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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 May 16, 2025, the Texas Supreme Court issued a decision ruling that, absent specific contractual language, surface owners retain ownership of the caverns created by salt mining operations.

In the first major National Environmental Policy Act (“NEPA”) case to reach the Supreme Court in almost two decades, the U.S. Supreme Court issued its decision on May 29, 2025, in Seven County Infrastructure Coalition v. Eagle County, Colorado.

On May 1, 2025, the federal government brought separate suits against both New York and Vermont alleging that these state’s “climate Superfund” statutes are unconstitutional on multiple grounds.

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.

On March 14, 2025, President Trump signed legislation disapproving the Environmental Protection Agency’s regulation implementing the Inflation Reduction Act’s tax on methane emissions from the oil and gas sector.