PUTTING AMERICA FIRST IN INTERNATIONAL ENVIRONMENTAL AGREEMENTS

Similar to Trump’s first term, he has taken action to withdraw the United States from international environmental agreements.

This order directed the immediate withdrawal from the Paris Agreement under the United Nations Framework Convention on Climate Change. It also calls for withdrawal from any agreement, pact, accord, or similar commitment made under the United Nations Framework Convention on Climate Change.

It is unclear at this point whether the Trump Administration will move to roll back actions taken under the AIM Act to phase down HFCs, consistent with the Kigali Amendment to the Montreal Protocol. The Aim Act had bipartisan support when it passed Congress, and several key rules, such as the Technology Transitions Rule, have been finalized for some time. However, a recently enacted rule entitled Management of Certain HFCs and Their Substitutes Under the AIM Act is still currently in the window for potential cancellation under the Congressional Review Act (CRA). The CRA is a tool that allows Congress to cancel regulations finalized within a certain timeframe. Passage requires a simple majority in the House and Senate and presidential signature. CRA’s use has historically come after a change in administration, such as the current situation.

REGULATORY FREEZE AND UNLEASHING PROSPERITY THROUGH DEREGULATION

As is typical of incoming administrations, Trump has placed a temporary freeze on rulemaking activity. He has directed agencies not to propose or issue any rule in any manner until a department or agency head appointed or designated by the President reviews and approves the rule. Any rules sent to the Federal Register under the Biden Administration but not published were Immediately withdrawn for review. Any rules published but that had not taken effect were postponed to review any questions of fact, law, and policy that the rules may raise.

In addition to a temporary freeze, Trump issued an order stating that it is the policy of his Administration to significantly reduce the private expenditures required to comply with Federal regulations to secure America’s economic prosperity and national security and the highest possible quality of life for each citizen. To that end, it will be the policy of the Trump Administration that for each new regulation issued, at least 10 prior regulations be identified for elimination. The new practice is intended to ensure that the cost of planned regulations is responsibly managed and controlled through a rigorous regulatory budgeting process. Going forward, whenever an agency publicly proposes a new regulation, it shall identify at least 10 existing regulations to be repealed. Further, heads of all agencies have been directed to ensure that the total incremental cost of all new regulations, including repealed regulations, being finalized this year, shall be significantly less than zero, as determined by the Office of Management and Budget. The new policy may be used by agencies such as EPA to roll back regulations instituted during the Biden Administration, such as the Safer Communities by Chemical Accident Prevention, which amended the Risk Management Program.

DEPARTMENT OF GOVERNMENT EFFICIENCY

Trump has created a new Department of Government Efficiency (DOGE), led by Elon Musk, to identify ways to make the government more efficient and reduce federal expenditures. DOGE is placing personnel in all federal Departments and reviews of spending are currently underway. Trump placed a blanket freeze on federal programs, which was challenged in court and subsequently withdrawn. However, some programs remain frozen and DOGE has already identified a significant number of programs for cancellation.

HIRING FREEZE, RETURN TO WORK AND REDUCTION IN FEDERAL WORKFORCE

The Trump Administration is taking aggressive steps to transform the federal workforce beginning with a hiring freeze and mandating that all workers return to the office in-person. Heads of all departments and agencies in the executive branch of Government are directed to take all necessary steps to terminate remote work arrangements and require employees to return to work in-person at their respective duty stations on a full-time basis.

In an effort to reduce the federal workforce, the Office of Personnel Management sent federal employees a buyout offer allowing them to resign immediately and retain their pay and benefits through September 30, 2025. It has been reported that approximately 75,000 employees (roughly 3% of the federal workforce) accepted the offer. Once the offer closed, agencies began to implement “reductions in force,” starting with probationary employees. The total number of employees being targeted for reduction is not clear at this time, but Administration officials have indicated that further efforts to reduce the workforce are expected. Once the hiring freeze is lifted, agencies will be permitted to hire no more than one employee for every four employees that depart. Changes to the federal workforce could impact how regulatory agencies conduct enforcement and engage with industry.

TARIFFS

Another policy area that has been subject to numerous executive actions is the use of tariffs. During the campaign, Trump indicated his intention to utilize tariffs to achieve policy goals as well as rebalance what he sees as unfair trade relationships. Trump has ordered 25 percent tariffs on Canada and Mexico to pressure them to focus more resources on border security and addressing fentanyl trafficking. Those tariffs were paused for 30 days as both countries committed to dedicating additional resources to the border. China has also been hit with an additional 10 percent tariff on imports, citing its role in the production and movement of fentanyl. New 25 percent tariffs have also been placed on all aluminum and steel imports, similar to a move Trump made during his first term. Trump is also taking action to implement reciprocal tariffs on countries that are currently placing tariffs on American goods. Depending on the duration of the tariffs and expected retaliatory measures taken by trading partners, it is expected that inflationary pressures will mount. This could impact food prices, materials needed for construction, and a variety of other goods.

While it is too early to know the longer-term impacts of Trump’s early executive actions, it is clear that his administration is working to transform how the federal government does business. IIAR will continue to keep members updated as policies and actions evolve.