SCO
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
PROGRAM AUDIT OF THE
CALIFORNIA CLEAN ENERGY
JOBS ACT
Audit Report
PROPOSITION 39 PROGRAM
Chapter 29, Statutes of 2013
July 1, 2020, through June 30, 2021
BETTY T. YEE
California State Controller
June 2022
BETTY T. YEE
California State Controller
June 30, 2022
Adrienne Alvord, Chair
Citizens Oversight Board
1516 9th Street, MS 19
Sacramento, CA 95814
Dear Ms. Alvord:
The State Controller’s Office audited a selection of completed projects related to the California
Clean Energy Jobs Act for the period of July 1, 2020, through June 30, 2021.
As of June 30, 2021, 512 local educational agencies (LEAs) reported $341,987,811 in completed
project costs. From the list of completed projects, we selected for audit five LEAs, which
together reported total expenditures of $19,318,586. No community college districts were
included in this year’s audit. Our audit found that:
Two LEAs sole-sourced a portion of their project costs, resulting in unallowable costs of
$508,108;
Three LEAs did not identify the projected energy savings in the awarded contracts; and
Four LEAs submitted their final project completion reports after the deadline.
This final audit report identifies two LEAs that sole-sourced a portion of their project costs, in
violation of Public Resources Code section 26235(c). In addition, Public Resources Code
section 26240(h) states, in part, “The Superintendent of Public Instruction shall require local
educational agencies to pay back funds if they are not used in accordance with state statute or
regulations.”
Finding 1 is apportionment-significant for LEAs. If you disagree with the finding, you have
30 days from the date the State Controller’s Office emailed this report to request a summary
review of any apportionment-significant audit findings on the grounds of substantial compliance.
In addition, you have 60 days from delivery of this letter—or 30 days following the conclusion
of a summary review regarding the finding included in that review—to file a formal appeal of
any apportionment-significant audit findings on any one or more of the grounds set forth in
Education Code (EC) section 41344(d). The request for a summary review or formal appeal
should be submitted to the following address:
Executive Officer
Education Audit Appeals Panel
770 L Street, Suite 1100
Sacramento, California 95814
Adrienne Alvord, Chair -2- June 30, 2022
If you have any questions regarding the summary review process or the appeal process, please
see the Education Audit Appeals Panel website (www.eaap.ca.gov) or call Education Audit
Appeals Panel at (916) 445-7745.
LEAs working to resolve audit exceptions may request structured repayment plans under EC
section 41344. To request a repayment plan, the LEA must submit a letter to the California
Department of Education (CDE) within 90 days of receipt of this letter; within 30 days of
withdrawing or receiving a determination of a summary review if there is no appeal; or within
30 days of withdrawing or receiving a final determination regarding an appeal pursuant to EC
section 41344(a). More information on repayment plans can be found on the CDE’s website
(http://www.cde.ca.gov/fg/au/ag/resolution.asp) or by contacting the CDE, School Fiscal
Services Division, Categorical Allocations and Management Assistant Unit, at (916) 323-8068.
If you have any questions about the audit findings, please contact Lisa Kurokawa, Chief,
Compliance Audits Bureau, by telephone at (916) 327-3138.
Sincerely,
Original signed by
KIMBERLY TARVIN, CPA
Chief, Division of Audits
KT/as
cc: Jim Bartridge, Program and Policy Advisor
Citizens Oversight Board
Jack Bastida, Program Specialist
Citizens Oversight Board
The Honorable Tony Thurmond, State Superintendent of Public Instruction
California Department of Education
Alice Lee, Director
Audits and Investigations Division
California Department of Education
Kelly Levario, Staff Services Manager II
Audits and Investigations Division
California Department of Education
Elizabeth Dearstyne, Director
School Fiscal Services Division
California Department of Education
Derrick Andrade, Education Fiscal Services Consultant
School Fiscal Services Division
California Department of Education
David Hochschild, Chair
California Energy Commission
Drew Bohan, Executive Director
California Energy Commission
Adrienne Alvord, Chair -3- June 30, 2022
Michael Sokol, Deputy Director
Efficiency Division
California Energy Commission
Armand Angulo, Assistant Deputy Director
Renewable Energy Division
California Energy Commission
Mary C. Kelly, CPA, Executive Officer
Education Audit Appeals Panel
Patricia Speer, President
Board of Education
Banta Unified School District
Rechelle Pearlman, Superintendent
Banta Unified School District
Adriana Florez Lopez, Business Services Supervisor
Banta Unified School District
Kathy Zack, President
Board of Education
Bishop Unified School District
Katie Kolker, Superintendent
Bishop Unified School District
Midge Milici, Chief Business Officer
Bishop Unified School District
Tom Snyder, Deputy Superintendent
Business/Financial Services
Inyo County Office of Education
Patricia Smith, Chief Financial Officer
Business Services
Los Angeles County Office of Education
Kelly Gonez, President
Board of Education
Los Angeles Unified School District
Alberto M. Carvalho, Superintendent
Los Angeles Unified School District
David D. Hart, Chief Financial Officer
Los Angeles Unified School District
Peter Yee, Senior Project Manager
Maintenance and Operations Division
Los Angeles Unified School District
Dr. Natalie Lindemann, President
Board of Education
Rim of the World Unified School District
Michelle Murphy, Superintendent
Rim of the World Unified School District
Jenny Haberlin, Chief Business Official
Rim of the World Unified School District
Richard De Nava, Assistant Superintendent
Business Services
San Bernardino County Superintendent of Schools
Adrienne Alvord, Chair -4- June 30, 2022
Michael Simonson, Deputy Superintendent
Business Services
San Diego County Office of Education
Scott Anderson, Deputy Superintendent
Business Services
San Joaquin County Office of Education
Stacy Carlson, President
Governing Board
San Marcos Unified School District
Andrew S. Johnsen, Ed.D., Superintendent
San Marcos Unified School District
Erin Garcia, Assistant Superintendent
Business Services
San Marcos Unified School District
Tova Corman, Executive Director
Facilities Planning and Development
San Marcos Unified School District
Diane deBruyn, Accounting Technician
Facilities Planning and Development
San Marcos Unified School District
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Contents
Audit Report
Summary ............................................................................................................................ 1
Background ........................................................................................................................ 1
Audit Authority.................................................................................................................. 3
Objective, Scope, and Methodology ................................................................................. 3
Conclusion .......................................................................................................................... 5
Follow-up on Prior Audit Findings .................................................................................. 5
Views of Responsible Officials .......................................................................................... 5
Restricted Use .................................................................................................................... 5
Schedule—Total Completed Proposition 39 Program Costs for
Local Educational Agencies ....................................................................... 6
Findings and Recommendations ........................................................................................... 15
Appendix A—Audit Results by Local Educational Agency ............................................... A1
Appendix B—Overview of Issued Audit Reports ............................................................... B1
Attachment A—Banta Unified School District’s Response to Audit Results
Attachment B—Bishop Unified School District’s Response to Audit Results
Attachment C—San Marcos School District’s Response to Audit Results
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Audit Report
Summary The State Controller’s Office (SCO) audited a selection of completed
projects related to the California Clean Energy Jobs Act for the period of
July 1, 2020, through June 30, 2021.
As of June 30, 2021, 512 local educational agencies (LEAs) reported
$341,987,811 in completed project costs. From the list of completed
projects, we selected for audit five LEAs, which together reported total
expenditures of $19,318,586. No community college districts (CCDs)
were included in this year’s audit.
Our audit found that:
Two LEAs sole-sourced a portion of their project costs, resulting in
unallowable costs of $508,108;
Three LEAs did not identify the projected energy savings in the
awarded contracts; and
Four LEAs submitted their final project completion reports after the
deadline.
Appendix A summarizes the audit results for the five LEAs.
Background The California Clean Energy Jobs Act was created with the approval of
Proposition 39 (Chapter 29, Statutes of 2013) in the November 2012
statewide election. The statute changed the corporate income tax code to
allocate projected revenue from the General Fund to the Clean Energy Job
Creation Fund for five fiscal years, beginning with fiscal year
(FY) 2013-14. Under the initiative, it is estimated that up to $550 million
is available annually to be appropriated by the California State Legislature
for purposes of funding eligible projects that create jobs in California
while improving energy efficiency and expanding clean energy
generation.
Senate Bill 73 requires that 89% of the funds deposited annually into the
Clean Energy Job Creation Fund be made available to LEAs for energy
efficiency and clean energy projects, and 11% be made available to CCDs
for energy efficiency and clean energy projects.
An eligible energy project is an installation at or modification to a school
site that improves energy efficiency or expands clean energy generation.
Energy efficiency measures include heating, ventilation, and air
conditioning (HVAC) system retrofits and various interior and exterior
retrofits; clean energy generation measures include photovoltaic (solar)
panels. All facilities within an LEA are eligible for Proposition 39 program
funding.
Citizens Oversight Board
Proposition 39 also established the Citizens Oversight Board to review
expenditures, audit the Clean Energy Job Creation Fund, and maintain
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
transparency and accountability of the Fund. The California Treasurer,
Attorney General, and State Controller each appoint three members of the
Citizens Oversight Board; the California Energy Commission (CEC) and
the California Public Utilities Commission appoint two ex officio
members.
California Department of Education
The California Department of Education (CDE) is responsible for
distributing Proposition 39 funding to LEAs that serve grade K-12
students. CDE allocates funds based on the following formula:
85% based on average daily attendance reported as of the second
principal apportionment for the prior year; and
15% based on the number of students eligible for free and reduced-
priced meals in the prior year.
These funds may be used by LEAs for energy efficiency and clean energy
projects, as well as related energy planning, energy training, and energy
management. LEAs are required to submit an energy expenditure plan
(EEP) to the CEC for consideration and approval. An EEP includes a
technical description and project specifications for the proposed eligible
energy measures. Funds are released to an LEA only after the CEC
approves the EEP.
LEAs with prior-year average daily attendance of 1,000 or lower are
eligible to receive funding for both the current year and the following year
in the current year. LEAs that select this option do not receive a funding
allocation in the following year.
LEAs whose first year of eligibility was FY 2013-14 also had the option
of requesting a portion of that year’s award allocation for energy planning
activities without submitting an EEP to the CEC. The energy planning
funds can be spent only on the following four activities:
Energy audits and energy surveys/assessments;
Proposition 39 program assistance;
Hiring or retaining an energy manager; and
Energy-related training.
Any unused energy planning funds must be applied toward implementing
energy projects from an LEA’s approved EEP.
California Energy Commission
The CEC is the primary state agency responsible for energy policy and
planning. Public Resources Code (PRC) section 26235(a) requires the
CEC to establish guidelines in consultation with the State Superintendent
of Public Instruction, the Chancellor of the California Community
Colleges, and the California Public Utilities Commission.
On December 19, 2013, the CEC adopted program implementation
guidelines, to which substantive revisions have been made. For this audit
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
period, we referred to Proposition 39: California Clean Energy Jobs Act –
2016 Program Implementation Guidelines (2016 Program
Implementation Guidelines). These guidelines provide direction to LEAs
on the types of awards and the required proposals, explain the screening
and evaluation criteria, describe the standards to be used to evaluate
project proposals, and outline the award process.
The 2016 Program Implementation Guidelines include a savings-to-
investment ratio (SIR) calculation. To be approved for Proposition 39
funding, energy projects must achieve a SIR above 1.0. For example, for
every dollar invested in the eligible energy project, the LEA must accrue
over $1 in savings. The SIR calculation is based on the present value of
the savings divided by project installation costs, subtracting rebates and
other grant funding sources. The 2016 Program Implementation
Guidelines also include a formula for estimating job creation benefits,
pursuant to PRC section 26235(e)(10).
The CEC also developed the Proposition 39: California Clean Energy
Jobs Act – 2015 Energy Expenditure Plan Handbook (EEP Handbook),
which includes step-by-step instructions to assist LEAs in completing the
required forms.
This is the sixth program audit report that we have issued for the California
Clean Energy Jobs Act, pursuant to an interagency agreement between
SCO and the Citizens Oversight Board. Appendix B summarizes the
amounts expended and audited; the audit finding amounts; and our
conclusions for all six audit reports.
Audit Authority Government Code (GC) section 12410 and PRC section 26210 provide the
legal authority to conduct this audit.
GC section 12410 states, in part, “The Controller shall superintend the
fiscal concerns of the state and audit the disbursement of any state money
for correctness, legality, and for sufficient provisions of law for payment.”
The SCO’s interagency agreement with the Citizens Oversight Board,
pursuant to PRC section 26210(d)(2), commissions the SCO to review a
selection of completed projects to assess the effectiveness of the
expenditures in meeting the objectives of the California Clean Energy
Jobs Act.
Objective, Scope, On July 21, 2020, we entered into an agreement with the Citizens
Oversight Board to conduct an audit of a selection of completed projects
and Methodology
to evaluate their effectiveness in meeting the objectives of the Clean
Energy Job Creation Fund’s program guidelines. We selected five LEAs
for audit. No CCDs were included in this year’s audit.
The audit period was July 1, 2020, through June 30, 2021.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
To achieve our audit objective, we selected five LEAs with project costs
totaling $19,318,586 and determined whether:
Planning funds were expended in accordance with program
requirements and unspent planning funds were applied towards
implementing eligible energy projects approved by the CEC;
The LEA submitted an EEP to the CEC consistent with the LEA’s
priority of eligible projects;
The CEC approved the EEP in compliance with the 2016 Program
Implementation Guidelines and EEP Handbook;
The approved EEP included:
o A signed utility data release form from the LEA allowing the CEC
to access both historical and future utility billing data;
o A benchmarking process established by the CEC to determine a
prioritized plan for implementing the eligible energy projects;
o An identification of eligible energy projects according to any one
of the three methods available to LEAs (these include an energy
survey; an American Society of Heating, Refrigerating and Air-
Conditioning Engineering Level 2 energy audit; or data analytics);
o A SIR that adheres to the cost-effectiveness determination set
forth by the CEC; and
o A job-creation benefits estimation that adheres to the formula set
forth by the CEC.
The final report to the CEC contained the information outlined in PRC
section 26240(b), paragraphs (1) through (7);
The LEA did not use a sole-source process to award funds;
The LEA had a signed contract that identified project specifications,
costs, and projected energy savings (if applicable);
The LEA supported project costs;
The LEA paid back Proposition 39 funds if the project was torn down,
remodeled, or deemed surplus and sold prior to the project’s payback
period.
Errors found in the selected samples were not projected to the intended
(total) population.
We did not audit the LEAs’ financial statements.
We conducted this audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based on our audit objective.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Conclusion As a result of conducting the audit procedures, we found instances of
noncompliance with the audit objective described in the Objective, Scope,
and Methodology section. These instances of noncompliance are
quantified in the Schedule and described in the Findings and
Recommendations section.
We selected five LEAs with total completed project costs of $19,318,586.
Our audit found that:
Two LEAs sole-sourced a portion of their project costs, resulting in
unallowable costs of $508,108;
Three LEAs did not identify the projected energy savings in the
awarded contracts; and
Four LEAs submitted their final project completion reports after the
deadline.
Follow-up on Appendix B summarizes the audit findings for the five Proposition 39
program audits previously conducted and issued between June 30, 2017
Prior Audit
and August 9, 2021.
Findings
The five LEAs selected for the current audit were not previously audited
under the Proposition 39 program. However, we found that the current
audit identifies the same issues noted in prior audit reports.
Views of We discussed our audit results with representatives of the five LEAs
selected for testing during audit fieldwork, and via email at the end of the
Responsible
audit. All responses to the findings have been included in the LEA’s
Officials
respective section of Appendix A; and each formal response received on
letterhead has been included as an Attachment to this report.
Restricted Use This report is solely for the information and use of the Citizens Oversight
Board, the CDE, the CEC, the Banta Unified School District, the Bishop
Unified School District, the Inyo County Office of Education, the Los
Angeles Unified School District, the Rim of the World Unified School
District, the San Bernardino County Superintendent of Schools, the
San Diego County Office of Education, the San Marcos Unified School
District, and the SCO; it is not intended to be and should not be used by
anyone other than these specified parties. This restriction is not intended
to limit distribution of this report, which is a matter of public record, and
is available on the SCO website at https://www.sco.ca.gov.
Original signed by
KIMBERLY TARVIN, CPA
Chief, Division of Audits
June 30, 2022
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule—
Total Completed Proposition 39 Program Costs
for Local Educational Agencies
July 1, 2020, through June 30, 2021
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects selected for audit:
Banta Elementary School District $ 187,327 $ 11,480 $ 1 98,807 $ (166,801) Finding 1, 2, 3
Bishop Unified 569,811 - 569,811 (341,307) Finding 1, 2, 3
Los Angeles Unified School District 5,195,862 7 ,884,191 13,080,053 - Finding 3
Rim of the World Unified 851,852 - 851,852 - -
San Marcos USD 4,356,345 261,718 4,618,063 - Finding 2, 3
Total, completed projects selected for audit $ 11,161,197 $ 8,157,389 $ 19,318,586 $ (508,108)
Completed projects not selected for audit:
Achieve Charter School $ 86,957 $ 51,024 $ 1 37,981
Acton-Agua Dulce Unified 216,012 47,528 263,540
Adelante Charter 8 8,572 8 ,934 97,506
Adelanto Elementary 2,123,491 - 2,123,491
Alameda County Office of Education 219,246 56,781 276,027
Alameda Unified School District (2 EEPs) (EEP #6123) 980,262 32,000 1,012,262
Alameda Unified School District (2 EEPs) (EEP #126) 253,708 32,000 285,708
Albert Einstein Academy Charter Middle 264,129 - 264,129
Alder Grove Charter 9 9,980 52,893 152,873
Alhambra Unified 2,346,582 102,816 2,449,398
Alisal Union 2,159,473 130,692 2,290,165
Alliance College-Ready Middle Academy 4 266,466 17,234 283,700
Alliance College-Ready Middle Academy 5 249,580 22,915 272,495
Alliance Gertz-Ressler Richard Merkin 6-12 Complex 287,593 24,483 312,076
Alliance Judy Ivie Burton Technology Academy High 270,414 19,328 289,742
Alliance Ouchi-O'Donovan 6-12 Complex 281,816 24,599 306,415
Alpine County Office of Education 3 7,651 14,432 52,083
Alpine County Unified 6 8,294 10,567 78,861
Alta Loma Elementary 758,326 96,200 854,526
Alternative Cooperative Education Charter 7 3,622 15,085 88,707
Alternatives in Fction 204,139 52,200 256,339
Alview-Dairyland Union Elementary 8 1,973 26,886 108,859
American Indian Public Charter School II 281,083 - 281,083
America's Finest Charter 204,306 26,887 231,193
Anaheim Elementary 2,623,094 293,311 2,916,405
Antioch Charter Academy 228,270 23,852 252,122
Antioch Charter Academy II 161,469 50,392 211,861
Arcadia Unified 1,968,876 96,000 2,064,876
Arcata Elementary 245,678 25,849 271,527
ARISE High 133,720 26,659 160,379
Arts In Action Community Charter 190,140 27,029 217,169
ASCEND 211,131 56,245 267,376
Aspire APEX Academy 263,137 3 ,000 266,137
Aspire Benjamin Holt College Preparatory Academy 264,076 3 ,000 267,076
Aspire East Palo Alto Charter 4 8,472 - 48,472
Aspire Firestone Academy 7 4,178 3 ,333 77,511
Aspire Gateway Academy 7 3,428 3 ,333 76,761
Aspire Golden State College Preparatory Academy 281,027 3 ,000 284,027
Aspire Inskeep Academy 5 2,467 3 ,333 55,800
Aspire Juanita Tate Academy 5 2,467 3 ,333 55,800
Aspire Langston Hughes Academy 263,950 3 ,000 266,950
Aspire Port City Academy 219,730 3 ,000 222,730
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Aspire River Oaks Charter 222,750 3 ,000 225,750
Aspire Rosa Parks Academy 272,449 3 ,000 275,449
Aspire Slauson Academy 5 3,179 3 ,333 56,512
Bachrodt Charter Academy 279,825 - 279,825
Ballico-Cressey Elementary 231,039 23,429 254,467
Bass Lake Joint Union Elementary 268,863 14,904 283,767
Bear Valley Unified 597,844 - 597,844
Beaumont Unified School District 2,240,590 130,000 2,370,590
Belleview Elementary 207,791 6 ,075 213,866
Bellevue-Santa Fe Charter 2 6,492 45,765 72,257
Bellflower Unified (2 EEPs) (EEP #5906) 225,031 84,226 309,257
Bellflower Unified (2 EEPs) (EEP #5897) 2,909,083 84,226 2,993,309
Bogus Elementary 3 4,690 - 34,690
Bonita Unified School District 1,404,913 130,000 1,534,913
Bonny Doon Elementary 5 9,659 45,911 105,570
Bradley Union Elementary 7 7,970 - 77,970
Brawley Elementary 912,116 61,654 973,770
Bret Harte Union High 258,207 11,400 269,607
Bridgeville Elementary 7 1,661 5 ,143 76,803
Buckeye Union Elementary 201,905 - 201,905
Buena Park Elementary 1,130,993 59,300 1,190,293
Burton Elementary 592,182 40,000 632,182
Calaveras County Office of Education 127,819 12,658 140,477
California Connections Academy @ Ripon 6 3,742 10,000 73,742
California Montessori Project - Elk Grove Campus 204,462 50,859 255,321
California Montessori Project-San Juan Campus 459,566 12,000 471,566
California Montessori Project-Shingle Springs Campus 202,496 50,467 252,963
Calistoga Joint Unified School District 148,770 36,754 185,524
Camino Nuevo Academy #2 271,107 - 271,107
Camino Nuevo Charter Academy 290,889 - 290,889
Camino Nuevo Charter Academy #4 293,247 - 293,247
Camino Nuevo Charter High 270,386 - 270,386
Camino Nuevo Elementary #3 303,029 - 303,029
Camino Nuevo High #2 222,989 - 222,989
Camino Science and Natural Resources Charter 100,344 - 100,344
Camino Union Elementary 264,936 - 264,936
Canyon Elementary 3 0,215 - 30,215
Capistrano Unified (2 EEPs) (EEP #5136) 3,277,717 246,000 3,523,717
Capistrano Unified (2 EEPs) (EEP #5939) 4,253,446 201,994 4,455,440
Carmel Unified 511,667 - 511,667
Carpinteria Unified 523,800 - 523,800
Cascade Union Elementary School District 562,412 - 562,412
Celerity Cardinal Charter 3,450 31,642 35,092
Celerity Nascent Charter 255,053 29,640 284,693
Celerity Octavia Charter 960 33,620 34,580
Celerity Palmati Charter 1,125 27,200 28,325
Centinela Valley Union High 251,765 55,213 306,978
Central City Value 282,727 - 282,727
Central Union High School District 3 6,858 130,000 166,858
Century Community Charter 276,683 - 276,683
Ceres Unified 3,081,351 178,063 3,259,414
Charter Home School Academy 8 5,575 10,490 96,065
Chawanakee Academy Charter 100,344 - 100,344
Chico USD 2,565,659 163,312 2,728,971
Chino Valley Unified School District (2 EEPs) (EEP #5672) 2,717,259 39,000 2,756,259
Chino Valley Unified School District (2 EEPs) (EEP #5892) 2,333,942 39,000 2,372,942
Chowchilla Elementary 107,277 9 ,051 116,328
Chrysalis Charter 152,168 - 152,168
Chula Vista Elementary School District-Arroyo Vista Charter 8 5,977 - 85,977
Chula Vista Elementary School District-Chula Vista Learning Comm u n i t y C h a r t 170,411 - 170,411
Chula Vista Elementary School District-Discovery Charter 7 0,220 - 70,220
Cinnabar Charter 193,065 14,550 207,615
Claremont Unified 1,421,873 95,800 1,517,673
Classical Academy High School (2 EEPs) (EEP #5674) 200,279 31,080 231,359
Classical Academy High School (2 EEPs) (EEP #6149) 7 9,422 7 ,954 87,376
Clay Joint Elementary 234,314 17,137 251,451
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Clayton Valley Charter High 193,446 23,500 216,946
Clear Creek Elementary 246,689 7 ,585 254,274
Clovis Online Charter 212,963 - 212,963
Coastal Grove Charter 3 4,406 7 ,381 41,786
College Bridge Academy 180,342 - 180,342
College Elementary School District 107,485 51,695 159,180
Columbia Elementary 115,742 19,000 134,742
Columbia Union 256,235 14,822 271,057
Columbine Elementary School 251,311 3 ,500 254,811
Come Back Kids 218,489 - 218,489
Conejo Valley Unified 2,639,913 143,555 2,783,468
Connecting Waters Charter 2 6,670 - 26,670
Connections Visual and Performing Arts Academy 252,301 - 252,301
Contra Costa County Office of Education 217,648 82,755 300,403
Corcoran Joint Unified 776,729 68,121 844,850
Corning Union Elementary 565,057 - 565,057
Cottonwood Union Elementary 256,141 17,461 273,602
Cucamonga School District 356,110 60,040 416,150
Cuddeback Union Elementary 227,989 26,258 254,247
Curtis Creek Elementary 257,113 12,600 269,713
Cutten Elementary 238,428 29,435 267,863
Cypress Elementary 110,118 81,555 191,673
Da Vinci Charter Academy 153,603 - 153,603
Darnall Charter 248,566 8 ,250 256,816
Davis Joint Unified 624,094 127,429 751,523
Death Valley Unified 7 3,905 - 73,905
Del Norte County Unified 585,000 38,478 623,478
Delano Union Elementary School District 1,336,558 130,000 1,466,558
Delphic Elementary 7 6,040 - 76,040
Denair Unified 281,313 - 281,313
Desert Center Unified School District 3 4,851 - 34,851
Discovery Charter 263,915 4 ,000 267,915
Discovery Charter Preparatory No. 2 271,498 - 271,498
Dixon Unified 669,286 130,000 799,286
Douglas City Elementary 224,339 32,461 256,800
Dr. Lewis Dolphin Stallworth Sr. Charter 216,649 26,253 242,902
Dry Creek Joint Elementary School District 1,452,327 70,472 1,522,799
Dunham Charter 221,680 29,571 251,251
Dunham Elementary 6 3,588 8 ,769 72,357
Dunlap Leadership Academy 6 8,805 - 68,805
Edison-Bethune Charter Academy 272,541 13,769 286,310
Einstein Academy 262,232 - 262,232
El Dorado County Office of Education 252,000 - 252,000
El Rancho Charter 510,215 - 510,215
El Segundo Unified 523,674 130,000 653,674
El Sol Santa Ana Science and Arts Academy 297,097 - 297,097
Elise P. Buckingham Charter Magnet High 254,545 - 254,545
Elkins Elementary 2 6,829 5 ,246 32,075
Elverta Joint Elementary School District 4 8,916 53,327 102,243
Emery Unified 214,971 55,491 270,461
Encore Jr./Sr. High School for the Performing and Visual Arts 376,414 43,901 420,315
Enterprise Elementary 899,468 - 899,468
Escalon Charter Academy 220,493 - 220,493
Escondido Charter High 240,150 26,292 266,442
Escuela Popular/Center for Training and Careers, Family Learning 200,497 27,711 228,208
Etiwanda Elementary 601,232 86,801 688,033
Evergreen Elementary 2,731,939 78,423 2,810,362
Excelsior Charter 240,714 56,647 297,361
Exploer Elementary 247,707 10,000 257,707
Ezequiel Tafoya Alvarado Academy 242,154 27,891 270,045
Fallbrook Union Elementary 671,624 103,613 775,237
Fallbrook Union High 429,923 98,290 528,213
Fenton Primary Center 186,591 - 186,591
Ferndale Unified 236,864 28,746 265,610
Firebaugh-Las Deltas Unified 559,412 41,739 601,151
Folsom Cordova K-8 Community Charter 233,035 17,463 250,498
-8-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Folsom-Cordova Unified 4,299,482 20,760 4,320,242
Forest Charter 134,151 5 ,280 139,431
Forestville Academy 246,814 - 246,814
Forestville Union Elementary 145,634 - 145,634
Fort Ross Elementary 5 5,350 15,222 70,572
Freshwater Charter Middle 6 6,388 9 ,283 75,670
Garden Grove Unified (2 EEPs) (EEP #5683) 3,880,060 699,104 4,579,164
Garden Grove Unified (2 EEPs) (EEP #5707) 3,823,164 699,104 4,522,268
Garvey Elementary 1,235,121 70,000 1,305,121
Gateway International 165,543 54,041 219,584
Gazelle Union Elementary 6 1,500 15,554 77,054
Geyserville Unified School District 187,832 27,150 214,982
Gilroy Prep School (Navigators School) 8 0,707 43,865 124,572
Gilroy Unified School District 2,508,491 85,936 2,594,427
Gold Oak Union Elementary 233,581 20,000 253,581
Gold Trail Union Elementary 262,401 800 263,201
Golden Eagle Charter 7 1,926 53,422 125,348
Golden Valley Charter School of Sacramento 213,394 47,500 260,894
Golden Valley Unified 501,707 48,689 550,396
Goleta Union Elementary 397,415 100,752 498,167
Gompers Preparatory Academy 456,617 - 456,617
Gorman Learning Center 522,713 - 522,713
Grass Valley Elementary 169,459 35,214 204,673
Gravenstein Elementary 247,502 12,930 260,432
Gravenstein Union Elementary 7 2,812 12,930 85,742
Graves Elementary 2 2,724 8 ,367 31,091
Great Valley Academy 257,793 16,420 274,213
Grossmont Union High 3,993,349 169,283 4,162,632
Guadalupe Union Elementary 3 9,150 60,000 99,150
Gustine Unified 285,274 24,285 309,559
Hallmark Charter 263,236 - 263,236
Happy Valley Union Elementary School District 213,042 - 213,042
Harriet Tubman Village Charter 198,378 54,990 253,368
Hart-Ransom Union Elementary 264,826 16,235 281,061
Hawthorne Elementary 2,021,537 110,000 2,131,537
Hawthorne Math and Science Academy 275,107 - 275,107
Hayward Unified 870,752 - 870,752
Healdsburg Charter 230,600 20,000 250,600
Healdsburg Unified 543,447 17,500 560,947
Health Sciences High 252,048 28,006 280,054
Hermosa Beach City Elementary 248,625 - 248,625
High Tech Elementary Chula Vista 254,841 10,000 264,841
High Tech High Chula Vista 261,632 10,000 271,632
High Tech High Media Arts 253,713 10,000 263,713
High Tech LA 249,403 - 249,403
High Tech Middle Chula Vista 251,546 10,000 261,546
High Tech Middle Media Arts 260,602 - 260,602
Hillcrest Middle 244,332 12,930 257,262
Hillsborough City Elementary 400,189 100,000 500,189
Hollister Prep 208,021 - 208,021
Holly Drive Leadership Academy 7 8,821 8 ,446 87,268
Hometech Charter 4 9,750 3 ,125 52,875
Hope Elementary (2 EEPs) (EEP #6042) 208,435 51,046 259,481
Hope Elementary (2 EEPs) (EEP #5623) 259,597 54,357 313,954
Horizon Charter 498,704 52,998 551,702
Hot Springs Elementary 6 4,671 - 64,671
Howell Mountain Elementary School District (2 EEPs) (EEP #5291) 1 7,074 6 ,213 23,286
Howell Mountain Elementary School District (2 EEPs) (EEP #1701) 4 2,918 6 ,213 49,131
Hughes-Elizabeth Lakes Union Elementary 204,917 51,885 256,802
Humboldt County Office of Education 235,493 26,341 261,834
Indian Diggings Elementary 7 3,428 - 73,428
Inglewood Unified 2,499,340 180,796 2,680,136
Inland Leaders Charter 211,195 52,516 263,711
Inspire School of Arts and Sciences 255,184 5 ,350 260,534
Ivy Bound Academy Math, Science, and Technology Charter Middle 2 167,135 - 167,135
Jacoby Creek Elementary 224,330 30,618 254,948
-9-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Jamul-Dulzura Union Elementary 241,068 5 ,950 247,018
John Adams Academy 331,780 25,235 357,015
Junction Elementary 187,230 49,762 236,992
Kairos Public School Vacaville Academy 134,076 - 134,076
Kelseyville Unified 387,105 - 387,105
King-Chavez Academy of Excellence 249,896 23,433 273,329
King-Chavez Community High 262,820 23,433 286,252
King-Chavez Preparatory Academy 252,682 23,674 276,356
Kings Canyon Joint Unified 2,276,469 81,779 2,358,248
KIPP Comienza Community Prep 253,786 27,868 281,654
KIPP Empower Academy 245,838 27,347 273,185
KIPP Los Angeles College Preparatory 248,904 27,656 276,560
KIPP Philosophers Academy 215,874 16,220 232,094
KIPP Raices Academy 250,618 27,847 278,465
Kirkwood Elementary 7 7,796 15,602 93,398
Kneeland Elementary 6 0,431 15,016 75,447
Knights Ferry Elementary 7 3,287 3 ,172 76,459
Knightsen Elementary 229,827 32,720 262,547
La Canada Unified School District 604,695 74,659 679,354
Lafayette Elementary 663,466 46,506 709,972
Laguna Joint Elementary 8,344 - 8,344
Lake County International Charter 6 3,445 15,745 79,190
Lake County Office of Education 7 4,941 4 ,000 78,941
Lakeport Unified School District (2 EEPs) (EEP #6002) 135,095 - 135,095
Lakeport Unified School District (2 EEPs) (EEP #6006) 430,297 - 430,297
Lakeside Union 520,795 40,097 560,892
Larchmont Charter 413,234 20,000 433,234
Larkspur-Corte Madera 146,940 - 146,940
Las Virgenes Unified 1,513,974 30,515 1,544,489
Lassen County Office of Education 6 8,080 8 ,900 76,980
Laton Joint Unified 292,746 - 292,746
Leonardo da Vinci Health Sciences Charter 189,487 - 189,487
Lewiston Elementary School 6 8,270 10,000 78,270
Life Learning Academy Charter 7 5,617 - 75,617
Lincoln Elementary 796 - 796
Lincoln Unified 2,060,422 80,000 2,140,422
Linden Unified School District 457,353 85,127 542,480
Livermore Valley Joint Unified School District (2 EEPs) (EEP #2757 ) 730,896 159,280 890,176
Livermore Valley Joint Unified School District (2 EEPs) (EEP #1833 ) 680,796 159,280 840,076
Loma Prieta Joint Union Elementary 241,866 9 ,293 251,159
Loomis Union Elementary (2 EEPs) (EEP #5281) 123,543 - 123,543
Loomis Union Elementary (2 EEPs) (EEP #1770) 374,366 - 374,366
Los Altos Elementary 851,036 80,750 931,786
Lowell Joint 715,723 - 715,723
Lucia Mar Unified 2,331,825 143,126 2,474,951
Lynwood Unified School District 3,883,184 - 3,883,184
MAAC Community Charter 231,518 3 ,944 235,462
Madera County Independent Academy 247,902 16,038 263,940
Magnolia Elementary 1,831,067 - 1,831,067
Magnolia Science Academy 3 8 2,247 27,170 109,417
Magnolia Science Academy 4 3,522 26,204 29,726
Magnolia Science Academy 7 238,410 26,371 264,781
Magnolia Union Elementary 251,770 - 251,770
Manchester Union Elementary 7 2,899 - 72,899
Manhattan Beach USD 1,314,205 - 1,314,205
Manzanita Middle 124,017 51,838 175,855
Manzanita Public Charter 8 7,224 49,715 136,939
Marin County Office of Education 210,669 - 210,669
Marysville Joint Unified 2,323,979 - 2,323,979
Maxwell Unified 216,803 48,248 265,051
McCabe Union Elementary 477,954 55,500 533,454
McGill School of Success 155,945 - 155,945
McKinleyville Union Elementary 512,875 30,000 542,875
Mendota Unified 780,291 52,117 832,408
Millbrae Elementary 519,763 - 519,763
Millennium Charter 251,656 4 ,000 255,656
-10-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Millville Elementary 242,220 15,789 258,009
Mission Union Elementary (2 EEPs) (EEP #5765) 3 1,499 - 31,499
Mission Union Elementary (2 EEPs) (EEP #5786) 5 8,705 - 58,705
Modoc Joint Unified School District (2 EEPs) (EEP #2242) 2 2,754 - 22,754
Modoc Joint Unified School District (2 EEPs) (EEP #6046) 6 1,356 - 61,356
Monroe Elementary 177,771 32,579 210,350
Monterey County Office of Education 276,839 - 276,839
Montgomery Elementary 5 0,416 15,016 65,432
Moraga Elementary 461,308 38,880 500,188
Moreno Valley Community Learning Center 7 8,168 - 78,168
Morrice Schaefer Charter 212,667 15,611 228,278
Mountain House Elementary 2 2,264 13,930 36,194
Mountain Oaks 196,050 6 ,000 202,050
Mountain School 7 7,729 29,766 107,495
Mountain View Elementary 526,300 11,500 537,800
Mountain View Montessori Charter 205,665 51,190 256,855
Mt. Baldy Joint Elementary 166,176 - 166,176
Muir Charter (2 EEPs) (EEP #5806) 104,429 - 104,429
Muir Charter (2 EEPs) (EEP #5805) 175,571 42,731 218,302
Natomas Charter 454,717 70,464 525,181
Needles Unified 295,211 - 295,211
Nevada City Charter 2 1,781 - 21,781
Nevada City Elementary 250,521 17,000 267,521
Newark Unified School District 456,551 50,000 506,551
Newman-Crows Landing Unified (2 EEPs) (EEP #1286) 8 0,840 32,130 112,970
Newman-Crows Landing Unified (2 EEPs) (EEP #5342) 558,039 46,700 604,739
Newport-Mesa Unified 168,015 - 168,015
Nightingale Charter 164,095 50,000 214,095
Norris Elementary 937,816 56,142 993,958
North County Joint Union Elementary 266,106 - 266,106
North Cow Creek Elementary 205,051 12,000 217,051
North Monterey County Unified 1,110,864 10,517 1,121,381
Norwalk-La Mirada Unified 155,508 289,023 444,531
Novato Charter School 1 3,477 - 13,477
Nuestro Elementary 243,390 9 ,400 252,790
Nuview Bridge Early College High 256,132 - 256,132
Oak Grove Union Elementary 6 8,198 - 68,198
Oakdale Joint Unified 1,055,143 - 1,055,143
Oakland School for the Arts 228,844 - 228,844
Olivet Elementary Charter 209,760 16,574 226,334
Orange County Department of Education 1,749,984 36,275 1,786,259
Orange Unified 6,414,668 - 6,414,668
Orchard Elementary 282,166 - 282,166
Orcutt Academy Charter 238,489 26,274 264,763
Orcutt Union Elementary 954,046 63,725 1,017,771
Orinda Union Elementary School District 466,170 45,000 511,170
Oroville City Elementary 412,241 - 412,241
Pacheco Union Elementary School District 272,780 - 272,780
Pacific Collegiate Charter 202,152 50,665 252,817
Pacific Elementary 130,737 50,349 181,086
Pacific Law Academy 210,572 49,000 259,572
Pacific Union Elementary (2 EEPs) (EEP #5922) 239,743 - 239,743
Pacific Union Elementary (2 EEPs) (EEP #6045) 230,700 39,214 269,914
Pacoima Charter Elementary 557,872 23,429 581,301
Palm Desert Charter Middle 543,761 - 543,761
Palos Verdes Peninsula Unified (2 EEPs) (EEP #5161) 761,737 100,457 862,194
Palos Verdes Peninsula Unified (2 EEPs) (EEP #5162) 1,474,680 100,457 1,575,137
Panoche Elementary 1 9,661 - 19,661
Paradise Unified 646,852 65,000 711,852
Paramount Unified 3,983,320 144,416 4,127,736
Parlier Unified 757,470 130,000 887,470
Pasadena Rosebud Academy 230,913 - 230,913
Pasadena Unified (3 EEPs) (EEP #5235) 422,243 254,178 676,422
Pasadena Unified (3 EEPs) (EEP #2153) 2,970,437 254,178 3,224,615
Pasadena Unified (3 EEPs) (EEP #3880) 574,972 254,178 829,150
Peabody Charter School 260,035 15,631 275,666
-11-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Perris Elementary 1,157,580 44,865 1,202,445
Perris Union High 2,319,507 - 2,319,507
Petaluma Joint Union High 1,014,023 72,467 1,086,490
Piedmont City Unified 532,424 - 532,424
Piner-Olivet Charter 203,770 10,317 214,087
Piner-Olivet Union Elementary 207,091 18,241 225,332
Pioneer Technical Center 244,685 6 ,570 251,255
Pioneer Union Elementary 205,526 51,916 257,442
Pittman Charter 287,356 - 287,356
Pivot Charter School North Valley 6 2,160 15,362 77,522
Pivot Online Charter - North Bay 120,789 15,753 136,542
Placer Union High 420,265 32,400 452,665
Placerville Union Elementary 513,732 30,800 544,532
Plainsburg Union Elementary 203,626 - 203,626
Plaza Elementary School District 248,704 - 248,704
Pomona Unified School District (2 EEPs) (EEP #4994) 497,269 404,635 901,904
Pomona Unified School District (2 EEPs) (EEP #1999) 1,780,000 404,635 2,184,635
Pope Valley Union Elementary 6 7,963 7 ,898 75,861
Porterville Unified (2 EEPs) (EEP #1290) 811,442 17,915 829,357
Porterville Unified (2 EEPs) (EEP #2411) 2,432,693 196,794 2,629,487
Primary Charter 225,485 7 ,000 232,485
Provisional Accelerated Learning Academy 231,844 25,760 257,604
Public Safety Academy of San Bernardino 240,791 30,947 271,738
PUC Excel Charter Academy 241,307 27,408 268,715
Redwood City Elementary 1,921,767 133,162 2,054,929
Redwood Coast Montessori 7 7,595 15,274 92,869
Redwood Preparatory Charter 149,944 50,554 200,498
Reeds Creek Elementary 222,934 51,125 274,059
Renaissance Arts Academy 267,739 - 267,739
Rialto Unified School District (2 EEPs) (EEP #1116) 1,101,775 34,000 1,135,775
Rialto Unified School District (2 EEPs) (EEP #5568) 3,259,132 64,000 3,323,132
Richgrove Elementary 296,010 - 296,010
Richmond College Preparatory 237,942 26,746 264,688
Richmond Elementary 251,634 - 251,634
Rio Dell Elementary 215,044 35,580 250,624
Rio Elementary 602,337 109,686 712,023
River Valley Charter 250,975 - 250,975
Roberts Ferry Union Elementary 115,262 3 ,030 118,292
Rocketship Academy Brilliant Minds 5 1,119 23,165 74,284
Rocketship Alma Academy 7 0,776 23,165 93,941
Rocketship Spark Academy 8 2,425 - 82,425
Rockford Elementary 254,175 - 254,175
Rosedale Union Elementary 1,091,875 32,500 1,124,375
Roseville City Elementary 905,624 58,500 964,124
Roseville Joint Union High (2 EEPs) (EEP #398) 1,475,310 - 1,475,310
Roseville Joint Union High (2 EEPs) (EEP #5610) 597,255 - 597,255
Ross Elementary 211,481 32,000 243,481
Sacramento Valley Charter 251,947 251,947
Salinas City Elementary (2 EEPs) (EEP #5609) 1,878,759 59,004 1,937,763
Salinas City Elementary (2 EEPs) (EEP #491) 256,422 70,996 327,418
Salinas Union High 3,493,208 - 3,493,208
San Ardo Union Elementary 6 9,439 - 69,439
San Bernardino County Office of Education 620,932 - 620,932
SAN JACINTO UNIFIED SCHOOL DISTRICT 1,021,604 136,615 1,158,219
San Juan Choices Charter 204,778 51,266 256,044
San Juan Unified School District 865,595 400,049 1,265,644
San Lorenzo Valley Unified School District (2 EEPs) (EEP #5748) 163,315 - 163,315
San Lorenzo Valley Unified School District (2 EEPs) (EEP #5749) 328,642 - 328,642
San Luis Coastal Unified School District 963,790 130,000 1,093,790
San Mateo Union High 1,618,047 129,993 1,748,040
San Ramon Valley Unified 146,119 308,720 454,839
Santa Ana Unified School District (2 EEPs) (EEP #5666) 2,808,331 182,606 2,990,937
Santa Ana Unified School District (2 EEPs) (EEP #5665) 2,277,815 46,600 2,324,415
Santa Barbara County Office of Education 266,062 - 266,062
Santa Barbara Unified 2,572,274 92,250 2,664,524
Santa Clara Unified 3,400,820 55,794 3,456,614
-12-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Santa Cruz City High (2 EEPs) (EEP #4933) 794,411 - 794,411
Santa Cruz City High (2 EEPs) (EEP #5722) 121,436 - 121,436
Santa Cruz County Office of Education (2 EEPs) (EEP #5795) 225,607 - 225,607
Santa Cruz County Office of Education (2 EEPs) (EEP #5796) 6 5,651 - 65,651
Santa Maria-Bonita 3,942,896 230,704 4,173,600
Santa Monica-Malibu Unified 2,313,140 93,125 2,406,265
Santa Rita Union Elementary (2 EEPs) (EEP #5763) 696,335 - 696,335
Santa Rita Union Elementary (2 EEPs) (EEP #5762) 115,438 - 115,438
Santa Rosa Academy (2 EEPs) (EEP #5643) 139,408 - 139,408
Santa Rosa Academy (2 EEPs) (EEP #5642) 379,419 - 379,419
Santa Ynez Valley Charter School 9 0,039 50,048 140,087
Saratoga Union Elementary 420,882 420,882
Savanna Elementary 9 1,070 52,291 143,361
Scotts Valley Unified 358,908 - 358,908
Sebastopol Independent Charter 8 7,730 - 87,730
Sebastopol Union Elementary 250,801 17,902 268,703
Seeley Union Elementary 206,004 55,104 261,108
Shandon Joint Unified 163,725 - 163,725
Sherman Oaks Elementary School 264,348 6 ,690 271,039
Sierra Vista Charter High 2 8,387 - 28,387
Silver Valley Unified 412,891 107,407 520,298
Simi Valley Unified 2,021,268 114,000 2,135,268
Siskiyou Union High 230,652 14,500 245,152
Sixth Grade Charter Academy at Petaluma Jr. High 7 0,858 4 ,987 75,845
SLVUSD Charter 250,831 - 250,831
Solano County Office of Education 217,248 1 ,495 218,743
Soledad Unified 1,176,737 - 1,176,737
Sonora Elementary 259,947 12,160 272,107
South Bay Charter 6 2,558 15,544 78,102
South Bay Union Elementary 215,771 54,689 270,460
South Monterey County Joint Union High 616,791 - 616,791
South Pasadena Unified 918,269 73,515 991,784
South San Francisco Unified 1,866,597 40,000 1,906,597
South Whittier Elementary 789,343 19,300 808,643
Southern Humboldt Joint Unified 251,329 26,383 277,712
Southside Elementary 219,702 4 ,642 224,344
Spreckels Union Elementary 208,094 52,440 260,534
Stanislaus Alternative Charter 210,926 - 210,926
Steele Canyon High 399,229 34,790 434,019
Stella Middle Charter Academy 3 3,055 - 33,055
Stockton Unified Early College Academy 264,433 - 264,433
Stockton Unified School District 1,525,479 147,592 1,673,071
Summerville Elementary 253,167 10,640 263,807
Summerville Union High 226,783 30,817 257,600
Summit Charter Academy 574,236 - 574,236
Summit Leadership Academy-High Desert 188,704 - 188,704
Sunnyvale (3 EEPs) (EEP #2414) 762,005 - 762,005
Sunnyvale (3 EEPs) (EEP #2428) 535,687 - 535,687
Sunnyvale (3 EEPs) (EEP #5418) 6 9,076 - 69,076
Sunrise Middle 190,189 35,091 225,280
Surprise Valley Joint Unified 5 3,647 - 53,647
Susanville Elementary 307,696 33,595 341,291
Taft City 605,975 22,000 627,975
TEACH Academy of Technologies 243,105 27,069 270,174
Tehachapi Unified 954,967 - 954,967
The Education Corps 218,442 - 218,442
The O'Farrell Charter 519,485 58,166 577,651
Torrance Unified School District (2 EEPs) (EEP #2143) 803,440 - 803,440
Torrance Unified School District (2 EEPs) (EEP #2163) 3,056,900 - 3,056,900
Trillium Charter 2 5,000 5 ,933 30,933
Trinity Center Elementary 6 0,412 15,075 75,487
Tulare Joint Union High 1,283,316 - 1,283,316
Tuolumne County Superintendent of Schools 6 9,359 8 ,797 78,156
Turlock Unified (2 EEPs) (EEP #5184) 153,766 - 153,766
Turlock Unified (2 EEPs) (EEP #5959) 2,956,595 - 2,956,595
Union Hill Elementary (2 EEPs) (EEP #5741) 207,884 50,000 257,884
-13-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Schedule (continued)
Program Planning Amount
Local Educational Agency Implementation Funds 1 Total Unallowable Reference 2
Completed projects not selected for audit (continued):
Union Hill Elementary (2 EEPs) (EEP #5735) 209,670 - 209,670
Union Joint Elementary 3,144 - 3,144
University High 217,769 - 217,769
Upper Lake Unified 387,630 - 387,630
Vallecito Union 258,808 28,430 287,238
Vallecitos Elementary 246,583 5 ,540 252,123
Vallejo Charter 267,999 - 267,999
Vallejo City Unified 2,712,081 193,000 2,905,081
Valley Oaks Charter 148,370 8 ,500 156,870
Valley Preparatory Academy Charter 242,953 27,044 269,997
Valor Academy Middle 268,824 - 268,824
Ventura County Office of Education 260,929 22,970 283,899
Visalia Technical Early College 230,352 27,351 257,703
Visalia Unified 5,721,831 379,039 6,100,870
Visions In Education 387,430 78,000 465,430
Washington Unified 8 2,667 51,128 133,795
Washington Unified (2 EEPs) (EEP #5165) 1,077,909 - 1,077,909
Washington Unified (2 EEPs) (EEP #5669) 428,987 - 428,987
Washington Union Elementary 251,734 - 251,734
Watsonville Charter School of the Arts 113,068 - 113,068
West Side Union Elementary 202,351 50,491 252,842
West Sonoma County Union High 428,180 88,531 516,711
Western Sierra Collegiate Academy 235,457 15,040 250,497
Westmorland Union Elementary 191,022 55,019 246,041
Whitmore Charter High 117,136 50,475 167,611
Whitmore Charter School of Art & Technology 100,608 53,485 154,093
Whittier Union High 3,122,641 - 3,122,641
William Finch 163,797 13,630 177,427
Willow Creek Academy 246,707 15,014 261,721
Winton 589,886 25,896 615,782
Woodland Star Charter 131,800 16,000 147,800
Woodside Elementary 252,360 - 252,360
Wright Charter 248,729 25,377 274,106
Wright Elementary 508,940 46,909 555,849
Yav Pem Suab Academy - Preparing for the Future Charter 224,104 49,000 273,104
Yosemite Unified 512,502 45,794 558,296
Yu Ming Charter 224,760 25,135 249,895
Yuba City Charter 127,785 51,838 179,623
Yucaipa-Calimesa Joint Unified 1,804,441 130,000 1,934,441
Total, completed projects not selected for audit 302,141,775 20,527,450 322,669,225
Total completed projects $ 313,302,972 $ 28,684,839 $ 3 41,987,811
_________________________
1 The planning funds are requested directly from CDE before an EEP is submitted.
2 See the Findings and Recommendations section.
-14-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Findings and Recommendations
FINDING 1— We found that two local educational agencies (LEAs) sole-sourced a
portion of their project costs, totaling $508,108. The table below
Sole-sourced
summarizes this finding:
project costs
Sole-sourced
Local Educational Agency Amount
Banta Unified School District $ 166,801
Bishop Unified School District 341,307
Total $ 508,108
These two LEAs did not provide supporting documentation to show that
they considered other vendors before awarding contracts. The LEAs
contracted with various vendors for their Proposition 39 program energy
upgrade projects. Despite the implementation guidance and best practices,
the LEAs used noncompetitive processes to sign contracts with these
vendors and, thus, did not ensure the cost effectiveness of these services.
Public Resources Code (PRC) section 26235(c) states, in part, “A
community college district or LEA shall not use a sole source process to
award funds pursuant to this chapter.”
We have interpreted the requirement to “not use a sole source process to
award funds” as the necessity for a competitive process. Competitive
processes improve cost-effectiveness, prevent favoritism, and make the
procurement process transparent.
PRC section 26240(h)(1) states, “The Superintendent of Public Instruction
shall require local education agencies to pay back funds if they are not
used in accordance with state statute or regulations. . . . ”
Recommendation
We recommend that the California Department of Education (CDE) take
appropriate action in response to funds paid to LEAs that did not meet the
sole-source requirement. No additional recommendation for LEAs is
applicable to this finding, as the Proposition 39 program has ended.
LEAs’ Responses
We notified the two LEAs of this finding during our audit fieldwork and
at the end of the audit via email. Appendix A includes Findings and
Recommendations for individual LEAs and the LEAs’ responses. Formal
responses received on letterhead are included as an Attachment.
-15-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
We found that three LEAs did not identify the projected energy savings in
FINDING 2—
the awarded contracts as required. The table below summarizes this
Projected energy
finding:
savings not identified
in contracts
Projected
Energy
Savings Not
Local Educational Agency Identified
Banta Unified School District X
Bishop Unified School District X
San Marcos Unified School District X
This finding does not result in questioned costs; however, ensuring that
contracts include projected energy savings helps to ensure that program
objectives are achieved.
PRC section 26206(d) states, “All projects shall require contracts that
identify the project specifications, costs, and projected energy savings.”
Recommendation
No recommendation for the LEAs is applicable to this finding, as the
Proposition 39 program has ended.
LEAs’ Responses
We notified the affected LEAs of this finding during our audit fieldwork
and at the end of the audit via email. Appendix A includes Findings and
Recommendations for individual LEAs and the LEAs’ responses. Formal
responses received on letterhead are included as an Attachment.
We found that four LEAs submitted their final project completion reports
FINDING 3—
after the deadline. Each LEA is required to submit a final project
Final project
completion report to the California Energy Commission (CEC) 12 to
completion reports
15 months after the energy expenditure plan (EEP) is completed. An EEP
submitted after the
is considered complete when the LEA has completed all measures in the
deadline
approved EEP.
The following table identifies the number of months the final report was
submitted after the project was completed:
District Months
Banta Unified School District 17
Bishop Unified School District 23
Los Angeles Unified School District 22
San Marcos Unified School District 22
LEAs should submit timely final reports to the CEC to allow the CEC to
respond promptly to changing situations and maintain effective program
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
oversight. Information contained in the final reports is compiled into a
report that the CEC submits annually to the Citizens Oversight Board.
PRC section 26240(b) states, in part:
As a condition of receiving funds from the Job Creation Fund . . . , not
sooner than one year but no later than 15 months after an entity
completes its first eligible project with grant, loan, or other assistance
from the Job Creation Fund . . . , the entity shall submit a report of its
project expenditures to the Citizens Oversight Board. . . . To the extent
practical, this report shall also contain information on any of the
following:
(1) The total final gross project costs before deducting any incentives or
other grants and the percentage of total project costs derived from
the Job Creation Fund. . . .
(2) The estimated amount of energy saved, accompanied by specified
energy consumption and utility bill cost data for the individual
facility where the project is located, in a format to be specified by
the Energy Commission.
(3) The nameplate rating of new clean energy generation installed.
(4) The number of trainees.
(5) The number of direct full-time equivalent employees and the
average number of months or years of utilization of each of these
employees.
(6) The amount of time between awarding of the financial assistance
and the completion of the project or training activities.
(7) The entity’s energy intensity before and after project completion, as
determined from an energy rating or benchmark system. . . .
Recommendation
No recommendation for LEAs is applicable to this finding, as the
Proposition 39 program has ended.
LEAs’ Responses
We notified the four LEAs of this finding during our audit fieldwork and
at the end of the audit via email. Appendix A includes Findings and
Recommendations for individual LEAs and the LEAs’ responses. Formal
responses received on letterhead are included as an Attachment.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Appendix A—
Audit Results by Local Educational Agency
Banta Unified School District ................................................................................................ A2
Bishop Unified School District .............................................................................................. A6
Los Angeles Unified School District ..................................................................................... A13
Rim of the World Unified School District ............................................................................ A14
San Marcos Unified School District ..................................................................................... A15
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Banta Unified School District
Proposition 39 Program
Background The California Energy Commission (CEC) approved Banta Unified
School District’s energy expenditure plan (EEP) for $187,327, consisting
of $21,403 for energy management, $3,597 for training and services, and
$162,327 for program implementation. The district used its program
implementation funds for the following energy efficiency measures:
Proposition 39 Reported
Share Used Energy Annual Cost
School Site at School Site Efficiency Measures Savings
Banta Elementary $ 128,128 HVAC-Packaged/split system AC/Heat Pump/VRF $ 1,296
NextGeneration STEAM Academy 295 Interior lighting retrofit - convert compact fluorescent lamps to LED 5,358
NextGeneration STEAM Academy 58,904 Interior lighting retrofit - convert T8 fluorescent lamps to LED 5,358
Total $ 187,327 $ 12,012
With these energy efficiency measures, the district reported a combined
savings-to-investment ratio (SIR) of 1.01 and the creation of 0.91 direct
job-years.
In addition, the district received $11,480 in planning funds directly from
the California Department of Education (CDE), which it used for program
assistance.
We audited the Proposition 39 program costs to ensure compliance with
Audit Results
the Job Creation Fund program guidelines, as well as the CEC’s
Proposition 39: California Clean Energy Jobs Act – 2016 Program
Implementation Guidelines (2016 Program Implementation Guidelines)
and Proposition 39: California Clean Energy Jobs Act – 2015 Energy
Expenditure Plan Handbook (EEP Handbook). We identified the
following findings:
The district sole-sourced its $166,801 contract with Indoor Environmental
FINDING 1—
Services (IES) for facility solutions services. The district did not provide
Sole-sourced
supporting documentation to show that it considered other vendors before
project costs
awarding its contract to IES. Therefore, we found that the school district
sole-sourced this Proposition 39 contract.
Public Resources Code (PRC) section 26235(c) states, in part, “A
community college district or LEA [local educational agency] shall not
use a sole source process to award funds pursuant to this chapter.”
PRC section 26240(h)(1) states, “The Superintendent of Public Instruction
shall require local education agencies to pay back funds if they are not
used in accordance with state statute or regulations. . . . ”
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
We reviewed the district’s contract with IES and determined that the
FINDING 2—
contract did not identify the projected energy savings.
Projected energy
savings not identified
PRC section 26206(d) states, “All projects shall require contracts that
in contracts
identify the project specifications, costs, and projected energy savings.”
The district’s final report was submitted on April 6, 2020, which is
FINDING 3—
17 months after the reported project completion date of November 30,
Final project
2018.
completion reports
submitted after the
PRC section 26240(b) states, in part:
deadline
As a condition of receiving funds from the Job Creation Fund . . . , not
sooner than one year but no later than 15 months after an entity
completes its first eligible project with grant, loan, or other assistance
from the Job Creation Fund . . . , the entity shall submit a report of its
project expenditures to the Citizens Oversight Board. . . .
Recommendation
We recommend that the CDE take appropriate action in response to funds
paid to the district that did not meet the sole-source requirement. No
additional recommendation is applicable for the other two findings that we
identified, as the Proposition 39 program has ended.
District’s Response
We informed the district of the audit findings via email on February 14,
2022. Andi Lopez, Business Services Supervisor, responded by letter
dated February 23, 2022. The district’s response letter is included as
Attachment A.
The district’s response to Finding 1 is as follows:
The District relied on the professional knowledge and expertise of the
contractors, who also benefited from the implementation of
Proposition 39 improvements to the District. The passage of time and
change in staff has made it difficult to now search past records, emails,
documents, and recollections. Despite this, the District strongly believes
that it did not sole-source the contract and that it complied with legal
requirements for contracting under Proposition 39. . . .
The district’s current and past practice regarding contracting is to
competitively bid projects in accordance with law. Board
Resolution 17/18-19 made certain findings, consistent with Government
Code (GC) section 4217, including that the District “has conducted a
selection of process related to the development and implementation of
Proposition 39 projects, and has selected IES based on their
qualifications and references as to be ‘Best Value’.” Discussion with a
former superintendent and a former Board member confirm this and both
individuals believed that the District complied with requirements to bid
the project.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
The district’s response to Finding 2 is as follows:
Resolution 17/18-19 also stated that “based on comments, staff reports
and documents reviewed by the Board, the Board makes the formal
findings that the costs of the project will be offset by the anticipated
savings in energy consumption.” That step was consistent with
requirements of law (reaching conclusions similar in nature to those
required by GC section 4217). The Board made sufficient findings by
way of this Resolution to award the work to demonstrate substantial
compliance.
The IES Contract (“Contract”), at page C-5, includes the “Basis of
Engineering” which states that the Agreement “should be considered in
conjunction with the CEC approved energy savings forecast that are
presented in the amended Customer’s EEP, as required by Proposition
39 California Clean Energy Jobs Act.”
In regard to lighting, the Contact, at page C-7, states that “Energy savings
are realized due to the fact that total input watts of the lighting fixture
will be reduced.” In regard to heating, ventilation, and air conditioning
(HVAC), the Contract, at page C-9, states that “the intent of this project
is to reduce the Customer’s utility costs and operational expenses by
replacing the existing HVAC equipment with new high energy efficient
units.” The District’s contract with IES included statements regarding
energy savings in the Contract.
The district did not respond to Finding 3.
SCO Comment
Our findings and recommendations remain unchanged. We will address
the district’s responses in the order presented.
Finding 1—Sole-sourced project costs
During the audit, we worked with the district to find documentation
supporting that it conducted a competitive bidding process. During that
time, the district was ultimately able to support competitive bidding for its
planning services, but not for its project implementation costs. During a
meeting on February 8, 2022, the district’s Budget and Accounting
Consultant advised that the district was familiar with vendor IES and felt
comfortable awarding its contract to the company without completing a
formal bid solicitation.
In its formal response, the district cites reliance on GC section 4217.
Specifically, section 4217.12 relates to districts entering into energy
conservation contracts. The district also cites using “best value” criteria,
although the California State Legislature repealed the “best value”
provisions of PRC section 20133(c) in 2014. As a result, this statute was
not applicable when the district entered into its contract with IES.
In addition, we believe that PRC section 26235(c), is a requirement in
order to award funding under the Proposition 39 program. It does not affect
how other contracting provisions apply to other projects. As the district
applied for and obtained funding from the Proposition 39 program, it must
comply with the prohibition of using a sole-source process, and instead
use a competitive process in awarding its contracts for this program.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Finding 2—Projected energy savings not identified in contracts
Although we recognize that the district participated in the program to the
best of its ability, the scope of our audit is to ensure compliance with state
statutes and regulations. These requirements state that LEAs must identify
projected energy savings in the awarded contracts.
The program’s provisions require only an estimate of the projected energy
savings. We would also point out that no financial penalty is applied to
districts for violations of this program provision.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Bishop Unified School District
Proposition 39 Program
Background The CEC approved Bishop Unified School District’s EEP for $569,811,
consisting of $45,563 for energy management, $9,112 for training and
services, and $515,136 for program implementation. The district used its
program implementation funds for the following energy efficiency
measures:
Proposition 39 Reported
Share Used Energy Annual Cost
School Site at School Site Efficiency Measures Savings
Bishop Union High $ 325,056 Lighting-exterior retrofit, HVAC-chiller/boiler replacement $ 9,169
Home Street Middle 190,080 Lighting-interior retrofit, lighting controls 14,826
Total $ 515,136 $ 23,995
With these energy efficiency measures, the district reported a combined
SIR of 1.08 and the creation of 2.88 direct job-years.
We audited the Proposition 39 program costs to ensure compliance with
Audit Results
the Job Creation Fund program guidelines, as well as the CEC’s 2016
Program Implementation Guidelines and EEP Handbook. We identified
the following audit findings:
The district sole-sourced its contract with IES for energy manager services
FINDING 1—
($49,637), and for facility solution services ($291,670). The district did
Sole-sourced
not provide supporting documentation to show that it considered other
project costs
vendors before awarding its contract to IES. Therefore, we found that the
school district sole-sourced this Proposition 39 contract,
totaling $341,307.
PRC section 26235(c) states, in part, “A community college district or
LEA shall not use a sole source process to award funds pursuant to this
chapter.”
PRC section 26240(h)(1) states, “The Superintendent of Public Instruction
shall require local education agencies to pay back funds if they are not
used in accordance with state statute or regulations. . . . ”
We reviewed the district’s contracts with IES and determined that the
FINDING 2—
contracts did not identify the projected energy savings.
Projected energy
savings not identified
PRC section 26206(d) states, “All projects shall require contracts that
in contracts
identify the project specifications, costs, and projected energy savings.”
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
The district’s final report was submitted on February 10, 2020, which is
FINDING 3—
23 months after the reported project completion date of March 31, 2018.
Final project
completion reports
PRC section 26240(b) states, in part:
submitted after the
deadline
As a condition of receiving funds from the Job Creation Fund . . . , not
sooner than one year but no later than 15 months after an entity
completes its first eligible project with grant, loan, or other assistance
from the Job Creation Fund . . . , the entity shall submit a report of its
project expenditures to the Citizens Oversight Board. . . .
Recommendation
We recommend that the CDE take appropriate action in response to funds
paid to the district that did not meet the sole-source requirement. No
additional recommendation is applicable for the other two findings that we
identified, as the Proposition 39 program has ended.
District’s Response
We informed the district of the audit findings via email on January 27,
2022. Midge Milici, Chief Business Officer, responded by letter dated
February 8, 2022. The district’s response letter is included as
Attachment B.
The district’s response to Finding 1 is as follows:
The District believes that it acted in good faith and complied with the
relevant program requirements in entering into these contracts.
A. The District Complied with Proposition 39 and Applicable State
and Local Law in Awarding these Contracts.
Public Resources Code section 26235(c) (“Section 26235(c)”) provides
that an “LEA shall not use a sole source process to award funds pursuant
to this chapter.” Section 26235(c) further provides that “an LEA may use
the best value criteria as defined in paragraph (1) of subdivision (c) of
Section 20133 of the Public Contract Code to award funds pursuant to
this chapter.” (Emphasis added.) Notably, Section 26235(c) does not
define the term “sole source,” describe the precise scope of the sole
source limitation, or limit the procurement methods by which school
districts may comply with the limitation (i.e., it does not state that an
LEA may only use the best value method).
The language of Section 26235(c) leaves open the door for school
districts to utilize procurement methods other than traditional
competitive bidding and best value criteria to comply with its no sole
source limitation, which is consistent with longstanding state law.
Moreover, although Section 26235(c) generally regulates contract
procurement using Proposition 39 funds, other state laws specifically
regulate procurement of specific types of contracts, such as those here,
and therefore should operate as an exception to Section 26235(c)‘s
general provisions. (See Code Civ. Proc.§ 1859 [“when a general and
particular provision are inconsistent, the latter is paramount to the
former”]; (State Dept. of Public Health c. Superior Court (2015)
60 Cal. 4th 940, 961 [“it is the general rule that . . . the special act will
be considered as an exception to the general statute . . .”].)
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
GC section 53060 permits a school district to “contract with and employ
any persons for the furnishing [of] special services and advice in
financial, economic, accounting, engineering, legal, or administrative
matters,” without bid or with a very informal process. Although this bid
exception lists specified categories, it is applied broadly to include any
special services rendered to a school district. (See Fair Education Santa
Barbara v. Santa Barbara Unified School Dist. (2021) 72 Cal. App. 5th
884.) Services are special based on their specialized nature to the school
district, the qualifications necessary to furnish the services, and their
availability from public sources. (See Jaynes v. Stockton (1961)
193 Cal. App. 2d 47.)
The contracts at issue here were separate agreements for services. The
first agreement was for services related to energy efficiency upgrades
and engineering, construction management, and installation of the same
(the “Facility Solutions Agreement”). The second agreement was for
services related to energy management, student energy education, and
staff energy training (the “Energy Manager Agreement”). As evidenced
by the difficulty the District had in finding a vendor who could perform
the work under these contracts, the services were specialized to the
District, the vendor had particular expertise and qualifications necessary
for the work, and the services were otherwise unavailable to the District.
These were therefore specialized services under GC section 53060 and
did not require bidding.
The Energy Manager Agreement additionally fell within the purview of
state law related to contracts for services. Public Contract Code
section 20111 and corresponding California Department of Education
guidance indicate that a school district, as of 2017, did not need to
competitively bid contracts for services that were valued at less than
$88,300. (Pub. Contract Code,§ 20111, subd. (a)(l).) As a contract for
services valued at $49,637, the Energy Manager Agreement was well-
below the competitive bidding threshold.
Finally, the Facility Solutions Agreement expressly included significant
engineering and construction management services, which fall within the
scope of GC section 4526. This section provides in relevant part,
“[n]otwithstanding any other provision of the law, selection by a state or
local agency head for professional services of private architectural,
landscape architectural, engineering, environmental, land surveying, or
construction project management firms shall be on the basis of
demonstrated competence and on the professional qualification
necessary for the satisfactory performance of the services required.” (See
id., emphasis added.) The District was therefore authorized under the law
to enter into the Facility Solutions Agreement based on the demonstrated
competence of the vendor as opposed to competitive bidding.
The District’s contracts with IES were entered into in good faith and in
compliance with longstanding law specifically regulating the
procurement methods use by the District, and based on the belief those
methods did not conflict with the sole source limitation.
B. The District complied with the Sole Source Limitation even if it
applied to these Contracts.
While Section 26235(c) provides little detail regarding the procurement
methods that an LEA may use in the Proposition 39 context, the
California Energy Commission (“CEC”), in its “Frequently Asked
Questions California Clean Energy Jobs Act (Proposition 39),” (“FAQ”)
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
sheds some light on this issue. The FAQ provides that an “LEA shall
defer to [its] own procurement regulations and procedures, as long as
they reflect applicable state and local laws and regulations and do not
conflict with the minimum legal standards specified above.” (FAQ
(2020) California Energy Commission, at p. 27
<https://www.energy.ca.gov/sites/default/files/2020-05/prop39_k-12_f
aq_ada.pdf> [as of Mar. 18, 2020].)
Here, the District used its own procurement regulations based on and in
compliance with the applicable state law discussed above. The
procurement of the contracts at issue therefore complied with
Section 26235(c)’s sole source limitation.
C. The District Did Not Sole Source these Contracts.
The District did not “sole source” these contracts. While
Section 26235(c) does not define “sole source” as used in that section,
Public Resources Code section 25620.5(e) presents analogous language,
indicating that “single source” procurement involves choosing from
“two or more parties.” This statute further explains that “sole source”
procurement involves less competition than single source, seemingly
implying that sole source procurement involves no form of choice
between one option or another (Pub. Resources Code, § 25620.5,
subd. (c).) So it is therefore reasonable to view “sole source” for the
purposes of Proposition 39 to mean direct contracting with one vendor
without even considering other vendors. As discussed more fully below,
the District issued a Request for Proposals and considered the
qualifications and expertise of at least two other vendors before entering
into the contracts with IES.
As detailed in the Declaration of Midge Milici, attached hereto and
incorporated by reference, the District carried out a competitive process
for all work or services that would be funded with Proposition 39 dollars.
This included issuing a Request for Qualifications (“RFQ”) in 2014,
which garnered only a single response from Ameresco, Inc. [Declaration
of Midge Milici (“Milici Declaration”), ¶¶ 2–3; Exhibit A.] For the
specific project in question, involving replacement of a diesel-fueled
boiler (“Project”), the District reached out to not one but four total
vendors before selecting Indoor Environmental Services (“IES”).
[Milici Declaration, ¶¶ 5–7.] The District respectfully submits the Milici
Declaration and exhibits thereto as documentation specifically
supporting and establishing that the District did not use a sole source
process to select and award a contract to IES.
The district’s response to Finding 2 is as follows:
The District believes that it acted in good faith and complied with the
relevant program requirements in entering into these contracts.
Section 26206(d) requires that a contract “identify” a project’s
“projected energy savings.” Neither the statute nor the Guidelines
provide any guidance on how an LEA must satisfy this requirement. For
example, neither expressly requires this projection to be expressed as a
dollar figure, a detailed chart identifying each improvement and specific
estimate of energy savings, or any other form. Absent specific direction
from the California Energy Commission, LEAs were eft with reasonable
discretion to attempt to “identify” expected savings in good faith.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Here, the District’s contract with IES does, in fact, identify the Project’s
projected energy savings, although not in a specific dollar amount.
Exhibit C, Section 1 of the Facility Solutions Agreement (“Facility
Agreement”) dated September 5, 2017, states as follows:
This Agreement should be considered in conjunction with the
California Clean Energy Commission approved energy savings
forecasts that are presented in the District's approved energy
expenditure plan, as required by Proposition 39 California
Clean Energy Jobs Act.
[Exh. C to Milici Declaration, pg. C-5.] As described in the Facility
Agreement, the District already had an approved energy expenditure
plan. Reproducing such plan within the body of the Facility Agreement
would have been unnecessarily duplicative. Rather, the Facility
Agreement specifically “identifies” the project’s “projected energy
savings” by referencing the approved energy expenditure plan and
incorporating it by reference into the Facility Agreement. It is evident
that the District made a good faith effort to strictly and substantially
comply with the requirements of Proposition 39.
Notwithstanding the above, if the Controller feels that the Facility
Agreement could have more clearly articulated the projected energy
savings for the project in order to satisfy the Controller, for future
Proposition 39 projects, the District is committed to ensuring clear
identification and articulation of the projected energy savings within the
body of the contract.
The district’s response to Finding 3 is as follows:
The District entered into an Energy Manager Contract with IES on or
about September 5, 2017 for the provision of services to “complete
documentation and reporting to the California Energy Commission
(CEC) to meet Proposition 39 project annual progress and final reporting
requirements . . .” [Exhibit B to Milici Declaration, p. 4.] This contract
specifically required IES to submit the final report to CEC within 12-15
months after project completion. The District has been informed by IES
that they submitted the report only eight days late. However, CEC’s
project manager for this project reopened the report in order to seek
additional information regarding an increase in energy usage at one of
the sites which resulted in a delay in CEC’s processing of the report.
Regardless, it is clear from the District’s efforts to hire an independent
contractor experienced in preparing such reports that the District
recognized its obligation to submit the final report and took appropriate
action in good faith to comply. The District will take steps to better
monitor its independent contractors on future projects to ensure the final
report is timely submitted.
SCO Comment
Our findings and recommendations remain unchanged. We will address
the district’s responses in the order presented.
Finding 1—Sole-sourced project costs
In its response, the district indicates its reliance on the provisions of GC
section 53060, PRC section 25620.5(e), Public Contract Code
section 20111, GC section 4526, and its own procurement policies and
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
procedures. The district cites its compliance with these sources as a valid
reason for not complying with the sole-source language of PRC
section 26235(c).
However, from our perspective, PRC section 26235(c), is a requirement in
order to award funding under the Proposition 39 program. It does not affect
how other contracting provisions apply to other projects. As the district
applied for and obtained funding from the Proposition 39 program, it must
comply with the prohibition of using a sole-source process and instead,
use a competitive process in awarding its contracts for this Program.
The district is correct that the CEC’s Proposition 39 “Frequently Asked
Questions” document1 states:
The LEA shall defer to [its] own procurement regulations and
procedures, as long as they reflect applicable state and local laws and
regulations, and do not conflict with the minimum legal standards
specified above.
In addition, the CEC’s 2016 Program Implementation Guidelines
(“Contracts,” page 35) state:
The guidelines defer to the LEA’s own procurement regulations and
procedures, as long as they reflect applicable state and local laws and
regulations, and do not conflict with the minimum legal standards
specified above.
However, the district fails to recognize that the guidelines defer to the
LEA’s own procurement regulations as long as they “do not conflict with
the minimum legal standards specified above” (emphasis added).
The “minimum legal standards specified above” are PRC
sections 26206(d), 26235(a)(2), and 26235(c). The district’s procurement
regulations conflict with the sole-source prohibition contained in PRC
section 26235(c); therefore, we found that the district’s reliance on GC
section 53060, PRC section 25620.5(e), Public Contract Code
section 20111, GC section 4560, and its own policies and procedures in
lieu of PRC section 26235(c) was misplaced.
The district’s response also includes a legal theory of sole-sourcing that is
based on PRC section 25620.5(e). We are not qualified to opine on the
validity of legal arguments. The district may choose to pursue an appeal
of the audit findings. In the cover letter to this report, we provide guidance
on filing an appeal.
In its response, the district also states that it contacted four total vendors
before selecting IES. After we received the district’s response, we
requested documentation supporting that it invited vendors other than IES
to bid on its HVAC system Proposition 39 contracts. The district provided
documentation from two local vendors that had performed periodic
maintenance on the district’s HVAC systems. Both vendors acknowledged
that the district’s HVAC system needed replacement and that the district
1 Available under the “Program Information” tab on the “California Clean Energy Jobs Act K-12 Program – Prop 39”
page of the CEC’s website. The quoted text is in the second paragraph on page 27.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
should pursue the funding to do so. However, there was no language in
these documents offering a bid to perform the project for the district.
Furthermore, the district did not provide any evidence supporting that it
asked these vendors to provide a bid on the project.
Finding 2—Projected energy savings not identified in contracts
The district states that the program guidelines provide no clear guidance
on how districts can comply with the provisions of PRC section 26206(d).
We disagree. The CEC’s 2016 Program Implementation Guidelines
(“Contracts,” page 35) state:
All contracts need a clear and accurate description of the eligible energy
project, including material, products, or services to be procured, and a
budget that includes cost and an estimate of the projected energy savings
[emphasis added].
The program’s provisions require only an estimate of the projected energy
savings. We would also point out that no financial penalty is applied to
districts for violations of this program provision.
Finding 3—Final project completion reports submitted after the deadline
The district acknowledges the late submittal of its final completion report.
We would also point out that no financial penalty is applied to districts for
violations of this program provision.
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Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Los Angeles Unified School District
Proposition 39 Program
Background The CEC approved Los Angeles Unified School District’s EEP for
$5,195,862 for program implementation. The district used its program
implementation funds for the following energy efficiency measures:
Proposition 39 Reported
Share Used Energy Annual Cost
School Site at School Site Efficiency Measures Savings
Marshall High School $ 2,086,073 HVAC, lighting exterior, & controls $ 126,036
Santee Education Complex 3,109,789 HVAC, lighting interior/exterior retrofit, DHW, pumps, motors 210,629
Total $ 5,195,862 $ 336,665
With these energy efficiency measures, the district reported a combined
SIR of 1.26 and the creation of 29.10 direct job-years.
In addition, the district received $7,884,191 in planning funds directly
from the CDE, which it used for screening and audits, energy
management, and training.
We audited the Proposition 39 program costs to ensure compliance with
Audit Results
the Job Creation Fund program guidelines, as well as the CEC’s 2016
Program Implementation Guidelines and EEP Handbook. We identified
the following audit finding:
The district’s final report was submitted on June 23, 2020, which is
FINDING—
22 months after the reported project completion date of August 31, 2018.
Final project
completion reports
PRC section 26240(b) states, in part:
submitted after the
deadline As a condition of receiving funds from the Job Creation Fund . . . , not
sooner than one year but no later than 15 months after an entity
completes its first eligible project with grant, loan, or other assistance
from the Job Creation Fund . . . , the entity shall submit a report of its
project expenditures to the Citizens Oversight Board. . . .
Recommendation
No recommendation is applicable, as the Proposition 39 program has
ended.
District’s Response
We informed the district of the audit finding via email on March 15, 2022.
Peter Yee, Senior Project Manager, responded via email on March 24,
2022, saying, “The district reviewed the identified audit issue and take[s]
no exception to the finding.”
-A13-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Rim of the World Unified School District
Proposition 39 Program
Background The CEC approved Rim of the World Unified School District’s EEP for
$851,852, consisting of $85,185 for energy management, $17,037 for
training, ant services and $749,630 for program implementation. The
district used its program implementation funds for the following energy
efficiency measures:
Proposition 39 Reported
Share Used Energy Annual Cost
School Site at School Site Efficiency Measures Savings
Rim of the World Senior High $ 749,630 Electrical-high efficiency transformer, lighting-interior fixture $ 33,193
Total $ 749,630 $ 3 3,193
With these energy efficiency measures, the district reported a combined
SIR of 1.02 and the creation of 4.20 direct job-years.
We audited the Proposition 39 program costs and found that all costs
Audit Results
reported are in compliance with the Job Creation Fund program guidelines,
as well as the CEC’s 2016 Program Implementation Guidelines and EEP
Handbook.
District’s Response
We informed the district via email on January 27, 2022, that all costs
reported for Rim of the World Unified School District are in compliance
with the program guidelines. Jenny Haberlin, Chief Business Official,
responded via email on February 9, 2022, to thank us for our assistance in
the audit process.
-A14-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
San Marcos Unified School District
Proposition 39 Program
Background The CEC approved San Marcos Unified School District’s EEP for
$4,356,645 for program implementation. The district used its program
implementation funds for the following energy efficiency measures:
Proposition 39 Reported
Share Used Energy Annual Cost
School Site at School Site Efficiency Measures Savings
Carillo Elementary School $ 412,213 Lighting-interior/exterior retrofit, HVAC-packaged/split system $ 27,340
Discovery Elementary School 35,522 Lighting-interior retrofit 4,822
Joli Ann Elementary School 41,738 Lighting-interior/exterior retrofit 5,134
Knob Hill Elementary School 350,454 Lighting-interior/exterior retrofit 23,577
Mission Hills High School 235,641 Lighting-interior/exterior retrofit 47,713
Paloma Elementary School 100,282 Lighting-interior/exterior retrofit 13,051
Richland Elementary School 116,982 Lighting-interior/exterior retrofit 7,644
San Elijo Elementary School 43,380 Lighting-interior/exterior retrofit 23,587
San Elijo Middle School 140,940 Lighting-interior/exterior retrofit 12,714
San Marcos Middle School 1,340,232 Lighting-interior/exterior retrofit 51,246
Twin Oaks Elementary School 609,108 Lighting-interior retrofit, HVAC-packaged/split system 35,066
Twin Oaks High School 345,868 HVAC-Packaged/split system AC/Heat Pump/VRF 11,225
Woodland Park Middle School 583,985 Lighting-interior/exterior, HVAC-Packaged/split system 32,527
Total $ 4,356,345 $ 295,646
With these energy efficiency measures, the district reported a combined
SIR of 1.39 and the creation of 24.40 direct job-years.
In addition, the district received $261,718 in planning funds directly from
the CDE, which it used for program assistance, screening and audits.
We audited the Proposition 39 program costs to ensure compliance with
Audit Results
the Job Creation Fund program guidelines, as well as the CEC’s 2016
Program Implementation Guidelines and EEP Handbook. We identified
the following audit findings:
We reviewed the district’s contracts with Lusardi Construction and
FINDING 1—
Jackson & Blanc and determined that the contracts did not identify the
Projected energy
projected energy savings.
savings not identified
in contracts
PRC section 26206(d) states, “All projects shall require contracts that
identify the project specifications, costs, and projected energy savings.”
The district’s final report was submitted on October 5, 2020, which is
FINDING 2—
22 months after the reported project completion date of December 31,
Final project
2018.
completion reports
submitted after the
deadline
-A15-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
PRC section 26240(b) states, in part:
As a condition of receiving funds from the Job Creation Fund . . . , not
sooner than one year but no later than 15 months after an entity
completes its first eligible project with grant, loan, or other assistance
from the Job Creation Fund . . . , the entity shall submit a report of its
project expenditures to the Citizens Oversight Board. . . .
Recommendation
No recommendation is applicable, as the Proposition 39 program has
ended.
District’s Response
We informed the district of the audit findings via email on January 27,
2022. Myra Lopez, Executive Director of Maintenance and Operations,
responded by letter dated February 8, 2022. The District’s response letter
is included as Attachment C.
The district’s response to Finding 1 is as follows:
The scope of work for these contracts were written and signed before the
savings were estimated, therefore not included in the contracts. The
District accepts the findings as outlined.
The district’s response to Finding 2 is as follows:
The due date of the final project completion report was in March 2020.
While our consultant began working on the report at the beginning of the
year, the impacts of COVID 19 Virus on their workflow ultimately
resulted in a significant delay in collecting, analyzing, and reporting all
the data. Additionally, given that this was such a comprehensive project
that spanned multiple years of construction, there were many pieces of
information needed for this report that were not readily available, and it
took some time for the new project team to gather everything.
SCO Comment
Our findings and recommendations remain unchanged.
Although we recognize that the district participated in the program to the
best of its ability, the scope of our audit is to ensure compliance with state
statutes and regulations, which require that the final project report be
submitted within 12–15 months of completion of the district’s project. We
would also point out that there is no financial penalty for violation of this
program provision nor for the provision requiring the inclusion of
projected energy savings into the district’s contracts with its vendors.
-A16-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Appendix B—
Overview of Issued Audit Reports
Issued Proposition 39 Reports .............................................................................................. B2
Executive Summary ........................................................................................................... B2
Report issued June 30, 2017.............................................................................................. B3
Report issued July 13, 2018 .............................................................................................. B3
Report issued June 30, 2019.............................................................................................. B4
Report issued June 30, 2020.............................................................................................. B4
Report issued August 9, 2021............................................................................................ B4
Report issued June 30, 2022.............................................................................................. B5
-B1-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Issued Proposition 39 Reports
This is the sixth final program audit report that we have issued for the
Executive
California Clean Energy Jobs Act, pursuant to an interagency agreement
Summary
between the State Controller’s Office (SCO) and the Citizens Oversight
Board.
The following table summarizes the amounts expended and audited by
fiscal year for all six audit reports:
Report Audit Amount Amount Audited
Issue Date Period Expended Audited Percentage
June 30, 2017 December 19, 2013–June 30, 2016 $ 51,645,871 $ 1 8,553,175 35.92%
July 13, 2018 July 1, 2016–June 30, 2017 53,802,904 20,389,253 37.90%
June 30, 2019 July 1, 2017–June 30, 2018 85,519,333 24,233,274 28.34%
June 30, 2020 July 1, 2018–June 30, 2019 238,876,104 45,102,262 18.88%
August 9, 2021 July 1, 2019–June 30, 2020 250,241,010 39,178,611 15.66%
June 30, 2022 July 1, 2020–June 30, 2021 341,987,811 19,318,586 5.65%
Totals $ 1,022,073,033 $ 166,775,161 16.32%
The following table summarizes the audited amounts and audit finding
amounts for each report:
Report Audit Amount Audit Error
Issue Date Period Audited Findings Rate
June 30, 2017 December 19, 2013–June 30, 2016 $ 18,553,175 $ 527,514 2.84%
July 13, 2018 July 1, 2016–June 30, 2017 20,389,253 788,560 3.87%
June 30, 2019 July 1, 2017–June 30, 2018 24,233,274 3 ,033,349 12.52%
June 30, 2020 July 1, 2018–June 30, 2019 45,102,262 9 ,540,081 21.15%
August 9, 2021 July 1, 2019–June 30, 2020 39,178,611 1 ,583,747 4.04%
June 30, 2022 July 1, 2020–June 30, 2021 19,318,586 508,108 2.63%
Totals $ 166,775,161 $ 15,981,359 9.58%
During this six-year period, we audited 86 local educational agencies
(LEAs) and 19 community college districts (CCDs), and identified total
dollar findings of $15,981,359 (an error rate of 9.58%). We reported the
following findings:
Sole-sourced project costs totaling $15,535,493 – 32 LEAs spent
$14,365,423 and five CCDs spent $1,170,070 in Proposition 39
funding on sole-sourced project costs.
Ineligible costs totaling $326,866 – six LEAs spent $307,287 and
two CCDs spent $19,579 in Proposition 39 funding on ineligible
costs.
Overpayment totaling $47,072 – one LEA’s energy expenditure plan
(EEP) was improperly approved, resulting in an overpayment of
funds.
Unspent planning funds totaling $25,355 – one LEA did not spend all
of its approved planning funds.
-B2-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Unspent implementation funds totaling $102,725 – two LEAs did not
spend all of their approved implementation funds.
Unspent interest totaling $37,992 – two LEAs earned interest on their
Proposition 39 allocations but did not spend it.
Projected energy savings not identified – 60 LEAs and 16 CCDs did
not identify the applicable projected energy savings in the awarded
contracts.
No signed contracts – nine LEAs and two CCDs did not have signed
contracts with one or more of their vendors.
Late reports – 34 LEAs submitted their final project reports after the
deadline.
Apparent violation of payback period – one LEA appeared to be in
violation of the energy measure payback period, pending the sale of
school facilities.
Our reports also included the observation that seven LEAs properly
applied unused planning funds to project implementation; however, as
these funds were not included in the LEAs’ approved EEPs, the
Proposition 39 funds exceeded the LEAs’ approved EEPs by $494,426.
We audited 16 LEAs and four CCDs with projects completed during the
Report issued
period of December 19, 2013, through June 30, 2016, and total program
June 30, 2017
expenditures of $18,553,175. We identified the following findings:
Sole-sourced project costs totaling $507,056 – four LEAs spent
Proposition 39 funding on sole-sourced project costs.
Ineligible costs totaling $20,458 – one LEA spent Proposition 39
funding on ineligible expenditures, resulting in unallowable costs.
Projected energy savings not identified – 12 LEAs and three CCDs did
not identify the projected energy savings in the awarded contracts.
We audited 16 LEAs and four CCDs with projects completed during the
Report issued
fiscal year ending June 30, 2017, and total program expenditures of
July 13, 2018
$20,389,253. We identified the following findings:
Sole-sourced project costs totaling $557,645 – seven LEAs spent
Proposition 39 funding on sole-sourced project costs.
Ineligible costs totaling $227,987 – two LEAs spent Proposition 39
funds on ineligible expenditures, resulting in unallowable costs
($335,222 less $57,235 that was also sole-sourced).
Overpayment totaling $47,072 – one LEA’s EEP was improperly
approved, resulting in an overpayment of funds.
Projected energy savings not identified – 12 LEAs and three CCDs did
not identify the projected energy savings in the awarded contracts.
Late reports – Four LEAs submitted their final project completion
reports after the deadline.
-B3-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
We audited 16 LEAs and three CCDs with projects completed during the
Report issued
fiscal year ending June 30, 2018, and total program expenditures of
June 30, 2019
$24,233,274. We identified the following findings:
Sole-sourced project costs totaling $3,013,770 – seven LEAs spent
$2,189,993 and three CCDs spent $823,777 on sole-sourced project
costs.
Ineligible expenditures totaling $19,579 – one LEA spent $8,075 and
one CCD spent $19,579 in Proposition 39 funds on ineligible
expenditures, resulting in unallowable costs ($27,654 less $8,075 that
was also sole-sourced).
Projected energy savings not identified – 10 LEAs and three CCDs did
not identify the projected energy savings in the awarded contracts.
Late reports – Five LEAs submitted their final project completion
reports after the deadline.
Our report also included an observation that four LEAs properly applied
unused planning funds to program implementation; however, as these
funds were not included in the LEAs’ approved EEPs, the Proposition 39
funds paid to the districts exceeded the LEAs’ approved EEPs by $26,238.
We audited 17 LEAs and four CCDs with projects completed during the
Report issued
fiscal year ending June 30, 2019, and total expenditures of $45,102,262.
June 30, 2020
We identified the following findings:
Sole-sourced project costs totaling $9,537,047 – six LEAs spent
Proposition 39 funding on sole-sourced project costs.
Ineligible expenditures totaling $3,034 – one LEA spent Proposition
39 funds on ineligible expenditures, resulting in unallowable costs.
Projected energy savings not identified – 12 LEAs and four CCDs did
not identify the projected energy savings in the awarded contracts.
No signed contracts – four LEAs did not have signed contracts with
one or more vendors.
Late reports – Nine LEAs submitted their final project completion
reports after the deadline.
Our report also included an observation that two LEAs properly applied
unused planning funds to program implementation; however, as these
funds paid to the districts were not included in the LEAs’ approved EEPs,
the Proposition 39 funds exceeded the LEAs’ approved EEPs by $232,713.
We audited 16 LEAs and four CCDs with projects completed during the
Report issued
fiscal year ending June 30, 2020, and total program expenditures of
August 9, 2021
$39,178,611. We identified the following findings:
Sole-sourced project costs totaling $1,411,867 – six LEAs spent
$1,065,574 and two CCDs spent $346,293 in Proposition 39 funding
on sole-sourced project costs.
-B4-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Ineligible expenditures totaling $5,808 – One LEA spent $5,808 and
one CCD spent $34,513 in Proposition 39 funds on ineligible
expenditures, resulting in unallowable costs ($40,321 less $34,513
that was also sole-sourced).
Unspent planning funds totaling $23,355 – one LEA did not spend all
of its approved planning funds.
Unspent implementation funds totaling $102,725 – two LEAs did not
spend all of their approved implementation funds.
Unspent interest totaling $37,992 – two LEAs earned interest on their
Proposition 39 funds but did not spend it.
Projected energy savings not identified – 11 LEAs and three CCDs did
not identify the projected energy savings in the awarded contracts.
No signed contracts – five LEAs and two CCDs did not have signed
contracts with one or more of their vendors.
Late reports – 12 LEAs submitted their final project completion
reports after the deadline.
Apparent violation of payback period – one LEA appeared to be in
violation of the energy measure payback period, pending the sale of
school facilities.
Our report also included an observation that one LEA with unused
planning funds properly applied the funds to program implementation;
however, as these funds were not included in the LEA’s approved EEP,
the amount of Proposition 39 funds paid to the LEA exceeded its approved
EEP by $235,475.
We audited five LEAs with projects completed during the fiscal year
Report issued
ending June 30, 2021, and total completed project costs of $19,318,586.
June 30, 2022
We identified the following findings:
Sole-sourced project costs totaling $508,108 – two LEAs spent
Proposition 39 funding on sole-sourced project costs.
Projected energy savings not identified – three LEAs did not identify
the projected energy savings in the awarded contracts.
Late reports – four LEAs submitted their final project completion
reports after the deadline.
-B5-
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Attachment A—
Banta Unified School District’s Response
to Audit Results
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Attachment B—
Bishop Unified School District’s Response
to Audit Results
Program Audit of the California Clean Energy Jobs Act Proposition 39 Program
Attachment C—
San Marcos Unified School District’s Response
to Audit Results
State Controller’s Office
Division of Audits
Post Office Box 942850
Sacramento, CA 94250
http://www.sco.ca.gov
S22-39M-0001