This week, we submitted an official public comment to the US Environmental Protection Agency (EPA), sharing our feedback on their Greenhouse Gas Reduction Fund (GGRF) Accomplishment Reporting. This is our second official public comment to the EPA, following our initial comments in April 2024.

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

Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Comment Request; Greenhouse Gas Reduction Fund Accomplishment Reporting

This public comment is provided by Craftsman Technology Group (CTG) in response to the information collection request (ICR) related to the Greenhouse Gas Reduction Fund (GGRF) Accomplishment Reporting (Docket ID Number EPA-HQ-OA-2023-0393).

Please note that the Coalition for Green Capital (CGC) has endorsed our comments in their submission:

The Greenhouse Gas Reduction Fund (GGRF) is an unprecedented investment in size and scale that encompasses the need to understand financing solutions, community/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.

Over the past 10 years, CTG 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 design their CRM systems to build the optimal structure to meet both functional and reporting needs, using the flexibility of Salesforce and other integrated tools. We have extensive experience building dashboards and reports related to complex transactions, projects and impact/benefits for the CDFI Fund and other funder reporting. This, along with our careful review of critical files the EPA has provided, including the data dictionary, related flat files, reporting templates, as well as direct Q&A with the EPA in sessions with the awardees, provides the foundation for our comments for this ICR.

Craftsman Technology Group respectfully wishes that the EPA consider the following comments as part of its Information Collection Request:

General Comments

We believe the following recommendations will reduce the overall complexity of reporting while maintaining the integrity of outcome tracking. Our recommendations better align with the requirements other agencies and funders have in place now – thereby allowing organizations to build on existing structures vs. creating a custom reporting model.

• Reporting Burden: CTG understands that the EPA wishes to be comprehensive and thorough in its reporting related to the GGRF. However, the structure, detail, and complexity create a significant reporting burden for recipients and does not distinguish between critical measures and nice to haves. CTG recommends the EPA focus reporting on the most critical measures and layer in additional detail as their need and priority are solidified.

  • Benefits as a child of the Project Site record: This is an example of the reporting burden – Our understanding is if a Project has 20 Project Sites, then according to the EPA reporting structure, the Awardee or Recipient needs to provide 1 Benefit record for each Project Site, so 20 Benefit records. A simplified structure would be to aggregate benefits at the Project level instead of the Project Site.

• Reporting Period: Please clarify how long the expected reporting period in years for Awardees (and therefore Subrecipients) will be to the EPA. This will inform data retention policies and has the potential to impact privacy policies.

• Reporting Instructions: Given the complex reporting structure related to the EPA flat files, CTG recommends clear reporting instructions with concrete examples of what the data might look like, catering to the most common use cases. This will help ensure Awardees and Subrecipients can grasp critical relationships between Transactions, Projects, Project Sites, and Benefits.

Appendix D. Transaction and Project System Flat File Templates

• Transactions-Intermediaries, Transactions-EndBeneficiaries and Transactions-Administrative: We notice that the fields requested in these tabs are identical. Our recommendation is to combine these into 1 flat file with a field called Transaction Category where the options are Intermediaries, End Beneficiaries and Administrative.

• IDs: Please clarify if the IDs are mutually exclusive across flat files.

• Structural Components: We have provided an Entity Relationship Diagram (ERD) to better articulate how we would see a data model aligning with the reporting templates provided by the EPA. We believe this ERD better accommodates common data models and data management practices across the CDFI sector. Boxes highlighted in yellow correspond to those in the EPA ERD; the term “Project” can denote a single project or a portfolio of projects.

Based on our conceptual view of Transactions, Projects, etc. above, we have the following questions:

• Tab 1-Transactions-Intermediaries and Tab 2-Transactions-EndBeneficiaries

  • Structural Questions

    • Column AX: Project Identifier – Grantee: If the Transaction to the Intermediary results in multiple Projects, based on the reporting meeting with Awardees on 09.19.2024, Awardees should have 1 row for the Transaction, but within that row list multiple Projects associated with that Transaction, correct? However if so:

    • Columns BE-BM: Project Title to Project Financing Stage: do we list each Project Title, Project Sponsor Names, Project Sponsor Addresses, etc. within one row for each Transaction, even if there are multiple Projects involved? Wouldn’t it be more expedient to move these fields to the Project tab, with reference to the appropriate Transaction via the Transaction Identifier – Grantee and Transaction Identifier – EPA? This comment also applies to Columns BP, BS and BT.

    • Columns BN-BO, BQ-BR: Project Financing Source (Public) and Project Financing Source (Private): If there are multiple Project Financing Sources for each Project, should we list each one? In which case will the Transaction record potentially grow in row height, a) for multiple Projects and b) for within a Project, multiple Project Financing Sources? Wouldn’t it be more expedient to move individual Project Financing Source information to another tab called 7-Financing Sources, and include the Project Identifier – Grantee and Project Identifier – EPA fields as a reference?

      • Does Project Financing Source include funding from the related GGRF Transactions? We are assuming that the GGRF Transaction should not be listed as a Project Financing Source, since it is accounted for in the parent Transaction. Unless we want to identify what portion of the GGRF Transaction went into the Project Financing Source if multiple Projects are involved.

      • The Data Dictionary does not provide a clear definition for these fields: “Define brightline between PUBLIC and PRIVATE funds; what about foundation grants, e.g.?”

  • Detailed Questions

    • Column M: Investee or Borrower or Recipient – LIDAC Type: This does not match the title in the Data Dictionary for DE096, which is “Does Project Qualify as LIDAC?”. Should the title be renamed in the Data Dictionary to something more generic like “LIDAC?” or this field removed from Column M?

    • Column N: Qualifies as LIDAC in CEJST?: In the Data Dictionary, field DE263 is called “Does Project Site Qualify as LIDAC in CEJST”, and the definition refers to Project and Project Site. Should the title and definition be renamed in the Data Dictionary or this field removed from Column N?

    • Column P and Z: Transaction Date and Date Originated: What is the difference? Is Date Originated the date the closing documents are signed, and Transaction Date the date that money changed hands?

    • Column BN: Project Financing Source (Public) – Name: The title of this field includes “Name”, while according to the Data Dictionary the information provided should be one of 4 picklist options: FEDERAL; STATE; LOCAL; OTHER-GOVERNMENT. Should we name the public source or use the picklist?

• Tab 3-Transactions-Administrative

  • General Questions

    • Non Financing Transactions: How does one fit payroll, systems development costs, and professional services in the flat file set-up, Tab 3-TRANSACTIONS-ADMINISTRATIVE, with lending type fields such as Financial Assistance Type, Principal Amount, Interest Rate, Interest Type, Delinquency, etc. Should all these be NA?

    • Payroll: We are assuming that the Awardee does not need to report on each individual employee involved in GGRF, but rather the aggregate amount allocated to payroll for the reporting period?

• Tab 4-Projects

  • Detailed Questions

    • Column B: GGRF Program: The relevant field should be DE001, not DE002. Unless the title is wrong, and it should be Recipient Name instead of GGRF Program.

    • Column K: Project Resiliency Measures: The Data Dictionary only defines 1 picklist option for this field.

    • Column L: Does Project Qualify as LIDAC?: Is there a threshold measure for this? For example, if the project involves 10 project sites, 5 of which are located in LIDACs, 5 of which are in affluent communities, would it qualify as LIDAC? How about if 1 is located in LIDAC, then 9 are in affluent communities? And also what if the work on the project sites are not equal in size? Should we use some kind of dollar percentage invested in LIDAC as a threshold?

    • Column AA: Project Status: Options include Started, Complete and Cancelled. What if the project has not started yet? Should we leave this field blank, or should we add another option called “Not Yet Started”?

    • Columns AA-AD: Project Status to Project Placed in Service Date: Is the expectation that each quarter the Grantee will report on these metrics for all Projects, so that each quarter the Grantee will report on all Projects since the beginning of the grant, and update these fields?

    • Column AD: Project Placed in Service Date: Is there a requirement for Projects to be completed by a specific date? Noting that it may be easily more than 3-4 years for a Project to be placed in service, especially if the financing starts with pre-development costs.

    • Column BD: Transmission Project type: Data Dictionary indicates that the picklist values are TBD

    • Column BS: Net-Zero Calculation Method: Data Dictionary indicates that the picklist values are TBD

    • Column DJ: Fuel consumption unit: Data Dictionary indicates that the picklist values are TBD.

    • Column DS: Renewable Natural Gas (RNG) Source: Data Dictionary indicates that the picklist values are TBD

    • *Suggested New* Column ES: Transaction Identifier-EPA: Thinking that the EPA would want this information linked to Projects. Of course this field can be moved earlier next to Transaction Identifier – Grantee. For now it is placed here to ensure that columns match original EPA flat files.

• Tab 6-Benefits

  • Structural Question

    • Parent Object of Benefits: According to the EPA ERD, Benefits are a child object of the Project Site. If this is the case (please confirm), and not directly a child of the Project itself, then we are assuming that each Project Site will have at least one Benefit record. In this case we may want to add the fields Project Site Identifier – Grantee and Project Site Identifier – EPA to the 7-Benefits tab.

    • Projected vs. Actual: Just confirming that the Benefits that Awardees need to report are just projected benefits, not actual?

Please see attached Appendix D. Transaction and Project System Flat File Templates_CTG to see our suggestions regarding the reporting flat files.

2024-08-26 EPA GGRF ICR Engagement Presentation

• Slide 8

  • Transactions and Projects Report due Quarterly for NCIF grantees: Does this consist of all the flat files mentioned in slide 12?

  • Annual Reports: Assume a template will be provided by the EPA?

• Slide 14

  • Transaction identifiers (say, for multiple disbursements): If one investment (such as a construction loan) has multiple disbursements, would that be multiple Transactions? Or is the EPA thinking in this case that this would constitute 1 Transaction?

Appendix E. NCIF and CCIA Semi-annual Progress Report Template

• Semi-Annual Metrics

  • For Income Type, would Total include all the categories above it from Principal Repayment to Other Program Income Generated, and then subtract Costs Incidental to Generation of Program Income? Or do we just include the total from Principal Repayment to Other Program Income Generated, and not subtract Costs Incidental to Generation of Program Income?

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

Many thanks for reviewing our comments,
Craftsman Technology Group