I don't know the regulation details, but what I do know is that there's a need to harmonize regulations in Quebec so that the PACE mechanism can be scaled up.
Quebec had a precursor to the PACE model, which was called Financement innovateur pour des municipalités efficaces, or FIME. In particular, Plessisville put that in place. It's well known that it works.
Now, to enable municipalities to lend money, there has to be a regulatory change to make it possible to scale up. I agree with that.
There's another barrier to implementing the PACE model. Once the municipalities have provided the grants or budgets for implementing the PACE model, there will be very few private investors there to support or simply continue the PACE-style programs. It's important to know that grants are limited. The model is effective as long as the grants are there, but afterward, how can municipalities go about demonstrating the effectiveness of the economic model to attract private investors? What can be done to allow a private investor to invest or to lend funds to the municipality? How can capital be pooled so that the municipality can lend money through property taxes to carry out energy retrofits on homes?