On March 18, 2025, the federal district court for the District of Columbia issued a temporary restraining order (TRO) enjoining the U.S. Environmental Protection Agency (EPA) from taking actions to implement the termination of three nonprofit financial institutions’ (plaintiffs’) grants under the National Clean Investment Fund (NCIF). The TRO also enjoined Citibank from moving or transferring the grant funds. EPA established the NCIF under the Inflation Reduction Act’s Greenhouse Gas Reduction Fund to provide financing for clean technology projects. EPA awarded the grants to the three plaintiffs under the NCIF in April 2024, and the grant funds were disbursed to accounts at Citibank pursuant to agreements between Citibank and the U.S. Department of the Treasury and between Citibank, EPA, and the plaintiffs. After EPA Administrator Lee Zeldin announced on February 12, 2025 that EPA planned to take control of the grant funds, Citibank stopped releasing funds to the plaintiffs. Plaintiff Climate United Fund filed a lawsuit on March 8 and filed a TRO motion two days later. The other two plaintiffs—Coalition for Green Capital and Power Forward Communities, Inc.—filed their lawsuits on March 10 and March 11, respectively. (Their lawsuits were originally filed in the Southern District of New York but were voluntarily withdrawn and refiled in the District of Columbia.) On March 11, EPA sent letters to the plaintiffs advising them that it was terminating the grants effective immediately. In its decision granting the TRO motion, the court rejected the EPA defendants’ argument that jurisdiction for the plaintiffs’ lawsuits challenging the terminations lay with the Court of Federal Claims. The court concluded that the plaintiffs were challenging agency action, not bringing “simple breach of contract claims.” The court also rejected EPA’s contention that the TRO request was moot because EPA terminated the grants after the TRO motion was filed. On the merits of the TRO request, the court found that because it could not find that EPA complied with the required procedures and regulations governing the termination of federal awards, the plaintiffs showed a substantial likelihood of success on the merits. The court also found that the plaintiffs made a sufficient showing of irreparable harm because the plaintiffs were reliant on the grant funds for both day-to-day activities and the financing of projects and would have to cease operations without the funds. In addition, the court concluded that balancing the equities and the public interest supported granting a TRO. The court found that a TRO preserving the status quo would not significantly harm EPA or Citibank and that there was a public interest in ensuring governmental agencies abide by federal laws.

Lawsuits challenging EPA's freezing and purported termination of funding under the Inflation Reduction Act’s Greenhouse Gas Reduction Fund.

Climate United Fund v. Citibank, N.A.

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Federal Court Temporarily Enjoined EPA’s Termination of Greenhouse Gas Reduction Fund Grants

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

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Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

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The management and allocation of funds, assets and investments to meet various objectives

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A loan is a policy instrument where funds are provided to a borrower with the expectation of repaying the principal plus interest.

Financial support to help individuals manage the effects of unexpected events, securing their livelihoods and increasing the resilience of people and businesses to the changing climate. It’s especially vital in developing regions where everyday risks, climate-related weather extremes, or crop failures can push people into poverty. Without insurance, people may have to resort to selling assets or cutting consumption to cope with losses.

Either money or something of monetary value is transferred between two or more organisations, people or countries.

Actions to reduce emissions in energy generation and supply.

Technologies that capture and hold energy in reserve for later use.

Social protection systems consist of policies that help people manage social risks in order to prevent poverty and maintain decent incomes and living standards

Production of electricity and heat from solar irradiation.

Fossil gas, commonly known as natural gas, is a fossil fuel consisting chiefly of methane with smaller amounts of other hydrocarbons and trace gases, found in underground deposits.

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People whose health, both mental and physical, makes them more vulnerable to the effects of climate change

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Federal Court Temporarily Enjoined EPA’s Termination of Greenhouse Gas Reduction Fund Grants

Policy instrument

Impacted group

Just transition

Renewable energy

Fossil fuel

Greenhouse gas

Economic sector

Finance