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goals. The challenge is how best to achieve <br />that result. <br />Legislative discussions have suggested that <br />minimum energy efficiency improvements <br />could be added as point of sale <br />requirements, including energy use <br />disclosure and basic renovations such as <br />improved attic insulation levels, window <br />caulking and other air sealing, or improved <br />light fixtures. <br />While the goals of such a program are <br />laudable, there are a number of concerns for <br />how this would actually be accomplished in <br />individual cities. Most cities do not, for <br />example, have point of sale inspections. <br />There will also be cases where the building <br />could be structurally unable to meet high <br />attic insulation requirements, such as with <br />manufactured housing or with older houses <br />with very little attic space. There are also <br />concerns that the cost of meeting these <br />energy requirements could result in <br />homeowners being reluctant to sell their <br />houses because of the expense of the <br />improvements that would be required to <br />meet new standards or property owners <br />passing on the cost of upgrades to tenants. <br />Increased exposure to educational <br />information, such as increased access to <br />energy audits and more familiarity with and <br />access to programs that finance energy <br />efficiency projects could increase adoption <br />of energy efficiency improvements. Electric <br />utilities provide successful, cost-effective <br />energy efficiency programs, have a customer <br />relationship with homeowners, a regulatory <br />requirement to meet energy demand <br />reduction goals through conservation <br />spending, and access to technical expertise <br />that can take into account variations in <br />building age and construction. Cities could, <br />however, play a strong role in increasing <br />public exposure to approved educational <br />materials and providing incentives through <br />the use of other local financing support <br />options for property owners, such as grants, <br />loans, a Property Assessed Clean Energy <br />(P.A.C.E.) program, and other financing <br />tools. <br />Response: The League of Minnesota <br />Cities agrees that there is a need to <br />improve the energy efficiency of <br />residential building stock to reduce <br />energy consumption and improve the <br />affordability and livability of housing. <br />The state should focus its efforts on <br />improving educational programs and on <br />improving the use of the existing <br />statewide Conservation Improvement <br />Program (CIP) and similar programs, <br />and provide property owners with <br />technical and financial support for <br />weatherization and energy efficiency <br />improvements. Further, the state should <br />work to make residential Property <br />Assessed Clean Energy (P.A.C.E.) <br />programs viable for local governments. <br />Cities should use their communication <br />tools, such as newsletters, web sites, and <br />staff communications to promote these <br />efforts and to help link property owners <br />to educational materials and program <br />resources. Additionally, cities could be <br />incentivized to adopt strategies to disclose <br />energy usage data for building owners to <br />identify options for cost-efficient energy <br />improvements. <br />LE-11. In -Home Day Care Facilities <br />Issue: There are restrictions on the ability of <br />a city to regulate licensed day care facilities. <br />Minn. Stat. § 462.357, subd. 7, states that <br />certain licensed residential facilities and day <br />care facilities must be considered a <br />permitted single-family use for zoning <br />purposes. The restriction is designed to <br />protect "in -home" daycare facilities, but the <br />law applies even if the facility is not the <br />League of Minnesota Cities <br />2018 City Policies Page 58 <br />