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HomeMy WebLinkAbout#15 WAPPA AGENDA ITEM #15 Public Utility District m MEETING DATE: October 2, 2024 TO: Board of Directors FROM: Jared Carpenter, Electric Utility Director SUBJECT: Consideration of Amendment #1 to the Contract with Western Area Power Administration for Delivery of Renewable Energy from the Stampede Hydroelectric Power Plant. APPROVED BY: Brian C. Wright, General Manager RECOMMENDATION: Approve and authorize the Board President to sign Amendment #1 to Contract 07-SNR- 01026, with Western Area Power Administration for the Purchase of Base Resource Power from the Stampede Power Plant at a Price Set to the Applicable Monthly Locational Marginal Price in the Heavy Load Hours, and Light Load Hours, through December 31, 2044. BACKGROUND: Truckee Donner Public Utility District (TDPUD), City of Fallon (Fallon) and Western Area Power Administration (WAPA) are parties to the Stampede Energy Exchange Account (SEEA) Agreement, WAPA Contract 07-SNR-01026. The TDPUD Board approved the existing SEEA agreement with WAPA on April 4, 2007, and it expires on December 31, 2024. The SEEA Agreement provides for TDPUD and Fallon to take the Stampede generation and pay directly into the SEEA for the generation. TDPUD manages the SEEA and pays the utility bills of the project use facilities associated with the Stampede Power Plant with funds from the SEEA. With Board approval, the parties have agreed to extend the term of the SEEA Agreement through December 31, 2044, and the extension is documented in Attachment 1, including a revision to the methodology to determine the value calculation (Exhibit A), along with an Example of Stampede Energy Exchange Account Monthly Transactions (Exhibit B), and updating the mailing and contact information (Exhibit C). In 1933 the California Legislature first authorized the Central Valley Project (CVP) as a State water project but was unable to finance the project at the time. The Rivers and Harbors Act of 1935 re-authorized the CVP as a Federal project and defined its purposes to improve navigation and flood control, to supply water for irrigation and domestic uses, and to generate power. Today the CVP is owned and operated by the Bureau of Reclamation (BOR), a Federal agency under the United States Department of Interior. The CVP covers approximately 400 miles in California, from Redding to Page 1 of 5 Page 170 of 231 Bakersfield, and draws from two large river basins: the Sacramento and the San Joaquin. It is composed of 20 dams and reservoirs and many miles of water storage and conveyance infrastructure. In an average year, the CVP delivers more than 7 million acre-feet of water to support irrigated agriculture, municipalities, and fish and wildlife needs, among other purposes. About 75% of CVP water is used for agricultural irrigation, including 7 of California's top 10 agricultural counties. The CVP is operated jointly with the State Water Project (SWP), which provides much of its water to municipal users in Southern California. When Congress enacted the Central Valley Project Improvement Act (CVPIA) in 1992, the 1935 Act was amended to add fish and wildlife mitigation, and other environmental enhancements, as authorized CVP purposes. The CVP has 11 hydroelectric generation facilities with 2,100 megawatts (MW) of installed capacity producing on average, over the historical record, 4,600,000 megawatt-hours (MWh) of generation annually. CVP generation is first used to operate the project, including water pumping and deliveries, which consumes roughly 23 percent of total CVP generation. The Western Area Power Administration (WAPA), a Power Marketing Administration under the United States Department of Energy, markets the remaining wholesale generation, termed Base Resource energy, to entities such as State and local governments, municipalities, public agencies and cooperatives. TDPUD, along with all other Northern California Power Agency (NCPA) members, are Base Resource power customers. WAPA also collects funds from Base Resource power customers to meet allocated revenue requirements pursuant to CVPIA environmental mitigation measures on behalf of the BOR. Base Resource generation from the CVP is mostly classified as large hydroelectric (greater than 30 MW) and therefore does not meet the California definition of renewable. However, this energy is emissions-free and is considered a carbon-free resource under California regulations. Under SB 100, TDPUD is required to procure 60% of our energy from renewable resources by 2030, and the remaining 40% from carbon-free resources by 2045. Base Resource generation, with its carbon-free attributes, can help TDPUD to achieve the State's clean energy requirements for energy procurement. Another important attribute of CVP generation is that it is shaped to load, unlike other hydroelectric generation. This means that the BOR maximizes energy production so that energy is predominately available during peak demand hours from late afternoon through early evening. This attribute enhances the value of this hydroelectric resource to TDPUD. Contractually, the term Base Resource technically includes the CVP and also the Washoe Project. The Washoe Project is better known locally as the Stampede Dam and Power Plant (Stampede). TDPUD, along with the City of Fallon, Nevada are under a separate contract with WAPA to receive 100% of Stampede energy generation. It is important to note that TDPUD has the right to receive Stampede generation, subject to a separate contract, by virtue of the fact that TDPUD is an existing Base Resource customer. The TDPUD Board approved the existing 20-year Base Resource contract with WAPA for CVP generation by Resolution 2000-20 on October 18, 2000, with a start date of Page 2 of 5 Page 171 of 231 January 1, 2005. TDPUD's allocation is 0.2210 percent of total Base Resource generation. TDPUD did not directly receive energy, but assigned our Base Resource percentage to NCPA, who was also performing power scheduling services for TDPUD. The Base Resource energy was sold through the NCPA power pool. The proceeds were used to purchase energy from Utah Associated Municipal Power Systems (UAMPS) for delivery to TDPUD. This arrangement lasted until July 1, 2014, when all power scheduling services were transferred by TDPUD from NCPA to UAMPS. On June 4, 2014, the Board terminated the agreement that assigned the Base Resource to NCPA and approved a new agreement to transfer the Base Resource to Plumas Sierra Rural Electric Cooperative (Plumas). At the time, Base Resource costs were rapidly increasing and reached peaks in 2015 and 2016. Essentially, this new agreement with Plumas transferred our obligation to receive and pay for Base Resource energy as prices rapidly increased, but also allowed TDPUD to legally remain a Base Resource customer. TDPUD's existing Base Resource contract with WAPA was set to expire on December 31, 2024, but was extended by the Board under a new contract beginning January 1, 2025, and ending December 31, 2054. However, while the Stampede Power Plant is part of the CVP, it has a separate pricing structure due to its allocation of power being assigned to Truckee and Fallon due to its relationship with the Truckee River Operating Agreement (TROA). All CVP generators cost for power is primarily dependent on the amount of energy generated, and setting the value of that output is important for both the seller (WAPA) and the buyers (TDPUD and Fallon). When TDPUD extended the CVP contract with Board authorization, it was explained that WAPA, TDPUD, and Fallon were going to negotiate for new terms, especially the value of the energy, at a later date but before 2025. The single most important factor driving the amount of CVP hydropower generation is hydrology (annual weather, including snowfall and other precipitation) and is highly variable year-to-year. The timing and availability of Base Resource generation is also subject to CVP operational limitations and scheduling constraints, and climate change. In 2015, the driest year on record, Base Resource generation was at its lowest point, 1,732,000 MWh, since the start of the existing Base Resource contract in 2005. In 2017, one of the wettest years on record, Base Resource generation rebounded to a total of 4,157,000 MWh. Since 2005, the 15-year Base Resource annual average generation is about 3,000,000 MWh. The CVP Base Resource is a take-or-pay resource contract. In essence, take-or-pay contracts guarantee the seller (WAPA) a minimum payment whether the buyer (Base Resource customers, including TDPUD) takes delivery of the CVP generation. In general terms, take-or-pay contracts benefit sellers by reducing the risk of losing money on any capital improvements made to produce generation. They also benefit buyers by obtaining energy at lower prices, as they are taking on some of the seller's risk. Base Resource customers repay Federal government CVP power-related construction costs (with interest), annual operation and maintenance costs, and other costs such as transmission. Construction repayment obligations include BOR's power plants, a share of multipurpose dam and reservoir costs, WAPA's transmission infrastructure and switch yard costs, and both agencies' annual power operating costs, including labor, Page 3 of 5 Page 172 of 231 maintenance, and overhead. In addition to CVP power costs, Base Resource customers also pay a mitigation and restoration environmental fund surcharge (Restoration Fund) under the Central Valley Project Improvement Act of 1992 or CVPIA. CVP power customers' share of annual CVPIA Restoration Fund contributions should match the share of CVP capital costs assigned to power customers, which is less than 30% of the total. However, in the case of Stampede, there is no additional base costs. TDPUD and Fallon will just pay for the energy received from Stampede. Most purchase power contracts offer a fixed cost-per-unit ($ per MWh) price and quantity of generation. Predicting the future energy rate for the new Base Resource contract is challenging, because both CVP costs and energy production are highly variable. The methodology behind this amendment is to set the value of the nearest Locational Marginal Price to the Stampede power plant. For reference, TDPUD does not receive its allocation of Base Resource energy from the CVP except for the source from Stampede. The non-Stampede resources from WAPA are transferred to a different electric utility. Historically, the reason for not accepting that allocation was because while the cost of energy was competitive, the additional transmission fees made it more expensive. Today, that is not the case and Staff is investigating if and how much power TDPUD might accept from the WAPA CVP's in the future. While Stampede is a CVP project, it has a different pricing and delivery structure unique to TDPUD compared to other California publicly owned utilities due to TDPUD and Fallon being the only buyers of the energy. Staff is recommending that the TDPUD continue accepting power from Stampede through acceptance of the changes represented in Exhibits A, B, and C in Attachment 1. ANALYSIS AND BODY: Over the past few years, hydroelectric power has been operating effectively due to California having average to high rain and snow accumulation years as seen in the levels of the reservoirs across the state. In 2021 a historical analysis was performed by NCPA that yielded an average cost of about $30 per MWh over a 15-year period for Base Resource energy, compared to an average market price of about $40 per MWh for that same time period. Total transmission wheeling costs are about $30 per MWh. Therefore, the total energy cost to TDPUD for Base Resource generation including transmission costs was about $60 per MWh if TDPUD were to take delivery of it. Over the past few years, TDPUD's average annual purchase power portfolio cost, including transmission charges, has ranged from $65 MWh to $75 MWh, which includes the transmission fees from NV Energy. With this information in mind, the cost of CVP is more viable than previous years. However, Stampede as a CVP project is different because it is uniquely assigned to TDPUD and Fallon, and is a small hydroelectric power plant that is therefore classified as renewable energy. For TDPUD to receive Stampede, the transmission costs only need to utilize the NV Energy system that costs about $7 per MWH. The current contract is for non-firm energy, valued at approximately 75 percent of the firm energy. Page 4 of 5 Page 173 of 231 The firm energy value is determined using the average of the current and previous years month's Mid-C price index as determined by the Intercontinental Exchange. In 2023, TDPUD paid $14.068M for 166,385 MWH of energy, including $471 k for 10,081 MWHs from Stampede. For reference, this is about $47 per MWH. The 2024 total budget for purchase power is $14.764M, including 9,770 MWHs of energy from Stampede at a budget of$469K, which represents $48 per MWH. Staff and WAPA decided the best way to mitigate risk for all parties was to use the Stampede Locational Marginal Price in the Heavy Load Hours and Light Load Hours instead of the Mid-C location. The table below shows the results of the pricing in the Heavy Load Hours (HLH) and Light Load Hours (LLH) since 2020. 2022 was an abnormal year due to many factors that created the most unstable pricing in many years. 2023 turned out to be a more stable year with more expected results. 2020 2021 2022 2023 Nodes HLH LLH HLH LLH HLH LLH HLH LLH Truckee $34.43 $26.55 $42.63 $38.08 $73.87 $75.76 $51.50 $51.72 Stampede$34.46 $26.38 $43.01 $38.30 $73.87 $75.76 $51.92 $51.92 Glenshire $34.63 $26.48 $42.56 $37.96 $73.39 $75.45 $51.78 $52.05 Average $34.51 $26.47 $42.73 $38.11 $73.71 $75.66 $51.73 $51.90 GOALS AND OBJECTIVES: District Code 1 .05.020 Objectives: 5. Manage the District in an environmentally sound manner. 6. Manage the District in an effective, efficient and fiscally responsible manner. District Code 1 .05.030 Goals: 1. Manage for Financial Stability and Resiliency FISCAL IMPACT: The 2024 total budget for Purchase Power is $14.764M, including 9,770 MWHs of energy from Stampede at a budget of $469K. This Value Calculation change in Exhibit A, as part of Amendment 1 is expected to result in a budget increase of $39k in 2025, which represents a 0.26% increase within the Power Purchase budget. ATTACHMENTS: 1. Stampede Amendement 1 Page 5 of 5 Page 174 of 231 Contract 07-SNR-01026 UNITED STATES DEPARTMENT OF ENERGY WESTERN AREA POWER ADMINISTRATION CENTRAL VALLEY PROJECT, CALIFORNIA AMENDMENT 1 (Term Extension; Value Calculation) TO CONTRACT FOR ENERGY EXCHANGE SERVICES WITH THE TRUCKEE DONNER PUBLIC UTILITY DISTRICT AND THE CITY OF FALLON i Page 175 of 231 Contract 07-SNR-01026 UNITED STATES DEPARTMENT OF ENERGY WESTERN AREA POWER ADMINISTRATION CENTRAL VALLEY PROJECT, CALIFORNIA AMENDMENT 1 (Term Extension; Value Calculation) TO CONTRACT FOR ENERGY EXCHANGE SERVICES WITH THE TRUCKEE DONNER PUBLIC UTILITY DISTRICT AND THE CTY OF FALLON Section Table of Contents Page 1. Preamble................................................................................................................. 1 2. Explanatory Recitals ............................................................................................... 1 3. Agreement............................................................................................................... 2 4. Term of Amendment ............................................................................................... 2 5. Modification to Section 4 (Effective Date, Term, and Termination of Contract) ofthe Contract...................................................................................................... 3 6. Modification to Section 10 (Value Calculation) of the Contract ............................... 3 7. Execution by Counterparts...................................................................................... 3 8. Electronic Signatures .............................................................................................. 4 ii Page 176 of 231 1 Contract 07-SNR-01026 2 3 UNITED STATES DEPARTMENT OF ENERGY 4 WESTERN AREA POWER ADMINISTRATION 5 CENTRAL VALLEY PROJECT, CALIFORNIA 6 AMENDMENT1 7 (Term Extension; Value Calculation) TO 8 CONTRACT 9 FOR 10 ENERGY EXCHANGE SERVICES WITH 11 THE TRUCKEE DONNER PUBLIC UTILITY DISTRICT 12 AND 13 THE CITY OF FALLON 14 15 1. PREAMBLE: 16 This Amendment 1 (Amendment) to Contract 07-SNR-01026 (Contract) is made this 17 between the UNITED STATES OF AMERICA, DEPARTMENT OF 18 ENERGY, WESTERN AREA POWER ADMINISTRATION (WAPA) and the TRUCKEE 19 DONNER PUBLIC UTILITY DISTRICT, a Public Utility District, organized and existing 20 under the laws of the State of California, hereinafter referred to as Truckee; and the 21 CITY OF FALLON, a political subdivision organized and existing under the laws of the 22 State of Nevada, hereinafter referred to as Fallon; jointly referred to as TDF, their 23 successors and assigns; all also hereinafter referred to individually as Party and 24 together as Parties. 25 26 2. EXPLANATORY RECITALS: 27 2.1. The United States owns, and the U.S. Department of the Interior, Bureau 28 of Reclamation (Reclamation) operates, the Stampede Powerplant (Stampede) Amendment 1 to Contract 07-SNR-01026 1 Page 177 of 231 1 located in Sierra County, California. Stampede has an installed capacity of 2 3.65 megawatts, with an average annual energy generation of approximately 3 11,000 megawatthours. 4 5 2.2. Truckee and Fallon have Network Integration Transmission Service 6 Agreements (NITS) with SPPC and, therefore, can receive the Stampede 7 Energy. 8 9 2.3. WAPA and TDF entered into the Contract on May 10, 2007. The Contract 10 provides for TDF to take the generation available from Stampede into its system 11 and, through an energy exchange account, serve two U.S. Department of the 12 Interior, Department of Fish and Wildlife Service project use loads located within 13 its service territory. 14 15 2.4. The Contract is scheduled to terminate on December 31, 2024. The 16 Parties desire to extend the term through December 31, 2044. 17 18 2.5. The Parties agree the Value Calculation in Exhibit A should be updated to 19 accurately value the Stampede generation and are doing so in this Amendment. 20 21 3. AGREEMENT: 22 The Parties agree to the terms and conditions set forth herein. 23 24 4. TERM OF AMENDMENT: 25 This Amendment shall become effective upon execution and shall remain in effect 26 concurrently with the Contract. 27 28 Amendment 1 to Contract 07-SNR-01026 2 Page 178 of 231 1 5. MODIFICATION OF SECTION 4 (EFFECTIVE DATE, TERM AND 2 TERMINATION OF CONTRACT) OF THE CONTRACT: 3 Section 4.1 of the Contract is hereby modified as follows: 4 4. EFFECTIVE DATE, TERM, AND TERMINATION OF CONTRACT: 5 4.1 This Contract will become effective on the first day of the first 6 month following the termination of Contract 00010 with SPPC and shall 7 remain in effect through December 31, 2044; subject to prior termination 8 as otherwise provided for herein. 9 10 6. MODIFICATION OF SECTION 10 (VALUE CALCULATION) OF THE 11 CONTRACT: 12 Section 10 of the Contract is hereby modified as follows: 13 10. VALUE CALCULATION: 14 The calculation to be used in determining the value of Stampede Energy is provided 15 in Exhibit A attached hereto. 16 17 7. EXECUTION BY COUNTERPARTS: 18 This Amendment may be executed in any number of counterparts and, upon execution 19 and delivery by each Party, the executed and delivered counterparts together shall have 20 the same force and effect as an original instrument as if all Parties had signed the same 21 instrument. Any signature page of this Amendment may be detached by any 22 counterpart of this Amendment without impairing the legal effect of any signatures 23 thereon and may be attached to another counterpart of this Amendment identical in 24 form hereto, by having attached to it one or more signature pages. 25 26 27 28 Amendment 1 to Contract 07-SNR-01026 3 Page 179 of 231 1 8. ELECTRONIC SIGNATURES: 2 The Parties agree that this Amendment may be executed by handwritten signature or 3 digitally signed using Adobe E-Sign or DocuSign. An electronic or digital signature is 4 the same as a handwritten signature and shall be considered valid and acceptable. 5 6 IN WITNESS WHEREOF, the Parties have caused this Contract to be executed 7 the day and year first above written. 8 9 WESTERN AREA POWER ADMINISTRATION 10 11 By: 12 Name: Arun K. Sethi Title: Power Marketing Manager 13 Address: 114 Parkshore Drive 14 Folsom, CA 95630-4710 15 16 TRUCKEE DONNER PUBLIC UTILITY DISTRICT 17 18 Attest: By: 19 Name: Jeff Bender 20 Title: Board President By: Address: Post Office Box 309 21 Title: Truckee, California 96160 22 23 CITY OF FALLON 24 25 26 Attest: By: Name: Ken Tedford, Jr. 27 Title: Mayor By: Address: 55 West Williams Avenue 28 Title: Fallon, Nevada 89406 Amendment 1 to Contract 07-SNR-01026 4 Page 180 of 231 THE TRUCKEE DONNER PUBLIC UTILITY DISTRICT AND THE CITY OF FALLON CERTIFICATE Page 181 of 231 Page 182 of 231 Truckee Donner Public Utility District City of Fallon Exhibit A, Revision 1 to Contract 07-SNR-01026 EXHIBIT A (Value Calculation) 1. This Exhibit A, Revision 1 to be effective under and as a part of Contract 07-SNR-01026, shall become effective upon execution of Amendment 1; and shall remain in effect until either superseded by another Exhibit A or termination of the Contract. 2. The value of Stampede Energy shall be determined using the current month's average On-Peak and Off-Peak Stampede Generation LMP price, obtained from CAISO OASIS. Any negative LMP price shall be replaced with a zero value to avoid negative monthly average pricing. This shall be calculated and updated monthly using the most recent published indices in the following calculation: Calculation (The average of the current month's Stampede Generation CAISO LMP On-Peak index price * the current month's total On-Peak Stampede Energy) = Month's On-Peak value of Stampede Energy (The average of the current month's Stampede Generation CAISO LMP Off-Peak index price * the month's total Off-Peak Stampede Energy) = Month's Off-Peak value of Stampede Energy TRUCKEE DONNER PUBLIC UTILITY DISTRICT By: Name: Jeff Bender Title: Board President Address: Post Office Box 309 Truckee, California 96160 CITY OF FALLON By: Name: Ken Tedford, Jr. Title: Mayor Address: 55 West Williams Avenue Fallon, Nevada 89406 1 Page 183 of 231 Truckee Donner Public Utility District City of Fallon Exhibit A, Revision 1 to Contract 07-SNR-01026 WESTERN AREA POWER ADMINISTRATION By: Name: Arun K. Sethi Title: Power Marketing Manager Address: 114 Parkshore Drive Folsom, CA 95630-4710 2 Page 184 of 231 Truckee Donner Public Utility District City of Fallon Exhibit B, Revision 1 to Contract 07-SNR-01026 EXHIBIT B (Example of Stampede Energy Exchange Account Monthly Transactions) 1. This Exhibit B, Revision 1 to be effective under and as a part of Contract 07-SNR-01026, shall become effective upon execution of Amendment 1; and shall remain in effect until either superseded by another Exhibit B or termination of the Contract. 2. Example First Month of Contract: Example Transaction Credit Debit Balance $ 0.00 January 2025 On-Peak Generation = 300 MWh Current years' January average On- Peak Price = $96 Off-Peak Generation = 200 MWh Current years' January average Off- Peak Price = $96 $ 48,00000 300*$96+ 200*$96 $ 48,000.00 Reclamation's Power Bill from SPPC $ 21.17 $ 47,978.83 FWS' Power Bill from SPPC $ 25,553.94 $ 22,424.89 Administration Fee $ 250.00 $ 22,174.89 TRUCKEE DONNER PUBLIC UTILITY DISTRICT By: Name: Jeff Bender Title: Board President Address: Post Office Box 309 Truckee, California 96160 1 Page 185 of 231 Truckee Donner Public Utility District City of Fallon Exhibit B, Revision 1 to Contract 07-SNR-01026 CITY OF FALLON By: Name: Ken Tedford, Jr. Title: Mayor Address: 55 West Williams Avenue Fallon, Nevada 89406 WESTERN AREA POWER ADMINISTRATION By: Name: Arun K. Sethi Title: Power Marketing Manager Address: 114 Parkshore Drive Folsom, CA 95630-4710 2 Page 186 of 231 Truckee Donner Public Utility District City of Fallon Exhibit C, Revision 1 to Contract 07-SNR-01026 EXHIBIT C (Mailing Addresses) 1. This Exhibit C, Revision 1 is to be effective under and as a part of Contract 07-SNR-01026, shall become effective upon execution of the Contract; and shall remain in effect until either superseded by another Exhibit C or termination of the Contract. 2. The following Mailing Addresses are to be used for any notices and/or payments as provided for in the Contract: Western Area Power Administration - Notices Rates Manager Western Area Power Administration Sierra Nevada Region 114 Parkshore Drive Folsom, California 95630 wolfe(a).wapa.gov Western Area Power Administration — Payments U.S. Department of Energy Western Area Power Administration File No. 4185 Post Office Box 894185 Los Angeles, California 90189-4185 Bureau of Reclamation Mr. Scott Schoenfeld Manager of O&M Division Lahontan Basin Area Office 705 North Plaza Street, Room 320 Carson City, NV 89701 Office: (775)-884-8351 Cell: (775) 430-3080 sschoenfeld(E�usbr.gov 1 Page 187 of 231 Truckee Donner Public Utility District City of Fallon Exhibit C, Revision 1 to Contract 07-SNR-01026 Fish & Wildlife Service Ms. Lisa Heki Fisheries Manager U.S. Department of the Interior Fish and Wildlife Service 1340 Financial Blvd., Suite 234 Reno, Nevada 89502 Truckee Donner Public Utility District Mr. Jared Carpenter Electric Utility Director Truckee Donner Public Utility District 11570 Donner Pass Road Post Office Box 309 Truckee, California 96160 0aredcarpenter(a-)_tdpud.org City of Fallon Mr. Sean Rowe Deputy City Attorney City of Fallon 55 West Williams Avenue Fallon, Nevada 89406 srowe falIonnevada.gov TRUCKEE DONNER PUBLIC UTILITY DISTRICT By: Name: Jeff Bender Title: Board President Address: Post Office Box 309 Truckee, California 96160 2 Page 188 of 231 Truckee Donner Public Utility District City of Fallon Exhibit C, Revision 1 to Contract 07-SNR-01026 CITY OF FALLON By: Name: Ken Tedford, Jr. Title: Mayor Address: 55 West Williams Avenue Fallon, Nevada 89406 WESTERN AREA POWER ADMINISTRATION By: Name: Arun K. Sethi Title: Power Marketing Manager Address: 114 Parkshore Drive Folsom, CA 95630-4710 3 Page 189 of 231