On July 3, the Office of Management and Budget released the Trump Administration’s Unified Agenda for 2026. The document, typically released once or twice a year, compiles all regulatory actions that an administration plans to take during the covered period. Consistent with President Trump’s aim of downsizing government, a large portion of the proposed rules reflect rollbacks of existing regulations. Many of these proposals would reverse important federal climate safeguards, including by reducing protections for federal lands; removing incentives for and imposing regulatory hurdles to the buildout of clean energy; and significantly scaling back air and water pollution limits.
This blog post highlights some of the most significant and potentially destructive proposals from the Unified Agenda—from a climate perspective. The Sabin Center’s Climate Backtracker provides a more comprehensive compilation of actions taken by the current Trump Administration to eliminate federal climate mitigation and adaptation measures, while the U.S. Climate Regulation Database provides an up-to-date resource for climate-related regulatory actions by federal agencies over the last several administrations.
DOI: Rescission of Conservation and Landscape Health Rule, RIN 1004-AF03.
On May 9, 2026, the Department of the Interior issued the Rescission of Conservation and Landscape Health Rule as a final rule. It went into effect on June 11 but was nonetheless included in the July 3 Unified Agenda. The rule revoked the 2024 regulation known as the Public Lands Rule, which required the Bureau of Land Management (BLM) to consider conservation and landscape health as an equivalent priority to other land uses like energy development and livestock grazing. It also allowed leasing of public land specifically for landscape restoration. The rescission of this rule removes restoration and mitigation leasing mechanisms, which allowed for environmental conservation to be weighed against extractive proposals. This, in turn, enables future extraction, creates a pathway for direct emissions, and disrupts the land’s ability to act as a carbon sink.
Although there have been no legal challenges to the final rule as of writing, litigation may follow. The rule may be contrary to the best reading of the Federal Land Policy and Management Act (FLPMA). As described in a comment by Clean Air Task Force, “the best reading of FLPMA includes conservation and compensatory mitigation in the statutory mission and authority of the BLM,” as indicated by consistent agency interpretations of the statute since its passage. The new rule may also be arbitrary and capricious under the Administrative Procedure Act (APA) because BLM failed to adequately justify it. As noted by a coalition of California-based nonprofits, the new rule reverses the Public Lands Rule “without any mention whatsoever about [BLM’s] serious concerns—announced only months prior and grounded in its own science—about building resilience, stemming degradation, and addressing the impacts of climate change on BLM public lands.” It further “contradicts factual findings that underlay the prior policy” without justification, per Clean Air Task Force, which suggests that BLM failed to adequately support its decision-making.
DOI: Rights-of-Way, Leasing, and Operations for Renewable Energy, RIN 1004-AF32.
The Department of the Interior proposed rescinding the Biden-era Rights-of-Way, Leasing, and Operations for Renewable Energy rule, which was issued on May 1, 2024. The Trump administration initially proposed rescission on May 14, 2025, though it has yet to publish the proposal in the Federal Register. The 2024 rule in part granted the Secretary of the Interior discretion to reduce rental rates and capacity fees for wind and solar providers, as was enabled by the Energy Act of 2020. Reversing the rule would raise acreage rents and capacity fees to pre-2024 levels, significantly raising costs for wind and solar projects on public land managed by the BLM and thus making the clean energy transition less cost-competitive in favor of oil and natural gas. The One Big Beautiful Bill Act, passed on July 4, 2025, already revoked the Secretary of the Interior’s authority to alter rates. Until the proposed rule is published, it is difficult to predict possible legal challenges.
DOI: Offshore Wind Regulatory Reform, RIN 1010-AE38.
Aligning with President Trump’s outspoken opposition to offshore wind projects, the Department of the Interior has proposed a rule that will include “revisions to the offshore wind regulations addressing bidding credits and financial assurance.” Details on the proposed rule are sparse, though DOI plans to publish a notice of proposed rulemaking in the Federal Register in August. It is poised to reform provisions of the Renewable Energy Modernization Rule, which planned to increase certainty and reduce costs for offshore wind projects by modernizing regulations, implementing a five-year leasing schedule, and investing in sustainable practices. Given that offshore wind projects require significant capital and multi-year development timelines, uncertainty and a lack of federal support would make it more difficult to develop these programs, codifying the administration’s aims of undercutting clean energy buildout. Earlier, in December 2025, a federal court voided President Trump’s executive order halting federal permitting and leasing for new offshore wind projects, finding that the ban was arbitrary and capricious and outside of the president’s authority. Instead, the Trump Administration has engaged in negotiations with energy companies to stop wind projects and fund fossil fuel projects, including with TotalEnergies and others. The administration has spent nearly $2 billion to cancel previously approved offshore wind leases, requiring developers to redirect that capital to oil and gas production.
DOI: Oil and Gas Leasing Rescission Rule, RIN 1004-AF05.
On June 24, the Bureau of Land Management published its intent to revise regulations around royalty allocations for oil and gas leases. The proposed rule would “reduce barriers” to oil and gas development on federal land and return minimum bond amounts to the levels prior to the passage of the Fluid Mineral Leases and Leasing Process Rule in 2024. The 2024 rule increased the minimum individual lease bond for oil and gas leases to $150,000 and the minimum statewide bond to $500,000. These bonds act as financial assurances that companies will abide by regulations to plug wells and restore the land after extraction, and can act as a deterrent against abandonment. They also provide BLM with funds to clean up extraction sites if companies declare insolvency. By returning individual lease bonds to $10,000 and statewide bonds to $25,000, the revised regulation would increase the risk of wells being abandoned by operators and increase the bureau’s burden to pay for reclamation. Given that unplugged oil and gas wells are a major source of methane, benzene, and other emissions, this change would represent a step backward in the management of greenhouse gas emissions.
Additionally, the proposed rule would shorten the public participation period from ninety days to ten days, eliminating two thirty-day public comment periods and shortening the final protest period from thirty days to ten. This would mean the public could no longer comment on leases before they are finalized. BLM claims that the change is aimed at “facilitating quicker decision-making, thus allowing for more timely access to resources.” Slashing the public comment period could result in more litigation related to these leases because there would be less opportunity to address concerns during the permitting process. Similar recent rollbacks of public participation periods under the National Environmental Policy Act (NEPA) have been challenged by environmental groups as arbitrary and capricious under the APA for failing to provide a reasoned explanation for the moves. If finalized, this rule may be challenged on similar grounds.
DOI: Royalty for Oil and Gas Lost from Onshore Federal and Indian Leases, RIN 1004-AF33.
The Department of the Interior proposed revising a 2024 rule to remove waste minimization requirements for oil and gas producers. The proposed rule would dramatically reduce oversight of flaring and venting activities by eliminating volume caps on gas flaring and expanding the definition of unavoidable losses, thus reducing royalty payments for these activities. By eliminating the requirement for waste-minimization plans and self-certifications for the venting and flaring of natural gas, this revision rolls back incentives that would have pushed producers to capture, rather than release, their emissions. Compounded with the decision to “streamline royalty determinations” on lost gas, which previously penalized flared or vented gas beyond a point, this would likely increase the share of vented gas and direct methane emissions from oil and gas wells.
If passed, the rule would potentially violate the DOI’s fiduciary duty to Indian tribes under the Mineral Leasing Act given the loss of revenue to tribes that would result from reduced royalties, according to one commenter. Additionally, it may be arbitrary and capricious under the APA because it fails to quantify the foreseeable impacts of emissions from increased flaring and venting activities, rendering its regulatory impact analysis incomplete.
EPA: Carbon Pollution Standards Repeal, RIN 2060-AW55.
In April 2024, the Environmental Protection Agency (EPA) issued the Carbon Pollution Standards (CPS), limiting greenhouse gas emissions from new and existing fossil fuel–fired power plants. The Trump Administration plans to repeal the rule this summer. The repeal will remove the requirement for coal- and gas-fired power plants to achieve a 90 percent reduction in their carbon emissions through carbon capture or other equivalent technology. The original rule was projected to create net climate and health benefits amounting to $370 billion, accounting for reduced climate change impacts and property damage, health improvements, increased agricultural productivity, and lowered risks of energy disruptions, conflict, and environmental migration. According to the EPA’s own Regulatory Impact Analysis (RIA), the repeal of this rule would increase emissions by 123 million metric tons by 2035 (Table 3-1), flattening the trajectory of a projected 73–86 percent emissions reduction below 2005 levels in the original plan. Additionally, the RIA predicts an increase in air pollution–related deaths (as many as 120 from ground-level smog and 1,100 from fine particulate matter in 2035), amounting to health costs of approximately $130 billion by 2047. The EPA did not provide monetary estimates of the costs of the new rule, but independent modelling predicts that increased emissions as a result of this new rule might translate into climate damages amounting to between $109 billion and $497 billion, depending on gas prices.
If the final rule conforms closely to the proposed repeal of the Carbon Pollution Standards, it may be challenged as an invalid interpretation of section 111(b)(1) of the Clean Air Act (CAA). As described in a public comment by the National Parks Conservation Association, Congress lays out a two-step process in parts (A) and (B) of CAA section 111(b)(1) to first identify and then control sources of air pollution. EPA’s proposed justification for the repeal relies on an incorrect interpretation of this and unlawfully inserts policy factors like cost and industry impact into the initial step, one that Congress intended to be based on purely scientific data and facts. EPA’s reliance on these economic considerations likely directly conflicts with the statutory definition of “public welfare” under CAA section 302(h), which encompasses climate and environmental impacts, not economic values from reliance on fossil fuels. Moreover, according to a comment from the Center for Biological Diversity and Food and Water Watch, if the EPA were to revoke the protections in section 111(d), it would trigger a mandatory obligation under CAA section 108 to classify greenhouse gases as a criteria pollutant and establish National Ambient Air Quality Standards (NAAQS). While this is one interpretation of the proposed repeal, commenters argue that it would form a more comprehensive regulatory regime than the previous one.
EPA: Reconsideration of Criteria Pollutant Standards for Light-Duty and Medium-Duty Vehicles, RIN 2060-AW96.
The EPA proposed this rule on May 18, 2026, to reconsider the Tier 4 criteria pollutant standards for new motor vehicles, extending the Tier 3 standards to a slew of vehicles. This revision would delay the implementation of Tier 4 vehicle emissions standards by two model years until 2029. Tier 4 standards, finalized by the EPA in 2024, place limits on air contaminants like nitrogen oxides, particulate matter, carbon monoxide and formaldehyde to manage air pollution and facilitate higher electric vehicle (EV) adoption. On its own, this delay increases air pollution in the short term and extends air pollution as manufacturers have no statutory obligation to reduce emissions immediately.
If the final rule adheres to the proposed rule, the delay of the Tier 4 emission standards may violate the statutory mandates of the CAA. As described in a comment by NRDC, under the Supreme Court’s ruling in Bowen v. Georgetown University Hospital, administrative agencies lack retroactive rulemaking authority unless explicitly granted by Congress, a grant not found in the text of the CAA. The proposed rollback would also likely violate the CAA’s anti-backsliding provision under 42 U.S.C. § 7521(b)(1)(C)—a provision that EPA has historically adhered to—which dictates that “[a]ny revised standard shall require a reduction of emissions from the standard that was previously applicable.” Furthermore, the proposed delay may be arbitrary and capricious under the APA given the EPA’s failure to provide a reasoned basis for its decision. Per a public comment by a coalition of state attorneys general and chief legal officers, the EPA relied on an unsupported narrative of a permanent downward shift in the EV market while ignoring readily available data on projected falling battery costs and increased gas prices, which would actually create upward shifts in the EV market. The proposal also unlawfully fails to analyze its impact on nonattainment areas, violating the CAA general conformity requirement, which “disallows federal agency action that would serve to undermine NAAQS air quality goals.” Finally, as noted in public comments by Our Children’s Trust and NRDC, the EPA lacks statutory authority to prioritize “consumer choice” over public health, and finalized action doing so would fail to “rationally balance the statutory factors it must consider under Section 202—including reducing dangerous emissions, technological feasibility, lead time, and costs.” In issuing the proposal, the EPA failed to explain its departure from the Tier 4 standards, consider public interests, or evaluate a range of reasonable alternatives.
EPA: Greenhouse Gas Reporting Rule Reconsideration, RIN 2060-AW76.
On September 9, 2025, the EPA proposed to amend the Greenhouse Gas Reporting Program (GHGRP) to remove program obligations for most source categories, suspending most obligations and delaying oil and gas methane reporting requirements until 2034. Established in 2009, the GHGRP provided decision-makers with accurate emissions data to guide policy, regulation, investment, and scientific innovation. The removal of this mechanism has far-ranging impacts on other laws; the Clean Air Act uses GHGRP data to evaluate performance standards; the Methane Emissions Reduction Program uses GHGRP data to determine fees and financial assistance for oil and gas methane emissions; and the Inflation Reduction Act uses GHGRP regulation to calculate tax credits for carbon storage. If reporting is indeed suspended until 2034, it will mean almost a decade-long blind spot during which climate action and mitigation are unable to proceed, and leaks go unidentified and unaddressed.
If finalized as proposed, the rule would likely incorrectly assert that EPA lacks authority to collect GHGRP data under CAA section 114(a)(1), running contrary to the best reading of the statute. A public comment by the Environmental Defense Fund (EDF) explains that Congress has mandated that EPA develop and implement the GHGRP in several acts: in both the Consolidated Appropriations Act of 2008 and the Omnibus Appropriations Act of 2009, Congress provided funds for requiring mandatory reporting of greenhouse gas emissions. These Congressional appropriations exemplify the broader authority EPA has to collect GHGRP data, and the “legislative history demonstrates that both Congress and EPA viewed the directive as a permanent mandate.” As noted by David Doniger, a senior attorney at NRDC, this legislation established a permanent mandate, clearly anticipating a program to operate beyond those specific years. Furthermore, the proposed rollback may also be arbitrary and capricious under the APA given that the EPA’s proposal lacks any reasoned factual justification for its determination that the GHGRP is unnecessary. In its current proposal, EPA has failed to support its claim that the necessary information can be obtained from other sources, failed to justify its change in position on the program’s costs, did not adequately consider regulatory alternatives, and ignored the harms to established reliance interests.
DOE: Interim Final Rule on Energy Dominance Financing, RIN 1901-AB72.
On October 28, 2025, the Department of Energy issued an interim final rule amending its loan guarantee regulations to implement the Energy Dominance Program contained in the One Big Beautiful Bill Act. The comment period officially closed on December 29, 2025, and DOE’s next steps is to review and consider the submitted comments to eventually issue their final rule. The original rule required that federal energy infrastructure loan guarantees be conditional on the reduction of air pollution or greenhouse gas emissions, while the new rule facilitates coal and fossil fuel projects by removing the criteria requiring projects to “avoid, reduce, utilize, or sequester air pollutants or anthropogenic emissions.” As such, federal funds can now be directed toward the construction of fossil fuel infrastructure, undermining commitments to emissions reduction.
Although the interim rule has not been formally challenged, DOE’s June announcement of a conditional loan commitment under the new interim rule will likely trigger litigation. The interim final rule may be most vulnerable to a challenge under the APA. The interim rule likely incorrectly asserts that the Department of Energy has good cause to bypass standard notice-and-comment requirements, as is necessary under the APA. A public comment by Citizens Rulemaking Alliance highlights that the rule “addresses longstanding policy issues rather than a sudden, unforeseen emergency.” There were also several delays in developing the amendments, revealing that there was adequate time to have conducted a proper notice-and-comment period. Furthermore, as described by Citizens Rulemaking Alliance, the rule may also be challenged under the Regulatory Flexibility Act (RFA), which requires an initial analysis at proposal and a final analysis at adoption unless the head of the agency can certify that the rule “would not have significant economic impact on a substantial amount of small entities.” It is foreseeable that a number of entities would be affected by this change, including energy developers, contractors, technology vendors, and financial institutions that participate in energy-related credits. The Department of Energy failed to show any adequate analysis.
USDA: Oil and Gas Resource Revision, RIN 0596-AD33.
Effective February 27, 2026, the United States Department of Agriculture (USDA) revised its regulations regarding National Forest System oil and gas resources. This final rule, included in the July 3 Unified Agenda, consolidates the Forest Service and BLM’s environmental review processes with the goal of improving efficiency and accelerating permitting across oil and gas resources on National Forest System lands. According to the USDA, there are currently 5,154 federal oil and gas leases over 3.8 million acres, of which approximately 2,850 currently contain oil and gas wells. By facilitating permitting, this new rule will bring more wells into production sooner. It will likely lead to a cumulative increase in emissions; adverse consequences to ecosystem health, wildlife, and public health; and decreased carbon sequestration capacity on forested land.
Although the final rule has not faced formal legal challenges yet, litigation is likely to follow. The final rule appears to directly violate NEPA, which mandates that federal agencies accompany recommendations on major federal actions affecting the quality of the human environment with a detailed statement discussing “the environmental impact of the proposed action.” NEPA also dictates that agencies are required to take a “hard look” at the environmental consequences, assessing impacts and effects, including “ecological, aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative.” Here, the Forest Service failed to evaluate reasonable alternatives and take any adequate look at the impacts on climate, wildlife, or water resources. In addition, the rule is likely arbitrary and capricious under the APA. According to a public comment by the National Audubon Society, the agency’s cost-benefit analysis highlighted only de minimis administrative savings—savings which amount to a mere 1–4 percent of the cost to drill a single well—while excluding significant environmental costs. The rule fails to provide a reasoned explanation of these costs and benefits.
Conclusion
The 2026 Unified Agenda represents a stark rollback of federal climate regulation and threatens significant environmental safeguards. It includes proposals to remove protections for public lands, eliminate incentives for green energy production, and remove protections for clean air and water, among many others. Many of these regulations may be vulnerable to legal challenges, including violations of environmental statutes and the APA. The Sabin Center will continue tracking these proposals throughout the rulemaking process and any legal challenges that arise.
Peter Kranitz
Ananya Srinivas
