With the confirmation of Lee Zeldin as Administrator of the U.S. Environmental Protection Agency, the Trump Administration is ushering in a time of fear and uncertainty in environmental law. The January 29th confirmation comes after an initial swath of Executive actions that have laid the foundation for environmental deregulation en masse. The purpose of this blog post is to summarize how the Trump Administration’s first 14 days have spelled change for the environmental and administrative law world, and what to keep an eye out for as an advocate.
Impacts Already Felt in the First 14 Days
In addition to the slew of Executive Orders issued by President Trump on January 20, 2025, he also rescinded a grand total of 66 Executive Orders. Eight of the rescinded Executive Orders were specifically designed to protect the environment. Of course these rollbacks have impacts felt nationwide (and even worldwide), but some have more immediate consequences than others. For example, President Trump rescinded Biden’s Executive Order 14096 Advancing Environmental Justice for All. With the loss of this Executive Order came the removal of an essential tool used daily by environmental advocates and rule-makers: the Climate and Environmental Justice Screening Tool (CEJST). Without the CEJST available on federal sites, it is much more difficult for advocates and policymakers alike to consider environmental justice factors in their efforts to protect the public from polluters.
Similarly, on Inauguration Day, President Trump directed the United States Ambassador to the UN to immediately withdraw the United States from the Paris Agreement. The practical and emotional effects of these Orders are only compounded by the realization that President Trump is opportunistically using climate disasters to exempt harmful projects from federal law. For example, under the guise of providing immediate relief to those struck by the devastating wildfires in California, President Trump has Ordered the exemption of the Central Valley Project and the State Water Project from critical procedures under the Endangered Species Act and National Environmental Policy Act in the long-term. To be clear, as stated by U.S. Representative Jared Huffman, “none of the policies in this Executive Order will move even a single drop of extra water to communities devastated by these wildfires.” This Order takes advantage of a climate disaster to access critically protected water resources in California.
The Regulatory and Hiring Freezes
As of the 15th day of Trump’s second presidency, all federal rulemaking activities remain frozen. What does this mean for the environmental law community? Well, no proposed federal rule regulating how an environmental statute is implemented may be passed until a Department or Agency head appointed by President Trump reviews the rule. In a similar vein, President Trump has frozen all hiring of federal civilian employees for at least 90 days. The goal of this hiring freeze is to allow the OMB to consult with the U.S. DOGE Service to create a plan to reduce the size of the federal government’s overall workforce. Environmental advocates and policymakers should expect both of these freezes to impact the implementation of federal environmental statutes, whether that’s because of inadequate federal resources to fulfill FOIA requests, or the reopening of comment periods on pending federal rules.
The last 14 days have been full of radical and aggressive Executive action undermining environmental protections and the ability of agencies and communities to safeguard the environment and human health. As a community, we must work together to persevere and creatively solve new problems created by these Executive actions.
Last updated February 4, 2025