CSG Law Alert: Offshore Wind Projects Defeat Federal Shutdown Order
In a significant development for renewable energy efforts, all five major offshore wind projects targeted by the Trump Administration’s recent stop-work order have now been cleared by federal courts to resume construction. These legal victories for offshore wind follow more than a year of uncertainty caused by the Trump Administration’s campaign against offshore wind development.
Efforts to impede offshore wind construction started on January 20, 2025, with a Presidential Memorandum withdrawing all areas of the Outer Continental Shelf from disposition for wind-energy leasing and instructing federal agencies to pause the issuance of new or renewed approvals for offshore wind projects. The Memorandum operated as a moratorium on new offshore wind development, which was immediately challenged by several states, as well as the companies supporting offshore wind projects.
On December 8, 2025, the District of Massachusetts vacated orders from the federal agencies implementing the Memorandum, finding that the federal government’s decision to pause offshore wind authorizations violated the Administrative Procedure Act. The victory was short lived. Two weeks later, on December 22, 2025, the United States Department of the Interior announced that it was suspending leases for large-scale offshore wind projects under construction in the United States due to national security concerns. Unlike the Memorandum, the suspension order stopped work on five offshore wind projects in various stages of construction, including Revolution Wind in New England, Sunrise Wind in New York, Empire Wind in New York, Vineyard Wind 1 in Massachusetts, and Coastal Virginia Offshore Wind in Virginia.
On January 7, 2026, the District of Massachusetts issued a preliminary injunction in favor of Vineyard Wind 1, allowing the project to resume full activities. During the week of January 12, 2026, three federal judges granted preliminary injunctions in favor of Revolution Wind, Empire Wind, and Coastal Virginia Offshore Wind, and allowed each to continue construction while their cases against the federal government were pending. As of February 2, 2026, the remaining project impacted by the suspension order, Sunrise Wind, was also cleared to continue construction.
At the time of the shutdown, the Sunrise Wind project was 45% complete. Upon completion, the project will deliver 924 MW – enough electricity to power 600,000 homes and businesses in New York. The combined nameplate capacity for the five projects will exceed 5,800 MW.
With the recent decision just last week, all five projects targeted by the federal shutdown are authorized to continue while their respective cases remain pending, to be further litigated. While the federal government has yet to appeal any of the January and February decisions, the United States Secretary of the Interior has indicated that the Department of the Interior will appeal the rulings. CSG Law will continue to monitor the pending federal cases as they develop.
For more information or updates, please contact the author of this post or the CSG Law Environmental Group.