Virginia Regulatory Town Hall
Department of Energy
Department of Energy
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8/23/18  2:06 pm
Commenter: Girard J Gurgick


We need a robust PACE plan advanced by the state to include:

Residential PACE THIS IS ALLOWED NOW ON ALL  JUMBO and  CONVENTIONAL Loans  and AND ALL NON FHA loans!!!!!! and all properties with no mortgage.

Enforcement of PACE assessment by local jurusdiction 

Collection and disbursement by local taxing authority/ jurisdiction

Retroactive dates for project eligibility once and ordinance is proposed for adoption.

PACE applied to both new construction and rehab

Inclusion of energy and operations and maintenance in the savings calculation

Valuations of PACE LTV based on data servers plus buidlings, just like hotels include furniture

Carbon footprint reduction before renewables  We could use a mid range carbon tax as part of the evaluation say $100 /ton ( I have seen values for $35/Ton as used by the Federal Government and $900/Ton as proposed by an economist?? in a Forbes article.) 

30 years for solar panels

Low cost third party PACE administrators 

Open PACE finance include wealthy individuals etc

Higher PACE loan allowances LTC PACELTV SIR  allowances for synergies.  , using waste heat from a concrete plant, data center and  to provide heat and 

Opportuniities for the existing power company(ies)  to assist customers with PACE financed projects: design- build-administer.  This would allow a switch to fossil fuel free geothermal for heat and hot water and projects administered by a trusted competent party.  

We need to consider the value of using PACE financing to fund conservation easements, protections for sea level  rise in the Hamton Roads Area and SWM measures as needed in Alexandria.

CommentID: 66482