Trump Administration’s 2025 Energy Policy Roundup Part 2: Unplugging Renewables

Houston, Tex. (March 14, 2025) - To underscore its 2025 energy policy goal of prioritizing fossil fuel development, the Trump administration has actively rolled back initiatives aimed at accelerating renewable energy growth.  One of the administration’s most direct actions in this regard is the recent imposition of a moratorium on offshore wind energy leasing.  Additionally, the administration has scaled back federal support for renewable infrastructure, cut funding for green energy projects, and dismantled regulations favoring renewables--all to refocus efforts on traditional energy sources.

Some of these policy shifts have been implemented through recent executive orders and memoranda, outlined below:

1. Offshore Wind Presidential Memorandum  – “Temporary Withdrawal of All Areas on the Outer Continental Shelf From Offshore Wind Leasing and Review of the Federal Government’s Leasing and Permitting Practices for Wind Projects”

• Effective January 21, 2025 and until the memorandum is revoked, all areas within the Outer Continental Shelf (OCS) must be withdrawn from new or renewed offshore wind energy leasing, if such leasing is for the purposes of electricity generation. [Sec. 1]
   
• Withdrawal is not applicable to existing wind leases or leases for other purposes such as oil, gas, minerals and environmental conservation. [Sec. 1] 
   
• The Secretary of the Interior must conduct a comprehensive review of the ecological, economic, and environmental impacts of existing wind leases in the withdrawn areas, assess them for potential termination or amendment, and identify any legal bases for terminating them. [Sec. 1]
   
• The Secretary of Energy and other department heads are precluded from issuing any new or renewed federal approvals, permits, and loans for both onshore and offshore wind projects, pending a comprehensive review of federal wind leasing and permitting practices. [Sec. 2(a)]
   
• A temporary moratorium is placed on activities related to the Lava Ridge Wind Project due to alleged legal deficiencies and public interest concerns. [Sec. 2(b)]
   
• The environmental impact and cost of defunct and idle windmills must be assessed, and  recommendations made for their removal. [Sec. 2(c)]
   
• The Attorney General may notify courts of this order and request stays or delays in litigation related to federal wind leasing or the Lava Ridge Wind Project. [Sec. 2(d)]

2. EO 14154 – "Unleashing American Energy"

• Requires federal agencies to immediately stop disbursing funds appropriated through the Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA); review all processes for issuing grants, loans, or contracts related to these funds to ensure alignment with the new administration's energy policy priorities; and refrain from disbursing any future funds until further approval from the Office of Management and Budget (OMB) and the National Economic Council (NEC).  [Sec. 7(a)]
   
• Agencies are instructed to prioritize cost-effectiveness and American workers and businesses in procurement, leasing and other spending decisions; and are granted authority to use discretion with regard to regulatory enforcement when advancing the administration’s energy policy goals. [Sec. 7(b)(c)]                                                        

3. OMB Memo M-25-11 – The White House

• Provides guidance from the OMB and NEC on implementing Section 7 of  EO 14154.
   
• Narrows the pause on disbursements under the IRA and IIJA to specific programs that are inconsistent with the administration’s energy priorities outlined in Section 2 of EO 14154.
   
• Defines funds addressed in Section 7 of  EO 14154, i.e., “Green New Deal” funding, as any appropriations that do not align with the administration’s new energy policies.
   
• Grants agency heads discretion to release funds after consulting with the OMB.

While the renewable energy momentum of recent years has not been completely derailed, the Trump administration’s policy shifts are slowing its progress. Offshore wind has taken a particularly direct hit, with the administration’s moratorium on new leasing further stalling an industry already facing economic and logistical challenges. Additionally, the decision to halt disbursements under the IRA and the IIJA disrupts financing for key renewable initiatives, including solar, battery storage, hydrogen, and carbon capture. New administrative hurdles and regulatory reviews are also creating uncertainty and potentially deterring investment in clean energy projects. As the federal government pivots away from the Biden-era focus on renewable energy development, the future of those industries will likely depend more on state governments and private sector initiatives, rather than federally driven programs, setting the stage for future policy battles between renewable energy advocates and the administration.

Read Part 1 of our roundup, detailing the Trump administration's policy priorities, here.

For more information on these developments, contact the author or editor of this alert. Visit our Energy, Marine & Power Practice page to learn more about Lewis Brisbois' capabilities in this area.

Author:

Odette Bruce-Tagoe, Partner

Editor:

Andrew Pidgirsky, Partner and Co-Chair of Energy, Marine & Power Practice