GCC Explainer | Key Trump Administration Actions to Restrict Offshore Wind Development

This explainer is part of GCC’s efforts to help state officials and stakeholders understand how recent federal actions may affect state policies and programs related to clean energy, climate change, and climate adaptation. Our goal is for this explainer to remain useful and accurate in a rapidly changing landscape, so we will be updating this document as needed. Earlier versions of this explainer were published in summer 2025. This updated explainer reflects Georgetown Climate Center’s understanding of the status of these policies as of February 5, 2026. Feedback regarding this analysis or additional information to be added, clarified, or updated, can be sent to climate@georgetown.edu, ATTN: Melissa Birchard.^{See footnote 1}  View GCC's other Understanding Recent Federal Actions explainers here.

What You Need to Know:

In the past year, the Trump Administration has taken a slate of actions that have slowed or halted offshore wind development. First, the Administration issued a Presidential Memorandum on January 20, 2025, that, among other things, initiated a freeze of all offshore wind permitting and leasing and called on federal agencies to reevaluate current permitting practices for offshore wind projects and previously issued approvals for ongoing projects. In alignment with the Presidential Memorandum, agencies across the Administration have taken a variety of steps that have further slowed or halted offshore wind projects by restricting permitting, seeking to reconsider finalized project approvals, and pulling funding for related infrastructure. States, local governments, and project developers are pushing back, with some success, on some of these actions through negotiations and in court, and states can continue to make progress on offshore wind development in key ways. This explainer provides an overview of federal actions over the past 12 months, the legal and policy issues they raise, and state responses. 

Overview: 

The Trump Administration has taken a variety of steps, acting through multiple federal agencies, to slow or halt the development of both offshore and onshore wind energy in the United States. This explainer focuses primarily on impacts to domestic offshore wind. For offshore wind, the most significant actions to date are: 

• The Trump Administration issued a Presidential Memorandum on January 20, 2025, that temporarily withdrew all wind energy leasing areas within the Outer Continental Shelf (OCS), paused all wind energy permitting actions, and ordered the review of federal offshore wind practices and certain projects.

• The U.S. Department of the Interior (DOI) subsequently issued three secretarial orders to implement the permitting freeze ordered by the Presidential Memorandum and revise the agency’s treatment of wind projects in permitting and other processes. On August 5, 2025, DOI rescinded 3.5 million acres of designated OCS wind energy areas and its renewable lease sale schedule rule. DOI has also issued stop work orders to two fully-permitted projects—Empire Wind and Revolution Wind—and sought court permission to vacate or reconsider federal approvals for three other projects—Maryland Offshore Wind, SouthCoast, and New England Wind. On December 22, 2025, DOI suspended the leases for five fully-permitted, large-scale offshore wind projects under construction: Empire Wind, Revolution Wind, Sunrise Wind, Vineyard Wind, and Coastal Virginia Offshore Wind. Courts have granted all five of those projects preliminary injunctions against the federal government, allowing work to proceed.

• The U.S. Department of Transportation (DOT) has also taken actions to limit offshore wind development, asking Congress to investigate safety risks from wind turbines near transportation infrastructure, recommending a national 1.2-mile setback of wind turbines from such infrastructure, and rescinding $679 million in port infrastructure funding–some of which has already been spent.

• The U.S. Environmental Protection Agency (EPA) requested and received permission to reconsider an outstanding Clean Air Act approval for the Atlantic Shores project off the coast of New Jersey, effectively halting the project on March 14, 2025.

Analysis: 

Presidential Memorandum on Wind Energy

On January 20, 2025, President Trump issued a Presidential Memorandum entitled “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,” which kicked off the Administration’s multi-agency efforts to alter federal treatment of wind projects.^{See footnote 2}  The Presidential Memorandum states that it does the following:

• Withdraws all areas within the Outer Continental Shelf from disposition for wind energy leasing,^{See footnote 3}  halting all future U.S. offshore wind development lease sales and lease renewals until the Presidential Memorandum is revoked or invalidated.^{See footnote 4} 
• Directs DOI to conduct a comprehensive review of the ecological, economic, and environmental necessity of terminating or amending any existing wind energy leases, identify any legal bases for such removal, and submit a report with recommendations to the President.^{See footnote 5} 
• Directs all relevant agencies to cease issuance of new or renewed approvals, rights of way, permits, leases, or loans for both onshore and offshore wind projects.^{See footnote 6} 
• Directs DOI to lead a comprehensive assessment and review of Federal wind leasing and permitting practices in consultation with relevant agency heads, considering the environmental impact of both onshore and offshore wind projects on wildlife, “economic costs associated with the intermittent generation of electricity,” and “the effect of subsidies on the viability of the wind industry.”^{See footnote 7}  
• Directs DOI to place a temporary moratorium on all activities and rights of the developers of the Lava Ridge onshore wind project and conduct a new analysis of the implicated interests and potential environmental impacts.^{See footnote 8} 
• Directs DOI, EPA, and the Department of Energy (DOE)  to assess the environmental impact and cost to surrounding communities of “defunct and idle windmills” and report findings and recommend authorities to require removal of such “windmills” to the President.^{See footnote 9}  
• Suggests that the Attorney General provide notice of the Presidential Memorandum to any court with pending litigation related to “any aspect” of the Federal leasing or permitting of onshore or offshore wind projects or the Lava Ridge Wind Project.^{See footnote 10} 

Agency Actions

Several federal agencies—including DOI, DOT, and EPA—have carried out actions directed by the Presidential Memorandum, as well as other actions to hinder specific projects or offshore wind development generally. 

Department of the Interior 

DOI has thus far played the largest role in implementing the Presidential Memorandum on wind energy. Since January 20, 2025, DOI has (1) withdrawn the OCS from wind energy leasing; (2) issued secretarial orders implementing a permitting freeze and mandating reviews of wind-related regulations, permitting practices, and projets impacts; (3) issued stop work orders to two fully permitted projects, one of which was eventually rescinded and one of which is still in effect; (4) indicated, in ongoing litigation, the agency’s intent to vacate or reconsider its approvals of construction and operations plans for three fully permitted projects; and (5) suspended leases for five large scale offshore wind projects under construction.

1. Withdrawing Outer Continental Shelf from wind energy leasing

Section 1 of the January 20 Presidential Memorandum temporarily “withdraw[s] from disposition for wind energy leasing all areas within the Offshore Continental Shelf.”^{See footnote 11}  To  implement this objective, the Bureau of Ocean Energy Management (BOEM)—a subagency under DOI—issued a direct final rule rescinding the wind leasing schedule on August 5, 2025.^{See footnote 12}  The rescission will impact states whose emissions-reduction plans depend on the wind power projected in the BOEM’s 2024 Renewable Energy Leasing Schedule,^{See footnote 13}  which identified a number of potential lease sale locations and timelines for lease sales through 2028. States with emissions-reduction plans that depend on power from new wind projects in those areas should not count on those lease sales taking place during the remainder of the Trump Administration’s second term.

2. Secretarial Orders

In response to the Presidential Memorandum, DOI has issued three secretarial orders that collectively suspended agency permitting authority and mandate sweeping reviews of wind-related regulations, permitting frameworks, and environmental and land-use policies. 

• On January 20, 2025, immediately following the publication of the Presidential Memorandum, Acting Secretary Walter Cruickshank issued Order 3415, temporarily suspending the authority of bureaus and offices within DOI to issue any onshore or offshore renewable energy authorization.^{See footnote 14}  Although the order stated that the suspension would only be effective for a term of 60 days, in subsequent litigation the government acknowledged DOI had ceased issuing any permits “until the Assessment and Review is complete, as instructed in the” Presidential Memorandum.^{See footnote 15}  

• On July 29, 2025, in Order 3437, Secretary Burgum directed DOI to evaluate all policies affecting wind development and to issue determinations about whether those projects remain in the public interest.^{See footnote 16}  The order also mandates that DOI complete, within 45 days, an assessment that re-evaluates the environmental impacts of onshore and offshore wind projects, the economic costs associated with “intermittent” energy sources, and the potential implications of wind deployment for military readiness.^{See footnote 17}  Additionally, the order directs the Solicitor’s Office to review all pending litigation involving wind projects, with an eye toward seeking remand of previously issued approvals to ensure they align with the Administration’s new priorities and potential new applications of relevant laws.^{See footnote 18}  As described further below, the Administration has already sought remand or vacatur of three project approvals.

• On August 1, 2025, Secretary Burgum issued Order 3438, which further instructed DOI to embed new land-use efficiency evaluations directly into the agency’s review process under the National Environmental Policy Act (NEPA). The order directs DOI to assess the “capacity density” of proposed energy projects, defined by DOI as megawatts per acre, when determining which alternatives constitute appropriate uses of federal land.^{See footnote 19}  Because wind facilities have a lower “capacity density” under that definition than most fossil fuel generation, the order appears to position wind development as categorically inferior during a NEPA alternatives analysis. As a result, NEPA reviews would be structured to disfavor wind projects as compared to “higher-density energy sources.”

Together, DOI’s secretarial orders invite broad reconsideration of wind permitting and impose new requirements that will slow or halt progress on wind energy development.

States have pushed back on the legality of one of these orders. Seventeen states and the District of Columbia challenged the legality of Order 3415,^{See footnote 20}  and on December 8, 2025, a federal district court in Massachusetts vacated the order. The court concluded it was a final agency action, was arbitrary and capricious because the agency offered no explanation for its action other than the Presidential Memorandum, and did not comply with other statutory and regulatory provisions requiring the Agency to act on permit applications by certain deadlines and to generally act within reasonable timeframes.^{See footnote 21}  So far, the federal government has not appealed the district court’s order to the U.S. Court of Appeals for the First Circuit.

3. Stop Work Orders

Following the Presidential Memorandum on offshore wind, BOEM has issued stop-work orders to two projects. However, neither of those orders is currently in effect after either court intervention or negotiations with the developer and relevant state and local governments. 

BOEM issued an initial stop work order, under 43 U.S.C. § 1337(p)(4) and its implementing regulations, against Empire Wind off the coast of New York on April 16, 2025.^{See footnote 22}  The project is intended to help replace approximately 517 megawatts of energy generated by small natural gas plants in New York City, which are planned for retirement by 2031.^{See footnote 23}  The stop-work order was notable for two reasons. First, it did not identify any violation of applicable law as a basis for halting all work. Rather, it cited a need to “address feedback” it had received about the environmental analyses for the project.^{See footnote 24}  Second, the stop-work order did not follow standard procedure for halting offshore wind construction. OCSLA’s implementing regulations authorize the Bureau of Safety and Environmental Enforcement (BSEE), a DOI subagency, to halt offshore wind construction if the developer is in violation of “an applicable law; regulation; order; or provision of a lease, grant, plan, or BSEE or BOEM approval.”^{See footnote 25}  That same regulation also says BSEE will give a lessee time to correct any noncompliance before halting work. But the Empire Wind stop-work order did not cite this regulation, was not issued by BSEE, and did not allege any violations. Instead, it relied on generic statutory and regulatory provisions detailing factors DOI and BOEM must consider in managing Outer Continental Shelf leases.^{See footnote 26}  BOEM ultimately lifted that stop-work order on May 19, 2025.^{See footnote 27}  In a statement, Equinor said the order was lifted “[f]ollowing dialogue with regulators and federal, state, and city officials.”^{See footnote 28}  

On August 22, 2025, BOEM issued a second stop-work order against Revolution Wind off the coasts of Rhode Island and Connecticut.^{See footnote 29}  This time, BOEM ordered a halt of all work on the project to address what the agency referred to as “concerns that had arisen” related to the protection of national security and interference with the nation’s reasonable uses of federal territory under OCSLA.^{See footnote 30}  Revolution Wind is projected to power 350,000 homes across Rhode Island and Connecticut once completed.^{See footnote 31}  At the time BOEM issued the stop-work order to Revolution Wind, the project was 80 percent complete.^{See footnote 32}  On September 4, Revolution Wind, LLC, and, jointly, Rhode Island and Connecticut filed two lawsuits seeking to invalidate the stop-work order.^{See footnote 33}  The Court granted their request for a preliminary injunction on September 22, 2025, temporarily enjoining BOEM from enforcing the stop-work order.^{See footnote 34} 

4. Voluntary Remands of Construction and Operations Plans in Open Litigation 

DOI has indicated its intent to reconsider or vacate the Construction and Operation Plan (COP) approvals for three different offshore wind projects. A COP is the central permitting document that developers of offshore wind projects must prepare and obtain approval from the federal government before they can build and operate turbines in U.S. waters.^{See footnote 35}  It serves as both a technical blueprint and a regulatory compliance document, laying out in detail how the project will be designed, built, maintained, and ultimately decommissioned.^{See footnote 36}  Without an approved COP, developers will be unable to move forward with construction.^{See footnote 37}  

DOI has moved to remand or vacate its COP approvals in three lawsuits concerning the Maryland Offshore Wind project as well as the SouthCoast and New England Wind projects off the coast of Massachusetts. Each of those three projects would have the potential to generate between 2,200 and 2,600 megawatts of energy. Local governments and community groups had filed lawsuits challenging the federal government’s approvals for each of these three projects under NEPA and/or the Administrative Procedure Act (APA). Rather than defend the merits of the Biden Administration’s approvals, the Trump Administration is now asking courts to remand the approvals back to DOI so that it can either vacate or reconsider each one, citing deficiencies in the past assessment of requirements set for projects on the Outer Continental Shelf.^{See footnote 38}  In each case, the impacted offshore wind project developers have intervened in the lawsuits and are opposing the federal government’s efforts to roll back its approvals.

On November 4, 2025, the D.C. federal district court granted DOI’s request to remand the COP for SouthCoast wind, dismissing the developer’s concerns of financial loss.^{See footnote 39}  This case was also unique because the lawsuit challenged the project’s Environmental Impact Statement—not the federal government’s approval of the project’s COP—but the court still granted the federal government’s remand motion for the entire case in order to reconsider the COP.^{See footnote 40}  In other words, DOI used its efforts to reconsider offshore wind COPs to obtain a remand in a case where the COP was not even challenged. Whether similar efforts will succeed before other courts remains to be seen.

5. Lease Suspensions

On December 22, 2025—in what is perhaps the Administration’s most consequential move on offshore wind to date—DOI announced it was pausing the leases for all large-scale offshore wind projects under construction, effective immediately.^{See footnote 41}  BOEM is authorized to suspend a lease if it is necessary to comply with judicial decrees or if the suspension is necessary for reasons of national security or defense.^{See footnote 42}  DOI’s press release attributed the pause to national security risks recently identified by the Department of Defense in classified reports, also referencing “inherent” national security risks that had been identified previously in unclassified reports, namely, radar clutter. According to the release, the pause is meant to allow government agencies to work with leaseholders and state partners to mitigate these security risks. 

BOEM issued separate Director’s Orders to Vineyard Wind 1, Revolution Wind, Coastal Virginia Offshore Wind, Sunrise Wind, and Empire Wind 1 on December 22.^{See footnote 43}  The orders use DOI’s regulatory authority^{See footnote 44}  to suspend all activity on the Outer Continental Shelf related to these projects for 90 days, during which time BOEM would determine if the projects must be cancelled for national security reasons. BOEM may also extend the suspension period if needed. In a deviation from other orders, the Vineyard Wind suspension allows it to continue activity necessary for its current level of power production.

The developers of all five affected projects have brought challenges to their respective lease suspension orders.^{See footnote 45}  The complaints universally claim that the orders violate the Administrative Procedure Act, and some raise Fifth Amendment takings arguments. 

States have joined developers’ pushback against recent lease suspensions. New York filed two complaints against the Sunrise Wind and Empire Wind suspension orders, respectively.^{See footnote 46}   Rhode Island and Connecticut jointly filed for a preliminary injunction of the Revolution Wind suspension order, building on their previous challenge to the stop-work order for the project.^{See footnote 47} 

All five  projects have already received preliminary injunctions allowing them to resume construction. Three of those preliminary injunctions were granted by the U.S. district court for the District of Columbia. First, on January 12, 2026, that court granted the injunction sought by Rhode Island, Connecticut, and the developers of Revolution Wind (Ørsted), finding that the federal government had failed to rationalize its abrupt change in position or explain why the new information warranted a total halt of construction.^{See footnote 48}  The court further suggested that the national security justification for the suspension may have been pre-textual.^{See footnote 49}  Three days later, the same court granted a second preliminary injunction to the developer of Empire Wind (Equinor). The court found Equinor had demonstrated it would suffer irreparable harm due to the order, and that there was no substantive proof the developer had been given proper notice before the stop-work order went into effect.^{See footnote 50}  That same court granted a third  preliminary injunction to the developers of Sunrise Wind on February 2, 2026. A separate court—the federal district court for the Eastern District of Virginia—granted a preliminary injunction to the developer of the Coastal Virginia Offshore Wind project (Dominion) on January 16.^{See footnote 51}  Another federal court, this time in Massachusetts, granted a preliminary injunction to the developers of Vineyard Wind on January 27,^{See footnote 52}  calling the federal government’s suspension “irrational.”^{See footnote 53}  The Climate Center will continue to monitor developing litigation closely. 

Department of Transportation (DOT)

In addition to DOI, DOT has recently taken actions that negatively affect the offshore wind industry. On July 29, 2025, DOT asked Congress to approve a 1.2-mile setback for turbines built near highways and railroads.^{See footnote 54}  DOT based this recommendation on safety concerns raised by a single study regarding radio interference, which recommended a 0.3-mile buffer from railways and made no recommendations for highways.^{See footnote 55}  A month later, DOT also announced it will withdraw and terminate $679 million in infrastructure funding that had previously been awarded to support the development of ports and manufacturing facilities for offshore wind for projects in six states: California, Maryland, New York, Virginia, New Jersey, and Massachusetts.^{See footnote 56}  The announcement identified 12 offshore wind grants and projects that it said did not “align with the goals and priorities of the administration.”^{See footnote 57}  The majority of those funds had not yet been obligated, but $75.2 million across five projects had been obligated and $22.4 million had already been spent.^{See footnote 58}  Two projects near Radio Island, North Carolina, and Portsmouth, Virginia, have spent 100 percent of their grants. 

Environmental Protection Agency (EPA)

EPA has played a role in halting at least one offshore wind project. Following the Presidential Memorandum’s pause of permitting actions, the Environmental Appeals Board (EAB) granted a request from EPA Region 2 for a voluntary remand of a Clean Air Act permit already issued to the Atlantic Shores Offshore Wind project located off the coast of New Jersey.^{See footnote 59}  Private parties filed the EAB challenge to EPA’s September 2024 issuance of the permit in October 2024, and the dispute has been fully briefed and pending since November 5, 2024. EPA Region 2 then filed a motion for a voluntary remand on February 28, 2025, requesting the EAB remand the permit to the Region for reconsideration in light of the Presidential Memorandum and to further evaluate the impacts of the Project.^{See footnote 60}  On March 14, 2025, the EAB granted EPA’s request and remanded the permit to the Region for further review. It is unclear when EPA Region 2 might make a final permit decision; however the developers of Atlantic Shores Offshore Wind have asked the New Jersey Board of Public Utilities to terminate its Offshore Renewable Energy Certificate, essentially asking to cancel the 1.5-gigawatt project.^{See footnote 61}  Notably, the Atlantic Shores permitting action is unique in that the remand was only possible because the EAB had not yet addressed the petition filed against the permit in October 2024.^{See footnote 62}  Although other projects do not appear to be vulnerable to this type of agency action, EPA’s successful request for a remand from the EAB is consistent with DOI’s efforts to obtain remands from courts to reconsider permits, causing disruption and confusion for ongoing offshore wind projects.

Implications for State Programs and Authorities:

Each of these actions has the effect of chilling wind energy development while introducing substantial uncertainty into state and regional planning for economic development, electric reliability, and the mitigation of climate impacts. Some timelines for offshore wind availability on the electric grid are likely to shift, particularly for projects not yet fully permitted. 

As described throughout the analysis above, states and offshore wind developers have successfully pushed back on some of the Administration’s actions against offshore wind, both in litigation and through negotiations as in the case of the stop-work order issued against Empire Wind. States have successfully argued that some of the Administration’s actions harm them because they hurt the states’ efforts to secure reliable and affordable energy, impact billions of state dollars in wind-related supply chains and infrastructure investments, and undermine the states’ statutory- and policy-based efforts to address air pollution and climate change.^{See footnote 63}  For example, in finding DOI’s Order 3415 unlawful, the Massachusetts federal district court cited the “ample evidence” of imminent injuries to the states, including reduced tax revenue and return on investment, disruptions in state plans for an influx of wind energy, and lowered energy costs.^{See footnote 64}  A key question will be how appellate courts treat recent district court wins for offshore wind, which will influence how much confidence states and others can have in expected availability timelines for already-permitted projects.

Despite near-term uncertainty, states can continue to take certain types of actions to advance offshore wind as well as its integration into the electric system. On April 28, 2025, for example, the Northeast States Collaborative on Interregional Transmission published a “Strategic Action Plan on Interregional Transmission” (Action Plan) that identifies gaps in interregional transmission initiatives and recommends concrete steps states can take over the next three years to fill those gaps while advancing offshore wind.^{See footnote 65}  The Collaborative is a nine-state forum that includes Connecticut, Delaware, Massachusetts, Maine, Maryland, New Jersey, New York, Rhode Island, and Vermont. The Action Plan recommends steps such as harmonizing technical standards for offshore wind-related transmission technologies, improving alignment of offshore wind and transmission procurements, expanding the infrastructure needed to integrate a future offshore grid network, and developing interregional coordination principles in accordance with Federal Energy Regulatory Commission Order 1920. States can also continue to coordinate on public engagement, workforce training, and supply chain development.

Related GCC Explainer: "Energy Emergency" Declaration and State Energy Policies (Released July 1, 2025)