由Jacob Corvidae和Martha Campbell

上个月，联邦住房管理局（FHA）宣布将停止在房产评估清洁能源（PACE）贷款的房产上的新抵押贷款。关于它的决定是什么 -

according to itsletter到美国住房和城市发展部 - FHA“关注缺乏与速度评估的消费者保护相关的消费者保护，这远远不如传统的抵押贷款融资产品。”本公告直接矛盾guidance issued by the FHAin 2016.

Rocky Mountain Institute feels this decision is misguided for three key reasons:

• The FHA overstates the risk of PACE to taxpayers while failing to acknowledge or account for the significant default risk that the excessive energy expenditures of inefficient homes can create for a homeowner.
• 这将禁止房主从制作有价值的家庭改进，同时遏制步伐的建筑和翻新行业的工作创造潜力。
• It undermines existing state-level consumer-protection standards that are in place and federal standards that are in development, and may in fact guide homeowners toward more risky financing solutions, such as high-interest rate credit cards, that lack such standards.

关于PACE

PACE, founded in the early 2000s as an innovative way to finance home energy upgrades, tackles a significant market failure. It does so by increasing American households’ access to financial resources so they can afford cost-saving energy performance retrofits — a need which has largely been unfulfilled by any other financing instrument.

PACE not only removes the upfront cost of energy-efficiency, renewable-energy, and water-efficiency investments for homeowners, but also provides them with a more affordable financing alternative by offering longer payback terms and low repayment costs that are transferable upon a home’s sale (along with the benefits of the home improvements). PACE, like any other assessment, is attached to the property — not the individual — which makes it an innovative and unique green financing instrument. It also serves the community-wide interest in improving the housing stock while correcting for the failure of the market to fully recognize the impact of energy profiles on housing valuations.

To date, residential PACE (or R-PACE) has been used to finance $4.2 billion in home energy improvements, creating over 36,000 jobs in the states in which R-PACE is enabled,according to PACENation。自2008年以来，R-Pace已成功用于三个国家的158,000多个改造，这表明其市场可接受性，可扩展性和潜力作为转型市场融资工具。值得注意的是，R-Pace在加利福尼亚州看到了前所未有的增长，这主要是通过实现国家立法推动的。这种增长现已开始在佛罗里达州和密苏里州的其他州传播。

The real risk of high energy bills

This new guidance from FHA is like telling someone to tie their shoes before running away from an attacker; it’s distracting from the real threat. Home energy costs present a material threat to the mortgage industry and to the financial health of homeowners, and yet FHA has not taken any steps to address this threat. Worse, by attacking PACE, it is removing an important tool for homeowners to improve their energy bills, making that threat worse.

一项研究由北卡罗来纳大学的社区资本中心分析了来自Corelogic的实际贷款绩效数据，贷款行业的领先来源的这种数据。该研究发现，违约风险平均，节能房中平均32％，控制其他贷款决定簇。换句话说，如果我们要考虑效率的常态，那么平均违约风险的非高效家庭具有47％的风险。

Meanwhile, the Energy Programs Consortium reports that default rates for PACE customers are far lower than for typical customers. The burden of utilities is quite high for most American households. A 2017study by ATTOM Data Solutions和UtilityScore发现，平均美国的能源和水费票据增加了25％的房屋费用。

Homes with poor energy performance are a much more significant threat to consumers than homes with good energy performance. Despite the fact that homeowners say that energy efficiency is the top unmet need for their homes (greater than safety concerns, school access, or kitchen upgrades), the real estate and mortgage industries have failed to provide information for consumers to make informed decisions. Worse yet, homes with poor energy performance often have a greater potential for moisture problems, pest infestations, drafts, and other problems that can contribute to asthma and other health concerns.

Protecting consumers

By ignoring these consumer protections, the FHA is steering consumers who want to upgrade their homes toward far more risky options. A 2015 report由BMO Harris Bank发布found that 58% of Americans pay for home improvements with savings, 18% pay with credit cards, and 17% use home equity lines of credit. With 76% of Americans financing their home improvements through savings or credit cards, it appears that the market for home improvement financing models that could simultaneously benefit consumers’ financial health is large.

Especially important to note is that 37% of PACE financing is used to respond to emergency repair or replacement needs, while an additional 23% is used to repair something that “was likely to fail in the near future” according to a 2017 study by Research Into Action. These are situations where homeowners may not have been planning to make an upgrade, but in the face of a broken furnace, air conditioner, or roof had to protect their health, safety, and home investment. Therefore, relying on savings or credit cards may often be their only option in the face of an emergency, since traditional financing often takes too much time or may not be available to as many homeowners.

The same BMO Harris report found that 45% of Americans undertaking improvements also intended to make their homes more energy-efficient, demonstrating the importance of lending models that enable homeowners to meet multiple home improvement goals.

With the historical momentum and expansion of PACE, parties at the state and national levels have set and implemented robust consumer-protection guidelines. The Department of Energy’s “Guidelines for Pilot PACE Financing Programs” served as the basis for early best practices established in 2014 by PACENation, an organization focused on promoting PACE by providing leadership and support to a growing member base (then operating as PACENow).

PACENation — in collaboration with industry leaders — developed and releasedConsumer Protection Policies Version 2.0earlier this year. The policies were adopted by the California Statewide Communities Development Authority and the Western Riverside Council of Governments — both of which heavily informed California’s PACE policies — and now serve as an industry standard.

Today, more consistent consumer protection standards upheld across local communities and states will help ensure the successful growth and scaling of residential PACE programs, while protecting the integrity of PACE as a public–private partnership. Standardization of operations across jurisdictional boundaries will reduce the need for customization and enable consistency, which will allow PACE programs to continue to streamline their operations, and thus provide lower costs to participating homeowners.

FHA: Get out in front of the market

Secretary of Housing and Urban Development Ben Carson stated, “Assessments such as these are potentially dangerous for our Mutual Mortgage Insurance Fund and may have serious consequences on a consumer’s ability to repay, or when they attempt to refinance their mortgage or sell their home.” But this statement doesn’t match the data available about where true default risk lies. So far, customers with PACE financing have a lower mortgage default rate, while non-energy-efficient homes have a 47% higher default risk than efficient homes.

We laud Carson’s concern about default rates, and agree that the industry should act fast to protect against defaults — but if that’s really the concern, then the industry needs to move to integrate energy use into the appraisal process so that homeowners understand the real cost of homeownership and can get better mortgages to support more efficient homes. In fact, much of the industry is moving toward improved models to address this, which FHA could support, rather than simply sitting back and being reactive.

如果FHA对其担忧具有违约风险，应响应能源成本提出的违约风险，并加入对谈话进一步加强消费者保护的谈话，适合其使用和与家庭估值相关的使用和规模。让我们努力扩大消费者的安全选择，以升级他们的家园并降低月度费用。想象一下更节能的住房库存，将违约风险降低30％。RMI已经努力寻找非泊斯班，经济上可行的市场解决方案，以更好地使用35年。如果HUD和FHA对解决方案感兴趣，我们就准备了帮助。

Jacob Corvidae works as a manger in the Rocky Mountain Institute’s Building Practice. Martha Campbell is manager of the Residential Energy+ team in RMI’s Buildings Practice. © 2017 Rocky Mountain Institute. Published with permission. Originally posted on RMI Outlet.