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May 22, 2023

NHT Provides Comments in Response to EPA's Greenhouse Gas Reduction Framework

NHT continues to engage federal agencies that will play critical roles in implementing the Inflation Reduction Act of 2022  to ensure that the benefits of clean energy, energy efficiency, and electrification reach multifamily affordable housing providers and residents.

On May 12, NHT provided comments to EPA in response to its April 19 Greenhouse Gas Reduction Framework to encourage the agency to:

  • Lift capitalization limits in the Clean Communities Investment Accelerator to encourage broader participation by CDFIs and HFAs, given that they are critical and trusted funding intermediaries that invest in affordable housing.
  • Ensure that a broader array of financial products can be funded through the GGRF programs – including grants, which can more easily be used to fill critical funding gaps in the capital stack for sustainable and affordable multifamily housing projects.
  • Require national applicants to commit to providing a minimum level of capital to community lenders with track records serving affordable housing and community development needs.
  • Support technical assistance to affordable housing owners (in addition to lenders) to help plan, execute, and manage decarbonization retrofits.
  • Refine the definition of low-income and disadvantaged communities to include the CDFI Fund’s “investment areas,” which cover more households and more census tracts than the alternate definition.

NHT is encouraged by the Greenhouse Gas Reduction Fund framework – particularly to the degree that it identifies building decarbonization retrofits of existing buildings as a priority project category.  But more is needed to ensure that the benefits flow to affordable multifamily housing where it is most urgently needed: preserving affordable housing, reducing energy cost burdens, and improving indoor air quality for its residents.

Link to NHT GGRF comments

Danielle Arigoni
Danielle Arigoni

Managing Director for Policy and Solutions