2-Attachment 1 EPA Comprehensive Climate Action Plan.pdf

ATTACHMENT 1

EPA Comprehensive Climate Action Plan: An Outline for Tribes and U.S. Territories

Comprehensive Climate Action Plan: An Outline for Tribes and U.S.

Territories

January 2025

PREPARED FOR:

The Climate Pollution Reduction Grant Program

State and Local Climate and Energy Program

U.S. Environmental Protection Agency

PREPARED BY:

ICF

2550 S Clark St. Arlington, VA 22202

Tel: (571) 842‐4500

With contribution and review by U.S. EPA

CCAP Outline for Tribes and Territories

PART 1. HOW TO USE THIS DOCUMENT

Disclaimer: This document offers an illustrative approach to drafting a Comprehensive Climate Action

Plan (CCAP) for Tribes and Territories under the Environmental Protection Agency’s (EPA’s) Climate

Pollution Reduction Grants (CPRG) Program. Grantees are not required to follow this outline or use its format. However, CCAPs must meet the submission requirements described in the EPA’s CPRG: Formula

Grants for Planning, Program Guidance for Federally Recognized Tribes, Tribal Consortia, and U.S.

Territories (program guidance). To the extent that anything in this document conflicts with the program guidance, the program guidance is the official guidance that takes precedence and priority. Please contact CPRG@epa.gov with questions.

The document includes a functional CCAP outline and an appendix with additional information to support CCAP development for Tribes, Tribal Consortia, and territories. In this outline, the term “Tribes” refers to and applies to single or multiple federally recognized Tribe(s) and Tribal consortia eligible under the CPRG Planning Grant Program. The term “Territory” refers to and applies to the U.S. Territories of

Guam, American Samoa, U.S. Virgin Islands, and the Northern Mariana Islands.

The CCAP outline and appendix are intended to help clarify the requirements for CCAPs and present an outline that, when filled in, will satisfy those requirements. The outline also includes options for Tribes and territories to “enhance” their plans by going beyond the basic program requirements.

Tribes and territories may draw from or reference elements of existing climate action plans or other relevant plans in conjunction with, or instead of, using this outline. Grantees may also leverage the content of the Priority Climate Action Plan (PCAP) as a starting point recognizing that there are more required elements to the CCAP.

The following table shows the required CCAP elements, where they are described in the program guidance, and where those elements are addressed in this outline.

Table 1. Required CCAP elements and guidance locations

Required CCAP Elements Location in Program Guidance

CCAP Outline Section Location in CCAP Outline

Greenhouse gas (GHG) inventory Page 26 Section 3 Page 3

GHG reduction targets Page 27 Section 4 Page 6

GHG emission projections Page 27 Section 5 and Section 6.2 Page 7 and 10

Quantified GHG reduction measures Page 28 Sections 6.1 and 6.3 Page 10 and 11

Benefits analysis Page 29 Sections 6.3 and/or 7 Page 16

Review of authority to implement Page 29 Section 6.3 Page 11

Intersection with other funding availability Page 30 Section 6.3 Page 11

Workforce planning analysis Page 31 Sections 6.3 and/or 8 Page 11 and 18 https://www.epa.gov/system/files/documents/2023-02/EPA%20CPRG%20Planning%20Grants%20Program%20Guidance%20for%20Tribes-Tribal%20Consortia-Territories%2003-01-2023.pdf https://www.epa.gov/system/files/documents/2023-02/EPA%20CPRG%20Planning%20Grants%20Program%20Guidance%20for%20Tribes-Tribal%20Consortia-Territories%2003-01-2023.pdf https://www.epa.gov/system/files/documents/2023-02/EPA%20CPRG%20Planning%20Grants%20Program%20Guidance%20for%20Tribes-Tribal%20Consortia-Territories%2003-01-2023.pdf mailto:CPRG@epa.gov

Grantees are encouraged to modify the elements of the outline to accommodate local needs, goals, and knowledge, as necessary. Sections may be added or deleted, provided that the document still includes the required CCAP elements. Not all headings included in this outline represent required elements for the CCAP.

Headings and subheadings are indicated by large blue font and are numbered throughout the document. Grantees may use this text style if desired, but it is not required.

Help text is italicized. The help text describes the purpose and kind of information that may be included in each section of the document.

Grantees are not required to follow the suggestions of the help text. Please delete all help text prior to submission.

Italicized bulleted lists are used to describe the contents of specific sections. Not all CCAPs will need to address each point of a bulleted list in the outline or program guidance, unless otherwise specified.

Please delete any unused or irrelevant bulleted lists prior to submission to the EPA.

To support grantee CCAP development, the outline includes example tables, example text boxes, and ideas to “enhance your plan,” which are noted with blue, yellow, and green outlines respectively. Some examples are derived from grantee PCAPs and may have been slightly adapted for clarity and conciseness. Trainings on the CCAP elements and Question & Answer documents for each element can be found at CPRG Training - Tools and Technical Resources. Technical Assistance Forum (TAF)

Participants may also consult the TAF Resource Library.

Navigating Text

Headings

Subheadings

Help Text

• Bulleted list https://www.epa.gov/inflation-reduction-act/cprg-training-tools-and-technical-resources https://endyna2.sharepoint.com/sites/CPRGTAFResourceLibrary/SitePages/TrainingHome.aspx i

PART 2. DRAFT CCAP OUTLINE

Tribes and Territories CCAP Title Page Customize this title page to include the grantee organization(s), date, CCAP authors, and contact information for the organization leaders and/or authors. Grantees may include a photograph or logo(s).

This page may include the following disclaimer:

“This project has been funded wholly or in part by the United States Environmental Protection Agency

(EPA) under assistance agreement <number> to <recipient>. The contents of this document do not necessarily reflect the views and policies of the EPA, nor does the EPA endorse trade names or recommend the use of commercial products mentioned in this document.”

If this disclaimer is not included on a title page, grantees must include it somewhere else within the CCAP document submitted to the EPA.

Acknowledgements Use this space to acknowledge the CCAP writing and analysis team and any stakeholders, contributors or collaborators that were integral to the development of the CCAP. This may have its own page or section.

Definitions and Acronyms Use this space to define any key terms and acronyms used in the CCAP. This may have its own page or section.

ii

Table of Contents The CCAP may benefit from a table of contents to help readers navigate various sections. The table of contents typically includes primary headings, subheadings, and page numbers. The final CCAP document may include live links from the table of contents to document sections to help easily navigate to specific sections in the electronic version.

Tribes and Territories CCAP Title Page........................................................................................................... i

Acknowledgements ........................................................................................................................................ i

Definitions and Acronyms .............................................................................................................................. i

Table of Contents .......................................................................................................................................... ii

List of Figures ............................................................................................................................................... iii

List of Tables ................................................................................................................................................ iii

Executive Summary

1 Introduction

1.1 CPRG Overview

1.2 CCAP Purpose and Scope

1.3 Approach to Developing the CCAP

2 Tribal or Territorial Organization and Considerations

2.1 The Tribal or Territorial PCAP Management and Development Team

2.2 Special Considerations for Tribal or Territorial Entities

2.3 Collaboration

3 Greenhouse Gas (GHG) Inventory

3.1 Inventory Methodology

3.2 Inventory Results

3.3 Inventory Trends and Analysis

4 Near-Term and Long-Term GHG Reduction Targets

5 BAU GHG Emission Projections

5.1 BAU Projections Methodologies

5.2 BAU Projections Results

6 GHG Emission Reduction Measures and Implementation Scenario Projections

6.1 GHG Emission Reduction Measures Summary

6.2 Implementation Scenario Projections

6.3 GHG Emission Reduction Measures

6.3.1 Sector 1 Measures (repeat sections as needed for each sector)

7 Benefits Analysis

8 Workforce Planning Analysis

9 Appendices iii

List of Figures A CCAP with multiple visual elements may benefit from a List of Figures. Figures can be photographs, illustrations, charts, etc. List each figure title along with their respective page number(s).

List of Tables A CCAP with multiple tables may benefit from a List of Tables. Unlike figures, tables display raw data in rows and columns. List each table title along with their respective page number(s).

Executive Summary The Executive Summary allows readers to understand the overall content of the CCAP without reading the entire document. This summary may be used by the general public, policy makers, specific stakeholder groups, or other intended audiences and should be drafted with those audiences in mind.

This section may contain a high-level overview of the CCAP including:

• The purpose of and scope of the CCAP

• CCAP overview o Identifying CCAP team leadership o Responsible agency/agencies (e.g., grantee and subgrantees) or staff and roles o Tribe- or Territory- specific considerations for the CCAP (e.g., existing plans and processes integrated in the CCAP, existing policy or programmatic context, special interests) o High-level review of existing climate action plans and other relevant plans or policies

(e.g., PCAP) used for the CCAP o Summary of collaboration and coordination with other Tribes, agencies, and municipalities o Summary of CCAP engagement with community members, businesses, workforce organizations, and other partners (e.g., established committees, engagement or feedback approaches, collaborators, contributors)

• CCAP elements and their impacts on the Tribes or Territory, including:

o GHG inventory results (Section 3 and Business-as-Usual (BAU) projections (Section 5) o GHG reduction targets (Section 4) o Estimated GHG reductions and costs due to planned emission reduction measures

(Section 6) o Benefits and disbenefits estimated for the plan’s full geographic area (Section 7 o Key plan implementation milestones and metrics (Section 6)

Please note that an Executive Summary may contain more or fewer elements than listed above. Adding summary figures or tables (e.g., see Table 2, Table 3, Table 4, or Figure 1) in the Executive Summary is optional.

1 Introduction The introduction section provides the reader with enough background information to understand the contents of the CCAP.

1.1 CPRG Overview

This section may include a brief overview of the CPRG program and could discuss why the grantees chose to participate in the CPRG program.

1.2 CCAP Purpose and Scope

This section may include a brief overview of the CCAP purpose, including how it builds on the work submitted in the PCAP or in other pre-existing climate action or related planning efforts. This may include a summary of local context, including existing mandated or legislated GHG reduction targets and/or sector specific goals, GHG emission reduction policies or programs, Tribal or territorial decision-making approaches, or other relevant information.

Descriptions of scope may include defined geographic regions covered by the CCAP and the range of years included in the historic inventory data and future projections. In instances where grantees’ geographic scope is located across multiple states or counties, consider discussing the points above for all relevant jurisdictions.

1.3 Approach to Developing the CCAP

This section may describe the grantees’ high-level approach to developing the CCAP, which may include, but is not limited to the following:

• Timeline and brief description of work to current date.

• Contributing organizations and their role(s) in developing the CCAP (e.g., intra- and/or inter-governmental coordination, subgrantees).

• A description of the grantee’s approach to completed and planned meaningful engagement, which may include but is not limited to tribal and community organizations, governments, businesses, utilities, trade associations, and the general public.

This section may reference or include information from the grantee’s workplan or information from the

PCAP that is consistent with the CCAP.

2 Tribal or Territorial Organization and Considerations This section could provide the reader with background information on the organizational structure of the

CCAP management team and collaborators, along with Tribe- or Territory-specific considerations that may have an impact on the CCAP’s development and/or implementation. Alternatively, this information could be included within the Introduction (Section 1) instead of having its own section (Section 2).

2.1 The Tribal or Territorial CCAP Management and Development Team This section may describe the organizations involved with drafting the CCAP, which may include but are not limited to the following:

• Tribal leaders (e.g., Presidents, Chief(s), Chairman, Tribal Council, etc.)

• Territorial leaders

• Tribal agencies (e.g., environment, natural resources, land use departments)

• Territorial agencies (e.g., environment, natural resources, land use departments)

• Advisory committees

• Other groups, (e.g., third-party consultants, community-based organizations)

This section may include a description or explanation of the organizational structure and decision-making authority of the Tribal or Territorial CCAP Management and Development Team.

2.2 Special Considerations for Tribal or Territorial Entities This section may describe any specific cultural or community considerations that influence the Tribal or

Territorial CCAP development and/or implementation. For the CCAP, grantees may describe how these considerations contributed to the selection of priority measures. These considerations may include, but are not limited to the following:

• Presence of sector-specific goals

• Existing GHG inventories or similar assessments

• Benefits quantifications

• Existing emission reduction plans, programs, or strategies

• Authority and accountability structures or systems associated with emission reduction plans, programs, or strategies

• Cultural restrictions, geographic remoteness, land governance and/or need for special permissions that can impact emission reduction measures and strategies

2.3 Collaboration

This section could describe how the CCAP Management and Development Team worked with other entities/organizations to develop the CCAP. This information may also be included in Section 1.3. These organizations may include but are not limited to:

• Individual Tribal members or Territory residents

• Community organizations

• Local, state government, and federal government

• Private businesses

• Utilities

• Trade associations

3 Greenhouse Gas (GHG) Inventory This section must summarize a comprehensive GHG inventory describing emission sources and sinks (e.g., through the uptake of carbon and storage in forests, vegetation, and soils) for every sector for the entire geographic scope of a Tribe or Territory (to the extent possible). The full inventory must be provided in the CCAP, in a CCAP appendix, or by reference to a GHG inventory report or website. Grantees may only re-use PCAP inventories if they meet the requirements of a comprehensive inventory (i.e., an inventory that addresses all sources and sinks of GHG emissions), which are described in the subsections below.

GHG emissions from all sources and sinks should be reported in both metric tons of each GHG and in metric tons of carbon dioxide equivalent (MT CO2e). To calculate emissions in CO2e, each GHG’s emissions in metric tons are multiplied by that GHG’s global warming potential (GWP), as shown in

Equation A-1 in 40 CFR Part 98 (the Greenhouse Gas Reporting Program or GHGRP). GWPs must reflect the Fifth Assessment Report (AR5) of the Intergovernmental Panel on Climate Change (IPCC).

3.1 Inventory Methodology

The EPA encourages grantees to provide a description of the methods and data used to estimate historical GHG emissions. The method may depend on the data available, and grantees may use the method best suited to these data and the geographic region. There are several accepted methodological frameworks grantees may use to estimate emissions depending on whether it is a Tribe or Territory, such as the Global Protocol for Community-Scale GHG Emissions Inventories or methodologies that are consistent with the IPCC GHG inventory guidance. EPA has compiled a list of GHG inventory resources that may be useful for CPRG deliverables. A methods section may include clear descriptions of:

• Tools or methodologies used for each sector and sources or sinks within the sector.

• GWP selection (e.g., 100-year time horizon from the AR5).

• Geographic scope of inventory.

• Reasoning for selection of any base, interim, and recent inventory year(s).

https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98?toc=1 https://www.epa.gov/inflation-reduction-act/cprg-tools-and-technical-resources-greenhouse-gas-inventory-and-projections

• Data sources, including where and how proxying or scaling of data are used.

• Data review and quality assurance practices.

Grantees may select any reasonable inventory year(s) given the availability of emissions data. Grantees are encouraged to develop inventories for more than one year to show trends in emissions over time.

Often earlier GHG inventory years will serve as the inventory base year for a GHG reduction target (for more information, see Section 4). The most recent year may serve as the base year for grantees with limited data availability. Grantees may elect to include inventory data for one or more interim years between the base year and a recent inventory year (represented by the grayed out columns in Table 2) to provide additional insights into emission trends, if the appropriate data is available.

When selecting methods and considering data availability, grantees are encouraged to examine the data gaps and refine any proxy methods used as a part of PCAP inventories. Tribes or Territories with multiple inventories must compile these results into one complete inventory for the CCAP.

A more detailed discussion of GHG inventory methods may be included in a CCAP appendix or a separate referenced website or inventory report.

3.2 Inventory Results

This section must include an overview or summary of emissions for GHG inventory years estimated by a

Tribe or Territory. The GHG emissions inventory must include emissions data for each GHG in both metric tons and metric tons of carbon dioxide equivalent (MT CO2e) (note: grantees are required to report emissions for all major sectors in the CCAP). Grantees may choose to use data visualization tools to clearly display inventory results. Inventory charts and tables may include:

• Tables and graphs displaying total inventory results by gas for the inventory year(s).

• Tables and graphs displaying total inventory results by sector, subsector, or gas (gross and net) for the inventory year(s).

• Tables and graphs displaying changes over time or trends for the total inventory and by sector, subsector, or gas (e.g., % change from prior years).

Grantees may select one or a mix of approaches to display GHG inventories. Table 2 provides an example of inventory emissions by sector expressed in CO2e. Additional details for the GHG inventory may be provided in an appendix or a separate, referenced inventory report. See, for example, Table 8, Table 9, and Table 10 in Part 3 of this document.

Table 2. GHG inventory emissions by sector (MTCO2e)

Note: Where appropriate, grantees can include notations indicating that emissions for a particular sector are not applicable (NA), included elsewhere (IE), or not occurring (NO).

3.3 Inventory Trends and Analysis

Grantees are encouraged to examine historic trends in GHG emissions and provide some analysis of results. For example, inventories may show significant GHG emissions decreases in 2020 due to the

COVID-19 pandemic. Use this section to give context to inventory results where needed. Grantees may also integrate Sections 3.2 and 3.3 into one report section if preferred.

Text Box 1. Enhance your plan with a GHG inventory trends analysis

Sector Base Year (for GHG Reduction Targets) (e.g., 2005)

Interim Year 1 (e.g., 2010)

Interim Year 2 (e.g., 2015)

Interim Year 3 (e.g., 2020)

Most Recent Inventory Year (e.g., 2022)

Commercial and Residential Buildings

Electricity Generation

Transportation

Industry

Agriculture

Natural and Working Lands

Waste and Materials Management

Total Emissions

To enhance your plan:

Consider analyzing GHG inventory results by sector or sub-sector and identifying trends in emissions over time. Identify which emission sources or sinks have driven those trends, and what external factors may have influenced these increases or decreases (economic shifts, demographic shifts, changes in supply or demand, etc.).

4 Near-Term and Long-Term GHG Reduction Targets A CCAP must include:

• An economy-wide near-term (e.g., 2030) GHG reduction target on a gross or net GHG emission basis.

• An economy-wide long-term (e.g., 2050) GHG reduction targets on a gross or net GHG emission basis.

Grantees may define targets by populating the bracketed contents “[ ]” in the language below:

𝑇𝑎𝑟𝑔𝑒𝑡 = 𝑟𝑒𝑑𝑢𝑐𝑒 [𝑒𝑐𝑜𝑛𝑜𝑚𝑦 𝑤𝑖𝑑𝑒 𝑜𝑟 𝑠𝑒𝑐𝑡𝑜𝑟 𝑏𝑎𝑠𝑒𝑑] 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 [𝑝𝑒𝑟𝑐𝑒𝑛𝑡] 𝑏𝑒𝑙𝑜𝑤 [𝑏𝑎𝑠𝑒 𝑦𝑒𝑎𝑟] 𝑒𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠 𝑏𝑦 [𝑡𝑎𝑟𝑔𝑒𝑡 𝑦𝑒𝑎𝑟]

Text Box 2. Example GHG reduction targets

Text Box 3. Enhance your plan with sector-based targets

Grantees may select any appropriate base year but must include a discussion supporting their base year selection.

When selecting a base year, consider:

• Do existing Tribal or Territorial goals, policies, or programs for emission reductions specify a base year? Do other regional agencies (states, Metropolitan Statistical Areas (MSAs), counties) specify a base year?

• Is the selected base year representative of general emissions patterns (e.g., not uncharacteristically high or low due to external factors)?

• Do robust data exist to support the GHG inventory in that year?

The EPA recommends using 2005 as a base year, when possible, as it is consistent with many GHG reduction targets, but recognizes it may not be feasible for all grantees. Therefore, grantees are encouraged to select an alternate base year if historical GHG data are unavailable or to align with an existing target that uses a different base year. In instances where grantees only have data for a single inventory year, this year may also serve as its base year for target reduction.

Grantees must select both a near-term and long-term target year for emission reductions. When selecting a target year, consider:

GHG Reduction Targets

The Chickaloon Native Village intends to target 50% reduction below 2022 levels by 2030 and will achieve net-zero GHG emissions by 2050.

To enhance your plan:

Evaluate opportunities to incorporate sector-based targets, especially for high priority sectors (e.g., the largest sources of emission). In addition, grantees may use this section to discuss how GHG reduction targets were developed and identified.

• Do existing Tribal or Territorial goals, policies, or programs for emission reductions specify a target year? Do other regional agencies (i.e., states, MSAs, counties) specify a target year?

• What sectors and sources are responsible for the largest or fastest growing emissions in the grantees’ jurisdiction? How quickly can these trends be realistically shifted?

• What target years present an appropriate balance of accountability, achievability, and ambition?

• If data are collected only at certain intervals, will data be available for the target year?

If consistent with local planning practices and existing targets, the EPA recommends 2030 and 2050 target years to promote consistency among grantees.

When selecting emission reduction percentages (both economy-wide and by sector), consider:

• Do existing Tribal or Territorial goals, policies, or programs for emission reductions specify reduction percentages? Do other regional agencies (i.e., states, MSAs, counties) specify reduction percentages?

• What analyses, tools or models are accessible or available for creating new targets or refining existing ones?

• Which emission sources have the largest potential for reduction? How much additional CO2e can be reduced to meet economy-wide targets?

• How do the reduction percentages balance technical and economic feasibility with science-based reduction trajectories?

The United States has committed to reduce GHG emissions 50-52% relative to 2005 levels by 2030 and to reach net-zero GHG emissions by 2050.1 Grantees are not required to adopt targets identical to the US commitments and may develop consistent, independent targets that account for climate science, technical and economic feasibility, mitigation priorities, and other factors. Tribes and Territories with existing GHG reduction targets may use their existing targets, but are encouraged to update, modify, or expand those targets as appropriate.

5 BAU GHG Emission Projections GHG emission projection methods vary in scope and certainty. This section must at minimum include:

• Short-term projections (e.g., 2030) under a “business as usual” (BAU) scenario.

• Long-term projections (e.g., 2050) under a BAU scenario.

Note that emission projections under a CCAP implementation scenario are also required—this information may be presented here alongside the BAU projections and/or at the beginning of Section 6, which describes the GHG reduction measures that comprise the CCAP implementation scenario.

Grantees may include BAU projections at time horizons consistent with the near- and long-term target years (e.g., 2030 and 2050). Grantees are required to provide projections at the economy-wide level and are encouraged to include a breakdown of sector-specific GHG projections.

1 https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/22/fact-sheet-president-biden-sets- 2030-greenhouse-gas-pollution-reduction-target-aimed-at-creating-good-paying-union-jobs-and-securing-u-s-leadership-on-clean-energy-technologies/ https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/22/fact-sheet-president-biden-sets-2030-greenhouse-gas-pollution-reduction-target-aimed-at-creating-good-paying-union-jobs-and-securing-u-s-leadership-on-clean-energy-technologies/ https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/22/fact-sheet-president-biden-sets-2030-greenhouse-gas-pollution-reduction-target-aimed-at-creating-good-paying-union-jobs-and-securing-u-s-leadership-on-clean-energy-technologies/ https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/22/fact-sheet-president-biden-sets-2030-greenhouse-gas-pollution-reduction-target-aimed-at-creating-good-paying-union-jobs-and-securing-u-s-leadership-on-clean-energy-technologies/

5.1 BAU Projections Methodologies

Describe the methods used to develop projected GHG emissions. They may include:

• A description of tools or processes used for BAU emission projections for each sector.

• Method limitations or uncertainties.

• GWP selection (e.g., 100-year time horizon from the AR5).

• Data sources, including where and how proxying or scaling of data are used.

• A summary of key assumptions included in the BAU scenario, such as market changes or policies that will occur without any new interventions from grantees.

A discussion of methods may also be included in the CCAP appendix.

5.2 BAU Projections Results

The projected GHG emissions may be shown through the following tables or figures.

• Gross and net emissions GHG emissions in the short- and long-term, by sector and overall. The

EPA recommends the use of the years 2030 and 2050, but grantees may choose the years that are best suited to their reduction targets.

o Grantees may also elect to show percent changes in emissions over time and as compared to a GHG target base year.

o Report emissions at incremental steps (e.g. annually or every five years).

• GHG emissions over time compared to emissions required to meet mitigation targets.

Grantees may choose to organize this information in table format such as that seen in

Table 3, which may also be expanded to show interim projection years. Grantees may repeat the format of

Table 3 to report emission projections for hazardous air pollutants (HAPs) and criteria air pollutants

(CAPs). Grantees may opt to include sub-sector emission sources as seen in Table 11.

Table 3. BAU projections by sector

Base Year Emissions (MT CO2e)

Most Recent Inventory Year Emissions (MT CO2e)

Short-Term BAU Projection Year (e.g., 2030) (MT CO2e)

Long-Term BAU Projection Year (e.g., 2050) (MT CO2e)

Industry

Agriculture

6 GHG Emission Reduction Measures and Implementation Scenario

Projections

6.1 GHG Emission Reduction Measures Summary

Grantees may use this section to summarize the suite of proposed emission reduction measures and their quantified emission reductions (i.e., a CCAP implementation scenario projection). Grantees may choose to organize key information about measures in a summary table organized by sector (see Text Box 4);

additional information may be added to this table (e.g., GHG reductions as compared to a base year or

BAU, costs), or this information may be presented in a different format. Grantees may choose to provide a summary of measures in text and/or using visual aids. If certain measures apply to certain sectors, sub-regions, or sub-groups, identify them in the measure summary and/or within the measure description.

Text Box 4. Example measure summary by sector

The measures presented above are examples for illustrative purposes and do not indicate a required number or type of measure.

6.2 Implementation Scenario Projections

Grantees may provide a summary of quantified emission reductions from the measures displayed as a

CCAP implementation scenario. If preferrable, grantees may elect to combine this section with Section

6.1 above. Tables or figures that may be useful include:

• Gross and net GHG emissions in million metric tons CO2e through short- and long-term projection years (e.g., by 2030 and 2050), by sector and economy-wide, to meet GHG emission reduction targets (see Table 4).

• Projected implementation scenario GHG emissions trajectories compared to the BAU scenario

(see Figure 1)

• Emissions per capita (or other normalization metrics) over time.

When presenting implementation scenario GHG emission reductions, grantees can show reductions compared to BAU emissions in a given year and/or as compared to the goal base year. Grantees must be clear about what the GHG reductions represent. Grantees may consider presenting summary information in this section for HAPs and CAPs as well. Grantees may consider using smaller or larger units as needed depending on the magnitude of emissions by measure with all units and years clearly labeled in each table.

Measure Sector

Measure 1: Implement a pilot program to install geothermal heat pumps in existing single- and multi-family homes.

Commercial and Residential Buildings

Measure 2: Replace and retrofit older, inefficient boat motors with more energy efficient, electric, and hybrid electric models or parts.

Transportation

Measure 3: Implement forest and wetland conservation and restoration projects to sequester carbon.

Natural and Working Lands

Figure 1. Example graphic to compare BAU projections and implementation scenario emissions

Table 4. Implementation scenario emissions by sector

6.3 GHG Emission Reduction Measures

The CCAP must describe a suite of GHG emission reduction measures to meet the reduction targets outlined in Section 4. A measure is a specific, tangible action that will reduce emissions. Measures must

Sector Base Year Emissions (MT CO2e)

Most Recent Inventory Year Emissions (MT CO2e)

Short-Term Implementation Scenario Year (e.g., 2030) (MT CO2e)

Long-Term Implementation Scenario Year (e.g., 2050) (MT CO2e)

Industry

Agriculture be quantifiable actions with clear responsible parties. While measures may help grantees achieve emission reduction goals, they must not describe goals alone (e.g., “reduce transportation emissions by

50%” is not an appropriate measure). Rather, measures must describe the necessary actions to achieve those emission reduction goals.

Measures must be described in complete sentences and organized by sector. Where measures may affect emissions in multiple sectors, grantees may select the most appropriate place to present the measure within the CCAP. Throughout the CCAP, grantees must refer to specific measures consistently to avoid confusion – measure identifiers (e.g., Measure 1) may be used. To the extent feasible, the CCAP must include measures that address each sector: electricity generation and/or use, transportation, commercial and residential buildings, industry, agriculture, natural and working lands, and waste and materials management. Grantees may omit measures for sectors where they have minimal emissions or limited authority, in which case they should explain the rationale for the omission. Measures may be presented by sector within this section (e.g., Sector 1 is Transportation).

Text Box 5. Enhance your plan with measure selection details

Text Box 6. Organizing measures in the CCAP outline

To enhance your plan:

Consider adding additional information discussing how and why these measures were chosen. For example, discuss any unique characteristics of the region that influenced planning (e.g., geography and climate impacts, population demographics and needs, ease of implementation, etc.).

Organizing Measures in this CCAP Outline:

Section 6.3.1 demonstrates one approach to organizing required CCAP measure information, in which all required elements are listed under each measure. To use this outline, Section 6.3.1 can be copied and pasted for each measure in the CCAP and then populated with the relevant information for each measure. Grantees may opt to provide this information in table format. Grantees may also wish to “bundle” reduction measures to collectively assess their GHG emission reductions. In some cases, full measure implementation may depend on enabling polices that are challenging to assess on their own (e.g., evaluating the impact of building a new electric vehicle (EV) charging network separate from other actions being taken to encourage EV deployment). Measure bundling may also make sense where a group of related measures in a sector produce like outputs that are most reasonably summed and evaluated together (e.g., modeling the GHG impacts of a suite of energy efficiency measures that reduce electricity demand from buildings.)

Please note, grantees are not required to follow the outline structure in Section 6.3.1 and may choose to organize CCAPs by element (e.g., “Quantified emission reductions” as a header with each measure’s quantification included). Grantees may also choose to organize information in a series of tables to ensure that each measure is consistently accounted for under each heading. For an example of how measures can be summarized as a group for each CCAP element, refer to the PCAP Guidance Outline for Tribes and Territories.

https://www.epa.gov/system/files/documents/2024-02/draft-pcap-guidance-outline-for-tribes-and-territories_508compliant.pdf https://www.epa.gov/system/files/documents/2024-02/draft-pcap-guidance-outline-for-tribes-and-territories_508compliant.pdf

6.3.1 Sector 1 Measures (repeat sections as needed for each sector) Measures can be organized by sector (e.g., transportation) to align discussion around similar GHG modeling approaches, co-benefits, authority to implement, and benefits, among other measure elements. Grantees may copy and paste this structure to repeat for each economic sector. Grantees may choose to organize key information about measures in a summary table (e.g., Table 5).

Table 5. Measure summary table for Sector 1

Measure 1 (repeat sections as needed for each measure)

The following headings provide an organizational structure for required measure-level information. Grantees may copy and paste this structure to repeat for each measure within each sector. Grantees may also choose to summarize measure information in a table format (e.g., Table 12) as presented in

Part 3 of this document.

Description

Describe the proposed measure in detail, including:

• A short qualitative description of the measure.

• Expected geographic location and geographic scope.

Implementation Authority and Responsibilities

Provide a description of:

• Specific entities (e.g., tribal governments, leadership, third party stakeholders) with the authority to implement proposed GHG reduction measures (see Text

Box 7).

o If additional authority is required, describe the anticipated process to acquire that authority from key entities (e.g., administrative agency, tribal council).

• Critical implementation roles for specific grantees or other organizations based on actual or anticipated authority to implement (see Text Box 8).

Annual GHG emissions reduced in 2030*:

X MTCO2e

Annual GHG emissions reduced in 2050*:

X MTCO2e

Annual CAP or HAP emissions reduced in 2030*:

X [unit]

Annual CAP or HAP emissions reduced in 2050*:

X [unit]

Cost:

$X (include notes on what the cost represents, such as a net present value, capital costs, etc.)

*Emission reductions from measure implementation as compared to BAU.

Sector 1 Measure Summary GHG Emission Reductions in 2030 Compared to the BAU (MTCO2e)

GHG Emission Reductions in 2050 Compared to the BAU (MTCO2e)

Measure 1

Measure 2

Measure 3

Text Box 7. Example confirming authority to implement

Text Box 8. Example plan for obtaining authority to implement

Implementation Timelines and Milestones

Describe plans for implementing the measure:

• An implementation schedule for project completion (e.g., specific dates, quarters, calendar years, or approximate timeframes for completing key milestones).

• Key milestones must include obtaining implementation authority as appropriate.

Metrics for Tracking Progress

For each measure, provide metrics for tracking progress and any systems for tracking these metrics.

Metrics must be measurable indicators that provide transparent ways to track progress of measure implementation. Grantees may consider the following when selecting metrics:

• Is data or information currently collected to support metric tracking? If not, can this data or information be effectively collected year over year?

• Who or what organization owns or collects the data or information to track progress of measure implementation? Do any data sharing agreements or arrangements need to be established to ensure that data or information needed will be available long-term?

• What data and information will resonate the most with different stakeholders?

Quantified GHG Emission Reductions

Present projected GHG emission reductions (or enhancement of carbon sinks) from identified measures to the extent possible:

• A brief description of quantification methods, including assumptions and tools or methods used.

Authority to Implement Measure 1: Accelerate the transition to EVs through a rebate program, government fleet electrification, and installation of Level 2 EV chargers.

A U.S. Territory retains the authority to update its EV infrastructure (i.e., electrifying its fleet, installing charging stations, etc.) as granted by the Executive Office of the U.S. Territory Government.

Authority to Implement Measure 2: Implement energy efficiency and full electrification services for tribal housing units.

Per section Article VII of the Constitution of the Wampanoag Tribe of Gay Head (Aquinnah), “the

Tribal Council shall manage, control and administer the affairs of the Tribe and determine its policies and procedures.” However, of the 33 Tribal Housing units, five are privately owned. The Tribe will require permission from these five owners to conduct energy efficiency and electrification work at those properties. Deployment of solar and battery storage requires approval from the Land Use

Commission, the Tribal Historic Preservation department where applicable, and the Tribal Council. In addition to the required intra-Tribal authority, the Tribe must also receive approval to interconnect solar and battery storage projects and comply with local and state building and electrical codes.

• Separate GHG emission reduction estimates assessed at time horizons consistent with the near-and long-term target years (e.g., 2030 and 2050) as compared to a BAU year and/or to a specific base year (e.g., the GHG target base year).

• If emission reductions are bundled due to the collective impacts of multiple measures, note which measures were quantified together. For example, if there are three energy efficiency measures that cumulatively save 10,000 MWh per year, the emission reductions can be bundled together to simplify emission reductions modeling.

Grantees may choose to organize results as a table (e.g., Table 6) or may present results in a text box

(see example on page 13). Grantees do not need to present emission reduction data in two formats; the

EPA is providing two example presentation options and grantees may elect to use one of these or a similar presentation approach for GHG, CAP or HAP reductions.

Table 6. Measure 1 quantified emission reductions as compared to BAU emissions (MT CO2e)

Measure Costs

For each measure, present measure implementation costs. Describe what presented costs represent and include a brief description of data and methods used to estimate costs. Grantees may tailor information presented to meet their needs, including using available supporting data, considering stakeholder interests, or analyzing costs or savings required to secure funding or move measures forward in implementation. Costs may be presented as: net present value; capital costs, operating and maintenance costs, and savings; program or policy implementation/administration costs; or other appropriate metrics determined by the grantee.

Intersection with Other Funding Availability

Grantees must identify funding sources for each measure, if relevant:

• Federal or other funding opportunities which would support implementation of the CCAP measures including the name of the funding source (e.g., federal, state, utility), the amount of funding requested, and the status of the request (e.g., pending, requested, or secured). Note, some funding sources may cover multiple measures.

Text Box 9 and Text Box 10 below address optional measure-level analyses that align with CCAP elements separately required at the plan or jurisdictional level. Grantees may include the optional measure-level analyses as a substitute for a plan-level analysis or adopt a hybrid approach that provides certain high-priority measures in detail but retains a plan-wide analysis for the remaining measures.

Measure 2025 2030 2050

Measure 1 Emission Reductions

Text Box 9. Enhance your plan with a benefits analysis by measure

Text Box 10. Enhance your plan with workforce analysis by measure

7 Benefits Analysis Grantees are required to include a benefits analysis for the suite of measures included in the CCAP. If grantees analyze and present benefits at the measure level in line with the plan enhancement option presented in Section 6, they must also provide plan-level quantification (see the first bullet in the list below) and may use this section to do so. They may also use this section to summarize the measure-level results and/or discuss other benefits that were not analyzed at the measure level. Grantees must include:

• Quantified estimates of co-pollutant reductions (e.g., PM2.5, NOx, SO2, VOCs, air toxics, etc.)

associated with the proposed suite of GHG reduction measures. Grantees should specify the base year estimates of each co-pollutant, including criteria pollutants (and/or precursors), air toxics, or hazardous air pollutants. Grantees may not have access to specific Tribal or Territory data for co-pollutants but can meet minimum requirements by using the EPA’s National Emissions

Inventory to source data for any counties that overlap Tribal jurisdictions.

• The methods or tools used to complete the calculations above (this may be included in a technical appendix). Tools and models that may help inform the CCAP benefits analysis may include AVERT, GLIMPSE, COBRA, BenMAP, ESIST, or RIMS-II. For more information on how to conduct this analysis, see the CPRG Tools and Technical Assistance page on Benefits Analysis.

• Discussion of any potential disbenefits associated with the suite of GHG reduction measures.

To enhance your plan: Benefits Analysis

Grantees may choose to report benefits by measure. For each measure, report:

• A quantitative benefits analysis that includes estimates of measure co-pollutant reductions

(e.g., PM2.5, NOx, SO2, VOCs, air toxics, etc.) at time horizons consistent with the near- and long-term GHG target years.

• A brief description of quantification methods, including any assumptions.

• Any potential disbenefits and how they will be minimized or mitigated.

• If applicable, an analysis (qualitative or quantitative) of other benefits (such as co-pollutant reductions, increased climate resilience, improved access to services and amenities, jobs created and workforce development, and decreased energy costs).

To enhance your plan: Workforce Analysis

Grantees may provide a workforce analysis by measure, identifying the following:

• Whether the community’s existing workforce is sufficient to implement the measure.

• Solutions to address any worker shortages, including job training for currently unskilled workers.

• Any partnerships that can help address workforce challenges.

• Estimates of the number of jobs the measure will create.

https://www.epa.gov/avert/avert-overview-0 https://www.epa.gov/air-research/glimpse-computational-framework-supporting-state-level-environmental-and-energy https://www.epa.gov/cobra https://www.epa.gov/benmap https://www.epa.gov/statelocalenergy/energy-savings-and-impacts-scenario-tool-esist https://www.bea.gov/resources/methodologies/RIMSII-user-guide https://www.epa.gov/inflation-reduction-act/cprg-tools-and-technical-assistance-benefits-analysis#:~:text=The%20Benefits%20Analysis%20element%20of%20climate%20action%20plans,and%20greenhouse%20gas%20%28GHG%29%20reduction%20goals%20are%20met.

See Text Box 11 for an expansive benefits framework with sample metrics. Note that grantees are encouraged to tailor this table to their CCAP measures and discuss co-benefits associated with the GHG reduction measures, such as improved public health outcomes, economic benefits, increased climate resilience, or other environmental benefits. In addition, grantees may consider presenting benefits by measure in a table (see Text Box 12 as an example).

Text Box 11. Example framework for evaluating benefits and disbenefits

Benefit Category

Benefits and Disbenefits Example Metrics

Jobs and Workforce Development

• Educational and training opportunities

• Employment opportunities and access to jobs

• Number of people participating in clean energy job training programs or apprenticeship programs

• Number of jobs created or lost

• Average wage of new jobs created

Public and Community Health

• Exposure to environmental hazards and/or pollution

• Access to amenities that affect physical and mental health

• Expected reductions of GHGs, criteria air pollutants and toxic air pollutants

• Area of green space created for urban heat island mitigation

Energy Cost Burden and Security

• Increased or decreased energy burden • Change in annual energy costs

• Change in annual energy consumption per square foot

Climate Resilience

• Improved grid resilience

• Improved community infrastructure

• Number of power outages

• Number of utilities shut offs

Housing Availability and Quality

• Housing burden, particularly for renters

• Displacement caused by new projects, and/or increased property values

• Average housing cost

• Number of available units for rent or purchase, or affordable housing units

• Average rate of annual price increase per unit

• Number of units with annual rate or price over the rate of inflation

Transportation Access and Costs

• Reliability and accessibility of transit options

• Lowered transportation burden

• Increased access to electrified transit

• Estimated change in transit costs

• Reductions in travel time for non-vehicular mobility alternatives

Community Engagement and Awareness

• Participation in solution and project design

• Number of stakeholder event and/or dollars spent to engage with organizations and residents

• Number of Tribal priorities addressed by new projects

Text Box 12: Example benefits summary by measure table

Note: Example measures with potential direct benefits are denoted in blue; measures with potential indirect benefits are denoted in green. This summary table is just a visual representation of benefits, to be expanded upon within surrounding text. Grantees should alter headings as needed.

8 Workforce Planning Analysis Grantees are required to provide an analysis of workforce development activities needed to implement measures included in the CCAP. Grantees may use this section to identify skilled labor shortages, impacts on existing jobs and industries, opportunities for the creation of high-quality jobs in disadvantaged communities, and expanding economic opportunities to underserved workers through activities in the plan. Grantees are encouraged to describe how activities or policies will lead to the creation of high-quality jobs in alignment with the U.S. Department of Labor’s Good Job Principles.