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  • Comment Detail

  • Date: 01/24/20
    First Name: Girard
    Last Name: Gurgick
    Organization: G2EM dba Energy: Target Zero
    City: N/A
    State: N/A
    Attachment: N/A
    Number: 2020-N-1

  • Comment

    I have reviewed Morningstar reports, D&B reports, Journal of Structured Finance Reports , Rocky Mountain Institute Reports and the only common thread is that PACE is or can and should be beneficial. Occasionally bad or fraudulent actors have caused problems . FHFA experienced this in the 2008 Home Mortgage Debacle. The resulting market crash tells you exactly why neither consumers nor FHA should expose funds needed for geothermal HVAC and solar to the vagaries of the market. Instead FHFA needs to provide PACE loans in addition to mortgage loans. No need to throw the baby out with the bathwater. This way, as GSE's they can create criteria acceptable to them and have a mortgage value exposed to market risk and a MAGA loan (Make America Green Again) for the portions that do just that. One of their criteria can be the PACE loan must be cash flow positive. That is the energy $$$ saved are greater than the fixed price PACE payment.

    In the Virginia climate region I study GHG reductions possible with conversion to geothermal HVAC and if solar exposure allows, adding solar PV. Average US SEER is 10. I am told Code SEER is 14, Geothermal can reach a 43 SEER equivalent. Freon 22 is now obsolete. Many systems need conversion. It costs twice what an air to air system costs to convert to geothermal. It is 3-4 times more efficient. It eliminates fossil fuel use on site, NO gas is burned for heat or hot water. The resulting carbon footprint reduction from implementing a geothermal system is is 50-90%. GT increases year round utility plant load. It adds winter heating in an efficient heat pump sourced in 60 degree ground. GT adds year round water heating. GT efficiency reduces summer peaks for the utility company. It benefits all consumers and the environment

    In a PACE program, this change creates a cash flow positive PACE transaction. Financed over twenty five years (the average useful life of the equipment is 20 years, and the plastic heat exchange piping is good for 50 years) the energy savings pays for the PACE payment in the Virginia region and provides additional cash flow to pay the main mortgage to FHFA. In addition it requires less maintenance in general and the equipment is not exposed to weather so it lasts longer.

    Please consider helping consumers, the planet, and your balance sheet. Pick up the PACE become a PACE lender.