Livable Cities Update: EPA Releases CPRG Status Report Primer

EPA clarifies CPRG Status Report requirements and expectations for grantees.

The U.S. EPA has released a new Status Report Primer for recipients of Climate Pollution Reduction Grants (CPRG) planning funds, confirming that a Status Report is required at the end of the four-year grant period.

The primer outlines EPA’s expectations for the report and offers recommendations on how jurisdictions can structure it and track implementation progress under their Comprehensive Climate Action Plans (CCAPs).

Key Elements Required in the Status Report

Consistent with earlier CPRG guidance, EPA confirms that Status Reports must include updates on several core CCAP elements, plus one additional requirement, including:

Required

  • Implementation status of greenhouse gas (GHG) reduction measures

  • Metrics tracking and quantified results for completed measures

  • Review of authority to implement measures

  • Intersection with other funding opportunities

  • Workforce planning progress

  • Updated benefits analysis

  • Additional Requirement: Identify and outline next steps for CCAP implementation, including near-term projects, timelines, milestones, and associated budget and staffing needs

Encouraged

  • GHG inventory updates

  • GHG emissions projections and reductions

  • Updates to GHG reduction targets

  • Implementation narratives providing additional detail on progress

  • Updated cost analysis

  • Public outreach related to CCAP implementation

These components largely reflect the reporting expectations outlined in the original 2023 CPRG planning grant guidance, which anticipated that the Status Report would provide updates on CCAP implementation and identify next steps.

What’s New in the Primer

While the core requirements remain largely consistent with earlier guidance, the primer provides additional detail on how grantees should approach the report, including:

  • Clarification that updates to GHG inventories and emissions projections are encouraged but optional.

  • The previously required LIDAC benefits analysis is no longer required for the Status Report.

  • Recommended approaches for tracking implementation progress.

  • Grantees must report quantified emissions reductions for fully implemented GHG reduction measures using the metrics in their CCAP. Reporting for partially implemented or under-development measures is encouraged but not required. Grantees are also encouraged to update estimated or actual GHG reductions for any measures as needed.

  • Guidance on updating benefits analysis and co-pollutant reductions

  • Expanded discussion of funding alignment, workforce needs, and implementation barriers

Takeaways and Implications

Implementation tracking will be critical.

The Primer signals that jurisdictions should establish processes to track implementation progress and measurable outcomes throughout the grant period, rather than waiting until the end to compile reporting materials. 

The Status Report is more than a compliance exercise.

EPA emphasizes that the report should be used to communicate progress, adjust priorities, and identify resources needed to sustain climate action beyond the CPRG planning grant period.

Narratives must address progress across all measures. 

Reduction measures will be at varying stages of implementation, making narrative updates essential to clearly communicate progress. All measures must be addressed in the Status Report, including those with limited or no progress, along with explanations and next steps.

Client Alert: CARB Approves Climate Disclosure Regulation

Client Alert: CARB Approves Climate Disclosure Regulation

On February 26, 2026, the California Air Resources Board (CARB) unanimously approved the initial implementing regulation for California’s Corporate Greenhouse Gas Reporting (SB 253) and Climate-Related Financial Risk Disclosure (SB 261) laws.

Read More

Client Alert: CARB Issues Draft Regulations for SB 253 and SB 261 on December 9, 2025

Client Alert: CARB Issues Draft Regulations for SB 253 and SB 261 on December 9, 2025

The California Air Resources Board (CARB) released draft regulations on December 9, 2025, as part of its initial rulemaking to implement California’s corporate climate disclosure laws, SB 253 (greenhouse gas emissions reporting) and SB 261 (climate-related financial risk reporting).

Read More

Client Alert: EU Parliament’s Nov. 13 Vote Slashes Corporate Sustainability Rules

Client Alert: EU Parliament’s Nov. 13 Vote Slashes Corporate Sustainability Rules

The Omnibus package, voted on by the European Parliament on November 13, 2025, makes significant changes to EU sustainability regulations, including the Corporate Sustainability Reporting Directive (CSRD), the Corporate Sustainability Due Diligence Directive (CSDDD), the Taxonomy Regulation, and the Carbon Border Adjustment Mechanism (CBAM). 

Read More

Client Alert: Important Summary Status for EU Omnibus

Client Alert: Important Summary Status for EU Omnibus

As the EU finalizes the Omnibus amendments to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), significant debates remain over company scope, assurance requirements, and the inclusion of Climate Transition Plans. The next Parliament vote is scheduled for November 14, 2025. Learn what these pending changes could mean for your organization’s reporting strategy, materiality assessments, and disclosure obligations.

Read More

The Sustainability Update - Key Market Trends as of Q3 2025

The Sustainability Update - Key Market Trends as of Q3 2025

In our Q3 2025 update, Nick McCreary, Senior Vice President of Sustainability; Emilee O’Neill, Vice President of Livable Cities; and Amber Greaney, Vice President of Sustainability, share the latest regulatory developments, global insights, and innovations shaping sustainability this quarter.

Read More

Client Alert: CARB Delays Climate-Disclosure Rulemaking Timeline to Q1 2026

Client Alert: CARB Delays Climate-Disclosure Rulemaking Timeline to Q1 2026

The California Air Resources Board (CARB) did not issue its expected proposed rulemaking package on October 14, but the agency has since clarified that it plans to bring the initial rulemaking to the Board in Q1 2026. This timing adjustment does not affect statutory reporting deadlines.

Read More

Client Alert: CARB Releases Draft SB 253 Scope 1 & 2 Reporting Template

Client Alert: CARB Releases Draft SB 253 Scope 1 & 2 Reporting Template

The California Air Resources Board (CARB) has released a draft Excel reporting template and accompanying guidance memo to support companies preparing for compliance with SB-253, California’s new corporate climate disclosure law.

Read More

Client Alert: California Publishes Draft List of 4,160 Companies Under Climate Disclosure Laws

Client Alert: California Publishes Draft List of 4,160 Companies Under Climate Disclosure Laws

CARB has released a preliminary list of 4,160 companies potentially subject to California’s SB 253 and SB 261 climate disclosure laws. KERAMIDA breaks down what this means, highlights key considerations, and provides links to the draft list and stakeholder survey.

Read More

Client Alert: EPA Proposes Major Rollback of Greenhouse Gas Reporting Requirements

Client Alert: EPA Proposes Major Rollback of Greenhouse Gas Reporting Requirements

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on September 16, 2025, that would significantly scale back the Greenhouse Gas Reporting Program (GHGRP) under 40 CFR Part 98. Under the proposal, reporting obligations for most industries would be eliminated, while reporting for the petroleum and natural gas sector (subpart W) would be suspended until 2034.

Read More

Client Alert: IFRS S2 Section Update

Client Alert: IFRS S2 Section Update

The International Sustainability Standards Board (ISSB) has issued significant 2025 proposals to expand and refine IFRS S2 climate disclosure requirements. These updates could affect Scope 3 reporting boundaries, industry-specific guidance, and climate transition plan disclosures. Companies should review the changes now to prepare for potential adoption as early as 2026.

Read More