The following statement is our public comment to the U.S. Environmental Protection Agency (EPA) on Greenhouse Gas Reduction Fund (GGRF) Accomplishment Reporting:

This public comment is provided by Craftsman Technology Group in response to the information collection request (ICR) related to the Greenhouse Gas Reduction Fund (GGRF) Accomplishment Reporting (EPA ICR Number 2783.01, OMB Control Number 2090–NEW).

Relevant Docket: Docket ID Number EPA–HQ–OA–2023–0393

The Greenhouse Gas Reduction Fund (GGRF) is an unprecedented investment in size and scale that encompasses the need to understand financing solutions, community and program management, and environmental impacts. As a result, the planning, design, delivery, reporting and support components of deploying the GGRF will require a significant investment from both Recipients and Sub-Recipients, in the form of human capital and technology.

In its nearly 10 year history, Craftsman Technology Group (Craftsman) has worked with a wide range of Community Development Financial Institutions (CDFIs) and other mission oriented lenders, including a number of green banks and environmental CDFIs. We have helped these institutions build and/or enhance their technology solutions to track the financing they offer, related technical assistance, and their impact on the borrowers and the communities they serve. Through this process we have seen the challenges these institutions face in implementing their programs, both human and technological, as well as helped them achieve their mission, through our services and support.

As a result, Craftsman Technology Group respectfully wishes that the EPA consider the following comments as part of its information collection request:

• Time to Build Capacity (Human and Technology): Craftsman has spoken to a number of parties interested in the GGRF, and they have mentioned that they will need to significantly invest in their human and technology capacity in order to deploy the funds and manage a program of this size. While CDFIs are intimately knowledgeable regarding practices around financing solutions, many of them are unfamiliar with the specifics related to climate financing, such as: how to establish such a program, how to reach out to the target audience (Do they market to the homeowner? Property owners? Contractors?), what the application process might look like, how to underwrite and close these loans, and ultimately, how to track impact over time. People need to be hired to originate and service these loans. Desired system enhancements range from upgrading their platform to track environmental impact to fully building a new CRM and climate financing platform in anticipation of GGRF funding.  Understandably these institutions wish to make the investments to build their capacity but are reluctant to do so until they receive notice of their awards.

  • Recommendation: Provide Recipients (and their Sub-Recipients) a 6 month period to ramp up their capacity prior to requiring Quarterly Performance Reports.

• Clear Guidelines around Use of Grant Funds for Capacity Building: Under the section labeled 3. Use of Technology, the ICR mentions that the “EPA will allow Recipients to charge the grant awards for costs that support data reporting”.  Later the document outlines the Preliminary Estimates of Burden Hours and Costs, but the assumption for Burden per Response (Hours) is that the Recipient/Sub-Recipient already has a system in place to track reporting needs, and the hours do not include the time required to enhance existing systems or build a new one.  The ICR also states that “Our preliminary estimate of start-up costs is $146,440”. Recipients will therefore need funding to not only pay for the hours to report results, but also to invest in their systems and processes, including the start-up costs. Are these investments and start-up costs covered by the GGRF?

  • Recommendation: Provide Recipients clear guidance and limitations around what they (and their Sub-Recipients) can charge the grant awards for costs that support data reporting, specifically whether awards include investments in infrastructure and human capacity. Ideally the GGRF includes these types of investments since the work cannot be done without them.

  • Recommendation: Provide greater flexibility on the $146,440 figure. Quite a few organizations will need to make more significant investments to adequately upgrade their systems to support the related start-up requirements. Also, please provide a breakdown or rationale for the $146,440 figure.

• Clear Identification and Definition of Environmental Impact Metrics: The ICR mentions measuring Project Benefits such as GHG and air pollution reductions, equity/community benefits, market transformation benefits. However it does not exactly specify what metrics are associated with these reductions and benefits. For example what exactly do Recipients need to track to know the level of air pollution before and after their intervention? What does the EPA mean by equity/community benefits? How is market transformation measured?

  • Recommendation: Provide Recipients with a specific list of environmental and communal impact metrics related to the type of intervention involved, along with clear definitions.  At the same time these impact metrics need to be reasonably easily measured, so as not to cause undue hardship to Recipients when determining the environmental impact of deploying the GGRF.

• Clear Guidelines on How to Measure Environmental and Communal Impact Metrics: After clear definition of desired impact metrics, Recipients then need to know how to track those metrics. For example, how do they measure greenhouse gas reduction? Who is authorized to make these measurements? Can they simply ask any contractor or are specific certifications required? Are they able to track baseline measures along with changes over time?

  • Recommendation: Provide Recipients with clear guidelines on how to measure environmental and communal impact metrics over time.

• Examples and Templates of Reporting Requests: The EPA is collecting data from Recipients through a number of data collection instruments, including Quarterly Performance Reports, Final Narrative reports, Transaction forms, Project forms, etc. Unless Recipients are given examples and further guidance regarding these reporting requirements, they will create their own versions of each of these reports, making aggregation of impact data difficult.

  • Recommendation: Provide examples and templates of each reporting instrument.

• Leverage Existing Reporting Structures: We recognize the unique nature of the GGRF and that it cannot simply replicate another agency’s model. However, many Recipients and Sub-Recipients likely have familiarity with the US Department of Treasury / CDFI Fund reporting models and technology. Where possible, we recommend EPA model its own reporting structures around the existing structures and technology in place at the CDFI Fund. Were EPA to adopt the CDFI Fund model and then modify it to meet its needs, there would be significant efficiency in that awardees would already have a degree of fluency in the terms and model. The infrastructure investment on the part of an awardee could be substantially less.

  • Recommendation: Leverage CDFI Fund reporting models and technology.

The GGRF is a significant milestone in the effort to address the climate crisis. We at Craftsman are excited about the opportunities it presents to many mission-oriented climate financers as well as its potential to reduce greenhouse gas emissions, and will do our best to support this critical initiative.

Many thanks for receiving our comments.
Craftsman Technology Group

Related Documents: