Since returning to office in January, President Trump and his administration have promulgated many actions to reduce and revamp the US federal government, and additional actions focused on specific agencies. I wrote about general approaches to environmental regulation HERE. In addition, The Environmental Protection Agency (EPA) has been a target of specific directives, and new EPA administrator Lee Zeldin has already announced important policy and procedural changes at his agency. The remainder of this note summarizes EPA-specific changes ordered and/or instituted as of the end of February 2025.
Executive orders and memoranda
Executive orders (EOs) and executive memoranda to agency heads that apply to EPA include:
- January 20 (these are included in my summary of first-day EOs HERE):
- EO 14148 “Initial Rescissions of Harmful Executive Orders and Actions” – repealing Biden EOs and adopting new directives, including stricter vehicle emission limits, and provisions for scientific and data review
- EO 14154 “Unleashing American Energy” – repeal “electric car mandate” (stricter vehicle standards), and require review of EPA’s greenhouse gas (GHG) “endangerment finding?
- Memorandum for the Heads of Executive Departments and Agencies “Regulatory Freeze Pending Review” – block additional rule proposals and adoptions until after reviews by Trump-appointed officials
- January 31 – EO 14192 “Unleashing Prosperity through Deregulation” – requiring agencies to identify 10 regulations to repeal each time a new one is adopted (exceptions are available)
EPA regulatory actions
EPA adjustments to its regulatory activities include the following.
- Published in Federal Register
- January 28 – delay effective date for four recently-finalized rules, including regulation of trichlorethylene (TCE) under the Toxic Substances Control Act (TSCA), and 3 Clean Air Act (CAA) regulatory determinations
- January 31 – reopen comment periods in 6 rulemakings, including CAA and Clean Water Act (CWA)
- February 3 - reopen comment periods in 3 rulemakings, including work on the next update to the general industry stormwater discharge general permit (CWA)
- February 5 – delay effective date for 2 regulations (Resource Conservation and Recovery Act (RCRA) hazardous waste, and addition of specified Per- and Polyfluoroalkyl Substances (PFAS) to Toxics Release Inventory (TRI) for reporting year 2025
- February 20 – reopen comment period for proposed revocation of pesticide residue levels for chlorpyrifos, and extend comment period on petition to change pesticide labeling requirements
- February 21 – extend comment periods on 2 CWA rulemakings
- February 26 – extend comment period on a hazardous air pollutant (HAP) rulemaking (CAA)
EPA’s administrative and policy priorities
Since January 29, EPA’s Administrator has been former Congressman Lee Zeldin. He has made a number of public changes to the agency’s policies and procedures. These include:
- February 4 – Zeldin announced 5 pillars for his first 100 days:
- pushing for ‘Clean Air, Land, and Water for Every American’
- ‘Restore American Energy Dominance’
- 'Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership’
- ‘Make the United States the Artificial Intelligence Capital of the World’
- ‘Protecting and Bringing Back American Auto Jobs’
- February 11 - EPA placed 171 environmental Justice (EJ) and diversity, equity, inclusion and accessibility (DEI) employees on leave
- February 18 – EPA “urged” employees to return to work in agency offices
- February 26 – EPA clarified a statement made by President Trump during his first cabinet meeting that EPA’s personnel will be cut by 65%, to mean that EPA’s budget will be cut by 65% (I’ve written about EPA budget requests several times, most recently HERE)
What happens next?
Administrator Zeldin and the Trump administration continue to work to realign EPA to meet the administration’s new priorities. States, federal employees and other interest groups are protesting, and have begun to file lawsuits to delay or block some changes. Things remain unsettled.
Self-assessment checklist
Does the organization operate facilities subject to permits issued by EPA or the state, under direct or delegated authority of federal environmental laws (CAA, CWA, RCRA etc.)?
Does the organization manufacture, import or distribute chemical substances subject to TSCA?
Is the organization subject to cleanup requirements under direct or delegated authority of federal environmental laws (Superfund, RCRA, etc.)?
Does the organization participate in EPA-sponsored voluntary programs subject to elimination?
Where can I go for more information?
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com