Greenhouse Gas Reduction Fund

“The days of ‘throwing gold bars off the Titanic’ are over. The well documented instances of self-dealing and conflicts of interest, unqualified recipients, and intentionally reduced agency oversight pose unacceptable risk. EPA will be an exceptional steward of taxpayer dollars dedicated to our core mission of protecting human health and the environment, not a frivolous spender in the name of ‘climate equity.’”

- EPA Administrator Zeldin

President Donald J. Trump signed the Working Families Tax Cut into law on July 4, 2025, which repealed Section 134 of the Clean Air Act and rescinded the funding for the Greenhouse Gas Reduction Fund (GGRF).  

Earlier in the year, on March 11, 2025, EPA Administrator Zeldin terminated $20 billion in GGRF funding that was awarded to eight National Clean Investment Fund and Clean Communities Investment Accelerator entities as serious concerns were raised regarding self-dealing and conflicts of interest, unqualified recipients, and reduced government oversight. 

On August 7, 2025, Administrator Zeldin announced the agency will no longer be implementing the $7 billion Solar for All program to remain aligned with Congressional intent. The Working Families Tax Cut repealed EPA’s authority to administer the program and rescinded all remaining funds.

The Greenhouse Gas Reduction Fund

The $27 billion Greenhouse Gas Reduction Fund was created through President Joe Biden’s Inflation Reduction Act, which passed both chambers of Congress in 2022 without any bipartisan support. GGRF is comprised of three programs: the National Clean Investment Fund, Clean Communities Investment Accelerator, and Solar for All. All of these programs were designed to shell out billions of taxpayer dollars to passthrough entities.

Self-Dealing and Conflicts of Interest

On December 3, 2024, a video from Project Veritas circulated of a former Biden Administration EPA political appointee boasting that “it’s like we’re on the Titanic and we’re throwing gold bars off the edge.”  

  • The video highlighted the need to get the money out the door as fast as possible before the Trump Administration was sworn in. “Now it’s how to get the money out as fast as possible before they [Trump Administration] come in...”  
  • “Over the last year, we’ve given out $50 billion dollars for climate things…so to go work for one of these places would be really cool.”  
  • “We gave them [nonprofits] the money because… it was an insurance policy against Trump winning. Because they aren’t [a government agency], they’re safer from Republicans taking the money away.” 

Read more below about the apparent self-dealing and conflicts of interest of the eight pass-through, Non-Governmental Organizations (NGOs) selected as the prime recipients of $20 billion in taxpayer funding.

National Clean Investment Fund Grantees 

Climate United Fund: $6,970,000,000 

  • The players:  
    • Climate United Fund’s CEO served as a special assistant in the Office of Management and Budget during the Obama-Biden Administration.  
    • Climate United Fund’s Chief Strategy Officer served as a strategic advisor to the Department of Energy during the last two years of the Biden-Harris Administration. 
    • A Climate United Fund board member was appointed to the Treasury Department’s community development advisory board by President Biden. 
    • Another Climate United Fund board member served as the U.S. Secretary of Transportation in the Obama-Biden Administration. 

Coalition for Green Capital: $5,000,000,000 

  • The players: 
    • A Biden-Harris Administration climate advisor previously served on the board of the Coalition for Green Capital and rejoined the board in 2023 while the organization was applying for GGRF funding.  
    • Coalition for Green Capital’s CEO served as a senior advisor to the Obama-Biden Administration Department of Energy and as New York Governor Andrew Cuomo’s “energy czar.” 
    • Coalition for Green Capital’s Policy Director until 2021 left CGC to work at President Biden’s Climate Policy Office on GGRF implementation and later as a political appointee at EPA. 
    • A Coalition for Green Capital board member served as senior director for environmental justice at the Council on Environmental Quality in the Biden-Harris White House. 

Power Forward Communities: $2,000,000,000 

  • The players:  
    • Power Forward Communities’ CEO served as CEO of Fannie Mae during the Obama-Biden Administration.   
    • The Vice Chair of Enterprise Community Partners, an arm of Power Forward Communities, worked in the Obama-Biden Administration.  
    • The founder and co-chair of Power Forward Communities worked in the Obama-Biden Administration.  
    • CEO and president of Enterprise Community Partners served in the Obama-Biden Administration as the U.S. Housing and Urban Development Secretary in addition to the Office of Management and Budget Director. 

Unqualified Recipients

Comments from the panel of government career staffers during the application review process highlighted concerns over handing billions of American tax dollars to these groups in addition to the lack of financial background to handle such large sums of money. 

Unlike other EPA grant recipients, GGRF recipients had requirements baked into their grant agreements to take a training entitled, “How to Develop a Budget.” Grantees were encouraged to start drawing down funds in the first 21 days, even though they were given 90 days to complete the training to learn how to create a budget.  

Examples of NGOs Lacking Financial Experience

  • The Coalition for Green Capital had only expended $1.42 million in 2023 before receiving a $5 billion award from EPA. 
  • Power Forward Communities had reported a total of $100 for both “total revenue” and “net assets” in its 2023 tax return – the year before receiving a $2 billion grant from EPA. 

Comments on Applications 

Climate United Fund 

  • Two separate reviewers noted that “exec comp seems high,” and that the large budget could “add risk to a federal award.”  
  • Dedicated 2.2% of its budget to “market predevelopment,” about which an employee needed “additional clarity.”   
  • One federal employee wrote that “these numbers don’t make sense” in response to Climate United Fund’s plan to decarbonize homes. 

Coalition for Green Capital 

  • Reviewers flagged that its “FY2022 and 2021 financials show a net loss with declining fees for service income.”  
  • “Of the 71 expected hires, more than 20% would be making salaries more than approximately $450,000.”  
  • The organization’s “assumption of deploying $10 billion in the first fiscal year of performance seems unattainable,” another federal employee noted.  
  • “Ambitious assumptions around deployment call into question the risks being modeled by the lead applicant. It stands to reason that the accelerated deployment of capital well beyond what has been seen historically would result in losses well beyond what has been recorded historically,” the reviewer continued, noting that Coalition for Green Capital did not address this issue in its application materials.   

Power Forward Communities 

  • “The salary structure for top officers seems high for a nonprofit – or rather high enough that it merits some explanation,” one reviewer wrote. “[I’m] wondering if this could be a problem with public perception,” they continued.  
  • “For such an important section, it was pithy, though not always in a good way. Many of the costs were just presented, but little or no explanation as to why they are reasonable. I would have preferred they omitted the travel discussion and explained why they need to pay the CEO $800,000, growing to $948,000 in year 7. And chief operation officer $455,000 per year.”  
  • Another reviewer wrote that “executive salaries appear excessive,” adding that the amount did “not seem appropriate for federal funds.” Another added that “senior management salaries are seemingly high without justification.”  
  • Twenty-two of the Power Forward Communities employees were slated to earn more than $150,000.  
  • Reviewers also criticized the nonprofit for its lack of planning for “proactive oversight.”  
  • Reviewers repeatedly listed Power Forward Communities’ partnership with United Way and Habitat for Humanity as a strength of its application, but both of the organizations later pulled out of the coalition.   

Appalachian Community Capital 

  • Two reviewers noted a lack of experience in their comments, saying “the amount of money managed under previous agreements was much less than what is being proposed under this grant opportunity.”   
  • A reviewer also noted that Appalachian Community Capital planned to use $215 million to finance 600 zero-emission vehicles and $105 million to finance 700 charging stations. “This is $358,333 per EV vehicle,” the reviewer wrote, adding that $150,000 per charging station “seems too high.” 

Reduced Agency Oversight 

The Biden-Harris Administration’s unprecedented choice to use a financial agent for EPA grants deprives the government of immediate control over money held in accounts at Citibank. EPA’s use of a financial agent in connection with the GGRF program was the first use of a financial agent for a nonexchange grant program administered by the federal government.   

EPA lacks sufficient oversight and transparency into the use of grant funding because every single grant recipient acts as a pass-through for subrecipients, many of which are themselves pass-throughs, and EPA is not a party to agreements with the subrecipients.  

Modifications and amendments to the grant agreements that took place after the 2024 election appear intentionally designed to reduce EPA’s oversight and control over grant funding.  

Citing deeply concerning matters of financial mismanagement, conflicts of interest, and oversight failures within the program, EPA’s Acting Deputy Administrator formally referred GGRF to the Office of Inspector General. 

EPA’s OIG has initiated an investigation into the GGRF program, and the agency is cooperating fully in that investigation, which remains outgoing. 

Following the referral letter, EPA initiated further efforts to increase agency oversight including a letter requesting information from the eight recipients of the $20 billion for the National Clean Investment Fund and Clean Communities Investment Accelerator. 

IG Testimony 

September 2024

  • Former EPA Inspector General Sean O’Donnell testified to the House Energy and Commerce Subcommittee on Environment, Manufacturing, and Critical Materials that EPA’s “pace of spending” GGRF funds “escalates not only the risk for fraud but also the urgency for oversight.” He testified that EPA’s OIG “would need to hire oversight professional[s] with specialized expertise” to conduct sufficient oversight regarding the NCIF grants in particular, not only to “preven[t] waste, fraud, and abuse, but also [to] ensur[e] that IRA funds deliver the real environmental and human health benefits that the public is paying for.” 

February 2025

  • Acting Inspector General Nicole Murley testified to the House Subcommittee on Oversight and Investigations that EPA was “particularly concerned about” the GGRF program, including apprehension that the grant “structure makes providing effective oversight challenging,” and that EPA is “concerned that there will be critical gaps in monitoring, accountability, and compliance in the GGRF.” 

Solar for All  

"One of the more shocking features of Solar for All was with regards to the massive dilution of the money as many grants go through pass-through after pass-through after pass-through after pass-through, with all of the middlemen taking their own cut—at least 15% by conservative estimates. What a grift!

"Furthermore, the Biden-Harris Administration exempted this program from the Build America, Buy America law that requires federal agencies to use American workers, American products, and American infrastructure for projects using American taxpayer dollars. That’s great news for China, not so much for the USA.

"Lastly, while this program was stood up in 2024, very little money has actually been spent. Recipients are still very much in the early planning phase, not the building and construction process.

"But the bottom line again is this: EPA no longer has the authority to administer the program or the appropriated funds to keep this boondoggle alive.

"With clear language and intent from Congress in the One Big Beautiful Bill, EPA is taking action to end this program for good. We are committed to the rule of law and being a good steward of taxpayer dollars." 

Timeline

August 16, 2022

  • Inflation Reduction Act of 2022 signed into law by President Biden.

April 1, 2024

  • EPA announces 8 entities selected to receive National Clean Investment Fund (NCIF) and Clean Communities Investment Accelerator (CCIA) grants.  

August 8, 2024

  • EPA issues grant agreements to selected entities directing and encouraging them to start drawing down funds in 21 days and then giving 90 days to complete training entitled, “How to Develop a Budget.” 

September 19, 2024 

  • U.S. Department of Treasury entered into an agreement with Citibank to serve as financial agent for the funds for NCIF and CCIA grantees. EPA is not party to the Financial Agency Agreement.  

August 13, 2020 – October 1, 2024

  • EPA General Terms and Conditions for grant agreements: “EPA may unilaterally terminate [the] award in whole or in part: (a) If a recipient fails to comply with the terms and conditions of the award including statutory or regulatory requirements; or (b) if the award no longer effectuates the program goals or agency priorities.” 

October 1, 2024

  • Change to EPA General Terms and Conditions for grant agreements: Situations “in which EPA may terminate an award under this provision include when” EPA “obtains new evidence that was not considered in making the award” that brings the award’s effectiveness or feasibility into question or when “EPA determines that the objectives of the award are no longer consistent with funding priorities for achieving program goals.” 

November 1, 2024

  • EPA, Citibank, and GGRF grantees entered into an Account Control Agreement for the funds held at Citibank. The Grant Agreement authorized grantees to withdraw funds without prior EPA approval.

November 5, 2024

  • President Trump wins Presidential Election.

December 3, 2024

  • Project Veritas “Tossing Gold Bars Off the Titanic" video released highlighting the need to get the money out the door as fast as possible before the Trump Administration is sworn in.

December 20, 2024

  • EPA issued amended grant agreements that revised compliance and termination provisions and defined contractual terms, including “waste, fraud, and abuse.”

January 13, 2025

  • EPA, Citibank, and a grantee signed an amendment to the Account Control Agreement. 

January 16, 2025

  • Nebraska Senator Pete Ricketts asked Administrator Zeldin at his confirmation hearing “how some of these dollars were being distributed” and secured a commitment that EPA would “look into this to make sure those dollars were spent appropriately” and to “claw back those taxpayer dollars.” 

March 2, 2025

  • EPA referred its findings on financial mismanagement, conflicts of interest, and oversight failures within the GGRF program to EPA’s Office of the Inspector General for further investigation. 

March 11, 2025

  • EPA terminated the Grant Agreement with NCIF and CCIA entities by sending a Notice of Termination to the Agency’s contact of record for the grant. The termination was based on substantial concerns regarding program integrity, the award process, and programmatic waste and abuse. 

July 4, 2025

  • President Trump signs the Working Families Tax Cut into law repealing and rescinding funding for the GGRF.  

In the News

In the Courts

“While the Biden EPA touted ‘tossing Gold Bars off the Titanic,’ these terminated grants, riddled with self-dealing and wasteful spending, are now frozen by court order. The Biden EPA handed politically connected and inexperienced nongovernmental organizations tens of billions in taxpayer funding in a manner that deliberately reduced the ability of EPA to conduct proper oversight. I will not rest until these hard-earned taxpayer dollars are returned to the U.S. Treasury. Every penny EPA spends will go towards our core mission of protecting human health and the environment and Powering the Great American Comeback.”

– EPA Administrator Lee Zeldin

On September 2, 2025, the U.S. Court of Appeals for the District of Columbia Circuit ruled 2-1 in favor of the agency and vacated a district court order preventing EPA from terminating certain grants previously awarded under the Greenhouse Gas Reduction Fund and requiring the agency to make payments pursuant to those grants. The court noted that EPA’s terminations of the grants fell “well within the Executive Branch’s authority and responsibility to manage the expenditure of funds to ensure that money appropriated by Congress is properly spent for its intended purposes.” 

The agency released the following statement: “It’s fantastic to see reason prevail in the court system. EPA has a duty to be an exceptional steward of taxpayer dollars. Administrator Zeldin cancelled these grants due to well documented concerns about self-dealing and conflicts of interest, unqualified recipients, and intentionally reduced agency oversight. The gold bar recipients were wrong about jurisdiction all along and wrong to act so entitled to these precious public funds that belong to hardworking American taxpayers.”   

The opinion states, “We conclude the district court abused its discretion in issuing the injunction. The grantees are not likely to succeed on the merits because their claims are essentially contractual, and therefore jurisdiction lies exclusively in the Court of Federal Claims. And while the district court had jurisdiction over the grantees’ constitutional claim, that claim is meritless. Moreover, the equities strongly favor the government, which on behalf of the public must ensure the proper oversight and management of this multi-billion-dollar fund. Accordingly, we vacate the injunction.” 

  • “The month before President Trump’s inauguration, EPA modified the grant agreements—with no apparent consideration from the grantees—to make it more difficult for the government to terminate the grants.”   
  • “[N]othing in the Inflation Reduction Act prevented EPA from taking care that the grant programs be faithfully executed…. [T]his preliminary injunction … bar[red] EPA from carrying out basic executive functions to ensure the prudent and effective management of substantial public funds.”   
  • “The district court also ignored the government’s evidence of mismanagement of the grant funds, such as the damning ‘gold bars’ video, which further supports EPA’s good faith in deciding to terminate the grants and recommit the funds with proper supervision and accountability.”   
  • “Our jurisdiction, however, rests on law, not on the severity of the alleged wrongdoing claimed by the grantees and reported by The Washington Post, The New York Times, and Politico.”   

Read the full opinion (pdf). 

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Last updated on September 30, 2025