Top 5 Energy and Environmental Actions You Should Know from President Trump's First Day

On January 20, 2025, President Trump began his second term with the signing of 26 executive orders (EOs), which included the recission of almost 80 EOs of the previous administration. Trump’s orders contain both repeals of key Biden administration policies and calls to agency action to reassess treatment of major energy and environmental issues associated with domestic energy production, motor vehicles, and climate change. Here are the top five actions to know from President Trump’s first day as the new administration begins its reshaping of U.S. energy and environmental policy for his second term in office. 

1. Rollback of Climate Policies. President Trump made clear that there will be new U.S. policy on climate change, as he repealed all climate-focused EOs from the Biden administration. This included a directive to the United Nations to remove the United States from the Paris Agreement, the international treaty to limit global greenhouse gas (GHG) emissions. Trump also called upon the U.S. Environmental Protection Agency (EPA) to review two key aspects of EPA regulatory policy on climate: 
   • First, EPA must submit a report on the “legality and continuing applicability” of its 2009 endangerment finding for GHGs under the Clean Air Act (CAA). Revoking the finding would undermine EPA’s regulations covering carbon dioxide and other GHG emissions from vehicles and power plants, and its climate regulatory authority in general. During the previous Trump administration, EPA considered and rejected a petition to reconsider the endangerment finding.
   • Second, EPA must issue guidance on the “social cost of carbon” — a metric used by agencies to quantify the climate impacts of regulations and permitting — that considers whether its use should be eliminated. The Biden administration significantly increased the value of the social cost of carbon, which EPA and other agencies used to support climate regulation and policy. 

   If EPA shifts course on either of these, significant litigation should be expected.

2. Increase Domestic Energy Generation With Emphasis on Oil and Gas Production and Exports. Pursuant to the National Emergencies Act, President Trump declared a national emergency regarding insufficient domestic energy infrastructure and supply, including oil exploration and production and petroleum refining — activating all emergency agency authority to expedite energy generation. Through several EOs, Trump also lifted Biden administration policies restricting oil and gas development and liquified natural gas (LNG) exports: 
   • First, Trump reopened for development federal waters in the Arctic, Atlantic, and Pacific Oceans, and parts of the Gulf of Mexico (now renamed by the United States as the Gulf of America in a separate EO) that President Biden had restricted.
   • Second, Trump directed the secretary of energy to restart reviews of applications for approvals of LNG exports that Biden had paused in January 2024 to countries lacking a free trade agreement with the United States (including China and European Union members).
   • Third, Trump ordered agency heads across the federal government to revoke, rescind, or revise regulations that are inconsistent with resource development in Alaska, including restrictions on oil and gas leasing in the Arctic National Wildlife Refuge.
3. Pausing Leasing for Wind Projects. President Trump halted the issuance of any new or renewed wind energy leases for Outer Continental Shelf (OCS) locations effective January 21, 2025. Additionally, the Department of the Interior (DOI) must review existing offshore wind leases in the OCS via a “comprehensive review” to determine whether to terminate or amend such existing leases. More broadly, with respect to both onshore and offshore wind projects, Trump directed the DOI and other agencies not to issue new or renew approvals, rights of way, permits, leases, or loans for offshore wind projects, pending a “comprehensive review” of federal wind leasing and permitting practices.
4. Pause on IRA and IIJA Funds Disbursement and Proposed Revocation of Electric Vehicle Goals. President Trump’s EO, Unleashing American Energy, directed agencies to immediately pause the disbursement of funds appropriated through the Inflation Reduction Act of 2022 (IRA) and the Infrastructure Investment and Jobs Act of 2022 (IIJA). The administration clarified in a subsequent memo that the pause applies only to those funds implicating the administration’s policy agenda. The EO specifically directs agencies to pause funds for electric vehicle (EV) charging stations. Agencies must review their policies and programs for issuing IRA and IIJA funding and recommend changes for alignment with the administration’s policy agenda. Funds may only be disbursed once the director of OMB and the assistant to the president for economic policy determine that the disbursements are in accordance with recommendations they have chosen to accept. Legal challenges to Trump’s efforts to impound the IRA and IIJA funds are expected. The Unleashing American Energy EO also reflects a goal to eliminate President Biden’s EV “mandate” and revoke California’s waiver, promulgated under that state’s unique CAA authority to develop vehicle emission standards stricter than federal standards. In a separate EO, Trump rescinded Biden policies regarding net-zero GHG emission goals for motor vehicles and other industries.
5. Removal of Environmental Justice Considerations. Finally, President Trump called to terminate all environmental justice (EJ) offices and positions in federal government, as well as any EJ initiatives, programs, or other activities. This move reverses the EJ commitments undertaken by the Biden administration and tracks toward the removal of all EJ considerations from agency action promulgated in Trump’s first term.

On top of these, the White House issued a regulatory freeze on agency rulemaking (broadly encompassing notices and policy statements), directing agencies to not only refrain from proposing or issuing new rules, but to withdraw any rules from publication consideration and consider postponing forthcoming effective dates for further internal review or public comment. This move is typical for new administrations and is similar to action taken by the Biden administration in January 2021.

Executive orders do not have the force and effect of regulations per se, but nonetheless are powerful statements of presidential policy and direction that can have immediate legal and/or practical consequences. Presidents are generally free to revoke the EOs of their predecessor without meeting the type of procedure requirements necessary for changing a regulation, which is the case with the revocation of many of President Biden’s EOs here. Stay tuned for further EOs and specific agency actions implementing President Trump’s policies.