A few weeks ago, during one of my monthly Ask Me Anything sessions, a student of mine shared that she felt I was being unfair to criticize the Trump administration for its slew of deregulatory policies that would increase harm from toxics, while ignoring what previous administrations had also done. If I’m going to criticize Trump, I also need to criticize Biden and Obama…
Never one to back down from a challenge, I decided to pull together a fairly comprehensive (but not exhaustive) review of the policies that would have reduced toxins or pollution and those that would have increased them, for every administration going back to Clinton.
Instead of just stating that republican administrations have been, on the whole, far more pro-industry and pro-deregulation than democratic administrations (this is factually true), I wanted a concrete list - a tally of sorts.
Because this is a huge undertaking, I’m doing it one administration at a time. My hope is that this will serve as a resource for others facing folks who say, “all administrations are the same!”
Policies aren’t fixed - they expand, contract, get rolled back, or eliminated altogether. I’ve called out, for each of the policies listed below, major changes that were made by subsequent administrations. Changes that would have a positive impact on toxics & pollution get a ✅, while policies that would have a negative impact get a 🚨. I’m sure I’ve left things out—as I said, this isn’t intended to be an exhaustive list. There are a few instances where a policy change has a ✅/🚨 designation—these are situations where a policy may have moved in the wrong direction before getting corrected during a term, or that a policy had both positive and negative aspects.
If there’s something obvious I’m missing here, please let me know, and I’ll update the list.
I struggled with whether this format was the right and logical way to “red string” all of these together. This is what works for now, but I may change it later. 🤷♀️
Tier 2 Vehicle Emission Standards and Gasoline Sulfur Rule (1999/2000) - one of the most consequential air quality rules in EPA history, establishing stricter vehicle emission standards, reducing NOₓ emissions, sulfur, and PM2.5 [FR]
Heavy-Duty Engine and Diesel Fuel Rule (2000) - Established stricter heavy-duty diesel engine standards and required ultra-low sulfur diesel fuel, reducing particulate and NOₓ emissions from trucks and buses. [FR]
National Ambient Air Quality Standards (NAAQS) for Ozone (1997) - Set the maximum allowable concentration of ground-level ozone in outdoor air to 84 ppb. [FR]
Changes to this policy:
✅ /🚨 Bush EPA lowered the maximum allowable level to 75 ppb, but this was still less than the 60–70 ppb range recommended by EPA’s science advisers, drawing strong public‑health criticism.
🚨 The Obama administration rejected a proposed rule that would have strengthened these rules further.
✅ Obama finally strengthened the primary and secondary ozone NAAQS to 70 ppb
🚨 Trump’s EPA changed the NAAQS review process to speed up timelines, significantly limiting the studies available to the EPA for review of the NAAQS because many epidemiological studies use confidential health information that cannot be made public.
✅ /🚨 Biden’s EPA issued a final rule again retaining 70 ppb, despite recommendations to drop it to the 55–60 ppb range.
🚨 Three days after Biden’s final rule took effect, Trump issued an Executive Order freezing all regulatory review. Two months later, the EPA launches its “Biggest Deregulatory Action in US History,” including “Reconsideration of Particulate Matter National Ambient Air Quality Standards that shut down opportunities for American manufacturing and small businesses (PM 2.5 NAAQS).”
National Ambient Air Quality Standards for PM2.5 (1997) - Established the first federal limits on fine particulate matter (PM2.5), setting health-based standards for annual and daily exposure. Also required states to reduce emissions in areas exceeding those limits. [FR]
Changes to this policy:
🚨 Implementation of this rule was delayed under Bush
✅ Strengthened under Obama based on more data that PM2.5 causes harm at lower levels
✅ Strengthened again under Biden to provide greater protection against premature death, asthma, and cardiovascular disease
🚨 The Trump administration stopped defending this rule and asked the court to vacate it entirely.
Regional Haze Rule (1999) - Regulations to improve visibility, or visual air quality, in 156 national parks and wilderness areas across the country. [FR]
NOx SIP Call (1998) - Required 22 eastern states to reduce NOₓ emissions from power plants and industrial sources to address interstate ozone pollution, lowering regional smog formation. [FR]
MACT Standards for multiple industries - Established technology-based limits on hazardous air pollutants from major industrial sources under Title III of the Clean Air Act, covering petroleum refineries, pulp and paper, aerospace, auto manufacturing, and others, thereby reducing emissions of toxic pollutants across multiple industries. (Authorized under George H. W. Bush, implementation under Clinton) [FR]
Changes to this policy:
🚨 Bush delayed implementation
✅ The Obama administration strengthened MACT by implementing MATS or the Mercury and Air Toxics Standards, requiring coal and oil-fired power plants to limit emissions of hazardous air pollutants (HAPs) like mercury, arsenic, chromium, and other toxics. This had a MASSIVE impact on air quality: mercury emissions from power plants dropped by 81.7% between 2011 and 2017.
🚨 Trump reversed the “once in, always in” MACT policy, allowing major polluters to reclassify as smaller sources and avoid stricter toxic emissions controls.
✅ Biden reinstated the “once in, always in” rule.
🚨 Trump’s EPA repealed MATS, which will result in increased pollution, disease, and death.
NESHAP for Hazardous Waste Combustors (1999) - Established MACT-based limits on dioxin, mercury, and toxic emissions from cement kilns, industrial boilers, and hazardous waste incinerators. [FR]
Changes to this policy:
✅ Expanded under Obama to reduce methane gas
🚨 During Trump’s 1st term, EPA repeatedly tried to delay and stretch the implementation deadlines for the 2016 landfill emissions guidelines, and states plus NGOs kept suing to force EPA back onto the original, faster schedule. An August 2019 timing rule and later appellate decisions ultimately allowed EPA to push the federal plan deadline back to August 30, 2021.
✅ Under Biden, the EPA tightened methane controls through enforcement actions, updated emissions factors, and new rulemakings.
🚨 In Trump’s second term, the EPA proposed eliminating landfill greenhouse gas reporting requirements and extending reporting deadlines for 2024 data.
Municipal Solid Waste Landfill Rules - (1999) Established emission standards for landfills, requiring controls on methane and other landfill gases, reducing air pollution and toxic emissions. [FR]
Nonroad Engine Emission Standards - (1994) First-ever emission limits for off-road engines, lawn mowers, chainsaws, and similar equipment [FR]
Changes to this policy:
✅ The Bush EPA finalizes more stringent emission standards for nonroad diesel engines to reduce emissions from construction, agricultural, and industrial equipment by more than 90%, and adopts a limit to decrease the allowable level of sulfur in nonroad diesel fuel by more than 99%
Clean Air Act Enforcement Initiative against Power Plants (1999) - Launched enforcement actions against coal-fired power plants for Clean Air Act violations, requiring pollution controls and reducing emissions. [PE]
Changes to this policy:
🚨 The Bush administration changed the definition of key language that would undermine efforts to enforce clean air rules.
✅ The Obama administration restored stricter enforcement and pursued major settlements with utilities requiring pollution controls and emissions reductions.
🚨 In Trump’s first term, the EPA narrowed NSR and proposed permitting changes that would make coal-plant upgrades less likely to trigger Clean Air Act enforcement. New Source Review (NSR) is a Clean Air Act permit rule that says if a factory or power plant is new or makes a change that increases pollution, it has to get approval first and install modern pollution controls.
✅ The Biden administration’s EPA canceled Trump’s easier NSR rules and proposed stricter permitting for power-plant upgrades to support stronger enforcement
🚨 Another reversal under Trump 2.0. The EPA dropped Biden’s NSR changes and reinstated easier permitting rules to reduce enforcement pressure on power plants.
Interim Enhanced Surface Water Treatment Rule (1999) - Final rules strengthening microbial contamination, including Cryptosporidium, in public drinking water systems. [FR]
Stage 1 Disinfectants and Disinfection Byproducts Rule (1998) - Established enforceable limits and monitoring requirements for disinfectants and disinfection byproducts (e.g., trihalomethanes and haloacetic acids) in drinking water [FR]
Radon in Drinking Water Rule [PROP] - Proposed rule to regulate radon levels in drinking water - was never finalized.
Arsenic in Drinking Water (2001) - Proposed rule lowered the allowable arsenic level in public drinking water from 50 to 10 ppb, reducing exposure to a known carcinogen. Was finalized under the Bush administration [PROP - FR]
Unified National Strategy for Animal Feeding Operations (1999) - A policy framework for managing waste from animal feeding operations to reduce water pollution from agricultural runoff.
Beaches Environmental Assessment and Coastal Health (BEACH) Act (2000) - Required coastal states to monitor beach water quality and notify the public of contamination, reducing exposure to harmful pathogens.
Food Quality Protection Act (FQPA) (1996) - Landmark bipartisan legislation enacted by Congress and signed by Clinton; one of the most significant pesticide reforms in US history. Required the collection of pesticide residue data on commodities most frequently consumed by infants and children. [LEG]
Safe Drinking Water Act Amendments (1996) - Major overhaul of the US water supply safety, required annual water quality reports, required EPA to use risk-based standards and cost-benefit analysis when setting new drinking water standards. [LEG]
Changes to this policy:
✅ The Biden administration’s EPA finalized the first national enforceable drinking water limits for six PFAS chemicals under the Safe Drinking Water Act. This was a BIG deal. No new contaminants were regulated after the 1996 amendments.
🚨 In 2025, Trump’s EPA rescinded limits for 4 of the 6 PFAS that had just been added to the regulation list, and extended compliance deadlines.
Pesticide Tolerance Reassessment (1999) - Reassessed allowable pesticide residue levels in food under updated safety standards, strengthening protections for children and cumulative exposures. [LEG]
Organophosphate Pesticide Review (1999) - Reassessed and restricted organophosphate pesticides under updated safety standards, reducing exposure to neurotoxic chemicals, especially in children. [FR]
Changes to this policy:
✅ Obama orders EPA to ban chlorpyrifos a pesticide linked to neurodevelopmental disorders in children.
🚨 Trump reverses the ban of chlorpyrifos, allowing continued use
✅ Biden banned the use of chlorpyrifos in all but 11 crops in late 2024.
🚨 Trump extends comment period on chlorpyrifos regulation, allowing for more pushback from industry.
Toxic Release Inventory (TRI) Expansion (1994-2000) Expanded TRI reporting to cover more industries—like electric utilities and federal facilities—and additional toxic chemicals. This made more information publicly available about what pollutants were being released into communities, improving transparency and awareness. [FR]
Methyl Bromide Phase-Down - Established the US regulatory framework and timeline to phase out methyl bromide by 2005 under the Montreal Protocol. [INTL/FR]
Endocrine Disruptor Screening Program (EDSP) - Aims to screen pesticides and chemicals for potential endocrine-disrupting effects on estrogen, androgen, and thyroid systems [LEG/Policy]
Community Right-to-Know Enhancements (1996) - Expanded and strengthened public access to information on toxic chemical storage and releases under right-to-know laws. This made it easier for communities to understand and respond to local environmental exposures. [FR]
Persistent Bioaccumulative Toxics (PBT) Strategy (1999) - Launched a national effort to identify and reduce high-risk toxic chemicals that persist and build up in the body and environment, prioritizing substances like mercury and dioxins for action. [GUID/Policy]
Requirements for Lead-Based Paint Activities in Target Housing and Child-Occupied Facilities (1996) - Regulation that people conducting lead-based paint projects in housing built before 1978, and facilities occupied by children, are properly trained and certified, that training programs providing instruction are accredited, and that these activities are conducted according to reliable, effective, and safe standards.
Prohibition on Lead in Plumbing (1986, Reagan; strengthened 1996, Clinton) - Amended the Safe Drinking Water Act, requiring plumbing fittings and fixtures to be in compliance with lead leaching standards that were previously voluntary. The amendments also prohibited the introduction into commerce of any pipe, pipe fitting, or plumbing fixture that is not lead-free. [FR]
Roadless Area Conservation Rule (2001) - Aimed to limit new road construction and most logging in large, undeveloped areas of national forests, totaling nearly 60 million acres, with the intention of preserving intact ecosystems and wildlife habitat and reducing erosion, sediment runoff, and water pollution. [FR]
Changes to this policy:
🚨 Under Bush, implementation was delayed multiple times via executive memos, and the rule was replaced in 2005 with a state petition process allowing governors to opt out completely.
✅ Obama defended this rule in court during ongoing litigation. By 2012, it was upheld nationally.
🚨 Trump’s first administration exempted the Tongass National Forest in Alaska in 2020, rolling back protections.
🚨 Trump 2.0 announced the intent to rescind the entire rule nationwide, lifting restrictions on 60 million acres.
Executive Order on Environmental Justice (1994) - Directs federal agencies to identify and address the disproportionately high and adverse human health or environmental effects to minority and low-income populations, and develops a strategy for implementing environmental justice [EO]
Changes to this policy:
🚨 Trump 1.0, rescinded related Obama/Biden EJ executive orders and reduced dedicated EJ programs.
✅ Biden created the first White House Office of EJ and Justice40 Initiative to direct 40% of federal climate/environment benefits to disadvantaged communities.
🚨 Trump 2.0 completely closes all environmental justice offices and cancels grants due to “DEI.”
Okay, so that’s a count of (at least—remember, this isn’t exhaustive, but I am exhausted from looking all of this up) 30 policies, executive orders, etc., passed, established, etc., during the Clinton administration that would have reduced environmental toxins or strengthened protections.
But no administration is perfect, so let’s tally up the policies that would have increased pollution or weakened protections.
Continued Subsidies for Fossil Fuels - Clinton continued to offer subsidies for fossil fuel R&D.
Pesticide Reassessment Pace - The Government Accountability Office determines that implementation of a statutory mandate to assess pesticides is very slow.
That’s all I could find. I have likely overlooked at least a few—remember, this isn’t intended to be exhaustive. The Clinton administration is well known for its robust efforts to protect environmental health and public health, and some of our most important policies were established or improved during this term.
As I said, no administration is perfect, but Democratic administrations are far, far more progressive on environmental protections, climate change, and renewable energy than Republicans. Democratic administrations typically move toward stronger federal regulations, which means “bigger” government. Republican administrations historically (and currently) are deregulatory. Fewer regulations. Free market blah blah. In fact, in March of last year, Lee Zeldin, head of the EPA, announced the “Biggest Deregulatory Action in U.S. History.” Zeldin is currently on the short list to replace Pam Bondi as Attorney General, who was recently fired.
What a clown show.
Anywhoo - I hope this list is helpful. I certainly learned a lot in reviewing each of these policies. I’m sure some will say this doesn’t absolve me of the accusation of bias, but this isn’t about political preference, truly. It’s merely a reflection of the policy record.
Here’s a little code for the various types of policy/action:
[FR] = Final Rule
[EO] = Executive Order
[PE] = Policy Enforcement
[LEG] = Legislation signed into law
[PROP] = Proposed but never finalized or enacted
[INTL] = International agreement
[VOL] = Voluntary program or agreement
[GUID] = Guidance document or policy interpretation
[INACT] = Legislative or regulatory inaction (failure to act)
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