On March 12th, 2025, EPA Administrator Lee Zeldin announced 31 major actions, what he termed “the largest deregulatory announcement in U.S. history.” The announcement aligns with President Trump’s Day One executive orders and EPA’s previously announced “Powering the Great American Comeback” initiative. Zeldin’s priorities are to advance environmental protection while unleashing American energy, lowering living costs, revitalizing the auto industry, and restoring the rule of law. Key regulatory changes include reconsidering the Clean Power Plan, the particulate matter (PM2.5) National Ambient Air Quality Standard (NAAQS), certain NSPS and NESHAP regulations, and Greenhouse Gas Reporting Program. In line with criticism of the previous administration’s regulatory efforts, the announced rollbacks are expected to reinvigorate U.S. energy production, improve manufacturing opportunities, and bring back auto jobs to the country.
In this article, we will explore several significant environmental policy changes proposed in the March 12th announcement and provide an overview of the issues that are being reconsidered. Trinity will be providing regular updates on these topics as additional details are released about future EPA, court rulings, and congressional actions.
1. Reconsidering the Clean Power Plan: The Battle Over Carbon Emissions
The Clean Power Plan (CPP), first introduced in 2015 under the Obama administration, aimed to reduce carbon emissions from power plants, which are major contributors to climate change. The CPP set emissions reduction targets for states, encouraging a shift from coal to cleaner energy sources like natural gas, solar, and wind. The 2015 plan was broadly opposed by industry stakeholders and aligned States, and the first Trump administration repealed it in 2019, citing concerns over its economic impact. CPP was replaced with a less stringent regulation, the “Affordable Clean Energy (ACE)” plan. The Biden administration, emphasizing bold actions to combat climate change, began efforts to reinstate or strengthen the CPP. However, a 2022 Supreme Court decision in West Virginia v. EPA, limited the EPA’s authority to regulate emissions from power plants under the Clean Air Act, creating a new “major questions doctrine” to restrict agencies from making broad regulatory decisions without clear congressional authorization. Another noteworthy Supreme Court decision during this time period was in Loper Bright Enterprises v. Raimondo, which overturned Chevron v. NRDC further constraining agency authority.
In 2024, the EPA retooled the regulatory framework surrounding the CPP, now referred to as Clean Power Plan 2.0, and included aggressive schedules for reducing CO2 emissions from new and existing power plants (including mandatory carbon capture in some cases). The new rule has faced criticism for attempting to address the court’s ruling while maintaining similar fuel-shifting objectives previously blocked. Supporters argue that strict regulations on power plants are needed to curb emissions in light of the seriousness of the threat posed by climate change, while critics raise concerns about potential impacts on energy prices and job markets in certain industries. Ultimately, the success of Clean Power Plan 2.0 will depend on how it navigates the complex intersection of environmental goals, legal constraints, and political pressures.
2. Reconsideration of the PM2.5 National Ambient Air Quality Standard (NAAQS)
While the CPP reboot was to broadly impact the electric generation sector, a regulation with even broader reach was the Biden administration’s reconsideration of the fine particulate matter (PM2.5) national ambient air quality standard. The Biden EPA aggressively lowered the level of the NAAQS to 9.0 µg/m3 from 12.0 µg/m3, and even greater reduction than some public health advocates expected to see.
Critics argued (correctly in many cases) that the new regulation would stop numerous air permit projects in their tracks, as the new NAAQS was set so low that it was at or below the background level of ambient particulate in many parts of the country. Major expansion plans for broad sectors of industry (steelmaking, petrochemicals, pulp and paper, etc.) have been delayed or paused due to an inability to meet dispersion modeling requirements based on the new NAAQS. Proponents of the new regulation have argued that impacts to industrial expansion are exaggerated, while the new standard provides the margin of safety to protect public health that is required by law.
3. Throttling the Oil and Gas Industry: New Emission Standards for Crude Oil and Natural Gas Facilities
The reconsideration of emission standards for the oil and gas industry involves the EPA’s publication of the NSPS OOOOb on March 8, 2024, which replaced the previous NSPS OOOOa standards (introduced under the Obama administration). The new standards focus on emissions from equipment at crude oil and natural gas facilities constructed or modified after December 6, 2022. The rule applies to a range of equipment, including compressors, pneumatic controllers, storage tanks, and well completions.
Critics of NSPS OOOOb argue that the stricter standards place a significant financial burden on the oil and gas sector, which is already facing fluctuating commodity prices and regulatory challenges. Additionally, under NSPS OOOOb, small and mid-sized operators may face difficulties in meeting compliance costs. The strengthened rules come on the heels of an aggressive EPA enforcement initiative targeting excess emissions of methane and VOC from oil and gas production sites.
For older facilities, the EPA issued NSPS OOOOc, providing guidelines for States to produce mandatory plans to reduce greenhouse gas emissions from existing facilities. While the goal is to reduce the environmental impact of fossil fuel extraction, concerns remain about the broader economic implications of these policies on job creation and energy market stability, and whether these costs are worth the benefits of reduced emissions from production sites, the majority of which are far from population centers.
4. Reconsidering the Greenhouse Gas Reporting Program (GHGRP)
The Greenhouse Gas Reporting Program (GHGRP), after being funded through 2009 legislation, has been an essential tool for tracking emissions from thousands of industrial facilities across the U.S., requiring facilities to calculate and report their greenhouse gas emissions annually. However, the costs associated with compliance—estimated to exceed $690 million annually—have sparked debate.
The EPA announced its reconsideration of the GHGRP, including revisiting the “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” and the “Mandatory Reporting of Greenhouse Gases,” along with amendments. These revisions are driven by concerns from industry stakeholders regarding the burdensome nature of some monitoring requirements, particularly for smaller oil and gas producers. The reconsideration need not extend to the 2024 Methane Waste Emissions Charge (WEC) rule, which was repealed by a Congressional Review Act resolution in late February.
The agency believes these changes could improve the accuracy of emission estimates, particularly in sectors like landfills, and streamline reporting requirements across other industries, potentially reducing the burden on reporters. However, critics warn that these revisions might slow efforts to monitor and mitigate greenhouse gas emissions effectively, hindering progress toward a low-carbon economy. Given the age of the program, however, it is unclear at this time whether EPA Intends to reconsider only the recent amendments, or the GHGRP as a whole. Unlike core Clean Air Act programs such as the NAAQS, GHGRP has a relatively marginal status within the overall legislative framework.
For more details on this action, check out Trinity’s recent article by clicking here.
5. Reconsideration of Risk Management Program Rule
The Risk Management Program (RMP), part of the Clean Air Act, requires facilities that handle hazardous chemicals to develop plans to prevent accidents and mitigate potential damage. Recent revisions to the RMP introduced more stringent safety measures, particularly impacting oil and gas refineries and chemical plants.
These updated regulations have faced criticism from industry stakeholders, who argue that the new safety measures are costly and may not be feasible in all cases. Some have called for reconsidering these regulations to provide more flexibility for industries while still focusing on preventing accidents.
6. Reconsideration of Greenhouse Gas Regulations for Vehicles
Transportation is a major source of U.S. greenhouse gas emissions, prompting efforts to introduce stricter emissions standards for light-duty, medium-duty, and heavy-duty vehicles. These regulations aim to reduce pollutants like nitrogen oxides (NOx) and promote the adoption of electric vehicles (EVs) and cleaner technologies.
The EPA has also revisited the 2022 Heavy-Duty Nitrous Oxide rule, which some critics argue could increase costs for businesses reliant on trucks for transportation. The regulation is viewed as a significant component of broader efforts to shift the trucking industry toward electric vehicles, but industry stakeholders have argued that the new standards are unrealistically stringent, and signal a de facto phaseout of the internal combustion engine itself. The rules also raise concerns about their potential impact on small businesses and consumers in terms of price and consumer choice in purchasing new vehicles.
7. Reconsideration of the 2009 Endangerment Finding: A Key Legal Challenge
In December 2009, the EPA made an “endangerment finding” under the Clean Air Act, determining that certain greenhouse gases, including carbon dioxide and methane, posed a threat to public health and the environment. Following the Supreme Court’s 2007 decision in Massachusetts v. EPA, which deemed greenhouse gases “air pollutants” under the Clean Air Act, the endangerment finding has served as the legal basis for numerous environmental regulations, including vehicle emissions standards and the greenhouse gas reporting program.
The endangerment finding has been challenged by some who argue that it was based on flawed science, while supporters of the finding treat the science as axiomatic. As environmental regulations are reconsidered, the future of this finding is again under scrutiny. A successful effort to overturn it could undermine a broad range of climate-related regulations.
8. The Good Neighbor Plan: Federal vs. State Authority
The “Good Neighbor Plan” was introduced to address interstate air pollution by reducing emissions of nitrogen oxides (NOx) and ozone-forming pollutants. However, critics argue that the plan overextends federal authority, imposing federal regulations on states that may be unnecessary or inappropriate for local circumstances. This has led to legal challenges from several states. For legal observers, one noteworthy facet of the 2024 litigation was the Supreme Court’s willingness to stay the rule via its emergency appeals (or “shadow”) docket.
The reconsideration of the Good Neighbor Plan underscores the ongoing debate about the balance between federal and state authority in environmental regulation. While proponents of strong Federal action argue that many States cannot be trusted to control their emissions to the extent needed to meet the Nation’s air quality goals, opponents argue that States must retain primacy in matters of environmental protection—they are best equipped to address local environmental issues and should not be subject to federal mandates that may not align with local needs.
9. Environmental Justice and DEI Programs
Significant changes have been made by the new federal administration affecting Environmental Justice (EJ). Executive Orders 14167 and 14171, executed on January 20 and 21, 2025, effectively ended many federal EJ initiatives. Included with the Executive Order 14167 is direction to “terminate, to the maximum extent allowable by the law, all DEI, DEIA, and ‘environmental justice’ offices and positions,” among other directives. DEI(A) refers to “Diversity, Equity, Inclusiveness (and Accessibility),” a broad set of initiatives focused on improving the fairness of corporate and government activities for minority groups. Multiple EJ-related resources have been taken down, such as EJScreen and CEJST on February 6, 2025. At the same time, the newly-formed Department of Government Efficiency (DOGE) has announced the cancellation of numerous EJ- and DEI-related contracts.
The 2025 Executive Order was largely focused on rescinding a 2021 Executive Order on the same topic. Given that the 2021 order was not accompanied by any basic legal changes, In many parts of the country the recent federal changes will not immediately or directly impact state- and local-level policies, regulations, or legislation (e.g., criteria for public notice, comment, meetings, impact assessments, or promulgated/issued state laws or rules) however some state/local agencies may reduce their EJ emphasis (and alter their requirements) based on the change in federal emphasis.
Conclusion
The ongoing developments in environmental policy reflect the complex balancing act between addressing climate change, economic considerations, and regulatory authority. From reconsidering the Clean Power Plan and emission standards for various industries to revisiting key regulatory programs, the challenges of mitigating environmental impact while maintaining economic stability and industry competitiveness remain central. The debates surrounding the future of the EPA’s regulations—on topics ranging from greenhouse gas reporting to air pollution—highlight the differing perspectives on how best to achieve a sustainable and equitable future. As these policies continue to evolve, finding solutions that promote environmental protection while considering the diverse needs of industry, communities, and the economy will be essential in shaping the path forward.
The Trinity team actively tracks the implications of both federal and state elections and the impacts of proposed policy changes to the broader environmental regulations industry. Our subject matter experts can help advise clients across a variety of industries, from data centers to the oil and gas industry, on how their business may be impacted by upcoming elections.
Stay tuned for further updates as the situation unfolds or contact Trinity Consultants directly to talk with a local expert.
