The US administration recently published its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, providing an overview of the federal regulatory priorities over the next several months. The agenda reflects the administration’s objective of rolling back US Environmental Protection Agency rules the administration perceives as burdensome to industry, hindering economic growth, and stifling innovation and competition, but it also introduces new proposed regulations, identifies ongoing environmental regulatory efforts, and retains some Biden-era proposals.
The proposed actions of the US Environmental Protection Agency (EPA) in the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions (Unified Agenda) are broad, touching upon areas of climate, air, water, and chemicals (including per- and polyfluoroalkyl substances (PFAS)) under nearly all major environmental statutory and permitting regimes. These actions are expected to have significant and far-reaching impacts on the nation’s environmental regulatory landscape and on regulated communities. Several notable aspects of the agenda are discussed herein.
Greenhouse Gas Endangerment Finding
EPA expects to issue a final rule in September to repeal the 2009 Greenhouse Gas (GHG) endangerment finding, the landmark Obama-era finding that the combined atmospheric concentrations of six greenhouse gases constitute "air pollution which may reasonably be anticipated to endanger public health and welfare.” The endangerment finding has been foundational to EPA’s regulatory approach to GHGs, acting as the legal basis for EPA’s regulation of GHGs, and directly influenced climate-related policy and litigation.
The proposed rule to repeal the endangerment finding was first published in July 2025, with the public comment period closing on September 22, 2025. The Unified Agenda reflects EPA’s objective to finalize that rulemaking this month.
Greenhouse Gas Reporting
The White House is actively reviewing proposals to reduce annual greenhouse gas reporting requirements for various industrial sectors, including power plants, oil refineries, coal mines, and manufacturers of petrochemicals, cement, glass, iron and steel. The reporting rule for non-oil-and-gas sectors is currently under review by the White House, and a final rule is anticipated in November 2025.
Emissions Standards
EPA announced a slew of planned national emission standards-related deregulatory actions, from compliance deadline extensions to relaxed emissions standards, that will impact a number of sectors and industries, including oil and gas, waste management, manufacturing, agriculture, chemicals, tire and rubber manufacturing, and commercial sterilization sectors, among others.
Relaxed rules affecting the oil and gas sector from the previous administration—including regulations for methane and volatile organic compounds (VOCs) from the oil and gas sector, revisions to the GHG Reporting Program Subpart W, and the Waste Emissions Charge in the Inflation Reduction Act—appear in the Unified Agenda. The Unified Agenda further includes intended air toxics emissions standards rollbacks for ethylene oxide (EtO), mercury, hydrogen chloride, and hydrogen fluoride.
Cross-State Emissions
EPA intends to replace the now-defunct Biden-era 2023 “Good Neighbor” plan, which aimed to limit smog-forming emissions that cross state lines under the 2015 ozone National Ambient Air Quality Standards, with a new two-step process. The “Good Neighbor” program intended to require 23 states to reduce emissions of nitrogen oxides (NOx) from power plants and other industrial sources to help downwind states achieve air quality standards for ozone. The Trump EPA believes that the 2023 rule impermissibly expanded federal rules to states and sectors “beyond the program’s traditional focus and led to the rejection of nearly all State Implementation Plans.”
EPA will also replace a stricter annual soot standard issued under the Biden administration. A final version of the relaxed standard is expected in February 2026, with a proposed rule expected in the fall.
EPA identified sweeping rollbacks of various Biden-era Clean Water Act (CWA) rules that will impact a wide array of industries, including coal-fired power generators, steel mills, copper smelters, lime manufacturers, and bulk gasoline terminals.
Coal Power Plant Rules
EPA plans to revise a rule issued under the Biden administration that required coal power plants to install more advanced water pollution controls, with a proposed rule expected in November. Under the previous administration, EPA required power plant owners to virtually eliminate heavy metals and other harmful pollutants from three major waste streams through the installation of new technologies. Regulated entities had until 2029 to comply, or notify EPA by December 31, 2025 that they would permanently stop burning coal by 2034. The current EPA plans to extend those deadlines.
Waters of the United States (WOTUS) Rule
A proposed rule narrowing the scope of the CWA would restrict the types of water bodies regulated under the act and is expected to limit federal regulation of wetlands and small streams. Until a final rule is implemented or additional action taken, EPA and the US Army Corps of Engineers (Corps) continue to follow the EPA and Corps’ joint March 2025 interim guidance regarding the definition of “waters of the United States.”
Section 401 Revision
EPA is also expected to roll back requirements under CWA Section 401, which requires applicants for a federal permit that may result in a discharge to “waters of the United States” to obtain a certification from the relevant state or tribe that the discharge will comply with state water quality standards. According to the agenda, the Clean Water Act Section 401 Water Quality Certification Improvement Rule will “increase transparency, efficiency, and predictability” for states and energy companies seeking permits. The proposed rule is expected in December 2025.
The US Administration is expected to pursue a number of Biden-era policies impacting PFAS, or “forever chemicals.” Plans are underway to finalize CWA regulations for monitoring and reporting PFAS in wastewater discharges, as well as to finalize effluent limitation guidelines (ELGs) for chemical manufacturers. Other rules are expected to be narrowed and deadlines extended.
Safe Drinking Water Act
As previously announced by the agency, EPA is expected to retain the enforceable four parts per trillion maximum contaminant levels (MCLs) for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) under the Safe Drinking Water Act (SDWA). However, it will propose a rule by October 2025 to extend the compliance deadline for water systems by an additional two years, with a final rule expected by April 2026.
EPA also intends to propose a rule in September 2025 to withdraw its regulatory determinations to regulate four PFAS (perfluorohexane sulfonic acid (PFHxS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid and its ammonium salt (HFPO-DA, commonly known as GenX), and the mixture of these three PFAS plus perfluorobutane sulfonic acid (PFBS)) under the SDWA, and to rescind all associated regulatory provisions. This rule is expected to be finalized by February 2026.
The Unified Agenda also includes plans to finalize two Biden-era Toxics Release Inventory (TRI) PFAS rules, as well as a rule that would add 16 individual PFAS and 15 PFAS categories to the TRI.
EPA is also eyeing a more relaxed PFAS TSCA Section 8(a)(7) reporting rule. On August 9, it submitted the “Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation” to the US Office of Management and Budget. The rule aims to roll back a Biden-era PFAS reporting regulation under TSCA that required manufacturers and importers to submit information on their PFAS production volumes, disposal, exposures and hazards as far back as 2011, for both chemicals and articles.
EPA plans to propose a rule in December 2025 to incorporate “certain exemptions and other modifications to the scope of the [TSCA PFAS] reporting rule,” which is expected to be finalized by June 2026. EPA also delayed the start of the reporting period, which will now begin on April 13, 2026 and end on October 13, 2026 for most regulated parties. EPA cited the need to prepare the Central Data Exchange (CDX) reporting system as the reason behind the delayed reporting requirement.
The Unified Agenda also includes proposals to finalize the pending rules for regulation of nine PFAS as “hazardous constituents” under the Resource Conservation and Recovery Act (RCRA), together with the associated rule definition amendments (to modify the regulations to confirm with the statutory definitions and EPA practice), both by April 2026. Notably absent from the Unified Agenda is any reference to rulemaking relating to the designation of PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act. Refer to our May 16 LawFlash for more information about EPA’s PFAS agenda.
The Unified Agenda is largely deregulatory and underscores this administration’s actions to support US industry, with initial counts indicating EPA has the fourth most deregulatory actions of all federal agencies. EPA’s Unified Agenda items largely align with prior deregulatory announcements from EPA since January and are in line with various environmental and energy executive orders signed by the president during his first weeks in office aimed at unleashing US energy, lowering the cost of living for US families, and advancing cooperative federalism. Some of the new proposed rules included in the Unified Agenda also are deregulatory in nature because they seek to reverse prior rulemakings through the rulemaking process.
Rollbacks of EPA regulations, such as the Section 401 revision and narrowed WOTUS rule, will result in both the streamlining of the federal permitting process through the reversal or elimination of permitting hurdles and the need for fewer required federal permits. Fewer restrictions on air emissions and water discharges will ease regulatory burdens on all manner of industry, including stationary energy generation sources such as power plants and mobile sources, including vehicles and aircraft. Relaxed endangered species protections and eased leasing requirements are also expected to hasten domestic energy exploration and production.[1]
In all, these identified actions, which include completed, ongoing, and long-term rulemakings (i.e., those anticipated to be on a 12-month time horizon or longer), will have a resounding impact across industries. It will be imperative for stakeholders and members of the regulated communities to continue to monitor regulatory developments and related rulemaking activities. Interested parties should also take notice of stated rulemaking timelines included in the Unified Agenda, as these proposed deadlines (while not set in stone) are instructional. It can also be expected that these actions will spur challenges and litigation. Stakeholders should consider options for participation in the rulemaking process, such as through direct submission of comments in response to the rulemaking, or indirect participation through industry groups or other channels.
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[1] In addition to the EPA actions, other federal agencies’ proposals and revisions also impact oil and gas activities. The US Department of Interior (DOI), for instance, is easing federal restrictions on the take of protected and endangered species in oil and gas exploration and extraction sites, including the Southern Beaufort Sea, Kodiak, Alaska, and Seward, Alaska. Another DOI proposed rule would ease the Bureau of Land Management’s leasing and bonding requirements for oil and gas development and production.