIBITS None

3 MOTION

Moved by Council Member , seconded by

Council Member ______, that the Council hereby authorizes the

City Manager, or a designee, to:

1. Execute and submit a grant application to the Santa Monica Mountains

Conservancy under the Water Quality, Supply, and Infrastructure Improvement

Act of 2014 (Proposition 1) for $1,875,000, to convert the natural turf baseball

field at Pacific Park to artificial turf; and

2. Execute all necessary agreements, certifications, and documents to apply for;

accept, and implement the funding.

Vote as Follows:

Ayes:

Noes:

Absent:

Abstain:

M,chdel ( Grant Principal Assistant City Attorney Date: ~ ~

J:WILES\DOCFILESWACTFINOPACIFIC PARKS PROP 1 GRANTAPPLICATION ~2O18• COUNCIL MOTION.dOCK gLen

CITY OF GLENDALE, CALIFORNIA REPORT TO THE:

Joint ~ City Council ~ Housing Authority L Successor Agency ~ Oversight Board ~

April10, 2018

AGENDA ITEM

Report: Grayson Repowering Project — Final Environmental Impact Report and Consideration of Project Approval or Approval of an Alternative 1. Resolution Certifying the Environmental Impact Report as Lead Agency 2. Resolution Making Certain Findings and Determinations Regarding the Environmental Effects of the Grayson Repowering Project and Approving a Mitigation Monitoring and Reporting Program 3. Resolution Approving the Project or Project Option and Directing Staff to Take Actions in Furtherance Thereof 4. Motion Providing Direction to Staff COUNCIL ACTION Public Hearing ~ Ordinance Li Consent Calendar El Action Item Li Report Only El Approved for a~-~A9 (O,,90~ calendar

ADMINISTRATIVE ACTION

Submitted by: Stephen M. Zurn, General Manager- GWP

Prepared by: Christine Godinez, Principal Assistant City Attorney

Approved by: Yasmin K. Beers, City Manager

Reviewed by: ~4’Robert P. Elliot, Director of Finance

Michael J. Garcia, City Attorney

9 RI RECOMMENDATION Staff respectfully requests that the City Council certify the Final Environmental Impact Report for the proposed Grayson Repowering Project (Project). It is further recommended that the City Council adopt a resolution approving the Project, or a Project Option, and direct staff to take actions in furtherance thereof.

BACKGROUND! ANALYSIS The City faces several significant decisions over the next few years in order to (a) maintain reliable energy service, (b) comply with state regulations regarding renewable energy supplies and greenhouse gas emissions, (c) keep electricity rates affordable to ratepayers in the City, and (d) comply with current and future South Coast Air Quality Management District (SCAQMD) regulations.

The City’s aging Grayson Power Plant is experiencing an increasing frequency in unplanned and forced outages. These outages threaten local reliability. The power plant is not expected to continue in operation beyond the early 2020s. Additionally, forthcoming SCAQMD regulations are expected to require a major air quality retrofit, or force the closure of the power plant, by 2023.

Without the power plant, the City will not have sufficient sources of power to meet energy demand within the City, and maintain sufficient power reserves, on the hottest days of the year. The City has one major interconnection through the Air Way Substation to import energy from generation sources outside of the City. These imports rely on available transmission, but Glendale’s ability to import energy into Glendale from outside sources of generation is limited and finite. Glendale does not have sufficient transmission rights to allow it to import all the energy that is necessary to provide reliable service to Glendale. Additional transmission capacity is not available. In addition, some of City’s outside generation sources are planned for retirement or contract termination. In light of these circumstances, it is necessary for Glendale to repower the Grayson Power Plant.

In August 201 4, following a competitive Request for Proposal process, the City Council approved the retention of PACE Global Energy Services, Inc. as the consultant to develop and complete an Integrated Resource Plan. Following a competitive Request for Proposal process, City Council also authorized retention of Stantec (then Processes Unlimited International, Inc.) as Owner’s Engineer to undertake engineering, environmental, and permitting support in order to ensure that, if the City Council elects to proceed with the repowering of the Grayson Power Plant, the City can meet state environmental requirements associated with repowering Grayson.

In June 2015, the Integrated Resource Plan was completed and presented to the City Council. The Integrated Resource Plan was an integrated plan that evaluated the best options for providing reliable energy to the City, taking into consideration regulatory compliance obligations (such as Renewables Portfolio Standard requirements and greenhouse gas emissions reduction requirements), coal replacement, energy storage, demand response and load, distributed generation (including solar photovoltaics), the Scholl Canyon landfill biogas, the City’s transmission limitations, the aging Grayson Power Plant, and retail rates. The City Council approved the Integrated Resource Plan and directed City staff to proceed with the design, engineering, environmental reviews, and evaluation of financing options for a 250 megawatt (MW) repowering project.

California Environmental Quality Act The purpose of the California Environmental Quality Act (CEQA) process is to: (1) identify the significant effects to the environment of a project, identify alternatives, and indicate the manner

2 in which those significant effects can be avoided or mitigated; (2) provide full disclosure of the project’s environmental effects to the public, the agency decision-makers who will approve or deny the project, and the responsible and trustee agencies charged with managing resources that may be affected by the project; and (3) provide a forum for public participation in the decision-making process with respect to environmental effects.

The standards for adequacy of an EIR, as defined in Section 15151 of the State CEQA Guidelines, are as follows:

An EIA should be prepared with a sufficient degree of analysis to provide decision makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of a Project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the math points of disagreement among the experts. The courts have looked not for perfection but for adequacy, completeness, and a good faith effort at full disclosure.

The EIR has been prepared in accordance with these standards.

EIR Evaluation

The City, as Lead Agency, has conducted an environmental impact review of the proposed Project under CEQA. An Initial Study/Notice of Preparation of an Environmental Impact Report was prepared and circulated between December 20, 2016 and January 20, 2017 for a 30-day review period. The purpose of the Notice of Preparation was to solicit early comments from public agencies with expertise in subjects that would be discussed in the Draft EIR. On January 12, 2017, the City conducted two public scoping meetings regarding the preparation of the Draft EIR. The City also conducted meetings with interested parties, including a meeting with the Pelanconi Homeowner’s Association on January 25, 2017, a meeting with the Chamber of Commerce on February 21, 2017, and a meeting with the Homeowners Coordinating Council on March 6, 2017.

Topics to be evaluated in the Draft EIR were identified based on the comments received in response to the Notice of Preparation, and review of the Project by City staff. The following nine areas with potentially significant impacts were assessed in the Draft EIR:

• Aesthetics • Air Quality • Geology and Soils • Greenhouse Gases • Hazards and Hazardous Materials

• Hydrology and Water Quality - • Noise • Traffic and Transportation • Tribal Cultural Resources

The Draft EIR evaluated each of these resource areas to determine if the project could result in a significant impact requiring mitigation, or whether impacts on the resource were less than significant such that no mitigation is required. The EIR identified four areas as having potentially significant impacts that can be mitigated to a less than significant level:

3 • Aesthetics (less than significant with mitigation) • Hazards and Hazardous Materials (less than significant with mitigation) • Noise (less than significant with mitigation) • Traffic and Transportation (less than significant with mitigation)

The Draft EIR determined that impacts to Air Quality and Hydrology, Geology and Soils, Greenhouse Gases, and Hydrology and Water Quality are less than significant with no mitigation required, and determined that the Project has no impact on Tribal Cultural Resources.

Thus, as analyzed in the Draft EIR, the Project does not result in any potentially significant and unavoidable impacts.

The Draft EIR was made available for a 45-day public review and comment period beginning on September 15, 2017, which was subsequently extended for an additional 21 days, for a total public review and comment period of 66 days ending on November 20, 2017. During the public comment period, two public meetings to receive oral comments on the Draft EIR were conducted: (1) public testimony was taken at the GWP Commission meeting held on Oct 16, 2017; and (2) a community meeting was held where oral comments were received at the Utility Operations Center on October 19, 2017.

During the public comment period, the City received approximately 1133 written comment letters regarding the Draft EIR, and an additional 131 oral comments were recorded during the public meetings on October 16 and 19, 2017. Written comments received during the public comment period include comments from following agencies and organizations: the Los Angeles! Orange County Building and Construction Trades Council, the California Department of Transportation (CalTrans), the Office of Planning and Research, and Los Angeles Councilmember Jose Huizar, Historic Highland Park Neighborhood Council, California Clean Energy Committee, Friends of the LA River, Save our Community SGV, Glendale Historical Society, Earth Justice, Friends of Griffith Park, Glendale Environmental Coalition, and Walk Bike Glendale. The remainder of the comments were submitted by the general public.

All of the comments received during the comment period, and the City’s responses to those comments, are included in the Final EIR for the City Council’s consideration.

Following the close of the public comment period, the City received additional written comments, set forth in Attachment 3 to this Report, and additional oral testimony relating to the Final EIR was provided at the GWP Commission hearing on April 2, 2017. The comments received after the close of the public comment periods were addressed previously in the Final EIR, including the responses to comments, with limited exceptions. CEQA does not require responses to comments received after the close of the public comment period. However, to the extent that any comments received after the close of the public comment period raise new issues, those comments are addressed herein or will be addressed at the hearing. Certain of the newly-raised issues are addressed below:

• A member of the public asserted that the project description is inadequate because the Grayson Power Plant is described as being located within an industrial neighborhood when residential communities are located nearby. Section 3.1 of the Final EIR accurately describes the site location, including surrounding land uses. An aerial photograph of the site and its surroundings is included as Figure 3-2 in the Project Description, which clearly shows nearby residences. In addition, important environmental analysis in the EIR describe the nearest residences as sensitive receptors

4 and specifically evaluate impacts on those sensitive receptors (e.g. aesthetics, air quality, and noise).

• A member of the public claimed that the decision of the Planning Commission to recommend to the City Council that it prepare an Environmental Impact Report for the Biogas Renewable Generation Project at Scholl Canyon Landfill somehow affects the Final EIR for the Grayson Repowering Project. As described in Topical Response No. 11 of the Final EIR, the Biogas Renewable Generation Project is a separate project and the Grayson Repowering Project does not depend upon approval and construction of the Biogas Renewable Generation Project. The Planning Commission’s recommendation that an Environmental Impact Report be prepared for the Biogas Renewable Generation Project does not change the analysis in the Final EIR that the projects have independent utility and are separate projects under CEQA.

• A member of the public claimed that the City failed to analyze health risks attributed to construction emissions. In the past, risk assessments were sometimes conducted for short-term construction projects, but the results of those assessments consistently showed off-site health risk impacts that are below levels that are deemed to be significant. As a result of historic findings from repowering projects, current practices do not generally include risk assessments of short-term construction operations. Health risks attributed to construction emissions include cancer risk associated with diesel soot emissions from the operation of construction equipment. Cancer risk is associated with lifetime exposure rates (typically over 30 years). For the Project, peak emissions from construction equipment occur during a short period (the year in which site grading occurs) and not over an extended period that is equivalent to a receptor lifetime. Based upon conservative models, peak year emissions are estimated to be 369 pounds, which is equivalent to less than 13 pounds per year over a 30-year lifetime exposure period. Furthermore, emissions from grading operations originate from multiple points throughout the ten-acre site so exposure to those emissions by offsite receptors is inconsistent because the distance between emission sources and receptor locations differ on a daily basis.

• A member of the public expressed doubt that asbestos can be 100% controlled during construction. As specified in the EIR, all asbestos work will be in accordance with Cal

OSHA Asbestos & Lead — California Code of Regulations. Mitigation Measure HAZ-2 in the EIR requires facilities to be demolished containing asbestos to be decontaminated or encapsulated prior to removal from the Project site and disposed in accordance with an Asbestos and Lead Paint Management Plan prepared by the demolition contractor and submitted to the City for review and approval prior to initiating demolition activities.

• A member of the public expressed concern regarding the noise associated with backup safety devices during construction. Demolition and construction activities would include the use of vehicles and equipment with backup safety alarms required for safety in accordance with applicable safety regulations. These activities would only take place between 7:00 a.m. and 7:00 p.m. Monday through Saturday, excluding City holidays. These construction times are consistent with that required by the City of Glendale’s Nosie Ordinance.

• A member of the public claimed that the City failed to consider vibration effects of pile driving. Vibration effects of pile driving associated with the Project were quantitatively analyzed in Section 4.8 of the EIR (please refer to the subsection titled “Exposure of persons to or generation of excessive ground borne vibration or ground borne noise

5 levels” beginning on page 4.8.35 in the Final BR). Predicted maximum demolition and construction vibration levels are below the vibration thresholds of significance at the nearest residential and commercial buildings. The Project would therefore not result in exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels, nor would damage to the nearby structures be expected.

Certain topics were raised frequently in the comments. A summary of the frequently-raised topics and the City’s responses to those comments is included in Section 9 of the Final EIR. Some of the key areas of comment are briefly summarized here.

1. Integrating Increased Use of Renewables and Continued Reliability of Electricity at Reasonable Rates

Several commenters expressed concern that the City is pursuing the Project at the expense of pursuing renewable energy alternatives. First, Glendale is already well ahead of the state average in terms of meeting its renewable and carbon-free energy goals. Glendale will continue its commitment to increasing renewable energy use and conservation within the City, both by actively encouraging private solar investment and by pursuing new City-sponsored programs and contracts.

Second, while it may seem counterintuitive, a repowered power plant will assist Glendale in its efforts to integrate additional renewables into its system, and increase use of renewables, in several ways:

• Due to their age, the current units at the power plant cannot “ramp up” and “ramp down” quickly enough to respond to the fluctuations from intermittent renewable energy systems within the City. As more solar power systems online within the City, there will be an increased need for dispatchable resources to smooth out the energy fluctuations. A modern power plant will be able to adjust up and down quickly to ensure a smooth and predictable supply of energy.

• The power plant can also be used to “firm and shape” renewable sources purchased by the City from remote locations. That is, if the energy supply from a remote wind farm dips because the wind is not blowing, the Grayson Power Plant can be dispatched in to fill in and replace the wind energy that does not materialize. If Grayson is not capable of performing this service, Glendale is forced to buy energy that is already “firmed and shaped,” meaning that less of the energy that is imported to the City on the transmission lines is actually renewable.

• When Glendale buys short-term energy to meet energy needs on a hot day, or when a power plant unit fails unexpectedly, Glendale must go out to the spot market to purchase energy. This spot market energy is not only very expensive, but it is also not green energy. Renewable energy is not available for purchase in the short-term market. Because Grayson Power Plant is unreliable currently, Glendale needs to reserve some of its transmission capacity for those short-term power purchases. This means that Glendale cannot allocate its limited and finite transmission rights to 100% renewable energy now. However, with a modern, repowered plant and sufficient local reserves, Glendale can enter into new long-term renewable energy contracts, committing its transmission to renewable imports rather than keeping those lines available for short term nonrenewable energy purchases to meet load, or using those lines for firming and shaping energy.

6 2. Relationship Between Integrated Resource Plan and Project

Several commenters refer to the 2015 Integrated Resource Plan (IRP) Report and contend that the IRP is outdated and/or that, for reasons stated in the IRP, the project is not necessary.

An !RP is an electric utility planning document, and is a snapshot in time based upon the data, information, understandings and considerations available at the time of its preparation. Some data, information, understandings, and considerations have changed since the 2015 IRP, and the City’s plans for the repowering have evolved as the City has completed more detailed analysis. Further studies and developments that have occurred since the IRP was published make it even clearer that the Project is necessary and appropriately sized to meet the City’s needs. Among other things, cost for transmission and balancing services have increased, new air quality rulemaking is now underway that will require major retrof its to the aging power plant equipment, and electric vehicle usages is projected to increase much more dramatically than was projected in the IRP.

3. Project Need

Commenters have questioned the need for and size of the power plant.

The size of the power plant is driven by the need to meet peak power demand even if the City’s two largest sources of power are not available. Glendale must have sufficient power to meet its peak load and to maintain sufficient reserve (backup) power capacity at the ready to go online if Glendale’s first and second largest generation sources are not available. Glendale’s all-time peak load was 346 MW, which occurred on September 1,2017. Therefore, for planning purposes, GWP plans for a 350 MW load. GWP’s power needs can be summarized as follows:

Maximum Load 350 MW Maximum Available Power w/o Project -287 MW Glendale’s Need wlo Covering Reserves: 63 MW Reserves Aequired: N-i or single largest contingency (Loss of DC Intertie) 100 MW N-i-i or second largest contingency (Loss of a Unit) + 71 MW Total Required Reserves: 171 MW

Glendale’s Total Need: 234 MW

The Project’s capacity is 262 MW, and on a 95 degree day, falls to 242 MW (and slightly less than that on a peak load day of 100 degrees plus). Therefore, with the Project, Glendale would be able to reliably serve energy needs on a peak load day and meet reserve requirements.

4. Project Alternatives

Comments were received that the Draft EIR did not analyze the right Project Alternatives.

Because the Project will not result in any significant environmental impacts after imposition of mitigation, the selection of alternatives focused on choosing alternatives that could potentially reduce environmental impacts as compared to the Project, while still feasibly attaining at least some of the Project objectives. The EIR analyzed a reasonable range of Project alternatives, including alternative energy sources, energy storage, and smaller power plants. In addition, the EIR includes detailed explanations as to why other alternatives were considered, but not selected for further analysis.

7 5. Renewable Energy

Several commenters expressed that the EIR should have considered alternative projects that would include all or more renewable energy sources, such as rooftop solar installations throughout the City, increased funding for solar rebates, or funding private solar development in Glendale with municipal bonds.

Glendale has a robust solar incentive program and encourages solar and renewable energy development within the City through a number of initiatives. However, Glendale cannot rely solely upon solar and renewable energy development to replace the Project and still meet Glendale’s energy supply needs.

In all the years that rooftop solar has been available, and with GWP incentives, Glendale now has approximately 14.7 MW of solar. Based upon methodology developed by the National Renewable Energy Laboratory, the IRP projected 35 MW to 40 MW of solar by 2030. Even if solar development was twice as much, it would not provide enough generation to meet Glendale’s needs. Municipal finance laws restrict the City’s ability to use GWP rate revenue to pay for everyone in Glendale to have a solar roof, either through incentives, or bond financing. Since the Grayson Power Plant is projected to cease operating by the early 20205, it would imprudent from a reliability perspective to count on enough solar being built quickly enough to fully meet Glendale’s needs.

Glendale has considered utility-scale solar developments within the City, but does not have sufficient land under its control for a project of the size that would be needed to meet Glendale’s energy needs.

Glendale continues to evaluate and pursue solar and renewable energy opportunities both within and outside of Glendale. The repowered Grayson, with its more flexible generation units, will assist Glendale with integrating more and more variable renewable resources without causing impacts on the energy grid.

6. Deferring the Repowering

Comments were received that Glendale should continue operating the Grayson Power Plant for the foreseeable future, or at least until there is sufficient demand reduction or aTternative technologies available such that no plant, or a smaller plant, will be required. Commenters expressed doubt that the Grayson Power Plant cannot continue to run without proper maintenance.

The Grayson Power Plant is well beyond its useful life, and despite continued, costly, ongoing efforts to maintain it, the plant experiences frequent unplanned outages and is not expected to remain in service (other than Unit 9) beyond the early 2020s. In addition, new SCAQMD air quality regulations will require that the plant undergo costly air quality retrofits, or cease operations, within the next few years. The City has commissioned numerous studies over the years regarding appropriate measures to keep the plant running. Each of those studies recognized that the plant is beyond retirement age and needs to be repowered in the near future. Despite the City’s extensive efforts to keep the plant alive, in keeping with the maintenance recommendations in those studies, the plant cannot continue to operate much longer. The repowering must occur imminently in order for the City to be able to continue to reliably serve power to its customers.

8 7. Demand Management

Comments were received that the City should consider demand management as an alternative to the Project.

The City has in place many demand management strategies and programs. Since 2000, the City has invested over $46 million on energy efficiency and demand management programs to benefit its customers. Each year, the City has successfully met and exceeded its energy efficiency targets, which are consistently among the top targets among all publicly-owned utilities in the State. However, Glendale’s peak load of close to 350 MW was achieved even with GWP’s comprehensive demand management and energy efficiency measures in place. While the City has and will continue to set and achieve ambitious energy efficiency goals and implement demand management strategies, GWP cannot rely solely on energy efficiency and demand management to ensure that a reliable supply of energy is available for Glendale customers on peak days. Energy efficiency and demand response programs are part of an integrated plan that includes the Project.

8. Air Quality and Public Health

Several commenters expressed concern that the Project will increase harmful air emissions.

The EIR contains an extensive analysis to confirm that the Project will comply with all applicable local, state and federal air quality regulations. It is important to note that the emissions analysis in the BR was based upon the very conservative methodology used by the SCAQMD for permitting purposes. This SCAQMD methodology looks at the worst-case scenario emissions from the Project, assuming all four of the units will be running all the time, with the maximum starts and stops, and that all annual maintenance operations will occur on one day. The SCAQMD methodology also assumes that the actual emissions from the current plant are lower than they actually are. That is, a discounting factor is applied to the current, actual emissions from the plant.

Therefore, the SCAQMD methodology assumes the extremely unlikely, worst case possible emissions from the Project, and compares this to an assumed ‘baseline” level that is lower than the actual emissions from the current plant.

Even using this conservative approach, the emissions levels are below significance thresholds. The South Coast Air Quality Management District has confirmed this conclusion.1

When the realistic, expected emissions from the Project are compared to the actual, current emissions at the power plant, the emissions from the Project will be lower than the current emissions at the plant.

The new equipment at the repowered plant will be substantially more efficient, and will use less fuel. This will minimize emissions from combustion of fuel. For example, for PM1O, PM2.5and SO,~, the Project will reduce emissions by approximately 50% to 90% on a pound per megawatt hour basis. For NOR, CO and VOC, emissions rates will be decreased by 85% to 97% compared to the operation of the existing power generating equipment.

See February 20, 2018 South coast Air Quality Management District Memorandum entitled “Modeling Review of Glendale Department of water and Power’s Grayson Power Plant (Facility ID 800327),” attached to this Report as Attachment 1.

9 With regard to the health risk of the Project, the highest increase in cancer risk attributed to the Project is less than one in one million. This is below the significance threshold of 10.0 in on million established by SCAQMD and the Office of Environmental Health Hazard Assessment (“OEHHA”). The repowered plant will also significantly reduce the health risk rates and exposures compared to the existing plant.

9. Greenhouse Gas Emissions

Comments were received that the Project will increase greenhouse gas emissions.

Greenhouse gas emissions depend largely upon fuel type and equipment fuel efficiency. The proposed new equipment for the Project is more efficient than existing equipment. The Project

will result in lower greenhouse gas emissions on a ton per MWh basis -- less than half the rate of the current power plant.

As with the air emissions, the EIR used a conservative analysis to calculate baseline greenhouse gas emissions from the Project. The analysis assumed that landfill gas will continue to be combusted at a different location even after the repowering. This conservative methodology ensures that the net increase in greenhouse gas emissions due to the project is not understated.

Additionally, the City is required to comply with the state Cap-and-Trade program by reporting CO2 emissions from the Grayson power plant. One hundred percent of the GHG emissions from the combustion equipment must be offset.

10. Liquefaction

Commenters expressed concern that the Project is within a mapped liquefaction zone and that the Grayson Power Plant is likely to be destroyed in the event of a major earthquake event, leaving the City without power.

The Project will be designed in accordance with the latest engineering and building code standards. For example, the Project will incorporate 55-foot long piles that provide the necessary support in the dense and stiff alluvial soils below the liquefiable zone. These standards are specifically designed to mitigate against the impact of constructing within a liquefaction zone and are designed to ensure the structural integrity of the structures and foundations at the Project site.

It should be noted that the existing Grayson Power Plant, which has been on the site and operated since the 1940s, is not designed to today’s seismic standards. The Grayson Power Plant did not suffer major damage during the 1971 San Fernando and 1994 Northridge earthquakes and was able to come back online and return power to Glendale customers, including critical facilities, quicker than other utilities in Southern California.

11. Relationship to Biogas Renewable Project

Comments were received that the Project and the Biogas Renewable Generation Project must be analyzed as one project. The Biogas Renewable Generation Project is not part of, or the same as, or a direct or reasonably foreseeable consequence of, the Grayson Repowering Project. The Grayson Repowering Project does not compel or presume completion of the Biogas Renewable Generation Project. The Project and the Biogas Renewable Generation

10 Project are distinct facilities that serve different purposes and neither Project depends upon the other. The Project could proceed or be abandoned with or without the Biogas Renewable Generation Project because landfill gas at Scholl Canyon can be flared under a permit from the SCAQMD. The Biogas Renewable Generation Project could be developed with or without the repowering of Grayson, and it could be abandoned whether or not the Project is approved and implemented.

12. Environmental Justice

Comments were received that the area surrounding the Project site is designated by the California Environmental Protection Agency as a disadvantaged community and therefore, the Project raises environmental justice concerns.

The EIR considered environmental justice impacts of the Project. Environmental justice populations are those areas where the minority of low-income population percentage is meaningfully greater than the minority or low-income population percentage in the general population. Based upon this analysis, the EIR determined that the Project would not disproportionately affect a low-income or high-minority population. Neither Glendale as a whole nor the census tracts in the Project area would meet the criteria for designation as an environmental justice community under CEQA.

The California EPA’s environmental justice analysis uses different criteria than those used in a CEQA analysis. The CaIEPA designation is designed to identify disadvantaged communities for purposes of allocating funding under the Cap and Trade program. Based upon the CaIEPA’s analysis, much of Glendale and the greater Los Angeles area are considered a disadvantaged community. This CaIEPA designation means that Glendale qualifies for funding under the California Cap-and-Trade program, but this designation alone is not indicative of environmental justice concerns.

13. Puente Power Project

Several commenters note that the California Energy Commission is proposing to deny a permit for a gas-fired power plant to serve Southern California Edison customers because clean energy sources can meet local capacity requirements. Commenters note that the state is moving away from fossil fuels and that there is a “glut” of fossil fuel power plants already.

Grayson and the Puente Power Project are different. Puente is an independent power producer supplying energy to the broader, interconnected California Independent System Operator (CAISO) transmission system. Glendale is not a part of the CAISO system and does not have access to CAISO transmission resources or to any “glut” of power generation sources at the end of those transmission lines. Glendale’s transmission import rights are extremely limited. In addition, the Puente Project represents 1% of Southern California Edison’s peak load. By contrast, Grayson represents 89% of Glendale’s peak load. Not repowering Grayson would have a much more dramatic impact than deferring the repowering of La Puente.

14. LADWP Moratorium on Rebuilding of Gas Plants

Comments were received that LADWP has put all planned local repowering projects on hold until it completes a system-wide study to analyze the need for repowering and to identify all viable alternatives to repowering. The commenters suggest that Glendale should similarly delay the repowering of the Grayson Power Plant.

11 Glendale and LADWP are not similarly situated. LADWP has a large electrical system with multiple plants and flexibility to meet peak demand. LADWP has already completed extensive program to repower its in-basis thermal power plants and has the flexibility of placing a moratorium on new repowering projects. By contrast, Glendale is relying on a single power plant that is well past its useful design life, Glendale has very limited transmission import capabilities, and is more vulnerable compared to LADWP other southern California electric utilities.

Moreover, in the past, Glendale has relied upon LADWP to purchase emergency supplies of energy when Glendale has been short on power. LADWP’s hold on new repowering proiects, which potentially delays or reduces LADWP’s ability to generate surplus energy, may pose an

additional risk element for Glendale in the future as to the availability of emergency power — this is particularly the case if the Project is not completed and Glendale’s need for emergency energy is even greater than it is now.

15. Comments Requesting an “Independent” Consultant

Several commenters requested that the City put the Project on hold and retain an independent consultant with strong clean energy credentials to conduct an independent study of clean energy alternatives for powering Glendale. Comments were also received that PACE Global Energy Services, Inc., the firm that prepared the IRP, has a conflict of interest and skewed the results of the IRP in favor of a 250 MW power plant recommendation because it is a subsidiary of Siemens Industry, Inc., the parent company of Siemens Energy, Inc., the company providing the proposed power equipment at Grayson.

The consultants retained by the City, PACE Global Energy Services, Inc. (“PACE”) and Stantec were selected by the City following a competitive Request for Proposal (RFP) process. PACE is an independently operated subsidiary of Siemens Industry, Inc. PACE’s contract to prepare the IRP was a fixed-fee contract not related to any future work or proposals. In fact, in preparing the IRP analysis, PACE used General Electric power plant equipment in its assumptions for a repowering. Further, the selection of Siemens Energy Lnc. as the power equipment vendor occurred only after a competitive RFP and a rigorous evaluation of nine proposals received from two vendors (General Electric and Siemens Energy, Inc.). While Siemens was the successful vendor, it is also worth noting that Siemens’ parent provides many services and products, including not only geothermal products but also energy storage and renewable energy products such as biomass, wind, and hydropower.

The recommendation of the IRP to repower Grayson did not occur in a vacuum or solely from the consultant that prepared the IRP. PACE is one of many consultants that the City has retained over the years to objectively evaluate the condition of the Grayson Power Plant and to assess the best approach for GWP to continue to reliably meet the City’s electricity needs. Each of these consultants reached the same conclusion that a repowered Grayson Power Plant is necessary. Furthermore, the City employs professional engineers and other energy industry professionals who remain updated on emerging trends in the industry, including review and analysis of reports and papers prepared by renewable energy consultants, including the consultants referenced by commenters. GWP continues to implement, pursue, and promote renewable and conservation measures and is a leader among California utilities for its renewable portfolio and energy efficiency programs. GWP staff and management — current and past — have significant experience in issues pertaining to reliability and integrated resource management and have the ability and experience to independently assess the credibility of the recommendations of the IRP.

12 With respect to the EIR consultant, the City retained Processes Unlimited Inc. (now Stantec), to prepare the Draft EIR for the Project, following a competitive REP process. While some commenters contend that Stantec does not have strong clean energy credentials, Stantec is a large, multi-national environmental and engineering company founded in 1954 with substantial experience in both conventional and renewable energy projects. Stantec collaborates across disciplines and industries on energy and resource, environmental, water and infrastructure projects.

In addition, City planning, legal and GWP staff have been an integral part of the EIR process since the beginning, and have independently reviewed, evaluated, and exercised judgment over all documentation prepared by Stantec with respect to the Draft and Final EIR.

Retention of another consultant to further study the City’s clean energy alternatives will delay the Project, will cause the City to re-incur development costs, and will ieopardize the City’s electrical reliability. In addition, it is not likely to change the conclusion that many independent consultants have already reached: Grayson must be modernized in order to ensure a reliable source of power for Glendale businesses and residents. Modernizing the 40- to 70- year old units with cleaner-burning, up-to-date, energy-efficient technology is essential in order for Glendale to reliably meet the energy needs of the City, both in the near term and in the long term.

16. Comments Suggesting Potential State Legislation Will Make the Power Plant Obsolete

Several commenters noted that the State is considering legislation that could increase the percent of required renewable energy in a utility’s portfolio to 100% by 2045.

The EIR considered the potential for the adoption of a 100% renewable energy standard by the State. Such legislation has not been adopted to date, and the details of such potential legislation, including potential grandfathering of existing assets, have yet to be determined. As stated in the Final EIR, the Project is part of an integrated plan to increase the amount of renewable energy in Glendale’s portfolio, and the Project is necessary even as the State moves towards a higher renewables portfolio standard (RPS) requirement. GWP currently exceeds renewables energy portfolio standard requirements and routinely sets and achieves among the highest energy efficiency targets in the State. GWP will continue to comply with all regulatory requirements, including RPS. The Project will allow Glendale to free up its limited transmission assets to import renewable energy, will allow Glendale to firm and shape imported renewables, and will enable GWP to manage fluctuations in load from an increasing amount of solar generation. Additionally, repowering the obsolete units at the power plant with cleaner-burning, up-to-date energy efficient technology is essential in order for Glendale to reliably meet the energy needs of its businesses and residents in the near term and the short term. The current plant is not expected to remain operational beyond the early 2020s.

EIR Analysis of Alternatives

As part of the CEQA analysis, the City considered a number of alternatives, with more in-depth evaluation of the following:

• No Project Alternative — Older, less efficient equipment at Grayson would continue to operate as long as maintenance is still feasible and economic, and when maintenance is no longer practical, would be shut down.

• Energy Storage Project Alternative — This alternative would use existing City electrical generation and transmission capacity to serve the City’s electrical load, and

13 charge batteries when excess capacity is available. Energy stored in the batteries would then be discharged to serve the electrical load when demand exceeds the combined capacity of Unit 9 at Grayson, electricity imports from Magnolia Power Plant, and available transmission.

• Alternative Energy Project Alternative — a project with some combination of photovoltaic power production or wind power production with energy storage and transmission lines.

• 150 MW Project Alternative — a reduced size power project located on the existing project site with a new transmission interconnection.

• 200 MW Project Alternative — a reduced size power projected located on the existing site with a battery energy storage system.

The City has considered the environmental impacts of each of the alternatives and the extent to which the alternatives feasibly meet the Project objectives. The EIR determined that the proposed Project would meet all project objectives while resulting in the fewest impacts when compared to the feasible alternatives, and is considered the environmentally superior alternative. The 200 MW Alternative would meet most of the Project objectives, but not to the same extent as the Project. The remaining alternatives would not meet several of the Project objectives.

GWP Commission

The GWP Commission considered the Final Environmental Impact Report and the Project in a public meeting on April 2, 2018. The GWP Commission recommended that the City Council take no action on the certification of the Final EIR and further recommended that the City Council direct GWP staff to issue a Request for Information, relating to market input for additional alternatives that would reduce the carbon footprint of the Grayson Power Plant, to be completed in no later than 90 days. The GWP Commission’s April 2, 2018 motion is attached to this report as Attachment 2.

Recommended Action

GWP recommends that the City Council certify the Final EIR. Certification of the Final BR is a prerequisite to approving a project or any alternative to a project. Provided that the City Council certifies the Final EIR, it is recommended that the City Council adopt a resolution approving either the Project, or a Project Option, and direct staff to take actions in support thereof. Some of the options available to the City are discussed below.

Option 1: Approval of the Project

Approval of the Project would authorize and direct City staff to proceed with the four-unit, 262 MW Project as described in the EIR. Subject to the City Council’s approval in a future meeting or meetings, staff would implement the following Project actions:

• Issue bids for electric revenue bonds for the Project, prepare bond documentation, and seek City Council adoption of a bond ordinance; • Issue a Final Notice to Proceed to Siemens Energy, Inc. to proceed with the manufacture and procurement of the major equipment (the power island equipment); • Following City Council award, enter into a contract to an Engineering, Procurement and Construction contractor to proceed with the engineering, procurement of balance of plant equipment, and construction of the Project;

14 • Solicit bids for the demolition of the Grayson Power Plant and following award, enter into a contract for the demolition contract; • Execute contracts for the purchase of emissions reduction credits for the Project.

Option 2: Approval of a 191 MW Plus Battery Project

By approving this option, the City Council would authorize and direct City staff to proceed with implementation of a three-unit, 191 MW plant plus a 50MW battery storage system. This option was analyzed as the 200 MW plus storage alternative in the EIR.2 Approval of Option 2 does not require City Council to undergo further analysis under CEQA; the certification of the EIR allows the City Council to proceed with this alternative.

Subject to the City Council’s approval in a future meeting or meetings, staff would implement the same actions as specified under Option 1, with the following changes:

• The electric revenue bonds would cover a 191 MW Plus Battery Project Alternative, instead of a four-unit, 262 MW Project. • The Final Notice to Proceed issued to Siemens Energy, Inc., would direct Siemens to manufacture and deliver three power island equipment units instead of four. Specifically, Glendale would purchase one combined cycle unit and two simple cycle units. This would reduce the cost of the equipment purchase by $35,631,996. • City staff would issue bids for the procurement of a 50 MW battery storage system. • The City would negotiate with prospective EPC Contractors for the costs of designing a three-unit plus battery project, in lieu of the four-unit Project. The EPC bidders have already provided pricing for the deduction of one combined cycle unit from the scope of work. • A reduced number of emissions reduction credits would be purchased.

This option would meet many of the City’s objectives, but would not do so as well as the Project. The City would forego a dispatchable generating unit that if needed, can operate for an extended time. By contrast, a battery has a finite supply of electricity. Once the battery is exhausted, it must be recharged. With the 191 MW plus with battery option, the City would be able to cover the N-i contingency with some reserves, but not the N-i-i contingency during peak load periods.

Option 3: Approval of a 131 MW Plus Battery Project

By approving this option, City Council would authorize and direct City staff to proceed with implementation of a two-unit, 131 MW plant plus a 50 MW battery storage system. Subject to the City Council’s approval in a future meeting or meetings, staff would implement the same actions as specified under Option 1, with the following changes:

• The electric revenue bonds would cover a 131 MW Plus Battery Project, instead of a four-unit, 262 MW Project; • The Final Notice to Proceed issued to Siemens Energy, Inc. would direct Siemens to manufacture and deliver three power island equipment units instead of four. This would reduce the cost of the equipment purchase by $56,936,117. • City staff would issue bids for the procurement of a 50 MW battery storage system.

2 Because power units are only available in standard sizes, the actual size of a 3-unit project is slightly smaller than 200 MW.

15 • The City would negotiate with prospective EPC Contractors for the costs of designing a two-unit plus battery project, in lieu of the four-unit Project. The EPC bidders have already provided pricing for the deduction of one combined cycle unit from the scope of work; pricing for the deduction of another unit would be obtained. • A reduced number of emissions reduction credits would be purchased.

This option is not recommended because while Glendale would be able to serve the peak load and cover the N-i contingency, it would have to fully commit all resources to serving peak load, and would have no remaining reserves.

Option 4: “No Project” Option

The “No Project” Option would mean that the City would not proceed with any Project, but would continue to utilize the existing Grayson Power Plant, to the extent that it continues to function, to serve the City’s power needs. City staff does not recommend this option, for several reasons, including the following:

• The existing Grayson Power Plant is well beyond its useful life and can no longer reliably serve the City’s energy needs. • The existing Grayson Power Plant is experiencing an increasing frequency in unplanned and forced outages. • Failure to repower Grayson will require GWP to undertake costly, ongoing repair and maintenance work with little benefit, given the age of the units and their propensity to fail. • Forthcoming SCAQMD regulations will require expensive air quality retrofits, or require the plant to shut down, by 2023. • The health risk of the existing Grayson Power Plant far exceeds the health risk of the proposed Project. • The existing plant units do not have the flexibility to adiust rapidly to meet fluctuations in voltage from solar and renewable energy. This puts the reliability and stability of the electric system at risk. • GWP has limited transmission rights and cannot meet its energy needs Without a local source of generation.

Option 5: “Pause” the Project and Conduct Additional Study

A number of commenters have proposed “pausing” the Project and retaining independent consultant to evaluate clean energy alternatives. City staff does not recommend this option.

With a “pause,” GWP estimates that the repowering would not be completed until six years from now. The repowering of the power plant will take three years from demolition until commissioning. GWP estimates that “pausing” the project to commission an independent study adds three years to the Project schedule; one year to issue a Request for Proposals for an “independent” consultant, contract with the independent consultant, complete the study, evaluate the results, and review the conclusions with City Council, one year of engineering and procurement, and one year to apply for and obtain air quality permits and complete environmental reviews. In the meantime, maintenance costs will continue. Expensive spot market purchases during unexpected outages will continue. Ancillary service payments to LADWP will continue and increase in the future, and reliability concerns will not be addressed.

Failure to take action to modernize the aging Grayson Power Plant creates risk for the City. If the project or a project option is put on hold, the City will continue to have an unreliable power

16 plant and GWP’s ability to continue to reliably serve power to the residents and businesses of the City of Glendale would be at risk. Without a reliable power plant, GWP must go out to the market and make emergency energy purchases to meet load when it is hot, and hope that the transmission lines do not fail. In addition, GWP must reserve some of its transmission for spot

market purchases — not renewable energy — because GWP needs to meet load. Not having a reliable power plant means that GWP must continue to pay LADWP to supply reserve capacity and ancillary services, and GWP must continue to curtail its use of its transmission assets. In addition, SCAQMD regulations are expected to require expensive retrofits to the existing Grayson units, or require their shut down, no later than 2023.

The City is a leader among California cities in terms of its renewable and zero carbon energy use and has, and will continue to have, a successful energy efficiency program, solar energy incentives, and renewable procurement strategy. The Project will not change that. The City has undertaken a substantial and thorough analysis of clean energy alternatives in the EIR and has considered, analyzed and responded to all questions, comments, and suggestions regarding clean energy alternatives. The Project is proposed not as an alternative to clean energy, but rather as a component of GWP’s clean energy strategy.

“Pausing” the move towards a repowered Grayson would substantially delay the Project and would cause the City to incur additional cost. For example, while the City has no contractual obligation to proceed with issuing a Full Notice to Proceed with the manufacture and procurement of the power island equipment, the equipment prices are subject to a $348,000 monthly escalation factor if the Full Notice to Proceed with manufacture of that equipment is not issued by May31, 2018. This equates to a $2 Million additional cost if the project is delayed six months. A redesign of the Project would cause the City to re-incur engineering costs, new environmental review costs, the cost and time of new procurement processes (at the risk of receiving fewer and higher cost bids), and would require the City to go through a new permitting process with the SCAQMD. The City estimates that this would cause the City to incur an additional $4 Million in engineering and EIR preparation costs, plus additional costs to redo the structural and foundation work for the power island equipment. The City would lose the benefit of engineering costs already undertaken, including $8 Million for engineering, environmental, permitting, legal and financial, plus $3.8 Million incurred for the limited notice to proceed issued to support permitting and the preparation of a Request for Proposals for the EPC Contractor. With regard to the Engineer, Procure Construct Contractor procurement, the proposals have been received but not awarded; proposals will expire on June 13, 2018.

Accordingly, City staff recommends that the City Council certify the Final EIR and direct City staff to proceed with Option 1 or Option 2 as described herein.

FISCAL IMPACT There is no fiscal impact resulting from certification of the Final EIR. If the City Council adopts a resolution approving the Project or a Project Option, the City will incur costs related to the development of the Project or the Project Option. The cost of the Project Option will depend upon which option the City Council elects to pursue. Cost estimates for each of the Options are provided below. Detailed costs will be presented to City Council in connection with the City Council’s consideration of bond financing for the Project or Project Option.

Fiscal Impact of Option 1: The estimated cost of the Project is $500 million. GWP proposes to fund the project through the issuance of bonds. The current Grayson Power Plant is costly to run due to the age and inefficiency of the units, and the need to undertake frequent and expensive repairs to keep the units running. Additionally, when the units unexpectedly fail, GWP pays a premium to purchase power in the spot or real-time market. GWP also pays

17 LADWP to provide required reserves to meet contingencies, rather than being able to self- supply reserve power that would be possible with a repowered plant.

Based upon the improved plant efficiencies, and avoiding the cost of paying LADWP to supply reserves, the Project is projected to have no cost impact on GWP’s customers. The Project funding does not rely on, or contempTate, any sales of excess power to other entities. The Project is sized to meet load and reliability obligations and not for sales of energy third parties.

Fiscal Impact of Option 2 (191 MW Plus Battery Proiect): The estimated cost of the 191 MW Plus Battery Project is $461 Million. If the City Council elects to proceed with this option, GWP proposes that the 191 MW Plus Battery Project would be funded the project through the issuance of bonds.

Fiscal Impact of Option 3 (131 MW Plus Battery Proiect): The estimated cost of the 131 MW Pius Battery Project is $411 Million. If the City Council elects to proceed with this option, GWP proposes that the 131 MW Plus Battery Project would be funded the project through the issuance of bonds.

Fiscal Impact of Option 4 (No Proiect Option): The no project option exposes the City to the risk of not being able to continue to reliably serve power to the residents and businesses of the City of Glendale. The future costs of maintaining the power plant, until it fails or must be taken offline due to SCAQMD regulations, cannot be precisely quantified. However, past maintenance expenses are an indicator of future costs. Over the past five years, the total cost to maintain Units 1 through 8BC has been $56 Million, or approximately $11.6 Million per year (excluding Unit 9 maintenance costs). In addition, GWP will continue to incur spot market purchases for replacement power, payments to other utilities for ancillary services. Forced outages and repair costs will continue, and GWP will face significant costs for emissions control upgrades. The effect on rates is unknown.

Fiscal Impact of Option 5 (“Pause” the Proiect and Conduct Further Study): Pausing the Project would set the Project schedule back by up to 3 years and would result in an estimated fiscal impact of $17.8 Million, including additional development costs, the loss of the benefit of the development costs already incurred, and the increase in power island equipment price, as detailed above under Option 5. As with Option 4, forced outages and repair costs will continue, GWP will continue to incur spot market purchases for replacement power and payments to other utilities for ancillary services.

ALTERNATIVES Alternatives with respect to Resolution # 1 (EIR Certification): Alternative 1: Council may certify the Final EIR for the proposed Grayson Repowering Project. Alternative 2: The City Council may decline to certify the EIR for the proposed Grayson Repowering Project.

Alternatives with respect to Resolution # 2 (Approval of Proiect or Alternative): Alternative 1: Provided that the City Council certifies the Final EIR for the Project, the Council may approve the Project and direct staff to proceed with actions in support thereof. Alternative 2: Provided that City Council certifies the Final EIR for the Project, Council may approve any project option that have the same or less impact as the Project and direct staff to proceed with actions in support thereof.

18 Alternative 3: Provided that City Council certifies the Final EIR for the Project, The City Council may consider any other option not proposed by staff.

Additionally, or in the alternative, the City Council may adopt a motion providing direction to staff.

CAMPAIGN DISCLOSURE Not applicable.

EXHIBITS Attachment 1: February 20, 2018 South Coast Air Quality Management District Memorandum entitled “Modeling Review of Glendale Department of Water and Power’s Grayson Power Plant (Facility ID 800327)” Attachment 2: Glendale Water & Power Commission Motion dated April 2, 2018 Attachment 3: Correspondence pertaining to the Draft EIR or Final EIR received by the City following the close of the public comment period

19 RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT (SCH No. 2016121048) FOR THE GRAYSON REPOWERING PROJECT

WHEREAS, the Final Environmental Impact Report (State Clearinghouse No. 2016121048), for the Grayson Repowering Project (the “Final EIR”) has been prepared and consists of: (a) the Draft Environmental Impact Report (“Draft EIR”), inclusive of all appendices and exhibits, dated September 15, 2017; (b) a list of persons, organizations, and public agencies commenting on the Draft EIR; (c) the Comments to the Draft EIR; (d) the Responses to Comments to the Draft ER; and (e) revisions to the Draft EIR (collectively compiled into a consolidated Final EIR, dated March 1, 2018); and

WHEREAS, the Final EIR has been completed in conformance with the California Environmental Quality Act, Public Resources Code Section 21000 etseq. (“CEQA”), Title 14 of the California Code of Regulations, Section 15000 etseq. (“State CEQA Guidelines”), and the Guidelines of the City of Glendale for the Implementation of the California Environmental Quality Act of 1970, as amended (“City CEQA Guidelines”); and

WHEREAS, on April 2, 2018, the Glendale Water and Power Commission held a duly-noticed public meeting on the Final EIR and recommended that the City Council of the City of Glendale (“City Council”) not certify the Final EIR at this time; and

WHEREAS, the Final EIR has been presented to the City Council and the City Council has held a duly-noticed public hearing on the Final EIR; and

WHEREAS, the City Council has reviewed and considered the information and testimony presented at the public hearing, including the written documentation from staff, the recommendation of the Glendale Water and Power Commission, and others; and

WHEREAS, the City Council wishes to certify that: (1) the Final EIR has been completed in compliance with CEQA and the State and City CEQA Guidelines; (2) the City Council has reviewed and considered the information contained in the Final EIR; and (3) the Final EIR reflects the independent judgment and analysis of the Lead Agency for this Project, which is the City of Glendale. I’l l’’

~1 F:/filenetcopy/council Reports/ 041018 Resolution Certifying the Final EIR for the Grayson Repowering Project 9A1 NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Glendale, California that it hereby certifies that: 1. The Final Environmental Impact Report (State Clearinghouse No. 2016121048), for the Grayson Repowering Project (“Final EIR”) has been completed in compliance with CEQA and the State and City CEQA Guidelines; and.

2. The Final EIR has been presented to the City Council at a duly-noticed public hearing and the City Council has independently reviewed and considered the information contained in the Final EIR; and

3. The Final EIR reflects the independent judgment of the City of Glendale as the Lead Agency for the Grayson Repowering Project.

BE IT FURTHER RESOLVED, that the custodian of the Final ElR and all materials which constitute the record shall by the Planning Department of the City of Glendale at 633 East Broadway, Glendale, California.

Adopted this ______day of 2018.

Mayor

ATTEST:

City Clerk

ASTO FORM

2 F:)filenetcopy/Council Reportsf 041018 Resolution certifying the Final EIR for the Grayson Repowering Project STATE OF CALIFORNIA SS COUNTY OF LOS ANGELES

I, Ardashes Kassakhian, Clerk of the City of Glendale, certify that the foregoing

Resolution No. ______was adopted by the Council of the City of Glendale,

California, at a regular meeting held on the ______day of ______2018, and that same was adopted by the following vote:

Ayes:

Noes:

Absent;

Abstain:

City Clerk

3 F:ffilenetcopy/Council Reports/ 041018 Resolution certifying the Final LIR for the Grayson Repowering Project RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA MAKING CERTAIN FINDINGS AND DETERMINATIONS REGARDING THE ENVIRONMENTAL EFFECTS OF THE GRAYSON REPOWERING PROJECT AND APPROVING A MITIGATION MONITORING AND REPORTING PROGRAM

WHEREAS, the City of Glendale Department of Water and Power proposes to repower the existing Grayson Power Plant by replacing 235 MW (gross) of the existing capacity from the boiler units (Units 3, 4, 5) and combined-cycle units (Units 1, 2, 8A and 8BC3) with more efficient generation. The Proposed Project would comprise two 71 MW (net) combined-cycle units and two 60 MW (net) simple-cycle units; and

WHEREAS, a Draft Environmental Impact Report (“Draft EIR”) for the Proposed Project was prepared and circulated on September 15, 2017 for a 45-day public review period pursuant to the California Environmental Quality Act, Public Resources Code Section 21000 etseq. (“CEQA”), Title 14 of the California Code of Regulations, Section 15000 etseq. (“State CEQA Guidelines”), and the Guidelines of the City of Glendale for the Implementation of the California Environmental Quality Act of. 1970, as amended (“City CEQA Guidelines”), which was subsequently extended for an additional 21 days, for a total public review period of 66 days; and

WHEREAS, notice was duly provided to the public, government agencies, and all other interested parties that they may submit written comments on the Draft EIR to the Cityon or before November 20, 2017; and

WHEREAS, a Final Environmental Impact Report for the Proposed Project, State Clearinghouse No. 2016121048 (“Final EIR”), was prepared in conformance with CEQA, the State CEQA Guidelines, and the City CEQA Guidelines and released on March 1, 2018, and incorporated into the Draft EIR and included written responses to comments made during the CEQA public review period; and

WHEREAS, on April 2, 2018, the Glendale Water and Power Commission held a duly-noticed public meeting on the Final EIP and recommended that the City Council of the City of Glendale (“City Council”) not certify the Final EIR at this time; and

WHEREAS, after due notice, on April 10, 2018, the City Council conducted a public hearing on this maffer at which it reviewed and considered the information contained in the Final EIR as well as supplemental responses and information; and

WHEREAS, on April 10, 2018, the City Council certified that (I) the Final EIR has been completed in compliance with CEQA and the State and City CEQA Guidelines, (U)

1 F:/tilenetcopyfcouncil Reports/041018 Resolution Making Findings and approving MMRP.docx gA2 the Final EIR has been presented to the City Council at a duly-noticed public hearing and the City Council has independently reviewed and considered the information contained in the Final EIR, and (Hi) the Final E!R reflects the independent judgment of the City of Glendale as the Lead Agency.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Glendale, California that:

1. Each and all of the Findings and Determinations contained in this document are based upon competent and substantial evidence, both oral and written, contained in the entire record relating to the Project and the Final EIR. The Findings and Determinations constitute the independent Findings and Determinations of the City Council in all respects and are fully and completely supported by substantial evidence. All of the language included in this document constitutes findings by the City Council, whether or not any particular sentence or clause includes a statement to that effect.

2. All summaries of information and the Findings to follow are based on the Final EIR and/or other evidence in the record. The absence of any particular fact from any such summary is not an indication that a particular finding is not based in part on that fact. The summaries of information below are only summaries. Cross-references to the Final EIR and other evidence in the record have been made where helpful, and reference should be made directly to the Final ElR and other evidence in the record for more precise information regarding the facts on which any summary is based. In addition, unless noted or stated otherwise, the rationale for the Findings is that set forth in the Final EIR (including the responses to comments) or elsewhere in the administrative record.

3. The following Findings are heieby adopted by the City Council as required by Public Resources Code Sections 21081, 21081.5, and 21081.6, and CEQA Guidelines Section 15091 and 15092, in conjunction with the approval of the Project. Significant impacts of the Project would be mitigated to a less-than-significant level pursuant to mitigation measures identified in the Final EIR. There is no resource areas for which a residual significant impact would occur. Specifically, CEQA Guidelines Section 15091 requires the City Council to make one or more of the following written findings:

a) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final ER. b) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

2 F:/tilenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx c) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR.

These Findings accomplish the following: (a) they address the potentially significant environmental effects identified in the Final EIR for the Proposed Project; (b) they incorporate all mitigation measures associated with these potentially significant impacts identified in the Final EIR; (c) they indicate whether the potentially significant impact is less-than-significant or whether the potential significant impact is avoided or reduced by the adopted mitigation measure; and (d) they address the feasibility of all project alternatives and mitigation measures identified in the Final EIR.

The City Council hereby adopts and incorporates, as conditions of approval to

Resolution No. ____ approving the Project, the mitigation measures set forth in the Findings below to reduce or avoid the potentially significant impacts of the Project, as well as certain less-than-significant impacts. In adopting these mitigation measures, the City Council intends to adopt each of the mitigation measures recommended in the Final EIR, except to the extent such mitigation measures are specifically rejected or modified by these Findings. In comments on the Draft EIP, a number of measures or project alternatives were suggested by various commenters as proposed additional mitigation measures or project alternatives. With respect to the measures or alternatives that were proposed in the comments, and not adopted by the Final EIR, the responses to comments in the Final EIR explain why the proposed mitigation measures are not recommended by the Final EIR for adoption. The City Council hereby adopts and incorporates by reference the reasons stated in the responses to comments contained in the Final EIR as its grounds for rejecting adoption of these proposed mitigation measures.

4. The Proposed Proiect

The City of Glendale Department of Water and Power (“GWP”) proposes to repower the existing Grayson Power Plant by replacing 235 MW (gross) of the existing capacity from the boiler units (Units 3, 4, 5) and combined-cycle units (Units 1, 2, 8A and 8BC3) with more efficient generation. The Proposed Project would comprise two 71 MW (net) combined-cycle units and two 60 MW (net) simple-cycle units

5. Environmental Review Process and Contents of the Final Environmental Impact Report

Absence of Significant New Information CEQA Guidelines Section 15088.5 requires a lead agency to recirculate an EIR for further review and comment when significant new information is added to the EIR after public notice is given of the availability of the Draft ER, but before certification of 3 F:/tilenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx the Final ER. New information added to an EIR is not “significant” unless the EIfl is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect that the project proponent declines to implement. The City recognizes that the Final EIR incorporates information obtained by the City since the Draft EIR was completed, and contains additions, clarifications, modifications, and other minor changes. The City approves incorporation of each of the refinements into the Project and finds that the refinements do not cause the Project to result in new or substantially more severe adverse environmental effects, or otherwise require recirculation of the ER. Various minor changes and edits have been made to the text and tables of the Draft ER, as set forth in the Final ER. These changes are generally of an administrative nature such as correcting typographical errors, making minor adjustments to the data, removing regulatory references not applicable to the Project, and adding or changing certain phrases to improve readability. The City finds this additional information does not constitute significant new information requiring recirculation, but rather that the additional information merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. In addition to the changes and corrections described above, the Final EIR provides additional information in response to comments and questions from agencies and the public. The City finds that information added in the Final EIR does not constitute significant new information requiring recirculation, but rather that the ad~fitional information clarifies or amplifies an adequate EIR. Specifically, the City finds that the additional information, including the changes described above, does not show that: (1) A new significant environmental impact would result from the Project or from a new mitigation measure proposed to be implemented. (2) A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted that reduce the impact to a level of insignificance. (3) A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it. (4) The Draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded. 4 F:/tilenetcopylcouncil Reports/041 018 Resolution Making Findings and approving MMRP.docx Based on the foregoing, and having reviewed the information contained in the Final EIR and in the record of City’s proceedings, including the comments on the Draft EIR and the responses thereto, and the above-described information, the City finds that no significant new information has been added to the Final EIR since public notice was given of the availability of the Draft EIR that would require recirculation of the Final EIR. Differences of Opinion Regarding the Impacts of the Proiect In making its determination to certify the Final EIR and to approve the Project, the City recognizes that there are a range of public opinion related to the Project need and environmental issues, involves several controversial environmental issues. The City has acquired an understanding of the range of this technical and scientific opinion by its review of the Draft EIR, the comments received on the Draft EIR and the responses to those comments in the Final EIR, as well as testimony, letters, and reports regarding the Final EIR and its own experience and expertise in assessing those issues. The City has reviewed and considered, as a whole, the evidence and analysis presented in the Draft EIR, the evidence and analysis presented in the comments on the Draft EIR, the evidence and analysis presented in the Final EIR, the information submitted on the Final EIR, and the reports prepared by the experts who prepared the ER, the City’s consultants, and by staff, addressing those comments. The City has gained a comprehensive and well-rounded understanding of the environmental issues presented by the Project. In turn, this understanding has enabled the City to make its decisions after weighing and considering the various viewpoints on these important issues. Accordingly, the City certifies that its findings are based on full appraisal of all of the evidence contained in the Final EIR, as well as the evidence and other information in the record addressing the Final EIR.

6. Impacts and Mitigation Measures These Findings provide the written analysis and conclusions of the City regarding the environmental impacts of the Project and the mitigation measures identified in the Final EIR and adopted by the City as conditions of approval for the Project. In making these findings, the City has considered the opinions of other agencies and members of the public, including opinions that disagree with some of the analysis used in the Final ER. The City finds that the determination of significance thresholds is a judgment within the discretion of the City; the significance thresholds used in the Final E!R are supported by substantial evidence in the record, including the expert opinion of the Final EIR preparers and City consultants and staff; and the significance thresholds used in the Final EIR provide reasonable and appropriate means of assessing the significance of the adverse environmental effects of the Project. Exhibit A attached to these findings and incorporated herein by reference, summarizes the environmental determinations of the Final ER about the Project’s 5 F:/filenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx environmental impacts before and after mitigation. This exhibit does not attempt to describe the full analysis of each environmental impact contained in the Final EIR. Instead, Exhibit A provides a summary description of each environmental impact, identifies the applicable mitigation measures described in the Final EIR, and states the City’s findings on the significance of each environmental impact after imposition of the applicable mitigation measures. A full explanation of these environmental findings and conclusions can be found in the Final ElR and these Findings hereby incorporate by reference the discussion and analysis in the Final EIR supporting the Final EIR’s determinations regarding the Project’s environmental impacts and mitigation measures designed to address those impacts. The City approves the Findings set forth in Exhibit A as its findings regarding the Project’s environmental impacts before and after mitigation. In making these Findings, the City ratifies, adopts, and incorporates the analysis and explanation in the Final EIR, and ratifies, adopts, and incorporates in these Findings the determinations and conclusions of the Final EIR relating to environmental impacts and mitigation measures, except to the extent any such determinations and conclusions are specifically and expressly modified by these Findings. 7. Basis for the City’s Decision to Approve the Proposed Project and Reiect the Other Alternatives the City Findings Relating to Alternatives In making these findings, the City certifies that it has independently reviewed and considered the information on alternatives provided in the Final EIR, including the information provided in comments on the Draft EIR and the responses to those comments in the Final ER. The Final ER’s discussion and analysis of these alternatives is not repeated in total in these findings, but the discussion and analysis of the alternatives in the Final ER are incorporated in these Findings by reference to supplement the analysis here. The City also certifies that it has independently reviewed and considered all other information in the administrative record. The City finds that the range of alternatives studied in the Final EIR reflects a reasonable attempt to identify and evaluate various types of alternatives that would potentially be capable of reducing the Project’s environmental effects, while accomplishing most of the Project Objectives. The City finds that the alternatives analysis and additional information provided in the response to comments in the Final EIR is sufficient to inform the City, agencies, and the public regarding the trade-offs between the degree to which alternatives to the Project could reduce environmental impacts and the corresponding degree to which the alternatives would hinder the achievement of the Project Objectives and other economic, environmental, social, technological, and legal considerations. In light of the alternatives analysis, the City requires implementation of the Project which is the Environmentally Superior Alternative other than the No Project Alternative.

6 F:/tilenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx As set forth in Part 2 above, the City has adopted mitigation measures that avoid or reduce the potentially significant environmental effects of the Project to a less-than- significant level. Accordingly, the City has determined to approve the Proposed Project instead of approving one of the alternatives, for the reasons set forth below and in the Final EIR. a. Proposed Proiect The Proposed Project is a 262 MW repowering of the Grayson Power Plant. The Proposed Project removes 238 MW gross (219 MW net) of existing generation equipment that is past the end of its useful life and replaces it with approximately 270 MW gross (262 MW net) efficient equipment. The current total generating capacity at the Grayson Power Plant is 286 MW gross (267 MW net). The Project would result in a Grayson Power Plant net generation capacity of 310 MW. The Repowering Project would consist of two independently operating simple- cycle natural-gas—fired combustion turbine power blocks, and two independently operating, one-on-one, combined-cycle natural-gas fired power blocks. Other equipment and facilities to be constructed and shared by the four power blocks include six natural gas compressors, a gas pressure control and metering station, two cooling towers, water treatment facilities, fire protection and emergency services, generator step-up transformers, other electrical switchgear and axillary transformers, a steam turbine generator building, and an operations and maintenance building. The Project would be constructed on approximately ten acres entirely within the footprint of the existing Grayson Power Plant and located within the City of Glendale’s Utility Operations Center. The Proposed Project is fully described in the Final EIR Section 3.0, Project Description. The Proposed Project isthe environmentally superior alternative because it has the least environmental impacts of any feasible alternative and is aligned with all of the Project objectives to the greatest degree. The Project will achieve the following benefits: • Maintain reliable service. • Keep rates affordable to Glendale customers. • Facilitate compliance with state regulations regarding renewable energy supplies mandated through the Renewable Portfolio Standards and greenhouse gas emissions without the need for new transmission lines. • Allow the City to meet its existing and future electrical demands even if Glendale is separated from existing interconnections with the electric grid. • Replace the aged, unreliable, less efficient, high maintenance steam boilers with new efficient and cleaner electricity generation technologies.

7 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx • Provide a locally controlled source of generation to minimize the City’s reliance on importing power from remote generation locations. • Support water conservation efforts by eliminating the use of potable water for generation purposes. The City hereby accepts the Proposed Project as feasible and indicates that it is environmentally preferable. b. No Proiect Alternative Under CEQA, a “No Project Alternative” compares the impacts of proceeding with a proposed Project with the impacts of not proceeding with the proposed Project. A No Project Alternative describes the environmental conditions in existence at the time the Notice of Preparation was published or some other supportable time period, along with a discussion of what would be reasonably expected to occur at the site in the foreseeable future, based on current plans and consistent with available infrastructure and community services. Under the No Project Alternative, the proposed repowering would not occur, and the project site would remain in its existing condition. The City hereby rejects the No Project Alternative as infeasible. The City could no longer meet its obligations as a load serving entity for its residents and customers, placing them at significant risk for decreased electrical system reliability and availability. Moreover, the No Project Alternative would not satisfactorily meet the Project objectives and would fail to comply with Federal and State reliability standards. While this alternative would avoid the Project’s potentially significant and significant unavoidable impacts and have less impact on all environmental topical areas, this alternative would not advance any of the project objectives. c. Energy Storage Proiect Alternative The Energy Storage Project Alternative involves an energy storage system that would be charged during times of the day when there is available transmission capacity not needed to serve the City’s load. The available energy would be stored and “time shifted” to be used during high load periods when the available transmission capacity is inadequate to serve the City’s load. In this Alternative, which presumes all Units, but Unit 9 will ultimately be shut down, the City would use the available 48 MW (net) from Unit 9, 39 MW from the Magnolia Power Plant, and 200 MW imported over transmission lines from outside of the City. This would provide the City a total supply of 287 MW, which is less than the City’s peak loads. With the NERC required planning assumption that the single largest source of power will unexpectedly cease to be available (an event known in the power industry as “the loss of the single largest contingency”) which would be losing the 100 8 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx MW delivered to Glendale over the Pacific DC Intertie transmission line), available capacity would fall to 187 MW increasing the shortfall in capacity. The Energy Storage Project Alternative was described as reducing certain localized impacts, but also increasing certain impacts due to the additional night-time generation needed to charge the batteries, when renewable solar energy will not be available. Additionally, as discussed in Section 5.2.2.1 of the Final EIR, it is not possible to import enough electricity during the summer season to charge the batteries to serve the daytime load. Lastly, this Alternative does not feasibly meet the Project objectives to the same extent as the Project. d. Alternative Energy Proiect Alternative The Alternative Energy Project Alternative evaluates the feasibility of both photovoltaic (PV) solar and wind powered production alternative energy options.

PV power production requires approximately 4 — 6 acres per MW of electricity depending on the specific PV technology used (e.g., crystalline vs. thin film) and configuration of the solar array tracker system (single or dual axis). The Project site is approximately 10 acres in size and would support PV power production up to 2.5 MW. In order to generate power equivalent to the Project, the Alternative Energy Project Alternative would need to acquire an approximately 1,310-acre site that is capable of development as a utility-scale PV solar project. The City does not own or control 1,310 acres that are developable as a PV solar project. Glendale is predominantly urbanized with open space reserved within its existing parks and mountainous areas, much of which is preserved open space, designated as. significant ecological areas, in a high fire danger area, or too steep for any form of development. Therefore, development of a utility-scale PV solar project to provide an equivalent power source as the Project within the City of Glendale is not feasible. Therefore, the only path to using an alternative energy in place of the Project is to construct a new transmission line to access solar, wind, and geothermal resources outside the Los Angeles basin. However, building such a transmission system is in its own right a significant undertaking that brings about its own potential environmental impacts stemming from such large-scale development. The Alternative Energy Project Alternative was described as reducing certain localized impacts, but also increasing certain off-site impacts due to the need for increased transmission and the large area needed for a wind farm or solar field. Because of the very limited ability to site solar or wind resources within the City and due to the limited transmission capacity coming into Glendale, additional transmission would be needed to implement this Alternative. Because solar and wind resource opportunities within Glendale are limited, combined with energy storage considerations, as well as the complications associated with building a new transmission line to import alternative energy, the Alternative Energy Project Alternative was described as not being an adequate replacement for the power that would be generated by the Project. 9 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx Additionally, the Alternative Energy Project Alternative does not feasibly meet the Project objectives to the same extent as the Project.

e. 150 MW Project Alternative This Alternative would consist of three simple cycle combustion turbines at the Grayson Power Plant and a new transmission line to import additional electricity into the City. However, due to the reduction in generating capacity, this Alternative consequently also requires additional transmission and energy imports into Glendale to provide sufficient capacity. An additional consideration is that being simple cycle units, the available operating hours would be much less than what is available from the combined cycle units that are a part of the Project. Although feasible to develop, the 150 MW Project Alternative would not provide sufficient capacity or generate sufficient energy under all required planning scenarios necessary to meet load demands and reliability requirements. In addition, this Alternative would not be able to meet the reserve requirements set forth by NERCIWECC. Thus, the 150 MW Project Alternative would require additional import capacity (transmission capacity) for the City to meet load and reliability criteria. The 150 MW Project Alternative was described as having incrementally less, but similar, impacts as the Project. However, the 150 MW Project A!ternative would also require construction of a new transmission line because additional capacity would be needed to meet peak load and reserve requirements. Construction of a new transmission line has the potential to result in increased impacts where the line would be constructed. In addition to the potential environmental impacts, the 150 MW Project Alternative does not feasibly meet many of the Project objectives or meet them as well asthe Project. f. 200 MW Proiect Alternative A 200 MW Project Alternative would consist of two simple cycle units and one combined cycle unit. Because 200 MW of generation alone does not provide sufficient capacity that meet required planning scenarios, this Alternative would require either additional transmission capacity or “time shifting” energy storage via a Battery Energy Storage System (BESS) to provide the requisite capacity and energy to serve load. Given the amount of required additional capacity, and the difference in necessary activities to implement the two options, an energy storage system is preferred over transmission because: • Developing a new transmission connection presents property siting and acquisition challenges and new environmental impacts. • The source of power to be imported over the new transmission system would necessarily be located outside of the City and create a new contingency. 10 F:/filenetcopy/Council fReports/041018 Resolution Making Findings and approving MMRP.docx Having the 50 MW source located within the City is preferred. For energy storage, a BESS is the only available storage technology that can be sited at Grayson. The BESS could utilize either Lithium ion rechargeable battery or reduction-oxidation flow battery technologies. The 200 MW Alternative was described as having reduced air and greenhouse gas emissions and noise from one less generation unit compared to the Project, with the reduction of one-unit offset by the addition of a battery energy storage system (one that is smaller than the earlier alternative). However, the battery energy storage system adds the impact of periodic battery replacement as well as the need to dispose/recycle the batteries when they reach end of life. If sufficient transmission capacity were not available for charging the battery energy storage system, then the air emissions may not be reduced due to the need to operate additional unit(s) to charge the battery energy storage system. For these reasons, the overall environmental impacts of a 200 MW Alternative are expected to be comparable to the Project, but at the expense of not having fully dispatchable generation capacity after exhaustion of the battery energy storage system. This alternative was noted as having a higher associated cost than the Proposed Project in the Draft EIR. Since the time the Draft EIR was prepared, the cost for a BESS has decreased. As a result, the cost of this alternative may be lower than the Proposed Project. Although this alternative may be viable, it does not meet the Project objectives as well as the Proposed Project. Alternatives Reiected from Further Consideration A number of alternatives were considered but eliminated from further consideration in the EIR. The alternatives that were not evaluated further include alternative sites, and a variety of alternative technologies (generation technology, fuel technology, and alternative power plant cooling). The alternatives that were rejected from further consideration are described below. a. Power Plant Site Alternatives A review of industrial zones with the lowest concentration of building was conducted and identified two alternative power plant site locations. Both site locations would require acquisition of new land and the construction of new transmission lines as well as the extension of the recycled water line, high pressure gas line, and waste line. Locating the Project at a different site would also result in the loss of SCAQMD ‘offset exemption for replacement in kind’ per SCAQMD Rule 1304(a)(2) that is applicable as long as the Project is located at the current site. Neither alternative site presents an environmentally superior alternative to the existing site. Furthermore, the Project has a strong relationship to the existing industrial site. As a result, no alternate sites are analyzed in the Final E!R.

11 F:/filenetcopy/Councfl lReportsIO4l 018 Resolution Making Findings and approving MMRP.docx b. Project Technology Alternatives Combustion generation technology alternatives considered in the ER include conventional boiler and steam turbine, large gas simple cycle combustion turbine, large combined cycle combustion turbine generator, and reciprocating engine generators. The conventional boiler and steam turbine alternative is less efficient than the Project and would not meet the California’s SB 1368 Emission Performance Standard of less than 1,100 lbs of C02/MWh for new non-peaking generation. For these reasons, the conventional boiler and steam turbine generator technology was eliminated from consideration. The large simple cycle combustion turbine alternative is described as an efficient alternative, however, the size of such a unit is as big as the City’s existing single largest contingency and the power generated would exceed that is which required by the City. As such, this turbjne is too large to provide the required need for flexibility of operation that allows for integration of the startup and shut down of the unit, load following, or the efficient integration of renewable resources into the City’s electric grid. Furthermore, large turbines do not meet the Western Electricity Coordinating Council requirement that the City provide its own economic spinning and non-spinning reserve included in the Project objectives. Lastly, simple cycle turbines are restricted in their operating hours by the air permitting process. Therefore, with only large simple cycle turbines, the capacity would be available however the total energy may not. For these reasons, the large simple cycle combustion turbine alternative was eliminated from consideration. The large combined cycle combustion turbine generator alternative is described as an efficient source of generation, however, the size of such a unit is too large considering the City’s existing single largest contingency. As such, this technology does not provide the required need for flexibility of operation nor allows for the efficient integration of renewable resources into the City’s electric grid. Furthermore, large turbines do not meet the Western Electricity Coordinating Council requirement that the City provide its own economic spinning and non-spinning reserve included in the Project objectives. For these reasons, the large combined cycle combustion turbine generator alternative was eliminated from consideration. The reciprocating engine generators (PEGs) alternative was considered to supply part of the simple cycle generation because of the flexibility and good efficiency over the load range that multiple REGs offer. However, the REGs were eliminated from consideration due to the higher expected total project cost, increased maintenance, and air permitting concerns.

12 F:ffilenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx c. Alternative Fuel Technologies Technologies based on fuels other than natural gas do not meet the Project objectives. Additional factors rendering alternative fuel technologies unsuitable for the Project are as follows: • No geothermal or hydroelectric resources are available within Glendale. • Biomass fuels such as wood waste, digester or landfill gas are not locally available in sufficient quantities to make them practical as alternative fuels. • Coal, nuclear, and oil technologies would not meet the environmental stewardship objective of the Project. Furthermore, distributed energy resources or microgrids are not practical because the City cannot mandate its customers to self-supply and the City would still need to provide a reliable source of standby power to its customers. For these reasons, the alternative fuel technologies alternative was eliminated from consideration. d. Power Plant Cooling Alternatives Both wet and dry cooling alternatives were considered as a form of heat rejection for the Project. Wet cooling using recycled water is acceptable under state policy and is available at the Project site insufficient quantity required by the Project and is therefore included for use in the Project. Wet cooling using fresh or potable water uses an essential resource that has a much higher beneficial use other than use for power plant cooling and was therefore eliminated from consideration. Dry cooling using an air-cooled steam condenser (ACSC) was considered as an alternative to the uthe of wet cooling. Air-cooled condensers require more space on a site, consume more electricity, have a higher capital cost, and cannot produce as low a condensing pressure in hot weather as wet-cooled condensers. For these reasons, and since recycled water is available, dry cooling was not selected. The two commercially available methods of using hybrid cooling, the plume abatement cooling tower and the use of an ACSC and cooling tower in parallel service, were considered as alternatives to the use of solely wet or dry cooling. Both of these alternative methods result in a higher capital cast than wet cooling. For this reason, as well as limited commercial experience with these hybrid systems, these alternatives were not selected over wet cooling using recycled water. e. Distributed Solar PV Deployed on Glendale Residential and Commercial Rooftops The adoption and implementation of solar PV projects on privately owned property is voluntary and would not ensure a reliable power supply commensurate with the amount of power needed and with the reliability associated with utility-scale projects.

13 F:/filenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx Distributed solar PV deployed on residential and commercial rooftops is therefore not considered a feasible alternative to the Project and was eliminated from consideration. With respect to alternatives rejected from further consideration, the City hereby adopts and incorporates by reference the reasons set forth in the Final EIR as its grounds for finding infeasible rejecting those alternatives.

Findings Regarding Adequacy of Range of Alternatives The City finds that the range of alternatives evaluated in the EIR and the additional background provided in the Response to Comments in the Final EIR reflects a reasonable attempt to identify and evaluate various types of alternatives that would potentially be capable of reducing the Project’s environmental effects, while accomplishing most but not all of the Project Objectives. The City finds that the alternatives analysis is sufficient to inform the City and the public regarding the tradeoffs between the degree to which alternatives to the Project could reduce environmental impacts and the corresponding degree to which the alternatives would hinder the City’s ability to achieve most or all of its Project Objectives.

8. Growth-Inducing Impacts Section 15126.2(d) of the State CEQA Guidelines requires that an EIR “discuss the ways in which the Project could foster economic or population gräwth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.” Please refer to Final EIR Section 6.1 for an analysis of the potential growth-inducing impacts of the project. In general terms, a project may induce spatial, econpmic or population growth in a geographic area if it meets any one of the four criteria: (1) removal of an impediment to growth (e.g., establishment of an essential public service or the provisions of new access to an area); (2) economic expansion or growth (e.g., changes in revenue base, employment expansion, etc.); (3) establishment of a precedent-setting action (e.g., an innovation, a change in zoning or general plan amendment approval); or (4) development or encroachment in an isolated area or one adjacent to open space (being different from an “infill” type of project). The Project would not introduce features such as other public infrastructure that draw other developments into an area. The Project would not encourage growth in the area; growth would occur consistent with the City of Glendale General Plan. Additionally, no significant infrastructure that could serve other development would be developed as part of the Project. The Project would provide for ongoing energy needs of the residents and businesses within Glendale and would not significantly increase local employment or create other effects that could indirectly encourage growth.

14 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx Based upon these considerations, the Proposed Project will not result in significant growth-inducing impacts. 9. Mitigation Monitoring and Reporting Program The City adopts, and incorporates as conditions of approval of the Project, the mitigation measures set forth in the Mitigation Monitoring and Reporting Program set forth in Chapter 10 of the Final EIR and incorporated herein by this reference in support of this Resolution. The City Council hereby finds that the Mitigation Monitoring and Reporting Program meets the requirements of Section 21081.6 of the Public Resources Code.

9. Section 21081 .6(a)(2) of the Public Resources Code and CEQA Guideline Section 15091(e) require that the public agency shall specific the location of the custodian of the documents or other materials that constitute the record upon which its decision is based. Accordingly, the record and custodian of documents is the Glendale Planning Department, 633 East Broadway, Room 103, Glendale, California, 91206- 4386. BE IT FURTHER RESOLVED, that the custodian of the FEIR and all materials which constitute the record shall by the Planning Department of the City of Glendale at 633 East Broadway, Glendale, California.

APPROVED AND ADOPTED this ______day of ______2018.

Mayor

ATTEST:

~ AS TO FORM City Clerk ______PRINCIP~kikSpISTaT CITY ATTORNEY DATE67~?c~’C7 fl~79)

15 F:/filenetcopyfCouncil Reports/041018 Resolution Making Findings and approving MMRP.docx STATE OF CALIFORNIA SS COUNTY OF LOS ANGELES

I, Ardashes Kassakhian, Clerk of the City of Glendale, certify that the foregoing

Resolution No. ______was adopted by the Council of the City of Glendale,

California, at a regular meeting held on the ______day of ______2018, and that same was adopted by the following vote:

Ayes: Noes: Absent: Abstain:

City Clerk

16 F:ffilenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx Exhibit A - Impact Analysis 1.0 Environmental Effects Which Were Analyzed in the Initial Study (IS) and Determined to have No Impact or a Less than Significant Impact As a result of the Initial Study, in connection with preparation of the Notice of Preparation for the EIR, the City determined, based upon the threshold criteria for significance, that the Grayson Repowering Project, now referred to as the Project, would have “no impact” or a “less than significant impact” on the following environmental factors, and therefore, determined these potential environmental effects would not be carried forward and addressed further in the Draft EIR. Based upon the environmental analysis presented in the EIR, and the comments received on the Draft EIR, no substantial evidence was submitted to or identified by the City which indicated that the Project would have an impact on the following environmental areas: 1.1 Aesthetics a) Scenic Vista: The Project site is in the City of Glendale at 800 Air Way, Glendale, CA 91201, just northeast of the Interstate 5 and Highway 134 interchange. The site has a flat topography and is bounded to the south by the Verdugo Wash and Highway 134, to the west by the Los Angeles River and Interstate 5, to the north by commercial property and to the east by commercial property and then residential property. No scenic vistas, as identified in the City’s Open Space and Conservation Element (January 1993), exist within or in proximity to the Project site. Therefore, there would be no impact on a scenic vista. This issue was not further analyzed in the ER, consistent with CEQA Guidelines Section 15063 (c)(3). b) State Scenic Highway: The Project site is currently developed as the Grayson Power Plant and there are no unique geological features on the Project site. In addition, according to the City of Glendale General Plan established by Caltrans “California Scenic Highway Mapping System,” there are no state scenic highways located adjacent to, or within view of, the Project site. Therefore, no impacts to scenic resources within a state scenic highway would occur. This issue was not further analyzed in the EIR. 1.2 Agriculture and Forestry Resources a) Prime Farmland to Non-Farmland: The California Department of Conservation, Farmland Mapping, and Monitoring Program (FMMP), compiles Important Farmland maps pursuant to the provisions of Section 65570 of the California Government Code. Based on this resource, there is no existing prime farmland, unique farmland, or farmland of statewide importance within or adjacent to the Project site and no agricultural activities take place on the Project site. No agricultural use zone currently

17 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx exists within the City of Glendale, nor are any agricultural zones proposed. Therefore, no impacts would occur. This issue was not further analyzed in the ER. b) Williamson Act: Williamson Act contracts restrict land development of contract lands. The contracts typically limit land use in contract lands to agriculture, recreation, and open space, unless otherwise stated in the contract. The proposed property is not in the Williamson Act Conservation Contract database. Because the Project site is not part of a Williamson Act contract, no impacts associated with this issue would occur with development of the Project. This issue was not further analyzed in the ElR. c) Conflict with Forest Land: There is no existing zoning of forest land or timberland in the City of Glendale. Therefore, no impacts to these resources are expected to occur as a result of this Project. This issue was not further analyzed in the EIR. d) Loss of Forest Land: There is no forestland within the City of Glendale. No forestland would be converted to non-forest use under the Project. Therefore, no impacts are expected to occur as a result of this Project. This issue was not further analyzed in the ElR. e) Conversion of Farmland or Forest land: There is no farmland in the vicinity of or on the Project site. The Project would not result in conversion of farmland to non agricultural uses. No impacts are expected to occur as a result of this Project. This issue was not further analyzed in the EIR. 1.3 Biological Resources a) Effect Species Policieá or Regulations: The Project site is located in an urban area on developed land for the existing Grayson Power Plant and does not contain vegetation. A California Natural Diversity Database (CNDDB) review identified several occurrence records of sensitive plant and wildlife species within ten miles of the Project. However, no sensitive plant or wildlife species were observed, nor was suitable habitat located during an October 23, 2015 field survey of the site and a 300-foot surrounding buffer area. The Project would therefore have no direct impact to sensitive plant and wildlife species. Coyote brush scrub (Baccharis pilularis Shrubland Alliance) and willow thickets (Salix sp. Shrubland Alliance) vegetation communities were identified in the buffer area but would not be directly impacted by Project implementation. Therefore, no impacts to sensitive habitats or species would occur from project implementation. This issue was not further analyzed in the ER. b) Effect on Sensitive Habitat: The Project site does not contain any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service. The Project proposes to use recycled water from the Los Angeles Glendale Water Reclamation Plant (LAGWRP) rather than potable water for generation system cooling. There is riparian habitat downstream of the LAGWRP that could be affected if there was a substantial diversion of effluent supporting this habitat as a result 18 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx of the Project. The Cities of Los Angeles and Glendale jointly own the LAGWRP, for which the City of Glendale is a 50% owner of the facility. The wastewater treatment plant is rated for 20 million gallons per day (mgd) or 20,000 acre-feet per year. The plant produces between 16 and 18 mgd, which equates to an approximate volume of 16,000 to 18,000 acre-feet of recycled water per year. The City of Glendale’s allocation is between 8,000 and 9,000 acre-feet per year. Over the last three years, the City of Glendale has been using between 1,500 and 2,000 acre-feet per year of its allocation. The treated water not reused is discharged to the Los Angeles River. As a result, the Project’s use of recycled water is not anticipated to result in a substantial change in the volume of discharges to the Los Angeles River, particularly when considering that the LAGWRP is one of many water discharge sources to the Los Angeles River. Therefore, the Project would not impact a riparian habitat or other sensitive natural communities. This issue was not further analyzed in the EIR. c) Effect on Protected Wetlands: The Project Site does not contain wetlands and would not have impacts related to federally protected wetlands as defined by Section 404 of the Clean Water Act. The Project is adjacent to the Los Angeles River and would have no substantial change to hydrological conditions to receiving waters. Therefore, the Project would have no impact on wetlands. This issue was not further analyzed in the EIR. d) Interfere with Miciratorv Species: The Project site does not contain rivers, creeks, or waterways. The Project is located entirely within the existing Grayson Power Plant Site and surrounded by urban uses and wildlife species are unlikely to use the Project site as a migratory corridor due to the urban and industrial nature of the surrounding areas. The Los Angeles River and Verdugo Wash located adjacent to the Project site provide potential habitat for fish and wildlife as well as a movement corridor. However, as noted in the Reader’s Guide for the Los Angeles River Ecosystem Restoration Project, the development that occurs along the waterways and concrete channelization that lines on portions of the Los Angeles River limit the habitat quality and connectivity service of the system (City of Los Angeles, 2016). The Project would not involve any work activities in the Los Angeles River or Verdugo Wash nor would the Project’s use of recycled water result in a substantial reduction in the volume of discharges to the Los Angeles River. As a result, the Project would have no impact on the movement of any resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors. Therefore, this issue was not further analyzed in the EIR. e) Conflict with Protected Biological Resources: The Project would occur on developed land with poor quality habitat to support biological resources. The Project would not result in removal of vegetation or trees nor would it involve an activity that has the potential to substantially reduce the volume of discharges to the Los Angeles River from the LAGWRP that could adversely affect biological resources in the Los Angeles River. The Project would have no impact. This issue was not further analyzed in the EIR.

19 F:/tilenetcopy/Council ReportsfO4lOl8 Resolution Making Findings and approving MMRP.docx f) Conflict with Habitat Conservation Plan: According to the Glendale General Plan, there is no habitat conservation plan or natural community conservation plan in the City of Glendale. There is a Significant Ecological Area (SEA) within the Verdugo Mountains, which is implemented with the intention to preserve designated sensitive areas. However, the Project is not located within the SEA. As such, implementation of the Project would not conflict with the SEA program or other habitat conservation plans. No impact would occur. This issue was not further analyzed in the EIR. 1.4 Cultural Resources a) Change the Significance of Historical Resource: An archaeological survey and a historic resource inventory and evaluation of the Grayson Power Plant were conducted in 2003 and 2016 respectively. The 2003 cultural resources survey of Unit 9, conducted by URS, did not identify any cultural resources. The 2016 Historic Resource Inventory and Evaluation of the Grayson Power Plant for the City of Glendale, California evaluates the structures constructed between 1941 and 1947 (the “2016 Resource Study”). The Grayson Power Plant was evaluated against the criteria established for including a property on the National Register of Historic Places (NRHP) and the California Register of Historic Resources (CRHR). In order to be eligible for the NRHP or CRHR, a resource must be determined significant under at least one of the four criteria and retain integrity to its period of significance. The Criteria for the NRHP and Criterion for the CRHR are paraphrased below: Criteria A/Criterion 1: Resources that are associated with events that have made a significant contribution to the broad patterns of our history; Criteria B/Criterion 2: Resources that are associated with the lives of significant persons in our past; Criteria C/Criterion 3: Resources that embody the distinctive characteristics of a type, period, or method of construction, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; and Criteria D/Criterion 4: Resources that have yielded or may be likely to yield, information important in history or prehistory. In addition to significance under one or more of the criteria listed above, a resource must possess integrity, defined by seven aspects as follows: Location: the place where the historic property was constructed or the place where the historic event took place.

Design: the composition of elements that constitute the form, plan, space, structure, and style of a property.

20 F:/filenetcopy/Council Reports/041018 ResolUtion Making Findings and approving MMRP.docx Setting: the physical environment of a historic property that illustrates the character of the place. Materials: the physical elements combined in a particular pattern or configuration. Workmanship: the physical evidence of the crafts of a particular culture or people during any given period of history. Feeling: the quality that a historic property has in evoking the aesthetic or historic sense of a past period of time. Association: the direct link between a property and the event or person for which the property is significant. The City of Glendale also provides a series of criteria for evaluating properties for inclusion on the Glendale Register of Historic Resources (GRHR). These criteria are aligned with those presented by the state for including a property on the CPHR. They include the following: • Is the proposed historic resource identified with important events in a national, state, or city history, or does it exemplify significant contributions to the broad cultural, political, economic, social, or historic heritage of the nation, state, or city? • Is the proposed historic resource associated with a person, persons, or groups who significantly contributed to the history of the nation, state, region, or city? • Does the propo~ed historic resource embody the distinctive and exemplary characteristics of an architectural style, architectural type, period, or method of construction; or present a notable work of mater designer, builder or architect whose genius influenced his or her profession; or possess high artistic values? • Has the proposed historic resource yielded, or have the potential to yield, information important to archaeological pre-history or history of the nation, state, region, or city? • Does the proposed historic resource exemplify the early heritage of the city? While the Plant does possess significance for the NRHP Criteria C and CRHR Criterion 3 for its engineering, the numerous alterations and expansions have degraded its integrity negating its eligibility. Integrity has been significantly diminished at the site due to continuous improvements such as alterations, changes, additions, and demolition of the buildings and structures. Further, the power plant lacks significance for the Glendale

21 F:/filenetcopy/council Reports/041018 Resolution Making Findings and approving MMFIP.docx Register of Historic Resources. The Grayson Power Plant is therefore not eligible for the NRHP under all criteria, CRHR under all criterion, the City of Glendale Register of Historic Resources, or as a historic resource for the purposes of CEQA. Therefore, this issue was not further analyzed in the EIR. a) Change the Significance of Archaeological Resource: Similar in respect to the above historical resources discussion, the potential to encounter archaeological resources appears to be very low because the Project area has been previously disturbed and altered by construction of the existing Grayson Power Plant. There were no archaeological resources identified during the 2003 survey and no other archaeological resources were documented within or adjacent to the Project area. Based on the findings in this study, the Project would not cause a substantial adverse change to the significance of archaeological resources as defined in Section 15064.5, nor would the Project have impacts on significant local resources as defined in Chapter 15.20 of the City of Glendale Municipal Code. However, there is always a possibility that buried historic, cultural, or paleontological deposits could be found during construction and earth disturbing activities. Therefore, in the event archeological resources are discovered, regulatory compliance of State Health and Safety Code Section 7050.5 and Public Code Resources Code Section 5097.98 would be implemented. This would be a less than significant impact. Therefore, this issue was not further analyzed in the EIR. b) Destroy a Unique Paleontological or Geologic Feature: While the Project would be constructed in an area that has been considerably disturbed and/or altered, any extensive ground disturbing activities have the potential to encounter geologic formations that could potentially contain paleontological resources. In the event that potential paleontological resources are encountered during construction activities, all work must stop, and a qualified paleontologist should be contacted immediately to assess the significance of the new find. Additionally, the following may be implemented in order to ensure that impacts are less than significant: 1) worker education training for all construction personnel regarding the significance of paleontological resources; 2) monitoring during construction by a qualified paleontologist; 3) screening of sediment samples for small fossil remains; 4) documentation and identification of newly identified resources and their handling. Based on the foregoing, there would be a less than significant impact and this issue was not further analyzed in the EIR. c) Disturb Human Remains: There is no evidence to suggest the Project site has been used for human burials. The California Health and Safety Code (Section 7050.5) states that if human remains are discovered onsite, no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98, including coordination with persons to be the descendants of the deceased Native Americans if the remains are identified as prehistoric. Adherence to applicable California Health and Safety Code and Public Resource Code requirements is standard for all Projects. Impacts associated with the disturbance of human remains would be a less than significant. Therefore, this issue was not further analyzed in the EIR.

22 F:ffilenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx 1.5 Geology and Soils a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:

Alciuist-Priolo Fault: The Alquist-Priolo Earthquake Fault Zoning Act (Act) mitigates fault rupture hazards by prohibiting the location of structures for human occupancy across the trace of an active fault. The Act requires the State Geologist to delineate Earthquake Fault Zones” along faults that are “sufficiently active” and “well defined.” The boundary of an “Earthquake Fault Zone” is generally 500 feet from major active faults and from 200 to 300 feet from well-defined minor faults. These maps are distributed to all affected cities, counties, and State agencies for their use in developing planning policies and controlling renovation or new construction. Based on a review of the Map of the State of California Special Studies Zones (Burbank Quadrangle), effective January 1, 1979), the Project site is not identified as being within an Alquist-Priolo Earthquake Fault Zone. As such, no fault rupture impact would result from the implementation of this Project. This issue was not further analyzed in the EIR. Seismic Ground Shaking: Like all of Southern California, the Project site has and would continue to be subject to ground shaking generated from activity on local and regional-faults. As identified above, the Project site is not within an earthquake fault zone. The Project site has the potential to be subject to seismic ground shaking and failure during a major earthquake along the San Andreas Fault. The intensity of the ground shaking would depend on the distance to the epicenter and the geology of the areas between the epicenter and the Project area. In accordance with the California Building Code (California Code of Regulations, Title 24), seismic structure design requirements would be based on the Seismic Design Category (SDC) for the proposed structures, which is based on the Occupancy Category for the structure and on the level of expected soil modified seismic ground motion. Compliance with the seismic design requirements specified by the California Building Code would reduce the potential impacts from seismic ground shaking and ground failure on building occupants and structures to a less than significant level. This issue was not further analyzed in the EIR. Hi. Landslides: According to the United States Geological Survey Map, the area contains no major Iandforms, is relatively flat, and contains no potential for landslides. Additionally, a review of the State of California

Seismic Hazards Zones — Burbank Quadrangle Map (released March 25, 1999) indicates that the Project area is not located within an “Earthquake Induced Landslides” zone, which is defined as an area where previous

23 F:/tilenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx occurrence of landslide movement or local topographic, geological, geotechnical, and subsurface water conditions indicate a potential for permanent ground displacement such that mitigation as defined in Public Resources Code Section 2693(c) would be required. Impacts associated with landslides are anticipated to be less than significant. This issue was not further analyzed in the EIR. d) Located on Expansive Soil: Expansive soils generally have a significant amount of clay particles which can give up water (shrink) or take on water (swell). The change in volume exerts stress on buildings and other loads placed on these soils. The extent of shrink/swell is influenced by the amount and kind of clay in the soil. The occurrence of these soils is often associated with geologic units having marginal stability. The distribution of expansive soils can be widely dispersed, and they can occur in hillside areas as well as low-lying alluvial basins. A Geotechnical Study was conducted at the site in September 2015. This investigation found that the near-surface soils encountered in the proposed construction area are predominantly sand with variable amounts of silt. Based on experience with these types of soils, the Plasticity index (P1) is expected to be less than 15 P1, determined in accordance with American Society for Testing Materials (ASTM) D431 8. In addition, based on the portion of the soils passing a No. 200 sieve (75 micrometers [pm], it is expected to consist of silt particles greater than 5 micrometers (pm) in size. The Geotechnical Study concluded that the soils are not expansive, as identified in the Uniform Building Code (2016), and do not create substantial risks to life or property. Therefore, development of the Project would have a less than significant impact from shrink/swell potential, subsidence or differential settlement and substantial risks to life or property are not anticipated. This issue was not further analyzed in the EIR. e) Soil Incapable of Supporting Septic Tanks or Wastewater: The Project does not include any new construction of septic tanks or alternative wastewater disposal system. Therefore, there would be no impact. This issue was not further analyzed in the EIR. 1.6 Hazards and Hazardous Materials c) Emit Hazardous Emissions: The Project site is not located within a quarter mile of an existing school and therefore, does not have the potential to expose students to hazardous emissions such as diesel emissions during construction. Therefore, there would be no impact associated with this issue. This was not further analyzed in the ElR. d) Located on a Hazardous Materials Site: The Project site is not included on a list of hazardous materials site identified by Government Code Section 65962.5. The Project site is within the boundary of the initial investigations for the San Fernando Valley Superfund Sites, which is an area of contaminated groundwater covering approximately 7 square miles beneath the North Hollywood neighborhood of the City of Los Angeles and the City of Burbank. The use of an alternate water supply and the operation of the groundwater treatment system in the North Hollywood and Burbank

24 F:/filenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx areas have reduced the potential of exposure to contaminated drinking water at the San Fernando Valley site and will continue to protect residents near this site while additional cleanup activities are planned and implemented. Regardless, the Project is not expected to result in encountering potentially impacted groundwater. Therefore, there would be no impact associated with this issue. This issue was not further analyzed in the EIR. e) Located Near Airport: There is no public airport or public use airports within the vicinity of the Project site. The Project site is not located within the Air Installation Compatible Use Zone (AICUZ). Therefore, the Project would not result in a safety hazard for people utilizing or working within the Project area. No impact would occur. This issue was not further analyzed in the EIR. f) Located Near Private Airstrip: The Project site is not located within the vicinity of a private airstrip or heliport. Consequently, no impacts associated with this issue would occur. This issue was not further analyzed in the EIR. g) Interfere with Emergency Response Plan: The Project would be designed, constructed, and maintained in accordance with applicable standards associated with vehicular access, resulting in the provision of adequate vehicular access that would provide for adequate emergency access and evacuation. Construction activities that may temporarily restrict vehicular traffic would be required to implement adequate and appropriate standards to facilitate the passage of persons and vehicles through/around any required road closures. Adherence to these standards would reduce potential impacts related to this issue to a less than significant level. This issue was not further analyzed in the ElR. h) Wildfire Hazard Zone: The Project site is not located within the wildfire hazard zone as specified by the City of Glendale General Plan. Areas surrounding the Project site consist of urban development with minimal ground cover or vegetation. Because of lack of abundant vegetation and the amount of industrial development within the vicinity of the Project site, on-site and adjacent areas do not have the capability to support a wildfire. Therefore, the Project does not have the potential to expose people or structures to a significant risk of loss, injury or death involving wildland fires. No impact would occur, and this issue was not further analyzed in the EIR. 1.7 Hydrology and Water Quality b) Deplete Groundwater Resources: There are currently two water wells on the Project site and the Grayson Power Plant uses approximately 20-acre feet of well water per year. The Project would entirely utilize recycled water for generation process cooling thereby limiting groundwater use to domestic consumption by the plant staff and for emergency generation process cooling in the event service of recycled water from the Los Angeles-Glendale Water Reclamation Plant was interrupted. As a result, operation of the Project would utilize less groundwater and contribute more to groundwater recharge compared to existing Grayson Power Plant operation. Operation of the Project 25 F:/filenetcopy/Council Rpports/041018 Resolution Making Findings and approving MMRP.docx would therefore have a beneficial impact to groundwater resources. Construction of the Project does not include any component with the potential to deplete groundwater supplies or interfere substantially with groundwater recharge and would therefore have no impact. This issue was not further analyzed in the EIR. d) Alter Existing Drainage Pattern: The Project site is located on developed lands with impervious services. Stormwater flows via surface sheet flow to existing localized gutters, catch basins, storm drain piping and outfalls to Verdugo Wash and Los Angeles River. The Project would include redevelopment of an existing site land use and equivalent amount of impervious surface subject to sheet flow. The Project also includes a stormwater infiltration component to improve site drainage and groundwater recharge potential compared to existing Grayson Power Plant operation. Operation of the Project would not substantially alter the existing drainage pattern of the site or area or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site. Project construction does not include a component with the potential to increase surface runoff in a manner that would result in on- or off-site flooding. No impact related to this issue is anticipated to occur. This issue was not further analyzed in the EIR. f) Degrade Water Quality: The Project does not include a component with the potential to otherwise substantially degrade water quality. No impact would occur. This issue was not further analyzed in the E!R. g) Within a 100-Year Flood Hazard Area: The Project is not within a 100-year flood hazard area as identified on the Flood Insurance Rate Map (FIRM; Panel 06037C1345F, effective 9/26/2008) generated by the Federal Emergency Management Agency (FEMA). The Project is also not within a 100-year Los Angeles River overtopping flood hazard area identified by the US Army Corps of Engineers Hydraulics and Floodplain Analysis of the Los Angeles River (US Army Corps of Engineers, 2016). The 2016 US Army Corps analysis indicates that overbank flow during a 100-year and 500-year storm event would impact Ferraro Fields on the southwest side of the Los Angeles River would not flood the Project site located on the opposite (northeast) side of the river. In addition, the Project does not involve the construction of housing. Therefore, the Project would not place housing within a 100-year flood hazard area. No impact related to this issue is anticipated to occur. This issue was not further analyzed in the EIR. h) Redirect Flow Flows Because of 100-Year Flood Hazard Area: See above response. No impacts would occur. This issue was not further analyzed in the EIR. i) Failure of Levee or Dam: There are no levees or dams within the vicinity of the Project site according to the City of Glendale General Plan and the Project site is not located within an inundation area or within the 100-year Los Angeles River overtopping area identified by the US Army Corps of Engineers. Therefore, the Project would have no impact related to the exposure of people or structures to flooding risks, including

26 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx flooding as a result of the failure of a levee or dam. This issue was not further analyzed in the EIR.

j) Inundation by Seiche. Tsunami, or Mudflow: A tsunami is a series of waves generated in a body of water by a pulsating or abrupt disturbance that vertically displaces water. Inundation of the Project site by a tsunami is highly unlikely as the Project site is more than 15 miles from the Pacific Ocean. Seiches are oscillations in enclosed bodies of water that are caused by a number of factors, most often wind or seismic activity. There are no enclosed bodies of water within the vicinity of the Project. Because the Project site is not located adjacent to any enclosed bodies of water, no seiche-related flooding is anticipated to occur on-site. Due to the relatively flat topography in the vicinity of the Project site, it is unlikely that a mudflow would impact the site. There would be no impact from inundation, seiche, tsunami, or mud flow. These issues were not further analyzed in the EIR. 1.8 Land Use and Planning a) Divide Established Community: The Project would be replacing existing generating units and ancillary facilities and would not physically divide an established community. The existing power plant is in an industrial area of the City and there are no existing residential uses located on the property. The Project would not entail the displacement of any residential uses or the use of any land designated fqr residential uses. Therefore, the Project would have no impact and would not disrupt or physically divide an established community. This issue was not further analyzed in the EIR. b) Conflict with Land Use Plan: The Projects is consistent with surrounding development and does not conflict with the adopted plans for the purpose of avoiding or mitigating an environmental effect. The Project is a permitted use in the Industrial zone and is not anticipated to conflict with any applicable land use plan. Therefore, the Project would have no impact related to this issue. This issue was not further analyzed in the ElR. c) Conflict with Habitat Conservation Plan: According to the Glendale General Plan, there is no habitat conservation plan or natural community conservation plan in the City of Glendale. There is, however, a Sensitive Ecological Area (SEA) program in the City of Glendale, which is implemented with the intention to preserve these designated sensitive areas. According to the Glendale General Plan, the Grayson flepowering Project site is not located within the established SEA. As such, implementation of the Project would not conflict with the SEA program or other habitat conservation plans. Therefore, the Project would have no impact to local, regional, or State habitat conservation plans. This issue was not further analyzed in the ER. 1.9 Mineral Resources a) Result in Loss of Mineral Resource: The Project site is located in an MRZ-2 for sand, gravel, and Portland cement concrete (PCC) aggregate. However, the Project site 27 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx is located within a substantially industrial area surrounded by existing industrial uses, limiting its potential for mineral resource conservation or extraction. No mineral resource extraction, recovery, or processing activities underway on or adjacent to the Project site. The site is not designated in the City’s General Plan or Zoning Code for any extractive use. Implementation of the Project would therefore have no impact on the availability of known mineral resources in the Project vicinity currently available for extraction. This issue was not further analyzed in the EIR. b) Loss of Availability of Locally Important Mineral Resource: The Project site is located within a substantially industrial area surrounded by existing industrial uses, limiting its potential for mineral resource conservation or extraction. The Project site is not classified as an area of locally important mineral resource recovery. As such, no impact related to this issue would occur. This issue was not further analyzed in the EIR. 1.10 Noise e) Excessive Noise Within Airport Land Use Plan: The Project is not within an airport land use plan. Therefore, no impacts to excessive noise levels as a result of airports in the vicinity of the Project site would occur. This issue was not further analyzed in the EIR. f) Excessive Noise Near Private Airstrip: The Project is not within the vicinity of a private airstrip. Therefore, no impacts to excessive noise levels as a result of private airstrips in the vicinity of the Project site would occur. This issue was not further analyzed in the EIR. 1.11 Population and Housing a) Induce Substantially Population Growth: The Project does not include new residents or extend any major infrastructure that could support additional development. The incremental increase in power would serve existing demand, meet reliability requirements, and allow for increased integration of renewable energy sources into GWP’s portfolio to meet RPS requirements. The Project does not include new homes or businesses. No new substantial employment would be generated by the Project that could potentially contribute to additional demand for housing or services in the surrounding area. In addition, the regional area has the required workforce that would commute daily to the Project site and would not require new housing infrastructure. The workforce required to operate the Project would be similar to that required to operate the existing power plant. Therefore, the Project would not have impacts related to population growth. This issue was not further analyzed in the EIR. b) Displace Existing Housing: The Project would not result in the removal or demolition of any residential units because there are no existing residential units on the property. The Project would not entail the displacement of any residential uses or the use of any land designated for residential uses. No impacts would occur. This issue was not further analyzed in the EIR. 28 R/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx a) Displace Substantial Amount of People: The Project would not result in the removal or demolition of any existing residential units because there are no existing residential uses on the property. The Project would not entail the displacement of any residential uses or the uses of any land designated for residential use. Therefore, the Project would not have impacts related to the displacement of people. This issue was not further analyzed in the EIR. 1.12 Public Services a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impact, in order to maintain acceptable service ratios for any of the public services: Need for New or Altered Fire Protection: The City of Glendale Fire Department (GFD) provides fire and paramedic services to the Project site. The nearest fire station is Station 25 located at 353 N. Chevy Chase Drive, approximately two miles from the Project site. The Project would not cause an incremental increase in the need for fire service due to the Project’s replacing of existing generating units and ancillary facilities. The Project is required to comply with all Fire Department standards and policies, including installation of public and private fire hydrants as specified by the Glendale Fire Department. The Project would comply with the City’s latest standards and will therefore, improve the site’s existing conditions. For these reasons, the Project would have no impact. This issue was not further analyzed in the EIR. U. Need for New or Altered Police Protection: Existing law enforcement service in the area would adequately meet the demand for police protection services under the Project because repowering of the Grayson Power Plant would not require additional services beyond those currently provided. Therefore, the Project would have no impact. This issue was not further analyzed in the EIR. Hi. Need for New or Altered Schools: The Project would not adversely impact schools because no population increase or shifts in population would occur as a result of the Project. The Project would not include any residential population or increase the number of employees at the facilities. Therefore, the Project would have no impact. This issue was not further analyzed in the ElR. iv. Need for New or Altered Parks: The Project would not entail the construction of residential or commercial uses that would result in an increase in park usage. The Project is not anticipated to contribute substantially to meet the need for additional parks. Therefore, the Project would have no impact. This issue was not further analyzed in the EIR. v. Need for Other New or Altered Public Facilities: The Project is not anticipated to adversely affect the City’s overall ability to provide services Citywide including school and library services. The Project would not create any significant increase in demand for 29 F:/filenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx library services. Therefore, the Project would have no impact. This issue was not further analyzed in the EIR. 1.13 Recreation a) Increase Need in Parks or Recreational Facilities: The Project would not entail the construction of residential or commercial uses that would result in an increased use of area parks or recreation facilities. There are no increases to the use of existing neighborhood or regional parks or other recreation facilities such that substantial physical deterioration of the facility would occur or be accelerated. Therefore, no impacts related to the physical deterioration of a park associated with the Project would occur. This issue was not further analyzed in the EIR. b) Include Recreational Facilities: The Project does not include the construction of recreational facilities either on or off the Project property. Therefore, the Project would have no impacts. This issue was not further analyzed in the EIR. 1.14 Transportation and Traffic c) Change in Air Traffic Patterns: There are no private airstrips within the vicinity of the Project site. Therefore, the Project would not cause any change in the air traffic patterns during construction or operation. No impact would occur, and this issue was not further analyzed in the EIR. d) Increase Hazards due to Design: The Project would be constructed in the existing boundaries of the Grayson Power Plant in which deliveries of large equipment do not require modifications or changes to existing City streets or state highways. Roadway improvements in and around the Project site have not changed and would continue to satisfy all City requirements for street widths, corner radfl, intersection control, and design standards tailored specifically to site access requirements. A less than significant impact would occur. This issue was not further analyzed in the EIR. e) Inadequate Emergency Access: The Project’s emergency access would not change in design from the existing and approved Grayson Power Plant. The Project would be required to be designed, constructed, and maintained to provide for adequate emergency access and evacuation. Construction activities, which may temporarily restrict vehicular traffic, would be required to implement adequate and appropriate measures to facilitate the passage of persons and vehicles through/around any required road closures. The Project design would be submitted to and approved by the City’s Fire and Police Departments prior the issuance of construction permits. A less than significant impact related to this issue would occur. This issue was not further analyzed in the EIR. f) Conflict with Public Transit Policies: The Project site is located in an industrial area that contains an extensive network of sidewalks, bike plans, and public transit system. The Project as designed would not conflict with adopted transportation policies 30 F:Jfilenetcopy/council Peports/041 018 Resolution Making Findings and approving MMRP.docx as indicated in the City General Plan. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. 1.15 Tribal Cultural Resources a) Listed in California Register of Historical Resources: Based on previous studies and the 2016 Resource Study, the Project would not cause a substantial adverse change to the significance of historical resources as defined in Section 15064.5, nor would the Project have impacts on significant local resources as defined in Chapter 15.20 of the City of Glendale Municipal Code. However, there is always a possibility that buried historic, cultural, or paleontological deposits could be found during construction and earth disturbing activities. In the event, buried historic, cultural, or paleontological deposits are discovered, regulatory compliance of State Health and Safety Code Section 7050.5 and Public Code Resources Code Section 5097.98 would be implemented. There would be no impact to historical resources. This issue was not further analyzed in the EIR. 1.16 Utilities and Service Systems a) Exceed Wastewater Treatment Requirements: Wastewater discharge from operation of the Project would be regulated by an Industrial Wastewater Discharge Permit, which establishes pretreatment standards for wastewater effluent prior to discharge into the City of Glendale sewer system. The Grayson Power Plant currently operates under an existing Industrial Wastewater Discharge Permit. The existing Industrial Wastewater Discharge Permit would be modified to address the new process of wastewater generation and treatment from the Project. Compliance with the Industrial Wastewater Discharge Permit requirements would ensure that the Project would not exceed the wastewater treatment requirements of the City of Glendale or RWQCB. Therefore, the project would not exceed wastewater treatment requirements of the applicable RWQCB. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. b) Require New Wastewater Treatment Facilities: The Project will rely on recycled water for generation process cooling and will result in a reduction of groundwater use compared to existing power plant operation. The volume of recycled water necessary for the Project’s wet cooling system is within the City’s allocation from the Los Angeles- Glendale Water Reclamation Plant that maintains a connection infrastructure with the Grayson Power Plant. The Project may also incorporate on-site water treatment in support of cooling tower operation. The project would not require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. c) Require New Stormwater Drains: The Project site is located on developed lands with impervious services. Stormwater flows via surface sheet flow to existing localized gutters, catch basins, storm drain piping and outfalls to Verdugo Wash and Los Angeles 31 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx River. The Project would include redevelopment of an existing site land use and equivalent amount of impervious surface subject to sheet flow. The Project also includes a stormwater infiltration component to improve site drainage and groundwater recharge potential compared to existing Grayson Power Plant operation. The Project would not require or result in the construction of new off-site storm water drainage facilities or expansion of existing facilities. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. d) Have Sufficient Water Supplies: Grayson has had 600 acre-feet per year allocation of recycled water since 1978. Recycled water use at Grayson in 2015, was approximately 370 acre-feet per year. The Project would eliminate the use of potable water in the generation process by increasing use of recycled water. The potential increase of 230 acre-feet per year of recycled water from the Project is within Grayson’s allocation. In addition, the volume of recycled water being used by the City has declined in recent years as golf courses and other large water users have reduced their demand for water. There are sufficient water supplies available to serve the Project from existing entitlements. A less than significant impact associated with this issue would occur. This issue was not further analyzed in the EIR. e) Wastewater Treatment Provider Determining Capacity of Facility: The Project will rely on recycled water from the Los Angeles-Glendale Water Reclamation Plant for generation process cooling. The volume of recycled water necessary for the Project’s wet cooling system is within the City’s allocation from and treatment capacity of the Los Angeles-Glendale Water Reclamation Plant that maintains a connection infrastructure with the Grayson Power Plant. No impact associated with this issue would occur. This issue was not further analyzed in the EIR.

f) . Landfill Capacity: Similar to existing conditions onthe project site, waste generated by operation of existing power generating units and associated facilities would be properly managed and/or disposed of in compliance with federal, state, and local statutes and regulations related to solid and hazardous waste management. Because the Project involves the replacement of the existing generation units and would not increase the number of employees on site, the Project would not result in increased waste disposal over existing conditions. The minimal hazardous waste that would be generated during project construction would be transported to a Class 1 landfill in California. The amount of waste disposed would remain similar to existing conditions and additional capacity would not be required. Therefore, operational impacts of the Project would be less than significant. This issue was not further analyzed in the EIR. g) Abide by All Solid Waste Regulations: In response to State-mandated waste reduction goals, and as a part of the City of Glendale’s ongoing efforts to reduce the landfill disposal of waste, the City adopted Ordinance No. 5478 in 2005 (Chapter 8.58 of the Glendale Municipal Code). The ordinance as amended by Ordinance No. 5627 in 2008, requires that the waste from certain construction and/or demolition projects be either taken to a certified mixed debris recycling facility or to a recycler that will divert all

32 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx the accepted waste, such as concrete, metal, etc. from the landfill. The Project would be required to comply with applicable solid waste ordinances, and thus, would meet Glendale’s and California’s solid waste diversion regulations. In addition, the Project would comply with Chapter 8.58 of the Glendale Municipal Code and design requirements for refuse storage areas. Therefore, the Project would follow applicable federal, state, and local statues and regulations related to solid waste and impacts would be less than significant. This issue was not further analyzed in the EIR. 1.17 Environmental Justice a) Increase Air Emissions Impacting Low-Income Communities: Glendale is not considered an environmental justice community and the Project would therefore not substantially increase project air emissions that disproportionately impact low-income or minority communities in proximity to the project site. No impact associated with this issue would occur. This issue was not further analyzed in the Draft EIR. In response to comments received on the Draft EIR, clarifying information with respect to the potential for environmental justice impacts was discussed in Topical Response No. 12 of the Final EIR. b) Degrade Health and Safety of Low-Income Communities: Glendale is not considered an environmental justice community and the Project would therefore not degrade the health and safety of low-income or minority communities disproportionately. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. In response to comments received on the Draft EIR, clarifying information with respect to the potential for environmental justice impacts was discussed in Topical Response No. l2of the Final EIR. c) Fail to Provide Participation of Low-Income Communities: Glendale is not considered an environmental justice community. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. In response to comments received on the Draft EIR, clarifying information with respect to the potential for environmental justice impacts was discussed in Topical Response No. 12 of the Final EIR. d) Cause Higher Impact on Low-Income Communities: Glendale is not considered an environmental justice community. No impact associated with this issue would occur. This issue was not further analyzed in the EIR. In response to comments received on the Draft ER, clarifying information with respect to the potential for environmental justice impacts was discussed in Topical Response No. 12 of the Final EIR. 1.18 Socioeconomics a) Alter Existing Economic Characteristics: The Project involves repowering an existing power plant which would not change the economic characteristics in the vicinity or the region. The local and regional economy would support the construction and operation of the Project. The Project would require a maximum workforce of 33 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx approximately 250 workers, which would cause no adverse impact on the socioeconomic character of the City of Glendale. The local economics of the City of Glendale would potentially improve with the purchase of local resources and employment of a local workforce. Therefore, the Project would not alter the economic base, fiscal resources, and economic characteristics of the vicinity and region affected by the construction and operation of the Project. There would be no impact. This issue was not further analyzed in the EIR. b) Increase Expenditures for Materials: The Project would not substantially decrease the expenditures for locally purchased materials for the construction phase of the Project. In fact, the local economics of the City of Glendale would potentially improve with the purchase of local resources and employment of a local workforce. There would be no impact. This issue was not further analyzed in the EIR. c) Result in Increase of Population and Housing: The Project would not increase the population and housing of the surrounding Project area by producing more electricity for developing housing Projects within the City of Glendale. The Project would not be producing more electricity. In fact, the Project is repowering the existing Grayson Power Plant. In addition, a potential increase in the number of workers to be employed each month by craft during construction and for operations would not increase the population and housing of the surrounding community. There would be no impact. This issue was not further analyzed in the EIR. 2.0 Environmental Effects Which Were Determined to be Potentially Significant by the Initial Study and Further Analyzed in the Environmental Impact Report These environmental factors listed below were identified during the Initial Study to potentially be affected by the Project, and therefore were carried forward for analysis in the Draft EIR. The findings of the potential impacts were determined in the Draft EIR to be either less than significant or potentially significant requiring mitigation to become less than significant with mitigation incorporated. 2.1 Aesthetics (1) Potential Impact: Substantially degrade the existing visual character or quality of the site and its surroundings.

Finding: The demolition and operation of the Project would have a less than significant impact on the existing visual quality and character of the Project site. The temporary impact of Project construction, however, would be a potentially significant impact. After the implementation of project design features, standard conditions of approval, and mitigation measures, the Project will have a less than significant impact with mitigation incorporated.

34 F:/filenetcopyfcouncil Reports/041018 Resolution Making Findings and approving MMRP.docx Facts in Support of Finding: The existing Utility Operations Center Project site is bounded by a masonry wall to the east, west, and north. Therefore, construction activities, staging areas, and construction vehicles within the existing Utility Operations Center boundaries would be primarily screened and generally not visible to sensitive viewer groups. However, temporary construction activities occurring near the south side of the Project site, as well as temporary construction equipment (e.g., cranes) that exceed the height of the 12-foot masonry walls would be temporarily visible to sensitive viewer groups. In addition, the construction materials stored at the offsite construction laydown area would be visible to sensitive viewer groups within the area (e.g., Griffith Manor Park). However, the increased presence of construction activities, and storage of construction materials would temporarily contrast with the existing visual character and quality of views throughout the Project area during the 27-month construction period. In order to minimize short-term construction impacts, implementation of Mitigation Measure (MM) AES-1 would require the Applicant to visually screen construction activities and laydown areas and limit views of materials, equipment, vehicles, and other items used during construction from sensitive viewer groups. Once construction activities are complete, all evidence of the laydown areas and linear facility construction activities would be restored to the original condition or better condition. Therefore, with implementation of MM (Mitigation Measure) AES-1 impacts on visual resources would be less than significant. AES-1: Screen Lavdown Areas. Staging and laydown areas within view of residences, motorists, and recreational facilities shall be located away from public views or effectively screened using opaque fencing to limit views of materials, equipment, vehicles, and other items used during construction. All laydown areas shall be effectively reclaimed immediately following completion of their use. (2) Potential Impact: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

Finding: The potential for Project construction and operation to create a new source of light and glare, which would adversely affect day or nighttime views in the area would be less than significant. Facts in Support of Finding: There would be times during the construction/commissioning period when localized areas of the Project site would experience both increases and decreases in light levels depending on which phase/area of the Project is under construction. The sensitive receptors with elevated views occur at distances in which these changes would blend with existing industrial and urbanized nighttime lighting conditions. Lighting would be designed and installed to illuminate the Project site, and minimize spillover illumination into the Project’s immediate vicinity. Furthermore, lighting installed for the Project would comply with local policies and ordinances outlined in the City’s Municipal Code. Therefore, the potential for the Project

35 F:/filenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx operation to create a new source of light and glare, which would adversely affect day or nighttime views in the area would be less than significant. 2.2 Air Quality (1) Potential Impact: Conflict with or obstruct the implementation of the applicable air quality plan. Finding: The Project would not conflict with or obstruct the implementation of the applicable air quality plan because the significance levels of the Project from construction and operation activities are determined to be below the significance thresholds. The Project will use Best Available Control Technology to control the Project’s emissions. Additionally, the facility will offset the required emissions in accordance to SCAQMD Rule 1303. Therefore, the impacts would be less than significant. Facts in Support of Finding: The maximum daily emission caused by construction activities were calculated to be below the significance mass daily threshold for all criteria pollutants as summarized in Tables 4-12 and 4-13 of the Final EIR. The net increase of CC, PM1O, PM2.5, and 50x emissions from Project operations are estimated to be below the significance daily mass emission thresholds as reflected in Table 4-26 of the Final EIR. Additionally, the ambient air quality impact analysis, as shown in Table 4-29 of the Final Elfl, demonstrates that the Project will not be expected to cause or significantly add to a violation of national and California ambient air quality standards. Furthermore, the net emission increase of PM1O and SOx will be offset using emission reductions from SCAQMD internal account to account for Rule 1 304(a)(1) offset exemptions for replacement of functionally identical eqijipment. The net increase of NOx emissions from Project operations are estimated to exceed SCAQMD’s daily mass emission significance threshold. However, the ambient air quality impact analysis shows the NC2 emissions from this Project will not exceed the national and California ambient air quality standards as reflected in Table 4-29 of the Final EIR. Additionally, the increase in NOX emissions from the Project will be offset through the purchase of Emissions Reduction Credits in the open market and allocations from SCAQMD internal accounts. The net increase of VOC emissions from Project operations are estimated to exceed the daily mass emission significance threshold. The increase in VOC emissions attributed to the Project will be fully offset using emission reductions from SCAQMD internal account to account for Rule 1304(a)(1) offset exemptions for replacement of functionally identical equipment. (2) Potential Impact: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable

36 F:/filertetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx federal or state ambient air quality standard (including releasing emissions, which exceed quantitative thresholds for ozone precursors). Finding: Potential impacts relating to a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard are determined to be less than significant. Facts in Support of Finding: The criteria pollutant emissions caused by the construction and operation of the Project are determined to be less than significant by complying with South Coast Air Quality Management District (SCAQMD) rules and regulations. Additionally, as shown in Table 4-29 of the Final ER, the Project would not result in significant changes to existing air quality for which the region will be nonattainment under federal or state ambient air quality standards. Therefore, the impacts would be less than significant. (3) Potential Impact: Potentially violate any air quality standard or contribute substantially to an existing or projected air quality violation. Finding: As shown in Table 4-29 of the Final EIR, the Project is not expected to violate any air quality standard or contribute substantially to an existing or projected air quality violation. Therefore, potential impacts would be less than significant. Facts in Support of Finding: The air quality impact during the construction phase does not exceed the mass daily significance thresholds; and the air quality impact in operating the facility will be below the ambient air quality standards based on the air dispersion modeling conducted. • (4) Potential Impact: Potentially expose sensitiye receptors to substantial pollutant concentrations.

Finding: Potential impacts related to the exposure of sensitive receptors to substantial pollutant concentrations would be less than significant. The toxic air contaminants emission impacts from the earth moving activity would be less than significant. Facts in Support of Finding: The Project site is located in an industrial area of the City of Glendale at 800 Air Way Glendale, California 91201, northeast of the Interstate 5 and Highway 134 interchange. There is no K-i 2 school within 1,000 feet; the closes K-i 2 school will be Mark Keppel Elementary school, which is located more than 0.6 miles northeast from the emission sources. The nearest residential receptor is located approximately 694 feet (211 meters) from the emission sources and the nearest worker/commercial receptor is located approximately 572 feet (174 meters) from the emission sources. Both receptors are located in the northeast direction of the emission sources. Based on the result of ambient air quality analysis shown in Table 4-29 of the Final EIR, criteria pollutant concentrations from the Project are expected to disperse substantially before reaching any sensitive receptors. The Project will neither cause, nor substantially add to an existing violation of state or federal ambient air quality standards. 37 F:/filenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx Additionally, impacts from construction activities are expected to be below daily significance thresholds as well as localized significance levels as reflected in Tables 4- 12 and 4-13 and analyzed in Section 4.3.4 of the Final EIR. Toxic air contaminants emissions associated with the earth moving activity will consist primarily of combustion byproducts from off-road equipment and vehicles trips. The construction of the facility is anticipated to take place over a period of 27 months. Therefore, toxic air contaminants emissions from construction activity are not expected to have significant health impacts on cancer and non-cancer chronic risks because these risks are typically assessed for continuous exposure for 30 years. Additionally, the heaviest impacts of earth moving activity can be expected to occur within the fence line of the power plant. A health risk assessment was conducted following both OEHHA and SCAQMD guidelines. Based upon SCAQMD Rule 1401 and the SCAQMD CEQA significance thresholds, a cumulative maximum individual cancer risk (MICR) increase less than 10 in a million is considered to be less than significant when Best Available Control Technology for Toxics is used. Additionally, in accordance with SCAQMD guidelines, a cancer-burden greater than 0.5 excess cancer cases in areas with an incremental increase greater than one in one million individuals is considered to be significant. To assess acute and chronic non-cancer exposures, annual and 1-hour Toxic Air Contaminants ground-level concentrations are compared with the reference (safe) exposure levels (REL), which is developed by OEHHA. A hazard index (HI) is the ratio of Toxic Air Contaminants exposure of one hour for acute and long-term level for chronic from the facility to the REL. The total HI is calculated separately for acute and chronic effects. A total hazard index of less than one is considered to be below significance. The MICR values for residential receptors are 0.91 E-06, and for worker receptors are 0.06E-06, which are below the significance threshold of 10.OOE-06. The acute HI values for residential receptors are 0.0073, and for worker receptors are 0.0065, which are below the significance threshold of 1.00. The chronic HI values for residential receptors are 0.0024, and for worker receptors are 0.0026, which are below the significance threshold of 1.00. This information is summarized in Table 4-32 of the Final EIR and shows that the health risks that the Project poses to nearby residential and worker receptors are expected to be below the significance thresholds. 2.3 Geology and Soils (1) Potential Impact: Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction.

38 F:/tilenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx Finding: Potential impacts related to the exposure of people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving seismic- related ground failure, including liquefaction would be less than significant. Facts in Support of Finding: The Project site is not located within a mapped Alquist Priolo Special Studies Fault Zone (CDMG, 2002). The nearest fault is the Verdugo fault, located approximately 1.7 miles northeast of the Site. Based on available geologic data, there is low to moderate potential for surface rupture from the Verdugo fault and other nearby active faults during the design life of the proposed development. Because the site is located within a currently, mapped California Liquefaction Hazard Zone, a liquefaction evaluation for the site was completed. Results of this evaluation (encompassing the upper 40 feet of soils of the Project area) indicated that site conditions may be susceptible to seismically induced liquefaction in the event of a major earthquake (Stantec, 2015). To date, based on results provided in Stantec’s Geotechnical Study, dated December 10, 2015, the implementation of applicable building codes and recommendations provided in the aforementioned report, geological impacts are expected to be less than significant. (2) Potential Impact: Result in substantial soil erosion or the loss of topsoil.

Finding: With the implementation of required plans and procedures, impacts from soil erosion or loss of topsoil would be less than significant. Facts in Support of Finding: An erosion control plan, which is subject to review and approval by the City Engineer, would be required prior to any demolition- and construction-related activiti@s. Such plans must include procedures and equipment necessary to contain onsite soils and minimize potential for contaminated runoff from the Project site. In addition to the erosion control plan, preparation and implementation of a Stormwater Pollution Prevention Program (SWPPP), Dust Control Plan and Best Management Practices (BMPs) would also minimize erosion. (3) Potential Impact: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction of collapse. Finding: Impacts related to on- or off-site landslide, lateral spreading, subsidence, liquefaction of collapse would be less than significant. Facts in Support of Finding: Due to minimal slopes at the Project Site, landslides are not considered a potential hazard. Impacts would be less than significant. Near surface soils in the unsaturated zone consist of loose to very dense silty sands and stiff to very stiff silt. Loose, silty sands may be prone to volumetric strain resulting from cyclic loading of seismic activity. Surface settlements in the unsaturated zone were estimated to be approximately 11 inches, with differential settlements in the order of five to six 39 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx inches. Impacts would be less than significant. Lateral spreading typically occurs as a form of horizontal displacement of relatively flat-lying alluvial material toward an open or “tree” face such as an open body of water, channel, or excavation. This movement is generally due to failure along a weak plane, and may often be associated with liquefaction. As cracks develop within the weakened material, blocks of soil displace laterally toward the open face. Due to the depth of groundwater, the potential for lateral spreading is considered minimal. Impacts would be less than significant. The near- surface soils encountered in the proposed construction area consist predominantly of sands with varying amounts of silt. These soil types are not considered expansive, as identified in the Uniform Building Code (1994), and do not create substantial risks to life or property. It is not anticipated that soil will be imported for the Project. If imported soils are used for earthwork at the site, they should be tested for expansion potential prior to import. Impacts would be less than significant. 2.4 Greenhouse Gases (1) Potential Impact: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Finding: Potential impacts related to the generation of greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment would be less than significant. Facts in Support of Findings: As shown in Table 4-37 of the Final ER the net increase of Greenhouse Gases (GHG) emissions from the operation of the Project exceeds the significance threshold of 10,000 metric tons per year. The GHG emissions exceedance is solely contributed from operating the proposed combustion turbines and transformers. However, the Project is required to comply with the State cap and trade program by reporting C02e emissions from the Grayson Power Plant and acquiring allowances and offset credits to mitigate 100 percent of GHG emissions from the combustion equipment and transformers. Net emissions after mitigation will include only emissions related to facility occupants and will be well below the 10,000-metric ton significance threshold. Therefore, the impact would be less than significant. (2) Potential Impact: Potentially conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

Finding: Potential impacts related to a conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases would be less than significant. Facts in Support of Finding: Even though the Project will generate GHG emissions exceeding the C02e significance threshold of 10,000 metric tons per year, the Project will be required to comply with the State cap and trade program, which was established to support the State’s goals to reduce GHG emission to 40 percent below 1990 by 2030 and 80 percent below 1990 levels by 2050. Emissions from the Project will be fully 40 F:/filenetcopy/Council ReportsfO4l 018 Resolution Making Findings and approving MMRP.docx offset through the retirement of GHG allowances held by Glendale Water and Power (GWP), and additional credits to be purchased by GWP. The Project includes installing and operating newer equipment that generates less GHG emissions on a pound per megawatt-hour basis than the existing equipment at Grayson Power Plant. In addition, the Project will allow the City to maximize the import of renewable energy sources through the limited existing transmission capacity into the City which will further assist the City in meeting the Renewable Portfolio Standards and GHG reductions specified in the Greener Glendale Plan. The Project is therefore consistent with the Greener Glendale Plan. Therefore, the impact would be less than significant. 2.5 Hazards and Hazardous Materials (1) Potential Impact: Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Finding: The level of significance before mitigation would be a potentially significant impact. After the implementation of mitigation measures, the Project will have, a less than significant impact with mitigation incorporated. Facts in Support of Finding: Soil contaminated with petroleum hydrocarbons may be encountered during subsurface demolition activities based on soil sampling surveys and analysis. Although it is unlikely to encounter groundwater during demolition activities, volatile organià compounds found in groundwater samples indicates that soil may be contaminated with volatile organics and could be encountered during subsurface demolition activities. Excavation, handling, and transport of contaminated soil and ground water has the potential to impact workers and the public if not handled and contained properly. The quantities of hazardous materials that will be used onsite during construction will be limited to the quantities required to complete construction of the Project. The potential exists for fuels, oil, and grease to drip from construction equipment. The volume of incidental drips of petroleum products is not anticipated to require clean up or disposal of hazardous materials. Spills of fuel may occur during onsite refueling operations if refueling operations are not conducted properly. It is not anticipated that spills related to refueling operations would be large and would be limited to the immediate area and cleaned up at the time of the spill using spill kits stationed on the fuel truck. It is unlikely that the volume of refueling spills will travel beyond the immediate area of the spill and impact offsite receptors. Therefore, with the implementation of MMs HAZ-1, HAZ-2, HAZ-3, HAZ-4, and HAZ-5, the impacts to the public or environment through routine transport, use, or disposal of hazardous materials would be less than significant. HAZ-1: Prior to demolition of facilities associated with the Grayson Repowering Project, hazardous materials stored onsite and not required for continued operation of the facility shall be inventoried, packaged, removed, and disposed in accordance with a Hazardous Materials Management Plan prepared by the

41 F:/filenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx demolition contractor and submitted to the City for review and approval prior to initiating demolition activities. HAZ-2: Buildings or equipment to be demolished containing lead based paint or asbestos shall be either decontaminated or encapsulated prior to removal from the Project site and disposed in accordance with an Asbestos and Lead Paint Management Plan prepared by the demolition contractor and submitted to the City for review and approval prior to initiating demolition activities. HAZ-3: Contaminated soil encountered during demolition activities shall be handled, removed, and disposed in accordance with regulatory requirements and the Project’s Soil Management Plan. HAZ-4: Hazardous materials used during construction shall be limited to the quantities required for construction and shall be stored and handled in accordance with regulatory requirements. HAZ-5: Utility trucks and refueling trucks operating onsite shall have a spill kit onboard at all times. Small spills of petroleum products or other hazardous materials during construction operations shall be reported to the Construction Supervisor and ~ Spill Response form completed with a description of the type and quantity of the spill accompanied by photographs and a description of the disposition of the spill material. Hazardous spill material shall be disposed according to regulatory requirements. In the event of a large spill of hazardous materials equal to or above reportable quantities federal, state, and local reporting requirements shall be followed. (2) Potential Impact: Create a significanthazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Finding: The level of significance before mitigation would be a potentially significant impact. After the implementation of mitigation measures, the Project will have a less than significant impact. Facts in Support of Finding: An off-site consequence analysis was performed for the accidental release of aqueous ammonia using the U.S. Environmental Protection Agency approved SLAB dispersion model. The analysis assumed the complete failure of the storage tank, the immediate release of the contents of the tank and the formation of an evaporating pool of aqueous ammonia within the secondary containment structure. Under this scenario, evaporative emissions of ammonia would be subsequently released into the atmosphere. The dispersion and transport of these emissions into the atmosphere would be subject to meteorological conditions at the time of the release. To further provide a conservative analysis of potential offsite consequences .of an ammonia release, a concentration of 75 parts per million ammonia has been adopted as the applicable significance threshold. The 75 parts per million 42 F:/tilenetcopy/Council Reports/041 018 Resolution Making Findings and approving MMRP.docx threshold is considered by the California Energy Commission to be the concentration the public could be exposed to during a one-time event without experiencing serious adverse effects. As it relates to the Project, a concentration of ammonia exceeding 75 parts per million beyond the property boundary of the power plant would be considered a potentially significant impact. The nearest property boundary is approximately 70 feet from the nearest ammonia tank. The results of the offsite consequence analysis for the worst-case release of ammonia indicate that the 75 parts per million concentration would extend 528 feet from the ammonia tan k/release. This distance would extend beyond the Grayson Power Plant eastern property boundary and is considered a potentially significant impact. Therefore, with the implementation of MM HAZ-6, the impacts to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment would be less than significant. HAZ-6: The surface area of the proposed and existing ammonia tank containment systems shall be effectively reduced by 90 percent or greater through the installation and maintenance of three-inch diameter high density polyethylene balls or similar method. 2.6 Hydrology and Water Quality (1) Potential Impact: Violate water quality standards or waste discharge requirements. Finding: During demolition and construction, impacts to water quality standards or waste discharge requirements would be less than significant. Based on the improvements to the facility’s stormwater management systems proposed as part of the Project, impacts related to water quality and stormwater discharge would be less than significant and would result in a beneficial impact. Facts in Support of Finding: Soil temporarily exposed during excavation and grading activities associated with construction of the Project may be subject to sheet erosion during rain events thereby increasing the level of suspended solids in flows emanating from the site. In addition, the demolition of the existing facility may result in the exposure and/or disruption of contaminated soils, which may impact surface water quality during storm flows. To comply with applicable requirements of the National Pollutant Discharge Elimination System (NPDES) program and, Stormwater and Urban Runoff Pollution Prevention Control and Standard Urban Stormwater Mitigation Plan (SUSMP) of the Glendale Municipal Code, the applicant is required to prepare a SWPPP containing structural treatment and source control measures appropriate for the Project, which would be incorporated as a condition of approval. The SWPPP will incorporate BMPs that control pollutant discharges through the use of best available technology economically achievable (BAT) and best conventional pollutant control technology (BCT). Examples of BAT/BCT include straw wattles and/or hay bales, straw bale inlet filters, filter barriers, and silt fences. Implementation of the measures included in the

43 R/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx SWPPP as well as those included in the Project’s Soil Management Plan would ensure that Regional Water Quality Control Board (RWQCB) water quality standards are met during demolition and construction activities associated with the Project. Therefore, impacts would be less than significant during demolition or construction. The proposed stormwater capture, treatment and infiltration system would result in improved drainage conditions and stormwater runoff quality compared to the existing system. Based on the improvements to the facility’s stormwater management systems proposed as part of the Project, impacts related to water quality and stormwater discharge would be less than significant and would result in a beneficial impact. (2) Potential Impact: Potential to substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site.

Finding: Potential impacts related to the alteration of the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or off-site would be less than significant. Facts in Support of Finding: Construction activity associated with the Project may result in wind- and water-driven erosion of soils due to minor grading activities if soil is stockpiled or exposed during construction. However, this impact is considered short term in nature because the site would expose a relatively small amount of soil during construction activities and would then be covered with building and pavement upon completion of the Project. Soils disturbed during demolition and/or construction would be handled in accordance with the Project’s Soil Management Plan. Furthermore, as part of the Project, the applicant would be required to adhere to conditions under the NPDES Permit set forth by the RWQCB, and to prepare and submit a SWPPP to be administered throughout Project construction. The SWPPP would incorporate BMPs to ensure that potential water quality impacts from water-driven erosion during construction would be reduced to a less than significant level. Furthermore, the SWPPP would incorporate BMPs by requiring controls of pollutant discharges that utilize BAT and BCT to reduce pollutants. In addition, Stormwater and Urban Runoff Pollution Prevention Control and Standard Urban Stormwater Mitigation Plan of the Glendale Municipal Code, a SUSMP containing design features and BMPs to reduce post- construction pollutants in stormwater discharges would be required as part of the Project. Consequently, impacts are considered to be less than significant. (3) Potential Impact: Potentially create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff. Finding: Potential impacts related to the creation or contribution of runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff would be less than significant.

44 F:/tilenetcopyfCounoil Reports/041 018 Resolution Making Findings and approving MMRP.docx Facts in Support of Finding: As part of the Project, the applicant would be required to adhere to conditions under the NPDES Permit set forth by the RWQCB, and to prepare and submit a SWPPP to be administered throughout Project construction. The SWPPP would incorporate BMPs to ensure that potential water quality impacts from water-driven erosion during construction would be reduced to a less than significant level. As discussed above, the SWPPP would incorporate BMPs by requiring controls of pollutant discharges that utilize BAT and BCT to reduce pollutants. In addition, Stormwater and Urban Runoff Pollution Prevention Control and Standard Urban Stormwater Mitigation Plan of the Glendale Municipal Code, a SUSMP containing design features and BMPs to reduce post-construction pollutants in stormwater discharges would be required as part of the Project. Consequently, impacts are considered to be less than significant.

2.7 Noise (1) Potential Impact: Potential to expose persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Finding: The level of significance before mitigation would be a potentially significant impact. After the implementation of mitigation measures, the Project will have a less than significant impact. Facts in Support of Finding: The finding classification was potentially significant because, with the exception of the power equipment supplied by Siemens, the final selection for the remaining equipment is not yet known. It is entirely possible that without the noise limits advised in Table 4.53, found in the EIR, the final equipment selected for the project could result in the Project exceeding the noise design targets and effecting significant noise impacts. The noise mitigation measures described below represent limits on noise emissions from equipment and Project components that are not part of Siemens supply. These limits are reasonable and can be practically accommodated. Therefore, with the implementation of MMs NOl-1 through NOl-lO, the impact of potential exposure to persons or the generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies would be less than significant.

NOl-1: Noise Source and Required Noise Control Measures: Cooling Towers — The noise emissions from each cooling tower shall be limited to 57 dBA at 400 feet (107 cIBA sound power level). Mats may be required to limit the water splash noise. NOl-2: Noise Source and Required Noise Control Measures: Cooling Tower Fan

Motors and Gearboxes - The sound power levels for cooling tower motors shall be limited to 98 dBA (85 dBA at 3’) the motors shall be placed on the west side of the towers.

45 F:/filenetcopy/Council Reportsfo4l 018 Resolution Making Findings and approving MMRP.docx NOl-3: Noise Source and Required Noise Control Measures: Fuel Gas

Compressors - The noise emissions from each of the two fuel gas compressor areas shall be limited to 44 cIBA at 400 feet. Compressor enclosures or properly designed noise barriers can be utilized. Under the current assessment scenario open air compressor equipment packages with total sound power level of 108 dBA were treated with 21-foot sound barrier to yield appropriate results. NQl-4: Noise Source and Required Noise Control Measures: Water Treatment

Area - The noise emissions from the water treatment area shall be limited to 48 dBA at 400 feet. It is expected that this level can be achieved through a combination of equipment selection, small enclosures and barriers. NOl-5: Noise Source and Required Noise Control Measures: Boiler Feed Water

Pumps for Combined Cycle Units - The sound power levels for boiler feed water pumps shall be limited to 105 dBA when placed outside near the respective HRSGs. NOl-6: Noise Source and Required Noise Control Measures: Circulating Water

Pumps for Cooling Towers - The sound power levels for circulating water pumps shall be limited to 101 dBA when placed outside near the respective cooling towers. Ndl-7: Noise Source and Required Noise Control Màasures: Generator Step-up

Transformers - Standard NEMA 95 MVA rated transformers or lower shall be utilized. NOl-8: Noise Source and Required Noise Control Measures: Steam Turbine

Building - The sound power level of the noise breaking out from the steam turbine building shall be limited to 95 dRA and 115 dBC (45 cIBA and 65 dBC at 400 feet). Specialized enclosures for the gearboxes shall be required and steam turbine building walls and roofs shall have an STC 40 composite transmission loss rating.

NOl-9: Noise Source and Required Noise Control Measures: Steam Pipe Rack - The sound power level for the steam pipe rack shall be limited to 82 dBA per meter of piping. Nd-i 0: Noise Source and Required Noise Control Measures: Steam Sky vents

and safety valves - Steam sky and safety valves shall be equipped with silencers to limit their noise emissions to 115 dBA sound power (approximately, 90 cIBA at 5’). (2) Potential lm~act: Potential to expose persons to or generate excessive ground borne vibration or ground borne noise levels.

46 F:/filenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx Finding: Potential impacts related to the exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels would be less than significant. Facts in Support of Finding: No significant vibration or ground-borne noise effects are expected during the construction or operation of the Project. Project vibration levels beyond the Project site boundary during operations are expected to be negligible. The operational vibration levels are expected to be well below the City of Glendale presumed perception limit of 0.01 in/s anywhere outside of the Project site boundary and as such, are not expected to be detectable. Predicted maximum demolition and construction vibration levels are below the preferred vibration thresholds. The Project would therefore not result in exposure of persons to or generation of excessive ground borne vibration or ground borne noise levels nor would damage to the nearby structures would be expected. Potential impacts are less than significant. (3) Potential Impact: Potential to create a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project. Finding: Potential impacts related to a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project would be less than significant. Facts in Support of Finding: Overall, the Project noise results in a permanent increase in area ambient sound levels of less than 2.5 dB during nighttime hours and less than 1 dB during the daytime hours. The change in the ambient sound level should be barely perceptible. Table 4-62, found in the EIR, shows the summary of predicted increases in ambient sound levels. During the ambient sound survey, the existing Grayson facility was substantially nonoperational with. only a minimal amount of pieces of equipment running. Correspondingly, the current ambient sound levels do not reflect the full operation of the facility and are thus understated. It is therefore expected that the actual change in the area ambient sound levels will be lower than that predicted. Therefore, the impact would be less than significant. (4) Potential Impact: Potential to create a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project.

Finding: Potential impacts related to a substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project would be less than significant. Facts in Support of Findings: A substantial temporary increase in ambient noise levels may result from the demolition and construction activities associated with the project. Such increases will fluctuate with changing activities and to a certain extent be intermittent. Some of the noisiest activities, such as pile driving will be relatively short term. Most of the noise sources associated with the existing operation will be removed. This should provide a considerable off-set for the construction and demolition noise 47 F:/filenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx effects at the nearby residential receptors. It should be pointed out that the current construction schedule calls for construction work to be done during the daytime hours of 7:00 a.m. to 7:00 p.m. Correspondingly, construction and demolition noise is will comply with the City of Glendale Noise Ordinance. However, to the extent that is feasible and practical, the contractor will limit the noise effects from construction and demolition activities to between 65 and 70 cIBA Leq during the daytime hours. Some activities may intermittently be above the 65 and 7OdBA Leq levels. Overall, the temporary increase in ambient noise levels from demolition and construction actives will have a less than significant impact because thresholds for Project construction and operation will not be exceeded. Therefore, the impact would be less than significant. 2.8 Transportation and Traffic (1) Potential Impact: Potential to conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit.

Finding: The level of significance before mitigation would be potentially significant impact. After the implementation of mitigation measures, the Project will have a less than significant impact. Facts in Support of Finding: Roadway segments in the local transportation network could potentially be damaged by truck traffic. There is also the potential for tracking dust, soils, and other materials from the construction sites onto public and private roads. Although relatively large volumes of loaded trucks have the potential to chronically damage roadways, truck trips associated with the project construction would be legally loaded. Any extra-legal loads needed for specialized deliveries, would be subject to a permit process involving fees and special requirements. The potential for damage to public and private roadways from construction traffic is considered significant. Caltrans District 7 has established LOS FO as the minimum acceptable level of service on the freeway system (Caltrans, 1996). If an existing freeway system is operating at less than the acceptable LOS, the existing Measure of Effectiveness should be maintained. Segment 7 along 1-5 has an existing LOS below the minimum acceptable level. The AADT for segment 7 is 294,000 vehicles. The Project would add an ADT average of 513 vehicles during the peak period (construction, January 2020). The construction trip distribution calculates that 65% of the 513 vehicles will utilize I-S. Therefore, approximately 334 vehicles may travel along segment 7 of 1-5 consisting of 0.11% of the AADT along this freeway. The Project contribution of 0.11% is not expected to degrade the existing measure of effectiveness (MOE) along segment 7. The Project would generate a short-term impact at the San Fernando Road/Doran Street intersection by adding V/C 0.05 during the p.m. peak hour, which would exceed the City of Glendale’s threshold of V/C 0.02 for signalized intersections operating at LOS D, E, or F. As per the

48 F:/filenetcopy/council RepdHs/041 018 Resolution Making Findings and approving MMRP.docx direction by the City, the Project personnel trip generation estimates assume that 25 percent of construction personnel arrive during the a.m. peak hour and 50 percent of construction personnel depart during the p.m. peak hour to provide for a conservative analysis. The threshold is exceeded when the total number of project personnel exceed 95 persons. As per Table 4-68, project personnel expected during the construction phase is 180 persons. Project personnel trips during the demolition and commissioning phases are not expected to exceed 60 and 35 persons; respectively. The intersection can accommodate 24 vehicle trips during the p.m. peak hours before the threshold is exceeded. The additional traffic during the construction phase is directly related to construction worker parking on the temporary lot on Doran Street. This short-term significant impact is expected to be for a maximum 21-month time period (construction duration). Although actual construction personnel shifts may typically begin and end outside of peak traffic times, the potential temporary construction impact to the San Fernando Road/Doran Street intersection has been conservatively assumed to be a potentially significant impact. Therefore, with the implementation of MMs TRA-1 through TRA-8, the impact to conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit would be less than significant. TPA-1: To accommodate turning movements by large trucks (CA-Legal 65 feet) and public safety on Fairmont Avenue, the demolition and construction contractor shall be required to prepare a traffic control plan for City review and approval prior to initiating demolition and construction activities that includes the use of large trucks entering and departing the Grayson Power Plant from Fairmont Avenue: TRA-2: To reduce construction traffic at the San Fernando Road and Doran Street intersection during the p.m. peak hours, a construction traffic control plan shall be developed by the contractor, reviewed and approved by the City, and implemented for the duration of the construction phase. The plan shall include measures to limit vehicle trips to a total of 24 trips or less during the hours of 4 to 6p.m. for the San Fernando Road and Doran Street intersection. Measures may include scheduling of construction activities or trip routing to minimized travel during peak p.m. traffic times, ride sharing, closing the parking lot, and/or other effective and verifiable measure. TRA-3: The applicant shall ensure that traffic control is implemented for the duration of demolition and construction phases. Traffic control shall include construction warning signs on Fairmont Avenue (Trucks Entering Exiting), and monitoring (flag person) on public roadways as needed during large transports.

49 F:ffilenetcopy/council Reports/041018 Resolution Making Endings and approving MMRP.docx TRA-4: A construction traffic control plan shall include provisions for days when high truck traffic is generated (sail delivery days, peak concrete delivery days). The plan will include considerations for truck staging to ensure that truck parking/staging can be accommodated off the City streets. TRA-5: Traffic control monitors shall direct traffic whenever heavy construction equipment is entering and exiting the plant as warranted to ensure public safety. The traffic monitor shall be posted throughout the demolition and construction periods, as necessary. The applicant shall coordinate with the Glendale Fire Department in order to ensure that traffic control routes and procedures would allow for adequate emergency access. TRA-6: All construction-related vehicles, equipment staging and storage areas shall be located in approved pre-determined areas that are outside of adjacent road right of ways. The applicant shall provide all construction personnel with a written notice of this requirement and a description of approved parking, staging and storage areas. The notice shall also include the name and phone number of the applicant’s designee responsible for enforcement of this restriction. TRA-7: Construction traffic shall comply with the California Vehicle Code sections related to vehicle weight and width. Any extra-legal loads needed for specialized deliveries shall be subject to special permit requirements from the City of Glendale. Should roadway damage occur along the haul route that is directly attributable to the demolition and construction of the Project, repairs will be assessed by the City and completed accordingly. TRA-8: Fugitive dust control shall be implemented according to SCAQMD Rule 402, 403 and 1186, and California Vehicle Code Section 23114, and Building & Safety requirements. Dust control mitigation measures include: • Soil stabilizers and dust suppressants to control fugitive dust levels from exposed soils. • On-site water trucks to provide control of fugitive dust while soil is moved or disturbed. • Off-site vacuum and broom sweepers to remove any fugitive materials from the public roadways. • Track-out control to prevent dirt and mud from being spread to public • roadways: o Sweeping or spray cleaning trucks prior to leaving project site. o Adequate truck load covering.

50 F:/filenetcopy/council Reports/041 018 Resolution Making Findings and approving MMRP.docx o Limit on-site vehicle speeds to 15 mph. (2) Potential Impact: Potential to conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit.

Finding: Impacts related to a conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non-motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit would be less than significant. Facts in Support of Finding: Caltrans District 7 has established Level of Service (LOS) FO as the minimum acceptable level of service on the freeway system (Caltrans, 1996). If an existing freeway system is operating at less than the acceptable LOS, the Measure of Effectiveness (MOE) should be maintained. Segment 7 along I-S has an existing LOS below the minimum acceptable level. The Average Annual Daily Traffic (AADT) for segment 7 is 294,000 vehicles. The Project would add an ADT average of 513 vehicles during the peak period (construction, January 2020). The construction trip distribution calculates that 65% of the 513 vehicles will utilize 1-5. Therefore, approximately 334 vehicles may travel along segment 7 of 1-5 consisting of 0.11% of the AADT along this freeway. The Project contribution of 0.11% is not expected to degrade the existing MOE along segment 7. Based on the foregoing analysis, the Project will not conflict with the Congestion Management Plan LOS. Therefore, potential impacts would be less than significant. 2.9 Tribal Cultural Resources (1) Potential Impact: Potentially cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

Finding: There would be no impact to the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

51 F:/tilenetcopy/Council Reports/041018 Resolution Making Findings and approving MMRP.docx Facts in Support of Finding: The City has notified California Native American tribes who have formally requested notification on CEQA projects under Assembly Bill 52 that the City proposes to undertake the Project. This notification affords California Native American tribes the opportunity for consultation pursuant to Public Resources Code § 21080.3.1. The Fernandeno Tataviam Band of Mission Indians and Soboba Band of Luiseno Indians were notified by the City of Glendale and did not seek further consultation. On this basis, and also on the basis of the previous cultural resource survey which did not identify any cultural resources on the project site, the Project would have no significant impact to the criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.

52 F:/tilenetcopy/council Reports/041018 Resolution Making Findings and approving MMRP.docx RESOLUTION NO.

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF GLENDALE, CALIFORNIA APPROVING THE GRAYSON REPOWERING PROJECT [OR A PROJECT OPTION] AND DIRECTING STAFF TO TAKE ACTIONS IN FURTHERANCE THEREOF

WHEREAS, the City’s aging Grayson Power Plant is experiencing an increasing frequency in unplanned and forced outages, which threaten local reliability; and

WHERAS, the Grayson Power Plant is not expected to be able to continue operating beyond the early 2020s and proposed regulations by the South Coast Air Quality Management District are expected to require a major air quality retrofit, or force the closure of the Grayson Power Plant, by 2023; and

WHEREAS, without the Grayson Power Plant, the City will not have sufficient sources of power to meet energy demand within the City, while also maintaining sufficient power reserves, on the hottest days of the year; and

WHEREAS, the City of Glendale Department of Water and Power proposes to repower the existing Grayson Power Plant by replacing 235 MW (gross) of the existing capacity from the boiler units (Units 3, 4, 5) and combined-cycle units (Units 1, 2, 8A and 8BC3) with more efficient generation (“Proposed Project”). The Proposed Project would comprise two 71 MW (net) combined-cycle units and twO 60 MW (net) simple- cycle units; and

WHEREAS, a Final Environmental Impact Report, State Clearinghouse No. 2016121048 (“Final EIR”), was prepared for the Proposed Project in conformance with the California Environmental Quality Act, Public Resources Code Section 21000 etseq. (“CEQA”), Title 14 of the California Code of Regulations, Section 15000 etseq. (“State CEQA Guidelines”), and the Guidelines of the City of Glendale for the Implementation of the California Environmental Quality Act of 1970, as amended (“City CEQA Guidelines”) and released on March 1, 2018; and

WHEREAS, on April 10, 2018, at a duly-noticed public hearing, the City Council certified that (i) the Final EIR has been completed in compliance with CEQA and the State and City CEQA Guidelines, (ii) the Final EIR has been presented to the City Council at a duly-noticed public hearing and the City Council has independently reviewed and considered the information contained in the Final EIR, and (iH) the Final EIR reflects the independent judgment of the City of Glendale as the Lead Agency.

F:/filenetcopy/CG/Council Reports/041 018 Resolution Approving Projector Option 9A3 NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Glendale, California that: 1. The Grayson Repowering Project, defined herein as:

is hereby approved, adopted, and shall hereafter be known as Grayson Repowering Project; and 2. Staff is hereby directed to issue bids for electric revenue bonds for the Grayson Repowering Project, prepare bond documentation, and seek City Council adoption of a bond ordinance; and 3. [IF THE PROPOSED PROJECT IS SELECTED] Staff is hereby directed to Issue a Final Notice to Proceed to Siemens Energy, Inc. to proceed with the manufacture and procurement of the major equipment (the power island equipment) required to implement the Grayson Repowering Project; and [IF THE 191 MW OPTION OR 131 MW OPTION IS SELECTED] Staff is hereby directed to Issue a Final Notice to Proceed to Siemens Energy, Inc. to proceed with the manufacture and procurement of the major equipment (the power island equipment) required to implement the Grayson Repowering Project. In addition, staff is hereby directed to issue bids for the procurement of a 50 MW battery storage system; and 4. [IF THE PROPOSED PROJECT IS SELECTED] Following City Council award, staff is hereby directed to enter into a contract with an Engineering, Procurement and Construction contractor to proceed with the engineering, procurement of balance of plant equipment, and construction of the Grayson Repowering Project; and [IF 191 MW OPTION IS SELECTED] Staff is hereby directed to negotiate with prequalified Engineering, Procurement, and Construction Contractors for the costs of designing a three-unit plus 50 MW battery project, in lieu of the four-unit Project. Following City Council award, staff is hereby directed to enter into a contract with an Engineering, Procurement and Construction contractor to proceed with the engineering, procurement of balance of plant equipment, and construction of the Grayson Repowering Project; and [IF THE 131 MW OPTION IS SELECTED] Staff is hereby directed to negotiate with prequalified Engineering, Procurement, and Construction Contractors for the costs of designing a two-unit plus 50 MW battery project, in lieu of the four-unit Project. Following City Council award, staff is hereby directed to enter into a contract with an Engineering, Procurement and Construction contractor to proceed with the

2 F:/filenetcopy/CG/council Reports/04101 8 Resolution Approving Project or Option engineering, procurement of balance of plant equipment, and construction of the Grayson Repowering Project; and 5. Staff is hereby directed to solicit bids for the demolition of the Grayson Power Plant and following award, enter into a contract for the demolition contract; and 6. Staff is hereby directed to finalize the negotiation of contracts for the purchase of emissions reduction credits for the Grayson Repowering Project.

Adopted this day of ______, 2018.

Mayor

ATTEST:

City Clerk

FORM ~9~1AISThNTWAUORNEY

3 F:/tilenetcopy/CG/Council Reports/041 018 Resolution Approving Project or Option STATE OF CALIFORNIA SS COUNTY OF LOS ANGELES

I, Ardashes Kassakhian, Clerk of the City of Glendale, certify that the foregoing

Resolution No. ______was adopted by the Council of the City of Glendale,

California, at a regular meeting held on the ______day of ______2018, and that same was adopted by the following vote:

Ayes: Noes: Absent: Abstain:

City Clerk

4 F:/filenetcopy/CG/Counoil Reports/041018 Resolution Approving Project or Option MOTION

Moved by Council Member ______, seconded by Council

Member ______, that, with respect to the proposed repowering of the

Grayson Power Plant and its Final EIR, the City Council directs staff as follows:

Vote as follows:

Ayes;

Noes;

Absent:

Abstain:

TO FORM

9A4 F:/filenetcapy/041018 Grayson FE~ Provide Staff Direction.docx ATTACHMENT 1

South Coast Air Quality Management District

Memorandum Dated February 20, 2018 • SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT. MEMORANDUM DATE February 20,2018

TO:• AndrewLee : . FROM: Jd Kay Ghosh SUBJECT: Modeling Review of Glendale Department of Water and Power’s GraysOn Power Plant (Facility ID 800327) (A/N 595673-597684)

As you requested, Planning, Rule Development & Area: Sources (PRDAS) staff reviewed a dispersion modeling analysis andHealth Risk Assë~smëftt ~HRA) conduCted for the proposed increase of 24 MW generating capacity at located at 800 Air Way in the city of Glendale. The project consists of the installation of two simple cycle gas turbine generators and two combined cycle gas turbine generators. These will replace existing boilers 3, 4, 5, and gas t bine generators 8A, 8B, and 8C The dispersion modeling analysis, ERA, and supporting electronic files were submitted for PRDAS staff review along with the modeling request memo dated July 14, 2017 A revised dispersion modeling analysis for particulate matter and a revised report Were subthitted to PRDAS staff on December 8, 2017

PRDAS staff comments on the dispersion modeling analysis and 1-IRA conducted are as follows

SUMMARY OF MODELING REVIEW ...... • Modeling Conducted Pursuant to SCAQMD Regulations XIII Requirements “ The modeling requirements of Rule l303(b)(l.) apply.to the proposed project for CO. N02, 802 and PMio. The modeled impacts are below all thresholds in Rule 1303 for CO, NO2,

SO2 and PMio. . • Modeling Conducted Pursuant to SCAQMD Regulation XIV Requirements V The proposed prOject’s health risks are less than the Rule 1401 cancer and non-cancer permit limits of 1 in one million (for permit units without T-BACT), and hazard index of 1, respectively.

DETAILED COMMENTS ON THE MODELING REVIEW

• AERMOD Dispersion Modeling . V the applicant utilized AERMOD (version 162 16r) for the air dispersion mod~eling, which is the current U.S. EPA approved model. V The applicant used meteorological data from SCAQMD’s Burbank station for the years of

2008 - 2012, which was the appropriate meteorological data set at the time Of the analysis. V The applicant used NED 1 arc-second terrain data as input into AERMAP (version 11103) to deterthine receptor, source; and building elevations, which is appropriate. V The modeling domain used: was 6.5 kilometers by. 6.0 kilometers, with a Cartesian receptor grid of 50 meters by 50 meters spacing and fenceline spacing of 2Q meters. Discrete

Attachment 1 Andrew Lee -2 - February 20,2018

Cartesian receptors were placed at residential and off-site worker locations for the health risk analysis. The receptor grid selection is appropriate to capture the maximum impacts. V The applicant used the monitoring data from SRA 1, Central Los Angeles monitoring stations for the last three years (2013 —2015) to determifle the background concentrations. The predicted modeling impacts were added to the highest backgroun4 concentrations for comparison to the state and federal ambient air 4uality standards (AAQS), which is appropriate. V The applicant used the URBAN dispersion option in AERMOD, with a population of 9,862,049 for Los Angeles County, which was the appropriate value at the time of the analysis. V PRDAS staff reproduced the dispersion modeling analysis and NRA, and~ the results are summarized below.

Impacts During Commissioning V Turbine commissioning is an once-in-a-lifetime event. Cc5thmissiohing activities for the four turbines will be sequential. V The stack parameters and emission rates modeled are consistent with the parameters listed in Table 3-6 and 3-7, Page 11 of the report. Engineering & Permitting staff confirmed that the parameters were correct. V Commissioning period emissions were combined with normal operation emissions for 24- hour particulate matter modeling runs. Therefore, the 24-hour PMio and PM2.s emissions

will be listed in Tables F — J and will represent the maximum concentrations from both scenarios.

-2- Andrew Lee. . February 20, 2018

Table A — Impacts during Commissioning—Total Project

Maximum ...... Attainment . . . . . Baclcground . Total... California Federal .

Pollutant & Modeled Concentration Concentration . AAQS b •AAQS b Exceeds : Concentration ...... Threshold? Averaging Time (~.sg/m3) .. .., (~/m3).~ : (jig/rn3) (jig/rn3)

CO. 1-hr . 186.5 . 3,68Q.0 3,866.5 . 23,000 40,000 . No

N02,1-hrc 142.8 109.8 . 312.5: .d . No

N02,Annual0 0.4. 41.7 411 57 . . . 100 .•~ NO

SO2, lIt 1.6 35.1 36.7 655 196 C No

. . Maximum . . . Non-attainment California FederalS . . . . . ~ Modeled . . . Rule 1303 Thresholds Exceeds Pollutant & . . AAyS AAyS ...... Concentration 3 . . (jig/rn3). . Threshold? Averaging Time (/3) (gg/m) ~g/m3) . . ..

PMio,Annual. 0.2 20 -. . I . . :No

PM15, Annual 0.2 12 . 12 . :1 . .No Note: ‘Maximum values for CO, NO2, PM10, and 502 from SRA 1, Central Los Angeles (No. 87) monitoring station for

the last three years (2013 —2015) was used. . .. . b Both the California and Federal AAQS values listed are not.to be exceeded, except.otherwise noted. The conversion ofNOx to NO2 was done using Tier 2 ARM2 methdd for 1-hour nnd ARM ratio of 0.75 for annual,

which was an acceptable niethod at the time of submittal. . . .• .,. .: . . . On April 12,2010, the US. EPA established anew 1-hourNO2 standard of 100 ppb (188 ~Wm3). The form of the federal 1-hour NO2 standard mvolves a three year average of the 98th percentile of the annual distribution of daily maxithum 1-hour concentrations. Based on the U.S. EPA’s memo dated March 1,201 1, commissioning is a once in a lifetime event and therefore, can be etluded from compliance with the federal 1-hour NO2 standard. On June 2, 2Q10, the.U.S. EPA established anew 1-hour. SO2 standard of 75 ppb (196 ~g/rn3). The form of the federal I -hour SO2 standard involves a three year average of the 99th percentile of the annual distribution of daily

maximum 1-hour concentrations. . . . . The South Coast Air. Basin is designated non-attainment for the state PM10 standards, and state and federal PM2.s standards; therefore, project increments are compared to the significant change thresholds in Rule. 1303.

-3- Andrew Lee -4- February 20, 2018

Table B — Impacts during Commissioning — Unit 10 Maximum Attainment Background Total California Federal Modeled Pollutant & Concentration a Concentration AAQS ,b AAQS b Exceeds Concentration Threshold? Averaging Time (jig/rn3) (gg/m3) (jig/rn3) (jig/m3)

CO, 1-hr 43.2 3,680.0 3,723.2 23,000 40,000 No

N02, I-hr’ 20.1 169.8 189.9 339 - d No

N02, Annual C 0.2 41.7 41.9 57 100 No

SO2, 1-hr 0.8 35.1 35.9 655 196 e No Maximum Non-attainment Modeled California Federal Rule 1303 Thresholds Exceeds Pollutant & Concentration AAQS AAQS Averaging Time (/3) (jig/rn3) (jig/m3) (jig/rn3) Threshold?

PMjo, Annual 0.1 20 - 1 No PMa5, Annual 0.1 12 12 1 No Note: Maximum values for CO, NO2, PM10, and SO2 from SRA 1, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted. The conversion of NOx to NO2 was done using Tier 2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submittal. On April 12,2010, the U.S. EPA established a newl-hourNO2 standard of 100 ppb (188 jig/m3). The form of the federal I-hour NO2 standard involves a three year average of the 98th percentile of the annual distribution of daily maximum I-hour concentrations. Based on the U.S. EPA’s memo dated March 1,2011, cothmissioning is a once in a lifetime event and therefore, can be excluded from compliance with the federal 1-hour NO2 standard. On June 2, 2010, the U.S. EPA established a new I-hour SO2 standard of 75 ppb (196 ~.tgJm3) The form of the federal 1-hour SOz standard involves a three year average of the 90 percentile of the annual distribution of daily maximum I-hour concentrations. The South Coast Air Basin is designated non-attainment for the, state PM10 standards, and state and federal PM25 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-4- Andrew Lee . :-s~ February 20, 2018

Table C Impacts during Commissioning Unit 11

Maximum .. Attainment . .. Background Total:~ ~ California Federal .. . Polkitant & Modeled : Concentration ¶ Concentration .AAQS b. AAQS b EXceeds ...... Concentration . .. . 3 .~ Threshold? Averaging Time (jig/rn3) .. (~W~) . .~ (pg/rn.) ~. (jig/rn) (jig/rn) .

CO, 1-hr . 42.7 . . 3,680.Q 3,722.7. 23,000 40,000 .. No

.N02, 1-hr° 35.7. 169.8 :. . 205.4 . . No

N02,Ahnual° 0.2 . 41.7. . 41.9 . 57 100 . . No

S02, 1-hr . . 0.8 35.1 . . 35.9... 655 . . 196° No. . . Maximum ...... Non-attainment : :Modeled: California. Federal Rule 1303. Thresholds Exceeds

Pollutant & . AAQS...... Concentration . 3 3 . . . (pg/rn) :. . Threshold? Averaging Time (jig/rn3) (jig/rn) .~ (jig/rn) .. . ~.

PMio,Annual Q.1 20 - . 1 . : No

PM2.5, Annual 0.1 12 12 .~ 1 ...... No Note: a Maximum values for CO, NO2, PM10, and S02 from SRA 1, Central Los Angeles (No. 87) monitoring station for

the last three years (2013 .— 2015) was used. .. .~ : . Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted; °The conversion ofNOx to NO2 was done using Tier 2 ARM2 method for 1-how and ARM ratio of 0,75 for annual,

which was an acceptable method at the time of submittal...... : On April 12,2010, the U.S. EPA.cstablished a new I-hour NO2 standard of 100 ppb (188 gg/m3). .The.form of the federal 1-hour NO2 standardinvolves a three year average of the 981h peràentile of the anilual distribution of daily maximum i-hour cbncentrations. Based on the U.S. EPA’s inemo dated MarchI, 2011, commissioning is a once in a lifetime event and therefore, can be excluded from compliance with the federal 1-how NO2 standard.. ¶ On June 2, 2010, the US. EPA established a new 1-hour SO2 standard of:75 ppb (196. gg/m3). The form of the federal 1-hour 502 standard inyolves a three year average of the 99th percentile of the annual distribution of daily

maximum I-how concentrations. . . . •: . . . The South Coast Air Basin is designated non-attainment for the state PM10 standards, and state and federal PM2.5 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-5- Andrew Lee -6- February 20, 2018

Table B — Impacts during Commissioning — Unit 1.2 Maximum Attainment Background Total California Federal Modeled Pollutant & Concentration Concentration a Concentration AAQS b AAQS b Threshold?Exceeds Averaging Time (rn3) (jig/rn3) (jig/rn3) (jig/rn3) (jig/rn3)

CO, 1-hi 11.9 3,680.0 3,691,9 23,000 40,000 No

NO2, 1-hr 12.1 169.8 181.9 - d No

N02;Annual C 0.02 41.7 41.72 57 100 No SO2, 1-hr 0.4 35.1 35.5 655 196 e No Maxim urn Non-attainment Modeled California Federal Rule 1303 Thresholds Exceeds Pollutant & Concentration AAQS AAQS Averaging Tirne (/3) (jig/rn3) (jig/rn3) (jig/rn3) Threshold?

PMio, Annual 0.01 20 - I No PM2.s, Annual 0.01 12 12 1 No Note: a Maximum values for CO, NO2, PM10, and 802 from SRA 1, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted. The conversion ofNOx to NO2 was done using Tier 2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submittal. On April 12, 2010, the U.S. EPA established a new 1-hour NO2 standard of 100 ppb (188 ~iWm3). The form of the federal 1-hour NO2 standard involves a three year average of the 98dI percentile of the annual distribution of daily maximum 1-hour concentrations. Based on the U.S. EPA’s memo dated March 1,2011, commissioning is a once in a lifetime event and therefore, can be excluded from compliance with the federal 1-hour NO2 standard. eOn June 2,2010, the U.S. EPA established a new 1-hour SO2 stafidard of 75 ppb (196 ig/m’). The form of the federal 1-hour 802 standard involves a three year average of the 99ih percentile of the annual distribution of daily

maximum 1-hour concentrations. . ‘The South Coast Air Basin is designated non-attainment for the state PM10 standards, and state and federal PM25 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-6- Andrew Lee• -7- February 20, 2018

Table E — Impacts during Commissioning—Unit 13 .

.. ~Maxijnum . . .. Attainment Background Total California Federal

Pollutant & M1thcI•~ Concentration a Concentration .AAQS b . ~QS Exceeds . Concentration 3 3• . 3 ~.. Threshold? Averaging Time (pg/rn3) (pg/rn) (jig/rn) . (pg/rn) (pg/rn)..

CO, 1-hr ~. 21.1 . 3,680.0 3,701.1 23,000 . 40,000 No

N02, 1-hr ~ 23.9 169.8 193.7 :. No N02,Annual° 002 417 4172 57 100 No

SO2, 1-hr 0.3 35.1 . 35•4 655 196C . No

. Maximum . :. . . Non-attainment Modeled California Federal Rule 1303 Thresholds’ Exceeds

~ Pollutant & . . . AAQS. AAQS . . Concentration . 3 3 (pg/rn3) Threshold? Averaging Time (~ig/rn3) (pg/rn) (pg/rn) . .

PMi0, Annual . 0.01 20 .. - . 1. No

PMzs,AnnUal . . 0.01 12 12 . 1 . No• Note: ‘Maximum values for CO, NO2, PM10, and SO2 from SRA 1, Central Los Angeles (No. 87) monitoring station for

the last three years (2013 — 2015) was used. ~. . . Both the Califotnia and Federal AAQS values listed are not to be exceeded, except otherwise notód. ~ conveñi6n ofNOx to NO2 was done using Tier2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual,

which was an acceptable method at the time of submittal...... On April 12,2010, the U.S. EPA established a new 1-hour NO2 standard of 100 ppb (188 jig/rn3). The form of the federal 1-hour NO2 standard involves a three year average of the 98~~ percentile of the annual distribution of daily maximum I-hour conôentrations. Based on the U.S. EPA’s memo dated March 1, 2011, commissioning isa once in a lifetime event and therefore, can be excluded from complian with the federal l-hour•N02 standard. ° On June 2, 2010,the U.S. EPA established.a new 1-hour SO2 stáftdard of 75 ppb (196 jzg/n~3). The form of the federal 1-hour S02stándard involves a three yëár average of.the 99th percentile Of the annual distribution of daily

maximum I-hour concentrations. . . . ,...... The South Coast Air Basin is designated non-attainment for the state PM o standards, and state and federal PM2,5 standards; therefore, project increments are compared to the significant change thresholds in Ruie 1303.

-7- Andrew Lee -8- February 20, 2018

• Impacts During Normal Operations V The stack parameters and emission rates modeled are consistent with the parameters listed in Table 3-6 and 3-7, Page 11 of the report. Engiheering & Permitting staff confirmed that the parameters were correct.

Table F — Impacts during Normal Operation — Total Project Maximum Attainment Modeled Background Total California Federal Exceeds Pollutant & Concentration Concentration a Concentration AAQS b 4JLQS b Threshold? Averaging Time (pig/rn3) (jig/rn3) (jig/rn3) (jig/rn3) (jig/rn3)

CO, 1-br 148.8 3,680.0 3,828.8 23,000 40,000 No CO, 8-hr 34.3 2,300.0 2,334.3 10,000 10,000 No

N02, 1-hr C 140.9 169.8 310.7 339 - No

N02, 1-hr~ - 184.2 - 158d No

N02, Annual C 0.3 41.7 42.0 57 100 No

SO2, 1-hr 1.7 35.1 36.8 655 196 C No

SO2, 3-hr 1.7 35.1 36.8 - 1,300 No

SO2, 24-hr 0.4 4.2 •4.6 105 -. No

PM10, 24-hr 0.8 88.0 88.8 - 150 No Maximum Non-attainment Modeled California Federal Rule 1303 Thresholds ~ Exceeds Pollutant & Concentration AAQS AAQS Averaging Time (~/m3) (jig/m3) (~W~’3) ~ig/m3) Threshold?

PMio, 24-hr 0.9 50 - 2.5 No

PMi0, Annual 0.2 20 - 1 No

PM2.s, 24-hr 0.9 - 35 2.5 No PM2.s, Annual 0.2 12 12 1 No Note: a Maximum values for CO, NO2, PM10, and SO2 from SRA I, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted. ~ conversion of NOx to NO2 was done using Tier 2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submittal. On April 12,2010, the U.S. EPA established a new 1-hour NO2 standard of 100 ppb (188 jig/rn). The form of the federal 1-hour NO2 standard involves a three year average of the 98th percentile of the annual distribution of daily maximum 1-hour concentrations. Seasonal by hour background concentrations were included in the modeling analysis. On June 2,2010, the U.S. EPA established a new 1-hour 502 standard of 75 ppb (196 gg/m3). The form of the federal 1-hour SO2 standard involves a three year average of the 99th percentile of the annual distribution of daily maximum 1-hour concentrations. Effective July 26, 2013, the South Coast Air Basin has been re-designated to attainment for the federal 24-hour PM10 AAQS. g The South Coast Air Basin is designated non-attainment for the state PM10 standards, and state and federal PM2.5 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-8- Andrew Lee -9- February 20, 2018

Table G — Impacts during Normal Operation ~: Unit 10

. . . Maximum. . Attainment . . . Background .. Total California Federal

Pollutant & . . Modeled.. Concentration a Concentration AAQS b. ~QS ~ . . . Concentration . 3 . 3 3 . ~ Threshold? Averaging Time (jig/m3) (l.~t1tp ) ...: (jj,g/~n ) (gg/m ) (gglm)

CO, lhr . 1.4 . 3,680.0 3,681.4 23,000 ~40,000 No

CO~ 8~hr 7.8 .. 2,30 .0 . 2,307.8~. 10,000 10,000 . No

N02,1-hr° 20 1698 1717 339 - No

NO2, 1-hr° .. 2.8” 120.6 ~. 123.3 . - 188 d No

N02,AnhuáP. 0.1 41.7 . 41.8 7 100 No

S02, 1-hr 0.8 . 35.1 . 35.9 655 ... 196i No

802, 3-hr . 0.8 35.1 35.9 - .. 1,300 NO.

502,24-hr . 0.2 4.2 4.4 105 - . No.

PMio, 24-hr 0.3 88.0 88.3 . - . 150 No

Maximum ...... :. Non-attainment Modeled California Federal Rule 1303 Thresholds g Exèeeds

Pollutant & . . . AAQS . . . . Concentration 3 . 3 . (pg/ni3) Threshold? Averaging Time (~/3) (gg/m) (pg/rn)

PM1o, 24-hr 0.4 50 . . 2.5 . No

PMio, AnnUal o:i 20 -. . I No

PM2.S, 24-hr 03 - 35 2.5 . No

PM~s;Annuai 0,1.. .~ 12 12 . . 1. No Note: a Maximum values for CO, NO2, PM10, and 802 from SRA 1, Central Los Angeles (No. 87) monitoring station for

the last tlüee 3’ears (2013—2015) was used. . . .~ : :. . Both the California and FOderal AAQS values listed are not tobe exceeded,except otherwise noted. C The conversion ofNOx to NO2 was done using Tier 2 ARM2 method for 1-hour ahd ARM ratio of 0.75 for annual,

which was an aciceptable method at the time Of submittal. .~ Oh April 12, 2010, the U.S. EPA established a new 1-how NO2 standard of ioo ppb (188 ~g/m3). The form of the federal 1-hour NO2 standard involves a three year average of the 98th percentile of the annual distribution of daily

maximum 1-hour cioncentrations...... On June 2,2010, the U.S~ EPAestablished a new 1-hOur 802 stãndai~d of 75 ppb (196 ggfm3). The form of the federal 1-hour 802 standard involves a three year average of the 99th percentile of the annual distribution of daily

maximum 1-hour cOncentrations...... 1Effective July 26, 2013, the SoOth Coast Air Basin has been re-designated to attainment for thefederal 24-hour

PM10 AAQS. . . .~ ...... 8The South CoastAir.Basin is designated nun-attainment for the state PMw stafidards, and state and federal PM2,5 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-9- Andrew Lee - 10- February 20, 2018

Table H — Impacts during Normal Operation — Unit 11

. Maximum Attainment Modeled Background Total California Federal Pollutant & Concentration Concentration a Concentration AAQS i, AAQS b Threshold?Exceeds Averaging Time (~/m3) (jig/rn3) (jig/rn3) (jig/rn3) (jig/rn3) CO, 1-hr 1.4 3,680.0 3,681.4 23,000 40,000 No• CO, 8-hr 8.0 2,300.0 2,308.0 10,000 10,000 No

N02, 1-hr 0 2.7 169.8 172.5 339 - No

N02, 1-hr° 1.9” 120.6 122.5 - 188 d No

N02, Annual C 0.1 41.7 41.9 57 100 No 502, I-hr 0.8 35.1 35.9 655 196 No

SO2, 3-hr 0.8 35.1 35.9 - 1,300 No

SO2, 24-hr 0.2 4.2 4.4 105 - No

PM10, 24-hr 0.3 88.0 88.3 - 150 No Maximum Non-attainment California Federal Modeled Rule 1303 Thresholds g Exceeds Pollutant & Concentration ~~QS AAQS Averaging Time (~/rn3) . (jig/rn3) (jig/rn3) Threshold?

PMio, 24-hr 0.4 50 - 2.5 No

PMio,Annual 0.1 20 - 1 No

PM2.5, 24-hr 0.3 - 35 2.5 No

PM2j,Annual 0.1 12 12 1 . No Note: a Maximum values for CO, NO2, PM10, and 502 from SRA 1, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted. °The conversion ofNOx to NO2 was done using Tier 2 ARM2 method for I-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submittal. dOn April 12,2010, the U.S. EPA established a new 1-how NO2 standard of 100 ppb (188 jig/rn3). The form of the federal 1 -hour NO2 standard involves a three year average of the 98Ih percentile of the annual distribution of daily maximum 1-hour concentrations. o On June 2,2010, the U.S. EPA established a new 1-hour SO2 standard of 75 ppb (196 jtg/m3). The form of the federal 1-hour SO2 standard involves a three year average of the 99th percentile of the annual distribution of daily maximum 1-hour concentrations. “Effective July 26, 2013, the South Coast Air Basin has been re-designated to attainment for the federal 24-hour PM10 AAQS. The South Coast Air Basin is designated non-attainment for the state PM10 standards, and state and federal PM2.5 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

-10- Andrew Lee —11— February 20,2018

Table I— Impacts during Normal Operation -~ Unit 12

. Maximum . Attainment Background Total Ca!ifornia Federal

• Pollutant & ~ . Concentration Concentration AAQS b AAQS b . Exceeds ... . Concentration . 3 . 3•~ ..~. •~ Threshold? Averaging Time . (p.gJm3) (~Wm) .. (gg/m) (gg/m) . (gg/m)

CO, Ihr 0.7 3,680.0 3,680.7:• .. 23,000 40,000 No

CO, 8-hr 0.8 .. . 2,300.0 2,300,8 10,000 10,000 ... No:

N02, 1-hr° 1.2 169.8 •. 171.0 . 339 - . No

NO2;1~hr° 0~6d 120.6 121.2 . - . . No

N02,Annuai 0 0.01 41.7 41.71 . 57 . 106 . . No

SO2, 1-hr 0.3 35.1 . 35.4 :. 655 . 196 C No.

502, 3-hr 0.3 35.1 35.4 - 1,300 No

502, 24-hr 0.04 4.2 4.24 . 105 - . No

PMio, 24hr 0.1 88.0 . 88.1 .. . - 150 : No

. Maximum . . . . . Non-attainment . Modeled. California Federal Rule 1303. Thresholds g

. Pollutant & Conèentration AAQ~ AAQ~ . (jig/in3) Threshold?

Averaging Time (jig/rn3) (jig/rn) . (jig/rn) .• . .. . .

PM10,24-hr 0.1 50 . - . 2.5 . .. No

PMio,Annual 0.005 20 - . . 1 . . No

PMis, 24-hr 0.1 - . . 2.5 . No

PM2.5, Annual 0.005 . 12 . 12 . . . 1 . . No

Note~ ..~ Maximum values for CO, NO,, PMId, and SO, from SRA I Central Los An~êles (No.87) mOnitoring station for

the last three years (2013—2015) was used. ... : . Both the California and Federal AAQS values listed are not.to be exceeded, except otherwise noted. The conversion ofNOx to NO, was done using Tier 2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual,

which was an acceptable method at the time of submittal. : . ~. . ~. . dOn April 12,2010, the U.S. EPA.established a new 1-hour NO, standard of 100 ppb (188 gg/m3). The form of the federal 1-hour NO, stahdard.involves a three year. average of the 98’ peróentile.of the annual distribution of daily maximum .1-hour concentrations. On June 2,2010, the U.S. EPA established a new I-hour SO, standard of 75 ppb (196 gg/rn3). The form of the federal: I-hour SO, standard involves a three year aveta~ê of the ggth percentile of the annual distribution of daily

maximum I-hour concentrations...... ~ ~Effebtive July 26, 2013, the South Coast Air Basin has been re-designated to attainment for the federal 24-hour

PM10 AAQS. . : . . . S The South Coast Air Basin is designated non-attainment for the state PMio standards, and state and federal PM,.5 standards; therefore, project increments are compared to the significant change thresholds in Rule 1303.

—11— Andrew Lee - 12- February 20, 2018

Table J — Impacts during Normal Operation — Unit 13 Maximum Attainment Modeled Background Total California Federal Pollutant & Concentration a Concentration AAQS I, I, Exceeds Concentration AAQS Threshold? Averaging Time (~rn3) (gag/m3) (jig/rn3) (jig/rn3) (jig/rn3)

CO, 1-hr 0.7 3,680.0 3,680.7 23,000 40,000 No CO, 8-hr 3.6 2,300.0 2,303.6 10,000 10,000 No

N02, 1~hr° 1.2 169.8 171.0 339 - No

N02,1-hr0 05d 120.6 121.1 - 188d No N02, Annual° 0.01 41.7 41.71 57 100 No so2, 1-hr 0.3 35.1 35.4 655 196c No

SO2, 3-hr 0.3 35,1 35.4 - 1,300 No

SO2, 24-hr 0.04 4.2 4.24 105 - No

PMio, 24-hr 0.1 88.0 88.1 - 1501 No Maximum Non-attainment California Federal Modeled Rule 1303 Thresholds g Exceeds Pollutant & Concentration AAQS AAQS Averaging Time (~)3) (jig/rn3) (jig/rn3) (jig/rn3) Threshold?

PMio, 24-hr 0.1 50 - 2.5 No

PMio, Annual 0.005 20 - 1 No

PM2.5, 24-hr 0.1 - 35 2.5 No PMz.s, Annual 0.005 12 12 1 No Note: a Maximum values for CO, NO2, PM10, and 502 from SR.A 1, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS values listed are not to be exceeded, except otherwise noted. The conversion ofNOx to NO2 was done using Tier 2 ARM2 method for 1-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submittal. On April 12,2010, the U.S. EPA established a new 1-hour NO2 standard of 100 ppb (188 ~ig/m3). The form of the federal I-hour NO2 standard involves a three year average of the 98th percentile of the annual distribution of daily maximum 1-hour concentrations. On June 2,2010, the U.S. EPA established a new 1-hour SO2 standard of 75 ppb (196 ~Wm’). The form of the federal I-hour SO2 standard involves a three year average of the 99th percentile of the annual distribution of daily maximum 1-how concentrations. 1Effective July 26, 2013, the South Coast Air Basin has been re-designated to attainment for the federal 24-hour PM10 AAQS. The South Coa~t Air Basin is designated non-attainment for the state PM10 standards, and state and federal PM2.5 standards; Therefore, project increments are compared to the significant change thresholds in Rule 1303.

-12- Andrew Lee - 13 - February 20, 2018

Table K — Impacts during Normal Opcr4tion — Black Start GçneratQr

. . Maximum ...... Attainment . Background TotalS California Federal

Pollutant & . . Modeled . Concentration’ Concentration . AAQS I, . ~QS b Exceeds . . . Concentration . Threshold? Averaging Time . (jig/rn3) (pig/rn3) (gg/m3) (gg/m3) (pig/rn3)

CO, 1-hr 148 5 3,6800 3,828 5 23,000 40,000 No

CU, 8-hr 32.9 2,300.0 2,332.9 10,000 10,000. ~. No

N02, 1~hrC 140.9 169.8 310.7 339. - No

N02,1_hrc 1841d - . •1g4L. ~ No

N02,Annual° 0.O2 41.7 41.82.. . .. 100 No

502, J~ffi~ . 0.5 35.1 35.6 655 . 196 No

SO2, 3-hr . 0.5 35.1 35.6 . 1,300 No

502,24,-hr 0.04 4.2 . 4.24 •105 - .. . No

PMio, 24-hr 0.04 88.0 88.04 - l5O~” No

. Maximum ...... Non-attainment California Federal .. Modeled Rule 1303 Thresholds g Exceeds Pollutant & Concentration AAQS AAQ~ (pig/rn3) . Threshold?

Averaging Time (~/th3) . . 4LWm) . . ~g/m) ......

PMjo, 24-hr 0.04 50 . ~. - ...... 2.5. . No

PM10, Annual 0.0001 20 - 1 No

PM2;5, 24-hr . 0.04 -. .. . 35 . . ~: 2.5 No

PMj5,Annual .0.0001 ~ 12*:. . 12 . . 1 No

Note: •‘ Maximum values for CO, NO2, PMi9, and 502.from SRA 1, Central Los Angeles (No. 87) monitoring station for the last three years (2013 —2015) was used. Both the California and Federal AAQS yalues listed are not to be exceeded, except otherwise noted. °The conversion ofNOx to NO2 was done using Tier 2 ARM2 thethod for 1-hour and ARM ratio of 0.75 for annual, which was an acceptable method at the time of submthal. NO~ rhodeled concentrations include seasonal by hour

background concentrations...... OnApril 12,2010, theU.S. EPA established a hew l-hourNO2 standard of 100 ppb (188 jig/rn3). The form of the federal 1-hour NO2 st~ndhrd involves a three year average pf the 980 percentile of the annual distribution of daily maximum 1-hour concèn&ations. Seasonal by hour background concentrations were included in the modeling

analysis...... C On June 2, 2010, the U.S. EPA established a new 1-hour SO2 standard of 75 ppb(196 jig/ni3).. The form of the federal 1~höur SOz standard involves a threó year iverage of the 99’~’. percentile of the annual distribution of daily maximuin 1-hour concentrations...... : . Effective July 26, 2013, the South Coast Air Basin has been re-designated to attainment for the federal 24-hour

PM19 AAQS. . . . . The South Coast Air Basin is designated non-attainment for the state PM19 standards, and state and federal PM2.5 standards; therefore, project incrOmehts are compared to thO significant change thresholds in Rule 1303.

-13- Andrew Lee - 14- February 20, 2018

SCAQMD Regulation XIV — Health Risk Impacts V The applicant performed the HRA with the Hot Spots Analysis and Reporting Program (HARP2, version 17023). The SCAQMD’s HRA procedures require HARP to be used in Tier 4 risk assessments. V The stack parameters and emission rates modeled are consistent with the parameters listed in Table 4.1, Page 19 of the report. Engineering & Permitting staff confirmed that the parameters were correct.

Table L — Health Risk Impacts - Total Project

. Chronic Acute Cancer Chronic Exceeds Receptor Cancer Hazard Hazard Risk I-H Acute HI Any Type Risk Index Index Threshold Threshold Threshold Threshold?

Sensitive 0.77 in one One in one million 0.002 0.007 million a 1.0 1.0 No (1.81 E-03) (7.46 E-03) (7,71 E-07) (1.0 E-06) Worker 0.03 in one One in one. million 0.002 0.007 million a 1.0 1.0 No (1.98 E-03) (7.23 E-03) . (3.05 E-08) (1.0 E-06)

Note: a For permit units without T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold of one in one million (1.0 x 10.6). For permit units with T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold often in one million (1.0 x I ~

Table M — Health Risk Impacts — Unit 10

Chronic Acute Cancer Chronic . Exceeds Receptor Cancer Hazard Hazard Risk ifi Acute HI Any Type Risk Index Index Threshold Threshold Threshold Threshold?

Sensitive 0.50 in one One in one million 0.001 0.003 million a 1.0 1.0 No (1.35 E-03) (2.70 E-03) . (5.02 E-07) (1.0 E-06) Worker 0.02 in one One in one million 0.001 0.003 milliona 1.0 1.0 No (1.46 E-03) (2.88 E-03) (1.89 E-08) (1.0 E-06) Note: a For permit units without T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold of one in one million (1.0 x 10.6). For permit units with T-BACT, the increased MICR cannot be greater than the RUle 1401 cancer risk threshold often in one million (1.0 x l0~).

-14- Andrew Lee - 15- February 20, 2018

Table N — Health Risk Impacts —Unit 11

. . Chronic . Acute. Cancer Chronic . Exceeds Receptor Cancer . . .. Acute HI . . Hazard Hazard Risk . HI . Any Type Risk Index Index Threshold Threshold Threshol4 Threshold?

Sensitive 0.52 in one . One in one .

~ million ~ ‘2 0.003. n~illion a •1 .0 1.0 . No

(5j5 E-07) - .~ ~ (1.0 E-06)

Worker 0.02 in one . . One in one million 0002 2 ~10~3o3 million a 1 0 1 0 No

~ (1.95E-08) (1. 3) L. -) O.OE-oø) .. . Note: a For permit units without T-BACT, the increased MICR cannot be greater than the Rule 14Q1 cancer risk threshold of one in one million (1.0 x •lOj. For permit units with T-BACT, thô increased MICR cannot be greátet thE the

Rule 1401 cancer risk threshold often in one million (1.0 x l0~) . . .

Table 0 — Health Risk Impacts Unit 12

. . . Chronic . Acute Cancer Chronic Exceeds Receptor Cancer . . Acute HI . Hazard Hazard Risk HI ~. Any Type Risk. . Threshold . . . Index .. . Index . Threshold Threshold . Threshold?

Sensitive 0.02 in one . One in one

~ (2J2E-08) (5g40E-05) (&22E-04) 1.0 ~•1.0. No

Worker 0.0009 in . . One in one

~ (&OOE-05) (738 EM4) .. 1~ 1.0. No Note: a For permit units without T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold of one in one million (1.0 x I 0~). For permit units with T-BACT,.the increased MICR cannot be greater than the

Rule 1401 cancer risk threshold often in one million (1.0 x 10~). .

-15- Andrew Lee - 16 February 20, 2018

Table P — Health Risk Impacts — Unit 13 Chronic Acute Cancer Chronic Exceeds Receptor Cancer Hazard Hazard Risk HI Acute ~ Any Type Risk Index Index Threshold Threshold Threshold Threshold?

Sensitive 0.02 in one One in one million 0.00005 0.002 million a 1.0 1.0 No (5.19 E-05) (1.67 E-03) ~ (2.05 E-08) (1.0 E-06) Worker 0.0009 in One in one one million 0.00006 0.001 million a 1.0 1.0 No (6.05 B-OS) (9.95 E-04) (8.64 B-b) (1.OE-06) Note: For permit units without T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold of äne in one million (1.0 x ioj. For permit units with T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold often in one million (1.0 x I ~

Table Q — Health Risk Impacts — Black Start Generator Chronic Acute Cancer Chronic Exceeds Receptor Cancer Hazard Hazard Risk Acute m Any Type Risk Index Index Threshold Threshold Threshold Threshold?

Sensitive 0.10 in one One, in one million 0.000004 0.002 million a 1.0 1.0 No (4.18 E-06) (1.62 E-03) (9.86 E-08) (1.0 E-06) Worker 0.005 in One in one one million 0.000006 0.002 million a 1.0 1.0 No (6.29 E-06) (2.03 E-03) . (4.85 E-09) (1.0 E-06) Note: For permit units without T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold of one in one million (1.0 x l0~). For permit units with T-BACT, the increased MICR cannot be greater than the Rule 1401 cancer risk threshold often in one million (1.0 x 10j.

Modeling staff spent a total of 160 hours on this review. Please direct any questions to Melissa Sheffer at ext. 2346.

cc:. LiChen JKG:MS

-16- ATTACHMENT 2

Glendale Water & Power Commission Motion

Dated April 2, 2018 MOTION

Moved by Glendale Water & Power (“GWP”) Commissioner Hale, seconded by

GWP Commissioner Lall, that, having considered the April 2, 2018 presentation regarding the proposed Grayson Repowering Project and Final Environmental Impact

Report, and the comments of interested members of the public regarding the same, the

GWP Commission recommends that the City Council:

• Take no action at this time on the certification of the Final Environmental Impact

Report for the proposed Grayson Repowering Project.

• Direct Glendale Water & Power Department staff to issue a Request For

Information, relating to market input for additional alternatives that would reduce

the carbon footprint of the Grayson Power Plant, to be completed no later than

ninety days.

Vote as follows:

Ayes: Lall, Camargo, Hale, Avanessian, Kedikian

Noes:

Absent:

Abstain:

Attachment 2 ATTACHMENT 3

Correspondence pertaining to the Draft EIR or Final EIR

Received by the City of Glendale following the

Close of the Public Comment Period April 6,2018

GLENDALE GALLERIA 100 W BROADWAY STE 100 GLENDALE, CA 91210

WWW.GGP.COM

To: Mayor Charpetian and Glendale City Council

Dear Mr. Mayor and members of the Council,

On Behalf of Glendale Galleria, I am here today to voice our support GWP’s and City staff’s recommendation to re-power Grayson Power Plant

As you already know, The Glendale Galleria welcomes n,illions of guests to our wonderful community each year. We’ve positioned the shopping center to be more than a place to shop and dine; we are a gathering place for people.

As one can imagine, it takes a tremendous amount of electricity to operate our shopping center, providing a safe environment for our guests and retailers. This includes everything from lighting our parking garages to our common areas, as well as our heating and cooling and, the most paramount, the ability to welcome and provide a safe environment for our guests.

While we have recently installed solar panels on our parking deck and roof of the mall for some of our power needs, we still place significant importance on Grayson’s ability to operate and generate enough power to help support the shopping center. That is why it is important to us that Grayson Power Plant continues having the ability to generate its own power. We have significant concern to just have feeder lines providing power to the city of Glendale. If one of the main feeder lines ever fails, we risk inability to operate and provide a safe experience to our guests.

We understand that GWP will maximize Graysons ability to produce the city of Glendale’s power needs, but the plants new efficiencies will allow these feeder lines to be maximized with power generated by renewable resources versus fossil fuels. Glendale Galleria is extremely cognizant of our carbon footprint and appreciates GWP taking every possible step to ensure this project seeks maximize Glendale’s efforts to utilize renewal resources and further appreciate no variances to any Federal, State or local ordinances surrounding quality of life measures such as air quality.

We hope that you support re-powering Grayson Power Plant and approve its Environmental Impact Report as presented by the staff.

Sincerely,

Brent Gardner, Sr. General Manager April 2,2018

Mayor and Members of City Council City of Glendale, CA

Dear Mayor and Members of City Council;

I am the President of Dear Canyon Oakmont Property Owners Association, and on behalf of majority of members of our Board of Directors we wish to express our support for the re powering of the Grayson Power plant.

We Imow that Grayson Water and Power has legal obligations to have significant portions of its power generated from renewable energy. We support GWP in those efforts. At the same time, we believe that the members of Glendale City Council have an obligation to make sure Glendale residents have some electricity available to them without interruptions and at the lowest rate possible. Re-powering of Grayson Power Plant covers all these requirements. This project, as proposed, will meet the state mandates on renewable energy while prqviding reliable and affordable electricity for the residents of Glendale. This way, the responsibility of maintaining some of our power generation and its reliable and affordable delivery is in our own hand.

We urge you to support re-powering of Grayson Power Plant and certify its Environmental Impact Report as proposed.

Sincerely, Dan Watson

President Dear Canyon Oakmont Property Owners Association

CC: Ms. Yasmin Beers — Glendale City Manger

Mr. Stephen Zurn — General Manger GWP April 2, 2018 c~rv r~

2018 APR 44 PH 2: WI Vartan Gharpetian, Mayor Glendale City Council Members 613 B. Broadway Glendale City Hall Glendale, CA 91206

Dear Mayor Gharpetian and City Council Members:

The attached comments in relation to the February 10, 2018 agenda item on the Final Environmental Impact Report (FEW) for the proposed Grayson Expansion are being submitted into the formal public hearing record.

The preparation of an Environmental Impact Report (FIR) is fundamentally related to land use policy, environmental impacts, negative long term impacts on the public’s health, which must be incorporated in a concise description of the surrounding community, it’s current demographic profile, and specific regressive environmental impacts on vulnerable groups ‘at risk’ to a proposed project.

The Final Environmental Impact Report (FEW) in relation to the proposed Grayson Power Plant Expansion (Grayson) fails on all of these levels. It does not meet California’s mandated California Environmental Quality Act (CEQA) standards of analysis. The document needs significant, substantial and fundamental revisions, new sections and inclusion of specific sections mandated by CEQA. A revised Draft EIR and FEW, must subsequently be recirculated for public comments and independent analysis.

In addition, nowhere in this purpdrted ‘environmental analysis’ is a concise statement that this proposed project would “result in the single most signjficant generator of regressive airpollution in the City of Glendalefor the next 3Opl~years.” This is a basic fact that is implied in the volumes of data in the appendices, yet, nowhere in the Project Description is this fundamental impact clearly stated. This lack of candor is indicative of a major analytical inadequacy, an acute lack of specific attention to the long term negative public health impacts of residents, in particular vulnerable populations, who reside in immediate proximity of the proposed action and, at minimum, a three !mile radius which will be directly impacted from severe air pollution emanating from this massive energy generating plant reliant solely on a non-renewable polluting energy source.

The FEIR fails to comprehensively address fundamental state law in relation to mandatory actions to reduce Green House Gas Emissions (GHG). Specifically, the FEW fails to address how this proposed action in terms of energy generation from non renewable sources is correlated with the City of Glendale’s early compliance with state law. The relevant law, Senate Bill 350, along with AB 802 will govern all GWP energy policies into the mid-2000s. The City will be developing plans, policies and goals directly related to both laws. The fact that the FEIR fails to comprehensively address how the proposed project impacts these laws, GWP requirements, nor much less analyze the proposed actions negative impact on this law within the city of Glendale is a major failure of the document. Neither SB 350 or AB 802 are not comprehensively addressed in either the Project Description nor the Alternative sections.

A fact is that the city in 2018, is currently relying on 47% renewable energy sources which is at 94 % compliance of the state mandated requirement by 2030, twelve years early. Achieving this level of compliance indicated that it is highly likely that the city will be utilizing, relying upon approximately 60% renewable energy sources, if not higher by 2030.

The City of Glendale ‘Lc already at 142% compliance with the 2020 and 94% compliance with the 2030 state law’ SB 350 mandates. This significant fact is not documented in the FEIR

The FEIR in essence assumes that the City of Glendale and GWP could potentially abandon any further increases in the reliance on renewable energy sources. (If the City’s current rate of transition toward renewable energy resources continues into the future, it is highly likely that by 2040 the City will have exhibit a 75% reliance on renewable energy sources). This issue, both in terms of public costs and public policy, needs to be comprehensively addressed in the FEIR.

The following analysis being submitted for public review and comment to the Glendale City Council of a range of CEQA sections, identifies numerous deficiencies, lack of current demographic data, failure to address a range of arenas of conventional environmental analysis, and other fundamental problems that are inherent in the FEIR. The FEIR requires substantive and significant structural changes and additions. The document is not adequate in relation under CEQA in a range of issues and requires substantial additions, changes and inclusions that require a redraft that also will necessitate an additional series of public comment periods.

R$s’~ec$ffilly,v~ / DIkI~~ idR. ~az Ph.D. Urban Planning, UCLA 1994 1211 Scenic Drive Glendale, CA 91205

cc. City Council Members Paula Devine Ma Najarian Zarch Sinanyan Vrej Agajanian City Manager, Yasmin Beers City Clerk, Andy Kaffakhian GWP General Manager, Steve Zurn Critique of the Grayson Repowering Project Final Environmental Impact Report March 29, 2018

Dr. David R. Diaz Ph.D. Urban Planning, UCLA 1994

The Final Environmental Impact Report (FEIR) in relation to the proposed Grayson Power Plant Expansion (Grayson) fails on all of these levels. It does not meet California’s mandated California Environmental Quality Act (CEQA) standards of analysis. The document needs significant, substantial and fundamental revisions, new sections and inclusion of specific sections mandated by CEQA. A revised Draft FIR and FEIR, must subsequently be recirculated for public comments and independent analysis.

In addition, nowhere in this purported ‘environmental analysis’ is a concise statement that this proposed project would “result in the single most signj/icant generator of regressive airpollution in the City of Glendalefor the next 30 plus years.” This is a basic fact that is implied in the volumes of data in the appendices, yet, nowhere in the Project Description is this fundamental impact clearly stated. This lack of candor is indicative of a major analytical inadequacy, an acute lack of specific attention to the long term negative public health impacts of residents, in particular vulnerable populations, who reside in immediate proximity of the proposed action and, at minimum, a three mile radius which will be directly impacted from severe air pollution emanating from this massive energy generating plant reliant solely on a non-renewable polluting energy source.

The FEII{ fails to comprehensively address fundamental state law in relation to mandatory actions to reduce Green House Gas Emissions (GHG). Specifically, the FEIR fails to address how this proposed action in terms of energy generation from non renewable sources is correlated with the City of Glendale’s early compliance with state law. The relevant law, Senate Bill 350, along, with AB 802 will govern all GWP energy policies into the mid-2000s. The City will be developing plans, policies and goals directly related to both laws. The fact that the FEIR fails to comprehensively address how the proposed project impacts these laws, GWP requirements, nor much less analyze the proposed actions negative impact on this law within the city of Glendale is a major failure of the document. Neither SB 350 or AB 802 are not comprehensively addressed in either the Project Description nor the Alternative sections.

If the City’s annual demand, in 2018 is being met with approximately 50% renewable energy sources, it is mandatory that the FEW address how this success will structurally limit any need of a substantial increase in non-renewable energy generation for the long term future. This fact, publicly disseminated by the City, is among the most problematic aspects of this proposed action Thus, one issue the FEW is wholly inadequate in relation to conventional CEQA mandates is the failure to address this fundamental issue related to state laws in the Project Description, Alternatives, Adverse Impacts, Short and Long Term Impacts and Socio-Economic Impacts in a conventional, and factual based assessment in relation to whether the proposed action is even necessary to meet the future needs of Glendale in relation to energy resources.

The City of Glendale ‘Lc already at 142% compliance with the 2020 and 94% compliance with the 2030 state law’ SB 350 mandates. This significant fact is not documented in the FEIR

The proposed action, in fact could arbitrarily delay andJor force the city to abandon further actions to substantially increase the utilization of renewable energy sources because it will be compelled to rely on a non-renewable energy strategy to pay for bonds of a proposed action grossly designed over capacity for existing and long term energy demands in Glendale. This is a fundamental issue that is not addressed, much less adequately assessed in either the Alternative nor Socio-Economic Impacts section required by CEQA.

If this in fact occurs, a reduction in constant increa~ed reliance on renewable energy sources, the City will most likely face sanctions and/or court action from the California Air Resources Board, City residents and/or regional environmental organizations in the future. This will potentially result in the closing of a significant level of Grayson Power Plant operations in relation to achieving reliance on renewable energy sources significantly beyond the mandated 50% by 2030. Thus, a key issue correlated with this issue is how will local rate payers be negatively impacted (short and long term) is not comprehensively addressed.

The following analysis, of a range of CEQA sections, identifies numerous deficiencies, lack of current demographic data, failure to address a range of arenas of conventional environmental analysis, and other fundamental problems that are inherent in the FEW.

2 The FEIR requires substantive and significant structural changes and additions. The document is not adequate in relation under CEQA in a range of issues and requires substantial additions, changes and inclusions that require a redraft that also will necessitate an additional series ofpublic comment periods.

Project Description

The Project Description section of the FEIR is inadequate in relation to numerous fundamental arenas of conventional and required environmental analysis required by CEQA.

The FEIR wholly fails to establish a comprehensive ‘Analysis of the Surrounding Community’. The FEIR fails to comprehensively describe the land use, socio demographic characteristics, the number of local schools, at-risk populations who will be exposed to long term regressive air pollution impacts, land use characteristics of the cities of Los Angeles and Burbank in close proximity, the Los Angeles River and/or LA River Recreational Planning actions, Griffith Park/ L.A. Zoo, the proximity to a the second major source of severe long term air pollution, the intersection oftwo major state freeways, the Golden State and Ventura, nor other significant land use characteristics directly adjacent, in close proximity or within a three mile radius of the most severe air pollution impacts.

There is no Clear statement that this proposed project “will be the single most sijnjficant source oflong term regressive air pollution” in Glendale for the next 30 plus years.

For example, the FEW fails to identi& and quanti~ two of the most vulnerable population groups to exposure to serious long term air pollution impacts, children and youth, and seniors.

Thus, there is an acute failure to analyze the demographic groups most at risk in relation to constant and long term serious air pollution impacts in proximity to the proposed project. There is a significant, dense population base in close proximity to the proposed action which will experience long term exposure to the single most significant source of regressive air pollution for the next three decades in relation to this proposal. They reside in three different cities. This serious public policy and public health crisis is a mandatory requirement for analysis under CEQA.

The FEW fails to provide a comprehensive land use analysis of at minimum, a three mile radius. This project is not similar to a normal proposed project, for example, a large commercial center or a substantial number of residential units at one site. Nor is it similar to a specific plan that might encompass two or three city blocks. It cannot be assumed that the air pollution impacts of this significant proposal will stop a few blocks, or a quarter of a mile from the site. The FEIR acknowledges a regional, long term regressive environmental impact, yet fails to address the public health consequences of the proposed action.

3 This is a major sub-regional power plant that will, as per the FEIR, continue to contaminate the air for over thirty year period, It will have a definitive range of negative impacts on the public’s health from at minimum a three to five mile radius until 2050, if the proposed timeframe of completion is ever achieved.

The FEIR fails to comprehensively describe current demographic information from which to analyze short and long term serious negative public health impacts of the proposed project specifically on those who reside in immediate proximity to the proposed action. In fact, the 2010 Census and other conventional socio-demographic sources are not referenced nor appear in the appendices.

The proposed action is projected to meet peak efficiency demands “only 500 hours in an annual operating year,”approximately 5.7% of an annual operating year. The FEIR requires a focus analysis of the proposed action’s ‘system load capacity’ in relation to actual energy demands over time. The fact that the proposed action will not be required to operate at peak production efficiency for 94% of an annual operating year has significant, long term economic impacts in relation to energy costs to rate payers, bond holder financial contradictions, and a fundamental determination of whether the massive scale of the proposed action is viable.

in fact, as the Project Description documents, that the proposed project will operate at near peak efficiency on an annual basis the FEIR fails to address plans to use the resulting ‘grossly excessive’ electrical energy generation. Thus, the City and GWP will be forced to address the following issues which the FEIR completely ignores:

-level of daily, weekly, monthly annual unnecessary and excessive energy generation -existing storage capacity for excess energy generation, and limitations related to this issue -No analysis in relation to changes in this level of projected daily operations, if fundamental assumption are in fact inaccurate -alternative strategies and/or plans if the projected future energy demand proves inaccurate

This fact, a relational analysis of the system load capacity of the proposed action versus three viable long term scenarios also has a substantive role in the structural role in the inadequacies within the Alternatives section, which has been wholly abandoned in the FEIR. The project description, at minimum, needs to provide the public with a table estimating in a percentage relationship the range of days the proposed project’s actual system load capacity versus actual daily demand for system wide users! use.

This will clarifS’ the misconceptions inherent in the Project Description in relation to a wide range of environmental, land use, public health and socio-economic impacts related to Grayson.

The table should indicate, in percentage relationship, an estimate of annual system load capacity versus daily actual demand between 50% to 59%, 60% to 69%, 70% to 79%,

4 80% to 89%, 90% to 94% and 95% to 100%. In the Alternatives Section, this table, which is non-existent, would form the basis for elected officials, senior management and the general public to accurately assess the merits of viable alternatives, which in fact appear to be far superior to the proposed project.

The lack of this essential information, not contained in the FEW, is a major inadequacy. The Glendale city council, senior city government officials, the general public and residents from surrounding cities are thus being deprived of a critically important set of data necessary to assess both fundamental long term negative environmental impacts, and key socio-economic impacts. In addition, this information is of significant importance to the Alternatives section.

In the Project Description, the FEIR fundamentally fails to identil5’ the demographic characteristics of the immediate and surrounding communities adjacent to the proposed action, nor is this fundamental data provided for Burbank and Los Angeles residents who will reside within close proximity to this proposed project. The FEW fails to incorporate basic land use information from either city, including relevant Community Plan and/or General Plans of communities in Burbank and Los Angeles directly impacted by the proposed project.

There are two major regional recreational resources, Griffith Park/ L.A. Zoo and the Los Angeles River which are characterized by both active and passive recreational users. These regionally popular end destinations have an annual level of daily users of over 10 million visitors. The FEIR fails to address a range of significant negative environmental impacts on these users in relation to the proposed action.

In addition, the FEIR fails to reference nor utilize any information related to Land Use sections of the General Plan of the City of Glendale, nor any community plan that may exist in this sector of the city.

City of Glendale Energy Policy

The FEW fails to address how this proposed project will impact the City of Glendale’s energy policy, and has resulted in “a majorpublic policy controversy”, locally, regionally and at a state level. This proposed project essentially would produce far more energy than the City requires for the foreseeable future. In essence, this could regressively preclude significant increases on renewable energy sources, which contradict clearly stated State of California policies on this matter.

One of the major failures under CEQA of the FEIR is the wholly inadequate analysis of the future decline on the reliance on non-renewable, polluting energy resources versus an historic transformation toward renewable resources, and the relationship of this proposed action to this reality. City officials, GWP management, and civic leaders are eminently aware of major recent state laws, specifically SB 350 and AB 802, that mandate structural changes of all utilities toward substantial increased in renewable energy resources. The City has widely disseminated public information in relation to this matter. In fact,

S Glendale is among the highest ranking cities in the entire state in it’s current percentage relationship between renewable and non-renewable energy sources. This issue is documented in state legislation, academic research, the press, and the Governor of California is a leading advocate of this movement. Yet, the FEIR’s failure to incorporate any meaningful focus on this crucially important issue is beyond puzzling. This failure constitutes a major inadequacy under CEQA.

Under CEQA, the FEIR is mandated to comprehensively address how this project, which is totally reliant on non-renewable energy resources, will impact, positively or regressively, the City’s ability to continue to transition toward a dominate reliance on renewable energy resources by 2030, and into mid-century. This is not a minor environmental public policy issue, “it constitutes the most signjflcant energy policy controversy” confronting the modem history of Glendale.

At minimum, the FEW needs to clearly indicate to city officials and the general public the impact, short and long term, on the acute contradiction on a reliance inherent in an over designed project proposal based solely upon non-renewable energy sources, which will have a negative impact on the public’s health, potentially severely limit future transition toward a substantial increase in renewable energy resources, and contribute, for over 30 years, to the serious air pollution problem in the worst air pollution basin in the U.S.

The FEIR completely fails to address the City’s current relationship between renewable and non-renewable energy sources. In 2018 the City clearly states, in publicly distributed GWP documents, that this is a 47% to 53% relationship (renewable! non-renewable energy resources). The FEIR fails to state either that the City is already virtually in compliance with SB 350, at 47% renewable energy use rate that state law mandates a 50% level by 2030. The FEIR fails to state that GWP is at 142% of this law’s 2020 mandate (33%).

Key facts not addressed in the FEIR:

-SB 350 requires all utilities to have a minimum of 33% renewable energy sources by 2020. Currently, the City is at 142% of this state mandate.

-SB 350 requires all utilities to have a minimum of 50% renewable energy sources by 2030. Currently, the City is at 94% of this state mandate, 12 years before this mandate is to be met.

-Integrated Resource Plan: Prior to the projected start date (per the FEIR), SB 350 requires the development and submission of an Integrated Resource Plan (IRP) to the CA Public Utilities Commission (CPUC) by 2018. This plan is in conjunction with the CA Renewables Portfolio Standards (RPS) which sets goals for public utilities.

6 -A total reliance on non-renewable energy resources contradicts current state laws and policies mandating a transition to renewable energy resources in the short and long term fixture in California

It must be acknowledged in this analysis that GWP is a municipal utility.

Conversely, GWP has an 1RP report that is designed to inform the state how the GWP has engaged in future energy planning to transition toward predominately renewable energy sources in the future. Establishment ofthis IRP is pro-active public policy. In reality, the recent widely distributed public information packet sent by GWP offers the goals of it’s IRP and clearly indicates that GWP continues to submit reports to the public identif3ring it’s current, highly successful transition to renewable energy policy for the City.

In reality, the City’s current success strongly indicates, an impressive 12 years before the compliance mandate, that the City will continue to transition into a period of significant reliance on renewable energy sources for it’s long term energy requirements.

This fundamental failure to incorporate these basic facts in the FEIR, thus eliminates a critically significant public policy issues that structurally contradicts the inherent problematic reliance on non-renewable energy resources correlated with this massive proposed Grayson Expansion project, and challenges an assumption as to whether it is even necessary.

If a comprehensive analysis within the following sections, Project Description, Short and Long Term Impacts, Alternatives, Mitigation Measures and Adverse Impacts were incorporated in the FEIR, the City Council, other City agencies, the general public, residents in adjacent cities and regional organizations and/or groups would have a fundamental and basic understanding of key relevant issues directly related to City of Glendale energy policies and it’s relationship to the proposed action.

The failure of the FEIR to address the following in relation to the proposed project renders the FEIR inadequate under CEQA standards:

-Fundamental CA laws governing utilities in relation to future energy management -Total reliance on non-renewable energy resources in an era where state law is mandating a transition into renewable energy resources -CA state laws mandating a substantial and long term increases in the dependence on renewable energy sources -Improved energy technologies and there relationship to a statewide consensus on a future based predominately on renewable energy resources, -City of Glendale energy policy, the current relationship between renewable and non renewable energy sources -The success of the City of Glendale to meet and exceed current state energy mandates, and a projection that by 2030, it can conservatively be assumed, the City will be 20% to 30% above SB 350 mandates

7 -Projected future increases in the reliance on renewable energy sources versus the long term public costs of a project -Correlation to current GWP success and future substantial increased reliance on renewable energy sources

Hot Spots

The analysis of Hot Spots in contained in Appendix D. The FEW indicates that since the ‘estimate’ of cancer risk is only .099 from the threshold for severe cancer risk, this proposed action does not need to fully assess long term cancer risks to the immediate and surrounding community.

This is an arbitrary decision, that the City Council and the Glendale Department of Water and Power should reject. This is only a slight difference, too narrow to fail the ‘public’s right to know’ about potential cancer related, and other long term illness, that will be a direct result of the proposed action.

This critical arena of public health impacts and qualitative assessment is required under the “Description of the Surrounding Community” mandate under CEQA law. This is among the most glaring deficiencies of the FEIR While the FEW identifies Hot Spots as being an essential factor in environmental and public health analysis, it then completely fails to document and assess the long term negative impacts on the immediate and surrounding community. Of particular focus, which is mandatory, is identification of at- risk populations, youth and seniors (higher levels of respiratory illnesses and cancer), and what negative impacts over time they will experience from the single most significant source of regressive air pollution in the City for over the next three decades.

Alternatives

The FEIR, instead of utilizing the Alternative Section for a serious discussion and realistic analysis of the City’s fhture energy options, is a flimsy, disjointed and inadequate discussionthat fails to inform either city elected officials, GWP administration nor the general public of clearly defmed and realistic alternative scenarios.

The Alternative Section fails to meet fundamental CEQA requirements in developing the type of reflective and serious information from which a sound judgement on the merits that exist between three realistic options to the proposed action. Thus, the FEW offers sound alternatives, then subsequently fails to provide basic data, information and assessment from which a balanced public policy decision could be arrived at after a conventional determination of the benefits of each alternative.

This section fails to offer any type of cost estimate nor cost range for an~ alternative. Theft is no tirneframe offered in relation to each alternative. There is no realistic assessment in relation to how each alternative “will meet the future energy demands” of the City of Glendale on a long term basis.

8 No alternative is analyzed in relation to a critically important issue, ‘system load factor’, nor is this issue assessed in a comparative manner. A basic technical table would offer elected officials, senior management and the general public an objective resource from which to judge the actual merits of viable alternatives to the proposed project.

Thus, unfortunately the clear identification of at least three clearly viable alternatives is a missed opportunity in which the FEIR, if it was serious about meeting conventional CEQA standards, would have offered all interests concerned about this controversy a formal basis of conventional land use, environmental and energy policy decision making.

The following alternatives are all viable options: Alternative Energy Program 150 Megawatt Facility 200 Megawatt Facility

The Energy Storage Project is also viable, due to the location in the largest metropolitan region in the U.S. and the substantial transmission infrastructure in the immediate and surrounding region.

This critique of the Alternative Section will focus on the three being identified as being most eminently viable.

150 Megawatt Facility and 200 Megawatt Facility

Given the fact that the City is already 142% of the SB 350 2020 mandate, either alternative as designed, in conjunction with the current and future reliance on renewable energy sources will readily meet any and all energy demands of the City. The City will clearly exceed the SB 2030 goal, since it is already at 94% compliance 12 years before the state mandated due date, most likely among the highest echelon of utility entities in the state transitioning to renewable energy sources by that date.

Thus, either alternative offer far superior factors in the following areas:

-Long term cost savings to rate payers and the City -Seamless integration into a future reliance on renewable sources and a substantial reduction in non-renewable sources -Ability to reduce facility capacity with less negative cost impacts on rate payers. -Ability to address any emergency energy demands -Ability to provide excess energy to other public utilities in an emergency -Increased physical space to develop battery storage infrastructure on-site -Substantially less sever long term air pollution impacts -Significant reductions in short and long term negative Public Health illnesses and related medical costs

9 The FEIR has failed to offer the operating data that the proponents have available to factually indicate the percentage relationship of a realistic range of a percentage relationship of daily operational levels of Grayson on an annual basis.

The table should indicate, in percentage relationship, an estimate of annual daily ‘system load factor’ versus estimated daily energy demand on a percentile basis between 50% to 59%, 60% to 69%, 70% to 79%, 80% to 89%, 90% to 94% and 95% to 100%.

Why is this information critical to the Alternatives Section and specifically to the 150 Megawatt Facility and 200 Megawatt Facility Alternatives identified in the FEIR? The data will clearly indicate the merits of how each Alternative will address the following:

-meet the daily energy needs of the city -significant variations in long term environmental impacts -long term socio-economic impacts on city residents -bond holder long term debt -viability of renewable energy as the main component addressing short and long term energy demands. -long term reduction of serious air pollution related illnesses and associate medical costs

Alternative Energy Program

The scant analysis is narrowly based on assumed construction costs of required transmission lines. The fundamental CEQA inadequacy in making this assumption is that the FEIR fails to offer a cost analysis to attempt to valid this weak claim.

This is wholly inept in relation to the City’s impressive current 47% renewable energy resources utilization rate. The fact that “No Analysis” about this widely distributed, public information is addressed in the FEIR is constitutes a major inadequacy in the Alternatives Section. This is particularly significant in relation to the Alternative Energy Program scenario.

Thus, for example if the projected cost for newiransmission lines to implement an Alternative Energy Program is $50,000,000, this would constitute only 10% of the clearly identified cost of the proposed action. If an accurate cost was established, the City and rate payers would rely on a system that would deliver 100% of current and long term energy needs at a public savings of a substantial 90% of the proposed action. If the cost projection was doubled to $100,000,000 the city would only require 20% of the projected project costs estimate. If there is a difference in either estimate, the concept, offering a specific cost to validate the denial of an critically important alternative is lost due to the failure of the FEIR to inform the public why that alternative was deemed not viable. The FEIR clearly fails to place a projected cost to construct new transmission lines. Thus, the analysis of this alternative fbndamentally lacks a key fact to validate this assumption.

10 In addition, this alternative fails to address current City policies to encourage solar panels on residential units, future solar on new residential and commercial construction in the Civic Center area, increased reliance on solar energy in all public buildings, which is currently being implemented by the Glendale Unified School District and other entities. This alternative fails to offer information on the substantial increase in residential solar installation in CA, the region (clear indication of no market for excess energy generation), and the City. The FEIR fails to correlate how this alternative will directly benefit from new technology in solar panels, batteries, energy storage and CA state policies supportive of cities transitioning to renewable energy sources.

The FErn, in arbitrarily identifying issues against this Alternative Scenario clearly states in Point #5, that this Alternative will have “no air emissions.” It is incompetent and irrational to state that ‘No Air Emissions’ is a net environmental negative.

The FEIR is required to offer support data and information on this fundamental issue and assumption contained in the Alternatives section.

The Alternative Section in the FEIR totally excludes significant and long term Public Health cost benefits to residents in the immediate and surrounding communities, and the sub-regional levels. A non-polluting system inherently has substantial beneficial fiscal impacts on the public health delivery system, at-risk populations residing near the proposed project, and major regional active and passive recreational resources.

The Alternative Section of the FEIR is wholly inadequate in offering realistic data, infonnation, addressing current state law, public health costs and benefits, impacts of major regional recreational resources and addressing how each alternative is far superior in facilitating the long term success of the City’s transition to renewable energy sources, which constitutes a disservice to elected officials, GWP staff and the general public in failing to offer a conventional analysis of a range of eminently viable alternatives to the proposed action.

City of Glendale General Plan

The acute lack of utilization of the City of Glendale General Plan is both perplexing and wholly inadequate. There is no reference to the Land Use Element nor the Housing Element. The only sections, from a review of the References section are the Bicycle Transportation Plan and Circulation Section.

The FETE. cites the following, “1993 General Plan for the City of Glendale.” This is puzzling since the city’s own website’s General Plan section, identifies that the General Plan was adopted in 1986. The General Plan, as indicated, has been amended for specific plans. However, it is apparent that these amendments on not related to a comprehensive General Plan update, mandated by California General Plan law.

The only General Plan related document with a 1993 date, is the Open Space and Conservation Element, per the City of Glendale website or the Glendale Central Library.

11 No FEIR prepared for a massive public works project that will be the single largest source of regressive air pollution in the City of Glendale for over a generation, which will negatively impact the public’s health in three cities, that cumulatively will impact the already poor regional and sub-regional air quality can legitimately rely on a General Plan that is based on 1980 Census Data, land use surveys and policies that date to the early l980s and late 1970s, planning policies which are beyond outdated, as a mild critique, if not wholly inadequate to form the basis of land use and demographic analysis for a proposed project with a planned operating date in the 3rd decade of the 21st Century.

The proposed action, expansion of the Grayson Power Plant is the single most significant land use proposal producing negative long term environmental impacts in the City’s history, in the last quarter century, if not longer.

That this FEW, r assume in some aspects, relies partially upon 1970 Census Data that is utilized in the sole General Plan (1986) indicated on the City’s land use planning documents is beyond incompetent.

There is no legitimate professional nor conventional rational for this incompetent and wholly inadequate source for any land use, planning, housing, circulation and/or open space analysis contained in this FEIR, given the massive scale of this proposed project. There have been three U.S. Census counts into the current period from that document.

Cumulative Impacts

The FEIR fails to comprehensively address cumulative air pollution impacts in relation to the propo~ed action and specific land use and transportation uses in direct proximity to the proposed action. Specifically, the FEIR fails to address the severe, existing air pollution that exists in relation to the intersection of two major California state freeway routes, the Golden State (1-5) and Ventura (1-134). This is one of the worst air pollution sectors in the entire region. These freeways experience severe gridlock for, at minimum, 6 hours per day (am and pm peak traffic), and experiences constant, grade level F gridlock on a daily basis, including weekends.

The ~roposed action will, over a 30 year period, contribute directly to the long term regressive air pollution public health impacts on residents within a 3 to 5 mile radius. The FEIR is wholly inadequate in failing to address the long term cumulative impact of the proposed action in relation to the already existing, major freeway based, severe air pollution sources in the immediate and surrounding ~ommunity.

In addition, the site is adjacent or in close proximity to heavy industrial manufacturing zones in both Glendale and Burbank. The FEIR fails to address how this proposed action will cumulatively increase serious air pollution impacts in conjunction with existing land uses in the immediate and surrounding area. For example, Disney Corporation is in a period of significant expansion of both employees and land demands. The company is in direct proximity to the proposed action, yet neither the employment growth of this or any

12 other company in the immediate and surrounding community are identified nor analyzed in this FETE.. The FEIR acts as if commute patterns generated by both residents and key employment sectors in Los Angeles and Burbank, in close proximity to the proposed action, are of no importance to fundamental environmental analysis.

Short Term versus Long Term Environmental Impacts

While construction impacts, which are both short term and have a minimal to modest impact on the environment are comprehensively assessed, the FEIR fails to adequately identi~’ and comprehensively analysis long term regressive environmental impacts. This is specifically problematic in relation to the long term serious and regressive air pollution impacts on the immediate and surrounding community.

Clearly stated, the single most significant source of regressive air pollution that would result from the proposed action, will have definitive public health risks and negative impacts for over 30 year period. Irrespective of the obvious, newer technologies are less polluting than those of a generation ago, the proposed action is fundamentally dependent on a highly polluting energy source that will continue to contaminate the local and regional air basin into the long term future. It will result in a continual, essentially permanent negative impact on air quality.

This is a long term, negative environmental impact that the FEIR is wholly deficient in conventionally analyzing. It fails to define at-risk populations, it fails to define estimates of health risks over time, and it fails to address how this air pollution generation will negatively impact both active and passive recreation in the immediate and surrounding communities.

In addition. the FEW fails to provide mitigation measures to address long term regressive air pollution.

Thus the FEIR fails to meet conventional CEQA standards addressing short and long term environmental impacts in a range of significant and important arenas of environmental analysis.

Adverse Impacts

The FEIR Adverse Impacts section is inadequate under CEQA standards. Fundamentally, the proposed action is dependent on an energy source which will result on a significant level of air pollution impacting the immediate and surrounding community. This is a basic fact documented throughout both the formal proposal for the proposed expansion of the Grayson Power Plant and the subsequent FEW prepared in conjunction with this conceptual strategy to address future energy demands for the City. This generational production of constant air pollution, on a daily and hourly basis, will have definitive adverse impacts that are permanent. The FEW fails to address the negative impacts of this proposed action will have both to the air basin, the public health, land use policy and

13 it’s potential to limit the City’s ability to transition into a renewable energy strategy mandated by California state law.

The numerous adverse impacts need to be comprehensively addressed. The FEIR appears to rely on a traditional framework, that since state of the art technology are proposed to be utilized, serious negative impacts are of secondary significance. This is an erroneous assumption.

Long term generation of negative air pollution has definitive public health impacts including respiratory disease, cancer, impacts on local property values, public health

social costs, impacts on local recreation within the school system and continual - contribution to air poJlution to the worst air basin in the U.S.

The Adverse Impact section of the FEIR is inadequate in numerous levels and needs to be reassessed and re-drafted to incorporate, in a conventional context, all adverse impacts to both the environment and the public’s health.

Socio-Economic Impacts

The FEIR fails to incorporate a CEQA mandated section, Socio-Economic Impacts in any conventional nor analytical context There are a number of fUndamentally essential environmental issues directly impacted by this massive proposed project.

The following issues which are required to be comprehensively addressed include Public Health, Urban Growth, LA River Revitalization, Griffith Park1 L.A. Zoo, Youth oriented public health and recreational concerns, and Land Values, both commercial and residential. While not solely inclusive of the entire realm of critically important Socio- - Economic Impacts, this assessment will focus on those identified.

The most fUndamental negative social impact is Public Health. This proposed action, the single most significant generator of regressive air pollution in the modem history of Glendale, and a source of pollution that will persist through mid-2lst century. This proposed action will have numerous and definitive, long term negative public health impacts. This section is devoid of a serious discussion in the following areas:

-failure to adequately provide accurate and current demographic data of the population characteristics of residents in the immediate and surrounding community -failure to identify those population groups at-high-risk from long term exposure to severe air pollution --failure to identify key illnesses attributed to high, long term exposure to high levels of air pollution including cancer and severe respiratory illnesses -acute lack of identification of any mitigation measures to protect at-risk population groups, associated medical costs related to air pollution based illness

- minimal or no conventional mitigation measures impacting surrounding schools from high levels of air pollution -

14 - comparative analysis in relation to how three of the alternatives would substantially reduce risk factors associated with illnesses attributable to populations residing within close proximity -identification of mitigation measures designed to structurally reduce the generation of high levels of regressive air pollution over decades.

In the failure to comprehensively address significant public health issues, the FEIR also fails to address long term public health benefits of three eminently viable alternatives. The Alternative Energy concept offers substantial public health cost benefits. It is far superior than the proposed action. Yet the FEIR fails to either document this fact nor analyze it’s important in a conventional environmental impact analysis required by CEQA.

Urban growth and land use patterns and policies are inherently related to energy generation. The proposed project is directly linked to land use and growth patterns conelated to the future of the City of Glendale. At minimum, future urban growth needs to be comprehensively addressed in this CEQA mandated section. Why the FEW fails to address this findamental issue is inexcusable.

The proposed project is central to all future city growth and significant land use patterns. This will have a significant influence on any and all issues related to population growth, increased residential construction, increased commercial construction, major land use zone changes in the future, General Plan policies and directly related environmental impacts of land use policies for the long term future. The FEIR is wholly deficit in addressing fundamental and basic land use and growth related impacts on the City of Glendale which would result from the proposed action.

.LA River Revitalization planning and Griffith Park! L.A. Zoo (10 million annual visitors), short and long term recreational projects, and active and passive recreation will all be directly impacted by the proposed action which is located in direct proximity. This massive source ofpollution, on a long term basis, has definitive negative environmental impacts, especially on recreational users of the LA River corridor. The FEW fails to comprehensively address either social, short term vs long term, adverse and/or mitigation measures that the massive scale of the proposed action would have on a major regional recreational resource directly adjacent to the proposed site. The FEW inadequately addresses fundamental issues related to this existing, and significant recreational resource. In fact the FEIR almost presupposes that the LA River is of no consequence to conventional environmental impact analysis. This is among the many major deficiencies of the socio-economic impact section.

Youth oriented issues are an important consideration of any proposed project that will generate historically significant regressive air pollution in the immediate and surrounding community. Medical literature is clear, the younger populace is particularly vulnerable to long term illnesses due to constant exposure to sources of significant air pollution. This project will be the single most significant source of long term regressive air pollution in Glendale for over a generation. Thus, this high-risk populace will be negatively impacted

15 over time. The FEIR fails to adequately document the socio-demographic characteristics of youth residing in the immediate and surrounding coniniunity, fails to address the anticipated level of illnesses which medical science has validated through medical research dating from 2000, how impacts from regressive air pollution can be mitigated to protect this populace and whether other energy generation strategies can simultaneously protect the public’ health and produce sufficient energy to meet normative demands for Glendale.

In addition, active recreation in the immediate and surrounding area of a proposed action that will result in long term generation of regressive air pollution is an essential arena of conventional analysis. Severe air pollution has definitive and negative impacts on both active and passive recreation. However, active recreation, either at school sites and parks, is ofparticular concern in protecting the public’s health. These types of conventional social uses are predominately composed of children and youth.

The wholly inadequate analysis in the FEIR is a major flaw in the document. This massive proposed power plant will have a direct and negative impact on the public’s health, in particular youth.

Land values are an important consideration of any major proposed development action. This proposed action, a massive power plant expansion, will have definitive and long term impacts on both residential and commercial land values in the immediate and surrounding community. It will also influence land values for the entire City of Glendale. It will also impact lands values in parts of Burbank and Los Angeles. The FEIR is silent on this fundamental issue.

At minimum, the FEIR is required under CEQA to address land use and land value impacts on the immediate and surrounding area: The fact that this massive power plant proposal will continue to be the single most significant source of regressive air pollution in the City of Glendale for decades indicates that it would have a direct and significant impact on these communities. The FEIR is deficient is comprehensively analyzing this issue in any meaningful and substantial context.

Given the immense scale of the proposed action, it also influences future land use and land values in the City of Glendale for the long term future. It potentially influences future zoning, growth and urban planning actions that will have a definitive influence on the future urban character of the entire City. These impacts may have a varying range of influence, yet the FEIR fails to inform the public and the City’s policy arena on this fundamental urban issue.

Environmental Justice and CA SB 350 & SB 32

California state law mandates that cities and jurisdictions directly involved in the production and generation of Green House Gases comprehensively address the impacts on minorities and lower income groups impacted by any proposed action in this field. The FEIR is wholly deficient in meeting this state legal mandate.

16 The FEW offers no legitimate justification to ignore this matter. This is in view of the reality that the City of Glendale is “one ofthe most ethnically diverse cities in the entire

state. “ The FEW fails to provide basic demographic data, much less comprehensive analysis, of the composition of Glendale’s populace. It fails in this aspect in both the immediate and sunounding community, and the entire City. In addition, the FEW fails to provide demographic data in relation to the cities of Burbank and Los Angeles, both of which have residential communities in close proximity to the proposed action. In addition, both cities have significant commercial and/or employment centers that will be directly impacted from the negative environmental impacts that would occur from the proposed action.

The FEW, in essence, has abandoned any reasonable and conventional analysis on how lower income and/or minority communities will disproportionally suffer from the negative impacts associated with this proposal. This is unusual given the fact that Glendale is among the most ethnically diverse cities in both California and the U.S.

CA SB 350 and SB 32 mandate that localities address adverse, negative, unequal impacts from proposed actions related to environmentally polluting, energy related proposals. This FEIR fails to meet the clearly stated standards of either law.

The FEIR is required to, at minimum, accurately identi& the specific socio-demographic characteristics of all lower income and/or minority communities that will be negatively impacted, address specific public health risks to these populations, establish realistic and credible mitigation measures to substantially reduce inequitable treatment due to serious long term negative environmental impacts, and address how the proposed action will avoid overt, discriminatory environmental impacts on both a short and long term basis.

This FEW is wholly deficient in relation to conventional environmental analysis related to this section established within CEQA.

State of California General Plan and CEQA Law.

The only FEW reference in relation to state laws governing land use policy is the 2005 Tribal Consultation Guidelines from the Office of Planning and Research. This is a niche, narrow reference, which while important for a specific section of analysis, does not suffice in relation to the magnitude of the numerous, significant negative environmental impacts in correlation to the sub-regional scope and scale of the proposed action.

Why neither the City of Glendale’s current General Plan and CEQA were not properly referenced, especially in relation to Adverse, Short v Long Term, Cumulative, Growth Inducing and Socio-Economic Impacts, and Alternatives within CEQA, and the Land Use, Transportation and Housing Elements in relation to the General Plan is odd, in relation to the narrow identification of Tribal Guidelines within the references section.

David R. Diaz 1211 Scenic Drive Glendale, CA 91205

17 Jr.. ~~H7 Ellis ~~I? April2,2018 Pfl

Mayor Van Gharpetian Glendale City Hall 613 E. Broadway Glendale, CA 91 20t

Dear Mayor Gharpetian,

I urge you to support the re-powering of our (3rayson Power Plant and certil3r the EIR on April 10.

With the city’s growth spurt in the last few years, the citizens of Glendale need reliable electric power. Alter hearing both sides of the issue, I support the plan and feel it is imperative that there is no delay in getting this project going.

I have lived in Glendale since 1986 and have been pleased with our infrastructure. The new plan will allow GWP to minimize power interruptions, which could be a real threat in our overbuilt city. We are fortunate to have our own power plani and we need to keep it going.

The fact that 47% of the power comes from renewables while the rest of our state is only at 25% proves to me that our city has shown very good leadership regarding our environment. We need to put the new plan into action as soon as possible. I know that our environment will always be considered into the future.

Sincerely,

Carol Prager 1400 Cleveland Road Glendale, CA 91202 March 28, 2018 281g ~

The Honorable Mayor and Members of the City Council City of Glendale California 613 E. Broadway Glendale, CA 91206-4391

Dear Mayor and Members of the City Council

As a longtime resident and home owner in the City of Glendale, I am writing you to express my support for the re-powering of the Grayson Power plant and would urge you to support it as well.

With 47% of its power generation coming from renewables, Glendale Water and Power (GWP) has demonstrated significant leadership in this regard, particularly when the rest of California is reported to be at only 25%. Given this record of leadership, I am confident GWP will do even more to increase its renewable mix in the future.

I believe maintaining a large portfolio of renewable energy sources by GWP is important, but it is equally important that GWP to be able to deliver reliable and affordable electric power to Glendale residents and businesses. lam certain the re-powering of the Grayson project will accomplish that need. It will allow GWP to minimize power interruptions during the most critical times when other sources may be interrupted or reduced for extended periods of time.

For these reasons, I support the re-powering of Grayson Power Plant a~ proposed and request that you also support this project and certify the EIR.

Thank you.

Sincerely,

Ronald F. Brusha City Council March 27, 2018 ~ST~H~r ~ Mr. Mayor, Honorable Council Members, My name is Dorothea Malina. I live in Glendale. 2016 APR ~2 PIt 14; ~

I am troubled about the Grayson repowering plan.

1. Especially for those who live close to Grayson -- 4 members of my family live within 1/2 mile, (and I am not far away). In October we were told the plan is to do environmentally sensitive work at night “to minimize negative effects on residents’ But THAT IS WHEN MOST PEOPLE ARE AT HOME, with WINDOWS OPEN TO GET FRESH AIR. Not to breathe air pollution from dust and fumes from construction. And I understand asbestos covers a large portion of the site.

2. FAILURES (whether from miscaiculations, cost cutting, inferior materials, or acts of God) result in tragic accidents. Last week in Florida a bridge collapsed. Closer to home were the highway bridge fire while under construction east of Los Angeles County, Torrance refinery frequent mishaps, and catastrophic gas leaks at Aliso Canyon---the biggest in US history. The less we rely on hazardous fuels, the safer we will be. Incidentally, on Monday the expansive Reading Spa in the newly renovated Glendale Central Library was closed due to water damage” from the rain.

3. Funds should be dedicated to needed transmission expansion, not burning more fossil fuel. 4. $500,000,000 WILL cost us more than we currently pay. I am not a CPA nor financial prognosticator, but neither is whoever wrote Page 20 of the Grayson Project overview. The tooth fairy might believe its quotation: ‘There is no projected cost impact to our customers” but you and I should not. I am not an expert, but I have common sense and a wealth of experience from years of paying attention. We who elected you believe EACH of you has common sense, integrity, and a devotion to the good of this city. Mr. Mayor, you, and perhaps others, objected to rallies where hundreds who live or work in Glendale met to express their objections, reservations, or concerns about the original Grayson proposal. But those rallies were peaceful and respectful of this council and its staff, and with 90 people requesting to speak at your official presentation meeting, how else could the others be heard? How could they demonstrate they were real, not just names on petitions or letters? Thank you. Councilmember Paula Devine Glendale City Council 44’~~ Management Services, Rm. 200 “it 613 E. Broadway

Glendale, CA 91206-4391

Dear Councilmember Devine: We are members of the Sierra Club Angeles Chapter Verdugo Hills Group, which represents Burbank and Glendale. We are writing to you regarding the proposed rebuilding and expansion of the Grayson Power Plant. We ask that you not vote to certify the Environmental Impact Report on March 27 but instead second the motion of Councilmember Sinanyan to conduct an independent study of how to replace Grayson with 100 percent clean energy resources and to set up a citizens’ advisory committee to participate in the process together with GWP.

The Sierra Club opposes new electric generating units powered by natural gas, including peaking and combined cycle units. California has pledged to get 50 percent or 60 percent of its power from renewables by 2015, and the state legislature is likely to pass a bill (SB 100) this year that will set a target of zero fossil fuel electricity by 2045.

The three-year construction period anticipated for Grayson’s makeover will cause the release of more pollutants, especially particulates, in Glendale, Burbank and east Griffith Park. This will worsen the pollution in neighborhoods where the air quality already fails to meet federal clean air standards.

Scientists are alarmed about the recent “heat wave” in the Arctic. It has caused them to reconsider even their bleakest forecasts of climate change. Everywhere we can see the results of increasing amounts of heat-trapping gasses in our atmosphere This is enhanced by human burning of fossil fuels. Pausing and conducting a study of renewable alternatives to natural gas power is low cost and low risk. Lunging forward to bet hundreds of millions of dollars on the polluting technology of the past is high cost and high risk. Glendale can decline to participate in the march of folly and can, instead, set an example.

Thank you for vow consiqeration.

21St Krause, Erik

From: Sophia Santitoro ([email protected]) Sent You a Personal Message Sent: Thursday, March 15, 2018 5:00 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

As a resident of Glendale and a GWP customer, I’m writing to voice my strong opposition to rebuilding and expanding the Grayson Power Plant. Rather than sinking $500 million into a polluting fossil fuel facility, I urge you to seize the opportunity to make Glendale a showcase for clean energy alternatives. The list of concerns with this project is long.

? Emissions of carbon monoxide, nitrogen dioxide, sulfur dioxide, small particulate matter and other pollutants will increase across the board. This will worsen already bad air quality in an area that houses two elementary schools (Mark Keppel and Franklin), the Disney Creative Campus and Disney Children’s Center, the residential neighborhoods of Pelanconi Estates and Moorpark, and popular outdoor spaces such as the John Ferraro Athletic Fields and Glendale Narrows Riverwalk.

7 Greenhouse gas emissions, which are heating up our region and increasing risks of drought and fire, will increase by more than 415,000 tons of carbon dioxide each year. That’s an increase of six times over the current levels, and equivalent to adding 90,000 cars to Glendale’s roadsl

7 The plant would be built in an identified liquefaction zone. That makes the plant itself, and the gas piping and transmission systems, all highly vulnerable to a serious earthquake. Apart from the obvious safety risks, this raises questions about its ability to maintain reliable service in an emergency.

7 Spending $500 million on a single, large fossil fuel plant creates huge financial risks for Glendale ratepayers. With efforts underway in Sacramento to move the state to 100% clean energy by 2045, it’s more likely than not that we’ll be paying for this plant long after it’s been forced to shut down.

Glendale doesn’t even need this much power. Your own reports forecast falling demand for electricity in Glendale. If demand is falling, why would we need to build a plant that increases generating capacity by 33% as this proposal does?

This project would lock us into legacy technology that harms public health just at a time when the rest of the state is surging forward. I urge you to halt efforts to expand Grayson and commission a study of clean energy alternatives.

Sincerely,

Sophia Santitoro 1012 Franklin Ct Simi Valley, CA 93065 minecraftraRel4 @gmai I .com (805) 791-0687

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. - ~ fl~ danielbwatson@aoLcom Date: March 3, 2018 at 1O:17:2OPMPST T~i~ [email protected], [email protected], zsinanyan @glencialeca:gds’, ~‘vagaianian @ gleddaleca.gov, vgharpeti~n @ gleiidhlecá. gov, ybèers @ glendaleca.g&v Subject: Deer Canyop-Oa~cmont Property Owners Association The Deer Canyon-Oakmont Property Owners Association (DCOPOA) held their annual breakfast/business meeting this morning (March 3). Fire Chief Greg Fish and General Manager of Glendale Water and Power Steve Zurn both spoke to the residents. Sot Chief Fish and Mr. Zurn were both very well prepared and informative. I recieved several positive comments after the meeting about how valuable the presentations were. Mr. Zum presented information on the proposed re-powering of the Grayson Power Plant. There has been a lot of negative information put out criticizing the plan to replace the aging generators. Mr. Zurn did a very good job of explaining the need and benefits to the residents in a very professional way. After learning a great deal to day about this issue, I strongly encourage the City Council to move forward with the project to re-power the Grayson Power Plant. I am making this recommendation solely as a resident and not as an official position of the DCOPOA. Dan Watson, President Deer Cahyon-Oakmont Property Owners Association

1 ______From: Gregory Tan {mailto:[email protected]] Sent: Wednesday, January 17, 2018 3:20 PM To: Zurn, Stephen Cc: ‘Judee Kendall’ Subject: Chamber supports Grayson repowering

Hi Steve, I wanted to let you know that the Chamber Board voted to support the Grayson repowering project. Thank you for bringing your team to our Board meeting to inforhi us and to clarify aspects of the project. I appreciate you taking the time. Please keep us in the Ioàp as this moves forward.

Greg

Gregory Tan, P.E., LEED AP BD+C, O+M Project Manager CMGT Construction Company 818-636-2420 cell

1 W6M ~ S~si~éTi~6 L~Ô1Ti’ Fr bi1f5~iió~öft~[dên~ö ?bml Sent Wedrfesday, M&ch 07, 2018 10 47 AM To DL GraysoriRepowerPrOjeCt SUbject: gia~yoñ?e~~bWerifl9 - Messa~é from a visitor! grasyonrepoweilng -You have a new message from a vieitor!

Please reply to: miketmoculloughi @cimaiLcom

Name: Mike McCullough

Email: miketmcculloucihl @cjmail.com

Message: The mailer that you recently sent to residents was very well done and informative. i believe that most people were not aware of many of the facts that you shared in these documen~. I only have one question for you and this is regarding the ability of Glendale to meet its renewable energy source goal of 50% by 2030 after you have put into operation the new and more efficient equipment that is being proposed. If only 20% of the current plant is in use today, I understand why it was easy to obtain from outside sources in 2016 47% renewable energy. You had to buy energy, and so why not buy renewable, but when you put into use the new gas generating equipment, I assume that tnuch more energy will be self generated, thus leaving fewer opportunities to purchase renewables, and thus making it more challenging to achieve the 2030 requirement of 50%. I would appreciate a response so I can share t his with others in the community. By the way, I don’t think the City can afford not to go forward with this sound engineering plan. Thank you! - 1

~ • ..-•

~a S~NTh CU%~flA CTh.~fl3~ ___

P I ~b≥Yli-t PN2 IL

&/~Md~Ie w4Fav~ /~~n A! 6kv&4i&4~

S7t~~evp 2~ ~

frvct~(gb~ t~ ~c7~bi PO~2~

P ~ %~2ct~4-o’q, ~ f€~1 n~;A~’a/ycø ~42~ ~ p~%. ~

~ an ,tcr ,z~qan1e’i y4~≤- z~

M/ct ,1, ~

j~c~&vjv - Uz~ no 1- 6’tQ’ C” eYi~~a cif cnn2r Krause, Erik

From: Christopher Gullixson ([email protected]) Sent You a Personal Message Sent: Tuesday, February 20, 2018 10:04 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

? Greenhouse gas emissions, which are heating up our region and increasing risks of drought and fire, will increase by more than 415,000 tons of carbon dioxide each year. That’s an increase of six times over the current levels, and equivalent to adding 90,000 cars to Glendale’s roads!

? The plant would be built in an identified liquefaction zone. That makes the plant itself, and the gas piping and transmission systems, all highly vulnerable to a serious earthquake. Apart from the obvious safety risks, this raises questions about its ability to maintain reliable service in an emergency.

? Spending $500 million on a single, large fossil fuel plant creates huge financial risks for Glendale ratepayers. With efforts underway in Sacramento to move the state to 100% clean energy by 2045, it’s more likely than not that we’ll be paying for this plant long after it’s been forced to shut down.

This project would lock us into legacy technology that harms public health just at a time when the rest of the state is surging forward. I urge you to halt efforts to expand Graysonand commission a study of clean energy alternatives.

Sincerely,

Christopher Gullixson 5782 Owl Light Ter Santa Rosa, CA 95409 ch risgullixson @sbcgloba I. net (707) 326-8400

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. F

- Forwarded message - From: Jennifer Pinkerton Date: Feb 7, 2018 8:37 PM Subject: Grayson Repowering/Expansion To: “Gharpetian, Vartan” ,”Agajanian, Vrej” ,”Devine, Paula” ,”Najarian, Ara” ,”Sinanyan, Zareh” ,”Lorenz, Tom” Cc:

Dear Mayor and Councilmembers:

Thank you for the opportunity to speak last night on the proposed Grayson Repowering/Expansion.

Because there was insufficient time to address all issues that are of concern to me, Jam submitting these tonight. For ease of review, each item is numbered.

Those of us who are opposed to the Grayson repowering/expansion as proposed acknowledge that utilities are confronted with the very difficult task of planning for decades into the future in ways that other businesses are not. At one time, Glendale could have committed itself - for decades - to natural gas; that approach worked well in the past, when industry technology advances were measured in decades. That strategy is no longer applicable, when technology advances can be measured on a yearly basis - or less. True, renewables are not “easy” because they are intermittent, but utilities must plan for a 100% renewable future, even if it never comes to pass. I ask that you prioritize the health of Glendale’s residents by prioritizing renewables.

A. Environmental & Other Impacts to Adjoining Neighborhoods 1. I am the President of the Grand Central Neighborhood Association. The Grand Central and the Pelanconi neighborhood are the two that will be the most directly impacted by the Grayson project. 2. Please note that our neighborhoods are already disproportionately burdened by multiple pollution sources, according to the Office of Environmental Health Hazard Assessment (CaIEPA). 3. It must be noted that the project documents do not reference public health risks associated with the construction phase. 4. We know there is asbestos and likely as-yet unidentified hazardous material in the eight (8’) feet of soil that will be removed. a. I believe it is unrealistic to promise that the asbestos — a carcinogen - and other pollutants can be 100% controlled, based on my many years working in environmental compliance for construction projects. b. Should construction commence at Grayson, I strongly urge that asbestos monitors be employed not only at the Grayson site perimeter but also in adjoining neighborhoods, including the nearby soccer field across the river, which is enjoyed by many children, who are extremely vulnerable to air pollution. 5. Basic pollution controls were not enforced during the 9 months that the Disney Child Care Center was under construction across from my house, a site located not far from Grayson, with many of the same soil pollutants as the Grayson site. Ongoing construction dust was awful; my neighbors and I had to keep our windows shut at all times and therefore run our air conditioners - even during mild weather. In my opinion, shaker plates were not kept clean, gravel at exits and entrances was not replenished frequently enough, and the site was watered too infrequently. The result was that soil from the site was tracked onto streets, blown onto our properties and into our homes - on a daily basis.

6. The repowered plant will produce higher emissions of criteria pollutants — including air toxics identified as carcinogenic, as was acknowledged by one of the project consultants last night. a. Yes, offsets are an option, but offsets will do absolutely nothing to protect Grayson’s immediate neighbors 7. Because the project documents call for 12 hour construction days, 6 days a week, White Sound® or equivalent reversing alarms are preferred to the standard, piercing equipment “backup beeps,” which carry long distances. Continuous exposure to noise is known to be harmful to health. 8. Given Grayson is in a liquefaction zone, will the final EIR calculate how far vibrations frompile driving may be conveyed and 1 perceived, and what types of damage could result? Homes in my neighborhood suffered damaged from the Disney construction, including interior cracks in walls and ceiling, holes in exterior walls, etc.

B. Renewable Energy 1. The City now has a very laudable 47% renewably-sourced power; however, I believe his repowering proposal represents a step backward, away from renewables. 2. I am very surprised at the small amount of solar PV that is proposed, given the size of the Grayson site, the clear need for distributed generation and locally-generated renewable power, neither of which can be impeded by transmission line capacity/barriers. 3. I must respectfully disagree with Mr. Zurn; solar PV is NOT difficult. I worked as a consultant to the LADWP Solar Power Program for many years. 10 megaWatt systems (MW) were quickly installed at locations that are a fraction of the size of the Grayson site. 4. The project documents reject Scholl Canyon Landfill (LF) as a site suitable for solar PV because it is “unstable.’ That conclusion is contrary to current trends. The US EPA, the Rocky Mountain Institute, and many other entities advocate for such systems and/or have issued guidelines for PV systems AT municipal landfills. LFs are usually ideal for PV because they are typically close to interconnection systems, less expensive and impactful. More than 15 US LFs now have solar PV and there are plans for many more. The Annapolis Solar Park is an 18-MW system; when completed, it will be the largest PV project exclusively installed on a closed landfill in the U.S.

C. General Comments 1. I am troubled by the fact that the largest possible repower, just shy of what would trigger a CEC review, has been proposed; this seems disingenuous, particularly given that Scholl LF gas is not factored.

Thank you for your consideration.

Jennifer Pinkerton [email protected] 818-588-2354

2 February 6, 2018

The Honorable Vartan Charpetian Mayor, City of Glendale Glendale City Hall 613 F. Broadway Glendale, CA 91206

Dear Mayor Gharpetian: I am writing relative to the Grayson Repowering Project Environmental Review process, item 8 on yoUr City Council agenda today. As you are well aware, this item has attracted significant ahention from members of our community and pertains to one of the larger investments in electricity delivery infrastructure that Glendale Water and Power will make in generations. The oldest generating units at Grayson Power Plant are over 80 years old and require near constant maintenance by Glendale Water and Power staff in order to keep them running and thus keep the lights on for the residents of Glendale. They are extremely problematic in that they produce far more emissions, for far less electricity, than modern generating stations. That they need to be replaced is not controversial, the question is: with what? At a special meeting on October 17, 2017, your Glendale Water and Power Commission considered the consultant study on the proposed project and each commissioner offered comments to be considered in the official record in its California Environmental Quality Act (CEQA) Environmental Impact Report (EIR). At our meeting, there was understandable and relatable frustration from members of the public with the nature of the Grayson Repowering proposal, as recommended by the CEQA consultant. The “preferred” alternative in the EIR as it was presented to the GWP Commission was to build a 250- megawatt natural gas generating station consisting of two baseload power plants and two rapid-start “peaker” plants to manage spikes in demand for electricity during hot summer months. I do not prefer this recommendation, and I want to know if the serious concerns I voiced with my fellow Commissioners at the October hearing, along with the comments of dozens of speakers from the community, and the aver one thousand comments received to the Draft EIR, will be reflected in an updated Final EIR document. With work largely complete on the Final EIR, and only a week or two until it is scheduled to be released, it seems unnecessary to discard all of the work by the consultants and ignore the comments by the community days before the scheduled publication of the document. That said, I have faith in the staff at GWP and its General Manager to propose a project that takes into account the community’s feedback, addresses the environmental concerns with the FIR-preferred alternative, and disregards any project recommendation from outside consultants that would fail to make our ratepayers proud. Despite the negative attributes of the current FIR-preferred alternative, I believe that freezing the CEQA process is unwarranted and will only result in further delay in producing a better project. GWP has an opportunity to consider better alternatives well within the scope of the existing process, and at an incrementally higher cost in time and money, rather than essentially doubling the project planning costs and lead time by starting the process all over again. Further delays will also result in GWP operating the existing Grayson Power Plant even longer, with higher maintenance costs, and worse, producing more emissions per unit of natural gas than any of the proposed project alternatives; this is the very opposite of what the public wishes for our neighborhoods. I encourage the adoption of the staff recommendation by you and the Council today. Let the public and your Commission have an opportunity to review the consultant’s work and let your GWP staff make this project right for our City. If the consultant does not respond to the substantive comments made by the Commission and the community, and direction from GWP, then we can work together to explore other options. Thank you for your consideration in this matter.

Commissioner, GWP Commission

CC: Councilmember Paula Devine Councilmember Ara Najarian Councilmember Zareh Sinanyan CouncilmemberVrej Agajanian From: Kay Campitelli Date: February 6, 2018 at 9:44:29 AM PST To: [email protected] Cc: akassakhian@ plendaleca.pov

Subject: Grayson Power Plant - Please pause and seek clean energy alternatives!

Dear Michael,

Please put the health and well being of your citizens before the Gray~on energy plan, which has proven to not be necessary, and will have a negative impact on the community. Seek an independent expert study for clean energy alternatives. Protect our health and environment.

Thank you

Kay Campitelli ~L:zZzEEZiZZEEZEZZZzEEEzZZzZZZ.ZEZE11

— i — Krause, Erik

From: Virginia Melin SeAt: Monday, February 05, 2018 2:11 PM To Krause, Erik, Gharpetian Vartan, Devine, Paula, Agajanian, Vrej, Sinanyan, Zareb, Najarian, Ara Subject Grayson

Dear Mr. Krause, I am writing to express my STRONG oppb~ition to the Grayson repowering project as outlined in the September .2017 Draft EIR.

My husband and I just bought a house in Eagle Rook for over a million dollars and my family (including my young children) will be negatively impacted by the poorer quality of air this expansion will create This plant is unnecessary as California plants already create more power than we need and Californians are footing the bill There was an LATimes investigation that found that the state is actually operating with an oversupply of electricity which is leading to HIGHER electricity rates for Californians Let’s be smart and push for the expansion of CLEAN energy and continue to make California be a beacon for the bilght future of Ameilca.

Thisproposed expansion will emit 7 times more emissions than it currently produces -- raising toxic air particulate levels 542% in NELA which cause cancer and asthma and impaired neurological function in children (MY children perhaps).

I call on the City to pause the CEQA process and immediately commission an independent study of clean energy alternatives for powering Glendale This study should be conducted by a group such as NREL or E3 with strong clean energy credentials and not by the consultants who have been working on the Grayson EIR.

Sincerely, Virginia Melin

5130 Ellenwood Drive Los Angeles, CA 90041 310,869.9858 February 4, 2018 Glendale City Council

Dear Council Members, I appreciate clean renewable energy, clear skies, and threats to our planet’s environment. But there is a lot of misinformation being spread about Glendale’s Grayson re-powering project that threatens to delay this vital plant. I’ve read the project plan, Draft Environmental Impact Report, the opposition website, and I’ve talked with our city staff. I’ve found that those against the project use a lot of fear mongering. They use cherry-picked data out of context, and have an impractical zero-tolerance attitude toward risk. It’s a complex issue, so I can only address a few of their major arguments. Become informed yourself by reading about Grayson on the GWP website, and Rumors page under the City Office of Communications. The proposed repowering project is sized for the City to meet peak load and ensure Glendale can comply with regulatory obligations which require Glendale to maintain significant amounts of reserve power to quickly respond if a power source goes offline. Weighing population expansion, reduction of demand by roof-top solar generation, and potential increased demand of electric vehicle recharging, GWP chose to plan for a 350MW capacity to cover demand and potential lossof sources. Currently, Grayson has limited capacity to integrate intermittent renewable sources, like rooftop solar. The new plant will make that possible. Old Grayson units are subject to upcoming SCAQMD regulations, and equipment failure in old units caused 40 unplanned outages since May of 2015. Those units are unreliable and spare parts are scarce or unavailable, making us vulnerable in emergencies. I too, want to reduce burning fossil fuels. But realistically, zero use of fossils fuels will not be an economical option for the next several decades. The great news is that re-powering Grayson means that we eliminate electricity from coal that we must currently buy from other suppliers. The new Grayson project is more energy efficient. We’ll be able to produce more electricity than the existing plant while using just over ‘/2 the natural gas of the existing plant at a cost that is nearly 40% cheaper per MW than the existing plant. What’s the truth about the new Grayson plant emitting 415,000 metric tons of greenhouse gasses per year? Will there be health effects? The 415,000MT/yr is a value calculated for permit purposes, based on running the entire plant at full capacity, 24/7/365. Based on historic demand profiles, Glendale expects future greenhouse gas (GHG) emissions from the Project to be about 37% of 1990 levels for the GWP portfolio. The SCAQMD concurs that the new plant does not cause unacceptable air quality impacts on either a local or regional basis. There are many factors that may correlate to health risks. Proximity to traffic, socio-economic status, and genetics also correlate to health risks. By lowering overall emissions, the new Grayson plant will only lower any risk of health impacts like cancers or low birth weight. A repowered Grayson is an integral part of Glendale’s plan to move to a 100% clean energy future, and there is no practical way to skip forward without this project. Glendale has almost twice the state average of renewable resources. Glendale uses 64% renewable and carbon-free, compared to 44% for the California average. Glendale funds solar and renewable energy development through rebates and other programs. These measures, to date, have brought approximately 12.5 MW of rooftop solar to Glendale. As aggressive as that program has been, it provides less than 4% of the city’s need. The existing generators at Grayson (except newer #9) will reach their end of serviceable life in about 2021. Without replacing Grayson’s capacity, Glendale won’t be able to import (buy) enough electricity to make up the peak demands. Nobody really wants rolling blackouts during a heat wave. Our ability to import electricity is limited by our transmission line connection capacity (the wires can carry only about 200MW). The main goals of the Grayson re-power project are to meet peak load demand, meet regulatory reliability requirements, generate at least 234 MW of power, and be able to integrate more renewable energy. To reach those objectives,.the project chose to provide 250 MW of generation at Grayson and get the balance of our needs from external sources. The plant won’t run at full capacity year-round. I have no reason to doubt the assessments of our current situation or the Grayson re-power plan. I want these facts to be taken seriously. Engineers are good people trying to solve our problems, not evil cyborgs trying to find insidious ways to harm humans for profit or arrogance. The City’s electric customers’ needs, and local, state, and federal regulations drive GWP operations and decision-making. Today, Grayson is expensive, inefficient, unreliable, and a relatively high polluter. Glendale needs local generation to allow maximum use of transmission lines to import renewable resources and to integrate local solar. I urge our City Council members to resist the distraction of the Stop Grayson movement. We already have a thorough and responsible study of alternatives and a project plan, from Pace Global Engineering. We have an acceptable Draft EIR. We already know that we’ll tomply with SCAQMD and meet various other regulatory requirements. Put an end to their conjecture, innuendo, and misinformation about the project. The Grayson project will be in construction for about 3 years. Let’s get started before the lights go out! Sincerely, Kurt Sawitskas 550 Cumberland Rd Glendale, CA 91202 818 640-6295 cc: via email Glendale Water & Power Commission Yasmin Beers, Acting City Manager Ardashes Kassakhian, City Clerk Stephen M. Zurn, General Manager—GWP

Tom Lorenz - Director, Communications & Community Relations Glendale News Press (via separate email) Krause, Erik

From: Michael Mitsuda ([email protected]) Sent You a Personal Message Sent: Thursday, February 01, 2018 3A2 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Michael Mitsuda 33210 Lake Oneida Street Fremont, CA 94555 [email protected] (510) 754-9751

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. H __ ___

~ ~fr~ojeth J~E -_ “.1

From: ~ - - - Date: March 5, 2018 at 10:57:57 AM PST To: “Zurn, Stephen” Cc: , Subject: RE: NWGHA Board and Grayson PP Project

Steve, thanks for the meeting and your review of the Grayson Plant repowering last week. Yasmin, thanks for attending.

We will be neutral on the project because we do not have a clear mandate from our membership. However, we will no longer advocate for a pause. Your presentation gave us a better understanding of the comprehensive scope of the consultant’s report and the various options that have been considered, as well as the issue of needing to have the reliability to meet peak power needs.

Peter

t ~t I ~ ~ —H a Northwest Glendale Homeowners Association

P. 0. Box 3232 Glendale, CA 9122 1-0232 (818) 754-8274 nwglendaleha.org February 1, 2018 nwg1enda1e(a2~maiLcom

Officers ~ó Dear Councilmembers, Peter Fu.ad, President, Editor of The Guardian We are writing this letter with reference to the proposed Grayson Power Lawrence Kalfayan, Plant project to be considered at next Tuesday’s Council meeting. Vice President Carl Moseley, Treasurer We believe that the project should be “paused” immediately. We fully Holly Keenan, support what many other local groups are asking Council to do: Membership Chair Philip Keller, DRB 1. Pause the Grayson Power Plant EIR process immediately. Representative 2. Retain truly independent consultants to: Carol Brusha, Recording Secretary, Publicity Chair, • Determine our actual power needs Associate Editor of The • List clean energy solutions to meet those needs Guardian • To the extent there is a plan to sell excess energy, determine the Royal Barber, Director viability of such plan given the glutted market for energy. Sam Engel, Director 3. Create a citizen’s oversight committee to participate in the planning Jerome Sander, Director Margi Simpkins, Director process for this expansion Taimni Relyea, Webmaster This will be a major project that involves issuing bonds costing $500 million plus interest. Will this be funded by increased rates? Ratepayers will not appreciate any increase related to an expansion that is not clearly justified.

Finally, the fact that the City owns GWP means we have a greater opportunity to be on the forefront of promoting alternative, sustainable energy.

Thank you for your consideration,

Sincerely,

Peter Fuad President Krause, Erik

From: Madison Spahr ([email protected]) Sent You a Personal Message Sent: Wednesday, January 31, 2018 8:00 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

This project would lock us into legacy technology that harms public health just at a time when the rest of the state is surging forward. I urge you to halt efforts to expand Grayson. and commission a study of clean energy alternatives.

Sincerely,

Madison Spahr 2961 Haddington Dr. Los Angeles, CA 90064 [email protected] (310) 490-7257

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. (3W January 29, 2018 AUMINIS1 RAILON

Vartan Gharpetian, Mayor 2016 JAN 30 AM IT~ II City of Glendale

613 Broadway Blvd - Glendale, CA 91206

Subject: Public Comments for the February 6, 20018 Public Hearing on the Proposed Grayson Energy Plant Expansion

Dear Mayor Gharpetian:

I oppose the proposed Grayson Energy Plant expansion. It is a bad idea. Glendale needs to establish a long term strategy based on renewable energy sources. The city will be required to meet state mandates to rely on 40% renewable sources in about 15 years. In addition there are numerous serious problems with the planning and environmental review process to~date.

The Project Description is wholly inadequate and does not meet CEQA standards.

The DEIR section related to land use and planning issues is, at best, incompetent, relies on a [993 City of Glendale General Plan. This plan is significantly out of date, The city is required to update it’s General Plan every 30 years. Thus, the DEIR’s analysis is based on a substantial level of information from the 1980s, and most likely some information developed in the late 1970s. Utilization of this document has no credibility.

Due to the long term, significant negative environmental impacts to the Public’s Health, it is essential that the DEIR create a Public Health Impact section. This should have been established under the CEQA Socio-Economic Impacts requirement.

There is a substantial sector of city residents who live in immediate proximity of this proposed action. They will suffer significant long term regressive public health impacts, which are not identified comprehensively in the DEIR. While some analysis is contained in the Mr Quality section, this analysis fails to fundamentally address regressive health impacts, in particular toe children and seniors who reside in direct proximity to the proposed project.

No city should abandon their own citizens in providing specific, relevant and current public health information, especially to those social sectors who will suffer the brunt of the long term, negative environmental impacts.

Since the proposed Grayson Energy Plant is the city’s only massive, energy generation resource, it inherently is linked with a series of current and future state policies demanding a transition to renewable energy source. The DEIR is wholly inadequate in addressing how the City of Glendale will meet current and long term state laws and policies, how this proposed project fails to address these state mandates, how the proposal most likely will impede the City’s ability to meed state requirements, and how a strategy based solely on natural gas will ever allow the City to meet renewable energy targets, either short t.eijn. or long tØEIt. This is among the most gl~tirg failures oldie DEIR.

The DEIR appears to assume that there are no minority groups in the City of Glendale. They blithely aba~idon the envirot~ent4j justice section of both CEQA and NEPA wghout any valid rationale. For instance, no one reviewing the data and information contained in the DEW would know if any minorities live in close proximity to the proposed action. The analysis needs to be revisited to address the long tent regressive environmental impacts on the socio-demqgraphic communities within a three mile radius of the proposed action. I would argue a five nile radius given the substantial long term environipental degcadation directly related to the operation oftius proposed energy facility identified in the document While the analysis, nanowly focuses on improvements, ilie reality of the proposed action remains fiind~mentaliy th~ same, long term, severe respiratory pollution to anyone living in proximity of the facility What the DEER fails to identi&, is the minority populace impacted by the proposed action.

IrG1~é tun~ èntal problem, in reality a contradiction, is the fact that both the compaiiy identified to buxltjHe proposed project is also }vlthin the corporate structure ofthe company developing the ~EJR~Thi~ is an Mh~rent conflict of interest.

It is puzzling why GWP and/or the city can!ot recognize this structi4al problem The city needs to retain an Environmental entity that has no direct or indirect corporate conuiection withthe finn company identified to built the proposed project. The independence ~d integrity of the.process is the minimsitiithteshold the city should fight for it’s residents.

These coth1ient~ are not inclusive of a sigi~ificAht leveL of problematic issues with the DEER. Conversely, they are indicative of the numerous inadequacies, non-existent analysis, extremely dated information from which key aspects of analysis are based on, and mi inadequate project description section. The City neçds to re-think it’s long tern energy strategy, substantially reduce any utilization of pollution driven generation sources, meet the future of California, renewable energy, aM in changing the contours ofihis proposal retain a]i environmental consultant firm that has no corporate connection to the entity OWl’ has identified to construct the proposed action in the future.

Respectiblly,

£4javiA~z’( th5 M.CR.P. City ax~d Regional lanning, UC Berkeley, 1976 Ph. 0. Urban Pl~4ding, UCLA, 1994 Director of Urban Studies, CSU Los Mgeles (retired) 1211 Scenic Dr Glepdale, CA 91205; Adams Hill

ccc: Steve Zurn, General jg[anager, GWP city council Krause, Erik

From: Jillana Laufer ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 9:49 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Jillana Laufer 3940 Laurel Canyon Blvd #804 Studio City, CA 91604 [email protected] (818) 261-0291

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: JOHN PASQUA ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 7:50 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

As a resident of Glendale and a GWP customer, I’m writing to voice my strong opposition to rebuilding and expanding the Grayson Power Plant. Rather than sinking S500 million into a polluting fossil fuel facility, I urge you to seize the opportunity to make Glendale a showcase for clean energy alternatives. The list of concerns with this project is long.

Sincerely,

JOHN PASQUA 8435 ESCONDIDO BLVD ESCONDIDO, CA 92025 kil lself515O(~va hoo .com (760) 484-3741

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Sheila Desmond ([email protected]) Sent You a Personal Message Sent Monday, January 29, 2018 7:10 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Sheila Desmond 3148 Piper Court Cameron Park, CA 95682 sheila [email protected] (530) 676-3426

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: harry knapp ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 6:30 PM To: Krause, Erik Subject: Graysori Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

harry knapp 2560 Colgate Way Riverside, CA 92507 H. KNAP P@C HARTER. N ET (951) 683-5056

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Gail McMullen ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 3:11 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

? Emissions of carbon monoxide, nitrogen dioxide, sulfur dioxide, small particulate matter and other pollutants will increase across the board. This will worsen already bad air quality in an area that houses two elementary schools (Mark Keppel and Franklin), the Disney Creative Campus and Disney Children’s Center, the residential neighborhoods of Pelanconi Estatesand Moorpark, and popularoutdoorspacessuch astheiohn FerraroAthletic Fieldsand Glendale Narrows Riverwalk.

Sincerely,

Gail McMullen 1734 N Kingsley Dr Apt 4 Los Angeles, CA 90027 [email protected] (323) 555-5555

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Karla Devine ([email protected]) Sent You a Personal Message Sent Monday, January 29, 2018 2:02 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Karla Devine 1406 11th St Manhattan Beach, CA 90266 [email protected] (310) 937-9722

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Robert Seltzer ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 1:27 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Robert Seltzer 18408 West Clifftop Way Malibu, CA 90265 rsscpa @ea rth 1k. net (310) 278-9944

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krau5e, Erik

From: Jill Davine [email protected]) Sent You a Personal Message Sent Monday, January 29, 2018 1:18 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Jill Davine 4047 La Salle Avenue Culver City, CA 90232

jsdavine~aol.com -. (310) 999-9999

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Ettie Councilman ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 12:54 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Ettie Councilman 3938 Mc Nab Ave Long Beach, CA 90808 [email protected] (562) 425-0000

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Donita Lowrey ([email protected]) Sent You a Personal Message Sent Monday, January 29, 2018 11:22 AM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Donita Lowrey 14451 Sayre ST Los Angeles, CA 90049 [email protected] (940) 594-1957

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Colleen Lobel ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 9:11 AM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

questions about its ability to maintain reliable service in an emergency. -

Sincerely,

Colleen Lobel 8111 Kenova St San Diego, CA 92126 [email protected] (858) 566-3033

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Chrissie Rappolt ([email protected]) Sent You a Personal Message Sent: Monday, January 29, 2018 7:40 AM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

This project would lock us into legacy technology that harms public health just at a time when the rest of the state is surging forward. I urge yoU to halt efforts to expand Grayson and commission a study of clean energy alternatives.

Sincerely,

Chrissie Rappolt 1915 smith Road Lodi, CA 90049 [email protected] (570) 222-4835

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

From: Animae Chi ([email protected]) Sent You a Personal Message Sent: Sunday, January 28, 2018 6:15 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

Sincerely,

Animae Chi 12022 Crest Cii Beverly Hills, CA 90210 wolfgangbear1~gmail.com (555) 555-5555

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. Krause, Erik

Frém: Daniella D. Lodge Sent Tuesday, November 21, 2017 7:02 AM To Krause, Erik, Gharpetian, Vartan, Devine, Paula, Agajanian, Vrej Sinanyan, Zareh, Najarian, Ara Subject: strong opposition to the Grayson repowering project as outlined in the September 2017 Draft BR

Dear Mr. Krause,

I am writing to express my strong opposition to the Grayson repowering project as outlined in the September 2017 Draft EIR.

I call on the City to pause the CEQA process and immediately commission an independent study of clean energy alternatives for powenng Glendale This study should be conducted by a group such as NREL or E3 with strong clean energy credentials and not by the consultants who have been working on the Grayson EIR.

Regards,

Daniella Lodge

Sent front thy iPhone Krause,_Erik

From: Jamie Barker ([email protected]) Sent You a Personal Message Sent: Wednesday, January 17, 2018 10:29 PM To: Krause, Erik Subject: Grayson Power Plant: Go Away

Dear Mr. Erik Krause,

When did the EPA stop working FOR the environment? As a resident of Glendale and a GWP customer, I’m writing to voice my strong opposition to rebuilding and expanding the Grayson Power Plant. Rather than sinking $500 million into a polluting fossil fuel facility, I urge you to seize the opportunity to make Glendale a showcase for clean energy alternatives. The list of concerns with this project is long.

7 Emissions of carbon monoxide, nitrogen dioxide, sulfur dioxide, small particulate matter and other pollutants will increase across the board. This will worsen already bad air quality in an area that houses two elementary schools (Mark Keppel and Franklin), the Disney Creative Campus and Disney Children’s Center, the residential neighborhoods of Pelanconi Estates and Moorpark, and popular outdoor spaces such as the John Ferraro Athletic Fields and Glendale Narrows Riverwalk.

Glendale doesn’t even need this much power. Your own reports forecast falling demand for electricity in Glendale. If demand is falling, why would we need to build é plant that increases generating capacity by 33% as this proposal does?

This project woUld lock us into legacy technology that harms public health just at a time when the rest of the state is surging forward. I urge you to halt efforts to expand Grayson and commission a study of clean energy alternatives.

Sincerely,

Jamie Barker 1746 N Los Robles Ave Pasadena, CA 91104 [email protected] (323) 423-2053

This message was sent by KnowWho, as a service provider only, on behalf of the individual noted in the sender information. [ñTáilto:sunrort~sidengo.com1 Sent: Saturday, December 30, 2017 11:57 AM To: DL GraysonRepowerProject

Subject: grasyonrepowering - Message from a visitor!

grasyonrepowering - You have a new message from a visitor!

Please reply to: [email protected]

Name: amelia

Email: [email protected]

Message: this is a terilble idea. PLEASE do not go ahead with this polluting waist of money. I am upset and will be ~

1 CAPITOL OFFICE COMMITTEES STATE CAPITOL BUDGET & FISCAL REVIEW SACRAMENmCA95BI4 Olaftfnruza $tat~ $euat2 SUBCOMMFI-rEE I ON TEL 19161 651-4025 CHAIR FAX 19161 6514925 BUDGET & FISCAL REVIEW GLENDALE DISTRICT OFFICE ANTHONY J. PORTANTI NO GOVERNMENTAL hOE. BROADWAY ORGANIZATION GLENDALE. CA 91205 SENATOR HUMAN SERVICES TEL ISIS) 4090400 TWENTY-FIFTH SENATE DISTRICT INSURANCE. BANKING & FAX 1818) 409-I 250 FINANCIAL INSTITUTIONS

PUBLIC EMPLOYMENT & SATELITE OFFICE RETIREMENT 203 EAST BONITA AVE. - SANDIMAS.CA9I773 4’ ~. ;. TEL 19091 599-7351 ~.( — SELECT COMMITTEES FAX 19091 599-7692 4 CALIFORNIA. ARMENIA - I &ARTSAKH MUTUAL SENATOR PORTANTINO~SENATE CA COy TRADE. ART & CULTURAL EXCHANGE CHAIR December 18, 2017

Glendale City Council 613 East Broadway Glendale, CA 91206

RE: Grayson Power Plant

Dear Mayor & City Council,

I write today regarding the Draft Environmental Impact Report for the Grayson Power Plant expansion. I have heard from a number of my constituents concerned about increased greenhouse gas and particulate emissions that will result from the proposed, expansion. I understand that Glendale has recently adopted a unanimous resolution in support of the United Nations’ Paris Agreement by joining the Mayors National Climate Action Agenda, agreeing to take local action on climate change. I also understand that councilmembers have been expressing reservations about moving forward with the Grayson expansion. I wish to associate myself with these concerns.

The DEll? is contrary to the visionary promise of the Paris Agreement. The proposed alternatives would increase emissions and particulates that would adversely affect our climate and impact the health of children at Benjamin Franklin Elementary, Mark Keppel Elementary, and the Disney Children’s Center, as well as elderly residents of nearby Pelanconi Estates. In fact, the DEIR predicts C02 emissions will increase nearly seven-fold, equivalent to 90,000 additional cars on Glendale’s roads.

As a longtime advocate for clean air and a healthy planet, I encourage Glendale to instead embrace the future and investigate clean energy alternatives. For instance, a multi-pronged renewables portfolio that relies on incentivizing solar capacity throughout the city, combined with increased battery storage and state- of-the-art demand-response methodologies, would meet California’s increasingly stringent emission requirements while addressing the city’s future power needs.

Glendale should also consider some of the legislative proposals on the horizon as it considers its options. Specifically, there are several bills working through the legislature that would increase the renewable portfolio standard by 60% by 2030 and set a standard of zero carbon electricity by 2045. This would force GWP to Page 2 of 2

mothball a new plant since the DEIR’s analysis assumes the proposed fossil-fuel- based equipment would have a 30-year lifespan. If SB 100, which passed the Senate and is currently in the Assembly, becomes law, the proposed Grayson lifespan would fall short by 25% and GWP would again have to pay to replace it.

Other points to consider:

• Financial analysis relies on GWP selling a large amount of excess power, but with a glut of gas-fired power in the marketplace today they may very well have to sell below cost to get rid of excess power. • Investor-owned utilities (bUs) like nearby Edison have shown they are reluctant to enter into long-term purchase power agreements involving fossil fuels. Also, the future cost of carbon under the cap-and-trade program will impact the cost of carbon credits. • Grayson sits on a known earthquake liquefaction zone, subject to major gas line leaks and ruptures in the event of an earthquake greater than magnitude 7.0. This belies GWP’s rationale that centralizing power at Grayson is needed to maintain energy security in the event of a major incident such as an earthquake. A robust and varied renewables portfolio would mitigate this risk. • Incentivizing solar throughout the city, residential or otherwise, will reduce emissions whether or not GWP would get the associated carbon credits. • Glendale has not exploited demand-response methodologies to shift use from high-demand times, such as time of use pricing and HVAC direct load control programs. • The consultants GWP has relied on are fossil fuel technologists, not entities with strong clean energy credentials.

And, finally, with a week of unusually late December fires including the Thomas Fire, on course to become California’s largest-ever wildfire, we have an ever- increasing mountain of evidence that we must take climate change seriously and do everything in our power to mitigate its impacts. I therefore respectfully urge the city council to continue its leadership on climate and environmental protection policy and call for the study of new, clean energy alternatives.

Respectfully,

Hon. Anthony J. Portantino Senator, 25th District Godinez, Christine

From: Elisa Cohen Sent: Tuesday, November21, 2017 8:56 AM To: Gharpetian, Vartan; Devine, Paula; Agajanian, Vrej; Sinanyan, Zareh; Najarian, Ara Subject: Stop Grayson Expansion

Dear Glendale City Council,

I am writing to express my strong opposition to the Grayson repowering project as outlined in the September 2017 Draft EIR.

I feel it is unconscionable to jeopardize the health of residents in the area, and further destroy the planet by increasing the levels of dangerous emissions from this plant.

I call on the City to pause the CEQA process and immediately commission an independent study of clean energy alternatives for powering Glendale. This study should be conducted by a group such as NREL or S with strong clean energy credentials and not by the consultants who have been working on the Grayson EIR.

Regards,

Elisa Cohen Los Feliz, Los Angeles 90027

Sent from my iPhone

1 Fi~ni Mig ~9igdia chinea@gmail corn> .Tu&a~yJ~overnbet 21, 2017 7:18 PM To Pápaz~pp, Eliza Cc assernblymember friedman@assembly ca gov, ayochelson@da lacounty gov Subject: Re~ ~?6pd≤Ed Grayson Repowering Project

Dear M.r;Gharpetian and Ms. Papazian. Thanks so much for you for your response

I was aghast to read that the city of Glendale would even consider a project — the proposed Grayson Repowering Plant

— that would pollute our air, putting us and our children at risk — making this an undesirable city for anyone to live in.

Already, W&P hikes are unsustainable by people who— like me -I struggle to maintain our homes. I believe that with a complete lack of logic, the Glendale City Council wants to practice apartheid Glendale citizens v the city of Glendale government. It wants to push us out. It is unresponsive to discrimination in our community college. Further, It is endangering our streets with rampant constrUctIon and traffic.

Sincerely.

Sent from Migdia’s iPhone, plus Cato the Younger and Tullia-Zoe - great Roman Statepups. Migdia Chinea

On Nov 21, 2017, at 5:08 PM, Papazian, Eliza wrote:

Good Afternoon,

On behalf of Mayor Charpetian and the Glendale City Council, thank you for your ernail regarding the proposed Grayson Repow~ring Project. This email is to acknowledge receipt of your comments. To give you an idea of the next steps for this proposed project, please allow me to provide some information.

As you are aware, the comment period for the Draft Environmental lmpaqtReport (was extended to and) closed at 5pm yesterday, November 20, 2017. The City will be evaluating all of the comments, concerns, and suggestions received, and will be incorporating and addressing them in the Final EIR Ultimately, the Final EIR will be presented to the City Council for consideration and certification at a public hearing in early 2018.

To learn more about the Grayson Repowering Project, please click here. You can also find additional information by visiting myglendalecitynews.org. If you would lilçe to receive future updates about the proposed Grayson Repowering Project, please reply to this email indicating so, and we will add you to our outreach list.

Thank you again for your comment and for being engaged in the process.

Regards,

Eliza Papcizian I City of Glendale I Management Services 613 East Broadway, Suite 200 I Glendale, CA 91206 11818) 548-4844 I #papaz~an(~alendapeya pay

From: Daniella D. Lodge Sent: Tuesday, November21, 20177:02 AM To: Krause, Erik; Sharpetian, Vartan; Devine, Paula; Agajanian, Vrej; Sinanyan, Zareh; Najarian, Ara Subject: strong opposition to the Grayson repowering project as outlined in the September 2017 Draft EIIR

Dear Mr. Krause,

I am writing to express my strong opposition to the Grayson repowering project as outlined in the September 2017 Draft FIR.

I call on the City to pause the CEQA process and immediately commission an independent study of clean energy alternatives for powering Glendale. This study should be conducted by a group such as NREL or E3 with strong clean energy credentials and not by the consultants who have been working on the Grayson ER.

Regards,

Daniella Lodge

Sent from my iPhone

1 Godinez, Christine

From: Anna Hovhannisyan Sent: Tuesday, November 21, 2017 12:43 AM To: Gharpetian, Vartan; Devine, Paula; Agajanian, Vrej; Sinanyan, Zareh; Najarian, Ara Subject: Stop Grayson Expansion

Importance: High

Dear Glendale City Council,

I am writing to express my strong opposition to the Grayson repowering project as outlined in the September 2017 Draft FIR.

Our family is very concerned about the project and is very disappointed that no one really cares about the people who live in the area.

I call on the City to pause the CEQA process and immediately commission an independent study of clean energy alternatives for powering Glendale. This study should be conducted by a group such as NREL or E3 with strong clean energy credentials and not by the consultants who have been working on the Grayson EIR.

Regards,

Anna H Glendale, CA