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Vinson & Elkins is pleased to offer this round-up of recent developments in federal enforcement, with a particular emphasis on changes during the first few months of the second Trump administration.

This session will explore how rising global tariffs—and those proposed by the Trump administration—are affecting the U.S. energy and infrastructure sectors.

On August 22, 2025, the Environmental Protection Agency (“EPA”) announced decisions on 175 small refinery exemption (“SRE”) petitions stretching back over the last four years.

On July 3, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”), the U.S. Army Corps of Engineers (“Army Corps”), and the Departments of Energy (“DOE”), Interior (“DOI”), Transportation (“DOT”), Agriculture (“USDA”), and Defense (“DOD”) released sweeping updates to their regulations and procedures implementing the National Environmental Policy Act (“NEPA”).

The federal government is continuing to implement President Donald Trump’s Unleashing American Energy mandate to promote domestic energy and infrastructure projects.

On June 17, 2025, the U.S. Environmental Protection Agency (“EPA”) published its proposed “Set 2” rule under the Renewable Fuel Standard (“RFS”) program (the “Set 2 Rule”).

On June 17, 2025, the U.S. Environmental Protection Agency (“EPA”) published a proposed rule that, if finalized, would repeal all greenhouse gas (“GHG”) standards for the power sector.

On June 17, 2025 the U.S. Environmental Protection Agency (“EPA”) published a proposed rule to repeal the amendments to the Mercury and Air Toxics Standards (“MATS”) adopted by the Biden administration in 2024.

This week, the U.S. Environmental Protection Agency (EPA) took the penultimate step to granting Texas the authority to directly issue Class VI permits under the Safe Drinking Water Act’s Underground Injection Control (UIC) program for carbon capture and sequestration (CCS) projects when it proposed to approve the State’s primacy application.

On April 11, 2025, the Marine Environment Protection Committee (“MEPC”) of the International Maritime Organization (“IMO”) announced the approval of a long-awaited framework to reduce greenhouse gas (“GHG”) emissions from the international shipping industry to further the IMO’s carbon intensity reduction goals.

On April 8, 2025, President Trump issued an Executive Order titled “Protecting American Energy From State Overreach” (the “Executive Order”), which directs the United States Attorney General to identify and halt the enforcement of state laws and civil actions that burden energy production and may be preempted by Federal law or are otherwise unconstitutional.

A series of recent actions undertaken by President Biden, near the end of his term, and President Trump, in the early days of his presidency, have called into question a key issue under the Outer Continental Shelf Lands Act (“OCSLA”) — whether the President can revoke a previous President’s withdrawal of areas of the United States Outer Continental Shelf (“OCS”) from oil and gas leasing.