Please note that in lieu of a collective nervous breakdown, L4GG and EPN’s offices will be closed starting at the end of the day this Friday, December 19 through the first week of January. EPN will reopen on Monday, January 5. L4GG will reopen on Tuesday, January 6.
So, for terminated EPA grantees—please review the four time-critical steps listed below and contact us TODAY if you’re approaching your closeout deadline and still need assistance (some deadlines may be as soon as December 27!). It’s critical you contact us now so that our staff can get you answers in the next two days before they take a much-needed break.
We are also excited to share some good news: earlier today the U.S. Court of Appeals for the D.C. Circuit has granted the Greenhouse Gas Reduction Fund (GGRF) awardees’ request for en banc rehearing. This means that the full court will reconsider their appeal after it was previously denied by a panel of three judges. That hearing will take place on February 24, 2026. (We are also thrilled that the judges explicitly referenced L4GG’s amicus brief written for various Members of Congress as part of the reason for the ruling—woo hoo!)
In addition, thank you! We would never have wished this year on anyone, but if we had to go through everything we’ve all gone through, we are so glad we got to do it with YOU. We have learned so much from you, and we are ALL stronger as a result.
And lastly, for our fellow terminated grantees, because of YOUR resilience and diligence:
– YOU are a community of over 600 federal grantees in all 50 states that pushed back against unlawful terminations totaling billions of dollars.
– YOU have gathered virtually and in-person early and often, and over 1,500 of you have joined our Federal Funding Webinars & Office Hours.
– YOU have stayed in close communication with us and each other via our Federal Funding Updates.
– YOU met with over 200 L4GG pro bono attorneys.
– YOU joined L4GG litigation, filing suits that helped you draw down funds and keep fighting.
– And now many of YOU are heading with us to the Court of Federal Claims!
The resistance is strong and growing—thanks to ALL OF YOU and your incredible work.
Four Time-Critical Steps for Terminated Grantees (who have NOT already closed out) to Take Before the End of the Year:
STEP 1. Calculate Your Closeout Date
For all terminated grantees who have NOT already closed out, it is critical that you take a moment to calculate your 120-day closeout deadline ASAP. The 120-day clock should start when your grant is terminated or, if you filed a dispute, when the dispute decision official (DDO) makes a final determination on your termination dispute. For example, if you disputed your termination and the DDO reaffirmed your termination on August 29th, your deadline for closeout would be December 27th. For many, this deadline is approaching or has already passed. Note that some EPA POs have claimed that the closeout deadline is 120 days from the termination, not the DDO letter. We do not agree with this interpretation and are here to help you navigate your situation if you have received this kind of notice from your PO. If you need assistance determining or fighting for your closeout date, please email us at SFA@L4GG.org (for Solar for All grants) or FPC@L4GG.org (all other grants) TODAY (as our offices will be closed by COB Friday.)
STEP 2. Read Our Guidance Brief on Legal Avenues and Closeout Considerations
To help terminated grantees determine their options and decide whether or not to close out (and if so, how), L4GG has created a Guidance Brief (access on our website). While we cannot advise on which pathway is appropriate for your organization, we encourage you to read the entire brief before deciding on your next steps, and email SFA@L4GG.org or FPC@L4GG.org TODAY if you would like to review your options.
STEP 3. Court of Federal Claims Clinic Registration
Recent Supreme Court guidance has shifted the landscape for grant termination disputes, identifying them as contractual matters more appropriately litigated in the U.S. Court of Federal Claims (COFC). L4GG and EPN have launched the COFC clinic, providing free legal assistance for grantees considering bringing a claim.
If you are interested in filing a claim or learning more about COFC, please complete our COFC Clinic intake form (scroll down) at your earliest convenience. Please note that L4GG will be closed from December 20, 2025, through January 6, 2026. That said, you will receive guidance resources automatically when you complete the intake form, which should help you get started.
Additionally, we are currently recommending that if you are nearing or past your 120-day closeout deadline, you may want to consider submitting documents for Closeout with Reservations (see the Guidance brief on Legal Avenues and Closeout Considerations) to protect your right to litigate in the future. Please note that if you choose to Closeout without Reservations, filing a claim in district court or COFC in the future might be very difficult.
Lastly, if you are interested in becoming a pro bono volunteer for the COFC Clinic, please fill out the volunteer form (scroll down).
STEP 4. Compliance and Closeout Support
Even after you decide on your legal path and closeout (or not closeout) plan, you may need assistance staying in compliance or need an extra set of eyes on a draft email or report to the agency. (Yes, even terminated grants have to submit regular reports!) If you have compliance questions, need sample language, or need draft documents or emails reviewed, please email Patricia Kwon at PKwon@trccompanies.com ASAP. She will be checking this email over our winter break, but the sooner you reach out the better!
Webinars/Office Hours:
Grants Management Webinars Restart in January
– Our Biweekly Grantee Assistance Webinar series will continue in January. Keep your eyes out for an email confirmation with these new dates and be sure to add them to your calendar! Webinars/Office Hours will continue to be held on the second and fourth Wednesday of each month from 12:30-2pm EST.
– If you haven’t ever attended one of our grants webinars, please sign up here to get the Zoom links.
– If you have a terminated DOE grant, please complete L4GG’s Intake Form. L4GG is actively supporting numerous DOE grantees.