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Dear Commissioners,

I was part of a group years ago that did a deep dive on PACE and advocated for its adoption.

However, PACE was designed for commercial--- not residential benefits, and was, at the time, I thought illegal for residential. I was surprised at its adoption here including residential.
There is too much opportunity for predatory practices especially regarding elderly and low income homeowners, and, now with the high standard deduction on taxes, even many people who could afford the increase on their tax bill, have no benefit anymore

The proposed changes to determine ability for residential to afford this are insufficient I think

Restrict residential contracts to only residential owners who can still do itemized deductions. They are not at risk from a higher tax bill, and can still make use of the tax deduction.

Commercial is great — that is what PACE was designed to benefit

For residential owners who do not itemize their taxes, look instead, and strengthen,   other programs to help with weatherization and major repairs and upgrades such as CWC, ReBuild and other non profits, GRU’s LEAP programs, CDFI programs etc.,, that can strengthen our local economy, be more affordable to low income and middle income homeowners and build our local resilience.

Thank you
Nancy Deren

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