EPA Announces Sweeping Deregulatory Agenda: The Complete Set of EPA’s 31 Actions and Affected Environmental Regulations

Framed as an effort to advance the goals of President Trump’s Unleashing American Energy Executive Order, the agency seeks to promote cooperative federalism, lower the cost of living, and revitalize the auto and energy industries by decreasing regulatory burdens. These proposed changes span air and water quality standards, energy and manufacturing sector regulations, and enforcement priorities, reflecting a broad shift in federal environmental policy toward deregulation and state-led environmental governance.

Noticeably absent from the 25 press releases issued on March 12 was any reference to Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) or Superfund reform, or to the EPA’s 2024 rulemakings on per- and polyfluoroalkyl substances (PFAS): the Safe Drinking Water Act maximum contaminant levels (MCLs) and the designation of two PFAS as hazardous substances under CERCLA. The administration recently signaled that it may reconsider last year’s PFAS rules by requesting stays in ongoing litigation challenging each action—suggesting that an announcement by Administrator Zeldin regarding these regulations may be forthcoming.

Overview of the Proposed Actions
The EPA’s 31 proposed deregulatory actions are grouped into three key initiatives outlined by the EPA.

Unleashing American Energy
Under the Unleashing American Energy initiative, the agency aims to reconsider or revise several regulatory frameworks affecting energy production, air and water quality standards, and industrial emissions. Key proposals include:

• Greenhouse Gas Reporting Program (GHGRP). The EPA is reviewing requirements that mandate approximately 8,000 facilities to report greenhouse gas (GHG) emissions, including data from large GHG emission sources, fuel and industrial gas suppliers, and CO₂ injection sites.
• Power Plant Emission Limits. The agency will reconsider the Clean Power Plan 2.0, which sets CO₂ limits for new gas-fired combustion turbines and emission guidelines for existing coal, oil and gas-fired steam generating units.
• Mercury and Air Toxics Standards (MATS). The EPA is reevaluating emissions standards for mercury and other hazardous air pollutants emitted by coal-fired power plant units with a capacity of more than 25 megawatts.
• Emission Limits for the Oil and Gas Industry. The agency plans to reconsider methane and volatile organic compound regulations, known as Subparts 40 CFR Part OOOOb and OOOOc. These performance standards apply to emissions from new and existing sources in oil and gas operations.
• Water Quality Standards for Steam Electric Power Generation. Proposed revisions would affect pollution limits for coal-fired power plants, including discharge standards for flue gas desulfurization wastewater, bottom ash transport water, combustion residual leachate and legacy wastewater.
• Air Rules for Manufacturing and Chemical Sectors. The EPA intends to revise multiple National Emission Standards for Hazardous Air Pollutants (NESHAPs), impacting industries such as integrated iron and steel manufacturing, rubber tire manufacturing, synthetic organic chemical production, medical sterilizers, lime manufacturing, coke ovens, copper smelting and taconite ore processing.
• Wastewater Regulations for Oil and Gas Extraction. The agency will review effluent limitation guidelines (ELGs) to ease wastewater discharge restrictions for drilling operations.
• Risk Management Plan (RMP) Requirements. The EPA aims to reduce compliance burdens for businesses handling extremely hazardous substances by revising chemical accident prevention regulations.

Lowering the Cost of Living for American Families
As part of its broader deregulatory agenda, the EPA has proposed several actions aimed at reducing regulatory costs that it contends contribute to higher consumer expenses. These initiatives include:

• Climate-Related Cost Metrics. The agency is reconsidering the Social Cost of Carbon metric, which estimates the economic damages from each additional ton of CO₂ emissions and has been used to justify climate-related regulations.
• Air Quality Standards. The EPA plans to revise National Ambient Air Quality Standards (NAAQS) for fine particulate matter (PM2.5) and issue guidance to provide greater flexibility in NAAQS implementation, New Source Review reforms and permitting obligations.
• Greenhouse Gas Endangerment Finding. The agency will revisit the 2009 Endangerment Finding, a key regulatory determination that underpins GHG rules, and reassess all regulations based on it. 74 FR 66496
• Vehicle Emissions Requirements. The EPA will reconsider several vehicle emissions rules, including the Model Year 2027 and Later Light-Duty and Medium-Duty Vehicles regulation, GHG Emissions Standards for Heavy-Duty Vehicles, and the 2022 Heavy-Duty Nitrous Oxide (NOx) rule.
• Technology Transition Rule. The agency is reviewing restrictions on the use of hydrofluorocarbons (HFCs) in refrigeration, air conditioning and heat pumps, foams, and aerosols.
• Restructuring Regional Haze Program. The EPA is reconsidering its approach to implementing Regional Haze Program under the Clean Air Act.
• Redirecting Enforcement Resources to EPA’s Core Mission. The agency plans to shift enforcement priorities to reduce what it describes as unnecessary bureaucratic burdens that increase consumer costs.
• Terminating Federal Environmental Justice and DEI Initiatives. The EPA will phase out programs that integrate environmental justice and diversity, equity, and inclusion (DEI) considerations into regulatory decision-making.

Advancing Cooperative Federalism
The EPA has outlined several deregulatory initiatives aimed at expanding state authority in environmental decision-making. These actions include:

• “Good Neighbor Plan” for Interstate Air Pollution. The agency intends to provide states with greater flexibility in addressing cross-border pollution controls in State Implementation Plans (SIPs)
• Rules for Coal Combustion Residuals. The EPA will reconsider regulatory requirements for coal ash disposal, prioritizing state-led implementation and oversight.
• Clearing the Backlog of Clean Air Act Implementation Plans. The EPA plans to collaborate with states and Tribes to resolve what it calls a “massive backlog” of SIPs and Tribal Implementation Plans (TIPs).
• Exceptional Events Rule. The EPA directed EPA staff to revisit the Exceptional Events rulemaking and prioritize the allowance of prescribed fires in SIPs and TIPs to decrease the risk of catastrophic wildfires.
• Reconstituting EPA’s Science Advisory Board (SAB) and the Clean Air Scientific Advisory Committee (CASAC). EPA will be open nominations for the SAB and CASAC through an announcement in the Federal Register.
• Use of Enforcement Discretion to Further North Carolina’s Recovery from Hurricane Helene. The EPA will extend the no action assurance for North Carolina, allowing the continued use of large air curtain incinerators to clear storm debris without requiring Title V permits.

From Proposal to Policy
These proposed regulatory changes will not take effect immediately. Generally, the EPA must follow the federal rulemaking process as outlined in the Administrative Procedure Act (APA). This process includes several key steps:

• Proposing Rulemaking. The EPA will publish notice of its proposed rule changes in the Federal Register, detailing the rationale behind the changes and their anticipated impacts.
• Public Comment Periods. Industry stakeholders, environmental groups and the public will have an opportunity to submit comments on the proposal.
• Final Rulemaking. After considering public input, the EPA will publish the final rule in the Federal Register, accompanied by a preamble explaining its provisions and addressing significant comments.
• Interagency Review. The White House Office of Management and Budget (OMB) will assess regulations deemed to have significant economic or regulatory impacts.
• Potential Legal Challenges. Once finalized, these actions may face legal challenges from states, advocacy groups or affected industries.

However, certain rules—even if already in effect—may be subject to recission through a joint resolution of disapproval under the Congressional Review Act (CRA). Generally, the CRA applies to rules submitted to Congress within the previous 60 legislative days. However, the CRA’s “look-back” provision resets the review window if the rule was finalized during the last 60 legislative days of the prior Congress, granting the new Congress a fresh 60-legislative-day period to act.

In the House, CRA resolutions proceed under normal legislative procedures, including committee referral. By contrast, the CRA provides expedited procedures in the Senate, allowing the resolution to avoid a filibuster, proceed to a vote with limited debate (up to 10 hours), and pass by simple majority. If both chambers pass the resolution and the President signs it (or Congress overrides a veto), the rule is retroactively nullified and treated as though it had never taken effect.

The CRA has already been used to rescind a Biden-era EPA rule, with several others under consideration. Two days after the EPA issued its deregulatory press releases, President Trump signed Public Law No. 119-2, a CRA joint resolution of Congress, disapproving of an EPA rule issued last November that established methane emissions charges under the Inflation Reduction Act’s Methane Emissions Reduction Program. The disapproved rule would have imposed annual waste emission charges on petroleum and natural gas facilities exceeding certain methane thresholds and was a key element of the Biden-era climate policy framework. The disapproval process moved quickly: the resolution was introduced in the House on February 4, debated and passed on February 26, received and passed in the Senate on February 27, and signed into law on March 14.

Implications and Next Steps
The EPA’s proposed deregulatory actions will have significant implications for businesses across multiple industries, particularly in the energy, automotive and manufacturing sectors. Companies should evaluate how these regulatory changes may impact their operations, compliance obligations and investment decisions. Engaging in the public comment process provides an opportunity to help shape the final rule and mitigate potential risks.

Pillsbury’s Environmental and Natural Resources attorneys are closely tracking the EPA’s regulatory developments. For further analysis or assistance in preparing for these changes or in submitting public comments, please contact our team.