C‑PACE + PPA Stack: Off‑Balance‑Sheet Solar Without CapEx — Legal & Accounting Treatment

How to structure a Property Assessed Clean Energy (C‑PACE) improvement alongside a Solar PPA so you reduce utility spend without recognizing solar assets on your balance sheet.

Updated: September 12, 2025

Thesis: separate the equipment from the energy

Pairing a Solar PPA with C‑PACE lets owners pay for energy as a service while financing building‑side upgrades (roof, switchgear, insulation, reroof coordination) through a property assessment. The PPA keeps solar assets off your balance sheet; C‑PACE improves building cash flow and NOI with long‑tenor, non‑recourse‑like repayment through the tax bill. Done right, you get lower $/kWh and stronger coverage ratios without CapEx.

8–20¢/kWh
Typical commercial blended utility cost range (Texas, 2024–2025)
3–7 $/kW
Typical monthly demand charges per kW (TX large C&I)
7–10 W/ft²
Practical rooftop DC density on low‑slope roofs
120–240 days
Common interconnection timeline band (design → PTO)

2. How to Structure a C‑PACE + PPA Stack (Step‑by‑Step)

  1. Separate scopes: PPA covers solar generation; C‑PACE covers building improvements (roof, switchgear, structural, insulation). Avoid cross‑collateralization.
  2. Lender consent: Obtain mortgagee consent for the C‑PACE assessment; align SNDA so PPA survives transfer or foreclosure.
  3. Service language: Draft PPA to emphasize energy delivery, not equipment rental, to avoid embedded lease classification.
  4. Transfer provisions: Ensure PPA is assignable to a buyer/tenant and that the C‑PACE assessment automatically runs with the land.
  5. Insurance & O&M: Keep O&M with PPA owner; building owner maintains roof warranty—get roofer letters.

3. Decision Checklist for CFOs & General Counsel

Accounting & Legal

  • Confirm PPA is service under ASC 842 (no identified asset/control indicators).
  • Document C‑PACE as a property assessment; align with lender consent.
  • Set transfer & SNDA language so both instruments survive a sale.

Finance & Risk

  • Run coverage ratios using measured interval data (energy savings vs. assessment + PPA).
  • Stress test: demand charges, interconnection delays, production variance.
  • Coordinate reroof timing and roof‑warranty letters.

4. Where to go deeper

5. FAQ: C‑PACE + PPA for Off‑Balance‑Sheet Solar

Q: Will a PPA appear as a lease under ASC 842?
A: If drafted and operated as a service (no identified asset, no control over use, output‑based payments), many auditors treat it outside lease accounting. Always confirm with your auditor.
Q: Does C‑PACE increase my debt ratios?
A: C‑PACE is a property assessment, not a traditional loan. Lenders evaluate it differently; expect consent and underwriting, but treatment may be more favorable than senior debt.
Q: Can I sell or refinance with C‑PACE + PPA in place?
A: Yes—ensure PPA transfer language and SNDA are in your documents; C‑PACE typically runs with the land.

What should a building owner do next?

1) Share interval data and roof details. 2) We design the PPA as a service and map eligible C‑PACE scope. 3) We coordinate lender consent and transfer language. 4) You lock an energy rate without CapEx.

We’ll deliver a redlined term sheet (PPA + C‑PACE) and a coverage ratio model your board and lender can underwrite.

*This article is informational and not legal, tax, or accounting advice. Consult your counsel and auditor. We’ll supply primary‑source citations (ASC 842, state statute, utility manuals) in your custom package.