EPA Climate Pollution Reduction Grants: Compliance Requirements

Planning phase grantees must submit Priority Climate Action Plan (PCAP) and Comprehensive Climate Action Plan (CCAP), plus status reports on schedule. Implementation grantees must submit required progress reports and documentation of GHG reduction achievements.

Deadline: PCAP due March 1, 2024 (states/MSAs) or April 1, 2024 (tribes/territories); CCAP due June 1, 2026; Status report due July 31, 2027

Source: CPRG Planning Grant Guidance; EPA CPRG program guidance

Grantees must expend the requested funding amount over the period of performance (up to 7 years) and must comply with all terms and conditions of the grant agreement, including potential corrective action remedies for violations.

Deadline: Continuous compliance requirement; penalties apply for unexpended funds or violations

Source: CPRG NOFO; 2 CFR 200.208, 200.339, 200.340

A single audit is required when a nonfederal entity expends $750,000 or more of federal award funds in a fiscal year. Audit must comply with 2 CFR Part 200 Subpart F.

Deadline: Audit must be completed and submitted within 9 months of the end of the fiscal year in which funds were expended

Source: 2 CFR 200.501; EPA assistance agreement requirements

All named contractors (including consultants and equipment vendors) with contract amounts exceeding the micro-purchase threshold must be selected in compliance with competitive procurement requirements in 2 CFR Part 200. Sole source justifications are not acceptable for services available in the commercial marketplace.

Deadline: Must be demonstrated and documented prior to contract award

Source: CPRG General Competition NOFO, Section IV; 2 CFR 200.320(a)(1)

If a Quality Assurance Project Plan (QAPP) is required by the award terms and conditions, the recipient must develop and submit it to EPA for approval, typically within 30-90 days of award. Environmental information operations cannot begin until EPA approves the QAPP.

Deadline: Within 30-90 days of award issuance (as specified in award terms and conditions)

Source: EPA environmental assistance agreement terms; EPA Quality Assurance guidance

Recipients must maintain documentation supporting contractor selection decisions and procurement procedures, including how the full and open competition requirements were met.

Deadline: Records must be maintained throughout the award period and available for audit

Source: CPRG General Competition NOFO, Section IV; 2 CFR 200.318-200.326

Proposed GHG reduction measures in implementation grant applications must have been included in the applicable Priority Climate Action Plan (PCAP) submitted to EPA; measures not covered by a PCAP are ineligible.

Deadline: PCAP must be submitted prior to implementation grant application deadline

Source: CPRG Implementation Grants guidance; NOFO Section III.A

Named subrecipients in implementation grant applications must be identified in coalition applications and must meet eligibility requirements in EPA Subaward Policy Appendix A. Failure to demonstrate subrecipient compliance results in application rejection.

Deadline: Must be demonstrated at time of application submission

Source: CPRG General Competition NOFO, Section IV; EPA Subaward Policy