How Councils of Governments Fund Green Infrastructure: Possible Applications for the Sustainable Ohio Public Energy Council

1
How Councils of Governments Fund Green Infrastructure: Possible
Applications for the Sustainable Ohio Public Energy Council
Jeff McKinney
Master of Science in Environmental Studies, George V. Voinovich School of Leadership and Public
Service, Ohio University
Leadership Practicum
July 8, 2021
Community Partner:
Mathew Roberts, Director of Marketing, Sustainable Ohio Public Energy Council
Advisory Committee:
Dr. Amy Lynch, Department of Geography, Ohio University
Dr. Gilbert Michaud, George V. Voinovich School of Leadership and Public Service, Ohio University
Dr. Geoff Dabelko, George V. Voinovich School of Leadership and Public Service, Ohio University

2
CONTENTS
Introduction….............................................................................................................................4
Scope of Work….........................................................................................................................6
Goal…............................................................................................................................6
Deliverables…................................................................................................................6
Literature Review….....................................................................................................................6
Introduction….................................................................................................................6
Green Infrastructure….....................................................................................................7
Green Roofs…....................................................................................................8
Green Walls….....................................................................................................9
Benefits of Green Roofs….............................................................................................. 9
Lifecycle Cost Benefit Analysis…......................................................................9
Energy Savings in Heating and Cooling…........................................................10
Other Financial Benefits.....................................................................................10
Green Roof Costs and the Need for Financing................................................................11
Green Roof Project Cos.ts...................................................................................11
Financing Options and Deficiencies...................................................................12
Financing of Municipal Green Infrastructure Projects.....................................................13
Financing of Green Infrastructure by Councils of Governments.....................................17
Research Questions.......................................................................................................................18
Methods.........................................................................................................................................18
Scope Adjustments and Rationale....................................................................................20
Results............................................................................................................................................21
Councils of Governments as Conveners...........................................................................21

3
Councils of Governments as Fiscal Intermediaries...........................................................24
Councils of Governments as Program Administrators......................................................28
Financial Tools COGs Use to Fund Green Infrastructure.................................................30
Commercial PACE...............................................................................................30
Efficiency as a Service.........................................................................................38
Below Market Loans............................................................................................40
Community Development Financial Institutions....................................40
Revolving Loan Funds............................................................................41
Grants and Program-Related Investments...............................................43
Conclusions....................................................................................................................................44
Recommendations for SOPEC.......................................................................................................47
Personal Reflection on Practicum Experience...............................................................................49
Works Cited...................................................................................................................................51
Appendix A....................................................................................................................................55
Appendix B....................................................................................................................................60
Self-Evaluation...............................................................................................................................
Approval of Leadership Practicum Proposal..................................................................................
Approval of Leadership Practicum Presentation............................................................................
Client Evaluation of Student..........................................................................................................

4
INTRODUCTION
The Sustainable Ohio Public Energy Council (SOPEC) is a community choice aggregator (CCA),
council of governments (COG), and one of the most prominent regional organizations in Ohio. SOPEC
started as a CCA in 2014 (Sustainable Ohio Public Energy Council, n.d.) by facilitating the sharing of
energy services between communities. In 2015, the organization began to broaden its focus into the
areas of energy conservation, energy efficiency, and renewable energy development. COGs are
voluntary associations of local governments that work on planning needs that cross the lines of the
individual local entities or that require regional attention (National Association of Regional Councils,
personal communication, 02-25-2021). They can coordinate planning and provide a regional approach to
problem solving through cooperative action for mutual benefit. The ultimate goal of COGs is to improve
the quality of life for all residents of their geographical footprint. As a COG and regional and statewide
leader, SOPEC is strategically positioned to consider expansion into new projects that advance their
energy mission and fit the needs and circumstances of Ohio.
One potential area of expansion is green infrastructure (U.S. Environmental Protection Agency
[EPA], 2019). In addition to managing stormwater, green infrastructure helps to reduce heat islands in
the summer and insulates or shades nearby buildings, which reduces the energy needed to heat and
cool buildings. Green infrastructure technologies that would create energy savings include green
roofs, green walls, and tree canopy expansion. Technologies that would absorb carbon include green
roofs, green walls, bioswales, constructed wetlands, rain gardens and bioretention, tree canopy
expansion, and wet ponds. SOPEC is most interested in supporting energy savings and
decarbonization. Consequently, the most valuable technologies for SOPEC would be those that
facilitate both energy savings and decarbonization: green roofs and green walls. Tree planting would
also fit these criteria, but does not align with SOPEC’s goals and situation, principally because it is
most often employed in dense urban areas. Green roofs and green walls could potentially be
constructed in a variety of zones within the SOPEC region: residential areas, transportation right of

5
ways, public lands and parks, and institutional and commercial sites (Green Infrastructure Ontario
Coalition, 2017).
There is a large demand for green infrastructure, but due to the high upfront costs of building
green roofs and green walls, financing is often a barrier. While there is significant research (Beyer &
Gartner, 2019; Carter & Fowler, 2008; Koscielniak & Gorka, 2016; Rugh & Liu, 2014; Zimmerman,
Brenner & Abella, 2019) on how government entities like municipalities fund green infrastructure,
less is known about regional organizations like COGs. Financing is particularly challenging for COGs
because they do not have the statutory authority to raise general revenue through levying taxes or fees.
They also cannot issue bonds, and 75% of funding for infrastructure projects comes from tax-exempt
municipal bonds (Chen & Bartle, 2017). However, regional organizations do have potential in this area.
SOPEC’s experience in organizing and facilitating funding for large energy projects, for example,
places them well for building partnerships with organizations that have greater funding capacities.
Yet, academic literature on the role of regional organizations in green infrastructure funding is thin.
More information is needed to understand the specific roles that regional organizations can play in
facilitating green infrastructure to meet energy and decarbonization goals. This practicum helps to fill
this gap in knowledge as it relates to SOPEC’s characteristics and situation. Through a combination of
interviews and document reviews, this project examines how COGs and similar regional organizations
support green infrastructure and the specific mechanisms and partnerships they use.
The findings of this project show that the most plausible role for a COG like SOPEC is that of a
third-party intermediary that convenes stakeholders that are interested in installing green roofs and green
walls. Promising funding mechanisms for such a group would include PACE, below-market loans, and
grants. COGs are free to facilitate installation of green infrastructure if state statutes, organizational
board policy and organizational capacity permit it and frequently they do. Green roofs and green walls,
while not common technologies employed by COGs, are possibilities if they meet the goals of the
organization. Notably, among the organizations convened by SOPEC for a project, at least one would
ideally have financing authority, through taxes or borrowing, since COGs are not permitted by statute to

6
raise funds in that way. However, COGs do have the ability to form a parallel organization that could
borrow, as exemplified by NOPEC.
SCOPE OF WORK
Goal
The purpose of this practicum is to use informal interviews and document review to examine
what United States COGs, such as SOPEC, are doing to access funding mechanisms for installing and
maintaining green infrastructure such as green roofs and green walls. SOPEC requested that the work
focus on three likely funding mechanisms: commercial PACE, Efficiency as a Service, and below
market loans. In addition, the practicum identifies and examines the convening, fiscal intermediary, and
program administrative roles that COGs take nationally in promoting green infrastructure. This is
designed to assist SOPEC in identifying practical ways to expand its mission to include facilitating
reduction of energy use and increase in carbon sequestration in communities through green infrastructure.
Deliverables
1. A final report of research findings and recommendations, in PDF format, to be submitted to Mat
Roberts of SOPEC.
2. A final practicum portfolio.
LITERATURE REVIEW
Introduction
The purpose of this literature review is to survey existing academic research on the role of COGs in
financing green infrastructure, including green roofs and walls. While there is some literature addressing
the funding of green walls, far more attention is given to green roofs. Consequently, most of the

7
examples concern green roofs. The literature review was conducted in early to mid 2020 in the process of
preparing the proposal for practicum research. During the actual practicum, some items were found
which were added to the literature review. Part of the original literature review in the proposal stage was
not included in the final practicum product because of some alterations in the research questions.
There is a clear deficiency in the academic literature about the role of COGs in the financing of green
roof projects. Searches on internet search engines and academic sites such as Google Scholar, along with
searches through the university library, did not show articles. Much more information is available on the
role of municipalities and non-COG regional organizations, especially those with dedicated funding
sources or financing authority. Some funding mechanisms are also better covered than others. There is a
large amount of literature on PACE and below market loans, for example, but less about Efficiency as a
Service. For all three mechanisms, there is little about how COGs use them.
Green Infrastructure
Infrastructure is comprised of “the physical structures and networks that deliver the requisite
services to various sectors and communities and that facilitate the overall development of a
nation…Broadly, infrastructure includes water supply, sewage, housing, roads and bridges, ports, power,
airports, railways, urban services, communications, oil and gas production, and mining” (Kumari &
Sharma, 2016, p. 50). A sound infrastructure is the foundation for economic and agricultural
development at the national, regional and local levels.
Infrastructure is classified into two categories, physical/economic, describing infrastructure that
makes economic functions possible, and social, which refers to infrastructure that promotes and expedites
social development and increases healthy life outcomes (Kumari and Sharma, 2016). Green infrastructure
falls within the social category, providing not only environmental, but social and material advantages
(U.S. Environmental Protection Agency [EPA], 2019). Some in the field use the phrase “stormwater
control measures” to describe the whole range of infrastructure technologies. The stormwater
management benefits of green infrastructure include both water quantity and water quality (Mid-America

8
Regional Council [MARC], 2020). The U.S. EPA defines green infrastructure as being comprised of a
foundation of vegetation which manages water flows at their source by mitigating the speed, absorbing it
into the ground, evaporating it, or transpiring it.
There are three major categories of green infrastructure: (1) situated on terrain (bioretention, rain
garden, bioswale, natural buffers, constructed wetland, wet pond) and on streets (porous pavement, green
streets, tree canopy expansion); (2) positioned on buildings (green roof, downspout removal, cisterns, rain
barrels); and (3) varied applications and set-ups, such as green walls within buildings (Zimmerman,
Brenner, & Abella, 2019). As previously mentioned, while looking at green infrastructure as a whole,
this study emphasizes green infrastructure that has the most potential to both save energy and absorb
carbon: green roofs and walls.
Green Roofs
Green roofs consist of four main components: growing medium (soil), a drainage layer, a
waterproof membrane, and vegetation (plants) overlying a traditional roof. Green roofs are used to
achieve environmental benefits including reducing stormwater runoff, energy use, and the heat island
effect. The two broad categories of green roofs are extensive and intensive. Extensive green roofs offer
lower maintenance, use less growing medium (three to six inches), utilize drought and temperature
tolerant plants (e.g., sedum and other succulents), and usually only require irrigation in the first year. In
contrast, intensive green roofs are more expensive, are heavier due to use of deeper growing medium (six
inches or more), usually require irrigation, but allow for a greater variety of plants from herbs to trees.
Extensive green roofs are more common than intensive roofs because they are less expensive and easier to
maintain. Within the category of intensive green roofs, semi-intensive roofs (six to 12 inches growing
medium) are more common than the intensive green roofs that have over 12 inches of growing medium
(U.S. General Services Administration [GSA], 2011).
Green Walls

9
Green walls involve the vegetation of a vertical surface with a variety of possible plant species.
The structure can be outside or inside of a building. Green walls are more visible from the ground than
green roofs and have surged in popularity during the last decade. The two categories of green walls are
green facades, which are comprised of climbing plants that grow from the bottom to the top of a wall, and
living walls, which use modular and other technologies to grow plants uniformly up the surface of a wall.
Both are primarily installed in urban environments. While, at one time, green facades were mainly valued
for their aesthetic contributions, they are now considered a sustainability strategy and a method for
retrofitting buildings for energy efficiency. The benefits of green walls include enhancing the inside
climate of a building, providing an insulation layer, fostering evaporative cooling, and absorbing solar
radiation, all of which lead to reduced energy demands for a building (Manso & Castro-Gomes, 2015).
Benefits of Green Roofs
Lifecycle Cost Benefit Analysis
Cost benefit analysis shows that the lifecycle costs of green roofs can be recouped in the majority of
the world’s cities. Kats and Glassbrook, 2018, for example, report the results of cost-benefit analyses of
smart surface technologies, including green roofs. Their research analyzes 40 years of data on energy and
greenhouse gases, stormwater, health, climate change and employment and finds substantial net benefits
of green roofs across cities. Washington, DC showed benefits which exceeded costs by $1.8 billion,
Philadelphia by $3.6 billion, and El Paso, TX by $538 million (Kats & Glassbrook, 2018). Another study
shows that an extensive green roof with 3-inch to 6-inch media covering 10,000 square feet saves $2.70
per square foot per year more than a traditional roof (GSA, 2011). Dollar amounts given here and
elsewhere in this section are inflation-adjusted and presented in 2020 values.
Over a 50-year period, stormwater and energy savings along with carbon dioxide sequestration
more than compensate for the costs of installing, maintaining and replacing green roofs by providing a
benefit of approximately $21.85 per square foot of roof. Benefits to the community, such as air quality,

10
heat island, and biodiversity (in contrast to impacts on owners or occupants of property), have the greatest
upward effect on net present value at a savings of almost $44 per square foot of green roof (GSA, 2011).
Energy Savings in Heating and Cooling
A study in Ottawa found that an extensive green roof with a 6-inch medium mitigated heat gains
by 95%, and curtailed heat losses by 26% compared to a conventional roof (Liu & Baskaran, 2003). For a
two-story building in Florida, researchers found that 18% of energy used for indoor cooling was saved by
a green roof compared with a conventional roof. When the plants were more mature, 44% was saved
(Sonne, 2006). Finally, the economic benefit of reduction in space conditioning demand has been
quantified by a previous study, which demonstrated that a green roof can save $0.180.68 per m2
in
cooling, and 0.22 per m2
in heating annually (Bianchini & Hewage, 2012).
Green roofs also contribute to the reduction of the urban heat island effect. An urban heat island
occurs when a metropolitan area becomes warmer than surrounding areas due to the built environment
(buildings and pavement) and excess heat emitted by energy usage. Green roofs mitigate urban heat
islands through evapotranspiration, along with providing insulation for buildings. A study from the
Mediterranean region demonstrates that 10%–14% of the electricity used in air conditioning residences
and apartment buildings can be saved by green roofs (Zinzi & Agnoli, 2012). Green roof mitigation of the
urban heat island effect varies, however, due to differences in the surrounding environment and the
structure of the buildings.
Other Financial Benefits of Green Infrastructure
The longer life span of green roofs compared to traditional roofs lead to financial savings as
fewer new roofs are needed over the life of a building. The duration of a roofing membrane can be up to
40 to 50 years for green roofs (Clark, Adriaens, & Talbot, 2008), while a conventional roof’s life ranges
from 10 to 30 years (Oberndorfer et al., 2007). Another category of green roof financial savings results
from Leadership in Energy and Environmental Design (LEED) certification. Installing a green roof is one

11
step toward earning LEED certification, which increases access to capital. The return on investment of
LEED certified buildings increased by 19.2% for green retrofits of existing buildings, and 9.9% for new
green buildings (U.S. Green Building Council [USGBC], 2015). Financial benefits also accrue from the
mitigation of stormwater runoff. Green roofs can reduce the sewer system capacity needed by absorbing
between 50%-95% of rainfall in the area of a building (Beecham & Razzaghmanesh, 2015). Cities pay
high costs for managing stormwater, so this reduction can yield substantial cost savings.
Green Roof Costs and the Need for Financing
Green Roof Project Costs
The long-term financial benefits of green roofs are important because green roofs remain costly.
Installation and maintenance increase short-term costs well over that of traditional roofs (see Table 1).
The installed costs for extensive green roofs range from $11.85 to $14.38 per square foot more than a
conventional roof. The installed costs for semi-intensive green roofs range from $18.63 to $22.66 per
square foot more compared to a conventional roof. However, due to economies of scale, green roof
installation costs per square foot do decrease as size of the roof increases. Annual maintenance for a
green roof is also higher than for a conventional roof, by a range of $0.24 to $0.36 per square foot, with
costs declining per square foot as roof size increases (GSA, 2011).
Despite the higher short-term costs for green roofs over conventional roofs (Table 1), the benefits
in the life cycle of green roofs appear to compensate for these initial costs. If money can be found to
invest in their installation, long term savings for property owners and surrounding communities will
exceed the short-term costs of installation.

12
Table 1. Calculated green roof costs by building type and size.
Size of Roof
Extensive Green
Roof:
Installation costs
over that of a
conventional roof
Semi-Intensive
Green Roof:
Installation costs
over that of a
conventional roof
Extensive Green
Roof:
Total annual
maintenance costs
over that of a
conventional roof
Residential Roof
1,700 sq ft $24,000 $38,000 $600
Older Commercial
Roof
5,000 sq ft
$67,000 $106,000 $1,600
Recent Commercial
Roof
10,000 sq ft
$127,000 $200,000 $2,800
One-third the size of a
box store
50,000 sq ft
$592,000 $931,000 $12,000
Note: Adapted from data given in GSA, 2011. Numbers are adjusted for inflation to the year 2020.
Financing Options and Deficiencies
The cost of green roof projects is high, creating a clear need for financing, which is often
challenging. Some potential private and public investors consider green infrastructure investments to be

13
less attractive than alternative investments that are not as “green.” Reasons for this include the smaller
scale of green infrastructure transactions, the lack of regulatory support and carbon pricing mechanisms
from governments, and the perceived lag in technological development and therefore implementation of
certain green infrastructure methodologies. Many of the benefits of green roofs are also difficult to
monetize. Public and private sector collaboration will likely be needed to overcome these types of
challenges. Public lending agencies can offer grants, for example, to encourage private bank-type
instruments and other private finance flows (Baietti, Shlyakhtenko, La Rocca, & Patel, 2012).
Investment in other types of sustainable or green enterprises highlights additional drawbacks to
this deficiency. A 2020 report suggested that, despite an increase in Environmental, Social and
Governance (ESG) investment funds, the money currently being invested in renewable energy and green
infrastructure represents only about half what would be needed to mitigate global temperature increases.
This deficiency indicates the need to find more methods to raise funds for green installations of many
types, but including green roofs and walls. Some commentators recommend carbon taxes world-wide to
properly account for the externalities of greenhouse gas emissions, along with more accurate
measurements of progress toward financing green infrastructure, but these broad recommendations are
beyond the scope of this review (“Green investing has shortcomings”, 2020).
Financing of Municipal Green Infrastructure Projects
In the U.S., a growing desire to address climate change mitigation and adaptation has motivated a
movement to overcome financial barriers to implementation of green infrastructure technologies at the
local level, particularly in municipalities. Municipalities are key actors in many – if not most – green
infrastructure projects and have funding, administration, and implementation roles. While there is no
evidence in the literature that COGs are adapting municipal funding strategies, it is useful to survey
municipal mechanisms to understand the breadth of funding strategies and challenges and the
complementary role that COGs might play. Most green infrastructure financing literature is conducted at
the municipal scale.

14
Challenges abound in the financing of municipal green roof and green wall projects. Some of
these challenges include increasing capital building costs, tightened public sector budgets due to spiking
health insurance and pension costs, and unpredictable federal and state funding sources (Chen & Bartle,
2017). Nearly half (42%) of local government practitioners express that municipalities and other
jurisdictions need significant influxes of local, state or federal funding to sustain even basic maintenance
of existing green infrastructure, let alone build additional technologies. Government spending on green
infrastructure has also not matched the financing demands brought about by population expansion (Chen
& Bartle, 2017).
The practice of jurisdictions attempting to use funds from general revenue, which normally are
designated for gray infrastructure, presents a challenge because of legal restrictions on investing public
funds on private properties. Gray infrastructure refers to concrete sewage and stormwater systems.
Another barrier is the lack of monetary valuation given for ecosystem services, which means that the
financial benefits of green infrastructure are often undervalued. Due to this undervaluing, the payback
period for loans becomes extended beyond 10 years, which discourages private investors (Dhakal &
Chevalier, 2017). Yet another challenge occurs in some municipalities where cross-sector collaboration
within city government – frequently necessary for green infrastructure – has been discouraged. Individual
departments often seek single purposes in projects, and the cross-sector benefits of projects are not
considered, much less quantified. This leads to higher overall costs for municipal investment in green
technologies (Beyer & Gartner, 2019).
While challenges to municipal green infrastructure financing can be daunting, solutions for these
financing challenges are growing in number and impact. Financing for green roof and green wall
installation and maintenance has come from multiple tools. One category of these tools is direct
incentives. A primary example of a direct incentive is grants, which do not need to be repaid. Grants
have been the most common form of financing in recent years, with about two-thirds of funded projects
receiving grant funding. This may be due to reliance on new technologies which do not have a long,
established track record to support financial pay-back flows. As these technologies become more well-

15
known, non-grant sources, some of which need to be paid back, may become more common. These direct
incentives include subsidies such as loans and loan guarantees, bonds, taxation, and philanthropic funds
(Carter & Fowler, 2008). 75% of all public infrastructure projects are funded by tax-exempt municipal
bonds. Most of these projects are sponsored by state and local governments (Chen & Bartle, 2017).
Another solution to barriers in the direct incentive category is financing on a 10 to 15-year fee
schedule in order to attract private investors and financiers. Recently, municipal green bonds have
become more popular as a funding approach. Green bonds raise funds to provide capital for green
technology installations that attempt to mitigate or adapt to climate change. As mentioned above, green
roofs and green walls sequester carbon. The labeling of bonds as “green” attracts funds from socially
conscious investors. Since 2010, U.S. states and municipalities have issued over $15 billion of green
bonds (Dhakal & Chevalier, 2017). An example of a direct incentive from a philanthropic foundation was
when the Chesapeake Bay Foundation implemented a grants program for green roof projects, which
provided approximately 20% of green roof installation costs to seven projects in the mid-2000s (Carter &
Fowler, 2008).
Another direct incentive solution, the Property Assessed Clean Energy (PACE) program
authorized in many U.S. states, attempts to overcome risks to upfront investment (Baietti et al., 2012) in
green roofs and the retrofitting of buildings. PACE allows building owners to pay for renewable energy
technologies and green infrastructure through special charges added on to their property taxes. The
instrument makes long-term, fixed-rate financing for green infrastructure installation more feasible for a
wider range of clients. In highly organized transactions, PACE authorizes property owners to avoid up-
front cash outlays, and the savings realized from the project can equal or exceed the special assessment
costs (U.S. Environmental Protection Agency [EPA], 2011).
One direct incentive approach to public and private sector collaboration is public-private
partnerships, or PPP. PPP is the most popular avenue to financing green infrastructure globally (Kumari
& Sharma, 2016). The strategy involves use of private resources to leverage and support public policy
assets and services, which would include goals of socially conscious investment. The private sector

16
partner agrees to execute at least one public sector function, such as upfront project capital financing,
operations and maintenance. This collaboration would be long-term and lead to mutual social and
commercial benefits. Revolving loan funds would assist in this collaboration by including borrowers who
have not yet established a favorable risk position. An advantage for the private partners would be
opening avenues to financially sound types of projects which would only be available through the public
sector. Advantages for the public partner would include lifting some of the financial burden, use of more
modern technologies, improved management, reduced political opposition to the projects, and marketing
benefits (Koscielniak & Gorka, 2016).
PPPs potentially can reduce green infrastructure retrofitting costs through innovation in
technology, alternative financing and use of private sector advantages. An example of a PPP program for
green infrastructure is found in Washington, DC, where the District Department of the Environment
(DDOE) has promulgated stormwater management regulations. For land-disturbing projects, the water
from 1.2-inch storms must be retained, while for substantial improvement projects, the water from 0.8-
inch storms must be retained. DDOE seeks to incentivize green infrastructure retrofits by a stormwater
credit trading program. Private-public projects may include several technologies, including green roofs
(U.S. Environmental Protection Agency [EPA], 2015).
Another possible direct incentive solution is to connect gray and green financing, which
potentially could stimulate private-public collaboration. Green infrastructure finance attracts a different
set of investors than traditional gray infrastructure, since there is an additional element of social return on
investment (Zimmerman et al., 2019).
In addition to direct incentives as the first general category of solutions to the challenges of
financing municipal green infrastructure projects, indirect incentives comprise a second category.
Stormwater utility fee credits are a popular indirect incentive. In this incentive, credits are given to help
offset a stormwater utility fee if builders install green infrastructure technologies that minimize
impervious surface on a property. For example, Portland permits up to a 35% reduction of the stormwater
utility charge depending on the effectiveness of green technology installed on the property. Another type

17
of indirect incentive is a building density bonus, which allows a developer to build more housing units on
a particular site if the developer installs green roofs or walls on the buildings. Cities such as Portland and
Chicago select areas within the city that qualify for the density bonuses, then set specific bonus space
amounts for each square foot of green roof or green wall (Carter & Fowler, 2008).
Financing of Green Infrastructure by Councils of Governments
Unlike counties and municipalities, councils of governments do not have access to general funds
or other fee/tax revenues and must be more creative to support green infrastructure installations. There is
a clear deficiency in the academic literature about the role of regional organizations such as COGs in
financing green roofs and green walls. There is much more information available regarding the activities
of municipalities. This practicum will help fill that gap by gathering information about the green
infrastructure financing activities of COGs.
Given the imbalance between research on municipalities and COGs, it would be useful to
consider whether green infrastructure finance methods implemented by municipalities, such as PPP, could
be adapted for use by COGs. One example of a regional COG that is empowered to fund green
infrastructure projects is the North Central Texas Council of Governments, through their Sustainability
Development Funding Program in cooperation with a Regional Transportation Council. Technologies
funded so far include pervious walkways, a bioretention drainage garden, paving materials which reflect
more heat back to the atmosphere, bioswales, and shade trees. Green roofs would qualify for the funding,
but they are not currently listed among projects that have been completed. The program has offered
funding in four different years (2001, 2006, 2010, and 2018), awarding $163 million, including a local
match of $32.6 million for infrastructure projects to support sustainable development (North Central
Texas Council of Governments [NCTCOG], n.d.). However, this funding grew out of the partnership with
the Regional Transportation Council, not solely through the auspices of the North Central Texas Council
of Governments. Therefore, this cannot be considered as a COG adapting a municipal funding strategy.

18
Similarly, the above-referenced federal Housing and Urban Development Sustainable
Communities Regional Planning grants have stimulated regional investments in green infrastructure.
Nine non-urban regional planning organizations received grants in the 2010s for multijurisdictional
projects such as water infrastructure, water quality, green housing, watershed protection, development of
sustainability planning and performance measures, green space, reduction of energy costs, and climate
change mitigation and adaptation through mitigation of greenhouse gas emissions. The goals of these
projects included sustainability and livability. Green roofs could be one technology implemented through
these grants (HUD, n.d.). However, these organizations are not COGs and the grants were possible
because of other jurisdictions with whom these organizations partnered.
RESEARCH QUESTIONS
Due to deficiencies in the literature regarding how COGs facilitate green infrastructure projects, my
research focused on the following:
1. What roles could a COG like SOPEC play in facilitating green infrastructure projects,
particularly green roofs and green walls?
2. How could a COG potentially facilitate implementation of PACE, Efficiency as a Service, and
Below Market Loans/Grants for green infrastructure projects?
3. What lessons do these examples provide for SOPEC? How could SOPEC apply this information
to facilitate green roof or wall projects in its focal region?
METHODS
To answer the first two research questions, I began with an internet search of information about
regional organizations, including COGs and (1) green infrastructure, (2) green roofs, (3) financing, and
(4) specific funding mechanisms: commercial PACE, Efficiency as a Service, and Below Market Loans,

19
and additional terms that describe these mechanisms. I also sought out and spoke with representatives
from umbrella organizations of regional organizations, such as the Council of Development Finance
Agencies, the National Association of Regional Councils, the National Association of Development
Organizations, and the Mayors Climate Protection Center. I then directly contacted individuals associated
with potentially relevant organizations and reviewed the information available on the organization’s
website. Depending upon the email responses, I scheduled a phone or Zoom conversation or conducted
the interview over email. Many contacts also provided additional materials or references for review. After
the initial search, I employed a snowball sampling method. I asked interviewees if there was anyone else
they could think of that I should speak with and added new contacts to my list as I identified them in
reading provided documents. Many interviewees did suggest additional individuals to contact. A complete
list of contact organizations is available in Appendix A. I have withheld the names of specific individuals
as they did not give permission for their name to be shared in this document.
I corresponded with 46 individual practitioners in COGs, umbrella regional planning
organizations, and financial institutions throughout the United States who provide leadership in accessing
or lending funds for the installation and maintenance of green infrastructure, including green roofs and
green walls. Some of these were emails while others were phone calls (see Table 2). I examined
approximately 70 websites. I also spoke to practitioners regarding the roles played by COGs in
facilitating the financing of green infrastructure. In terms of organizations, 39 were contacted by email, 22
by phone, and three through webinars or conferences. I received information from 32 different
organizations. Some of these practitioners were in municipalities, regions, and states across the US, while
others were in the state of Ohio. Since SOPEC is in Ohio, knowing specifically how Ohio organizations
function in terms of green infrastructure installation roles and financing mechanisms was particularly
important. The umbrella regional planning organizations I contacted organize and assist regional
councils, development organizations, and development finance organizations. The purpose of contacting
umbrella organizations was to streamline collecting information on COGs, which number in the
thousands. The umbrella organizations directed me to specific COGs that they thought would be able to

20
provide information about my research questions. The umbrella organizations often also provided
information directly.
Table 2. Summary of direct contacts with various types of organizations.
Type of
Organization
Emails
Sent
Emails
Received
Phone/Zoom Conference/
Webinar
Info
Received?
Umbrella
Organizations
6 6 3 0 13
PACE
Administrators
4 4 3 2 6
Capital Firms 3 2 1 0 3
Government
Agencies
6 8 1 4 8
Regional Planning
Organizations
9 5 2 0 3
Higher Education 6 4 1 0 3
Private Convener 4 4 2 0 4
Environmental
Finance Centers
19 9 4 0 3
Councils of
Governments
3 3 0 0 2
Research and
Policy
3 1 1 1 2
Advocacy and
Trade Groups
3 3 2 0 1
Private
Construction
7 3 1 0 2
Miscellaneous 8 5 3 0 4
TOTALS 81 57 24 7 54
Scope Adjustments and Rationale
As previously discussed, the green infrastructure technologies that are most aligned with
SOPEC’s current mission are green roofs and green walls. COGs, however, facilitate the funding of a
wide range of technologies. Some of these strategies could be adapted for green roofs and green walls, so
findings described below are not limited to green roofs and walls.

21
In addition, the original intention of this practicum was to survey the green infrastructure
financing mechanisms of regional organizations of several types, including councils of governments.
However, it quickly became clear that such an endeavor would run beyond the time frame of the project
and could result in findings not directly applicable to SOPEC. Therefore, I refocused on councils of
governments, specifically. The other potential option would have been to examine community choice
aggregators (CCAs), which is also a role that SOPEC takes. But because there is significant overlap
between CCAs and COGs, a study of COGs would include most CCAs, nationally. SOPEC’s identity as
a COG, and those organizational characteristics, supersedes its identity as a CCA for the purposes of this
study.
The other scope adjustment that was required was urban vs. rural focus. It was my initial plan to
focus on rural COGs, but I expanded this to include all COGs, regardless of their location along the urban
to rural gradient. This was for two reasons. First, SOPEC was interested in gaining information about the
functioning of COGs from urban and suburban as well as rural areas. Secondly, SOPEC has been in the
process of expanding its regional footprint to include non-rural areas.
RESULTS
The two parties fundamental to a green infrastructure project are the jurisdiction that desires to
build it and a construction or landscape design firm that is the direct implementer. The term “third-party”
refers to an organization such as a COG that would work with these two fundamental parties to facilitate
the project. There are three variations of the third-party role that Councils of Governments (COGs) can
play in funding green infrastructure: (1) convener, (2) fiscal intermediary, and (3) program administrator.
As a convener, the third-party COG would bring in additional helpful stakeholders. As a fiscal
intermediary, the COG would oversee and manage funds coming from a source that is allowed to raise
money, such as the federal government, a state government, or a municipality. As a program

22
administrator, the COG would manage the day-to-day operations of a green infrastructure project, such as
ensuring that PACE loans are actually repaid. In addition to these roles, a COG could decide which
funding mechanism would best fit a particular green infrastructure project, such as PACE, Efficiency as a
Service, or below market loans.
COGs as Conveners
This role involves calling together stakeholders with a common interest in facilitating a green
infrastructure project, which could include green roofs or green walls. COGs can serve in this role if it is
permitted in their by-laws (University of Maryland and Syracuse Environmental Finance Centers,
personal communication, 03-02-2021) and due to their in-depth knowledge of their region and its actors
and needs, they are well-placed to do so.
Each geographic area in the U.S. has entities that fund and govern green infrastructure through
different methods and structures, including not for profits, sewer districts, and COGs. The entity that
performs the role of convener for these projects varies. There is a lack of role clarity for conveners, with
overlapping organizations and jurisdictions. While this may appear to be a disadvantage for organizations
around the U.S. interested in fulfilling this role, it can also allow for more flexibility and options for
COGs like SOPEC (United States Environmental Protection Agency, personal communication, 05-26-
2021). The keys for such organizations are the statutory boundaries from each state for permissible COG
functions, as well as board approval within individual COGs. One example is Metroplan of Central
Arkansas, a COG which convenes stakeholders to deal with environmental issues. It focuses on power
strategies such as energy efficiency and renewable energy, but addresses urban heat island effects, energy
consumption, urban forests, cool roofs and cool pavements. It currently is not using green infrastructure
technologies such as green roofs and green walls, but does provide an example of a COG using the
convener role to take action in similar sectors (Metroplan of Central Arkansas, n.d.).

23
In a greener infrastructure-oriented example, the Mill Creek Alliance of Cincinnati Ohio works
with the Municipal Sewer District of Cincinnati to manage the Mill Creek Watershed and facility
planning area. The Sewer District, which is associated with the city of Cincinnati, administers a green
infrastructure implementation plan and is the central organization in the effort. The Sewer District is
required to install green infrastructure to mitigate sewage overflows that end up mixed with stormwater
and going into streams. The Ohio-Kentucky-Indiana Council of Governments (COG) participates by
overseeing the “water quality management plan” for each watershed in the region, which requires
organizing a number of local stakeholders, although it has not been a major participant in the broader
project (Shifflett et al., 2019). A COG could have a larger role in such a project, perhaps as the convener,
a role played by the U.S. EPA played here (USEPA, personal communication, 05-26-2021). There are no
Ohio state laws precluding this function, so it would depend on the individual COG board policy (Ohio
Revised Code, 2021).
Hospital systems also could present opportunities for COGs to convene stakeholders for green
infrastructure programs and is a category that seems likely to attract capital. The Ohio Health system has
hospital facilities in southern and central Ohio. Its Sustainability Program has built green roofs on
hospitals at Riverside and Dublin. Along with the green roofs, they have installed healing gardens and
rain gardens at these facilities. The purposes range from energy savings, aesthetics, to emotional and
mental health benefits. Ohio Health intends to loop sustainability into any new structures they build.
They have used internal funding resources (Ohio Health, personal communication, 01-05-2021), but their
interest suggests healthcare as a potential partner for SOPEC in future green infrastructure projects.
The Buckeye Hills Regional Council, based in Marietta, Ohio, is a regional planning organization
that serves southeast Ohio in various ways, including applying for grants by working with foundations
and government entities. While not a COG, the organization has similar roles and powers, including
convening local governments and financing entities to help meet their goals. An example is the building
of a senior housing facility. Buckeye Hills obtained the services of a private investor, who received tax

24
credits for participating in the project. They also attempted to access Just Transition funds to help
expedite the transition of southeast Ohio to solar energy, but were not funded in this cycle. They confirm
that other regional organizations, including COGs, have the potential to convene stakeholders in this
manner (Buckeye Hills Regional Council, personal communication, 03-22-2021).
COGs as Fiscal Intermediaries
This role involves serving as a fiscal agent or otherwise providing spending oversight of funds
allocated by another entity for a green infrastructure project. This would include serving as a fiscal agent
for grants flowing from the federal government, state governments (commonly transportation agencies),
and foundations. No contacts or interviewees were able to give an example of a COG serving as a capital
firm that actually provides the funds for a project (see the Eastgate COG and Southeast Michigan COG
examples below). Indeed, there are few, if any, funds that are directly generated by a region, with the
exception of regions created for utility service provision (National Association of Regional Councils
[NARC], personal communication, 02-25-2021). But this does not hinder COGs from serving as a fiscal
intermediary for outside funds.
As COGs have limited power to raise funds, association with a capital firm can be important. The
main contribution of a capital firm is to provide funds for up-front installation costs (Lean and Green
Michigan, n.d.). In the Baileys Trails project in southern Ohio, representatives from Athens County, the
City of Athens, the City of Nelsonville, the Village of Chauncey, and York Township convened
stakeholders and then brought Quantified Ventures (Figure 1) on board to secure financing for installation
and maintenance costs. Later, a COG (Outdoor Recreation Council of Appalachia) was organized to take
on the role of continuing project management and facilitating stakeholder collaboration. Therefore, the
roles of a COG and Quantified Ventures as a capital firm are distinct (Quantified Ventures, n.d.). Figure
1 depicts the functioning of Quantified Ventures, a capital firm. It may appear at first glance that they are

25
more of a convener or intermediary than a capital firm. But a closer look at their activities – primarily
securing funding-- shows that they are a capital firm.
Figure 1. Quantified Ventures primary role in Baileys Project was to secure capital (Chesapeake Bay Foundation,
n.d.)
One example of a COG playing a variety of roles, including as the fiscal intermediary of a federal
grant, is Northwest Michigan Council of Governments (now Networks Northwest). They received a
United States Department of Housing and Urban Development (HUD) Sustainable Communities

26
Regional Planning Grant in 2011 under the title of “Grand Vision to Grand Action: Regional Plan for
Sustainable Development.” HUD partnered with the U.S. Department of Transportation and the U.S.
EPA to fund these grants, the purpose of which was to support metropolitan and multijurisdictional
environmental planning efforts. Networks Northwest provides technical assistance to local decision-
makers and stakeholders on natural resource issues, then oversees implementation of policy and practice.
In 2014, the COG conducted research on low impact development to produce a regional plan, “A
Framework for Natural Resources in Northwest Michigan,” which was considered as part of an
overarching plan, “Framework for Our Future: A Regional Prosperity Plan for Northwest Michigan.”
Much of the efforts of this COG has been applying for state level grants for placemaking in communities
and then serving as a third-party administrator. They have, for example, been an overseer of stormwater
control programs, such as the use of rain gardens in Manastee County (Networks Northwest, personal
communication, 12-15-2020).
Another example, one which illustrates the combination of fiscal agent and plan-making roles, is
the Southeast Michigan Council of Governments (SEMCOG), which has facilitated a plan to build green
infrastructure. They have served as a fiscal agent for funds originating with the Department of
Transportation of the state of Michigan. SEMCOG offered competitive sub-grants for this program
(National Association of Development Organizations [NADO] personal communication, 03-10-2021).
SEMCOG has partnered with the Great Lakes Commission to oversee and monitor this program. Prior to
this program, SEMCOG developed an extensive green infrastructure plan for the region entitled, “Green
Infrastructure Vision for Southeast Michigan” (Southeast Michigan Council of Governments [SEMCOG],
2014). This plan recommended installation of green infrastructure for the purpose of managing
stormwater runoff and improving water quality. In addition, SEMCOG has partnered with the US EPA to
develop a green infrastructure technical assistance program for local jurisdictions entitled, “Green
Infrastructure Targeting in Southeast Michigan” (SEMCOG, 2016). The technical assistance program
includes statistical studies and projections for stormwater volume reduction based on the area of green

27
infrastructure technologies such as bioswales, permeable pavement, and rain gardens. Technical
assistance can also cover help to local jurisdictions with the grant-writing process. Green roofs are
mentioned in SEMCOG reports but are not highlighted in the data analysis (NARC, personal
Environmental justice is a current emphasis of the Biden Administration and many state agencies.
A COG that incorporates environmental justice goals could support underserved communities and
strengthen its position in applying for grants. The U.S. EPA defines environmental justice as “the fair
treatment and meaningful involvement of all people regardless of race, color, national origin, or income
with respect to the development, implementation and enforcement of environmental laws, regulations,
and policies” (US EPA, Environmental Justice, para. 1, n.d.). SOPEC’s connection with historically
underserved Appalachian areas along with urban areas in Akron and Canton could open opportunities for
grant proposals that would include environmental justice.
One example of this is the Central Midlands Council of Governments (CMCOG) in South
Carolina, which addresses environmental justice in the planning and implementation of its environmental
programs. CMCOG plans and develops programs for regional concerns such as air and water quality,
open space preservation, and energy efficiency and renewable energy. CMCOG also provides planning
involving GIS/Mapping, technical support for local jurisdictions, wetlands mitigation, hazard mitigation.
Laws and policies which guide CMCOG is applying this to the jurisdictions in their region include the
federal Safe, Accountable, Flexible, Efficient Transportation Equity Act and the regional
CMCOG/COATS Title VI plan. These laws and plans set forth the following principles:
• “Avoiding, minimizing or mitigating disproportionately high and adverse health or
environmental effects on minority or low-income populations;
• Ensuring full and fair participation by all potentially affected communities in the
transportation decision-making process;

28
• Preventing the denial, reduction or significant delay in the receipt of benefits by minority
populations and low-income communities” (Central Midlands Council of Governments,
Title VI Plan, 09-28-2020)
CMCOG’s environmental justice emphasis particularly applies to policies impacted by their
partnership with South Carolina transportation agencies. If SOPEC were to partner with transportation
agencies, they could support an environmental justice program similar to CMCOG’s on green
infrastructure projects such as green streets which are connected to transportation. They could also
support green roofs in urban areas historically disadvantaged by redlining policies which restricted
property ownership to minorities and led to less green space and worsened urban heat islands.
COGs as Program Administrators
This role would involve conducting operation and management tasks for a program such as
PACE. This could include ensuring repayment of debts in the PACE program, along with other duties
such as working with engineers, construction contractors, equipment vendors, capital lenders, utilities,
and government agencies which issue permits. They could also analyze and monitor the progress of
projects. There is a recent trend toward municipalities seeking a third-party organization to be program
administrators because they do not have the time, expertise, or resources to do it themselves (U.S.
Department of Energy Better Buildings Summit, C-PACE Toolkit, 05-18-2021). COGs serving as
program administrators could help move regional organizations more strongly toward implementation.
This would seem to be a positive shift. One critique of the HUD Sustainable Communities Grant program
(e.g., Networks Northwest) is that the regional planning organizations that received the grants for
infrastructure spent most of the resources on planning rather than implementation (NADO, personal

29
An example of a program where a COG practices program administration is the Clean Ohio
Greenspace Conservation Fund program, which became law in 2000 through a state referendum. It
authorizes budgetary assistance to local communities to preserve green spaces, protect ecosystems,
expand local park impacts on wildlife, and restore streams. The Eastgate Regional Council of
Governments in the Youngstown, Ohio, area is the local administrator of the funds in that area (Eastgate
Regional Council of Governments, n.d.)
While funded by a municipal government, another example of a regional organization playing an
administration role is the Anacostia Watershed Society in Bladensburg, MD. They organize a RiverSmart
Rooftops Program and facilitate the installation of green roofs as part of retrofitting buildings for the
purpose of mitigating the volume of stormwater runoff flowing into District of Columbia and the
surrounding area’s waters. The program uses rebates calculated on the square footage of green roof
installed on the building. In addition to commercial buildings, there is funding available for smaller
residential projects. Funds come from the District of Columbia Department of Energy and Environment.
Applicants are required to submit plans for a green roof from a structural engineer and plans for
maintenance (Anacostia Watershed Society, n.d.). A COG like SOPEC potentially could partner with a
watershed organization to be a third-party administrator of a similar project.
Another example is the US Department of Energy Weatherization Assistance Program (WAP),
which is often administered by COGs in regions across the US (NARC, personal communication, 02-25-
2021). Along with its counterpart program, the Weatherization and Intergovernmental Program, DOE
provides grants, technical assistance, and serves as an information clearinghouse to states and local
jurisdictions and agencies for energy programs. Green infrastructure, including green roofs, can be
financed by this federal program since it is considered weatherization (US Department of Energy,
Weatherization, n.d.)
An example of COG administration of these DOE weatherization funds is conducted by the
Upper Coastal Plain Council of Governments (UCPCOG) in eastern North Carolina. Financing from the

30
US DOE’s Cities Leading through Energy Analysis and Planning project enabled UCPCOG to strengthen
the efficiency of energy delivery to low-income households between 2016 and 2018. This was done by
improving the sharing of critical information among various governmental jurisdictions and utility
companies. Residents benefit from the improved energy efficiency and other assistance programs offered
by utilities and local jurisdictions. Stakeholders convened by UCPCOG included the North Carolina
Department of Health and Human Services, the North Carolina Department of Environmental Quality,
Community Action agencies, the Choanoke Area Development Association, the Wayne Action Group for
Economic Solvency, and a few utility companies (Upper Coastal Plain Council of Governments, n.d.).
While this particular program does not fund green roofs, it does demonstrate how a COG can be in charge
of a weatherization program that possibly could fund green roofs.
Financial Tools COGs Use to Fund Green Infrastructure
Commercial PACE
Commercial PACE is a method of finance in which building owners borrow funds for energy
efficiency, renewable energy, and decarbonization and then repay the loans through an assessment on
their property tax bill. The amount of funds invested in Commercial PACE nationally is expected to
increase from $2 billion (2014) to $86 billion, over the next four years. The health care and multi-family
building sectors are currently experiencing the fastest growth (Bricker and Eckler PACE webinar, 01-12-
21). PACE is only available in states with specific enabling legislation and established energy special
improvement districts (ESIDs). SOPEC is eligible to participate in PACE because Ohio has passed
enabling legislation. ESIDs are necessary for PACE funding because they authorize the local collection
of PACE paybacks through property tax bills (NEOAED, personal communication, 12-16-2020). 33 new
ESIDs were created in Ohio in 2020 (Bricker and Eckler PACE webinar, 01-12-21). Currently, the only
ESID in southern Ohio is a small demonstration project in Scioto County, but there may be other southern

31
Ohio ESIDs in the planning stage (Bricker and Eckler, personal communication, 01-15-2021) and others
could be created. One advantage of PACE is that the financing agreement remains with the property even
if it is sold, which encourages long-term private and government capital investments which are based on
the projected energy savings to be realized in the building (US DOE Better Buildings Finance Navigator,
n.d.)
PACE provides upfront capital funding for retrofitting existing buildings through the
replacement, refurbishing or new installation of energy and water technologies. It can also fund new
construction or gut rehabilitation by installing energy efficiency and water conservation measures which
exceed code requirements. It can also be used for refinancing projects already underway which meet
energy efficiency guidelines. Examples of technologies funded by PACE include heat pumps, LED
lighting and green roofs.
The six main parties that are normally essential to a PACE project are the convener of
parties/program administrator (which can be the same party), the property owner, the contractor that
installs the technology, the capital lender, the jurisdiction that enforces the loans (in Ohio, an energy
special improvement district [ESID] as described above), and program administrator (Lean and Green
Michigan, personal communication, 03-05-2021). In Ohio, the Bricker and Eckler law firm is the major
organization serving as a program administrator. Program administrators are involved in originating a
project by assessing whether a project is eligible for PACE funding, providing consumption data analysis
which demonstrates potential energy savings of a project, using building energy simulation from
engineering, finding a capital financier, and monitoring the project’s outcomes as it proceeds (Bricker and
Eckler, personal communication, 01-14-21). In Michigan, for projects above $250,000, the proposed
project must demonstrate that more savings will be generated than costs of installing and maintaining
(Lean and Green Michigan, personal communication, 03-05-2021). There are both public and private
benefits of energy efficiency and green infrastructure technologies, but they need to be quantified in order
to bring capital investment on board. In addition, program administrators can identify leverage points for

32
growing projects, which helps stakeholders accelerate PACE projects. They can provide leadership in
talking directly to property owners as potential customers and financiers as potential sources of capital in
order to emphasize the attractive benefits of PACE financing: the long terms of financing, the lack of
personal guarantees, lower interest rates, and the ability to borrow greater amounts of money (Berkeley
Labs, personal communication, 05-28-2021). Gaining customers is enhanced by leading off with an
economic and jobs message and then moving to explain the sustainability benefits (National Association
of State Energy Officials, personal communication, 05-19-2021).
There is a current trend toward third-party PACE program administration, with consistent advice
and technical assistance often requested by local governments (Missouri Energy Initiative, personal
communication, 06-04-21). A PACE administrator oversees the project and convenes stakeholders. The
administrator also monitors and measures fidelity to program stipulations. A local government,
authorized by the establishment of an ESID, collects the PACE payback that is added on to the property
tax bill. A contractor installs the equipment or technology (such as LED lights or a green roof) while the
building owner makes timely payments. Councils of Governments can serve as PACE intermediaries and
program administrators, depending on each state’s PACE legislation. Missouri, California and Oklahoma
are states where COGs are very involved as PACE program administrators (Missouri Energy Initiative,
personal communication, 06-04-21).
An example from California is the Association of Bay Area Governments (ABAG), which is a
Council of Governments representing the nine counties and 101 cities that make up the San Francisco Bay
Area. The Bay Area Regional Energy Network (BayREN) is a program of ABAG, and they serve the
board of ABAG, the facilitator of Commercial PACE projects in their region (Bay Area Regional Energy
Network, personal communication, 05-19-2021). BayREN is also comprised of the nine counties in the
Bay Area, and ABAG is the program administrator. They implement a portfolio of energy efficiency and
decarbonization programs in their territory, and employ Commercial PACE as one mechanism of funding
(Bay Area Regional Energy Network, n.d.)

33
Another California COG is the Western Riverside COG (WRCOG). It serves in the role of
convener and administrator for the PACE program within this region. It also oversees other sustainability
programs, including the Riverside County Habitat Conservation Agency, the Transportation Uniform
Mitigation Fee, and Western Community Energy (Western Riverside COG, n.d.). It has the authority to
levy transportation fees, while Ohio COGs do not. However, there was a controversy in 2020 about the
residential PACE program there, and WRCOG dropped certain parts of the program in response to
complaints from consumer advocates (Riverside Based Agency to end Controversial Pace Loans, 12-22-
2020)
Ohio is a state where a COG would theoretically be permitted to serve in this capacity (Bricker
and Eckler, personal communication, 01-15-2021). The ESID would be considered as a client of the
COG (Lean and Green Michigan, personal communication, 03-05-2021). The COG would need to
include in its by-laws the parameters for the fee structure and to create a manual with rules for a project
(Missouri Energy Initiative, personal communication, 06-04-21). In the case of a COG like SOPEC,
capital would be provided by either a specialized, boutique private investor (Berkeley Labs, personal
interview, 05-28-2021), a port authority such as the Columbus-Franklin County Finance Authority, or a
government fund. The program administrator and mortgage lender would then review and approve the
project (US DOE Better Buildings Finance Navigator, n.d.).
If SOPEC were to consider getting involved with facilitating financing of PACE, a factor to
weigh would be whether possible projects would be located in jurisdictions with an existing ESID. If not,
they would need to work toward the establishment of a new ESID. Ohio HB 444 makes it easier to
manage PACE districts, since jurisdictions included in a local ESID no longer have to be geographically
contiguous (Bricker and Eckler PACE webinar, 01-12-21). Another consideration would be if long-term
financing (10-20 years) and lower monthly payments would make sense for a potential SOPEC-sponsored
project. SOPEC also would need to consider whether they would want to devote the resources to conduct
the study necessary to demonstrate that the long-term savings would more than cover the amount of the

34
loan. Other factors would be whether SOPEC would prefer to set up pilot projects before implementing
more wide-spread work and whether the initial proposed project would meet the minimum threshold
requirements for a project. Currently, a port authority, the Columbus-Franklin County Finance Authority,
for example, requires a minimum project of $2 million in order to enter as a financier of a PACE project
outside Franklin County (Columbus-Franklin County Finance Authority, personal communication, 12-24-
2020). Another port authority funder, the Southeast Ohio Port Authority, is not involved in any
environmental projects. They are strictly supporting economic development, which includes fossil fuels,
plastics and pipelines (Southeast Ohio Port Authority, n.d.). For small projects in Appalachian Ohio,
credit unions could possibly be a source of capital (Missouri Energy Initiative, personal communication,
06-04-21). Finally, another consideration for SOPEC would be that Ohio has a decentralized approach to
PACE, which means there are already multiple active PACE programs in the state led by Bricker and
Eckler Attorneys, port authorities in Toledo and Columbus, and by NOPEC and the Northeast Ohio
Advanced Energy District. SOPEC would need to identify a niche for getting involved in PACE
financing for green infrastructure.
Bricker and Eckler is not overseeing any PACE green roof or green wall projects at this time.
However, they noted “huge” potential to expand in that direction (Bricker and Eckler, personal
communication, 01-15-2021). If property owners and private lenders could be convinced that green roofs
and walls pay for themselves over the lifecycle of an installation through reducing energy costs, managing
stormwater, reducing heat islands, sequestering carbon and aesthetic value, those in the field believe
interest in using PACE would increase (Donovan Energy, personal communication, 01-14-21).
Donovan Energy of Cincinnati serves as a private consultant for commercial property owners to
counsel them about energy efficiency and building decarbonization opportunities through PACE funding.
Donovan specializes in larger projects, such as warehouses. After a client expresses a strong interest in
moving forward with a project, Donovan contacts entities in their PACE lending network, such as private
lenders, the Greater Cincinnati Redevelopment Authority, and Bricker and Eckler Attorneys, which has
superseded the Redevelopment Authority on PACE, to a large extent. Donovan’s heavy involvement

35
with PACE in the tri-state area (Ohio, Kentucky and Indiana) has enhanced its national notoriety, leading
to membership on the PACENation board (Donovan Energy, personal communication, 01-14-21).
Coordinating with a company like Donovan could accelerate SOPEC’s PACE work.
In a complex arrangement, the Northeast Ohio Public Energy Council (NOPEC) partners with the
Northeast Ohio Advanced Energy District (NEOAED) to facilitate financing energy efficiency and
decarbonization projects through PACE. The Northeast Ohio First Suburbs Consortium, a COG which
was originally charged with a purely economic development mission, founded NEOAED to participate in
funding environmental and energy projects. NEOAED is an energy special improvement district (ESID),
which is necessary in Ohio for PACE projects. NOPEC reached out to NEOAED in 2015 to suggest
collaboration on PACE. Since NOPEC as a COG cannot be an ESID, they proposed to NEOAED that
NOPEC could earmark NOPEC funds by investing in PACE as a financial partner. NOPEC borrowed
funds through the USDA Rural Energy Savings Program, created an LLC, and were able to relend the
funds for energy efficiency projects through their STEP program (a non-PACE program) at a low interest
rate. However, NOPEC used their own funds to contribute to PACE projects with NEOAED. The
projects funded by the NEOAED/NOPEC PACE collaboration have spanned from small “mom and pop”
efforts to large mixed-use, highly sophisticated enterprises. These partners in recent years have tapped
equity from private lenders after experiencing difficulty obtaining funding in the past (Northeast Ohio
Advanced Energy District, personal communication, 12-16-2020).
Lean and Green Michigan (LAGM) serves as another example of how SOPEC could administer
PACE. LAGM led the effort to build the first PACE-funded green roof in the state of Michigan. While
Lean and Green Michigan is not a COG, it mirrors how a COG functions in at least one important way—
select local jurisdictions, especially municipalities, are clients of LAGM. LAGM provides services that
the jurisdictions either do not have the time or staffing resources to perform themselves. LAGM is the
sole convener and intermediary for PACE in Michigan. They are known for their development of PACE
Express, which opens opportunities for funding for smaller projects under $250,000 (Lean and Green

36
Michigan, n.d.) LAGM’s work most relevant to SOPEC is the green roof installed on the Belt Line
Center. The roof was in need of replacement, and Belt Line selected the green roof option. Several
entities are stakeholders for this project. The Belt Line Center is the property owner, while Wayne
County established a PACE district that enables PACE funding to flow through. The PACE contractor is
Inhabitect, while the lender for the project is CounterpointeSRE. Over a million dollars was financed for
a 20-year term, with projected 20-year savings exceeding the amount financed (Michigan PACE laws
require that for projects of over $250,000).
Green infrastructure technologies installed in the LAGM Belt Line Center project include a green
roof, a blue roof, and a rain garden. Lean Green Michigan estimates that the CO2
emissions sequestration
will result in the equivalent of removing 100 cars off the road per year. The green roof/blue roof/rain
garden will also contribute to the aesthetics of the Belt Line Center’s shops and offices which house
artisans and entrepreneurs. Along with the green roof, the over 9,000 square foot blue roof will serve as a
secondary layer beneath the green roof that will contribute to stormwater management. The rain garden
on the terrace will also contribute to containing stormwater runoff. PACE makes this cost-effective by
providing the up-front capital investment and enabling the repayment to be spread across 20 years, thus
assuring that the savings will exceed the up-front PACE capital. Commercial loans typically have a tenor
(maturity period) of 3–5 years, resulting in an annual repayment greater than the energy and stormwater
management savings.
Wayne County’s elected leaders created a countywide PACE district, required by Michigan law,
in December 2013 by partnering with the Lean and Green Michigan PACE program. Since the County
will ensure collections of the PACE assessment similarly to any other property tax bill, private lenders
feel more confident in providing fixed-interest loans with terms of 20 years.
The relevant distinction for SOPEC concerns Lean and Green Michigan’s role and how that role
differs from that of CounterpointeSRE. CounterpointeSRE’s role was to provide the actual capital. On
the other hand, Lean and Green Michigan serves as a not-for-profit project administrator/consultant that

37
coordinates stakeholders, including local jurisdictions, contractors, property owners, and lenders to utilize
PACE to finance energy and economic development. Their role is to provide quality control, facilitate
cooperation among stakeholders, study applicants to determine whether their project qualifies for PACE,
find a financier, and provide technical assistance to determine the level of monetary savings over time.
While SOPEC could not function in the financier capacity (as Counterpointe SRE does), SOPEC could
function in the same capacity as Lean and Green Michigan, if SOPEC’s board agrees to devoting
resources to that role. SOPEC would then be looking to those starting Ohio Energy Special Improvement
Districts as potential clients for PACE projects.
Another example, Ygrene Financing, is a PACE third party provider similar to Lean and Green
Michigan, except that it operates in four states: California, Florida, Missouri and Ohio. Counties in Ohio
serviced by Ygrene are Hamilton, Summit, Franklin, Lucas and Wood. Ygrene includes green roofs as
one of the roofing technologies available for Ohio (Ygrene Financing, n.d.), although no examples were
readily available.
Some COGS take all three third-party roles, in support of PACE. Metro Washington Council of
Governments (MWCOG) has served as a convener, fiscal intermediary and program administrator for
PACE-funded green roofs. They have had a Green Roof Subsidy Program since 2007. An example of
MWCOG overseeing PACE green roof projects is the Taylor Street Self Storage building, where the
green roof serves as ballast for installation of solar panels. Another example is the United Audi Field, a
20,000-seat soccer stadium that includes a green roof (Mid-Atlantic Pace Alliance, 2021).
The Southwest Regional Development Commission (SRDC) in Minnesota is structured similarly
to a Council of Governments. It facilitated the original meetings where establishing a regional PACE
program was discussed. The counties involved asked the SRDC to seek funding for a PACE pilot project
to determine need. The Executive Director raised $1.1 million in grant and loan funds to establish the
program. It was decided that the program would operate under the auspices of the Rural Minnesota
Energy Board (RMEB) with SRDC staff administering the program under contract. The RMEB is an

38
eighteen-county joint-powers Board created to work on energy policy in southern Minnesota. The SRDC
has provided staff support to the RMEB since its inception, so it was a natural fit for SRDC staff to
administer the PACE program on their behalf. Southwest Minnesota is known for its renewable energy
industries such as wind power and ethanol and bio-diesel production. The region has no traditional natural
resource-based energy production such as coal or oil but has been a net exporter of energy since the early
2000s exclusively from renewable sources. The goal of the region has been not only to produce more
energy than it consumes, but to continue to reduce the overall consumption of energy. The PACE
program contributes to this regional goal by providing financing to businesses to reduce their energy use.
This reduction results in more money in their pocket while also achieving regional energy goals. The
PACE program also helps stimulate the local economy by providing work for contractors and installers of
energy systems. The end result of the program is a reduction in energy use, an increase to the bottom line
of local businesses utilizing the program and more business for local contractors and installers, truly a
win-win-win (Southwest Regional Development Commission, n.d.).
Efficiency As A Service
Efficiency as a Service (EaaS) is a relatively new means of financing energy efficiency, water
efficiency, or decarbonization projects with no upfront capital expenditures by building owners. Private
companies with technical expertise and the ability to raise capital pay for and install and maintain the
equipment. Building owners benefit from lower utility bills and they contract to pay the providers out of
the energy savings achieved. Retrofits of existing buildings are off the business balance sheet with third-
party ownership of installations with no money down for a contracted period of five to fifteen years. The
third-party provider handles the installation and maintenance. This method allows more flexibility
embedded in contracts for smaller projects (US DOE Better Buildings Finance Navigator, n.d.) Third-
party providers specify expected outcomes and measure them after installation. The process is less
standardized than other finance methods, with a wider variety of customers. EaaS is most commonly

39
executed in the commercial/industrial and MUSH (municipalities, universities, schools and hospitals)
categories.
Third-party providers are popular with EaaS because they consolidate all transaction costs into
one intermediary. Efficiency in buildings fails among property owners for several reasons, including lack
of technical expertise to evaluate their buildings, lack of awareness that energy efficiency is a problem,
and lack of understanding of available funding options. There is a fear of a low return on any possible
investment in building energy efficiency. EaaS operationalizes a turnkey option which is funded by the
energy savings achieved by installing technologies that are measured by circuit level meters. Third-party
providers deliver simplicity to property owners to address the underlying issue of complexity. Examples
of technologies used include high efficiency HVAC units, heat pumps and LED lighting. Customers can
contract with the third-party to have such equipment designed, installed and maintained with zero upfront
costs, and the provider only gets paid when the customer saves money. Meters commonly are used to
measure results. One advantage of EaaS is that it works for all sizes of businesses. Third-party providers
promote EaaS to potential customers by providing information to a staff contact within the property
owner organization who then presents this as a recommendation to the property owner’s leadership team
(US DOE Better Buildings Summit, Efficiency as a Service session, 05-18-2021).
EaaS has size limitations as providers tend to favor large projects ($1 million+) over smaller
projects (less than $250,000), but there is flexibility. Small projects can be bundled into larger projects.
Another disadvantage is on leased property, where EaaS will not work if the contract term is shorter than
the lease time. In addition, EaaS deals can be complicated by the length of time required to complete all
the necessary financial and legal paperwork (US DOE Better Buildings Navigator, n.d.)
COGs could theoretically facilitate EaaS projects by convening stakeholders, but there is no
evidence that such an arrangement actually has been implemented. Multiple private firms currently fill
the role of financier of installation and maintenance of technologies such as heat pumps and meters (US

40
DOE Better Buildings Finance Navigator, n.d.). A COG considering becoming a direct provider of EaaS
would have to consider whether they would want to develop and devote the technical expertise and time
required. A COG would also have to determine if they have sufficient organizational funds to leverage the
risk of being an EaaS provider (Missouri Energy Initiative, personal communication, 06-04-21). Leaders
in the field believe, however, that COGs could serve as EaaS third-party providers (US DOE Better
Buildings Summit, Five Finance Trends, 05-17-2021; Berkeley Lab, personal communication, 05-28-21),
largely because of the trend in the financing mechanisms toward third party administration due to
municipalities and other jurisdictions electing not to invest personnel resources in the administrative
tasks.
Below Market Loans
Below market loans from public organizations, foundations, or other entities are characterized by
below-market interest rates that assist organizations interested in investing in specific social policy
missions. Organizations such as the Bank of America and the Cleveland Foundation in Ohio are
motivated to accept lower financial returns on loans and to take greater risks with poor credit ratings
because of their commitment to environmental progress such as mitigating climate change. The missions
could include sustainability efforts such as retrofitting buildings that would lead to certain
decarbonization outcomes (US DOE Better Buildings Navigator, n.d.). In addition to philanthropic
motivations, other organizations, such as manufacturers, sellers of products, and construction firms
sometimes are willing to offer financing at lower interest rates in order to expedite deals for projects.
Banks and other private sector lenders are often favorably disposed toward investing in these types of
projects. Below-market loans are sometimes issued by banks authorized by local governments, historical
societies and philanthropic organizations for retrofitting historical buildings. These present a potential

41
mode of financing for green infrastructure. Categories of below-market loans include community
development financial institutions, revolving loan funds, and grants and program-related investments.
Community Development Financial Institutions
In recent years, there has been an increase in the number of Community Development Financial
Institutions (CDFIs), which provide a type of below market loan. They are lending organizations that use
a combination of federal funds and private capital in order to offer loans to disadvantaged and distressed
communities for resilience, climate adaptation, and other sustainability technologies (Georgetown
University, n.d.), along with their main goal of community economic development. A COG like SOPEC
could convene a green infrastructure project and assist a stakeholder entity (e.g., a capital financier) in
obtaining funding from CDFIs because green infrastructure can be linked to community development,
which is the main goal of CDFI funding. However, CDFIs in the SOPEC region such as AceNet
Ventures, Appalachian Growth Capital AGC and Appalachian Partnership do not currently fund green
infrastructure projects. CDFIs can contribute to the start-up capital for green banks. Green banks make
available a wide range of funding options for sustainability projects such as energy efficiency and water
conservation. Often, but not always, green banks operate in underserved areas. The Solar and Energy
Loan Fund (SELF) is a green bank that began in St. Lucie County, Florida, as a CDFI. As the program
grew from its inception in 2011 to 65 other Florida jurisdictions, SELF transcended its status as a CDFI
by adding on several other funding mechanisms and thus became a green bank (Green Bank Network, 10-
17-2018).
Revolving Loan Funds
A revolving loan fund is a pool of capital that serves as a source of below market loans. Internal
revolving loan funds come from within the financial resources of an organization for the use of that
organization, including sustainability projects. As energy costs are saved as a result of such a project, the

42
funds are repaid and then reloaned internally for another project. State and local jurisdictions and other
organizations can set up revolving loan programs that serve external organizations, and those are also
repaid to the revolving loan fund from energy savings. One of the most prominent examples among the
more than 30 states that have established such programs is the LoanSTAR Revolving Loan Program in
Texas (US DOE, Revolving Loan Funds, n.d.) If defaults remain low, this process of handling capital can
be used many times over to fund projects.
A COG could administer revolving loan funds. COGs can structure revolving loan funds within
their own organization, drawing upon a designated pool of internal funds to finance projects by lending to
their own organization and then being paid back into that pool with some of the savings that are realized
from energy savings. By contrast, as described above for state and local governments, mission-minded
COGs can create revolving loan funds to serve outside organizations with loans to fit energy efficiency
and decarbonization projects. These loans often offer lower interest rates than do other private sector
lenders. An example is the Clean Water State Revolving Fund, which is a US EPA federal-state
collaboration that assists communities in borrowing funds for water quality infrastructure projects
(Climate X Change Webinar, 11-20-20). Since the Clean Water program gives special attention to
underserved areas and the socially vulnerable, it is possible that SOPEC could convene stakeholders to
borrow from this fund for Appalachian projects. While a COG could not borrow from such a fund, it
could administer a program for other organizations.
Another example of how COGs could get involved with revolving loan funds is the City of
Pittsburgh’s Green Initiatives Trust Fund (GITF). This is a revolving loan fund that pays for energy
efficiency and other conservation efforts such as energy aggregation, installing LED lights on city streets,
and retrofitting the city building. GITF funds are leveraged with other funding sources. The energy
savings are measured and quantified and the money is placed back in the GITF (US DOE, Pittsburgh,
n.d.). While SOPEC’s structure as a COG rather than a municipality (like Pittsburgh) would not permit it
to levy for funds for a GITF-type fund, SOPEC could convene its member jurisdictions and other

43
stakeholders to establish a similar fund. SOPEC could then serve as a program administrator to use the
RLF for green infrastructure projects such as green roofs and walls. Energy savings could then be placed
back in the RLF.
The Northeast Ohio Public Energy Council (NOPEC) Savings Through Efficiency Program
(STEP) is another energy-related example. NOPEC offers loans to help commercial property owners to
complete renewable energy or efficiency projects. It is a below market loan which accommodates smaller
projects in a NOPEC community that PACE financing will not consider. Types of projects financed
include lighting, HVAC, windows, doors, roofing, insulation, geothermal, solar panels, and water heaters.
The project range is from $5,000 to $100,000 for up to a 10-year loan at a 3% fixed interest rate. One
example of a NOPEC STEP project is Terrace House, which borrowed from the STEP program to finance
a new boiler and LED lighting. Terrace House is saving $4,535 a year (NOPEC, n.d.).
The Mark Twain Regional Council of Governments in Missouri serves elected officials in eight
counties. The COG fills the role of a planning commission and also provides other professional services.
One of its major services is to assist localities in applying for grants. The COG also administers the Mark
Twain Revolving Loan Fund, which provides interim loans to new or expanding businesses to finance the
gap between base loans and maximum durable loans. The interest rates are below market level and
external to businesses receiving the loans. Specific services include processing applications, working
with the RLF board, attracting private capital, servicing loans, monitoring the loan fund projects, and
providing information to the US Economic Development Administration. A COG like SOPEC could
serve in a similar role and could move beyond a purely economic development mission to include green
infrastructure projects such as green roofs and walls (Mark Twain COG, n.d.).
Grants and Program-Related Investments

44
Foundations and various levels of governments have the authority and resources to award grants
which do not need to be repaid, grants subject to repayment at interest rates even lower than typical below
market loans, and program-related investments (PRIs) to fund energy efficiency and decarbonization
projects in organizations that prioritize sustainability work. The PRI model has advanced in recent years.
The grantor issues a loan with an interest rate that is far below market rate. The grantor then is able to
report the PRI as a charitable donation for tax purposes. However, I was not able to locate any COGs
which are currently using PRI. There is a vast network of such grant-issuing organizations across the US,
which have diverging markets and goals (US DOE Better Buildings Finance Navigator, n.d.). An example
of this is an unnamed city which leveraged its use of a federal Energy Efficiency and Conservation Block
Grant funding to partner with multiple cities under a regional COG umbrella. The COG assisted the city
by convening stakeholders in establishing a regional PACE lending program (US Mayors, 06-02-2017).
Another example is the Southeast Michigan Council of Governments receiving state of Michigan grants,
which is discussed above. Other examples are the Fresh Coast Guardians Resource Center and the Green
Infrastructure Partnership Program in Wisconsin (Fresh Coast Guardians, n.d.).
CONCLUSIONS
Nationally, green roofs and green walls are not the primary technologies employed for energy
efficiency or carbon sequestration, but they are part of the mix and have potential for growth. The
literature clearly shows that green roofs are valuable over their life-cycle for an array of benefits ranging
from energy savings, stormwater management, urban heat island mitigation, and carbon sequestration. As
COGs act in convener, fiscal intermediary or program administration roles, they could employ green roofs
and green walls as technologies to achieve energy use reduction or decarbonization goals. For example,
health care systems are installing green roofs and green walls and are candidates to collaborate with
COGs on projects.

45
However, financing for COG-led projects is a concern. Regional organizations like COGs are not
authorized to directly generate funds through taxes or bonds. Neither do they serve as capital firms that
provide private funding for green infrastructure projects. However, COGs can serve as fiscal agents to
oversee funding from other entities such as state transportation agencies or other agencies and can work
on the financial side of green infrastructure projects in that capacity. COGs also have the opportunity to
pursue funding for green roofs and green walls through U.S. DOE WAP/WIP weatherization
programming and several grants. The U.S. EPA states that green roofs can be covered by this WAP/WIP
program. Other green infrastructure-oriented state and federal grants are available to COGs, as
exemplified by the grants received by the Southeast Michigan Councils of Government described above.
In addition, many foundations offer grants for sustainability projects, including the Fresh Coast Guardian
program.
While there are additional options, the most likely role for COGs in facilitating green
infrastructure is that of facilitator or intermediary, rather than the organization funding or installing a
green roof directly. The main roles of COGs nationally are regional planning, technical assistance, and
partnering with transportation agencies, but – as shown through the examples in the previous section –
they do also serve as conveners for green infrastructure and similar projects. Due to their connection to
the needs, resources, and organizations of their focal region, COGs are well placed to do this. This study
shows that the type of organization that serves as a convener of stakeholders for green infrastructure
projects varies by project and location. There is no standard operating procedure within states or
nationally. This gives COGs some flexibility in how and with whom they play this role. COGs could
partner with watershed organizations such as the above-referenced Anacostia Watershed on green
infrastructure projects and – if operating in an area where equity is a concern – could have the opportunity
to promote the adoption of environmental justice policies in their green infrastructure efforts. Connecting
with green infrastructure efforts could also facilitate funding.

46
COGs can also serve as program administrators for various green infrastructure efforts in order to
lift that burden from other jurisdictions, such as municipalities. A COG could, for example, serve as a
program administrator for Commercial PACE. There is a national trend toward third-party administrators
in PACE. In Ohio, Bricker and Eckler Attorneys, which is not a COG, is currently the main PACE
program administrator, but there is potential for expansion. However, in Ohio, energy special
improvement districts (ESIDs) are required in order to finance a local PACE project. While the number
of such districts has grown by over 30 in the last two years, it requires time to move through that process.
Another challenge, particularly in southeastern Ohio, is finding a large enough project to qualify for
funding from capital firms like the Columbus-Franklin County Finance Authority, which typically works
only with projects outside Franklin County that are larger than $2 million. One possible solution could be
to bundle several projects.
Lean and Green Michigan, the only PACE program administrator in centralized Michigan, is not
a COG, but can serve as model for how SOPEC could build PACE client relationships with local ESIDs
and other entities. Their green roof project at the Belt Line Center in Detroit was a major step forward for
green roofs because it was the first PACE-financed green roof in Michigan and involved Lean and Green
Michigan convening multiple providers and stakeholders. Another potential model is the Southwest
Regional Development Commission in Minnesota, which is structured similarly to a COG and could
provide insight into how SOPEC could function as a PACE program administrator.
I could not identify any COGs that serve as Energy as a Service providers, but it is theoretically
possible. The major barrier for COGs in this role is the technical expertise needed to procure, install and
maintain equipment, and the liability issues involved. A COG would need to be quite specialized to
succeed in this area.
Below market loans are also less common than PACE in my sample, but more common than
EaaS. SOPEC could assist a capital firm in obtaining US Treasury Department Community Development
Finance Institutions (CDFI) funding for a green infrastructure project, for example, due to the positive

How Councils of Governments Fund Green Infrastructure: Possible Applications for the Sustainable Ohio Public Energy Council

How Councils of Governments Fund Green Infrastructure: Possible Applications for the Sustainable Ohio Public Energy Council

Recommended

Recommended

More Related Content

Recently uploaded

Recently uploaded (20)

Featured

Featured (20)

How Councils of Governments Fund Green Infrastructure: Possible Applications for the Sustainable Ohio Public Energy Council