BILL ANALYSIS                                                                                                                                                                                                    






                         SENATE COMMITTEE ON EDUCATION
                              Gloria Romero, Chair
                           2009-2010 Regular Session
                                        

          BILL NO:       SB 1193
          AUTHOR:        Lowenthal
          AMENDED:       April 5, 2010
          FISCAL COMM:   Yes            HEARING DATE:  April 14, 2010
          URGENCY:       No             CONSULTANT:Kathleen Chavira

           SUBJECT  :  Modernization Project Funding
          
           POLICY ISSUE  

          Should the provisions of the High Performance Incentive  
          Grant Program be statutorily modified for modernization  
          projects?  What elements would create incentives for  
          participation while ensuring that modernization projects  
          take meaningful steps toward the creation of high  
          performance schools?  

           
          SUMMARY  

          This bill increases the amount of a modernization grant by  
          $250,000 per schoolsite if the project incorporates the use  
          of high performance design and materials and can  
          demonstrate that it meets one of a number of specified  
          objectives.  

           BACKGROUND  

          The Kindergarten-University Public Education Facilities  
          Bond Act of 2006, authorized Proposition 1D a statewide  
          general obligation bond proposal for $10.4 billion.   
          Proposition 1D, approved by the voters in November 2006,  
          provided $7.3 billion for K-12 education facilities.  Among  
          other things, Proposition 1D provided $100 million for high  
          performance incentive grants to promote the use of designs  
          and materials in school facility new construction and  
          modernization projects that include the attributes of high  
          performance schools, pursuant to regulations adopted by the  
          State Allocation Board. (Education Code 101012)

          Current law defines high performance attributes as  




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          including the use of designs and materials that promote  
          energy and water efficiency, maximize the use of natural  
          lighting, improve indoor air quality, utilize recycled  
          materials and materials that emit a minimum of toxic  
          substances, and employ acoustics that are conducive to  
          teaching and learning. (EC 17070.96) 





           ANALYSIS
           
           This bill  :

          1)   Increases the amount of a modernization grant by  
               $250,000 per schoolsite if the project incorporates  
               the use of high performance design and materials and  
               can demonstrate that it meets one of the following  
               objectives:

                    a)   Achieves 20 points for meeting high  
                    performance criteria as determined by the SAB and  
                    certified by the Division of the State Architect.
                    b)   Obtains Collaborative for High Performance  
                    Schools (CHPS) "verified" status in accordance  
                    with the California Edition of the CHPS criteria.
                    c)   Obtains certification status in accordance  
                    with the Leadership in Energy and Environmental  
                    Design for Schools (LEEDS).

          2)   Requires the State Allocation Board to provide  
               additional funding for modernization projects that  
               exceed the criteria outlined in #1 above.

          3)   Requires the SAB to adopt emergency regulations to  
               administer these provisons within 14 calendar days and  
               the Office of Administrative Law to process the  
               emergency regulations within 14 calendar days of their  
               adoption.

          4)   Prohibits school districts from being required to  
               provide matching funds for any funds received under  
               these provisions.

          5)   Declares that these funds do not constitute a  




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               modernization apportionment and do not reduce  
               modernization eligibility authorized under the Leroy  
               Greene Act.

          6)   Requires that the energy efficiency and renewable  
               energy savings realized, as specified, be retained by  
               the school district and prohibits the reduction of  
               state funding on the basis of these savings.

          7)   Requires that these funds be made available for  
               reimbursement and grants for contracts signed on or  
               after April 1, 2010.

           STAFF COMMENTS  

           1)   Need for the bill  .  According to the author, the High  
               Performance Schools program has been stalled by a  
               well-intentioned but onerous process for awarding the  
               grants.  The existing process awarded points to  
               various environmental and energy-related features of  
               school construction projects.  According to the  
               author, while the number of points determine the  
               amount of funding a district would receive, the points  
               have no relationship to the actual cost of the desired  
               features.  Some districts found that the costs  
               associated with the required certification of these  
               features to earn the points were almost as high as the  
               percentage grant increase they would receive as part  
               of the program. This bill, by establishing a base  
               grant of $250,000 per school site when a district  
               modernizes buildings and meets high performance  
               criteria will provide districts with a real incentive  
               to create green schools.

           2)   Current program features  .  The SAB adopted regulations  
               for the implementation of the High Performance  
               Incentive (HPI) grant program on October 1, 2007.   
               Under these regulations, applications are scored and  
               receive points using established criteria in five  
               categories (Sustainable Sites, Energy, Water,  
               Materials, Indoor Environmental Quality) to determine  
               the high performance attributes in a project. These  
               criteria were modeled after the rating criteria  
               identified in the Collaborative of High Performance  
               Schools (CHPS) standards, but modified to assure that  
               funds allocated from this program focus on facility  




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               attributes.  Grants are provided on a first-come,  
               first-serve basis and augment base project grants.  

               The minimum point threshold for new construction  
               projects to qualify for the additional grant is 27  
               points, while the minimum point threshold for  
               modernization projects is 20 points.  The final score  
               is verified by the Division of the State Architect.  
               The increase to the base grant is determined by the  
               number of points the project receives multiplied by a  
               graduated percentage factor with the potential to  
               increase the grant amount by two to approximately10  
               percent.  

           3)   How has it worked  ?  The first HPI grants were  
               apportioned at the February 2008 SAB meeting.  Since  
               then, the Office of Public School Construction (OPSC)  
               reports that about $18.5 million in HPI grants for 76  
               projects have been awarded.  Nearly all these funds  
               went toward new construction projects with only one of  
               the grants being approved for a modernization project.  
                OPSC is currently processing 34 HPI grant requests  
               for about $6.7 million, of which seven are  
               modernization projects. Almost three-fourths of the  
               $100 million available since 2007 has gone  
               undistributed.

               School districts have anecdotally reported that the  
               current program is too complex and funding amounts are  
               not adequate, particularly within the modernization  
               program.   They have also cited the lack of a link  
               between the number of points obtained for  
               incorporating high performance attributes and the cost  
               of those elements within a project.  Whereas the size  
               of a new construction project allows some ability to  
               absorb these costs, the smaller scope of many  
               modernization projects makes it especially difficult  
               to absorb these costs within those projects.   

           4)   Where do the funds come from  ?  It appears to be the  
               intent of the author to make provision for the use of  
               the $100 million provided by Proposition 1D for the  
               High Performance Incentive Grants.  However, as  
               drafted, the bill increases the amount of a  
               modernization grant without specifying that the  
               funding authorized by the bill is to come from, and be  




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               provided only to the extent funds are available from,  
               the HPI program.  

               Staff recommends the  bill be amended to link the  
               purposes outlined in the bill to the funding  
               authorized in Education Code section 101012(a)(8). 
           
          5)   Too statutorily prescriptive  ? This bill would  
               statutorily establish 20 points as the high  
               performance criteria threshold for eligibility for  
               funding under the HPI program.  As noted in staff  
               comment #2, the program currently delineates several  
               categories of high performance attributes via  
               regulation, with 20 points being the current score  
               necessary to be eligible for an HPI modernization  
               grant.  But what if new standards or goals for "high  
               performance" emerge? What if it is determined that the  
               existing score threshold is too high? Should the SAB's  
               flexibility in adjusting the criteria and scoring  
               thresholds through regulation be compromised?  

               Staff recommends the bill be amended to delete the  
               requirement that 20 points be achieved and instead  
               require that the project achieve the number of points  
               necessary for meeting high performance criteria as  
               determined by the SAB and certified by the DSA  
               pursuant to regulations. 
           
          6)   Is $250,000 the right amount  ? This bill establishes a  
               base grant of $250,000 for qualifying high performance  
               projects in an effort to address concerns about  
               funding inadequacy and to incent increased  
               participation in the HPI program.  This amount appears  
               to be based upon grant programs operated under the  
               Integrated Waste Management Board and the California  
               Energy Commission.  Staff was unable to determine  
               whether the features and requirements of these  
               programs were comparable to those of the HPI.  In  
               addition the committee may wish to consider the  
               following:

                           What threshold of grant is necessary in  
                    order to incent participation in the program?

                           Is it reasonable to award a base grant of  
                    $250,000 if it exceeds the cost of the entire  




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                    modernization project?  

                           What are the real costs of incorporating  
                    high performance attributes into the project?   
                    Are they greater, less, or even close to the  
                    proposed base grant amount?    

           1)   CHPS and LEED  .  Leadership in Energy and Environmental  
               Design (LEED) is an internationally recognized green  
               building certification system developed by the U.S.  
               Green Building Council (USGBC), a non-profit  
               organization focused on the realization of  
               cost-efficient and energy-saving green buildings.    
               The Collaborative for High Performance Schools (CHPS)  
               is a national, non-profit organization, originally  
               created in California, which exists to facilitate the  
               design, construction and operation of "high  
               performance schools" which are energy and resource  
               efficient as well as healthy, comfortable, well lit,  
               and contain the amenities for a quality education.    
               Each of these entities offers third-party verification  
               that school construction projects have achieved a  
               "status" related to standards for design and  
               construction established by their respective  
               organizations.  

          2)   Should a private entity be given the authority to  
               determine who receives state bond funds  ? This bill  
               would award funds to school districts that demonstrate  
               that they have achieved CHPS or LEED status on the  
               basis of those entities granting the projects a  
               certification or verification status.   Essentially,  
               state bond dollars would be awarded on the basis of a  
               private "third-party" certification that their own  
               standards had been met.  While the current state  
               program is linked to some CHPS standards (which are  
               similar in nature to LEED standards), the state  
               developed HPI grant is based upon a funding model  
               developed to recognize CHPS criteria which are  
               specifically facilities related and consistent with  
               the HPI program goals. Should state bond funds be  
               distributed on the basis of non-state criteria,  
               developed and modified by private entities whose  
               objectives may or may not be aligned with the state  
               goals for funding high performance schools?  What  
               potential conflicts of interest arise might arise from  




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               empowering private entities the power to determine who  
               receives limited state dollars?  

           3)   Application of provisions based upon a contract date  ?  
               Under the SFP, an application for funding under the  
               Modernization Program may be submitted for work to be  
               performed, or for reimbursement of work already  
               completed.  Receipt of funding is not generally  
               contingent upon the date of the signing of a contract,  
               as is the case with new construction.  This  
               accommodation exists in order to allow districts to  
               compile a number of smaller modernization projects and  
               submit their request for reimbursement of these  
               projects in a single application. This bill would  
               apply its provisions only to modernization projects  
               that have entered into contracts as of April 1, 2010  
               effectively excluding reimbursement projects which may  
               have been designed and constructed to meet the  
               existing high performance criteria but had not yet  
               been submitted for funding.  
          
               Staff recommends the bill be amended to delete  
               subdivision (g) and allow the funding to be available  
               for reimbursement and grants for any qualifying  
               modernization funding applications received after the  
               bill's effective date.  

           4)   Administrative vs. statutory solutions  .  At its  
               February 2010 meeting, the SAB, cognizant of the  
               limited participation in the HPI, requested that OPSC  
               staff convene a workgroup to examine the HPI grant  
               program with an emphasis on the lack of modernization  
               requests.  A workgroup was assembled, input is being  
               gathered from various stakeholders and staff is in the  
               process of preparing proposed regulatory changes to be  
               discussed and considered by the SAB at its April  
               meeting. 

               Staff notes that many of the questions raised in this  
               analysis are currently under consideration by the SAB,  
               the School Facility Program policy making body which  
               has the authority to modify regulations as necessary  
               to achieve program objectives.  Regulations adopted by  
               this body generally undergo extensive review and  
               discussion by districts and other interested parties  
               prior to coming before the SAB.  It appears that such  




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               a process has been initiated and that the changes  
               proposed by this bill are already under consideration  
               by the SAB.

           SUPPORT  

          California Labor Federation
          Small School Districts' Association
          County School Facilities Consortium
          California's Coalition for Adequate School Housing
          California School Boards Association


           OPPOSITION

           None received.