Frequent Questions about Solar for All
Through the $7 billion Solar for All competition, EPA awarded 60 grants to states, territories, Tribal governments, municipalities, and eligible nonprofits to expand the number of low-income and disadvantaged communities primed for residential solar investment—enabling millions of low-income households to access affordable, resilient, and clean solar energy.
The content on this page includes frequently asked questions about the Solar for All program design and application period. For frequently asked questions about the implementation of all three Greenhouse Gas Reduction Fund programs, please visit the Frequent Questions About the Fund page.
- General Program Questions
- Application and Threshold Eligibility
- Competition Terminology
- Application Components and Evaluation Criteria
- Award Administration
General Program Questions
Application Logistics
Whom can I contact with technical questions that are not addressed in a current solicitation notice or in the FAQs?
- Please email [email protected]
Can an applicant submit multiple applications to the same competition?
- An applicant can submit multiple applications to Solar for All, and there is no limit on the number of applications an applicant can submit. An applicant may submit more than one application for the Solar for All competition, including more than one application to a particular award option, so long as each application is for a different program (serving a different geography and different scope of work) and is separately submitted. Each application must address only one award option.
Can an applicant submit applications to more than one GGRF competition?
- An applicant can submit an application to more than one GGRF competition.
When is the deadline for submitting applications?
- The deadline for submitting applications to Solar for All is September 26, 2023, at 11:59 PM (Eastern Time) through Grants.gov.
When does EPA plan to start making awards?
- EPA anticipates beginning to make awards in July 2024.
Can EPA share the partner connection list with organizations that did not complete the partner connection forms?
- No, EPA cannot share the partner connection list with organizations that did not complete the partner connection forms. The partner connection forms are now closed and not open for additional submission.
Will there be additional competitions for Solar for All funding?
- EPA does not anticipate additional competitions for Solar for All.
- The Inflation Reduction Act requires EPA to award all Solar for All funds by September 30, 2024.
Where can applicants go for help navigating Grants.gov?
- For more information on how to apply to EPA grants please see EPA’s How to Apply for Grants.
- EPA also recommends applicants refer to information on Grants.gov including the:
Solar for All is focused on funding programs that provide financial assistance and technical assistance to enable low-income and disadvantaged communities to deploy and benefit from residential solar. Are there any similar federal programs that support non-residential solar projects?
- Solar for All is focused on delivering utility bill savings to households that need it the most, so this program is focused on residential solar (including residential-serving community solar).
- EPA does not have a comparable program for states, territories, Tribal governments, municipalities, and eligible nonprofit recipients to fund non-residential solar (i.e., community solar that does not serve households and utility-scale solar).The U.S. Department of Energy has some solar programs, including the National Community Solar Partnership. For additional opportunities, please refer to the “Search Grants” page on Grants.gov.
Can you provide additional instructions on how to complete the Application for Federal Assistance (SF-424) and Budget Information for Non-Construction Programs (SF-424A)?
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Applicants can find instruction for how to complete the required forms on EPA’s website. These instructions include:
Can an individual who is not the Authorized Organization Representative (AOR) sign mandatory forms such at the Grants.gov Lobbying Form?
- To submit an application in Grants.gov, the AOR must sign required forms such as the Lobbying Form. If an applicant wishes for another person to sign the required forms, the applicant can download the form from EPA.gov to sign by someone other than the AOR and upload the form as an attachment to the application, yet the uploaded form does not replace the form signed by the AOR.
Application and Threshold Eligibility
Eligible Applicants
Who is eligible for an award under this competition?
- States, territories, Tribal governments, municipalities, and eligible nonprofit recipients are eligible to apply for Solar for All. These categories include:
- States & Territories: All 50 states, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands.
- Municipalities: A city, town, borough, county, parish, district, or other public body created by or pursuant to state law. A council of government (COG), created by or pursuant to the laws of one or more states, is an eligible applicant under this category even if the COG is also an eligible nonprofit recipient.
- Tribal Government: Any Indian Tribe, band, nation, or other organized group or community, including any Alaska Native village, which is Federally recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians. EPA includes Intertribal Consortia that meet the requirements of 40 CFR § 35.504 as an eligible applicant under this category.
- Eligible Recipient (titled “Eligible Nonprofit Recipient”): An eligible recipient (a) is a non-profit organization; (b) is designed to provide capital, leverage private capital, and provide other forms of financial assistance for the rapid deployment of low- and zero-emission products, technologies, and services; (c) does not take deposits other than deposits from repayments and other revenue received from financial assistance provided using grant funds under this program; (d) is funded by public or charitable contributions; and (e) invests in or finances projects alone or in conjunction with other investors.
- Both individual applicants as well as coalition applicants are eligible to apply to Solar for All.
- Solar for All offers applicants three different award options to apply for; the eligible applicants for each award option differs; the below table summarizes which applicants are eligible for each award option:
Applicant, Award and Scope of Work information |
Award Option #1 – State and Territory Programs |
Award Option #2 – American Indian and Alaska Native Programs |
Award Option #3 – Multi-state Programs |
---|---|---|---|
Eligible applicants including coalitions with a lead applicant that is an eligible recipient |
States |
||
Territories |
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Tribal governments |
Tribal governments |
Tribal governments |
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Municipalities |
Municipalities |
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Eligible nonprofit recipients |
Eligible nonprofit recipients |
Eligible nonprofit recipients |
|
Number of awards |
Up to 56 |
Up to 5 |
Up to 10 |
Geographic Scope of work |
Develop Solar for All programs that serve a specific state/territory |
Develop Solar for All programs that serve American Indian and Alaska Native Communities |
Develop Solar for All programs that serve similar communities in multiple states |
- Refer to Section III.A: Eligible Applicants of the Notice of Funding Opportunity for additional detail on considerations for eligibility.
Are individual households, buildings, or organizations with one or a few solar projects eligible to apply to Solar for All?
- No, only states, territories, municipalities, Tribal governments, and eligible nonprofit recipients can compete for funding under the Solar for All grant competition.
- Selected recipients will use the grant funds to develop long-lasting programs that assist individual households, buildings, organizations, and other beneficiaries in their jurisdictions or program geographies.
- Refer to Section III.A: Eligible Applicants of the Notice of Funding Opportunity for more details on the definition of an eligible applicant.
Can for-profit companies (e.g., solar developers, small business owners, technology providers) apply to Solar for All?
- No, only states, territories, municipalities, Tribal governments, and eligible nonprofit recipients can compete for funding under the Solar for All grant competition, as defined in Section III.A: Eligible Applicants of the Notice of Funding Opportunity.
What types of nonprofits are eligible applicants for Solar for All?
- As described in the Notice of Funding Opportunity, Section III.A: Eligible Applicants, Section 134(c)(1) of the Clean Air Act provides that an eligible recipient (a) is a nonprofit organization; (b) is designed to provide capital, leverage private capital, and provide other forms of financial assistance for the rapid deployment of low- and zero-emission products, technologies, and services; (c) does not take deposits other than deposits from repayments and other revenue received from financial assistance provided using grant funds under this program; (d) is funded by public or charitable contributions; and (e) invests in or finances projects alone or in conjunction with other investors. An applicant must describe how they are an eligible recipient in the applicant’s Summary Program Cover Page, as described in Section IV.C: Content of Application Submission.
- Each nonprofit seeking eligibility must provide supporting evidence (including organizational documents, such as articles of incorporation or similar documents filed with a governmental authority as a condition of carrying out its activities; tax filings; financial statements; investment records; and/or any other information the applicant deems appropriate), showing that it:
- Meets the definition of Nonprofit organization set forth in 2 CFR § 200.1;
- Has an organizational mission consistent with being “designed to provide capital, leverage private capital, and provide other forms of financial assistance for the rapid deployment of low- and zero-emission products, technologies, and services;”
- Does not receive any “deposit” (as defined in Section 3(l) of the Federal Deposit Insurance Act) or “member account” or “account” (as defined in Section 101 of the Federal Credit Union Act);
- Is funded by public or charitable contributions; and
- Has the legal authority to invest in or finance projects.
If an entity is waiting for a 501(c)3 approval, will the entity qualify as a nonprofit with provisional approvals from IRS?
- An entity may still qualify as a nonprofit organization without 501(c)(3) approval because 501(c)(3) status is not required for an entity to meet the definition of “nonprofit organization” in 2 CFR § 200.1.
- 2 CFR § 200.1 states that a nonprofit organization “means any corporation, trust, association, cooperative, or other organization, not including Institutes of Higher Education, that: (1) is operated primarily for scientific, educational, service, charitable, or similar purposes in the public interest; (2) is not organized primarily for profit; and (3) uses net proceeds to maintain, improve, or expand the operations of the organization.
Are agencies and instrumentalities of a unit of government eligible for Solar for All?
- Yes, an entity recognized by an eligible unit of government (i.e., a state, territory, tribal government, or municipality) as an agency or instrumentality is eligible to apply as the unit of government. Examples of entities that may be recognized as an agency or instrumentality include housing authorities, municipal utilities, rural cooperative utilities, and public institutions of higher education.
- As described in Section III.C: Threshold Eligibility Criteria of the Notice of Funding Opportunity, if more than one agency of a unit of government submits an NOI, EPA staff will contact the agencies and advise them to coordinate to decide which agency(ies) will withdraw the NOI(s) such that EPA receives only one NOI per unit of government.
Can multiple agencies from the same unit of government submit separate applications to Solar for All?
- For this competition, if an entity applies as an agency or instrumentality of a unit of government, EPA considers that entity to be applying on behalf of the entire unit of government. Agencies or instrumentalities within the same unit of government cannot submit duplicate applications (i.e., applications that have the same scope of work). This requirement applies to all units of government eligible to compete in this competition (i.e., states, territories, tribal governments, and municipalities).
- As described in Section III.C: Threshold Eligibility Criteria of the Notice of Funding Opportunity, if more than one agency of a unit of government submits an NOI for applications with the same scope of work, EPA staff will contact the agencies and advise them to coordinate to decide which agency(ies) will withdraw the NOI(s) such that EPA receives only one NOI per unit of government.
- Given the limited number of awards in this competition, EPA strongly suggests agencies and instrumentalities in the same unit of government coordinate and submit one application. While, technically, agencies and instrumentalities from the same unit of government may submit multiple applications for programs with different scopes of work, EPA discourages this. As described in Section II.A: Number and Amount of Awards of the Notice of Funding Opportunity, EPA aims to maximize geographic coverage across all three award options. EPA anticipates making up to 60 awards under the Solar for All competition. If EPA receives multiple applications serving the same geography, EPA will likely only award one award to serve that geography, especially under award option #1.
Can an eligible applicant apply with the intent of contracting with another entity to administer the program?
- Yes, applicants do not need to identify all subgrantees at the time of application (only coalition members must be named) or all contractors at the time of application. Applicants should specify in the Budget Narrative and the Budget Table the intent to award subawards and enter into a procurement contract even if the other entity is not identified. Applicants should also explain in the Program Narrative their vision, plan, and strategy for the program and the role of the program administrator in implementation.
- Additional information on subgrantees and coalition applications is included in Section I.D: Competition Terminology and Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity.
- Additional information on the Budget Table is in Appendix B: Program Budget of the Notice of Funding Opportunity.
Can a for-profit company participate in a Solar for All application?
- EPA strongly advises applicants not to name for-profit companies (including consultants) as subrecipients or contractors in their application. It is highly likely that, unless an applicant has reviewed EPA’s Subaward Policy, EPA’s Guidance on Participant Support Costs, and the Procurement Standards in 2 CFR § 200 and 1500, applicants that name for-profit companies in their application will fail to demonstrate compliance with the requirements for the transfer of funds to a for-profit company described in Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity. Failure to comply with these requirements will result in the application being deemed ineligible for the competition.
- In most instances, for-profit companies are not eligible to receive subawards, consistent with 2 CFR § 200 and 1500 and the EPA Subaward Policy. Therefore, for-profit companies are unlikely to be eligible coalition members.
- In most instances, when a grantee transfers funds to a for-profit company, the transaction is considered a contract subject to the competitive procurement requirements.
- A grantee who transfers funds awarded through this competition must comply with the Procurement Standards in 2 CFR § 200 and 1500, EPA’s Subaward Policy, and EPA’s Guidance on Participant Support Costs, as applicable, depending on the vehicle that the grantee uses to transfer funds, as well as the Participation by Disadvantaged Business Enterprises in EPA Programs requirements in 40 CFR § 33.
- If an applicant names contractors (including consultants) or subrecipients in an application, please carefully review Section IV.d, “Contracts and Subawards,” of EPA Solicitation Clauses as well as the guidance in Section III.B: Named Contractors and Named Subrecipients in the Notice of Funding Opportunity. By 2 CFR § 200.320(c)(2) and (4), the Agency does not accept justifications for sole source contracts for services or products available in the commercial marketplace based on a contractor’s role in preparing an application or existing relationships that an applicant may have established without complying with competitive procurement requirements. 2 CFR § 200.320(c)(2) and (4), the Agency does not accept justifications for sole source contracts for services or products available in the commercial marketplace based on a contractor’s role in preparing an application or existing relationships that an applicant may have established without complying with competitive procurement requirements.
- State applicants have different procurement requirements. As provided in 2 CFR § 200.317, States, as defined in 2 CFR § 200.1, follow the same competitive policies and procedures they use for procurements with non-Federal funds, so EPA defers to state determinations on sole source contracting.
- If applicants name contractors or subrecipients in their application, they must demonstrate in their application how they adhered to the Procurement Standards in 2 CFR § 200 and 1500, EPA’s Subaward Policy, and EPA’s Guidance on Participant Support Costs, as applicable, depending on the vehicle that the grantee uses to transfer funds, as well as the Participation by Disadvantaged Business Enterprises in EPA Programs requirements in 40 CFR § 33.
- Failure to demonstrate compliance with these requirements for named contractors in the application will result in the rejection of the application. All applications must comply with the requirements for named contractors and subrecipients, as described in Section III.B: Named Contractors and Named Subrecipients in the Notice of Funding Opportunity.
- Successful applicants that do not name procurement contractors in their applications must also comply with these requirements, regardless of if the contractor was procured before or after the EPA grant agreement is awarded. For example, firms or individual consultants that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements as provided in 2 CFR § 200.319(b).
Do applicants to Solar for All need to be U.S. owned/operated?
- Applicants, including lead applicants for coalition applications, must be incorporated in the United States.
Can smaller groups be subgrantees of the Solar for All grant?
- Yes, Solar for All grantees can award subgrants. As described in Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, a grantee who transfers funds awarded through this competition must comply with the Procurement Standards in 2 CFR § 200 and 1500, EPA’s Subaward Policy, and EPA’s Guidance on Participant Support Costs, as applicable, depending on the vehicle that the grantee uses to transfer funds, as well as the Participation by Disadvantaged Business Enterprises in EPA Programs requirements in 40 CFR § 33.
For local communities, do applications have to include a municipal utility as a coalition partner?
- No, there is no requirement that an applicant partner with a utility to apply to Solar for All.
Can a municipality that is not a low-income and disadvantaged community as defined by the White House Climate and Economic Justice Screening Tool (CEJST) apply to Solar for All?
- An entity that meets the definition of municipality in the Notice of Funding Opportunity, Section III.A: Eligible Applicants is eligible to apply to Solar for All.
- A municipality must use Solar for All funds to provide financial and technical assistance to enable “low-income and disadvantaged communities” to deploy and benefit from residential distributed solar. If the municipality is not identified as disadvantaged in CEJST or EJScreen, the municipality may have eligible beneficiaries that are in either geographically dispersed low-income households or properties providing affordable housing.
- GGRF defines low-income and disadvantaged communities as any community covered by one or more of the following four categories: (a) communities identified as disadvantaged by the CEJST mapping tool; (b) a limited number of additional communities identified as disadvantaged by the EJScreen mapping tool; (c) geographically dispersed low-income households; and (d) properties providing affordable housing.
- More information on these four categories is in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
What documents are required for states, territories, Tribal governments, and municipalities for “Attachment C: eligibility evidence documents supporting that the applicant is an eligible applicant as described in Section III.A: Eligible Applicants” as described in Section IV.B: Application Materials?
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Applicants applying as a state, territory, Tribal government, or municipality can leave “Attachment C” blank, except municipalities under the definition of a council of government (COG) and Intertribal Consortia are required to provide evidence documents as described in Section III.A of the Notice of Funding Opportunity.
Coalition Applications
Can coalitions apply to Solar for All (i.e., one eligible applicant leading a coalition of eligible subrecipients with the one eligible applicant acting as a pass-through entity for program funds)? What is the difference between a coalition and a partnership?
- Yes, coalitions are eligible to apply to Solar for All. A coalition is a type of partnership in which one lead applicant partners with one or more non-lead coalition member(s) that are named in the application and would receive subawards (in the form of subgrants) to carry out a portion of the grant’s activities if the application is selected. The definition of a coalition application is described in more detail in the Notice of Funding Opportunity, Section I.D: Competition Terminology.
- For this competition, all named subrecipients must be coalition members as described in Section III.B: Named Contractors and Named Subrecipients in the Notice of Funding Opportunity, and if the application names a subrecipient, the entity must be eligible for a subaward in compliance with Appendix A of EPA's Subaward Policy.
- As described in Section III.B: Named Contractors and Named Subrecipients, EPA does not require nor encourage applicants to name subrecipients in their Solar for All applications. Even if applicants intend to make subawards, applicants do not need to identify all subrecipients at the time of application.
- If applicants intend to award any subawards during the program, applicants should identify in the Budget Narrative and the Budget Table the intent to award subawards even if the subgrantee is not specified. Detail on filling out the Budget Table can be found in the Notice of Funding Opportunity in Appendix B: Program Budget.
- The only difference between a coalition application and a non-coalition application is that a coalition application must name the non-lead coalition members as subrecipients and include a Memorandum of Agreement that confirms the participation of the non-lead coalition members. The Memorandum of Agreement requirement does not need to be legally binding and is described in Section III.C: Threshold Eligibility Criteria in the Notice of Funding Opportunity. EPA does not intend to provide a template Memorandum of Agreement.
What is the difference between a lead applicant and a subrecipient for coalition applications? Can a coalition application include organizations that contribute to the program meaningfully, such as an implementation partner, but do not receive a subaward?
- As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, a lead applicant is an eligible applicant who applies on the coalition's behalf. If selected, the lead applicant will become the grantee, administer the grant as a pass-through entity for the purposes of 2 CRF Part 200, and be accountable to EPA for effectively carrying out the full scope of work and the proper financial management of the grant (including subawards to non-lead coalition members). Note that pursuant to 2 CFR § 200.332(a)(2), as implemented in Items 2 and 4 of EPA’s Establishing and Managing Subawards General Term and Conditions, successful lead applicants of coalitions must ensure that the terms and conditions of the grant agreement “flow down” to any coalition members as well as other eligible subrecipients that are provided subawards.
- A non-lead coalition member is an entity that is eligible to receive a subaward under the EPA Subaward Policy and is named in the application as a subrecipient that would receive a subaward (in the form of subgrant) to carry out a portion of the grant activities if the application is selected. If selected, as provided in 2 CFR § 200.332, non-lead coalition members will become subrecipients accountable to the lead applicant for proper use of EPA funding.
- Only organizations that receive a subaward should be considered coalition partners. Applicants can highlight organizations, key contributors, or implementation partners to the program who will support the program in the Program Narrative. An applicant may provide letters of support from these partners, as described in Section IV.B: Application Materials of the Notice of Funding Opportunity.
- All named subrecipients must be coalition members as described in Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, and if the application names a subrecipient, the entity must be eligible for a subaward in compliance with Appendix A of EPA’s Subaward Policy.
- EPA does not require nor encourage applicants to name subrecipients in their Solar for All application, and even if applicants intend to make subawards, applicants do not need to identify all subrecipients at the time of application.
Do all members of a coalition have to be eligible applicants?
- A lead applicant in a coalition must be an eligible applicant as defined in Section III.A: Eligible Applicants of the Notice of Funding Opportunity and apply on behalf of the coalition.
- As described in Section I.D: Competition Terminology and Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, the non-lead coalition member(s) may be eligible nonprofit recipients as well as other types of nonprofits, governmental entities, and Institutions of Higher Education, as defined in 2 CFR § 200.1, that are eligible for subawards under the EPA Subaward Policy.
- For-profit entities, including for-profit firms, individual consultants, proprietary colleges and universities, and similar for-profit providers of educational services, are not eligible for subawards under this program and cannot be coalition members.
Can a nonprofit that is not an eligible nonprofit recipient still be eligible as a non-lead coalition member?
- Yes, as described in Section III.A: Eligible Applicants in the Notice of Funding Opportunity, non-lead coalition members may be eligible nonprofit recipients, other types of nonprofits, governmental entities, and Institutions of Higher Education that are entities eligible for subawards under the EPA Subaward Policy.
- See the definition of Institution of Higher Education at 2 CFR § 200.1. Proprietary colleges and universities and similar for-profit providers of educational services are not eligible for subawards under this program.
For coalition applicants, do Memorandums of Agreement need to be legally binding?
- No, the required Memorandum of Agreement for coalition applications, as described in Section III.C: Threshold Eligibility Criteria of the Notice of Funding Opportunity, does not need to be legally binding.
Can an entity be in a coalition and submit multiple applications?
- Yes, an entity may submit more than one application for the Solar for All competition and be a coalition partner in more than one application, so long as each application is for a different program (serving a different geography and/or different scope of work) and is separately submitted, as described in Section II.A: Number and Amount of Awards.
Is there a maximum or minimum amount of grant funds that a lead coalition applicant may subaward to coalition members?
- There is no maximum or minimum amount of grant funds that a lead applicant can subgrant to coalition members. Entities exploring partnering with a lead applicant in a coalition application should discuss the amount of grant funds they need to perform their respective scope of work.
Are there any additional limitations on the grant activities a lead applicant of a coalition can perform?
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No, coalition applications can choose what grant activities the lead applicant executes and subsequently the grant activities the non-lead coalition members carry out.
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If selected, the lead applicant will become the grantee, administer the grant as a pass-through entity for the purposes of 2 CRF Part 200, and be accountable to EPA for effectively carrying out the full scope of work and the proper financial management of the grant (including subawards to non-lead coalition members).
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Additionally, if selected, as provided in 2 CFR § 200.332, non-lead coalition members will become subrecipients accountable to the lead applicant for proper use of EPA funding.
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Note that pursuant to 2 CFR § 200.332(a)(2), as implemented in Items 2 and 4 of EPA’s Establishing and Managing Subawards General Term and Conditions, successful lead applicants of coalitions must ensure that the terms and conditions of the grant agreement “flow down” to any coalition members as well as other eligible subrecipients that are provided subawards.
Notice of Intent
Do applicants need to provide a Notice of Intent (NOI) for each application they submit?
- Yes, applicants must submit a Notice of Intent (NOI) to be eligible to apply to the Solar for All competition, as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity. An NOI is required for every application you anticipate submitting. Additionally, in the submitted application, each applicant must attach a copy of the NOI submission that applies to that application as Attachment B to the Program Narrative, as described in Section I.IV: Application Materials of the Notice of Funding Opportunity.
What is the NOI deadline for a coalition application?
- The lead applicant determines the NOI deadline for a coalition application, as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity. For example, if the lead applicant of a coalition is a municipality, then the deadline to submit an NOI for the coalition is August 14, 2023—the NOI deadline for all municipal applicants. As listed in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity, the deadlines for NOIs are:
- July 31, 2023, for states, the District of Columbia, and Puerto Rico;
- August 14, 2023, for territories (specifically, The Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands), municipalities, and eligible nonprofit recipients; or
- August 28, 2023, for Tribal governments and Intertribal Consortia.
Can applicants submit multiple NOIs?
- Yes, applicants can submit multiple NOIs since applicants may apply multiple times to Solar for All, as described in Section II.A: Number and Amount of Awards of the Notice of Funding Opportunity. Applicants must submit an individual NOI for each application they anticipate submitting, as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
For a nonprofit in Puerto Rico and the District of Columbia, what is the deadline to submit an NOI?
- The NOI deadline for all eligible nonprofit recipients, including eligible nonprofit recipients in Puerto Rico and the District of Columbia, is August 14, 2023, 11:59 PM (Eastern Time), as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
Can applicants provide a range of funding requested in the NOI response?
- EPA suggests applicants provide an estimate of the funding they will request in their application in the NOI. As described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity, all applicants may change the EPA requested funding amount submitted in the NOI in their application. If applicants change their EPA requested funding amount, they must explain why the requested funding amount in the application differs from the requested funding amount in the NOI. However, applicants may provide a range if necessary. Applicants must request a specific amount of funding when applying.
If a state submits an NOI for this grant, can a municipality in the same state apply?
- Yes, if a state submits a NOI for Solar for All, a municipality in the same state can submit a NOI and apply separately from the state.
Do coalition applications need all coalition members listed in their NOI? Can coalition applicants add new coalition members in the application that were not initially listed in the NOI?
- As described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity, coalition applications do not have to have coalition members listed in their NOI.
- Applicants can add new coalition members in the application that were not initially listed in the NOI.
- If coalition partnerships are uncertain, EPA recommends applicants do not include coalition partner names in their NOI.
- If coalition partnerships are certain, EPA recommends applicants include coalition partner names in their NOI.
For coalition applications, may a potential subrecipient submit an NOI on behalf of a lead applicant?
- No, the lead applicant must submit an NOI for coalition applications to be eligible for Solar for All, as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
Do applicants need to indicate in their NOI that they are applying as a coalition?
- No, applicants do not need to indicate in the NOI that they are applying as a coalition.
- The lead applicant of coalition applications must have submitted a Notice of Intent (NOI) by the listed deadline and according to the instructions in Section I.F: Required Notice of Intent and described in Section III.C Threshold Eligibility of the Notice of Funding Opportunity to be eligible for Solar for All.
How do applicants determine who is an appropriate authorized official to sign a letter of support for the Notice of Intent?
- Applicants are required to submit a Notice of Intent with a letter of support signed by an authorized official.
- The authorized official differs based on the type of entity the eligible applicant the applicant is (i.e., state, Tribal government, municipality, eligible nonprofit recipient), and is described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
- The type of entity determines who is the appropriate authorized official, and the list of authorized officials by type of entity can be found in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
- For example, if the applicant is an eligible nonprofit recipient, the authorized official is the executive director or equivalent senior management level official of the nonprofit (e.g., executive director, chief executive officer, chief operating officer).
- If the application is a coalition, then the authorized official is determined by the lead applicant. For example, if the coalition application has designated a Tribal government as the lead applicant for the coalition, the authorized official is the chief executive of the Tribe (e.g., chairperson, president) or executive director or equivalent senior management level official of an intertribal consortium that meets the requirements of 40 CFR 35.504.
- For eligible nonprofit recipients, the authorized official does not differ if the eligible nonprofit recipient is serving a specific geography or the jurisdiction. For example, if an eligible nonprofit recipient is applying to serve a state, the authorized official is the executive director or equivalent senior management level official of the nonprofit (e.g., executive director, chief executive officer, chief operating officer). In this, and similar, scenarios, the governor of the state, or leader of the jurisdiction, is not an authorized official.
Is EPA reviewing NOIs to confirm applicant eligibility?
- EPA will not be reviewing or making determinations about an applicant’s eligibility based solely on the information provided in the Notice of Intent; EPA will determine an applicant’s eligibility based on the information provided in the full application.
- To understand if you are an eligible applicant, please refer to Section III.A: Eligible Applicants and Section III.C: Threshold Eligibility Criteria of the Notice of Funding Opportunity.
Can an entity withdraw a Notice of Intent?
- Yes, applicants may withdraw a Notice of Intent by emailing [email protected].
Will EPA “approve” NOIs? Should applicants wait to hear from EPA before drafting their application?
- No, EPA is not approving NOIs. Applicants should not wait to hear from EPA before drafting their application.
- EPA will reach out to applicants if their NOI is incomplete—specifically, when an applicant does not submit answers to all the required questions or an applicant does not have a letter signed by an appropriate authorized official.
Will EPA offer extensions for interested entities that did not submit an NOI ahead of the deadline?
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No, EPA will not offer extensions for entities that did not submit an NOI.
Is an entity that did not submit an NOI eligible to apply to the competition as a lead applicant for a coalition if one of the non-lead coalition members submitted an NOI?
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No, the lead applicant of a coalition must submit an NOI by the listed deadline and according to the instructions in Section I.V: Required Notice of Intent as described in Section III.C: Threshold Eligibility Criteria. Coalitions with a lead applicant that did not submit an NOI according to the instructions in Section I.V: Required Notice of Intent will be deemed ineligible.
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In addition to meeting the relevant threshold eligibility criteria detailed in Section III.C: Threshold Eligibility Criteria in the Notice of Funding Opportunity, the lead applicant of a coalition must also have an active SAM.gov registration and Unique Entity ID (UEI) as described in Appendix A: Grants.gov Application Submission Instructions of the Notice of Funding Opportunity. Please review Appendix A. Grants.gov Submission Instructions of the Notice of Funding Opportunity to understand how to submit an application.
If an applicant that has submitted an NOI will no longer submit an application to Solar for All, can another eligible applicant, such as an applicant who intended to be a coalition member of the original entity that submitted an NOI, apply with the NOI?
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As described in Section III.C: Threshold Eligibility Criteria, applicants that are eligible nonprofits recipients, councils of government, and intertribal consortia must be the same legal entity that submitted an NOI unless EPA’s Selection Official or designee grants a waiver to this requirement based on an unanticipated change in circumstances that have taken place since the submission of the NOI.
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EPA will consider granting a waiver to this requirement if the original legal entity that submitted an NOI emails [email protected] to inform EPA in the body of an email that they will no longer apply to Solar for All; explain the change in circumstances that have taken place since the submission of the NOI; state explicitly what legal entity they want to apply to Solar for All with the original NOI; and state that no other legal entity will apply with the original NOI.
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If EPA grants this waiver, all requirements detailed in the Solar for All Notice of Funding Opportunity in Section I.F: Required Notice of Intent and Section III.C: Threshold Eligibility Criteria apply.
Can applicants submit an application with a different program geography than described in the Notice of Intent?
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Information submitted in the NOI must be identical to information submitted in the application, except answers to question 1 (applicant name) for some applicants and answers to question 3.c (estimated EPA funding amount requested) for all applicants.
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Information on program geography submitted in the NOI must be identical to information submitted in the application.
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These exceptions are explained in Section III.C: Threshold Eligibility Criteria.
Can applicants change the coalition members listed in the Notice of Intent in their application?
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Yes, applicants may apply to Solar for All with a different list of coalition members than was originally listed in the Notice of Intent, including removing a coalition member.
Can EPA provide contact information for entities that submitted NOIs?
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If an entity that submitted an NOI emails [email protected] requesting contact information for another entity that submitted an NOI, EPA will ask both entities to separately confirm in an email that EPA can share their contact information with the other entity. If both entities confirm in separate emails that EPA may share their contact information, EPA will share contact information with the specific entities.
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Please note, EPA will only consider requests for contact information from entities that submitted NOIs.
Can a group of applicants that submitted separate NOIs with separate program locations form a coalition that collectively serves all the program locations described in all of the separate NOIs apply to Solar for All?
- No, information submitted in the NOI must be identical to information submitted in the application, except answers to question 1 (applicant name) for some applicants and answers to question 3.c (estimated EPA funding amount requested) for all applicants. These exceptions are explained in Section III.C: Threshold Eligibility Criteria.
- Information on program geography submitted in the NOI must be identical to information submitted in the application.
- Additionally, an NOI is required for every application, as described in Section I.F: Required Notice of Intent of the Notice of Funding Opportunity.
Can applicants that suggested in their NOI that the program may serve a specific and clearly defined geography (in addition to the geography that was stated in the NOI as the explicit program location) apply to Solar for All with a program that serves the geography suggested in their NOI?
- EPA requests that applicants that intend to submit an application serving a geography that the applicant listed as uncertain in their NOI email [email protected] to request clarification from EPA with a copy of their NOI and a short sentence regarding what specific geography their application intends to serve.
- Generally, information on program geography submitted in the NOI must be identical to information submitted in the application.
Number and Amount of Awards
Should coalitions of municipalities that are all located in one state apply to award option #1 or award option #3?
- Coalitions of municipalities that are all located in one state should apply to award option #1.
Can multiple municipalities from the same state submit separate applications to award option #1?
- Given the limited number of awards in this competition, EPA strongly encourages municipalities within the same state to either:
- Coordinate with the state government if the state government has submitted a Notice of Intent to apply to Solar for All, or
- Coordinate and submit one coalition application to serve the state to award option #1.
- As described in Section II.A: Number and Amount of Awards, EPA only intends to award a maximum of 56 awards under award option #1—one for each state and territory eligible for Solar for All. If EPA receives multiple applications serving the same state in award option #1, EPA will likely only award one award to serve that state under award option #1. While programs under award option #1 do not need to serve the entirety of the state or territory, EPA will evaluate applications that maximize geographic coverage more favorably, as described in Section II.A: Number and Amount of Awards.
- Municipalities from the same state can technically submit individual or coalition applications under award option #1. However, given the limited number of awards in this competition, EPA strongly suggests municipalities within the same state coordinate and submit one application.
If multiple states are interested in working with a nonprofit that will apply to award option #3, will those states “lose” their allocation in award option #1?
- Section 134(a)(1) of the Clean Air Act provides that Solar for All is a competitive grant program. Therefore, there are no statutory allocations in the competition, and EPA may modify award allocations based on the quality of applications that are received and other program considerations.
- As described in Section II.A: Number and Amount of Awards of the Notice of Funding Opportunity, EPA aims to maximize geographic coverage across all three award options. EPA anticipates making up to 60 awards under the Solar for All competition, and the number of awards described for each award option in Section II.A: Number and Amount of Awards is an approximate maximum amount of awards EPA anticipates making in each bucket—EPA intends to limit the total number of awards across all three award options to 60 awards; however, EPA may modify this award allocation.
Could an applicant for award option #2 – American Indian and Alaska Native programs apply to fund programs that serve specific American Indian and Alaska Native communities? Do all award option #2 applicants have to apply to fund programs that serve all American Indian and Alaska Native communities?
- Applicants to award option #2 – American Indian and Alaska Native programs can apply with a program that serves specific American Indian and Alaska Native communities. Applicants to this award option do not need to serve all American Indian and Alaska Native communities nationwide to be eligible to apply.
- EPA encourages applicants for award option #2 – American Indian and Alaska Native programs to develop applications that maximize the communities and households that can benefit from the program. EPA anticipates awarding up to 5 awards for award option #2 as described in Section II.A: Number and Amount of Awards of the Notice of Funding Opportunity, and EPA aims to maximize geographic coverage across all three award options.
Can multiple states and/or territories apply as a coalition application and propose a program that serves multiple states and/or territories?
- No, as described in Section II.A: Number and Amount of Awards of the Notice of Funding Opportunity, state and territory applicants can only apply to award option #1, which requires all applications to propose a program that serves low-income and disadvantaged communities in one state or territory.
For award option #3, is an application that intends to serve two states and territories eligible for this award option?
- Yes, an application that serves two or more states and territories can apply to award option #3 so long as the application satisfies all threshold eligibility requirements defined in Section III.C Threshold Eligibility Criteria of the Notice of Funding Opportunity.
What does it mean for a program to serve a household?
- A program serves a household when the program enables the household to benefit from a solar photovoltaic (PV) system based on power production. A household benefits from a solar PV system when the household:
- Receives solar-generated electricity directly (e.g., a rooftop solar system delivering power directly to a single-family home);
- Is subscribed to part of a community solar system and receives a monetary credit for their share of the electricity generated from the community solar system; or
- Benefits indirectly from a solar PV system through a financial or non-financial benefit that meaningfully improves the lives of households directly (examples included in recent guidance from the U.S. Department of Housing and Urban Development) for households without individual electricity meters. Additional suggestions on how to serve households without separate electric meters are included in Appendix.C: Household Savings Guidance of the Notice of Funding Opportunity.
- Beyond directly serving households as defined above, applicants should also consider how the program will deliver additional meaningful benefits, as described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, of solar to households served by the program.
- EPA will evaluate applicants on the extent and quality of the plan to maximize meaningful benefits to households served by the program. This criterion is described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity.
Will EPA award partial awards?
- Yes, EPA may partially fund applications. As described in Section II.C: Partial Funding of the Notice of Funding Opportunity, EPA reserves the right to partially fund applications by funding discrete portions or phases of proposed projects. If EPA decides to fund an application partially, it will do so in a manner that does not prejudice any applicants or affect the basis upon which the application, or portion thereof, was evaluated and selected for award, and therefore maintains the integrity of the competition and selection process.
Is it possible for a state and a municipality in the same state/territory to both receive awards under award option #1?
- Yes, but it is unlikely. EPA anticipates awarding up to 56 grants under award option #1 to serve state and territory geographies. All eligible applicant types—states, Tribal governments, municipalities, and eligible nonprofit recipients are eligible to apply to award option #1.
- EPA anticipates making up to 60 awards across all three award options. Depending on the scope of the applications, EPA could make awards to both a state and a municipality in the same state/territory under award option #1, yet this is unlikely.
- Solar for All is a competitive grant competition. As described in Section V.B: Review and Selection Process, review panel(s) will review, score, and rank all eligible applicants that pass the threshold eligibility review based on the merit evaluation criteria listed in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity. All applicants to award option #1 will be ranked in the same ranking list.
- The review panel will present final rankings and selection recommendations to the Selection Official, who will then make the final selections for awards. Selections will be made to maximize geographic coverage across all three award options.
- In addition to this information, the Selection Official may also consider any of the following “other factors” in making final selection decisions from among the high-ranking applications, including GGRF program objectives; EPA strategic goals and objectives; availability of funds. The Selection Official may also consider the “other factors” across the three award options.
If the 60 selected applications exceed the total funds available, is it more likely EPA will partially fund applications or award fewer awards?
- As described in the Notice of Funding Opportunity, Section II.A: Number and Amount of Awards, EPA anticipates making up to 60 awards under this announcement—up to 56 awards for each state/territory eligible in this competition, up to 5 awards set aside to serve American Indian and Alaska Native Communities, and up to 10 awards for multi-state programs.
- EPA reserves the right to modify this award allocation based on the quality of applications that are received and other program considerations. EPA aims to maximize national geographic coverage of the program across all three award options.
- As described in Section II.C: Partial Funding, in appropriate circumstances, EPA reserves the right to partially fund applications by funding discrete portions or phases of proposed projects. If EPA decides to partially fund an application, it will do so in a manner that does not prejudice any applicants or affect the basis upon which the application, or portion thereof, was evaluated and selected for award, and therefore maintains the integrity of the competition and selection process.
What is the definition of Tribal leader for the Solar for All competition?
- For eligible nonprofit recipients applicants applying to award option #2, the applicant must have Tribal leadership at the senior management level of the organization.
- ‘Tribal leadership’ in this context means Tribal representation at the senior management level (e.g., Chief Executive Officer, Chief Operating Officer, at least one Member of the Board of Directors) of the organization, as described in Section III.C: Threshold Eligibility Criteria of the Notice of Funding Opportunity. Tribal representation means that the senior manager is an elected official or authorized representative of a Tribal Government as defined in Section III.A: Eligible Applicants in the Notice of Funding Opportunity.
- EPA expects applicants to document how they satisfy this threshold eligibility requirement in the Summary Program Cover Page of the Application as described in Section IV.C: Content of Application Submission of the Notice of Funding Opportunity.
Can applicants under award option #1 propose a program that serves both Tribal and non-Tribal households located in the same state?
- Yes, applicants under award option #1 can propose a program that serves both Tribal and non-Tribal households.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, applications for award option #1 in which there are American Indian and Alaska Native households in the state or territory the program will operate in, the application will be evaluated on the extent and quality of the plan to serve these communities. If the program will not serve one or more of these types of communities, the application will be evaluated on the quality of the rationale for why. Additionally, if the application is serving American Indian and Alaska Native households, the application will be evaluated on the quality and extent of the plan to meaningfully involve American Indian and Alaska Native households in program planning and operations.
If an applicant designs a two-part program for award option #1, one part focused on serving American Indian and Alaska Native households and another focused on non-Tribal households, can the applicant adjust the minimum intended funds dedicated to financial assistance to 65% for the program serving American Indian and Alaska Native households?
- No, the target minimum funding amounts for financial assistance, as described in Section IV.C: Content of Application Submission, is determined by the award option the applicant is applying to, not the communities or geographies the program is serving.
- For an applicant to award option #1, the guidance on minimum share of funds for financial assistance is 75%.
Can applicants include other low-income and disadvantaged communities' population data in addition to the CEJST population data to determine the award size for which they are eligible?
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To determine the applicable program award size for an applicant, applicants must use the population of disadvantaged census tracts identified by the CEJST within the geography the program will serve.
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Applicants may not augment the CEJST identified disadvantaged community population with other population data when determining the applicable program award.
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EPA is choosing to use the CEJST population as a proxy metric to determine the appropriate award range for applications, so all applicants are using the same readily available data to identify the appropriate award range.
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Applicants may still serve other categories of low-income and disadvantaged communities through their programs in alignment with the definition provided in Section I.D: Competition Terminology of the Notice of Funding Opportunity in their program.
Can applicants include population from census tracts labeled “TRUE” as “Is low income?” in column “Z” in addition to census tracts identified as disadvantaged in column “T” in their calculation of the total population of disadvantaged census tracts in the program geography?
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No, the only census tracts identified as disadvantaged are classified as “TRUE” in column “T” of the 1.0 communities list Excel.
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Column “Z” identifies census tracts that have been classified as low-income. There are some census tracts that are low-income but not identified as disadvantaged by the Climate and Economic Justice Screening Tool (CEJST), and while these census tracts are low-income, these census tracts are not identified as disadvantaged because they do not meet the threshold for at least one of the tool’s categories of burden.
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For a census tract to be identified as disadvantaged the census tract must meet the threshold for at least one of the tool’s categories of burden or if they are on land within the boundaries of Federally Recognized Tribes.
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The tool uses datasets as indicators of burdens. The burdens are organized into categories. A community is highlighted as disadvantaged on the CEJST map if it is in a census tract that is (1) at or above the threshold for one or more environmental, climate, or other burdens, and (2) at or above the threshold for an associated socioeconomic burden.
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Census tracts that are low-income but not identified as disadvantaged do not meet the threshold for one or more environmental, climate, or other burden.
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Conversely, there are census tracts that are identified as disadvantaged but are not low-income. These census tracts:
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Contain land within the boundaries of Federally Recognized Tribes
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Census tracts that are completely surrounded by disadvantaged communities and are at or above the 50% percentile for low-income
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Census tracts that are identified as disadvantaged because they are at or above the threshold for workforce development; the associated socioeconomic burden for the workforce development category is determined by high school education in the census tract as opposed to low-income
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Can applicants include population from census tracts identified as “partially” disadvantaged when calculating the total population of census tracts identified as disadvantaged by the CEJST in the geography they intend to serve?
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Yes, applicants may include a share of the total population of partially disadvantaged census tracts. The CEJST identifies some census tracts as “partially disadvantaged.” A partially disadvantaged census tract is one that does not meet any of the burden thresholds in the tool but contains land within the boundaries of Federally Recognized Tribes. The parts of the tract that contain the land of Tribes are considered disadvantaged.
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The communities list data Excel identifies partially disadvantaged census tracts in column “EC,” titled “percent of tract that is disadvantaged by area.” Census tracts with values in this column are partially disadvantaged. For purposes of determining the applicable program size, applicants who will be serving partially disadvantaged census tracts can count the population of partially disadvantaged tracts by taking a share of the population data in column “W” proportional to the share of the land in the tract that is disadvantaged.
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Census tracts with “0” values in column “EC” may be rounded up to “1 percent” since those listed as “0” in column “EC” have less than 1 percent and greater than 0% of the tract within the boundaries of Federal Recognized Tribes. For example, if a census tract is partially disadvantaged, and column “EC” states that 44 percent of the land by area is disadvantaged, applicants may count 44% of the total population (as stated in column “W”) of that census tract.
There are some Alaska Native Villages in census tracts that are not identified as disadvantaged by the CEJST. Can an applicant include the population of these Alaska Native Villages in their calculation of population identified as disadvantaged by the CEJST?
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Yes, communities on land within the boundaries of Federally Recognized Tribes are considered disadvantaged by the CEJST.
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The 1.0 communities data list Excel from the CEJST website does not have specific population data for Alaska Native Villages.
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Applicants may state in their application the population of the Alaska Native Villages the program will serve and include 100% of the population of the Alaska Native Villages when calculating what size award for which an applicant is eligible.
Can applicants applying to award option #2 – American Indian Alaska Native programs include the entire population of census tracks identified as disadvantaged by the CEJST when identifying the award amounts for which they are eligible? Should these applicants only include the American Indian and Alaska Native populations in census tracts identified as disadvantaged by the CEJST?
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Applicants applying to award option #2 – American Indian Alaska Native programs should identify the census tracts identified as disadvantaged by the CEJST in the geography that program will serve and include the entire population of those census tracts when calculating what size award for which the applicant is eligible, even when the program intends to serve a specific community or population in that census tract.
If applicants are proposing programs that serve a subset of low-income and disadvantaged communities in a geography, how should applicants determine the award size for which they are eligible to apply?
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Applicants serving a subset of low-income and disadvantaged communities can include 100% of the population in all census tracts identified as disadvantaged by the CEJST that the program will serve when calculating the award size for which the application is eligible.
What size program can applicants that are proposing programs in geographies with no census tracts identified as disadvantaged by the CEJST apply for?
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Applicants proposing a program in a geography with no census tracts identified as disadvantaged can apply for a small program – between $25 million and $100 million.
How should applicants who intend to serve American Indian and Alaska Native communities across multiple states and multiple Tribal Nations calculate their total population of disadvantaged census tracts identified by CEJST in their geography?
- Applicants that intend to serve American Indian and Alaska Native communities across a broad geography (e.g., multiple states, “nationwide”) can include the population of all census tracts identified as disadvantaged by CEJST in the geography they intend to serve. Applicants that intend to only serve households in Tribal Lands can either list the census tracts the applicant intends to serve specifically or consider using the data in column “EC”, titled “Percent of the Census tract that is within Tribal areas”, in the Communities list data Excel to estimate the population within the boundaries of Federally-recognized Tribes. To use column “EC”, applicants can filter the Excel by the geography of the program (e.g., a specific state), then sum 100% of any census tract which is both identified as disadvantaged and includes any Tribal areas (i.e., column EC with any numeric value) and sum the population of partially disadvantaged tracts by taking a share of the population data in column “W” proportional to the share of the land in the tract that is disadvantaged. As a reminder:
- Applicants may include a share of the total population of partially disadvantaged census tracts. The CEJST identifies some census tracts as “partially disadvantaged.” A partially disadvantaged census tract is one that does not meet any of the burden thresholds in the tool but contains land within the boundaries of Federally Recognized Tribes. The parts of the tract that contain the land of Tribes are considered disadvantaged.
- The communities list data Excel identifies partially disadvantaged census tracts in column “EC,” titled “percent of tract that is disadvantaged by area.” Census tracts with values in this column are partially disadvantaged. For purposes of determining the applicable program size, applicants who will be serving partially disadvantaged census tracts can count the population of partially disadvantaged tracts by taking a share of the population data in column “W” proportional to the share of the land in the tract that is disadvantaged.
- Census tracts with “0” values in column “EC” may be rounded up to “1 percent” since those listed as “0” in column “EC” have less than 1 percent and greater than 0% of the tract within the boundaries of Federal Recognized Tribes. For example, if a census tract is partially disadvantaged, and column “EC” states that 44 percent of the land by area is disadvantaged, applicants may count 44% of the total population (as stated in column “W”) of that census tract.
Scope of Work
Are applicants applying for funding for a single, specific solar project eligible for this program?
- EPA will not fund individual projects through this program. EPA aims for this program to fund long-lasting programs—these programs will transform markets by not only providing financial assistance to many projects in the market but also funding project-deployment technical assistance such as workforce development, project development services, consumer education and outreach, among other critical services needed to overcome non-financial residential deployment barriers.
If an applicant is considering a few different and distinct programs that serve different low-income populations, should each of these designs be submitted as individual or separate applications?
- If an applicant is interested in funding different programs in the same geography (e.g., a rooftop residential program and a community solar program), EPA recommends that applicants submit all programs in the same application.
What is the difference between a program and a project?
- Solar for All is a competition to fund long-lasting programs that fund many individual solar projects. EPA will not fund individual projects through Solar for All.
- A Solar for All program is a program that ensures low-income households have access to residential rooftop and residential-serving community solar energy, often through providing financial support and other incentives. A Solar for All program has a scope of work to provide financial assistance to many projects while providing multifaceted technical assistance sub-programs to many energy market stakeholders. A program has a scope of work that has catalytic impacts on the distributed residential solar market beyond the projects the program directly funds.
- A project is a single or few residential distributed solar projects that an entity is interested in receiving financial assistance to build. A project has a known scope of work that the entity does not intend to expand beyond a handful of distributed residential projects. In most cases, if a potential applicant knows all the projects the applicant is interested in using EPA grant funds to finance, the potential applicant does not have a program.
- EPA intends the programs funded by the Solar for All competition to fund projects. Entities with projects should wait for EPA to award Solar for All grants to programs next year and engage with the Solar for All grantees for financial assistance. EPA intends all communities nationwide to have access to Solar for All funds through Solar for All grantees.
Can a jurisdictional entity (e.g., a municipality, a Tribal government) propose a program that serves a geography larger than the entity’s geographic boundaries?
- Yes, a jurisdictional entity may propose a program that serves a geography larger than the entity’s geographic boundaries.
- For a jurisdictional entity, carrying out activities in another jurisdiction may pose more challenges, such as having to seek approval from the other jurisdiction for projects. This varies by state and local law. It is the responsibility of the recipient to address these challenges in carrying out the award. An applicant should therefore be mindful of any jurisdictional issues in developing a program strategy.
Period of Performance
Is the one-year planning period included in the five-year program period of performance?
- Yes, applicants should develop a program plan that deploys all grant funds within five years of receiving the award, including up to one year of program planning. For example, if an applicant designs a program plan with one year of program planning, then the applicant has four years to deploy all program funds.
What funds will be available to grantees in the planning period?
- Before using grant funds for financial and technical assistance, grantees may use funds for expenditures such as program administration costs that are allowable under federal awards provided they are necessary and reasonable for the performance of the award, consistent with 2 CFR § 200.403.
- During a planning period, grantees may use funds for direct costs such as salaries, fringe benefits, equipment, and indirect costs.
- Grantees may use grant funds to procure contractors or issue subawards to carry out the program, provided they are necessary and reasonable for the performance of the award.
- Similarly, these costs may include procuring services and tools that support the grantee in program design (e.g., technical assistance from the U.S. Department of Energy National Laboratories to support the grantee directly during program design).
What would constitute funds being “deployed within five years of the award” for a revolving loan fund?
- In a revolving loan fund capitalization scenario, the grantee must disburse grant funds to borrowers to reimburse them for costs incurred for eligible projects within the grant’s 5-year period of performance or the 120-day period following the end of the period of performance for liquidating obligations made during the performance period authorized by 2 CFR 200.344(b). However, as provided in 2 CFR 1500.8(d) a recipient may use the grant funds before using any program income generated by the revolving fund and retain that program income (as well as post-award program income) for use under a close out agreement after the period of performance ends.
- Note that, unlike other EPA revolving loan fund capitalization grant funding (e.g., Brownfields State Revolving Loan Funds), appropriations for the Solar for All program are “time limited”. Thus, the period of performance for Solar for All cooperative agreements is five years.
If the timeline for eligible recipients to deploy funds is five years, what does that mean for the use of funds in financial instruments such as loan guarantees?
- As provided in Section I.E. Scope of Work, EPA expects a recipient to deploy all grant funds within the five-year period of performance. This means a recipient must disburse all grant funds, including any payments to borrowers as required by the terms of loans and payments to financial institutions participating in loan guarantee programs, within the 5-year period of performance or the 120-day period following the end of the period of performance for liquidating obligations made during the performance period authorized by 2 CFR 200.344(b).
Should applicants plan to fully spend financial assistance dollars by the end of the 5-year period of performance, or is it sufficient to plan to commit these dollars to projects by the end of the 5-year period?
- The recipient must liquidate any financial obligation (i.e., commitment) that the recipient incurred under the award within 120 days following the end of the five-year period of performance, per 2 CFR § 200.344(b).
Named Contractors and Named Subrecipients
What is the difference between a subrecipient and a contractor?
- A subrecipient is an entity that receives a subaward from the recipient (referred to as the “pass-through entity”) to carry out part of the federal award.
- A contractor is an entity that receives a contract from the recipient or subrecipient to carry out the federal award. A contractor may further subcontract with subcontractors.
- For additional details on the requirements for subrecipients and contractors, please refer to Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity.
How is a grantee’s transaction with a nonprofit different from a transaction with a for-profit?
- A transaction between a grantee and a nonprofit is generally considered to be subaward because the transfer of funds to the nonprofit is for the purpose of carrying out the grant.
- A transaction between a grantee and a for-profit entity is generally considered to be a contract. For-profit entities, including individual consultants, operate in a competitive environment and provide goods and services on commercial terms to many different purchasers rather than carrying out a program for public purposes under the statute authorizing EPA to award financial assistance.
- For additional information on determining whether a transaction qualifies as a subaward or a procurement contract, please refer to Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity and EPA’s Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements.
What are the application requirements for named contractors and named subrecipients for applicants that are states?
- States must follow the requirements for named subrecipients described in Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity. The requirement that applicants demonstrate compliance with the procurement standards for any named contractors does not apply to states.
Do applicants need to identify all subrecipients and/or contractors before submitting their applications?
- EPA does not require nor encourage applicants to name contractors or subrecipients in applications for grant funding, with the exception of named subrecipients in coalition applications. As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, EPA requires any named subrecipient to be part of a coalition application as a non-lead coalition member, which must be eligible for a subaward in compliance with Appendix A of EPA's Subaward Policy.
Can subrecipients use funds for program administration activities?
- Yes, as described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, consistent with 2 CFR § 200.403, expenditures such as program administration costs are allowable under federal awards provided they are necessary and reasonable for the performance of the award. Expenditures for program administration activities include those for program performance, financial and administrative reporting, and compliance, including but not limited to activities to support, monitor, oversee, and audit subrecipients, contractors, and program beneficiaries. Program administration costs include procuring services and tools that support the grantee in program design (e.g., technical assistance from the DOE National Laboratories to support the grantee directly for program design).
- Please refer to Section I.D: Competition Terminology and Section III.D. Allowable and Unallowable Costs of the Notice of Funding Opportunity for additional information on allowable administration costs.
May contractors, subrecipients, and other award partners change over the program period?
- Yes, recipients may change contractors, subrecipients, and program beneficiaries during the period of performance so long as the changes are consistent with the applicable regulations and terms and conditions of the grant. Some changes may require modifications or amendments to the grant.
Can a grantee award a contract to a for-profit entity that helped prepare the grant agreement but did not participate in the final procurement documents?
- A grantee may award a contract to a for-profit entity involved in preparing the application and/or grant agreement, so long as the grantee selects the entity in accordance with the competitive procurement standards in 2 CFR § 200 and 1500.
- Please refer to Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, EPA’s Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements, and EPA’s Financial Assistance Conflict of Interest Policy for further guidance and details.
What regulations must applicants comply with if they chose to name for-profit contractors in their application?
- As described in Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, EPA does not require or encourage applicants to name procurement contractors (including consultants) in applications for grant funding. However, if an applicant chooses to identify a procurement contractor(s) to conduct work proposed in this application, the applicant must comply with the following requirements even if the entity is referred to as a “partner” in the application.
- Applicants (other than states) that identify a procurement contractor(s) in their application where the amount of the contract will be more than the micro-purchase threshold in 2 CFR § 200.320(a)(1) ($10,000 for most applicants) must demonstrate, in their application, how the contractor (including consultants) was selected in compliance with the fair and open competition requirements in 2 CRF § 200 and 2 CFR § 1500.
- EPA provides guidance on complying with the competition requirements in the Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements. For example, EPA will not accept sole source justifications for proposed procurement contracts for services such as environmental consulting and engineering that are available in the commercial marketplace.
- Applicants (other than states) must describe the procurement procedures that were followed to hire the contractor(s) that is named in this application and include information on where and when the Request for Proposals/Request for Qualifications was posted in the Summary Program Cover Page, as described in Section IV.C: Content of Application Submission.
Do consultant caps apply to grant writers?
- A recipient's use of federal funds to compensate a grant writer is subject to the cap in 2 CFR 1500.10 if the recipient contracts with the grant writer at a daily or hourly rate. The recipient must also select, direct, and control the grant-writer in order for the cap to apply. If the recipient contracts with a multi-employee firm that selects, directs, and controls the grant-writer, then the cap does not apply. For additional guidance, please see Best Practice Guide for Procuring Services, Supplies, and Equipment Under EPA Assistance Agreements.
If an entity is serving a Tribe, is it reasonable for the entity to select a program partner who was not the lowest bidder to procure from a Native-owned and operated company?
- Under the Indian Self-Determination and Education and Assistance Act, as amended, tribal recipients may give preference to Indian organizations and to Indian-owned economic enterprises when awarding procurement contracts under EPA assistance agreements. Giving preference to Indian Organizations and Indian-owned economic enterprises may result in the recipient awarding a contract to an Indian Organization or Indian-owned economic enterprise that is not the lowest bidder.
Can grantees purchase goods and services from foreign-owned companies?
- Recipients may purchase goods and services from foreign-owned companies using the applicable procurement standards in 2 CFR 200, with the exception of the prohibition in 2 CFR 200.216 on the procurement of certain telecommunications and video surveillance services and equipment, and the requirement that all travel services must be on available U.S. air carriers certified under 49 U.S.C. Section 40118.
- Applicants should also be mindful of the domestic sourcing requirements. As described in Section VI.B: Administrative and National Policy Requirements of the Notice of Funding Opportunity, certain projects under this competition are subject to the Buy America Sourcing requirements under the Build America, Buy America (BABA) provisions of the Infrastructure Investment and Jobs Act (IIJA)(P.L. 117-58, §§70911-70917) that apply when using Federal funds for the purchase of goods, products, and materials on any form of construction, alteration, maintenance, or repair of infrastructure in the United States. The Buy America preference requirement applies to all the iron and steel, manufactured products, and construction materials used for the infrastructure project under an award for identified EPA financial assistance funding programs. Please consider this information when preparing budget information. EPA will provide further guidance on which projects are subject to BABA provisions and will work with grantees to support implementation as necessary, as applicants comply with applicable Buy America preference requirements or apply for a waiver for each infrastructure project.
Should applicants anonymize all subrecipients that are not coalition members?
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Yes, applicants may only name subrecipients who are coalition members. As described in Section III.C: Threshold Eligibility Criteria, for the Solar for All competition, EPA requires any named subrecipient to be part of a coalition application as a non-lead coalition member. Thus, the lead applicant and the named subrecipient must have a memorandum of understanding as described in Section III.C: Threshold Eligibility Criteria.
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Applicants must demonstrate that named subrecipient/non-lead coalition members are eligible for a subaward in compliance with Appendix A of EPA's Subaward Policy.
According to 2 CFR 200.317, States can follow their own procurement procedures and policies for non-federal funds for EPA grant funds. If a subrecipient is a state, can the state subrecipient follow their own procurement procedures and policies for non-federal funds for EPA grant funds?
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Yes, state subrecipients can follow their own procurement procedures as provided by 2 CFR 200.317.
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Note: unless state law provides otherwise, a state agency cannot subaward grant funds to another state agency in the same state since EPA recognizes all instrumentalities of a unit of government to be part of the same entity.
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Please note: This FAQ was revised on October 6, 2023. Additional information on transfer of funding between departments or agencies of the same unit of government can be found in the "Program Budget" section of this web page.
Can applicants mention the name of a potential contractor or subrecipient in the Program Narrative, or include a letter of support from a potential contractor or subrecipient, if it is explicitly stated that all eventual transfers of funds awarded through the Solar for All competition will comply with the Procurement Standards in 2 CFR § 200 and 1500, EPA’s Subaward Policy, and EPA’s Guidance on Participant Support Costs, as applicable?
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Applicants (other than states) that identify a procurement contractor(s) in their application where the amount of the contract will be more than the micro-purchase threshold in 2 CFR § 200.320(a)(1) ($10,000 for most applicants) must demonstrate, in their application, how the contractor (including consultants) was selected in compliance with the fair and open competition requirements in 2 CRF § 200 and 2 CFR § 1500.
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As described in Section I.D: Competition Terminology and Section III.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity, the non-lead coalition member(s) may be eligible nonprofit recipients as well as other types of nonprofits, governmental entities, and Institutions of Higher Education, as defined in 2 CFR § 200.1, that are eligible for subawards under EPA’s Subaward Policy.
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Failure to comply with these requirements will result in the application being deemed ineligible for the competition.
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Applicants may include letters of support from potential partnerships with community-based organizations, unions, industry associations, workforce development programs, worker centers, and other partners who are interested in helping the program execute the program as described in Section IV.C: Content of Application Submission.
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Applicants may include letters of support from potential contractors or subrecipients who are otherwise not named in the application or budget. Letters of support from potential contractors or subrecipients who are otherwise not named in the application or budget does not constitute a “named contractor or named subrecipient”, and applicants do not need to demonstrate compliance with the requirements detailed in Section II.B: Named Contractors and Named Subrecipients of the Notice of Funding Opportunity for entities submitting letters of support.
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Entities that submit letters of support in the application are not disqualified from eventually receiving a transfer of funds as a subrecipient or contractor.
Are there any requirements under Solar for All on the solar developers/installers that install infrastructure receiving financial assistance from Solar for All grantees?
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EPA does not require that grantees use specific certification requirements for solar developers/installers that install infrastructure receiving financial assistance from Solar for All grantees.
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As described in Section V.A: Evaluative Criteria of the Solar for All Notice of Funding Opportunity, EPA will evaluate applications on how the program will ensure entities and partners that support the program activities achieve the program goals, including goals for labor and workforce development as well as consumer protection.
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A grantee who transfers funds awarded through this competition for solar developers/installers must comply with the Procurement Standards in 2 CFR § 200 and 1500, EPA’s Subaward Policy, and EPA’s Guidance on Participant Support Costs, as applicable, depending on the vehicle that the grantee uses to transfer funds, as well as the Participation by Disadvantaged Business Enterprises in EPA Programs requirements in 40 CFR § 33.
EPA’s General Terms and Conditions (pdf) (494 kb) state that grantees are required to “work with EPA’s Project Officer to obtain the written consent of EPA’s Office of International and Tribal Affairs (OITA), prior to awarding a subaward to a foreign or international organization, or a subaward to be performed in a foreign country even if that subaward is described in a proposed scope of work.” Does this term and condition apply to subawards to Tribal governments?
- No, if a grantee intends to make a subaward to a Tribal government, the grantee is not required to obtain the written consent of OITA prior to awarding the subaward to the Tribal Nation.
Are subawards to Tribal governments governed by the same responsibilities, reporting requirements, and other requirements as subawards to other types of entities?
- Yes, paragraph 8 “Establishing and Managing Subawards,” in EPA’s General Terms and Conditions, applies to subawards to Tribal governments.
Cost Sharing or Matching
Are there any match or cost-sharing requirements? Do applicants need to secure other sources of funding to apply?
- No, there are no match nor cost-sharing requirements for the Solar for All competition.
- Applicants do not need to secure other funding sources to apply to the Solar for All competition.
When should an applicant request prior approval for allowable costs that require prior approval from the EPA official according to Section III.D: Allowable and Unallowable Costs of the Notice of Funding Opportunity?
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For costs that require prior approval from EPA, the applicant may include them in the application for EPA to approve at the time of award or the applicant may request approval after the award has been made.
Competition Terminology
Capitalization Mobilization
Is there a specific ratio of capital mobilization that EPA considers successful for capital or private capital mobilization?
- EPA does not have a specific ratio of capital mobilization that EPA considers successful for the purpose of the Solar for All program.
Are tax credits such as the Low-Income Housing Tax Credit included in the calculation of private capital mobilization?
- As defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity, tax credits are included in the calculation of capital mobilization but are excluded from the calculation of private capital mobilization.
- Tax increment financing and other tax incentives are considered a source of public capital.
Eligible Zero-Emissions Technology
Can grantees use program funds to provide financial assistance to solar projects that are not behind the meter?
- Yes, grantees may use program funds to financially assist solar projects not behind the meter. Still, projects that are not behind the meter must be residential-serving solar projects according to the definition of residential rooftop solar and residential-serving community solar defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
Can grantees use program funds to provide financial assistance to solar projects that provide energy to non-residential customers (e.g., municipal buildings/local government buildings, community centers, schools, houses of worship, health facilities, nonprofit companies) and common spaces and offices in master-metered, multi-family buildings?
- Grantees may use program funds to provide financial assistance to residential-serving community solar projects. The definition of a residential-serving community solar project is a solar PV power-producing facility or solar energy purchasing program from a power-producing facility, with up to 5 MWac nameplate capacity, that delivers at least 50% of the electricity generated from the system to multiple residential customers within the same utility territory as the facility. The definition of residential-serving community solar is described in the Notice of Funding Opportunity, Section I.D: Competition Terminology.
Under the definition of residential-serving community solar, what does it mean for a project to serve households within the same utility territory?
- A program serves a household when the program enables the household to benefit from a solar photovoltaic (PV) system based on power production. For a residential-serving community solar project, a household in the same utility territory as the solar project will most likely be subscribed to a community solar system and receive a monetary credit for their share of the electricity generated from the community solar system.
Are mobile solar generator programs designed to support families in low-income and disadvantaged communities eligible for Solar for All?
- Yes, mobile solar generator programs enabling low-income and disadvantaged communities to deploy and benefit from distributed residential solar are eligible to apply to Solar for All.
- Applicants proposing programs to provide financial and technical assistance to mobile solar generators should explain in their application how the program will ensure all the benefits (e.g., clean power produced, electricity cost savings) of the mobile solar generators flow to low-income and disadvantaged communities.
- As detailed in the Notice of Funding Opportunity, Section III.C: Threshold Eligibility Criteria, all program funds must be used to enable low-income and disadvantaged communities to deploy and benefit from residential distributed solar.
Are solar projects supporting mobile homes eligible for Solar for All financial assistance?
- Yes, solar projects supporting mobile homes are eligible for Solar for All financial assistance.
Do applications need to provide financial assistance to both rooftop residential solar and residential-serving community solar?
- Applicants may decide whether the program provides financial and technical assistance to both rooftop residential solar and residential-serving community solar or focuses on one of the two types of eligible solar projects.
- EPA will evaluate applicants on the extent and quality of the plan to maximize meaningful benefits, as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity, to households served by the program. This criterion is described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity.
Are there any restrictions on the types of residential-serving community solar projects eligible for Solar for All financial assistance based on who owns the asset (e.g., community-owned, developer-owned)?
- As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, there are a variety of community solar ownership models that can be considered, including community-owned solar, third-party-owned community solar, and utility-owned community solar.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, EPA will evaluate applicants on the extent and quality to which the proposed program commits to maximizing household and community ownership models and includes a plan to support low-income and disadvantaged households and communities building equity in projects. If community ownership is not being proposed, applicants will be evaluated on the quality to which they justify why the program cannot facilitate community ownership models.
Under the definition of residential-serving community solar, is the 5 MW nameplate capacity maximum in AC or DC?
- The definition of a residential-serving community solar project is a solar PV power-producing facility or solar energy purchasing program from a power-producing facility, with up to 5 MWac nameplate capacity, that delivers at least 50% of the power generated from the system to multiple residential customers within the same utility territory as the facility.
Is energy storage infrastructure associated with an eligible rooftop residential solar project receiving financial assistance eligible for financial assistance?
- Yes, as described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, energy storage assets that are deployed in conjunction with and connected to an eligible rooftop residential solar project are eligible for financial assistance from a Solar for All grantee if the residential solar project is also receiving financial assistance from the Solar for All grantee.
Is energy storage infrastructure associated with an eligible residential-serving community solar project receiving financial assistance eligible for financial assistance?
- Yes, as described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, energy storage assets that are deployed in conjunction with and connected to an eligible residential-serving community solar project are eligible for financial assistance from a Solar for All grantee if the residential solar project is also receiving financial assistance from the Solar for All grantee.
Under the enabling upgrade definition, are grid infrastructure investments eligible for financial assistance?
- Yes, grantees may use program funds for financial assistance to distribution and transmission infrastructure investments that must be borne by the project (i.e., is not rate-based or part of planned capital improvement by a utility) and are necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project receiving financial assistance from Solar for All.
Under the enabling upgrade definition, are investments in energy efficiency, such as building envelopes, eligible for financial assistance?
- Yes, applicants may use program funds for financial assistance supporting building infrastructure improvements necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project receiving financial assistance from Solar for All.
What is the suggested share of funds that applicants can use for enabling upgrades?
- As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, financial assistance for enabling upgrades may comprise up to 20% of the total financial assistance deployed during the program performance period.
- For example, suppose a program uses 80% of the total grant funds for financial assistance to projects. In that case, a program may use up to 20% of the 80% of financial assistance (i.e., 16% of total program funds) for enabling upgrades.
Can applicants use program funds for financial assistance to make projects “solar-ready?”
- As described in Section I.D: Competition Terminology of the Notice of Funding opportunity, enabling upgrades that are investments in energy and building infrastructure that are necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project are eligible uses of funds.
- Enabling upgrades can include, but are not limited to, electrical system upgrades, structural building repairs and energy efficiency. Applicants may decide the exact types of enabling upgrades that are eligible for Solar for All financial assistance, yet all enabling upgrades should be energy and building infrastructure related and deployed in conjunction with financial assistance for an eligible solar PV system.
- Financial assistance for enabling upgrades may comprise up to 20% of the total financial assistance deployed during the lifetime of the program.
What does EPA consider a “residential” building? Does this include buildings in which people live but do not own or rent (e.g., hospitals)? Does this include households that are also agricultural businesses?
- EPA’s Solar for All competition is designed to deliver the benefits of solar energy to households. Solar for All grantees can fund both residential rooftop solar projects and residential-serving community solar projects so long as the projects serve households. These projects can be sited on buildings in which people live but do not own or rent so long as the project serves households.
- As described in Section I.D: Competition Terminology, residential rooftop solar is defined as any behind-the-meter solar photovoltaic (PV) power-producing facilities, including rooftop, pole-mounted, and ground-mounted PV systems, that support individual households in existing and new single-family homes, manufactured homes, and multifamily buildings. The definition of residential rooftop solar includes behind-the-meter solar facilities serving multifamily buildings classified as commercial buildings so long as the solar facility benefits individual households either directly or indirectly such as through tenant benefit agreements. Residential rooftop solar includes properties that are both rented and owned.
- Residential-serving community solar is defined as a solar PV power-producing facility or solar energy purchasing program from a power-producing facility, with up to 5 MW nameplate capacity, that delivers at least 50% of the power generated from the system to multiple residential customers within the same utility territory as the facility. There are a variety of community solar ownership models that can be considered, including community-owned solar, third-party-owned community solar, and utility-owned community solar.
Can applicants use grant funds for renewable energy projects other than solar?
- No, Solar for All grant funds must be used for financial assistance and technical assistance to enable low-income and disadvantaged communities to deploy and benefit from rooftop residential solar and residential-serving community solar as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
Can burying the existing power lines to improve hurricane resiliency be an eligible enabling upgrade?
- Grantees may use grant funds for financial assistance to distribution and transmission infrastructure investments that must be borne by the project (i.e., is not rate-based or part of planned capital improvement by a utility) and are necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project receiving financial assistance from Solar for All.
- As described in Section I.D: Competition Terminology of the Notice of Funding opportunity, enabling upgrades that are investments in energy and building infrastructure that are necessary to deploy and/or maximize the benefits of a residential rooftop and residential-serving community solar project are eligible uses of funds.
- Enabling upgrades can include, but are not limited to, electrical system upgrades, structural building repairs and energy efficiency. Applicants may decide the exact types of enabling upgrades that are eligible for Solar for All financial assistance, yet all enabling upgrades should be energy and building infrastructure related and deployed in conjunction with financial assistance for an eligible solar PV system.
- Financial assistance for enabling upgrades may comprise up to 20% of the total financial assistance deployed during the lifetime of the program.
What does EPA mean when specifying that financial assistance for associated storage must be deployed in conjunction with financial assistance for a solar PV system and the storage asset must be connected to the solar PV system?
- Associated storage infrastructure is defined as energy storage infrastructure to store solar-generated power for the purposes of maximizing residential rooftop and residential-serving community solar deployment, delivering demand response needs, aggregating assets into virtual power plants, and delivering residential power during grid outages.
- Financial assistance for associated storage must be deployed in conjunction with financial assistance for a solar PV system and the storage asset must be connected to the solar PV system.
- EPA uses the phase “connected to a solar PV system” to describe how proposed energy storage assets must be co-located with a solar PV system receiving financial assistance from the Solar for All grantee to be eligible for financial assistance.
How can Solar for All applicants support virtual power plants?
- Solar for All applicants can use program funds to deploy distributed residential solar and associated storage—two types of distributed energy resources that can be aggregated into virtual power plants.
Does EPA consider installing water cistern systems technology acceptable for financial and/or technical assistance under the GGRF Solar for All Awards so long as it is ancillary to the solar installations?
- Solar for All funds may only be used toward financial and technical assistance to enable low-income and disadvantaged communities to deploy and benefit from rooftop residential solar, residential-serving community solar, associated storage, and enabling upgrades.
- A water cistern system does not qualify as one of the four technology categories eligible for financial assistance under this program nor is it an eligible use of funds under the definition of technical assistance.
- For more information on the definition financial assistance, technical assistance, rooftop residential solar, residential-serving community solar, associated storage, and enabling upgrades, please refer to Section I.D: Competition Terminology in the Notice of Funding Opportunity.
Can applicants provide financial assistance to install energy storage assets on existing rooftop residential solar and residential-serving community solar installations?
- No, financial assistance for associated storage must be deployed in conjunction with financial assistance for a new solar PV system as described in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
Can a program provide financial assistance to an eligible residential-serving community solar project that is built in conjunction with and on the same site as a utility-scale solar project?
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Rooftop residential solar and residential-serving community solar projects, as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity are eligible for financial assistance under Solar for All.
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A program can provide financial assistance to a residential-serving community solar project that is built in conjunction with and on the same site as a utility-scale solar project if the residential-serving community solar project meets the requirements of Section I.D: Competition Terminology and is a “single project” as determined by the single project factors tests provided in section 7.01(2)(a) of Notice 2018–59(pdf) (95 KB) or section 4.04(2) of Notice 2013–29(pdf) (34 KB), as applicable. Whether multiple energy properties are treated as a single energy property will depend on the relevant facts and circumstances and is not determined by a single factor or factors.
Is there a limit on the number of solar PV power-producing facilities a grantee can deploy?
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There is no limit on the number of solar PV power-producing facilities allowed by the program.
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EPA encourages applicants to maximize the number of households served by the program.
Does the definition of residential-serving community solar in Section I.D: Competition Terminology define a maximum nameplate capacity for projects eligible for financial assistance from Solar for All grantees?
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Yes, the maximum nameplate capacity for a residential-serving community solar project to be eligible for financial assistance from a Solar for All grantee is 5 MW ac. Projects with a nameplate capacity greater than 5 MWac are not eligible for financial assistance from a Solar for All grantee.
What is the definition of “behind-the-meter”?
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“Behind-the-meter” is defined as a project located on the distribution system. Specifically, “behind-the-meter” refers to assets located after the point of power deliver to the customer and on the “customer side of the meter”. This point of power delivery can be the customer’s billing meter or an unmetered fixture.
What does it mean for a residential-serving community solar project to “deliver at least 50% of the power generated from the system” to residential customers, as stated in Section I.D: Competition Terminology of the NOFO?
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Any community solar project under the Solar For All program must verify that at least 50% of the benefits and/or credits of the power generated from a community solar system be delivered to residential customers in the same service territory.
Low-Income and Disadvantaged Communities
Can applicants (such as states) use their own low- and moderate-income definitions for this program?
- EPA defines low-income and disadvantaged communities in Section I.D: Competition Terminology of the Notice of Funding Opportunity. Applicants must use the definition of low-income and disadvantaged communities as defined in the Notice of Funding Opportunity to determine if a household is eligible for Solar for All financial assistance.
- If an applicant’s definition is the same or a subset of EPA’s definition of low-income and disadvantaged communities, then the applicant may use their definition of low-income and disadvantaged communities.
- Grantees must use all Solar for All program funds to enable communities that fall within the scope of EPA’s definition of low-income and disadvantaged communities to deploy and benefit from residential distributed solar.
What exactly does “enable” mean when you say 100% of funds must be used to “enable” low-income and disadvantaged communities to deploy and benefit from residential distributed solar?
- EPA defines “enable” as providing financial and technical assistance to households, community-based organizations, and businesses in low-income and disadvantaged communities to overcome financial and non-financial barriers to residential distributed solar deployment and to increase the benefits these communities experience from solar deployment.
- EPA has identified five meaningful benefits of residential distributed solar: household savings, equitable access to solar, resilience benefits, community ownership, and workforce development and entrepreneurship. These meaningful benefits are defined in Section III.D: Competition Terminology of the Notice of Funding Opportunity.
Do program beneficiaries (i.e., households and communities) have to be both low-income and disadvantaged?
- Households and communities can benefit from Solar for All if they are qualified under any one or more of the categories in the EPA definition of low-income and disadvantaged communities, which includes:
- Households and communities must also be within the boundaries of the United States (including Puerto Rico) and its territories.
- So long as the household or community is covered under one of the four categories listed above and within the boundaries of the United States (including Puerto Rico) and its territories, the household or community is eligible to benefit from Solar for All.
- Section I.D: Competition Terminology of the Notice of Funding Opportunity includes more information about the definition of low-income and disadvantaged communities.
For applications under award option #2, what is the definition of American Indian and Alaska Native Communities?
- Applicants to award option #2 must propose a program which serves American Indian and Alaska Native Communities.
- American Indian and Alaska Native Communities are a subset of the eligible program beneficiaries defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity under the definition of low-income and disadvantaged communities.
- As a reminder, the definition of low-income and disadvantage communities, as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity, Section 134(a)(1) of the Clean Air Act appropriates $7 billion for the purposes of providing financial and technical assistance to enable “low-income and disadvantaged communities” to deploy and benefit from residential distributed solar. GGRF defines low-income and disadvantaged communities as encompassing the following four categories, as defined below: (a) communities identified as disadvantaged by the CEJST mapping tool; (b) a limited number of additional communities identified as disadvantaged by the EJScreen mapping tool; (c) geographically dispersed low-income households; and (d) properties providing affordable housing.
- American Indian and Alaska Native Communities are a subset of households and communities within the geographic boundaries defined in:
- Under category (a), American Indian and Alaska Native Communities include all Federally Recognized Tribes, including Alaska Native Villages, are considered disadvantaged communities. This is consistent with definitions incorporated in the White House Climate and Economic Justice Screening Tool (CJEST). Solar for All funding will also incorporate the CJEST geographic boundaries for determining “land within the boundaries of Federally Recognized Tribes.”
- Under category (b), American Indian and Alaska Native Communities include geographic areas within Tribal lands as included in EJScreen.
- Under category (d), American Indian and Alaska Native Communities include any housing assistance program administered by a tribally-designated housing entity, as defined in Section 4(21) of the Native American Housing Assistance and Self-Determination Act of 1996 (25 U.S.C. § 4103(22).
- Federally recognized tribal members living outside categories (a), (b), and (d) as described above may be eligible for Solar for All by meeting low income or disadvantaged definition described in category (c) geographically dispersed low-income households. Please refer to Section I.D: Competition Terminology of the Notice of Funding Opportunity.
Do persistent poverty census tracts qualify as a low-income and disadvantaged communities?
- Households and communities can benefit from Solar for All if they are qualified under any one or more of the categories in the EPA definition of low-income and disadvantaged communities, which includes:
- Households and communities must also be within the boundaries of the United States (including Puerto Rico) and its territories.
- For any persistent poverty census tract not included in categories a) CEJST or b) EJScreen, of the GGRF definition of low-income and disadvantaged communities, individuals and households within those tracts may still be able to qualify for financial assistance under categories c) household income, or d) affordable housing.
Is a Historically Black College and University considered a low-income and disadvantaged community?
- A Historically Black College and University is considered a low-income and disadvantaged community if the institution is located in a low-income and disadvantaged community by one of the four categories defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
For geographically dispersed low-income households, how should applicants determine whether an individual or household is in a Metropolitan Area or a Non-Metropolitan Area?
- Metropolitan and non-metropolitan (i.e., micropolitan) area designation for counties are designated by the Office of Management and Budget.
- Applicants may reference the U.S. Treasury’s CDFI Investment Area Eligibility Data Set, which contains these designations in Column E.
For geographically dispersed low-income households, can you clarify whether the income limit set by the different income levels (e.g., Area Median Income, Federal Poverty Level) is determined by the maximum or the minimum of those income levels?
- The income limit is determined by the maximum of those income levels, not the minimum.
- For Metropolitan Areas, an individual or household can have an income that is at or below the greater of (1) 80% Area Median Income (AMI) and (2) 200% of the Federal Poverty Level, wherein the maximum of these two figures determines the income limit.
- For Non-Metropolitan Areas, an individual or household can have an income that is at or below the greater of (1) 80% AMI; (2) 80% Statewide Non-Metropolitan Area AMI; and (3) 200% of the Federal Poverty Level, wherein the maximum of these three figures determines the income limit.
For geographically dispersed low-income households, how should applicants determine what income is 80% Area AMI; 200% of FPL; and 80% Statewide Non-Metropolitan Area AMI?
- The Area Median Income (AMI), also called the Median Family Income, is the midpoint of a defined area’s income distribution, adjusted for household size. AMI is calculated and published annually by the U.S. Department of Housing and Urban Development. Applicants may reference HUD’s AMI tables.
- The Federal Poverty Level (FPL) is an economic metric of poverty in the United States. Poverty thresholds by household size are calculated annually by the U.S. Census Bureau, then the U.S. Department of Health and Human Services uses those thresholds to issue poverty guidelines, commonly called the FPL. Applicants may reference the HHS FPL tables.
- The Statewide Non-Metropolitan Area Median Income is the midpoint of household income distribution for a state's nonmetropolitan counties and portions of metropolitan counties outside of cities, published by the U.S. Department of the Treasury. GGRF grantees may reference the U.S. Treasury’s CDFI Investment Area Eligibility Data Set. Column L, “mfi2020_nonmetro_st,” provides the metric for a family/household of four persons, which should then be adjusted for household size using HUD’s Family Size Adjustment factor.
The definition of low-income and disadvantaged communities includes “properties providing affordable housing” and lists some eligible housing programs including HUD Section 8. Are all programs commonly referred to as Section 8—including Project-Based Rental Assistance (PBRA), Project Based Vouchers (PBV), and Housing Choice Vouchers (HCV)—eligible under the definition of low-income and disadvantaged communities?
- PBRA will be covered under the first category of such properties, which includes multifamily housing under the federal and state housing assistance programs listed in the Notice of Funding Opportunity that have active affordability covenants.
- PBV and HCV may be covered through the second category of such properties, which includes naturally-occurring affordable housing, provided that the housing has rents not exceeding 30% of 80% AMI for at least half of residential units.
- Refer to Section I.D: Competition Terminology of the Notice of Funding Opportunity.
For geographically disbursed low-income households, can you clarify what income verification requirements are required?
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, applicants should explain their proposed program’s methodology for verifying income qualification in the Program Narrative section 1.6 Equitable Access and Meaningful Involvement Plan.
- As described in Section V.A: Evaluation Criteria, “to reduce risk from fraud and waste, the application will be evaluated on the extent and quality to which the program plans to perform robust income verification above and beyond attestation…while minimizing burdens on households.”
- To avoid duplicative income verifications for households, GGRF participants may rely upon the certification or acceptance of that household for participation in other existing need-based federal, state, Tribal, or utility assistance programs (e.g., WAP, SNAP, TANF, Lifeline, LIHEAP).
Financial Assistance
Is financial assistance provided by a recipient or subrecipient under the Greenhouse Gas Reduction Fund considered federal financial assistance under 2 CFR 200.1?
Most financial assistance will be considered federal financial assistance under 2 CFR 200.1. Recipients and subrecipients under EPA’s Greenhouse Gas Reduction Fund programs—the National Clean Investment Fund (NCIF), Clean Communities Investment Accelerator (CCIA), and Solar for All (SFA)—will provide financial assistance to eligible projects. Financial assistance under these programs will be in the form of subawards, participant support costs, and acquisitions of Intangible property, as defined in 2 CFR 200.1, with the characterization dependent on the nature of the financial assistance. Federal financial assistance under the Greenhouse Gas Reduction Fund therefore includes financial assistance to eligible projects in the form of subgrants, subsidies, loans, and other financial instruments that are subawards or participant support costs; loan guarantees are also considered federal financial assistance, but the federal financial assistance is typically provided to the lender whose loan is guaranteed (rather than the borrower of the loan). Note that acquisitions of intangible property are only eligible under NCIF and CCIA, rather than SFA. EPA has determined that financial assistance in the form of subawards and participant support costs are considered Federal financial assistance under 2 CFR 200.1, while acquisitions of intangible property are not considered federal financial assistance for the purposes of that regulation.
Under the Greenhouse Gas Reduction Fund programs, are there any programmatic restrictions tied to whether individuals and organizations receiving financial assistance can take advantage of tax credits and other forms of financial assistance available from the federal government?
EPA has not made any programmatic restrictions related to whether individuals and organizations that receive financial assistance for projects under the Greenhouse Gas Reduction Fund (GGRF) can also take advantage of tax credits and other forms of financial assistance available from the federal government. However, there may be restrictions under tax credits or other financial assistance programs that prevent the use of GGRF financial assistance alongside them. Please note that EPA does not provide advice on tax matters or on policies from other federal agencies. Individuals and organizations with questions may contact their tax advisors, the Internal Revenue Service, and the respective federal agencies, as appropriate.
Can grantees provide financial assistance that is not a financial product (e.g., subsidies, grants)?
- Yes, Solar for All allows grantees to use funds for financial assistance that is not a financial product, including subsidies and grants.
- As defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity, financial assistance is defined as subgrants, rebates, subsidies, other incentive payments, debt (including loans, partially forgivable loans, forgivable loans, soft loans, subordinate debt), and other financial products consistent with the definition of Federal financial assistance in 2 CFR § 200.1 and Participant support costs in 2 CFR § 1500.1.
Can a project that receives financial assistance from a Solar for All grantee benefit from other federal funding sources (e.g., tax credit) or local funding sources (e.g., local rebates)?
- Solar for All funds do not restrict a project's ability to leverage other federal or local sources of funding.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, EPA will evaluate applicants on how the financial assistance strategy proposed in the application complements and does not duplicate existing sources of capital and financial assistance. Applicants will be evaluated on the quality and extent to which the financial strategy is designed to ensure program longevity and market transformation beyond the program period detailed in this application; plans to leverage innovative financing structures such as renewable energy credits, tax credits, debt financing, leases, power purchase agreements, other third-party ownership options, revolving loan programs, green bonds, guarantees, or other financing products; and includes a strategy to engage with other capital providers to maximize deployment including supporting other public (including the National Clean Investment Fund and the Clean Communities Investment Accelerator) and private sources of capital.
Can grantees use funds to provide other services to communities, such as rental assistance or health services?
- No, Solar for All funds can only be used for financial and technical assistance to enable low-income and disadvantaged communities to deploy and benefit from residential distributed solar projects, inclusive of rooftop residential solar, residential-serving community solar, associated storage, and enabling upgrades as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
What project costs are eligible for financial assistance from Solar for All?
- Eligible project costs under Solar for All are described in Section II.D: Allowable and Unallowable Costs of the Notice of Funding Opportunity. These costs must also be consistent with 2 CFR 200 Subpart E Cost Principles, EPA’s Supplemental Grant Regulations at 2 CFR 1500, and the terms and conditions of the grant, which will be negotiated after applications are selected to receive a grant.
- For example, eligible costs for a rooftop residential solar project may include the hardware costs, such as solar panels, inverters, and electrical equipment, and the service costs to install the hardware.
Are equity investments an eligible form of financial assistance?
- No, equity investments such as purchases of ownership interests in companies through acquisition of intangible personal property, as defined in 2 CFR 200.1 is not an eligible cost under Solar for All program.
Can applicants provide financial assistance for 100% of project costs for beneficiaries?
- EPA does not provide any guidance or limit to the share of project costs that can be covered by financial assistance from Solar for All grantees. However, applicants should refer to Section I.C: GGRF Solar for All Program Objectives of the Notice of Funding Opportunity to understand program objective 3: mobilize financing and private capital to stimulate additional deployment of greenhouse gas- and air pollution-reducing projects.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, EPA will evaluate applicants on the extent and quality of the plan ensures that the Solar for All financial assistance strategy proposed in the application complements, and does not duplicate, existing sources of capital and financial assistance; is designed to ensure program longevity and market transformation beyond the program period detailed in this application; plans to leverage innovative financing structures such as renewable energy credits, tax credits, debt financing, leases, power purchase agreements, other third-party ownership options, revolving loan programs, green bonds, guarantees, or other financing products; and includes a strategy to engage with other capital providers to maximize deployment including supporting other public (including the National Clean Investment Fund and the Clean Communities Investment Accelerator) and private sources of capital.
Can applicants provide financial assistance to subsidize subscriptions for low-income and disadvantaged communities to participate in existing community solar programs?
Applicants may provide financial assistance for low-income and disadvantaged communities to benefit from community solar installations. As described in Section III.C: Threshold Eligibility Criteria, applicants must submit an application for a program that provides grants, loans, and other forms of financial assistance (e.g., participant support costs), as well as technical assistance, to enable low-income and disadvantaged communities to deploy and benefit from residential rooftop and residential-serving community solar, associated storage, and enabling upgrades as defined in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
Does EPA’s Final Financial Assistance Conflict of Interest Policy (COI Policy) apply to loans and other forms of financial assistance made to individuals and organizations to deploy qualified projects?
- Pursuant to section 2.0 (c) of the COI Policy, EPA will establish conflict of interest terms and conditions that will cover loans and other forms of financial assistance made by recipients and subrecipients.
Technical Assistance
Can grantees provide technical assistance to energy businesses, such as training businesses in solar development processes?
- Yes, Section 134(a)(1) of the Clean Air Act provides that funds for this competition be used for “technical assistance.” As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, technical assistance is called “project-deployment technical assistance” in the competition and includes services and tools provided by grantees to communities and energy stakeholders to overcome non-financial barriers to solar deployment.
- Energy stakeholders may include distributed solar developers and contractors.
Can grantees use program funds to reach out to communities and increase awareness of the benefits of distributed solar?
- Yes, Section 134(a)(1) of the Clean Air Act provides that funds for this competition be used for “technical assistance.” As described in Section I.D: Competition Terminology of the Notice of Funding Opportunity, technical assistance is called “project-deployment technical assistance” in the competition and includes services and tools provided by grantees to communities and energy stakeholders to overcome non-financial barriers to solar deployment.
- Customer awareness is an example of a non-financial barrier to solar deployment, and community outreach to increase awareness of the benefits of distributed solar can help overcome this barrier.
Can applicants propose programs that provide financial products to communities and businesses such as credit enhancements, working capital lines of credit, or predevelopment grants and loans?
- Yes, providing financial products to communities and businesses to enable low-income and disadvantaged communities to deploy and benefit from distributed residential solar is an eligible activity under Solar for All. These financial products would be classified as project-deployment technical assistance for the purposes of this program.
Can applicants use Solar for All grant funds to provide financial or technical assistance to help electric utilities upgrade their billing systems to allow for virtual net metering?
- Grant funds may be used for billing system upgrades to enable virtual net metering if the applicant can demonstrate that the upgrades are “project-deployment technical assistance,” described in Section I.D: Competition Terminology of the Notice of Funding Opportunity. Project-deployment technical assistance is defined as services and tools provided by grantees to communities and energy stakeholders to overcome non-financial barriers to solar deployment.
- Examples of these services and tools include workforce training, customer outreach and education, project deployment assistance such as siting, permitting, and interconnection support (including procurement of services and tools from National Labs), and coordination with utilities for the purposes of project deployment.
Program Administration Costs
Is there a requirement or preference for a percentage of grant funds that a grantee may spend on program administration?
- As described in Section I.E: Scope of Work and Section IV.C: Content of Application Submission of the Notice of Funding Opportunity, EPA expects applicants to maximize financial assistance to projects. Applicants to award option #1 and option #3 should aim to use at least 75% of the award for financial assistance to solar projects. Applicants to award option #2 – American Indian and Alaska Native programs should aim to use at least 65% of funds for financial assistance to solar projects. These targets for financial assistance to solar projects include financial assistance for associated storage and enabling upgrades in conjunction with a solar project supported under this program. The remaining funds may be used for project-development technical assistance and program administration.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, EPA will evaluate applicants on their plan to maximize financial assistance to projects and whether the applicant demonstrates a plan to achieve the guidance on the share of funds for financial assistance.
- As described in Section IV.C: Content of Application Submission of the Notice of Funding Opportunity, in Section 2.1 Budget Narrative of applicants’ Program Narrative, applicants should describe how they will deploy funds efficiently and cost-effectively and explain how the costs are prudent and necessary to achieve the outcomes of the program.
Meaningful Benefits
What is the definition of 20% household savings?
- Household savings can be delivered as a direct financial benefit or, for households without an individual utility bill, a direct non-financial benefit equivalent to 20% of the average electric utility bill in the household’s utility territory. Additional detail on calculating household savings is included in Appendix C: Household Savings Guidance of the Notice of Funding Opportunity.
Do all projects have to provide 20% household savings to all households benefiting from the project?
- EPA aims to maximize household savings delivered to households that benefit from the program. While not technically required as a threshold eligibility requirement to apply to the program, applications that do not provide at least 20% household savings to households that benefit from the program will be evaluated less favorably than an application that commits to delivering at least 20% household savings, as described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity.
- EPA will evaluate applicants on the quality and extent of the plan to ensure all households that benefit from the Solar for All program experience minimum household savings of 20% of the average household utility bill in the utility territory as explained in Section V.A: Evaluative Criteria of the Notice of Funding Opportunity.
Should 20% savings be calculated based on the energy portion of the bill or the entire bill, including fixed costs?
- Household savings should be calculated based on the average household’s entire electric utility bill, including both the energy portion of the bill and the fixed cost portion, in the household’s utility territory.
How should applicants consider providing 20% household savings to households in master-metered, multi-family buildings?
- As explained in Section V.A: Evaluative Criteria of the Notice of Funding Opportunity, applicants will be evaluated on the quality and extent of the plan to deliver equivalent household savings for projects serving households without individual electricity bills (e.g., master-metered, multi-family buildings)—specifically, how the program will ensure households receive a financial or equivalent non-financial benefit of 20% or greater of the average household’s annual electricity expenditure; financial and equivalent non-financial benefit examples are described in recent guidance from U.S. Department of Housing and Urban Development.
- Applicants may propose other innovative solutions to delivering benefits to master-metered, multi-family buildings.
Does the 20% household savings rate need to be calculated for each individual household’s electric utility bill?
- No, as described in Appendix C: Household Savings Guidance of the Notice of Funding Opportunity, applicants may calculate household savings based on the average household electric utility bill in each utility territory applicants intend to serve.
- Applicants do not need to calculate each individual household’s 20% household savings based on the individual household’s electric bill.
Do all households served under the program have to receive 20% household savings (e.g., what if a program provides financial assistance to a residential-serving community solar project and 50% of the energy goes to income-qualified households and receive 20% household savings and the other 50% goes to market-rate households that do not receive 20% meaningful benefits)?
- EPA will evaluate applications on their strategy to provide at least 20% household savings to households served under this program, and EPA will award more points to applications which guarantee 20% household savings to all households served under this program, as described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity.
- Households served under this program must qualify to benefit based on the definition of low-income and disadvantaged communities explained in Section I.D: Competition Terminology of the Notice of Funding Opportunity.
- Applicants may propose a program that provides financial assistance to residential-serving community solar project that delivers at least 50% of the power to households that are covered under the definition of low-income and disadvantaged communities while the remaining project capacity is delivered to households that do not qualify as a low-income and disadvantaged communities. In this scenario, EPA will not evaluate applicants on their strategy to deliver 20% household savings to the households that do not quality as low-income and disadvantaged communities.
Does EPA have any recommendations on the timeframe applicants should use to calculate 20% average electricity bill?
- EPA does not have a universal recommendation on the timeframe applicants should use to calculate the 20% average electricity bill. EPA recommends applicants choose a reasonable timeframe which closely captures the electricity costs households will pay while they benefit from the program. A reasonable timeframe will likely change due to market conditions and unique geographic conditions.
- Applicants should consider how frequently the program will need to update the 20% average electricity bill calculation. Applicants should aim to accurately reflect the electricity costs households are facing as market conditions change overtime to the best of their ability. For example, applicants should have a plan to adjust the 20% household savings rate if the average bill changes significantly over the course of the program.
If a Solar for All grantee is providing financial assistance for a rooftop residential solar project on buildings that are also electrifying appliances—thus increasing electricity usage and costs for the occupants—how might the grantee provide 20% household savings?
- EPA’s definition of 20% household savings is not household specific. As defined in Appendix C. Household Savings Guidance, applicants should calculate 20% household savings from the average electricity expenditures of the average household in the utility territory.
How does EPA define the average electricity expenditures of the average household in the utility territory?
- EPA defines average as the mean household electricity expenditures of the average residential household in the utility territory the program will serve.
- EPA expects applicants to develop a robust and reasonable methodology to calculate the average household’s electricity expenditures. This methodology could include working with electric utilities and using data from the U.S. Energy Information Administration (including the Residential Energy Consumption Survey and electricity data) to calculate the average household annual utility costs.
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, applicants may propose a preliminary estimate of the 20% household savings rate and plan to refine the estimate during the one-year planning period.
- If the household saving figure included in the financial assistance model is an estimate, the application will be evaluated on the extent and quality of the plan to refine the estimated amount of savings a program beneficiary will receive from the program annually, including considering what data is required to better refine the estimate.
Is it feasible for an applicant applying to serve a state to provide an estimate in the application for the 20% household savings figure based on data from a handful of the largest utilities in the state?
- As described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, applicants may propose a preliminary estimate of the 20% household savings rate and plan to refine the estimate during the one-year planning period.
- If the household saving figure included in the financial assistance model is an estimate, the application will be evaluated on the extent and quality of the plan to refine the estimated amount of savings a program beneficiary will receive from the program annually, including considering what data is required to better refine the estimate.
How should applicants value storage benefits financially?
- EPA does not require applicants to value storage benefits financially in the application and does not have guidance on how applicants could value storage benefits. However, EPA will evaluate applicants on how the program will use investments in storage to generate resiliency benefits for program beneficiaries.
- As described in Section V.A: Evaluation Criteria, EPA will evaluate applicants on the quality and extent to which the application describes how the program will deliver energy resilience and grid benefits by creating capacity that can deliver electricity to low-income and disadvantaged households and/or critical facilities in low-income and disadvantaged communities in the event of a grid outage. Applicants may reference how the Financial Assistance Strategy for solar and storage achieves this meaningful benefit.
Would a solar and storage system installed on an affordable multifamily housing property, which cannot provide household energy savings due to the nature of utility bill arrangements, be eligible for financial assistance under this program?
- If the project is serving a low-income and disadvantaged community and is an eligible zero-emissions technology as defined in Section I.C: Competition Terminology of the Notice of Funding Opportunity, the project is eligible for financial assistance under this program.
- As explained in Section V.A: Evaluative Criteria of the Notice of Funding Opportunity, applicants will be evaluated on the quality and extent of the plan to deliver equivalent household savings for projects serving households without individual electricity bills (e.g., master-metered, multi-family buildings)—specifically, how the program will ensure households receive a financial or equivalent non-financial benefit of 20% or greater of the average household’s annual electricity expenditure; financial and equivalent non-financial benefit examples are described in recent guidance from U.S. Department of Housing and Urban Development.
- Applicants may propose other innovative solutions to delivering benefits to master-metered, multi-family buildings.
Can applicants provide financial assistance to projects on buildings that produce 20% household savings for some but not all the tenants in the building?
- Yes, a grantee may provide financial assistance for a residential-serving community solar project that only serves a subset of building tenants. However, the grantee should only count the households served by the solar project as being served by the program when reporting program activities and impacts.
- In this scenario, applicants may consider how to augment the tenants served by the program by encouraging building tenants to participate in other residential-serving community solar projects nearby.
How can applicants generate community ownership benefits if an owner of a building (i.e., a non-profit affordable housing developer) owns a solar project?
- The community ownership benefit is defined as local community members, subscribers, or local community organizations own or have equity in the project and can include other wealth-building strategies for the community in which the solar project is located.
- Applicants can generate community ownership benefits when a building owner who is a local community member or a local community organization owns or has equity in a project which received financial assistance from the Solar for All program.
Can affordable housing providers use building-level data to calculate 20% household saving?
- In Appendix C: Household Savings Guidance, EPA defines 20% household savings as 20% of an average household’s electricity bill of the average household in the utility territory.
- Programs may use customer-specific data (i.e., building-level data, household-level data) that is more specific to the customer than the average household in the utility territory if such data exists and will defensibly suffice to calculate 20% of the customer’s average electricity bill.
Can applicants incorporate financial benefits from enabling upgrades, energy storage, SRECs and other sources of financial benefits into the calculation of 20% household savings?
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Applications may propose methods to deliver 20% household savings that include other financial benefits households will realize from Solar for All in addition to financial benefits from solar generation.
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These additional financial benefits could include benefits from the installation of enabling upgrades, energy efficiency, and energy storage. Households can receive the financial value of Renewable Energy Credits, either directly or indirectly, that supports a minimum savings of 20 percent.
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EPA will evaluate the extent and quality to which the proposed strategy to ensure all households that benefit from the Solar for All program experience minimum household savings of 20% of the average household utility bill in the utility territory as described in Section V.A: Evaluative Criteria of the Notice of Funding Opportunity.
Application Components and Evaluation Criteria
Application Components
Is Attachment D: Program Planning Timeline and Workplan supposed to represent planning activities in the program planning stage during year one?
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Yes, Attachment D: Program Planning Timeline and Workplan is intended to primarily demonstrate an applicant’s timeline and workplan to plan the program during the optional year one program planning stage. However, if an applicant has parts of the program that do not need planning time and are ready to be implemented in year 1, the applicant should include implementation steps in year one to demonstrate that the program meets the evaluation criteria detailed in Section V.A: Evaluation Criteria.
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Applicants do not need to address the workplan to operate the entire program in Attachment D, yet applicants should address the workplan to operate the entire program in the Program Narrative in Section 1.7.
Should applicants detail the program workplan after the planning period in Section 1.7 Program Planning Timeline and Workplan Narrative of the Program Narrative?
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Yes, applicants should address the workplan to operate the program after the planning period in the Program Narrative in Section 1.7. EPA will evaluate the extent and quality to which the application expends all funds within five years of the award as explained in Section V.A: Evaluation Criteria.
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Applicants do not need to address activities after the year 1 in Attachment D.
Can applicants choose to use year one to plan components of the program while implementing and operationalizing other parts?
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Yes, applicants may choose to use time to plan components of the program while implementing and operationalizing other parts simultaneously.
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If an applicant has parts of the program that do not need planning time and are ready to be implemented in year 1, the applicant should include implementation steps in Attachment D in year 1 to demonstrate that the program meets the evaluation criteria detailed in Section V.A: Evaluation Criteria.
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The application will be evaluated on the extent to which the implementation timeline narrative includes reasonable steps for planning and implementing the Meaningful Benefits Plan (Section 1.2), Distributed Solar Market Strategy (Section 1.3), the Financial Assistance Strategy (Section 1.4), the Project-Deployment Technical Assistance Strategy (Section 1.5), and the Equitable Access and Meaningful Involvement Plan (Section 1.6).
Can applicants include graphics in the 40-page Program Narrative?
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Yes, applicants may choose to include graphics in the 40-page Program Narrative.
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As described in Section IV.C: Content of Application Submission, The Program Narrative must follow all the requirements listed below.
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Must not exceed the aforementioned page limits
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Must only rely on the text in the above-mentioned page limits. While attachments do not count toward the above-mentioned page limits, they may only serve as reference documents for content described in the Program Narrative; attachments that provide new content, rather than serve as reference documents, will not be reviewed or considered. Links to external websites or content will not be reviewed or considered
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Must be Letter size (8 ½ inches x 11 inches) typed, single-spaced pages in 12-point Times New Roman font with one column per page with 1-inch margins on all sides
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Please note: including graphics does not expand the Program Narrative page limit.
If an applicant has a letter of support from entities that cover more than one Program Narrative section, how should the applicant attach the letter of support to the application?
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As described in Section III.B: Application Materials of the Notice of Funding Opportunity, applicants may use the “Other Attachments Form” in the Workspace on Grants.gov to submit the following documentation, which is not required, but encouraged to be submitted, and will not count toward the 40-page limit for the Program Narrative:
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Attachment I: Letters of support from potential partnerships with community-based organizations, unions, industry associations, workforce development programs, worker centers, and other partners who are interested in helping the program execute the Section 1.2 Meaningful Benefits Plan as described in Section IV.C: Content of Application Submission.
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Attachment J: Letters of support from public utility commissions, utilities, governor’s offices, lead sponsors on legislative text, or other evidence of support for the proposed scope of work in the Section 1.3 Distributed Solar Power Market Strategy of the Program Narrative, as described in Section IV.C: Content of Application Submission, that enable low-income and disadvantaged communities to deploy and benefit from residential rooftop and residential-serving community solar and storage.
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Attachment K: Letters of support from potential partnerships with community-based organizations, nonprofits, unions, industry associations, worker centers, workforce development programs, and other partners who are interested in helping the program execute the Section 1.5 Project-Deployment Technical Assistance Plan as described in Section IV.C: Content of Application Submission.
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Attachment L: Letters of support from potential partnerships with community-based organizations, public housing authorities, utilities, rural electric utilities, affordable housing developers, unions, industry associations, workforce development programs, and other partners who are interested in helping the program execute the Section 1.6 Equitable Access and Meaningful Involvement Plan as described in Section IV.C: Content of Application Submission.
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To ensure partnerships that apply to multiple sections of the Program Narrative are evaluated with the appropriate context, applicants should either:
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Attach multiple copies of the same letter of support that details how the entity will support multiple parts of the Program Narrative in each of the relevant attachments, or
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Ask the entity to draft multiple, unique letters of support—one letter of support for the relevant Program Narrative sections and attach the relevant letter of support to attachments I, J, K, & L as relevant.
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Should all “other attachments” as described in Section IV.B: Application Materials of the Notice of Funding Opportunity be consolidated into one document?
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Yes, to upload other attachments to your application, use the “Other Attachments Form” in your Workspace on Grants.gov. Please limit the number of files for the attachment items by consolidating all attachment items into one document in the order presented in Section IV:B: Application Materials of the Notice of Funding Opportunity.
What do applicants need to submit in Section 3 of the Program Narrative “Programmatic Capabilities & Environmental Results Past Performance” as described in Section IV.C: Content of Application Submission?
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As described in Section IV.C: Content of Application Submission, applicants must submit in Attachment F of the application:
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A list of federally and/or non-federally funded assistance agreements (assistance agreements include federal grants and cooperative agreements but not federal contracts) that your organization performed within the last three years (no more than five agreements), and
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Answers to all the below prompts:
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Whether, and how, you were able to successfully complete and manage those agreements;
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Your history of meeting the reporting requirements under those agreements including whether you adequately and timely reported on your progress towards achieving the expected outputs and outcomes of those agreements (and if not, explain why not) and whether you submitted acceptable final technical reports under the agreements; and
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Your organizational experience and plan for timely and successfully achieving the objectives of the proposed project, and your staff expertise/qualifications, staff knowledge, and resources or the ability to obtain them, to successfully achieve the goals of the proposed project.
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The list of federally and/or non-federally funded assistance agreements should be a simple list of assistance agreements. Applicants may choose to include the following information in the list of assistance agreements: the name of the Grantor, the program name/project name, the project period dates, and identifying number (e.g., the assistance number) if applicable.
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The answers to all the prompts above will primarily be paragraphs of narrative. Applicants may include a timeline to support the third prompt.
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The first two prompts relate to the list of federally and/or non-federally funded assistance agreements. Applicants should answer for each of the assistance agreements listed:
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Whether, and how, you were able to successfully complete and manage those agreements; and
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Your history of meeting the reporting requirements under those agreements including whether you adequately and timely reported on your progress towards achieving the expected outputs and outcomes of those agreements (and if not, explain why not) and whether you submitted acceptable final technical reports under the agreements.
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Applicants should explain in the last prompt the plan for timely plan for timely and successfully achieving the objectives of the Solar for All program and how the applicant has the organization experience, expertise/qualifications, staff knowledge, and resources or the ability to obtain them, to successfully achieve the goals of the proposed project.
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Section IV.C: Content of Application Submission, in evaluating applicants under these factors in Section V.A: Evaluation Criteria, EPA will consider the information provided by applicants and may also consider relevant information from other sources, including information from EPA files and from current/prior grantors (e.g., to verify and/or supplement the information provided by the applicant).
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Section IV.C: Content of Application Submission, if you do not have any relevant or available past performance or past reporting information, please indicate this in the application and you will receive a neutral score for the first two factors (a neutral score is half of the total points available in a subset of possible points). If you do not provide any response for these items, you may receive a score of 0 for these factors.
To whom should letters of support be addressed?
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Letters of support can be written to U.S. Environmental Protection Agency headquarters and addressed, "To whom it may concern."
Section E of the SF-424A form asks for applicants to detail budget needs for the first four years of the program. How should applicants provide estimates for the budget needs for the fifth year of the program in the form?
- Applicants should include information on the budget for the full period of performance in Section A, B, and C of the SF-424A. Applicants only need to detail the budget needs for the first four years of the program in Section E of the SF-424A form.
- Applicants should include budget information for all years of the period of performance (i.e., beyond year four if relevant for the applicant) in the Program Narrative Attachment E, Budget Table, as described in Section IV.B: Application Materials and Appendix B. Program Budget of the Notice of Funding Opportunity.
Evaluation Criteria
What constitutes an “environmental results past performance”?
- As described in Section IV.C: Content of Application Submission in the Notice of Funding Opportunity, in the Program Narrative Section 3 “Programmatic Capability and Environmental Results Past Performance,” EPA asks applicants to submit in Attachment F of their application a list of federally and/or non-federally funded assistance agreements (assistance agreements include federal grants and cooperative agreements but not federal contracts) that the applicant performed within the last three years (no more than five agreements) and answer all the below prompts. Note: for coalition applicants, the list of funded assistance agreements must be from the lead applicant.
- Whether and how you were able to successfully complete and manage those agreements
- Your history of meeting the reporting requirements under those agreements including whether you adequately and timely reported on your progress towards achieving the expected outputs and outcomes of those agreements (and if not, explain why not) and whether you submitted acceptable final technical reports under the agreements
- Your organizational experience and plan for timely and successfully achieving the objectives of the proposed project, and your staff expertise/qualifications, staff knowledge, and resources or the ability to obtain them, to successfully achieve the goals of the proposed project
- In evaluating applicants under these factors as described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, EPA will consider the information provided by applicants and may also consider relevant information from other sources, including information from EPA files and from current/prior grantors (e.g., to verify and/or supplement the information provided by the applicant). If the applicant does not have any relevant or available past performance or past reporting information, the applicant should indicate this in the application and will receive a neutral score for these factors (a neutral score is half of the total points available in a subset of possible points). If an applicant does not provide any response for these items, you may receive a score of 0 for these factors.
How should applicants consider O&M costs given funds must be expended in five years?
- As described in Section V.A: Evaluative Criteria, EPA will evaluate applicants on their strategy to provide O&M support for projects that receive financial assistance under Solar for All.
- While the period of performance of this program is five years, a solar project could have a lifetime of anywhere between 15 to 30 years. Thus, applicants should design strategies to provide O&M services to assets beyond the five-year period of performance.
How should applicants consider “duplicate” financial assistance?
- Applicants should avoid using Solar for All grant funds on projects or activities that could be financed through other sources of funding including other federal, state, and local assistance programs such as DOE’s Weatherization Assistance Program.
- For example, if a single family home eligible for energy efficiency rebates from a local utility, the Solar for All program should not provide the single family home financial assistance for energy efficiency.
Is EPA open to applicants proposing strategies that would require legislative action, so long as the applicant can provide evidence that the legislative action is/will be under consideration?
- Yes, as described in Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, in the Distributed Solar Market Strategy section of the Program Narrative, EPA will evaluate applicants on the extent and quality to which applications addresses policies and regulations that are either barriers or benefits to the deployment of residential distributed solar. An applicant’s program strategy to address barriers or benefits may require policy or regulatory changes.
- If a recipient’s program strategy depends on legislative or regulatory action that ultimately does not materialize the cooperative agreement may need to be amended.
- Applicants should also be mindful of the restrictions in 2 CFR 200.450 that restrict a recipient’s use of grant funds for lobbying purposes.
In Section V.A: Evaluation Criteria of the Notice of Funding Opportunity, what is the definition of “award funding requested” in the Impact Targets part of the Program Narrative.
- Award funding requested is the total grant funds an applicant is requesting from EPA in their application. For example, if an applicant is applying for a $25 million award, the award funding requested in $25 million.
Should costs for workforce development programs be classified as financial assistance or project-development technical assistance?
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Workforce development activities and costs are project-development technical assistance as defined in Section 1.D: Competition Terminology of the Notice of Funding Opportunity.
Program Budget
What is the indirect cost rate that coalition members (i.e., named subrecipients) charge to Solar for All?
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Indirect costs (IDCs) are those incurred for a common or joint purpose that benefit more than one cost objective or program and are not readily assignable to specific cost objectives or projects as a direct cost. Indirect costs may be budgeted and charged by recipients of Federal assistance agreements in accordance with 2 CFR Part 200.
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Per EPA’s Subaward Policy, the indirect cost rate may be a rate negotiated and approved by the subrecipient’s cognizant Federal agency. If the subrecipient does not have a Federal indirect cost rate, the pass-through entity may negotiate an indirect cost rate with the subrecipient that complies with 2 CFR Part 200, Subpart E or use the 10% de-minimis indirect cost rate described at 2 CFR 200.414(f).
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In the budget table, a subrecipient’s indirect cost should be included in the subaward line item. Only the grantee’s indirect costs should be included in the indirect budget line item.
Do applicants have to submit both the Budget Information for Non-Construction Programs (SF-424A) form as well as Attachment E: Budget Table described in Section 2.1 Budget Narrative of the Program Narrative?
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Yes, as described in Section IV.C: Content of Application Submission, applicants must submit budget information in SF-424A and the Budget Table included in Attachment E of the application.
How should states, municipalities, and Tribal governments categorize transfer of funding between departments or agencies of the same unit of governments?
- A recipient’s exact mechanism for transferring grant funds between departments or agencies of the same unit of government depends on the applicable state, local, and tribal laws and policies governing the unit of government.
- EPA’s general policy is to recognize states, municipalities, and tribal governments as individual legal entities, even if one agency within the unit of government is named in the assistance agreement. For this reason, transfers of funds between agencies of the same unit of government are typically not considered procurement contracts or subawards.
- However, in some cases, a state, municipality, or tribal government may recognize an agency within the unit of government as legally separate for the purposes of financial transactions or financial management policies that require separate instruments for accounting purposes (e.g., due to differences in indirect cost rates). In such cases, the recipient may consider the transaction a subaward if the recipient complies with the requirements for pass-through entities at 2 CFR 200.332 and EPA’s subaward policy.
- Some units of government may choose to transfer funds via Interagency Service Agreements for distribution of direct costs, subawards, or procurement contracts. Budgets describing these types of transactions will take various forms but must clearly assign costs to appropriate categories. The recipient may categorize direct costs under the interagency Service Agreement as “contractual,” if the transaction between the two units of government is considered a procurement contract in accordance with state, local, or tribal law.
- EPA staff will work closely with the governmental recipient to develop accurate information on how EPA funds will be transferred and expenditures characterized for budget purposes. It is possible that the indirect cost rates for departments or agencies within the same unit of government will be different. For example, recipients may either provide separate budgets (encompassing both direct and indirect costs) for each department’s share of the EPA award or characterize the transactions as subawards with allowable indirect costs.
- If the governmental recipient provides separate budgets for each department, the EPA award document should include separate budget worksheets for each department receiving EPA funds. However, these budgets may be consolidated into a single budget table at time of award depending on the practice of the EPA awarding office.
- Expenditures under an Interagency Service Agreement should be classified under the appropriate direct cost (e.g., personnel, travel, contractual, etc).
- If the governmental recipient characterizes the funding transfers among departments as subawards, a line-item amount would be included in the budget narrative for the “Other” cost category. The recipient must comply with the requirements for pass-through entities at 2 CFR 200.332 if the transfer will be in the form of a subaward.
- If under state law transactions between agencies is classified as a procurement contract, then the costs may be classified as contractual. Transactions between agencies or departments of other units of government may also be classified as contractual depending on the nature of the transaction and state, tribal or local government law.
- Under 2 CFR 200.302(a) states expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds.
- Please note: This FAQ was revised on October 6, 2023.
How should applicants list technical assistance in the budget table?
- The correct categorization of costs to provide technical assistance to enable low-income and disadvantaged communities to deploy and benefit from residential distributed solar depends on the type of cost. For example:
- The cost for the grantee to hire a team of two full-time employees to engage with utilities on interconnection costs should be listed in the “personnel” cost category since the cost is to hire staff.
- The cost for a third-party to provide technical assistance services to developers on siting and permitting should be listed in the “other” cost category. Note, this form of technical assistance cost is not considered a subaward since technical assistance in the form of services instead of money or other assistance in the form of revenue sharing or direct appropriations is not a “subaward”.
- The cost for the grantee to provide technical assistance in the form of financial products to communities and businesses such as predevelopment grants and loans should be listed in the “other” cost category as a subaward or a participant support cost since technical assistance in the form of money are considered subawards or participant support costs.
- For more information, please review Interim General Budget Development Guidance for Applicants and Recipients of EPA Financial and EPA’s “How to Develop a Budget” training.
How should applicants list subrecipients in the budget table?
- In the budget table, subawards/subgrants/subrecipients should be listed in the “other” category.
- Subawards (i.e., “Subgrants”) are a distinct type of cost under the “Other” category and are subject to the requirements in 2 CFR 200.331 and 200.332 as well as EPA’s Subaward Policy, GPI 16-01.
- As provided in the definition of Subaward at 2 CFR 200.1 and 2 CFR 200.331(a) the term “subaward” means an award of financial assistance (money or property) by a pass-through entity (the recipient) to a subrecipient to carry out part of the EPA funded project even if the recipient provides the assistance under an instrument designated as a “contract.” When a recipient provides a subaward to a subrecipient, the recipient becomes a Pass-through entity as defined at 2 CFR 200.1. b. The term “subaward” does not include:
- Technical assistance in the form of services instead of money or other assistance in the form of revenue sharing or direct appropriations.
- Payments to program beneficiaries such as participant support costs.
- For more information, please review Interim General Budget Development Guidance for Applicants and Recipients of EPA Financial and EPA’s “How to Develop a Budget” training.
What is the indirect cost rate that coalition members (i.e., named subrecipients) charge to Solar for All?
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Indirect costs (IDCs) are those incurred for a common or joint purpose that benefit more than one cost objective or program and are not readily assignable to specific cost objectives or projects as a direct cost. Indirect costs may be budgeted and charged by recipients of Federal assistance agreements in accordance with 2 CFR Part 200.
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Per EPA’s Subaward Policy, the indirect cost rate may be a rate negotiated and approved by the subrecipient’s cognizant Federal agency. If the subrecipient does not have a Federal indirect cost rate, the pass-through entity may negotiate an indirect cost rate with the subrecipient that complies with 2 CFR Part 200, Subpart E or use the 10% de-minimis indirect cost rate described at 2 CFR 200.414(f).
Do applicants have to submit both the Budget Information for Non-Construction Programs (SF-424A) form as well as Attachment E: Budget Table described in Section 2.1 Budget Narrative of the Program Narrative?
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Yes, as described in Section IV.C: Content of Application Submission, applicants must submit budget information in SF-424A and the Budget Table included in Attachment E of the application.
Award Administration
National Policy Requirements
Does Build America, Buy America applies to Solar for All?
- Yes, as described in Section VI.B: Administrative and National Policy Requirements of the Notice of Funding Opportunity, Build America, Buy America does apply to Solar for All. EPA intends to issue additional guidance on how Build America, Buy America applies to Solar for All at a later date. Certain projects under this competition are subject to the Buy America Sourcing requirements under the Build America, Buy America (BABA) provisions of the Infrastructure Investment and Jobs Act (IIJA) (P.L. 117-58, §§70911-70917) that apply when using Federal funds for the purchase of goods, products, and materials on any form of construction, alteration, maintenance, or repair of infrastructure in the United States. The Buy America preference requirement applies to all the iron and steel, manufactured products, and construction materials used for the infrastructure project under an award for identified EPA financial assistance funding programs. Please consider this information when preparing budget information. EPA will provide further guidance on which projects are subject to BABA provisions and will work with grantees to support implementation as necessary, as applicants comply with applicable Buy America preference requirements or apply for a waiver for each infrastructure project.
Does Davis-Bacon and Related Acts apply to Solar for All?
- Yes, as described in Section VI.B: Administrative and National Policy Requirements of the Notice of Funding Opportunity, Davis-Bacon and Related Acts apply to Solar for All. EPA intends to issue additional guidance on how Davis-Bacon and Related Acts apply to Solar for All at a later date. The Davis-Bacon Act (42 USC §§3141-3144) (DBA) sets out labor standards, including prevailing wages and fringe benefits, and applies to most federally funded contracts for construction of public works. The DBA labor standards and reporting requirements also apply to projects assisted with grants authorized by the Clean Air Act as provided in Section 314 of the Clean Air Act (DBRA) (42 USC §7614). The grant agreement will include a term and condition specifying DBRA compliance requirements.
Do Title IX Requirements apply to Solar for All?
- If the recipient is an education program or activity (e.g., school, college or university) or if the recipient is conducting an education program or activity under the assistance agreement, the recipient must comply with Title IX of the Education Amendments of 1972. Title IX prohibits discrimination on the basis of sex in education programs and activities operated by entities receiving Federal financial assistance. For further information about compliance obligations regarding Title IX, see 40 CFR Part 5 and the Department of Justice.
Is Solar for All a covered program under Justice40?
- As described in Section VI.B: Administrative and National Policy Requirements of the Notice of Funding Opportunity, the Greenhouse Gas Reduction Fund, including Solar for All, is a covered program under the Justice40 Initiative.
What are the Justice40 requirements for Solar for All grantees?
- According to the Interim Implementation Guidance for the Justice40 Initiative released by the Office of Management and Budget on July 20, 2021, the Justice40 Initiative directs that EPA track and measure program benefits, setting the goal that at least 40% of the overall benefits from certain federal investments in climate, clean energy and other areas flow to disadvantaged communities.
Are projects funded under Section 134 of the Clean Air Act subject to review procedures required by the National Environmental Policy Act (NEPA)?
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It depends. Projects that are carried out with grants awarded under Section 134 of the Clean Air Act are exempt from NEPA pursuant to 15 USC § 793(c)(1). However, if a part of a project is also carried out with funding from another Federal agency, NEPA may apply to that agency’s funding. Grantees should consult with an appropriate representative from the other Federal agency to determine whether NEPA applies in such a situation.
Fund Draw Down Mechanisms
Will grant funds be disbursed to grantees once awards are made?
- No, EPA will not disburse grant funds at the time of award. Once EPA awards the Solar for All cooperative agreement, the recipient will only have access to funding (“draw down”) to the extent authorized in 2 CFR 200.305(a) for states and 2 CFR 200.305(b) for non-state recipients.
- States draw down funds based on the standards specified in their Cash Management Improvement Act agreements with the U.S. Treasury or the Treasury regulations at 31 CFR part 205 and Treasury Financial Manual (TFM) 4A–2000, “Overall Disbursing Rules for All Federal Agencies” as provided in 2 CFR 200.305(a).
- Non-state recipients are subject to the “Proper Payment Draw Down” General Term and Conditions in EPA’s General Terms and Conditions for Assistance Agreements which interpret 2 CFR 200.305(b). Essentially, non-state recipients may only draw down funds to meet their immediate cash needs and must disburse substantially all of the drawn down funds within five business days to pay employees, contractors, subrecipients or other allowable costs.
Grant Agreements
If one entity submits multiple applications and is awarded multiple awards, would those awards be combined into one single assistance agreement?
- EPA and the entity will sign an assistance agreement for every award made. Multiple awards to a single entity will not be combined into one assistance agreement.
During the program period, can funds be shifted within the budget across different program activities?
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The ability of a grantee to shift funds within the budget across different program activities depend on the size and scope of the budget revision.
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Budget revisions must comply with section 13 of the competition policy, the regulations at 2 CFR 200.308, 2 CFR 200.407, EPA’s Interim General Budget Development Guidance for Applicants and Recipients of EPA Financial Assistance, and the terms and conditions of the awards.
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As provided at 2 CFR 200.308(f), grant recipients may transfer funding among direct budget categories, programs, functions, and activities if the cumulative amount of funding transfers are 10% or less of the total budget. Recipients must notify EPA’s Grant Specialist and Project Officer of cumulative funding transfers among direct budget categories or programs, functions and activities that do not exceed 10% of the total budget for the agreement.
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As provided at 2 CFR 200.308(f), grant recipients must obtain prior approval from EPA’s Grants Management Officer if the cumulative amount of funding transfers among direct budget categories or programs, functions and activities exceeds 10% of the total budget. Recipients must submit requests for prior approval to the Grant Specialist and Grants Management Officer with a copy to the Project Officer for this agreement.
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Prior approval by EPA’s Grant Management Officer is required if the transfer involves any of the items listed in 2 CFR 200.407 that EPA did not previously approve at time of award or in response to a previous post-award request by the recipient.
What are the program income requirements after the assistance agreement ends?
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EPA-specific rules on program income are provided at 2 CFR § 1500.8. Recipients may keep program income at the end of the assistance agreement as long as they use these funds to continue to operate the program or some other authorized purpose as outlined in their closeout agreement.
If a grantee violates any requirement under Section 134 of the Clean Air Act, what remedies may EPA or the U.S. Department of Justice (DOJ) seek under the Clean Air Act?
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The grantee may be subject to remedies available to the EPA pursuant to Clean Air Act Section 113, which include, but are not limited to, civil administrative penalties through an EPA administrative enforcement action, civil penalties and/or injunctive relief through a DOJ civil judicial enforcement action, or criminal penalties through a DOJ criminal judicial enforcement action.