Highlights
- President Donald Trump signed an executive order (EO), "Reinvigorating America's Beautiful Clean Coal Industry and Amending Executive Order 1424," on April 8, 2025, that places coal at the center of the administration's efforts to enhance national and economic security, power the artificial intelligence (AI)-driven economy and revitalize domestic industry by setting a national policy for federal agencies to support the coal sector.
- The EO signals a shift in federal energy strategy, mobilizing government agencies to remove regulatory and financial barriers to coal, streamlining access to federal lands and boosting coal-related exports and technologies.
- It also expands the definitions of "critical energy" and "industrial materials" to include coal and metallurgical coal, introducing a new policy framework aimed at reclaiming energy dominance through traditional resources.
President Donald Trump signed an executive order (EO) titled "Reinvigorating America's Beautiful Clean Coal Industry and Amending Executive Order 14241" on April 8, 2025, that places coal at the center of the administration's efforts to enhance national and economic security, power the artificial intelligence (AI)-driven economy and revitalize domestic industry by setting a national policy for federal agencies to support the coal sector.
The EO signals a shift in federal energy strategy, mobilizing government agencies to remove regulatory and financial barriers to coal, streamlining access to federal lands and boosting coal-related exports and technologies. It also expands the definitions of "critical energy" and "industrial materials" to include coal and metallurgical coal, introducing a new policy framework aimed at reclaiming energy dominance through traditional resources.
Key Provisions of the Executive Order
- Reclassifying Coal as a Strategic National Asset. The EO reclassifies coal as a mineral, granting it eligibility for federal support programs, including those under the Defense Production Act and U.S. Department of Energy's (DOE) loan authorities. It also directs a review of policies that may discourage coal production, with agencies tasked to revise or rescind such policies within 60 days.
- Accelerating Coal Access on Federal Lands. The EO directs the federal agencies to identify coal-rich areas on federal lands, address barriers to mining on federal lands and propose actions to maximize coal mining on federal lands. It also prioritizes coal leasing and encourages the use of emergency authorities to expedite permitting and environmental reviews, including a push for broader use of categorical exclusions under the National Environmental Policy Act (NEPA). The assessment requires an analysis of the impact the use of coal resources could have on electricity costs and grid reliability.
- Aligning Coal with Emerging Industrial Needs. The EO positions coal as a critical resource for emerging industries, directing agencies to assess its potential for powering AI data centers and supporting steelmaking. Additionally, it calls for accelerated development of coal technologies and commercial applications in advanced manufacturing such as coal-derived materials for batteries and construction.
Reclassifying Coal: From Fuel Source to Critical National Asset
One of the EO's most consequential moves is the reclassification of coal as a mineral under the president's March 2025 EO on domestic mineral production. (See Holland & Knight's previous alert, "Key Takeaways from President Trump's Executive Order to Strengthen U.S. Mineral Production," March 26, 2025.) This new designation extends the same regulatory streamlining, permitting prioritization and export facilitation previously reserved for critical minerals and materials to coal. Additionally, the EO directs the DOE and U.S. Department of the Interior (DOI) secretaries to evaluate whether coal and metallurgical coal meet the statutory definitions for "critical materials" under the Energy Act of 2020, with the goal of adding them to the departments' respective Critical Materials Lists.
These moves are not merely symbolic. If successful, they would cement coal's eligibility for a broad array of federal support programs – including those under the Defense Production Act and DOE loan authorities – while requiring agencies to prioritize coal in energy planning and permitting.
The EO also mandates an interagency review of policies that may "discourage" investment in coal-fired generation or coal production. Agencies are instructed to revise or rescind such policies within 60 days. The DOI has already announced plans to reopen federal coal leasing in Montana and Wyoming by pursuing an amendment to the Bureau of Land Management's (BLM) Miles City and Buffalo resource management plans issued in late 2024 and by directing the Office of Surface Mining Reclamation and Enforcement to pursue new rulemaking to revise the 2024 Ten-Day Notice Rule.
Finally, the EO directs the U.S. Department of Commerce to promote the export of coal and coal technologies, including facilitating international offtake agreements. These actions signal a major shift in U.S. energy policy, positioning coal as a strategic resource for both domestic and global markets.
Unlocking Coal on Federal Lands and Utilizing Categorical Exemptions for Environmental Reviews
The EO launches an aggressive federal land strategy to accelerate access to coal resources. Within 60 days, the DOI, DOE and U.S. Department of Agriculture are required to identify coal-rich areas on federal lands, assess current barriers to development and propose steps to open them for mining. The order prioritizes coal leasing as the primary land use in qualifying areas and urges agencies to invoke emergency authorities to expedite permitting and environmental review.
A key directive is for agencies to expand the use of categorical exclusions (CEs) under NEPA. The Council on Environmental Quality (CEQ) will coordinate this effort, which could significantly reduce environmental review timelines for coal projects. Though a federal appeals court formally ended the "Jewell Moratorium" on federal coal leasing in 2024, the EO instructs the DOI to publish a notice in the Federal Register indicating that no further NEPA reviews will be required for federal coal leasing, thus ending the final aspect of the moratorium. The order also mandates swift processing of royalty rate relief requests.
These land-access measures lay the groundwork for a potential resurgence of federal coal production, positioning coal as both a stabilizing force for the grid and a critical component of industrial revival.
Aligning Coal with Emerging Industrial Demand: AI, Steel and Advanced Manufacturing
The EO reflects a broader realignment of coal policy to meet the needs of emerging industries. It directs the DOE, DOI and Commerce Department to explore coal's potential to power AI data centers – an energy-intensive industry concentrated in regions with high energy demand. Agencies are tasked with identifying viable coal-powered infrastructure sites and recommending actions to support the sector with stable baseload power. The DOI recently announced $13 million in grants to transform abandoned mine lands into prime sites for infrastructure and energy development.
The EO also instructs DOE to accelerate coal technology development and submit an action plan to the National Energy Dominance Council within 90 days. This includes support for non-combustion applications such as coal-derived building materials, battery components and synthetic graphite – positioning coal as a feedstock for innovative technologies rather than merely a fuel.
Additionally, the EO emphasizes metallurgical coal's role in steelmaking, seeing to list it as a critical input for steel production. This aligns with the administration's goal of ensuring U.S. steel dominance with domestic energy resources. These provisions reflect President Trump's broader strategy of linking energy policy to supply chain resilience and economic security.
Shortly after the EO's signing, Energy Secretary Chris Wright announced a series of DOE actions to unleash coal production. These include reinstating the National Coal Council as a federal advisory committee, designating coal used in steelmaking as both a critical material and mineral in DOE's upcoming 2025 Critical Materials Assessment, and supporting efforts to commercialize technology that extracts critical minerals from coal ash. DOE will also make $200 billion in low-cost financing through the Loan Programs Office (LPO) Energy Infrastructure Reinvestment (EIR) Program available for coal energy investments, including those aimed at upgrading energy infrastructure.
Trump's 2025 Executive Orders: Updates and Summaries
Holland & Knight's Public Policy & Regulation Group is actively monitoring and reviewing President Trump's executive orders and other actions. View a comprehensive tracking chart of executive order summaries on our website.
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