Audit, Compliance and Risk Blog

Trumps first day executive orders and memoranda reversing Biden environmental initiatives

Posted by Jon Elliott on Thu, Feb 20, 2025

Environment-1Since re-entering office, President Trump has moved quickly to reverse many of President Biden’s environmental policies; actions include a flurry of Executive Orders (EOs) that reverse or cancel his predecessors EO-based and other environmental initiatives. The remainder of this note summarizes changes presented in the initial EOs. 

EO 14148 “Initial Rescissions of Harmful Executive Orders and Actions” (1/20/25) 

This EO presents a list of 78 of President Biden’s EOs and Executive Actions, revoking them all. The following revoked actions affecting environmental, health and safety policies and regulation (others touched on such issues, including environmental justice): 

  • EO 13990 (1/20/21) “Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis” – this EO froze a number of first-term Trump actions pending review by Biden appointees (I discussed it HERE ).
  • EO 13992 (1/20/21) “Revocation of Certain Executive Orders Concerning Federal regulations” – this EO revoked Trump EOs that changed federal regulatory procedures, including the application of science and statistics.
  • EO 14007 (1/27/21) (and revising EO 14044) “President’s Council of Advisors on Science and Technology” – established a 26-member advisory council.
  • EO 14008 (1/27/21) “Tackling the Climate Crisis at Home and Abroad” – committed to action on climate change, including rejoining the international Paris Accord.
  • EO 14027 (5/7/21) “Establishment of the Climate Change Support Office” – established office within State Department.
  • EO 14030 (5/20/21) “Climate-Related Financial Risk” – establish interagency task force to review and provide recommendations.
  • EO 14037 (8/5/21) “Strengthening American Leadership in Clean Cars and Trucks” – goal of 50% zero emission new vehicles by 2030, with direction to Environmental Protection Agency (EPA) and Department of Transportation. 

EO 14154 (1/20/25) “Unleashing American Energy” 

This EO states a purpose to support domestic energy development, and rescinds or attacks measures that are broadly defined to hamper this priority. These include: 

  • Eliminate the “electric vehicle mandate” (i.e, higher motor vehicle fleet standards adopted by EPA and DOT during the Biden administration, which increase pressure on auto makers to expand electric vehicle sales) (I’ve discussed such standards several times, including HERE) 
  • Immediate review by agencies of “all agency actions that potentially burden the development of domestic energy resources,” and begin processes to suspend, revise or repeal them 
  • Revoke or revise specified Biden EOs and regulatory actions, including those revoked by EO 14148 (above) 
  • Review and revise methodologies for environmental review including greenhouse gas and climate change costs and the “social cost of carbon” (I’ve written about earlier iterations of standards from the Council on Environmental Quality, including HERE) 
  • Review EPA’s 2009 endangerment finding for greenhouse gases, under the Clean Air Act 
  • “Terminate the Green New Deal” (i.e., electric vehicle infrastructure spending) 

EO 14162 (1/20/25) “Putting America First in International Environmental Agreements”

Reiterates US intent to withdraw as soon as possible from the Paris Accords. 

Memorandum for the Heads of Executive Departments and Agencies (1/20/25) “Regulatory Freeze Pending Review” 

This memorandum directs all agencies to cease work on any held-over Biden administration regulatory actions, as follows: 

  • Do not propose or adopt any rule until after review and approval by a Trump appointee 
  • Withdraw any rules submitted to the Federal Register but not yet published 
  • “consider” reopening any rulemaking for which a rule is published but is not yet effective, and postponing it for 60 days pending review (which may include reopening an applicable comment period 

What happens next? 

The Executive Orders and memoranda noted form part of President Trump’s accelerated effort to reverse much of his predecessor’s agenda and actions – which parallel but exceed those which incoming President Biden pursued after the end of President Trump’s first term. Since his first day, President Trump has continue to issue Executive Orders and Memoranda at historic paces. The experience of past revisionism following changes in administration suggests strongly that this process will continue throughout President Trump’s tenure. 

Implementation Checklist 

Is the organization subject to any federal regulations, policies or guidance? 

If so, were any of these provisions adopted or revised during the Biden administration? 

Has the incoming Trump administration identified any of these provisions for review, revision or replacement? 

Where can I go for more information? 

 - EO 14148 “Initial Rescissions of Harmful Executive Orders and Actions” (1/20/25) (1/28 Federal Register) 

- EO 14154 (1/20/25) “Unleashing American Energy” 

- EO 14162 (1/20/25) “Putting America First in International Environmental Agreements”

- Memorandum for the Heads of Executive Departments and Agencies (1/20/25) “Regulatory Freeze Pending Review”

About the Author

jon_f_elliottJon 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

 

Tags: Environmental, Environment, Environmental Policy, Joe Biden, Policy Change, Trump Administration