Thank you for the opportunity to comment on the VA Energy Plan. I’m a VA resident and energy advocate, and I work with Sustainable Real Estate Solutions (SRS), a Commercial Property Assessed Clean Energy (C-PACE) program administrator. C-PACE enabling legislation in VA was enacted a few years ago but to date only Arlington County has launched a program, which means only 2-3% of property owners in the addressable market in VA have access to this form of project finance. I’m writing to request action at the state level to expedite the launch of new programs in VA and increase access to the benefits of C-PACE for all program participants.

C-PACE programs are economic development programs that achieve broad, bipartisan support in locales that are aware of program benefits, which include:

• Local job creation for energy efficiency contractors and renewable energy project developers
• A new project finance choice for property owners and developers – covering 100% hard and soft costs at long terms (e.g., 25 years) - that can enhance asset value, increase NOI, and unlock projects that wouldn’t happen using cash or commercial loans
• Energy savings and reduced greenhouse gas emissions
• New funding opportunities for local and regional finance institutions
• Local infrastructure improvements

This form of financing is designed to encourage the use of higher performing energy efficiency and renewable energy systems in commercial buildings and, to facilitate its deployment, I encourage the expansion of utility energy efficiency programs for commercial buildings, removal of barriers to renewable energy and provision of incentives for projects in commercial buildings,  and that the state grant localities the authority to enact mandatory benchmarking programs for commercial buildings.

Further, I encourage action at the state level to educate VA jurisdictions on program benefits and tools they have at their disposal, and offer any other resources at your disposal to motivate them. For example, jurisdictions may review the 1) the Arlington C-PACE program design, infrastructure, and documents and 2) the Mid-Atlantic PACE Alliance (MAPA) document Toolkit and borrow elements that fit their jurisdiction’s specific needs. The goal here is to minimize staff time required to draft and enact a local ordinance, and then design and launch a program by leaning on established programs developed with best practice. 

The MAPA initiative has been valuable for raising awareness of C-PACE in VA, but a portion of the grant resources are spent supporting programs in DC and MD where market access to C-PACE is almost ubiquitous. In contrast, nearly all of VA remains in a policy development stage. The need for state-to-local engagement in VA at the policy level will persist for years to come, and state level C-PACE initiatives through DMME or otherwise should be dedicated to development of the C-PACE market in VA and should focus on new policies.

Every new market that launches a program will increase participation among contractors, capital providers, property owners and new construction developers in all jurisdictions. Please commit resources toward opening markets throughout the Commonwealth via the VA Energy Plan.

Scott Dicke

Sustainable Real Estate Solutions

SRS’ Director of VA C-PACE Programs and Director of Arlington C-PACE