NCN CCIA Program Implementation

There are a number of steps that community lenders could be taking to prepare to receive and deploy CCIA funds. NCN is developing a readiness assessment to help you with your preparations and will make that available when it is ready. A few more immediate suggestions include:

1. Identify your target market(s). Will your customers be tribes/tribal programs, Native homeowners, Native consumers, other non-profit organizations, or some other market?
2. For each target market, determine what loan products you either have in place or will need to develop to serve that market. If you are unsure – you may want to plan to use some of your technical assistance funds to conduct a market study to help you make these determinations.
3. Determine your organizational capacity to develop new loan products, underwrite and service them, etc. Do you have enough staff but need training and/or loan product templates, underwriting processes, etc.? Will you need to hire staff to manage/carry out the clean energy finance portion of your portfolios?
4. Begin to identify the vendors in your area (solar, wind, energy efficient appliance dealers, home retrofit contractors, etc.). They may become your partners in marketing/communications with the community, you may become their first line for financing projects, or you may discover that there are no vendors in your area and it may be necessary to work with clean energy apprenticeship programs to identify potential business owners to invest in.

NCN designed its CCIA application around the 63 lenders that originally committed to participate. If a lender signed on with NCN at the time NCN submitted the CCIA application to EPA, that lender is considered ‘preliminarily eligible’ and once the NCN lender applications open, this group will be considered first. If any of the original 63 lenders decide not to participate, or continue with the program, it is possible that NCN will open applications to other lenders, but that process and timeline will be determined once all 63 original NCN community lenders have had the opportunity to apply and eligibility of each has been confirmed.

In terms of metrics for the awards: based on the new award amount NCN will receive from EPA, NCN has budgeted capitalization funds for the 63 lenders to receive up to $5M each in capitalization funds. This amount is contingent on final determination of lender eligibility, lender organizational capacity, and eligibility of projects to be financed.

NCN will have an application process to ensure that the community lenders receiving subgrants from NCN meet certain EPA required criteria. For example, we need to ensure that the money is being used to finance qualified projects in low income and disadvantaged communities (LIDAC). Since NCN’s target population is Native communities, and Native communities are automatically considered LIDAC – we will require all subrecipients to show evidence that funds are being deployed to qualified projects that benefit Native communities. In addition, funds must be used to finance qualified projects as defined by the EPA and the community lender must be able to comply with EPA terms and conditions.

To help lenders in NCN’s network prepare for project implementation, we are developing a ‘readiness assessment’ that will walk you through the program requirements and help you determine what you need to have in place to receive funds and when (timing) it may be best for you to do so. We want to be sure everyone knows what is required and that you have the capacity to deploy the funds per EPA’s requirements. This might mean that members of NCN’s community lender network are applying for and receiving funds at different times throughout the six years of the program. Some lenders may need technical assistance before they can jump into lending, others may have shovel ready qualified projects, etc.

NCN’s commitment is to ensure GGRF funds benefit Native communities. In addition, 100% of CCIA funds are REQUIRED to be used to benefit Low-Income-Disadvantaged-Communities (LIDAC). Projects developed on tribal lands automatically qualify as LIDAC communities. There are no other CCIA programs that are prioritizing Native communities and only one other program has included Native communities in the description of their ‘potential’ Target Market. For this reason, NCN will include ‘financing projects that benefit Native communities’ as a priority eligibility criterion for accessing NCN’s CCIA funds.

Also of note: NCN is advocating for Federally Designated Service Counties to be included in the definition of LIDAC communities.

The Lender Handbook has guidelines with funding request details starting on pages 4-21. You can also reference Appendix B, C, D, and E of the Handbook for worksheets to walk you through your funding request.

The second criterion of the ORA is past performance, which assesses the Community Lenders’ capability to responsibly and compliantly administer and provide stewardship over CCIA funding. They will be asked to provide written descriptions of relevant past performance for lending to their target market, including Tribal governments, enterprises, Native businesses, and individuals. (See NCN CCIA Handbook for Community Lenders A. Capability and Capacity Assessment 2. 3. Lender Past Performance, page 9.)

The $10M cap per ‘eligible financial institution’ applies to only CCIA funds. In other words, lenders may access up to $10M in CCIA capitalization funds AND also access funds above that amount from the NCIF and/or SFA program. CDFIs can also receive multiple subawards from different CCIA recipients, so long as the total does not exceed $10 million (unless approved by the EPA).

Yes. Community Lenders are eligible to apply for funds from all CCIA awardees. The maximum amount of capitalization funds any single lender can receive is $10 Million, and the maximum amount of technical assistance funds any single lender can receive is $1 Million. However, community lenders are encouraged to work with NCIF awardees to seek capitalization funding above and beyond their CCIA subawards. Solar for All funding is designed to provide grants only to solar projects and community lenders are not eligible to receive funds through that program. However, Lenders are encouraged to connect with Solar for All awardees to explore how CCIA capital funds can be paired as part of the capital stack for solar projects in Native communities.

The eligibility validation phase will open on November 1st, 2024. After eligibility has been confirmed lenders can begin the Organizational Readiness Assessment (ORA). Once a lender has been assigned to an organizational readiness tier, the lender will enter into and sign a subgrant agreement. After those steps have been completed, lenders can submit funding requests for technical assistance funds and capitalization funds for eligible projects. Note: once funds are transferred to the CCIA subrecipient financial account (FA), funds must be expended within 14 days or they must be returned to NCN to be re-disbursed.

No, any expenditures incurred prior to the signing of the subrecipient’s subgrant agreement are not eligible to be reimbursed as part of the CCIA program.

Currently, the EPA has not set any limitations on loan terms. NCN will provide more guidance in regard to industry best practices in the future.

1. The Community Lender will submit an initial application to NCN to determine eligibility to receive funding. NCN will review for eligibility based on EPA eligibility criteria, evidence of Native communities as the target market, organizational capacity, and purpose for the funding (i.e., immediate financing of qualified project, technical assistance, program support. etc.)
2. Once determined eligible, NCN and the community lender will enter into a subgrant agreement.
3. The Lender will then submit a request to draw down their approved amount of capitalization funding. Approval will be contingent on the shovel ready status of one or more CCIA eligible projects. Applications for project funding will occur on a rolling basis until the maximum agreed upon allocation (up to $5M) is deployed.

Per CCIA terms and conditions, all project financing should be directed to supporting only CCIA qualified projects. Therefore, the Lender will need to produce the necessary documentation to provide evidence that the intended purpose of the funds will be used for CCIA eligible federal financial assistance options and that the project meets all CCIA terms and conditions. If this project information is provided after funds are dispersed and it is determined that the project did NOT meet CCIA qualified project criteria, the lender will be required to return the funds.

EPA, in coordination with the CCIA selected applicants are currently working to develop more detailed descriptions and examples of eligible projects. NCN is working with the team to ensure that examples of projects in Native communities are included in these descriptions. In addition, NCN is developing a NCN CCIA Lender Handbook that will not only include a detailed description of eligible projects, but also a checklist and assessment tool community lenders can use to determine project eligibility prior to applying for financing.

Yes. While $5 Million was budgeted for each community lender, NCN will work individually with each lender to determine their CCIA eligible pipeline and related capital demand. This information will guide development of the subgrant agreements and final TA funds and Capital Funds allocations for each individual lender.

NCN is currently working to develop a strategy around this. Please keep an eye out for updated information and guidance.

NCN is currently gathering information to confirm potential capital stacking options related to the use of NMTCs. Please keep an eye out for updated information.

The CCIA program does not require qualified projects to be owned, in whole or in part, by a Tribe or tribal member. The major requirement is that the qualified project must be located in a LIDAC community.  The EPA definition of a LIDAC community is any community that meets at least one of the following characteristics:

1. Identified as disadvantaged by the Climate and Economic Justice Screening Tool (CEJST)
2. Any census block group that is at or above the 90th percentile for any of EJScreen’s Supplemental Indexes when compared to the nation or state, and/or
3. Any geographic area within Tribal lands as included in EJScreen. The Tribal Lands category in EJScreen to use for this purpose includes Alaska Native Allotments (EPA Metadata Record), Alaska Native Villages (EPA Metadata Record), American Indian Reservations (EPA Metadata Record), American Indian Off-reservation Trust Lands (EPA Metadata Record), Oklahoma Tribal Statistical Areas (EPA Metadata Record).

Note: Projects owned by a tribe or that are built on tribal lands are not automatically considered an eligible project. The project must also meet the CCIA qualified project criteria (see Qualified Project section of FAQs).

All lands within an Indian reservation are considered LIDAC, so city and town status is not relevant.  NCN is working with EPA to include Hawiian homelands and Federally Designated Service Counties in the definition of low income and disadvantaged communities (LIDAC) and will update FAQs once that determination has been made.

For qualified projects located off tribal lands, the CDFI will have to show that the project is located in another LIDAC defined community (see above) or is with an individual tribal member or business owner that meets the low-moderate income requirements.

Yes, loans can be made to an enrolled Native American of a federally recognized tribe regardless of their geographic location.

NCN is still advocating for Hawaiian Homelands to be included as Native American lands, which are currently included in EPA’s definition of Low-Income Disadvantaged Communities (LIDAC). At this time, financing can only be provided for projects on Hawaiian Homelands that are specifically included in the LIDAC-eligible map (CJEST).

The establishment of tribal utility authorities (TUA) is out of the scope of the CCIA program. However, we recognize that for some tribes, the development and sustainability of clean energy projects, and eventual tribal energy independence may be dependent on a TUA. For that reason, the CCIA Team at NCN is dedicated to helping Community Lenders establish strong relationships with Tribal Entities, Housing, and Utilities as an essential component of developing clean energy projects within the CCIA program. These strategies will be emphasized within our NCN Clean Energy Finance Certificate program. In addition, NCN is working with a number of coalition and community partners with knowledge in this area and can connect lenders and their tribal partners with these experts.

To Be Determined, EPA will provide guidance on TILA-RESPA and other consumer protections.

Yes, NCN will facilitate the opening of these accounts on behalf of the community lender during the subgrant agreement phase. Lenders do not need to open this account themselves at this time. Please watch for more information regarding this moving forward. These accounts will primarily be used to facilitate transfer of funds from NCN’s CCIA account to the community lenders (subrecipients). Subrecipients will then be able to move funds to their own, preferred EPA eligible account (more details to come).

Community lenders will still be able to utilize Citibank regardless of not having a physical office in their state. NCN, in partnership with Citibank, will facilitate the opening of these accounts during the subgrant agreement phase.

NCN’s program follows EPA’s guidelines for the program. While forgivable loans are allowable, EPA does not encourage them, as the goal of the program is to continue to re-lend funds in perpetuity for CCIA eligible projects.

Currently, EPA has not set any limitations around loan terms. NCN will provide more guidance regarding industry best practices in the future.

EPA acknowledges that bad debt and loan loss is a part of any program and will not penalize lenders for instances of bad debt. EPA will provide further guidance around how loan loss reserves can be structured within the program and NCN will share that information as soon as it is available.

Lenders may support participation of an individual in your grant project through payment of stipends, travel allowances, and similar participant support costs. These transactions are neither procurement contracts nor subawards. EPA also considers subsidies and rebates for the purchase and/or installation of pollution control equipment that is owned by the program beneficiaries to be participant support costs. You must have prior EPA approval to pay participant support costs.

The official program does not start until NCN and the EPA execute the award agreement. Once the agreement is in effect, NCN is prepared to launch its own onboarding and application processes. However, NCN recognizes that not all NCN CCIA lenders will be ready to begin offering clean energy finance products and services right away. For that reason, NCN will be offering a ‘hub’ of technical assistance services to support the capacity building efforts each lender may need. In addition, lenders may apply for and receive technical assistance funds to conduct market studies, support strategic planning efforts, develop loan products, hire staff, etc. Receipt of technical assistance services and funds can and should be accessed prior to receiving capitalization funding.

NCN is working with our CCIA Coalition Partners to develop a menu of trainings and other technical assistance services. To date, 15 NCN CCIA lenders have taken a course on consumer solar lending offered by NCN partner, the University of New Hampshire – Center on Financial Impact and Inclusiv. In the near future, they will also be offering courses in commercial solar and community solar lending. In addition to offering these trainings, NCN is compiling sample loan products, policies, and related underwriting criteria for the other CCIA eligible project types and will make those available to lenders in the network.

Yes – NCN will play a role in connecting lenders with CCIA eligible projects. NCN has already received multiple inquiries from project leads in need of financing. NCN will notify the network of the opportunities and to the extent possible, connect lenders who express interest in collaborating with others.

One of NCN’s Coalition Partners, the National Renewable Energy Laboratory (NREL), has developed a matchmaking app to connect vetted community solar projects with solar lenders and is building out a specific mechanism in the app to connect projects in Native communities with Native-serving lenders. Check it out here.

NCN will provide (free) technical assistance through our TA hub to community lenders within the CCIA program. Some coalition partners are experienced in tribal matters, which the community lender can access on behalf of their tribal partner, however, the tribe(s) themselves will not be able to directly access NCN’s TA hub.

The weekly lender calls will be transitioned into monthly and quarterly calls. However, the Regional coordinators will offer weekly office hours as a time to ask questions or share any information. More details to come.

At this time we recommend you contact the full CCIA team with any question you have and we will be sure to get you the information you need. In the near future, lenders will receive information about who their direct contact will be within the CCIA team.

Pamela Boivin – CCIA Program Manager ([email protected])
Jodi Fischer – CCIA Regional Coordinator ([email protected])
Luke Robinson – CCIA Regional Coordinator ([email protected])

Required experience and competencies will be dependent on each lender’s designed program and staff capacity needs. NCN can help assess these needs on an individual basis as needed with each lender. In addition, NCN can provide example job descriptions that can be customized for your needs.

At NCN, we are passionately advocating for opportunities that will empower Native CDFIs to bolster our industry’s influence across Native communities. We are proud to collaborate with a diverse network of partners who are dedicated to supporting our cause. We urge our Community Lenders to subscribe to our weekly newsletter, to stay informed about upcoming opportunities, events, and dynamic training webinars tailored to elevate our industry.

There are no specific requirements, but NCN and lenders will have to have consumer protections which may include certain loan terms.

Currently, EPA terms and conditions state that the funds must be used for CCIA eligible projects in perpetuity.

Currently, EPA terms and conditions state that the funds must be used for CCIA eligible projects in perpetuity.

Yes, funds can be used for forgivable loans.

As a primary CCIA recipient, NCN will receive the funds as a grant. NCN will then pass through capitalization funds to eligible lenders in NCN’s CCIA network as subgrants. The lenders must then use the funds as debt or investment capital (but not grants) to finance CCIA qualified projects.

The leverage ratio for NCN’s CCIA program is 3:1. EPA has indicated that NCN will be able to define the what constitutes ‘leverage capital’ and how it is measured. Additional details will be forthcoming.

While leveraging will not be required on each and every loan, NCN does need to demonstrate that the 3:1 leveraging ratio is being met across its CCIA program. Therefore NCN will ask lenders to include information about secured and/or anticipated leveraging funds as part of each funding application. Additionally, lenders will be asked to report on capital leveraged as part of each quarterly report.

EPA’s guidance to date states that the ability to count other federal funds as capitalization leverage depends on the terms of other federal programs. Those terms will determine whether the funds can be counted as leverage.

At the heart of delivering the CCIA program is our unwavering commitment to empowering Native Community Lenders and preserving their certifications and good standing statuses. We aim to implement a thorough evaluation process to ensure that our Lenders are not just thriving but poised for expansion. Together, we will leverage industry best practices and CDFI Fund expectations to propel Community Lenders toward shared success. Should our evaluation uncover anything that may impact a Lender’s status, rest assured that we will collaborate closely with the Community Lender to craft effective corrective action plans.

NCN is currently working with CDFI Fund to determine an answer to this question. Please keep an eye out for more information.

Under this award agreement, the recipient is authorized to deduct the cost of generating program income. EPA-specific rules on Program Income are provided at 2 CFR 1500.8, and rules on allowable fund raising costs are provided under 2 CFR 200.442 (with additional details in Item 4 of the EPA Guidance on Selected Items of Cost for Recipients). Under this award agreement, the Recipient is authorized to deduct the cost of generating program income under 2 CFR 200.307(b) and 2 CFR 1500.8(b), provided the costs are reasonable and necessary for performance under the federal award and the costs are not charged to the EPA award. Costs incidental to the generation of program income include origination, servicing, and management costs that are not charged as direct costs to the Federal award or to Program Income.

Per EPA guidance, NCN will not provide capitalization funding in tranches but will provide funding to lenders as necessary to make the loan or investment. Funds will be held in a separate account on behalf of lenders in NCN’s lender network until they are used for the loan or investment.

2 CFR 200.1 defines Program Income as “gross income earned by the non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance except as provided in § 200.307(f).” 2 CFR 200.1 notes that Program Income “includes but is not limited to income from fees for services performed, the use or rental or real or personal property acquired under Federal awards, the sale of commodities or items fabricated under a Federal award, license fees and royalties on patents and copyrights, and principal and interest on loans made with Federal award funds.”

For this program, Program Income also includes but is not limited to income from origination fees, servicing fees, and asset management fees; dividends from equity investments; revenue from asset sales; release of grant funds previously used as Financial Assistance (such as through loan guarantees, loan loss reserves, or similar transactions); interest and other earnings on disbursements of grant funds that have not been transferred to third parties; and funds raised with costs charged against the grant award (such as private debt, philanthropic contributions, and other funds raised).

Program Income must be treated in accordance with the Program Income Programmatic Term and Condition. EPA-specific rules on Program Income are provided at 2 CFR 1500.8, and rules on allowable fund raising costs are provided under 2 CFR 200.442 (with additional details in Item 4 of the EPA Guidance on Selected Items of Cost for Recipients). Under this award agreement, the Recipient is authorized to deduct the cost of generating program income under 2 CFR 200.307(b) and 2 CFR 1500.8(b), provided the costs are reasonable and necessary for performance under the federal award and the costs are not charged to the EPA award. Costs incidental to the generation of program income include origination, servicing, and management costs that are not charged as direct costs to the Federal award or to Program Income.

Reporting systems will be developed by NCN. Therefore, lenders do not need to set up their own reporting software, etc. However, lenders will need to be able to provide specific data about each qualified project they finance or invest in to NCN for quarterly and annual reporting to the EPA.

NCN is waiting on reporting criteria from EPA and will update the FAQs once information is received.

EPA is still working on the reporting guidelines and required metrics. Once NCN receives this information, we will share it out with the lender network and provide relevant training on the reporting requirements.

NCN is working to draft samples to share with the lender network and will make those tools avaiable once they are developed.

Yes. Currently, EPA terms and conditions state that reporting will continue in perpetuity. However, no guidelines regarding the processes and procedures for this have been provided. EPA will release its reporting requirements in December 2024 including an outline of the reporting parameters of the CCIA program grant-related activities.

The source of the impact data will depend upon the scope and type of project. Community lenders are encouraged to address this before approving each loan to ensure all needed impact data is gathered. NCN will provide further guidance on this once EPA releases the final reporting requirements.

Qualified Project means any project, activity or technology meeting all six requirements listed below at the time that Financial Assistance is provided to the project, activity, or technology:

• The project, activity, or technology would reduce or avoid Greenhouse Gas Emissions. The project, activity, or technology may reduce or avoid such emissions through its own performance or through assisting communities in their efforts to deploy projects, activities, or technologies that reduce or avoid such emissions.
• The project, activity, or technology would reduce or avoid emissions of other Air Pollutants.
• The project, activity, or technology would deliver additional benefits (i.e., in addition to primarily reducing or avoiding emissions of greenhouse gases and other Air Pollutants) to communities within one or more of the following seven categories: climate change; clean energy and energy efficiency; clean transportation; affordable and sustainable housing; training and workforce development; remediation and reduction of legacy pollution; and development of critical clean water infrastructure.
• The project, activity, or technology may not have otherwise been financed.
• The project, activity, or technology would mobilize private capital.
• The project, activity, or technology would support only commercial technologies, defined as technologies that have been deployed for commercial purposes at least three times for a period of at least five years each in the United States for the same general purpose as the project, activity, or technology.

The Qualified Project must also be included in one of the following priority categories: Distributed Energy Generation and Storage, Net-Zero Emissions Buildings, and Zero-Emissions Transportation

The National Renewable Energy Lab is one of the coalition partners that will be able to provide technical assistance to CDFIs. NREL has multiple tools and other assistance to address this, and other types of resource or technology questions. NCN is in the process of compiling a list of these resources and will make them available to the lender network.

Funds can be used to finance or invest in any CCIA Qualified Project.

A Qualified Project can use biomass technology if the meets the requirements listed above, including greenhouse gas emission reductions, other pollutant emission reduction, commercially feasible and available technology.

This is not a documented exception, however, any concerns can be brought to NCN and NCN will address them with the EPA project officer to gain further clarity on possible exceptions along with the process to request an exception. (Terms and Conditions page 26).

Davis Bacon applies to any projects costing more than $2,000 that utilize federal funds. BABA does not relate to specific costs, however it applies to infrastructure related construction projects. Any project that involves a privately owned home or building not used by the general public does not have to comply with BABA. Any utility, public serving building, such as a hospital or childcare center, public energy generation projects, including, but not limited to microgrids, public transportation, or broadband infrastructure do fall under BABA requirements.

NCN’s CCIA Team will carefully evaluate each case individually and seek to gain a deeper understanding of the organization’s governing structure during the Eligibility process and may adjust requirements accordingly in a way that maintains compliance with CCIA terms and conditions.

A Board Resolution should outline the organization’s involvement with the NCN CCIA program, including goals and objectives. However, it can be lenient on the overall vision to accomplish the set tasks and work plan. NCN is creating a comprehensive Board Resolution Template for CCIA funding requests. This template will enable Community Lenders to easily adjust according to their policy requirements and boldly present to their Board of Directors. This innovative tool will set you up for success!

Federal filings are necessary, but they can vary based on your organization’s legal structure. According to EPA federal program eligibility requirements, a Community Lender must be one of the following entities: Public, Quasi-Public, Not-for-profit (other than a 501c3), or a nonprofit entity with 501c3 status. Federal tax filings will differ depending on your organization’s legal structure. If you have no tax filings, your case will be reviewed with NCN’s CCIA team to determine your eligibility for the CCIA Clean Energy program. In the case of a tribally run CDFI, NCN will require the submission of a tribal resolution and charter establishing the CDFI and showing its “status”.

NCN’s CCIA Team will carefully review your organization’s development plans on a case-by-case basis to establish suitable eligibility timelines that align with both the Community Lender’s requirements and NCN’s EPA approved project schedule.

Watch for registration information and links to register for the NCN Clean Energy Finance Institute or individual sessions.

NCN wants to emphasize that there is no limit on the participation of Community Lender staff in the NCN Clean Energy Finance Institute. We suggest that staff members who are involved in the planning and management of the organization’s clean energy initiatives should be the primary participants in the program. This will guarantee that the information and resources are effectively understood and communicated within your organization’s overall program.