Cal. Rev. & Tax. Code § 6010.8

“Sale” and “purchase” do not include any transfer of title of tangible personal property constituting any project to the California Alternative Energy and Advanced Transportation Financing Authority by any participating party, nor any lease or transfer of title of tangible personal property constituting any project by the authority to any participating party, when the transfer or lease is made pursuant to Division 16 (commencing with Section 26000) of the Public Resources Code. The terms “project” and “participating party” as used in this section have the same meanings as in Section 26003 of the Public Resources Code.