Monica Palmeira

Associate Director of Economic Equity

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Overview: 

The Greenlining Institute submitted comments to the Environmental Protection Agency (EPA) regarding the Greenhouse Gas Reduction Fund (GGRF) and the recently released Implementation Framework (Framework).

We applaud the EPA for moving so quickly to put forth this comprehensive Framework, and for offering several opportunities to provide feedback. Greenlining is supportive of much of what is proposed in the Framework and offers the below recommendations to ensure that the GGRF is the game-changer it is intended to be.

  • Technical assistance opportunities must be made available to low-income and disadvantaged communities to effectively develop a pipeline of potential projects eligible for financing from the GGRF.
  • An evaluation structure must be incorporated into the three competitions and implemented by the grantees.
  • Components of the Program and Organizational Plans listed as “may include” should be required, especially suggestions under the Equity and Community Benefits Plan, Partnerships Plan, Governance Plan, Meaningful Benefits Plan, and Equity Accountability Plan.
  • We support the use of the Climate and Economic Justice Screening Tool (CEJST) as well as Environmental Justice Screen (EJ Screen) Supplemental Indexes to define low-income and disadvantaged communities.
  • We support the prioritization of the three Priority Project Categories of Distributed Power Generation and Storage, Decarbonization Retrofits of Existing Buildings, and Transportation Pollution Reduction, and recommend requiring funding in these categories in the NCIF competition and more flexibility in the CCIA competition.
  • Grants should be considered as “financial assistance” in both the NCIF and CCIA.
  • Caps in the CCIA on capitalization funding and technical assistance should be increased or eliminated.
  • When delivering benefits to American communities, rather than the EPA requiring applicants to demonstrate how projects will alleviate burdens highlighted in the CEJST tool, the EPA should require a more community-driven approach.
  • In the Solar For All competition, the definition of “enabling upgrades” should be expanded to include energy efficiency as well as critical health and safety upgrades.

The comment letter can be found here.

Monica Palmeira

Associate Director of Economic Equity

Read Bio