It’s become an end-of-year tradition at ACRASphere global headquarters to highlight the top ten federal policy developments that impact CRM.
But this year has been anything but traditional, and 10 items won’t cover it. But Eleven is much more powerful, after all. So here are the top 11 stories from the world of CRM policy in 2025.
- A Blizzard of Executive Actions
From nearly the moment he took the Oath of Office on January 20, President Trump has issued a blizzard of Executive Orders (EOs). As ACRASphere reported at the time:
“He declared not one but two national emergencies . . . He killed federal diversity programs and ordered federal workers to report on colleagues who don’t comply. He freed everyone imprisoned over the January 6, 2021, attack on the Capitol and directed his attorney general to investigate the Jan. 6 investigators. . . . He rolled back some NEPA rules that had been around since the Disco era and anti-discrimination requirements for government contractors that were issued a year after the Beatles first came to America. Oh, and he ordered the Gulf of Mexico to be renamed the ‘Gulf of America,’ and the continent’s tallest mountain to go back to being called Mount McKinley.”
One of the most far-reaching orders affecting CRM was one declaring a “national energy emergency,” requiring federal agencies to accelerate energy production and generation (although renewable energy was pointedly left out). In response, the Advisory Council on Historic Preservation (ACHP) issued guidance encouraging agencies to use the emergency procedures in the 800 regulations for energy projects. (Fifteen states have filed suit against the administration, the Army Corps of Engineers, and the ACHP; the case is ongoing.)
The energy emergency was far from the only EO President Trump issued; on his first day back in office alone, he issued 25 orders, including ones rolling back energy efficiency policies, stopping wind energy projects, and withdrawing the US from the Paris Climate Treaty. Some of the EOs are subject of court cases, and others are more for show, but there’s no doubt about this administration’s intent to re-order the federal government.
- Grants and Contracts Up in the Air
From nearly Day One of the new administration, delays and cancellations of federal grants and contracts has brought uncertainty to CRM firms and others.
On January 28, the White House Office of Management and Budget (OMB) required agencies to freeze financial assistance. SHPOs, THPOs and non-profits saw grant monies stopped, while CRM firms and other businesses faced sudden stop-work orders on federal contracts.
The next day, a federal judge blocked the memo. OMB then rescinded it, but funding that the White House argued was related to climate and diversity, equity and inclusion (DEI), or arising from former President Biden’s Inflation Reduction Act, continued to be held up.
Further delays in providing funding to SHPOs and THPOs, even after Congress approved the funds, dominated the spring and early summer. At least one SHPO had to lay off staff due to the lack of funding. Only after a concerted advocacy campaign by preservation groups, including ACRA, plus calls from supportive members of Congress, did the administration release the funds.
As autumn rolled around, some CRM firms faced the prospect of being obligated to complete federal contracts without guarantees they would get paid, in violation of the law. While many of those issues have been resolved, grant and contract issues could continue into 2026.
If your firm has had a project cancelled, stalled, or modified, please let us know as much information as possible via this form. This information will be used internally by ACRA staff to understand the full scope of cancellations across multiple federal agencies.
- Dramatic Changes to the Federal Workforce
The early days of the second Trump administration were dominated by a single acronym: DOGE.
The Department of Government Efficiency, the brainchild of erstwhile Trump BFF Elon Musk, roared into Washington promising to shake up the bureaucracy and save taxpayers trillions of dollars. By the time Musk and Trump had their falling out, DOGE had not quite lived up to its promise to solve the budget deficit, but it nonetheless left its mark on the federal workforce.
A combination of reductions-in-force (RIFs), early retirements and buyouts has cut more than 300,000 workers from federal payrolls. Some of the cutbacks have been reversed, either by court order or the realization that some of those let go were in crucial roles. But a significant amount of institutional knowledge and experience has nonetheless been lost.
That includes at the ACHP, which announced its intention to reduce total staff from 39 to just 16 positions (in addition to having 10 of 42 council seats remaining unfilled, including the Chairmanship). Meanwhile, the Department of the Interior, which in April announced it was consolidating into its headquarters a wide range of administrative functions currently handled by individual bureaus and offices, is reportedly planning large RIFs early next year.
- Potential Threats to Section 106
2025 saw continued efforts by Congress to advance permitting reform – with some changes to Section 106 potentially on the table.
In October, the Senate Energy and Natural Resources Committee held a Section 106 hearing that, while revealing strong bipartisan support for 106, suggested an appetite among some Senators to explore changes. ACRA submitted written testimony to the Committee, calling Section 106 “an American success story, balancing the commitment to build the infrastructure our country needs in order to prosper with the imperative to preserve the properties that tell our nation’s story.”
With or without Congressional action, the Trump administration’s permitting reform moves could affect the 106 process. In February, ACRA joined with other cultural resource organizations to urge Interior Secretary Doug Burgum to protect and maintain Section 106 regulations at the Department, highlighting the “enormous benefits that Section 106 reviews generate for the nation and its states, tribes, communities, and economy, and how implementation of Section 106 has been accomplished efficiently and effectively for many decades.”
- NEPA Sees Major Overhaul
While Section 106 has not been touched, the same can’t be said for the National Environmental Policy Act (NEPA).
In April, the White House Council on Environmental Quality (CEQ) eliminated its NEPA regulations, following two court decisions that found that CEQ lacks the statutory authority to issue binding NEPA rules. A month later, the Supreme Court ruled that courts should narrow the scope of reviews required under NEPA to just the environmental effects of specific projects, and not to broader up- and downstream effects. Soon after, a host of federal agencies announced plans to amend their NEPA regulations in response to the CEQ action and to the Supreme Court decision.
ACRA urged the agencies to ensure that new NEPA regulations continue to ensure the protection of cultural resources, reminding them that “changes to . . . NEPA regulations do not release [them] from [their] obligations under Section 106 of NHPA and its accompanying regulations,” ACRA told the agencies.
As the year comes to a close, the House is poised to approve legislation that would further streamline NEPA for a range of projects.
- The Incredible Shrinking Congress
Despite its top position in Article I of the Constitution, Congress has increasingly taken a back seat to the Executive Branch in 2025.
The narrow Republican majorities on the Hill have generally avoided confronting the administration, even when its actions undermined congressional power. Republican leadership has mostly kept mum on President Trump’s more provocative statements. And the House even took an extended two-month recess during the government shutdown.
Congress did flex some legislating muscle in the early summer, passing the so-called One Big Beautiful Bill Act that extends tax cuts and reduces spending on some social welfare programs. But beyond that, Congress’ list of 2025 accomplishments is fairly meager.
With growing unhappiness in Congress, it’s no wonder that nearly a tenth of the House has announced plans to retire or run for other office in 2026, a number that is certain to grow.
- Supreme Court Gives Trump Wide Berth
It’s a story that has repeated constantly in 2025: lower federal courts block administration actions, only to have the Supreme Court reverse course.
On cases involving the firing of independent commission leaders, DOGE’s access to Social Security records, deportations, and termination of Education Department grants, the Court’s conservative majority used its emergency, or shadow, docket to reverse lower court rulings and allow administration policy to continue as cases wind through the courts.
The court also made it harder for lower court judges to block government actions across the country, ruling in June that lower federal courts likely exceed their authority when issuing “nationwide” or “universal” injunctions that block executive branch policies from being enforced anywhere in the country.
- Shifting the Rules for Small Contractors
As part of its effort to root out DEI programs from the federal government, and in response to various court decisions, the Trump administration is making far-reaching changes to federal procurement laws that may impact the CRM industry.
This fall, the U.S. Department of Transportation’s (DOT) announced that it is ending the use of race- and sex-based presumptions of disadvantage under the Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE) Programs and is requiring all current DBE/ACDBE firms to undergo reevaluation to prove their eligibility under the new standards. In its comments, ACRA urged DOT to provide more clarity about the re-evaluation process to recertify DBEs.
At the same time, the administration mostly kept in place the so-called “Rule of Two” that enables small businesses to win contracts, but clarified that the Rule of Two continues not to apply at the task or delivery order level under multiple award contracts, leaving it to the discretion of contracting officers (COs).
- History at Issue
As William Fauklner once said, “The past is never dead. It’s not even past.” That’s never been truer than in 2025, when President Trump has – depending on your point of view – either restored American history to accuracy or tried to distort it for partisan ends.
On his first day in office, he issued an EO to rename the Gulf of Mexico as the “Gulf of America” and Denali back to “Mount McKinley.” In March, another EO, “Restoring Truth and Sanity to American History,” directed the removal of “improper ideology from” the Smithsonian Institution, including from the National Zoo. Meanwhile, the Interior Department ordered the National Park Service to install signs asking National Parks visitors to share feedback on any info that is “negative about past or living Americans,” although they have not generally gotten the feedback they were looking for.
Last but certainly not least, President Trump has overseen the demolition of the White House East Wing to make way for a massive new ballroom; while the White House and its grounds are exempt from Section 106, the sudden actions have raised legal issues and serious concerns about the fate of other historic properties owned by the federal government.
- Investing in Historic Preservation – And Section 106
The past year has seen growing support for holding the line on critical historic preservation funding.
Although the White House suggested eliminating nearly all Historic Preservation Fund (HPF) monies in the new fiscal year, both the House and Senate appropriations committees have recommended $168 million for the HPF in FY26, keeping funding level with the past two years. Both bills also extend the authorization for the HPF for another year, enabling $150 million in Outer Continental Shelf drilling royalties to be placed into the Fund.
Meanwhile, a coalition of more than 300 CRM companies, organizations, Tribes and agencies across the preservation community pushed Congress to reauthorize and extend the HPF for 10 years. ACRA and its preservation partners are working to advance bipartisan legislation to do just that, H.R. 3418.
- The CRM Industry Speaks Up
The rapid pace of change in 2025 made clear that CRM advocacy is essential in making sure the sector’s voice is heard in the halls of power.
In March, ACRA joined forces with its allies in the preservation community during National Historic Preservation Advocacy Week, when preservation advocates and professionals from across the country headed to Capitol Hill to meet with their elected representatives and lobby them to support preservation and cultural resource management.
The 2026 Preservation Advocacy Week is rapidly approaching, click here to learn more and to register.
Over the summer, ACRA partnered with SAA and SHA on the #HistoryMatters campaign to bring senators and representatives to project sites to show them first-hand how CRM preserves our shared cultural heritage for present and future generations.
And this fall, ACRA launched its first-ever Advocacy Network. Open to anybody whose employer is an ACRA firm, the Advocacy Network allows members who wish to be more engaged on legislative and regulatory issues the opportunity to stay informed and make a difference.
As 2026 looms and more policy shifts on CRM await, joining the Network is the best way to make sure that your voice is heard in Washington.