Local

Government

Advisory

Committee

Hon. Leirion Gaylor Baird, Chair

Lincoln, NE

Hon. Lucy Vinis, Vice-Chair Eugene, OR

Hon. Ras Baraka Newark, NJ

Hon. Luke Bronin Hartford, CT

Hon. Sharon Broome Baton Rouge, LA

Mr. Gary Brown Detroit, Ml

Hon. Jose C. Aponte Dalmau Carolina, PR

Hon. Kimberly duBuclet Cook County, IL

Ms. Miki Esposito, Los Angeles County, CA

Hon. Sarah Fox, Vancouver, WA

Hon. Jacob Frey, Minneapolis, MN

Hon. Katherine Gilmore Richardson

Philadelphia, PA

Hon. Nick Gradisar Pueblo, CO

Hon. Jonathan Grieder Waterloo, IA

Hon. Evan Hansen Morgantown, WV

Hon. Brenda Howerton, Durham, NC

Hon. Deana Holiday Ingraham East Point,

GA

Hon. Ella Jones Ferguson, MO
Hon. Heather Kimball Hawaii County, HI
Hon. Christine Lowery Cibola County, NM
Hon. Ann Mallek Albemarle County, VA
Hon. Rachel May Syracuse, NY
Hon. Christian Menefee Harris County, TX
Hon. Douglas Nicholls Yuma, AZ
Hon. Ron Nirenberg, San Antonio, TX
Hon. Neil O'Leary Waterbury, CT
Hon. David Painter Clermont County, OH
Hon. Mary Lou Pauly Issaquah, WA
Mr. Whitford Remer Tampa, FL
Hon. Satya Rhodes-Conway Madison, Wl
Mr. Michael T. Scuse State of Delaware
Mr. Jeff Witte State of New Mexico
Ms. Lisa Wong, South Hadley, MA

Contributing Small Communities Advisory
Subcommittee Members:

Mr. Tom Carroll Cambridge, MD
Mr. Dave Glatt State of North Dakota
Hon. Jeremy Stutsman Goshen, IN

Paige Lieberman, Designated Federal
Officer, EPA

Edlynzia Barnes, Designated Federal
Officer, EPA

January 13,2023

Michael S. Regan, Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, N.W.

Washington, DC, 20460

Dear Administrator Regan:

The Local Government Advisory Committee (LGAC) appreciates the
opportunity and is eager to provide input on how EPA will develop
and implement its programs under the Inflation Reduction Act
(IRA)'s Climate Pollution Reduction Grants and Heavy-Duty Vehicle
Program.

As highlighted in our recommendations from December 2022, no
one knows the needs, challenges, and opportunities of a
community to catalyze action better than local governments. For
that reason, the LGAC recommends above all that EPA provide
funding directly to local and tribal governments. Where that is not
possible, the LGAC recommends that EPA require grant recipients
to partner with relevant jurisdictions when identifying, designing,
and implementing projects in their communities.

The LGAC recommends that EPA prioritize funding projects under
the Climate Pollution Reduction Grants that:

•	contribute to emissions reduction in the transportation sector,
particularly those that encourage mode shift or that have
health co-benefits for disadvantaged communities

•	support decarbonization of buildings, particularly new and
existing income-qualified housing projects

•	create green infrastructure and other natural climate
solutions, including expansion/restoration of urban tree
canopy

•	support the development and adoption of lower-emission and
zero-emission on-farm machinery and equipment

•	re-orient existing projects toward GHG reduction

•	prioritize specific projects or actions for implementation, as
well as specific goals and metrics, to promote action-oriented
funding

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Regarding technical assistance, the LGAC recommends that EPA:

•	use existing or new technical assistance centers to deploy support services to local governments
and community groups, with the goal of helping communities identify their overarching climate
goals, identifying the various components of realizing that program, and the funding streams to
support it

•	create planning templates and other resources to support communities in quickly creating
prioritized, actionable plans with useable metrics (e.g. calculators, case studies, and templates
that highlight how GHG reduction and other co-benefits can be achieved in common municipal
projects)

•	invest early in hiring staff to manage and coordinate program activities, targeting full program
staff by July 2023

•	develop communication strategies, tools, and templates for communities to use, and have EPA
staff available to answer questions and tailor strategies to specific locations.

•	provide better and more streamlined access to available resources, noting that EPA has the
expertise, but local governments don't know how to access it effectively

Regarding multi-government coordination the LGAC recommends that EPA:

•	fund local governments directly wherever possible, and require any states receiving funding to
demonstrate how local and tribal governments within their jurisdiction have been engaged in the
planning of the projects, and how they will be integrated into the implementation

•	create an Interagency Office with US DOT, US DOE, US HUD, US Commerce (EDA) with the goals of
coordinating on cross-cutting issues and developing an intuitive way for local governments to
stack funding for a specific goal

•	view any state planning grants as an opportunity to create alignment and coordination across
state agencies and with units of local governments, tribes, community groups, and private
business to increase the efficacy of the implementation grants, as well as other funding available
via the IIJA/BIL and IRA

For the Heavy-Duty Vehicle program, the biggest contribution the federal government could make
towards transitioning fleets to clean vehicles would be to rapidly and comprehensively transition its own
fleet. This would send a clear signal to the market, backed by federal purchasing power, that could help
move manufacturers, spur innovation, and bring prices down.

Another seismic opportunity would be to develop a single, simple application that covers all programs
related to transitioning away from heavy-duty vehicles. This would allow applicants to focus on the big
picture goals, rather than spending limited resources and staff time completing applications.

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Additionally, the LGAC recommends that EPA:

•	prioritize replacing vehicles that are used more within a community (thus generating more
emissions) over those that are less frequently used, and vehicles that are more often used in
low-income communities

•	design this program to account for asset management cycles and provide a long time frame for
expending grant funds so that communities on long replacement cycles can still benefit.

•	identify financing options for communities that are unable to budget for the base cost of the
vehicle

•	dedicate staff and other resources to encourage state utility regulators and utilities to adopt
rate structures that support EV charging

The LGAC looks forward to working with EPA more as the IRA programs are implemented.

Mayor Leirion Gaylor Baird, LGAC Chair	Mayor Satya Rhodes-Conway,

LGAC Air & Climate Workgroup Chair

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Climate Pollution Reduction Grants

1. What are the most promising greenhouse gas (GHG) planning and reduction opportunities that
could be catalyzed by the Climate Pollution Reduction grants, taking into consideration:

a.	Total potential for GHG reductions and other co-benefits;

b.	Gaps in existing resources, programs, or policies;

c.	Availability of other government funding streams?

There are many factors that determine the effectiveness of a GHG emission reduction opportunity,
including geography, local economy, and prior action taken by relevant units of government. In rural
areas, there is a need to decarbonize the agricultural industry and develop best management practices
for soil health. In urban areas, the biggest sources of emissions are buildings and transportation. In
suburban areas, there is a need for more efficient land use, including transit-oriented development. In
general, an honest accounting of local emissions sources is needed to assess opportunities to reduce
GHG emissions, particularly those that will provide co-benefits and support disadvantaged communities.

From a national perspective, the building and transportation sectors are responsible for the most
emissions. While decarbonizing the transportation sector poses challenges, the path is more
straightforward. Vehicles must transition to low or no emission fuels, via electrification or alternative
fuels. Infrastructure to deliver those fuels must be built. The light and heavy-duty vehicle industries
must transition to sell and maintain these vehicles. Older vehicles must be removed from service and
recycled, rather than being passed on to lower income households and communities. Transportation
modes must shift away from single occupancy vehicles. Much of this work is being undertaken by other
federal agencies (notably the U.S. Department of Transportation), but EPA can have a role in setting
standards and incentivizing the shift away from single-occupancy vehicles, as well as the transition of
light and heavy-duty vehicles to low or no emissions fuels (see below). The LGAC recommends projects
that contribute to emissions reduction in the transportation sector, particularly those that encourage
mode shift or that have health co-benefits for disadvantaged communities, be eligible for the Climate
Pollution Reduction Grants.

Decarbonizing Buildings

Where local governments need the most support - especially in urban and suburban areas - is
decarbonizing the building sector. The U.S. will need to add an estimated 20 million new homes in the
next decade. This problem is outside the authority of EPA, but there are actions that EPA can take to
ensure that the solution supports climate change mitigation and resilience. Research from the think tank
RMI estimates that if those homes were built as infill, in proximity to public transportation and other
infrastructure promoting sustainability, the nation could lower its carbon dioxide emissions by 200
million tons per year by 2030. That's roughly the equivalent of taking 43 million cars off the road (Subin,
2021). This issue is two-fold: there are the carbon emissions of the building itself, which includes its
construction and daily energy use, and there are the carbon emissions from the human activities
associated with using the building, such as travelling to and from the building. The LGAC recommends
that EPA use the Climate Pollution Reduction Grants to support decarbonization of new and existing
income-qualified housing projects, with an emphasis on using sustainable building standards and
supporting denser, transit-oriented development. Supporting decarbonization of government and
commercial buildings is also critical for reducing emissions from the building sector. Most affordable
housing projects include some form of HUD funding in the capital mix. Federally built or funded

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buildings should lead the way by being the most sustainable, low-emissions buildings in any community,
so the LGAC recommends that EPA collaborate with HUD to ensure that the buildings they fund are
constructed to the highest sustainability standards possible.

Another area for EPA to target the decarbonization of buildings is through building codes. States and
municipalities typically set codes based on models developed by private sector organizations (e.g. the
International Code Council), who use consensus-based processes to engage experts from a range of
fields. Some states and municipalities have used building code updates to drive energy efficiency in
residential and commercial buildings. Where this has not occurred, one of the barriers is state laws
limiting the authority of municipalities to set their own codes. The LGAC recommends that EPA leverage
Climate Pollution Reduction Grants and other resources to encourage states and municipalities to
adopt the most recent building codes, by requiring or giving preference to statewide planning grants
that include a section on "code modernization"

The LGAC learned about EPA's involvement with Voluntary Consensus Standards on green building,
transportation, energy and more. The LGAC recommends that EPA dedicate more EPA staff to this
work to ensure that consensus-based standards and model codes support the Agency's climate goals.
This is especially important as GSA implements its section of the IRA on upgrading and/or building new
facilities with low embodied carbon construction materials (which are currently being defined by EPA)
and investing in emerging and sustainable technologies. Department of Transportation will also use this
definition as part of its work to incentivize sustainable building. A final approach would be to work with
municipal leagues to encourage local government staff with climate expertise to participate in
development of standards where possible and provide trainings for those interested in learning more.

As noted above, the location of buildings as well as land use patterns impacts the carbon footprint of
communities. Higher density, infill, transit-oriented development enables low to no-carbon
transportation, including active modes of transportation and transit use. The LGAC recommends that
EPA leverage funding to support dense, infill, transit-oriented development of sustainable, low to zero
carbon buildings, including funding and technical support for climate-smart land use planning.

Locating and designing buildings and critical infrastructure in ways that avoid and minimize climate hazards,
like flooding, wildfires, and heat waves, not only improves community resilience but also avoids or
reduces the climate pollution associated with disaster response and recovery, disposal of debris, and
rebuilding. Climate resilience co-benefits are critical and should be prioritized because climate hazards
are impacting underserved communities first and worst. The LGAC recommends EPA work with
communities to integrate climate resilience considerations into climate action planning and
implementation projects and prioritize projects for funding that reduce or avoid carbon emissions and
improve community resilience, such as managed retreat from areas vulnerable to flooding and sea
level rise, and buildings that provide community services, which are both especially important for
resilience in underserved communities.

Creating and expanding natural and green infrastructure, such as urban tree canopy and other urban
ecosystems, is another proven way to cool cities, sequester carbon, reduce flood risk, and reduce
emissions. For example, projects that expand urban tree canopy can significantly reduce the urban heat
island effect, which reduces the need for cooling in buildings, reduces strain on the electric grid, and
cuts emissions. These strategies are especially important in a changing climate where extreme weather
is becoming more frequent, more severe, and disproportionately impacting disadvantaged communities.

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The LGAC recommends that green infrastructure and other natural climate solutions, including
expansion/restoration of urban tree canopy, be eligible uses for the Climate Pollution Reduction
Grants.

Ultimately, the carbon footprint of buildings is tied to the source of energy they use. While
electrification of heating and cooling enables decarbonization, the source of electricity must be low or
no carbon. Setting aside the EPA's larger role in decarbonizing the energy sector, it is important not to
overlook the role of low or no carbon distributed energy generation in reducing building GHG emissions.
All too often, renewable energy generation (solar, small-scale wind, geothermal, etc.) is hampered by
utility company policy and state or local regulation. Planning for and investing in building and
community-scale distributed generation is essential step to reducing climate pollution. The LGAC
recommends that distributed renewable energy generation and community solar projects be eligible
uses for the Climate Pollution Reduction Grants.

Agricultural and Rural Locations

Finally, the LGAC wishes to note the opportunity to reduce GHG emissions through adapting agricultural
practices. EPA's own report in 2020 attributed 11.2 percent of U.S. emissions to agriculture, and a report
from McKinsey & Company1 predicts that agricultural emissions could be reduced 20 percent by 2050
through adopting a set of proven GHG-efficient farming technologies and practices. Climate-smart
agriculture will allow farmers and ranchers to increase productivity while strengthening their climate
resilience and minimizing climate impacts to meet food security needs.

The LGAC recommends that EPA work closely with USDA to leverage program funding, and with its
Farm, Rural and Ranch Advisory Committee, local and tribal governments, and municipal leagues such
as the National Association of Counties and the National Association of State Departments of
Agriculture, to support the development and adoption of lower-emission and zero-emission on-farm
machinery and equipment. Additionally, EPA should work with these entities to invest in research and
technologies that allow for the adoption of land use practices to increase the carbon stored in soil or
vegetation, and production practices that reduce methane emissions from managed livestock manure
and nitrous oxide emissions from cropped and grazed soils. There are notable technological innovations
taking place to make fossil fuels less carbon intensive, and in some cases, the most efficient path to
lowering emissions may include adopting these practices, coupled with geological sequestration. Where
GHG emissions can be achieved, the LGAC recommends allowing such projects as eligible costs under
IRA funding.

Several LGAC members also emphasize the need for any federal action to include an appreciation for the
unique paradigm that rural communities face. Where there is limited existing infrastructure for electrical
transmission and charging stations, there is a longer and more arduous timeline ahead for implementing
such technology. At the same time, the lack of such infrastructure means that improving air quality is

1 Agriculture and climate change: Reducing emissions through improved farming practices. McKinsey & Company.
2020.

https://www.mckinsey.com/~/media/mckinsey/industries/agriculture/our%20insights/reducing%20agriculture%2
0emissions%20through%20improved%20farming%20practices/agriculture-and-climate-change.pdf

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less of a concern in such locations and additional strategies may be as impactful as making a swift
transition away from fossil fuels.

2. How should the EPA integrate the needs of underserved communities into the design of this
program, taking into consideration:

a.	What equity and justice concerns, opportunities, or priorities are most relevant for this
program and how can EPA best help address them?

b.	How can EPA best address the statutory requirement to consider the "degree to which
greenhouse gas air pollution is projected to be reduced in total and with respect to low-
income and disadvantaged communities"?

There are three ways the LGAC believes that EPA should integrate the needs of underserved
communities into this grant program. First, include communities in the planning process for grant-
funded plans and projects. Second, ensure that the benefits and co-
benefits of funded projects accrue to underserved communities.

Third, ensure that underrepresented businesses and individuals can
compete for any contracted work on funded projects.

Eugene, Oregon has an effective model for including underserved
communities in the planning process. In 2019 they worked with the
Urban Sustainability Director's Network to recruit individuals from
sixteen community groups that demonstrated a commitment to
equity, social justice, and/or environmental justice. Each
organization was paid $3,000 for their participation - similar to
compensation for other consultants hired by the city - and were
offered free childcare during their meetings. Meetings were
facilitated by a consultant but driven by the panel members'
conversations, which focused on their lived experience. The
immediate benefit from the panel was to provide tangible input on
the City's Climate Action Plan. Over time, the panel also built
capacity in organizations represented, so that they better
understood how to engage with and get support from the City. The
City of Eugene has now integrated this approach into other parts of
its work. The LGAC recommends requiring such engagement efforts for any planning grants, allowing
stakeholder engagement expenses as eligible costs, and providing technical assistance to communities
who do not have prior experience authentically engaging underserved communities. Further, the
LGAC recommends giving preference to implementation grant applications that show tangible,
authentic engagement with underserved communities.

The second part of this issue is how to ensure that benefits accrue to underserved communities. One
available tool is to overlay socioeconomic data with GHG emission intensity maps. This could lead to
prioritization of air quality programs in legacy energy communities, the capping and capture of methane
from a landfill that is located near a disadvantaged community or prioritizing the electrification of low-
income housing units that are served by older gas appliances. LGAC recommends that EPA give
prioritization to applications that demonstrate they used not just GHG emission intensity maps, but

Recommended Actions from
Eugene Equity Panel

-	Provide public transportation
subsidies for people living with
disabilities

-	Provide multilingual education
about climate change in
community spaces

-	Provide incentives for climate
change education and adaptive
actions in workspaces (both public
& private sector)

-	Encourage affordable, multi-use,
ADA compliant, energy efficient
buildings near public
transportation

-	Use radio, media, and trained
community advocates to share
information about climate
change, emergency preparedness,
and adaptation

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also socioeconomic data, to identify projects. In turn, EPA must provide technical assistance to
develop and use this data.

A related example to consider is the Philadelphia Energy Authority, a multi-faceted program created in
2016 to create jobs, strengthen communities, cut energy
bills, and reduce Philadelphia's carbon footprint. The
program has multiple aims, detailed to the right. Beyond the
obvious climate benefits of this program, one of its greatest
successes is workforce development. By investing in these
projects, they have created demand for skilled labor and
then trained members of the community to fill more than
2,500 positions over ten years. This can and should be
replicated in other locations. In 2019, solar installer was the
fastest growing occupation in the country, and rooftop solar
creates the most jobs per dollar invested compared to other energy projects.

Finally, underrepresented individuals and businesses must be able to compete for and benefit financially
from these projects. EPA can support contract language that requires or gives preference to local
businesses and workforce. More detail is included below in the response to question 9.

Across many sectors, members of the LGAC have effectively supported workforce development through
procurement policies. For example, as Detroit invested in lead sewer line replacement, they put
language in the bid solicitations that gives preference to bidders who employ workers living in Detroit.
When the bid is awarded, that requirement is then written into the contract with the City. This kind of
policy ensures that the local community is not only receiving an infrastructure upgrade, but also
receiving the income from good-paying jobs. The LGAC recommends requiring or giving preference to
applications that adopt a similar approach to hiring local, especially from low-income or
disadvantaged communities. At the same time, EPA should provide language and technical assistance
for applicants seeking to pursue this.

3. This program consists of $250 million in planning grants, $4,607 billion in climate

implementation grants, and $142.5 million for administrative funding. How should EPA
implement and coordinate planning and implementation funding to make the greatest impact
with the funds as a whole?

Planning Grants:

Nationwide, communities are at very different points of addressing climate change. Further, overlapping
levels of government in one place may be taking significantly different approaches; a state government
may have aggressive climate goals, while local governments in that state have none, and vice versa.
Accordingly, the LGAC believes that EPA funding should be directed to where it can do the most good
- including the local level. Local plans are more likely to be actionable and implemented because they
can be more specific, more responsive to on-the-ground opportunities and challenges, and more quickly
developed and deployed. Failing that, we recommend that any funded planning efforts be required to
include the relevant jurisdictions in the planning process. For example, a county level plan should
include the municipalities in that county as part of the planning process.

Goals of Philadelphia Energy Authority

-	Promote economic development by
brining established companies and
investors to new neighborhoods

-	Create clean energy jobs and careers

-	Reduce the energy burden for
Philadelphians by updating homes with
more efficient and safer technology

-	Improve public health by supporting
more clean energy

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Climate-related planning has an unfortunate history of focusing on the details of carbon inventories but
failing to identify and prioritize implementation steps that measurably reduce future GHG emissions. To
promote action-oriented funding, the LGAC recommends that EPA require any plans contain and
prioritize specific projects or actions for implementation, as well as specific goals and metrics. To that
end, we recommend that the EPA provide technical assistance both with GHG inventories and with plan
templates. See below for more details on those recommendations. Towards the goal of identifying
impactful, implementable projects, we encourage the EPA to work with communities to look at capital
improvement plans that already have a pipeline of projects, which can be matched with funding and
implemented at any time. These projects may not be designed in a way that explicitly reduces GHGs, but
they present an opportunity to insert adjustments to greenlit projects that can have major climate
impacts, with limited administrative work.

Funding for climate action planning through the Climate Pollution Reduction grants will provide
unprecedented support for state, local, and tribal governments to strategically address climate change.
It is imperative that these plans capture the essential and strategic approaches for tackling climate
change - goals and actions to both reduce GHG emissions and improve resilience to current and future
climate change impacts are critical components of such plans. Therefore, we encourage EPA to support
inclusion of climate vulnerability assessments and adaptation measures into climate action planning.
Bifurcating mitigation and adaptation planning slows progress toward resilience, misses opportunities
for innovative projects that provide co-benefits, and can even result in achieving one aim at the
expense of the other, producing untended financial, health, and safety consequences.

Implementation grants:

Implementation grants should support recipients of planning grants, proposals that focus on
underserved communities, and/or projects that provide multiple co-benefits. For example, a building
decarbonization project that focuses on affordable housing and includes indoor air quality
improvements might receive preference over one that focuses on market rate housing. However, the
LGAC is aware that there is a need to expedite the allocation and expenditure of some of these grant
funds. We recommend that communities who have existing GHG reduction plans and can identify
projects that will measurably reduce emissions, be eligible for implementation grants without first
receiving planning grants. We are confident that, if given the opportunity, local governments can supply
existing projects and programs that can reduce GHG emissions, improve air quality and thus community
health, and provide other co-benefits.

Finally, it's important to note that for many communities, the need to match any funding can be a major
barrier. The LGAC recommends that EPA set aside a portion of funding for 100% grants based on need.
Additionally, EPA should allow other federal funding to be used for any required match and encourage

communities to stack funding from multiple sources to achieve multifaceted, multi-benefit projects.

Administrative funds

Many communities want to take climate action but lack the staff to make it happen. In these places, the
ideal would be for EPA to establish a program where communities identify their overarching climate
goals and/or specific climate-smart projects, and EPA help identify the various components of realizing
that program, and the funding streams to support it. Specifically, EPA could use the allocated
administrative funding to work across the federal family - and with input from nonprofits and advisory

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groups - to create templates for common climate action plan projects, such as decarbonizing buildings
or fleet, creating transit-oriented development, increasing tree canopies, or creating more sustainable
solid waste management plans. Like the U.S. EPA Indian Environmental General Assistance Program, EPA
could identify capacity indicators for each program area that would allow a community to map out and
grow a program overtime. If these indicators were met, grants could receive prioritization for funding,
which would encourage communities previously untouched by EPA to spend the time to develop a
program and complete an application.

Similarly, EPA could use administrative funds to provide support for innovation and taking a whole of
government approach to GHG reduction in economic development, transportation policy, infrastructure
investment, equitable development, land use policy, climate adaptation and resilience, and more. EPA
would likely need to contract with technical assistance providers to assist communities. In general, local
governments lack the capacity to do this work on their own, but we believe that many would be eager
to participate if given the opportunity to do so.

The EPA already has infrastructure to provide this level of support (e.g. Environmental Finance Centers,
Thriving Communities Technical Assistance Centers, Brownfields Technical Assistance Centers), but it
must leverage and coordinate these resources to deploy real-time support services to local governments
and community groups wishing to support EPA's programs.

EPA staff can also be utilized for capacity building, as they were in previous administrations. LGAC
recommends that EPA invest early in hiring staff to manage and coordinate program activities,
targeting full program staff by July 2023. This should include at least one national liaison for local
governments and one for community-based organizations, plus one position within each EPA Regional
Office. Additionally, LGAC recommends that EPA utilize part of this funding (coupled with
administrative appropriation from other sections of IRA) to create an Interagency Office with US DOT,
US DOE, US HUD, US Commerce (EDA). This Office will provide coordination across agencies in the
implementation of IIJA and IRA, with a targeted emphasis to work "at all levels of government" and
provide coordination assistance with States, municipalities, and Tribes. This will increase the efficiency
and effectiveness of both laws, while supporting deep transformations rather than easy "symptom"
treatment.

4. EPA plans to provide technical assistance to grant recipients.

a.	What technical assistance would be most helpful to eligible entities as they develop
climate plans under the Climate Pollution Reduction Program?

b.	What technical assistance would be most helpful as applicants prepare for the
implementation phase of the program?

First and foremost, applicants need an easier way to parse through available federal funding
opportunities as well as support in completing complex applications. Refer to the LGAC's past
recommendations for more specific details. Beyond that, the LGAC believes that communities need
support in accessing emissions data, conducting community engagement, communicating about GHG
reduction work, and creating actionable GHG reduction plans. Finally, we believe there is an opportunity
to support innovation and a whole of government approach to climate via technical assistance (see
above).

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As many communities do not have GHG emission reduction plans, we recommend that EPA work with
technical assistance providers or national NGOs with expertise in this area, to create planning
templates to support communities in quickly creating prioritized, actionable plans with useable
metrics. EPA could also support cities by helping to identify policy solutions to reduce GHG emissions,

via both requirements and incentives. This support could come from Regional Office staff pulling
together best practices across each region and hosting quarterly workshops/in-services to showcase and
explain innovative policy solutions. Requirements might include local building energy codes (where
possible) or transportation demand management policies. Incentives might include offering tax
incentives to developers who meet certain sustainability goals or sponsoring a climate challenge that
compares GHG emissions reductions over a certain time against the other cities in a college sport
conference.

Part of this effort includes accessing tangible data points - specifically data that measures the impact of
potential projects, how discrete projects will ultimately save money, and a guide for prioritizing projects
with the greatest need. The more EPA can help to automate the process of creating a GHG inventory for
communities and updating it over time, the better. Similarly, identifying and quantifying the co-benefits
of programs and projects that reduce GHG reductions is critical for achieving the multifaceted goals of
communities. The LGAC recommends that EPA create resources like calculators, case studies, and
templates that highlight how GHG reduction and other co-benefits can be achieved in common
municipal projects (ex: integrating nature-based solutions into street redesigns can reduce urban heat
island, air pollution, and emissions from surrounding buildings). This should include quantifying the
economic, health, and other co-benefits of a project.

This data should feed directly into tools for climate messaging, which there is a tremendous need for at
the local level. Elected and appointed officials need support explaining the value of pursuing climate
projects to fellow elected officials, the business community, and residents, as well as the cost of not
taking action. Messaging should focus on examples that people can relate to, like the costs of repairing a
basement due to increased flooding, and the health impacts of an increasing number of hot days each
summer. The LGAC recommends that EPA develop communication strategies, tools, and templates for
communities to use, and to have EPA staff available to answer questions and tailor strategies to
specific locations. The LGAC would be happy to work with EPA on this project.

Finally, communities need thoughtful and detailed assistance with community engagement, particularly
to authentically engage with underserved communities. This could include examples of how to best
reach underserved communities, how to structure an engagement meeting to facilitate authentic
participation, and how to make it easier for community members to actively participate (i.e. offering
childcare, food, etc.). More importantly, communities need assistance with how to explain to residents
that despite urgent, day-to-day challenges like the rising cost of food and housing, it's important to talk
about climate change, and in fact those daily challenges are often related to larger climate issues.

5. How can EPA facilitate coordination and leveraging of other available funding and planning
efforts to maximize effectiveness of the program (e.g., timing of implementation grant
solicitations, time needed to complete a plan, guidance on program interactions, etc.)?

Any advance notice of funding opportunities is helpful for communities - especially small communities.
EPA funding announcements typically start immediately and run for 30 days. This timeline leaves

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communities in a scramble to piece together an application and receive internal approvals. Communities
that can afford it turn to consultants to help with this task, but many more either lack that funding or
won't take a risk on spending that money when they know the odds of receiving funding are limited. The
LGAC references its recent Small Communities Advisory Subcommittee recommendations
(https://www.epa.gov/ocir/small-community-advisory-subcommittee-scas) to underscore this point.
EPA should also include links to similar funding sources in any communications about grant
opportunities, so that communities can easily find the source that best fits their need.

The LGAC recommends that the federal family coordinate on cross-cutting issues and develop an
intuitive way for local governments to stack funding for a specific goal. For example, if a community
wants funding for weatherization, they can apply (with one application) for relevant funding and
support from EPA, HUD, and DOE.

Lastly, recognizing that the state of climate action across the country is as diverse as our nation, LGAC
recommends that EPA approach the timing of implementation grants with an understanding that
some states, local governments, and tribes will have "shovel ready" projects now and that there will
be more comprehensive longer-term projects that arise out of the planning grants, as well as regional
collaborations that are now starting to occur due to ARPA, IIJA, and IRA.

6.	What internal capacity challenges do you face regarding the development and implementation
ofGHG reduction plans? How can EPA help address those challenges?

Many local governments lack the capacity or expertise to develop GHG inventories or GHG reduction
plans (thus the need for technical assistance, see above). Similarly, local governments may lack capacity
to take on a large, new implementation project. Allowing project management costs to be covered by
grant funding could help fill this gap. The LGAC also recommends supporting capacity to re-orient
existing projects toward GHG reduction - for example, to support the use of low-carbon concrete in
infrastructure projects, or to support the addition of efficiency and renewable generation on building
projects. Pivoting or expanding projects that a local government is already committed to undertaking
could save staff time and money. Finally, supporting local governments in updating their codes, design
guidelines, and infrastructure project standards to account for GHG emissions - and providing staff
training to implement these standards - could have a significant long-term impact.

The LGAC also recommends providing better and more streamlined access to available resources. EPA
has the expertise, but local governments not knowing how to access it effectively, makes this an
information problem. The site https://www.epa.gov/statelocalenergy was removed in 2017, and should
be re-instated and built upon.

7.	What metrics should this program use for measuring success and ensuring accountability?
The LGAC recommends that EPA consider metrics that cover the following areas:

GHG emissions

Air quality

Efficiency of emissions reductions (e.g. support conversion of vehicles/buildings that are heavily

used over those that are not)

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Impact on underserved communities and equity

Positive local economic impact (via contracting and workforce)

Co-benefits such as climate resilience, health improvement, financial savings, workforce
development, etc.

Measures of partner and community engagement, including active participation and how input
informed plans and projects

These metrics are already included in many federal and state programs. Above all, EPA should ensure
that reporting metrics under this program align with existing reporting metrics for other federal and/or
state programs. Strive for efficiency and redundancy with existing efforts. If there is the need for a new
metric, ensure that the process for data collection is realistic, reasonable, and achievable by the
grantees.

8. How can EPA structure this program to facilitate cooperation and coordination within and across
triballocal, regional, and state agencies to implement climate policies?

As noted above, the most promising GHG planning and reduction opportunities will occur when the
"whole of government" is coordinated across federal, state, and local levels. Therefore, we highly
recommend that EPA view the State Planning Grant as the opportunity to create alignment and
coordination across state agencies and with units of local governments, tribes, community groups,
and private business to increase the efficacy of the implementation grants, as well as other funding
available via the IIJA/BIL and IRA. To accomplish this coordination, LGAC recommends that EPA require
any states receiving funding to demonstrate how local and tribal governments within their jurisdiction
have been engaged in the planning of the projects, and how they will be integrated into the
implementation. At the same time, local and tribal governments should be encouraged to demonstrate
how they have worked with the state, if their state has a climate action plan. However, they should be in
no way penalized if that option is unavailable in their state.

Another opportunity is to incentivize a holistic approach that uses multiple federal IRA funding streams
to achieve more effective and efficient planning and implementation. For instance, a planning grant
awarded to a state should showcase how the state, tribes, local governments, community groups, and
private sector are maximizing the GHG reduction impact of federal rebates, tax incentives, and
competitive funds such as the GHG Reduction Fund. As noted above, the LGAC recommends that
funding under this section focus on developing a strategic plan that maximizes federal incentives;
ensures co-benefits and advances for underserved communities; showcases the opportunities for new
domestic production and manufacturing of solar energy components, heat pumps, and other innovative
energy saving technologies; and creates a road map and investments for building the regional workforce
across all sectors within the plan.

9. What should EPA consider in the design of the program to encourage grantees to support high
quality jobs and adhere to best practices for labor standards, consistent with guidance such as
Executive Order 14063 on the Use of Project Labor Agreements and the Department of Labor's
Good Jobs Principles?

Wherever possible, the LGAC recommends that EPA align with requirements and incentives already
included in the IIJA and IRA. This will reduce the administrative burden of local governments in both

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applying for and managing grants. The LGAC also recommends supporting existing community-driven,
workforce development programs. Many communities already have job centers and workforce
development agencies that are doing good work. EPA would go a long way to support communities by
encouraging applicants to partner with these organizations when implementing their projects. In many
cases, this leads to more than just a one-time job opportunity, but the development of a career, as there
is an influx of investment in clean energy projects.

10.	How could EPA design this program to align with any legal, regulatory, or voluntary obligations
state, local and tribal governments - or regional planning bodies — may have to quantify and
reduce emissions including potential requirements from proposed rulemakings?

EPA should consider that proposed grants be additive and not funding existing programs or operations,
unless additional GHG or co-benefits can be shown by the influx of new funding.

11.	EPA wants to ensure applicants have adequate time and funding to develop their climate action
plans before the deadline to apply for implementation funds. In your experience, how much time
and funding is required to complete a state, municipalor tribal climate action plan?

Comprehensive climate planning efforts take time simply because the climate emergency cuts across all
sectors of the economy and society, and actions to reduce GHGs impacts all community members.

Based on anecdotal information, the average time is 18 months, although that can be much longer,
especially when including robust community engagement that represents disadvantaged communities
and receiving approval from the local decision-making body. This timeframe is too long, and EPA should
focus resources on reducing it in an effective manner. The comments and recommendations provided
above will assist greatly in reducing these timelines.

The cost of a climate plan at the local level is completely dependent upon the size of the community, the
scope of the plan, and the integration of regional and/or state efforts. Additionally, many communities'
current climate plans are based on the work of prior planning efforts including those in the
transportation, housing, economic development, and air quality regulatory sectors. A quality plan and
effort takes time and resources. LGAC recommends that EPA engage LGAC on this question further in
2023 to gather insight and information to inform on-going program decisions.

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Clean Heavy-Duty Vehicles

In addition to the noted funds, the LGAC believes that the biggest contribution the federal government
could make towards transitioning fleets to clean vehicles would be to rapidly and comprehensively
transition its own fleet. Local governments lack the purchasing power the federal government has, so a
clear signal to the market backed by federal purchasing power could help move manufacturers, spur
innovation, and bring prices down.

1. How do you see this program working in conjunction with the existing Diesel Emissions Reduction
Act (DERA), the Bipartisan Infrastructure Law (BIL) Clean School Bus program, and programs at
other agencies given the overlap in vehicles that could be funded?

All too often, local governments find the current programs impenetrable or require too much work to
access because of the length of applications, unclear eligibility, and/or the complexity of reporting
requirements. The LGAC recommends that EPA take this opportunity to develop a single, simple
application that covers all of these programs, allowing applicants to describe their fleet, desired
conversion, and other relevant information. EPA staff would then evaluate the applications and make
awards from the most applicable funding source. If it is possible to include relevant programs from other
agencies, that would be ideal. At a minimum, the application should be the same across all agencies.

DERA could serve as a complement to the Clean Heavy-Duty Vehicles (HDV) program, but because they
would address air pollution from medium and heavy-duty (MHD) vehicles in different ways, DERA and
Clean HDV are more likely to serve as complementary strategies for eligible entities to address air
quality in non-attainment and poor air quality areas than to be used in conjunction with each other.
Additionally, DERA legislation requires EPA to offer 30% of the annual appropriation to states and
territories to implement their own diesel emissions reduction programs. While state agencies must
select projects according to EPA's eligibility and cost-share requirements for DERA, selections are made
entirely by the states to suit state needs. If DERA serves to inform any of the design and implementation
of Clean HDV, the LGAC recommends that EPA find ways to ensure funding goes directly to local
governments. If money goes to a state program to then disburse to eligible entities, EPA should
include program guidance that requires recipients to partner with local governments when identifying
or prioritizing communities and needs.

Some smaller communities may have difficulty meeting the annual mileage requirements found in some
grant programs like DERA, so LGAC recommends that EPA develop eligibility criteria to enable
communities whose MHD vehicle service territories or duty cycles may limit annual miles driven the
opportunity to pursue resources or not include a mileage requirement similar to that in the Clean
School Bus Rebate Program.

Community Air Monitoring

The IRA provides $3 million for disadvantaged and low-income communities to benefit from improved
air quality sensors, along with $117 million for fenceline air pollution monitoring and $50 million for
multi-pollutant monitoring stations. Community air monitoring is an important tool to assess air quality
and inform the development of emission reduction strategies for frontline and overburdened
communities. Identifying communities that are disproportionately exposed to diesel MHD vehicle
pollution is essential for local governments to effectively address environmental justice issues, including
investments in zero emission vehicles and infrastructure operating in and near these communities.

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Leveraging funding, technical assistance and basic training on air monitoring science to build the
community capacity and knowledge necessary to support successful community-led monitoring
programs would be an important element of measuring and demonstrating the air pollution benefits of
MHD clean vehicle and infrastructure deployment. Some grants programs such as the DERA program
prohibit use of grant funding for air monitoring, so the ability to take advantage of these air monitoring
resources in conjunction with Clean HDV will be critical, in particular if there are air quality metrics
associated with tracking program impact.

2. For which significant Class 6/7 vehicle sectors should EPA prioritize funding?

Overall, the LGAC recommends that EPA prioritize replacing vehicles that are used more within a
community (thus generating more emissions) over those that are less frequently used. Examples
would be transit busses over school busses or garbage trucks over snowplows. However, this should in
no way exclude or impede small communities that simply do not have many miles to cover. We also
recommend prioritizing vehicles that are more often used in low-income communities, to ensure that
the benefits of reduced emissions benefit these communities.

In terms of specific vehicle sectors, there is already significant funding dedicated to school buses under
EPA's Clean School Bus Program and DERA. In addition, based on the number of electrified school bus
models currently available for purchase and those projected to be available in the next 3-5 years based
on manufacturer announcements, the market for zero-emission vehicle (ZEV) school buses is well
developed and fast approaching (if not at) life cycle cost parity with internal combustion engine (ICE)
vehicle options. The LGAC recommends focusing on other, non-school bus MHD vehicle-types such as
construction trucks and Class 6-7 stake and refuse trucks. These all play a significant role in local air
quality, and have high visibility and generally low charging barriers based on likely duty cycles (i.e. can
typically be charged overnight at their "home base"). The LGAC recommends that EPA ensure non-
school bus vehicle types in both classes be considered as viable award options to help drive new model
availability and market demand for MHD vehicle segments that will be increasingly important for fleet
decarbonization.

EV Charging Infrastructure

The cost of MHD EV charging infrastructure can add overwhelming expenses to local government fleets
already struggling to procure zero emission vehicles with high upfront costs. Local government fleets
must also coordinate with utilities to ensure sufficient electricity is available to operate charging
stations, meaning an increased number of stakeholders, prolonged timelines and steep "make-ready"
deployment costs. The LGAC recommends that EPA make available sufficient resources to support
clean MHD vehicle infrastructure in addition to the vehicles themselves as the charging infrastructure
will be important for continued ZEV adoption by municipal fleets and help drive vehicle and charger
manufacturer response to meet growing demand and the coevolution of the vehicle and charging
infrastructure markets.

Additionally, because it less expensive to dig once and install all the electrical capacity and conduit that
might be needed in the future for EV charging infrastructure rather than go back and dig a second time
to build out additional or higher-powered charging stations, the LGAC encourages EPA to give
consideration to charging infrastructure projects that include the ability to build out infrastructure
requirements that are not necessarily needed at the outset of a project but will help build infrastructure
capacity for eligible entities to help push future MHD vehicle demand and market options.

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Vehicle Scrappage

Scrappage requirements, a common feature of truck and bus incentive programs such as DERA, could
preclude some local government or other eligible entity fleets from participating in a program like this
because they may not have eligible older vehicles to scrap depending on their asset management
practices. Scrappage requirements can also be a disincentive to local government fleet operators that
may rely on other funding strategies (e.g. lease to own) rather than purchased MHD vehicles.

Similarly, some federal grant making programs, for example FTA-funded transit bus projects, have useful
life replacement requirements based on years of service or accumulation of miles which can hinder the
ability of some local governments to purchase new, leading edge clean MHD vehicle technologies under
a timeline faster than a vehicles minimum useful life requirement. The LGAC recommends EPA carefully
consider the scrappage requirements for the program and explore options for flexible scrappage
requirements (for example, consider the Clean School Bus Program option to donate or sell and
document newer diesel vehicles) that can maximize both air emission reductions and fleet participation.

3. How can EPA ensure the benefits of this program reach low-income and disadvantaged
communities?

The reason many local governments haven't upgraded from diesel to zero-emission vehicles is not
because they lack the will. In reality, a new diesel sanitation trucks costs $350,000 while an electric one
costs $500,000. The funding in the IRA provides only incremental funding - rather than the full cost of a
new vehicle. This means that communities who weren't already budgeting upgrades will be unable to
take advantage of the funding. It also means that low-income communities will be ineligible. LGAC
recommends that the EPA design this program to account for asset management cycles and provide a
long time frame for expending grant funds so that communities on long replacement cycles can still
benefit. We further recommend that EPA identify financing options for communities that are unable
to budget for the base cost of the vehicle.

EPA could consider prioritizing grants to areas with high asthma rates, poor air quality, or other
indicators of high negative impact from existing dirty vehicles. To ensure that these grants do not simply
move the problem around, EPA should either replicate guidance in DERA that prohibits resale of dirty
vehicles or consider adding the resale cost of the replaced vehicles to the grants and requiring that
replaced vehicles be taken out of service and recycled, rather than being sold to a different user.

In addition to the up-front cost of zero-emissions vehicles and their fueling/charging infrastructure, the
ongoing cost of operation is a major consideration and sometimes barrier to affordability. In many
states, the utility regulatory landscape and rate structure have not been updated to account for and
support the electrification of light and heavy-duty vehicles. As a result, high electricity rates and demand
charges can be prohibitive for charging fleets, high-use vehicles, and heavy duty-vehicles, precisely the
types of vehicles this program seeks to decarbonize. Similar to recommendations above to support
development and adoption of building codes that support EPA climate goals, the LGAC recommends
that EPA dedicate staff and other resources to encourage state utility regulators and utilities to adopt
rate structures that support EV charging by making it affordable and accessible, building on models of
success found around the country.

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EPA could prioritize investments in overburdened and underserved communities by allowing project
funding to cover deployment of make-ready infrastructure and investment of incentive funding to focus
on fleets operating in or near these communities. At the same time, EPA could prioritize projects that
address last-mile zero service areas or vehicle types to reduce polluting truck traffic in a congested areas
and heavily trafficked corridors, which can have disproportionate impact on low income and
disadvantaged communities.

Finally, workforce development needs to be considered. Workers currently employed in the automotive
sector—specifically truck and bus maintenance and repair —will need customized training to upskill and
successfully navigate job transitions tied to fleet turnover. In addition, many jobs tied to EV maintenance
and EV charging infrastructure deployment and maintenance will require electrical, mechanical, and
other specialized skills. EPA should support opportunities to stand up training and retraining and
workforce development programs in overburdened, underserved, and low-income communities.

4.	What should EPA consider in the design of the program to encourage grantees to support high
quality jobs and adhere to best practices for labor standards, consistent with guidance such as
Executive Order 14063 on the Use of Project Labor Agreements and the Department of Labor's
Good Jobs Principles?

The LGAC recommends that EPA provide standard contract language that grantees could adopt when
issuing RFPs or soliciting bids, as well as requirements for grantees regarding labor conditions in
garages/fleet centers, supported by spot check enforcement.

EPA should also support the development and distribution of resources that eligible entities need to
successfully plan and deploy clean MHD vehicles and infrastructure (e.g., vehicle basics, charging
equipment, utility connections, vehicle performance and operational considerations like duty cycles and
maintenance). This would help to ensure support of high-quality jobs tied to both charging
infrastructure deployment and maintenance and ongoing fleet maintenance.

EVI Installer and EVSP Selection

For eligible entities dependent on outside vendors for planning and hardware deployment or for
managing or optimizing fleet and charging utilization, having a pre certified set of EVI installers and
EVSPs to utilize that have demonstrated they can or already meet desired best practices and labor
standards and provide workforce development and training opportunities, including paying prevailing
wages and ensuring its workforce is certified and/or licensed could help streamline project
development, interconnection and implementation processes.

5.	What metrics should this program use for measuring success and ensuring accountability?

LGAC recommends considering the following metrics:

GHG reductions (taking into account the emissions from charging electric vehicles)

Efficiency of emissions reductions (fuel use/engine time)

Number of fossil fuel vehicles removed from, and zero emission vehicles added to service
Air quality benefits

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Projected GHG reductions vs. reductions achieved

Geography of emissions reductions relative to vulnerable populations

Impact on underserved communities and equity

Co-benefits such as climate resilience, health improvement, financial savings, workforce
development, etc.

Measures of partner and community engagement, including active participation and how input
informed plans and projects

Harmful criteria air pollutant emissions reductions in disadvantaged communities (e.g., NOx, PM2.5)
o Air monitoring that includes before and after measurement in particular in nonattainment
areas and underrepresented communities would be helpful in assessing program impacts in
these communities.

Life cycle emissions impacts or benefits, in particular GHG emissions looking upstream and across
the full energy and transportation cycle

Charging hardware utilization metric (e.g. uptime and downtime data)

Workforce diversity in employee recruitment, training, and retention for both charging

infrastructure and vehicle maintenance related jobs

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