Air monitoring
What does Trump mean for environmental regulation?
Jan 24 2025
On 19 February 1981, still less than month into office, United States’ President Ronald Reagan issued Executive Order (EO) 12291. This required that any regulation ─ including ‘currently effective rules’─ which were ‘likely’ to have an ‘annual effect on the economy of $100 million or more’ must ‘not be undertaken unless the potential benefits to society from the regulation outweigh the potential costs to society’, recognised as ‘costs or prices for consumers, individual industries, federal, state, or local government agencies, or geographic regions’.1
According to the respected legal scholar, and late founder of the International Association of Legislation, Professor Ulrich Karpen: “EO 12291 introduced two revolutionary innovations into federal rulemaking: a focus on benefits and costs, instead of a broader understanding of ‘economic impacts’, like ‘inflation, employment and the profits of affected industries’; and ‘centralized review of regulations’” by the Office of Management and Budget.2
Previously a part of the US Treasury, the Bureau of the Budget was the precursor to the Office of Management and Budget and became part of the Executive Office of the President in 1939, in the run up to the US’ entry into World War II. The Bureau was reorganised under the Nixon administration in 1970 and renamed and then repurposed by Reagon.
Thus, this Office of Management and Budget received significant power over the US federal government’s lawmaking especially with regard to the environment, and reduced questions around tackling pollution to a price-based, cost-loss calculation in which a polluting business’ balance sheet was the chief concern, taking precedence over public health or the protection of commonly shared natural capital.
As one early account of the Environmental Protection Agency (EPA) under Reagan’s presidency has it: “if a statute requires EPA to regulate pollution to protect the health of the most vulnerable members of the public, OMB can still insist that EPA adopt a standard that protects fewer people and costs industry less.”3
Reagan’s appointees to the EPA ,many of whom came from careers in regulated industries, presided over unprecedented redundancies. Ultimately firing more than a quarter of its staff, and the US Congress cutting the Agency’s budget by 21%, these reductions and redirected organisational priorities resulted in 78% fewer civil cases being referred to the courts.4 5
In the decades since Reagan left office, under both Republican and Democrat administrations, these changes were largely reversed – that is until President Donald J. Trump’s first term in 2016. With its budget cuts, layoffs, abdication of federal responsibility and massive reduction in enforcement ─ the US President as head of the executive branch of government has overall responsibility for enforcement of all legislation ─ Trump’s EPA functioned much like Reagan’s.
But it’s not 2016, anymore. The United Nation’s Intergovernmental Panel on Climate Change’s statement accompanying its third instalment of its Sixth Assessment Report in 2022, said:
“The next few years are critical … this assessment shows that limiting warming to around 2°C (3.6°F) still requires global greenhouse gas emissions to peak before 2025 at the latest and be reduced by a quarter by 2030.”6
But Trump’s first acts, as he returned to office in January 2024, saw him issue a barrage of first-day EOs that disturbingly and crudely targeted environmental regulation. The US is on the crest of a fresh wave of deregulation and institutional restructuring at the US’ most consequential environmental authority – all of which will occupy the final half of this critical decade.
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What did Trump do to environmental regulations in his first term?
On the day of President Joe Biden’s inauguration in 2021, the New York Times published a list of the environmental regulations that Trump’s administration had repealed, claiming that 98 had been completed and that 14 were still in progress as his term of office was ending.7 These included 30 (28 completed; 2 in progress) relating to air pollution and emissions; 9 (8;1) for water pollution; as well as 10 (9;1) regulations for toxic substances and safety. Here are a few notable repeals:
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Demanded a ‘Review of Estimates of the Social Cost of Carbon, Nitrous Oxide, and Methane for Regulatory Impact Analysis’, requiring ‘that agencies use estimates of costs and benefits’ while disbanding the Interagency Working Group on Social Cost of Greenhouse Gases (IWG) and withdrawing its recommendation ‘as no longer representative of governmental policy’. Used by the Obama administration, the social cost of carbon is an accounting concept that takes a long-run view of the monetary damages caused by greenhouse gas emissions as a means of giving climate mitigation more of a chance in cost-benefit calculations.8
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Diluted fuel economy and emissions standards for vehicles; (despite his repeated support for state’s rights) stopped California setting stricter emissions standards; undermined mercury emissions limitations for coal plants; stopped requiring oil and gas companies to report methane emissions; set a minimum value for greenhouse gas emissions that exempts oil and gas production facilities; revoked the goal of cutting the federal government’s greenhouse gas emissions by 40% over 10 years; repealed a requirement to track tailpipe emissions from vehicles on federal highways; and ended environmental impact reviews of natural gas export projects at the Department of Energy.
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Withdrew the United States from the historic 2015 Conference of Parties (COP) Paris agreement (for the first time); and from the World Health Organization, which recommends environmental legislation for public health.
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Narrowed standards limiting the release of volatile organic compounds; repealed regulations for hydrofluorocarbons from large refrigeration and air conditioning systems; allowed upwind States to contribute more ozone pollution to downwind States.
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Gave federal agencies the ability to override state objections (despite his still repeated support for state’s rights) to projects that don’t meet local water quality standards (including fossil fuel infrastructure); and diluted limits to toxic discharge from power plants into public waterways.
This carbon-fuelled bonfire of red tape kicked off just 10 days after Trump’s 2017 swearing in. Executive Order 13771 demanded that any federal agency proposing a new regulation must ‘identify at least two existing regulations to be repealed.’9 A month later, EO 13777 required that each federal agency ‘designate an agency official as its Regulatory Reform Officer (RRO)’ to ‘carry out regulatory reforms’ in a bid to ‘lower regulatory burdens’.10 One more month and another Order, EO 13781, entitled ‘Comprehensive Plan for Reorganizing the Executive Brand’, gave new powers to OMB to ‘eliminate unnecessary agencies ..., components of agencies, and agency programs’ – in effect, submitting even more legislation to cost-benefit calculations.11 The Environmental Data and Governance Initiative (EDGI) considers these three Orders to have created an ‘ever more powerful and inscrutable OMB’.4
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Did Trump cut funding to the EPA?
Beyond this formal deregulation, Trump also sought to massively reduce the capacity of the EPA to act by cutting both is staff and budget which led to a precipitous fall in its enforcement capability. An investigation by EDGI, using interviews with Agency staff and analyses of internal documentation, detailed how funding for FY2018 and FY2019 was ‘one of the agency’s smallest budgets of the last thirty years’ in real dollar terms. Despite some resistance by the Republican-dominated Congress, Trump’s intentions were to achieve ‘a 31 percent reduction in overall funding’ and ‘to bring staffing to their lowest level since the Reagan cuts of the early 1980s.’12
In fact, one analysis suggested that, considered departmentally, Trump’s budget slightly increased two of the Agency’s biggest budget items (one for clean water and another for drinking water infrastructure), meaning that all of the desired cuts would come from all of the other departments, actually amounting to a ‘43% cut to ... programs for clean air, water, and land and climate protection’.13 As such, Trump proposals ‘cut funds for implementing the Clean Air Act, Clean Water Act, and other major federal public health laws,’ as well as ‘elimination of most EPA climate programs, including climate research’.13
In FY2018, 10,612 inspections were conducted, ‘the lowest on record since 1994, and only about 55 percent of the mean number of inspections from 1994 to 2016.’12 This was, in part, a result of ‘extreme deference to States’ that refused to use the Agency’s superior might to enforce the law.12 Another set of interviews by EDGI found that testifying staff saw ‘the new administration as posing the single greatest challenge ever faced by the EPA in its entire half-century of existence.’5
Did Trump’s EPA have links to regulated industry?
Another reason for the Agency’s hands-off approach under Trump may well have been that many of its senior officials were ex-industry – yet another echo from the Reagan years.
Indeed, the Office of Enforcement and Compliance Assurance (OECA) was led by Susan Parker Bodine for the duration of Trump’s first term, who was a partner with the law and lobbying firm Barnes & Thornburg from 2009 to 2015. During that period Parker Bodine represented a trade association ─ American Forest and Paper Association ─ whose members had hundreds of enforcement actions issued against them by the EPA, according to The Intercept.14
Her deputy throughout the administration, Patrick Traylor, had previously represented multiple entities accused of violations under the Clean Air Acts and Endangered Species Act, as well as coal mining firms, coal-fired power generators, and engine manufacturers over pollution regulations, according to the biography at his current law firm. From 2018 to 2021, the person employed in the highest office ─ strangely dubbed the ‘Assistant Administrator’ ─ at the Office of Water was David Ross. The office is responsible for implementing the Clean Water Act (CWA) and Safe Drinking Water Act. Mr Ross had previously represented the American Farm Bureau Federation in its 2012 lawsuit against the EPA’s new pollution limits for Chesapeake Bay, and had challenged new water quality regulations introduced by the EPA in 2015 when he was Wyoming’s Assistant Attorney General, according to POLITICO.
In fact, Ross shares his achievements with Trump’s first appointee to EPA Administrator (2018-19), Scott Pruitt, who also sued the EPA over the Clean Water Rule and issued a legal opinion in support of the Farm Bureau’s lawsuit, both while serving in his capacity as Wyoming’s Attorney General. While Pruitt was not ex-industry, he was certainly a fervent deregulator. Pruitt’s first four months were regarded by experts in environmental law as the largest regulatory rollback in the agency’s 47-year history, according to The New York Times. When asked by CNBC’s Joe Kernen if he believes that carbon dioxide “is the primary control knob for climate” Pruitt answered: “I think that measuring with precision, human activity on the climate, is something very challenging to do and there’s tremendous disagreement about the degree of impact. So no, I would not agree that it’s a primary contributor to the global warming that we see … we need to continue the debate and continue the review and the analysis.”
Originally his deputy, his successor Andrew Wheeler, who served for the remainder of Trump’s first term, had even more links to industry, according to a report by American lobbying researchers OpenSecrets. Previously, he had represented major energy and mining companies, including Murray Energy. As a partner at Faegre Baker Daniels Consulting, he also worked for uranium-mining firm Energy Fuels Resources, the Bear Head LNG Corp., and others all with stakes in weakening environmental regulations.
Wheeler had previously served as chief counsel and staff director at the Senate Committee on Environment and Public Works for Oklahoma's longest-serving Senator, Republican James ‘Jim’ Inhofe. Wheeler opposed climate-related legislation and supported efforts to relax pollution controls, according to DeSmog. Additionally, he was vice president at the Washington Coal Club, a networking group for coal industry professionals.
It is important to understand that these connections to industry don’t just shape the perspective of these officials but necessarily raises the concern that the Agency’s rulemaking will be subcontracted out – a relatively common practice in the US – to their contacts in industry. According to one study of this outsourcing practice by so-called, liberal-centrist Washinton DC thinktank, The Brookings Institute, ‘the Environmental Protection Agency is by far the biggest spender in this area’.15
What were the environmental impacts of Trump’s first term?
As a result, Trump’s first term, coming after ‘three years of decline’ in emissions of greenhouse gases, saw the ‘second largest annual [increase] in more than two decades’, increasing by 3.4%.16 An investigation into the long-run effects of Trump’s deregulation of greenhouse gas emissions ‘as more higher-emitting equipment (e.g., cars, A/C units, oil and gas facilities) come online’ found that ‘in the absence of new federal policy, Trump's rollbacks will increase US emissions by 1.8 gigatons of CO2, cumulatively, through 2035’, which is ‘equivalent to nearly one-third of all US emissions in 2019’ and thus, ‘total US emissions in 2035 will be 3% higher than they would have been absent Trump’s rollbacks.’17
But, consequently, a peer-reviewed study of economic markers that assumed Trump deregulated for economic reasons found that: ‘Only the coal industry can be considered a beneficiary because it experienced repetitive significant positive abnormal returns’.18
In 2019, Trump repealed the Water of the United States (WOTUS) rule, which had increased the number of wetlands and waterways protected by the CWA – a move criticised by the EPA’s Scientific Advisory Board. Their opinion said:
“The proposed definition of WOTUS is not fully consistent with established EPA recognized science, may not fully meet the key objectives of the CWA … by failing to protect ephemeral streams and wetlands which connect to navigable waters below the surface. These changes are proposed without a fully supportable scientific basis, while potentially introducing substantial new risks to human and environmental health.”19
It was The Lancet’s opinion in 2021 that: “Trump’s hostility to environmental regulations has already worsened pollution ─ resulting in [an estimated] more than 22,000 extra deaths in 2019 alone.”20
Lastly, there is evidence that Trump’s administration had a cooling effect on scientific work within government and reduced transparency. According to EDGI, ‘the use of the term ‘climate change’ decreased by an estimated 38%’ and ‘access [was removed] to as much as 20% of the EPA’s website’.21 A peer-reviewed study found that ‘reports of political interference in scientific work and adverse work environments were higher at EPA and Fish and Wildlife Service in 2018 than in prior years.’22
Indeed, an academic study of Trump’s institutional politics claimed that his administration ‘sought to undermine the institutions and core values undergirding environmental and climate protection’, concluding ‘while Trump’s impact on organisations, regulations and even policies can be diluted (and his legacy diminished), Trump’s attack on the norms and trust underpinning environmental action may be more long lasting.’23
What has Trump promised on environmental regulations in his second term?
On the day of his second inauguration, Trump issued a number of EOs and memoranda that have set the mood on his approach to environmental regulations:
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Withdrew from the Paris Climate Agreement (again)24 and the World Health Organization (again).25
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Declared a ‘national energy emergency’, directing federal agencies to ‘identify and exercise any lawful emergency authorities available to them, as well as all other lawful authorities they may possess, to facilitate the identification, leasing, siting, production, transportation, refining, and generation of domestic energy resources’. It is clear that these energy resources are fossil fuels because the Order commands agencies to ‘pause the disbursement of funds appropriated through the Inflation Reduction Act’ that massively increased federal support for renewable energy infrastructure under the Biden administration, ensuring that the remaining allocation will go unspent. Interestingly, it orders ‘terminating, where appropriate, state emissions waivers that function to limit sales of gasoline-powered automobiles’.26 According to CalMatters, the state of California had already abandoned its attempts to phase out diesel and apply stricter emissions regulations to other vehicles prior to Trump’s inauguration, having learned their lesson in Trump’s first term.
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Revoked a goal of 50% of new vehicle sales to be electric cars by 2030 (Biden’s EO 14037).27
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Directed the Secretary of Energy to ‘restart reviews of applications for approvals of liquified natural gas export projects, as expeditiously as possible, consistent with applicable law.’28
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Issued a memorandum that federal agencies ‘shall not issue new or renewed approvals ... for onshore or onshore wind projects’.29
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Ordered a hiring freeze for ‘federal civilian employees’ (that ‘does not apply to military personnel ... or to positions related to immigration enforcement, national security, public safety’)30 and then, ‘immediately reinstated’ a re-classification (Schedule F) of thousands of permanent federal employees in the excepted civil service, making them far easier to fire;31 this classification was first created by executive order in 2020.32 Given much of Trump’s original reduction in the EPA’s workforce preceded this Order, there are significant concerns about this reinstatement being one of Trump’s first moves.
Who is Lee Zeldin, Trump’s pick for EPA Administrator?
Another early indicator of the future direction of travel for the EPA has been Trump’s nominee for its next Administrator, former Republican Congressman from New York, attorney and military veteran, Lee Zeldin. Environmental pressure group, the League of Conservation Voters gave Zeldin a lifetime score of 14% on its annual National Environmental Scorecard which tracks the voting records of all members of Congress on environmental, climate, environmental justice and democracy legislation. Zeldin’s voting record demonstrated his opposition to increasing wildlife protections, monitoring greenhouse gas emissions, adding to water quality regulation, pollution management and various forms of climate action.33
The Legislative Director of the Sierra Club, Melinda Pierce issued a statement following Lee Zeldin’s confirmation hearing earlier this month, stating that: “then-Congressman Zeldin regularly voted for more pollution and fewer public health protections ... opposed efforts to fund the national flood insurance program ... voted to drastically slash funding for the very agency he now claims he wants to lead ... called for the repeal of standards that protect clean air and clean water.’34 The Sierra Club is a US-based not-for-profit foundation that promotes climate solutions, conservation a through combining strategic philanthropy and grassroots advocacy.
Importantly, when Zeldin was questioned in his confirmation hearing regarding his opinion on Donald Trump’s much-publicised claims that climate change was a ‘hoax’ by Senator Bernie Sanders, he stated that he believes ‘climate change is real’ and that Trump’s concern was only with ‘the economic costs of some policies, where there’s a debate’. According to Newsweek, reversing Biden’s fracking moratorium was one of the planks of Zeldin’s 2022 bid to be elected Governor of New York.
Speaking to The Verge, representatives of the Environmental Data and Governance Initiative (EDGI) expressed concern for the future of EJScreen, a digital tool used by the EPA, urban planners, healthcare workers, teachers and non-governmental watchdogs alike, to understand risks posed by smog, toxic waste and other environmental hazards in particular areas.
While there’s no formal indication beyond Trump’s troubling record on data protections, one of the proposals in the much-discussed Heritage Foundation’s Project 2025, is ‘eliminating the stand-alone Office of Environmental Justice and External Civil Rights’, which manages EJScreen.35 Project 2025 was a white paper published by the Washington DC-based conservative thinktank in 2023 and outlined its agenda for the ‘next conservative administration’.
Co-founder and website monitoring program lead at EDGI, Gretchen Gehrke told The Verge that: “We may see massive data deletion, but we also might see just the deterioration of data because it’s not being actively managed or becomes inaccessible.”
What does Project 2025 recommend for environmental regulation?
Despite the Heritage Foundation’s project being a source of controversy on the campaign trail, and attracting the new president’s denials, many of Trump’s first day EOs echo proposals made in Project 2025, Newsweek reports. In fact, the chapter of Project 2025 that deals with the EPA was authored by Mandy Gunasekara, who the document itself credits as ‘former chief of staff at the Environmental Protection Agency’ (during Trump’s first term) and the official database of federal legislative information, Congress.gov, profiles as ‘the architect of the Paris Accord withdrawal and a defining voice in the Trump Administration’s environmental and energy agenda.’35 Indeed, reading through the document, there are multiple explicit recommendations that seem to call for actions very similar to those taken in Trump’s first term.
For instance, it calls for a Day One Executive Order to ‘set up pause and review teams to assess ... identify existing rules to be stayed and reproposed ... develop a tiered-down approach to cut costs, reduce the number of full-time equivalent positions ... revise guidance documents that control regulations such as the social cost of carbon; discount rates; timing of regulatory review (before options are selected); causality of health effects; low-dose risk estimation (linear no-threshold analysis); and employment loss analysis.’35
Staffing cuts, review of existing legislation, new standards by which environmental legislation should be judged (including getting rid of the social cost of carbon and raising regulatory thresholds), all of which is to be undertaken by a new internal authority – all of these measures are broadly familiar. Indeed, it recommends a transition to ‘using enforcement to ensure compliance, not to achieve extra-statutory objectives,’ implying that current levels of enforcement are excessive.35
Other passages indicate support for Trump’s repealing of the WOTUS rule, which deregulated certain waterways that discharge into regulated bodies of water, as the document calls for:
‘A rule that provides clarity and regulatory certainty regarding the CWA Section 401 water quality certification process to limit unnecessary delay for needed projects, including by establishing a discharge-only approach with a limited scope (from point sources into navigable waters), assessing only water quality factors that are consistent with specific CWA sections, and excluding speculative analysis regarding future potential harm.’35
Elsewhere, there’s a re-assertion of a long-held wish of certain pressure groups to: ‘establish a system, with an appropriate deadline, to update the 2009 endangerment finding’, which was the EPA’s finding that ‘the current and projected concentrations of the six, key, well-mixed greenhouse gases ... in the atmosphere threaten the public health and welfare of current and future generations’, the legal ‘prerequisite for implementing greenhouse gas emissions standards’.35
Trump’s second EPA Administrator in his first term, Andrew Wheeler was asked by The Washington Post in 2018 about a public statement that was deeply critical about this finding when it was issued. He told The Post: ‘I was very critical of the method that the Agency used to come up with the endangerment finding, that they did not do independent analysis’. However, a day before Biden’s inauguration, Wheeler’s EPA denied a petition calling for the repeal of this finding, with the rejection stating that ‘the petitioners’ arguments are not based on the body of the scientific evidence and include only a limited discussion of the science itself.’36
Other sections recommend that the EPA: ‘revisits the designation of PFAS chemicals as hazardous substances’; ‘ensures that decision-making is risk-based rather than defaulting to precautionary, hazard-based approaches like the Integrated Risk Information System (IRIS)'; and 'applies real-world use of chemicals when assessing conditions of use for risk evaluations' – all of which run the risk of massively deregulating all sorts of toxins and disruptive pollutants.35
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Finally, it recommends that the National Oceanic and Atmospheric Administration ‘be dismantled and many of its functions eliminated’ which would, in all likelihood, massively decrease scientific research into and frequent monitoring of climate dynamics.40
Is Trump’s second term a significant threat to global climate action?
As of 2023, the World Resources Institute had recorded the United States as the second-largest climate polluter. According to the US’ Energy Information Administration (a federal statistics agency), the United States became the world’s largest exporter of liquefied natural gas (LNG) that year – and maintained that position in 2024, per Reuters.
Many commentators take Trump at his word when he claims he wants to increase the supply of fossil fuels to lower overall energy prices but this is more likely to be an excuse than a sincere objective. It’s unlikely that fossil fuel suppliers will want their product devalued by increased supply, nor is it practicably possible when infrastructure is the bottleneck to increased supply ─ especially for exports. Further, it will take years for new projects to be operational and online in the supply chain.
In actuality, Trump is simply opening the floodgates for fossil fuel extraction in the understanding that these projects will not be dismantled by any Democratic or Republican successor once they’re in development. Indeed, while Biden’s EO 13990 ordered a moratorium on new oil and gas leases,37 he did not rescind permits issued under Trump.
Some observers remain hopeful that Trump will not be able to undermine the straight-forward economics of cheaper renewable electricity and hyper-efficient heat pumps.38 However, such a focus on the demand side fails to grasp significant supply-side troubles in renewable energies caused by marginal-cost pricing in wholesale markets that enforce hyper-competitive conditions which hamstring returns, making such assets less attractive to investors.39 40 41 Despite its flaws, Biden’s Inflation Reduction Act was a successful attempt to address these concerns through direct market subsidy.
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In essence, then, if the incoming Trump’s administration (at least) repeats the deregulation of greenhouse emissions that we saw in his first term, removing public funds from investment in renewable energy and allowing increased development of LNG guarantees, increasing long into the future the emissions of the world’s second-largest polluter. And, it represents an unprecedented attack on public health in the United States ─ and, of course, globally ─ that will be felt for generations.
1 Ronald Reagan, Executive Order 12291—Federal Regulation. Gerhard Peters and John T. Woolley. The American Presidency Project. UC Santa Barbara.
2 Implementation of Legislative Evaluation in Europe: Current Models and Trends. Ulrich Karpen. European Journal of Law Reform. 2004. p. 82.
3 A Season of Spoils: The Reagan Administration’s Attack on the Environment. Jonathan Lash. Pantheon. 1984. p. 24.
4 The First 100 Days, Part 1: The EPA Under Siege. Sellers et al. The Environmental and Data Governance Initiative. 2018.
5 New Federalism and Environmental Policy. James Lester. Publius. 1986.
6 The evidence is clear: the time for action is now. We can halve emissions by 2030. Intergovernmental Panel on Climate Change. 2022.
7 The Trump Administration Rolled Back More Than 100 Environmental Rules. Here’s the Full List. Popovich et al. The New York Times. 2021.
8 Promoting Energy Independence and Economic Growth. Donald Trump. 2017.
9 Reducing Regulation and Controlling Regulatory Costs. Donald Trump. 2017.
10 Enforcing the Regulatory Reform Agenda. Donald Trump. 2017.
11 Comprehensive Plan for Reorganizing the Executive Branch. Donald Trump. 2017.
12 A Sheep in the Closet: The Erosion of Enforcement at the EPA. Frederickson et al. Environmental Data and Governance Initiative. 2019. p. 7-9, 21.
13 Analysis of Trump Administration Proposals for FY2018 Budget for the Environmental Protection Agency. Environmental Protection Network. 2017. p. 4, 22.
14 Donald Trump’s pick for EPA Enforcement Office was a lobbyist for Superfund polluters. Sharon Lerner. The Intercept. 2017.
15 How much of rulemaking is done by contractors? Rachel Augustine Potter. Brookings. 2022.
16 Preliminary US Emissions Estimates for 2018. Rhodium Group. 2019.
17 The Undoing of US Climate Policy: The Emissions Impact of Trump-Era Rollbacks. Pitt et al. Rhodium Group. 2020.
18 Which industries benefited from Trump environmental policy news? Evidence from industrial stock market reactions. Nerger et al. Research in International Business and Finance. 2021.
19 Commentary on the Proposed Rule Defining the Scope of Waters Federally Regulated Under the Clean Water Act. U.S. Science Advisory Board. 2019. p. 3-4.
20 Public policy and health in the Trump era. Woolhandler et al. The Lancet Commissions. 2021.
21 Visualizing changes to US federal environmental agency websites, 2016–2020. Nost et al. PLOS ONE. 2021.
22 Perceived losses of scientific integrity under the Trump administration: A survey of federal scientists. Goldman et al. PLOS ONE. 2020.
23 The environmental legacy of President Trump. Elizabeth Bomberg. Policy Studies. 2021.
24 Putting America First in International Environmental Agreements. Donald Trump. 2025.
25 Withdrawing the United States from the World Health Organization. Donald Trump. 2025.
26 Declaring a National Energy Emergency. Donald Trump. 2025.
27 Strengthening American Leadership in Clean Cars and Trucks. Donald Trump. 2017.
28 Unleashing American Energy. Donald Trump. 2025.
29 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. Donald Trump. 2025.
30 Hiring Freeze. Donald Trump. 2025.
31 Restoring Accountability to Policy-Influencing Positions within the Federal Workforce. Donald Trump. 2025.
32 Executive Order on Creating Schedule F in the Excepted Service. Donald Trump. 2020.
33 National Environmental Scorecard: Representative Lee Zeldin (R). League of Conservation Voters. .
34 Sierra Club Statement on Lee Zeldin’s Confirmation Hearing to be EPA Administrator. Melinda Pierce. 2025.
35 Mandate for Leadership: The Conservative Promise. Project 2025. The Heritage Foundation. 2023. P. xiii, 286, 421-2, 425, 429, 431, 433-4, 664.
36 EPA’s Response to the Petitions to Reconsider the Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act (Vol. 3). U.S. Environmental Protection Agency (Office of Atmospheric Programs). 2021. p. 110.
37 Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis. Joe Biden. 2021.
38 What Does Trump Mean for the Climate? Gernot Wagner. Columbia Business School. 2024.
39 The private sector alone will not deliver the energy transition. Nick Butler. Financial times. 2019.
40 Solar power got cheap. So why aren’t we using it more? Ula Chrobak. Popular Science. 2021.
41 Missing profits may be a problem for the green transition. David Wallace-Wells. The New York Times. 2024.
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