On May 12, the Environmental & Energy Law Program (EELP) submitted comments on EPA’s Greenhouse Gas Reduction Fund (GGRF) implementation framework. The comments build upon recent discussions among expert stakeholders with experience in and perspectives from academia, NGOs, and the private and public sectors. This group was convened informally by EELP.
EPA’s proposed framework is sound and provides an excellent foundation upon which grantees and their partners can deploy resources to maximize emission reductions, improve quality of life and create jobs. But it is confusing as it relates to funding for activities that are essential to build demand for investment in disadvantaged communities. The comments offer suggestions as to how EPA can strengthen the framework, including clarifying technical assistance, explicitly identifying eligible and ineligible technologies, and providing templates and examples of formulas and performance metrics.