PRESIDENT TRUMP’S EOs REGARDING ENERGY TRANSITION ISSUES: The President’s Legal Authority to Pause Disbursements
Updated January 29, 2025, as the Office of Management and Budget (OMB) issued a recission of the guidance it issued on January 27, 2025, and instructed all Executive Branch agencies to contact their General Counsels with questions regarding President Trump’s Executive Orders. Despite this recission, as Executive Branch agencies interpret the intent of President Trump in the Executive Orders, it is likely that they will be guided by the rescinded OMB Disbursement Guidance.
The issuance of Executive Orders and associated internal guidance from the Office of Management and Budget (OMB) during the first days of President Trump’s second administration have created significant confusion and uncertainty in the energy transition space. News coverage of these events tend towards captivating headlines and a lack detail sufficient for businesses to assess risks.
ETAG will publish several articles over the coming days that provide concrete and objective information about the Executive Orders and OMB guidance that impact the energy transition.
This first article addresses the President’s legal authority to pause disbursements of Federal financial assistance.