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HomeMy WebLinkAbout2004-03-01 City Council (15)City of Palo Alto City Manager’s Rf .r I TO:HONORABLE CITY COUNCIL FROM:CITY MANAGER DEPARTMENT: UTILITIES DATE:MARCH 1, 2004 CMR:159:04 SUBJECT:ADOPTION OF A RESOLUTION AUTHORIZING THE CITY MANAGER TO EXECUTE A LETTER OF AGREEMENT FOR THE OPTION TO PURCHASE EXCESS CAPACITY FROM THE WESTERN AREA POWER ADMINISTRATION RECOMMENDATION Staff recommends Council adopt the attached resolution authorizing the City Manager to execute the attached Letter of Agreement with the Western Area Power Administration for the option to purchase excess capacity electric power that becomes available during the period of April 1, 2004 through December 31, 2004. BACKGROUND City of Palo Alto Utilities’ existing Western Commercial Firm Power contract is an important asset that allows for significant flexibility to cover electricity loads at cost- based prices. Over the years, CPAU and Western have developed several ancillary agreements to harvest extra value created by long-term relationships. These include a Letter of Agreement (LOA) that makes excess capacity electric power (WEC) available to customers such as CPAU. The current WEC LOA expires on March 31, 2004. This CMR requests Council approval of a nearly identical replacement WEC LOA. Council approved last year’s WEC LOA in CMR 179:03 on March 17, 2003. Palo Alto participated in the 2003 WEC to spend about $1.4 million for energy that saved about $2.7 million thereby producing a net savings of about $1.3 million. CMR:159:04 Page 1 of 4 WEC is an energy product that Western markets if the Central Valley Project is producing more energy than Western is obligated to provide under existing contracts. WEC power is typically priced at about 2 cents per kilowatt-hour (kWh). By purchasing it, CPAU can substitute it for higher cost resources in its energy portfolio that can range from 3 to 10 cents per kWh. This produces a savings for CPAU and helps maintain low retail rates. The volume of WEC available to CPAU is highly variable and depends on the water operations and the generator operating conditions of the Central Valley Project, and on the loads of CPAU and Northern California Power Agency (NCPA). Neither CPAU’s participation in, nor the existence of the WEC marketing program affect the physical operation of the Central Valley Project with respect to river releases. DISCUSSION Staff is requesting that Council adopt a resolution authorizing the City Manager to execute an LOA with the Western Area Power Administration for WEC purchases with a cost not to exceed $5,000,000. On February 24, 2004, Western provided signed WEC contracts for customers to execute for the April 1, 2004 - December 31, 2004 time period. WEC power will likely be available and economically attractive on about April 10, 2004. The attached WEC agreement is nearly identical to the four prior annual WEC contracts. Western offers signed standardized WEC contracts to participants and does not allow negotiation for customization. There is very low risk in executing transactions under the agreement, because the City is not obligated to accept the energy when it is offered by Western. NCPA will continue to use alternative resources if its cost (market price) is lower than the cost of WEC (2 cents). The market price would have to unexpectedly fall below 2 cents per kwh within one day in order to realize a loss. This would have to happen more than 90% of the time for net savings not to be realized. RESOURCE IMPACT Net savings to CPAU from its participation in the WEC program are estimated at about $1,000,000 for the term of the agreement and could range between $0 and $5 million. Net savings depend on many variables including: ¯a) Hydrology CMR: 159:04 Page 2 of 4 b) United States Bureau of Reclamation’s maintenance of generators c) The difference between market prices and the WEC price Entering into the agreement has no fixed cost. Exercising the agreement costs about 2 to 2.7 cents per kWh. NCPA, on Palo Alto’s behalf, will exercise the agreement as often as possible when the gross savings from that exercise exceed 2 cents/kWh. POLICY IMPLICATIONS The proposed agreement complies with, and is subject to, continuing adherence to the CPAU’s Energy Risk Management Policies, Guidelines, and Procedures. This recommendation also supports the second of the City’s Energy Risk Management Objectives listed in the Council-approved Energy Risk Management Policies [CMR 400:02], "Preserve a Supply Cost Advantage", whereby "Wholesale transactions are effected to maximize the value of assets for the benefit of CPAU’s retail customers. CPAU will take actions to: .... (b) enhance revenue by taking advantage of flexibility inherent in CPAU contracts and resources..." Furthermore, all daily transactions undertaken by NCPA to manage this agreement are subject to NCPA’s own internal risk management policies and procedures and are overseen by the NCPA Commission and its own Risk Oversight Committee. It is also consistent with the Council-approved Utilities Strategic Plan [CMR 418:00 and 432:02] Strategy 2: Preserve a supply cost advantage compared to the market price; and Strategy 3: Streamline and manage business process to allow the City of Palo Alto Utilities to work efficiently and cost-effectively. ENVIRONMENTAL REVIEW Execution of the WEC purchase agreement does not constitute a project for the purposes of the California Environmental Quality act. CMR:159:04 Page 3 of 4 ATTACHMENTS A: Resolution authorizing the City Manager to execute the attached WEC Letter of Agreement B: Western WEC Letter of Agreement 04-SNR-00647 April 1, 2004- December 31, 2004 C: Form 410: Certification of Nondiscrimination PREPARED BY: DEPARTMENT HEAD: CITY MANAGER APPROVAL: TOI~I" KABAT ~ L3/ Senior Resource Originator of Utilities HARRISON Assistant City Manager CMR: 159:04 Page 4 of 4 ****NOT YET APPROVED**** RESOLUTION NO. RESOLUTION OF THE COUNCIL OF THE CITY OF PALO ALTO APPROVING A LETTER OF AGREEMENT FOREXCESS CAPACITY 04-SNR-00647 WITH THE UNITED STATES DEPARTMENT OF ENERGY,WESTERN AREA POWER ADMINISTRATION WHEREAS, the City of Palo Alto (~City"), a municipal utility and a chartered city, is a "Preference Customer" of the Western Area Power Administration (~Western") of the United States Department of Energy; WHEREAS, the City’s existing one-year excess capacity Letter of Agreement with Western will expire on March 31, 2004; WHEREAS, the City, other Western customers and Western have been working together to formulate the excess capacity marketing program; WHEREAS, Palo Alto is entitled Western’s excess capacity program; to participate in WHEREAS, Western sells excess capacity to participants at attractive cost based rates; and WHEREAS, the City can save money by substituting lower cost excess capacity products for higher cost resources, as available; NOW, THEREFORE, the Council of the City of Palo Alto hereby RESOLVE as follows: SECTION i. The Council hereby approves the City of Palo Alto’s continuing participation in the Western Area Power Administration’s excess capacity marketing program relating to the Central Valley Project, California, as authorized under the attached Letter of Agreement 04-SNR-00647, which includes Exhibits A through D, and which has been signed by the United States Department of Energy, Western Area Power Administration, Sierra Nevada Customer Service Region. The City Manager is hereby authorized to sign the Letter of Agreement on behalf of the City of Palo Alto. // // // // 040204 cl 0072363 ****NOT YET APPROVED**** SECTION 2. The Council finds that the adoption of this resolution dues not constitute a project under the California Environmental Quality Act and no environmental assessment is required. INTRODUCED AND PASSED: AYES: NOES: ABSENT: ABSTENTIONS: ATTEST: City Clerk Mayor APPROVED: APPROVED AS TO FORM:City Manager Senior Asst. City Attorney Director of Administrative Services Director of Utilities 040204 cl 0072363 2 Department of Energy Western Are~ Power AdministrationSierra Nevada Customer Service Region 114 Parkshore Drive Folsom, California 95630-4710 FEB 2 4 2004 Letter of Agreement 04-SNR-00647 Mr. John Ulrich Director of Utilities City of Pale Alto 250 Hamilton Avenue 3rd Floor Pale Alto, CA 94301-2593 Dear Mr. Ulrich: This Letter of Agreement 04-SNR-00647 (LEA) is made between the Sierra Nevada Customer Service Region (SNR) of the Western Area Power Administration (Western) and the City of Pale Alto for SNR to provide Shasta Rewinds and daily excess capacity and associated energy to Pale Alto. Additionally, SNR needs, at certain times, the ability to reduce its Customers’ scheduled Central Valley Project commercial firm power. Pale Alto hereby agrees to assist SNR in its Ioadmanagement efforts according to the terms and conditions specified in this LeA. SNR and Pale Alto agree to the following terms and conditions: 1. This LeA shall become effective or~ April !, 2004, and shall remain in effect through December 31,2004, except as otherwise provided in Sections 14 and 17 herein.. All obligations incurred underthis LeA shall be preserved until satisfied. 2.Excess capacity and associated energy shall be made .available as follows: 2.1 Shasta Rewinds Excess Capacity (SREC): 2.1.1 Pale Alto will be allocated its percentage share (35.9%) of SREC as a result of participating in the Shasta Rewinds project in accordance with Contract 94-SAO-00047. Allocations will be based on the weekly average additional capacity available as defined in Contract 94-SAO-00047. SNR will offer SREC with at least a 50 percent capacity factor, however, Pale Alto.can preschedule SREC at less than a 50 percent capacity factor. The capacity factor associated with SREC shall not be more than 67 percent, unless agreed to by the Parties. 2,1.2 Five days prior to the beginning of each month, SNR will evaluate the upcoming estimated generation forecasts. Based on that evaluation, 2.2 2.3 SNR will determine whether it is more beneficial to SNIR to have Pale Alto purohase or return the energy associated with SREC. SNR will notify Pale Alto in wdting by facsimile or electronic mail whether SNR will make the energy associated with SREC available on a purchase or return basis. If SNR offers SREC as a sale, it will be at the rates provided in Exhibit D to this LeA, If SNR offers SREC on an exchange basis, SNR will notify Pale Alto in wdting by facsimfle or.electronic mail of the terms and conditions for the return to SNR of the energy associated with the SREC. 2.1.3 On Thursday of each week, by 3:00 p.m., SNR will notify Pale Alto of the amount of SREC and associated energy available for the following week (Monday through Sunday). Daily Excess Capacity (DEC): 2.2.1 Five days prior to the beginning of each month, SNR will evaluate the upcoming estimated generation forecasts. Based on that evaluation, SNR will determine whether it is more beneficial to SNR to have Pale Alto purchase or return the energy associated With DEC. SNR will notify Pale Alto in writing by facsimile or electronic mail whether SNR will make the energy associated with DEC available on a purchase or return basis. If SNR offers DEC as a sale, it will be at the rates provided in Exhibit D to this LeA. If SNR offers DEC on an exchange basis, SNR will notify Pale Alto in writing by facsimile or electronic mail of the terms and conditions for the return to SNR of the energy associated with the DEC. 2.2.2 SNR will notify Pale Alto of the total amount of DEC and associated energy available to Pale Alto each day during the term of this LeA, SNR will allocate the DEC MW to Pale Alto and SNR will allocate the DEC MWh to Pale Alto. 2.2.3 Pale Alto will have the dght to request all or a portion.of the DEC and associated energy available to Pale Alto. 2.2.4 SNR’s preschedulers will confirm the requested amount, or a lesser amount, depending on the amounts requested and the cdteria in Section 6. Load Management Excess Capacity (LMEC): 2.3.1 SNR will offer a monthly amount of LMEC to Pale Alto. SNR will determine, at its sole discretion, the amount of LMEC and the associated capacity factor to allocate to Pale Alto, SNR will make its best effort to determine the amount of LMEC available to Pale Alto at least three (3) days prior to the start of each month, during the term of this LOA. 2 2.3.2 SNR will offer LMI~C with at least a 50 percent capacity factor; heyever, Pale Alto can preschedule LMEC at less than a 50 percent capacity factor. The capacity factor associated with LMEC shall not be more than 67 percent, unless agreed to by the Parties. 2.3.3 As a requirement of Pale Alto receiving LMEC, Pale Alto agrees to reduce its schedule of commercial firm power in an amount equal to the amount of LMEC received for such month. SNR may waive this requirement on a case-by-case basis upon Pale Alto’s request. The maximum amount of commercial firm power subject to the required reduction is an amount equal to the amount of.LMEC allocated to Pale Alto during that month. Pale Alto will not be required to reduce its schedule of commercial firm power to an amount less than the remainder of Pale Alto’s maximum coincident allocation minus Pale Alto’s then- effective allocation of LMEC. Example: If, for the month of July 2004, SNR allocates 50 MW of LMEC to Pale Alto and Pale Alto’s maximum coincident allocation is 300 MW, SNR may require Pale Alto to reduce its schedule of commercial firm power to 250 MW (300 MW - 50 MW), and upon such request, Pale Alto must comply, or lose its allocation of LMEC. This reduction in schedule is in addition to any curtailments or reductions required under any other contractsbetween Western and Pale Alto. 2.3.4 Pale Alto understands that if LMEC becomes unavailable during any time that Pale Alto’s commercial firm power.schedule has been reduced pursuant to Section 2.3.3 above, Pale Alto will be able to increase its schedule of commercial firm power in an amount equal to the amount of LMEC that has become unavailable. 2.3.5 During the period of time that LMEC is available to Pale Alto, each reference to "Houdy Load. Pattern" in Contract DE-MO65-85WP59098 between SNR and the Northern California Power Agency, Pale Alto’s scheduling agent, shall mean "An amount of power in each hourly period multiplied by the ratio (not greater than one) of the MCA less the then- effective LMEC allocation divided by the forecasted peak systemload for the month." 3. SREC, DEC, and LMEC and. associated energy may be curtailed to the extent required by an outage of one or more Central Valley Project generating units affecting SNR’s ability to provide some or all of the S1REC, DEC, and LMEC and associated energy for the duration of the outage. SREC, DEC, and LMEC may also be curtailed to theextent required by increased project use pumping which reduces the amount of SREC, DEC and LMEC and associated energy available. SREC, DEC, and LMEC and associated energy may also be curtailed to. the extent required by either a reduction in transmission capability on the Califomia-Oregon Intertie affecting SNR’s ability to import power from the Northwest or a reduction in the transmission capability on the Central Valley Projecttransmission system. To the extent that SNR must curtail deliveries 3 hereunder, SNR will immediately notify Palo Alto and will reduce Palo Alto’s schedule at the commencement of the next applicable scheduling hour that begins at least 30 minutes after the notification. SNR will determine the extent to which it curtails the SREC, DEC, and LMEC and associated energy. If necessary, curtailments will first apply to DEC, then to SREC, and lastlyto LMEC, 4. The receipt of SREC, DEC, and LMEC and associated energy shall not reduce Palo Alto’s obligations to take its minimum annual energy entitlement and capacity requirements provided under existing contracts between Western and Palo Alto. The 35 percent minimum take requirement set forth in Contract DE-MO65-85WP59098 applies to Palo Alto’s entire contract rate of delivery as it is defined in such contract. 5. Exhibit A sets forth the authorized representatives for Pato Alto and SNR for scheduling and real-time transactions. 6. Palo Alto may request an amount of SREC, DEC, and LMEC and associated energy, in accordance with Exhibit B, not to.exceed the balance of its unmet expected peak load for the month after adjustment for its current contract rate of delivery. Palo AIto’s peak load shall not include wholesale sales for resale. Paio Alto shall provide its expected peak load forecast for a month by the 20th day of the preceding month. 7. SREC, DEC, and LMEC will be scheduled on the day and by the time specified in Exhibit B. Once scheduled, any changes to scheduled quantities requested by Pato Alto shall be implemented only if agreed to by SNR. 8. Palo Alto will not schedule amounts of SNR preference products, including commercial firm power, SREC, DEC, and LMEC, in excess of its load. 9. SREC, DEC,and LMEC and associated energy will be delivered to the point of delivery designated in Exhibit C. Transmission service beyond the point of delivery shall be the responsibility ~f Palo Alto, 10. SNR will bill Palo Alto for LMEC based on the scheduled energy. In the event of a curtailment of LMEC by SNR, Palo Alto will be required to pay for only that amount of LMEC made available at the delivery point. Exhibit D specifies the rate for LMEC provided hereunder. 11. Subject.to Sections 2.1.2 and 2.2.1, if SNRsells the SREC and/or DEC to Palo Alto, SNR will bill Palo Alto for SREC and/or DEC based on the scheduled energy, in the event that SNR curtails either SREC and/or DEC, Palo Alto will be required to pay for only that amount of SREC and/or DEC made available at the delivery point. Exhibit D specifies the rates for SREC and DEC provided hereunder. 12. In order to ensure SNR’s ability to continue to provide reliable, firm eiectdc service to all of its preference customers, Palo Alto hereby agrees to pay all or a portion of its bill under this LOA, as described herein, directly to SNR’s power suppliers. 4 13. 12.1 Polo Alto and SNR agree that Polo Alto assumes no obligation to the specified power suppliers for such payments and that they are made as an administrative and accounting accommodation to SNR. Polo Alto and SNR further agree that all. obligations for supply of Palo Alto’s power allocation hereunder remain with SNR. 12.2 SNR shall determine the amount of Palo Atto’s bill under this LOA to be paid to Power suppliers. Such amount shall be deducted from Polo Alto’s bill under this LOA. In no event shall Palo Alto be obligated to pay an amount in excess of its bill under this LOA, based on scheduled or actual use quantities. 12.3 Any failure to pay a power supplier in the time pedod specified on Palo Alto’s bill shall constitute nonpayment of a portion of Paio Alto’s bill and shall be subject to the General Power Contract Provisions attached hereto for nonpayment of bills in full when due, 12.4 Agreement by Pato Alto to pay a portion of SNR’s power purchase contract obligations shall not be contingent upon Congress making appropriations for expendftures by Western for such power purchase contract. Billing and payments for the power provided hereunder shall be as follows: 13.1 Billing and payment for power provided pursuant to-this LOA shall be in accordance with the Billing and Payment provisions (Article 13) of the General Power Contract Provisions attached hereto. Bills shall be sent to Polo Alto at the following address: City of Palo Alto Electdc Department Attn: Raveen Moan 250 Hamilton Avenue 3rd Floor Polo Alto, CA 94301-2593 13.2 In accordance with Section 12 above, SNR shall notify Palo Alto of the power suppliers, the amount to be paid to each power supplier, and all other necessary information, by sPecifying that information on Polo Alto’s bill. 13.3 PaloAito shall pay the designated power suppliers the amounts due within the payment period, specified on its bill. 13.4 Palo Alto shall make payments to the power suppliers by an electronic transfer of funds or check, at the option of Polo Alto, unless otherwise agreed between SNR andPalo Alto. Palo Alto shall send the documentation of payments sent to designated power suppliers to SNR as soon as practicable. 5 13.5 Payments due to Western may be wired for electronic transfer deposit to Western’s ~ub-account (American Bank Association No. 021030004, Subtype 10) of the Treasury Department’s account with the Federal Reserve Bank in New York City, (BNF -- AC-89001602). SNR will include account number information with the bill..Palo Alto may also send payments in check form to the following address: Department of Energy Western Area Power Administration File No. 51587 Post Office Box 60000 San Francisco, CA 94160-1580 t 3.6 If.agreed to by the Parties, SNR may credit monthly amounts due Palo Alto for power sold to SNR, under vadous contracts SNR may have for purchasing power from Palo Alto, against the amounts due to SNR under this LOA. In the event the amount due by Palo Alto to SNR is less than the amount owed by SNR to Palo Alto, then SNR shall pay the difference to Palo Alto. In the event the amount due by SNR to Palo Alto under those purchase power contracts is less than the amount owed by Palo Alto to SNR under this LOA, then Palo Alto shall pay the difference to SNR. 14. in the event that Contract 14-06-200-2948A is terminated, this LOA shall terminate concurrently; provided, That all outstanding energy return and payment obligations incurred prior to termination of this LOA shall be preserved until satisfied. 15. The Authorized Representatives; Posting, Response, and Confirmation Time Schedule; Point of Delivery; and the Rates for LMEC, SREC and DEC with Associated Energy are set forth in Exhibits A, B, C, and D, respectively. Exhibits A, B, C, and [3 are attached hereto, and each shall be in force and effect in accordance with its terms until superseded by a subsequent exhibit or termination of this LOA. 16. The General Power Contract Provisions dated July 10, 1998, attached hereto, are hereby made a part of thisLOA the same as if they had been expressly set forth herein; Provided; That Articles 20 through 30 shall not apply. 17. Either Party may terminate this LOA upon a thirty-day wdtten notice given to the other Party. 6 If you are in agreement with the terms and conditions written above, please indicate your approval by signing and dating both originals of this LOA, and return one original to Gioda Davis (N6205) at this office. If you have any questions, please contact Jeanne Haas at (9!6) 353-4438, or Hiroshi Kashiwagi at (916) 353-4477, Power Marketing Manager In Duplicate Seal Attest: By: Title: CiTY OF PALO ALTO By: Title: Address: Date: 7 City of Palo Alto Exhibit A to Letter of Agreement 04-SNR-00647 .E~XHIBIT A (Authorized Representatives) 1. This Exhibit A made to be effective under and as a part of Letter of Agreement 04-SNR-00647 (LOA), shall remain in effect until superseded by another Exhibit A or upon termination of this LOA. 2. SNR’s authorized representative for scheduling transactions shall be its preschedulers, who can. be contacted by telephone at (916) 353-4091 or (916) 353-4092, by fax at (916) 353-221.0, or by electronic mail at presched@wapa.gov. For real-time transactions, SNR’s dispatchers are the authorized representatives. Palo Alto can contact SNR’s dispatchers at (916) 353-2200. 3. The authorized representative for scheduling or real-time transactions for Palo Alto shall be ~ts scheduling agent, the Northem California Power Agency, who can be contacted by telephone at (916) 781-4281, by fax at (916) 781-4239, or by electronic mail at kevinm@ncpa.com. Page 1 of "I City of Palo Alto Exhibit B to Letter of Agreement 04-SNR-00647 EXHIBIT B (Posting, Response, and Confirmation Time Schedule) 1. This Exhibit B, made to be effective under and as a part of Letter of Agreement 04-SNR-00647 (LOA), shall remain in effect until superseded by another Exhibit B or upon termination of this LOA. 2. The following table outlines the normal sequence of events, provided there is no prescheduling holiday, observed by SNR and Palo Alto, during a particular week: If daily excess capacityi~, available on: Paio Alto schedules by 9:00 a.m. on the prior: SNR posts the amount available to Palo Alto by 12:00 p.m., Palo Alto responds by 1:00 p.m., SNR confirms the amount ._by 3:00 p.m. on the pdor: Thursday Thursday Fdday Mo.n_..day Tuesday WednesdaY Wednesd.#y Sunda_Y-Friday Monday ......Fdday Tuesda_y ...Monda_y_. Wednesday ._.Tuesday Thursday ....Wednesday Ffida.y Thursday Saturday .......Thursday 3.SNR reserves the right to modify this Exhibit B if SNR deems it necessary. Page 1 of ! City of Palo Alto Exhibit C to Letter of Agreement 04-SNR-00647 EXHIBIT C (Point of Delivery) 1. This Exhibit C, made to be effective under and as a part of Letter of Agreement 04-SNR-00647 (LOA), shall remain in effect until superseded by another Exhibit C or upon termination of this LOA. SNR, under terms and conditions stipulated in this LOA, will furnish excess capacity and associated energy to Palo Alto at the Tracy 230-kV Substation at a delivery voltage of 230 kV. 3. Delivery of excess capacity and associated energy to the point indicated will be subject to available transmission capability. Page 1 of 1 City of Palo Alto Exhibit D to Letter of Agreement 04-SNR-00647 EXHIBIT D (Rates for LMEC, SREC and DEC with Associated Energy) 1. This Exhibit D, made to be effective under and as a part of Letter of Agreement 04-SNR-00647 (LOA), shall remain in effect until superseded by another Exhibit D or upon termination of this LOA. 2.The rate for SREC and DEC and associated energy shall be comprised of: 2.1 The estimated Pacific Gas & Electric Company’s full thermal production rate (at the time of the excess capacity sale) used to determine Energy Account No. 2 transactions, currently 17.5 mills per kWh; 2.2 An administrative adder of 0.5 mills per kWh; 2.3 The Central Valley Project firm transmission rate of 1.0 mill per kWh; and 2.4 Any additional purchase power or other costs incurred by SNR due to decisions made to the benefit of the excess capacity program. SNR will assess this charge after the fact, once all costs are determined. 3. SNR may change the rate for SREC and DEC and associated energy by giving Palo Alto 30 days advance written notice. SNR will modify Exhibit D to reflect the change in rate. 4. The composite rate for LMEC and associated energy shall be the rate as set forth in the memorandum approved by Michael S. Hacskaylo or~ March 24, 2000, or any superseding memorandum. Page 1 of I CERTIFICATION OF NONDISCRIMINATION FORM 410 Project: Letter of Agreement 04-SNR-00647 for Palo Alto to purchase Western Excess Capacity. Certification of Nondiscrimination: As Suppliers of goods or services to the City of Palo Alto, the firm and individuals listed below certify that they do not discriminate in employment with regards to age, race, color, religion, sex, national origin, ancestry, disability, or sexual preference; that they are in compliance with all Federal, State and local directives and executive orders regarding nondiscrimination in employment. Firm: Sierra Nevada Customer Service Region of the Western Area Power Administration (Western) Date: //~/’~ Title of Officer Si~ing : Signature: ’ . CITY OF PALO ALTO: CERTIFICATION OF NONDISCRIMINATION