Flender/Flender Gear Units/Helical gear unit H4
icent to perform the test would not be to the Citys advantage . In the meantime, Bicent had confirmed Siemenss

availability to repair the gear set starting December 3, 2. Bicent scheduled the Fall 2 outage for December 3 -1

to accommodate this work. Bicent also requested that the City notify CAISO of the outage. Other 3 Notably, the City

had no right under the PPTA to demand Capacity Test this year at all. Section 7.2 is clear that the

City may only request test in year that Bicent is not conducting biennial Capacity Test. Bicent plans to condu ct such test this year. November 1, 2 Page 7 than Ms. Nguyens general assertion that the City is not willing to accommodate Bicent on this issue and that the City intends to delay any further action until the dispute it manufactured regarding the November 1 Capacity Test is resolved , Bicent has receive no response to this request . The Citys gamesmanship is particularly troubling (and dangerous) because it risks causing delay to completion of critical Facility maintenance that is essential to ensuring safe and reliable operation. The deadline for the City to notify CAISO of an outage for this essential maintenance is November 2, and Bicent will be irreparably harmed if the City does not do so. On November 1, 2, seeking single -handedly control all of the Citys interactions with Bicent, Ms. Nguyen wrote to Bicent to demand that all communications other than those involving plant emergency be directed to her alone. It is impossible to run power plant this way: City staff and the Facility operations team actually sit in the same control room on site and must interact continuously regarding Facility scheduling, availability and dispatch notices under the PPTA. Routine plant communications include daily Availability Notices, Forced Outage notifications, Forced Outage timeline updates, de -rate notifications, star