Tennessee C-PACER: active local programs with materially different requirements

Research checked: October 28, 2026. Status: operating programs in identified localities, including Nashville/Davidson County and Memphis; not automatic statewide financing.

Background and launch chronology

Tennessee enacted the Commercial Property Assessed Clean Energy and Resilience Act through Public Chapter 138 of 2021, SB 795/HB 667, effective July 1, 2021. The framework is codified at Tennessee Code Annotated 68-205-101 and following. Public Chapter 868 of 2022 subsequently revised the framework; use current program/legal documents rather than treating the original 2021 bill as the last word. TN01, TN02

Nashville's sequence demonstrates why dates must remain distinct: a statement of intent and October 4, 2022 hearing preceded adoption. Ordinance BL2022-1633 passed its final Council reading January 17, 2023 and received mayoral approval January 23. The Metropolitan Trustee reports bringing the operating program to that office in 2023. This is local adoption/launch evidence, not a claim that every Tennessee county launched then. TN03, TN07

Who administers the programs?

Nashville/Davidson County: the Office of the Metropolitan Trustee is the designated program administrator. Its current program page supplies guidelines, application checklist, assessment agreement, lienholder/ground-lessor consents and completion certificates. Trustee Erica Gilmore's 2026 official newsletters confirm continuing transaction activity. Private capital providers fund projects; annual assessments are billed/collected with property taxes and remitted to the lender. TN03, TN04, TN06, TN07

Memphis: the Economic Development Growth Engine (EDGE) maintains the C-PACER program and guidebook. The owner requests a City of Memphis assessment, which repays private capital. EDGE explicitly distinguishes the tool from tax reduction, grants and other public funding. Its local requirements differ from Nashville's and must not be used as a statewide rule. TN08

These are verified operating examples, not a comprehensive current list of participating Tennessee jurisdictions. A third-party platform's statewide name or a municipality's hearing agenda alone is not proof of an active local program.

Eligible properties and improvements

Nashville's ordinance covers privately owned commercial, industrial, agricultural and five-plus-unit multifamily property, including eligible nonprofit ownership and certain government-owned/private-lease arrangements. Its financing framework includes efficiency, renewables, water conservation and resilience. TN03

The currently linked Nashville guidelines include lead reduction in drinking water and resilience categories such as flood mitigation, stormwater management, wind resistance, energy storage and microgrids. Existing-building resilience projects require professional certification of improvement; new construction requires certification of performance beyond applicable county building-code requirements in the relevant category. An HVAC/ventilation project needs a documented qualifying scope, not merely a claim that newer equipment is greener. TN05

Consent, lien, repayment and project process

Nashville's application package separates technical certificates, financial documentation and lienholder approvals. Nashville's ordinance requires the capital provider to receive written consent from every mortgage or deed-of-trust holder before entering into the Financing Agreement. The currently linked guidelines separately require mortgage/deed-holder and applicable ground-lessor consent before the Assessment Agreement and describe holding county closing signatures in escrow until consent is obtained. Confirm the operative sequence with the Trustee and transaction counsel; do not assume consent can always wait until closing. The ordinance describes a recorded property lien that runs with the land, and financing repayment through annual assessment installments. Terms must respect improvement useful life. Sale, refinancing, prepayment and delinquency consequences should be explained from the actual signed documents, not through blanket claims that transfer is effortless or foreclosure impossible. TN03, TN04, TN05

A sensible sequence is: confirm active jurisdiction and eligible parcel; scope permanent improvements and obtain professional analysis; secure lender terms and all required consents before their applicable agreement triggers, including mortgage/deed-holder consent before the Financing Agreement; submit the local application; execute and record assessments; disburse under the financing agreement; obtain completion/installation verification; then service annual payments. A conditional application approval is not a funded project.

Known Nashville projects

Amounts are private financing, not grant awards. The examples do not establish a complete statewide portfolio or measured energy savings.

Local applicability and code verification

Memphis: EDGE's website describes improvements exceeding $1 million and local code, energy/water and resilience criteria. Its linked September 21, 2022 handbook describes a best-faith effort toward at least 25% MWBE participation on qualifying costs, not an unconditional quota on total development cost. The handbook uses both an at-least-$1-million improvement floor and qualifying-cost language exceeding $1 million: the exact $1 million boundary, applicable cost base and current implementation need administrator confirmation. These are Memphis-specific conditions, not Nashville or statewide thresholds. TN08, TND22

Nashville uses its own technical certification, economic-benefit and consent forms. BL2022-1634 passed its final reading on January 17, 2023 and received mayoral approval on January 23, approving forms substantially as Collective Exhibit A; that exhibit already contained the “PROPOSED” footer. The footer alone therefore does not establish non-adoption. This does not prove that every current live-linked template is byte-identical to the approved exhibit or that later material changes were authorized. Confirm the operative version and the ordinance's Council-resolution boundary for material changes with the administrator and counsel. TN04, TN05, TND26, TND27

For both localities, confirm current local building/energy codes, occupancy, permits and any floodplain, fire, stormwater or utility requirements independently. Resilience eligibility is not a building-code waiver. The exact address-specific flood/wind permit conditions and a comprehensive statewide local-ordinance map were not established in this review.

Prepare the local review before paying for a financing package

Start with a parcel-and-owner summary: the legal description or parcel identifier, the responsible locality, the record owner, proposed improvements and project stage. Mark costs and technical assumptions that are still unknown. A tenant's construction budget or a familiar business name is not a substitute for identifying the real-property interest and the parties who can authorize an assessment. Request the current application package before treating every construction cost as financeable. Nashville program materials, Memphis handbook

For Nashville/Davidson County, direct program-document questions to the Metropolitan Trustee. For Memphis, establish the actual City of Memphis parcel boundary before relying on EDGE's wider organizational name. MLGW's published C-PACER reference identifies commercial properties in the City of Memphis; an MLGW account, a Memphis postal address or a Shelby County parcel record does not by itself confirm financing coverage. For another locality, obtain its own adoption and administrator evidence. Nashville program, MLGW locality reference

Keep three decisions separate in the same evidence file: the administrator's program and document review; the capital provider's proposed financing terms; and the responsible authorities' technical, permit and occupancy decisions. Ask who prepares, signs and checks each item, and what remains outstanding before the next agreement or installation. An engineering or financing indication does not replace construction approval. The consent triggers and operative-form limitations described in this guide still apply. Prepare the separate requirement checks.

Nashville: turn an unknown cooling problem into an evidence worksheet

An owner can start with high cooling costs without knowing the replacement technology or budget. Nashville's linked A-7 certificate asks about the technical professional, information reviewed, proposed improvements and estimated useful lives; it distinguishes existing buildings from new construction. Use those fields to prepare questions, not to certify your own eligibility. The worksheet below is VERADUCT's original preparation framework, not an official application or a new program requirement. Nashville A-7, PDF pages 1–3

A contractor quote describes price; it does not itself substantiate the technical outcome. For new construction, the linked certificate calls for a comparison with the relevant current county-code requirements. Ask the design professional and authority to establish the applicable baseline rather than assuming the form's upload year supplies it. A working download does not establish today's operative form: BL2022-1634 approves forms substantially as its exhibit, while section 3 reserves material party-obligation changes or new Metro obligations for Council resolution. Current-template identity and later changes remain unconfirmed here. A-7, page 2, Forms ordinance, sections 1–3, Original exhibit, PDF pages 48–50

Memphis: check the transaction file and the completed work separately

Before comparing offers, request a written breakdown of money reaching construction versus fees or reserves, interest and installment timing, and conditions for each disbursement. These are owner-side due-diligence questions, not published prices or a promise that every offer has the same structure. Use the financing comparison guide alongside the separate requirements review.

The handbook still linked by EDGE is dated September 21, 2022. Its Attachment C identifies the owner, parcel, assessment principal and terms in a notice-of-lien template; Attachment H separately records application approval and financing closing, then asks the owner to certify completed work and intended operation. Those blank fields do not prove any actual transaction. Confirm current forms, signatures and the earliest binding consent requirement with EDGE and counsel; this review does not clear later amendments or make the handbook's dated fees, thresholds or calendar current. Memphis handbook, Attachment C, PDF pages 36–39; Attachment H, pages 49–50, EDGE's current guidebook link

Memphis project evidence: approval is not a closing

One Memphis Place, at 200–202 Jefferson Avenue, illustrates why a sponsor should keep amounts and milestones in separate fields. EDGE's exact database object—record 71261, project ED20240901C—lists a $1.7 million Loan Amount and a September 2024 approval-date field. The labeled loan field is approved-record evidence, not verified disbursement or an independently established vote date. Its narrative also contains a malformed loan figure; this guide uses the labeled field rather than silently repairing that text. EDGE One Memphis record

The annual report and database describe different cost scopes that remain unreconciled. The database closing-date field is empty in the reviewed capture; this means missing confirmation, not proof that the transaction never closed. Actual funding, exact closing, construction completion and measured operating savings are not established here. For a comparable project, request the relevant signed, recorded, disbursement and completion evidence instead of promoting an approval or forecast into a completed result. EDGE project record, EDGE FY 2024–2025 report, printed page 14

The MLGW locality reference, Nashville program page and labeled One Memphis database fields were rechecked on October 29, 2026. This is a scoped reference check, not a new whole-page legal or source census. The older source dates and transaction-specific limits remain visible in the references.

Gaps and next steps

Retrieve the latest consolidated state statute and any subsequent amendments before offering a legal opinion on lien priority or underwriting limits. Verify participating jurisdictions by adopted ordinance plus active administration, not agendas. Confirm Memphis's current qualifying-cost rules and exact $1 million boundary, and Nashville's operative forms, including reconciliation of the ordinance's pre-Financing Agreement consent trigger with the linked guide's Assessment Agreement and escrow provisions. Obtain recorded assessment and current construction status for each showcase project when dates matter. No financing application or outreach was made.

Continue your project research

Use the national C-PACE financing guide to compare the assessment-financing structure and its risks. Then use the state and local requirements guide to organize the parcel, authority and evidence checks that remain. This page does not accept applications or submit information to a provider.