U.S. Environmental Protection Agency
Environmental Financial Advisory Board
Public Meeting Minutes
December 1, 2022
Virtual
Respectfully submitted by Edward H. Chu, EPA Designated Federal Officer
Certified as accurate by Kerry E. O'Neill, Chair, Environmental Financial Advisory Board
NOTE AND DISCLAIMER: The minutes that follow reflect a summary of remarks and conversation during the meeting.
Such ideas, suggestions, and deliberations do not necessarily reflect consensus advice from the Board. Formal advice
and recommendations may be found in the final advisory reports or letters prepared and transmitted to the agency
following the public meetings. Moreover, the Board advises that additional information sources be consulted in
cases where any concern may exist about statistics, or any other information contained within the minutes.
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Contents
Purpose 1
Welcome and Review of Agenda 2
Execution, Reporting, and Accounting Workgroup 3
Program Structure Workgroup 4
Objectives Workgroup 6
Recap and Wrap-Up 7
Adjourn 7
Appendix 1. Federal Register Announcement 8
Appendix 2. Agenda 10
Appendix 3. EFAB Members 11
Appendix 4. Slide Presentations 16
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 1
Purpose
The U.S. Environmental Protection Agency (EPA) Financial Advisory Board (EFAB or Board) is an advisory
committee chartered under the Federal Advisory Committee Act (FACA) to provide advice and
recommendations to EPA on creative approaches to funding environmental programs, projects, and
activities. The purpose of the meeting was to discuss the Greenhouse Gas Reduction Fund charge.
The meeting was announced in the Federal Register (see appendix 1).
Please see appendix 2 for the agenda and appendix 3 for EFAB member names and affiliations.
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 2
Welcome and Review of Agenda
Edward H. Chu I EFAB Designated Federal Officer
Kerry O'Neill I EFAB Chair
Alejandra Nunez I EPA Charge Client
Tim Profeta I EPA Charge Client
Welcome
Ed Chu welcomed participants and noted that the sole purposed of the meeting was to discuss the
EFAB's Greenhouse Gas Reduction Fund (GHGRF) charge. He said that oral public comments would not
be recevied during this meeting; however, written comments could be submitted to efabgepa.gov.
which will be monitored throughout the meeting. He said that comments already received for the day's
meeting have been posted on EPA's website. Comments for the December 15 meeting are due by
December 8.
Alejandra Nunez said she appreciated workgroup members' hard work, which is resulting in some
concrete ideas and options for the Agency. Tim Profeta also expressed his gratitude to the group.
Kerry O'Neill thanked the public for their engagement with the EFAB. She shared the charge and said
that the present meeting will be a check-in with the full Board. She noted the compressed timeline the
members are working under and reminded attendees that the work that will be presented is not yet
done. She urged Board members to raise any concerns or issues that would prevent them from moving
the recommendations forward at the upcoming meeting on December 15.
Attendance
Ashley Allen Jones, present
Courtney L. Black, present
Steven J. Bonafonte, not present
Angela Montoya Bricmont, present
Matthew T. Brown, present
Stacy Brown, not present
Theodore Chapman, present
Albert Cho, present
Janet Clements, present
Lori Collins, present
Zachary Davidson, present
Jeffrey R. Diehl, present
Sonja B. Favors, not present
Phyllis R. Garcia, present
Eric Hangen, present
Edward Henifin, not present
Barry Hersh, present
Craig Holland, not present
Craig A. Hrinkevich, present
Margot Kane, not present
Thomas Karol, present
George W. Kelly, present
Gwendolyn Keyes Fleming,
Cynthia Koehler, present
Colleen Kokas, not present
Joanne V. Landau, present
Lawrence Lujan, present
MaryAnna H. Peavey, present
Dennis A. Randolph, present
Eric Rothstein, not present
Sanjiv Sinha, not present
William Stannard, present
Marilyn Waite, not present
David L. Wegner, present
Gwen Yamamoto Lau, present
David Zimmer, present
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 3
Execution, Reporting, and Accounting Workgroup
Ted Chapman and MaryAnna Peavey I Workgroup Co-chairs
Note: Presentations are in appendix 4.
MaryAnna Peavey began by explaining that, while not disregarding medium- to long-term goals, the
workgroup has been focusing on the short-term timeframe and specifically on success metrics and
developing recipient terms and conditions. The workgroup sought to learn from other federal programs
and to create guidance for EPA's consideration.
MaryAnna Peavey said the workgroup's initial measures of success included total GHG avoided in
disadvantaged communities; total funding awarded to direct recipients in disadvantaged communities;
total funding expended by indirect recipients; total leverage achieved; continued operability/self-
sufficiency ratio (earned income divided by total expenses); and number of jobs created or retained.
She shared information on the strengths and weaknesses of some of the programs the workgroup
researched. For example, she said the Clean Water State Revolving Fund (SRF) program can fund a broad
array of projects. Its strengths are that it has a decades-long track record of success; it has good
oversight, and it maximizes use of funds. In contrast, she said that some of the program's challenges are
that it depends on continued appropriations. Although the SRF is likely to be funded year after year, that
is not the case with the GHGRF.
MaryAnna Peavey said the workgroup also looked at EPA's nonpoint source program, EPA's Water
Infrastructure Finance and Innovation Act program, U.S. Department of Housing and Urban
Development's (HUD) Community Development Block Grant program, the American Recovery and
Reinvestment Act, and the American Rescue Plan Act. She welcomed suggestions from the group on
other programs they should look into.
Ted Chapman raised the issue of the need to get GHGRF monies out the door quickly versus the need for
accountability; he pointed specifically to the need to ensure that funds are going to the eligible
recipients they are intended for. He said the workgroup has been deeply engaged and the public
comments have been fantastic and are being worked into the discussion. He said the workgroup is
interested in making sure that money that is invested in disadvantaged communities stays in those
communities. For instance, if a solar farm is installed in a community, the energy shouldn't be shipped
elsewhere.
He said the workgroup considered the issue of how to create feedback loops without being
burdensome. Good governance goes hand-in-hand with technical assistance (TA) because reporting,
monitoring, or other types of feedback will be necessary for grant recipients. Recipients have to be able
to decide that the administrative burden won't be too high.
Ted Chapman said the group talked about guardrails and a way to stay accountable to low-income and
disadvantaged communities, and the workgroup would welcome more input into this part of the
discussion. Other discussions included how to ensure reductions in greenhouse gas emissions as well as
how to leverage and recycle the grants so that the GHGRF program doesn't end in 2024.
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 4
Eric Hangen explained that the workgroup was trying to look at how to align reporting and application
requirements with the core aspirations of the legislationgreenhouse gas reductionsbut also with
benefits from low- and moderate-income communities.
George Kelly suggested the workgroup look at a California law that includes guidance on reducing
greenhouse gas emissions in disadvantaged communities. He also asked about whether measures will
be at the project level or the programmatic level. Ted Chapman replied that the group had discussed the
issue, but the details need more consideration. George Kelly added that it's better for grant recipients
know up front how success will be measured.
Eric Hangen said one of the things the workgroup may want to talk about more is the possibility of
developing a tool to bring a methodology across sectors and regions that recipients or subgrantees
could use to estimate and report greenhouse gas abatement impacts.
Albert Cho suggested it may be helpful to look at the U.S. Department of Energy's loan programs office
and their funds for advanced technologies.
Regarding how to ensure additionality of projects and continued operability, Ted Chapman iterated that
feedback loops were important, and the workgroup has more to discuss on the issues.
Kerry O'Neill said that, although the presentation was high level, a lot of details are on the slides, and
she asked the group to read them.
Program Structure Workgroup
Lori Collins and Ashley Allen Jones I Workgroup Co-chairs
Lori Collins said that at the November 17 presentation, the workgroup shared four options. But as the
workgroup began to evaluate the options, they added two more: lender intermediaries and the
combination structures.
States, municipalities, and tribes. Lori Collins said the first approach is for EPA to solicit competitive
grant proposals from states, municipalities, and tribes. She said this is an option for the $7 billion pot of
money, but the entities could also be eligible for other funding. In this strategy, EPA would ask
applicants to describe how they would allocate the funds and how funds would benefit disadvantaged
communities. She said EPA could use a hybrid award model that makes funding contingent on meeting
certain qualifications and conditions. Next, she pointed out strengths of the model, such as equitable
access to the funds. Weaknesses in the model include a competitive process that may disadvantage
some entities, among others.
National Green Bank/Fund. The second approach Lori Collings discussed would solicit competitive
proposals from entities to create and manage a single national green bank that would then redeploy the
funds to other eligible entities or eligible recipients. In this strategy, EPA would ask applicants to
describe how they would allocate the funds across the country along the value chain and how the funds
would address greenhouse gas reductions at scale.
Lori Collins pointed out that an important strength of this approach is a relatively low administrative
burden on EPA. It is also the best option to optimize the funds. A national green bank doesn't yet exist,
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 5
but state level green banks already exist. She said weaknesses of the model include a concentration of
funds that have to flow through multiple layers before they reach end users.
Regional Collective Action. Lori Collins said this strategy would seek regional solutions. Applicants would
be asked to identify regional opportunities, barriers, and priorities for greenhouse gas reduction. In
addition, applicants would be asked to provide details on how the regional partnership would work.
Benefits of this strategy are that applicants would be encouraged to take a holistic view of what is going
on regionally, leverage resources, and establish partnerships. Challenges include the time it takes to
work at the regional level and potentially complex management structures. The workgroup felt this is
the least viable option.
Sectoral Collective Action. With this strategy, Lori Collins explained, EPA would ask applicants to address
a particular sector, such as community solar, home retrofits, electric vehicles, and so on. A big strength
is that it could promote innovation and free EPA to heavily invest in certain sectors. On the other hand,
she said, national sectoral strategies would still encounter regional challenges, and there are few
national players in specific sectors.
Lender Intermediaries. Lori Collins said this approach already exists, so it would be a way to channel
funding to green lending programs through established intermediaries. In this scenario, applicants
would describe their network of lending organizations and the strategies these organizations are using
to reduce greenhouse gas emissions, as well as the sectors and geographical reach. A strength of this
approach is speed, as well as a low administrative burden for EPA. Challenges include ensuring lenders
invest in TA, capacity building, and other value chain supports.
Combination of Structures. EPA could have a national strategy supported by state, regional, sectoral,
and direct solutions. Among other requirements, applicants would be asked to create partnerships.
Because EPA wouldn't rely on one strategy, this option reduces risks and can promote innovative
thinking. On the downside, there would be a large administrative and oversight burdens for EPA.
Lori Collins shared a table the workgroup created to capture GHGRF design requirements (including
governance, reporting systems, etc.) and the reasons they work or are viewed as burdens. She said the
Program Structure workgroup is coordinating with other GHGRF workgroups to be ready for the
December 15 public meeting.
Jeff Diehl suggested that EPA might consider dividing the $7 billion into two buckets: one for states and
municipalities or local authorities, and one for tribal communities. He added that, in terms of the hybrid
model, if applications exceed availability, then EPA could consider scaling back so that credible and
competitive applicants are funded, perhaps setting a floor so that competitive and credible applications
receive a minimal amount that provides an economy of scale.
Eric Hangen said that, although not every regional has strong collaborations, he is aware of mission-
driven lenders and TA providers who work in specific regions. Regarding the national green bank
strategy, he said there are many indirect recipients. He advised against suggesting allocations for EPA in
the combination of structures approach. Finally, emphasized that the workgroup is suggesting that EPA
run a competitive process for every strategy mentioned.
Ashley Allen Jones added that she's enthusiastic about the sector approach. She said that a consistent
theme in finance is that in order to fund projects, you need to understand the technology.
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 6
Barry Hersh said he was also interested in the sector approach as a way to promote technology. He said
the HUD block grant program was originally distributed based on population, but after the 9/11 terrorist
attacks, it became a way to get funding out the door quickly. He said EPA could also create a program
with flexibility in mind. He asked about capping administration fees. He also said he supports the idea of
using established lenders with track records. Lastly, he added that the Brownfields Program led by David
Lloyd has done an outstanding job of dealing with getting competitive applications around the country
and providing TA.
Ed Chu said that the federal government may not be using a consistent standard for overhead. He gave
an example of universities proposing very high overhead, whereas nonprofit organizations may have low
overhead.
Objectives Workgroup
Cynthia Koehlerand Margot Kane I Workgroup Co-chairs
Cynthia Koehler gave an overview of the workgroup's primary purpose, which is to help EPA think
through how to finance greenhouse gas emissions reductions projects that are not currently resourced,
primarily in historically disadvantaged communities.
She said the workgroup identified overarching principles to help EPA balance competing mandates in
the legislation. She pointed out a need to balance equity and access with leverage goals, and to balance
"shovel-ready" projects with capacity-building goals. Another principle is to consider is that there may
be competing mandates in the near-term vs. the long-term. Rather than looking for a silver bullet, the
workgroup advised designing the GHGRF to accomplish some objectives very well while ensuring
performance of the portfolio overall.
The workgroup also identified a number of near-term trade-offs between program efficiency and
program objectives. Cynthia Koehler offered the example of moving quickly to meet mandated timelines
versus obtaining a measurable GHG reductions; leveraging private capital versus building capacity in
disadvantaged communities; and the related challenge of ensuring that benefits reach disadvantaged
communities versus the long-term financial sustainability of the fund itself. She said that these and
other tradeoffs could be addressed by subjecting different funding streams to weights and to emphasize
or de-emphasize objectives based on the direct or indirect recipient.
Cynthia Koehler shared several slides that provide details on how trade-offs may look in practice.
Leverage, for example, allows for larger projects and helps taxpayer dollars go further, so it's a good
match for large asset-backed projects. As such, recipients such as states, large cities, national green
banks, and lender intermediaries would be a good match.
Cynthia Koehler said that part of the charge was to consider complementary structures to the GHGRF;
there are many of these programs and the workgroup put together a comprehensive list. She said the
workgroup believes it would be beneficial for EPA to develop a mechanism to collaborate internally to
coordinate financial assistance. The workgroup developed a few guiding principles to help EPA sort
through the large number of programs to find good fits, such as programs that prioritize low-income and
disadvantaged communities, focus on reducing greenhouse gas, or have established relationships with
direct recipients.
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 7
She said the workgroup spent a lot of time thinking about guiding principles for defining low-income and
disadvantaged communities. These include providing clarity to all direct and indirect recipients and
participants; acknowledging that no one definition will meet the needs of every region, state, or
community; and acknowledging the importance of defining disadvantaged communities more broadly
than by median income or other existing federal and/or state metrics. She shared several slides on the
workgroup's efforts to identify the strengths and weaknesses associated with each principle.
The workgroup also looked at the technical and financial assistance that funding recipients should be
able to provide to low-income and disadvantaged communities. Cynthia Koehler said the type of TA
needed will vary depending on the phase of implementation, project applicants, types of projects
proposed, and so on. Cynthia Koehler said that, in addition to TA, the charge also asked about financial
assistance. She said some public comments were helpful in this regard. One commenter suggested that
it may materially advance the goals of the Fund for EPA to establish as an objective the creation of tools
to facilitate the flow of funds through established vehicles for low-income communities, such as
community development, financial institutions, or credit unions. She said another interesting idea that
came via public comments was to establish alternative underwriting criteria, acknowledging that
conventional criteria can perpetuate disparities.
Finally, the workgroup put together some indicators for success, including reporting on the design
elements, reach into low-income and disadvantaged communities, capacity building and TA reporting,
and other indicators.
The floor opened for discussion.
Eric Hangen said that an important balance for EPA to consider is whether it wants to invest in building
balance sheets or invest in building markets. He said there needs to be significant investment in building
ecosystem systems and markets, but the tradeoff is no leverage.
Kerry O'Neill said the EFAB is in the final sprint toward the December 15 public meeting, and she urged
Board members to review the materials, looking in particular for anything that might prevent them from
voting favorably on the final product on December 15. She reminded listeners they can email comments
to efabgepa.gov but they should do it quickly, as the workgroups are in their final stretch.
Recap and Wrap-Up
Ed Chu I EPA Designated Federal Officer
Kerry O'Neill I EFAB Chair
Ed Chu thanked the group for their public service and tremendous efforts. He said their work will help
EPA to develop an impactful approach. He said written public comments will be due on December 8.
Alejandra Nunez shared her appreciation and said a lot has been achieved in a short time. Tim Profeta
said the workgroups have gone beyond expectations, and he is looking forward to the next meeting.
Adjourn
Ed Chu adjourned the meeting.
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 8
Appendix 1. Federal Register Announcement
'9
Federal Register/Vol. 87, No. "211 /Wednesday, November 2, 2022/Notices 66175
Polic\ Statement FERC-552 remains
th^ sdme and no changes are needed for
that collection.
the Commission.
Issued: October 27, 2022.
KimberlvD. Bose,
Secretary.
[FR Doc. 2022-23846 Filed 11-1-22; 8:45 am]
BILLING CODE 6717-01-P
DEPARTMENT OF ENERGY
Federal Energy Regulatory
Commission
Combined Notice of Filings
Take notice that the Commission has
received the following Natural Gas
Pipeline Rate and Refund Report filings:
Filings Instituting Proceedings
Docket Kumbeis RP23-77-000
Applicants: ANR Pipeline Company.
Description: ง4(d) Rate Filing:
Jackson Generation #1321201 NCNR to
be elective 11/1/2022.
Filed Date: lo/2b/22.
Accession Number: 2022102652U3.
Comment Date: 5 p.m. hi 11/7/22.
Docket Numbers: RP23-78-000.
Applicants: Algonquin Gas
Transmission. LLC.
Description: % 4(d) Rate Filing:
Negotiated RatesAmended Excelerate
510850 ett 11-01-22 to be effective 11/
1/2022.
Filed Date lo/^R/22
Accession Numbti 20221026-5215.
Comment Date 5 p m. ET 11/7/22.
Docket Nnmbei s RP23-7M-000.
Applicant* Tidnscontin^ntal Gas
Pipt Line Company TIC
Descnption Compliance filing:
Annual Penalty Re\ pnue Sharing Report
2022 to bp effective N/A.
Filed Date: 10/27/22.
Accession Number: 20221027-5020.
Comment Date: 5 p.m. ET 11/8/22.
Docket Numbers: RP23-8G-000.
Applicants: Destin Pipeline Company.
L.L.C.
Description: Compliance tiling: Destin
Pipeline Annual Fuel Retention
Adjustment to be eiiective N/A.
Filed Date: 10/27/22.
Accession Number: 20221027-5037.
CouumntDate 5pm ET 11/8/22
Docket Numbers: RP23-81-000.
Applicants: Carolina Gas
Transmission. LLC.
Description: ง4(dj Rate Filing: CGT
October 27. 2022 Administrative Change
to be effective 12/1/2022.
Filed Date 10/27/22
Accession Numbei 202210275043.
Comment Date: 5 p.m. ET 11/8/22.
Any person desiring to intervene or
piotesl m an^ ol the abo\e pioGH?dmgt>
must hie m accordance with Rules 211
and 214 ot the Commission s
Regulations (18 CFR 385.211 and
385 214) on in b( ton 5 00 p m Eastern
time on the specified comment datt
Protests may be considered, but
intervention is necessary to become a
party to the proceeding.
The filings are accessible in the
Commission's eLibrary system (https://
elibrary.ferc.gov/i dm ws/search/
fercgensearch.asp) by querying the
docket number.
eFiling is encouraged. More detailed
information relating to tiling
requirements mtenentions piottsts
service, and qualifying facilities tilings
can be found at: http //intu feic go1;/
do cs-filing/efiling/film %-req.pdf. Fo r
other information, call (86b) 208-3b7b
(toll free). For TTY, call (202) 5028b5y.
Dated: October 27, 2022.
Debbie-Anne A. Reese,
Deputy Secretary.
[FR Doc. 2022-23841 Filed 11-1-22; 8:45 am]
BILLING CODE 6717-01-P
ENVIRONMENTAL PROTECTION
AGENCY
[FRL-10382-01 -OWj
Notice of Public Environmental
Financial Advisory Board Virtual
Meetings
AGENCY: Environmental Protection
Agency (EPA).
ACTION: Notice of public meetings.
SUMMARY: The United States
Environmental Protection Agency I,EPA)
announces three public meetings of the
Environmental Financial Advisory
Board ^EFAB). The meetings will be
conducted in a virtual format via
webcast The puipose otthe met lings
will be tor the EFAB to provide
woikgioup updates and ^oik pioducts
fni the Greenhouse Gas Reduction Fund
charge. Written public comments may
be provided m advance. No oral public
comments will be accepted during the
meetings. Please see the SUPPLEMENTARY
INFORMATION section tor further details.
DATES: The meetings will be held on:
1. November 17, 2022, from 1 p.m. to
3 p.m. Eastern Time:
2. December 1. 2022, from '1 p.m. to
3 p.m. Eastern Time' and
3. December 15. 2022. from 1 p.m. to
5 p.m. Fdstein Time
ADDRESSES: The meetings will be
conducted in a virtual, format via
webcast only. Information to access the
webcast will be provided upon
registration in advance ot each meeting.
FOR FURTHER INFORMATION CONTACT: Any
member ot the public who wants
information about the meetings may
contact Taia Johnson \id telephone/
\ oitenidil dt (202) 5646186 ui enidil to
vfab^rpa go\ Geneial liifomidtion
concerning the EFAB is available at
h Up s://www. ep a. go vl
waterfmancecenter/efab,
SUPPLEMENTARY INFORMATION:
Background: The EFAB is an EPA
achison committee chaiten dund^rthe
Fed* idl Adt isoiv Committee Act
(FACA) 5t'SC App I to pro\ult
ad\ice and lecommendations to EPA on
innovative approaches to funding
environmental programs, projects, and
activities. Administrative support for
the EFAB is provided by the Water
Infrastructure and Resiliency Finance
Center within EPA s Qthce ot Water.
Pursuant to FACA and EPA policy,
m ttice is hereby gn en that the EFAB
will hold thiee public mnptmgs via
webcast foi the following pinpose:
Pini ide workgroup updates and work
products foi the Bodid s Greenhouse
Gas Reduction Fund charge.
Registration for the Meeting: To
register for the meeting, please visit
https //mni' epa goi /\\atei finance
tentei/e1ab#meetmg Inteiested peisons
who wish to attend the meeting via
webcast must legists b\ Noi embei 14,
2022 (tor the November 17. 2022.
meeting). November 28, 2022 (tor the
December 1. 2022. meeting), and
December 12 2022 (foi the Di cembor
15 2022 meeting) Pie-iegistiation is
strongly encouraged.
ailahihti of Meeting Matenals
Meeting materials, including the
meeting agenda and briefing materials,
will be available on EPA s website at
https://www.epa.gov/
u 'iteifinanc er entei/^fab
Procedures for Providing Public Input:
Public comment tor consideration by
EPA s federal ddi l ui\ committer has a
ditteient puipo e from public comment
prm ided to FPA piogiam office
Therefore thnpmces foi submitting
comments to a federal advisory
committee is different from the process
used to submit comments to an EPA
program office. Federal advisory
committees provide independent advice
to EPA. Members of the public may
submit comments on matters being
considered by the EFAB tor
consideration as the Board develops its
advice and recomnif ndations to EPA.
Written Statements Wntt^n
statements should be ircen od by
November 10, 2022 [torthp November
17, 2022, meeting), November 25, 2022
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 9
66176 Federal Register/Vol. 87, No. 211/Wednesday, November 2, 2022/Notices
(for the December 1. 2U22. meeting), and
December 8. 2022 (tor the December 15,
21)22 meeting) bo tlidt the intoinidtion
can be made awilable to the Lt AB toi
itb cunsidelation pnoi to the meeting
Wiilten ^Lilementb bhould bbent \ia
email in vUib(t<>pa qoi Vlemheib otthe
public should bo dWdii that their
peisonal contact mf>>imdt]>m if
included in an}' written comments, ma}?
be posted to the EFAB website.
Copyrighted material will not be posted
without explicit permission of the
copyright holder.
Accessibility: For information on
access or services for individuals with
disabilities or to request
accommodations for a disability, please
register for the meeting and list any
special requirements or
accommodations needed on the
registration form at least 10 business
days prior to the meeting to allow as
much time as possible to process your
request.
Andrew D, Sawyers,
Dm tor ce of Wastewater Management,
Offn t of It Ul T,
[FR Dot 23796 Filed 11122; 8:45 am]
BILLING CODE 65S0-50-P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA-HQ-OPPT-2022-0835; FRL-10293-
01]
Webinar and Opportunity To Submit
Applications for the Assessment of
Environmental Performance Standards
and Ecolabels for Potential Inclusion In
EPA's Recommendations for Federal
Purchasing
AGENCY: Environmental Protection
Agency (EPA).
ACTION; Notice.
asbessm^nts dgamst Sections I through
IV otthe tramewoik t'U the Assessment
id Em nnnmenldl Peifoinidiice
Standaidb and Lcolab^ls loi federal
Purchasing (trame"u oik) 1 he number of
full d t sm^ntb thai EPA can perform
will depend on thr oumbei of
applicant andaiailabk lesources.
DATES:
Webinar: The Webinar will, be held
virtually on November 15, 2022, from.
1:00 p.m. to 2:30 p.m. EDT. You must
register online at https://
mvw. zo omgo v. com/webin ar/regi sterf
WN^gXXflTpbSdCLgEQWQHsNKQ in
order to receive the webcast meeting
link and audio teleconference
information. EPA encourages timely
registration, but you can register at any
tim e before and up to the start of the
meeting. Once you register, you will
promptly receive an email with the
necessary webcast meeting information.
Applications: On or before January 1,
2023, interested parties must
electronically submit by email to epp%
epa.gov responses to the scoping
questions found at: https://
www.epa.gov/greenerproducts/
framework-assessment-environmental-
performance-standards-and-ecolahels-
federal. Do not submit electronically
any information 3?ou consider to be
Confidential Business Information (CBI)
or other information whose disclosure is
restricted by statute.
Speucla :ommodatwns Requests
foi sptcnl drnanmmldtiiins lui the
Wibm ti should b^ ubmitted on or
befoieN ivmbti 7 2022 toulhm EPA
time to process the i* qursts For
information on access oi sPivictstor
individuals with disabilities, and to
request accommodation for a disability,
please contact Jenna Larkin, listed
under FOR FURTHER INFORMATION
CONTACT.
SUMMARY: The Environmental Protection
Agency fLPAj is expanding the
Recommendations of Specifications,
Standards and Ecolabels for Federal
Purchasing (Recommendations) diid is
seeking manageis ol bl.mddidb
development oigdmzatioiib ecolabel
programs, and abbocidted coiiioiniity
assessment bodies to apply foi potential
assessment and inclusion in the
Recommendations. Interested applicants
should electronically submit, responses
to the scoping questions. Those
considering applying are invited to
attend a webinar hosted by the EPA's
Environmentally Preferable Purchasing
(EPP) Program to learn more and ask
questions about the assessment process.
Once all applications are received, EPA
will issue an estimated timeline for foil
ADDRESSES: EPA has established a
docket tor this action under docket
identification (ID) number EPAHQ-
OPPI2022-UF35 thatisdwildble *
online at https /vuim iemulation*, goi
Additional inbtm^tions on t isitmg the
dorket iloiig with moie mtoim rtion
about (lockets gem lalh is n> ul This notice mav be of specific
inteii st to pt isons who inpu s.-nt
standaids development oigdmVdtions,
ecoldbt-1 piograms dnd dssociated
s. ontoimiti, dsspssment bodies that
manage product or service
emiioiimentdl ppitomidnce stallddids
dnd/or ecolabels that could be
coiisideifd loi use in Unilt-d Stdtes
ledeidl bUbtdiiidblc piocui' ment eltorts,
B What acnon is the Agen^x taking?
EPA is pxpandmqthe
Recommendations of SpecitiCdlions.
Standards and Ecolabelb tin Fedeidl
Purchasing. Interested applicants must
submit then lesponses to the scoping
queblioiib flectiomcdlh to epp"ep(i.gov
\r\ Jdiiuan 1 2023 111' scoping
quebUoiib Cdii be lound in th^ dockt-t or
at https //mui tpago\l
qin'iuipiodu^ts/tiuhh uork-assessment-
i miionmcntal-peifoimance-standards-
and-ecolabf-h-ft'leial
C What is the \qtnc\ s authority for
taking this action1
lliib eiioit dir^cth uppoitb the
lmplf menldtioii ol sc\ eial Executn e
Oideib dnd st ttiitcs
tv-cutr\ e Oidei 14008. entitled
Tdcklmg the Climdte Cusis it Home
dtid Abiisad (86FR7hlM tebiuan 1,
2n21) duects the Fedeidl government to
lead b\ oxamplnand leverage its buying
power to "catalyze private sector
investment into, and accelerate the
advancement of America's industrial
capacity to suppfy domestic clean
energy, buildings, vehicles, and other
necessary products and materials". The
expansion of the Recommendations will
help to spui this maiket demand loi
moie siibtaiiidblfc pioductb diid ben ices.
St-iiiddids dnd pcoldb^lb included in
the Recomm>-nddtioiib will dlbo help to
meet E\ecuti\e Oidei 14030 entitled
Clinidte-Relat^d Fnunci d Risk (86 FR
27067 hla\ 20 2u21) which dnec ts the
Fedeial \cquisibon R^gulatoiy (FAR)
Council to consid" r amending the FAR
to ensnn that majoj piocuiem< nts
minimize the Jisk ot climate change.
The implementing instruction tor
Executive Oid^i i4057 entith d
Cdtdiving Ot an Fn^igy Industnes and
Jobs Thiough Ft deial Sustainabilit^ "
(8b TR 700 35 Decembei Li 2021)
directs EPA to consider expanding the
Recommendations to facilitate net-zero
emissions procurement and other
related sustainable purchasing goals. In
addition, it directs federal purchasers to
prioritize products and services that
address multiple environmental
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 10
Appendix 2. Agenda
U.S. Environmental Protection Agency
Environmental Financial Advisory Board
Public Meeting
Virtual Platform
December 1, 2022
1:00-3:00 pm Eastern Time
WELCOME AND REVIEW OF AGENDA
Edward H. Chu - EFAB Designated Federal Officer
Kerry O'Neill - EFAB Chair
Alejandra Nunez and Tim Profeta - EPA Charge Client
EXECUTION, REPORTING, AND ACCOUNTING WORKGROUP
Ted Chapman and MaryAnna Peavey - Workgroup Co-chairs
PROGRAM STRUCTURE WORKGROUP
Lori Collins and Ashley Allen Jones - Workgroup Co-chairs
OBJECTIVES WORKGROUP
Cynthia Koehler and Margot Kane - Workgroup Co-chairs
RECAP AND WRAP-UP
Edward H. Chu - EFAB Designated Federal Officer
Kerry O'Neill - EFAB Chair
ADJOURN
1:00 pm
1:15 pm
2:00 pm
2:25 pm
2:50 pm
3:00 pm
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 11
Appendix 3. EFAB Members
Ed Chu, Designated Federal Officer
Tara Johnson, Alternate Designated Federal Officer
NAME
AFFILIATION
LOCATION
PERSPECTIVE
REPRESENTED
CURRENT
TERM
ORIGINAL
APPOINTMEN
T DATE
Kerry O'Neill,
EFAB Chair
Chief Executive Officer,
Inclusive Prosperity
Capital, Inc.
Stamford,
Connecticut
(EPA Region 1)
Environmental/
Non-
governmental
Organization
July 20, 2021-
June 15, 2023
July 28, 2020
Ashley Allen Jones
Founder and Chief
Executive Officer, i2
Capital
Washington,
District of Columbia
(EPA Region 3)
Business -
Financial Services
June 21, 2022-
June 15, 2024
July 28, 2020
Courtney L Black
Deputy Finance
Director, City of Kent
Kent, Washington
(EPA Region 10)
State/Local
Government
June 21, 2022-
June 15, 2025
June 21, 2022
Steven J. Bonafonte
Assistant District
Counsel, The
Metropolitan District
of Hartford
Hartford,
Connecticut
(EPA Region 1)
Legal
June 21, 2022-
June 15, 2024
July 28, 2020
Angela Montoya
Bricmont
Chief Finance Officer,
Denver Water
Denver, Colorado
(EPA Region 8)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Matthew T. Brown
Chief Financial Officer
and EVP, Finance and
Procurement, District
of Columbia Water and
Sewer Authority
Washington,
District of Columbia
(EPA Region 3)
State/Local
Government
June 21, 2022-
June 15, 2025
June 21, 2022
Stacy Brown
President and Chief
Executive Officer,
Freberg
Environmental, Inc.
Denver, Colorado
(EPA Region 8)
Business -
Financial Services
June 21, 2022-
June 15, 2024
July 28, 2020
Theodore Chapman
Investment Banking
Analyst, Hilltop
Securities, Inc.
Dallas, Texas
(EPA Region 6)
Business -
Financial Services
July 28, 2020-
June 15, 2023
September 25,
2017
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 12
NAME
AFFILIATION
LOCATION
PERSPECTIVE
REPRESENTED
CURRENT
TERM
ORIGINAL
APPOINTMEN
T DATE
Albert Cho
Senior Vice President,
Chief Strategy and
Digital Officer, Xylem,
Inc.
Washington,
District of Columbia
(EPA Region 3)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
Janet Clements
President and
Founder, One Water
Econ
Loveland, Colorado
(EPA Region 8)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
Lori Collins
Owner and Principal,
Collins Climate
Consulting
Charlotte, North
Carolina
(EPA Region 4)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
Zachary Davidson
Director of
Underwriting,
Ecosystem Investment
Partners
Baltimore,
Maryland
(EPA Region 3)
Business -
Financial Services
June 21, 2022-
June 15, 2024
July 28, 2020
Jeffrey R. Diehl
Chief Executive Officer,
Rhode Island
Infrastructure Bank
Providence, Rhode
Island
(EPA Region 1)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Sonja B. Favors
Industrial Hazardous
Waste Branch Chief,
Alabama Department
on Environmental
Management
Montgomery,
Alabama
(EPA Region 4)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Phyllis R. Garcia
Treasurer, San Antonio
Water
System
San Antonio, Texas
(EPA Region 6)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Eric Hangen
Senior Research
Fellow, Center for
Impact Finance, Carsey
School of Public Policy,
University of New
Hampshire
Danby, Vermont
(EPA Region 1)
Academic
June 21, 2022-
June 15, 2025
June 21, 2022
Edward Henifin
General Manager
(retired), Hampton
Roads Sanitation
District
Virginia Beach,
Virginia
State/Local
Government
July 28, 2020-
June 15, 2023
June 15, 2018
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 13
NAME
AFFILIATION
LOCATION
PERSPECTIVE
REPRESENTED
CURRENT
TERM
ORIGINAL
APPOINTMEN
T DATE
(EPA Region 3)
Barry Hersh
Clinical Professor and
MSRED Chair, School
of Professional Studies,
New York University
New York, New
York (EPA Region 2)
Academic
June 21, 2022-
June 15, 2025
June 21, 2022
Craig Holland
Senior Director of
Urban Investments,
The Nature
Conservancy
Arlington, Virginia
(EPA Region 3)
Environmental/
Non-
governmental
Organization
July 28, 2020-
June 15, 2023
September 25,
2017
Craig A. Hrinkevich
Public Finance Team -
New Jersey Managing
Director, Robert W.
Baird & Company, Inc.
Red Bank, New
Jersey
(EPA Region 2)
Business -
Financial Services
June 21, 2022-
June 15, 2024
July 28, 2020
Margot Kane
Chief Investment
Officer, Spring Point
Partners LLC
Philadelphia,
Pennsylvania
(EPA Region 3)
Business -
Financial Services
June 21, 2022-
June 15, 2024
July 28, 2020
Thomas Karol
General Counsel
Federal, National
Association of Mutual
Insurance Companies
Washington,
District of Columbia
(EPA Region 3)
Legal
June 21, 2022-
June 15, 2025
June 21, 2022
George W. Kelly
Global Client Strategy
Officer,
Earth Recovery
Partners
Denver, Colorado
(EPA Region 8)
Business -
Financial
Services
June 21, 2022-
June 15, 2024
July 28, 2020
Gwendolyn Keyes
Fleming
Partner, DLA Piper LLP
Washington,
District of Columbia
(EPA Region 3)
Legal
June 21, 2022-
June 15, 2025
June 21, 2022
Cynthia Koehler
Executive Director,
WaterNow Alliance
San Francisco,
California
(EPA Region 9)
Environmental/
Non-
governmental
Organization
June 21, 2022-
June 15, 2024
July 28, 2020
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 14
NAME
AFFILIATION
LOCATION
PERSPECTIVE
REPRESENTED
CURRENT
TERM
ORIGINAL
APPOINTMEN
T DATE
Colleen Kokas
Executive Vice
President,
Environmental Liability
Transfer,
Inc.
Lahaska,
Pennsylvania
(EPA Region 3)
Business -
Industry
June 21, 2022-
June 15, 2024
July 28, 2020
Joanne V. Landau
President and Chief
Investment Officer,
Kurtsam Realty Corp.
Croton-on-Hudson,
New York
(EPA Region 2)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
Lawrence Lujan
Executive Director,
Taos Public
Utility Service
Taos, New Mexico
(EPA Region 6)
Tribal
Government
June 21, 2022-
June 15, 2025
June 21, 2022
MaryAnna H. Peavey
Grants and Loans
Bureau Supervisory,
Idaho Department
of Environmental
Quality
Boise, Idaho
(EPA Region 10)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Dennis A. Randolph
City Traffic Engineer,
City of Kalamazoo
Public Services
Department
Kalamazoo,
Michigan
(EPA Region 5)
State/Local
Government
June 21, 2022-
June 15, 2024
July 28, 2020
Eric Rothstein
Principal, Galardi
Rothstein Group
Montreat, North
Carolina
(EPA Region 4)
Business -
Financial Services
July 28, 2020-
June 15, 2023
September 25,
2017
Sanjiv Sinha
Chief Sustainability
Officer, Environmental
Consulting &
Technology, Inc.
Ann Arbor,
Michigan
(EPA Region 5)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
William Stannard
Chairman of the Board,
RAFTELIS
Kansas City,
Missouri
(EPA Region 7)
Business -
Financial Services
July 28, 2020-
June 15, 2023
June 15, 2018
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 15
NAME
AFFILIATION
LOCATION
PERSPECTIVE
REPRESENTED
CURRENT
TERM
ORIGINAL
APPOINTMEN
T DATE
Marilyn Waite
Managing Director,
Climate Finance Fund
Washington,
District of Columbia
(EPA Region 3)
Business -
Financial Services
June 21, 2022-
June 15, 2025
June 21, 2022
David L. Wegner
Senior Consultant on
Water, Climate
Change, and Asset Risk
Assessment, Water
Science and
Technology Board,
National Academy of
Sciences
Tucson, Arizona
(EPA Region 9)
Business -
Industry
June 21, 2022-
June 15, 2025
June 21, 2022
Gwen Yamamoto Lau
Executive Director,
Hawaii Green
Infrastructure Authority
Honolulu, Hawaii
(EPA Region 9)
State/Local
Government
June 21, 2022-
June 15, 2025
June 21, 2022
David Zimmer
Executive Director, New
Jersey Infrastructure
Bank
Lawrenceville, New
Jersey
(EPA Region 2)
State/Local
Government
July 28, 2020-
June 15, 2023
June 15, 2018
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 16
Appendix 4. Slide Presentations
EPA Environmental Financial Advisory Board
GHGRF Charge
Public Meeting
December 1, 2022
What is EFAB?
EFAB is a Federal Advisory
Committee, an independent
advisory body chartered
under the Federal Advisory
Committee Act (FACA) with
members representing
various constituencies
Ail meetings are open to
the public
All materials are available
online via EPA's website
For more information on EFAB, visit:
https://www.epa.gov/waterfinancecenter/efab
Water Infrastructure and Resiliency Finance Center
Envircnmerlal FtnปiKiปl
Environmental Financial Advisory
Board (EFAB)
* "inavlncRfirtia irJorog-aTiTti:1:"Serstwsteฎ lists
r, wfifa . irlba iri rw-gsvei
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 17
Charge Status
EFAB created three (3) workgroups for three (3) categories of charge
questions:
1. Objectives
2. Program Structure
3. Execution, Reporting, and Accountability
Workgroup Progress
Given the extremely compressed timeline of this charge (2 months
vs. 1-2 years), workgroups have drawn on their own expertise and
that of their constituent networks, reviewing public comments and
other readily available literature
Materials shared today are in no way meant to be exhaustive; they
represent deliberations up to this point
Workgroups have largely been working independently, with some
coordination
o Workgroup integration and coordination will be focus of next two (2) weeks
o Overlapping themes will be addressed leading up to December 15, 2022
Today - Check in with full EFAB,
review workgroup progress to date,
and solicit feedback
Critical to raise any concerns as
workgroups head into final two (2)
weeks
Upcoming charge schedule
December 15, 2022-EFAB Public
Meeting to present the final charge
deliverable(s) and vote on approval
Charge Background & Summary
Section 60103 of the Inflation Reduction Act of 2022 - Amended the Clean Air Act to create a new program:
the Greenhouse Gas Reduction Fund (GHGRF)
This first-of-its-kind program will provide competitive grants to mobilize financing and leverage private capital for clean
energy and climate projects that reduce greenhouse gas emissions - with an emphasis on projects that benefit low-income
and disadvantaged communities
The GHGRF provides $27 billion to EPA for expenditure until September 30,2024. This includes:
$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;
Nearly $12 billion for competitive grants to eligible entities to provide financial and technical assistance to projects that
reduce or avoid greenhouse gas emissions; ana
$8 billion for competitive grants to eligible entities to provide financial and technical assistance to projects that reduce or
avoid greenhouse gas emissions in low-income and disadvantaged communities
EPA launched a coordinated stakeholder engagement strategy to help shape the implementation of the
GHGRF and ensure economic and environmental benefits are realized by all Americans.
Public Listening Sessions - November 1 and November 9,2022; recordings available online
Request for Information - Public comment period open until December 5,2022
* EPA present! ei a set of formal change questions on October 13., 2ฉ22
ft on December 15 2022
For more information on the GHGRF at EPA, visit:
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 18
GHGRF Charge - Execution, Reporting, and Accountability
Recap of Tasks / Scope
How to meet key deadlines in the:
Short-term - The 180-day requirement
o Metrics for success - From application to post-implementation
o Responsible implementation and oversight of funding
Medium-term - Next two years before funds expire in 2024
Long-term - Beyond 2024
Execution, Reporting, and Accountability Workgroup
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 19
GHGRF Charge - Execution, Reporting, and Accountability
Metrics for Success - From Application to Post-Implementation
The metrics for success may be published in an Annual GHGRF Summary of Reports from direct
recipients. Metrics could include:
Total 6H6 emissions avoided (estimated metric tons C02)*
o GHG emissions avoided in disadvantaged communities (# and % of Total)
o GHG emissions avoided in non-disadvantaged communities (# and % of Total)
* Total funding awarded to direct recipients
o Total funding ($ and %) deployed and invested in disadvantaged communities
o Total funding ($ and %) deployed and invested in non-disadvantaged communities
o Total funding ($ and %) deployed to indirect recipients
Total funding expended by indirect recipients
o $ and % of funds deployed and invested into disadvantaged communities
ฆ Number of LMI households served
ฆ Estimated energy savings for LMI households
o $ and % of funds deployed and invested into non-disadvantaged communities
Total leverage achieved
o $ and % of leverage (total $ value of projects completed / total $ of GHGRF deployed) in disadvantaged communities
o $ and % of leverage (total $ value of projects completed / total $ of GHGRF deployed) in non-disadvantaged communities
* Continued operability - Self-sufficiency ratio (earned income / total expenses) for direct recipients
* # of jobs created or retained (EPA may choose to adopt SBA's jobs created / retained metric)
*GHG avoided may be reported for Year 1 as well as for life of the system s
GHGRF Charge - Execution, Reporting, and Accountability
Charge Question III.a: Given the tight timeline for implementation of the funds, what are key steps that EPA could take in the short- (next 180 da ys),
medium- (next two years before funds expire in 2024), and long-term (beyond2024)?
Considerations to meet key statutory deadlines:
Now through February 12, 2023
o Public comment period - Now through December 5, 2022
o EFAB GHGRF charge deliverable - December 15, 2022
o Identify fund award priorities, including workable metrics for success
o Develop application review structure and weighting
o Develop appropriate recipient terms and conditions
ฆ Reference other federal programs in place to reduce obstacles to assisting and deploying funds into low-income and disadvantaged
communities
ฆ Explore existing federal templates and best practices that are used to evaluate program effectiveness
February 13, 2023 -> September 30, 2024
o Make funding selection(s); commit and obligate all funding
o Monitor implementation milestones, including fund expenditure by recipients, to ensure funds are appropriately and
sustainably expended
o Evaluate deployment metrics and impact reporting
October 1, 2024 -> Beyond
o Monitor implementation milestones, including fund expenditure by recipients, to ensure funds are appropriately and
sustainably expended
o Evaluate program metrics
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 20
GHGRF Charge - Execution, Reporting, and Accountability
Responsible Implementation and Oversight of Funds - $7B Bucket
Timely deployment of funds to direct recipients (states, municipalities, tribal governments, and
eligible recipients)
o Direct recipient investments into qualified GHG reduction projects benefitting disadvantaged communities
(DC) in the form of loans
o Direct recipient investments into DC in the form of grants, other forms of financial assistance, and technical
assistance
o Direct recipient deployment to indirect recipients
ฆ Indirect recipient investments in qualified GHG reduction projects benefitting DC in the form of grants, loans, or other
forms of financial and technical assistance
Compliance to ensure investments in DC benefit the DC and are not merely located in a DC (e.g..
Utility Scale Solar Farm located in a DC)
Community accountability
o Diverse board composition*
o Historical track record and clean energy expertise to deploy funds to reduce GHG emissions in DC
Transformative application of funds
o Inclusive and non-traditional underwriting and structuring to reach deeper to benefit DC previously locked out
of GHG reduction financing / investments
Where practicable as it may be difficult for government agencies to achieve as directors may be statutorily appointed ฑq
GHGRF Charge - Execution, Reporting, and Accountability
Charge Question III.b; What types of requirements could EPA establish to ensure the responsible implementation and oversight of the funding ?
Existing Federal program examples (not exhaustive)
Program
Strengths*
"" " sses*
EPA Clean Water
State Revolving Fund
ซ Decades-long track record of success as 3 federal program
Spurs good governance and financial profile among eligible recipients to score
high enough to get funded
Maximizes useof limited funds
Reliant on contn
GHGRF is perhaf
EPA Nonpoint Source
Program (CWA Section 319}
* includes streamlining policies that could be replicated for the GHGRF
A September 2022 update includes Ei and equity considerations language
iiticipation to develop eligibility requirements
idpalities/Tribes structure
EPA WIFIA
EPA's OiG has an existing loan award monitoring process that could be
replicated for the GHGRF
any times larger than a typical eligible recipient
A for post-dosing activities and monitoring?
; is prolonged vs. riming requirements in the
HUDC8DG
Formulaic. Apolitical. Easily repticable
includes TA set-asides and targets low-and moderate-income persons
i input. While this ins never a bad thing, would
include non-profiss, WGOs, or businesses
ARRA
* Somewhat comparable example of a targeted federal stimulus
included renewable energy allocations
* Mixed results; net impact reduced over time by sequestration
- Monitoring and audrdngwere challenging
ARPA
Good comparable for getting federal money allocated on a short timeline as
well as setting "spend by" dates for eligible recipients to use the funds
Probably the best fit comparable because it provided funding to both state and
local governments as well as those who would also be GHGRF eligible recipients
ฆ "Need" was mainly defined by previous personal income tax filings? individuals]
and not well defined for businesses
Too early to know if ongoing monitoring and reporting has been effective
*To be integrated with Workgroup 1 (Objectives} and Workgroup 2 (Program Structure)
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 21
GHGRF Charge - Execution, Reporting, and Accountability
Responsible Implementation and Oversight of Funds - $8B Bucket
Transformative application of funds
o Inclusive and non-traditional underwriting and structuring to reach deeper to benefit DC previously locked out
of GHG reduction financing / investments
o # of new green lending organizations established / supported
ฆ Long-term sustainability of green lending organizations receiving GHGRF support
o Financing mechanisms or structures to attract private and other capital to leverage funds
o Fiscally responsible fund deployment to ensure continued operability [of GHGRF funds]
GHGRF Charge - Execution, Reporting, and Accountability
Responsible Implementation and Oversight of Funds - $8B Bucket
Timely deployment of funds to direct recipients (non-depository non-profit organization(s))
o Direct recipient investments into qualified GHG reduction projects benefitting disadvantaged communities
(DC) at the national, regional, state, tribal, and/or local levels
o Direct recipients to prioritize investments in qualified projects that would otherwise lack access to financing
o Direct recipient deployment to indirect recipients
ฆ Indirect Recipients investments in qualified GHG reduction projects benefitting DC
o Indirect investments in the form of funding and technical assistance to establish new or support existing
public, quasi-public, not-for-project, or non-profit entities that provide financial assistance to qualified
projects
Compliance to ensure investments in DC benefit the DC and are not merely located in a DC (e.g..
Utility Scale Solar Farm located in a DC)
Community accountability
o Diverse board composition*
o Historical track-record and clean energy expertise to deploy funds to reduce GHG emissions in DC
Where practicable as it may be difficult for government agencies to achieve as directors may be statutorily appointed ฑi
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 22
GHGRF Charge - Execution, Reporting, and Accountability
Charge Question III. c: What mechanisms could eligible recipients adopt, ineb ding g overna nee as well as other mechanisms, to ensurethattheir
applications andsubsequent implementation efforts ensure; (1} accountability to low-income and disadvantaged communities; (2J green house gas
emission reductions; and (3) the leveraging and recycling ofthegrants?
Mechanisms to ensure
(1) Accountability to low-i
ncome and disadvantaged communities
Accountability Strategy
Considerations for EPA
Application Guardrails
Track record / expertise of applicants in serving LMi and DAC communities
Depth of partnerships with community-based organizations
Federal Requirements
How requirements may impact ability of LMi and DAC-servtng projects to pencil
Governance
Board representation from LMI and DAC communities on recipient and indirect recipient /
subgrantee organizations
Reporting / Metrics
Metrics to capture meaningful co-benefits to communities such as job creation, energy savings,
wealth building
Metrics to track # and $ value of projects serving / benefiting {not just "in") LMI communities
Ciawback /
Redistribution
How application structure / roles of intermediaries enhances or limits the ability to redistribute
funding from underperforming to higher-performing sectors or organizations
iA
GHGRF Charge - Execution, Reporting, and Accountability
Responsible Implementation and Oversight of Funds - $12B Bucket
Timely deployment of funds to direct recipients (non-depository non-profit organization(s))
o Direct recipient investments into qualified GHG reduction projects at the national, regional, state, tribal,
and/or local levels
o Direct recipients to prioritize investments in qualified projects that would otherwise lack access to financing
o Direct recipient deployment to indirect recipients
ฆ Indirect recipient investments in qualified GHG reduction projects
o Indirect investments in the form of funding and technical assistance to establish new or support existing
public, quasi-public, not-for-project, or non-profit entities that provide financial assistance to qualified
projects
Historical track record and clean energy expertise to deploy funds to reduce GHG emissions
Transformative application of funds
o Financing mechanisms or structures to attract private capital to leverage funds
o # of new green lending organizations established / supported
ฆ Long-term sustainability of green lending organizations receiving GHGRF support
o Fiscally responsible fund deployment to ensure continued operability [of GFIGR funds]
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 23
GHGRF Charge - Execution, Reporting, and Accountability
Charge Question III. c: What mechanisms could eligible recipients adopt, in chiding governa nee as well as other mechanisms, to ensurethattheir
applications andsubsequent implementation efforts emu re: {1} accountabiiityto low-income and disadvantaged communities; (2) greenhouse gas
emission reductions; and (3) the leveraging and recycling ofthegrants?
Mechanisms to ensure:
(3) The leveraging arid recycling of the grants
Accountability Strategy
Considerations for EPA
Application Guardrails
Financial capacity / track record of recipient organizations
Finance expertise of recipient / indirect recipients and subgrantees
Federal Requirements
Governance
Reporting / Metrics
Define a consistent measure for leverage (e.g., GHGRF $ / total project costs funded)
Consider how leverage may also happen at multiple levels
Take the long view; Consider how capacity-building investments in a defined value chain may
ultimately unlock larger volumes of investment than focusing on levering capital for shovel-ready
projects
Clawback /
Redistribution
GHGRF Charge - Execution, Reporting, and Accountability
Charge Question ll/.c; What m echanisms could eligible recipients adopt, including g overna nee as well as other mechanisms, to ensurethattheir
applications andsubsequent implementation efforts ensure: (1) accountabiiityto low-income and disadvantaged communities; (2) greenhouse gas
emission reductions; and (3) the leveraging andrecycling ofthegrants?
Mechanisms to ensure:
(2) Greenhouse gas emission reductions
Accountability Strategy
Considerations for EPA
Application Guardrails
Technical knowledge of applicant team (ง> GHG abatement tech
"Systems change" approach of applicant to achieve scaled impacts
Finance expertise of applicant team
Scale of customer relationships / line of sight to GHG projects of applicant team
Federal Requirements
How requirements may impact contractor availability for smaller jobs than nonetheless could scale
in the aggregate to significant abatement
Governance
Reporting / Metrics
Provide a consistent and understandable methodology to help recipients and subgrantees
accurately estimate GHG impacts
Consider when to use "deemed" estimates vs. modeled, measured
Clawback /
Redistribution
Flow application structure / rales of intermediaries enhances or limits the ability to redistribute
funding from underperforming to higher-performing sectors or organizations
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GHGRF Charge - Execution, Reporting, and Accountability
How to promote continued operability?
Accountability Strategy
Considerations for EPA
Application Guardrails
Financial capacity / track record of recipient organizations
Finance expertise of recipient / indirect recipients and subgrantees
Treasury function expertise of applicant team
Federal Requirements
Consider whether permanent (vs. temporary) restriction of funds may promote recycling but
negatively impact ability for leverage, ability to make non-recycled but highly additional
investments
Governance
Fiduciary expertise of board members
Reporting / Metrics
Financial sustainabiiity metrics for applicants, recipients, indirect recipients {e.g., net income,
self-sufficiency)
Take the long view-Consider how market-building activities that don't recycle funds may
set the table for greater business opportunities and hence longer-term operability of
recipients
Claw back /
Redistribution
Consider how intermediation structures may help to mitigate risk of funding riskier indirect
recipients / subgrantees by phasing investment over time
GHGRF Charge - Execution, Reporting, and Accountability
How to ensure additionality of projects?
Accountability Strategy
Considerations for EPA
Application Guardrails
Types of projects that applicants propose to invest in (EPA could encourage / prioritize
applications focusing on project types it thinks are most additional)
Finance expertise of applicant team (ability to ID project not needing subsidy)
Federal Requirements
How requirements might help to avoid funding projects with negative environmental
impacts
How requirements might create costs
Governance
Reporting / Metrics
Additionality is difficult to report / confirm directly; consider proxies (such as project types
or community types that historically are challenged to access capital)
Claw back /
Redistribution
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 25
GHGRF Charge - Program Structure
Evaluation of Structure Options
Focus on six (6) major potential structural options:
1) States / Municipalities /Tribes
2) [Single Entity] National Green Bank / Fund
3) Collective Action - Regional
4) Collective Action - Sectoral
5) Lender Intermediaries
6) Combination of Structures
Provide strengths and weaknesses of each option based on proposed
design requirements
20
Program Structure Workgroup
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GHGRF Charge - Program Structure
1) States / Municipalities/Tribes
Strengths / Rationale
Equitable access to funds for qualified applicants
Public and transparent process to capital distribution
State-level expertise addresses unique needs of each
state related to LMI, GH6 reductions, leverage, etc.
Many states have well established infrastructure to
address GHG solutions (e.g., State Green Banks)
Some tribal fund mechanisms exist that are better
equipped to deal with tribal dynamics
Some states have preexisting state-wide GHG reduction
laws and funds that can be leveraged
Preexisting state infrastructure does not have to be
created and could be utilized in the first 180 days to
ensure expeditious distribution of funds
Weaknesses / Challenges
The competitive application process may disadvantage
states/ municipalities/tribes where political priorities
don't align with statute
Limits coordination across regions and sectors that could
strengthen outcomes
Some states much less existing infrastructure to receive
and distribute funds to disadvantaged communities
There may be differences in definitions between federal
and state laws
GHGRF Charge - Program Structure
1) States / Municipalities /Tribes
Strategy: Solicit competitive proposals from states, municipalities, and tribes and/or allocate funding based on
an EPA-established distribution methodology to qualified applicants
States / municipalities / tribes would then redeploy funds to other eligible recipients, indirect recipients, and for
technical assistance, and perhaps directly to projects
Ask applicants to:
Describe how they will allocate GHGRF funds across their state / municipality / tribe
Underscore how funds will be directly invested in, address barriers to, and/or benefit disadvantaged communities
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
EPA Methodology:
EPA would manage award from Federal level, potentially with internal teams providing first-level review in relation to
requirements and rankings, and expert panels providing second-level review
EPA could use a hybrid award model (like WIFIA) that would create an allocation methodology, with funding
contingent upon meeting qualifications and conditions under the competitive award process
21
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 27
GHGRF Charge - Program Structure
2) National Green Bank / Fund
Strengths / Rationale
Weaknesses / Challenges
Reduced administrative burden to EPA through
centralized management
ฆ Elevated management challenge and longer ramp-up
time to operationalize
Agreements with the funded entity could be structured
to provide flexibility over time, allowing shifts in strategy
ฆ Higher costs of intermediation / multiple layers of
intermediation before funds flow to end users
Provides broadest level of ability for the intermediary to
claw back funds and redistribute them, including across
regions and sectors, to the best opportunities
Probably the strongest structure to administer a "race to
the top" strategy (inter-state competition based on
regulatory reforms) over time
Concentration of funds in one entity elevates financial
management and political risks
Broad scope could create challenges in planning across
the whole value chain for all sectors, engaging
stakeholders broadly, responding to individual
communities
Network of state-level Green Banks and other indirect
recipients currently exist for downstream allocation
Requires new capacity/entity to address the broad remit
and requirements, which could delay timely distribution
of funds
24
GHGRF Charge - Program Structure
2) National Green Bank / Fund
Strategy: Solicit competitive proposals from entities to create and manage a single National Green Bank / Fund
The National Green Bank / Fund would then redeploy funds to other eligible recipients, indirect recipients, and for
technical assistance, and perhaps directly to projects as well
Ask applicants to:
Describe how they will allocate GHGRF funds across the country along a value chain
ฆ Address how funds would address GHG reduction objectives at scale
Underscore how funds will be directly invested in, address barriers to, and/or benefit disadvantaged communities
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
Describe how they will retain, manage, recycle, and monetize repayments to ensure continued operability
EPA Methodology:
EPA would manage award from Federal level, potentially with internal teams providing first-level review in relation to
requirements and rankings, and expert panels providing second-level review
EPA may impose sub-awardee criteria consistent with applicable guidelines
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GHGRF Charge - Program Structure
3) Collective Action - Regional
Strategy: EPA could set forth a pot of funding for regional approaches by either designating a set of regions
(could be EPA regions or other) or by seeking regional partnerships as determined by the applicants
Ask to see applications from partners within the regions (e.g., lead eligible recipient together with indirect recipients,
technical assistance providers, other key players)
Amounts to a series of "regional coordinators " to support GHGRF deployment
Ask applicants to:
Identify regional opportunities, barriers, and priorities for GHG reduction
Describe how the regional partnership would work together to implement a comprehensive strategy responding to
regional needs and interests, including on-the-ground delivery of projects and O&M
Describe how the initiative would be quarterbacked
Address how funds would address GHG reduction objectives within its regional footprint
Underscore how funds will be directly invested in, address barriers to, and/or benefit disadvantaged communities
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
Describe how they will retain, manage, recycle, and monetize repayments to ensure continued operability
EPA Methodology:
EPA could fund at least one application per region
GHGRF Charge - Program Structure
3) Collective Action - Regional
Strengths / Rationale
Encourage applicants to think about all the partnerships
needed to leverage resources, build a robust project
pipeline, and ensure that strong implementation capacity
is in place
Narrowed geographic focus allows for deeper thinking
and a more tailored approach to regional needs
Still allows EPA to manage a more limited number of
regions
Potential identification of community-level collaborations
within regions
If aligned with EPA regions, potentially some ease of
administration for EPA using regional offices
Regional intermediary could exercise clawback at
regional level to re-allocate among regional entities
Weaknesses / Challenges
Requires potential new capacity or entity to address the
"collective action" requirements
ฆ Some structures might be better supported at a national
scale (e.g., secondary market infrastructure, operating
platforms for lenders)
Management of strategies across different sectors within
a region would still be complex and lack consistency and
standardization
Some EPA Regions are not ideally drawn for easy regional
collaboration (e.g., Region 2 - NY, NJ + PR / USVI)
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GHGRF Charge - Program Structure
4) Collective Action - Sectoral
Strengths / Rationale
Weaknesses / Challenges
Promotes innovative thinking and collaboration across
.
National sectoral strategies would still need to account
the whole value chain - demand generation, pipeline
for differences from region to region (e.g., different
creation, implementation, O&M
regulatory regimes, electricity pricing and markets.
EPA could make determinations about certain sectors
climate factors in building design)
where it wants to make larger investments / perceives
Not that many truly national players with a focus on one
greater opportunities
specific sector, although there are some
Greater possibility to build platforms that facilitate
.
Going to a sectors-by-regions approach increases the # of
investment in a specific sector (e.g., Smart-E for single
funded applications and EPA management challenges
family housing energy retrofits)
.
Focus on sectors may limit types of solutions.
Several entities are well positioned to run a sector-based
approach
28
GHGRF Charge - Program Structure
4) Collective Action - Sectoral
Strategy: EPA would ask applicants to propose a strategy to address a particular sector (e.g., multifamily
housing, single-family home retrofits, EVs, or community solar)
Examine barriers and opportunities related to the value chain of activities to generate GHG reductions including
funding and financing, consumer demand generation, training / technical assistance / capacity-building needs,
workforce development and supply chain issues; Variant: EPA could invite sectoral collective applications within
specific regions (such that the total U of applications funded = tt of funded sectors x tt of funded regions)
Ask applicants to:
Pull together partnerships with all the stakeholders needed to address the value chain ("build the ecosystem")
Define sector(s), focus on financing needs and non-financing barriers
Address how funds would address GHG reduction objectives within its sector and timelines
Underscore how funds will be directly invested in, address barriers to, and/or benefit disadvantaged communities
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
Describe how they will retain, manage, recycle, and monetize repayments to ensure continued operability
EPA Methodology:
EPA could define sectors and fund at least one application per sector and define the sectors
Independent sector experts could serve on selection committees
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GHGRF Charge - Program Structure
5) Lender Intermediaries
Strategy: Channel money to green lending programs through existing and established intermediaries
Ask applicants to:
Describe the network of lending organizations they are supporting and the strategies these organizations are using to
finance GHG reduction
Demonstrate the strength and nature of that intermediary's relationship with the organizations in the network
ฆ Detail sectors and geographies served
Show track record in low-income communities and in green lending
Provide network-wide leverage, financing deployment, and GHG reduction goals and supports that would be
provided (e.g., TA, training, capacity building) to both lenders and other key players in the value chain
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
Describe how they will retain, manage, recycle, and monetize repayments to ensure continued operability
EPA Methodology:
EPA could issue awards to select intermediaries targeting a specific financial sector
Eligibility for secondary recipients tied to sector specialization
ป
GHGRF Charge - Program Structure
5) Lender Intermediaries
Strengths / Rationale
Easily the fastest time to market of any of the options
discussed here-the intermediaries and their network
relationships already exist
Relatively low administrative burden to EPA - fund 4 or 5
intermediaries
Provides ability for the intermediary to claw back unused
funds and redistribute them, within-network, to the best
performers
Diversifies risks compared to funding a single applicant
Individual lenders could have flexibility to make plans
tailored to the specific sectors and communities they
serve and stakeholders they partner with
Weaknesses / Challenges
ฆ Has the potential for fragmentation in terms of inability
to encourage lenders of different stripes to work together
ฆ Challenge to ensure that lenders invest adequately in
other value chain supports (e.g., TA or capacity building
for communities, clean energy project developers)
The broad scope of activities in any given lender network
could create challenges in planning and coordination at
the network intermediary level
Current intermediaries have not operated at the scale
required for the GHGRF; therefore, there's some
management and execution risk with ramping up capacity
and capabilities
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 31
GHGRF Charge - Program Structure
6) Combination of Structures
Strengths / Rationale
Reduces risk by distributing funds across a broader
universe of participants (portfolio effect)
Promotes innovative thinking and collaboration across
the whole value chain - demand generation, pipeline
creation, implementation, O&M
Allows EPA determinations about certain sectors and
regions with opportunities for larger or more critical
capacity investments
ฆ Creates balance of scale while ensuring underserved
communities are represented in the process
Greater possibility to build platforms that facilitate
investment in a specific region or sector without
sacrificing national-level capacity
Several entities are well positioned to compete in one or
more priority structure pools
Weaknesses / Challenges
Increases total number of funded applications and EPA
management challenges
Trade-off between EPA challenge in program oversight
and fund allocation versus risks to concentration of funds
in a single entity
GHGRF Charge - Program Structure
6) Combination of Structures
Strategy: EPA could allocate portions of the GHG Fund for national, state, regional, sectoral, and direct
solutions. A larger portion could be dedicated to a national strategy and then smaller distributions could be
made in each other category. Competition would occur within each category
Strategy would examine barriers and opportunities along the GHG value chain including financing, consumer demand
generation, training / technical assistance / capacity-building, workforce development, supply chain issues
Ask applicants to:
Pull together partnerships with all the stakeholders needed to address the value chain in each specific strategy
Define focus in state, region, sector
Focus on financing needs and non-financing barriers
Address how funds would address GHG reduction objectives within its regional footprint
Underscore how funds will be directly invested in, address barriers to, and/or benefit disadvantaged communities
Demonstrate success with deploying capital and innovation that drives additionality in GHG funding and reductions
Describe how they will retain, manage, recycle, and monetize repayments to ensure continued operability
EPA Methodology:
EPA could fund a cohort of applicants with each major strategy represented
Independent experts could serve on selection committees for each type of program
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 32
GHGRF Charge - Program Structure
Potential Design Requirements: EPA Matrix
Charge Question ll.c.i: Are there any potential program design requirements that would impact the ability of recipients to use
the GHGRF program funds?
Potential Program Design Requirements*
Strengths / Rationale
Weaknesses/Challenges
Federal funding requirements
Reasons these are burdens
Financial capacity to manage funds
Governance
Metrics/reporting systems
Due diligence expertise
Capacity to provide grants / debt / equity / credit
enhancements
Collective action systemic change
Sector expertise
Technology expertise
Community access / LMI reach
GHG reduction capacity
Leverage private capital
To be integrated with Workgroups 1 {Objectives) and 3 (Execution, Reporting, and Accountability)
GHGRF Charge - Program Structure
Next Steps
Continuing to coordinate with other EFAB GHGRF charge workgroups
on design requirements
Next EFAB public meeting - December 15, 2022
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 33
GHGRF Charge - Objectives
Workgroup Overview
Provide considerations around the GHGRF's primary purpose:
To fund and/or finance projects intended to reduce GHG emissions that are not being resourced today,
particularly those in low-income and historically disadvantaged communities, because:
o There is a lack of requisite capital at reasonable costs;
o Priority areas for reducing GHGs (e.g., buildings, industry, agriculture, transportation) may not readily lend
themselves to existing funding structures in priority communities;
o There is a lack of technical and human capacity to prepare grant applications; and
o There is a lack of start-up "capital" (e.g., technical assistance and planning grants)
Focused on two areas:
Program Efficiency
o Design Elements
o Complementary Programs and Structures
Environmental Justice / Definition of "Low-Income and Disadvantaged Communities"
o Definition and Support Considerations
o Technical and Financial Assistance, including application support assistance
36
Objectives Workgroup
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 34
GHGRF Charge - Objectives
Overarching Concepts
There may be competing mandates and objectives in the short-term
Leveraging financing and ensuring GHGRF funds flow to disadvantaged communities will not always
lead to prioritizing the same types of projects or community support
In the longer-term, investing in community capacity, technical assistance, and the ability to develop a
wider array of projects and sizes will increase GHG reduction ability on a national level
EPA has flexibility to design the GHGRF to empower states, municipalities, tribes, and eligible entities
to select solutions that accomplish one or multiple objectives well, while ensuring performance of
both in the aggregate
For example, EPA could enable project selection that:
o Prioritizes GHG reduction projects that provide direct benefits to disadvantaged communities, but that will not
necessarily leverage private capital in the short-term (e.g., capacity building, workforce development, reduction
of localized pollution)
o Enhances funding additionality and recycling that may not provide immediate benefits to disadvantaged
communities, but are likely to provide funding sustainability for GHG reduction programs for the longer-term
(beyond 2024)
o Establish performance metrics demonstrating that selected projects in the aggregate to accomplish overarching
objectives
38
GHGRF Charge - Objectives
Overarching Concepts
Balance equity and access with leverage goals
Seek higher levels of financing leverage for projects in communities with greater capacity and
access to resources
Lower leverage requirements for projects requiring some subsidization, associated with less
resourced communities
No leverage requirements for grant funded projects primarily intended to provide various
benefits/technical assistance to disadvantaged communities
Balance need for "shovel-ready" proj'ects with capacity building goals
Goal is rapid deployment
Conventional meaning of "shovel-ready" projects (e.g., designed, engineered, permitted) is
only one path to achieving this goal and could exclude projects that could/should be
supported by one or more of the GHGRF streams
37
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 35
GHGRF Charge - Objectives
Designing for Flexibility to Meet Varying Mandates
Near-term trade-offs between program efficiency and program objectives are:
o Timeline vs. measurable GHG reductions
o Leveraging and recycling vs. capacity building
o Community reach vs. timeline / administrative burden
o Benefits reaching low-income / disadvantaged communities vs. long-term financial sustainability
requirements (grants vs. loans)
o Prioritizing GHG reduction performance in the 1st year of the program could disadvantage efforts to
build low-income community capacity to conduct GHG reduction initiatives
In response, the GHGRF funding streams could be subject to varying weights and objectives in
order to achieve multiple goals. For example:
o $7B to States / Municipalities / Tribes heavily weighted towards capacity building, low-income
community impacts and programs
o $8B
o $12B
Additionally, emphasis should vary based on the nature of both direct and indirect recipients
39
GHGRF Charge - Objectives
Design Elements by Direct Recipient Type
Aligned Recipient
Leverage
Additionally
Capital
Recycling
Capacity
Building
Long-Term
Operability
States / Municipalities/
Tribes
Low weight
High weight
Medium weight
High weight
Low weight
National Green Bank / Fund
High weight
Medium weight
Medium weight
Low weight
High weight
Collective Action - Regional
Medium weight
High weight
Medium weight
High weight
Low weight
Collective Action - Sectoral
High weight
Medium weight
Medium weight
Medium weight
Medium weight
Lender Intermediaries
High weight
Medium weight
High weight
Low weight
High weight
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 36
GHGRF Charge - Objectives
Program Efficiency - Design Elements
Design Element
Strengths / Weaknesses
Strong / Weak Fits
Aligned Recipients
Strengths
Strong Fits
Higher Leverage
Crowds in additional dollars from other
Large asset-backed projects
* States / Municipalities/Tribes
sources
Subordinate tranches In structured funds
National Green Bank / Fund
Enables larger projects
Nonprofit and commercial projects
Lender intermediaries
Leverage: The ability of a
Stretches taxpayer resources further
Residential solar leases
recipient or project to evidence
* Can provide risk mitigation for private capital
additional private sector funding
Weaknesses
Weak Fits
Lower Leverage
sources
ซ Burdensome from 3 structuring and
* Smaller community-based organizations
ซ Collective Action - Regional
transaction cost standpoint
* Sn ties
8 Collective Action - Sectoral
* May increasecostofcapitat
* 5V1; i assistance dollars
ซ Less workable in smaller projects
* Nc roject costs {e.g., pre-
de
Strengths
Strong Fits
More Additiona lity
Enables attribution to leaders, organizations on
Where capita! has historically not been invested
States /Municipalities/Tribes
successful projects
Where funding is clearly taking "de-risking" role
* National Green Bank / Fund
Additionally; Demonstrating
ซ May enable projects in disinvested/
for private capital
* Collective Action - Regional
overlooked communities
ซ Planning and pre-development funding
Combination of Structures
the essential contribution of the
GHGRF to getting the project
Weaknesses
Weak Fits
Less Additionally
done; "but for this funding..."
Challenging to measure and easy to critique
Industrial/ large-scale projects
Collective Action - Sectoral
May complicate decision-making around
Loss-sharingguarantees
eligible projects
Pari passu fundingstructures
Doesn't always collaborate well with other
Senior debt
funding sources
GHGRF Charge - Objectives
Program Efficiency-Design Elements
Charge Question l.b.i:
How can the GHGRF 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 capital to
be recycled over time?
' Where (If at all) is it appropriate to Impose sustainability requirements on direct or indirect beneficiaries of GHGRF funding?
Providing guidance in terms of:
Strengths and weaknesses of each of the above elements by recipient / project type
Strong fits and weak fits of each element by recipient / project types
Examples / case studies of each element by recipient / project types
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 37
GHGRF Charge - Objectives
Program Efficiency - Design Elements
Design Element
Strengths / Weaknesses
Strong / Weak Fits
Aligned Recipients
Capital Recycling: The ability of
recipients to recycle / re-deploy the
funding provided overtime
Strengths
Strong Fits Higher Recycling Ability
of recipients for the long-term ป Financial intermediaries who are lenders NationaiGreen Bank/ Fund
r program funding window is Collective Action - Regional
* Collective Action -Sectoral
Lender Intermediaries
unities
5h payout
Strengths
Evident a
de id~d for rapacity bu'ldng ^uptiort.
Short-Term Capacity Building:
Use of funds is predominantly to hire
expertise / staff to improve
communities' ability to plan -and
execute GHG reduction projects
Higr, nermann rot n-connun t\, 'or.g-tem Hi mar- capdc>*v
Can increase uptake t denana foi f.nanc a I ass stance /
pipeline proieas
strong fits
In communit
to long-term
Stionger Capacity Building
workforce
; local skilled
-ir xr4 t^rm xratnsngs around gram
reporting, and compliance
sforGHG projects
uited to project-specific
Tribe*
3n-Regional
f Structures
GHGRF Charge - Objectives
Program Efficiency - Design Elements
Design Element Strengths / Weaknesses Strong / Weak Fits
Aligned Recipients
Strengths Strong Fits
ป Reassures EPA of recipient's abilities to manage, invest, and
report upon funds in compliant and efficient ways
Recipients with stronger long-term financial sustainabiiity have;
Proven track record of compietingGHGR projects
ป Proven ability to reach low-income and disadvantaged
communities
Long-Term Sustainabiiity Reporting; ป Greater likelihood of project completion
Gte^er g
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 38
GHGRF Charge - Objectives
Additional Considerations / Parking Lot
Considerations related to efficiency elements in program design, including:
Goals around deployment timing / thresholds
o Workgroup 2
Clawback / recapture capability - Both at EPA and direct recipient level
o Workgroup 3
Additional considerations related to overall objectives:
Risk of compromising other supports at the low-income / disadvantaged household level (e.g.,
benefits cliffs with consumer rebate or cash assistance programs)
Accountability to communities - Community voice / feedback loops at EPA, direct, indirect
recipients?
o Workgroup 2
45
GHGRF Charge - Objectives
Program Efficiency - Complementary Programs and Structures
Charge Question
Are there programs/structures at the federal or state level that could effectively complement the GHGRF?
How can EPA best leverage the GHGRF to support lasting, long-term (beyond 2024) transformation of the clean energy and climate
finance ecosystem, especially for disadvantaged communities, and greenhouse gas and other air pollution reductions?
Considerations include:
Where can EPA "piggyback" on existing capacity and pull examples from existing / established
federal programs and initiatives (e.g., Justice40)?
o Highlight existing programs that tie into GHG objectives and reductions and deliver synergistic solutions
(e.g.. National Community Solar Partnership, DOE Energy Efficiency Revolving Loan Fund)
Critical to use federal collaboration to coordinate financial assistance
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 39
GHGRF Charge - Objectives
Program Efficiency - Complementary Programs and Structures
Guiding principles / "good fits":
Share emphasis on low-income / disadvantaged communities (definitions may vary)
Seek defined co-benefits in communities
Share GHG reduction objectives and have ability to measure GHG impacts
Reach communities across the U.S. and/or state-level at a minimum with emphasis on low-
income/ disadvantaged communities
Established relationships with direct recipients, especially states / municipalities / tribes
Nice to haves:
Workforce development components in the "green economy"
Focus on orphan projects / additionality
47
GHGRF Charge - Objectives
Environmental Justice / Definition of "Low-Income and Disadvantaged
Communities" - Definition and Support Considerations
Guiding principles for EPA to consider in defining low-income / disadvantaged
communities:
Provide clarity to all recipients (direct and indirect) and participants;
Acknowledge that no one definition will meet the needs of every region, state,
and/or community;
Acknowledge the importance of defining disadvantaged communities more broadly than by
median income or other existing federal and/or state metrics to ensure inclusive and equitable
access to GHG and localized pollution reduction benefits;
Accept existing Federal program definitions and eligibility criteria;
Accept state definitions (by statute), as applicable;
Encourage the use of EJSCREEN and other Federal mapping tools; and
Acknowledge that existing Federal criteria used today may not be sufficient to capture sub-
populations in large cities as well as unique challenges in rural communities
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 40
GHGRF Charge - Objectives
Project-Level Fund Eligibility: Defining "Low-Income / Disadvantaged Communities"
No one definition will meet the needs of every region, state, and community
Guiding Principle
Strengths / Weaknesses
Acknowledge the importance of defining disadvantaged
communities more broadly
Strengths
Ability to optimize project benefits and expand range of solutions
Enables a more inclusive and equitable access to GHG reduction funds and benefits
Weaknesses
May create tracking challenges
Guardrails needed to ensure the definition does not become all-encompassing
Accept existing Federal program definitions and eligibility
criteria {e.g., HUD's Area Median Income, DHS's Tanf
eligibility criteria, SBA's size standards)
Strengths
Easy for EPA to deploy quickly
Supports standardized reporting nationwide
Allows for eligibility on the household / entity level
Weaknesses
May not be optimized for pollution reductions
May make it harder to include pockets of low-income and disadvantaged communities
that have been historically excluded from Federal support
Accept state definitions (by statute), as applicable
Strengths
Aligns with existing state priorities and funding programs
Prioritized projects on Intended Use Plans could be screened for GHG reduction
potential
Weaknesses
May not be optimized for pollution reductions
May make it harder to include pockets of low-income and disadvantaged communities
that have been historically excluded from state support
49
GHGRF Charge - Objectives
Project-Level Fund Eligibility: Defining "Low-Income/ Disadvantaged Communities"
No one definition will meet the needs of every region, state, and community
Guiding Principle Strengths / Weaknesses
Strengths
Standardized eligibility nationwide
Easy to access
Encourage the use of EJSCREEN and other Federal
Easy for EPA to deploy
mapping tools
Weaknesses
Excludes a significant number of communities
May miss sub-areas and sub-populations within large boundaries
May not be optimized for pollution reductions
Strengths
Ability to optimize for GHG reduction and community co-benefits
Inclusive of sub-populations within larger cities and rural locales lacking critical
Acknowledge that existing Federal criteria used today may
infrastructure
not be sufficient to capture sub-populations in large cities
Inclusive of other important criteria (e.g., health burdens caused by pollution
levels; cost of energy; cost of housing/living; climate fragility, etc.)
as well as unique challenges in rural communities
Weaknesses
Depending on whether the criteria is flexible or formulaic, could be overly
complex without ensuring equitable inclusivity
May create tracking challenges
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 41
GHGRF Charge - Objectives
Environmental Justice / Definition of "Low-Income and Disadvantaged
Communities" - Technical and Financial Assistance*
Charge Question l.a.iii: What kinds of technical and/or financial assistance should GHGRF funding recipients provide to ensure that low-
income and disadvantaged communities are able to be direct or indirect beneficiaries of GHGRF funding? Please identify supports that could
help communities with project implementation.
Type of TA will vary across phases of implementation and based on:
Project Applicants
Project Types
Local Benefit Pathways
o Workforce benefits
o Economic development benefits
o Public health benefits
Issues faced by community
Third parties to coordinate across communities and departments and create capacity to develop, apply, fund,
and implement projects. These could be national or regional organizations or include very localized community
groups. Examples include but are not limited to:
NGO Navigators to provide funding TA for application support
NGOs to provide project development, design, and implementation support
AmeriCorps
State extension programs
Silver Jackets (USACE)
Engineers Without Borders
Senior design projects at accredited university engineering programs
'To be integrated with GHGRF Charge Workgroup 2 (Program Structure) and 3 (Execution, Reporting, and Accountability) 51
GHGRF Charge - Objectives
Environmental Justice / Definition of "Low-Income and Disadvantaged
Communities" - Technical and Financial Assistance
Technical assistance will vary depending on several factors, including:
Who needs assistance (e.g., project developers, communities, local government entities,
households)?
Project type (e.g., buildings, industry, power sector, transportation)
What are the benefits being achieved?
o Funding benefits: TA for application assistance and other "navigator" support
o Local workforce development: TA for project development, design, implementation planning
workforce training, small business development
o Public health: TA for mapping to identify high leverage pollution reduction opportunities / needs;
project design and development, large-scale and more localized projects; performance metrics to
demonstrate connections
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 42
GHGRF Charge - Objectives
Third-Party Service Providers for Various Project Sponsors
TA Partner Examples
Project
Developers
State
Government
and Regional
Entities
Local
Government
Entities
Communities
/ NGOs
Households
Consultants
State extension
programs
AmeriCorps
Engineers Without
Borders
Senior design projects
at accredited university
engineering programs
GHGRF Charge - Objectives
Third-Party Service Providers and Project Expertise - and Cost
to Project Sponsor
State
Local
Government
Entities
Project
TA Partner Examples
Developers
Government
Communities , , ,
Households
/ NGOs
and Regional
Entities
.. . All infrastructure -
Consultants , .
High cost
All infrastructure -
High cost
All infrastructure -
High cost
State extension programs
Local roads
and sewers -
Moderate cost
AmeriCorps
Not needing
stamped plans -
Moderate cost
Not needing
stamped plans -
Moderate cost
Not needing
stamped plans -
Moderate cost
Engineers Without
Borders
Small infrastructure Small infrastructure
- low cost - Low cost
Senior design projects at
accredited university
engineering programs
Small infrastructure
- Very low cost
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 43
GHGRF Charge - Objectives
Financial Assistance - Tools to increase the accessibility of
capital to low-income and disadvantaged communities
Establish tools to facilitate flow of funds through CDFIs, credit unions,
and other established vehicles for low-income communities
For example - Per public comment, Maryland's community solar pilot
program required 30% of its solar capacity to be reserved for projects serving
LMI households
o To further drive adoption of community solar, the state incentivized developers and
investors by guaranteeing to recover any losses from non-payment of bills
o In exchange, developers had to agree to a 20% discount on low-income subscribers'
electricity bills with no credit limits / requirements
GHGRF Charge - Objectives
Financial Assistance - Tools to increase the accessibility of
capital to low-income and disadvantaged communities
Per public comment, establish alternative underwriting criteria
Conventional criteria (e.g., credit score, income, debt-to-income ratio) can
perpetuate racial disparities
Alternative underwriting criteria can provide investor assurances in other
ways (e.g., whether homeowner has consistently paid their utility bills)
Florida's Solar and Energy Loan Fund does not use conventional underwriting
criteria to serve LMI clients, and still achieves a default rate of less than 2%
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Environmental Financial Advisory Board Meeting, Dec. 1, 2022 | 44
GHGRF Charge - Objectives
Indicators of Success
Design element reporting
o Time-bound? (Deployment)
o Leverage
o Additionality
o Recycling
o Sustainability Reporting
Low-income and disadvantaged community reach reporting
Capacity Building and TA progress reporting
GHG reduction reporting
Community benefits reporting
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