I am not sure that this clarifies the ESPL for CHP’s who we have as exempt from rates. To be residential, the only way a property can be classified as Residential for the ESPL according to the manual is if it is classified as Residential for rating purposes under the Act. If it is exempt from rates, it is not classified as Residential (or any other rating category) for rating purposes, so can’t be classified as Residential for ESPL purposes. If they do not meet the Residential ESPL classifications as public benefit, then they must therefore fall to the default category which is Commercial. Does anyone have this interpretation?