It’s been two years since President Biden signed the Inflation Reduction Act into law. While some have criticized the slow pace of IRA implementation, one key climate provision of the law is already transforming climate action at the state level, particularly for states that  did not previously have a climate action plan.. 

The Climate Pollution Reduction Grants (CPRG) program,  provides funding to states, local governments, tribes, and territories to develop and execute climate action plans. While the program does not require that participants meet the climate commitments outlined in their plans, creating plans requires establishing baseline emissions data, engaging with key stakeholders, and identifying high-potential mitigation areas, all important steps towards realizing meaningful emissions reductions. 

The CPRG is a two-phase program, which consists of  released $250 million in funding for noncompetitive planning grants, and $4.6 billion for competitive implementation grants. 45 states, 16 of which had no existing state climate action plan, opted into the planning grant program, alongside numerous local governments, tribes, and territories. The 16 states that had no existing state climate action plans and opted in were: Alabama, Alaska, Georgia, Idaho, Indiana, Kansas, Mississippi, Missouri, Nebraska, North Dakota, Ohio, Oklahoma, Tennessee, Texas, Utah, and West Virginia. Five states that opted into the program had not released climate action plans in over a decade. Arizona’s most recent plan was in 2006, Arkansas’ in 2008, New Hampshire’s in 2009, South Carolina’s in 2008, and Virginia’s in 2008. 

States completed their first deliverable of the planning grant and submitted Priority Climate Action Plans (PCAPs) in March 2024. In July 2024, implementation grants were selected under the second phase of the CPRG program, to 13 states and 12 other eligible applicants, to implement measures included within relevant Priority Climate Action Plans. 

How excited should we be about 16 states developing an emissions reduction strategy for the first time? How likely are these states to follow through with the priority measures included in their PCAPs? 

To answer these questions, let us first examine the differences between traditional state climate action plans and Priority Climate Action Plans. 

Priority Climate Action Plans cannot be equated to state climate action plans. State climate action plans normally include a range of short- and long-term strategies and may touch on resilience, and economic and social goals, in addition to greenhouse gas reduction. 

Under the CPRG, the U.S. Environmental Protection Agency (EPA) only required the PCAPs to include: a greenhouse gas inventory, priority greenhouse gas reduction measures, low-income and disadvantaged community benefits analysis, and a review of authority to implement the measures. Priority measures had to be implementation-ready, near-term (all funds would be expended within five years), and already within the authority of governing bodies (meaning no new legislation would need to be passed), among other community engagement and emissions reduction requirements. These requirements limited priority measures to a list of ready-to-go actions. Optional elements of the PCAPs included: greenhouse gas reduction targets, wider benefits analyses, a summary of intersection with other federal funding, workforce planning analysis, and next steps. 

The 16 states with no existing climate action plans detailed a range of different measures in their PCAPs. Many states, including North Dakota and Idaho, focused on modest greenhouse gas reduction measures, such as improving energy efficiency in buildings, promoting sustainable agriculture practices, and implementing waste management programs. Some states, such as Indiana and West Virginia, included ambitious measures focused on the industrial and electricity sectors. 

All states that opted into the planning grant program must develop Comprehensive Climate Action Plans (CCAPs) by mid-2025, which will include a broader suite of greenhouse gas reduction measures from all key emitting sectors. These CCAPs will more closely resemble traditional state climate action plans, as the optional elements of the PCAPs listed above will become required, so all states will publish greenhouse gas reduction targets. In addition, the CCAPs will be released after implementation grants are awarded, so they will exist as standalone plans, rather than as resources to help develop implementation grant applications. 

Although the PCAPs do not fully resemble traditional climate action plans, they do lay out a list of easily implementable measures that would meaningfully reduce emissions. So how likely are these 16 states to act on the priority measures included in their Priority Climate Action Plans? The answer to this question depends on whether states received implementation funding, whether alternative funding sources exist to support their measures, and whether state leadership is committed to driving the measures forward. 

Did the 16 states receive CPRG implementation funding to carry out their priority measures? 

Of the 16 states that had never previously released climate action plans, Nebraska and Utah were the only states selected for implementation funding by EPA under the CPRG Implementation Grants General Competition. The Nebraska Department of Environment and Energy will receive $307 million to increase the adoption of climate-smart and precision agriculture and reduce agricultural waste from livestock, in addition to other energy efficiency and electrification projects. The Utah Department of Environmental Quality will receive $74.8 million to focus on transportation, solar power generation, oil and gas methane emissions reduction, and commercial and industrial efficiency upgrades. When implemented, these priority measures are projected to reduce emissions in Nebraska and Utah by 134.4 and 1.4 million metric tons respectively from 2025–2050. 

It is important to note that although the other 14 states were not awarded funding, tribes and municipalities within Texas, Ohio, Arkansas, Idaho, and Alaska were awarded. Some of the municipalities pulled from priority measures included in the statewide Priority Climate Action Plans in their implementation grant applications, so therefore certain priority measures will be implemented, just at a much smaller scale. Some examples are a $129.4 million grant to Cuyahoga County, Ohio, a $47.9 million grant to the City of Austin, Texas, and a $37.3 million grant to the Nez Perce Tribe, in Idaho and Oregon. 

In addition, the Tribes and Territories Only Competition has yet to award funding, which will further enhance climate action across certain states. 

Are there other federal funding options that make priority measure implementation possible without any CPRG implementation funding? 

There are other federal funding options for priority measures outside of the CPRG implementation grants. 

Nonprofits and research centers, such as the Sabin Center for Climate Change Law and ClimateXChange, are urging states that did not receive funding to keep up the momentum to follow through with their priority measures. They point to opportunities for other federal funding, such as the IRA’s Environmental and Climate Justice Community Change Grants, and the Charging and Fueling Infrastructure program under the Infrastructure Investment and Jobs Act. 

Some PCAPs, such as Indiana’s, North Dakota’s and Missouri’s, already include an optional element of EPA’s PCAP criteria: a summary of other federal funding available to support their priority measures. This proactive analysis has set up these states to leverage federal funding in the short term and act on their priority measures, even though they were not awarded funding through the CPRG implementation grants. All states will be required to include federal funding analyses in their CCAPs, which will prove extremely helpful in making the CCAPs into durable, realistic plans, especially in states with limited internal budgets. 

Is state leadership committed to implementing the measures? 

Since the implementation grants were recently selected, states likely have not yet developed plans on how to move priority measures forward without CPRG funding, but state leaders may release comments soon on next steps as they move to develop their CCAPs. 

From reading the PCAPs, there is already some indication about which states  may be leaders in pushing their priority measures forward. While all states were eligible to receive the same planning grant of $3 million, the PCAPs vary in length, detail, and climate action commitment. For example, North Dakota’s plan is 340 pages long (compared, for example, to Kansas’ 62-page plan), demonstrating a diligent effort by the North Dakota Department of Environmental Quality to engage with stakeholders and follow a rigorous methodology. 

Some states demonstrate a commitment to climate action by putting forward priority measures that are difficult to implement but would significantly reduce emissions. As Evergreen Action highlighted in their article written before implementation grants were awarded, Indiana’s implementation grant application focused on industrial pollution, the state’s second largest source of emissions. This shows that Indiana is willing to tackle one of their hardest-to-abate sectors head-on, in addition to a commitment to supporting efficiency and competitiveness in their industrial base. 

Another way that states have shown commitment to climate action is by developing priority measures in partnership with other states. Evergreen Action also noted that Oklahoma submitted a grant application with New Mexico and Arizona for a medium- and heavy-duty freight charging corridor. This demonstrates awareness that the climate crisis will require interstate solutions, and that Oklahoma is willing to engage in those partnerships. 

States had to work quickly to produce PCAPs. The EPA awarded states planning funding in the fall of 2023; they had to submit plans by March 2024, and then implementation grant applications by April 2024. But states have two years to develop and submit their CCAPs and will therefore have time to think realistically and pragmatically about what might be achievable. In addition, the greenhouse gas reduction targets must be included in the comprehensive plans, so states will be encouraged to be ambitious with their measures. States will also be required to submit a status report detailing the implementation status of the greenhouse gas reduction measures included in their CCAPs by mid-2027. The CCAPs will more closely resemble, in purpose and in scope, the independent state climate action plans we saw prior to the CPRG program. However, in states where climate action is politically divisive, additional federal funding will likely be necessary to drive forward implementation, as some states may remain unwilling to funnel limited state funding into climate action. 

Conclusion 

States should be applauded for their diligent work in developing PCAPs, especially if this was their first time developing an emissions reduction strategy. The process of developing CCAPs will be a constructive next step in helping states refine their understanding of diverse mitigation opportunities and helping draw attention to the benefits of climate action. The CPRG program has proven successful in encouraging states across the country to engage in climate action planning, including those without prior climate planning efforts, and it is crucial that the federal government continue to support states in realizing their priority measures. Reaching our climate goals will require action nationwide, and we must ensure that all states are supported along the way. 

See C2ES’ updated climate action plan map at: https://www.c2es.org/document/climate-action-plans 

In the map we have noted which states were awarded implementation grants.