The Center for Law, Energy & the Environment at Berkeley Law prepared our own comments in response to the proposed rule. In our comments, we urge FHFA to follow the requirements of the Administrative Procedure Act (APA) in setting its rinal rule, and to carefully consider the existing evidence of economic, environmental, and community benefits from PACE programs. We conclude that the most legally defensible decision would be to adopt the third risk-mitigation as the Agency’s final rule: allow the Enterprises to consent to first-lien PACE obligations that satisfy the key underwriting standards set forth in H.R. 2599, the PACE Assessment Protection Act of 2011. Read full story.