Agenda 05/14/2019 Item #11E (Property Assessed Clean Energy/PACE)05/14/2019
EXECUTIVE SUMMARY
Recommendation to direct the County Attorney to advertise and bring back for a public hearing an
ordinance to be known as “The Collier County Property Assessed Clean Energy (PACE)
Consumer Protection Ordinance.”
_____________________________________________________________________________________
OBJECTIVE: To better protect the public by providing for more restrictive or additional requirements
not found in the PACE Statute, the Standard Membership Agreement or any other applicable law.
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.
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 over 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.
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 Nos.
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
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(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
On April 2, 2019 GMD Staff and the County Attorney’s Office hosted a meeting with the four approved
PACE providers, community members, housing organizations, and the CBIA to speak about issues
reported with the current program and suggested consumer protection best practices, requesting that each
of the participants provide input and feedback within ten business days. Thirty -eight invitations were
sent, and twenty-two participants attended the meeting in person or by teleconference.
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, the Standard
Membership Agreement or any other applicable law. The attached presentati on highlights the research
conducted, changes proposed, and facts regarding the program.
FISCAL IMPACT: A PACE program would not have a current or future financial impact on the County
budget. 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. There will be limited County staff involvement
with administering and providing oversight to this program.
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 directs the County Attorney to advertise and bring back for a
public hearing an ordinance to be known as “The Collier County Property Assessed Clean Energy
(PACE) Consumer Protection Ordinance.”
Prepared by: James French, Deputy Department Head, Growth Management Department
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ATTACHMENT(S)
1. PACE Ordinance Revised Red-Line (PDF)
2. PACE Ordinance - JAK signed - 5-2-19 (PDF)
3. 5-3-19 PACE FINAL Power Point (PDF)
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COLLIER COUNTY
Board of County Commissioners
Item Number: 11.E
Doc ID: 8578
Item Summary: *** This item to be heard no sooner than 1:00 PM. *** Recommendation to
direct the County Attorney to advertise and bring back for a public hearing an ordinance to be known as
“The Collier County Property Assessed Clean Energy (PACE) Consumer Protection Ordinance.” (James
French, Deputy Department Head, GMD)
Meeting Date: 05/14/2019
Prepared by:
Title: Operations Analyst – Growth Management Operations & Regulatory Management
Name: Judy Puig
05/03/2019 3:32 PM
Submitted by:
Title: Dept Head - Growth Management – Growth Management Department
Name: Thaddeus Cohen
05/03/2019 3:32 PM
Approved By:
Review:
Growth Management Department Judy Puig Level 1 Reviewer Completed 05/03/2019 3:32 PM
Growth Management Department James C French Deputy Department Head Review Completed 05/03/2019 3:53 PM
Growth Management Department Thaddeus Cohen Department Head Review Completed 05/07/2019 3:24 PM
Office of Management and Budget Valerie Fleming Level 3 OMB Gatekeeper Review Completed 05/07/2019 3:36 PM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 05/07/2019 3:50 PM
Office of Management and Budget Laura Zautcke Additional Reviewer Completed 05/08/2019 8:09 AM
County Manager's Office Nick Casalanguida Level 4 County Manager Review Completed 05/08/2019 8:58 AM
Board of County Commissioners MaryJo Brock Meeting Pending 05/14/2019 9:00 AM
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ORDINANCE NO. 2019 - _____
AN ORDINANCE OF THE BOARD OF COUNTY COMMISSIONERS OF
COLLIER COUNTY, FLORIDA, ADOPTING THE COLLIER COUNTY
PROPERTY ASSESSED CLEAN ENERGY (PACE) CO NSUMER
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 a 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, largely from PACE program contractors, 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:
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Packet Pg. 467 Attachment: PACE Ordinance Revised Red-Line (8578 : **PACE Program Modification)
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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
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 with Collier County the Board.
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:
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(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 applicable Florida and local codes.
(2) Licensed Contractors: Any contractor constructing or installing a Qualifying Improvement
shall be properly licensed and insured.
(3) Contractor Pricing: PACE Providers shall have in place pricing rules and enforcement
mechanisms to ensure property owners are protected from excessive or unjustified prices and
charges.
(4) Contractor Management. PACE Providers shall:
a. To the extent available, recruit and approve local licensed contractors;
b. Establish a "Code of Conduct" that sets standards for participating contractors
such as licensing, advertising and marketing, accurate representation of the
program, and consumer protections ;
c. Train all PACE program contractors on the regulations related to the PACE
program and the Code of Conduct;
d. Require that all contractors hold nece ssary licenses and insurance;
e. Confirm contractor qualifications at least annually and as necessary based upon
consumer complaints or other indications of lack of compliance; and
f. Provide a list of all PACE approved licensed contractors to perform the desired
installation of the qualified improvement to the property owner to ensure the most
competitive pricing;
f. g. Remove contractors from the PACE program who no longer meet program
criteria, have not met program requirements, or fail to resolve consumer
complaints;
h. Provide the property owner with an estimate of savings from the Qualifying
Improvements, where applicable, including a statement that actual savings will
depend on usage patterns, seasonal variation and weather, utility rates, trends and
product specifications, together with any available rebates or incentives
associated with the Qualifying Improvements, if applicable;
i. Coordinate with the contractor and electrical utility service provider to ensure the
qualified savings are recognized upon Certificate of Completion from the County
for the installation of solar photovoltaic systems ;
j. Not process any PACE Assessment against the property owner until the
Qualifying Improvements on that property have received a Certificate of
Completion from the County; and
k. If requested, provide Spanish and Creole speaking customer service
representatives, as well as a translated copy of the documentation.
(5) Right to Cancel: A property owner may cancel a PACE Financing Agreement within 3
days of execution without cost or penalty.
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(6) Notice to Property Owner: At least 5 business days prior to entering into a PACE Financing
Agreement, PACE Providers shall provide the property owner with a separate written notice
disclosing the following items:
a. The estimated total amount of the homeowner’s debt, including amount financed,
fees, fixed interest rate, capitalized interest and the effective rate of the interest
charged ("Annual Percentage Rate" or "APR");
b. The estimated savings from the Qualifying Improvements, together with any
available rebates or incentives associated with the Qualifying Improvements;
c. The PACE Assessment will appear on the property owner's tax bill;
d. The PACE Assessment will be collected in the same manner as real estate taxes;
that failure to pay the PACE Assessment may cause a tax certificate to be issued
against the property; and that failure to pay may result in the loss of property
subject to the PACE Assessment, including homestead property, in the same
manner as failure to pay property taxes;
e. The installation of Qualifying Improvements may or may not affect the overall
market value of the Property;
f. The PACE Assessment may affect the sale or refinance of the Property;
g. The property owner may be required to pay any PACE Assessment in full at the
time of refinance or sale of the property;
h. The three-day right to cancel the PACE Financing Agreement without cost or
penalty; and
i. The notice shall be signed and dated by the property owner to acknowledge that
they understand these conditions.
j. A copy of all documents to be signed at the PACE Financing Agreement closing
must accompany the notice, and a copy of all documents signed by the
homeowner must be provided to the homeowner at the closing.
(7) 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,
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 resolv ed, shall be created, maintained and thereafter be treated as
Public Records as defined under Chapter 119, Florida Statutes, and provided to
anyone, including Collier County, upon request.
e. Upon the homeowner’s request, and at no charge, provide a full accounting of the
PACE Financing Agreement , including the total interest and principle paid to
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date, all fees paid to date, the outstanding balance left on the loan, and the total
interest paym ents left due on the loan, assuming no prepayment is made.
(8) 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 consented to any
proposed PACE Financing Agreement and PACE Assessment, or that the prior
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. Ensure that the total amount of any annual property taxes and assessments do not
exceed five percent (5%) of the property's fair market value, determined at the time
financing is approved, and that the property owner attests that the total amount of
annual PACE Assessments do not exceed five percent (5%) of the total annual gross
income of the property owner in the prior calendar or fiscal year. Fair market value
shall be that value determined by the Collier County Property Appraiser; and
c. The PACE Provider shall be solely responsible for all matters associated with
origination, funding, financing, collection and administration of each of the Special
Assessments.
9) 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, c anceled checks,
reports, customers property status of improvements, disbursements, and all other related records
produced and maintained by the PACE Provider, it’s employees, contractors, and consultants.
Records shall be deemed as public records in accor dance with Section 119, Florida Statutes.
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, upon public hearing before the Board, a violation of this Ordinance shall be considered
a substantial breach of the Standard Membership Agreement, and upon determination of the
Board, shall be grounds for the termination of the Standard Membership Agreement.
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Packet Pg. 471 Attachment: PACE Ordinance Revised Red-Line (8578 : **PACE Program Modification)
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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 William L. McDaniel, Jr., Chairman
Approved as to form and legality:
_______________________________
Jeffrey A. Klatzkow, County Attorney
11.E.a
Packet Pg. 472 Attachment: PACE Ordinance Revised Red-Line (8578 : **PACE Program Modification)
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Packet Pg. 473 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
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Packet Pg. 474 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
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Packet Pg. 475 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
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Packet Pg. 476 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
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Packet Pg. 477 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
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Packet Pg. 478 Attachment: PACE Ordinance - JAK signed - 5-2-19 (8578 : **PACE Program Modification)
Collier County
Property Assessed Clean Energy
Consumer Protection Ordinance
Jamie French -Deputy Department Head
Growth Management Division
Board of County Commissioners Meeting –May 14, 2019
11.E.c
Packet Pg. 479 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Stakeholder Meeting
Hosted stakeholder feedback session -April 2, 2019
PACE Industry
Public
City of Naples
Habitat for Humanity
CBIA
Ten day comment period seeking enhanced
consumer protections and best practices
Reporting information was requested and provided
by each PACE provider
Additional research was performed to determine
current program and activity
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Packet Pg. 480 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Recommended Consumer Protections
and
Enhancements
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Packet Pg. 481 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Qualifying Improvements
Qualifying Improvements must be permitted and
comply with applicable Florida Laws and County codes
Licensed Contractors
Qualifying Improvements must be done by a properly
licensed and insured contractor
Contractor Pricing
PACE Providers shall have pricing rules and enforcement
mechanisms to avoid excessive or unjustified pricing and
charges
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Packet Pg. 482 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Contractor Management
Recruit local licensed contractors, if available
Establish a Code of Conduct
Train all PACE program contractors
Contractors must have proper license and insurance
Annual contractor compliance checks
PACE Provider will provide a list of all approved licensed
contractors to ensure the most competitive price
Contractor will provide full warranty disclosure
Estimated savings provided to property owner with an
estimate of savings from Qualifying Improvements
Coordination between electric company and
contractor for installation of solar panels
PACE Assessment against the property owner will not be
processed until the Qualifying Improvements have
received a Certificate of Completion from the County
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Packet Pg. 483 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Notice to Property Owner
Five day disclosure notice of the following:
Total debt and interest rates
PACE assessment will appear on annual tax bill and
be collected by Collier County Tax Collector
Qualified Improvement may or may not affect
property value
Failure to pay disclosure
Risk of future sale or refinancing of the property
Right to cancel within three days
Required acknowledgements and signature sections
All documents required to be signed will be provided
to the property owner
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Packet Pg. 484 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Customer Service
Transparent customer
feedback and complaint
process
Defined dispute and
resolution process
Reporting and record
requirements
Full accounting of PACE
Assessment made available to
the property owner upon
request
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Packet Pg. 485 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Residential property requirements
Mortgage holder consent to PACE Financing Agreement
and PACE Assessment
Total amount of any annual property taxes and assessments
do not exceed five percent of the property's fair market
value
Property owner attests that the total amount of annual
PACE assessments do not exceed five percent of their total
annual gross income in the prior calendar year
PACE Provider responsible for all matters associated with
origination, funding, financing, collection and
administration of each of the Special Assessments
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Packet Pg. 486 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Reporting Documents
Ten day written request where the PACE Provider shall
supply the County any and all requested records
produced and maintained by the PACE Provider, it’s
employees, contractors, and consultants
All records shall be deemed as public record in
accordance with Florida Statute
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Packet Pg. 487 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
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
Violations shall be considered a substantial
breach of the Standard Membership Agreement
and grounds for the termination by the Board
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Packet Pg. 488 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
PACE Provider Percentage
of Permits
Issued to
PACE
Assessment
Percentage
of permits
with Cert.
of Compl.
Average
Loan
Amount
Average
Term of
Loan
Average
Interest
Rate
Average
Loan
Amount
Assessed
Annually
Counterpointe
(2019 -4)
100%75%$34,900.04 20 1.96%$1,836.85
Renew
(2019 -8)
100%85%$17,482.02 16.25 Not
Provided
$2,130.20
Renovate
America
(FRED)
(2019 -6)
100%33%$3,653.27 18.33 7.94%$1,805.51
Ygrene
(2018 -116)
99%73%$20,234.15 17.31 7.68%$2,636.73
Research 11.E.c
Packet Pg. 489 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)
Considerations
Ordinance ensures additional consumer protections
that provide information and options to participating
property owners
Supports competitive pricing practices and
protections against unlicensed and unpermitted
activities
Violations are punishable through the Collier County
Code Enforcement Ordinance
Recommendation
Direct the County Attorney to advertise and bring
back for adoption The Collier County PACE
Consumer Protection Ordinance
11.E.c
Packet Pg. 490 Attachment: 5-3-19 PACE FINAL Power Point (8578 : **PACE Program Modification)