Comment Submitted by Davis Birr, Synchronous Energy Solutions

1.Streamlining a. 9 months is reasonable timeline b.Lack of knowledge and expertise in HUD and PHA staff is a a major obstacle c.HUD needs to allocate adequate resources to engage expert trainers and consultants to support the approval process d.provide continuity and quality in HUD staffing of the centralized approval office 2.Measurement &Verification a.Third party independent verification has very little value.The best solution is to have the ESCO develop and administer a high quality M&V plan and HUD/PHA review and approve it.The extra cost of third party M&V adds little value that can not be captured by the ESCO doing it correctly.HUD or the PHA should engage expert consultants at the M&V plan approval stage,which is much more cost effective.c.As an expert witness who has testified in several M&V contract disputes,the problems arise from improper contract formation and failures of parties to adhere to contract requirements.Third party M&V after the fact can not fix these problems. e.Most Professional Engineers know relatively little about M&V,and that is not a useful requirement.Utility cost savings calculation methods should be approved at the contract formation stage by HUD.HUD staff should be thoroughly trained on how these calculations are performed. 4.Barriers to EPCs a.Most PHAs,even large ones do not have the capacity to self perform an EPC.Aggregation of smaller authorities supported by consultants may help,but unless every PHA participating has an economically viable projects,it is not likely to be a success.The drop out rate is high.