President Trump has begun his second term of office by issuing numerous new executive orders (EOs), including twenty-six new EOs just on his first day. This included the rescission of nearly eighty Biden administration EOs, many of which had significant impacts on the environmental and energy regulatory landscapes.

This article summarizes President Trump’s notable EOs related to environmental and energy policy and regulation so far. These recent EOs reshape federal policy goals to promote the development of domestic energy resources and energy infrastructure. In general, the Trump administration’s new policy goals are shaped by the declaration of a national energy emergency, directives that prioritize conventional energy production, and the removal of many Biden administration policies geared toward addressing climate change. Here are the top EOs from President Trump’s initial days in office that will shape the federal environmental and energy regulatory landscape in the months to come.

Initial Recissions of Harmful Executive Orders and Actions

This EO functions as the revocation of most of former President Biden’s executive orders on energy, climate change, electric vehicles, and continental shelf oil or natural gas leasing. Many of these previous EOs related to addressing greenhouse gas emissions, promoting non-conventional energy sources, and environmental justice initiatives.

The revocation of many of the Biden administration’s policy goals has the potential to impact federal regulatory priorities and rulemaking related to energy and the environment.

Putting America First in International Environmental Agreements

With this action, the Trump administration indicated that the United States will be withdrawing from the Paris Climate Agreement. Similarly, the new administration intends to withdraw the United States from any other agreements and financial commitments made under UN Framework Convention on Climate Change. This EO also revokes the U.S. International Climate Finance Plan.

Much like the revocation of many of the Biden administration’s EOs, the removal of the United States from these international climate change obligations is geared toward encouraging the development of conventional and domestic energy resources. These actions are likely to reduce some of the recent federal regulatory directives related to curbing greenhouse gas emissions and disincentivizing the use of fossil fuels.

Declaring a National Energy Emergency

To advance many of the new administration’s environmental and energy regulatory goals, a national energy emergency has been declared. This declaration cites inadequate energy infrastructure and high energy prices as a threat to national security.

The term “energy” as used in this EO is defined to mean “crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, the kinetic movement of flowing water, and critical minerals as defined by 30 U.S.C. 1606(a)(3).” Notably, energy, as defined by this EO, does not include solar and wind.

This EO includes the following directives (among others):

• Expediting the completion of all authorized and appropriated infrastructure, energy, environmental, and natural resources projects;
• Using emergency authorities and nationwide permits to grant approvals for energy projects under Clean Water Act  Sec. 404, Rivers and Harbors Act Sec. 10, and Marine Protection Research and Sanctuaries Act Sec. 103;
• Instructions to agencies to expedite infrastructure, energy, environmental, and natural resources projects by facilitating the supply, refining, and transportation of energy in and through the West Coast, Northeast, and Alaska;
• Direction to agency heads to facilitate the development of domestic energy resources on federal lands and through the Defense Production Act.

Unleashing American Energy

This EO specifically promotes the development of domestic energy. The Trump administration has directed the Environmental Protection Agency (EPA), in collaboration with other agencies, to submit recommendations to the Office of Management and Budget “on the legality and continuing applicability” of its 2009 endangerment finding for greenhouse gases under the Clean Air Act (CAA).

The EO directs agencies to review existing regulations that impose an undue burden on the identification, development, or use of domestic energy resources, “with particular attention to oil, natural gas, coal, hydropower, biofuels, critical mineral, and nuclear energy resources.”

This EO includes the following directives (among others):

• A call for the new administration to prepare recommendations for Congress on permitting reform;
• Direction to cabinet secretaries to eliminate permitting delays with general permitting and permitting by rule to expedite projects;
• Federal permitting processes are to adhere only to legislated requirements for environmental considerations;
• Termination of the use of estimates of the social cost of greenhouse gasses by directing the EPA to address deficiencies or rescind the current social cost of carbon methodology, which will impact cost-benefit analyses of new regulations;
• Declaring opposition to state emissions waivers, such as California’s, which develop vehicle emission standards stricter than federal standards.

Unleashing Alaska’s Extraordinary Resource Potential

This more narrowly tailored EO expedites the permitting and leasing of energy and natural resource projects in Alaska.

The Secretary of the Interior has been directed to withdraw orders and policies that prevent the development of energy projects in Alaska. This essentially returns the federal regulatory environment for energy development in Alaska to the first Trump administration’s policies.

Temporary Withdrawal of All Areas on the Outer Continental Shelf from Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects

This EO pauses the utilization of the outer continental shelf and offshore locations for wind projects. Permitting authorities have been directed to stop the lease of federal waters for offshore wind development.

No new or renewed approvals are to be issued. This includes rights of way and loans for onshore or offshore wind projects. In addition, regulatory authorities have been tasked with evaluating the environmental impact of onshore and offshore wind projects on wildlife, including, but not limited to, birds and marine mammals.

These directives do not apply to leasing for other purposes such as oil, gas, minerals, and environmental conservation. Significantly, existing rights under current leases are not categorically impacted. However, the Secretary of the Interior, in consultation with the Attorney General, will review existing leases to assess termination or amendments.

Putting People Over Fish: Stopping Radical Environmentalism to Provide Water to Southern California

Work to route more water from the Sacramento-San Joaquin Delta to other parts of California is to be restarted. The EO cites the need for a reliable water supply for use by Southern Californian populations.

As part of the justification for re-starting water development projects in this region, this EO notes the recent historically destructive wildfires. According to the new administration, these fires underscore why the State of California needs to reassess vegetation management practices and develop a reliable water supply.

Regulatory Freeze Pending Review

Underscoring significant shifts in the Trump administration’s approach to environmental and energy regulation and policy, a 60-day regulatory freeze has been put into effect. This is similar to measures that were previously taken by Presidents Obama, Trump, and Biden.

This regulatory freeze halts the issuance of new rules until they are reviewed by newly appointed department heads. Any rule not yet published in the Federal Register must be withdrawn until reviewed by an incoming administration official. This freeze applies to all executive departments and agencies.

A notable example of this EO in action is the Trump EPA withdrawal of its draft proposal setting PFAS effluent limits for the chemical manufacturing sector. In response to this EO, the EPA withdrew this draft proposal from the White House Office of Management and Budget review on Jan. 21, 2025. This raises concerns about whether the new administration will continue working on long-delayed federal PFAS standards. It is unclear if the EPA will advance the PFAS effluent limits rulemaking despite the first work on such a rule beginning during the prior Trump administration.

Conclusion

Keep in mind that not all of these EOs will have immediate effect. Many environmental and energy regulatory changes will likely require some form of rulemaking. Litigation surrounding many of these federal regulatory adjustments is expected to increase in the coming months, with some suits already being filed. Despite likely rulemaking and litigation challenges, these EOs adjust policy objectives that will impact the federal regulatory landscape for traditional domestic energy production and infrastructure development.

As these changes unfold, Taft will continue to monitor developments and assess their implications for the regulated community. The Taft team is ready to assist with navigating this evolving regulatory environment.