Trump Administration Executive Actions Mark Broad Rollback of Climate and Clean Energy Directives

EO 14302, along with three related orders released the same day, seeks to jumpstart a national strategy accelerating the deployment of advanced nuclear reactor technologies. EO 14302 specifically aims to “to provide affordable, reliable, safe, and secure energy … that secure[s] our global industrial and digital dominance, achieve[s] our energy independence, [and] protect[s] our national security … .” The order directs the Department of Energy (DOE) to complete designs and begin construction of 10 new large reactors by 2030 and dramatically increase public-private partnership under the Defense Production Act (DPA), while mandating the secretaries of the Energy, Defense, and Transportation departments submit a report to the president highlighting key areas of policy and legislative action necessary for revamping American nuclear infrastructure.

EO 14299 instructs the DOE to, among many numerous policy directives in this lengthy order, designate AI data centers at DOE sites as critical defense facilities and to fast-track the deployment of advanced nuclear reactors to power such infrastructure, with the first reactor targeted to be operational within 30 months. These reactors may be privately funded and located on DOE-controlled land, with priority given to supporting national security and AI energy needs. To expedite development, the Departments of Energy and Defense are instructed to streamline environmental reviews under the National Environmental Protection Act (NEPA) by using or creating categorical exclusions and emergency permitting processes.

EO’s 14300 and 14301 seek to streamline the Nuclear Regulatory Commission’s permitting process for quicker approval of nuclear projects, direct the DOE to enhance testing protocols for nuclear reactors, ensuring safety and efficiency in the deployment of new technologies, and modernize safety requirements and testing facilities to keep pace with modern advancements in nuclear technology.

Facilitating the expansion of nuclear power may be relevant to companies considering integrating nuclear energy into climate strategies, such as technology companies that may view investments in this space as a potential strategy for adapting climate targets to the energy demands of increased AI-related activities.

The administration's emphasis on advanced nuclear technologies presents opportunities for companies to invest in reliable, low-carbon energy sources that align with sustainability goals. By participating in the development and deployment of modern nuclear infrastructure, companies can address the dual challenges of meeting escalating energy demands and achieving climate targets.

However, it's essential for companies to consider the evolving regulatory landscape, public perception, and potential risks associated with nuclear energy investments. Rapid progress in renewables, grid storage, and other emerging technologies may reduce the relative value of nuclear investments given the expense and timeline for nuclear infrastructure to become operational. Further, companies may face challenges with cyber and physical security as well as with the operation and reputational risks of nuclear waste management.

EO 14260 seeks to limit the ability of individual states to use permitting authorities – such as Section 401 of the Clean Water Act – to delay or block federally permitted infrastructure. The EO directs the attorney general, in consultation with the heads of executive departments and agencies where relevant, to identify and take action to prevent the enforcement of state energy permitting and other climate-related laws deemed to be unconstitutional or preempted. Such action is directed to focus litigation efforts on challenging state climate-related laws on preemption or other constitutional grounds. The order specifically targets New York, Vermont and California as examples of climate-related laws and initiatives that constitute state overreach. The order prioritizes the identification of any state laws purporting to address “climate change” or involving “environmental, social, and governance” initiatives, “environmental justice,” carbon or “greenhouse gas” emissions, and funds to collect carbon penalties or carbon taxes.

This EO would weaken the ability of states to block or impose conditions on major energy projects; however, any impacts would likely not be immediate, as the attorney general would need to pursue litigation challenges to prevent the enforcement of relevant state laws. This order is primarily focused on energy-related state laws, such as cap and trade schemes or permitting restrictions, and does not reference state disclosure statutes, such as the California climate disclosures under SBs 253 and 261. To the extent that the attorney general does target such statutes under this order, or otherwise, this would supplement ongoing litigation challenges, which include preemption claims, that have been unsuccessful to date.

EO 14261 promotes the continued and expanded use of coal-fired electricity generation by granting regulatory waivers, extending the operational lives of coal plants and accelerating leasing on federal lands. The chair of the National Energy Dominance Council (NEDC) is directed to designate coal as a “mineral” pursuant to EO 14241 (see below), and the secretaries of the Interior, Agriculture and Energy departments are ordered to identify coal reserves on federal lands and assess impediments to mining with proposed policies to enable access. The order includes a two-year suspension of key emissions standards under federal law and prioritizes increasing leasing for coal production for grid reliability – particularly in support of high-load sectors, such as artificial intelligence (AI), electric vehicle (EV) infrastructure and cloud computing.

The EO restores coal to a central role in federal energy planning, albeit in tension with broader market trends favoring renewables and natural gas. The emissions exemptions and federal leasing provisions are expected to reduce operating costs for coal facilities while increasing potential environmental and public health impacts. Legal challenges are anticipated, particularly regarding Clean Air Act compliance and federal-state authority conflicts. However, the continued operation of plants may maintain supply during a transition to other energy sources, thus stabilizing energy costs to consumers in the short term.

EO 14262 addresses the increasing electricity demand driven by technological advancements, such as the expansion of AI data centers and increased domestic manufacturing, which have placed significant strain on the US electric grid. The order directs the secretary of energy to expedite the process for issuing emergency orders under Section 202(c) of the Federal Power Act during periods when grid operators forecast grid failures. The secretary of energy is further directed to create a procedure for analyzing current and anticipated reserve margins across all regions of the bulk power system regulated by the Federal Energy Regulatory Commission (FERC), identify and assess regional generation resources critical to grid reliability, ensure that such resources are retained within at-risk regions, and prevent significant generation sources (over 50 megawatts) from converting fuel sources if it would result in a net reduction in capacity. The secretary is directed to issue a report on the procedures identified regarding reserve margin management and findings related to ensuring grid reliability, to be made publicly available on the DOE’s website within 90 days of the order.

While this move may stabilize capacity markets and reduce blackout risks, it also could undercut renewable energy deployment, particularly in states that rely on federal transmission planning or funding support. Utilities and grid operators will need to reevaluate their investment strategies as federal incentives shift away from decarbonization.

EO 14236 rescinds several additional Biden-era presidential determinations issued under the DPA that were intended to accelerate domestic production of clean energy technologies. These include support for solar photovoltaic components, heat pumps, insulation materials and critical electrochemical devices, such as fuel cells and electrolyzers. The order also revokes EO 14081, which promoted biotechnology for sustainable energy and climate solutions.

This action weakens federal momentum for domestic clean energy manufacturing and supply chain diversification. By eliminating DPA-based market support, the administration is signaling reduced federal backing for solar, heat pump and advanced materials industries – sectors previously prioritized for decarbonization and inflation control. Developers and manufacturers may face slower project timelines, constrained innovation incentives and heightened import dependence for key energy components.

EO 14213 creates the NEDC, a new interagency body tasked with coordinating federal efforts to advance domestic fossil fuel production, streamline energy project permitting and prioritize US energy exports. The NEDC is tasked with advising the president on rapidly expanding domestic energy production by identifying agency actions, fast-tracking approvals for infrastructure, like pipelines and power plants, and recommending incentives to attract private investment within 100 days of the order. It also must review key energy markets, highlight regulatory barriers driving up energy costs and develop a national strategy to promote energy dominance and reliability. The NEDC is chaired by the secretary of the interior and composed of representatives from the departments of Energy, Transportation and Treasury, the Environmental Protection Agency (EPA) and others.

By centralizing policymaking under the NEDC, the administration is centralizing its “energy dominance” agenda and reducing the influence of climate-related advisory structures. The NEDC’s emphasis on fossil fuel exports, critical minerals and streamlined project approvals is likely to shape future regulatory proposals and budget priorities. However, a rapid restructuring of other scientific and policy advisory bodies may lead to knowledge gaps or implementation delays. International partners and investors should anticipate a continued decoupling of US energy strategy from climate-oriented multilateral frameworks.

EO 14192 directs all federal agencies and departments to identify and eliminate regulations deemed to impose “unjustified costs” on the energy, transportation, construction and manufacturing sectors by requiring a repeal of “at least 10 existing regulations” for every new rule or regulation adopted. Further, the EO directs all agencies to confirm that the cost of all new and repealed regulations is “significantly less than zero.” The EO revives and expands on a prior Trump administration regulatory rollback policy, requiring agencies to propose two deregulatory actions for every new regulation issued. It also directs the director of the Office of Management and Budget (OMB) to implement a regulatory reduction process within the Office of Information and Regulatory Affairs to oversee compliance and promote a cost-benefit analysis that prioritizes economic growth and energy affordability over environmental externalities.

This EO commits to a deregulatory posture across the federal government, especially in sectors with high energy usage or emissions profiles. However, a higher discount rate than applied in similarly themed policies of prior administrations means that the policy downplays the value of long-term environmental and health benefits, making regulations aimed at addressing future harms appear less cost-effective and resulting in future gains counting for less in the cost-benefit analysis. While businesses may benefit from reduced compliance costs and permitting delays, the directive increases the likelihood of agency-level rule rescissions that could be challenged in court under the Administrative Procedure Act. Environmental, labor and public health organizations are likely to contest high-impact rollbacks, particularly those affecting air and water quality standards or safety regulations.

EO 14148, an initial omnibus directive from the Trump administration, revokes an array of Biden-era climate, energy and environmental justice directives, signaling a dramatic shift in federal policy. To effectuate this EO, the director of the Domestic Policy Council (DPC) and the director of the National Economic Council (NEC) shall review all federal government actions taken pursuant to the energy- and climate-related EOs it revokes. Key actions include:

• Revocation of climate and environmental justice frameworks: EO 14148 repeals EO 13990, along with a broader suite of policies centered on climate science, environmental justice and the clean energy transition. The order calls for the dissolution of environmental justice offices and decreased staffing across federal agencies, including the Department of Justice’s Office of Environmental Justice and the EPA’s Office of Environmental Justice and Civil Rights. The order also instructs the OMB to review environmental justice-related programs, committees and budgets to assess their economic and social impacts – particularly regarding enforcement, litigation and regulatory efficiency.
• Targeting the transportation sector and EV policies: EO 14148 revokes EO 14037, eliminating federal support for EVs and nullifying emissions reduction targets in the transportation sector. It pauses pending regulations designed to increase fuel efficiency and accelerate EV adoption.
• Rollback of clean energy and infrastructure funding: EO 14148 also rescinds EOs 14052 and 14057, reducing federal investment in public transit and EV charging infrastructure, lifting requirements for agencies to transition to carbon-free electricity and net-zero buildings, and removing restrictions on fossil fuel procurement.
• Dismantling of Inflation Reduction Act (IRA) clean energy and equity provisions: EO 14148 revokes EOs 14082 and 14096, eliminating IRA-funded programs supporting clean energy and infrastructure in historically marginalized communities and ending initiatives focused on studying climate impacts on vulnerable populations.
• This provision is subject to a partial preliminary injunction and is pending resolution in the US Court of Appeals for the District of Columbia Circuit.
• Withdrawal from international climate commitments and environmental, social and governance (ESG) frameworks: EO 14148 repeals US policies that prioritized climate change in foreign policy and national security, including retraction from the Paris Agreement. It also withdraws federal support for financial regulations that required companies to assess and disclose climate-related financial risks and ends mandates for federal agencies to consider sustainability in procurement and investment decisions.

EO 14148 represents a comprehensive dismantling of Biden-era climate-focused governance infrastructure. It reduces oversight on environmental justice, halts the federal transition to clean energy and reorients US policy toward fossil fuel development and deregulation. While some companies – particularly in the energy, industrial, infrastructure and logistics sectors –may benefit from fewer compliance burdens and permitting delays, the sweeping nature of these reversals introduces new legal risks and could widen the gap between federal and state environmental policies. However, litigation risk remains, particularly in regions with strong state-level protections or active environmental litigation.

EO 14162 directs federal agencies to withdraw from or renegotiate international environmental and climate accords – particularly, “any agreement, pact, accord, or similar commitment made under the United Nations Framework Convention on Climate Change” – that are deemed contrary to US economic or sovereignty interests. Agencies are further instructed to reassess prior treaty commitments for their impact on domestic industry, energy security and trade competitiveness. This, among other broader diplomatic policy implications, allows the EPA to revise, in line with Trump administration priorities, methane emissions rules, power plant emissions standards and vehicle emissions limits.

EO 14162 weakens US alignment with global climate frameworks and may isolate federal regulatory strategy from international norms, especially in carbon-intensive sectors. However, this stance could offer US producers a competitive edge by freeing them from international compliance regimes, particularly those related to emissions accounting, environmental disclosures or supply chain sourcing.

EO 14154 reverses provisions in EO 14052 (bipartisan infrastructure law implementation) and EO 14082 (IRA execution), both of which advanced clean energy deployment and resilience. The EO deprioritizes renewable procurement, eliminates certain clean energy grant programs and removes climate-related requirements for federal funding eligibility. It also directs agencies to restore fossil fuel leasing as a national priority. The EO particularly focuses on reducing regulatory burdens on energy production and critical minerals, mandating the director of the OMB and the NEC begin implementing action plans to “suspend, revise, or rescind all agency actions identified as unduly burdensome … as expeditiously as possible.” It directs federal agencies to expedite domestic energy and mining projects, expedite permitting, and freeze funding for Biden-era climate initiatives, including EV charging stations. The EO rescinds 12 climate-related EOs from the Biden administration and orders federal contracts advancing climate goals to be canceled where legally possible. It also limits judicial challenges to energy projects and streamlines National Environmental Policy Act review.

This EO also instructs agencies to review all grants, loans, and contracts to ensure policy alignment with traditional domestic energy production, critical minerals development, and the elimination of EV mandates. In procurement or disbursement, agencies must prioritize cost-effectiveness, competitiveness of American business and taxpayer value. The order requires the secretary of state to explore critical minerals mining partnerships with Japan, India and Australia.

Currently, this executive order is subject to several preliminary injunctions within the US Court of Appeals for the First Circuit and DC Circuit. Both have been partially stayed and are pending appeal in both circuits.

This EO recenters federal energy policy around oil, gas and mineral development. Developers in these sectors will benefit from streamlined permitting and increased lease availability, particularly on federal lands, which may reduce costs to consumers. At the same time, the rollback of renewable incentives may reduce momentum for clean energy investments, particularly in early-stage or subsidy-reliant projects. Grant recipients and public-private partnerships should reassess funding pipelines and project viability under the new rules.

EO 14156 empowers the DOE to exercise emergency authority over energy production and distribution. Further, it directs the heads of other executive departments and agencies to take steps to advance domestic energy resources and issue emergency waivers to various regulatory burdens. It specifically targets permitting bottlenecks, regulatory burdens and market disruptions that the administration claims threaten domestic energy security and affordability, and directs agencies to use emergency powers to boost domestic energy production, including on federal land. It encourages the use of eminent domain and the DPA to support efforts. The EPA is instructed to consider fuel waivers allowing year-round sale of E15 gasoline. The EPA and Army Corps of Engineers also are directed to use emergency power to fast-track permitting for energy projects by streamlining regulations under the Clean Water Act, Rivers and Harbors Act and Endangered Species Act.

The term “energy” is defined to mean “crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, the kinetic movement of flowing water, and critical minerals.” The emergency designation fast-tracks project approvals for fossil fuel infrastructure and may suspend or bypass environmental review requirements in some cases, potentially lowering energy costs. While this EO is a boon for conventional energy developers, its legal durability is uncertain – clean-energy industry groups and some states are expected to challenge both the factual basis for the emergency and the legitimacy of any executive branch actions taken under this declaration.

This presidential memorandum halts all new offshore wind leasing activity on the Outer Continental Shelf pending a full review of federal leasing and permitting practices by the secretaries of the Interior, Agriculture and Energy and administrator of the EPA. The review will assess the economic justification, environmental risks and national interest alignment of the existing offshore wind agenda. This assessment must “consider the environmental impact of onshore and offshore wind projects upon wildlife, including, but not limited to, birds and marine mammals.”

The memorandum casts immediate uncertainty over offshore wind projects in various stages of development. Lease auctions will be paused, and permitting processes frozen, likely causing delays and cost overruns. This directive signals that offshore wind – long championed under former President Joe Biden – will face new political and regulatory headwinds under current federal leadership. Further, the anticipated onboarding of these generation sources could impact energy prices in the near term as grids are forced to account for lowered generation projections.