When former President Donald Trump exited the Oval Office in January 2021, he left behind a record of environmental rollbacks unrivaled in modern U.S. history. Over his 1,461 days as commander-in-chief, Trump replaced, eliminated, or otherwise dismantled more than 100 environmental rules — at least — from repealing the Clean Air Act to allowing coal plants to dump toxic wastewater into lakes and rivers to declaring open season on endangered gray wolves.
President Joe Biden then rolled back most of the rollbacks, largely before their full impacts could be felt, which is why some experts say the most significant climate consequence of Trump’s presidency was actually the loss of four years that could have moved the green transition forward.
Had all Trump’s policies gone into effect, the nonpartisan Rhodium Group estimated at the end of 2020, they would have added an additional 1.8 gigatons of CO2-equivalent to the atmosphere by 2035 — more than the annual energy emissions of Germany, Britain, and Canada combined. But even though we never felt the full brunt of them, the medical journal The Lancet estimated that the policies undertaken during his presidency were responsible for 22,000 deaths in 2019 alone due to sharp increases in things like asthma, heart disease, and lung cancer.
Now Trump is once again the presumed Republican nominee and currently leads Biden in general election polls. Were he to win, he has a ready roadmap for building on his dubious environmental legacy: Project 2025, a 920-page document developed by the right wing think tank The Heritage Foundation.
Project 2025 isn’t just a climate plan, or course — it’s a comprehensive proposal, covering everything from immigration to abortion, education, pornography, and child labor. Though billed as a “presidential transition project,” its wishlist includes numerous actions that would require Republican control of both chambers of Congress (admittedly possible, though currently looking like a longshot) to enact. Undaunted, the document sets its sights on the Inflation Reduction Act, Biden’s landmark climate legislation, which — since the U.S. is the world’s second-largest greenhouse gas emitter — is all but necessary to keep the planet off the path to 1.5 degrees Celcius.
Here is how, precisely, Project 2025 aims to gut the IRA, shrink environmental protections, and slow forward momentum on climate change.
It will turn ‘climate’ into a meaningless culture war
“‘Cheap grace’ aptly describes the Left’s love affair with environmental extremism. Those who suffer most from the policies environmentalism would have us enact are the aged, poor, and vulnerable. It is not a political cause, but a pseudo-religion meant to baptize liberals’ ruthless pursuit of absolute power in the holy water of environmental virtue … They would stand human affairs on their head, regarding human activity itself as fundamentally a threat to be sacrificed to the god of nature.”
Republicans have cannily turned “climate” into another culture war buzzword. As with Critical Race Theory before it, this rhetoric strategy divorces the climate movement from what it actually is — a disparate and diverse constellation of ideas for how to move forward in the face of the reality of human-driven global warming — and flattens it into a boogeyman that voters can easily dismiss. Rather than allow for honest debate over the upsides and drawbacks of LNG or of preserving ecosystems versus quickly building out renewables, the effect is to shut down any and all conversation before it can even start.
Project 2025 both outlines and embodies this strategy. In the foreword, Heritage Foundation president Kevin D. Roberts bafflingly characterizes climate as a “pseudo-religion”; elsewhere in the document, “climate extremism” is often lumped alongside “abortion, gender radicalism … and other woke ideas.”
For good measure, the Project 2025 playbook also uses religious metaphors to code any concern about the environment as being morally wrong or even evil. Republicans have already picked up on this cue: “We should not be bending the knee to this new religion … We are flogging ourselves and losing our modern way of life bowing to this new god of climate,” Florida Governor Ron DeSantis argued during a Republican presidential debate last year.
It will use science to create weapons of war — and basically nothing else
“The National Labs have been too focused on climate change and renewable technologies. American science dominance is critical to U.S. national security and economic strength.”
As part of the Inflation Reduction Act, the Biden administration channeled $1.5 billion to the Department of Energy’s national laboratories for “innovative research in clean technologies” and “advancing U.S. energy security.” This has been essential for “de-risking” the otherwise prohibitively expensive technological advancements necessary for reaching net zero.
Project 2025, naturally, wants none of that: “The three National Labs run by DOE’s [National Nuclear Security Administration] should continue to focus on national security issues,” Bernard McNamee, the former commissioner of the Federal Energy Regulatory Commission under Trump, writes in the document’s chapter on revamping the department. Additionally, the “ill-advised attempt to expand the National Science Foundation’s mission from supporting university research to supporting an all-encompassing technology transition” (a mischaracterization) should be reconsidered, and “there should be a review to measure, prioritize, and consolidate DOE programs based on a range of beneficial factors, including degree of relationship to national security.” (While addressing the nation’s climate goals is an NSF priority, it is not done at the expense of supporting university research. Also, the current director of the NSF is a Trump appointee).
The Trump administration was memorably hostile toward science, and there are no signs he’ll change his heart during a second term; he’s already vowed to revive “Schedule F,” which reclassifies many government researchers and scientists as at-will employees, making them easier to “clean out” if they “frustrate his policies.”
Still, it does appear that the Heritage Foundation sees some usefulness for scientists: “The next administration should fund the design, development, and deployment of new nuclear warheads, including the production of plutonium pits in quantity,” Project 2025 says.
It will abdicate responsibility for the global effects of U.S. emissions
“The next conservative Administration should rescind all climate policies from its foreign aid programs (specifically USAID’s Climate Strategy 2022–2030 ); shut down the agency’s offices, programs, and directives designed to advance the Paris Climate Agreement; and narrowly limit funding to traditional climate mitigation efforts.”
The United States is the single greatest historical contributor to climate change, but Project 2025 has little sympathy for nations that might be suffering as a result. “The [Biden] administration has incorporated its radical climate policy into every USAID initiative,” Max Primorac, a Heritage Foundation research fellow, complains in the document. “It has joined or funded international partnerships dedicated to advancing the aims of the Paris Climate Agreement and has supported the idea of giving trillions of dollars more in aid transfers for ‘climate reparations.’”
Notably, Biden has not promised climate reparations — despite Trump and other Republicans’ frequent claims to the contrary. And while climate change is “a top driver of humanitarian need and human suffering, particularly for the poorest countries,” according to the United Nations, the former president slashed $200 million from environmental initiatives in his 2019 budget, including investments to help nations move away from heavy carbon-emitting industries.
It will eliminate any program or office with a whiff of climate
“Taxpayer dollars should not be used to subsidize preferred businesses and energy resources, thereby distorting the market and undermining energy reliability.”
Among the programs and offices Project 2025 wants to eliminate (or at least substantially reduce) funding for are: the Climate Hub Office; the Clean Energy Corps, the Office of Domestic Climate Policy; the Office of Energy Efficiency and Renewable Energy; the Grid Deployment Office; the Interagency Working Group on the Social Cost of Carbon; the Conservation Reserve Program; the Office of Clean Energy Demonstrations; the Office of Environmental Justice and External Civil Rights; “the activities of EPA advisory bodies”; the Office of State and Community Energy Programs; ARPA-E; the DOE Loan Program Office; the Office of Fossil Energy and Carbon Management; “grant programs for things like energy storage and the testing of grid-enhancing technologies”; “carbon capture utilization and storage programs”; the Greenhouse Gas Reporting Program; the Bureau of Energy Resources; the Office of Emergency Management; the National Flood Insurance Program; and the National Oceanic and Atmospheric Administration (more on that below).
It will push to end green subsidies
“Support repeal of massive spending bills like the Infrastructure Investment and Jobs Act and Inflation Reduction Act, which established new programs and are providing hundreds of billions of dollars in subsidies to renewable energy developers, their investors, and special interests, and support the rescinding of all funds not already spent by these programs.”
Project 2025 opposes green subsidies across the board. It’s especially twitchy about programs aimed at helping “the private sector deploy and market clean energy and decarbonizing resources” — because, supposedly, the “government should not be picking winners and losers.”
Still, while it’s uncertain how much damage a Republican president could do to the Inflation Reduction Act without the help of a conservative-controlled Congress, Project 2025 makes clear there are lots of places conservatives can chip away, including going after “subsidies of electric vehicles,” “subsidies for transit expansion,” and subsidies renewables like wind and solar. Additionally, the Office of Energy Efficiency and Renewable Energy “is a conduit for taxpayer dollars to fund progressive policies, including decarbonizing the economy and renewable resources.” That won’t do: “Eliminate EERE,” it says, or otherwise defund it.
It will go after environmental, social, and governance-related anything
“While individual investors may prefer to invest in ‘green’ companies, ‘woke’ companies, or companies with greater board diversity, and may even be willing to sacrifice some financial gains to do so, the question relevant to [the Department of Labor] is whether, and under what conditions, fiduciaries should be permitted to follow this path as well.”
If we’re being honest, though, isn’t the whole “ESG is evil” thing kind of last year?
It will make it harder to protect scenic and culturally significant places
“The new Administration’s review will permit a fresh look at past monument decrees and new ones by President Biden. Furthermore, the new Administration must vigorously defend the downward adjustments it makes to permit a ruling on a President’s authority to reduce the size of national monuments by the U.S. Supreme Court.”
President Trump was responsible for the most significant reduction in protected land in U.S. history. When he took office, Biden reinstated the protections — mainly in Utah’s Bears Ears and Grand Staircase-Escalante. Project 2025 prioritizes rolling back the rollback of the rollback, but making it stick by taking the case to the conservative-controlled Supreme Court.
The former acting Bureau of Land Management director under Trump, William Perry Pendley, writes in the section on reforming the Department of the Interior that Biden is “abusing National Environmental Policy Act processes, the Antiquities Act, and bureaucratic procedures to advance a radical climate agenda,” and directs an incoming Republican president to “seek repeal of the Antiquities Act.” Republicans and Democrats alike have used the Antiquities Act over the decades to protect scenic and culturally significant places, including the Grand Canyon, Zion, and Olympic National Parks. Any Supreme Court ruling could effectively curb the ability of future presidents to protect scenic and culturally important parts of the country.
It will break up the National Oceanic and Atmospheric Administration
“NOAA consists of six main offices ... Together, these form a colossal operation that has become one of the main drivers of the climate change alarm industry and, as such, is harmful to future U.S. prosperity.”
Thomas F. Gilman, writing on reforms for the Department of Commerce, gets right to the point: “Break up NOAA.” The agency’s “emphasis on prediction and management seems designed around the fatal conceit of planning for the unplannable,” he claims, adding, that “its current organization corrupts its useful functions.”
In practice, that would mean the National Weather Service should “fully commercialize its forecasting operations,” since “Americans rely on weather forecasts and warnings provided by … private companies such as AccuWeather,” Gilman writes. It’s a notable shoutout: Barry Lee Myers, the former CEO of AccuWeather, was briefly a Trump nominee to, uh, run NOAA.
Gilman has ideas for the Office of Oceanic and Atmospheric Research, too, writing that it “provides theoretical science” and is “the source of much of NOAA’s climate alarmism,” and should therefore be “disbanded.” Data from the National Hurricane Center is further ordered to be “presented neutrally, without adjustments intended to support any one side in the climate debate.”
Echoing the Trump administration’s hostility toward the sciences, he goes on to allege that “scientific agencies like NOAA are vulnerable to obstructionism … if political appointees are not wholly in sync with administration policy” — never mind that disagreement is one of the most essential parts of scientific research and progress.
But don’t worry: Project 2025 also calls for an elevation of … “the Office of Space Commerce.” Phew.
Here are a few other ways Project 2025 aims to attack climate progress:
It will end energy efficiency standards
Republicans are going to make dishwasher cycle times a culture war or die trying.
It will take liquified natural gas export terminal approvals away from the DOE
Project 2025 dictates that “Congress should reform the Natural Gas Act” to “eliminate political and climate-change interference in DOE approvals of liquefied natural gas exports.” Currently, the DOE must decide if it is in the “public interest” to allow LNG exports to non-free trade agreement countries — the only part of the permitting process that could even potentially consider the export terminal’s impacts on frontline communities or their effect on climate change more largely
It will make it easier to approve new pipelines …
How? By narrowing the Natural Gas Act to only consider “whether there is a need for the natural gas” and the “impacts of the actual pipeline itself, not indirect upstream and downstream effects.”
… and sell fossil fuel leases. Lots of fossil fuel leases.
The next Republican president should “immediately” reopen the Arctic to drilling, expand the controversial Willow drilling project, max out offshore oil and natural gas lease sales, and restart coal leasing in Wyoming and Montana, the authors write.
It will make it harder to keep big polluters in check
Mandy Gunasekara, Trump’s former Environmental Protection Agency chief of staff, details almost gleefully how the agency’s regulatory powers will be dismantled, from preventing downwind states from “over-controlling” their upwind neighbors to loosening car emission standards and beyond.
It will revoke the California Clean Air Act waiver (...again)
Since 1968, California has been allowed to set stricter vehicle emission limits than the federal government thanks to a Clean Air Act waiver; other states are welcome but not required to opt in. As president, Trump revoked California’s right to include greenhouse gases in its emissions considerations and barred other states from adopting its criteria. That seems like it’s back on the table — and could be headed to a consequential decision in the Supreme Court.
It will reduce fuel economy requirements
Project 2025 proposes a fleet-wide average of 35 miles per gallon, far below current benchmarks of 49 miles per gallon by 2026 and 58 miles per gallon by 2032.
It will kill wild horses
There is no question that the management of wild horses and burros is a big problem for the Western United States. But Project 2025 waves off strategies like “expanded adoptions” and “more effective use of fertility controls” as “not enough,” writing that “Congress must enact laws permitting the BLM to dispose humanely of these animals.”
It will halt the reintroduction of grizzlies in Washington state
Project 2025 aims not only to gut the Endangered Species Act, but also to “direct the Fish and Wildlife Service to end its abuse of Section 10( j) of the ESA,” which is being used to reintroduce grizzly bears in Washington state and wolves in Colorado.
It will oppose ‘eyesore windmills’ and ‘self-driving robots’
Project 2025 says that “the Department of Energy should end the Biden Administration’s unprovoked war on fossil fuels, restore America’s energy independence, oppose eyesore windmills built at taxpayer expense, and respect the right of Americans to buy and drive cars of their own choosing, rather than trying to force them into electric vehicles and eventually out of the driver’s seat altogether in favor of self-driving robots.” But as far as roadmaps go, that doesn’t look much like a way forward — it looks like holding back the inevitable. If that’s the case, then self-driving robots start to look good.
REPEAT Project
SEIA and Wood Mackenzie