ordering data Ordering information When ordering B4-VV-26-D Bevel-helical gear units B4

Flender/Flender Gear Units/Bevel-helical gear units B4

tening irreparable harm to Bicent and the community at large . November 1, 2 Page 8 . Refusing to Agree to the December 3 -1 Sche duled Outage Violates the PPTA and Threatens to Cause Bicent Irreparable Harm As described above, Bicent has notified the City of the need for Scheduled Outage from December 3 -1, 2 so that Siemens and Flender may repair the gear set on the steam turb ine generator. This is critical item that is essential to operation of safe and compliant plant and that can only be performed with the availability of Siemens and Flender personnel. December 3 - 1 are the earliest dates on which they are available. Despite the importance of this work, Ms. Nguyen has caused the City to refuse to notify CAISO of the scheduled outage, in violation of its Scheduling Coordinator Obligations under the PPTA. Section 1.2 of the Agreement requires the City to submit all required notices and updates regarding each Generating Units status to the CAISO, including outage reports, and shall perform all other obligations required of Scheduling Coordinator, pursuant to the CAISO Tariff. Notice to CAISO is required if the pl ant is to be taken offlin from December 3 -1 for gear set maintenance on the steam turbine generator. By refusing to submit notice of the planned outage to CAISO, the City has imperiled critical maintenance work and violated its contractual obligation to submit all required notices and updates to CAISO. Ms. Nguyens behavior also places the City in violation of section 1.1 of the PPTA, which requires the City and Bicent to cooperate . . . to arrange and coordinate all Outage Schedules. Under ection 1.1, Bicent has the power to set Scheduled Outages. After Bicent submits schedule of proposed Scheduled Outages, the City is permitted to make reasonable request for changes to the Outage Schedule, which Bicent shall accommodate so long as doing so is consistent with Good Utility Practice.