Establishment of Sustainable Energy Loan Program

Online comments: 7

• David H Floyd

  Please provide information about the loan program

  Comment added October 28, 2020 3:56pm

• Margaret Logan

  Chapter 58 states: “The procedures required for receiving certification to perform an Energy System Feasibility Study are set forth in the Program Guidelines.” Where do we find the PROGRAM GUIDELINES?

  Comment added October 29, 2020 11:39am

• David Sivin

  The current rules allude to Article 5-L of the General Municipal Law, which outlines eligibility criteria for those carrying out Renewable Energy Feasibility Studies. In 5-L, feasibility studies for solar PV systems that can generate 25 kW or less can be carried out via NREL’s PVWatts calculator. It says that NYSERDA’s approval of such program includes a review of the entity using PVWatts and carrying out the calculation. What pre-qualifications exist to carry out these 25kW-or-less studies? Can it be a Certified Energy Manager (CE), Professional Engineer (PE), Registered Architect (RA), etc.? Energy Auditors (who meet eligibility requirements under 5-L) would find much benefit in being able to carry out these studies themselves and lump them within the total Energy Audit report recommendations.

  Comment attachment
  Commercial-PACE-Guidance-2.pdf

  Comment added November 16, 2020 4:02pm

• Margaret Logan, Armstrong Fluid Technology

  Current rule: “Energy Efficiency Improvement” means any renovation or retrofitting of a building to reduce energy consumption, such as window and door replacement, lighting, caulking, weatherstripping, air sealing, insulation, and heating and cooling system upgrades, and similar improvements, determined to be cost-effective pursuant to criteria established by the Authority.

  Proposed Edit:

  “Energy Efficiency Improvement” means any renovation or retrofitting of a building to reduce energy consumption, such as window and door replacement, lighting upgrades, caulking, weatherstripping, air sealing, insulation, high efficiency HVAC (Heating, ventilation, Air Conditioning) upgrades, energy-efficient plumbing upgrades (including smart pumps), and associated automation and optimization, and similar improvements, determined to be cost-effective pursuant to criteria established by the Authority.

  Comment added November 26, 2020 4:13pm

• Susan Leeds

  With respect to the definition of Lenders in Section 58-02, more information should be provided about the criteria for pre-qualification of lenders and the pre-qualification process. This would help to attract lenders to the program and provide clarity for stakeholders.

  Also in Section 58-02, the Proposed Rule Amendment refers to Program Guidelines. The Program Guidelines may include additional requirements for lenders and borrowers that may impact the success of the C-PACE program and its effectiveness in contributing to the climate, environmental and economic development goals of NYC. The Program Guidelines should be made available for review prior to implementation.

  With respect to Section 58-08 covering project reporting:

  a) If LL84 benchmarking data is used for project M&V reporting, then the publicly available spreadsheets that include annual energy and water data disclosure under LL84 should also include a data field that flags whether a PACE loan is present on the property. This will facilitate analysis of beneficial impacts from the PACE program.
  b) Lenders should report on an annual basis the characteristics of the EE Improvements and Renewable Energy Systems installed using PACE proceeds, the types of properties receiving PACE loans, and size, term, CO2 equivalent reduction calculated using a consistent protocol, and savings calculated under SIR for loans originated during the annual reporting period. This data will help understand the PACE program impacts and outcomes, and can be provided by lenders on an anonymous basis to protect privacy.
  c) In addition to the reporting requirements of the Administering Agency, the content of an annual report should be designed to reflect on the PACE program characteristics, climate and environmental impacts and outcomes, as well as the size and scale of the PACE market. The annual report should be made publicly available.

  Comment added December 2, 2020 2:42pm

• Valerie Strauss

  Please see the attached brief comment on the proposed rule.
  Valerie Strauss,
  Director of Policy and Regulatory Affairs
  Association for Energy Affordability

  Comment attachment
  Comments-on-PACE-rules.pdf

  Comment added December 2, 2020 3:56pm

• Donna De Costanzo

  NYC should commit to transparent reporting that allows the public to understand the beneficial impacts of the PACE program.

  If LL84 benchmarking data is used for project M&V reporting, then the publicly available spreadsheets that include annual energy and water data disclosure under LL84 should also include a data field that flags whether a PACE loan is present on the property. This will facilitate analysis of beneficial impacts from the PACE program.

  At a minimum, lenders should annually report the characteristics of the EE Improvements and Renewable Energy Systems installed using PACE proceeds, types of properties receiving PACE loans, and size, term, CO2 equivalent reduction calculated using a consistent protocol, and savings calculated under SIR for loans originated during the annual reporting period. This data will help people understand the PACE program impacts and outcomes, and can be provided by lenders on an anonymous basis to protect the privacy of the borrower.

  The content of annual reports should be designed to reflect the PACE program characteristics, impacts and outcomes, as well as the size and scale of the PACE market. The Administrator should consider stakeholder input in determining the content of this annual report, which should be made publicly available.

  Comment added December 2, 2020 7:33pm