Project 2025 Tracker / What’s done, what’s next

Section 3 · The General Welfare

13 Environmental Protection Agency

417–448 · Mandy M. Gunasekara

  • 15 done
  • 47 partially done
  • 12 attempted
  • 86 not started

Major recommendations (18)

What has happened

The Mandate said

“Depending on the outcome of regulations from the Biden Administration as well as intervention by the Supreme Court on both waters of the United States (WOTUS) and CWA Section 401, the repeal and reissuance of new regulations should be pursued.”

What happened

Partially done

The WOTUS half went back out for comment instead of forward to a rule. EPA and the Army issued a supplemental notice of proposed rulemaking on docket EPA-HQ-OW-2025-0322 (RIN 2040-AG44), supplementing the November 2025 proposal "with additional regulatory options on certain aspects of the proposed rule" after considering the comments received. Reissuance is what the Quote asks for and neither half has been reissued: the WOTUS rulemaking is now reopened, and the Section 401 proposal of 2026-01-15 is still not final.

The Mandate said

“A WOTUS rule that makes clear what is and is not a “navigable water” and respects private property rights. Coordinate with Congress to develop legislation, if necessary, to codify the definition in Rapanos v. United States that “waters of the United States” can refer only to “relatively permanent, standing or continuously flowing bodies of water…as opposed to ordinarily dry channels through which water occasionally or intermittently flows.””

What happened

Partially done

Still a proposal, and now proposed a second time. Having considered the comments on the November 2025 NPRM, EPA and the Army issued a supplemental notice of proposed rulemaking on the same docket (EPA-HQ-OW-2025-0322, RIN 2040-AG44) to "supplement the NPRM with additional regulatory options on certain aspects of the proposed rule". The Rapanos formulation the Quote asks be made clear is ten months into a rulemaking that has been reopened rather than finalized, so the rung does not move; the legislative half is still untouched.

The Mandate said

“Eliminate the use of unauthorized regulatory inputs like the social cost of carbon, black box and proprietary models, and unrealistic climate scenarios, including those based on Representative Concentration Pathway (RCP) 8.5.”

What happened

Partially done

OSTP, for the U.S. Global Change Research Program, proposed an amendment to the Fifth National Climate Assessment governing the federal use of results that depend on RCP8.5, SSP5-8.5 and similar high-emissions pathways — the first federal instrument aimed at the RCP 8.5 half of the ask, still at comment stage.

The Mandate said

“Revisit and repeal or reform outdated environmental statutes. A high priority should be the repeal or reform of the Global Change Research Act of 1990, which has been misused for political purposes.”

What happened

Attempted

OSTP, acting for USGCRP, proposed an amendment to the Fifth National Climate Assessment on the federal use of high-emissions-pathway results — the administration reshaping the Act's product administratively. No bill to repeal or amend the Act has been introduced.

The Mandate said

“Several ORD offices and programs, many of which constitute unaccountable efforts to use scientific determinations to drive regulatory, enforcement, and legal decisions, should be eliminated. The Integrated Risk Information System, for example, was ostensibly designed by EPA to evaluate hazard and dose-response for certain chemicals. Despite operating since the 1980s, the program has never been authorized by Congress and often sets “safe levels” based on questionable science and below background levels, resulting in billions in economic costs.”

What happened

Attempted

ORD is on the chart with nobody senior on it. OPM's PLUM listing of EPA's policy and supporting positions, reported by EPA and published as of 15 June 2026, returns 179 positions across 24 EPA components and **not one** under the Office of Research and Development — no Assistant Administrator, no Principal Deputy, no Deputy Assistant Administrator for Management, and none of the career senior executives who ran the four centers, all of which the 2024 Plum Book listed. Every other headquarters office reports its career SES directors in the same file, so this is an absence of positions and not an absence of reporting. EPA's own pages have not moved with it: the organization chart still lists ORD among the headquarters offices, and the ORD chart and About page, both last updated 2025-10-20 and re-read on 2026-09-06, still carry ORM, OSIM, OSAPE, the CCTE, CEMM, CESER and CPHEA centers, every division beneath them and all six research programs, with the Acting Assistant Administrator and the Deputy Assistant Administrator for Management vacant. That is a hollowed office rather than an eliminated one, and it is not what the Quote asks: no ORD office, center, division or program has been eliminated, and IRIS is named in no Primary record as ended. §3b's test is what happened to the functions, and a leadership vacuum is not a statement about functions either.

Still to come

Executive action 77

  1. 421 Eliminate the Office of Enforcement and Compliance Assistance Major Not started
  2. 431 Revisit the CERCLA hazardous substance designation for PFAS Major Not started
  3. 423 Issue a rule on consistent and transparent consideration of costs at OAR Notable Not started
  4. 424 Require CAA Section 126(b) petitions to identify a discrete group of upwind sources Notable Not started
  5. 424 Strip non-statutory requirements from states that reach attainment status Notable Not started
  6. 425 Streamline transportation conformity for federally funded highway projects Notable Not started
  7. 425 Establish a significant emissions rate for greenhouse gases Notable Not started
  8. 426 Count life cycle emissions of electric vehicles in vehicle standards Notable Not started
  9. 426 Stop using ICAO to raise aircraft emission standards Notable Not started
  10. 426 Exempt efficiency improvements from triggering New Source Review permits Notable Not started
  11. 427 Automatically withdraw proposed CAA rules not finalized within one year Notable Not started
  12. 427 Exempt unregulated fugitive emissions from MACT standards Notable Not started
  13. 427 Reassess the Linear Non-Threshold radiation standard Notable Not started
  14. 429 Issue a rule setting a time limit on CWA Section 308 information requests Notable Not started
  15. 429 Issue a rule clarifying criminal negligence under CWA Sections 402 and 404 Notable Not started

and 62 more →

Needs Congress 9

  1. 425 Return the air standard-setting role to Congress Major Not started
  2. 435 Reform the Endangered Species Act as applied to pesticides Notable Not started
  3. 438 Create False Claims Act-style incentives for reporting scientific flaws Notable Not started
  4. 439 Legislate greater transparency for advisory bodies under FACA Notable Not started
  5. 439 Reject appropriations for unauthorized EPA programs like IRIS Notable Not started
  6. 440 Create a Senate-confirmed Assistant Administrator for the American Indian Office Notable Not started
  7. 430 Increase funding for the Clean Water Act needs survey Minor Not started
  8. 435 Attach guardrails and third-party audits to pesticide program funding increases Minor Not started
  9. 439 Legislate reform of EPA's Science Advisory Board and advisory bodies Minor Not started

All recommendations in this chapter

Every recommendation this chapter is the home of, in printed-page order.

  1. 421 Rename Deputy Chief of Staff for Policy as Deputy Chief of Staff, Regulatory Improvement Not started
  2. 421 Eliminate the Office of Environmental Justice and External Civil Rights Done
  3. 421 Eliminate the Office of Enforcement and Compliance Assistance Not started
  4. 421 Develop a plan to relocate EPA regional offices Partially done
  5. 421 Restructure the Office of International and Tribal Affairs into the American Indian Office Not started
  6. 421 Eliminate the Office of Public Engagement and Environmental Education Done
  7. 421 Move Office of Children's Health Protection and OSDBU out of the Administrator's office Not started
  8. 421 Review the EPA grants program for political affiliation Partially done
  9. 422 Reset EPA science advisory boards Done
  10. 422 Restore the EPA guidance portal Done
  11. 422 Issue a Day One executive order reorganizing EPA with pause-and-review teams Day one Partially done
  12. 422 Stay and repropose existing major EPA rules and guidance Done
  13. 422 Grant petitions for rule reconsideration and stays of rules Done
  14. 422 Stop all EPA grants to advocacy groups Partially done
  15. 422 Reassess sue-and-settle cases and adopt a new settlement policy Not started
  16. 422 Downsize EPA by terminating newest hires in low-value programs Partially done
  17. 422 Cut EPA costs, FTEs, and duplicative programs via a tiered-down budget Partially done
  18. 422 End EPA activities lacking clear congressional authorization Partially done
  19. 422 Revise guidance on the social cost of carbon and other regulatory inputs Partially done
  20. 423 Assemble and deploy the EPA political appointee team before Day One Day one Not started
  21. 423 Issue a rule on consistent and transparent consideration of costs at OAR Not started
  22. 423 Revise RACT cost guidance to reflect actual regulatory burden Not started
  23. 424 Conduct CAA Section 321 evaluations of job and plant-closure effects Not started
  24. 424 Direct Inflation Reduction Act air funding to states, not nonprofits Partially done
  25. 424 Remove the Super-Emitter Response Program and other third-party enforcement authority Attempted
  26. 424 Revise regional haze rules and the 2064 natural visibility goal Partially done
  27. 424 Reverse the Good Neighbor program's 2022 expansion beyond power plants Partially done
  28. 424 Require CAA Section 126(b) petitions to identify a discrete group of upwind sources Not started
  29. 424 Require CASAC to weigh all statutory factors including economic effects Not started
  30. 424 Strip non-statutory requirements from states that reach attainment status Not started
  31. 425 Streamline transportation conformity for federally funded highway projects Not started
  32. 425 Adopt policies preventing abuse of the CAA error correction authority Not started
  33. 425 Limit EPA reliance on CAA Section 301 general rulemaking authority Not started
  34. 425 Return the air standard-setting role to Congress Needs Congress Not started
  35. 425 Remove the Greenhouse Gas Reporting Program for unregulated source categories Partially done
  36. 425 Update the 2009 endangerment finding on a deadline Done
  37. 425 Establish a significant emissions rate for greenhouse gases Not started
  38. 425 Repeal Biden-era AIM Act implementing regulations for HFCs Partially done
  39. 425 Refuse manufacturer petitions adding new HFC restrictions Done
  40. 426 Conduct realistic cost assessments of the HFC phasedown program Not started
  41. 426 Set greenhouse gas car standards under Department of Transportation leadership Partially done
  42. 426 Review the ramp rate for vehicle standards for achievability Partially done
  43. 426 Count life cycle emissions of electric vehicles in vehicle standards Not started
  44. 426 Restrict California's Clean Air Act waiver to California-specific issues Partially done
  45. 426 Bar other states from adopting California greenhouse gas standards Partially done
  46. 426 Stop using ICAO to raise aircraft emission standards Not started
  47. 426 Reconsider the Cleaner Trucks Initiative Attempted
  48. 426 Exempt efficiency improvements from triggering New Source Review permits Not started
  49. 426 Restore the Trump EPA Once-In, Always-In position Done
  50. 426 Revisit 24/7/365 potential-to-emit assumptions in permitting Not started
  51. 427 Bar Title V objection petitions from second-guessing state decisions Done
  52. 427 Clarify the relationship between New Source Review and Title V Done
  53. 427 Require predicate findings before regulating a new pollutant under CAA 111 Partially done
  54. 427 Automatically withdraw proposed CAA rules not finalized within one year Not started
  55. 427 Revise CAA Section 111(d) implementing regulations to defer to states Attempted
  56. 427 Exempt unregulated fugitive emissions from MACT standards Not started
  57. 427 Harmonize CAA Section 112 regulations with Section 111 regulations Not started
  58. 427 Align EPA radiation standards with NRC, DOE, and DOT standards Not started
  59. 427 Reassess the Linear Non-Threshold radiation standard Not started
  60. 428 Place political appointees over OTAQ in Ann Arbor and OAQPS in Research Triangle Park Partially done
  61. 428 Establish a political Chief of Staff for the Office of Air and Radiation Not started
  62. 428 Move the Renewable Fuel Standard program into its own suboffice Not started
  63. 428 Require OAR approval before regional air enforcement actions Not started
  64. 428 Strictly enforce the 2019 Office of Water Policy for Draft Documents memo Not started
  65. 429 Repeal and reissue WOTUS and CWA Section 401 regulations Partially done
  66. 429 Issue a WOTUS rule codifying the Rapanos definition of navigable waters Needs Congress Partially done
  67. 429 Issue a CWA Section 401 water quality certification rule Partially done
  68. 429 Issue a rule setting a time limit on CWA Section 308 information requests Not started
  69. 429 Issue a rule clarifying criminal negligence under CWA Sections 402 and 404 Not started
  70. 429 Issue a rule prohibiting retroactive or preemptive CWA Section 404 permits Not started
  71. 429 Issue a rule promoting nutrient trading Attempted
  72. 429 Issue a compensatory mitigation rule imposing no new requirements Not started
  73. 429 Issue a rule updating the Clean Water Act needs survey Not started
  74. 430 Issue an executive order expediting state primacy in CWA and SDWA programs Partially done
  75. 430 Increase funding for the Clean Water Act needs survey Needs Congress Not started
  76. 430 Shift Office of Water SES staff to regional offices Not started
  77. 431 Require project management training for OLEM cleanup project managers Not started
  78. 431 Adopt EPA's Lean Management System across all OLEM programs Not started
  79. 431 Delegate CERCLA authority to the OLEM Assistant Administrator Not started
  80. 431 Transfer OLEM cleanup work and funding to states and tribes Not started
  81. 431 Revise the National Contingency Plan to streamline cleanups Not started
  82. 431 Increase use of CERCLA removal authority for short-term cleanups Not started
  83. 431 Streamline ARAR determinations across Superfund sites Not started
  84. 431 Revise groundwater cleanup regulations to account for PFAS Not started
  85. 431 Revisit the CERCLA hazardous substance designation for PFAS Not started
  86. 431 Let potentially responsible parties conduct Superfund five-year reviews Not started
  87. 432 Fully stand up the Office of Mountains, Deserts and Plains Partially done
  88. 432 Develop a 10-year lead cleanup plan for existing cleanup sites Not started
  89. 432 Create an RCRA post-closure care permit Not started
  90. 432 Promulgate a rule creating an alternative pathway for recycled materials Attempted
  91. 432 Make the hazardous waste e-manifest system 100 percent electronic Attempted
  92. 432 Move RCRA Section 3004 air emission standards to the air office Not started
  93. 432 Revise the Risk Management Program rule to restore 2019 amendments Partially done
  94. 432 Eliminate or consolidate EPA regional laboratories Partially done
  95. 433 Consolidate OLEM non-core functions into a single suboffice Partially done
  96. 433 Eliminate the Office of Emergency Management and reassign its functions Done
  97. 433 Drop "Emergency Management" from the OLEM name Not started
  98. 433 Make chemical decisions risk-based rather than hazard-based like IRIS Partially done
  99. 433 Narrow the scope of TSCA chemical evaluations to uncovered exposure pathways Attempted
  100. 434 Revise the regulations governing new chemical reviews Partially done
  101. 434 Presume OSHA compliance and PPE use in TSCA risk evaluations Partially done
  102. 434 Use real-world chemical use in conditions-of-use assessments Partially done
  103. 434 Transition the Safer Choice program to the private sector Not started
  104. 434 Right-size the TSCA fees rule Not started
  105. 434 Revise policies implementing the 2016 Lautenberg TSCA amendments Partially done
  106. 434 Develop a TSCA framework rule for existing chemical risk management Not started
  107. 434 Use USDA and state pesticide usage data in registration and ESA reviews Not started
  108. 434 Set data standards for information used in pesticide registration review Not started
  109. 435 Reform the Endangered Species Act as applied to pesticides Needs Congress Not started
  110. 435 Require other EPA offices to defer to the pesticide office on toxicity Not started
  111. 435 Send involuntary pesticide registration withdrawals through OMB review Not started
  112. 435 Attach guardrails and third-party audits to pesticide program funding increases Needs Congress Not started
  113. 436 Notify Congress that EPA will halt unauthorized science activities Day one Partially done
  114. 436 Apply the Inauguration Day regulatory freeze to EPA with no exceptions Day one Done
  115. 436 Pause and review all EPA contracts above $100,000 Day one Partially done
  116. 436 Invite the public to report EPA research misconduct and bad science Day one Not started
  117. 436 Eliminate the social cost of carbon and RCP 8.5 as regulatory inputs Day one Partially done
  118. 436 Nominate a reform-minded Assistant Administrator for Research and Development Not started
  119. 436 Appoint a Science Adviser and six senior political appointees over EPA science Partially done
  120. 437 Suspend and review the activities of EPA advisory bodies Partially done
  121. 437 Retract science and risk-assessment delegations from career officials Not started
  122. 437 Eliminate ORD's use of Title 42 hiring authority Not started
  123. 437 Announce a plan to streamline EPA's laboratory structure Partially done
  124. 437 Eliminate unauthorized ORD programs including IRIS Attempted
  125. 438 Move research misconduct review out of the Office of Scientific Integrity Partially done
  126. 438 Create False Claims Act-style incentives for reporting scientific flaws Needs Congress Not started
  127. 438 Stop using proprietary black box models in major EPA regulations Partially done
  128. 438 Reject the low-dose linear non-threshold model and precautionary defaults Partially done
  129. 439 Refocus EPA research using the 2018 Back-to-Basics NAAQS memo Not started
  130. 439 Use the Congressional Review Act to disapprove EPA regulations Needs Congress Done
  131. 439 Legislate reform of EPA's Science Advisory Board and advisory bodies Needs Congress Not started
  132. 439 Legislate greater transparency for advisory bodies under FACA Needs Congress Not started
  133. 439 Legislate transparent, reproducible science requirements for EPA rules Needs Congress Attempted
  134. 439 Reject appropriations for unauthorized EPA programs like IRIS Needs Congress Not started
  135. 439 Repeal or reform the Global Change Research Act of 1990 Needs Congress Attempted
  136. 440 Repeal Inflation Reduction Act environmental science grant programs Needs Congress Partially done
  137. 440 Elevate the American Indian Office to a stand-alone Assistant Administrator office Not started
  138. 440 Relocate the American Indian Office to the American West Not started
  139. 440 Run all EPA tribal grants and tribal matters through the American Indian Office Not started
  140. 440 Create a Senate-confirmed Assistant Administrator for the American Indian Office Needs Congress Not started
  141. 440 Place career tribal staff under the American Indian Office, not regional offices Not started
  142. 441 Redefine Environmental Justice and review EPA's Title VI authority Partially done
  143. 441 Pause and review all ongoing Environmental Justice and Title VI actions Partially done
  144. 441 House all attorneys authorized to represent EPA in the Office of General Counsel Not started
  145. 441 Move enforcement attorneys from OECA into the Office of General Counsel Not started
  146. 441 Move OECA non-attorney program staff into program offices Partially done
  147. 442 Create a Deputy General Counsel for Enforcement position Not started
  148. 442 Give OGC, not OCIR, the authority to assert EPA legal positions to Congress Not started
  149. 442 Require OGC approval of legal positions taken by Regional Counsel offices Not started
  150. 442 Stop EPA from publicly undermining other agencies' NEPA reviews Done
  151. 443 Consolidate OGC attorney functions into a Cross-Cutting Issues Law Office Not started
  152. 443 Review OGC telework policies and off-site attorney duty stations Attempted
  153. 443 Rotate SES managers out of OGC and the Regional Counsel offices Not started
  154. 443 Monitor all EPA external communications conveying a legal position Not started
  155. 443 Bar unapproved public events presenting EPA legal positions Not started
  156. 444 Pause and review all EPA grants over a set threshold Partially done
  157. 444 Put a political appointee in charge of the EPA grants office Not started
  158. 444 Cap Office of Research and Development grants and require Administrator review Attempted
  159. 444 Consolidate OCFO office space and security contracts Partially done
  160. 444 Fill senior OCFO posts with political appointees and create an Appropriations Liaison Not started