Project 2025 and the EPA: How the Heritage Foundation Plans to Gut the Agency
As the 2024 election nears, most of us have heard about Project 2025 by now. The scant references here and there to the 900+ page document excoriate it as a play for absolute executive power. A lot of individuals could probably name some of the biggest policy proposals, but how many have actually read from it? This two-part series will highlight some of the most horrific changes it proposes for the Environmental Protection Agency and the Department of Energy, respectively. To put it simply, this diabolical playbook is so much worse than what you may already know.
I first heard about Project 2025 from candidate Maura Keller who is running against Brian Jack, Trump’s White House Political Director, for Georgia’s 3rd Congressional District. We were in a meeting with fellow Democrats from my home county when she had this massive book laying on the table she was sitting at. This was back in March when the primary races were heating up, so there wasn’t as much dialogue about it unlike now. During the course of that meeting, she went through several chapters, her copy of the book filled with highlighted sections, tabs, and sticky notes that referenced the most damning material. I sat in my seat and pondered all she had time to explain. I thought, “There’s no way these authors could be that outright extreme, right?”
To satisfy my own curiosity, I visited the official website for Project 2025, another name for it being the “Presidential Transition Project,” and scrolled down to read the PDF versions of the EPA and DOE chapters. My background in biology and environmental science drove me to find the truth, but despite the effort I put into it, I had no reason to celebrate. Words cannot articulate the horror, sadness, and anger I felt when reading from it. I knew that people needed to see it for themselves, so I compiled two individual reports that summarized those chapters and incorporated outside research to best evaluate how those proposed reforms would impact our environment and well-being. This article consists of excerpts from my EPA document with the corresponding page numbers to quotes in Project 2025 as well as external references.
Without further ado, let’s dive in with some of those quotes. Here are a few to start:
- “Although the U.S. environmental story is very positive, there has been a return to fear-based rhetoric within the agency, especially as it pertains to the perceived threat of climate change. Mischaracterizing the state of our environment generally and the actual harms reasonably attributable to climate change specifically is a favored tool that the Left uses to scare the American public into accepting their ineffective, liberty-crushing regulations, diminished private property rights, and exorbitant costs. In effect, the Biden EPA has once again presented a false choice to the American people: that they have to choose between a healthy environment and a strong, growing economy.” (page 419)
- “Returning the environmental justice function to the AO, eliminating the stand-alone Office of Environmental Justice and External Civil Rights.” (page 421)
- “EPA adopted by regulation a goal of restoring natural visibility by 2064. The statute does not require this, and EPA should consider whether a longer timeline is less disruptive or more realistic. Regional haze rules should be revised to prevent subsequent ‘planning periods’ from being abused to compel the shutdown of disfavored facilities.” (page 424)
- “Remove the Greenhouse Gas Reporting Program (GHGRP) for any source category that is not currently being regulated. The overall reporting program imposes significant burdens on small businesses and companies that are not being regulated. This is either a pointless burden or a sword-of Damocles threat of future regulation, neither of which is appropriate.” (page 425)
- “Level-set past, misleading statements regarding radiological risk and reassess the Linear Non-Threshold standard.” (page 427)
- “Revisit the designation of PFAS chemicals as ‘hazardous substances’ under CERCLA.” (page 431)
- “Allow PRPs to perform the statutorily required five-year reviews of Superfund cleanups to free OLEM resources.” (page 431)
- “Apply real-world use of chemicals when assessing conditions of use for risk evaluations.” (page 434)
- “Appoint and empower a Science Adviser reporting directly to the Administrator in addition to a substantial investment (no fewer than six senior political appointees) charged with overseeing and reforming EPA research and science activities. Qualifications for these positions should emphasize management, oversight, and execution skills (including in leading state environmental agencies) as opposed to personal scientific output.” (page 436)
- “Instead of allowing these efforts to be misused for scaremongering risk communications and enforcement activities, EPA should embrace so-called citizen science and deputize the public to subject the agency’s science to greater scrutiny, especially in areas of data analysis, identification of scientific flaws, and research misconduct.” (page 438)
Okay, now for some context. This is where critical research comes in as well as understanding the semantics of those quotes.
First of all, climate change is real and happening right now. It’s not some leftist tactic to paralyze people with fear and restrict their liberties. A recent example came in the form of hurricanes Helene and Milton which devastated communities in the Southeast. As a matter of fact, Milton was the quickest storm “to rapidly intensify into a Category 5 in the Gulf of Mexico” (Hurricane Milton was fastest on record to intensify into Category 5 in the Gulf of Mexico: “Historic storm” — CBS News). Increased warming in our oceans fuels these stronger systems and leads to a greater frequency of them as well. The effects of climate change harm us all, but it’s black and brown communities that suffer disproportionately from them.
This is where Project 2025 seeks to eliminate the Office of Environmental Justice and External Civil Rights which was created by the Biden Administration. According to the EPA, environmental justice means that people “are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers” (About the Office of Environmental Justice and External Civil Rights | US EPA). If Donald Trump is reelected, the Heritage Foundation would use Project 2025 as their official list of policies they want him to enact and take credit for. He denies any connection to the playbook, but a secretly recorded video shows Project 2025 co-author Russell Vought, who was Trump’s director of the Office of Management and Budget, explain that Trump is very supportive of their work and is intentionally distancing himself from it (Project 2025 co-author discusses work in hidden-camera video (youtube.com)).
Back to the subject at hand, eliminating this office subsequently means taking away the protections for these communities and stopping the crucial work that’s needed to fight environmental racism. The quote about restoring natural visibility refers to the EPA’s goal of restoring natural visibility for national parks by 2064 so that communities nearby and tourists alike can be safe and fully enjoy those experiences without the presence of smog (Clearing the Air in our National Parks (archives.gov)). Despite it not being an official law or regulation, undermining it would allow polluters to get away with making these treasured American spaces unsafe. The fourth quote, removing the Greenhouse Gas Reporting Program, would hamper our ability to keep track of our emissions from respective polluting sources (Greenhouse Gas Reporting Program (GHGRP) | US EPA).
Furthermore, questioning the Linear Non-Threshold Standard is an extremely dangerous notion as it asserts that any kind of exposure to radiation is harmful despite low dosage levels and that the effects are cumulative over time. Because of it, we have requirements for “dose limits for radiation workers and members of the public, monitoring and labeling radioactive materials,” and more (Federal Register :: Linear No-Threshold Model and Standards for Protection Against Radiation). It’s the reason we have aprons put on us when getting x-rays done at dentist and doctors' offices. Revisiting the designation of PFAS chemicals as hazardous substances, quote number 6, is another reckless idea. PFAS are forever chemicals found in our environment which stay in our bodies and lead to increased risks of cancer and other diseases (Per- and Polyfluoroalkyl Substances (PFAS) | FDA).
What’s so petrifying about these proposals is that they attack common sense efforts to keep our environment and communities safe! Another proposal, quote number 7, to allow PRPs (potentially responsible parties) to “perform the statutorily required five-year reviews of Superfund cleanups to free OLEM resources” would allow more polluters to influence the duties of the Office of Land and Emergency Management. This is like a teacher allowing a bully to take over his or her duties in the classroom. As for quote number 8, do we really want to assess the conditions of use and risk evaluations of chemicals by simply applying them to see what happens? Whether or not humans would be the test subjects should raise some red flags, especially when that statement in the book doesn’t specifically answer the question.
The ninth quote about political appointees comes from the idea of reinstating Schedule F, an executive action that would reclassify thousands of civil servants as political appointees that could be fired at will during a second Trump Administration. Instead of having these civil servants in the federal government based solely on merit/qualifications, Trump could simply fire those who aren’t loyal to him and replace them with those who are, even if they are not qualified to serve at all. Trump made some incendiary comments about current federal employees, stating, “They’re destroying this country. They’re crooked people, they’re dishonest people. They’re going to be held accountable” (Project 2025’s plan to gut civil service with mass firings: ‘It’s like the bad old days of King Henry VIII’ | US elections 2024 | The Guardian).
Finally, embracing “citizen science” from quote number 10 would inject misinformation from the public and a destabilizing amount of scientific illiteracy into the EPA’s core functioning. The United States is far from being the most scientifically literate nation, and trusting the general public to conduct scientific investigations and question EPA policies would be disastrous (How America’s Big Science Literacy Mistake Is Coming Back To Haunt Us (forbes.com)). Can you imagine someone with the scientific “literacy” of Marjorie Taylor Greene screaming that the government suddenly has the ability to control the weather? If you’re wondering if she has actually said such things, then yes, she unfortunately did (Government controls weather conspiracy theories flourish amid storms (usatoday.com)).
Here are some more quotes from the book. Again, context will subsequently be provided.
11. “Repeal Inflation Reduction Act programs providing grants for environmental science activities.” (page 440)
12. “Do not allow public events at which the agency puts forth its legal position unless they are specifically approved (for example, agency webinars on sensitive issues).” (page 443)
13. “Revisit and repeal or reform outdated environmental statutes. A high priority should be the repeal or reform of the Global Change Research Act of 1990, which has been misused for political purposes.” (page 439)
14. “Put a political appointee in charge of the grants office to prioritize distribution of grants to those who are most in need and toward projects that will tangibly improve the environment.” (page 444)
15. “Suspend and review the activities of EPA advisory bodies, many of which have not been authorized by Congress or lack independence, balance, and geographic and viewpoint diversity.” (page 437)
There is so much more material in the EPA chapter that boggles the mind, but I will end the list of quotes here so as not to overwhelm the reader. Quote number 11, repealing the Inflation Reduction Act, would immediately eliminate the biggest investment in our climate in U.S. history. It covers a broad range of objectives which include electric vehicle tax credits, green appliance tax credits, the creation of clean energy jobs, and reducing our emissions about 40% by 2030. According to Action for the Climate Emergency, “In addition to these tax incentives, the Inflation Reduction Act also includes significant investments in clean energy and infrastructure. The act provides funding for a wide range of programs, including renewable energy projects, electric vehicle infrastructure, and public transportation. These investments are intended to create jobs, reduce carbon emissions, and promote economic growth” (The Inflation Reduction Act Explained — Action for the Climate Emergency (acespace.org)).
Quote number 12 threatens to withhold potentially vital information from the public. This is different from Project 2025’s “citizen science” aspirations because, even though the general public as a whole can’t be trusted to understand the scientific work of the agency itself, the people still need to know the agency’s legal position in certain matters. That’s not to say that people should never have a modicum of feedback on scientific endeavors, but misinformation is our biggest enemy right now. In the same token of misinformation possibly being spread by so-called citizen scientists, it can also be propagated if the agency doesn’t release critical information as well, including legal stances.
Repealing the Global Change Research Act of 1990 in quote number 13 would fundamentally wipe away our efforts to mitigate climate change. Specifically, it’s “An Act to require the establishment of a United States Global Change Research Program aimed at understanding and responding to global change, including the cumulative effects of human activities and natural processes on the environment, to promote discussions toward international protocols in global change research, and for other purposes” (Appendix A: Global Change Research Act of 1990 | Accomplishments of the U.S. Global Change Research Program | The National Academies Press). Project 2025 would not only keep the EPA from continuing to protect our well-being and environment, but it will no longer be able to take steps to improve our climate.
Quotes 14 and 15 above would further degrade the agency’s ability to make its own decisions, leaving authority mostly to political appointees and Congress. All federal agencies need oversight, of course, but these proposals surpass that and would weaken the EPA as a result. Political appointees by Trump would not be qualified to lead because those people would only be there for their stout loyalty to him and nothing more. Congress can’t make all the decisions for the agency either. Representatives and senators are unable to replace the expertise that comes from those working in the agency, so any kind of overstep would be alarming.
In the end, I believe Project 2025 is one of the most nefarious political publications to have ever surfaced in the U.S., and just the major damages to the EPA alone demonstrate how far Trump’s supporters are willing to go for him. I couldn’t include all the information I had in my EPA report in this article, but for those who are interested in reading the entire work, please reach out to me directly in the comments. The Project 2025 EPA chapter can be accessed here: https://static.project2025.org/2025_MandateForLeadership_CHAPTER-13.pdf. The foundations of our democracy are at stake, so all of us should be doing everything possible to keep Project 2025 from happening.
As a final note, Kevin Roberts, President of the Heritage Foundation, made it very clear that those behind Project 2025 are treating their work as a complete takeover. He declared, “We are in the process of the second American Revolution, which will remain bloodless if the left allows it to be” (Project 2025 leader says SCOTUS immunity ruling is encouraging (usatoday.com)). None of this is hyperbole by any means. The evidence is there, so what are we going to do? Will we vote for democracy, or will we vote for a dictatorship under Donald Trump? You decide in November!
