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Capitalizing on the Greenhouse Gas Reduction Fund for renewable energy
Apr 02, 2024 · Authored by Joel M. Laubenstein, Tyler R. Inda, Serena Walters
What implications does the Greenhouse Gas Reduction Fund (GGRF) hold for the renewable energy landscape, and how can organizations strategically prepare for it?
The GGRF, with its substantial $27 billion allocation, presents an opportunity for stakeholders in the renewable energy sector, including states, investors, developers, Community Development Financial Institutions (CDFIs), Community Lenders and tribal entities. By leveraging this fund, organizations can accelerate the deployment of energy generation and energy efficiency solutions. The GGRF will lead to the emergence of green banks and increased capital investment in renewable energy solutions, thereby creating a robust pipeline for real estate and energy projects.
Overall program: Through financial assistance (i.e. grants, subsidies, rebates, loans or other incentives) and technical assistance, communities, developers and homeowners can transition residential properties to be powered by solar energy. Except for six, all states received funding to implement Solar for All programs. States that opted out include: Florida, Idaho, Montana, North Dakota, Nevada and South Dakota. However, projects within these states can receive funding through the funding for American Indian and Alaskan Native Program and the Multi-State Program managed by Solar for All recipient not-for-profits or municipalities serving the area.
What are qualified projects:
- Eligible Zero Emissions Technology, Section 134(a)(1) of the Clean Air Act provides that grants be used to provide financial assistance and technical assistance “to enable low-income and disadvantaged communities to deploy or benefit from zero-emissions technologies.” Section 134(c)(4) of the Clean Air Act provides that the term zero-emissions technology means any technology that produces zero emissions of (a) any air pollutant that is listed in section 108(a) (or any precursor to such an air pollutant) and (b) any greenhouse gas. The U.S. Environmental Protection Agency (EPA) is implementing this statutory language by identifying the four technology categories that exclusively qualify for financial and technical assistance from section 134(a)(1). These technology categories are defined below. Please note that “distributed solar” is used to refer to residential rooftop and residential-serving community solar throughout this Notice of Funding Opportunities (NOFO).
- Residential rooftop solar: Behind-the-meter solar photovoltaic (PV) power-producing facilities, including rooftop, pole-mounted, and ground-mounted PV systems, that support individual households in existing and new single-family homes, manufactured homes and multifamily buildings. The definition of residential rooftop solar includes behind-the-meter solar facilities serving multifamily buildings classified as commercial buildings so long as the solar facility benefits individual households either directly or indirectly such as through tenant benefit agreements. Residential rooftop solar includes properties that are both rented and owned.
- Residential-serving community solar: A solar PV power-producing facility or solar energy purchasing program from a power-producing facility, with up to 5 milliwatts (mw) nameplate capacity, that delivers at least 50% of the power generated from the system to multiple residential customers within the same utility territory as the facility. There are a variety of community solar ownership models that can be considered, including community-owned solar, third-party-owned community solar and utility-owned community solar.
- Associated storage: Infrastructure to store solar-generated power for the purposes of maximizing residential rooftop and residential-serving community solar deployment, delivering demand response needs, aggregating assets into virtual power plants and delivering residential power during grid outages. Financial assistance for associated storage must be deployed in conjunction with financial assistance for a solar PV system and the storage asset must be connected to the solar PV system.
- Enabling upgrades: Investments in energy and building infrastructure that are necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project. Enabling upgrades can include, but are not limited to, electrical system upgrades, structural building repairs and energy efficiency. Applicants may decide the exact types of enabling upgrades that are eligible for Solar for All financial assistance, yet all enabling upgrades should be energy and building infrastructure related and deployed in conjunction with financial assistance for an eligible solar PV system. Financial assistance for enabling upgrades may comprise up to 20% of the total financial assistance deployed during the lifetime of the program.
What types of projects are eligible under Solar for All: Eligible projects under the accelerator fund must meet the following criteria:
- Must be a qualified project;
- Must be in a low-income and disadvantaged community. The following mapping tool identifies eligible Justice40 communities: Climate and Economic Justice Screening tool (CEJST)
Overall program: Community Lenders have the right to receive up to $10 million to provide financial assistance and $1 million in technical assistance for staff and overhead. It is expected that the financial assistance to projects will be provided on more favorable terms than market. The financial assistance is deemed to be a loan, it can be forgivable if the Community Lender desires. Community Lenders are only able to access the $10 million once they have identified a qualified project to deploy the capital into.
Who are Community Lenders: New or existing public, quasi-public or not-for-profit entities that provide financial assistance to qualified projects at the state, local, territorial or tribal level or in the District of Columbia, including community- and low-income-focused lenders and capital providers. This includes but not limited too:
- CDFIs, Minority Deposit Institutions, credit unions, housing finance agencies and other types of lenders
- Community Lenders cannot provide financial assistance to their own project
What are qualified projects: Section 134(c)(3) of the Clean Air Act provides that qualified projects include any project, activity or technology that (A) reduces or avoids greenhouse gas emissions and other forms of air pollution in partnership with, and by leveraging investment from, the private sector; or (B) assists communities in the efforts of those communities to reduce or avoid greenhouse gas emissions and other forms of air pollution. EPA expects to implement this statutory language by requiring that all projects meet all of the requirements listed below, which ensures all projects meet the statutory definition while also supporting the GGRF program objectives. EPA expects that each applicant will define their methodology for operationalizing these requirements in their application. EPA expects to define these requirements as follows:
- Deployment of the proposed project, activity or technology will reduce greenhouse gas emissions in line with the U.S. Nationally Determined Contribution as well as Executive Order 14008 and will reduce emissions of other air pollutants. Specific portfolio-wide emissions targets may be set in the NOFO, and plans that equitably achieve the deepest emissions targets may be prioritized.
- Deployment of the proposed project, technology or activity will deliver benefits to American communities by alleviating two or more of the following categories of burdens, as defined in the methodology section of the CEJST: climate change, energy, health, housing, legacy pollution, transportation, water and wastewater and workforce development.
- Investment of awarded funds in the proposed project, technology or activity will finance deployment of a project, activity or technology that may not have otherwise been financed. EPA expects this to involve substantially better than market interest rates passing through to borrowers.
- Investment of awarded funds in the proposed project, technology or activity will spur private sector investment.
- The proposed project, technology or activity is already commercially available. Under this competition, EPA does not intend for program funds to support either (1) research and development, as defined in 2 CFR section 200.1, or (2) pre-commercial technologies, as defined by technologies that have not been installed and used in at least three commercial projects in the United States in the same general application.
Priority project categories: EPA has identified three priority project categories that are particularly impactful to achieving the GGRF program objectives and the near-term climate goals of the United States. EPA expects each applicant to explain their approach to these priority project categories in their investment strategies, but EPA expects to provide each applicant with flexibility to (1) invest in additional project categories and (2) not invest in any given priority project category, provided this decision is accompanied with a supporting explanation. EPA expects that specific guidance and standards, such as emissions reductions targets, for priority project categories may be provided in the NOFO.
- Distributed power generation and storage: Projects, technologies or activities that generate and/or store zero-emissions power near to the point of use, instead of in centralized plants. Examples include distributed solar, distributed wind, geothermal, stand-alone energy storage and community-wide microgrids.
- Decarbonization retrofits of existing buildings: Projects, technologies or activities that retrofit an existing building to reduce or eliminate greenhouse gas emissions and air pollution, with that project, technology or activity consistent with the targets and strategies of net-zero emissions buildings as specified in Executive Order 14057 (Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability) Implementing Instructions. Examples include grid-interactive appliance electrification in affordable multifamily housing alongside energy efficiency, indoor air quality improvements and solar; school building space and water heating grid-interactive electrification and energy efficiency; replacement of backup diesel generators with battery storage, including paired with distributed power generation; and community facility retrofits with on-site solar, storage and charging infrastructure.
- Transportation pollution reduction: Projects, technologies or activities that support zero-emissions transportation modes, especially in communities that are overburdened by existing diesel pollution, particulate matter concentration and degraded air quality. Examples include small business fleet electrification as well as public and multi-use charging depots (including for clean school buses and community facilities).
What types of projects are eligible under the CCIA: Eligible projects under the accelerator fund must meet the following criteria:
- Must be a Qualified Project;
- Must be in a priority project category; and
- Must be in a low-income and disadvantaged community. The following mapping tool identifies eligible Justice40 communities: CEJST
Overall program: Contractors, coalition members, not-for-profits and community-based organizations may receive financing for a qualified project or complete pre-development and market-building activities to reduce greenhouse gas emissions, particularly in low-income and disadvantaged communities.
What are qualified projects: Section 134(c)(3) of the Clean Air Act provides that qualified projects include any project, activity or technology that (A) reduces or avoids greenhouse gas emissions and other forms of air pollution in partnership with, and by leveraging investment from, the private sector; or (B) assists communities in the efforts of those communities to reduce or avoid greenhouse gas emissions and other forms of air pollution. EPA expects to implement this statutory language by requiring that all projects meet all of the requirements listed below, which ensures all projects meet the statutory definition while also supporting the GGRF program objectives. EPA expects that each applicant will define their methodology for operationalizing these requirements in their application. EPA expects to define these requirements as follows:
- Deployment of the proposed project, activity, or technology will reduce greenhouse gas emissions in line with the U.S. Nationally Determined Contribution as well as Executive Order 14008 and will reduce emissions of other air pollutants. Specific portfolio-wide emissions targets may be set in the NOFO, and plans that equitably achieve the deepest emissions targets may be prioritized.
- Deployment of the proposed project, technology or activity will deliver benefits to American communities by alleviating two or more of the following categories of burdens, as defined in the Methodology section of the CEJST: climate change, energy, health, housing, legacy pollution, transportation, water and wastewater and workforce development.
- Investment of awarded funds in the proposed project, technology or activity will finance deployment of a project, activity or technology that may not have otherwise been financed. EPA expects this to involve substantially better-than market interest rates passing through to borrowers.
- Investment of awarded funds in the proposed project, technology or activity will spur private sector investment.
- The proposed project, technology or activity is already commercially available. Under this competition, EPA does not intend for program funds to support either (1) Research and Development, as defined in 2 CFR section 200.1, or (2) pre-commercial technologies, as defined by technologies that have not been installed and used in at least three commercial projects in the United States in the same general application.
Priority project categories: EPA has identified three priority project categories that are particularly impactful to achieving the GGRF program objectives and the near-term climate goals of the United States. EPA expects each applicant to explain their approach to these priority project categories in their investment strategies, but EPA expects to provide each applicant with flexibility to (1) invest in additional project categories and (2) not invest in any given priority project category, provided this decision is accompanied with a supporting explanation. EPA expects that specific guidance and standards, such as emissions reductions targets, for priority project categories may be provided in the NOFO.
- Distributed power generation and storage: Projects, technologies or activities that generate and/or store zero-emissions power near to the point of use, instead of in centralized plants. Examples include distributed solar, distributed wind, geothermal, stand-alone energy storage and community-wide microgrids.
- Decarbonization retrofits of existing buildings: Projects, technologies or activities that retrofit an existing building to reduce or eliminate greenhouse gas emissions and air pollution, with that project, technology or activity consistent with the targets and strategies of net-zero emissions buildings as specified in Executive Order 14057 (Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability) Implementing Instructions. Examples include grid-interactive appliance electrification in affordable multifamily housing alongside energy efficiency, indoor air quality improvements and solar; school building space and water heating grid-interactive electrification and energy efficiency; replacement of backup diesel generators with battery storage, including paired with distributed power generation; and community facility retrofits with on-site solar, storage and charging infrastructure.
- Transportation pollution reduction: Projects, technologies or activities that support zero-emissions transportation modes, especially in communities that are overburdened by existing diesel pollution, particulate matter concentration and degraded air quality. Examples include small business fleet electrification as well as public and multi-use charging depots (including for clean school buses and community facilities).
What types of projects are eligible under the NCIF: Eligible projects under the accelerator fund must meet the following criteria:
- Must be a qualified project;
- Must be in a priority project category; and
- Must be in a low-income and disadvantaged community. The following mapping tool identifies these eligible Justice40 communities: CEJST
Watch the recording
Tune in as Joel Laubenstein, Jeannine Jacokes, Rob Hazelton and Serena Walters discuss key takeaways and important next steps for considerations. The discussion dives into the GGRF timeline and offers actionable guidance for developers, investors and energy leaders to position their projects effectively and stay ahead of federal compliance requirements. Explore strategies for identifying the right project partners and assembling a reliable project team. This webinar also includes:
- An overview of the GGRF
- Practical steps to enhance project readiness
- Available resources for training and capacity development
- An understanding of project compliance requirements
Next steps
- Identify qualified projects that we are already engaged or potentially engaged in.
- Work with developers, not-for-profits or other entities to build qualified projects.
- Design an easy-to-use compliance collection to monitor and report on program performance.
- Find capital solutions that apply to your qualified projects.
Baker Tilly is here to help
- Program administration and compliance
- CDFI technical assistance and advisory services
- Workforce development advisory
- Energy feasibility and technical assistance
- Project advisory
- Project management
- Inflation Reduction Act tax credit advisory
- Housing and real estate development advisory service
Discover how you can capitalize on the GGRF with our turnkey program design and deploy solution. We can help your organization maximize project funding by building a capital stack to include Inflation Reduction Act tax credits and other pairing sources. Are you eligible?
Related sections
- Not-for-Profit
- Real Estate
- State & Local Government
- Tribes
- Low-income and disadvantaged communities mapping tool
- Multifamily Housing
- Community Development Financial Institution Consulting
- Economic Development for Local Governments
- Greenhouse Gas Reduction Fund Advisory
- Inflation Reduction Act Tax Credit Solutions
- Project Finance
- Public Sector Advisory
- Real Estate Advisory Services
- Real Estate Valuation Services