Americans for Financial Reform Education Fund (AFREF) submitted two comments to the Environmental Protection Agency (EPA) in response to their request for information on the administration and implementation of the $27 billion Greenhouse Gas Reduction Fund (GHGRF), a provision of the Inflation Reduction Act (IRA) which became law in August 2022. 

AFREF submitted a coalition comment focusing on equity principles urging the EPA to prioritize environmental, racial, and economic justice as it administers the GHGRF. We led this letter alongside partners at Emerald Cities Collaborative, The Greenlining Institute, Just Solutions Collective, and Rewiring America. The letter was co-signed by 72 organizations across issue areas including environment and environmental justice, economic justice, racial justice, housing, clean energy, faith, and impact investing. 

AFREF also submitted a technical letter with The Greenlining Institute which was endorsed by The Chisholm Legacy Project, Public Citizen, and WE ACT for Environmental Justice. The letter covers our recommendations to the EPA on definitions for low-income and disadvantaged communities, thoughtful and inclusive program design, eligible projects based on community benefits, criteria for eligible recipients, and the need for strong oversight and reporting on the funds. Our comments emphasize targeted deployment of capital to maximize benefits for low-income and disadvantaged communities in addition to the other goals of the Fund (i.e. pollution and GHG emissions reductions, additionality, continued operability, etc.).