President Donald Trump issued a series of directives late Wednesday aimed at scaling back regulations covering everything from showerheads to endangered species as part of his pledge to enact the “most aggressive regulatory reduction” in the country’s history.

Trump’s deregulatory moves this week included an executive order on showerhead regulations, an order directing energy and environmental agencies to “sunset” certain regulations, an order aimed at eliminating “anti-competitive regulations” and a memo directing agencies to repeal existing rules that don’t align with a series of recent Supreme Court decisions.

The White House budget office is also soliciting calls from the public for ideas about how to slash regulations. “Today, OMB sent to the Federal Register a call for your ideas on how to deregulate, so please send them in!” Jeff Clark, the acting head of the White House Office of Information and Regulatory Affairs, posted on the social media platform X on Wednesday.

The directives are the latest moves from the administration working to fulfill Trump’s campaign trail promise to enact a large-scale demolition of government regulations, in some cases targeting decades-old energy and environmental rules that the administration says impede growth.

A White House fact sheet boasts that the orders will “unleash American energy innovation, which has been frozen in the 1970s,” adding that Carter-era regulations should not govern modern energy production.

“President Trump is laser focused on energy abundance, not just efficiency,” the White House said.

Critics, however, say Trump’s efforts violate federal requirements for public input on rule changes.

The Trump order directing the reversal of a Biden-era efficiency rule on showerheads includes a line stating, “Notice and comment is unnecessary because I am ordering the repeal.”

That’s “an invitation to illegal action,” said Richard Revesz, who served as the head of the White House regulatory office during the Biden administration. “Because the law requires notice and comment rulemaking.”

One executive order directs 10 agencies, including EPA, the Interior Department, the Department of Energy and the Federal Energy Regulatory Commission, to set a “sunset” date for laws that govern energy production.

Under the order, each agency would have to insert a conditional sunset into existing regulations, after which point the rules would cease to be in effect. Agencies have until Sept. 30 to issue a rule to set the sunset date, which agencies would be able to extend.

“Attempting to repeal every environmental safeguard enacted over the past 50 years with an executive order is beyond delusional,” said Brett Hartl, government affairs director at the Center for Biological Diversity, in a statement.

“Trump’s farcical directive aims to kill measures that protect endangered whales, prevent oil spills, and reduce the risk of a nuclear accident,” Hartl continued, predicting that “this chaotic administration is obviously desperate to smash through every environmental guardrail that protects people or preserves wildlife, but steps like this will be laughed out of court.”

The order lists a broad swath of rules including the Natural Gas Act, the Federal Power Act, the Federal Lands Policy and Management Act, and the Outer Continental Shelf Lands Act.

The executive order asks both EPA and the Army Corps of Engineers to provide their own list of rules that should be subject to the order within 30 days.

Joel Eisen, a law professor at the University of Richmond, said agencies would have to go through a notice-and-comment process to explain why the rules would be sunsetted.

“It’s at least an open question whether an agency can issue a sunset rule that applies to all of its regulations that are purportedly covered by the executive order,” Eisen said.

Also on Wednesday, Trump issued a memo directing agencies to evaluate whether current regulations are in line with recent Supreme Court rulings and could be more easily repealed.

The memo follows up on Trump’s February executive order, EO 14219, which also established the Department of Government Efficiency or DOGE.

The president directed agencies to review existing rules for compliance with high court rulings such as the decisions in Loper Bright v. Raimondo and West Virginia v. EPA.

Those Supreme Court decisions in 2024 and 2022, respectively, eliminated a legal doctrine directing courts to defer to agencies’ interpretations of ambiguous laws, and stated that Congress had to clearly delegate power on issues of major political and economic significance.

“There’s nothing in Loper Bright that suggests that it has a retroactive effect. There’s certainly nothing in West Virginia” either, said Eisen.

“This notion that constitutional challenges may be brought to an agency action does not, all of a sudden, make past agency action unlawful,” he said.

Trump told agencies that rules repealed for failing to comply with the recent decision do not need to issue a public notice of the repeal or seek public comment for the agencies to consider as they complete a recession rule.

Instead, agencies should rely on the “good cause” exemption in the Administrative Procedure Act. The exception allows an agency to forgo notice and comment when doing so is “impracticable, unnecessary, or contrary to the public interest.”

“Retaining and enforcing facially unlawful regulations is clearly contrary to the public interest,” Trump said in a memo late Wednesday.

“Furthermore, notice-and-comment proceedings are ‘unnecessary’ where repeal is required as a matter of law to ensure consistency with a ruling of the United States Supreme Court,” he continued. “Agencies thus have ample cause and the legal authority to immediately repeal unlawful regulations.”

The memo greatly expands on the use of the same exemption it cited to repeal the White House Council on Environmental Quality’s National Environmental Policy Act regulations.

The regulations told agencies how to comply with the landmark environmental law; the repeal goes into effect Friday.

The president’s invocation of the “good cause exemption” diverges from the past narrow interpretation of when it should apply, such as during disasters, said Eisen.

The administration has only one option to repeal regulations — and that’s through a public notice and comment process, said Todd Phillips, an assistant professor of law in the Robinson College of Business at Georgia State University.

“Everything they do here is going to be challenged,” Phillips said. “Congress enacted the notice and comment process to ensure that the public has a chance to weigh in on the decisions that the government is making. It is a legally required process and I can not imagine an end run around it will stand up in court.”

Phillips argued that the “good cause” exception is not for routine matters, but is for “when things need to happen so quickly that you just don’t have time for the notice and comment process to work itself out. That’s not the case here.”

The Trump administration’s early moves on rules share a collective goal of dismantling “federal regulations across the board,” said Pat Parenteau, an emeritus professor at Vermont Law and Graduate School. “Their aim is to not just create chaos, but to literally destabilize political institutions,” he added.

Parenteau views Trump’s directives as part of a broader attempt to assert the authority of the executive branch in determining what’s legal, he said.

The administration’s flurry of deregulatory directives is also handing federal agencies a hefty workload at the same time Trump and the Elon Musk-led DOGE operation are moving to dramatically scale back the number of agency workers available to do the work, said James Goodwin, policy director at the Center for Progressive Reform.

“There’s so much to do,” Goodwin said. “As a practical matter, particularly while they’re gutting their staff and fighting all these lawsuits, how are they supposed to get all this stuff done?”