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PREPARING FOR THE GREENHOUSE GAS REDUCTION FUND

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Frequently Asked Questions

In August 2024, OFN finalized its $2.29 billion EPA grant for the Clean Communities Investment Accelerator (CCIA), part of the $27 billion Greenhouse Gas Reduction Fund (GGRF), to finance the clean energy transition in underinvested communities.

Here we answer our members’ and stakeholders’ most frequently asked questions about the CCIA program. Visit the EPA’s website to see more frequently asked questions about CCIA and GGRF.

Watch CCIA 101

Program

CCIA is a $6 billion program for national nonprofit “hubs” to deliver financial resources and technical assistance to build the climate lending capacity of community lenders working in low-income and disadvantaged communities.

More than 90% of the CCIA funding will pass through the nonprofit awardees (hubs) to community lenders as capitalization and technical assistance subaward funding (see more below).

The awarded nonprofits will provide resources and services to the community lending industry and manage the program in coordination with the EPA over the six-year performance period.

Helpful Terminology

OFN is an awardee of the CCIA program. Awardees may also be referred to as “grantees” or “pass-through entities.” Organizations that receive funding from a grantee or pass-through entity are considered “subawardees.”

Each CCIA awardee, including OFN, will define its own application process, timeline, and requirements.

OFN will inform members of our anticipated application timeline as soon as is practical, but here is generally what you can expect:

  • CCIA award announcement: April 2024
  • Begin CCIA period of performance: August 2024
  • OFN’s first CCIA funding cycle (anticipated): second half of 2024
  • OFN will release a detailed notice of funding opportunity (NOFO) with the first funding cycle.

OFN members and other mission-driven community lenders can begin preparing for the funding opportunity now (see Question 134 below).

This is a six-year program, and there will be multiple funding rounds. 

In August 2024, the EPA obligated funds to all GGRF grantees, including OFN. Once funds have been obligated, they cannot be pulled back, and the November election will not impact the disbursement of these funds.

The communities served by mission-driven community lenders are the very ones most impacted by the effects of climate change.

In 2023, OFN issued a call to action that all CDFIs provide climate loans to mitigate the impact of climate change and help their communities become more resilient.

OFN’s CCIA program is designed to build a pathway to climate lending for all mission-driven community lenders, no matter where you are on your climate lending journey. OFN offers capital and capacity-building resources (and will develop more over the course of the program) for mission lenders seeking to begin or expand climate lending programs.

Eligibility And Funding

To receive CCIA funding from OFN, you must be both an OFN member in good standing (dues paid, annual member survey [AMS] completed) and a community lender according to the EPA’s definition. All certified CDFIs, whether nonprofit or for-profit, are considered community lenders.

For non-certified CDFIs to be considered a community lender, an organization must meet the following 3 requirements:

  • Be either a public, quasi-public, not-for-profit, or nonprofit entity.
  • Have the legal authority to provide financial assistance to qualified projects at the state, local, territorial, or Tribal level or in the District of Columbia.
  • Be eligible to receive a subaward under the EPA’s policy.

OFN will conduct an eligibility evaluation of all funding applicants.

Join OFN

Funding is available to OFN members (certified CDFIs and other mission-driven community lenders) in the form of capitalization funding and technical assistance funding.

Capitalization funding. Capitalization funding must be used to provide financial assistance to CCIA-eligible projects (see below for eligible projects). Capitalization is in the form of a restricted, on-balance-sheet grant.

Award maximum: $10 million in total capitalization funding from all CCIA grantees. OFN may approve certain exception subawards above $10 million.

OFN will provide the following types* of financial assistance:

  • Debt, such as loans, partially forgivable loans, forgivable loans, zero-interest and below-market interest loans, loans paired with interest rate buydowns, secured and unsecured loans, lines of credit, subordinated debt, warehouse lending, loan purchasing programs, and other debt instruments
  • Hybrids, such as mezzanine debt, preferred equity, and other hybrid instruments
  • Credit enhancements, such as loan guarantees, loan guarantee funds, loan loss reserves, and other credit enhancement instruments.

*OFN will not allow equity as a form of financial assistance. However, other CCIA awardees may allow it.

Technical assistance funding. Technical assistance subaward funding is available for capacity building to equip OFN members to provide financial assistance to CCIA-eligible projects. OFN will provide these subawards in the form of subgrants.

Award maximum: $1 million in total technical assistance subawards from all CCIA grantees. OFN may approve certain exception subawards over $1 million.

Technical assistance activities include, but are not limited to:

  • Procuring training, market analysis, and technical support
  • Hiring staff
  • Developing new financial products
  • Supporting pre-development activities, such as site and building assessments (e.g., energy audits), financial and technological feasibility studies (e.g., solar resource studies), design and engineering support, and permitting support.

OFN members must be selected for capitalization funding in order to receive a technical assistance subaward. OFN will provide other resources to help mission-driven community lenders find a path to access CCIA funding.

Use of Funds

Funding received through the GGRF programs may only be used on eligible projects. For CCIA, funding must support a project, activity, or technology that meets all the requirements for the three criteria outlined below:

Criteria A: Qualified Project

  • Reduces or avoids greenhouse gas emissions (including carbon dioxide, hydrofluorocarbons, methane, nitrous oxide, perfluorocarbons, and sulfur hexafluoride) consistent with the climate goals of the United States
  • Reduces or avoids emissions of other air pollutants
  • Delivers additional benefits to American communities within one or more of the following seven categories:
    • Climate change
    • Clean energy and energy efficiency
    • Clean transportation
    • Affordable and sustainable housing
    • Training and workforce development
    • Remediation and reduction of legacy pollution
    • Development of critical clean water infrastructure
  • Would not otherwise have been financed
  • Mobilizes private capital
  • Uses only commercial technologies

Criteria B: Priority Project

  • Falls within at least one of the following three priority project categories:
    • Distributed energy generation and storage
    • Net-zero emissions buildings
    • Zero-emissions transportation

Criteria C: Low-income and Disadvantaged Community

  • Serves a low-income and disadvantaged community (LIDAC), defined as
    • Climate and Economic Justice Screening Tool (CEJST)-identified disadvantaged communities
    • EJScreen-identified disadvantaged communities
    • Geographically dispersed low-income households
    • Properties providing affordable housing
    • See additional definition criteria below.

CCIA funds must be used to support projects in LIDACs. The EPA’s definition includes the following: :

  • Climate and Economic Justice Screening Tool (CEJST)-identified disadvantaged communities
  • EJScreen-identified disadvantaged communities
  • Geographically dispersed low-income households: low-income individuals and households that fall within either of the two categories listed below:
    • Individuals and households with incomes at or below the greater of:
      • For Metropolitan Areas: 80% Area Median Income (AMI) or 200% of the Federal Poverty Level
      • For Non-Metropolitan Areas: 80% AMI; 80% Statewide Non-Metropolitan Area AMI; or 200% of the Federal Poverty Level
    • Individuals and households currently approved for assistance from or participation in at least one of the following income-based or income-verified federal assistance programs, with an award letter within the last 12 months:
      • Department of Health and Human Services (HHS) Low Income Home Energy Assistance Program;
      • Department of Agriculture (USDA) Supplemental Nutrition Assistance Program;
      • Department of Energy (DOE) Weatherization Assistance Program;
      • Federal Communications Commission Lifeline Support for Affordable Communications;
      • USDA National School Lunch Program;
      • Social Security Administration Supplemental Security Income;
      • or any other verified government or non-profit program serving Asset Limited, Income Constrained, Employed (ALICE) individuals or households designated by the EPA Administrator
  • Properties providing affordable housing. Includes properties serving low-income individuals and households that fall within either of the two categories listed below.
    1. Multifamily housing with rents ≤ 30% of 80% AMI for at least half of residential units and with an active affordability covenant from one of the following federal or state housing assistance programs:
      • Low-Income Housing Tax Credit; A housing assistance program administered by the U.S. Department of Housing and Urban Development (HUD), including Public Housing, Section 8 Project-Based Rental Assistance, Section 202 Housing for the Elderly, Section 811 Housing for Disabled, Housing Trust Fund, Home Investment Partnership Program Affordable Rental and Homeowner Units, Permanent Supportive Housing, and other programs focused on the goal of ending homelessness funded under HUD’s Continuum of Care Program;
      • A housing assistance program administered by USDA under Title V of the Housing Act of 1949, including under Sections 514 and 515;
      • A housing assistance program administered by a tribally designated housing entity, as defined in Section 4(22) of the Native American Housing Assistance and Self-Determination Act of 1996 (25 USC § 4103(22)); or
      • Any other housing assistance program designated by the EPA Administrator
    2. Naturally occurring (unsubsidized) affordable housing with rents not exceeding 30% of 80% AMI for at least half of residential units

Commercial technology is defined as “technologies that have been deployed for commercial purposes at least three times for a period of at least five years each in the United States for the same general purpose as the project, activity, or technology.”

The “commercial technology” requirement in the definition of qualified projects applies to classes of technologies (e.g. heat pump) rather than an individual equipment manufacturer (e.g., a specific brand/model of heat pump). For example, financing heat pumps for heating and cooling would meet the commercial technology requirement because heat pumps have been deployed for commercial purposes at least three times for a period of at least five years each in the United States for the same general purpose (heating and cooling). A new heat pump brand/model would therefore meet the “commercial technology” requirement, even if it is a new original equipment manufacturer product.

Reporting and Compliance

Recipients of funding, both grantees and subawardees, will require significant reporting and compliance with federal regulations.

Reporting will be required semiannually and annually and will include specific technical information, including greenhouse gas reduction emissions and transaction-level details.

Subawardees must comply with 2 CFR 200 and be subject to single audit requirements if more than $750,000 in federal funds are expended annually.

CCIA is a six-year program with multiple rounds of funding and continual monitoring by EPA during that time. At the end of the performance period, grantees and subawardees will undergo a close-out process with EPA, although the details of this process are not currently known.

No, subawardees will need to report on projected GHG emissions reductions. OFN will provide further guidance on methodologies or tools which subawardees can use for reporting.

As applicable, subawardees will need to comply with the requirements listed below. OFN will assist subawardees with guidance to understand and manage the requirements.

  • Davis-Bacon and Related Acts (DBRA): DBRA labor standards apply to construction projects funded by CCIA. However, the timing and purpose of the CCIA funding can impact whether DBRA requirements are triggered. OFN will provide more guidance as soon as it becomes available from the EPA.
    • DBRA requires contractors and subcontractors to pay employed laborers and mechanics no less than locally prevailing wages. DBRA applies to contractors and subcontractors performing construction, alteration, or repair of buildings in excess of $2,000. Activities such as the installation of solar panels, installation of heat pumps, and retrofits of buildings for energy efficiency are considered construction projects. DBRA does not apply to pre-construction activities, such as environmental assessments, site acquisition, permitting, and engineering and design.
  • Build America Buy America (BABA): BABA establishes a domestic procurement preference for all federal financial assistance. BABA requires that all iron, steel, manufactured products, and construction materials used in projects be produced in the U.S. BABA does not apply to projects involving private homes.
  • National Historic Preservation Act (if applicable): This act establishes permanent institutions and creates a clearly defined process for historic preservation in the U.S. Historic structures affected by federally-funded projects must be documented to standards issued by the Secretary of the Interior.
  • Endangered Species Act (if applicable): CCIA-funded activities must not be likely to jeopardize the existence of any listed endangered species.
  • Coastal Zone Management Act (if applicable): CCIA-funded activities in coastal areas must be consistent with state coastal zone management plans that have been approved by the Department of Commerce.

 

 

OFN Support

Yes. OFN will provide technical assistance to help OFN members and other mission-driven community lenders find a path to access CCIA program funding for distributed energy generation and storage, net-zero emissions buildings, and zero-emissions transportation.

The suite of services will include nascent climate lender training and a climate help desk that will offer strategy-level and project-level assistance. OFN members, industry practitioners, and partners can always access climate lending resources in our resource library and learn from other practitioners on CDFI Connect.

If awarded funding, OFN will provide additional details and specifics on OFN’s CCIA program as soon as possible. In the meantime, OFN members and other mission lenders may prepare in several ways:

  • Sign up for an upcoming OFN climate lending training.
  • Join the Climate Mitigation and Adaptation Community on CDFI Connect.
  • Get familiar with the program by watching our CCIA 101 webinar.
  • Get familiar with eligible uses of CCIA funding (see above).
  • Get familiar with CCIA-eligible projects (see requirements above).
  • Ensure your organization’s processes are 2 CFR 200 compliant.
  • Understand single audit requirements.
  • Begin to build a pipeline of eligible projects.
  • Begin developing a strategy and plan to support your subaward application that includes the following:
    • A plan for the use of capitalization funding that aligns with the CCIA program objectives and OFN’s investment objectives (details to come)
    • A plan and budget for the use of technical assistance subaward funding received by the applicant to support the deployment of capitalization funding
    • Details on how your plan will deliver broader positive outcomes, such as:
      • Creation of high-quality jobs with a diverse, skilled workforce
      • Consumer protection across all entities that interact, transact, or contract with a consumer
      • Maintaining the affordability of existing housing stock, minimizing displacement, and preventing rapid cost increases.

Carbon emissions, clean energy, and climate change may not resonate with your communities, but there are related messages that may convince community members to act. For example:

  • Reduced energy costs: Energy efficiency upgrades reduce utility costs for homeowners and businesses, as do solar and battery installations.
  • Resilience against extreme weather impacts: Upgrades have the added benefits of providing resiliency against weather-related power outages and increasing home values.
  • Healthier communities: Choosing clean energy solutions, like electric vehicles and stoves, reduces air pollution in our homes, neighborhoods, and near our roadways.
  • Good jobs: Clean and renewable energy projects bring many good quality jobs to your community, which may attract additional investment.

OFN will provide marketing and messaging materials to help OFN members and other mission lenders reach diverse audiences with climate lending products.

Other

Yes. Organizations can apply for CCIA funds from multiple CCIA awardees. However, the maximum amount of CCIA funds that a single organization can receive is $10 million, unless an exception is granted. Each CCIA awardee may have different exception criteria.

NCIF is the National Clean Investment Fund, a $14 billion program of the Greenhouse Gas Reduction Fund to establish national clean financing institutions that deliver accessible, affordable financing for clean technology projects nationwide.

EPA selected three entities for NCIF funding: Climate United Fund, Coalition for Green Capital, and Power Forward Communities.

Organizations can apply for NCIF funding in addition to CCIA funding.

No, it does not. An organization can receive $10 in capitalization funding from CCIA and still be eligible to receive an investment from the NCIF.

Individuals, businesses, or organizations that are not community lenders are not able to apply directly for CCIA funding from OFN. However, they can access CCIA funding through OFN members that have received CCIA funds. These members will then finance CCIA-eligible projects in their communities.

Contact your local CDFI to learn if they plan to participate in this program.

If you’re interested in partnering with OFN on the historic CCIA program, please fill out this partner interest form. If you are looking for open positions or procurement opportunities, please visit our Work with OFN page.

These FAQs will be updated as often as practical with new questions and answers and the latest information. If you have a time-sensitive question that is not answered here or wish to suggest that we include an additional question and answer, please send an email to [email protected].

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