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Virginia Regulatory Town Hall
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8/18/21  11:14 am
Commenter: Chase Counts, CHP Energy Solutions

Existing Alternatives for R-PACE

I would strongly advise against pursuing R-PACE in Virginia. The PACE model is better suited for commercial properties. R-PACE creates conditions for fraud and abuse by predatory profit-driven companies that do not have the interests of the customers truly in mind, especially for under-resourced communities. This is demonstrated throughout the country where R-PACE exists and was even a featured segment on HBO's Last Week Tonight with John Oliver recently. 


I would also encourage decision-makers to learn from the experience of a Virginia electric utility using private, profit-driven companies to deliver energy efficiency services to income-qualifying households before turning to the weatherization provider network in 2015. The delivery of the program created conditions for contractors to optimize profits without taking building science and how the house works as a system into consideration. This resulted in moisture problems and other health and safety issues for the participants, many of who reached out to weatherization providers later on for support and corrective services. I would be concerned the development of an R-PACE program without stringent guardrails would result in similar outcomes.


And why develop an R-PACE program with guardrails when income-qualifying households already have access to other programs carrying far less risk? Federal WAP/LIHEAP and current electric and gas utility-sponsored programs in Virginia utilize the licensed, insured, and credentialed weatherization provider network to provide weatherization and energy efficiency services at no cost to the participants. These programs offer a means of receiving energy burden-reducing services without saddling the participants with any financial liabilities. These programs are delivered by mission-driven non-profit weatherization providers with strict training and licensing requirements, material specifications, and standard work specifications defined through the federal weatherization program. These criteria have also been adopted by the utility-sponsored weatherization programs.


Additionally, the Pay-As-You-Save (PAYS) on-bill tariff model being piloted by Rappahannock Electric Coop is much better suited for income-qualifying households and has a far better track record than R-PACE across the country in the limited rollout it has seen over the past few years. The PAYS model has some of the benefits of R-PACE but avoids the hazards of massive property tax bills for households already under-resourced. I’m cautiously optimistic about PAYS in Virginia and hope it pans out but this may still result in income-qualifying customers assuming debt unnecessarily when they may be better served through federally funded and utility-sponsored programs at no cost.


In my professional opinion, R-PACE would likely result in more harm than good for the intended beneficiaries of the services and it is attempting to fill a gap that is already filled by programs with less risk to participants. I would encourage decision-makers to avoid introducing R-PACE to Virginia.

CommentID: 99777