Comment
Name and Description
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Feedback
(Summary)
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Organization
#1
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Through
public comment and in discussion/written feedback provided as part
of burden, Organization #1
recommended:
Providing
more time for quarterly reporting (45 days)
Allowing
for proxies and estimates based on defined data and standards.
Requiring data from originating lenders that is beyond standard
loan applications would significantly restrict the universe of
originating lenders participating in the program.
Allowing
for N/A and unknown picklist selections for certain data fields
and certain loan types and sizes.
In
the Data Dictionary, the EPA should indicate the definition,
method (e.g., projected or actual), and intended frequency of
reporting (e.g., quarterly or annual, one-time or ongoing) for
each metric, being aware of the additional burden of quarterly
reporting.
Streamlining
LIDAC classification and evaluation. Recommend a consolidated
mapping tool for eligibility screening (on 4 categories) similar
to CDFI IMS, or a consolidated CSV of CEJST census tracts and
EJScreen census blocks.
Clarification
on terminology and frequency of reporting. Clarify third-party
validation, verification and assurance.
Organization
#1 also expressed concerns on labor reporting. Metrics need to be
reported on best-effort basis. Rate of pay and total hours worked
will be difficult at start. Recommend providing further guidance
around DBRA and BABA’s applicability, especially for small
projects (e.g., under $3 million in federal funds invested or
under 1MW of solar installed).
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Organization
#2
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Through
public comment and in discussion/written feedback provided as part
of burden, Organization #2 recommended:
Standardizing
a level of uniformity in data collection, measurement, and
reporting to protect the integrity of the data.
Requiring
all award winners to meet and confer with EPA to determine the
best way to build out and apply a standardized system.
Developing
new technology to enable uniform reporting for recipients and
sub-recipients.
Implementing
short-term modifications for response times to allow for a
“learning up” period.
Modifying
AVERT, COBRA or other models to measure the emissions benefits of
smaller projects.
Requiring
a standardized reporting method for economic impacts of
investment.
Reevaluating
burden analysis, which was vastly underestimated in the first
Federal Register notice.
These
proposed considerations will help create consistency in reporting
and enhance credibility
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Organization
#3
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Through
public comment and in discussion as part of burden, Organization
#3 recommended:
Providing
definitions of important GGRF programmatic terms in the award
agreement and compliance materials so award recipients and
subrecipients are clear on project eligibility and expected
compliance tracking. This will also ensure that EPA is receiving
standardized reporting across awardees and that entities wishing
to receive assistance understand project and potential reporting
requirements.
Allowing
modeling and sampling for GGRF assisted properties in areas of
the country where whole building data is not made available by
local utility providers. The inconsistency of utility data access
was recently highlighted in a letter sent from EPA, U.S.
Department of Housing and Urban Development, and U.S. Department
of Energy to state and local utility commissioners asking for
them to ensure this data is available for energy efficiency
improvements of multifamily properties.
Continuing
engagement through the award term, providing recipients
flexibility for compliance requirements that are impeding
effective delivery of GGRF resources. This could include
modifying such requirements during the compliance period and
other changes based on awardee and EPA experience.
Creating
exemptions from Davis-Bacon requirements for construction
projects under a certain dollar threshold, or when the GGRF funds
are a comparatively small portion of the total project costs, to
ensure these requirements don’t preclude using these
resources for eligible projects. In addition, it is important
that such requirements generally be applied only to large scale
development projects, rather than to working capital to small
businesses, market building, predevelopment, and other
non-construction activities.
Advising
against real-time reporting, too much effort and expense with not
enough value.
Recommending
being thoughtful and thorough about definitions and evaluating
whether what is asked for is actionable, especially at the
frequency of reporting. Don’t expect much change quarter to
quarter.
Recommending
replacing quarterly progress reports with oral consultations or
debriefs, exchanging ideas/best practices on transforming the
market.
Meeting
as a cohort to create one reporting platform that can optimize
reporting, increase effectiveness and create alignment.
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Organization
#4
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Through
public comment and in discussion as part of burden, Organization
#4 recommended:
Streamlining
and reducing reporting burden for mission-driven community
leaders.
Reducing
or limiting the amount of benefits data – particularly
climate and air pollution –collected from subrecipients to
drive down set-up and ongoing reporting costs.
Scaling
the level of reporting detail required on a project to the scale
and size of the project. Under CCIA, community lenders will fund
a high volume of impactful small-scale projects. It is simply not
practical to require the same level of reporting on a $30,000
residential solar installation as a multi-million-dollar large
renewable energy development.
For
some categories of projects that are smaller, simpler, and more
uniform, EPA could consider allowing lenders to report on key
project attributes and rely on modeled or derived savings or GHG
reductions. This approach can be validated as needed by using
statistical sampling methods.
Deciding
on a standard methodology for calculating emissions reductions.
This will reduce burden, create consistency, and support the
program objectives.
Taking
advantage of industry experience in energy savings and carbon
emissions reporting, as well as existing data, analysis, and
predictive tools to help lenders report on emissions, energy and
climate-related metrics.
Considering
Energy Star Portfolio Manager as solution for data collection
and analysis for many building projects. Portfolio Manager is an
easy, streamlined way of measuring savings from GGRF
investments; it is regularly updated by EPA, and it is weather
normalized.
Considering
RMIs Green Upgrade Calculator https://greenup.rmi.org/ for
project categories like green homes and clean transportation.
Considering
new data collection and analysis tools such as advanced smart
meters and building “digitization” that could
simplify the process for many projects. Allowing provisions for
incorporating new, efficient tools that deliver equivalent
results.
Consider
using sampling methodologies by ACEEE and Bright Power for
evaluating Bank of America’s EE Financing program for
CDFIs.
(https://www.aceee.org/sites/default/files/publications/researchreports/f1601.pdf).
Utilities and their regulators have used evaluation,
measurement, and verification methods to gauge energy efficiency
program effectiveness for years.
Releasing
detailed guidance describing the parameters and final reporting
requirements as soon as possible to allow for time-intensive IT
and supporting implementation to occur.
Setting
thresholds for Davis-Bacon compliance reporting, like U.S
Treasury’s approach for ARPA funds (e.g., State & Local
Fiscal Recovery Fund).
CCIA
program’s robust reporting must not become a barrier that
prevents small mission-driven community lenders from accessing the
program or dissuades lenders from investing in incredibly
impactful but small-scale projects.
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Organization
#5
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Through
written feedback Organization #5 recommended:
Reporting
on aggregated consumer loan data at the census tract level.
Depositories, such as credit unions, will find it challenging to
report the detailed data in the data dictionary. reporting within
90 days of the close of reporting period.
Allowing
90 days for Transaction and Project System reporting.
Establishing
a common methodology for cross-walking the lending outputs from
subrecipient community lenders to a common pre-approved
methodology for benefits calculations that recipients prepare
based on reporting they receive from sub-recipients.
To
expect each community lender to engage in their own benefits
calculations will increase burdens on the lender and will
introduce a high level of risk to the overall program and to all
recipients. There would be variation in assumptions and
methodology, thus opening the door to unnecessary risks to the
integrity of the data and the program.
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Organization
#6
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Through
public comment and in discussion as part of burden, Organization
#6 recommended:
Standardizing
metrics and reporting systems for sub-recipients of the CCIA
program: investee data, community benefits, and emissions
reductions. These data points are not commonly reporting across
the CDFI industry.
Clarifying
whether reporting time frames are based on the calendar or fiscal
year. Differences in recipient and sub-recipient fiscal year end
will increase the cost of reporting. Audits are completed -
generally 180 days from the Year End date according to most
organization bylaws. This discrepancy in Year End dates would
make it difficult for some organizations to be able to provide
timely reports that comply with the EPA timeline.
Extending
the reporting timeline to sixty days after quarter and annual
end. The chains of data from sub-recipients to recipients are
extended, unlike other EPA grant programs, and will require
additional time and quality checks to ensure the data integrity
and compliance with EPA Order 1000.33: U.S. EPA Policy for
Evaluations and Other Evidence-Building Activities.
Considering
a longer period of 120 days for first-year reporting to give time
to develop reporting technologies and train all recipients and
sub-recipients on the reporting tools and systems.
Providing
additional detail regarding the definition of a ‘project’.
In other words, at what stage of project development should this
be reported, what level of detail will be required, and what
metric(s) are desirable in terms of project location (e.g. zip
code, latitude/longitude, other)?
Delaying
the requirement of Scope 1 and 2 emissions until the second
reporting year.
Including
program income in annual reports rather than quarterly. For most
Native CDFIs, this metric will not be available until at least
year two of the program.
Developing
a software platform to enable uniform reporting for recipients
and sub-recipients and requiring a standardized reporting method.
The
cost burden analysis completed by EPA vastly underestimates the
time and hourly labor costs that it will take to adequately
prepare responses. Organization #6 estimates that its burden will
be significantly higher than EPA’s estimate because each
recipient will be required to collect data from multiple
sub-recipients prior to compiling their own reports. Without a
standardized platform or automated data collection, Organization
#6 estimates that the hourly time burden per response will be more
than double EPA’s initial estimates. In addition, EPA’s
estimate does not reflect initial technology support costs.
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Organization
#7
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Through
public comment and in discussion as part of burden, Organization
#7 recommended:
Considering
Organization #7’s definitions of “project” and
“community.” Project is the physical facility that
produces, stores, and provides energy as needed. Community
metrics describe a person’s experience with the projects
and programs.
Automating
data reporting. Organization #7’s proprietary platform is a
software tool built to automate community solar data and
subscription management processes, allowing the organization to
meet reporting needs more efficiently and effectively. The
platform reduced staffing needs by 1.33 FTEs in some cases.
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Organization
#8
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Through
public comment, Organization #8 recommended:
Developing
a metrics reporting and evaluation plan, including a data
dictionary. Be specific about the assumptions (e.g.,
grid-factors, low-income thresholds), calculations, datasets and
definitions so that each recipient does not spend time and
resources to clarify their individual approach. Many
sub-recipients (who may be small businesses) will not have the
time or resources to do so.
Developing
definitions and standards for investment types, technologies,
energy off-takers (or savings), guarantees, impacts, etc.
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Organization
#9
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Through
public comment, Organization #9 recommended:
Compelling
utility companies to provide easy access to data and reduce cost
of benchmarking.
Requiring
all building retrofit or highly efficient new building
construction projects that receive GGRF funding to perform annual
energy benchmarking.
Budgeting
for the cost of energy benchmarking.
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Organization
#10
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Through
public comment, Organization #10 recommended:
Allowing
time to build reporting capacity.
Developing
clear guidelines on use of funds for capacity building.
Clearly
defining environmental and community-based impact metrics and
developing guidelines on how to measure.
Leveraging
existing reporting structures and templates for collecting data.
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