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HomeMy WebLinkAbout25F - ELECTRIC VEHICLE CHARGING STATION UPGRADESREQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: MARCH 19, 2012 TITLE: AGREEMENT WITH CLIPPER CREEK INC. FOR ELECTRIC VEHICLE (EV) CHARGING STATION UPGRADES ?,GITY MANAGER RECOMMENDED ACTION CLERK OF COUNCIL USE ONLY: APPROVED ? As Recommended ? As Amended ? Ordinance on 151 Reading ? Ordinance on 2nd Reading ? Implementing Resolution ? Set Public Hearing For_ CONTINUED TO FILE NUMBER Authorize the City Manager and Clerk of the Council to execute the attached agreement with Clipper Creek Inc. to upgrade the two Electric Vehicle (EV) Charging Stations at the Santa Ana Regional Transportation Center under the State-funded Reconnect California Program at no cost to the City, subject to non-substantive changes approved by the City Manager and City Attorney. DISCUSSION In September 2011, the Executive Management Team adopted a 5-Year Alternative Energy Strategic Plan to move City fleet operations from conventional fuel (gasoline and diesel) to alternative energy such as Compressed Natural Gas (CNG), electricity, hydrogen, and propane. Currently, only 5% of the City fleet is powered by alternative energy. This includes 12 street sweepers on CNG; 27 hybrid cars, 5 of which run on hydrogen; 9 electric-powered utility vehicles; and 1 forklift fueled by propane. The goal of the Strategic Plan is to increase this 5% rate to 75% in five years by gradually retrofitting or replacing fleet equipment. The fueling infrastructure to support the alternative breed of fleet equipment is also addressed in the Strategic Plan. The Finance Department's Facilities-Fleet Management-Central Stores (FMCS) Division presently operates CNG and hydrogen fueling stations in addition to gasoline and diesel pumps. However, these facilities are exclusively for City fleet operations. The Strategic Plan proposes to develop electric, propane, and E85 (85% Ethanol) fueling stations to be used not only by City fleet operators but also by Santa Ana residents and the community at large. These publicly accessible facilities will be equipped with credit card readers to capture City revenue from the sale of alternative fuel to the public. The City expects to reap economic, environmental, and public health benefits by switching from conventional fuel to alternative energy. Economic benefits include the aforementioned revenue from public fuel sales and hard dollar savings from the lower unit cost of alternative fuel. Consider, for instance, the current per-gallon cost of $1.80 for CNG vs. $3.66 for diesel; or fully charging an electric car for a total cost of $3.00 vs. filling up a 14-gallon gas tank at $3.85 per gallon. 25F-1 Agreement for Electric Vehicle Charging Station Upgrades March 19, 2012 Page 2 Environmental benefits include more clean air and less hazardous waste. Cleaner air would result from the smaller carbon footprint and lower emission levels generated by alternative-fuel equipment. Hazardous waste would also be reduced as cars powered by BEV (Battery Electric Vehicle) and PHEV (Plug-in Hybrid Electric Vehicle) technology use less, if any, oil-related products such as transmission fluid and fuel filters. The Santa Ana community also gains from a public health perspective. Medical practitioners have long linked air pollution, which consists largely of emissions from automobiles and trucks, to cardiopulmonary morbidity and mortality. Medical and socio-economic studies have assembled strong evidence that diesel and other gaseous exhaust contribute to urban health problems such as asthma, bronchitis, emphysema, and lung cancer. Related findings have also identified diesel fuel emission as a health risk factor that disproportionately affects low-income urban neighborhoods. The move away from gasoline and diesel and into alternative energy is part of the City's response to concerns about air pollution as a major health risk for Santa Ana's residents and daytime population. Alternative energy plan implementation will be funded by a combination of City and grant monies. Thus far, FMCS has secured grant funding of over $600,000 for the acquisition of seven heavy-duty propane trucks, six diesel emission control systems, two electric vehicle charging stations, and a new propane station. The grant funds will also help pay for upgrades to the CNG fueling station and modifications to the City fleet maintenance facility (e.g., retrofitting the Corporate Yard Car Wash to run on solar energy). The 2012 Action Plan focuses on fleet equipment and fueling infrastructure to implement the Propane and Electric components of the Alternative Energy Strategic Plan. At this juncture, staff requests Council approval of the attached agreement with Clipper Creek for delivery and installation of two credit card-enabled Electric Vehicle (EV) charging stations valued at $3,000 each under the Reconnect California Program. This Program is funded by the California Energy Commission which awarded Clipper Creek a $2.3 million grant to upgrade 600 existing publicly available AVCOM EV chargers throughout the State (including three chargers in Santa Ana) with new SAE J1772 units at no cost to the site owners. The new SAE J1772 charging standard has been adopted universally by all the BEV and PHEV automakers in the United States. Two of the three Santa Ana chargers are on public property at the Santa Ana Regional Transportation Center (SARTC). The third charger is on private property at the Main Place Mall area and has already been upgraded. Subject agreement refers to the two chargers at the SARTC. Fiscal Impact There is no fiscal impact associated with this action. The California Energy Commission grant fully pays for the purchase and installation of new chargers and disposal of the old units. Francisco Gutierrez Executive Director Finance & Management Services Agency (Raul Godinez Executive Director Public Works Agency 25F-2 RECONNECT CALIFORNIA CHARGE STATION AND INSTALLATION AGREEMENT Site Owner: Site Location: (Charging Site) As an existing public electric vehicle charge station site owner ("Site Owner"), Site Owner is being provided an opportunity to upgrade one or more electric vehicle charge stations ("Charge Stations") to the new SAE-117721"' standard (CS-40, manufactured by ClipperCreek, inc. ("CCI") ) to be installed by its Program Partners, under the Reconnect California Program (the "Program"). The Program has been funded in part under the terms of PON-09-005 from the California Energy Commission ("CEC"). In order for Site Owner to receive its Charge Station upgrade and installation, Site Owner agrees to all of the following terms and conditions: 1. Grant Recipient: ClipperCreek, Inc. Auburn, CA - Grant Recipient and Program Manager CCI Program Partners: EV Connect, Inc. of Culver City, CA - Installer Tom Dowling, Folsom, CA -Coordinator 2. Charge Stations. Site Owners Charge Station upgrade is set forth in this section. CCI Model Number CS-40 Number of Charge Stations: Exhibit "A" to this Agreement sets forth the specific Charge Station(s) and the location(s) in which the Charge Stations are to be upgraded and installed. 3. Shipment and Delivery. CCI will pay for the cost of standard delivery charges of the Charge Stations to Site Owner's locations. CC] shall choose the method by which Charge Stations are to be delivered. 4. Installation. (a) Installation of the Charge Stations will be performed by CC[ Program Partners. Site Owner agrees to indemnify and hold harmless, CCI, CCI Program Partners, and their officers, directors, employees, shareholders from all losses, costs, expenses, claims and/or other charges Incurred by any of them as a result of the failure by Site Owner to observe each of the applicable reporting, and access requirements outlined in section 11 of this agreement. 5: Warranty, The Charge Stations will be covered by the terms of CCI's and CCI Program Partners' standard product and installation warranties, respectively, for a period of one (1) year from the date of installation. Should Site Owner wish to obtain an extended product or installation warranties, Site Owner should contact CCI Program Partners for a description of applicable terms and conditions. 6. Additional Products and Services. In the event that Site Owner desires to purchase additional Charge Stations and/or related products or services, this transaction will be handled outside of this agreement. 7. Access to the Public. All of the Charge Stations will be installed in a manner and in locations that make them available for access and use by the general public. The Charge Stations and the facilities, 25F-3 in which they are located, shall be kept clean and in good repair. Site Owner agrees to maintain appropriate signage that clearly and prominently identifies and, where appropriate, provides directions to the Charge Stations so that they may be easily located by drivers of electric vehicles. Site Owner shall promptly call CCI Program Partners, in order to arrange for the repair of any non- functioning Charge Stations. 8. Representations and Warranties. Site Owner represents and warrants to CCI and CCI Program Partners that: (i) Authority -- Site Owner has the power and authority to enter into and be bound by this Agreement and to authorize the replacement or installation of the Charge Stations and any other electric vehicle charge products or services at the location(s) (the "Locations") set forth in Exhibit "A"; (ii) No Violation With Existing Site Owner Electrical Supply or Other Agreements -- Site Owner assumes all responsibility that the electrical usage of the Charge Stations will not violate or otherwise conflict with the terms and conditions of any applicable electrical purchase or other agreement including, without limitation, any lease, to which Site Owner is a party; (iii) Installation of Charge Stations Will Not Violate Any Other Agreements or Laws -- Site Owner will not install or attach, or allow to be installed or attached, Charge Stations on or to infrastructure not owned by Site Owner without proper authority or consent, and will otherwise observe all applicable governmental or other restrictions (whether by agreement or otherwise) applicable to the Locations; and (iv) Compliance Laws -- Site Owner will comply with all applicable laws. 9. Further Representations and Warranties for Tenants. If the Charge Stations are to be installed at one or more locations at which Site Owner is a tenant rather than the owner thereof, Site Owner represents and warrants to CC] that Site Owner has received all consents from its landlord(s) that are necessary for the installation of the Charge Stations in a manner that does not violate its lease. Site Owner shall promptly reimburse CCI for any costs incurred by It, any of its Authorized Distributors or Certified Network Contractors, including, without limitation, reasonable attorneys fees, as a result of the installation of Charge Stations in violation of this section. 10. Publicity. Site Owner agrees to permit CCI and CCI Program Partners to use its name, in a manner reasonably approved by Site Owner, for purposes of publicizing the Program. For these purposes CCI and CCI Partners will inform Site Owner, in writing, at least ten (10) days, or less (if mutually agreed by Site Owner and CCI and CCI Partners), prior to using Site Owners name or its intent to do so, and will provide Site Owner with copies of any press releases, advertisements or other promotional materials in which Site Owner's name is to be used for review and approval. Site Owner's consent to such use will be presumed if Site Owner does not object within five (5) business days of actual receipt of notice from CCI and CCI Partners under this section. 11. Access (1) Charging Site Location. CCI and CCI Program Partners are hereby granted access to the Site Location, sufficient notice, to perform the site evaluation and subsequent upgrade of the EVSE units at the Site Location. (ii) Electrical Panel. Charging Site is aware and agrees that the upgrade project will require CCI and CCI Program Partners to have access to the electrical panel supporting the EVSE(s) and hereby agrees to make someone available to allow such access to the electrical panel as required access and authorization. 25F-4 (iii) Additional Upgrades. If more than one site visit is required, i.e., not all EVSE(s) are upgraded at the same time, to accommodate, smart grid upgrades or data collection Site Owner agrees to provide the same access for each visit. (iv) Removed EVSEs. Site Owner agrees to allow CCI and CCI Program Partners to dispose of the removed EVSEs as they see fit. - (v) Data Collection. CCI and CC] Program Partners are hereby granted access to the Charging Site location for the purpose of the collection of data, which shall remain anonymous related to the EV Driver. Access shall be unrestricted except as herein stated: (vi) Smart Grid Upgrades. CCI and CCI Program Partners are hereby granted access to the Charge Site location and corresponding electrical panel, upon scheduling required access with the city, for the purpose of performing the initial site evaluation, charging station upgrade and subsequent smart grid module installation. (vii) Public Database. Charge Site grants CCI and CC[ Program Partners permission to make the Charging Station Location and upgrade information publicly available through electronic databases. 12. No Amendment or Modification. No modification, amendment or waiver of this Agreement shall be effective unless in writing and either signed or electronically accepted by the party against whom the amendment, modification or waiver is to be asserted. 13. Waiver. CCI and CCI Program Partners failure at any time to require Site Owner's performance of any obligation under this Agreement will in no way affect the full right to require such performance at any time thereafter. CCI and CCI Program Partners failure to exercise any of its rights provided in this Agreement will not constitute a waiver of such rights. No waiver will be effective unless in writing and signed by a CCI and CCI Program Partners authorized representative. Any such waiver will be effective only with respect to the specific instance and for the specific purpose given. 14. Applicable law. This Agreement will be construed, and performance will be determined, according to the laws of the State of California without reference to such state's principles of conflicts of law and the state and federal courts of California shall have exclusive jurisdiction over any claim arising under this Agreement. 15. Insurance. (i) CCI and CCI Program Partners shall maintain, at it's own expense during the term of this Agreement, Workers' Compensation & Employer's Liability, or ensure that it's Agents provide the same insurance specified below with respect to it's employees, contractors or subcontractors accessing the Charging Site location pursuant to this Agreement. (ii) CCI and CCI Program Partners shall not be required to maintain any employment related insurance for any employee, contractor or agent of Site Owner, whether or not said person is engaged in the initial Upgrade or Access. (iii) CC) and CCI Program Partners shall maintain commercial general liability insurance which shall include, but not be limited to protection against claims arising from bodily and personal injury, including death resulting therefrom and damage to property, resulting from any act or 25F-5 occurrence arising out of CCCI or CCI Program Partner's operations in the performance of this Agreement, including, without limitation, acts involving vehicles. The amounts.of insurance shall be not less than the following: single limit coverage applying to bodily and personal injury, including death resulting therefrom, and property damage, in the total amount of $1,000,000 per occurrence, $2,000,000 in the aggregate. Such insurance shall (a) name the City, its officers, employees, agents, volunteers and representatives as additional insured(s); (b) be primary and not contributory with respect to insurance or self-insurance programs maintained by the City; and (c) contain standard separation of insureds provisions. 16. Regulations and Instructions. (i) CC] and CC] Program Partners agrees at all times to comply with all federal, state and local laws, ordinances, rules and regulations applicable to electronic vehicle charging units in California. (ii) Site Owner agrees at all times to comply with all federal, state and local laws, ordinances, rules and regulations applicable to hosting an electronic vehicle charging site in California. Site Owner shall indemnify and hold harmless, CCI and CCI Program Partners from any 3`d party claim arising from or relating to the real property at the Charging Site used by the EV Drivers use of the Charging Site. (iii) CCI and CCI Program Partners shall only permit personnel properly instructed in the characteristics and safe handling methods associated with Installation and data collection of the charging units to perform work at the site. 17. Severability. If any provision of this Agreement is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions will continue in full force and effect without being impaired or invalidated in any way. 18. Assignment. Site Owner may not assign any of Site Owners rights or obligations under this Agreement, whether by operation of law or otherwise, without the prior written consent of CC). 19. Counterparts. This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, but all of which, taken together, shall constitute but one and the same document. CLIPPERCREEK, INC. EV CONNECT INC. SITE OWNER City of Santa Ana By: By: By: Name: Jason France Name: Jordan Ramer Name: Paul M. Walters Title: Chief Executive Officer Title: Chief Executive Officer Title: City Manager Recommended for Approval: Raul Godinez, 11 Executive Director - PWA ATTEST: Maria D. Huizar Clerk of the Council 4 I_:;.uc t Stitt '.-e( 7 25F-6 f-.--klunt City Attorney EXHIBIT "A" DESCRIPTION OF AWARDED CHARGE STATIONS AND INSTALLATION LOCATIONS Charge Station Model Number Installation Location ClipperCreek CS-40 w/ Credit Card Reader 1000 E Santa Ana Blvd, Santa Ana, Ca 92701 5 25F-7 25F-8 L I P P E R C R E E K, INC. 11850 Kemper Road N N O V AT I V E INFRASTRUCTURE FOR Suite #E • Auburn, CA ELECTRIC AND HYBRID VEHICLES 95603 95603 • 9 (5(5300) 887 887--116674 E)IN * Fax (530) 887-8527 17olwo Reconnect California Grant Outline: (Site Identifier Form) Funded through CEC PON-09-006 ClipperCreek has received grant funding through the California Energy Commission (CEC) to replace and update existing EVSE (Electric Vehicle Supply Equipment) infrastructure to the new SAE J1772 standard. Through the grant funding we are able to offer the replacement and installation of the new SAE J1772 compliant EVSE(s) at no charge to qualified sites. The replacement chargers will be provided by ClipperCreek and the installation work will be done by a certified contractor partnering with ClipperCreek for this program. What the grant covers: - New EVSE (CS-40) to replace existing obsolete infrastructure - Installation of new CS-40 EVSE - Proper disposal of removed/obsolete EVSE If you are interested in taking advantage of this phenomenal opportunity I will need the following information from you. Site Owner/decision maker name and title: Contact Information: Site Address: On Site Contact Name and Phone Number: *Please include site photos if you have them* Thank you for your time. Please provide the above requested information to ClipperCreek in order to move onto the next step of the upgrade process. Upon site approval we will be contacting you to begin the installation process by scheduling a pre install inspection, which will be followed by the installation of your new upgraded EVSE's. Mail To: ClipperCreek, Inc. Attn: Will Barrett 11850 Kemper Rd #E Auburn, CA 95603 Email To: Will e,ClipperCreek.net Call in To: 530-887-1674 Ex 303 4/4/2011, WPB, Reconnect California Grant-Site Identifier (2).docx Office Use Only: Date entered into install queue: Site ID Number: Page 1 of 1 25F-9 25F-10 C LI PPER C REEK, INC. INNOVATIVE INFRASTRUCTURE FOR ELECTRIC AND HYBRID VEHICLES 11850 Kemper Road Suite #E • Auburn, CA 95603 • (530) 887-1674 • Fax (530) 887-8527 CE) 0 Reconnect Ca Grant Program Fact Sheet The Program - The California Energy Commission (CEC) together with ClipperCreek have funded a program to upgrade existing publicly available EV charging infrastructure to the new SAE J1772 charging standard that has been adopted universally by all the BEV (battery electric vehicle) and PHEV(plug in hybrid electric vehicle) automakers in the US. Together, the CEC and ClipperCreek have funded 100% of this upgrade so that it will be at NO COST TO YOU, the site owner Basic Grant Requirements - To qualify for grant funding under the Reconnect Ca grant program a site must meet the following requirements: 1.) Charge site must be accessible to the general public. 2.) "Legacy" EV charging infrastructure must be in place at the site. 3.) 1 SPI (Small Paddle Inductive) charger must remain in place where SPI chargers are currently installed. 4.) Site owner must agree to allow ClipperCreek to collect kWh usage information from the grant funded equipment. 5.) The grant funded equipment will be "Smart grid" ready. 6.) Site must be approved for funding by ClipperCreek and the CEC. Equipment that will be installed with grant funding - This is a list of the equipment that will be installed with grant funding and corresponding circuit requirements: l.) ClipperCreek CS-40 EVSE a. Input power requirements - 208-240 VAC 40 Amp dedicated branch circuit (this is the same power requirement as existing legacy equipment). 2.) ClipperCreek Pedestal (will be installed if required) a. 4' tall cold rolled steel pedestal for mounting the CS-40 - these will be installed at eligible locations where pedestal mounted EVSEs currently exist. 3.) Smart grid meter module - This is a module that will be installed inside the CS-40 EVSE, the module will contain a utility grade meter, and will offer demand response control to the local utility. 4.) Once the equipment is installed it will be the property of the site owner, however ClipperCreek will reserve the right to collect kWh usage data from the EVSE for a period of up to 2 years after the install. What this Grant covers - This grant program will provide funding for the following: 1.) Removal of the obsolete "Legacy" EVSE(s). 2.) New J 1772TM compliant EVSE(s) with a "Smart Grid" ready module. 3.) Installation of the New J 1772TM compliant EVSE (CS-40) performed by our install partner EVConnect. 4.) Installation of the "Smart Grid" ready module. Grant Participation Process - This is a step by step breakdown of the grant from a sites request to participate, to grant funding approval, and through the install and data collection process: 1.) The site will fill out a Reconnect Ca grant site identifier form. a. To get the process started an interested site owner will need to fill out a "Site Identifier Form" for each site they would like considered for upgrade through this program. 2.) ClipperCreek will qualify and approve or deny the site for grant funding. If the site is approved we move to step 3. 3.) ClipperCreek will provide the site owner with a "Reconnect CA Site Agreement" document; the site owner will need to sign this document. a. This form is what gives ClipperCreek access to the site and permission to perform the upgrades and return to the site to collect kWh usage data from the charging stations Smart grid ready module. 4.) The site will be entered into the install scheduling queue. a. Once the site has returned the Reconnect Ca Site Agreement document the site will be entered into our install scheduling queue. b. The turn around time from entering the schedule queue to having an install scheduled has been 2-4 weeks depending on scheduling availability. 5.) The install will be preformed by our install partners for this grant program EVConnect. 6.) A ClipperCreek Technician will return to the site to install a Smart Grid Module in early 2012. 7.) A ClipperCreek Technician will return to collect kWh usage data in late 2012. 9/8/2011, WPB, Reconnect Ca Grant Program Fact Sheet (3).docx 25F-11 25F-12 25F-13 Reconnect California Grant Program "California's Program to Update EV Charging Infrastructure" Program Administrator: ClipperCreek, Inc. CEC Grant Program Presentation v 25F-14 CVS, Granite Bay, CA 95746 61h Street Lot, Temecula, CA 92590 Santa Monica Airport, Santa Monica, CA 90405 "Plug-ins" are Here and More Are Coming ... Ford Focus EV 2012 Toyota RAV4 EV 2012 Nissan Leaf 2010 Ford Transit Connect 25F-15 Toyota Prius 2012 BMW ActiveE 2012 Chevy Volt 2010 Fisker Karma 2012 Smart Fortwo 2011 Reconnect CA -The Program • The California Energy Commission (CEC) together with ClipperCreek have funded a program to upgrade existing publicly available EV charging infrastructure to the new SAE J1772 charging standard • The SAE J1772 standard has been adopted universally by all BEV (battery electric vehicle) and PHEV (plug in hybrid electric vehicle) automakers in the us. • Together, the CEC and ClipperCreek have funded 100% of this upgrade so that it will be at NO COST TO YOU, the site owner Before? Aft Electronic Arts, Redwood City, CA 94065 - After 25F-16 Electronic Arts, Redwood City, CA 94065 - Before CEC Grant-Funded J1772 EVSE Upgrade Public Charging Sites • One of the largest EV infrastructure programs in California • "Legacy" EVSE installation qualifies site for no cost upgrade • Upgrades to the new J1772 standard will be no cost to the Site owners • ClipperCreek upgrades began July '11 and will conclude in June 2012 • To date over 100 Legacy EVSEs have been upgraded • This program has limited equipment available and the upgrade deadline is fast approaching - Contact ClipperCreek today to ensure your sites grant funded equipment allocation. ?a www.EVChargerNews.com 25F-17 EV Charging 101... EVSE - Electric Vehicle Supply Equipment • EVSEs serve primarily as a SAFETY device between the Power Grid (Building Power Supply) and the electric vehicle. • The safety of the unit includes: • Safety Electronics (GFI) • Vehicle Charging Cord • SAE-SAE-,11772TM compliant connector • SAE Communications Interlock • Pilot Signal Control Circuit Interface with the vehicle 25F-18 CEC Grant funded EVSE Product UC Davis, Davis, CA 95618 • ClipperCreek CS-40 EVSE will replace existing, outdated EVSEs • Input Power: 208-240 VAC 40 Amp dedicated branch circuit (this is the same power requirement as existing legacy equipment). • Output Power: 30 Amps, 7.2kW Maximum • ClipperCreek Pedestal - Fits the same footprint as existing pedestals • 4' tall Cold Rolled Steel - For mounting the CS-40 • Charge station hardware and installation are provided to the grant recipients at no cost under the Reconnect California program! 25F-19 Basic Grant Requirement To qualify for grant funding under the Reconnect Ca grant program a site must meet the following requirements: 1.) Charge site must be accessible to the general public. 2.) "Legacy" EV charging infrastructure must be in place at the site. 3.) 1 SPI (Small Paddle Inductive) charger must remain in place where SPI chargers are currently installed. 4.) Site owner must agree to allow ClipperCreek to collect kWh usage information from the grant funded equipment. 5.) The grant funded equipment will be "Smart grid" ready. 6.) Site must be approved for funding by ClipperCreek and the CEC. 25F-20 Marriott, Palm Desert, CA 92260 "Top 5 Reasons To Do This" Lowes, Elk Grove, CA 95624 • Upgrade old outdated equipment to the latest new equipment at No Cost! • Attract PEV owners to spend more time at your location. • Opportunity for PR as an owner committed to Green sustainability, and energy independence. • Site location advertised through location mapping web sites and smart phone applications. • Value of new equipment far exceeds the near term cost of electricity used - Instant payback! 25F-21 CLIPPERCREEK, INC. INNOVATIVE INFRASTRUCTURE FOR ELECTRIC AND HYBRID VEHICLES Grant funded equipment upgrades are Awarded on a first come first serve basis. Sign up Today to Take Advantage of This Program Thank You ... Will Barrett Will@ClipperCreek.net (530)-887-1674 ex 303 25F-22