Energy Policy Reversal during the Trump Administration: Examination of Its Legacy and Implications for Federalism

Abstract The Trump administration pursued eighty-four energy reversal actions between 2017 and 2020, the majority of which through executive action. In this article, we evaluate the effectiveness of such an administrative presidency in its ability to withstand political and legal challenges. We first set the context of U.S. energy policy predating the Trump administration, and then synthesize the administration’s reversal actions according to the mechanisms, the beneficiaries, and the legal process through which each evolved. We then analyze four reversal case studies that highlight how stakeholders responded to such actions, and the resulting variation in outcomes: the rollback of coal ash standards; the proposed coastal oil and gas auctions; the revocation of California’s vehicle emissions waiver; and the replacement of the Clean Power Plan with the Affordable Clean Energy rule. We find that the administration’s executive approach was regularly checked through litigation by states, interest groups, and industry, or had limited impact due to the high level of regulatory uncertainty that it fostered. We draw implications for ongoing state and federal dynamics and for the lasting durability of the Trump administration’s energy reversal legacy.