Sabin Center's Climate Deregulation Tracker, By the Numbers: The Systemic Dismantling of U.S. Climate Policy

Abstract

The trajectory of environmental governance in the United States has historically been defined by a tension between regulatory expansion and administrative retrenchment. This report provides an exhaustive analysis of the latter, utilizing the "Climate Deregulation Tracker" and "Climate Backtracker" developed by the Sabin Center for Climate Change Law at Columbia Law School as primary diagnostic tools. By cataloging and analyzing hundreds of distinct administrative, legislative, and executive actions taken during the Trump administrations (2017–2021 and the term commencing in 2025), this document reconstructs the systemic dismantling of the federal climate mitigation apparatus. We examine the specific legal mechanisms employed to repeal foundational policies such as the Clean Power Plan and the Corporate Average Fuel Economy (CAFE) standards, while exploring the technical and economic justifications—ranging from the manipulation of the Social Cost of Carbon to the revision of methane leak detection frequencies—used to support these shifts. Furthermore, we assess the environmental consequences of these actions, projecting the aggregate impact of regulatory rollbacks on domestic greenhouse gas emissions and the global climate system. The analysis reveals a sophisticated, multi-sectoral strategy of "energy dominance" that prioritizes fossil fuel extraction through the deliberate blinding of the administrative state to long-term environmental risks.

1. Introduction: The Oscillating State of Climate Policy in the US

The governance of climate change in the United States is not a linear progression toward sustainability but rather a volatile oscillation driven by the shifting interpretive philosophies of the executive branch. The legal bedrock of U.S. environmental policy—statutes such as the Clean Air Act, the National Environmental Policy Act (NEPA), and the Energy Policy and Conservation Act—provides broad mandates for environmental protection. However, the specific application of these laws is largely determined by administrative agencies, whose regulatory priorities can change dramatically with the inauguration of a new president.

The Sabin Center for Climate Change Law at Columbia Law School established the Climate Deregulation Tracker in 2017 to capture this volatility in real-time.¹ This initiative was born from the recognition that "deregulation" is rarely a singular event. It is, instead, a complex, diffuse process involving the delay of compliance dates, the revision of technical guidance documents, the defunding of scientific research, and the strategic narrowing of agency authority.¹ By logging these actions, the Tracker created a digital archive of the federal government's pivot away from climate mitigation during the first Trump administration.

Following the return of the Trump-Vance administration in January 2025, the Sabin Center launched a successor tool, the Climate Backtracker, to monitor a renewed and accelerated phase of deregulatory activity.³ Within the first year of this second term alone, the tracker recorded over 304 distinct deregulatory actions, signaling a doubling down on the strategies developed during the previous term.³ These trackers serve as the primary evidentiary basis for this report, which seeks to synthesize thousands of discrete bureaucratic maneuvers into a coherent narrative of policy reversal.

The significance of these tracking efforts lies in their ability to reveal the "regulatory yoyo" effect. Regulations implemented by one administration are suspended by the next, reinstated by a third, and repealed again by a fourth.⁵ This instability creates a challenging environment for long-term infrastructure planning and international diplomacy. By deconstructing the specific actions recorded in the trackers, we can understand how the executive branch utilizes the machinery of government to achieve "energy dominance"—a policy paradigm prioritizing the maximization of domestic fossil fuel production—and the concomitant marginalization of climate change as a regulatory imperative.³

This report explores the distinct theaters of this regulatory conflict. We examine the stationary power sector, where the battle over coal-fired power plants highlights the legal struggles over the Environmental Protection Agency's (EPA) authority. We then traverse to the transportation sector, analyzing the contentious rollback of fuel efficiency standards and the preemption of state authority. Subsequent sections explore the deregulation of methane emissions in the oil and gas industry, the opening of sensitive public lands like the Arctic National Wildlife Refuge to extraction, and the procedural changes to environmental review processes. Finally, we assess the cumulative quantitative impact of these measures, translating bureaucratic rule changes into gigatons of carbon dioxide equivalent emitted into the atmosphere.

2. Methodologies of Surveillance: Documenting the Retreat

To understand the scope of the findings presented herein, one must first understand the instrument of observation. The Climate Deregulation Tracker and its successor, the Climate Backtracker, employ a rigorous methodology to identify, categorize, and archive government actions, providing a taxonomy of the modern deregulatory state.

2.1 Scope, Definition, and the Database of Record

The trackers define "deregulation" broadly to encompass any effort to scale back, eliminate, or impede federal climate mitigation and adaptation measures.¹ This definition captures a wide array of administrative behaviors that might otherwise escape public notice. The scope includes:

• Executive Orders: Presidential directives that set strategic priorities or revoke previous orders. For example, the revocation of flood management standards or orders expediting infrastructure reviews.⁴

• Agency Rulemaking: The formal process of creating, amending, or repealing regulations through the Federal Register. This is the primary mechanism for changing binding law, such as the repeal of the Clean Power Plan.⁷

• Guidance Documents: Non-binding agency statements that interpret existing rules. These are often used to signal a relaxation of enforcement or a change in how a regulation is applied in practice.¹

• Congressional Review Act (CRA) Resolutions: Legislative tools used to overturn recently finalized regulations by a simple majority vote. This tool was used aggressively to repeal the Bureau of Land Management's (BLM) Methane Waste Prevention Rule.⁶

• Budgetary Actions and Personnel: Proposals to defund specific programs or research initiatives, and the appointment of personnel hostile to agency missions.⁵

The Sabin Center links these trackers to a broader "Climate Regulation Database," ensuring that every deregulatory action is contextualized against the history of the regulation it seeks to undo.³ This linkage is crucial for legal scholars and policy analysts, as it highlights the cyclical nature of U.S. climate policy. The database organizes actions across various federal agencies, including the Council on Environmental Quality (CEQ), the Department of Energy (DOE), and the EPA, creating a comprehensive map of the federal climate bureaucracy.⁸

2.2 Categorization and Sectoral Analysis

The trackers organize actions by agency and sector, revealing the ubiquity of the deregulatory agenda. While the EPA and the Department of the Interior (DOI) are the most active entities, the data shows involvement from the Department of Energy (DOE), the Department of Transportation (DOT), and even the Department of Housing and Urban Development (HUD).⁸

Key sectors identified in the tracker include:

• Energy and Fossil Fuels: Encompassing coal leasing, power plant emissions, and oil and gas permitting.⁷ This sector is the primary target of "energy dominance" policies.

• Transportation: Covering vehicle emissions standards and infrastructure planning.⁷ This sector represents the largest source of U.S. emissions.

• Environmental Protection and Science: Focusing on NEPA reviews, the Endangered Species Act, and the usage of science in rulemaking.⁷

• Appliances and Efficiency: Tracking changes to energy conservation standards for consumer products, a niche but impactful area of deregulation.⁷

2.3 The "Silencing Science" Parallel

A unique and disturbing subset of this tracking effort is the Silencing Science Tracker, a joint initiative with the Climate Science Legal Defense Fund.⁵ This tool monitors government attempts to restrict scientific research or education. It categorizes actions into three primary forms:

1. Government Censorship: This involves changing the content of websites and documents to suppress or distort scientific information. For instance, the removal of climate change data from EPA websites.⁹

2. Self-Censorship: This captures instances where scientists voluntarily change the content of websites or documents to suppress scientific information, potentially in response to political pressure or fear of retaliation.⁹

3. Research Hindrance: This includes destroying data needed to undertake scientific research, preventing the publication of findings, or pressuring scientists to alter their conclusions.⁹

The existence of this parallel tracker underscores a critical theme of this report: the deregulatory agenda is often predicated on the suppression or obfuscation of the scientific consensus regarding climate risks. By silencing the science, the administration seeks to undermine the legal and factual basis for regulation itself.

3. Stationary Sources: The Legal War for the Power Grid

The regulation of greenhouse gas emissions from stationary sources—primarily coal- and natural gas-fired power plants—represents the "ground zero" of federal climate litigation. The Climate Deregulation Tracker documents a concerted effort to dismantle the regulatory framework established under the Obama administration, specifically the Clean Power Plan (CPP), and replace it with a narrower, less stringent regime known as the Affordable Clean Energy (ACE) rule.

3.1 The Clean Power Plan vs. The ACE Rule

The Clean Power Plan, finalized in 2015, was ambitious in its scope. It interpreted Section 111(d) of the Clean Air Act to allow for a "best system of emission reduction" (BSER) that included "generation shifting"—moving electricity production from high-emitting coal plants to lower-emitting natural gas and renewable sources. This approach recognized the interconnected nature of the electrical grid, where electrons from wind farms and coal plants mix freely.

The Trump administration's EPA, however, argued that this interpretation exceeded statutory authority. In replacing the CPP with the ACE rule, the agency adopted a restrictive view of the Clean Air Act, limiting the BSER to "inside the fence-line" measures.¹⁰ This meant that the only permissible regulations were those that could be applied to the physical equipment of an individual power plant, such as heat rate improvements (efficiency upgrades), rather than systemic changes to the power grid.

Table 1: Comparative Analysis of CPP and ACE Rule Frameworks

Feature	Clean Power Plan (CPP)	Affordable Clean Energy (ACE) Rule
Regulatory Philosophy	System-wide "generation shifting" (renewables/gas)	Source-specific "inside the fence-line" upgrades
Best System of Emission Reduction	Included demand-side efficiency and fuel switching	Limited to Heat Rate Improvements (HRI)
State Authority	States given targets; flexible compliance mechanisms	States given broad discretion to set unit-specific standards
Projected CO2 Reduction (2030)	approx. 32% below 2005 levels	approx. 0.7% to 1.5% below baseline projections

3.2 Emissions Implications and the Rebound Effect

The shift from CPP to ACE was not merely a legal technicality; it had profound implications for carbon dioxide emissions. The EPA's own Regulatory Impact Analysis (RIA) for the ACE rule admitted that the regulation would result in minimal emission reductions compared to a business-as-usual baseline. Specifically, the RIA calculated that the ACE rule would reduce carbon dioxide emissions in 2025 by between 13 and 30 million short tons.¹¹

To put this in perspective, independent analyses by the Rhodium Group and others noted that the difference in emissions between the CPP and the ACE rule was stark. The ACE rule's focus on efficiency upgrades created a potential "rebound effect." By making coal plants slightly more efficient, their operating costs could decrease (using less coal per megawatt-hour). In a competitive electricity market, lower operating costs could lead these plants to be dispatched more frequently, potentially delaying their retirement.¹³ This phenomenon could, in certain scenarios, lead to a net increase in emissions at specific facilities compared to a scenario with no regulation at all.

Furthermore, the Tracker highlights that the EPA proposed less stringent emission standards for new coal plants, signaling a desire to keep the pathway open for future coal infrastructure, despite market trends heavily favoring natural gas and renewables.⁶ The "war on coal" narrative drove policy that sought to artificially extend the lifespan of an industry facing structural economic decline, utilizing the regulatory process to shield it from the full weight of environmental externalities.

3.3 The New Source Review (NSR) Loophole

A critical, often overlooked component of the ACE rule tracked by the Sabin Center was the amendment to the New Source Review (NSR) permitting program. The NSR program requires power plants to install modern pollution controls (like scrubbers) if they undertake major renovations that increase emissions.

The ACE rule proposed changing the accounting method for triggering NSR from an annual emissions increase to an hourly emissions increase.¹⁰ This change is significant and highly technical. A coal plant could undergo a massive renovation that allows it to run for many more hours in the year—vastly increasing its total annual pollution—but if its emissions per hour did not increase, it would avoid triggering the requirement to install new pollution controls. This regulatory sleight of hand exemplifies the granular mechanisms of deregulation: a technical change in a denominator that results in tons of additional unmitigated pollution.

4. Mobile Sources: The SAFE Vehicles Rule and the Preemption of California

While power plants are major emitters, the transportation sector has emerged as the largest source of greenhouse gas emissions in the United States. The deregulation of this sector, as documented by the Tracker, involved a dual attack: rolling back federal fuel efficiency standards and revoking the unique legal authority of California to set stricter standards.

4.1 From CAFE to SAFE: The Rollback

Under the Obama administration, the Corporate Average Fuel Economy (CAFE) standards and greenhouse gas standards were set to increase in stringency by approximately five percent per year, aiming for a fleet-wide average of over 50 miles per gallon by 2025. The Trump administration's response was the "Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule."

The SAFE rule froze standards at 2020 levels for several years before allowing a meager 1.5 percent annual increase.¹⁴ The administration argued that this rollback would lower vehicle prices, allowing consumers to replace older, unsafe cars with newer, safer ones more quickly—a rationale that gave the rule its acronym.

However, the scientific and economic consensus challenged this "safety" argument. The Council of Economic Advisers (CEA) argued that the marginal cost of complying with the stricter 2012 rule was prohibitively high.¹⁴ Yet, independent analyses and academic critiques pointed out severe flaws in the "scrappage model" used to justify the rule.¹⁶ Critics noted that the administration's model violated basic economic theory and that the fuel savings from more efficient vehicles often outweighed the upfront cost increases for consumers.¹⁷ The "safety" argument was widely viewed by experts as a pretext for deregulation, with the real driver being the relief of regulatory pressure on automakers who had lagged in efficiency innovation.

4.2 The "One National Program" and the Revocation of the Waiver

Perhaps the most constitutionally significant action tracked was the revocation of California's waiver under the Clean Air Act. For decades, California had been granted a waiver to set tailpipe emissions standards stricter than the federal minimum, a right necessitated by the state's severe smog problems. Section 177 of the Clean Air Act allowed other states to adopt California's standards, creating a powerful market bloc that drove the auto industry toward cleaner technologies.

The "Part One" of the SAFE Rule, finalized in September 2019, asserted that federal law (specifically the Energy Policy and Conservation Act of 1975) preempted state regulations of tailpipe carbon dioxide emissions because they were effectively fuel economy standards.¹⁹ This move stripped California and the "Section 177 States" (which include New York, Massachusetts, and others) of their ability to regulate greenhouse gases from vehicles.

The Tracker notes the immense legal backlash to this decision, with major environmental groups and a coalition of states filing suit immediately.¹⁹ The litigation highlighted a key insight: the deregulatory agenda was not just about lowering standards but about centralizing power in the federal executive to prevent sub-national actors from filling the climate policy void. It represented a shift from "cooperative federalism"—where states and the federal government work together—to a coercive federalism that enforced inaction.

4.3 Carbon Consequences of the Rollback

The emissions impact of the SAFE rule was staggering. The Rhodium Group estimated that freezing the standards would increase U.S. carbon dioxide emissions by 321 to 931 million metric tons cumulatively between 2022 and 2035.²¹ To contextualize this, the upper bound of this increase is larger than the combined annual emissions of the seventy smallest countries in the world. By allowing vehicles to consume more gasoline for every mile driven, the administration effectively locked in higher emissions for the 12-to-15-year lifespan of every vehicle sold during the deregulation window. This "lock-in" effect is one of the most pernicious aspects of infrastructure deregulation; the consequences persist long after the rule itself may be reversed.

5. Methane and the Oil & Gas Sector: Unplugging the Leaks

Methane is a potent greenhouse gas, with a global warming potential (GWP) more than eighty times that of carbon dioxide over a twenty-year period. Consequently, regulating methane leaks from oil and gas infrastructure is considered one of the most cost-effective ways to slow near-term warming. The Tracker documents a systematic dismantling of the Obama-era New Source Performance Standards (NSPS) known as "Subpart OOOOa."

5.1 The 2020 Policy and Technical Amendments

The EPA under the Trump administration issued two main rules in 2020 to weaken methane protections: the "Policy Rule" and the "Technical Rule".²²

1. The Policy Rule: This rule rescinded the methane-specific standards for the production and processing segments of the industry and, crucially, removed the "transmission and storage" segment from regulation entirely.²² The administration argued that methane was already controlled as a co-benefit of regulating Volatile Organic Compounds (VOCs), rendering specific methane targets redundant. However, this legal maneuver removed the trigger that would have required the regulation of existing sources, leaving thousands of older wells and pipelines effectively unregulated.

2. The Technical Rule: This rule relaxed the frequency of leak detection and repair (LDAR) inspections. Where the 2016 rule required quarterly inspections for compressor stations, the 2020 rule moved to semiannual monitoring.²³

5.2 The Low-Production Well Exemption

A critical detail highlighted in the research is the treatment of "low production" or marginal wells (those producing less than 15 barrels of oil equivalent per day). The 2020 rules introduced exemptions that relieved operators of these wells from the obligation to conduct routine leak monitoring.²³

While individual marginal wells produce little product, they are numerous and disproportionately leaky. Research indicates that these wells are responsible for a significant fraction of total industry emissions. By exempting them, the administration effectively blinded the regulatory regime to one of the largest sources of methane pollution. The Tracker shows that the reinstatement of stronger rules under the Biden administration (and subsequent attacks by Trump 2.0) pivoted around this specific threshold, with the Biden EPA estimating that their stricter rule would prevent 58 million tons of methane emissions through 2038.²⁵

5.3 Technical Implications of Leak Detection

The shift from quarterly to semiannual inspections is not merely a scheduling change; it is a statistical probability issue. Methane leaks are often stochastic—they happen randomly due to equipment failure, stuck valves, or "super-emitter" events. A semiannual inspection regime doubles the potential duration a massive leak can persist undetected compared to a quarterly regime. The move to weaken these standards ignored the "fat tail" distribution of methane leaks, where a small number of massive leaks contribute the majority of emissions. The deregulatory action privileged the reduction of compliance costs—estimated in the millions—over the mitigation of climate damages estimated in the billions.

6. Public Lands: The Arctic National Wildlife Refuge (ANWR) and the Carbon Bomb

The philosophy of "energy dominance" required access to vast reserves of fossil fuels located on federal lands. The Tracker meticulously documents the legislative and administrative steps taken to open the Coastal Plain of the Arctic National Wildlife Refuge (ANWR) to oil and gas drilling.⁶

6.1 The Tax Cuts and Jobs Act of 2017

The opening of ANWR was achieved not through environmental legislation but through the Tax Cuts and Jobs Act of 2017 (P.L. 115-97). Section 20001 of this act mandated the Secretary of the Interior to establish an oil and gas leasing program in the Coastal Plain, requiring at least two lease sales by 2024.²⁶ This legislative mandate bypassed the standard wilderness protections that had shielded the refuge for decades, treating the biological heart of the refuge as a revenue-generating asset.

6.2 The Carbon Bomb: Downstream and Soil Emissions

The environmental review process for the ANWR leasing program became a flashpoint for controversy. The Bureau of Land Management (BLM) published an Environmental Impact Statement (EIS) that was criticized for underestimating the climate impacts.

Independent analysis by the Center for American Progress (CAP), cited in the context of the Tracker's monitoring, estimated that the combustion of the oil extracted from ANWR (downstream emissions) could release roughly 4.3 billion metric tons of carbon dioxide equivalent.²⁷ This figure is roughly equal to three-quarters of the entire United States' annual emissions.

Furthermore, the Tracker highlights a less discussed scientific reality: soil carbon. The Arctic Refuge sits atop permafrost that holds massive quantities of ancient organic carbon. The physical disruption of this landscape for the construction of drill pads, roads, and pipelines—coupled with the warming effects of the climate change the oil burning would accelerate—threatens to thaw this permafrost. Estimates suggest that the disruption of the "active layer" of soil could release gigatons of additional carbon dioxide and methane, creating a positive feedback loop that the official government reviews largely ignored.²⁹ The failure to account for these "feedback loops" is a recurring theme in the deregulatory impact analyses tracked by the Sabin Center.

6.3 Biodiversity vs. Extraction

The Tracker also notes the intersection of climate deregulation and biodiversity loss. The DOI proposed lifting restrictions on drilling in Sage Grouse habitat and altering the Endangered Species Act (ESA) to limit the consideration of future climate impacts (like melting sea ice for polar bears) when designating critical habitat.⁷ This holistic deregulation ensures that neither the emissions nor the direct ecosystem impacts act as a barrier to extraction. The logic is one of compartmentalization: by breaking the ecosystem into discrete regulatory units (air, water, species), the administration could argue that the impact on any single unit was insufficient to halt the project, ignoring the cumulative destruction.

7. Procedural Deregulation: Changing the Rules of the Game

Beyond specific sectors, the Tracker reveals a transformation of the administrative procedures that govern all federal decision-making. These changes are systemic, affecting how the government perceives risk and analyzes data.

7.1 The NEPA Overhaul: Ignoring Cumulative Impacts

The National Environmental Policy Act (NEPA) is the "Magna Carta" of environmental law, requiring agencies to assess the environmental effects of their proposed actions. In 2020, the Council on Environmental Quality (CEQ) issued a rule that fundamentally redefined what effects must be considered.

Crucially, the rule eliminated the requirement to evaluate "cumulative impacts".³¹ Climate change is, by definition, a cumulative impact; no single highway or pipeline causes global warming on its own, but each contributes to the global accumulation of greenhouse gases. By removing the requirement to analyze cumulative effects, the administration created a legal framework where agencies could approve fossil fuel projects by claiming that their individual contribution to climate change was "de minimis" or insignificant. The Tracker notes that restoring this definition was a primary focus of the "reregulation" efforts in the intervening years, highlighting its centrality to climate governance.³³

7.2 The Social Cost of Carbon (SCC)

A recurring theme in the Tracker is the manipulation of the Social Cost of Carbon (SCC). The SCC is an estimate, in dollars, of the economic damage caused by emitting one additional ton of carbon dioxide. It is the central metric for cost-benefit analysis in climate regulation.

The Obama administration calculated SCC based on global damages, recognizing that climate change is a global problem that blows back on the U.S. economy. The Trump administration restricted the calculation to domestic damages only and raised the discount rate (the rate at which future damages are discounted to present value) to 7 percent. This mathematical adjustment caused the SCC to plummet from roughly 50 dollars per ton to as low as 1 to 7 dollars per ton.³⁴

This drastic reduction meant that the "benefits" side of the cost-benefit analysis for any climate regulation evaporated. If the damage of carbon is valued at near zero, then even a cheap regulation looks "too expensive." The Tracker notes legislation and executive actions prohibiting the use of the global SCC ⁷, effectively rigging the cost-benefit analysis against any climate action.

7.3 The "Transparency" Rule and Science

The Tracker also documents the "Strengthening Transparency in Regulatory Science" rule. This rule proposed to bar the EPA from using scientific studies where the underlying raw data (often confidential medical records) could not be made public. While framed as a transparency measure, its practical effect was to exclude major epidemiological studies—like the foundational Harvard Six Cities study—that link air pollution to premature death.⁹ By ruling this science inadmissible, the administration sought to lower the calculated "benefits" of reducing pollution, making deregulation easier to justify.

8. The "Climate Backtracker": The Second Wave (Trump 2.0)

As of January 2025, the Sabin Center's monitoring efforts evolved into the "Climate Backtracker" to address the actions of the Trump-Vance administration. The data from the first year of this term indicates an acceleration of the deregulatory agenda, leveraging the lessons learned from the first term.

8.1 Executive Actions and Emergency Declarations

The Backtracker records a flurry of Executive Orders in the first weeks of the new term. Notable among these are:

• "Unleashing American Energy": An order directing agencies to halt funds from the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA).³⁵ This targets the financial engine of the green transition.

• National Energy Emergency: A declaration directing the Secretary of Defense to audit energy supplies, framing fossil fuel expansion as a national security imperative.³⁵ This militarization of energy policy provides a powerful legal shield against environmental challenges.

• Paris Agreement Withdrawal: A repeated action to remove the U.S. from the global climate accord, accompanied by a halt to climate finance funding.³⁵

• "Preventing Woke AI": An executive order that, while seemingly cultural, has implications for government data usage and the modeling of climate risks by federal agencies.³⁶

8.2 The "Drill, Baby, Drill" Agenda Codified

The speed of action in the second term is notable. The Backtracker observed 304 actions in the first year alone.³ Unlike the first term, which saw a learning curve in administrative law, the second term exhibits a sophisticated understanding of the regulatory state. Agencies are issuing "interim" and "direct final" rules to bypass notice-and-comment periods, and the Department of Energy has emerged as a primary engine of deregulation, pausing efficiency standards for appliances and water heaters.⁴ The strategy has shifted from mere repeal to "preemption and pause"—freezing the implementation of green policies before they can take root.

9. Conclusion: The Aggregate Impact and Future Outlook

The ultimate measure of these trackers is not the number of rules changed, but the tons of greenhouse gases emitted. Integrating data from the Rhodium Group, Carbon Brief, and the Center for American Progress allows for an aggregate assessment.

9.1 The Emissions Gap

Analyses indicate that the major climate rollbacks of the first Trump term had the potential to add 1.8 gigatons of carbon dioxide equivalent to the atmosphere by 2035.³⁷ The projections for a second term are even more severe. Carbon Brief analysis suggests that a second Trump term could lead to an additional 4 billion tonnes (4 gigatons) of U.S. emissions by 2030 compared to the baseline established by the Biden administration's policies.³⁸

To visualize this: 4 gigatons is roughly equivalent to the combined annual emissions of the European Union and Japan. This increase would almost certainly cause the United States to miss its Paris Agreement pledge of reducing emissions by 50-52 percent below 2005 levels by 2030, likely achieving only a 28 percent reduction.³⁸

9.2 The Cost of Inaction

The economic translation of these emissions is equally stark. Using updated Social Cost of Carbon valuations, the extra 4 gigatons of emissions would cause global climate damages exceeding 900 billion dollars.³⁸ These damages manifest as increased storm intensity, agricultural yield loss, heat-related mortality, and coastal inundation. The deregulatory agenda, therefore, represents a massive transfer of value: saving industry billions in compliance costs while imposing nearly a trillion dollars in climate damages on the global public.

Table 2: Projected Cumulative Emissions Impact of Major Deregulatory Actions

Policy Area	Action	Estimated Additional Emissions (Million Metric Tons CO2e)	Source Context
Mobile Sources	SAFE Vehicles Rule (Rollback)	321 to 931 (Cumulative to 2035)	Rhodium Group Analysis 21
Oil & Gas	Methane Rule Rescission	approx. 58 (Methane tons avoided by Biden rule, now reversed)	EPA / WRI Analysis 25
Public Lands	Arctic Refuge (ANWR) Leasing	approx. 4,300 (Total downstream)	Center for American Progress 27
Power Sector	ACE Rule vs CPP	Minimal reduction vs Baseline (effectively locks in coal)	EPA RIA 11
Aggregate	All Trump 1.0 Rollbacks	1,800 (Cumulative to 2035)	Rhodium Group 37
Aggregate	Projected Trump 2.0 Impact	4,000 (Cumulative to 2030)	Carbon Brief 38

The Columbia Law School Climate Deregulation Tracker and Climate Backtracker serve as more than just historical archives; they are diagnostic tools for the health of American environmental governance. They reveal a system where the executive branch possesses immense power to pivot the nation's energy trajectory, constrained only by the slow friction of the Administrative Procedure Act and the federal courts. The report finds that the deregulatory efforts are characterized by three distinct strategies: legal minimalism, scientific obfuscation, and procedural exclusion. As the "regulatory yoyo" continues to spin, the cumulative load of greenhouse gases in the atmosphere increases, leaving a legacy that will persist long after the regulations themselves have been rewritten once more.

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