A documented analysis of both Trump administrations
Coverage
January 20, 2017 to January 20, 2021
January 20, 2025 to September 20, 2026
Prepared for Judith Polich
Main conclusion The two administrations repeatedly converted private compliance savings into public costs. The most defensible quantified subtotal for a limited set of second-term rollbacks is about $156.6 billion in annual net benefits at risk. It excludes many water, biodiversity, toxic-exposure, public-land, enforcement and institutional harms and therefore should not be treated as the total environmental cost.
Important limitation This report does not put a price on extinction, sacred sites, cultural continuity or the loss of scientific knowledge. Dollar estimates are reported only when an agency or credible model supplies a traceable basis.
These 50 actions are selected for the scale, duration or irreversibility of their likely harm. They are numbered for reference, not ranked from worst to least bad. The list includes completed repeals, rules later reversed, pending proposals and institutional actions. Legal status is current to September 20, 2026.
| Finding | Evidence |
| A conservative second-term subtotal | $156.6 billion in annual net benefits at risk; $17.1 billion in consumer savings, $22.3 billion in health benefits and $122.3 billion in climate benefits at risk. Categories overlap within rule-level net calculations, so they should not be casually added again. |
| Health consequences | About 3,299 premature deaths, 7,461 new childhood asthma cases, 3,922 hospital or emergency admissions, 139,415 missed workdays and 320,260 missed school days annually in the covered subset. |
| Largest measured action | Repeal of model-year 2027-and-later light and medium duty vehicle standards: about $101.9 billion in annual net benefits at risk. |
| Major legislative shock | The 2025 reconciliation law puts more than $500 billion in clean-energy and transportation investment at risk and could raise average household energy bills by $78-$192 in 2035. |
| Who benefits | Fossil-fuel producers, high-emitting facilities, developers and regulated firms receive near-term compliance relief, access or delay. Benefits are usually concentrated among a relatively small number of firms. |
| Who pays | Households, children, downwind and fenceline communities, Tribes, water systems, states, future taxpayers and species bear dispersed health, climate, cleanup, cultural and ecological costs. |
How to read the dollar figures
- Net benefits at risk means the public benefits of a rule minus its compliance costs, using the underlying regulatory analysis and inflation adjustments. It is not the same as federal spending.
- Industry compliance savings are real but are not automatically a net social benefit. When a polluter avoids a control and the public receives more illness or climate damage, cost has been shifted rather than eliminated.
- Annual estimates should not be multiplied mechanically forever. Rules have different start years, lifetimes, baselines and overlaps. A present-value calculation requires year-by-year modeling that is beyond what the published record supports for all 50 actions.
- Unquantified does not mean zero. Biodiversity, cultural resources, cumulative toxic exposure and ecological tipping risks are routinely omitted because they are difficult to monetize.
Recurring distributional pattern
The gains are generally immediate and concentrated: avoided capital spending, fewer inspections, more land or water access, or expanded sales of fuel and commodities. The losses are delayed, dispersed and often involuntary: more medical care, higher fuel or electricity use, contaminated water, disaster exposure, lost wildlife, cleanup liabilities and diminished options for future generations. This mismatch explains why a rollback can be profitable to its direct beneficiary while economically harmful to the country.
The 50 actions
1 Withdrawal from the Paris climate agreement in the first term
Climate and energy | 2017-2021
What happened
Trump announced withdrawal in 2017; it became effective on November 4, 2020. The act removed the federal government from the principal global framework for ratcheting down national greenhouse-gas commitments and weakened U.S. diplomatic leverage. [3,4,9,13]
Dollar cost and time horizon
No single defensible dollar figure isolates this decision from domestic rollbacks. Its cost is the portion of added U.S. and global climate damage attributable to slower mitigation and weakened international cooperation. Even small changes in global emissions create damages lasting centuries. [3,4,9,13]
Future generations and species
Future Americans inherit higher adaptation, disaster, insurance, health, water and ecosystem costs. Warming increases extinction risk, shifts ranges, acidifies oceans and compounds habitat loss; polar, alpine, coral and drought-sensitive species are especially exposed. [3,4,9,13]
Litigation status
No live merits lawsuit could compel continued treaty participation; foreign-affairs authority made judicial relief unlikely. The United States rejoined in 2021, so the first withdrawal is completed history. [3,4,9,13]
Who benefits and who pays
Coal, oil and gas producers gained political protection against stronger federal climate constraints. Short-run compliance savings were concentrated; climate damages were dispersed globally and over time. [3,4,9,13]
2 Repeal of the Clean Power Plan and substitution of the Affordable Clean Energy rule
Climate and air | 2017-2021
What happened
EPA repealed the Obama Clean Power Plan and replaced it with a narrow plant-by-plant heat-rate rule that did not require broader generation shifting. [4,5,6,7,14]
Dollar cost and time horizon
EPA’s own 2018 analysis projected that the weaker approach could cause up to roughly 1,400 additional premature deaths annually by 2030 under some comparisons, plus thousands of asthma attacks and lost workdays. The original plan had projected up to $45 billion in annual climate and health benefits in 2030. [4,5,6,7,14]
Future generations and species
Added carbon persists for decades to centuries; co-pollutants damage lungs now. Aquatic and terrestrial species face climate-driven range loss and pollution deposition. [4,5,6,7,14]
Litigation status
The D.C. Circuit vacated the ACE rule in 2021. In West Virginia v. EPA (2022), the Supreme Court nevertheless used the dispute to restrict EPA’s ability to mandate generation shifting under the major-questions doctrine. ACE itself is no longer operative, but the legal constraint persists. [4,5,6,7,14]
Who benefits and who pays
Coal generators and coal suppliers avoided pressure to retire or dispatch less. Benefits were strongest for relatively high-emitting plants; downwind communities bore much of the health burden. [4,5,6,7,14]
3 Rollback of passenger vehicle greenhouse-gas and fuel-economy standards
Climate and transportation | 2017-2021
What happened
The 2020 SAFE Vehicles Rule weakened model-year 2021-2026 standards and revoked California’s waiver authority, slowing fleet efficiency gains. [4,5,8,23]
Dollar cost and time horizon
The administration claimed lower new-car prices, but its own analysis showed substantially more fuel consumption. Independent analyses found consumers would pay more for gasoline over vehicle lifetimes; net effects depended heavily on fuel prices and contested safety assumptions. [4,5,8,23]
Future generations and species
Extra gasoline combustion raises carbon, particulate precursors and ozone-forming pollution for years because vehicles remain in the fleet. Climate and air-pollution burdens fall on children and roadside communities; wildlife bears indirect climate and habitat costs from oil production. [4,5,8,23]
Litigation status
California and environmental groups sued. The Biden administration restored stronger standards and California authority, mooting or resolving most first-term litigation. The regulatory conflict returned in the second term. [4,5,8,23]
Who benefits and who pays
Automakers gained short-term compliance flexibility and petroleum refiners gained fuel sales. Buyers of inefficient vehicles could face lower upfront prices but higher lifetime fuel expense. [4,5,8,23]
4 Rollback of methane standards for new oil and gas facilities
Climate and air | 2017-2021
What happened
EPA removed transmission and storage segments and rescinded federal methane limits for portions of the oil and gas industry, relying more heavily on volatile-organic-compound controls. [3,4,22,23]
Dollar cost and time horizon
EPA described industry savings, while foregone methane reductions carried much larger climate consequences when methane’s near-term warming power is counted. Lost saleable gas partly offsets compliance costs, so avoided cost is not the same as social benefit. [3,4,22,23]
Future generations and species
Methane accelerates warming over the next several decades; associated toxic and smog-forming emissions affect nearby residents. Species in rapidly warming Arctic, alpine and freshwater systems face heightened risk. [3,4,22,23]
Litigation status
States and groups challenged the rule, but Congress used the Congressional Review Act in 2021 to disapprove it. The first-term rollback cannot be reissued in substantially the same form without new authority; later EPA rules created a new dispute. [3,4,22,23]
Who benefits and who pays
Oil and gas operators, particularly firms with older or leakier equipment, avoided monitoring and repair expenses. Communities near wells and compressor stations lost protection. [3,4,22,23]
5 Weakening of the Bureau of Land Management methane waste rule
Climate public lands and revenue | 2017-2021
What happened
Interior suspended and then replaced requirements limiting venting, flaring and leaks from oil and gas operations on federal and Tribal lands. [1,3,4,23]
Dollar cost and time horizon
The rule was designed to conserve publicly owned gas and increase royalty receipts as well as cut pollution. Avoided operator compliance costs were offset by wasted product, foregone public royalties and climate and health damages. [1,3,4,23]
Future generations and species
Methane’s early warming effects burden people alive today and lock in later ecosystem change. Flaring and co-pollutants affect nearby Tribal and rural communities and habitat. [1,3,4,23]
Litigation status
Federal courts repeatedly rejected delay efforts; a California court vacated the replacement rule in 2020. A later Wyoming ruling invalidated the 2016 rule, and BLM adopted a new rule in 2024, now targeted again. [1,3,4,23]
Who benefits and who pays
Federal lessees with high leak or flare rates benefited. Taxpayers, states, Tribes and future generations lost gas value and royalties. [1,3,4,23]
6 Lifting the federal coal leasing moratorium
Climate public lands and water | 2017-2021
What happened
Interior ended the pause on new federal coal leasing without completing the programmatic review intended to examine climate impacts and whether royalty rates compensated the public. [1,4,23]
Dollar cost and time horizon
Near-term beneficiaries gained access and avoided delay. Public costs include carbon damages, mine reclamation risk, water impacts and potentially below-market returns; an exact increment depends on leases and production actually induced. [1,4,23]
Future generations and species
Coal combustion creates long-lived carbon and toxic pollution; mines fragment sagebrush and grassland habitat and can impair streams for decades. [1,4,23]
Litigation status
A district court found Interior had failed to conduct adequate NEPA review. Later administrations reinstated and altered the leasing posture; litigation over subsequent leasing and program decisions continues in different forms. [1,4,23]
Who benefits and who pays
Coal companies, railroads and coal-dependent utilities benefited. Taxpayers assumed market, reclamation and climate risk, while mining communities remained exposed to boom-bust cycles. [1,4,23]
7 Opening the Arctic National Wildlife Refuge coastal plain to oil leasing
Climate biodiversity and Indigenous rights | 2017-2021
What happened
The 2017 tax law mandated leasing and the administration completed a rushed program and January 2021 lease sale covering the refuge’s coastal plain. [1,23,30]
Dollar cost and time horizon
The sale generated only about $14.4 million in bids, far below earlier federal revenue expectations. Potential spill, infrastructure, climate and subsistence costs were not captured by bid revenue. [1,23,30]
Future generations and species
Roads, seismic work and drilling threaten polar bears, migratory birds and the Porcupine caribou herd, with consequences for Gwich’in culture and food security. Damage to tundra can persist for generations. [1,23,30]
Litigation status
The Biden administration suspended leases and later canceled seven; litigation followed. The second Trump administration reopened the program, making current challenges distinct from the first sale. [1,23,30]
Who benefits and who pays
Leaseholders and Alaska state entities sought future petroleum revenue. The first sale’s weak bidding suggests private expectations were limited; ecological and cultural risks remained public. [1,23,30]
8 Attempted expansion of offshore oil and gas leasing
Oceans climate and spill risk | 2017-2021
What happened
The administration proposed opening nearly all federal offshore areas and reversed Obama-era withdrawals for parts of the Arctic and Atlantic, although many sales never occurred. [4,23]
Dollar cost and time horizon
Potential bonus bids and royalties were emphasized; omitted or uncertain costs include catastrophic spill risk, routine pollution, fisheries and tourism losses, and carbon damages. Expected cost cannot be reduced to a single figure without a specific leasing and production scenario. [4,23]
Future generations and species
Offshore infrastructure and spills threaten marine mammals, seabirds, corals, fish nurseries and coastal wetlands. Carbon from new reserves shifts costs to future generations. [4,23]
Litigation status
A federal court held that the president lacked authority to revoke prior Outer Continental Shelf withdrawals; the Ninth Circuit later dismissed the appeal after a change in policy. Specific lease-sale cases had mixed outcomes. [4,23]
Who benefits and who pays
Oil producers, drilling contractors and some coastal governments stood to gain. Fishing, tourism, subsistence users and the public carried spill and climate risks. [4,23]
9 Revival of the Keystone XL pipeline permit
Climate water and land | 2017-2021
What happened
Trump issued a presidential permit for the cross-border pipeline intended to carry Canadian oil sands crude to Nebraska and onward to Gulf refineries. [1,4,23]
Dollar cost and time horizon
The project was valued at roughly $8 billion, but that is investment, not social benefit. Costs included spill risk, eminent-domain conflict and the climate effects of facilitating high-carbon oil; causation depended on alternative transport and oil-market response. [1,4,23]
Future generations and species
Pipeline crossings threatened rivers, wetlands and habitat. Oil-sands emissions would contribute to long-term warming; Indigenous communities faced cultural and water risks. [1,4,23]
Litigation status
Courts blocked streamlined permitting, including Nationwide Permit 12 use. President Biden revoked the permit in 2021; the developer canceled the project and domestic litigation was dismissed. No current project remains. [1,4,23]
Who benefits and who pays
The developer, construction firms, shippers and oil-sands producers expected gains. Landowners and Tribes bore route-specific risks; the climate burden was diffuse. [1,4,23]
10 Approval and defense of the Dakota Access Pipeline crossing
Water Tribal rights and oil infrastructure | 2017-2021
What happened
The administration directed expedited approval of the Lake Oahe easement and allowed operation without a full environmental impact statement. [1,23]
Dollar cost and time horizon
The pipeline’s private capital value and shipping savings do not measure public welfare. Expected costs include spill probability times damages, climate effects from induced production and procedural harms to the Standing Rock Sioux Tribe. [1,23]
Future generations and species
A spill could affect drinking water, fisheries, wetlands and culturally important resources. Fossil infrastructure can operate for decades and shift climate costs forward. [1,23]
Litigation status
A district court ordered an environmental impact statement and vacated the easement, though an appellate court allowed operation while review continued. In May 2026 the Corps issued a new easement with conditions; litigation risk remains. [1,23]
Who benefits and who pays
Pipeline owners, Bakken producers and refiners gained cheaper transport. The Standing Rock Sioux Tribe and downstream users carried concentrated water and sovereignty risks. [1,23]
11 The 2020 Navigable Waters Protection Rule
Water wetlands and flood protection | 2017-2021
What happened
EPA and the Army Corps sharply narrowed Clean Water Act jurisdiction, excluding many ephemeral streams and wetlands from federal permitting and pollution controls. [4,15,19,23]
Dollar cost and time horizon
There was no comprehensive national valuation of lost wetlands and waters. Costs include treatment, flooding, nutrient pollution, lost habitat and state replacement programs; avoided permitting costs accrued project by project. [4,15,19,23]
Future generations and species
Wetlands store floodwater, recharge aquifers and support amphibians, fish, birds and plants. Once filled or drained, functions can be expensive or impossible to restore. [4,15,19,23]
Litigation status
Courts remanded or vacated the rule in 2021, and agencies replaced it. The Supreme Court’s 2023 Sackett decision later independently narrowed federal wetlands jurisdiction, leaving a lasting gap not solely attributable to the 2020 rule. [4,15,19,23]
Who benefits and who pays
Developers, mining, agriculture and oil and gas interests gained reduced federal permitting exposure. Downstream households, water systems and states inherited risk and enforcement costs. [4,15,19,23]
12 Restriction of state authority under Clean Water Act Section 401
Water federalism and infrastructure | 2017-2021
What happened
EPA’s 2020 rule limited the time, scope and conditions states and Tribes could use when certifying federally permitted pipelines, dams and other projects. [1,4,23]
Dollar cost and time horizon
The rule shifted costs rather than eliminating them: sponsors could avoid mitigation or delay, while downstream pollution, habitat and treatment costs could increase. No credible national net-dollar estimate was produced. [1,4,23]
Future generations and species
Long-lived infrastructure can alter flows, temperature, sediment and water quality for generations, harming fish, mussels and riparian systems. [1,4,23]
Litigation status
A district court vacated the rule in 2021; the Supreme Court temporarily restored it in 2022 pending appeal. EPA replaced it in 2023. The second administration has proposed renewed limits, producing new litigation risk. [1,4,23]
Who benefits and who pays
Pipeline, hydropower and other permit applicants benefited from fewer state conditions. States, Tribes and water users lost leverage to prevent locally concentrated harm. [1,4,23]
13 The 2020 NEPA rollback
Environmental review and public participation | 2017-2021
What happened
CEQ imposed time and page limits, narrowed effects analysis and reduced consideration of cumulative and indirect consequences, including climate effects. [1,4,20,23]
Dollar cost and time horizon
Faster reviews may reduce applicant expense, but incomplete review can increase redesign, litigation, pollution, disaster and stranded-asset costs. The government did not supply a credible aggregate net-benefit estimate. [1,4,20,23]
Future generations and species
NEPA does not dictate outcomes, but it exposes effects before irreversible decisions. Weak analysis shifts risk to future residents, Tribal nations and species affected by habitat fragmentation and climate change. [1,4,20,23]
Litigation status
Multiple coalitions challenged the rule. The Biden CEQ reversed major portions in 2022 and 2024, altering or mooting claims. Congress amended NEPA in 2023; the second Trump administration has now withdrawn CEQ-wide rules entirely. [1,4,20,23]
Who benefits and who pays
Infrastructure, extraction and development proponents gained shorter review and fewer analytical requirements. Communities lacking political power lost information and negotiating leverage. [1,4,20,23]
14 Weakening Endangered Species Act implementing rules in 2019
Biodiversity | 2017-2021
What happened
Interior and Commerce changed listing, critical-habitat and consultation rules, allowed economic information into listing presentations, and ended automatic threatened-species protections for newly listed species. [1,4,17,23]
Dollar cost and time horizon
Extinction and genetic diversity cannot be responsibly reduced to a single dollar amount. Avoided consultation and mitigation expenses were private gains; lost ecosystem services, option value and recovery potential were public losses. [1,4,17,23]
Future generations and species
Delayed protection can be irreversible because extinction cannot be remedied later. Narrower safeguards also reduce resilience to climate-driven range shifts. [1,4,17,23]
Litigation status
A district court vacated the rules in 2022, but the Ninth Circuit stayed that vacatur while agencies revised them. Biden agencies restored key protections in 2024; the second Trump administration is again dismantling them. [1,4,17,23]
Who benefits and who pays
Developers, extractive industries and some landowners gained regulatory flexibility. Species, future generations, Tribes and recreation-based economies bore risk. [1,4,17,23]
15 New barriers to designating and protecting critical habitat
Biodiversity and land use | 2017-2021
What happened
The administration adopted rules narrowing when unoccupied habitat could be designated and expanding the ability to exclude areas from critical habitat. [1,17,23,24]
Dollar cost and time horizon
Project proponents could avoid consultation and mitigation costs. The countervailing value is habitat’s contribution to species recovery, ecosystem services and avoided emergency measures; national monetization is not credible. [1,17,23,24]
Future generations and species
Climate change forces species to move. Excluding currently unoccupied but essential future habitat can turn temporary population decline into permanent extinction. [1,17,23,24]
Litigation status
Conservation groups sued. Later administrations rescinded or replaced the rules, and much first-term litigation became moot; current ESA rules are the subject of new 2026 challenges. [1,17,23,24]
Who benefits and who pays
Mining, energy, timber and development interests with projects in potential habitat benefited. Conservation, recreation and future recovery options lost value. [1,17,23,24]
16 Narrowing the Migratory Bird Treaty Act to intentional killing
Birds energy and industry | 2017-2021
What happened
Interior interpreted the MBTA not to prohibit incidental killing from industrial activity, oil pits, power lines, buildings or habitat destruction, then codified the position. [1,4,18,23]
Dollar cost and time horizon
Industries avoided prevention and penalty costs. The public lost birds’ pest control, pollination, recreation and cultural value. The Deepwater Horizon bird settlement illustrated that incidental mortality can create very large liabilities. [1,4,18,23]
Future generations and species
The policy removed incentives for simple safeguards and exposed hundreds of migratory species to cumulative mortality. Population losses can cascade through food webs. [1,4,18,23]
Litigation status
A federal district court rejected the legal opinion in 2020. The Biden administration revoked the rule in 2021. The second Trump administration has renewed steps toward the narrower interpretation. [1,4,18,23]
Who benefits and who pays
Oil and gas, utilities, construction and other operators gained reduced liability. Bird populations and communities reliant on hunting, birding and ecosystem services lost protection. [1,4,18,23]
17 Reduction of Bears Ears and Grand Staircase Escalante National Monuments
Public lands archaeology and biodiversity | 2017-2021
What happened
Trump reduced Bears Ears by about 85 percent and Grand Staircase-Escalante by about 47 percent, exposing excluded lands to mining and other uses. [4,16,23]
Dollar cost and time horizon
Potential mineral access was the principal private gain. Costs include damage to archaeological sites, tourism, ecosystem services and Tribal cultural values, none captured well in commodity-market prices. [4,16,23]
Future generations and species
Disturbance in arid landscapes can last centuries. Habitat fragmentation and damage to sacred or archaeological resources may be irreversible. [4,16,23]
Litigation status
Tribes and conservation groups sued. President Biden restored the boundaries in 2021, and courts later dismissed or redirected challenges. New second-term monument rollback plans create renewed litigation. [4,16,23]
Who benefits and who pays
Mining and grazing interests obtained opportunity; Tribal nations, local recreation businesses, scientists and the public lost protection and certainty. [4,16,23]
18 Exemption of the Tongass National Forest from the Roadless Rule
Forests climate and fisheries | 2017-2021
What happened
The Forest Service opened about 9.3 million acres of the Tongass to road construction and potential logging. [1,4,23]
Dollar cost and time horizon
Timber access was subsidized by road and sale administration costs in a region where federal timber sales have often lost money. Foregone carbon storage, salmon habitat, tourism and subsistence values can exceed timber receipts. [1,4,23]
Future generations and species
Old-growth trees store centuries of carbon and support salmon, bears, wolves and birds. Logging and roads fragment habitat and affect streams well beyond a harvest cycle. [1,4,23]
Litigation status
Conservation and Tribal plaintiffs challenged the exemption. The Biden administration restored Roadless Rule protections in 2023; many claims became moot. The second administration’s national Roadless Rule repeal proposal reopens the issue. [1,4,23]
Who benefits and who pays
A small timber sector and associated road contractors benefited. Fishing, tourism, Alaska Native communities, taxpayers and the global climate carried costs. [1,4,23]
19 Undermining the legal foundation of Mercury and Air Toxics Standards
Air toxics and health | 2017-2021
What happened
EPA withdrew the finding that regulating power-plant mercury and air toxics was appropriate and necessary, while leaving numeric limits temporarily in place. The action destabilized the rule and narrowed how co-benefits were counted. [4,5,23,33]
Dollar cost and time horizon
EPA had previously estimated very large particulate-matter co-benefits and thousands of avoided premature deaths annually from MATS implementation. Industry compliance had already occurred, so rollback offered limited new savings while creating legal uncertainty. [4,5,23,33]
Future generations and species
Mercury bioaccumulates in fish and impairs fetal and child neurological development. Long-term deposition affects aquatic food webs and communities reliant on subsistence fishing. [4,5,23,33]
Litigation status
States and groups challenged the action. The Biden EPA restored the finding in 2023 and strengthened limits in 2024. Those 2024 additions were rescinded in 2026; the older core standards remain. [4,5,23,33]
Who benefits and who pays
Coal plant operators sought reduced legal and future compliance exposure. Pregnant people, children, anglers and downwind communities bore the health risk. [4,5,23,33]
20 Weakening coal ash disposal requirements
Water waste and cleanup | 2017-2021
What happened
EPA extended deadlines and eased requirements governing unlined coal-combustion-residual impoundments and contaminated sites. [1,4,23,35]
Dollar cost and time horizon
Utilities deferred closure and treatment expense. Public costs include groundwater contamination, catastrophic impoundment failure, lost property value and future cleanup. Deferral can increase total remediation cost. [1,4,23,35]
Future generations and species
Arsenic, selenium, mercury and other contaminants persist in groundwater and sediments, threatening drinking water and aquatic species for decades. [1,4,23,35]
Litigation status
Environmental groups challenged several amendments; courts remanded aspects of the broader program. Biden-era rules tightened oversight, and the second administration is again delaying deadlines. [1,4,23,35]
Who benefits and who pays
Coal utilities and ratepayers in the short run benefited from deferred spending. Fenceline communities and future ratepayers inherited cleanup and health liabilities. [1,4,23,35]
21 Weakening power-plant wastewater limits
Water toxics and public health | 2017-2021
What happened
EPA revised effluent guidelines for steam-electric plants, extending compliance and allowing less protective treatment pathways for toxic wastewater. [1,4,23,34]
Dollar cost and time horizon
Industry saved treatment costs; EPA’s earlier rule projected substantial benefits from reduced toxic discharges. Some ecological and health benefits were not monetized, so a low official benefit estimate did not mean low harm. [1,4,23,34]
Future generations and species
Mercury, arsenic, selenium and nutrients damage fish, wildlife and drinking-water sources. Persistent contamination shifts cleanup and health burdens to later generations. [1,4,23,34]
Litigation status
Environmental and industry petitions challenged successive versions. EPA issued a stronger rule in 2024; the second administration delayed it and is considering broader revision. [1,4,23,34]
Who benefits and who pays
Coal-fired generators avoided or postponed capital expense. Downstream communities, anglers and aquatic ecosystems carried the cost. [1,4,23,34]
22 Refusal to strengthen the national ozone standard
Air and health | 2017-2021
What happened
In 2020 EPA retained the 2015 ozone standard despite evidence and advisory recommendations supporting stronger protection. [1,4,23]
Dollar cost and time horizon
A stronger standard would impose control costs but prevent premature deaths, asthma attacks, missed work and crop damage. The decision’s incremental cost is the foregone net benefit of the stronger alternative; no single consensus figure covers all exposure and implementation scenarios. [1,4,23]
Future generations and species
Ozone damages lungs and vegetation. Children, outdoor workers and people with asthma face immediate effects; forests and crops experience cumulative injury. [1,4,23]
Litigation status
States and health groups challenged the decision. EPA later reconsidered it, and litigation was held in abeyance or overtaken by review. The second administration announced another deregulatory reconsideration. [1,4,23]
Who benefits and who pays
Fossil-fuel, industrial and transportation sources avoided tighter controls. Downwind states and urban communities retained the burden. [1,4,23]
23 Refusal to strengthen the fine-particle pollution standard
Air and health | 2017-2021
What happened
EPA retained the annual PM2.5 limit at 12 micrograms per cubic meter in 2020 despite evidence that harm occurs below that level. [1,4,23]
Dollar cost and time horizon
Fine-particle pollution is associated with mortality and cardiovascular and respiratory illness. A stronger standard’s benefits were estimated in the billions annually in later rulemaking, with compliance costs substantially smaller. [1,4,23]
Future generations and species
Exposure affects fetal development, children and older adults and can shorten lives. Ecosystems also receive acidic and nutrient deposition. [1,4,23]
Litigation status
Health and environmental groups challenged the decision. EPA strengthened the annual standard to 9 in 2024; the D.C. Circuit upheld it in 2026. That later rule, not the 2020 decision, is the current legal focus. [1,4,23]
Who benefits and who pays
Power plants, refineries, industry and other sources avoided controls. Densely populated and environmental-justice communities bore disproportionate exposure. [1,4,23]
24 Refusal to ban agricultural uses of chlorpyrifos
Pesticides food and neurodevelopment | 2017-2021
What happened
EPA denied a petition to revoke food tolerances for chlorpyrifos despite evidence of neurodevelopmental risk, allowing continued agricultural use during most of the term. [4,21,23]
Dollar cost and time horizon
Growers avoided substitution and pest-management costs. Potential costs include IQ loss, developmental disability, medical and educational services and lost lifetime earnings; national totals depend on exposure assumptions but can be very large. [4,21,23]
Future generations and species
Prenatal and childhood exposure can have lifelong effects. The pesticide also harms birds, fish and beneficial insects and can contaminate waterways. [4,21,23]
Litigation status
The Ninth Circuit ordered EPA in 2021 to act. EPA revoked food tolerances, but the Eighth Circuit later vacated that rule for inadequate consideration of narrower alternatives; EPA continues a new process. The original refusal was judicially rejected. [4,21,23]
Who benefits and who pays
Some growers and the pesticide manufacturer benefited from continued use. Farmworkers, nearby families, children and wildlife bore exposure. [4,21,23]
25 Artificially lowering the social cost of greenhouse gases
Regulatory economics and climate | 2017-2021
What happened
The administration disbanded the interagency working group, counted mainly domestic rather than global damages and used high discount rates, shrinking the monetized cost of a ton of carbon from tens of dollars to roughly $1-$7 in many analyses. [3,4,5]
Dollar cost and time horizon
This accounting choice did not make climate damage disappear; it hid much of it from regulatory balance sheets and supported weaker rules. Across high-emitting rules, the resulting undervaluation can amount to tens or hundreds of billions of dollars. [3,4,5]
Future generations and species
High discounting treats harms to children and later generations as nearly valueless today. Global exclusion ignores cross-border food, migration, conflict and economic feedbacks that return to the United States. [3,4,5]
Litigation status
Courts scrutinized particular rules rather than permanently resolving one universal metric. Biden restored an interagency estimate. Trump again dismantled that framework in 2025-2026. [3,4,5]
Who benefits and who pays
Carbon-intensive industries benefited whenever hidden damages made regulation appear less justified. The cost shifted to the public and future generations. [3,4,5]
26 Second withdrawal from the Paris climate agreement
Climate and diplomacy | 2025-present
What happened
Trump ordered withdrawal on January 20, 2025; it became effective January 27, 2026. The United States again left the global accord while promoting expanded fossil production. [3,9,13]
Dollar cost and time horizon
The direct federal budget saving is small. The material cost is additional climate damage and weaker global cooperation. Rhodium projected that the broader rollback agenda could cut the pace of U.S. decarbonization by more than half and raise annual 2035 emissions by as much as roughly 1.3 billion metric tons versus prior-policy pathways. [3,9,13]
Future generations and species
The consequences continue for centuries through heat, drought, fire, flood, sea-level rise and ecosystem disruption. Species with limited ranges or migration corridors face elevated extinction risk. [3,9,13]
Litigation status
Treaty withdrawal is generally not susceptible to an ordinary environmental merits lawsuit. The withdrawal is effective as of this report. [3,9,13]
Who benefits and who pays
Fossil-fuel producers and governments opposing stronger commitments gain political space. Exporters of clean technology, climate-vulnerable communities and future taxpayers lose. [3,9,13]
27 Rescission of EPA’s greenhouse-gas endangerment finding
Climate and administrative law | 2025-present
What happened
In April 2026 EPA rescinded the 2009 scientific finding that greenhouse gases endanger public health and welfare, attacking the legal predicate for vehicle and other Clean Air Act climate rules. [1,2,3,28]
Dollar cost and time horizon
The downstream stakes are enormous because the finding supports multiple rules. Policy Integrity’s partial tracker already identifies more than $156.6 billion in annual net benefits at risk from a subset of rollbacks; rescission could reach beyond that subset. [1,2,3,28]
Future generations and species
Removing the regulatory foundation permits more cumulative emissions and transfers disaster, health and adaptation costs to later generations. Species impacts track the full climate system. [1,2,3,28]
Litigation status
States, environmental organizations and public-health groups have filed challenges; they were pending as of September 20, 2026. Litigation will test statutory interpretation, the scientific record and arbitrary-and-capricious review. [1,2,3,28]
Who benefits and who pays
Vehicle, oil, gas, coal and some manufacturing interests gain broad relief from federal climate regulation. The public bears climate and co-pollutant costs. [1,2,3,28]
28 Repeal of light and medium duty vehicle greenhouse-gas standards
Climate transportation and consumers | 2025-present
What happened
EPA fully repealed model-year 2027-and-later greenhouse-gas standards after rescinding the endangerment finding. [1,2,28]
Dollar cost and time horizon
Policy Integrity estimates about $101.9 billion per year in net benefits at risk, including $11.4 billion in consumer savings, $10.9 billion in health benefits and $78.7 billion in climate benefits, plus roughly 2,577 premature deaths annually. [1,2,28]
Future generations and species
Vehicles sold under weaker rules remain for 15 years or more, locking in fuel use and pollution. Children near roads and communities near refineries are especially exposed; climate harm persists much longer. [1,2,28]
Litigation status
Legal challenges are expected or pending alongside challenges to the endangerment rescission. Final status will depend on D.C. Circuit review and likely Supreme Court proceedings. [1,2,28]
Who benefits and who pays
Automakers gain compliance flexibility and petroleum firms sell more fuel. Consumers may see some cheaper configurations but lose far more in modeled fuel savings and health benefits overall. [1,2,28]
29 Repeal of power-plant greenhouse-gas limits
Climate electricity and air | 2025-present
What happened
In September 2026 EPA repealed most 2024 greenhouse-gas standards for coal and gas plants and proposed foreclosing similar future standards. [1,2,3,28]
Dollar cost and time horizon
The targeted standards had been estimated to deliver about $23.6 billion in annual net benefits, including $17.4 billion in climate and $7.6 billion in health benefits, with about 555 premature deaths avoided annually. EPA’s final repeal estimates additional emissions while emphasizing operator savings. [1,2,3,28]
Future generations and species
Power plants last for decades; weakened rules encourage extended fossil operation. Climate and particulate pollution damage health, water, agriculture and species across generations. [1,2,3,28]
Litigation status
Challenges were being prepared immediately after the September 2026 final action. Earlier challenges to the 2024 rule do not eliminate new plaintiffs’ right to contest the repeal. [1,2,3,28]
Who benefits and who pays
Coal and gas plant owners avoid controls or retirement pressure; fuel suppliers benefit. Downwind communities and electricity customers exposed to fuel-price risk bear costs. [1,2,3,28]
30 Repeal and delay of oil and gas methane controls and the waste-emissions charge
Climate air and public revenue | 2025-present
What happened
Congress and EPA repealed the methane fee and EPA delayed or exempted major portions of methane monitoring, reporting and control requirements. [1,2,3]
Dollar cost and time horizon
Policy Integrity estimates $236 million in annual net benefits at risk from the fee repeal and about $9.3 billion annually from delayed oil-and-gas methane standards, including roughly $10.5 billion in climate benefits and 52 premature deaths at risk. [1,2,3]
Future generations and species
Methane has especially strong warming effects in the next 20 years. Co-emitted benzene and ozone precursors affect nearby residents; warming damages sensitive species. [1,2,3]
Litigation status
Congressional Review Act repeal is generally not reversible by ordinary agency action. Litigation over EPA delays and exemptions is pending or expected; outcomes vary by provision. [1,2,3]
Who benefits and who pays
Oil and gas operators, especially high emitters, avoid fees, inspections and equipment costs. Low-leak competitors lose the advantage of prior investment; communities and the climate absorb leakage. [1,2,3]
31 Early termination of major clean energy and vehicle incentives in the 2025 reconciliation law
Climate energy bills jobs and industry | 2025-present
What happened
The One Big Beautiful Bill Act accelerated expiration or restricted numerous Inflation Reduction Act incentives for clean power, vehicles, buildings and manufacturing and rescinded unobligated program funds. [9,10,11,27]
Dollar cost and time horizon
Rhodium estimates 53-59 percent less new clean-power capacity through 2035, more than $500 billion in investment at risk, and average household energy bills $78-$192 higher in 2035. Energy Innovation modeled up to $1.1 trillion less GDP and hundreds of thousands of lost jobs under the legislative package it assessed. [9,10,11,27]
Future generations and species
Reduced clean capacity increases cumulative fossil generation and pollution for decades. Climate and air impacts fall on future generations and species; canceled factories can also weaken long-run U.S. technology capacity. [9,10,11,27]
Litigation status
Because Congress enacted the changes, ordinary APA suits cannot reverse the policy choice. Litigation focuses on implementation, grant termination, tax guidance and constitutional or statutory limits. [9,10,11,27]
Who benefits and who pays
Fossil generators and fuel suppliers benefit from reduced competition. Federal revenue may improve from smaller credits, but households, clean-energy developers, manufacturers and host communities lose investment and bill savings. [9,10,11,27]
32 Federal wind permitting blockade and project suspensions
Clean energy oceans and electricity | 2025-present
What happened
Trump ordered agencies to stop new wind leasing and approvals; agencies also suspended or pressured major offshore projects and later pursued agreements to relinquish leases. [1,25]
Dollar cost and time horizon
Delays destroy financing value, raise construction costs and can increase electricity prices by removing planned supply. Exact loss depends on each project; billions of dollars in committed capital and contracted generation were exposed. [1,25]
Future generations and species
Replacing wind with fossil generation increases air and climate damages. Wind also has wildlife impacts, but project-specific review and mitigation can address them; a blanket block prevents comparative assessment. [1,25]
Litigation status
A federal district court vacated the across-the-board authorization pause in December 2025, and the administration withdrew its appeal in June 2026. Separate project-specific disputes and compensation claims continue. [1,25]
Who benefits and who pays
Fossil generators and competing fuels benefit from delayed supply. Some fishing and coastal groups opposed particular projects, but leaseholders, workers, states and ratepayers lost certainty and investment. [1,25]
33 Reopening the Arctic National Wildlife Refuge leasing program
Climate biodiversity and Indigenous rights | 2025-present
What happened
Interior reinstated an oil and gas program covering the 1.56-million-acre coastal plain and moved to reverse Biden-era protections and lease cancellations. [1,23,30]
Dollar cost and time horizon
Potential federal and Alaska revenue is uncertain; the 2021 sale’s weak bids demonstrate limited market value at that time. Spill, infrastructure, carbon and subsistence costs remain largely externalized. [1,23,30]
Future generations and species
The coastal plain is calving habitat for the Porcupine caribou herd and denning habitat for polar bears, and supports migratory birds. Industrial footprints in tundra can persist for generations. [1,23,30]
Litigation status
Challenges to reinstatement and site-specific leasing are pending or anticipated; current status should be checked before relying on a particular lease parcel. [1,23,30]
Who benefits and who pays
Oil companies and Alaska state interests gain access. Gwich’in communities, wildlife, climate-vulnerable regions and taxpayers assume risk. [1,23,30]
34 Reopening most of the National Petroleum Reserve Alaska
Climate public lands and wildlife | 2025-present
What happened
BLM replaced the 2024 conservation rule with the older framework and approved a plan reopening roughly 82 percent of the reserve to leasing. [1,24,31]
Dollar cost and time horizon
Lease and royalty prospects are uncertain and depend on prices and discoveries. Public costs include infrastructure, spill and cleanup risk, carbon damages and loss of ecosystem services. [1,24,31]
Future generations and species
The reserve includes globally important wetlands and habitat for caribou, polar bears and millions of migratory birds. Roads and pipelines fragment habitat for decades. [1,24,31]
Litigation status
Environmental and Alaska Native challenges to programmatic and project decisions are pending or likely. Individual approvals require separate review, creating multiple litigation tracks. [1,24,31]
Who benefits and who pays
Petroleum companies and service firms gain acreage and options. Subsistence communities, wildlife and future climate bear costs. [1,24,31]
35 Massive expansion of proposed offshore oil and gas leasing
Oceans climate and coastal economies | 2025-present
What happened
Interior proposed a five-year program and statutory lease schedule spanning up to about 1.3 billion offshore acres. [1,3,23]
Dollar cost and time horizon
Bonus bids, royalties and production may create revenue, but expected net value must subtract federal administration, spill risk, fisheries and tourism loss, stranded infrastructure and carbon damages. No single net figure is credible before lease locations and production are known. [1,3,23]
Future generations and species
New leases can support production beyond mid-century. Spills and seismic activity threaten whales, seabirds, corals and coastal nurseries. [1,3,23]
Litigation status
Programmatic challenges are expected once final decisions ripen; individual lease sales can also face NEPA, endangered-species and marine-mammal claims. [1,3,23]
Who benefits and who pays
Offshore producers, drilling firms and some revenue-sharing governments benefit. Coastal businesses, fishers and the public carry low-probability but very high-consequence risk. [1,3,23]
36 Withdrawal of government-wide NEPA regulations and agency-specific shortcuts
Environmental review and public participation | 2025-present
What happened
CEQ withdrew all government-wide NEPA implementing rules in 2026, while agencies adopted narrower rules, guidance, categorical exclusions and emergency or alternative arrangements favoring rapid energy approvals. [1,20,23]
Dollar cost and time horizon
Applicants may save time and consultant expense. Inadequate analysis can generate design errors, litigation, community conflict, disaster exposure and irreversible damage. Those external costs have not been credibly aggregated. [1,20,23]
Future generations and species
Reduced cumulative and climate review makes it harder to see how many individually modest projects combine to fragment habitat, consume water or raise emissions over decades. [1,20,23]
Litigation status
Challenges to CEQ and agency actions are pending or expected, complicated by 2023 statutory amendments and recent Supreme Court limits on NEPA remedies. [1,20,23]
Who benefits and who pays
Energy, mining and infrastructure sponsors gain speed and leverage. Tribes, local governments, affected residents and species lose information and preventive review. [1,20,23]
37 Further narrowing the definition of Waters of the United States
Water wetlands and flood risk | 2025-present
What happened
EPA and the Corps proposed a still narrower post-Sackett jurisdictional rule in November 2025 and supplemented it in 2026. [1,15]
Dollar cost and time horizon
Permitting savings accrue to landowners and developers, while states and households face water-treatment, flood, drought and habitat costs. Tens of millions of wetland acres are potentially outside federal protection after Sackett; the rule’s incremental effect requires mapping after finalization. [1,15]
Future generations and species
Wetland loss reduces flood storage, aquifer recharge, carbon retention and nursery habitat. Restoration rarely recreates all functions and becomes more costly later. [1,15]
Litigation status
As of September 20, 2026, the rulemaking was not fully settled; litigation will follow a final rule. Existing Sackett litigation does not pre-approve every administrative narrowing. [1,15]
Who benefits and who pays
Development, agriculture, mining and oil and gas interests gain reduced federal jurisdiction. States, Tribes and downstream communities inherit responsibility and expense. [1,15]
38 Renewed effort to restrict state and Tribal water-quality certification
Water federalism and infrastructure | 2025-present
What happened
EPA proposed limits on the scope and timing of Clean Water Act Section 401 certifications, reducing state and Tribal leverage over federally licensed projects. [1,23]
Dollar cost and time horizon
Project sponsors may avoid delay and mitigation costs. Those savings can become downstream treatment, fisheries, flood and restoration costs; aggregate net harm is not yet quantifiable. [1,23]
Future generations and species
Pipelines, dams and terminals can alter water quality and flow for generations. Fish passage, temperature-sensitive species and wetlands face site-specific risks. [1,23]
Litigation status
The proposal was pending as of the report date. Finalization would almost certainly draw state, Tribal and environmental challenges. [1,23]
Who benefits and who pays
Pipeline, hydropower, mining and terminal developers benefit. States and Tribes lose a principal tool for protecting local waters. [1,23]
39 Rescission of the Endangered Species Act definition of harm
Biodiversity and habitat | 2025-present
What happened
The administration finalized a rule removing or sharply narrowing the long-standing interpretation that habitat modification causing injury or death can constitute prohibited harm; a September 2026 directive further limited incidental-kill exposure. [1,17,23,24]
Dollar cost and time horizon
Avoided consultation, permitting and mitigation costs are concentrated among land users. Extinction, ecosystem-service and recovery-option losses are not responsibly monetized as a single total. [1,17,23,24]
Future generations and species
Habitat destruction is the leading driver of endangerment. Removing liability until an animal is directly targeted ignores ecological causation and can make loss irreversible. [1,17,23,24]
Litigation status
States and conservation organizations filed challenges in 2026; cases were pending as of September 20. Plaintiffs cite statutory text, Supreme Court precedent and arbitrary-and-capricious defects. [1,17,23,24]
Who benefits and who pays
Logging, development, mining, agriculture and energy projects gain freedom to alter habitat. Imperiled species and communities valuing fisheries, wildlife and intact ecosystems bear the cost. [1,17,23,24]
40 Proposal to repeal the national Roadless Rule
Forests water climate and biodiversity | 2025-present
What happened
USDA proposed rescinding protections covering about 58.5 million acres of inventoried roadless national-forest lands. [1,23]
Dollar cost and time horizon
Timber and access benefits must be weighed against taxpayer-funded roads and maintenance, wildfire and erosion risk, carbon loss, drinking-water protection and recreation. The Forest Service already carries a multibillion-dollar road-maintenance backlog. [1,23]
Future generations and species
Roads fragment habitat, spread invasive species and sediment streams. Old forests and headwaters provide carbon storage and resilience that take generations to recover. [1,23]
Litigation status
The proposal was pending in September 2026. A final rule would face NEPA, administrative-law and forest-statute challenges; state-specific roadless protections complicate effects. [1,23]
Who benefits and who pays
Timber, mining and some motorized-access interests benefit. Taxpayers, downstream water users, recreation economies, fish and wildlife carry long-term costs. [1,23]
41 Delaying and proposing to rescind PFAS drinking-water protections
Drinking water toxics and health | 2025-present
What happened
EPA delayed compliance deadlines for two PFAS standards and proposed rescinding standards for four other PFAS compounds. [1,23,32]
Dollar cost and time horizon
Utilities may defer billions in treatment and monitoring expense, but delay transfers costs to medical care, households buying filters or bottled water, contaminated property and later cleanup. Health effects are incompletely monetized. [1,23,32]
Future generations and species
PFAS persist for years to centuries and can accumulate in people and wildlife. Continued exposure burdens children not yet born and contaminates water supplies that are difficult to restore. [1,23,32]
Litigation status
States, utilities and environmental groups have pursued or prepared challenges on different sides of the rule. The rescission proposal was not final as of September 20, 2026. [1,23,32]
Who benefits and who pays
PFAS manufacturers and dischargers gain reduced pressure; some utilities gain time. Exposed households and future water customers bear health and treatment costs. [1,23,32]
42 Rescission of the 2024 Mercury and Air Toxics Standards additions
Air toxics health and fish | 2025-present
What happened
EPA rescinded stricter 2024 mercury and particulate limits and restored the older 2012 framework. [1,2,33]
Dollar cost and time horizon
Policy Integrity estimates at least $38 million in annual monetized health benefits and $17 million in annual climate benefits at risk, with about three premature deaths annually; many mercury neurodevelopmental and ecological harms remain unquantified. [1,2,33]
Future generations and species
Mercury deposited today cycles through ecosystems and bioaccumulates in fish, affecting fetal development and wildlife for decades. [1,2,33]
Litigation status
Challenges to the rescission are expected or pending. Existing industry litigation against the 2024 rule may be mooted or reshaped by repeal. [1,2,33]
Who benefits and who pays
Coal plant owners avoid upgraded controls and monitoring. Pregnant people, children, subsistence fishers and aquatic food webs bear risk. [1,2,33]
43 Delay and planned weakening of steam-electric power-plant wastewater controls
Water toxics and health | 2025-present
What happened
EPA extended compliance dates for the 2024 effluent rule while preparing broader revisions affecting discharges from coal-fired power plants. [1,2,34]
Dollar cost and time horizon
Policy Integrity estimates about $2.2 billion in annual net benefits at risk, including $1.7 billion in health and $1.6 billion in climate benefits, and roughly 112 premature deaths annually. [1,2,34]
Future generations and species
Arsenic, mercury, selenium and other pollutants persist in water and sediment, harming drinking water, fish and wildlife beyond a plant’s operating life. [1,2,34]
Litigation status
Delay and any final weakening are subject to Clean Water Act and APA challenges. Litigation posture differs by deadline and substantive standard. [1,2,34]
Who benefits and who pays
Coal utilities defer treatment investment. Downstream communities and future ratepayers inherit contamination and cleanup. [1,2,34]
44 Delay of coal ash protections
Waste groundwater and disaster risk | 2025-present
What happened
EPA delayed deadlines for coal-ash closure and remediation requirements, allowing some unlined and contaminated units to remain unresolved longer. [1,23,35]
Dollar cost and time horizon
Utilities gain cash-flow relief; delay can increase plume size and ultimate cleanup cost. National health and groundwater damages are not fully quantified in EPA cost-benefit tables. [1,23,35]
Future generations and species
Toxic metals persist and migrate. Impoundment failure can impose sudden, catastrophic costs; chronic leakage affects communities and aquatic systems for decades. [1,23,35]
Litigation status
Environmental groups are expected to challenge unlawful or inadequately justified extensions; individual site enforcement and citizen suits continue separately. [1,23,35]
Who benefits and who pays
Coal utilities benefit immediately. Nearby communities, groundwater users and future utility customers bear deferred liability. [1,23,35]
45 Attempted termination of the seven billion dollar Solar for All program
Climate energy affordability and environmental justice | 2025-present
What happened
EPA terminated grants intended to bring rooftop and community solar to nearly one million low-income households. [26,29]
Dollar cost and time horizon
The face value is $7 billion, but program value also includes bill savings, avoided pollution and jobs. Cancellation could strand planning expenditures and raise household energy costs; not all grant dollars equal net social benefit, so the face value should not be treated as the damage total. [26,29]
Future generations and species
Lost solar deployment increases fossil generation and pollution over equipment lifetimes. Low-income families and children in polluted neighborhoods lose disproportionate benefits. [26,29]
Litigation status
On September 18, 2026, a federal judge ruled the termination unlawful and vacated it. EPA was considering appeal; related Court of Federal Claims cases continued. [26,29]
Who benefits and who pays
Competing generators and fiscal hawks favoring rescission benefit politically or economically. Grant recipients, installers, households and states were harmed by delay and uncertainty. [26,29]
46 Termination of environmental and climate justice grants and programs
Environmental justice enforcement and local resilience | 2025-present
What happened
EPA canceled grant programs and dismantled offices and initiatives aimed at pollution burdens in disadvantaged communities. [1,23,29]
Dollar cost and time horizon
Courts and reporting identify roughly $1.6 billion to several billion dollars in disputed grants, depending on the program set. Losses include sunk planning costs, delayed cleanup, health burdens and foregone local investment. [1,23,29]
Future generations and species
Communities with cumulative pollution and climate vulnerability lose capacity to monitor, reduce exposure and adapt. Harm compounds across generations through health, wealth and property-value effects. [1,23,29]
Litigation status
Federal courts in 2026 ruled important terminations unlawful; some awards were ordered restored, while appeals and money claims continued. Status varies by grant program. [1,23,29]
Who benefits and who pays
Regulated firms may face less community monitoring and fewer locally funded controls. The direct losers are Tribes, local governments, nonprofits and residents in high-burden areas. [1,23,29]
47 Hollowing out environmental science enforcement and public data capacity
Institutions science and enforcement | 2025-present
What happened
The administration pursued major staffing, budget, grant and program reductions at EPA, NOAA and related agencies, curtailed climate and environmental-justice functions and disrupted data and research capacity. [1,4,23,24]
Dollar cost and time horizon
Payroll savings are visible; losses from weaker forecasts, inspections, enforcement, science and grant oversight are much larger but diffuse. A proposed EPA budget cut exceeding half was not itself an enacted outcome, so this report counts implemented reductions and disruption, not every budget proposal. [1,4,23,24]
Future generations and species
Lost monitoring creates blind spots that delay action until contamination, species decline or climate risk becomes costlier or irreversible. Scientific capacity takes years to rebuild. [1,4,23,24]
Litigation status
Unions, employees, grantees and organizations brought multiple suits over firings, reorganizations, records and grant terminations. Results are mixed, with injunctions and merits rulings in some cases and jurisdictional barriers in others. [1,4,23,24]
Who benefits and who pays
Regulated entities gain from fewer inspections, slower rules and weaker enforcement. Taxpayers may save salaries short term but assume accident, disaster and cleanup risk. [1,4,23,24]
48 Loosening hydrofluorocarbon transition requirements
Climate refrigeration and buildings | 2025-present
What happened
EPA proposed delaying or weakening requirements that shift refrigeration, air-conditioning and other sectors away from high-global-warming-potential HFCs, despite U.S. obligations under the Kigali Amendment and the AIM Act. [1,3]
Dollar cost and time horizon
Manufacturers and users avoid near-term conversion costs, but HFC climate damage is high and efficiency gains from new equipment can produce savings. The net amount depends on the final rule and technology path. [1,3]
Future generations and species
HFCs are powerful greenhouse gases; emissions now affect warming for decades, adding stress to coral, polar, alpine and heat-sensitive species. [1,3]
Litigation status
The rulemaking was ongoing as of September 20, 2026. Any final weakening that conflicts with the AIM Act or lacks reasoned analysis is likely to be challenged. [1,3]
Who benefits and who pays
Producers and users of older refrigerants and equipment gain more time. Firms that invested early in alternatives lose regulatory certainty; the public bears climate costs. [1,3]
49 Accelerating commercial deep seabed mining outside the international framework
Oceans biodiversity and minerals | 2025-present
What happened
An April 2025 executive order directed NOAA and Interior to expedite exploration and commercial recovery of seabed minerals, including in areas beyond national jurisdiction. [1,23,36]
Dollar cost and time horizon
Potential mineral revenue and supply-chain diversification are speculative. Deep-sea ecosystem loss, carbon-cycle effects, fisheries risks and monitoring costs are poorly known and cannot yet be credibly priced. [1,23,36]
Future generations and species
Many deep-sea species are long-lived, slow-reproducing and unknown to science. Sediment plumes and habitat removal may cause damage on centuries-long timescales or permanent loss. [1,23,36]
Litigation status
Permit decisions would face administrative and environmental review challenges. International legal objections may arise because the United States has not ratified the Law of the Sea Convention; no mature merits judgment existed by the report date. [1,23,36]
Who benefits and who pays
Mining firms, equipment suppliers and mineral users may gain options. Coastal and Pacific communities, fisheries, scientific heritage and deep-ocean species carry uncertain but potentially irreversible risk. [1,23,36]
50 Opening marine monuments to commercial fishing and targeting national monuments for rollback
Oceans public lands and biodiversity | 2025-present
What happened
Trump opened the Northeast Canyons and Seamounts Marine National Monument to commercial fishing and directed review or rollback of other monument protections. [1,16,23,24]
Dollar cost and time horizon
Fishing revenue may rise in the short term, but protected areas support biodiversity, scientific reference sites, tourism and spillover into fisheries. Net national value depends on ecological response and enforcement, not gross catch alone. [1,16,23,24]
Future generations and species
Deep corals and seamount communities recover slowly from gear damage. Terrestrial monument reductions can expose archaeological resources and fragmented habitat to irreversible disturbance. [1,16,23,24]
Litigation status
Conservation groups and states are pursuing or preparing Antiquities Act and administrative-law challenges. The Supreme Court has not definitively resolved every question about a president’s power to reduce prior monuments. [1,16,23,24]
Who benefits and who pays
Commercial fishing and extractive interests gain access. Conservation-dependent tourism, Tribes, scientists, future fishers and species bear long-term risk. [1,16,23,24]
Cross cutting conclusions
The dollar total is necessarily incomplete
The $156.6 billion annual subtotal is the strongest compact figure in the current record because it uses a transparent rule-by-rule method and largely relies on agencies’ own prior analyses. It nevertheless covers only a subset of second-term actions. It omits most first-term effects, ecosystem-service loss, many toxic outcomes, enforcement decline, cultural harms, public-land damage and the possibility that broad legal changes prevent future safeguards. A comprehensive total would therefore be higher, but claiming a precise all-in number would be false precision.
Intergenerational accounting is the central issue
Many rollbacks produce modest savings during a firm’s planning horizon while creating carbon, contamination, habitat and infrastructure effects that last decades or centuries. Conventional discounting can make a large harm in 2080 look small in today’s dollars. That is an accounting convention, not evidence that the future harm is unimportant. The social-cost-of-carbon decisions in both administrations explicitly altered this balance.
Species loss cannot be repaired like ordinary capital
A destroyed building can be rebuilt. An extinct lineage, lost migration route, damaged sacred landscape or deep-sea community may not be replaceable at any price. For that reason, the species analysis focuses on irreversibility, exposure pathways and recovery time rather than assigning arbitrary dollar values.
Litigation has mattered but is an incomplete safeguard
Courts vacated or constrained numerous actions, including the first-term ACE rule, the first-term migratory-bird interpretation, parts of the first-term water and land agenda, the second-term blanket wind pause and the attempted Solar for All termination. Yet litigation often arrives after delay, staffing loss, investment cancellation or environmental disturbance. Supreme Court doctrines limiting agency authority and remedies can also leave lasting effects even when a particular Trump rule disappears.
The principal beneficiaries are identifiable
The repeated beneficiaries are incumbent fossil-fuel producers, high-emitting plants, extractive industries, developers and firms with older equipment. Some households may receive lower upfront product prices, some workers and communities may gain short-term activity, and taxpayers may avoid selected subsidies. But the record frequently shows that claimed savings exclude fuel bills, health damage, climate loss, cleanup, public royalties, ecosystem services and risk transferred to governments and families.
Sources and research notes
Bracketed numbers in the entries refer to the sources below. Regulatory and litigation status changes quickly. Court descriptions are summaries, not legal advice, and should be docket-checked before publication or filing.
1. Harvard Law School Environmental and Energy Law Program, Regulatory Tracker
2. Institute for Policy Integrity, Tracking the Damages of Regulatory Rollbacks
3. Columbia Sabin Center, Climate Deregulation Tracker
4. UC Berkeley Law, Reversing Trump Environmental Rollbacks
5. Brookings, The Trump administration’s major environmental deregulations
6. EPA archive, Clean Power Plan by the numbers
7. EPA, Regulatory Impact Analysis for the Affordable Clean Energy Rule
9. Rhodium Group, Trump 2.0 What’s in Store for U.S. Energy and Climate
10. Rhodium Group, Impacts of the final One Big Beautiful Bill
11. REPEAT Project, Impacts of the One Big Beautiful Bill on the U.S. Energy Transition
12. EPA, March 2025 deregulatory announcements
13. U.S. Department of State, Paris Agreement withdrawal notice
14. Supreme Court, West Virginia v. EPA opinion
15. Supreme Court, Sackett v. EPA opinion
16. Congressional Research Service, Trump Administration actions on national monuments
17. U.S. Fish and Wildlife Service, 2019 ESA regulatory revisions
18. Migratory Bird Treaty Act rule history, U.S. Fish and Wildlife Service
19. EPA, 2020 Navigable Waters Protection Rule
20. Council on Environmental Quality, NEPA rule history
21. EPA, chlorpyrifos regulatory history
22. U.S. District Court for D.C., Clean Air Council v. Pruitt materials
23. Earthjustice, Trump lawsuit and court record summaries
24. Center for Biological Diversity, Trump lawsuit tracker
25. Harvard EELP, federal court vacates wind authorization pause
26. Reuters, court ruling on the Solar for All cancellation, September 18 2026
27. Energy Innovation, reconciliation bill energy costs jobs health and emissions
28. EPA, greenhouse gas endangerment finding regulatory materials
29. IRA Tracker, litigation and implementation database
30. Congressional Research Service, Arctic National Wildlife Refuge oil and gas program
31. Bureau of Land Management, National Petroleum Reserve Alaska
32. EPA, PFAS National Primary Drinking Water Regulation
33. EPA, Mercury and Air Toxics Standards
34. EPA, steam electric power generating effluent guidelines
36. NOAA, deep seabed mining program
Selection and evidence method
Selection emphasized national scale, likely magnitude, duration, irreversibility, effects on vulnerable populations, biodiversity significance and institutional consequence. The report includes proposals only where the administration had taken a concrete formal step and labels them as pending. It does not treat all 50 as equally costly and does not add incompatible annual, cumulative, face-value and investment figures into one headline total.
Primary federal materials were preferred for rule text and official analyses. Harvard, Columbia and Berkeley law-school trackers were used to connect regulatory history and litigation; the Institute for Policy Integrity was used for a consistent second-term cost subtotal; Rhodium, REPEAT and Energy Innovation supplied economy and energy-system modeling. Advocacy organizations were used mainly to identify cases and affected species, with legal status checked against law-school trackers or reported court outcomes where possible.