Loading...
HomeMy WebLinkAboutResolution 2011-25 Amend Energy Independence Program (EIP) Report and Administrative GuidelinesCITY OF PALM DESERT STAFF REPORT REQUEST: ADOPT CITY COUNCIL RESOLUTION 2011-25 APPROVING AMENDMENTS TO THE ENERGY INDEPENDENCE PROGRAM (EIP) REPORT AND ADMINISTRATIVE GUIDELINES SUBMITTED BY: Martin Alvarez, Redevelopment Manager DATE: March 24, 2011 CONTENTS: Proposed Amendments to EIP Report Resolution No. 2011- 25 Recommendation Waive further reading and adopt: Resolution No. 2011- 25 , a Resolution of the City Council of the City of Palm Desert approving amendments to the Energy Independence Program Report and Administrative Guidelines prepared pursuant to Section 5898.22 of the California Streets and Highways Code. Background On July 21, 2008, the Governor signed into law AB 811, which amended Chapter 29 of Part 3 of Division 7 of the California Streets and Highways Code (as amended, the "Act"). The bill authorized cities and counties to establish a program to enter into contractual assessment agreements with property owners to finance the installation of distributed generation renewable energy sources or energy efficiency improvements that are permanently fixed to real property. On August 28, 2008, the City Council approved Resolution No. 08-89, which established the City's Energy Independence Program Report and Administrative Guidelines (the "EIP Report") prepared pursuant to Section 5898.22 of the California Streets and Highways Code. The City Council has made amendments to the EIP Report twice since its adoption, June 25, 2009 and January 14, 2010. On February 24, 2011, the City Council adopted Resolution No. 2011-9 declaring its intent to amend the EIP Report to address the new requirements of AB 44 (discussed below) and ordering a public hearing to be held on March 24, 2011. In accordance with applicable law, the City Clerk provided notice of the public hearing by publishing Resolution No. 2011-9 once a week for two weeks in The Desert Sun. \\srv-fi12k3\groups\rda\Martin Alvarez\2011\Staff Reports\3-24-11EIPGuideline ModsMdocx Staff Report Resolution No. 2011-25 Amend EIP Report and Guidelines March 24, 2011 Page 2 of 3 AB 44 Assembly Bill No. 44, Chapter 564 of Statutes of 2010 ("AB 44"), effective January 1, 2011, added Section 5898.15 to the California Streets and Highways Code. Section 5898.15 provides that the City shall not permit a property owner to participate in EIP if the owner's participation would result in the total amount of any annual property taxes and assessments exceeding 5 percent of the property's market value, as determined at the time of approval of the owner's contractual assessment on or after January 1, 2011. AB 44 also added Section 5898.23 to the California Streets and Highways Code, which provides that the report required pursuant to Streets and Highways Code Section 5898.22 in order to establish a contractual assessment program under the Act shall include safeguards that will be used to ensure that the requirements of Section 5898.15 are met. To comply with the new requirement the Office of Energy Management has already implemented the Section 5898.15 requirement to any property owners applying for EIP financing on or after January 1, 2011. Although the EIP Report was adopted before the adoption and effectiveness of AB 44, staff recommends that the EIP Report be amended to expressly state the requirement imposed by Streets and Highways Code Section 5898.15 and to set forth the method for verifying compliance with the requirement, which will assist property owners' and City staffs evaluations of EIP applications. Section 5898.15 expressly states that the new requirements imposed by the statute are evaluated only at the time the contractual assessment (i.e., Loan Agreement) is approved and shall not be construed to void or otherwise release a property owner from the contractual assessment obligations, particularly in the event that the total amount of annual property taxes and assessments exceeds 5 percent of a property's market value after the property owner has entered into a contractual assessment. Therefore, it is not expected that there will be any adverse consequence to EIP assessment collections as a result of new Section 5898.15. Proposed Amendments to EIP and EIP Report The proposed amendments to the EIP Report (attached) were reviewed and approved by the Energy Subcommittee prior to submission to the City Council for approval and have been on file with the City Clerk and available for review prior to the March 24, 2011, public hearing. After opening the public hearing and taking public comment, staff recommends approval for the modifications to the EIP Report and Administrative Guidelines. Staff Report Resolution No. 2011-25 March 24, 2011 Page 3 of 3 Fiscal Analysis Amend EIP Report and Guidelines There is no fiscal impact associated with this request. Submitted By: M in Alvarez, Redeve opment Mgr. Department Head: McCarthy, ACM f9PR-e4evelopment Paul S. Gibson, Director of Finance CITYCOUNCIL"fION APPROVED ✓✓ DENTED......... RECEIVED _ OTHER AYES:.�1.:�_� ABSENT:....;,......... ABSTAIN: AjQJ....�.�..... VERIFIED Ir �..�.... OriginW on File with City erk's Office \\srv-fi12k3\groups\rda\Martin Alvarez\201 1 \Staff Reports\3-24-11 EIPGuideline ModsPH.docx a- r Energy Independence Program Report and Administrative Guidelines Outline Introduction Goals Background Benefits Program Administration Program Requirements Eligible Property Owners Eligible Properties Consent Agreement Eligible Equipment Eligible Costs Tracks for Participation The Efficiency Track The Solar Track The Custom Measure Track Financial Strategy Energy Surveys Energy Independence Program Parameters Minimum Loan Amount Maximum Loan Amount Maximum Portfolio Assignment of Rebates and Incentives Duration Interest Rate Administrative Fees Changes to Report Appendices A. Equipment List B. Map of Program Area C. Draft Program Application D. Draft Loan Contract E. Summary of Loan Process F. Consent Agreement G. Notice of Assessment H. Payment of Contractual Assessment Required Revised March 24, 2011 Introduction This Report has been prepared pursuant to Section 5898.22 of the California Streets and Highways Code in connection with the establishment of the City of Palm Desert Energy Independence Program ("EIP"). This is the guiding document for EIP and fulfills the Section 5898.22 requirements that this report contain: l . A map showing the boundaries of the territory within which contractual assessments are proposed. (See Appendix B.) 2. A draft contract between a property owner and the City. (See Appendix D.) 3. City policies concerning contractual assessments. 4. A plan for raising a capital amount to pay for the work performed. The Energy Independence Program described herein is designed to help Palm Desert property owners save energy and gain independence from the scarcity of sources of energy that are compromising the California power grid, threatening national security, and endangering the global climate. The Energy Independence Program helps Palm Desert property owners save energy and money while doing right for the environment. Goals EIP will carry out the City's mission of helping property owners of improved real property make principled investments in the long-term health of the local, state, and national economy and global environment. EIP aims to provide multiple benefits. By enabling property owners to take responsible energy actions, the program seeks to cut their utility bills. At the same time it shores up the local economy, the California power grid, and national and global energy interests, and makes it possible for Palm Desert to fulfill energy conservation and climate protection commitments. The City has established a goal to reduce electric and natural gas energy consumption by 30%. The City welcomes innovative energy solutions that will contribute to this goal. The City intends to initially fund EIP with $2.5 million for energy reduction investments that might not have otherwise been possible, with a maximum aggregate amount of $25 million. Background As a result of Palm Desert's authorship and advocacy of what became Assembly Bill 811, the bill was approved by the California Legislature, signed into law by the Governor on July 21, 2008 and became immediately effective as an urgency measure. Under this bill, the California Legislature has declared that a public purpose will be served by a contractual assessment program that provides the local government with the authority to finance the installation of distributed generation renewable energy sources — such as solar -- and energy efficiency improvements that are affixed to residential, commercial, industrial, or other real property (collectively known as "Energy Improvements"). 2 To make Energy Improvements more affordable and to promote their installation, AB 811 provides procedures for authorizing voluntary assessments to finance the cost of these improvements. The Energy Independence Program works with the free and willing consent of owners of the property on which the Energy Improvements are to be made. The City will make loans ("EIP Loans") to property owners within the City to finance the installation of Energy Improvements pursuant to contractual assessment agreements. Property owners in the City will repay EIP Loans through an assessment levied against their property which is payable in semi-annual installments on property tax bills. Program Benefits From the Cit'sperspective, the Energy Independence Program will be a key element in achieving the City's 30% energy reduction goals. EIP provides a significant channel for funneling more resources into the shift to greater efficiency and renewable energy, while securing the energy future. For example, $25 million of energy efficiency and renewable energy investments has the potential to provide over $50 million in direct consumer benefits over time while contributing to regional, state, national and international goals. For property owners, EIP offers: ■ A no -money -down means of financing Energy Improvements. ■ Fixed-rate loans. ■ Financing without requiring a property appraisal. ■ A stream -lined loan process. Program Administration EIP will be administered by the City's Office of Energy Management ("OEM"), which is headed by the Director of the Office of Energy Management (the "Director") and staffed by EIP professionals. EIP staff will be responsible for: ■ Community outreach ■ Energy surveys ■ Advising property owners ■ Processing loan applications ■ Managing and tracking funds available for EIP Loans ■ Monitoring individual and collective energy conservation ■ Integrating EIP with Palm Desert's successful Set to Save rebate program. The intent of these services is to provide a "turn -key" service for Palm Desert property owners who would otherwise be unable or unwilling to finance efficiency measures and renewable energy options. Their participation is critical to the City in achieving its 30% energy reduction goals and for the State to meet its greenhouse gas commitments to reduce carbon emissions to 1990 levels by 2020. Program Requirements No Construction Prior to City Authorization If construction has commenced on an improvement prior to (a) property owner submittal and City approval of an EIP application for the improvement (see Appendix C), and (b) execution of an EIP contract by the City with respect to the improvement (see Appendix D), such improvement will not be eligible for financing under the EIP. After execution of an EIP contract by the City and the property owner, the City will provide confirmation of an acceptable title policy and authorization to commence work. Property owners should note the City's obligation to fund amounts under an EIP contract is contingent upon the City's confirmation of a title policy issued to the City in the EIP Loan amount and insuring the EIP Loan and the lien of the EIP assessment (see Appendix D). If a property owner commences of construction of an EIP Improvement prior to City confirmation of its receipt of an acceptable title policy, the property owner proceeds at its own risk. Eligible Property Owners All owners of improved real property are eligible for the Energy Independence Program. Owners may be individuals, associations, business entities, cooperatives, and virtually any owner which pays real property taxes. A property owner needs to be current in the payment of property taxes and the property must be free and clear of all liens, excluding customary mortgage liens and assessment liens. Property owners are eligible to make multiple applications for additional Energy Improvements with the maximum aggregate of these applications not to exceed $100,000 per parcel. Applications may be submitted by property owner or the contracting company, limit one application per day. Eligible Properties EIP Loans are available to all owners of improved real properties in the City including, but not limited to, residential, commercial, and industrial properties. Unfortunately at this time, EIP Loans are not available for properties that do not pay property taxes, such as governmental entities and certain non-profit corporations. Consent Agreement All EIP Loans $30,000 or more (whether a single EIP Loan, or multiple EIP Loans combined for a single property owner) shall have a Consent Agreement, signed by each private institution or individual which is the beneficiary and holder of a pre-existing Deed of Trust, authorizing the placement of the Notice of Assessment on the property. (See Appendix F.) 0 Eligible Equipment EIP affords property owners in Palm Desert the opportunity to take advantage of a wide range of energy -savings measures, consistent with the following provisions: 1. EIP provides financing for Energy Improvements that are permanently affixed to property. 2. EIP Loans are specifically made available for Energy Improvements. Property owners that elect to engage in broader retrofit projects — such as home or business remodeling — will only be provided EIP Loans for that portion of the costs used to retrofit existing structures with Energy Improvements. (This is discussed further in Eligible Costs.) EIP Loans are intended for retrofit activities to replace outdated equipment and to install new equipment that takes energy off the grid. However, EIP Loans are also made available for purchasers of new homes and businesses that wish to add Energy Improvements after the property owner takes title to the property. 4. EIP Loans are made available for the following types of improvements that are presented in greater detail in Appendix A: a. Efficiency Measures. EIP supports a wide range of efficiency measures as presented in Appendix A. EIP also supports Energy Improvements that are eligible for Set to Save program rebates. b. Solar Systems. EIP Loans will be available for a range of solar systems, from photovoltaic to solar thermal. c. Custom Measures. Upon review and approval by the Office of Energy Management, EIP Loans are made available for emerging technologies for Energy Improvements that provide new ways to save or generate energy and that will be evaluated on a case -by -case basis. 5. EIP is flexible and provides three "Tracks" for participation that focus on Efficiency Measures, Solar Systems, and Custom Measures. See "Tracks for Participation" below for more information. 6. EIP Loans are also made available for combinations of Energy Improvements such as bundling energy efficiency and renewable energy measures. For instance, a property owner may choose to replace both an aging and inefficient air conditioner and install a solar system. Eligible Costs Eligible costs of the Energy Improvements include the cost of equipment and installation. Installation costs may include, but are not limited to, labor, drafting, engineering, permit fees, and inspection charges. The installation of Energy Improvements can be completed by a qualified contractor of the property owner's choice. Eligible costs do not include labor costs for property owners that elect to do the work themselves. 5 In each case, the Office of Energy Management will determine whether the estimated equipment and installation costs are reasonable. The OEM will evaluate market conditions and may require additional bids to determine whether costs are reasonable. While the property owner will be able to select the bidder of his or her choice, the amount available for the EIP Loan may be limited to an amount deemed reasonable by the OEM, and may be reviewed by the City Manager and the Palm Desert City Council. Credit Criteria for Eligibility Satisfaction of the credit criteria for eligibility is required for participation in the Program, in order to reduce risk for both the property owner and the City. All three of the tests below must be met, at the time of the application approval: 1. Repayment Term — the term of the EIP Loan shall not exceed the reasonably expected useful life expectancy of the Energy Improvements financed by the EIP Loan. "Useful life expectancy" shall be determined in accordance with the then current policy maintained by the OEM, which policy establishes reasonably expected useful life expectancy for the purpose of the EIP. a. For properties participating with respect to multiple types of Energy Improvements, reasonably expected useful life expectancy shall be calculated on a weighted basis, weighted by cost value of each improvement. b. Exceptions to the repayment term limitation above may be granted by the City Manager, to provide for a longer repayment term (up to a maximum of the reasonably expected useful life expectancy of the Energy Improvements plus 5 years), upon sufficient evidence, provided by the property owner, of the fiscal prudency and rationale for such exception. The determinations of whether the evidence is sufficient and whether or not to grant an exception shall be in the City Manager's sole discretion and shall be final. 2. Value -to -Lien Ratio — the ratio of (a) the value of the property to (b) the sum of the amount of (i) the requested amount of the EIP Loan (including contingency) and (ii) the amount all other liens on the property securing a special tax levied pursuant to the Mello - Roos Community Facilities Act of 1982, a special assessment, or any other contractual assessment (e.g., EIP Loan), must be at least 10:1. a. "Value of the property" will be determined as (i) the assessed value of the property, as reflected on the County Assessor's most current tax roll, or (ii) if the property was recently purchased by the property owner and the sale price has not yet been reflected on the County Assessor's most current tax roll, the sale price of the property as established by purchase and sale documentation provided by the property owner to the OEM in form and substance satisfactory to, and approved by, the OEM (in its sole discretion) and legal counsel to the City. In the alternative, the property owner may request the City to have an appraisal (in form and substance acceptable to the City and from an appraiser of City's choice) rol conducted on the property, at the cost of the property owner, for the purpose of establishing the value of the property. b. Exceptions to the minimum 10:1 value -to -lien ratio may be granted by the City Manager (to a minimum of an 8:1 value -to -lien ratio), upon sufficient evidence, provided by the property owner, of the fiscal prudency and rationale for such exception. The determinations of whether the evidence is sufficient and whether or not to grant an exception shall be in the City Manager's sole discretion and shall be final. 3. Total Annual Property Taxes and Assessments —the total amount of any annual property taxes and assessments shall not exceed five percent (5%) of the market value of the property. a. "Total amount of any annual property taxes and assessments" will be calculated as the sum of (i) the total annual property taxes and assessments levied on the Riverside County consolidated property tax bill for the current fiscal year, and (ii) the maximum projected annual installment of the EIP contractual assessment, as calculated by the OEM. If the property owner has received any bills for taxes or assessments directly from a local taxing entity for the current fiscal year, the property owner will provide copies to the OEM, and the annual amount shown on any such direct bills also will be included in amount determined in clause (i). b. "Market value of the property" will be determined in the same manner as "value of the property," as described above under "2. Value -to -Lien Ratio." Tracks for Participation There are three ways for property owners to participate in the Program. Eligible equipment and standards are presented in greater detail in Appendix A: The Efficiency Track The Efficiency Track covers a wide range of energy efficiency fixtures, from windows and doors, attic insulation that are Energy Star rated. Packaged and central air conditioning systems must meet the minimum efficiencies specified in the Set to Save program. Given Palm Desert's preponderance of pools, specific efficiency requirements are presented for pool pumps and heaters. All other efficiency measures must go through the Custom Measure Track. The Solar System Track The Solar System Track makes available Energy Independence Program loans for Energy Improvements. The Solar Track also helps property owners with solar electric and solar thermal investments by offering optional consultation by EIP experts. Custom Measure Track All other proposed measures follow the Custom Measure Track. These measures may include renewable energy sources (other than solar), such as wind, geothermal, and potentially solar- 7 hydrogen fuel cells, as well as more complex and innovative energy management solutions and emerging technologies. The developments of technologies are encouraged by EIP as a means of diversifying the City's energy sources. Applicants for the Custom Measure Track should consult the OEM to determine eligibility. In some cases, the findings of national energy laboratories and nationally accredited research and testing centers will be required for EIP approval. In all cases, the City reserves the right to decline funding of a custom measure. Energy Surveys The Office of Energy Management offers energy surveys at owners' properties. During these on -site surveys, a trained Program expert will review as appropriate, energy efficiency, energy management, and renewable energy opportunities and EIP financial details with the property owner. Energy surveys are highly recommended but not required. The Financial Strategy The City will create the Energy Independence Program Fund which may accept funds from any available source and which may disburse such funds for the purpose of funding Energy Improvements. Loan repayments — through the property assessment mechanism — will be made to the Energy Loan Fund. The City initially will seed the Energy Loan Fund with $2.5 million from the General Fund. Thereafter, the Energy Loan Fund may be funded from a number of other potential sources, and combinations of sources, which may include but are not limited to additional funding from the General Fund, the issuance of notes, bonds, or agreements with utilities or public or private lenders or other governmental entities and quasi -governmental entities such as CALPERS. EIP Funds will then be used by the City for additional EIP Loans and/or to establish a Reserve Fund or pay administrative costs and/or to reimburse itself for advancing moneys from the General Fund to the EIP Fund. At a minimum, $1.25 million of the $2.5 million loan amount will be reserved for EIP Loans for residential property owners. The Office of Energy Management will report on penetration to the City Manager and Council on a quarterly basis at a minimum, providing Council with the information necessary to shift funds as it elects to do so at its sole discretion. The City may also establish an EIP Reserve Fund if bonds are issued to cover EIP Loan payments in the event of assessment delinquencies prior to foreclosure and tax sale if deemed necessary by the City Manager and the City Council. Energy Independence Program Parameters Minimum Energy Loan Amount The minimum size for an EIP Loan is $5,000. Maximum Energy Loan Amount The maximum size for an EIP Loan is $100,000. All EIP Loans greater than $60,000 must be approved by the City Manager. Maximum Portfolio The maximum principal amount of the Energy Loans to property owners under the Program is $25 million. This may be increased by the City Council at its discretion. A minimum of 50% of the loan funds available shall be set aside and used only for energy efficiency upgrades and retrofits, as determined by the Office of Energy Management. Assignment of Rebates and Incentives The Office of Energy Management recommends that the amount of an EIP loan be reduced by an applicable California Solar Initiative Expected Performance Based Buy -Down rebate, Self - Generation Incentive Program (SGIP) rebate, and any Set to Save rebates. Such rebates may be assigned to the applicable contractor. Duration EIP Loans are made available for up to 20-year terms to accommodate a wide range of efficiency measures and renewable energy investments. The term of the loan is in the discretion of the property owner in consultation with the Office of Energy Management. Interest Rate EIP Loans will be made for the initial $2.5 million an annual interest rate not to exceed 7% for all loans. Thereafter, the City Council will maintain the discretion to adjust the interest rate up to an amount not to exceed 10%. The Council will determine interest rates so that the Energy Loan Fund remains financially viable up to the legal limit. The City will set the interest rate for an EIP Loan at the time that the City and property owner enter into the contractual assessment agreement. Administrative Fees The City of Palm Desert will offer the Energy Independence Program as an additional City service that will help property owners achieve their energy goals, while helping the City achieve its energy and climate protection goals. The City of Palm Desert will be responsible for all EIP marketing and outreach, as well as the duties of the Office of Energy Management. 0 The City may elect to cover a portion of its costs through the "spread" between its combined earnings rate, and the EIP Loan issuance rate. Similarly, it may elect to recover EIP costs through a spread between bond rates and loan rates, or the spread between interest rates of any financial vehicle. The City will not charge property owners a fixed administrative fee. Two forms of costs will be the responsibility of the property owner: 1. Title costs — including title insurance — will be paid by the property owner. 2. Assessment collection costs will appear as a line item on property taxes not to exceed $40 per property per year and will be paid by property owner. This cost was determined after consultation with the County of Riverside Assessor's Office. Additionally, if the property owner requests the City to cause an appraisal to be conducted for the purposes of determining the "value of the property" or "market value of the property" in connection with credit eligibility requirements described above, the cost of the appraisal will be paid by the property owner. Changes to Report The Director or City Manager may make changes to this Report that the Director or City Manager reasonably determines are necessary to clarify its provisions. Any changes to this Report that materially modify the Energy Independence Program shall only be made after approval by the City Council. The City Manager or Director may modify from time to time the Equipment List, draft Loan Contract and draft Application attached hereto as Appendix A, Appendix D and Appendix C, respectively, as deemed necessary by the City Manager or the Director to effectuate the purposes of the Program. 10 Appendix A: Equipment List The Energy Independence Program offers EIP loans for a number of equipment types, including efficiency measures, solar systems, and other innovative, energy -saving custom measures. In each case, the use of rebates and tax credits to prepay a portion of the loan is at the discretion of property owner. Efficiency Measures The Energy Independence Program provides services and loans for a wide range of Energy Star - rated efficiency measures, including many Set to Save Efficiency Measures for which property owners can get rebates as well as EIP Loans. Except HVAC equipment as noted below, efficiency measures that are Energy Star rated must meet the Energy Star minimum efficiency levels. For all packaged and central air conditioning systems funded in this loan program, the minimum efficiency levels shall be as required by the current minimum requirements set forth in Set to Save program. All other proposed efficiency measures will be considered in the Custom Measure Track. The City of Palm Desert anticipates that Energy Star requirements will "ratchet up" to greater efficiency levels over time. Energy Star will also become more inclusive of technologies over time. Thus the EIP will evolve with Energy Star and the market for energy -efficient technologies. The following Energy Star measures — among others — are eligible in the Efficiency Track. ■ Attic and wall insulation ■ Light fixtures (no bulb -only retrofits) ■ Reflective roofs and coatings ■ Windows, doors, and skylights Pool Equipment Given the preponderance of pools in Palm Desert the following prescriptive standards must be upheld for Efficiency Track funding: o Pool circulating pumps (must be Variable Flow and/or Multi -speed with controllers) o Natural gas pool heaters (must have a thermal efficiency of 84% or greater) 11 Solar Equipment Solar Track funding is available for a wide range of solar equipment. EIP Loans will be available for photovoltaic equipment and installers listed by the California Energy Commission. Solar thermal equipment must be rated by the Solar Rating Certification Council (SRCC). As with efficiency measures, the property owner maintains the discretion as to whether to prepay a portion of the gross loan with any solar rebates and tax credits. Eligible solar equipment includes: Solar thermal systems (hot water) Photovoltaic systems (electricity) o Battery back-up systems will be allowed o Funding for off -grid systems will be allowed o PV systems can be sized to accommodate plug-in electric vehicles Custom Measures The City of Palm Desert encourages innovation in saving energy to meet its energy -savings goals. Custom Measures will only be funded for EIP Loans if sufficient proof of energy savings is provided to the Office of Energy Management that the measure will reduce usage by 20%. The Director reserves the right to defer funding until he deems the evidence sufficient to verify this performance requirement. The following types of measures — among others — will be considered for EIP Loans through the Custom Measure Track: ■ Building Energy Management controls ■ HVAC Duct zoning control systems ■ Irrigation pumps and controls ■ Lighting controls ■ Motors and controls ■ Natural gas fuel cells ■ Water heating equipment o Tank -style o Tankless o Central water heating system As these "Custom Measures" become Energy Star rated they will be included in the Efficiency Measure Track. 12 RESOLUTION NO. 2011- 25 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM DESERT APPROVING AMENDMENTS TO THE ENERGY INDEPENDENCE PROGRAM REPORT AND ADMINISTRATIVE GUIDELINES PREPARED PURSUANT TO SECTION 5898.22 OF THE CALIFORNIA STREETS AND HIGHWAYS CODE RECITALS: WHEREAS, pursuant to Chapter 29 of Part 3 of Division 7 of the California Streets and Highways Code (the "Act"), the City Council established its Energy Independence Program (the "Program" or "EIP") to assist property owners with the cost of installing distributed generation renewable energy sources or making energy efficient improvements that are permanently fixed to their property; and WHEREAS, on August 28, 2008, in connection with the Program and in accordance with Section 5898.22 of the Act, the City Council approved the Energy Independence Program Report and Administrative Guidelines (the "Report"); and WHEREAS, on June 25, 2009, the City Council approved amendments to the Report following a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed amendments to the Program or any of its particulars, including without limitation amendments (i) to require documentation of consent by a preexisting lender for any Program loan that is $30,000 or more, (ii) to establish $100,000 as the maximum amount of any Program loan, and (iii) to require fifty percent of funds available for Program loans to be reserved for energy efficiency upgrades and retrofits; and WHEREAS, on January 14, 2010, the City Council approved amendments to the Report following a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed amendments to the Program or any of its particulars, including without limitation amendments (i) to clarify the City's right of access to the project, (ii) to clarify the City's right to inspect property owners' books and records, (iii) to require certain annual certification from property owners, (iv) to require that property owners maintain property insurance covering the EIP improvement and provide evidence of such insurance prior to entering into the EIP Contract, (v) to require a minimum value -to -lien ratio, (vi) to require a nexus between the repayment term and the reasonably expected useful life expectancy of the EIP improvements, and (vii) to provide for the form of a notice required by Section 5898.24(d) of the Act (as amended by AB 474, adopted October 11, 2009 and effective January 1, 2010), for recordation in the Office of the Recorder of the County of Riverside concurrently with the creation of each new contractual assessment; and WHEREAS, Assembly Bill No. 44, Chapter 564 of Statutes of 2010 ("AB 44"), effective January 1, 2011, added Section 5898.15 to the California Streets and -1- P6401-0001\1337658v Ldoc RESOLUTION NO. 2011- 25 Highways Code, which provides that the City shall not permit a property owner to participate in the EIP if the owner's participation would result in the total amount of any annual property taxes and assessments exceeding 5 percent of the property's market value, as determined at the time of approval of the owner's contractual assessment on or after January 1, 2011; and WHEREAS, the Office of Energy Management has already implemented the requirements of Section 5898.15 of the California Streets and Highways Code with respect to any property owners applying for EIP financing on or after January 1, 2011; and WHEREAS, AB 44 also added Section 5898.23 to the California Streets and Highways Code, which provides that the report required pursuant to Streets and Highways Code Section 5898.22 in order to establish a contractual assessment program under the Act shall include safeguards that will be used to ensure that the requirements of Section 5898.15 are met; and WHEREAS, although the Report for the EIP was adopted prior to the adoption and effectiveness of AB 44, the City Council has determined that the best interests of the community and the EIP would be served by amending the Report to expressly state the requirement imposed by Streets and Highways Code Section 5898.15 and to set forth the method for verifying compliance with such requirement; and WHEREAS, on February 24, 2011, the City Council adopted its Resolution No. 2011-9 declaring its intention to further amend the Report and directing the Redevelopment Manager of the City (the "Redevelopment Manager") to prepare amendments to the Report to expressly state the requirement imposed by Streets and Highways Code Section 5898.15 and to set forth the method for verifying compliance with such requirement; and WHEREAS, the Redevelopment Manager has filed the proposed amendments to the Report, as described in Resolution No. 2011-9, with the City Clerk; and WHEREAS, Resolution No. 2011-9 set the time and place for a hearing on the proposed amendments to the Report; and WHEREAS, on March 24, 2011, following notice duly given in accordance with law, the City Council held a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed amendments to the Report; and WHEREAS, the City Council, having considered all oral and written testimony, desires to approve the amendments to the Report; NOW, THEREFORE, BE IT RESOLVED, DETERMINED, AND ORDERED BY THE CITY COUNCIL OF THE CITY OF PALM DESERT AS FOLLOWS: Section 1. The above recitals are all true and correct. -2- G:\rda\Martin Alvarez\2011\Staff Reports\Reso Approving Amndmnts - EIP Report (AB 44).docx RESOLUTION NO. 2011- 25 Section 2. The City Council declares that the amendments to the Report as filed are hereby approved. PASSED, APPROVED AND ADOPTED this 24th day of March 2011, by the following vote, to wit: AYES: NOES: ABSENT: ABSTAIN: Jean M. Benson, Mayor ATTEST: Rachelle D. Klassen, City Clerk -3- G:\rda\Martin Alvarez\2011\Staff Reports\Reso Approving Amndmnts - EIP Report (AB 44).docx RESOLUTION NO. 2011-9 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM DESERT DECLARING ITS INTENTON TO AMEND ENERGY INDEPENDENCE PROGRAM REPORT AND ADMINISTRATIVE GUIDELINES PREPARED PURSUANT TO SECTION 5898.22 OF THE CALIFORNIA STREETS AND HIGHWAYS CODE AND SETTING A PUBLIC HEARING THEREON WHEREAS, pursuant to Chapter 29 of Part 3 of Division 7 of the California Streets and Highways Code (the "Act"), the City Council established its Energy Independence Program (the "Program" or "TIP") to assist property owners with the cost of installing distributed generation renewable energy sources or making energy efficient improvements that are permanently fixed to their property; and WHEREAS, in connection with the Program and as required by the Act, the Director of the City's Office of Energy Management prepared a report (the "Report") in accordance with Section 5898.22 of the Act; and WHEREAS, the Report contains (a) a map showing the boundaries of the territory within which the Program is proposed to be offered, (b) a draft application for participation in the Program, (c) a draft contract (the "Contract") specifying the terms and conditions that would be agreed to by a property owner and the City for participation in the Program, (d) a statement of city policies concerning contractual assessments including: (1) identification of types of facilities, distributed generation renewable energy sources, or energy efficiency improvements that may be financed through the use of contractual assessments, (2) identification of a City official authorized to enter into contractual assessments on behalf of the City, (3) a maximum aggregate dollar amount of contractual assessments, (4) a method for setting requests from property owners for financing through contractual assessments in priority order in the event that requests appear likely to exceed the authorization amount, (e) a plan for raising a capital amount required to pay for work performed pursuant to contractual assessments, (f) a statement of or method for determining the interest rate and time period during which contracting property owners would pay any assessment, (g) the establishment of any reserve fund or funds, (h) the apportionment of all or any portion of the costs incidental to financing, administration, and collection of the contractual assessment program among the consenting property owners and the City, and (i) a report on the results of the consultations with the County Auditor -Controller's office; and WHEREAS, on August 28, 2008, the City Council approved the Report and established the Program following a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed Program or any of its particulars; and WHEREAS, on June 25, 2009, the City Council approved amendments to the Report following a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed amendments to the -1- o�em_nnmvi�u��z.,� .+..� Program or any of its particulars, including without limitation amendments (i) to require documentation of consent by a preexisting lender for any Program loan that is $30,000 or more, (ii) to establish $100,000 as the maximum amount of any Program loan, and (iii) to require fifty percent of funds available for Program loans to be reserved for energy efficiency upgrades and retrofits; and WHEREAS, on January 14, 2010, the City Council approved amendments to the Report following a full and fair public hearing at which interested persons were afforded the opportunity to object to, inquire about or provide evidence with regard to the proposed amendments to the Program or any of its particulars, including without limitation amendments (i) to clarify the City's right of access to the project, (ii) to clarify the City's right to inspect property owners' books and records, (iii) to require certain annual certification from property owners, (iv) to require that property owners maintain property insurance covering the EIP improvement and provide evidence of such insurance prior to entering into the EIP Contract, (v) to require a minimum value -to -lien ratio, and (vi) to require a nexus between the repayment term and the reasonably expected useful life expectancy of the EIP improvements; and WHEREAS, Assembly Bill No. 44, Chapter 564 of Statutes of 2010 ("AB 44"), effective January 1, 2011, added Section 5898.15 to the California Streets and Highways Code, which provides that the City shall not permit a property owner to participate in EIP on or after January 1, 2011 if the owner's participation would result in the total amount of any annual property taxes and assessments exceeding 5 percent of the property's market value, as determined at the time of approval of the owner's contractual assessment; and WHEREAS, the Office of Energy Management has already implemented the requirements of Section 5898.15 of the California Streets and Highways Code with respect to any property owners applying for EIP financing on or after January 1, 2011; and WHEREAS, AB 44 also added Section 5898.23 to the California Streets and Highways Code, which provides that the report required pursuant to Streets and Highways Code Section 5898.22 in order to establish a contractual assessment program under the Act shall include safeguards that will be used to ensure that the requirements of Section 5898.15 are met; and WHEREAS, although the Report for the EIP was adopted prior to the adoption and effectiveness of AB 44, the City Council has determined that the best interests of the community and the EIP would be served by amending the Report to expressly state the requirement imposed by Streets and Highways Code Section 5898.15 and to set forth the method for verifying compliance with such requirement; and WHEREAS, the City Council now desires to further amend the Report to expressly state the requirement imposed by Streets and Highways Code Section 5898.15 and to set forth the method for verifying compliance with such requirement. -2- n.�..�.,���.,.�:., NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF PALM DESERT HEREBY FINDS, DETERMINES, RESOLVES, AND ORDERS AS FOLLOWS: Section 1. The City Council hereby directs the Redevelopment Manager to prepare and file at or before the time of the public hearing described in Section 2 hereof with the City Council proposed amendments to the Report as described in the Recitals hereto. Section 2. The City Council hereby calls a public hearing to be held on March 24, 2011 at 4:00 p.m., or as soon thereafter as feasible, in the Council Chambers, 73-51 Fred < Waring Drive, Desert, California, on the proposed amendments to the Report. At the public hearing all interested persons may appear and hear and be heard and object to or inquire about the proposed amendments to the Report. Section 3. The City Clerk is hereby directed to provide notice of the public hearing by publishing this Resolution once a week for two weeks, pursuant to Section 6066 of the California Government Code, in the Desert Sun and the first publication shall not occur later than 20 days before the date of such hearing. PASSED, APPROVED AND ADOPTED this 24th day of February, 2011, by the following vote: AYES: NOES: ABSENT: ABSTAIN: ATTEST: Rachelle D. Klassen, City Clerk Jean M. Benson, Mayor -3- I��\.An\\An..�.. Klassen, Rachelle From: Martinez, Gloria Sent: Wednesday, March 09, 2011 8:34 AM To: Klassen, Rachelle Cc: Diana K. Chuang Subject: FW: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines FYI From: Moeller, Charlene [mailto:CMOELLER(cbpalmspri.gannett.coml Sent: Tuesday, March 08, 2011 5:21 PM To: Martinez, Gloria Subject: RE: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines Ad received and will publish on date(s) requested. Charlene Moeller I Media Sales Legal Notice Representative The Desert Sun Media Group 750 N. Gene Autry Trail, Palm Springs, CA 92262 t 760.778.4578 1 f 760.778.4731 IeaalsCabthedesertsun.com I dpwlegalsCa-.thedesertsun.com The Coachella Valley's #1 Source in News & Advertising! i T,� I twitter wN1% `>���� � = facebook M% l)c.wri.corl www.mydesert.com From: gmartinez(&cityofpalmdesert.org (mailto:gmartinez(d)cityofpalmdesert.orgl Sent: Tuesday, March 08, 2011 5:04 PM To: tds-legals Subject: FW: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines Charlene! PLEASE PUBLISH THE SUBJECT LEGAL NOTICE One additional time: SATURDAY, MARCH 12, 2011 if you have any questions or require additional information, please give me a call. Thank you! Records Technician City of Palm Desert 1 73-510 Fred Waring Drive Palm Desert, California 92260 (760) 346-0611 Ext. 354 gmartinez@cityofpalmdesert.org From: Martinez, Gloria Sent: Tuesday, March 01, 2011 5:20 PM To: 'legals@thedesertsun.com' Subject: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines PLEASE PUBLISH THE FOLLOWING: NOTICE OF PUBLIC HEARING Resolution No. 2011-9 — Declaring Its Intention to Amend Energy Independence Program Report and Administrative Guidelines Prepared Pursuant to Section 5898.22 of the California Streets and Highways Code and Setting a Public Hearing Thereon. TWICE IN THE DESERT SUN Thursday, March 10, 2011 Thursday, March 17, 2011 If you have any questions or require additional information, please give me a call. Thank you, Charlene! Records Technician City of Palm Desert 73-510 Fred Waring Drive Palm Desert, California 92260 (760) 346-0611 Ext. 354 gmartinez@cityofpalmdesert.org 2 Klassen, Rachelle From: Martinez, Gloria Sent: Thursday, March 03, 2011 5:01 PM To: Klassen, Rachelle Subject: FW: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines 0!1 From: Moeller, Charlene fmailto:CMOELLER(a)palmspri.gannett.coml Sent: Thursday, March 03, 2011 4:37 PM To: Martinez, Gloria Subject: RE: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines Ad received and will publish on the 5th and 10th as discussed.:-) Charlene Moeller I Media Sales Legal Notice Representative The Desert Sun Media Group 750 N. Gene Autry Trail, Palm Springs, CA 92262 t 760.778.4578 1 f 760.778.4731 legals(a)thedesertsun.com I dpwlegals(c)thedesertsun.com The Coachella Valley's #1 Source in News & Advertising! www.mvdesert.com I twitter rr M ; i )'- :rt facebook MI Dcsky .rl.c om From: gmartinez(acityofpalmdesert.org [mailto:gmartinez(a-cityofpalmdesert.orcil Sent: Thursday, March 03, 2011 4:34 PM To: tds-legals Subject: FW: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines Charlene! Is it at all possible for you to publish this notice on Saturday, PLEASE!!!!!!! From: Martinez, Gloria Sent: Tuesday, March 01, 2011 5:20 PM To: 'legals@thedesertsun.com' Subject: Legal Notice - Res No. 2011-9 PH 03/24/11 Amnd EIP Report & Admin Guidelines PLEASE PUBLISH THE FOLLOWING: NOTICE OF PUBLIC HEARING Resolution No. 2011-9 — Declaring Its Intention to Amend Energy Independence Program Report and Administrative Guidelines Prepared Pursuant to Section 5898.22 of the California Streets and Highways Code and Setting a Public Hearing Thereon. 1 TWICE IN THE DESERT SUN Thursday, March 10, 2011 Thursday, March 17, 2011 If you have any questions or require additional information, please give me a call. Thank you, Charlene! Records Technician City of Palm Desert 73-510 Fred Waring Drive Palm Desert, California 92260 (760) 346-0611 Ext. 354 gmartinez@cityofpalmdesert.org PALM DESERT Energy Independence Program Report and Administrative Guidelines Outline Introduction Goals Background Benefits Program Administration Program Requirements Eligible Property Owners Eligible Properties Consent Agreement Eligible Equipment Eligible Costs Tracks for Participation The Efficiency Track The Solar Track The Custom Measure Track Financial Strategy Energy Surveys Energy Independence Program Parameters Minimum Loan Amount Maximum Loan Amount Maximum Portfolio Assignment of Rebates and Incentives Duration Interest Rate Administrative Fees Changes to Report Appendices A. Equipment List B. Map of Program Area C. Draft Program Application D. Draft Loan Contract E. Summary of Loan Process F. Consent Agreement G. Notice of Assessment H. Payment of Contractual Assessment Required Revised March 44-,2WB74,= In each case, the Office of Energy Management will determine whether the estimated equipment and installation costs are reasonable. The OEM will evaluate market conditions and may require additional bids to determine whether costs are reasonable. While the property owner will be able to select the bidder of his or her choice, the amount available for the EIP Loan may be limited to an amount deemed reasonable by the OEM, and may be reviewed by the City Manager and the Pahn Desert City Council. Credit Criteria for Ellgibility Satisfaction of the credit criteria for eligibility is required for participation in the Program, in order to reduce risk for both the property owner and the City. BothA11 b= of the tests below must be met, at the time of the application approval: L Rumen! Term —the term of the FIP Luan shall not exceed the reasonahlyex nsefiil life a ce_tancy of the Fnera Improvements financed by the EIP Loan. "Uselijl life ec� t,ann ,v" shall he determined in accordance with the then current �,li y maintained JZL the OEM which policy establishes reasonahly expected nseffil life ex e,R�an,cv for the n=s. of the .IP a, For properties participating with regmet to multiple j=es of F.ner= Improvements expected uselij He xnectansy shall be calculated on a w ight dr I�asis weiabteed 4 cost valuer offach iwVrovemenL jy Exceptions to the reA3vment term limitation shove may he granted 12Y the City Manager to provide for a longer rcpa=ent term (nn to a maximum of the reasonably expected lisclul lif xnectancv of the Fnerov Improvements I; % S years), upon suffi i to evidence provided by the =pWy owner_ of the fiscal =deny and rationale for such excofinn_ The determinations of whether the, evidence is s uffi i nt and whether or not to ¢rant an exception shall be in the City Manager's sole discretion and shall he final 2 4—.Yahw_LQ-Lien RaLw —the ratio of (a) the value of the property to (b) the sum of the amount of (i) the requested amount of the EIP Loan (including contingency) and (ii) the amount all other liens on the property securing a special tax levied pursuant to the Mello -Roos Community Facilities Act of 1982, a special assessment, or any other contractual assessment (e.g., EIP Loan), must be at least 10:1. a. "Value of the property" will be determined as.W the assessed value of the property, as reflected on the County Assessor's most current tax roll- or (iii) if the MoperLy was recently purchased by t_heprr pcM owner and the sale price has not yet been reflected on the Cguaty Assessor's most current tax roll the gale price of the pry eprty as established by piochnse and sale documentation providedthe =WJU owner to the ORM in fnrm and substance satisfactory to_ and :r} rnved by, the OEM (in its sole discretion)) and lelegal o tnc t c-I to City, In the alternative, the property owner may request the City to have an appraisal (in form and substance acceptable to the City and from an appraiser of City's choice) conducted on the property, at the cost of the property owner, for the purpose of establishing the value of the property. In each case, the Office of Energy Management will determine whether the estimated equipment and installation costs are reasonable. The OEM will evaluate market conditions and may require additional bids to determine whether costs are reasonable. While the property owner will be able to select the bidder of his or her choice, the amount available for the EIP Loan may be limited to an amount deemed reasonable by the OEM, and may be reviewed by the City Manager and the Pahn Desert City Council. Credit Criteria for Eligibility Satisfaction of the credit criteria for eligibility is required for participation in the Program, in order to reduce risk for both the property owner and the City. Be9jA II b= of the tests below must be met, at the time of the application approval: L RRal1 yment Term —the term of the FIP 1,Uan Shall not exceed the r asnnab`X 01jertea nsef it life expectancy of the Energy im+ mvements financed by the RIP Loan "IJseful He �TUiII iit MiY.VIlt4Mi l' u L Fxcentions to the repayment term limitation above may he granted by the City Manager_ to provide for a longer repayment term (yp to a maximum of the reasonably expected uschil life xpectancy of the F.nQ= luallroyements plus ve rc upon cpffi i nt exidence,provided by the pw=y owner. of the fiscal prudency and rationale for %ncb x tion The determinations of whether the evidence is sufficient and whether or not to grant an exception shall he in the city Manager's sole discretion and shall be final 2_ 4-value-ta Lien Ratio — the ratio of (a) the value of the property to (b) the sum of the amount of (i) the requested amount of the EIP Loan (including contingency) and (h) the amount all other liens on the property securing a special tax levied pursuant to the Mello -Roos Community Facilities Act of 1982, a special assessment, or any other contractual assessment (e.g., EIP Loan), must be at least 10:1. a. "Value of the property" will be determined as.11l the assessed value of the property, as reflected on the County Assessor's most current tax roll. or ij if the property was recently purchased by the pru=g owner and the sale price has not vet bcen =fl he C'o mty Assessor's most cnayul tax roll the sale r�}, ice of the property ac established by purchase and sale documentation pmvided the pronertv owner to the OEM in farm and c h n e catisfa tort' to d approved lit'- the OEM (nits Sole discretion) and legal counsel to the City. In the alternative, the property owner may request the City to have an appraisal (in form and substance acceptable to the City and from an appraiser of City's choice) conducted on the property, at the cost of the property owner, for the purpose of establishing the value of the property. b. Exceptions to the m nimum 10:1 value -to -lien ratio may be granted by the City Manager (to a minimum of an 8:1 value -to -lien ratio), upon sufficient evidence, provided by the property owner, of the fiscal prudency and rationale for such exception. The determinations of whether the evidence is sufficient and whether or not to grant an exception shall be in the City Manager's sole discretion and shall be final. establishes teitseffably-expeete4-uieP&Ptk-e*peetaney-kp4he- p_= . se—� a, weighted b 3. jDtaZAjjuLgaj Prnnrriv Tireve an J A=UQ?C rl the total anionnt nf� tazes�ecementc cha11 nor exceed five Heir nt / /) of tl arl t I ert v nrnn=y Tracks for Participation There are three ways for property owners to participate in the Program. Eligible equipment and standards are presented in greater detail in Appendix A: EIP Loans will be made for the initial $2.5 million an annual interest rate not to exceed 7% for all loans. Thereafter, the City Council will maintain the discretion to adjust the interest rate up to an amount not to exceed 10%. The Council will determine interest rates so that the Energy Loan Fund remains financially viable up to the legal limit. The City will set the interest rate for an EIP Loan at the time that the City and property owner enter into the contractual assessment agreement. The City of Pahn Desert will offer the Energy Independence Program as an additional City service that will help property owners achieve their energy goals, while helping the City achieve its energy and climate protection goals. The City of Palm Desert will be responsible for all EIP marketing and outreach, as well as the duties of the Office of Energy Management. The City may elect to cover a portion of its costs through the "spread" between its combined earnings rate, and the EIP Loan issuance rate. Similarly, it may elect to recover EIP costs through a spread between bond rates and loan rates, or the spread between interest rates of any financial vehicle. The City will not charge property owners a fixed administrative fee. Two forms of costs will be the responsibility of the property owner: 1. Title costs — including title insurance — will be paid by the property owner. 2. Assessment collection costs will appear as a line item on property taxes not to exceed $40 per property per year and will be paid by property owner. This cost was determined after consultation with the County of Riverside Assessor's Office. Additionally, if the property owner requests the City to cause an appraisal to be conducted for the pnrpesepugw= of determining the `value of the property" f - the pufliese ef the satis6ing the wAnimum value fatieor "market value of the llroj=3f in connection with credit eligibility fegeirementrmtluirements described above, the cost of the appraisal will be paid by the property owner. Changes to Report The Director or City Manager may make changes to this Report that the Director or City Manager reasonably determines are necessary to clarify its provisions. Any changes to this Report that materially modify the Energy Independence Program shall only be made after approval by the City Council. The City Manager or Director may modify from time to time the Equipment List, draft Loan Contract and draft Application attached hereto as Appendix A, Appendix D and Appendix C, respectively, as deemed necessary by the City Manager or the Director to effectuate the purposes of the Program. 10 b. Exceptions to the minimum 10:1 value -to -lien ratio may be granted by the City Manager (to a minimum of an 8:1 value -to -lien ratio), upon sufficient evidence, provided by the property owner, of the fiscal pendency and rationale for such exception. The determinations of whether the evidence is sufficient and whether or not to grant an exception shall be in the City Manager's sole discretion and shall be final. ... L Tracks for Participation There are three ways for property owners to participate in the Program. Eligible equipment and standards are presented in greater detail in Appendix A: