Dramatic shifts to EPA’s priorities and structure are central to plans for a GOP-led White House drawn up by Trump-era officials and right-leaning influencers.
Project 2025, organized by the conservative-leaning Heritage Foundation, lays out detailed proposals agency by agency for a Republican president if President Joe Biden loses his reelection bid. EPA would see a return to Trump administration policies that elevated deregulation and downsized the agency, which led to tumult among staff and questions over its future.
“This is a serious report, and it needs to be taken seriously,” said Stan Meiburg, who served 39 years at EPA, including as acting deputy administrator during the Obama administration. He said the proposal largely repeats right-wing attacks on the agency.
“The EPA it envisions would be a pale imitation of an agency charged with protecting human health and the environment for all Americans,” Meiburg said.
Mandy Gunasekara, a principal at consulting firm Section VII Strategies and a visiting fellow at Heritage, authored Project 2025’s chapter on EPA. She said the plan focuses on “delivering tangible benefits” in cleaner air and water as well as “improved industrial efficiency.”
“The plan will balance environmental goals with economic growth that will deliver similar benefits realized during President Trump’s first term,” Gunasekara said, citing reductions in air pollution, cleaned-up toxic waste sites and savings from cut regulations.
Policies from the Trump EPA must be revived, according to the proposal.
A 2019 memo from the water office should be enforced so guidance documents can’t be confused with the force of law. Ex-Administrator Scott Pruitt’s “Back-to-Basics” memo should be embraced for risk assessments when reviewing air quality standards. And the Office of Mountains, Deserts and Plains should be expanded for cleaning up abandoned mines.
The plan also envisions deep organizational shifts. It would eliminate the enforcement office, spreading its function to other offices; develop proposals to relocate the agency’s 10 regional offices; push the public engagement office into the public affairs shop; and split the children’s health office among other programs.
Science advisory boards would be reset, and grants would come under review. New hires in “low-value programs” would be terminated, while Senior Executive Service positions would be considered for relocation.
“Organizational and personnel proposals all have the same objective,” Meiburg said. “To ensure that even the smallest EPA decisions are controlled by a tight corps of political officials under no obligation to heed the scientific and technical expertise of dedicated EPA career staff.”
Target: EPA
Republican presidential candidates plan to take a similar tack on EPA if they win the White House in 2024.
Among other moves, former President Donald Trump, considered the front-runner for the GOP nomination, plans to pull back EPA’s latest tailpipe emissions limits for cars and light-duty trucks, projected to spur electric vehicles to account for about two-thirds of all auto sales by 2032, and the agency’s rule requiring polluters to clean up coal ash at inactive power plant and waste sites.
Another Republican contender, former South Carolina Gov. Nikki Haley, would speed up permitting and ensure EPA doesn’t stop new energy projects.
Former Vice President Mike Pence, who suspended his presidential campaign last year, would have eliminated the agency.
The America First Policy Institute, a Trump-aligned think tank, has targeted EPA too, seeking emails of its career staff and documents from the agency’s union negotiations via the Freedom of Information Act.
Aides who served at the Trump EPA contributed to the Project 2025 plan for the agency. Gunasekara, who wrote the chapter, served as a senior air official and later chief of staff. Other Trump EPA officials, including David Harlow, Scott Mason IV, Justin Schwab and Clint Woods, were thanked in an author’s note for the plan.
“I had help from dozens of environmental, legal and administrative experts,” Gunasekara said. “Some did not want their names publicly listed, and I will continue to respect their requests.”
More funds could flow elsewhere under Project 2025’s proposal. While the plan’s overall goal is to reduce government spending, it urges a boost in funds for EPA’s support of water infrastructure.
“Increased targeted funding would greatly benefit water systems across the country at a time when intervention is crucial, leaving fewer communities with significant water service challenges,” said the plan.
The Project 2025 plan aims for EPA to “significantly elevate” its American Indian Environmental Office, calling for it to have a Senate-confirmed assistant administrator and be located out West. The proposal suggests Oklahoma City, Dallas or Denver as its home base, putting it closer to tribes and the agency’s regional offices.
“All EPA tribal grants and tribal matters should be run from this office as a one-stop-shop for all tribal affairs,” said the plan.
In turn, EPA’s international and tribal affairs office would be restructured under the proposal, with its international functions sent to other program offices.
While the agency has been central to Biden’s agenda in fighting climate change, the Project 2025 proposal would end that.
The agency would not use the social cost of carbon in drafting its rules; would preclude California’s Clean Air Act waiver from applying to “global climate issues”; and would scrutinize the Greenhouse Gas Reporting Program.
In addition, the agency’s 2009 endangerment finding on greenhouse gases, the cornerstone ruling for its climate change regulations, would be updated.
“Rolling back the endangerment finding is an idea so radical that even the Trump administration did not pursue it due to the likelihood that they would be laughed out of court,” Meiburg said.
Science, EJ offices under threat
Project 2025 also takes aim at EPA’s research and development office.
The next Republican president’s regulations freeze, which would come on the day of their inauguration, would halt the agency’s scientific assessments and guidance. Contracts worth more than $100,000 that focus on peer reviews and regulatory models would be paused.
Also, the proposal would end the research office’s use of the Title 42 hiring authority, which allows EPA to hire scientists above civil service pay levels, and put into motion plans to streamline EPA’s laboratories. Elsewhere in the Project 2025 chapter, it advises closing or consolidating the agency’s regional labs.
Liz Borkowski, the managing director of the Jacobs Institute of Women’s Health at George Washington University, said the plan’s call to cut staffing levels and suspend advisory boards threatens EPA’s capacity to use the best available science.
“I don’t want the quality of my air and water to be dependent on people without specialized scientific knowledge,” Borkowski said. “And I suspect that much of the ‘public’ input on EPA science would come from industries that care more about their ability to pollute freely than they do about public health.”
In addition, Project 2025 would eliminate the Office of Environmental Justice and External Civil Rights, created in 2022, and return its function to the administrator’s office. EPA’s application of its Title VI authority under the Civil Rights Act, which the Biden administration has attempted to use to fight pollution in disadvantaged communities, would fall under review too.
The agency’s resources, grants and enforcement work “should be based on neutral constitutional principles,” the plan said.
Vernice Miller-Travis, an executive vice president at Metropolitan Group, a social change agency, said if those changes are implemented at EPA, they will be challenged.
“As long as the Civil Rights Act stands, agencies will have to enforce it,” said Miller-Travis, a longtime environmental justice advocate. “Will people litigate that? You bet your boots that people will be litigating that.”
‘Chilling effect’ for EPA employees
The Project 2025 plan would land political appointees in far-flung corners of EPA.
Political appointees would be placed in Ann Arbor, Michigan, for the Office of Transportation and Air Quality and in Research Triangle Park, North Carolina, for the Office of Air Quality Planning and Standards. A political appointee would lead the grants office, and another would take charge of the appropriations liaison, which consults with the congressional committees that fund EPA.
EPA employees have taken notice of the plan.
The agency’s largest union, American Federation of Government Employees Council 238, has asked lawmakers to pass legislation barring the return of Schedule F, a new class of federal worker created by Trump that could be easily fired. Biden reversed that move and proposed a rule to strengthen civil service protections, which is expected to be finalized in April.
Nicole Cantello, president of AFGE Local 704, which represents EPA Region 5 employees, said the publicity around Project 2025 is creating “a chilling effect” for agency staff.
“Employees are wondering whether a year from now, will working at EPA be intolerable — or even worse — will they be fired because they don’t embrace the Trump party line?” Cantello said. “Some won’t stick around to find out. Several employees have stated they will leave EPA rather than suffer through another Trump administration.”
Gunasekara disagreed, saying the proposal would focus agency staff on bettering the environment.
“As far as morale, the public servants I know and previously worked with at EPA will once again be relieved that their work is tangibly improving lives and ecosystems, instead of being used as a cover for political promises and payouts,” Gunasekara said.
If a Republican wins the White House, changes at EPA like those proposed by Project 2025 will be contested. Miller-Travis said she is on “maximum alert” to guard rights that may be eroded.
“When I tell you that we’re going to fight this, please believe me,” Miller-Travis said. “We know they’re coming. At least this time they wrote it down.”
