Since President Trump’s inauguration, he, his administration and Congress haven’t wasted any time propelling a new agenda for transportation regulations, ACT Research contends. On day one, Trump issued an executive order, Unleashing American Energy. It is a wide-ranging and specific order calling for the end of "EV mandates," terminating related CA emissions waivers and halting IRA funding. It also called for a review of the EPA’s 2009 Endangerment Finding (that GHGs threaten the public health and welfare of current and future generations) that requires the EPA to take action to curb GHG emissions. With this call to action, things in the nation’s capital have been off to a quick start.

The road ahead may be uncertain, but understanding the risks and opportunities now will help you navigate it successfully. That’s where this report comes in. Businesses across the trucking industry need to understand both the rules that are already in motion and the possible disruptions ahead. Whether the administration fully repeals, modifies, or delays key regulations, the impact on equipment decisions, fleet planning, and operational costs will be significant. This report provides a clear breakdown of the current regulations, the potential paths forward, and what industry stakeholders should be considering to stay prepared.

ACT Research's Regulatory Roadmap suggests that staying ahead of these shifting policies is crucial. The road ahead may be uncertain, but understanding the risks and opportunities now will help you navigate it successfully.

New Federal Actions Include:

Funding Freeze:
President Trump’s attempt to freeze federal funding via executive order (without congressional approval) has been blocked by a U.S. District Judge, extending a temporary order issued in January. The Trump administration may now appeal the ruling. Judge John McConnell wrote in his original ruling, “The Executive’s categorical freeze of appropriated and obligated funds fundamentally undermines the distinct constitutional roles of each branch of our government.” This is a key decision for many programs, but notably for the industry, it means funding under the IRA or IIJA cannot be withheld where it has been “obligated” as part of a binding agreement between the DOT and the recipient.

CARB Waiver Review:
On Feb. 14, the EPA submitted three California waivers to Congress for review—those for Advanced Clean Cars, Advanced Clean Trucks, and HD Omnibus. The EPA claims that the Biden administration was supposed to send the waiver decisions to Congress previously per statutory reporting requirements but failed to do so. The EPA is essentially giving Congress the power to overturn the EPA’s previous waiver decisions through congressional review, but there is a potential snag in this plan.

EPA waiver decisions are considered "orders" not "rules." They adjudicate but do not promulgate and implement new policy. Under the Congressional Review Act (CRA), agencies are required to submit rules to Congress, and Congress has a mechanism to overturn a rule. The Government Accountability Office (GAO) confirmed in 2023 and reconfirmed earlier this month that waivers are orders and not subject to the CRA.

Transportation Freedom Act:
The Transportation Freedom Act (SB 711) tackles issues related to auto workers and passenger vehicle regulations, but most importantly for the CV industry, it takes aim at GHG-3 and California waivers. The bill would attempt to repeal GHG-3, though that rule falls outside of the time constraints for a direct repeal under the Congressional Review Act.

The bill would require the EPA to develop new GHG-3 standards that reflect achievable technological advancements based on affordability and market readiness, and rely on evidence from industry market data and expert feasibility assessments. While the new rules would be developed, this bill states that the MY 2024 standards under GHG-2 would be the prevailing standards. This bill does not attempt to repeal or change the EPA’s 2027 low-NOx rule.

The Transportation Freedom Act also contains a major upheaval to the Clean Air Act, and California, should it pass. The bill would amend the Clean Air Act to include a paragraph stating that no further waivers would be granted for any rules on vehicle emissions that differ from federal rules. It would revoke any waivers issued prior to the enactment of the bill, which would include things like Advanced Clean Trucks and HD Omnibus. The bill would also amend the Clean Air Act by repealing Section 177, which allows other states to adopt California’s emissions standards instead of federal standards. This would be a major overhaul of a long-standing authority for California to set its own vehicle emissions standards based on the unique air quality problems in the state.

The bill was introduced on Feb. 25 and has been referred to the Senate finance committee. With Republican majorities in both the House and Senate, we expect the bill to pass, once it makes its way through the standard legislative process. While we expect this bill to eventually be adopted, we do believe it would run into legal challenges, especially for the portion that would revoke already granted waivers. We do not see any certain recourse for future waivers here, but there is certainly question about the ability to retroactively end existing waivers. For this reason, our forecast still assumes that the Advanced Clean Trucks waiver will ultimately prevail.

EPA to Reconsider GHG-3 and 2027 HD Low Nox:
On March 12, the EPA announced it would reconsider the GHG-3 rule. The rule is likely to see a complete overhaul. The EPA also stated that it would “reevaluate” the 2027 HD low-NOx rule. We expect that reevaluation may primarily impact the useful life and warranty standards expected to significantly increase the price of trucks in 2027.

Read the entire report here.