Regulatory Tracker – Environmental and Energy Law Program

Federal Offshore Wind Deployment

February 2, 2026

President Trump issued a memorandum withdrawing areas for wind energy leasing and ordering agency heads not to issue approvals for wind projects; a court vacated agencies’ implementation of that order in Dec. 2025. Also in Dec. 2025, DOI paused leases for five large-scale offshore wind projects.

Greenhouse Gas Endangerment Finding

January 30, 2026

EPA proposed rescinding its 2009 finding that greenhouse gas emissions contribute to air pollution that endangers human health or welfare, which is the basis for EPA regulation of greenhouse gas emissions from US cars, power plants, and oil and gas facilities.

Air Transport Rules: Cross-State Air Pollution Rule/Good Neighbor Plan Rule

January 30, 2026

The Clean Air Act’s Good Neighbor provision requires upwind states to ensure that their instate sources do not contribute to downwind states’ attainment of the NAAQS. On Mar. 12, 2025, EPA announced its plan to roll back the Biden administration’s Good Neighbor Plan, which the Supreme Court stayed in June 2024.

Oil and Gas Development in Alaska’s National Petroleum Reserve

January 27, 2026

The Bureau of Land Management replaced the 2024 rule regulating management of the NPR-A with the prior rule, promulgated in 1977.

Clean Car Rules — Corporate Average Fuel Economy Standards/Greenhouse Gas Standards

January 27, 2026

The Trump EPA issued a proposal to rescind the Endangerment Finding and the GHG standards for light, medium, and heavy-duty vehicles.

Paris Climate Agreement

January 27, 2026

On Jan. 27, 2026, the United States withdrawal from the Paris Agreement became effective after a year-long process.

Regional Haze Rule

January 26, 2026

Through two state plan approvals, EPA finalized a new policy that eases all states’ Regional Haze planning obligations. Environmental groups are challenging the approvals.

Deep Sea Mining

January 22, 2026

Following the April 2025 executive order Unleashing America’s Offshore Critical Minerals and Resources, the Bureau of Ocean Energy Management and the National Oceanic and Atmospheric Administration have taken steps to facilitate commercial deep sea critical minerals mining.

NEPA Environmental Review Requirements

January 21, 2026

The Trump administration published a final rule withdrawing all CEQ rules implementing NEPA. Agencies now use their own rules or guidance to implement NEPA.

Power Plant Effluent Limits

January 19, 2026

The Biden EPA strengthened final effluent limits for wastewater discharges from steam power plants in May 2024. In Oct. 2025, EPA proposed a rule to extend deadlines of the 2024 rule while the agency works on a more comprehensive proposal for revision.

Section 401 Water Quality Certification

January 15, 2026

CWA section 401 governs certification of water quality and provides significant latitude to states to decide how to issue certifications. The Biden EPA updated Section 401 implementing regulations, and litigation is ongoing.

Arctic National Wildlife Refuge — Oil and Gas Development

January 13, 2026

In October 2025, BLM reinstituted a Coastal Plain Oil and Gas Leasing Program which opened the 1.56 million acre Coastal Plain of the Arctic National Wildlife Refuge for oil and gas leasing.

Federal Onshore Extractive Energy Leasing

January 13, 2026

President Trump directed agencies to review and remove regulations that the administration believes burden domestic energy production. BLM has begun the process of offering expanded areas for leasing and expedited lease reviews.

PFAS in Drinking Water

January 12, 2026

Under the SDWA, the Biden EPA set strict standards and requirements for certain PFAS chemicals in public drinking water supplies. The Trump EPA is delaying compliance deadlines for two of those Biden-era SDWA rules and working to rescind four others.

Once In Always In Guidance for Major Sources under the Clean Air Act

January 2, 2026

Congress repealed the 2024 rule using the Congressional Review Act and EPA reinstated the 2020 rule, which allows a major source to reclassify as an area source if the source reduces HAP emissions.

Power Plant Startup, Shutdown, and Malfunction Rule

January 2, 2026

In early January 2025, the Biden EPA withdrew its direct final rule and indicated it would release a subsequent rule addressing the 13 states that failed to submit state implementation plan revisions.

BLM Methane Waste Prevention Rule

December 22, 2025

In 2024, BLM released a final rule to reduce the waste of natural gas from oil and gas operations on federal and Tribal land. In Nov. 2025, BLM announced it will delay enforcement of portions of the rule that had been scheduled to take effect Dec. 2025. Other portions of the rule remain in effect and BLM is considering revisions.

The Dakota Access Pipeline (DAPL)

December 19, 2025

The pipeline is operational but lacks a key Army Corps permit. Litigation is ongoing.

Coal Ash Rule

December 16, 2025

EPA proposed to give 11 coal-fired power plants an additional three years to continue to dispose of coal ash in unlined ponds larger than 40 acres, allowing these coal plants to operate past their “currently scheduled” retirement date.

Financial Regulation, Climate Change, and Climate-related Risk Disclosure

December 9, 2025

Litigation challenging the SEC climate-related risk disclosure rule is held in abeyance while the SEC decides whether to rescind the rule.

EPA VOC and Methane Standards for Oil and Gas Facilities

December 4, 2025

The Biden EPA finalized three rules regulating methane emissions from the oil and gas sector. One of the rules, the Waste Emission Charge, was repealed using the Congressional Review Act. In Sept. 2025, EPA proposed to delay the GHG reporting rules until 2034. In Nov. 2025, EPA finalized the deadline exemptions for certain provisions regulating methane emissions from new and existing oil and gas sources.

National Ambient Air Quality Standards (NAAQS) for Particulate Matter (PM)

November 24, 2025

The CAA requires EPA to review and set primary and secondary standards for PM NAAQS every 5 years. The Biden EPA strengthened the standard in March 2024. On November 25, 2025, EPA requested the D.C. Circuit vacate the 2024 rule.

Federal Offshore Oil and Gas Leasing Program

November 20, 2025

The Department of the Interior proposed a new 5-year program for offshore oil and gas lease sales that will cover 1.3 billion acres. The administration also rolled out a schedule for additional offshore oil and gas lease sales to implement provisions in the OBBBA.

Endangered Species Act Regulations

November 19, 2025

The Trump administration issued its first proposed rollback to ESA protections.

Defining Waters of the United States (WOTUS)

November 17, 2025

Following a 2023 Supreme Court decision, the Biden administration revised the definition of WOTUS. In November 2025, EPA and the Army Corps proposed a rule to update and narrow the definition of WOTUS.

The Izembek Refuge Road

November 12, 2025

The Dept. of Interior and King Cove Corp. (KCC) signed a land swap agreement. The contract conveyed KCC 490 acres within the refuge in exchange for 1,739 acres of KCC-owned lands that would be added to the Izembek National Wildlife Refuge. Native Villages and environmental advocacy groups filed three lawsuits to dispute the legality of the exchange.

New Source Review

October 29, 2025

EPA establishes the baseline requirements for new source review (NSR) permits, which are then issued by state and local air pollution agencies. In 2025, EPA made multiple changes to the NSR program easing permitting requirements for new and existing sources.

Ethylene Oxide (EtO) Emissions Standards for Commercial Sterilizers

October 22, 2025

In 2024, EPA strengthened regulation of ethylene oxide (EtO) emissions from commercial sterilization facilities. In July 2025, the Trump administration exempted 41 facilities from the rule, prompting challenges from public health and environmental nonprofits.

Hydrofluorocarbons and the Kigali Amendment to the Montreal Protocol

October 17, 2025

In 2022, the U.S. Senate ratified the Kigali Amendment, which committed the U.S. to reducing the use of HFCs. EPA issued multiple rules to implement the mandate. In Oct. 2025, EPA issued a proposed rule to loosen requirements and compliance deadlines for air conditioning, retail food refrigeration, and other sectors.

Mercury and Air Toxics Standards

October 16, 2025

In June 2025, the EPA proposed a rule to rescind the 2024 mercury and air toxics standards (MATS) for power plants. Trump has exempted 74 electric generating units from the 2024 MATS.

Chemical Risk Evaluations

September 23, 2025

The Trump EPA published a proposed rule changing its chemical risk evaluation procedures under the Toxic Substances Control Act.

PFAS and the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

September 17, 2025

The Trump administration has decided to keep in place a Biden administration rule designating two common PFAS chemical sub-types as hazardous substances under CERCLA.

Municipal Solid Waste Landfill Air Pollution Emission Standards for Methane and Other Pollutants

September 16, 2025

MSW landfills are currently subject to EPA’s 2016 New Source Performance Standards and Environmental Guidelines. In Sept. 2025, EPA proposed to delay the GHG reporting rules until 2034.

Implementation of 2015 Ozone National Ambient Air Quality Standards (NAAQS)

September 15, 2025

Under the Trump executive order Regulatory Freeze Pending Review, the Biden administration’s final rule setting deadlines for states to submit SIPs for nonattainment areas did not go into effect. On June 3, 2025, EPA announced its plans to reconsider the rule.

Alaska Roadless Rule

August 29, 2025

Under President Biden, USDA finalized a rule restoring protections in national forests, including the Tongass, which was challenged. In Aug. 2025 the USDA announced it plans to propose to rescind the 2001 Roadless Rule.

Marine National Monuments & Marine Sanctuaries

August 11, 2025

The Trump administration took steps to roll back marine monument protections via executive order and proclamation.

BSEE Blowout Preventer and Well Control Rule

August 8, 2025

Following the Deepwater Horizon explosion and oil spill, DOI altered its regulatory scheme and consolidated blowout prevention and well control requirements. The Biden administration revised the rule, and the Trump administration is now seeking comment on potential changes.

Regulating Greenhouse Gases for New and Existing Fossil Fuel-Fired Power Plants

August 1, 2025

In June 2025 EPA proposed a rule rolling back the 2024 EPA standards for GHG emissions from existing coal-fired power plants and new gas-fired power plants.

Migratory Bird Treaty Act

July 29, 2025

The Trump administration has taken steps to withdraw Biden-era guidance and regulations that protected migratory birds.

The Social Cost of Greenhouse Gases (Carbon Dioxide, Methane, Nitrous Oxide)

July 29, 2025

President Trump disbanded the interagency working group on the social cost of greenhouse gases, withdrew the working group’s guidance documents, and ordered agencies to use emissions estimates from the 2003 version of OMB’s Circular A-4. He also directed EPA to review how and whether the social cost of carbon should be used.

Bristol Bay and the Pebble Mine

July 17, 2025

The Biden EPA issued a Clean Water Act determination that blocked the Pebble Mine, finding the project would significantly impact the Bristol Bay watershed. A court granted the Trump DOJ’s request to stay litigation challenging that determination.

Corporate Average Fuel Economy Penalties

July 4, 2025

In July 2025, Congress eliminated the Corporate Average Fuel Economy civil penalties, resetting penalties to $0.00.

NEPA — Department of Energy

June 30, 2025

DOE last updated its NEPA rules in April 2024.

NEPA — Department of the Interior

June 30, 2025

DOI last updated its NEPA rules in 2008. In April, DOI released “alternative arrangements for NEPA compliance,” outlining a novel process for certain energy projects to circumvent existing environmental review procedures.

NEPA — Forest Service

June 30, 2025

The Forest Service last updated its NEPA rules in 2008. It finalized additional categorical exclusions in 2013 and 2020.

Liquid Natural Gas by Rail Rule

June 23, 2025

Transportation of LNG by rail is allowed only when authorized by a special permit, but the Trump administration is seeking feedback on this rule.

National Monuments

May 27, 2025

The Biden administration designated and expanded national monuments. The Trump DOI has slated these for rollback.

National Ambient Air Quality Standards (NAAQS) for Ozone

May 1, 2025

On March 12, 2025, EPA announced a reconsideration of the NAAQS.

Regional Transmission Planning Rule

April 11, 2025

FERC approved Order No. 1920, directing utilities and RTOs to produce long-term regional transmission plans. The Fourth Circuit will review the rule.

Petroleum Refinery Sector Rule (NESHAPs / NSPS)

April 10, 2025

The Biden EPA amended the 2015 standards for refineries. On Mar. 12, the Trump administration slated these standards for rollback.

National Ambient Air Quality Standards (NAAQS) Review

March 12, 2025

EPA sets NAAQS for six common and harmful pollutants: carbon monoxide, lead, PM, ozone, nitrogen dioxide, and sulfur dioxide.

Generation Interconnection Rule

May 16, 2024

FERC issued an order revising standard procedures used by utilities and regional transmission organizations for connecting generation projects to the transmission system. The D.C. Circuit will review the order.

Single-Use Plastics Phase Out on Public Lands

December 26, 2023

The Department of the Interior announced a phase out single-use plastic on public lands in 2023.

Public Utility Regulatory Policies Act of 1978 (PURPA)

September 6, 2023

We are not currently updating this rule.

Keystone XL Pipeline

June 9, 2021

The project has been cancelled and all domestic litigation dismissed.

Greater Sage-Grouse Protection

May 28, 2021

We are not currently updating this rule.

NEPA — Federal Communications Commission (FCC)

May 3, 2018

FCC last updated its NEPA rules in 1986. FCC also issued a rule in 2018 excluding certain small wireless facilities from NEPA review.

NEPA — Department of Homeland Security

October 18, 2017

DHS does not have rules implementing NEPA. The agency last updated its NEPA guidance in 2014, with minor corrections in 2017.

BLM Land Use Planning 2.0

March 28, 2017

We are not currently updating this rule.

NEPA — Environmental Protection Agency

February 4, 2009

EPA last updated its NEPA rules in 2007, with minor corrections in 2009.