(1)Existing law authorizes the governing board of a school district or community college district to order an election and submit to the electors of the district whether the bonds of the district should be issued and sold, and sets forth requirements in that regard, including specifying that the term of a bond shall not exceed 25 years from the date of the bond or bond series.

This bill would specify that the term of a bond issue used for purposes of to finance projects that include furnishing and equipping classrooms shall have a weighted average maturity that does not exceed 120% of the average reasonably expected economic life of the furnishings and equipment. financed project.

(2)Existing law, additionally and alternatively to the authority described above, authorizes the issuance of bonds or refunding bonds by a school district or community college district secured by the levy of ad valorem taxes, and, pursuant to those provisions, authorizes a school district or community college district to issue bonds that do not allow for the compounding of interest and that have a maturity greater than 30, but no greater than 40 years, in accordance with specified requirements.

This bill, notwithstanding those provisions, would specify that a bond issue used for the purposes of to finance projects that include furnishing and equipping classrooms shall have a weighted average maturity that does not exceed 120% of the average reasonably expected economic life of the furnishings and equipment. financed project.

(1)Existing law authorizes the governing board of a school district or community college district to issue bonds for specified purposes, and order an election and submit to the electors of the district whether the bonds of the district should be issued and sold, and sets forth requirements in that regard, including, among other things, including specifying that the term of a bond shall not exceed 25 years from the date of the bond or bond series.

This bill would specify that the term of a bond used for purposes of furnishing and equipping classrooms shall not exceed 120% of the average reasonably expected economic life of the furnishings and equipment.

(2)The California Constitution limits the maximum amount of any ad valorem tax on real property to 1% of the full cash value of the property except for ad valorem taxes or special assessments that pay the interest and redemption charges on certain bonded indebtedness, including bonded indebtedness incurred by a school district, community college district, or county office of education for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities, approved by 55% of the voters if the proposition includes specified accountability requirements.

This bill would prohibit specify that proceeds from the sale of bonds authorized and issued after January 1, 2016, pursuant to the exception described above to may be used to purchase portable electronic devices, including, but not limited to, laptop computers and tablet computers, that are not closely connected to classroom instruction, are assigned to individual pupils, or are permitted to leave the schoolsite for more than one schoolday, or to purchase basic or supplemental instructional materials. devices only for furnishing and equipping classrooms and school facilities, and that the portable electronic devices shall only be used for instruction-related purposes in school facilities and shall not be assigned to individual pupils or removed from the schoolsite on a daily basis.

The California Constitution limits the maximum amount of any ad valorem tax on real property to 1% of the full cash value of the property except for ad valorem taxes or special assessments that pay the interest and redemption charges on certain bonded indebtedness, including bonded indebtedness incurred by a school district, community college district, or county office of education for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities, approved by 55% of the voters if the proposition includes specified accountability requirements.

This bill would prohibit proceeds from the sale of bonds authorized and issued pursuant to the exception described above to be used to purchase portable electronic devices, including, but not limited to, laptop computers and tablet computers, that are not closely connected to classroom instruction, are assigned to individual pupils, or are permitted to leave the schoolsite for more than one schoolday, or to purchase basic or supplemental instructional materials.

SENATE COMMITTEE ON GOVERNANCE AND FINANCE

Senator Robert M. Hertzberg, Chair

2015 - 2016 Regular

SCHOOL BONDS: TERM OF BONDS: FURNISHING AND EQUIPPING CLASSROOMS

Require all school district bond issues that finance furniture and equipment to have a weighted average maturity that doesn’t exceed 120% of the average reasonably expected economic life of the financed project.

Background and Existing Law

When public agencies issue bonds, they essentially borrow money from investors, who provide cash in exchange for the agencies’ commitment to repay the principal amount of the bond plus interest in the future. The California Constitution requires counties, cities, and school districts to get voter approval for long-term debt (Section 1, Article XIIIA). Counties, cities, school districts, community college districts, and some special districts can issue general obligation (GO) bonds, secured by ad valorem, or according to value, property tax revenues with 2/3-voter approval. Proposition 39 (2000) allows school districts and school facility improvement districts to issue GO bonds to build, rehabilitate, or replace schools with 55% voter approval subject to certain conditions, including tax limits.

For many years, the Education Code provided the sole avenue for school and community college districts to sell GO Bonds, which limited the number of years a community college or school district could issue a bond to 25 years, with a maximum interest rate of 8%. In 1993, the Legislature added sections to the Government Code to allow cities, counties, cities and counties, special districts, and school and community college districts to issue 40-year bonds. However, in 2013, the Legislature responded to school districts selling capital appreciation bonds with debt to principal ratios of 10 to 1 or worse, by limiting maximum bond terms that allow for capitalization of interest to 25 years along with other reforms, such as an interest rate cap, maximum debt to principal ratio, and call option requirement (AB 183, Buchanan, 2013). That measure also required bonds school districts issue under the Government Code with maturities longer than 30 years to make a finding that the useful life of the facility financed with the bonds equals or exceeds the maturity date of those bonds.

Under Proposition 39, bond proceeds may be spent on “the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities,” so many school districts have issued bonds for furnishing classrooms and purchasing technology to help students learn in addition to school facilities, instead of paying for these items out of general revenues. Legislative Counsel has since opined that while portable electronic devices such as iPads were not in existence when Proposition 39 was passed, they are evolved from desktop computers and as such, a court would construe Proposition 39 to authorize the purchase of portable electronic devices, as long as they were intended for use in a manner closely connected to classroom instruction at a school facility.

The Code of Federal Regulations requires the bonds to have a weighted average maturity of less than 120% percent of the average reasonably expected economic life of the facilities being financed with bond proceeds to remain tax exempt, so school districts often issue bonds with different maturities for furnishing or equipment, called serial bonds. Shorter-term bonds are more appropriate for acquiring technology or other relatively short-lived capital improvement projects, and align the costs of furniture or technology with the current generation of users to pay for the system. These “Ed-Tech Bonds” are a series of short-term bond financings repaid in approximately three-year increments, matching each borrowing to the useful life of the equipment. School districts can also “blend” the useful life of all financed assets into one issue to meet the rule.

Proposed Law

Assembly Bill 882 amends both the Education and Government Codes, to require all school bond issuance that include furnishing and equipping schools to have a weighted average maturity that doesn’t exceed 120% of the average reasonably expected economic life of the financed project.

State Revenue Impact

No estimate.

Comments

1. Purpose of the bill. According to the author, “In November of 2000, voters passed Proposition 39, a Constitutional Amendment which, among others, gives school districts and community colleges the opportunity to seek approval of a local General Obligation bond based on a 55% vote. On top of using bond funds for the construction and modernization of schools, local educational agencies use bond funds to furnish and equip school facilities, including furniture such as desks as well as desktop computers and other forms of technology. AB 882 would specify the term of a bond used for the purposes of furnishing and equipping a classroom, including electronic equipment, shall not exceed 120% of the bond maturity of the average reasonably expected economic life. My bill is consistent with federal tax rules to ensure that taxpayers are not paying long term bonds for items that have a shorter lifespan, and will reduce costs for these purchases. According to a Legislative Counsel opinion, portable electronic equipment such as ipads or tablets, are a type of equipment that is allowable under Proposition 39. This bill is consistent with the provisions in Proposition 39 and does not prohibit the use of Prop 39 bond proceeds to purchase technology. I am a huge proponent of equipping students with technology in the classroom, especially given our new common core standards. If we don’t empower our students with modern technology, we are putting our students at a disadvantage to provide them the opportunity to develop 21st century skills. AB 882 will protect taxpayer dollars by ensuring Prop 39 bond funds are paid off based on the life expectancy of the items being purchased. Finally, it is my hope this measure can be used as a platform to encourage further technology in the classroom and as a state, find ways to provide technology to those rural and disadvantaged communities.”

2. Necessary? AB 882 responds to the practice of school districts using bonds to finance personal electronic devices for education purposes; however, the measure only restates current requirements in federal regulations that school districts must comply with or risk having the Internal Revenue Service (IRS) revoke the tax-exempt status of its bonds. While inserting the requirement in state law places the responsibility on school districts to ensure compliance themselves, instead of waiting for the IRS, what’s the necessity or value of doing so? Inserting additional, duplicative language may make bond issuance more complicated and costly for school districts seeking clean opinions from bond counsel. Districts can’t always identify with certainty the exact projects that may be funded at issuance, and AB 882 could result in districts having to issue a different set of bonds should a project financed by a first set be delayed. Opponents of bond issues could also use AB 882’s standard to challenge the validity of the school district’s bonds because of differences measuring economic life, resulting in disputes and additional litigation. Additionally, the state standard would bind school districts if federal regulations change. The Committee may wish to consider whether AB 882 is necessary.

3. Incoming! The Senate Committee on Education approved AB 882 on an 8-0 vote. The Committee on Governance and Finance is hearing the measure as the committee of second referral.

Assembly Actions

Senate Education 8 - 0
Assembly Floor 79 - 0
Assembly Education 7 - 0

Support and Opposition

Support: Unknown

Opposition: Coalition for Adequate School Housing, Community College Facility Coalition, San Diego Unified School District.

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SENATE COMMITTEE ON EDUCATION

Senator Carol Liu, Chair

2015 - 2016 Regular

Bill No: AB 882

Subject: School bonds: term of bonds: furnishing and equipping classrooms

NOTE: This bill has been referred to the Committee on Education and the Committee on Governance and Finance. A "do pass" motion should include referral to the Committee on Governance and Finance.

SUMMARY

This bill prohibits the term of a bond used for purposes of furnishing and equipping classrooms, including but not limited to purchasing electronic equipment, from exceeding 120 percent of the average reasonably expected economic life of the furnishings and equipment.

BACKGROUND

Current law, under the Education Code authorizes school districts and community college districts to issue bonds with a maximum interest rate of 8 percent and a maximum maturity of 25 years. (Education Code § 15100, § 15140-15150)

Existing law also authorizes any city, county, city and county, school district, community college district, or special district to issue general obligation bonds, secured by the levy of ad valorem taxes, and establishes a process for such issuances under the Government Code. Among other things, the Government code authorizes the issuance of bonds with a maximum interest rate of 12 percent and a maximum maturity of 40 years. (Government Code § 53506-53509-5, § 53531)

ANALYSIS

This bill:

1. Modifies Education Code provisions establishing the authority to issue bonds for a maximum of 25 years to prohibit the term of a bond used for purposes of furnishing and equipping classrooms, including but not limited to purchasing electronic equipment, from exceeding 120 percent of the average reasonably expected economic life of the furnishings and equipment.

2. Modifies Government Code provisions establishing the authority to issue bonds for a maximum of 40 years to prohibit the term of a bond used for purposes of furnishing and equipping classrooms, including but not limited to purchasing electronic equipment, from exceeding 120 percent of the average reasonably expected economic life of the furnishings and equipment.

STAFF COMMENTS

1. Need for the bill? The author is concerned that bonds for buildings are not differentiated from bonds for furnishing and equipping facilities, which may include electronic equipment. It appears that the author is concerned that, with the passage of Proposition 39 in 2000 and the ability of school and community college districts to gain approval of general obligation bonds with a 55 percent vote, the potential for districts to use long term bonds for purchases of furniture and equipment with short term life-spans has increased. In particular the author cites concerns about the use of these funds to purchase portable electronic technology such as iPads or tablets. This bill would require the term of the bond to more directly align with the economic life span of the furniture and equipment it is used to purchase, and establishes a standard for making this determination based upon some elements of federal law.

2. Related Legislative Counsel Opinion. Proposition 39 specifically required the use of bonds authorized under its provisions “for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities.” Amid concerns about the use of these bond funds for the purchase of portable technology equipment by school districts, Legislative Counsel was asked to opine whether a school district could use bond proceeds to purchase portable technological devices, such as laptops and electronic tablets. In an April 2014 written confirmation of its oral opinion (#1330160), Legislative Counsel notes that while portable electronic devices such as the iPads were not in existence when Proposition 39 was passed, they are evolved from desktop computers and as such, they believe a court would construe Proposition 39 to authorize the purchase of portable electronic devices, as long as they were intended for use in a manner closely connected to classroom instruction at a school facility. In summary, it is Legislative Counsel’s opinion that Proposition 39 proceeds may be used to purchase portable technological devices, such as laptops and electronic tablets, for use in a manner that is similar to the use of desktop computers and that is closely connected to classroom instruction at a school facility.

3. Beyond federal law requirements. Federal law establishes various definitions for the purpose of meeting Internal Revenue Service requirements for tax exempt government bond issuances. Among these are conditions which must be met regarding the term of the bonds issued. Federal regulations generally require that portions of an issue used to finance or refinance capital projects must have a “weighted average maturity” that does not exceed 120 percent of the average reasonably expected economic life of the financed capital projects. The provisions of this bill are therefore similar, but not identical to the federal tax code provisions.

According to community college and school districts, bond programs are typically issued for a variety of purposes all at once, with varying maturities over the life of the program and with a mix of short-term and long-term issuances. As currently drafted it is unclear what effect the inclusion of furniture and equipment as a component of a bond issuance would have on a district’s overall bond program. Because the bill goes beyond the federal law requirements, the bill may have the unintended consequence of requiring the structuring of long-term obligation bond programs in a manner that increases the costs of bond issuances to the taxpayer. Additionally, it is unclear whether such a statutory restriction is necessary since at least one school district reports that it has balanced the need to acquire technology assets with shorter life spans, and the interest of taxpayers, by issuing bonds with maturities of 1 to 3 years for the acquisition of technology.

Since federal law already requires the alignment of the term and the economic life of furniture and equipment, and no examples of school districts failing to comply with these requirements were provided to the committee, it is unclear whether the provisions of this bill are necessary. However, if it is the desire of the committee to implement a state standard for the use of bond funds to purchase furniture and equipment, staff recommends the bill be amended on 2 and on page 4 to strike:

the term of a bond used for the purposes of furnishing and equipping classrooms, including, but not limited to, purchasing electronic equipment, shall not exceed 120 percent of the average reasonably expected economic life of the furnishings and equipment.

And to instead insert:

“bond issues used to finance projects that include the furnishing and equipping of classrooms, including, but not limited to purchasing electronic equipment, shall have a weighted average maturity that does not exceed 120 percent of the average reasonably expected economic life of the financed project.”

SUPPORT

None received.

OPPOSITION

Coalition for Adequate School Housing

Community College Facility Coalition

San Diego Unified School District

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ASSEMBLY THIRD READING

ATR Bill Id:AB 882

Author:(Wilk)

As Amended Ver:May 20, 2015

Majority vote

SUMMARY: Specifies that the term of a bond used for the purposes of furnishing and equipping of classroom, including, but not limited to, electronic equipment, shall not exceed 120% of the average reasonably expected economic life of the furnishings and equipment.

EXISTING LAW:

1. Authorizes, under California Constitution Article XVI, Section 18, a school district, community college district or county office of education to incur indebtedness in the form of General Obligation (GO) bonds for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities upon approval of 55% of the voters.

2. Specifies, under the Education Code, that the number of years the whole or any part of the bonds are to run shall not exceed 25 years, from the date of the bonds or the date of any series thereof.

3. Specifies, under the Government Code, that a school district or community college district may issue bonds that do not allow for the compounding of interest and that have a maturity greater than 30 years, but not greater than 40 years, if the school district or community college district does both of the following:

   1. Complies with the requirements of Education Code Section 15146 (b) and (c).

   2. Makes a finding that the useful life of the facility financed with the bonds that do not allow for the compounding of interest and that have a maturity greater than 30 years, but not greater than 40 years, equals or exceeds the maturity date of those bonds.

FISCAL EFFECT: None

COMMENTS: Proposition 39. In November, 2000, voters passed Proposition 39, a Constitutional Amendment which, among others, give school districts and community college districts the opportunity to seek approval of a local GO bond based on a 55% vote rather than a two-thirds vote, provided that the local bond initiative meets specified accountability measures, including identifying the list of specific school facilities projects that will be funded by bond proceeds and the requirement to conduct an annual independent performance audit and an independent financial audit.

Term of bonds. Under the Education Code, the term of local bonds cannot exceed 25 years, while bonds issued under the Government Code is no more than 40 years. Proposition 39 authorizes the proceeds from the sale of GO bonds to be used for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities. Existing law, however, does not differentiate between bonds for buildings versus bonds for furnishing and equipping of facilities, which may include electronic equipment. This bill specifies that the issuance of local bonds used to furnish and equip classrooms cannot exceed 120% of the life expectancy of the items being purchased, whether the bond is issued under the Education Code or the Government Code. This bill is consistent with federal tax rules to ensure that taxpayers are not paying long term bonds for items that have shorter lifespan, and will reduce costs for these purchases.

The author states, "This bill is consistent with the provisions in Proposition 39 and does not prohibit the use of Prop 39 bond proceeds to purchase technology. I am a huge proponent of equipping students with technology in the classroom, especially given our new common core standards.  If we don’t empower our students with modern technology, we are putting our students at a disadvantage to provide them the opportunity to develop 21st century skills. AB 882 will protect taxpayer dollars by ensuring Prop 39 bond funds are paid off based on the life expectancy of the items being purchased."

Analysis Prepared by: Sophia Kwong Kim / ED. / (916) 319-2087 FN: 0000484

Date of Hearing: May 13, 2015

ASSEMBLY COMMITTEE ON EDUCATION

Patrick O'Donnell, Chair

ABPCA Bill Id:AB 882

Author:Wilk – As Amended Ver:May 6, 2015

SUBJECT: School bonds: portable electronic devices.

SUMMARY: Specifies that proceeds from the sale of local bonds approved by voters after January 1, 2016, authorized and issued pursuant to Proposition 39 of 2000, may be used to purchase portable electronic devices only for furnishing and equipping classrooms and school facilities.  Specifically, this bill:

1. Specifies that portable electronic devices purchased with proceeds from the sale of bonds pursuant to Proposition 39 of 2000 shall only be used for instruction-related purposes in school facilities and shall not be assigned to individual students or removed from the schoolsite on a daily basis. 

2. Specifies that the term of a bond used for the purposes of furnishing and equipping of classroom, including, but not limited to, electronic equipment, shall not exceed 120% of the average reasonably expected economic life of the furnishings and equipment.

3. Expresses the intent of the Legislature to ensure that the proceeds of bond funds issued pursuant to Proposition 39 of 2000 be used consistent with the intent and requirements of the act, and expresses the intent of the Legislature to clarify that portable electronic devices, such as laptops, tablets, and iPads, may be purchased with Proposition 39 bond funds only for the equipping of school facilities and be used for instruction-related purposes in school facilities.    

EXISTING LAW:

1. Authorizes, under Section 1 of Article XIII A of the California Constitution, school districts, community college districts, or county offices of education to pass a general obligation (GO) bond by a 55% vote, provided that the local initiative includes the following accountability measures:

1. A requirement that the proceeds from the sale of the bonds be used only for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities, and not for any other purpose.

2. Provide a list of the specific school facilities projects to be funded and certification that the school district board, community college board, or county office of education (COE) has evaluated safety, class size reduction, and information technology needs in developing that list.

3. A requirement that the school district board, community college board, or COE conduct an annual, independent performance audit to ensure that the funds have been expended only on the specific projects listed.

4. A requirement that the school district board, community college board, or COE conduct an annual, independent financial audit of the proceeds from the sale of the bonds until all of those proceeds have been expended for the school facilities projects.

2. Authorizes, under Article XVI, Section 18 of the California Constitution, a school district, community college district or COE to incur indebtedness in the form of GO bonds for the construction, reconstruction, rehabilitation, or replacement of school facilities, including the furnishing and equipping of school facilities, or the acquisition or lease of real property for school facilities upon approval of 55% of the voters.

FISCAL EFFECT: None. This bill is keyed non-fiscal by the Legislative Counsel.

COMMENTS: Proposition 39. In November, 2000, voters passed Proposition 39, a Constitutional Amendment which, among others, give school districts and community colleges the opportunity to seek approval of a local GO bond based on a 55% vote rather than a 2/3 vote, provided that the local bond initiative meets specified accountability measures, including identifying the list of specific school facilities projects that will be funded by bond proceeds and the requirement to conduct an annual independent performance audit and an independent financial audit.

This bill specifies that local bonds can be used to purchase portable electronic devices for furnishing and equipping of school facilities and be used for instructional purposes. The provision specifying that the devices shall not be removed from the schoolsite on a daily basis was included to enable students to take the devices off campus for special projects or for short term basis.

Furnishing and equipping school facilities. Local educational agencies use bond funds to furnish and equip school facilities, including furniture, such as desks, and equipment, such as desktop computers. According to the Legislative Counsel, portable electronic equipment is a type of equipment that is allowable under Proposition 39. While portable electronic devices such as the iPads were not in existence when Proposition 39 was passed, they are evolved from desktop computers and as such, a court would construe Proposition 39 to authorize portable electronic devices. However, the equipment must be a part of equipping classrooms and school facilities and be used in connection with instruction in the classroom. This bill is consistent with the provisions in Proposition 39 and does not prohibit the use of Proposition 39 bond proceeds to purchase technology.

Technology. Many school districts have embarked on new technology programs, partly in response to the new Common Core State Standards and the accompanying Smarter Balanced assessments. The new assessments are computer-based and began in the 2014-15 school year. In 2013, the Los Angeles Unified School District (LAUSD) launched the first phase of the Common Core Technology Project, which provided iPads to 31,000 students and 1,500 teachers at 47 schools. The iPads are installed with English and math curriculum and are assigned as personal devices to pupils, who are allowed to take the devices home. The district has since suspended the project.

San Diego Unified School District implemented a technology program several years ago through the passage of two local bonds. The district upgraded technology in the classrooms and purchased portable electronic devices. The devices are used in the classrooms, but the district also allows pupils to take the devices home and provides internet coverage to families that do not have access.

Other school districts have purchased other types of portable electronic devices, such as the Chromebooks or MacBook Air laptops. Most school districts are not assigning devices to each student, and instead are rolling them into classrooms on carts.

Term of bonds. This bill also specifies that the issuance of local bonds used to furnish and equip classrooms cannot exceed 120% of the life expectancy of the items being purchased. Under the Education Code, the term of local bonds cannot exceed 25 years, while bonds issued under the Government Code is no more than 40 years. State law does not differentiate between bonds for buildings versus bonds for furnishing and equipping of facilities. This bill is consistent with federal tax rules to ensure that taxpayers are not paying long term bonds for items that have shorter lifespan, and will reduce costs for these purchases.

Arguments in support. The author states, "… local educational institutions have been using Prop 39 bond funds to purchase non-facility related items with much shorter usable life, while still taking decades to pay them off. One example is the purchase of thousands of iPads by the Los Angeles Unified School District in 2013, a cost to the taxpayers of $500 million. These iPads have an estimated usable life of only 5 years. Inasmuch as Prop 39 bonds are meant for construction and modernization of school facilities, they are meant to fund projects that have a long usable life, and can take decades to pay off. This measure will protect taxpayer dollars by ensuring that Prop 39 bond funds are used for the appropriate purposes and are directed toward projects that have a longer usable life and are justified in being paid off over a long period of time."

Arguments in opposition. The Riverside County Superintendent of Schools states, "We believe that if voters are informed of, and subsequently approve, local bonds that in part may be used to equip the students in their communities with technology and devices that will enhance their educational experience and provide greater access to the content standards they are required to learn, school districts should not be precluded from using bonds as a source of funding."

Author's amendments. The author has requested the Committee to adopt an amendment striking Section 2 of the bill.

Prior related legislation. AB 1754 (Hagman), introduced last session, would have been amended to be consistent with the provisions of this bill if passed by this Committee. The bill failed on a 3-0 vote.

REGISTERED SUPPORT / OPPOSITION:

Support

California Association of County Treasurers and Tax Collectors (prior version)

California Association of Realtors (prior version)

Howard Jarvis Taxpayers Association (prior version)

Opposition

California School Boards Association (prior version)

Coalition for Adequate School Housing (unless amended)

Riverside County Superintendent of Schools

San Diego Unified School District

Analysis Prepared by: Sophia Kwong Kim / ED. / (916) 319-2087