Analysis: US Climate Policy Under the Trump Administration (2017–2026)

Abstract

The governance of climate change in the United States has historically been characterized by oscillation, but the era spanning the first and second terms of the Trump administration (2017–2021; 2025–Present) represents a structural decoupling from the global decarbonization trajectory. This report provides an exhaustive examination of the policy mechanisms employed to dismantle the U.S. climate regulatory architecture, ranging from the "Energy Dominance" doctrine of the first term to the legislative radicalism of the "One Big Beautiful Bill Act" (OBBBA) in the second. Through a synthesis of legal analysis, economic modeling, and Earth system science, we demonstrate how these administrative actions have created a "net-zero gap" of approximately 7 billion tonnes of CO2 equivalent by 2030. Furthermore, we analyze the long-term biophysical consequences of this policy shift, specifically the activation of irreversible feedback loops—including the destabilization of the Atlantic Meridional Overturning Circulation (AMOC), the degradation of the Amazonian hydrological pump, and the acceleration of permafrost thaw. The report concludes that the primary legacy of this era is not merely a delay in emissions reductions, but the engineering of a robust "carbon lock-in" that creates formidable physical and economic barriers to achieving climate stability for the remainder of the 21st century.

1. Introduction: The Pendulum and the Ratchet in Climate Policy Swings

The history of environmental policy in the United States is often viewed as a pendulum, swinging between periods of regulatory expansion and deregulatory retrenchment. However, the events spanning the last decade suggest that this metaphor is insufficient to capture the profound structural changes that have occurred. Rather than a pendulum, which returns to its center, the trajectory of U.S. climate policy under the Trump administration—across both the 2017–2021 term and the term beginning in 2025—resembles a ratchet. The dismantling of the administrative state’s capacity to regulate greenhouse gases has been systematic, creating legal and infrastructural realities that are difficult to reverse.

This report seeks to document the mechanics of this reversal. It is written from the perspective of early 2026, a vantage point that allows for the assessment of the immediate legislative impacts of the second term while contextualizing them within the longer arc of the first term’s regulatory philosophy. The analysis is grounded in the theory of "carbon lock-in," a concept describing how industrial economies become trapped in fossil fuel-based energy systems through the co-evolution of technology and institutions. The phenomenon of lock-in suggests that the "Energy Dominance" agenda is not merely a temporary policy preference but a strategic effort to entrench high-carbon infrastructure—pipelines, export terminals, and combustion-engine vehicle fleets—that will persist for decades due to their immense sunk costs and long economic lifespans.¹

To understand the magnitude of the current moment, we must first dissect the legal and administrative tools used to construct this new reality. We will explore how the "One Big Beautiful Bill Act" (OBBBA) systematically deconstructed the financial incentives for renewable energy, how executive orders paralyzed the federal bureaucracy’s ability to consider climate science, and how these human decisions translate into the impartial and unforgiving physics of the atmosphere.

The stakes of this analysis are defined by the "remaining carbon budget"—the finite amount of carbon dioxide that can be emitted before the 1.5°C or 2.0°C temperature thresholds of the Paris Agreement are breached. As we will demonstrate, the policy shifts of 2025 and 2026 have effectively exhausted the U.S. share of this budget, pushing the global climate system toward tipping points that lie beyond the reach of any future legislative correction.

2. The Architecture of Reversal: The First Term (2017–2021)

The first term of the Trump administration served as the proof-of-concept for the more aggressive actions taken in the second. Between 2017 and 2021, the administration initiated over 200 distinct rollbacks of environmental regulations. While often described in the media as "deregulation," this effort was more accurately a re-regulation—a restructuring of the legal environment to favor the extraction and combustion of fossil fuels.³

2.1 The "Energy Dominance" Doctrine

The guiding philosophy of the first term was "Energy Dominance." This doctrine posited that the United States should not merely seek energy independence but should aggressively maximize the production of oil, natural gas, and coal for export to leverage geopolitical influence. This framework necessitated the systematic removal of any regulatory friction that slowed extraction or increased the cost of fossil energy.

The implementation of this doctrine was seen most clearly in the administration's handling of the National Environmental Policy Act (NEPA). NEPA, often called the "Magna Carta" of environmental law, requires federal agencies to assess the environmental impact of major projects. The Trump administration finalized rules to narrow the scope of NEPA reviews, explicitly excluding the consideration of "cumulative" and "indirect" impacts—a legal term of art that effectively meant agencies could ignore climate change, as any single project's contribution to global CO2 concentrations is technically small, even if the aggregate effect is catastrophic.⁴

2.2 The War on Standards: SAFE vs. CAFE

Perhaps the most consequential domestic policy of the first term was the assault on vehicle emissions standards. The transportation sector is the largest source of greenhouse gas emissions in the U.S. economy, and the Corporate Average Fuel Economy (CAFE) standards are the primary lever for reducing them.

Under the Obama administration, automakers were required to improve fleetwide fuel efficiency by approximately 5% per year, a trajectory designed to force the electrification of the vehicle fleet. The Trump administration replaced this with the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, which reduced the required improvement to a negligible 1.5% annually.

Scientific and Industrial Implications:

The scientific justification provided for the SAFE rule relied on a controversial interpretation of safety data, arguing that cheaper, heavier, less efficient cars were safer for passengers. However, the biophysical impact was clear: it decoupled the U.S. market from the global trend toward efficiency.

• Fleet Turnover Dynamics: A passenger vehicle has a median lifespan of roughly 12 to 15 years. By relaxing standards for the model years 2021–2026, the administration ensured that millions of less efficient internal combustion engine (ICE) vehicles would be sold. These vehicles constitute a "committed emissions" wedge—they will continue to burn gasoline and emit CO2 well into the late 2030s.

• Emissions Impact: Rhodium Group modeling estimated that this single rule change, if left in place, would add approximately 600 million metric tons of CO2 to the atmosphere by 2035—roughly equivalent to the total annual emissions of Canada.⁶

2.3 The Clean Power Plan and the Rebound Effect

In the power sector, the administration targeted the Clean Power Plan (CPP), which had been designed to shift electricity generation from coal to natural gas and renewables. The EPA repealed the CPP and replaced it with the Affordable Clean Energy (ACE) rule.

The ACE rule was distinct in its "inside the fenceline" approach. It limited the EPA's regulatory authority to efficiency improvements that could be made within the physical footprint of an individual power plant. This was a critical legal distinction. By preventing the EPA from considering "system-wide" shifts (like building wind farms to replace coal plants), the ACE rule structurally limited the potential for decarbonization.

The Rebound Paradox:

From a thermodynamic and economic perspective, the ACE rule introduced a perverse incentive known as the "rebound effect." By requiring coal plants to make minor efficiency upgrades (heat rate improvements), the rule effectively lowered the operating costs of these aging facilities. This made them more competitive in the wholesale electricity market, potentially leading to increased utilization and higher overall emissions compared to a scenario where they were simply allowed to retire due to inefficiency. This policy was not just a pause on climate action; it was a lifeline to the most carbon-intensive assets in the energy fleet.3

2.4 The First Withdrawal from Paris

The diplomatic capstone of the first term was the withdrawal from the Paris Agreement. While the legal withdrawal process took three years to complete (finalizing on November 4, 2020), the announcement in 2017 immediately shattered the global diplomatic consensus.

The mechanism of the Paris Agreement relies on "Nationally Determined Contributions" (NDCs)—voluntary pledges that are supposed to be ratcheted up every five years. The U.S. withdrawal removed the pressure for other nations to increase their ambition. Brazil, Australia, and other nations utilized the U.S. exit as political cover to weaken their own environmental enforcement. The biophysical result was a "lost half-decade" of global climate action during a window when the IPCC Special Report on 1.5°C (2018) warned that radical reductions were urgently needed.⁹

3. The Legislative Pivot: The 2025 "Shock and Awe" Campaign

If the first term was characterized by administrative attrition, the second term, beginning in January 2025, was defined by legislative shock and awe. Having learned from the procedural setbacks of the first term—where many rollbacks were overturned by courts for violating the Administrative Procedure Act—the administration arrived with a coordinated plan to use statutory law to permanently dismantle the U.S. climate apparatus.

3.1 Executive Order 14156: "Unleashing American Energy"

On inauguration day, January 20, 2025, President Trump signed Executive Order 14156, colloquially titled "Unleashing American Energy." This order was far more expansive than its predecessors. It declared a "national energy emergency," a legal status that unlocked extraordinary powers for the executive branch to bypass standard regulatory hurdles.¹¹

Key Provisions:

1. Mandatory Rescission: The order directed all agency heads to identify and rescind any regulation burdening the development of domestic energy resources within 30 days. This created a "guillotine" for environmental rules, forcing agencies to slash protections without the lengthy notice-and-comment periods usually required.

2. The End of the "Social Cost of Carbon": The order formally revoked the interagency working group on the Social Cost of Carbon (SCC). The SCC is a metric used in cost-benefit analyses to quantify the economic damage of one ton of CO2 emissions. By setting this value to near zero (or focusing only on domestic impacts), the administration mathematically justified the approval of high-emissions projects, arguing that their economic benefits outweighed their "zero" calculated climate costs.

3. The Second Paris Withdrawal: The President signed the instrument to withdraw from the Paris Agreement immediately. Unlike the first term, this withdrawal was accompanied by a cessation of all funding to the UNFCCC and the IPCC, severing the U.S. from the international scientific community.¹⁰

3.2 The "One Big Beautiful Bill Act" (OBBBA)

The legislative vehicle for the second term's agenda was the "One Big Beautiful Bill Act" (OBBBA), signed into law on July 4, 2025. This omnibus legislation was a direct negation of the Biden-era Inflation Reduction Act (IRA).¹⁵

Dismantling the Green Tax Code:

The IRA had utilized the tax code to make renewable energy cheaper than fossil fuels. The OBBBA systematically dismantled these incentives:

• Repeal of Section 45 and 48 Credits: The production tax credit (PTC) for wind and the investment tax credit (ITC) for solar were eliminated for all projects commencing construction after the bill's enactment. This sudden removal of subsidies caused an immediate capital flight from the sector.

• The EV Credit Reversal: The Section 30D tax credit of $7,500 for electric vehicles was repealed. This change fundamentally altered the economics of EV ownership for the average American consumer, stalling the demand growth that automakers had banked on.

• Foreign Entity of Concern (FEOC) Expansion: The OBBBA expanded the "Foreign Entity of Concern" rules to be draconian. It denied tax credits not just to vehicles with battery components from China, but to any energy project with even tangential supply chain links to "adversarial nations." Given China's dominance in the solar and battery supply chains, this effectively disqualified the vast majority of planned renewable projects from receiving any remaining federal support.¹⁸

Incentivizing the Old Order:

In place of green incentives, the OBBBA introduced provisions to support fossil fuels:

• Accelerated Depreciation for Gas Infrastructure: The bill allowed for the rapid depreciation of natural gas pipelines and LNG terminals. This tax treatment effectively subsidized the capital costs of new fossil fuel infrastructure, encouraging a build-out that market forces alone might not have supported.¹⁵

3.3 The Impact on Deployment

The market reaction to the OBBBA was swift and severe. Analysis by Carbon Brief and the REPEAT Project quantified the impact:

• Solar and Wind: Cumulative solar capacity additions are projected to be 29 GW lower by 2030 than they would have been under the IRA. Wind capacity is projected to be 43 GW lower.

• Electric Vehicles: The removal of the 30D credit is expected to result in millions of fewer EVs on the road by 2030, keeping gasoline demand artificially high.

• The Emissions Gap: The cumulative effect of these legislative changes creates an emissions gap of 7 billion tonnes of CO2e between 2025 and 2030 compared to the Paris-aligned trajectory. This is a massive deviation, representing a structural break from the path to net-zero.¹⁷

4. Legal Warfare: Federal Preemption and the Battle for States' Rights

Recognizing that many states (particularly California and the Northeast) would attempt to fill the federal policy vacuum, the Trump administration launched a novel legal strategy in its second term to preempt state-level climate action.

4.1 Executive Order: "Protecting American Energy from State Overreach"

On April 8, 2025, the President issued an executive order directing the Attorney General to challenge any state law that "impedes the production or transport of American energy." This order inverted the traditional conservative stance on states' rights, arguing that state climate policies violated the Commerce Clause of the Constitution by discriminating against energy products from other states (e.g., oil from Texas or coal from Wyoming).¹⁹

4.2 The Attack on California's Waiver

The Clean Air Act grants California a unique waiver to set vehicle emissions standards stricter than the federal government's. The Trump administration moved to revoke this waiver for a second time.

• The Argument: The administration argued that the waiver was intended for local pollution (smog), not global pollutants like CO2. They contended that by regulating CO2, California was effectively setting a national fuel economy standard, which is the sole prerogative of the federal government (preempted by the Energy Policy and Conservation Act).

• The Impact: This move created regulatory chaos. Automakers, who rely on the California standard to guide their long-term product planning, were left in limbo. The uncertainty acted as a de facto freeze on progress, as manufacturers delayed investments in EV production lines until the litigation could be resolved—a process likely to take years.²¹

4.3 Litigation: OEC v. IRS and the Battle for Transition

The resistance to these policies moved to the courts. A landmark case, Oregon Environmental Council (OEC) v. IRS, was filed in late 2025.

• The Complaint: The plaintiffs challenged the IRS guidance issued under the OBBBA, which eliminated "safe harbor" provisions for renewable energy projects. Previously, developers could qualify for tax credits if they had invested 5% of the project cost. The new IRS rules, under pressure from the administration, removed this pathway for wind and solar while retaining it for fossil fuel projects.

• The Argument: The plaintiffs argued this distinction was "arbitrary and capricious" under the Administrative Procedure Act (APA), lacking any rational basis other than animus toward renewable energy. This lawsuit highlighted the administration's use of bureaucratic procedure as a weapon to stall clean energy deployment.²³

5. The Biophysical Reality: Feedbacks, Tipping Points, and the Carbon Gap

The laws and lawsuits described above are merely the human inputs into a much larger, impartial system: the Earth's climate. The true detrimental effect of the Trump administration's policies is the activation of biophysical mechanisms that cannot be repealed by Congress or overruled by the Supreme Court.

5.1 The 7-Gigaton Gap and the Carbon Budget

The concept of a "carbon budget" is central to understanding the long-term damage. To limit warming to 1.5°C, humanity has a fixed number of tonnes of CO2 left to emit.

• The Deficit: The policies of the second Trump term add an estimated 4 billion tonnes of additional emissions by 2030 (Carbon Brief analysis) to 7 billion tonnes (REPEAT Project analysis) compared to the previous trajectory.

• The Consequence: This excess usage of the carbon budget effectively bankrupts the U.S. contribution to the 1.5°C goal. Biophysically, this means the U.S. is pushing the world into "overshoot" scenarios, where temperature targets are exceeded, necessitating unproven negative emissions technologies in the future to pull CO2 back out of the air.¹⁷

5.2 Methane: The Short-Lived Forcing Multiplier

A critical component of the "Energy Dominance" agenda was the deregulation of methane emissions from the oil and gas sector.

• The Mechanism: Methane (CH4) is a potent greenhouse gas, 80 times more powerful than CO2 over a 20-year period. By removing requirements for leak detection and repair (LDAR) at wellheads and pipelines, the administration sanctioned the release of "fugitive emissions."

• The Chemistry: Methane in the atmosphere is broken down by hydroxyl radicals (OH). However, a rapid surge in methane emissions can deplete the available OH concentrations, extending the lifetime of the methane that remains. This non-linear atmospheric chemistry means that the warming impact of the Trump-era methane surge could be longer-lasting and more intense than standard models predict.⁶

5.3 Tipping Points: The Point of No Return

The most profound long-term risk of the Trump administration's high-emissions trajectory is the triggering of planetary tipping points. These are thresholds where a small additional amount of warming triggers a self-perpetuating change in a major Earth system component.

5.3.1 The Atlantic Meridional Overturning Circulation (AMOC)

The AMOC is the "conveyor belt" of the ocean, moving warm salty water north and cold fresh water south. It is a primary regulator of global climate.

• The Mechanism: Salt-Advection Feedback: The AMOC is driven by density. Salty water is dense and sinks in the North Atlantic. The circulation itself brings salty water north, maintaining the density required for sinking. This is a self-sustaining loop.

• The Trump Effect: The accelerated warming caused by U.S. policy deviations accelerates the melting of the Greenland Ice Sheet. This injects massive volumes of fresh water into the North Atlantic. Freshwater is buoyant and does not sink. This dilutes the salinity, weakening the density-driven sinking.

• The Bifurcation: If the freshwater input crosses a critical threshold (the Stommel Bifurcation), the self-sustaining salt loop is broken. The AMOC could slow dramatically or collapse entirely. Research indicates the tipping point could be between 2.5°C and 4°C of warming, ranges that become increasingly likely under the Trump administration's "high emissions" scenarios. A collapse would catastrophically alter weather patterns, causing severe cooling in Europe, sea-level rise on the U.S. East Coast, and the disruption of monsoons essential for global agriculture.²⁸

5.3.2 The Amazon Rainforest Dieback

The Amazon rainforest is not just a collection of trees; it is a biotic pump.

• The Mechanism: Moisture Recycling: Trees in the Amazon transpire water vapor into the atmosphere. This vapor forms clouds that are blown westward, raining down and sustaining the forest further inland. This "moisture recycling" accounts for up to 50% of the rainfall in the basin.

• The Threshold: Deforestation and warming weaken this pump. If the forest becomes too fragmented or the climate too hot (approaching 3°C), the recycling mechanism fails. The rainforest abruptly transitions into a fire-prone savannah.

• Policy Link: The U.S. withdrawal from international climate finance and biodiversity protection, combined with trade policies that favor agricultural commodities (soy/beef), exacerbates the pressure on the Amazon. Crossing this tipping point would release the massive stores of carbon held in the Amazon's biomass, creating a "carbon bomb" that no human policy could mitigate.³²

5.3.3 Permafrost Thaw and the Microbial Loop

In the Arctic, the administration’s policies accelerate "Arctic Amplification," where the poles warm much faster than the global average.

• The Mechanism: Permafrost contains organic carbon frozen for millennia. As it thaws, microbes break this carbon down. This decomposition is an exothermic (heat-releasing) reaction, which can thaw more soil even without external warming.

• The Trap: This is a positive feedback loop. The release of CO2 and methane from thawing permafrost causes more warming, which causes more thawing. The Trump administration's policies, by ensuring higher peak temperatures, commit the planet to centuries of permafrost emissions, long after the U.S. might eventually reach net-zero.³⁴

6. Infrastructure Inertia: The Economics of Carbon Lock-In

While tipping points represent biophysical lock-in, the Trump administration also engineered a powerful economic lock-in. The infrastructure built during these years—pipelines, terminals, and power plants—creates a financial imperative to continue emitting carbon.

6.1 The LNG "Golden Age" and Sunk Costs

The second term oversaw a massive expansion of Liquefied Natural Gas (LNG) export capacity. By expediting permits and removing the "public interest" pause on LNG reviews, the administration facilitated the construction of terminals with operational lifespans of 30 to 50 years.

• Depreciation and Class Life: Under IRS and FERC rules, these assets are depreciated over long periods (e.g., 20–35 years for pipelines and terminals).³⁷ This accounting reality means that the capital costs are recovered slowly.

• The Lock-In: Once billions of dollars are sunk into a terminal, the owners (and their financiers) will lobby aggressively to ensure the facility remains utilized to pay back the debt. This creates a structural political constituency for continued gas extraction and export through the year 2050 and beyond, directly contradicting net-zero goals.³⁹

6.2 Stranded Assets vs. Ratepayer Bailouts

The conflict between this infrastructure and the necessity of future decarbonization creates a dilemma. If future administrations impose climate regulations, these new pipelines will become "stranded assets." However, because many of these assets are regulated by FERC, pipeline companies may attempt to pass these stranded costs onto ratepayers (consumers). The Trump administration’s policies have thus set the stage for a future economic crisis: either the climate is sacrificed to protect asset values, or the public is forced to bail out bad investments made during the "Energy Dominance" era.⁴¹

7. Conclusion: The Long Shadow

The legacy of the Trump administration’s climate policies, spanning the first and second terms, is a profound alteration of the United States' developmental trajectory. By treating environmental regulation as an impediment to be removed rather than a safeguard for the future, the administration successfully engineered a "Great Divergence" from the global path toward sustainability.

The consequences are not theoretical. They are measured in the 7 billion tonnes of excess carbon in the atmosphere, in the salt-advection feedbacks slowing the North Atlantic currents, and in the sunk capital of a revitalized fossil fuel infrastructure. The administration did not merely pause climate action; it actively constructed barriers—legal, physical, and economic—to its resumption.

As the world moves deeper into the 21st century, the "lost decade" of U.S. climate leadership will likely be viewed as a decisive moment where the window for a managed, orderly transition to net-zero was closed, forcing future generations to confront a more chaotic, volatile, and dangerous planetary reality.

Table 1: The Carbon Gap - Projected vs. Required Emissions (2030)

Scenario	Projected Emissions Reduction (vs 2005)	Cumulative Excess Emissions (2025–2030)
Paris Agreement Goal (NDC)	-50% to -52%	--
Biden Baseline (IRA)	-40%	+2.0 Gt CO2e
Trump 2.0 (OBBBA)	-20% to -28%	+7.0 Gt CO2e

Source: Derived from Carbon Brief ¹⁷ and Rhodium Group ⁴³ analysis.

Table 2: Key Tipping Point Thresholds Risks

Tipping Element	Mechanism	Estimated Threshold (Warming)	Trump Policy Risk Factor
AMOC	Salt-Advection Feedback	2.5°C – 4.0°C	High: Accelerated Greenland melt via high emissions.
Amazon Rainforest	Moisture Recycling Failure	2.5°C – 3.0°C	High: Diplomatic withdrawal from protection; trade policy.
Permafrost	Microbial Decomposition	> 1.5°C	Very High: Arctic Amplification from global overshoot.

Source: IPCC AR6 ³¹ and Research Snippets.²⁸

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