Seeking energy solutions for the County is laudable, but entering into an energy development agreement before the County has a comprehensive energy policy is not advised. Members of the General Plan Advisory Committee recommended the addition of
a comprehensive energy policy as part of the General Plan update. But Community Development Dept. did not adopt this recommendation. By entering an energy development agreement prematurely, the County can be undermining its negotiating position and closing the door to opportunity—providing residents with real energy cost savings and generating revenue from the County’s energy resources.
The Microgrid Incentive Program might be good for the County, but it is too early to sign a pre-development agreement. More information is needed to better weigh benefits and costs.
Comments and questions on the FLASHES project follow below.
Thank you for your time and attention.
Sincerely,
Margaux Kambara
Lake County Resident
Lake County General Plan Advisory Committee, Representative
(speaking for myself)
____________________________________________________________________________
Timing of FLASHES project
1. What is driving the timing of the FLASHES project?
a. Trane is responding to a County Request for Quote (RfQ). Trane’s response is dated 27 Feb 2020. Six years after receiving the RfQ, the County is responding. Why?
b. Ideally, the County would have its comprehensive energy policy in place before entertaining energy development projects. A comprehensive energy policy can offer the County protection: financially, environmentally, and to County infrastructure.
In addition, a comprehensive energy policy would explore energy sovereignty fund potential and energy sovereignty for the County. This would allow the County to generate income from its energy resources and development efforts as well as provide lower cost energy to County residents. Development agreements defined by a County comprehensive energy policy could set County expectations on access and rate (wholesale vs. retail) to energy generated. It could also set local employment and subcontractor hiring goals for the project.
c. What benefit or advantage does the County enjoy if it pursues this project now—as opposed to waiting for the development of a County comprehensive energy policy?
d. Based on the project information posted by the County, it seems there are gaps in the total cost of the project. Specifically, the County’s operations and maintenance costs are not known. A major factor is the knowledge and experience of County staff with the new equipment and facility. If the County will depend on Trane staff for maintenance and support, that has to be factored into the project budget and the County budget as an ongoing expense.
Pre-Development Activity – Environmental Reports
Q: From the presentation and project information available, it looks like the County is the lead in producing environmental reports for the project. Is this correct?
Q: Or is Trane the lead on behalf of the County?
Q: Trane estimates Environmental Consulting / Draft Environmental Impact Report (EIR) cost for the Lucerne site to be $214,780 [FLASHES Lucerne 20 MW Reimbursement Agreement 6.23.2026.pdf, Projected Lucerne 20 MW Billings by Month by Scope].
• What is the basis of this estimate?
• What about the cost for the final EIR?
• If the cost for the Draft EIR exceeds this estimate, what are the County’s options?
• Will the County be reimbursed for its full cost of the Draft and Final EIR?
A land use attorney estimated EIR cost to easily reach $500,000 and take more than a year to complete. FLASHES requires two environmental studies. Cost parameters need to be better defined.
“Agreement for Development Reimbursement Services for the Firemain Linked Auxiliary Supply/Hydraulic Energy Storage (FLASHES) Lucerne 20 MW Project”1 identifies the maximum amount available for Environmental Consulting / Draft EIR for the Lucerne site as $185,440.
Q: How does this amount relate to the estimated cost of the Lucerne EnvironmentalConsulting?
Q: Is the cap for Lucerne Environmental Consulting $185,440?
Q: What are the options for Lake County if the cost of Lucerne Environmental Consulting exceeds $185,440?
Q: Trane estimates Environmental Consulting / Draft Environmental Impact Report (EIR) cost for the Hartley site to be $92,720 [FLASHES MIP Grant Agreement for Hartley Site, “County of Lake MIP Grant Agreement – Hartley 10 MW – 6.23.2026”]
• What is the basis of this estimate?
• What about the cost for the final EIR?
• If the cost for the Draft EIR exceeds this estimate, what are the County’s options?
• Will the County be reimbursed for its full cost of the Draft and Final EIR?
• Why is the cost estimate for this site’s environmental consulting less than the Lucerne site?
The County of Lake MIP Grant Agreement for Lucerne describes, “A. Events of Default and Termination
“(f) Failure of the MIP Project Resource to achieve commercial operations pursuant to its Interconnection Agreement.” [County of Lake MIP Grant Agreement – Lucerne 20 MW – 6.23.2026, p. 9]
Q: What is “failure to achieve commercial operations”? What is the County’s responsibility to ensure that commercial operations are achieved?
Milestones
Schedule between milestones seems aggressive when milestones are set monthly and are based on the amount of project expenditure. It would be more meaningful to identify other milestones, as proposed in Alternative B.
Q: Can County finances handle the schedule of expenditure required to meet project milestones?
Q: How quickly can the County expect to be reimbursed for meeting a milestone?
Q: It looks like the County is fronting the funds for the project and PG&E is reimbursing the County. If so, what is the advantage of participating in this PG&E program (other than getting reimbursed for the cost of the project)? It seems that the County could finance $2.5 million without PG&E and retain project controls allowing for energy sovereignty and true energy savings for the County.
Recommendation: Incentive Milestone Payment Schedule – Alternative B looks more reasonable than Alternative A, which looks like an aggressive schedule based on expenditures alone.
Trane Request for Quote
Q: How valid is Trane’s response, dated 27 Feb 2020, to the County’s Request for Quote (RfQ)?
• Are the Trane personnel identified as project contacts still onboard?
• Are hourly rates and markups listed in the RfQ accurate for 2026?
• Why isn’t a more current RfQ response available from Trane?
__________________________________________________________
1 County file name: FLASHES Lucerne 20 MW Reimbursement Agreement 6.23.2026.pdf
Honorable Members of the Lake County Board of Supervisors,
While I support the goals of the FLASHES proposal and believe the project demonstrates the tremendous opportunity that energy development may provide for Lake County, I am concerned that the County is being asked to enter into agreements regarding a significant energy asset before establishing the Energy Policy Framework necessary to protect and maximize long-term public benefits for Lake County residents.
The issue before the Board is not whether FLASHES is a worthwhile project. The combination of energy generation, pumped-hydroelectric storage, microgrid capability, wildfire resilience, and public infrastructure investment has the potential to provide meaningful long-term benefits to the County and its residents. The issue is that Lake County has not yet established the policy framework needed to guide negotiations involving projects of this scale and significance. Without that framework, the County risks entering negotiations without clearly defined objectives regarding local control, public benefits, ratepayer savings, revenue participation, infrastructure investment, and long-term community value.
An Energy Policy Framework does more than establish goals. It allows the County to negotiate from a position of strength. It establishes the County's priorities before project structures, ownership arrangements, contractual obligations, and development pathways begin to take shape. It provides clear direction regarding what benefits the County expects to receive, what protections should be secured, and how local resources should be leveraged to benefit local residents.
The Board recognized the importance of this issue when it created the Energy Policy Ad-Hoc Committee and directed it to develop recommendations regarding the County's energy future. However, before that framework has been completed, the County is being asked to enter into agreements concerning a project that has the potential to generate substantial energy, storage capacity, resilience benefits, and long-term economic value.
FLASHES therefore illustrates precisely why an Energy Policy Framework should come first. The County should establish the policies, priorities, public-benefit expectations, and negotiating objectives that will govern energy development before entering into binding agreements that may influence those outcomes.
According to the materials presented to the Board, FLASHES would include approximately 30 megawatts of generation capacity coupled with substantial pumped-hydroelectric storage. At full output, a facility of this size could produce enough electricity to serve roughly 12,000 Lake County homes while also providing valuable energy storage, wildfire resiliency, and emergency preparedness benefits.
Projects of this scale are not simply infrastructure projects. They are long-term economic assets with the potential to generate public benefits for decades. The fact that a single project can potentially provide energy equivalent to the needs of a substantial portion of Lake County households demonstrates why the County should establish its Energy Policy Framework before committing to binding agreements. Opportunities of this magnitude warrant policy-guided negotiation that protects the County's interests before negotiating leverage is diminished.
The County's Energy Policy Framework should already be establishing the mechanisms through which those benefits are protected and delivered to Lake County residents.
Those policy components should include:
• A Local Control Framework that preserves meaningful County authority over energy infrastructure developed within the County.
• A Public Benefit Framework that ensures local energy resources generate measurable and recurring benefits for Lake County residents.
• A Revenue Participation Framework that enables the County to lawfully participate in the value created by major energy projects through development agreements, public-benefit payments, infrastructure contributions, franchise arrangements, revenue-sharing mechanisms, or other negotiated benefits.
• A Ratepayer Benefit Program that delivers visible and measurable benefits to residents through lower energy costs, bill credits, infrastructure improvements, or other direct public benefits.
• A Local Energy Access Strategy that preserves opportunities for Lake County residents, businesses, critical facilities, water systems, emergency shelters, and public infrastructure to benefit from locally produced energy before those benefits are committed elsewhere.
• An Energy Legacy Fund or Intergenerational Infrastructure Fund that converts energy development into permanent community assets capable of supporting public safety, infrastructure, resilience, and future generations long after individual projects have been constructed.
The scale of the FLASHES project demonstrates why these protections should be established before agreements are executed.
If Lake County first adopts the appropriate Energy Policy Framework, future negotiations could preserve opportunities for local power procurement, ratepayer savings, public-benefit revenue sharing, infrastructure investment, emergency preparedness funding, workforce development programs, and the creation of permanent community assets that continue benefiting residents for generations.
For example, the County may ultimately determine that it should pursue a Community Choice Aggregator, Joint Powers Authority, public power partnership, or similar structure capable of securing rights of first refusal or preferential opportunities to acquire locally generated power at or near wholesale rates. Such arrangements could allow Lake County residents and businesses to receive direct and measurable benefits from energy produced within the County.
Similarly, a properly structured public-benefit framework could allow a portion of the long-term value generated by major energy projects to be directed into a permanent Energy Legacy Fund that supports infrastructure, emergency preparedness, wildfire resilience, workforce development, and other community priorities long after the initial project has been completed.
These opportunities should be identified, evaluated, and protected before project structures and contractual relationships become fixed.
The County's negotiating leverage is greatest before agreements are executed. Once development pathways, ownership structures, and contractual arrangements become established, opportunities to secure additional public benefits may become more limited.
Lake County should engage in policy-guided negotiation rather than project-by-project negotiation. The County should first establish the rules, priorities, protections, and public-benefit expectations that will govern energy development and then evaluate individual projects through that framework.
Accordingly, I respectfully recommend that the Board refrain from approving binding reimbursement, development, or other long-term agreements at this time.
At most, the Board should authorize staff to continue discussions and due diligence through a limited non-binding Letter of Intent, memorandum of understanding, or similar preliminary instrument that preserves the opportunity while allowing the County to complete an interim Energy Policy Framework. Once that framework is adopted, the Board can evaluate FLASHES from a position of strength, with clear policy guidance regarding local control, ratepayer benefits, revenue participation, community resilience, and long-term public benefit.
Lake County has an opportunity to create a best-in-class model for energy governance. The County should not merely decide whether to participate in its energy future; it should first establish the terms under which participation occurs.
22 June 2026
Dear Chair Rasmussen and Supervisors,
Seeking energy solutions for the County is laudable, but entering into an energy development agreement before the County has a comprehensive energy policy is not advised. Members of the General Plan Advisory Committee recommended the addition of
a comprehensive energy policy as part of the General Plan update. But Community Development Dept. did not adopt this recommendation. By entering an energy development agreement prematurely, the County can be undermining its negotiating position and closing the door to opportunity—providing residents with real energy cost savings and generating revenue from the County’s energy resources.
The Microgrid Incentive Program might be good for the County, but it is too early to sign a pre-development agreement. More information is needed to better weigh benefits and costs.
Comments and questions on the FLASHES project follow below.
Thank you for your time and attention.
Sincerely,
Margaux Kambara
Lake County Resident
Lake County General Plan Advisory Committee, Representative
(speaking for myself)
____________________________________________________________________________
Timing of FLASHES project
1. What is driving the timing of the FLASHES project?
a. Trane is responding to a County Request for Quote (RfQ). Trane’s response is dated 27 Feb 2020. Six years after receiving the RfQ, the County is responding. Why?
b. Ideally, the County would have its comprehensive energy policy in place before entertaining energy development projects. A comprehensive energy policy can offer the County protection: financially, environmentally, and to County infrastructure.
In addition, a comprehensive energy policy would explore energy sovereignty fund potential and energy sovereignty for the County. This would allow the County to generate income from its energy resources and development efforts as well as provide lower cost energy to County residents. Development agreements defined by a County comprehensive energy policy could set County expectations on access and rate (wholesale vs. retail) to energy generated. It could also set local employment and subcontractor hiring goals for the project.
c. What benefit or advantage does the County enjoy if it pursues this project now—as opposed to waiting for the development of a County comprehensive energy policy?
d. Based on the project information posted by the County, it seems there are gaps in the total cost of the project. Specifically, the County’s operations and maintenance costs are not known. A major factor is the knowledge and experience of County staff with the new equipment and facility. If the County will depend on Trane staff for maintenance and support, that has to be factored into the project budget and the County budget as an ongoing expense.
Pre-Development Activity – Environmental Reports
Q: From the presentation and project information available, it looks like the County is the lead in producing environmental reports for the project. Is this correct?
Q: Or is Trane the lead on behalf of the County?
Q: Trane estimates Environmental Consulting / Draft Environmental Impact Report (EIR) cost for the Lucerne site to be $214,780 [FLASHES Lucerne 20 MW Reimbursement Agreement 6.23.2026.pdf, Projected Lucerne 20 MW Billings by Month by Scope].
• What is the basis of this estimate?
• What about the cost for the final EIR?
• If the cost for the Draft EIR exceeds this estimate, what are the County’s options?
• Will the County be reimbursed for its full cost of the Draft and Final EIR?
A land use attorney estimated EIR cost to easily reach $500,000 and take more than a year to complete. FLASHES requires two environmental studies. Cost parameters need to be better defined.
“Agreement for Development Reimbursement Services for the Firemain Linked Auxiliary Supply/Hydraulic Energy Storage (FLASHES) Lucerne 20 MW Project”1 identifies the maximum amount available for Environmental Consulting / Draft EIR for the Lucerne site as $185,440.
Q: How does this amount relate to the estimated cost of the Lucerne EnvironmentalConsulting?
Q: Is the cap for Lucerne Environmental Consulting $185,440?
Q: What are the options for Lake County if the cost of Lucerne Environmental Consulting exceeds $185,440?
Q: Trane estimates Environmental Consulting / Draft Environmental Impact Report (EIR) cost for the Hartley site to be $92,720 [FLASHES MIP Grant Agreement for Hartley Site, “County of Lake MIP Grant Agreement – Hartley 10 MW – 6.23.2026”]
• What is the basis of this estimate?
• What about the cost for the final EIR?
• If the cost for the Draft EIR exceeds this estimate, what are the County’s options?
• Will the County be reimbursed for its full cost of the Draft and Final EIR?
• Why is the cost estimate for this site’s environmental consulting less than the Lucerne site?
The County of Lake MIP Grant Agreement for Lucerne describes, “A. Events of Default and Termination
“(f) Failure of the MIP Project Resource to achieve commercial operations pursuant to its Interconnection Agreement.” [County of Lake MIP Grant Agreement – Lucerne 20 MW – 6.23.2026, p. 9]
Q: What is “failure to achieve commercial operations”? What is the County’s responsibility to ensure that commercial operations are achieved?
Milestones
Schedule between milestones seems aggressive when milestones are set monthly and are based on the amount of project expenditure. It would be more meaningful to identify other milestones, as proposed in Alternative B.
Q: Can County finances handle the schedule of expenditure required to meet project milestones?
Q: How quickly can the County expect to be reimbursed for meeting a milestone?
Q: It looks like the County is fronting the funds for the project and PG&E is reimbursing the County. If so, what is the advantage of participating in this PG&E program (other than getting reimbursed for the cost of the project)? It seems that the County could finance $2.5 million without PG&E and retain project controls allowing for energy sovereignty and true energy savings for the County.
Recommendation: Incentive Milestone Payment Schedule – Alternative B looks more reasonable than Alternative A, which looks like an aggressive schedule based on expenditures alone.
Trane Request for Quote
Q: How valid is Trane’s response, dated 27 Feb 2020, to the County’s Request for Quote (RfQ)?
• Are the Trane personnel identified as project contacts still onboard?
• Are hourly rates and markups listed in the RfQ accurate for 2026?
• Why isn’t a more current RfQ response available from Trane?
__________________________________________________________
1 County file name: FLASHES Lucerne 20 MW Reimbursement Agreement 6.23.2026.pdf
Honorable Members of the Lake County Board of Supervisors,
While I support the goals of the FLASHES proposal and believe the project demonstrates the tremendous opportunity that energy development may provide for Lake County, I am concerned that the County is being asked to enter into agreements regarding a significant energy asset before establishing the Energy Policy Framework necessary to protect and maximize long-term public benefits for Lake County residents.
The issue before the Board is not whether FLASHES is a worthwhile project. The combination of energy generation, pumped-hydroelectric storage, microgrid capability, wildfire resilience, and public infrastructure investment has the potential to provide meaningful long-term benefits to the County and its residents. The issue is that Lake County has not yet established the policy framework needed to guide negotiations involving projects of this scale and significance. Without that framework, the County risks entering negotiations without clearly defined objectives regarding local control, public benefits, ratepayer savings, revenue participation, infrastructure investment, and long-term community value.
An Energy Policy Framework does more than establish goals. It allows the County to negotiate from a position of strength. It establishes the County's priorities before project structures, ownership arrangements, contractual obligations, and development pathways begin to take shape. It provides clear direction regarding what benefits the County expects to receive, what protections should be secured, and how local resources should be leveraged to benefit local residents.
The Board recognized the importance of this issue when it created the Energy Policy Ad-Hoc Committee and directed it to develop recommendations regarding the County's energy future. However, before that framework has been completed, the County is being asked to enter into agreements concerning a project that has the potential to generate substantial energy, storage capacity, resilience benefits, and long-term economic value.
FLASHES therefore illustrates precisely why an Energy Policy Framework should come first. The County should establish the policies, priorities, public-benefit expectations, and negotiating objectives that will govern energy development before entering into binding agreements that may influence those outcomes.
According to the materials presented to the Board, FLASHES would include approximately 30 megawatts of generation capacity coupled with substantial pumped-hydroelectric storage. At full output, a facility of this size could produce enough electricity to serve roughly 12,000 Lake County homes while also providing valuable energy storage, wildfire resiliency, and emergency preparedness benefits.
Projects of this scale are not simply infrastructure projects. They are long-term economic assets with the potential to generate public benefits for decades. The fact that a single project can potentially provide energy equivalent to the needs of a substantial portion of Lake County households demonstrates why the County should establish its Energy Policy Framework before committing to binding agreements. Opportunities of this magnitude warrant policy-guided negotiation that protects the County's interests before negotiating leverage is diminished.
The County's Energy Policy Framework should already be establishing the mechanisms through which those benefits are protected and delivered to Lake County residents.
Those policy components should include:
• A Local Control Framework that preserves meaningful County authority over energy infrastructure developed within the County.
• A Public Benefit Framework that ensures local energy resources generate measurable and recurring benefits for Lake County residents.
• A Revenue Participation Framework that enables the County to lawfully participate in the value created by major energy projects through development agreements, public-benefit payments, infrastructure contributions, franchise arrangements, revenue-sharing mechanisms, or other negotiated benefits.
• A Ratepayer Benefit Program that delivers visible and measurable benefits to residents through lower energy costs, bill credits, infrastructure improvements, or other direct public benefits.
• A Local Energy Access Strategy that preserves opportunities for Lake County residents, businesses, critical facilities, water systems, emergency shelters, and public infrastructure to benefit from locally produced energy before those benefits are committed elsewhere.
• An Energy Legacy Fund or Intergenerational Infrastructure Fund that converts energy development into permanent community assets capable of supporting public safety, infrastructure, resilience, and future generations long after individual projects have been constructed.
The scale of the FLASHES project demonstrates why these protections should be established before agreements are executed.
If Lake County first adopts the appropriate Energy Policy Framework, future negotiations could preserve opportunities for local power procurement, ratepayer savings, public-benefit revenue sharing, infrastructure investment, emergency preparedness funding, workforce development programs, and the creation of permanent community assets that continue benefiting residents for generations.
For example, the County may ultimately determine that it should pursue a Community Choice Aggregator, Joint Powers Authority, public power partnership, or similar structure capable of securing rights of first refusal or preferential opportunities to acquire locally generated power at or near wholesale rates. Such arrangements could allow Lake County residents and businesses to receive direct and measurable benefits from energy produced within the County.
Similarly, a properly structured public-benefit framework could allow a portion of the long-term value generated by major energy projects to be directed into a permanent Energy Legacy Fund that supports infrastructure, emergency preparedness, wildfire resilience, workforce development, and other community priorities long after the initial project has been completed.
These opportunities should be identified, evaluated, and protected before project structures and contractual relationships become fixed.
The County's negotiating leverage is greatest before agreements are executed. Once development pathways, ownership structures, and contractual arrangements become established, opportunities to secure additional public benefits may become more limited.
Lake County should engage in policy-guided negotiation rather than project-by-project negotiation. The County should first establish the rules, priorities, protections, and public-benefit expectations that will govern energy development and then evaluate individual projects through that framework.
Accordingly, I respectfully recommend that the Board refrain from approving binding reimbursement, development, or other long-term agreements at this time.
At most, the Board should authorize staff to continue discussions and due diligence through a limited non-binding Letter of Intent, memorandum of understanding, or similar preliminary instrument that preserves the opportunity while allowing the County to complete an interim Energy Policy Framework. Once that framework is adopted, the Board can evaluate FLASHES from a position of strength, with clear policy guidance regarding local control, ratepayer benefits, revenue participation, community resilience, and long-term public benefit.
Lake County has an opportunity to create a best-in-class model for energy governance. The County should not merely decide whether to participate in its energy future; it should first establish the terms under which participation occurs.
Respectfully submitted,
Thomas Lajcik
Lake County Resident