Deregulation has been atop President Donald Trump’s agenda since assuming office, particularly within the environmental sector. Some of the Trump administration’s earliest actions include issuance of executive orders aiming to ease the burden of existing regulations, and high-profile rollbacks of major Obama-era rules like the Clean Power Plan and Waters of the United States Rule. In addition, the Trump administration has sought to delay the implementation of a host of other rules that were published during the later years of President Obama’s second term.

Though much has been made of the current administration’s deregulatory efforts, Trump is not the first president to try to undo or delay the previous administration’s work. Just last month, the U.S. Court of Appeals for the D.C. Circuit in Air Alliance Houston v. Environmental Protection Agency—a case challenging EPA’s delay of certain amendments to the Risk Management Program under the Clean Air Act (CAA)—ordered EPA to produce a list of pre-Trump examples where a federal agency sought to delay a previous administration’s final rule. EPA’s response to the order included more than 20 EPA actions alone, and an additional 16 actions by other federal agencies, most of which occurred after presidential transitions.

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