Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022

October 2022

EFAB Charge
Greenhouse Gas Reduction Fund

Problem / Question Statement

The Inflation Reduction Act of 2022 amended the Clean Air Act to create a new program - the
Greenhouse Gas Reduction Fund. The Greenhouse Gas Reduction Fund includes: (1) $7 billion for
competitive grants to enable low-income and disadvantaged communities to deploy or benefit from
zero-emission technologies, including distributed technologies on residential rooftops, and to carry out
other greenhouse gas emission reduction activities; (2) nearly $12 billion dollars for competitive grants
to eligible entities to provide direct and indirect financial and technical assistance to projects that
reduce or avoid greenhouse gas emissions; and (3) $8 billion for competitive grants to eligible entities to
provide direct and indirect financial and technical assistance to projects that reduce or avoid
greenhouse gas emissions in low-income and disadvantaged communities. These $27 billion dollars are
available to EPA to award grants until September 30, 2024.

EPA seeks the advice of the EFAB regarding the following questions. For each charge question, the EFAB
should provide a range of options (including research and literature references and other resources,
where available), outlining their advantages and disadvantages.

I. Objectives

A.	Environmental Justice/Definition of "low income and disadvantaged communities"

1.	What considerations should EPA take into account in defining "low-income" and/or
"disadvantaged" communities in order to ensure fair access/that the funding benefits
disadvantaged communities?

2.	How can EPA ensure that communities and organizations who have received little or no
funds in the past receive priority consideration for funding? How could EPA identify the
low-income and disadvantaged communities it should prioritize for greenhouse gas and
other air pollution reduction investments?

3.	What kinds of technical and/or financial assistance should the Greenhouse Gas
Reduction Fund provide to ensure that low-income and disadvantaged communities are
able to be direct or indirect beneficiaries of Greenhouse Gas Reduction Fund funding?
Please identify supports that could help communities with project implementation.

B.	Program Efficiency

1.	How can the Greenhouse Gas Reduction Fund grant competition be designed so that
funding is highly leveraged (i.e., each dollar of federal funding mobilizes multiple dollars
of private funding)? How can the funding be used to maximize "additionally" (i.e. the
extent to which funding catalyzes new projects that would not otherwise occur)? How
can EPA balance the need for grants for capacity-building and short-term results with
financial structures that will allow that capital to be recycled over time? Where (if at all)
it is appropriate to impose sustainability requirements on direct or indirect beneficiaries
of Greenhouse Gas Reduction Fund funding?

2.	Are there programs/structures at the federal or state level that could effectively
complement the Greenhouse Gas Reduction Fund? How can EPA best the leverage
Greenhouse Gas Reduction Fund to support lasting, long-term (beyond 2024)

Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022


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Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022

October 2022

transformation of the clean energy and climate finance ecosystem, especially for
disadvantaged communities, and greenhouse gas and other air pollution reductions?

II.	Program Structure

A.	Eligible recipients.

1.	Who could be eligible entities and/or indirect recipients under the Greenhouse Gas
Reduction Fund? What should be the thresholds for deployment—both amount and
timing—for Greenhouse Gas Reduction Fund funding by these entities? Please provide
references regarding the total capital deployed by these entities into clean energy and
climate projects.

2.	What eligible entities and/or indirect recipients would best enable funds to reach
disadvantaged communities? What are their challenges and opportunities and how can
EPA maximize the use of these channels?

B.	Eligible projects.

1.	What types of projects/sectors/market segments could EPA prioritize for funding
through the eligible recipients?

2.	Considering each major project type/sector/market segment, discuss:

i.	What are the barriers to private sector capital?

ii.	Please provide any citations to relevant case studies in low-income and
disadvantaged communities, in terms of emissions reductions and other
benefits, including cost-effectiveness, wealth creation, economic
empowerment, workforce development, etc.

iii.	What project-level gaps could the Greenhouse Gas Reduction Fund fill for which
types of projects? What form could capital take to fill these gaps? Please
provide references that analyze the deal-level economics for the various types
of projects, including whether and how these may vary by geography.

iv.	Beyond assembling the capital stack for a deal, what other barriers and
constraints exist that could constrict the pipeline of successful projects? What
program strategies are needed to respond to these barriers and constraints?

3.	What types of contracting vehicles and structures will best support rapid deployment of
clean technology solutions and direct involvement of the private sector, including in
supporting disadvantaged communities?

C.	Structure of Funding. Are there any potential program design requirements that would impact
the ability of recipients to use the Greenhouse Gas Reduction Fund program funds? How could
EPA address these issues through program design? How could recipients comply with relevant
federal requirements? How can the EPA streamline the distribution of funds so that applicable
federal and state review can be accomplished in a coordinated and efficient manner?

III.	Execution, Reporting and Accountability

A.	Given the tight timeline for implementation of the funds, what are key steps that EPA could take
in the short- (next 180 days), medium- (next two years before funds expire in 2024), and long-
term?

B.	What types of requirements could EPA establish to ensure the responsible implementation and
oversight of the funding?

Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022


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Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022

October 2022

C. What mechanisms could eligible recipients adopt, including governance as well as other

mechanisms, to ensure that their applications and subsequent implementation efforts ensure:
(i) accountability to low-income and disadvantaged communities; (ii) GHG emission reductions;
(iii) leverage and recycling of the grants?

EFAB Mission Fit

EFAB's mission is to explore ways to lower costs and increase investments in environmental protection.
The GHG has the potential to create valuable new capacity through existing and new channels for
funding greenhouse gas reductions, and to specifically deliver gains to disadvantaged communities
where GHG solutions are often compromised by high financing risks (capacity for repayment, access),
lack of clear delivery systems (ability to reach beneficiaries) and awareness of potential solutions. These
areas represent major segments of potential environmental harm and related benefits.

Type of EFAB Engagement

EFAB is positioned to assist EPA by providing focused guidance to EPA on strategies for establishing and
developing the GHGRF.

EFAB is comprised of experts across many segments of environmental finance and program delivery. EFAB
members have deep experience and broad networks that can be quickly leveraged to provide focused
advice to EPA around a critical and rapidly moving agenda. EFAB capacity can provide immediate, actionable
solutions that increase potential success around the GHG program.

Approach

Convene (fast) expert roundtables or listening sessions around topics that will inform implementation of
the GHGRF and summarize key takeaways and recommendations. Orchestrate specific conversations
that reach audiences not otherwise readily accessible to internal EPA staff. Take specific reference from
private equity and venture capital fund-of-fund models and philanthropic "venture fund" models that
have been successful over time in delivering capital to emerging fund managers.

Deliberative - Draft charge document for EFAB workgroup discussion

October 17, 2022


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