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Agenda 06/11/2019 Item #9B (Pace Ordinance)06/11/2019 EXECUTIVE SUMMARY Recommendation to further discuss the adoption of the Collier County Property Assessed Clean Energy (PACE) Consumer Protection Ordinance to better protect the public by providing additional requirements. _____________________________________________________________________________________ OBJECTIVE: To further discuss the Collier County Property Assessed Clean Property Assessed Clean Energy (PACE) Consumer Protection Ordinance to better protect the public by providing for more restrictive or additional requirements not found in the PACE Statute or the Standard Membership Agreement. CONSIDERATIONS: This matter was first brought to the Board by Commissioner Taylor on March 12, 2019 as Item 10B. At the Board of County Commissioners March 26, 2019 meeting, the Board directed the County Manager to work with all stakeholders to identify opportunities to provide additional consumer protection, and to bring back at a future regular meeting an executive summary creating an Ordinance that addresses the concerns brought forth by the Board. This was further discussed at the May 14, 2019 and May 28, 2019 regular Board meetings. The Board of County Commissioners voted at its regular meeting of May 28, 2019 to terminate the Property Assessment Clean Energy (PACE) program pursuant to paragraph 18 of the Standard Form Membership Agreement and instructed the County Manager to bring back a PACE Consumer Protection Ordinance for consideration. Staff has worked with the interested parties to prepare an Ordinance that tries to balance consumer protections and maintain a viable program. The item, as presented, does not include a solar energy component as an allowable use for the PACE program. This exception may still require further discussion and direction from the Board. Background In 2010, the State of Florida passed its PACE enabling statute, F.S. Section 163.08, in an effort to promote energy efficiency, renewable energy, and wind resistance/hardening measures for residential, commercial, and industrial buildings throughout the State of Florida. The PACE program is a method of public financing designed to have “qualifying improvements” paid for through a special tax assessment, on the property, which would allow project expenditures to be spread out over a term up to 30 years and repaid as part of a property owner’s tax bill. As outlined in Section 163.09(2)(b), Florida Statutes, eligible PACE improvements are limited to: energy efficiency (including electric vehicle charging equipment) renewable energy equipment and wind resistance/hurricane mitigation measures. PACE financing is a land-secured assessment that property owners voluntarily undertake in order to secure 100% up-front financing of a qualifying improvement, which includes fees and interest o ver the term of the PACE assessment. PACE loans are unique in that they take priority over other traditional liens, regardless of the date the prior liens were recorded. In addition to economic and property value benefits, PACE also presents benefits in terms of resource conservation, environmental protection, and hurricane preparedness. By removing barriers to implementation of energy efficiency and renewable energy projects, PACE could result in decreased use of energy and a shift to cleaner energy sources, decreasing air pollutants, and greenhouse gases. Florida’s inclusion of resiliency projects in the list of eligible types could also increase the number of properties with hurricane preparedness improvements. 9.B Packet Pg. 201 06/11/2019 In 2017, by Resolution No. 2017-130, the Board of County Commissioners adopted a Resolution establishing the Property Assessment Clean Energy (PACE) program within the unincorporated areas of Collier County for residential, commercial and industrial properties. Since that time, by Resolution No s. 2017-127, 2017-128, 2017-129, and 2017-153, four PACE providers have entered into the standard membership agreement and are operating a PACE program within Collier County. It has been reported that potential abuses of the PACE program have taken place, largely from a minority of PACE program contractors, which the proposed new Ordinance seeks to address. This item was discussed by the Board on March 12, 2019 and then on March 26, 2019, where the Board directed the County Manager to work with the PACE providers, the Collier Building Industry Association (CBIA) and local housing organizations to bring back an updated Ordinance for consideration that enhanced consumer protections while allowing the PACE providers to continue to operate within unincorporated Collier County. Research Staff conducted a review of the current liens filed with the Collier County Tax Collector and requested information from each of the four PACE providers to better understand how the current program is functioning. The primary focus was on work performed, licensed contractor, permit issued, project certificate of completion from the County, loan to appraised value, terms of loan, and the annual PACE assessment owed. Staff was provided with feedback from Pasco and Palm Beach County and further researched consumer protections within PACE programs throughout the state. This Executive Summary, together with the attached documents, is intended to address concerns and provide for additional consumer protections that are not currently identified within Resolution Nos. 2017- 130, 2017-127, 2017-128, 2017-129, and 2017-153. Considerations for the Board The purpose of the current PACE Program is to facilitate the financing of qualifying improvements in accordance with Section 163.08, Florida Statutes, for County property owners within unincorporated Collier County, including residential, commercial and industrial properties. This new Ordinance provides for more restrictive and/or additional requirements not found in the PACE Statute, th e Standard Membership Agreement or any other applicable law. FISCAL IMPACT: A PACE program review and approval process by County staff would have a future financial impact on the County General Fund of $30,000 per year. It is the responsibility of PACE Provider and a Third-Party Administrator to secure the private financing necessary for the implementation of the program, and they are responsible for recovering any losses in the event of defaults on the assessments. They cover the costs of collecting the assessments and administrative costs through their fees and interest rates. GROWTH MANAGEMENT IMPACT: There is no Growth Management Impact associated with this action. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and legality, and requires majority vote for approval. -JAK RECOMMENDATION: That the Board of County Commissioner adopt the Collier County Property Assessed Clean Energy (PACE) Consumer Protection Ordinance to better protect the public by providing 9.B Packet Pg. 202 06/11/2019 additional requirements and reconsider the decision to terminate the PACE program and associated membership agreements identified within Collier County Resolutions Nos. 2017-130, 2017-127, 2017- 128, 2017-129, and 2017-153. Prepared by: James French, Deputy Department Head, Growth Management Department ATTACHMENT(S) 1. Ordinance PACE Consumer Protection - Final (JCF_v7) (PDF) 2. PACE program - Customer Disclosure Agreement Final (JFv5) (003) (PDF) 3. Legal Ad - PACE - 5-31-19 (PDF) 9.B Packet Pg. 203 06/11/2019 COLLIER COUNTY Board of County Commissioners Item Number: 9.B Doc ID: 9020 Item Summary: ***This item to be heard at 1:00 p.m.*** This item has been continued from the May 14, 2019 BCC meeting.*** Recommendation to further discuss the adoption of the Collier County Property Assessed Clean Energy (PACE) Consumer Protection Ordinance to better protect the public by providing additional requirements. (James French, Deputy Department Head, GMD) Meeting Date: 06/11/2019 Prepared by: Title: Operations Analyst – Growth Management Operations & Regulatory Management Name: Judy Puig 06/05/2019 9:11 AM Submitted by: Title: Division Director - Operations Support – Growth Management Operations & Regulatory Management Name: Kenneth Kovensky 06/05/2019 9:11 AM Approved By: Review: Growth Management Department MaryJo Brock Level 1 Reviewer Skipped 06/04/2019 1:15 PM Growth Management Department Jeanne Marcella Department Head Review Completed 06/05/2019 9:43 AM Growth Management Department James C French Deputy Department Head Review Completed 06/05/2019 11:32 AM Office of Management and Budget MaryJo Brock Level 3 OMB Gatekeeper Review Skipped 06/04/2019 1:15 PM Office of Management and Budget MaryJo Brock Additional Reviewer Skipped 06/04/2019 1:15 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 06/05/2019 11:36 AM County Manager's Office Nick Casalanguida Level 4 County Manager Review Completed 06/05/2019 2:24 PM Board of County Commissioners MaryJo Brock Meeting Pending 06/11/2019 9:00 AM 9.B Packet Pg. 204 Page 1 of 4 ORDINANCE NO. 2019 - _____ AN ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA, ADOPTING THE COLLIER COUNTY PROPERTY ASSESSED CLEAN ENERGY (PACE) CONSUMER PROTECTION ORDINANCE; PROVIDING FOR CONFLICT AND SEVERABILITY; PROVIDING FOR INCLUSION IN THE CODE OF LAWS AND ORDINANCES; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, individual residents of Collier County may wish to improve energy efficiency, install energy improvements or retrofits, wind resistance/wind hardening measures, and improve water conservation for residential, commercial or industrial properties; and WHEREAS, one way to facilitate such improvements to real property is through a Property Assessment Clean Energy (PACE) financing program pursuant to Section 163.08, Florida Statutes; and WHEREAS, a PACE financing program is a financing structure by which commercial or residential property owners may voluntarily opt into a special assessment district to receive a loan to finance energy improvements and retrofits, where those loans are repaid through an annual assessment on the property owner's property tax bill; and WHEREAS, PACE providers that have been created under Section 163.01(7) Florida Statutes are considered local governments, and the County may select from those PACE providers and enter into agreements with the selected providers, without proceeding with a solicitation; and WHEREAS, by Resolution No. 2017-130, the Board (1) approved the establishment of a PACE program within the unincorporated area of Collier County for residential, commercial and industrial properties; and (2) approved a standard form membership agreement which would among other things authorize a PACE provider to operate a PACE program within Collier County; and WHEREAS, a number of PACE providers have entered into the standard membership agreement and are operating a PACE program within Collier County; and WHEREAS, it has come to the Board’s attention that potential abuses of the PACE program have taken place, which the Board wishes to correct and address by this Ordinance. NOW, THEREFORE, BE IT ORDAINED BY THE BOARD OF COUNTY COMMISSIONERS OF COLLIER COUNTY, FLORIDA, that: SECTION ONE: Title and Intent This Ordinance shall be known and cited as “The Collier County Property Assessed Clean Energy (PACE) Consumer Protection Ordinance," and is intended to add requirements to the provisions of Section 163.08, Florida Statutes, the Standard Membership Agreement and other applicable law as it currently exists and should be construed consistently with the PACE Statute and any such other applicable law. To the extent that the PACE Statute provides for additional 9.B.1 Packet Pg. 205 Attachment: Ordinance PACE Consumer Protection - Final (JCF_v7) (9020 : **PACE Program Modification) Page 2 of 4 requirements not otherwise found in this Ordinance or applicable law; the provisions of the PACE Statute must be met. To the extent that this Ordinance provides for more restrictive or additional requirements not found in the PACE Statute, the Standard Membership Agreement or any other applicable law, the provisions of this Ordinance shall apply. SECTION TWO: Definitions The following words, terms and phrases, when bolded and used in this Ordinance, shall have the meanings set forth herein: Board shall mean the Collier County Board of County Commissioners. PACE Assessment shall mean the non-ad valorem assessment placed on a property owner's tax bill as a result of financing obtained through a PACE Provider. PACE Financing Agreement shall mean the agreement entered into between a property owner and the PACE Provider or its administrator specifying the Qualifying Improvements to be installed at the property and the terms and conditions for financing those improvements through non-ad valorem assessments levied on the property. PACE Provider shall mean an entity created pursuant to the PACE Statute that has entered into a Standard Membership Agreement. PACE Statute shall mean Section 163.08, Florida Statutes, as may be amended from time to time. Qualifying Improvements shall mean only those improvements defined by the PACE Statute. Standard Membership Agreement shall mean the Board-approved standard form agreement as described in Resolution 2017-130 and as entered into by the PACE Provider. SECTION THREE: PACE Program Standards At a minimum, PACE Providers shall comply with each of the following standards: (1) Qualifying Improvements: PACE Providers shall finance, and contractors and owner- builders shall construct or install, only Qualifying Improvements, which shall be properly permitted and must comply with Florida and local codes. (2) Customer Service: PACE Providers shall provide a high level of customer service, including: a. Access to customer service representatives by email and phone during normal business hours; b. A transparent customer feedback and complaint process with quick response and resolution by both the contractor and the PACE Provider; c. All complaints and resolutions shall be logged, with the following information at a minimum: date and time of complaint, customer and contractor information, 9.B.1 Packet Pg. 206 Attachment: Ordinance PACE Consumer Protection - Final (JCF_v7) (9020 : **PACE Program Modification) Page 3 of 4 details of complaint, when and what actions were taken by both the PACE Provider and the contractor, and final resolution; and d. All disputes and complaints shall be investigated and resolved in a timely manner. Reports of such disputes and complaints, the actions taken and how they were resolved, or not resolved, shall be created and thereafter be treated as Public Records and provided to Collier County, upon request. (3) Additional Program standards for residential properties: In addition to requirements set forth in Section 163.08, Florida Statutes, PACE Providers that finance Qualifying Improvements on residential properties within Collier County shall: a. Verify that each prior mortgage or financing instrument holder has been notified of any proposed PACE Financing Agreement and PACE Assessment, or that the mortgage or financing instrument holder or loan servicer has consented to escrow sufficient funds to ensure payment of the annual assessment with each year's tax bill; and b. Prior to entering into a PACE Financing Agreement, require the property to file with Collier County a Collier County issued PACE Customer Disclosure Document that provides detailed PACE Assessment consumer information, which Document must be signed by the property owner, notarized, and submitted to a designated Collier County employee for review and approval; and c. Supplementing subsection (12)(a) the PACE Statute, ensure that the total amount of any and all PACE Assessments on any property does not exceed an aggregate amount of twenty percent (20%) of the just value of the property as determined by the County’s property appraiser; and d. Ensure that the total amount of any annual taxes and assessments do not exceed five percent (5%) of the property’s fair market value, determined at the time financing is approved and ensure that the total amount of the annual Pace Assessments do not exceed four percent (4%) of the total annual gross income of the property owner in the prior calendar or fiscal year, based upon an affidavit or attestation by the property owner of the owner’s total annual gross income; and e. Limit the financing term to ensure it does not exceed the amount of time identified in the product manufacture’s original stated warranty for the Qualified Improvements; and f. Not process any PACE Assessments against the property owner until the Qualifying Improvements on that property have received a Certificate of Completion from Collier County; and g. Not be used to finance residential solar panel projects. (4) Documents: Within 10 business days following written request by the County, the PACE Provider shall provide the County at no cost to the County any and all requested records including , but not limited to, construction, financial, correspondence, instructions, memoranda, bid estimate sheets, proposal documentation, back charge documentation, canceled checks, reports, customers property status of improvements, disbursements, and all other related records produced and maintained by the PACE District, it’s employees, contractors, and consultants. Records shall be deemed as public records in accordance with section 119.01 Florida Statute, General State Policy on Public Records. 9.B.1 Packet Pg. 207 Attachment: Ordinance PACE Consumer Protection - Final (JCF_v7) (9020 : **PACE Program Modification) Page 4 of 4 SECTION FOUR: Penalty for Violations Violation of any provision of this Ordinance shall be punishable by a fine not exceeding $500. All violations of this Ordinance may be processed according to the Collier County Consolidated Code Enforcement Ordinance (Ord. No. 2010-04, as amended) and per provisions of Chapter 162, pts. I or II, Florida Statutes, as may be applicable. In addition to the imposition of a fine, based upon a finding of a violation either of this Ordinance or the PACE Statute by the Code Enforcement Board or Special Magistrate, the Board may direct the Collier County Tax Collector to remove the PACE Assessment from the property which is the subject of the violation, and may immediately terminate for cause the Standard Membership Agreement. SECTION FIVE: Conflict and Severability In the event this Ordinance conflicts with any other ordinance of Collier County or other applicable law, the more restrictive shall apply. If any phrase or portion of the Ordinance is held invalid or unconstitutional by any court of competent jurisdiction, such portion shall be deemed a separate, distinct and independent provision and such holding shall not affect the validity of the remaining portion. SECTION SIX: Inclusion in the Code of Laws and Ordinances The provisions of this Ordinance shall become and be made a part of the Code of Laws and Ordinances of Collier County, Florida. The sections of the Ordinances may be renumbered or relettered to accomplish such, and the word "ordinance" may be changed to "section," "article," or any other appropriate word. SECTION SEVEN: Effective Date This Ordinance shall become effective upon receipt of notice from the Secretary of State that this Ordinance has been filed with the Secretary of State. PASSED AND DULY ADOPTED by the Board of County Commissioners of Collier County, Florida, this _______ day of _____________________, 2019. ATTEST: BOARD OF COUNTY COMMISSIONERS CRYSTAL K. KINZEL, Clerk COLLIER COUNTY, FLORIDA By: ___________________________ By: _____________________________ , Deputy Clerk W. L. McDaniel, Jr., Chairman Approved as to form and legality: _______________________________ Jeffrey A. Klatzkow, County Attorney 9.B.1 Packet Pg. 208 Attachment: Ordinance PACE Consumer Protection - Final (JCF_v7) (9020 : **PACE Program Modification) 1 Collier County – Residential PACE Program Disclosure ______ Initials PROPERTY ASSESSMENT CLEAN ENERGY (PACE) PROGRAM RESIDENTIAL CUSTOMER DISCLOSURE AGREEMENT This form must be initialed, signed, and notarized before being filed with Collier County for review and approval prior to the execution of the PACE Financing Agreement The review process will include, at a minimum, a discussion with the applicant, which may be by telephone, to ensure that the applicant is aware of the Program’s requirements and to answer any questions by the applicant. THINGS YOU SHOULD KNOW ABOUT PARTICIPATING IN THE RESIDENTIAL PROPERTY ASSESSED CLEAN ENERGY (PACE) PROGRAM What is the Residential PACE program? PACE or Property Assessed Clean Energy Program is a government sponsored program that is used in Florida to finance energy efficiency improvements, renewable energy improvements and wind resistance improvements. Is the PACE program free for me? The PACE Program is not free. To participate in the program, you must qualify for the PACE funds that finance the improvements. You owe the amount of the PACE lien plus interest, which is paid in installments as an additional line item on your property tax bill. When the assessment is paid off in full, the lien will be removed, and you will no longer see this line item on your property tax bill. 9.B.2 Packet Pg. 209 Attachment: PACE program - Customer Disclosure Agreement Final (JFv5) (003) (9020 : **PACE Program Modification) 2 Collier County – Residential PACE Program Disclosure ______ Initials How do I qualify for the financing? The law requires that to qualify you must have paid all your property taxes and not have been delinquent for the last 3 years, that there are no involuntary liens on your home and no notices to default and that you are current on your mortgage. The PACE Program is not required to look at whether your family budget can afford the additional loan. How do I repay the PACE funds? The PACE Program funds are paid with your property tax assessment. If you have a mortgage, your lender may include the property taxes in your monthly payment. If so, your monthly mortgage payment will increase accordingly. However, your mortgage lender will typically not make the adjustment until they receive the first tax bill with the assessment. Do I pay interest for the financing? PACE Programs charge interest over the repayment term you selected (up to 30 years). Please review the Financing Estimate to see the interest rate applicable to your PACE assessment, which may be higher than other financing options available to you. You should ask about any low interest loans available, like utility sponsored programs, federal weatherization programs or a lower rate loan at your bank or credit union with a second mortgage or a home equity line of credit. Are there other costs? PACE Program assessments also charge borrowers an up-front free, typically based on a percentage of project costs, and an administration fee based on a percentage of the annual payment, which is payable each year during the repayment term you selected. Please review the Financing Estimate to see the fees application to your PACE assessment. What happens If I am not happy with the improvements? A licensed contractor must do all PACE program improvements requiring a license under applicable law. However, your recourse against the contractor if you are not happy with the improvements may be limited by the nature of the PACE Program financing. That is why it is important to carefully select the contractor and read all paperwork carefully. 9.B.2 Packet Pg. 210 Attachment: PACE program - Customer Disclosure Agreement Final (JFv5) (003) (9020 : **PACE Program Modification) 3 Collier County – Residential PACE Program Disclosure ______ Initials For energy improvements, does the contractor have to give me an energy audit? The law does require any verification of energy savings for improvements to your home from a PACE Program loan. Any figures about energy savings given to you by a contractor would need to be independently verified by you. What happens if I have trouble making the increased tax payment? If you default on your PACE Program loan by failing to pay your property taxes, a tax certificate will be sold on the property. After two years of an unpaid tax certificate, your home could be sold through the Tax Deed Application process. Failure to pay your PACE assessment can result in your losing your home. Can I refinance my home while I still am making payments on my PACE Program Loan? PACE Program loans may impede your ability to refinance your home loan or to receive a home loan modification because some lenders will not want to enter into a new loan terms while a PACE Program loan is assessed against your home. You may be required to prepay PACE assessment as a requirement to refinancing. Can I sell my home before I have paid off the PACE Program loan? The PACE Program lien is automatically transferred to the buyer when you sell your home. BUT Fannie Mae, Freddie Mac, the Federal Housing Administration and the Department of Veterans Affairs may not insure mortgages with PACE assessments. Other lenders are not required to accept PACE Program liens. As a result, you may be required to prepay the PACE assessment as a requirement to selling your home. What is the most important thing I can do to protect myself? 1. Take your time before you sign any documentation. 2. Ask for and read all documentation relating to a PACE Program financing. 3. Get multiple estimates from licensed and insured contractors, other County approved PACE Program providers, and financial lenders to ensure that you are receiving the most competitive prices and the best value. 4. Make sure that your contractor acquires all necessary permits from the County, a Certificate of Completion from the County after the project is completed, and the project is signed off to your satisfaction. 9.B.2 Packet Pg. 211 Attachment: PACE program - Customer Disclosure Agreement Final (JFv5) (003) (9020 : **PACE Program Modification) 4 Collier County – Residential PACE Program Disclosure ______ Initials 5. Make sure that your contractor files a Notice of Commencement signed by you and filed with the Collier County Clerk of Courts. 6. Make sure that you ask for a printed copy of all documentation and warranties. 7. Do not sign anything that you do not understand. MAKE SURE YOU ASK FOR A PRINTED COPY OF ALL DOCUMENTS TO READ BEFORE YOU ALLOW ANYONE TO WORK ON YOUR HOME. KNOW BEFORE YOU OWE Please fill out the following: Full Legal Name: _____________________________________________________ Phone Number: Area Code ( ) _____ - ________ Physical Address: ____________________________________________________ Parcel Number: _____________________________________________________ Estimated Annual Payment: $ _____________________________ (Cannot exceed 4% of the total annual gross income of the property owner in the prior calendar or fiscal year) Total Assessment Amount: $ ____________________________ (Includes financing amount, interest charges and fees) Total Length of Assessment in Years: _____________ (Cannot exceed the manufactures original stated warranty) Estimated Tax Year First Payment Due: ___________________________ Annual Tax with PACE Assessment payment: ___________________________ (Cannot exceed 5% of the property’s fair market value as determined by the Collier County Property Appraiser at time of financing) 9.B.2 Packet Pg. 212 Attachment: PACE program - Customer Disclosure Agreement Final (JFv5) (003) (9020 : **PACE Program Modification) 5 Collier County – Residential PACE Program Disclosure ______ Initials I have read the above and I understand the information provided to me. I also understand there are other financing options possibly available and this is not a free program. I also acknowledge there are other PACE contractors and PACE providers I may choose from. Signature: ___________________________________________ (Property Owner) Signature: ___________________________________________ (Property Owner) Signature: ___________________________________________ (Property Owner) Signature: ___________________________________________ (Property Owner) ------------------------------------------------------------------------------------------------------------- State of Florida, County of Collier The foregoing instrument was acknowledged before me this ________ day of _____________________, 20______. by ___________________________________________________________ and __________________________________________________ (Property owner(s)) ☐ Personally Known to me ☐ Has produced identification _______________________ Notary Signature: __________________________________ Seal Entire package must be submitted for review and processing Collier County Representative: ___________________ _________________________ Y - N (circle one) Date received Printed Name Approval 9.B.2 Packet Pg. 213 Attachment: PACE program - Customer Disclosure Agreement Final (JFv5) (003) (9020 : **PACE Program Modification) 9.B.3 Packet Pg. 214 Attachment: Legal Ad - PACE - 5-31-19 (9020 : **PACE Program Modification)