What C-PACE can pay for: roofs, HVAC, envelope and resiliency

C-PACE does not finance a building. It finances a list of measures inside a building, and the list is written by state law and the programme that runs under it. An owner who asks “will C-PACE pay for my roof?” usually gets “it depends” — on the state, on what the new roof does, and on how the work is documented.

This guide goes measure by measure through what the programme documents we read on 7 October 2026 actually name. Every rule below is attributed to the programme that wrote it. A Texas rule is not a national rule, and a Washington resiliency category does not exist in a state whose law leaves it out. If C-PACE itself is new to you, start with our C-PACE overview.

The core categories

Across the documents we checked, the same families of work appear again and again.

Heating, cooling and controls. Colorado’s C-PACE Program Guide (version 5.6, January 2023) lists “heating, ventilating, or air conditioning and distribution system modifications or replacements,” automatic energy control systems, energy recovery systems, ground-source heat pumps, and combined heat and power. New Jersey’s Garden State C-PACE Program Guidelines, as posted by the New Jersey Economic Development Authority in January 2025, name energy-efficient heating, cooling and ventilation systems, “including, but not limited to, air and ground source heat pump systems,” and energy or water controls.

Envelope. Colorado lists insulation “in walls, roofs, floors, and foundations,” window and door upgrades, air sealing, and daylighting systems. New Jersey lists air sealing, insulation, and “energy efficient windows, doors, and glass.”

Lighting. Both name it: Colorado covers replacing or modifying lighting fixtures and controls, and New Jersey covers efficient lighting equipment and controls.

Water. New Jersey has a separate category for improvements that “reduce water consumption, increase the efficiency of water use, or reduce water loss.” Colorado folds water conservation fixtures into measures the district approves as utility cost-savings. The CRE Finance Council’s C-PACE Primer (January 2025) is careful here: water conservation is “eligible in some states.”

Renewables and storage. Colorado’s guide covers renewable energy on the customer side of the meter — “photovoltaic, solar thermal, small wind, low-impact hydroelectric, biomass, or fuel cells” — and requires a renewable energy feasibility study. New Jersey adds energy storage and microgrids, with a condition: storage must store energy from a renewable system or EV charging unless the Authority finds a “critical resilience need unique to a facility.”

Other building systems. Colorado lists elevator modernisation, EV charging equipment and green roofs. PACE Equity, a capital provider, lists on its own site elevator/escalator, indoor air quality, EV charging and “Seismic & resiliency” among the measures it finances.

On the Texas side, Lone Star PACE’s eligibility page names HVAC systems, roofing, windows, insulation, lighting, low-flow plumbing, solar panels and automation controls — with one condition that matters more than the list, below.

The condition behind the list: a performance test

A measure on the list still has to clear a performance bar. Lone Star PACE’s eligibility page, checked on 7 October 2026, says project improvements “must exceed code by five percent.” That is Lone Star PACE’s stated rule, not a national one.

New Jersey sets its bar at the code itself. Its guidelines say a retrofit that includes an energy efficiency improvement is “not eligible for Direct Financing funded with a C-PACE Assessment” if “the applicable State energy subcode minimum is not met or exceeded,” and the technical evaluation must show it — either by whole-building modelling or by a prescriptive list backed by a COMcheck form or equipment data sheets.

Colorado’s test is savings. Its guide says improvements must be “reasonably expected to save energy or water or generate renewable energy,” and the district prefers projects whose savings-to-investment ratio is greater than one.

So the honest question is not “is HVAC on the list?” It is “does this HVAC pass the test my programme applies — code, code-plus or savings?”

Roofs specifically

Lone Star PACE, PACE Equity and the CREFC primer all name roofing. Colorado’s list names insulation in roofs and green roofs rather than roofing as such, and New Jersey’s names insulation without singling out roofs.

The Philadelphia Energy Authority’s C-PACE Program FAQs (April 2020) set out a specific rule. A roof replacement is eligible in Philadelphia “so long as the replacements improve both the roof (membrane, coating, sealing, etc.) and the system below (insulation).” For new construction, “the eligible roof work must exceed the baseline code requirements.” For a retrofit, “an eligible roof replacement must result in a more efficient roof system than what is being replaced.”

Colorado’s guide draws the same line from the other side. It lists “a like-for-like roof upgrade associated with the installation of a roof-mounted solar photovoltaic array” as an ineligible measure — but adds that “if the roof upgrade results in energy savings such as through improved insulation, the roof upgrade would be considered an eligible measure.”

The practical reading: a programme wants to see a roof that performs better than the one it replaces, usually because of insulation. In Colorado, a like-for-like roof done for a solar array is not eligible on its own, though the guide lists it among ineligible measures that may be included in the financing within the 30 percent cap described below.

Resiliency: real, and strictly state by state

Resiliency is where the list varies most from state to state.

King County, Washington’s C-PACER Program Guidebook (November 2021) defines a resilience improvement to include “seismic retrofits, flood mitigation, stormwater management, fire detection and suppression, wildfire and wind resistance, energy storage, and microgrids.” New Jersey’s guidelines include stormwater management systems, flood-resistant construction — “the installation of break-away walls and building elevation alterations” — and hurricane-resistant construction to the state code’s wind-borne debris standard.

New Jersey also sets out what a resiliency project’s technical evaluation must contain: a narrative identifying the hazard and the site’s vulnerability; technical documentation such as engineering calculations or an insurer’s quote showing lower or avoided insurance costs; and documentation of savings, which may take the form of avoided business interruption.

The Environmental and Energy Study Institute described several states’ laws in an article dated 18 June 2020. As of that date it reported that Florida’s PACE law (2010) covered wind resistance improvements such as “storm shutters and wind-resistant shingles,” Alabama’s (2015) covered flood mitigation and wind resistance, California, Utah and Oregon covered earthquake-related upgrades, and Virginia (2019) covered “flooding and stormwater management.” Laws have changed since 2020, so treat that list as history and confirm your state’s current rule with its programme.

The CREFC primer (January 2025) gives the same broad shape: seismic strengthening in California, Oregon, Washington and Utah, wind resiliency in Florida, and stormwater and flood management “in much of the mid-Atlantic.”

Soft costs and project costs

Hard costs are not the whole budget, and the programme documents we read say so.

New Jersey’s guidelines define project costs to include direct costs (equipment, materials, labour), indirect costs — “expenses and fees of engineers, architects, financial advisors, legal counsel, and other professionals, inspection fees and permits, and warranties and pre-paid maintenance contracts” — the capital provider’s financing costs, and programme fees.

Colorado’s guide lets project-related expenses be capitalised “subject to acceptance by the qualified capital provider”: energy and water audits, feasibility studies, engineering and design, commissioning, prepaid operation and maintenance for up to five years, extended warranties covering the full finance term, capital provider or developer fees and required prepaid interest, programme, permit and closing fees.

Use our C-PACE calculator to see what the eligible share of your budget might be worth.

What usually does not qualify

Colorado’s guide gives an explicit list. It “cannot finance projects that include”:

• measures that do not result in utility cost savings;
• measures not permanently attached that “can be easily removed”;
• anything not commercially available;
• health and safety work not tied to the energy improvement;
• general construction costs.

Colorado then allows some ineligible measures inside the financing if they stay within 30 percent of total project cost — its examples include asbestos abatement tied to a boiler retrofit, new pads for a chiller, and electrical upgrades for a new solar system. Shading devices and window coverings are on its ineligible-measure examples list.

Two more limits come from the ownership side. PACE Equity says C-PACE is “not available for government or municipally owned buildings” — yet Colorado’s guide says buildings owned by state and local government agencies are eligible there. That is the whole point of this guide: check the programme, not the generalisation. And New Jersey’s main guidelines say that, unless its supplemental guidelines provide otherwise, they do not apply to refinancing, new construction or gut rehab.

When most of the budget is ineligible, C-PACE may simply be the wrong tool. We would rather tell you that up front.

How to check your own state’s list

1. Find your programme. Our state-by-state C-PACE tracker shows which states have one.
2. Read the eligible-measures section of its current guide. Note its date; lists change.
3. Look for the performance test — code-plus, savings-to-investment, or an engineer’s certification — and budget for the audit that proves it.
4. Separate eligible from ineligible line items before you talk to a capital provider.

If you would like a second pair of eyes on which parts of your scope a programme is likely to accept, talk to us. C-PACE Desk is an advisory and placement service, not a lender or a programme administrator.