On March 12, 2025, the U.S. Environmental Protection Agency (“EPA”) announced its deregulatory agenda.[1] Although most of the 31 actions identified by the EPA will require formal notice and comment rulemaking, with litigation ensuing, Wednesday’s announcement makes good on the Trump Administration’s promises to roll back environmental regulation.[2]

Of particular significance to the

President Obama’s centerpiece of his climate policy agenda, the “Clean Power Plan,” has become one of the most heavily litigated environmental regulations ever. Twenty-seven states and numerous industry groups have filed more than fifteen separate lawsuits challenging the Environmental Protection Agency’s (“EPA”) statutory authority to promulgate the regulations.   Seventeen states, the District of Columbia, the