NEPA “Modernization”: From the Trump Administration to the Biden Administration

Researchers have recently examined changes to American environmental policy under the Trump administration's first term, and to a lesser extent, under the Biden administration. Scholars have largely not considered changes to the National Environmental Policy Act (NEPA), one of the earliest environmental laws in the United States, and a law that requires federal agencies to consider the environmental and social impacts of their proposed actions prior to implementation. The Trump administration adopted major changes to the NEPA regulations in 2020, and the Biden administration reviewed and revised these changes in 2022 and 2024. Using the flexible pattern matching methodological approach, I examine how these changes match or mismatch with the combined theoretical concepts of neoliberal bureaucratization and rationalization. Though the Trump (first term) and Biden administrations have been portrayed as radically different on environmental policies, my findings suggest the importance of taking a more nuanced perspective in understanding the similarities and differences in NEPA regulatory change under these two administrations.