"Strongest" is a misnomer.

(1) EPA has turned almost exclusively to administrative cases to go after polluters, even the worst ones, rather than taking polluters to court.

(2) Not only that, this EPA annual report fails to include any figures on the number of judicial cases initiated or concluded, and the agency no longer includes its criminal cases in its public enforcement database, Enforcement and Compliance History Online (ECHO). These moves constitute a historic retreat from transparency, covering its tracks as it backs away at once from the courtroom and from public accountability.

(3) The EPA under Trump is registering historic highs of leniency in the cases it does take up or conclude, lowering penalties in both administrative and judicial cases and thereby severerly weakening the legal force and incentives provided by our environmental laws to polluting (see annotations below).

(4) Agency bragging about administrative cases it has concluded obscures a larger pattern. Nearly across the board, the EPA is backing way from initiating* * key enforcement activities. Not only are the administrative cases it began far less that those it concluded; drop-offs have come in judicial cases against violators and in many of the inspections that enable it to detect violations in the first place (see annotations below). This pattern points to still more weakening of its enforcement in the months and years ahead.

For more on all these fronts see EDGI, Making America Polluted Again: The Trump EPA’s 2025 Enforcement Record. For more especially on the agency's historic retreat from the courtroom, see also reports from EarthJustice, Public Employees for Environmental Responsibility and the Environmental Integrity Project.

ICYMI, only one of these "five pillars" actually commits the agency to protecting public health and the environment. The other four all commit to some form of deregulation, whether to lighten rules and enforcement for favored industries (oil and gas, AI, automobile production) or lessen oversight more generally for permitting, etc.

Tellingly, the agency offers no comparison here between FY2025 and earlier fiscal years. So let's compare, this time concentrating on periods that the Trump administration did not share with its predecessor:<br /> (1) the fines levied in admnistrative cases concluded during the first year of the second Trump administration (Jan. 21-Sept. 30, 2025) with the comparable period in 2024 under Biden * the percent with zero fines has gone up from 59% to 66%. Find our data here.

(2) Comparing the total penalities imposed in administrative cases concluded during that same time period under Biden (Jan. 21, 2024-Jan. 20, 2025) and under Trump (Jan. 21, 2025-Jan. 20, 2026) also points toward greater leniency. <br /> * The total of federal penalties fell from $68 million under Biden to $54 million under Trump, despite the Biden EPA concluding some four hundred fewer cases. Find our data here.

(3) Our recent report on EPA enforcement, comparing the public record of first 10 months of the Trump administration (Jan. 21-Nov. 30, 2025) with earlier years, found that the Trump EPA has set 20-year records for leniency in: * Figure 14. Number of Solid and Hazardous Waste Inspections Finding Violations Under the Resource Recovery and Conservation Act as Recorded in RCRAInfo, 2005-2025 * Figure 22. Percentage of EPA Administrative Cases Filed with Zero Dollars in Federal Penalties, 2005–2025 * Figure 23. Percentage of EPA Administrative Cases Filed with Zero Dollars in Compliance Costs, 2005–2025.

Points repeated from above; see our annotations above.

Well I know its latest since I've been following, like back to 2015. But could we refrain from saying "latest its ever been" until we have checked? Not sure how we'd find reports, say, from early REagan years....

These figures on case conclusions appear to be by fiscal year, which means that they also include work done in the final months of the Biden Administration. We've looked instead at EPA's own publicly available data for the Trump administration's calendar year (Jan. 21, 2025, to Jan. 20, 2026), and compared that to the same intervals for the first and fourth years of the Biden administration.<br /> The Trump administration concluded 3288 administratiive cases, compared to 2944 in Biden's fourth and 2659 Biden's first year.<br /> However, Trump's cases included over 400 more with zero dollars in federal penalties: 2257 versus 1813 for Biden, year 4, and 773 for Biden's year 1. * Moreover, the vast majority of cases concluded since January 21, 2025, rely heavily on earlier work from inspections to the initiation of cases.<br /> To see how much the cases concluded under Trump owed to work done at the agency under Biden and other predecessors, we analyzed the data EPA provides on the "inspection pipeline" for air pollution-related administrative cases. For the 947 fully documented cases there that were concluded January 21, 2025-January 20, 2026 (about a third of the total case conclusions for that interval), 87% of these cases relied on inspections that happened before Trump took office* for a second time.

Find our data here.

Again, the EPA provides no comparison with earlier years, but more generally, we've done that for data that is publicly available, for inspections under the Safe Drinking Water Act, Our recent report on EPA enforcement, comparing the public record of first 10 months of the Trump administration (Jan. 21-Nov. 30, 2025) with earlier years, for this type of inspection. As we reported there: * In this first year of the second Trump administration, there have been 1,128 SDWA inspections, down 29.98% from the average annual number of inspections under Biden, and down 17.48% compared to 2024." * "during the Biden administration, SDWA inspections averaged 1,611 annually. Only two years saw fewer than 800 SDWA inspections per year (2018 and 2020), both occurring during Trump’s first administration."

Boding poorly for the future of such work, our recent report on EPA enforcement, comparing the public record of first 10 months of the Trump administration (Jan. 21-Nov. 30, 2025) with earlier years, found that the Trump EPA set a 20-year record for leniency in: * Figure 14. Number of Solid and Hazardous Waste Inspections Finding Violations Under the Resource Recovery and Conservation Act as Recorded in RCRAInfo, 2005-2025

• Moreover, inspections under this act were the second lowest in 20 years, only higher than in the year of COVID: Figure 13. Annual Number of Solid and Hazardous Waste Inspection Activities, 2005–2025.

A point repeated a third time; see our annotation for the first time.

A point repeated a second time; see our annotation for the first time.

We can't tell where these totals came from. But what we do know, from looking at EPA's public data is that the total compliance costs for those administrative cases that the Trump Administration concluded between January 21, 2025 and Jan. 20, 2025 were significantly less than those for Biden's first or fourth years. <br /> * Despite concluding more cases, the Trump administration required $2.477 billion in compliance costs, less than the $2.677 billion required by the Biden EPA betweeen Jan. 21, 2024, and Jan. 20, 2025, * And both the Trump and final-year Biden figures ran lower that the $2.940 billion in total compliance costs in Biden's first year, Jan. 21, 2021, and Jan. 20, 2022.

Find our data here.

Again, EPA only offers raw figures for a single year. That's likely because a comparison with earlier would prove embarrasing and more, auguring further declines in enforcment up ahead. Inspections and other compliance monitoring are, after all, the way that EPA finds the violations it then pursues through cases. Since these activities so important for grounding future enforcement actions, we've done the comparisons that EPA has not, between the first year under Trump 2.0, Jan.21, 2025-Jan. 20, 2026, and earlier years.

• Inspections under the Toxic Substances Control Act (TSCA)-A severe decline Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 1430 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 1284 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 834

• Inspections for lead paint (a subset of those under TSCA)--A severe decline after robust recent growth Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 272 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 659 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 405

• Inspections under the Resource Conservation and Recovery Act (RCRA) for hazardous and solid waste--a significant decline Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 2055 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 1627 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 1410

• Inspections under the Clean Water Act (CWA) combing those for NPDES with other CWA programs): a decline after robust recent growth Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 2089 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 3194 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 3111

Inspections under the Clean Air Act (CAA) (overall, partial, full) * Overall inspection activities--a decline after significant recent growth Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 1755 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 1897 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 1662

• Partial, usually undertaken by federal EPA to check for particular toxic or other air pollutants--a severe decline Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 761 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 790 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 582

• Full inspections--a decline after robust recent growth Jan 21, 2021 - Dec 31, 2021 (Biden first year) = 92 Jan 21, 2024 - Dec 31, 2024 (Biden last year) = 214 Jan 21, 2025 - Dec 31, 2025 (Trump 2 first year) = 199

Blatantly contradicted by the many metrics across these many annotations demonstrating just how much EPA under Zeldin has backed away from enforcing our environmental laws.

EDGI's recent enforcement report, comparing the Zeldin/Trump EPA's track record over its first ten months to the same period over previous 20 years, found that in seven of twenty-four metrics, 2025 was the worst in the last two decades: * Figure 11. Annual Number of Partial Air Pollution Inspections, On-Site and Off -Site * Figure 14. Number of Solid and Hazardous Waste Inspections Finding Violations Under the Resource Recovery and Conservation Act as Recorded in RCRAInfo, 2005-2025 * Figure 16. Annual Inspections Under the Toxic Substances Control Act (TSCA), 2005–2025. * Figure 22. Percentage of EPA Administrative Cases Filed with Zero Dollars in Federal Penalties, 2005–2025 * Figure 23. Percentage of EPA Administrative Cases Filed with Zero Dollars in Compliance Costs, 2005–2025. * Figure 28. Annual Number of EPA Civil Judicial Cases Filed, 2005–2025. * Figure 31. Annual Number of EPA Civil Judicial Cases Concluded, 2005–2025

And imposing much lighter penalites, it appears (see next three annotations).

If you search EPA's Environmental Compliance History Online (ECHO) for how many criminal cases it undertook in 2025, you get an answer of zero. Unlike all other types of inspection activities, EPA has not made public any data on individual criminal cases since 2024. That has made anything the agency claims about its criminal case work impossible to verify or independently evaluate.

While the press release and report emphasize case conclusions, the public data available on case initiations offers a revealing window into where EPA's handling of newly begun cases is headed.

• The Trump administration did begin more civil administrative cases in its first calendar year (Jan. 21, 2025-Jan. 20, 2026) than did the Biden administration in its final year: 1823 versus 1246. But its settlments of the cases it started were far more lenient.
• 71% imposed zero penalities, as opposed to only 18% in the final year of Biden.
• Total federal fines amounted to only $21.6 million, as opposed to $60.3 million in the final year of Biden.

Find our data here.

While this number may sound tough, it is only 35 more defendants than in the previous fiscal year, exclusively under Biden (see EPA's own FY25 report). Such numbers also need to be squared with * the 101 fewer judicial cases concluded under Trump (Jan.21, 2025-Jan. 20, 2026) than in Biden's last year (Jan. 21, 2024-Jan. 20, 2025). * the 57 few judicial cases initiated ("complaint filed) under Trump (Jan.21, 2025-Jan. 20, 2026) than in Biden's last year (Jan. 21, 2024-Jan. 20, 2025).

Find our data here.

The figure here actually contradicts that given above on this very same page, even though the last part of both sentences is the same. So what is it EPA, 2300 or 2137 for the fiscal year (if that is even the time interval being used here)?

Given such discrepancies, might it be that our figure mentioned in the annotation for the above version of this sentence, culled from EPA's public data and also double-checked, is actually more reliable?

Astonishingly, this press release and EPA's FY25 annual report itself entirely ignore the other type of civil case that since the agency's founding in 1970 has been central to its enforcement efforts: the judicial case. That's when a pollution violation is so severe or egregious that the EPA feels compelled to take a polluter to court. Here the Trump administration's record has been absolutely dismal--likely why theirs has become the first annual enforcement report in decades (if not all the agency's history) not to include figures on judicial cases.

• EPA's own data (comparing periods between Jan. 21 of one year to Jan. 20 of the following year), shows a 58% drop in judicial case conclusions between the Biden administration's final year and the first year under Trump, from 173 to 72.

Find our data here.

By not including this kind of information on judicial cases in their FY2025 annual enforcement report, the Trump 2.0 EPA is taking a major, historic step backward in transparency and accountability; it is an act of unadulterated censorship.

While here EPA brags about controlling pesticides, it also approved several pesticides that are highly persistent and with scientifically esablished harms,<br /> * These include several agricultural poisons that include or break down into "PFAS" or "forever chemicals," * The EPA has also provided active support to pesticide manufacturers in court cases, such as those involving Bayer, a manufacturer of glycosophate. It seeks to defend itself against damage suits that have followed scientific assessments such as by the World Heatlh Organization that it is "probably carcinogenic." .

Unlike previous years’ reports, FY 2025 omits numbers pertaining to environmental justice (EJ). In an EPA OECA memo from March of 2025, Acting Assistant Administrator Jeffrey A. Hall states: “Pursuant to the President’s Executive Orders, environmental justice considerations shall no longer inform EPA’s enforcement and compliance assurance work.”

In prior reports (e.g., FY 2023, FY 2024) environmental justice data were provided for a range of enforcement activities (e.g., Federal Inspections, Civil Enforcement Case Conclusions, Superfund Enforcement Instruments, Environmental Crime Cases Opened, etc.). For several indicators, readers could see the total counts of a given enforcement activity, and a breakdown of where the activity occurred, comparing communities with EJ concerns to communities without EJ concerns.

When this information is not provided, it is unclear if enforcement gains (e.g., penalties assessed) and setbacks (e.g., declines in enforcement activity) are distributed equally across communities. EJ data is needed to test the claim that the EPA’s enforcement initiatives are “Improving Health for All Americans” [emphasis added].

Sources: FY 2025: https://www.epa.gov/enforcement/enforcement-and-compliance-assurance-annual-results-fiscal-year-2025 FY 2024: https://www.epa.gov/system/files/documents/2025-03/eoy2024.pdf FY 2023: https://www.epa.gov/system/files/documents/2025-03/eoy2023.pdf Also: https://www.epa.gov/system/files/documents/2025-03/necimemo-20250312.pdf

This appears to refer to Superfund site study and clean up, a type of Superfund Enforcement Commitment. For FY 2024, it was reported that responsible parties committed $1.17 billion to site study and clean up, representing a 38.95% decline from FY2024 to FY2025.

Totaling all forms of Superfund Enforcement Commitments from Private and Federal Parties, since 2016, FY 2025 was one of only three years that the EPA recovered less than $1 billion annually in commitments.

Source: https://www.epa.gov/enforcement/enforcement-and-compliance-assurance-annual-results-fy-2025-data-and-trends

According to last year’s report, 84 Enforcement Instruments were completed at 71 Superfund sites in FY 2024. This year’s report states 65 Enforcement Instruments were completed at 55 Superfund sites in FY 2025.

That’s fewer enforcement instruments at fewer Superfund sites, representing not only a 22.62% decrease in finalized Superfund enforcement instruments from FY 2024 to FY 2025, but apparently a ten-year record low in the number of annual completed Superfund Enforcement Instruments.

FY2024 Report: https://www.epa.gov/system/files/documents/2025-03/eoy2024.pdf (p. 153) FY2025 Report: https://www.epa.gov/enforcement/enforcement-and-compliance-assurance-annual-results-fy-2025-superfund-cleanup

McNamee is a lawyer who served in the Trump Administration, 2018-2020, as Commissioner of the Federal Energy Regulatory Commission. Confirmed by the Senate on a close and party-line vote (50-49), he had previously worked with the Texas Public Policy Foundation, a conservative think tank financed largely by the oil and gas industry. Kevin Roberts, who wrote the Foreword for Project 2025, was an executive vice-president at TPPF. https://energyandpolicy.org/video-trump-ferc-nominee-fossil-fuels/

The policy problem is that no state wants to host a depository for civilian nuclear waste. Nevada was chosen for political reasons and now that it's a swing state it is unrealistic to think that Yucca Mountain will be used. For how Yucca Mountain was selected and the problem of nuclear waste in general see: https://www.ucpress.edu/books/the-road-to-yucca-mountain/hardcover

It is commendable that this chapter actually suports the efforts of DOE to clean up the enormous environmental damage produced by decades of nuclear weapons production.

But: is this an effort to reclassify the waste so as to make the clean-up process cheaper? Is this just an example of cutting corners?

Having non-scientists direct scientific research is a troubling directive, but a strategy that crops up across many of the environmental plans of Project 2025.

Here the chapter ventures into outright climate denialism, beyond its usual approach of inattention or indifference. Decades of study have made clear both the disproportionately large contributions of the developed countries to the greenhouse emissions causing climate change https://www.cgdev.org/media/who-caused-climate-change-historically and the disproportionate burden that devleoping nations are already enduring from its consequences. https://www.usglc.org/blog/climate-change-and-the-developing-world-a-disproportionate-impact/

While support here for prevention of Uyghur forced labor may sound laudable, it runs against the grain of this chapter and Project 2025 in general, which purport to pare back or limit government. Except when they don't. This particular requirement is so anomalous that we suspect it may result from a personal favor or relationship.

This is consistent with the call to end funding for carbon capture utilization and storage (on p. 376) and the larger call for US energy policy to not subsidize any form of energy [implicitly: except for those already subsidized]. Since this chapter studiously avoids the manner in which oil and natural gas are currently subsidized, such points only further highlight the preference asserted here for the oil and gas industry, to the detriment of the nuclear power and coal industries as well as solar, wind, etc.

By picking winners, using government reshuffling to help force the nation's energy supply back into a single basket, fossil fuels, Project 2025 seems determine to undermine energy security and reliability.

One could argue that expanding renewable energy production helps achieve these goals, both of energy access and energy security.

There has long been a debate about the proper use of the SPR. Should it only be used in the event of actual supply shortages and gasoline lines? Or should it be used when prices spike "too high?" See https://www.tamupress.com/book/9781585446001/the-strategic-petroleum-reserve/

Political perception of the impact of SPR releases on Americans' prices at the pump tend to far outstrip the actual economic impact: https://visualizingenergy.org/can-releases-from-the-strategic-petroleum-reserve-lower-energy-prices/

Under Project 2025, promoting American energy interests is limited to expanding production and consumption of fossil fuels both in the United States and abroad. Currently, the U.S. leads the world in production of oil and gas. Where the U.S. is at greatest risk of falling behind is investments in clean energy manufacturing and deployment, as explained in the International Energy Agency's World Energy Investment 2024 report. For historical context about how the U.S. fell behind China in investments in clean clean energy, see https://uwapress.uw.edu/book/9780295752181/charged/(2022), chapter 4.

How many times does the licensing process need to be streamlined? It was last streamlined in the Energy Policy Act of 2005. What is left unsaid here is that the expected nuclear renaissance of the early 2000's was killed by cheap natural gas produced by fracking. The problem with nuclear power isn't burdensome regulation or environmentalists; it's that the technology is simply not cost-competitive. See https://www.academia.edu/41080344/Nuclear_Power_in_America_The_Story_of_a_Failed_Energy_Transition

While it is proper for the federal government to dispose of spent nuclear fuel, how is this not a subsidy to the civilian nuclear power industry? The fees collected will never come close to paying for disposal.

Substantial private-sector engagement with US energy infrastructure is well-documented: https://visualizingenergy.org/which-banks-fund-upstream-oil-and-gas/

This chapter stands in support of a presidential campaign that advocates increasing tariffs, which is literally the very definition of picking winners and losers (why industrial policy is okay for some sectors of the economy but not energy is left unexplained).

Putting that aside, there is a tension between the market liberalism of trying not to pick winners and losers and the goal of American energy dominance and energy independence. For if the proper role of government is to step back and let the market decide, it shouldn't matter where the energy comes from. It shouldn't matter if the US is energy-independent.

Our involvement in the Middle East over the past century suggests it does matter. Oil is not just another commodity. Daniel Yergin titled his history of oil "The Prize" for a reason. Oil (and energy more broadly) has always been considered too important for its distribution, price and reliability to be left solely to the private market. https://www.simonandschuster.com/books/The-Prize/Daniel-Yergin/9781439110126

This ignores the fact that government has played a role in every energy transition over the past two hundred years. For a study of how government "picked" coal in the early 1800s. See https://www.hup.harvard.edu/books/9780674970922

For more information on the history of energy subsidies for fossil fuels, nuclear, biofuels, and renewables see https://www.dbl.vc/wp-content/uploads/2012/09/What-Would-Jefferson-Do-2.4.pdf

Translation: these are the forms of energy that matter. And their impacts on the atmosphere and those millions whose lives will be disrupted or lost through climate change do not.

A peculiar turn of phrase suggesting we need more public control over the energy industry, especially if readers have some knowledge of how many contemporary energy markets work. If the author was serious about this goal, he would favor doing away with investor-owned electric utilities that possess state-sanctioned monopoly control of their territories.

While Project 2025 authors describe a contermporary "war on oil and natural gas," the data belie this claim. The U.S. currently produces more crude oil than any other country in world history and is producing record levels of natural gas. Biden administration energy policy has included provisions support expansion off-shore oil and gas development, to the consternation of climate hawks. The Energy Information Administration is the best source for information on domestic energy production. On natural gas, see https://www.eia.gov/todayinenergy/detail.php?id=61263 On crude oil production, see https://www.eia.gov/todayinenergy/detail.php?id=61545#:~:text=Crude%20oil%20production%20in%20the,than%2013.3%20million%20b%2Fd.

Such a policy goal disregards the longstanding federal policies subdidizing research, extraction, and deployment of all types of energy sources in the United States, including wood, fossil fuels, biofuels, nuclear power, and renewable energy. As Nancy Pfund and Ben Healey explain, based on their research on historical energy subsidies, "From land grants for timber and coal in the 1800s to tax expenditures for oil and gas in the early 20th century, from federal investment in hydroelectric power to research and development funding for nuclear energy and today’s incentives for alternative energy sources, America’s [i.e., our government's] support for energy innovation has helped drive our country’s growth for more than 200 years." While support for renewables has grown under the Biden administration, those policies are catching renewables up to the historical subsidies provided to the nuclear, oil and gas, and biofuels in the past, many of which also continue into the present. For more information, see https://www.dbl.vc/wp-content/uploads/2012/09/What-Would-Jefferson-Do-2.4.pdf

This is a recurring motiff: fossil fuels are reliable and renewable forms of energy (because they are intermittent) are unreliable. This chapter even references the February 2021 blackout in Texas during winter storm Uri as supporting evidence, repeating conservative talking points from the time that have persisted despite repeated debunking. By far the chief reason for the blackout was the widespread failure of Texas' insufficiently weatherized natural gas plants. They shut down just as natural gas demand for home heating rose. Texas suppliers were also hampered by how disconnected this state remained from any larger grids. Oklahoma suffered many of the same problem experienced in Texas but was able to draw power from states further north avoiding a blackout. https://energy.utexas.edu/research/ercot-blackout-2021#:~:text=In%20February%202021%2C%20an%20extreme,more%20than%204.5%20million%20homes.

Fossil fuels don't ensure reliability. On the contrary, there is a long history of blackouts associated with fossil fueled power; to an extent most people don't realize, these are often caused by issues of transmission lines running from coal-, fuel oil-, or gas-powered generation plants. See https://direct.mit.edu/books/book/3271/When-the-Lights-Went-OutA-History-of-Blackouts-in

We environmental historians are unaware of any recent calls for government ownership of the energy industry; the actual definition of nationalization. There was a debate, in the early years of American electrification, about whether electric utilities should be under public or private control, and other national governments have taken public control over the holdings of private oil companies, including Mexico in 1938. But we have seen no discernible trend toward this nationalization--what most scholars mean by the word-- in recent times in the United States.

Climate change: the problem that cannot be named or acknowledged as genuine here, as elsewhere in Project 2025. Many of the policies in this chapter make little sense absent the assumption that global warming is either a hoax or grossly exaggerated by "radical" environmentalists and a political left, which can be safely ignored. If only we lived in that world.

This claim ignores significant evidence. For instance: since 2015, the US has become a net exporter of gasoline: https://www.eia.gov/todayinenergy/detail.php?id=63224 The reliance on oil advocated here renders us dependent on Organization of Petroleum Exporting Countries (OPEC) largely because of its collective ability to set or influence global oil prices, despite America's current status as net fossil fuel exporter.

Moreover, finite oil supplies of particular fields and regions have a habit of running out. What happens when fracking runs its course and the US is no longer a net exporter of oil and gas? Likely: even greater dependence on other oil-producing nations.

Third, true energy independence or dominance is not possible with a reliance on an energy source that is priced by global supply and demand dynamics, such as oil. Not just oil but natural gas may soon rely on international price-setting; many expect a global price for natural gas is on the horizon. Our reliance on a commodity priced by global forces places true "independence" and "dominance" out of reach for national policy-makers.

Fourth, every form of energy is subsidized (some intentionally, some unintentionally) by a range of policies. (see especially the Introduction in https://www.ucpress.edu/books/crude-politics/hardcover). Historically, the oil and gas industry has received the lion's share of these subsidies. If one were to include greenhouse gas emissions, US foreign policy commitments, and federal preferece for automobility (over other forms of transportaton), federal subsidies for petroleum continue to overshadow those for other sources of energy.

The idea advanced by these authors simply ignores these historical and contemporary realities. When they say government should not be picking winners and losers by subsidizing energy, the authors only talk about the subsidies enjoyed by the forms of energy they dislike while ignoring the vast subsidies for the forms of energy they prefer.

As a result, the chapter ignores the costs to the economy of a continued reliance on fossil fuels.

The chapter would have the US completly disinvest from supporting and subsidizing renewable forms of energy arguing that the transition away from fossil fuels is bad for the economy, makes the US less energy secure, and involves the government picking winners and losers.

There are several problems with this analysis. First, burning fossil fuels produces pollution, an environmental externality, that is not factored into the price of oil, coal or natural gas. This is a subsidy that is not recognized by the authors of this chapter.

Second, the US economy is reliant on oil. Virtually every recession since 1945 has been preceded by a significant rise in oil prices. Even though the US is today 'energy independent' (i.e. a net exporter), world oil prices are determined by global supply and demand. It is in our interest not to see oil prices rise too high. There are two ways to achieve this goal: we can reduce our reliance on oil or insure that the world is sufficiently supplied. For the past fifty years, the focus has been on insuring the security of supply. Since the Middle East contains close to half the world's oil reserves and produces a large percentage of the world's oil and natural gas, the US cannot allow unfriendly regimes to control too large a percentage of that region's energy exports. As a result, the US has spent trillions of dollars over the past several decades attempting to support or create such friendly regimes. This interest doesn't change with energy independence and it serves as an enormous unacknowledged subsidy to the oil and gas industry since it would not exist absent our reliance on oil. https://us.macmillan.com/books/9780809075072/panicatthepump https://www.jstor.org/stable/41510316

Re-jiggering the understanding of reserve margins serves to tip the scales toward certain kinds of power. This is a political rather than engineering approach to our electrical grid.

LNG terminals have significant security concerns. https://crsreports.congress.gov/product/pdf/RL/RL32205

Translation: maybe global warming exists, but even if it did, addressing it is not a legitimate policy that serves the public interest.

Even staunchly conservative outlets such as the Wall Street Journal have found that problems with reliability of the electrical grid are substantially rooted in aging power lines and changing global climate. https://www.wsj.com/articles/americas-power-grid-is-increasingly-unreliable-11645196772

This is symbolic. But the US should work to deter nuclear weapons testing as well as the build-up of nuclear arsenals by our adversaries. To think that the only way to do so is by pouring trillions of dollars into designing and building thousands of new nuclear weapons is to learn nothing from history.

What happened to not picking winners and losers?

As pointed out, the region is of increasing strategic importance because of warming ocean temperatures and melting Arctic glaciers. https://www.noaa.gov/news-release/warmest-arctic-summer-on-record-is-evidence-of-accelerating-climate-change

Here we have conservatives applauding the expansion of government to address conditions created by global warming.

This office is only needed because global warming is melting glaciers in the Arctic. It is only a matter of time before goods shipped between Europe and Asia follow a northern route thereby making control and/or access to this region in our national interest.

This is a good idea. How is it achieved without picking winners and losers?

This makes perfect sense in a world where global warming does not exist.

Project 2025 flags increased energy costs as a substantial burden for American households. Yet consumer advocates note that energy-efficient appliances have saved American households significant amounts of money: Consumer Reports noted five years ago that "Households are saving hundreds of dollars annually as a result of increasing appliance efficiency standards," according to one analyst. https://www.consumerreports.org/energy-efficiency/why-new-major-appliances-use-less-energy/

The preferred forms of energy.

The previous page detailed how the original mission included, "minimizing the environmental impacts..."

Yes, this is a commendable goal. But it will never happen until conservatives recognize that addressing global warming is in the public interest.

This is a significant threat to the natural gas industry. Utility-scale wind and solar is cheaper than natural gas or will be in the future. Cheap batteries will eliminate the reliability issue threatening an important domestic market for the natural gas industry.

Deployment of grid-scale battery back up storage has grown dramatically in states with favorable policy environments, such as California and Texas. https://www.eia.gov/todayinenergy/detail.php?id=61202

Translation: research the energy technologies we like. Don't research the energy technologies we don't like.

Translation: we want less information on global warming.

China has become the world's leader in supply chains related to solar power. Ensuring that the US can maintain a place in markets and innovation related to photovoltaics and solar power is an important element of energy supply and infrastructure, but not one that Project 2025 acknowledges. https://www.iea.org/reports/solar-pv-global-supply-chains/executive-summary

The NRC was designed to be the cop on the beat. Any regulation could be viewed as "hampering" civilian nuclear deployment.

Subsidizing the commercialization of new energy technologies is not "government control of energy." This is sloppy analysis.

The Annual Energy Outlook (AEO) report by the US Energy Information Agency surveys long-term energy trends and is widely respected by traditional energy producers and analysts across many fields. The 2023 AEO concluded that "we project that the United States will remain a net exporter of petroleum products and natural gas through 2050 in all AEO2023 cases." Further, "As a result, in AEO2023, we see renewable generating capacity growing in all regions of the United States in all cases. Across all cases, compared with 2022, solar generating capacity grows by about 325% to 1019% by 2050, and wind generating capacity grows by about 138% to 235%. We see growth in installed battery capacity in all cases to support this growth in renewables. Across the span of AEO cases, relative to 2022, natural gas generating capacity ranges from an increase of between 20% to 87% through 2050." https://www.eia.gov/outlooks/aeo/narrative/index.php#ExecutiveSummary

This chapter provides no evidence that the US is experiencing an energy crisis. To wit: much evidence such as of record oil production suggests the opposite: https://www.forbes.com/sites/rrapier/2024/03/12/eia-confirms-historic-us-oil-production-record/

Finally some serious attention to Native American interests and rights. But the overriding concern here seems to be enabling these groups, as well, to step up extraction from public lands.

Pendley's proposals would effectively dismantle decades of agency efforts to implement Congressional mandates by executive fiat, without consulting Congress. Challenges to many of these proposals are likely to succeed in court.

In this paragraph and elsewhere, the authors emphasize the need for "Alaska" to have greater sovereignty and also condemn environmental protection as an "injustice" against the people of the state. However, as our other comments indicate, issues of Native sovereignty, food security, Indigenous rights, and struggles for environmental justice are completely disregarded in the monolithic, pro-development vision advanced in this report.

In the Trump administration's rush to drill in the Arctic National Wildlife Refuge, science was often disregarded or manipulated (including in the BLM studies that culminated in the 2020 EIS). For excellent reporting on these issues during the Trump years, see Adam Federman's 2019 article in Politico: https://www.politico.com/interactives/2019/trump-science-alaska-drilling-rush/ And for a brief, longer-term perspective on science denialism in the Arctic Refuge debate (ranging from the Reagan era to the Trump era), see: https://time.com/6332304/arctic-refuge-drilling-distortions/

It should be noted that the history and impact of ANCSA are incredibly complex--both for the many different tribal nations in Alaska and for the unfolding of different environmental conflicts across the state. To begin, ANCSA explicitly sought to undermine the sovereignty of tribes by making newly-created Native corporations the beneficiaries of land and financial resources. ANCSA, as Thomas R. Berger explained in his important book Village Journey (1985), did not give title to Indigenous people but rather "placed their land at risk" (p. 6 https://www.google.com/books/edition/Village_Journey/2nzYGwAACAAJ?hl=en) As indicated in another comment on this page, the authors of this report demonstrate little knowledge or concern about the diverse tribal governments and Indigenous peoples of Alaska; rather, they want to lump them together as a monolithic entity. Alaska Natives, in pages of this report, do not seem to care about subsistence practices, cultural traditions, and food sovereignty. These claims also overlook the long and significant history of alliances and coalitions forged between Indigenous peoples, environmentalists, and other groups, including around such high-profile environmental debates such as the Arctic National Wildlife Refuge.

This is a call to repeal the 1971 Wild Free Roaming Horses and Burros Act and subsequent acts that prevented the slaughter of horses. It also flies in the face of several court cases that have deemed slaughter policies illegal under these laws. See https://www.blm.gov/learn/blm-library/subject-guides/wild-horse-and-burro-subject-guide/policy-and-legal-resources#:~:text=The%20Public%20Rangelands%20Improvement%20Act%20of%201978%20(PRIA)%20amended%20the,and%20Management%20Act%20of%201976 It is important to note here that Pendley is veiling this agenda carefully, under the guise of reform and ecological considerations.

We cannot find this study. We did find one by rangeland ecologists in that year, which recommends a different kind of study to determine if ecologies with an overabundance of wild horses can recover and how long that recover would take. See https://doi.org/10.1093/biosci/biz060.

This is an exaggeration. Congress passed the 1971 bill on the heels of overwhelming public support. The massive letter-writing campaign by school children alone was astounding. See https://www.oupress.com/9780806149271/the-size-of-the-risk/

Pendley offers no citation or other evidence tor this sweeping claim how westerners felt about the relocation ["All of them...appreciated"]. If this were an undergraduate history paper, such a claim would get red-marked as both unsubstantiated and highly exaggerated. As pointed out earlier, the relocation was highly disruptive for employees. As of August 2024, the Grand Junction office had 24 employees.

https://www.gjsentinel.com/news/blm-continues-staffing-up-western-hq/article_ea8b8430-5052-11ef-812d-2be536fa4557.html

Tribal-federal relationships at Bears Ears were not built up with opportunities but manipulated an undermined. If past is prologue, this is an empty statement. https://www.pbs.org/newshour/politics/native-american-tribes-call-trumps-revamp-of-tribal-advisory-commission-a-slap-in-the-face

It isn't at all clear where Pendley gets the idea that Congress set aside the 1002 areas "specifically for future oil and gas exploration and development." ANILCA, codified in 16 USC Section 3142 a reads: "The purpose of this section is to provide for a comprehensive and continuing inventory and assessment of the fish and wildlife resources of the coastal plain of the Arctic National Wildlife Refuge; an analysis of the impacts of oil and gas exploration, development, and production, and to authorize exploratory activity within the coastal plain in a manner that avoids significant adverse effects on the fish and wildlife and other resources." There has been legitimate debate about whether or not oil and gas development is possible without negative impact on fish and wildlife.

The implication in much of the discussion about Alaska (including the case of the Arctic National Wildlife Refuge) is that the story is one pitting environmentalists versus oil and gas drilling proponents--a narrative frame that overlooks the long history of Indigenous leadership and advocacy in this fights. In the case of the Arctic National Wildlife Refuge, for example, the Gwich'in Nation completely reframed the narrative, turning a traditional wilderness campaign into a transnational fight for Indigenous rights and environmental justice. For a brief history of the Gwich'in role in the Arctic Refuge struggle, see https://www.washingtonpost.com/outlook/2021/03/14/indigenous-advocacy-transformed-fight-over-oil-drilling-arctic-refuge/

The Biden Administration restored unprecedented cuts to national monuments from the previous administration, most famously with Bears Ears in Utah which has begun a comanagement arrangement with local tribes.

The reduction under Trump, which the Biden administration reversed, may have exceeded presidential authority. Litigation ended after these monuments' restoration but will likely start up again should a new conservative administration heed Pendley's call.

https://www.sltrib.com/news/environment/2022/06/22/utah-tribes-secure-co/

https://crsreports.congress.gov/product/pdf/R/R45718

There are important political disagreements over the development of federal fossil fuels, and these deserve attention. The Trump administration's rhetoric and executive orders were aimed at increasing fossil fuel development; the Biden administration's rhetoric and executive orders were aimed at reducing fossil fuel development. But it is important to qualify this with two important points: 1) the rate of fossil fuel extraction is driven more by the market economy, with prices determined by global markets, than by federal policy, and 2) lower fossil fuel prices on these global markets will disincentivize its extraction in the US, and likely bring current record levels of US oil and gas production down.

Like the National Park Service (below), the Bureau of Indian Affairs receives almost no attention in this chapter. Indigenous peoples appear in this document only when they desire oil and gas production. But the BIA has been active under Secretary Haaland--the first Native American to hold this position--in addressing past and contemporary injustices. Her leadership for understanding Boarding School history, along with other episodes of missing and murdered Indigenous Peoples, is especially noteworthy. Neglect of all these issues and endeavors is one more way that Project 2025 has utterly expunged the challenges of environmental justice from its radar screen. The momentum generated by Haaland would likely not continue under an Interior administration that follows Project 2025. https://www.doi.gov/priorities/strengthening-indian-country https://prospect.org/environment/2024-09-26-preserving-public-lands/

A more grounded and explanatory way of referring to the DOI's "deploying of wolves" is this: "restoring endangered species according to requirements in the Endangered Species Act."

This is grossly misleading, as it suggests the turn toward environmental values came primarily from the executive branch. Certainly, the Carter administration advanced an environmental agenda, but the administration was implementing statutes passed with broad bipartisan support in Congress and signed by Republican presidents Nixon and Ford. https://www.unmpress.com/9780826352965/nixon-and-the-environment/

This statement is oblique and justified by a discursive footnote about Wyoming. Interior continues to operate in a bipartisan manner consistent with the laws enacted by Congress pursuant to the powers granted it by the Property Clause. https://scholarlycommons.law.emory.edu/cgi/viewcontent.cgi?article=1453&context=elj What Pendley disagrees with is the primacy of federal power on federal lands over the interests of state and private landowners. In western states with a preponderance of public lands, this primacy of federal power over federal land can conflict with state, county, and private land interests. However, it does not abrogate the power of the federal government to make decisions about its property. (See https://crsreports.congress.gov/product/pdf/R/R44267).

This statement from Pendley's book obfuscates the original purpose of Interior. According to Robert M. Utley and Barry Mackintosh in their administrative history of the agency in 1989 (for Interior's 150th anniversary), the federal government reorganized the departments mentioned to better serve the nation's internal affairs (as opposed to foreign affairs). Congress also meant for Interior to address the organization of the newly acquired cession from Mexico by the Treaty of Guadalupe Hidalgo. The bill creating Interior had bipartisan support. Over time, its mission evolved to where it now stands, providing stewardship of the nation’s land and related resources. (See https://npshistory.com/publications/doi/dept-everything-else.pdf)

Pendley has had a long career in government and conservative legal activism. He served in Interior in both the Reagan and Trump Administrations and has served as president of Mountain States Legal Foundation, a conservative law firm that has been on the forefront for decades in undermining public lands protected and administered by the Department of the Interior.

Pendley wrote a fawning biography of Reagan called Sagebrush Rebel for Regenery Publishing. Support for the Sagebrush Rebellion undermines many of the responsibilities Interior safeguards.

He was acting director of the Bureau of Land Management in 2019-20 and was never confirmed by the Senate. A federal judge removed him for serving unlawfully as nominated (but unconfirmed) "acting" director for longer than 210 days. Pendley refused to follow the ruling.

Pendley has dismissed science about ozone depletion and climate change and has joked about killing endangered species. He has also mocked Indigenous beliefs about sacred sites.

https://www.regnery.com/9781621571568/sagebrush-rebel/ https://www.nytimes.com/2020/09/26/us/william-perry-pendley-blm.html https://www.theguardian.com/environment/2020/oct/10/william-perry-pendley-bureau-of-land-management-refuses-to-leave https://www.cnn.com/2019/10/08/politics/william-perry-pendley-blm-kfile/index.html

Concern for congressional oversight is important, but it isn't clear why the executive is responsible for protecting that oversight. Congress has the constitutional authority to amend NEPA as it pleases.

That Pendley does not specifically name Bears Ears may be especially telling. A few lines above, he notes Tribal objections to a monument in Colorado. The Bears Ears Inter-Tribal Coalition remained steadfast behind the Bears Ears designation by Obama, felt excluded by the Zinke process Pendley references, and were angered by the reduction.

https://www.bearsearscoalition.org/timeline/

Since the Antiquities Act passed in 1906, only three presidents have not used it to create national monuments (Nixon, Reagan, and GHW Bush). It has been used widely.

None of this is required. It isn't clear that any of this is even permitted, much less envisioned. The quote and statistic come from an op-ed by a former Trump official and longtime radical Sagebrush Rebel. The numbers and claims seem to be invented; I can find no record of these figures in the EO or other press coverage related to it.

While the Project 2025 authors call for approval and implementation of the most aggressive and expansive version of the controversial project, it is important to emphasize that the Biden administration has approved this massive expansion of fossil fuel development in Alaska--despite the efforts of a broad coalition of environmentalists, Indigenous peoples, and others to stop the project. Opponents of this project include many Alaska Natives who live in Nuiqsut, the town closest to the proposed drilling sites, and a place already encircled by massive oil and gas operations that pose environmental and health risks to the community. Coverage of this topic has been fairly extensive; a a few examples include: Adam Federman in Grist, https://grist.org/energy/permafrost-thaw-conocophillips-willow-project-alpine-leak/; Finis Dunaway in Truthout, https://truthout.org/articles/big-oil-wants-to-refreeze-alaska-permafrost-so-it-can-keep-drilling-there/; and Lisa Friedman and Clifford Krauss in the New York Times, https://www.nytimes.com/2023/04/06/climate/willow-alaska-oil-biden.html

You wouldn't know it from reading these pages, but there are many in Alaska (including Indigenous communities, environmental allies, and others) who are calling for a Just Transition away from fossil fuels and for a state economy that is so exclusively reliant on unsustainable extraction. For one article about this, see Winona LaDuke in Truthout: https://truthout.org/articles/native-activists-are-forging-a-just-transition-to-renewable-energy/

There are 229 federally recognized tribes in Alaska. They share some interests but do not constitute a single community. It is a minor point, perhaps, but it suggests an othering that is a problem.

https://www.bia.gov/regional-office/alaska-region

This paragraph acknowledges the basic situation, but with exaggerated numbers. Wild horse and burro populations are actually greater than Pendley states because the population growth rate is closer to 20%. The amount of dollars spent on off-range corrals is less annually. Pendley also does not acknowledge what is working in the wild horses and burros program. See https://extension.colostate.edu/topic-areas/natural-resources/management-of-wild-horses-3-104/.

As acting director, Pendley stayed in DC.

Despite this cheery assessment, reporting indicates the move was disruptive, ineffective, and has been partly reversed.

One story explains: "But more than 87% of the affected employees either resigned or retired instead of moving to Colorado, The Washington Post reported. And it didn’t lead to the promised 27 to 40 jobs; only three BLM employees are currently based at the agency’s leased offices in Grand Junction, said Christian Reece, the executive director of Club 20, an organization that advocates for western Colorado interests."

https://www.denverpost.com/2021/09/17/bureau-of-land-management-colorado-dc-headquarters/

According to one source, "At the time of the move in 2019, the agency employed about 360 in Washington. Some 287 employees chose to retire or go work somewhere else, and that included more than half of the agency's Black employees. Another 41 employees relocated to other Western BLM offices.

Only three employees chose to move to Grand Junction."

https://www.coloradopolitics.com/news/blm-departs-grand-junction/article_e02e7910-5d0d-11ec-9acd-bf7eb917d6ed.html

State resource managers operate under different statutory requirements. A direct comparison to their management on state resource lands vs. federal lands is inappropriate and misleading.

It's worth noting that the Biden plans did not halt development on the petroleum reserve. Existing leases remain valid (https://www.blm.gov/sites/default/files/docs/2024-04/NPR-A%20Final%20Rule%20Factsheet_508.pdf), and developers have been able to bid on a total of 60 million acres between 1999 and 2019.

This has been a long-standing conservative critique of the Department of the Interior. When the Heritage Foundation prepared their report "Mandate for Leadership" for the Reagan administration and Interior's direction by James Watt, one claim they repeated was the federal government as a "monopolist of natural resources."

There are, in fact, broad swaths of this chapter that would comfortably fit in with "Mandate for Leadership," which likewise called for "maximiation of resources values," criticized supposed "zero leasing policies for coal and oil shale," and "rampant land withdrawals."

https://www.thenation.com/article/archive/the-conservative-promise/

Royalty rates is an important political issue. However, it is important note that the Federal Land Policy and Management Act directs the BLM to secure market value for federal resources, and the royalty rate of 12.5% is considerably lower than most state and private rates. https://www.gao.gov/assets/gao-17-540.pdf

It may be worth noting that Pendley did not write this section, according to the Author's Note at the end. The three authors include one who is part of an oil and gas industry group and another from a think tank that is skeptical of anthropogenic climate change.

https://www.hcn.org/articles/project-2025s-extreme-vision-for-the-west/

This is one of the only mentions of climate change in the entire document, aside from some of the planned rollbacks on Biden programs that are designed to address climate change.

The current Interior leadership's 2024-2027 plans: https://www.doi.gov/sites/default/files/documents/2024-07/doi-2024-climate-adaptation-report.pdf

This may be a minor point, but an error on such a basic figure raises questions about other figures in this chapter. The National Wildlife Refuge System is about 90 million acres of land and another 760 million acres of submerged marine acres. https://crsreports.congress.gov/product/pdf/R/R42346#:~:text=Today%20the%20federal%20government%20owns%20and%20manages%20roughly,of%20all%20federal%20land%20in%20the%20United%20States.

National parks are extremely popular and the public by wide bipartisan margins want them to be protected more, including for recovering endangered species.

This chapter virtually ignores the national parks and their role in a conservation future. This neglect is baffling. The parks cover more than 85 million acres visited by more than 325 million people annually. Yet this reflects the orientation toward Interior being not the protector of American lands but as the facilitator of their exploitation.

https://www.npca.org/articles/3610-new-poll-shows-united-support-for-national-park-wildlife

https://www.nps.gov/aboutus/visitation-numbers.htm

It is true that the Biden administration has emphasized climate mitigation and called for reduced fossil fuels. But the Biden administration has fully complied with federal law in OCS leasing and approving the Willow project. There is a more important issue here, namely the fact that the author regularly confuses legal and political decisions. Congressional statutes grant broad discretion to the BLM and Forest Service in determining the appropriate mix of uses on public lands. When the Biden administration uses that discretion to advance interests with which the author disagrees, it is not violating the law. https://eplanning.blm.gov/eplanning-ui/project/109410/510 https://crsreports.congress.gov/product/pdf/R/R44504

This is a small quibble, but the statute cited doesn't govern BLM lands. It governs Forest Service lands. There is another law that does govern BLM under multiple use terms. The error in citation indicates some sloppiness in this overall planning and should undermine all of its claims.

As repeatedly used here, "multiple use" is implied to be all about economic development, extractive and consumptive uses. But the actual statutory authority, FLPMA, cites other uses, such as recreation, watershed, wildlife and fish, natural scenery, and scientific and historic values. These are entirely or mostly ignored throughout this document, misrepresenting management directives.

https://www.govinfo.gov/content/pkg/STATUTE-90/pdf/STATUTE-90-Pg2743.pdf

Morale was low in agencies within Interior at the moment Pendley is claiming aid in accomplishing mission critical work. The Park Service is but one example. Never in the Trump administration was there a confirmed director of the agency. Pendley himself headed the Bureau of Land Management only as an "Acting" director. The haphazard, slipshod management spelled instability rather than what is described here.

(To be fair, morale remains low, but improving: https://peer.org/poor-national-park-service-morale-shows-scant-improvement/)

https://www.npca.org/articles/1878-how-zinke-is-undermining-national-park-service-employees

The Biden Administration issued nearly 50% more drilling permits during its first three years than did the Trump Administration during its first three years. The Department of Interior’s Bureau of Land Management granted 3,377 permits to drill on public land during Biden’s first three years, compared to only 2,507 permits during Trump’s first three years. https://subscriber.politicopro.com/article/2024/01/biden-administration-oil-drilling-permits-outpaces-trump-00138376?source=email

The citation for this is an opinion piece by the author. Without clearer definitions around energy dominance or energy independence, it is difficult to verify claims. However, by using only 2019, Pendley cuts short the story and is terribly misleading with regard to the current administration. (As indicated in the next comment. https://www.eia.gov/energyexplained/us-energy-facts/imports-and-exports.php

The chapter repeatedly appeals to the desires of "westerners" as if this is homogenous group. A quick review of voting maps shows that those living in the West are politically diverse, and many support environmental protection. https://www.nytimes.com/interactive/2021/upshot/2020-election-map.html

This is important history, as it reflects the nation's priorities in the early 20th century. But that history isn't normative. Congress has, over the last 125 years, developed a much broader set of priorities, informed by contemporary science and public values.

Also known as "NOAA Research," this office maintains NOAA's "Climate.gov" website, with such "alarmist" features as a "global climate dashboard" charting rising CO2 and other greenhouse gases, sea levels, and ocean heat, as well as declining sea ice and mountain glaciers. https://www.climate.gov/about.

The Trump administration let this portal go unfunded and at one point shut it down. The suppression of talk about climate change on this and other agency portals during these years, documented by EDGI, was far-reaching. Climate researchers had to alter webpages, for instance, by changing "climate change" to "climate," apparently taken as less politically charged. https://envirodatagov.org/wp-content/uploads/2019/07/New_Digital_Landscape_EDGI_July_2019.pdf

Trump's proposed funding cuts for this agency averaged a whopping 35.7% over the first three years. However, Congress pushed back hard, and actually authorized increases in it budget (8.5%) and staff (3.5%).<br /> https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Trump's average proposed budget cuts for his first three years for the Fish and Wildlife Service were slightly higher than those for NOAA itself--more than 18%. However, FWS fared much better in Congress, actually increasing its budget by 2% (adjusting for inflation). It nevertheless lost 5.8% of its staff. https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Trump tried to cut this service's budget by an average of 15.9% over his first years, but thanks to Congress its staff and budget barely budged. https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

For Project 2025, data supporting the reality of anthropogenic climate change appears biased by definition, since it takes sides in an imagined "climate debate" among scientists. This is a throwback to an earlier version of climate denialism. https://allianceforscience.org/blog/2024/01/new-analysis-exposes-shifts-in-climate-denial-tactics-on-youtube/

Trump's average proposed budget cuts for this service averaged a more modest 15% for his first three years. But through Congressional action, the inflation-adjusted budget fell over 40% and the staff over 10% during his time in office. https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Here's a belated recognition that the data used by commercial operations is indeed from the NWS. What it would mean for the NWS to also "fully commercialize its forecasting operations" is not at all clear.

A claim that seems to disregard how so much today's commercial services actually hinge on federal weather data. As AccuWeather chief executive Steven R. Smith put it: "NOAA’s 'foundational data' helps inform AccuWeather’s own forecasting software, artificial intelligence and meteorologists." Moreover, “it has never been our goal to take over the provision of all weather information.” https://www.washingtonpost.com/weather/2024/07/22/project-2025-weather-service-trump/

Here's the reason why NOAA receives such treatment: its contributions to the science of climate change. Another Project 2025 theme: future US prosperity depends on ignoring and not researching climate change, and certainly not seeking to prepare for or mitigate it.

While the roots of some NOAA functions date to the nineteenth century, it took on more modern form after the passage of the Marine Resources and Engineering Development Act in 1966. President Richard Nixon created the agency in 1970, the same year as the EPA. NOAA had the following goals: "to protect life and property from natural hazards, better understand the total environment, and explore and develop ways to use marine resources in a 'coordinated way' within the Department of Commerce." A recent report by the Congressional Research Service outlines the many efforts to legislate on this agency's work and structure.<br /> https://sgp.fas.org/crs/misc/R47636.pdf

The Trump Administration proposed cutting NOAA's budget an average of 17% in its four budget proposals. Because Congressional support for NOAA was less robust than that for other environmental agencies (including EPA), NOAA's actual budget slid over 14% between 2016-2019, the biggest actual funding cut of any environmental agency studied by EDGI over the Trump years. https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Gilman's proposals in the NOAA chapter are among the most hostile plans for any agency proposed by Project 2025.

Here, preparedness grants to the state, local, tribal, and territorial governments DON'T count as federalism. That's in stark contrast with the "New Federalism" proposed by Richard Nixon back in the early 1970s. For Nixon, federalism entailed "revenue sharing" of federal funds with the states, with the states granted more control over how the money was spent: “more money and less interference.” Here, federalism for relief efforts means that states, localities, tribes, etc. will no longer get any federal money. Their efforts will be entirely defunded. https://www.brookings.edu/articles/nixons-new-federalism-45-years-later/

If the NFIP had been wound down prior to Helene and Milton, the vast majority of those whose homes were damaged by these storms would have had means of receiving any compensation to cover the destruction. That's because only 25% of Floridians in storm-affected had purchased flood insurance and far fewer in hard-hit Western North Carolina. Moreover, the storms hitting Florida had come after Florida had passed reforms to attract private flood insurers back into its home insurance market. The struggles owners of these policies faced in getting companies to recognize their claims foreshadow what will happen if flood insurance markets turn completely private. https://www.nbcnews.com/business/consumer/hurricane-milton-helene-insurance-nightmares-torment-florida-residents-rcna175088

The Trump Administration deprived FEMA of funds by repeatedly taking its allocations for disaster relief and applying them to immigration and border policing. Funds transferred included nearly $10 million in 2018 and nearly $160 million in 2019. https://www.washingtonpost.com/news/morning-mix/wp/2018/09/12/document-shows-the-trump-administration-diverted-nearly-10-million-from-fema-to-ice-detention-program/ https://www.politifact.com/article/2019/oct/02/fema-money-reprogrammed-immigration-enforcement-wh/

Oversimplified. Since its establishment in 1968, the NFIP has indeed struggled to fulfill the roles envisioned by its architects and proponents, according to historian Scott Knowles. But waves of legislation have repeatedly sought reforms to incentivize and create other mechanisms for reducing risks from floods as well as discouraging development of flood prone areas. https://crsreports.congress.gov/product/pdf/R/R47646

According a recent history by the Congressional Research Service, the Stafford Act was passed in 1988 largely in response to an effort by the Reagan administration to reduce the federal funding share for many forms of disaster relief to just 50%, leaving states and localities to cover the rest. After a bipartisan outcry, Congress then acted to legislate a 75% federal/25% state and local rate for many of FEMA's programs. Most proposals here seek to reduce or eliminate federal support for disaster relief may face a similar fate to the Reagan Administration's effort. https://crsreports.congress.gov/product/pdf/R/R47646

In stark contrast to the approach recommended for immigration and the border, Cuccinelli suggests that FEMA pass more of its responsibilities off to the states and cities and to avoid disasters not considered sufficiently "large" and "widespread."

Cuccinelli's comment neglects another more recent cause of FEMA's dearth of funding: the Trump Administration. From its first proposed budget onward, Trump and his appointee sought to cut FEMA's and other funding for "long-term preparedness efforts, many of them put in place to address the sluggish federal response to Hurricane Katrina." https://www.washingtonpost.com/politics/as-agencies-respond-to-storm-some-face-cuts-under-trump-budget-proposal/2017/08/29/0fbbd6ca-8cc8-11e7-84c0-02cc069f2c37_story.html

This constitutes another move to erase climate change from the federal policy. This working group was established in 2009 to draw on the best available science to understand, define, and incorporate "the social benefits of reducing emissions of each of [the main]greenhouse gases, or the social costs of increasing such emissions, in the policy making process." Its calculations were then incorporated in agency cost-benefit analyses. Trump abolished the working group, which was restarted under Biden. https://www.whitehouse.gov/wp-content/uploads/2021/02/TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf

Consistent with Project 2025's other proposed erasures of climate change, the authors propose to continue this with the Oval Office. A Senior Advisor for "energy and environment" will replace an Office of Domestic Climate Policy.

The 2020 Trump-era rule revision for NEPA faced many questions about its constitutionality. Though court proceedings were cut short by the Biden revocation of that rule, these proposed measures may well be even more judicially vulnerable. https://www.theregreview.org/2020/08/24/glicksman-camacho-trump-administration-unconstitutional-power-grab/

This ruling from 1979 may prove judicially vulnerable in the wake of the Supreme Court's recent overturning of the Chevron decision, which had long grounded judicial doctrines of deference to agencies.

This 2020 rule revision to the National Environmental Policy Act (NEPA) rolled out early in 2020 and sought to curb the use of science in permitting federal or federally sponsored projects. They attempted to do so indirectly, by mandatory speed-up as well as circumscription of the environmental assessments that NEPA required. More directly, the Trump administration overturned guidance from the Obama administration that NEPA analyses consider effects on climate change. The new rule revision curbed consideration not just of climate change but of all other “effects” that are “remote in time, geographically remote, or the product of a lengthy causal chain” including "cumulative impact analysis"--long a required element of NEPA assessments. https://envirodatagov.org/an-embattled-landscape-federal-environmental-science-integrity-in-the-united-states-a-three-part-series-part-1-targeting-scientific-influence-on-policy/

Upon overturning this Trump-era rule, the Biden Administration also included environmental justice impacts among the "cumulative" assessments to take place under NEPA, a step which Project 2025 also seeks to reverse. https://www.insideenergyandenvironment.com/2024/05/ceq-final-nepa-regulations-and-department-of-energy-actions-aim-to-responsibly-accelerate-clean-energy-transmission-and-other-infrastructure-development/

When President Richard Nixon created the Council in 1970 and announced its first three members, he described CEQ to the press as "the environmental conscience of the nation." https://www.jstor.org/stable/27551558

In his and many subsequent administrations, Republican as well as Democratic, the CEQ played a central role coordinating environmental policy across the agencies. Trump's nomination of Mary Neumayr to head the CEQ came after the rest of his White House-based political appointees. Though she was at the time considered moderate politically, the Council's work under her leadership focused on circumscribing NEPA's requirements and scope under the guise of "streamlining." https://www.washingtonpost.com/news/energy-environment/wp/2018/06/13/trump-tries-a-more-middle-of-the-road-pick-for-top-white-house-environment-post/

This sweeping formulation simply ignores a major historical reason for the making of the administrative state from the late nineteenth century onward in the United States: the accumulation of private economic power. Once big corporations joined big property owners in dominating the economic landscape, THEY held sway over the lives of ordinary Americans. They could legally monopolize markets, pollute waterways, and contaminate consumer goods--until federal laws and agencies were created to control them. By beginning its historical backdrop in the 1970s, Project 2025's lead author ignores the history through which the modern admnistrative state was made. Even this phrase "administrative state" helps obscure these origins, through a repackaging of what scholars have long referred to as the "regulatory state." The terminological switch itself does significant ideological work, drawing attention away from what this state was actually created to do. https://academic.oup.com/edited-volume/34537/chapter-abstract/292976542?redirectedFrom=fulltext

Consequently, Project 2025's desired dismantlement of this state would have effects contrary to those of "self-governance." Instead, the loss of oversight would likely restore unchecked dominance of most Americans' lives by the privately rich and powerful. Moreover, as indicated by many further plans for the federal government in this document, the Project's version of conservativism, for all its self-declared anti-statism, also forsees unprecedented new arenas where it aims to exert state power.

Historians' more recent re-interpretations of the 70s, which have proliferated, are not reflected here. The 1970s were a "seminal decade for environmental protection" according to legal historian Richard Lazarus https://www.americanbar.org/groups/public_education/publications/insights-on-law-and-society/volume-19/insights-vol--19---issue-1/environmental-law---politics/, an interpretation affirmed by many other historians of environmental policy and environment such as Richard N. Andrews. https://yalebooks.yale.edu/book/9780300222913/managing-the-environment-managing-ourselves/ Thomas Borstelmann finds that feminism crested in the 1970s, becoming increasing woven into what he calls 'the ethics of daily life.' https://press.princeton.edu/books/paperback/9780691157917/the-1970s?srsltid=AfmBOoo0NVQ8J0JmEl2PZmaB3HGgDHBZ7m1Ql_6Nk2BMiHJybLBthzm5 Steven Tuck argues that the 1970s were 'the high-water mark of the black liberation movement." https://www-jstor-org.proxy.library.stonybrook.edu/stable/40543227 Historians Bruce Schulman and Julian E. Zelizer called the 1970s "the Big Bang" because of how the foundations came to be laid in this period for today's public debates. Central to this interpretation of the decade is the rise of a New Right that for Project 2025 authors, seems somehow extraneous to that era's "division and danger." https://www.hup.harvard.edu/books/9780674027589

Near-mystical sweeping assertions like this call to mind the "fairy tales" that the author accuses the "Washington Establishment" of telling later in this paragraph.

Environmental speaking, the original constitution included no reference to public lands including parks. The clear implication in this call to "dismantle the administrative state" back to its scope is that public lands of all sorts, our national parks as well as forests and monuments, will have to be commercialized, subcontracted, or sold off. The "human flourishing" nourished by visiting today's public lands will then only be available with those who have the money to buy them. While national park abolition occasional surfaced as a cause among leaders of the 1970s/80s neoconservative movement like Georgia Congressman and John Birch Society leader Larry McDonald (Chapter 7, https://ugapress.org/book/9780820344089/race-and-the-greening-of-atlanta/) it had waned by the early 2000s. Yet by 2016, an "anti-parks caucus" had consolidated among 20 Republicans in the US House of Representatives. https://www.americanprogress.org/article/the-rise-to-power-of-the-congressional-anti-parks-caucus/

Missing here is how, for instance in the Clean Air or Water Act, precisely this "vagueness" enables Congression legislation to articulate broad protections for American lives and livelihoods, for instance, against the threat of pollution. Also missing here is the necessary reliance of environmental and other agencies on scientific expertise, to determine the reality and certainty of health and environmental dangers. That is an expertise that most Congresspeople and judges can, at best, only pretend to have. If the last Trump Administration is any indication, the silence or constraining messages about science in conservative plans for the administrative state translate into aggressive efforts to shred federal scientfic workforces and funds when these conservatives do come to power. https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

What example does the author have of a country with a "high degree of economic freedom"? The author was quite specific about the failures of command economies. It is suggestive that he cannot provide a single example of an economy that works. The author might be interested to learn that Sweden is in fact one of the countries with the fewest regulations on economic activity, rating #9 among all nations according to the Heritage Foundation itself. https://www.heritage.org/index/pages/country-pages/sweden At the same time, according to the International Monetary Fund, "the 'Swedish model'—is marked by the use of big, centralized institutions and large-scale transfers, commonly provided on a universal basis (rather than being income related) with a view to reducing inequality, alleviating poverty, and insuring against social risks." https://www.elibrary.imf.org/display/book/9781589061583/ch001.xml

Abundant historical and economic literature now attributes the growth of America's middle class over the middle of the 20th century to the New Deal and other liberal policy-making that favored that growth.  Many scholars have also amassed abundant evidence connecting the middle-class struggles and pooling of wealth at the top since the 1970s to the  neoliberal, wealth-favoring policies that Heritage and other conservatives quie succesfully advocated for. https://scalar.usc.edu/works/growing-apart-a-political-history-of-american-inequality/index

This sentence establishes a demonstrably false equivalence between socialism and four other very different visions for government. It also insinuates ("whatever name it chooses") there is no meaningful difference between any of these "-isms", that socialists, for instance, might just as well refer to themselves as Communists, or Marxists, or progressives, or Fascists. This claim is not only false, it suggest a deep intellectual unseriousness, an unwillingness even to consider any of these political programs as historical realities. As historians know, the lumping together of many enemies into a monoliithic opponent is nothing new, reviving conservative narratives of subversion like that during Second Red Scare after World War II, highlighted in the anti-Constitutional activities of the House UnAmerican Affairs Committee.

The celebration of market freedom is still here, but now tucked within visions of all Americans achieving "happiness" by adhering to social and moral norms as well as "religious devotion and spirituality." Another instance in this document of "reshaping the past to change the present." http://www.jstor.org/stable/10.3998/mpub.11760539.7.

The document accuses environmentalism of "abandoning confidence in human resiliency and creativity." To the contrary, much actually existing environmentalism hopes for and demands human ingenuity, especially to craft and implement those manifold new solutions - not just governmenal but economic, technological and cultural - that together can mount an adequate, just, and empathic reponse to the ongoing and future realities of climate change.

Project 2025, in its insistence on not seeing climate change but instead simply preserving a fossil-fuel-only global economy, remains mired in the past. It fails to see recognize what's under its authors' noses, the current economic trends and positive shifts in energy productivity. For impacts of the shifts to clean energy, see https://www.the-big-green-machine.com/

Project 2025 relies here on an inconsistent and oddly contradictory argument. They accuse "the left" of "cheap grace," which they define as "publicly promoting one's own virtue without risking any personal inconvenience." Yet the "environmental extremism" being castigated here sounds like quite the opposite: involving a radical willingness to sacrifice one's own and others' "personal conveniences," even to the point of "standing human affairs on their head."

By contrast, there's also a favorable invocation here of "stewardwardship and conservation" as less extreme, presumably because not concerned about curbing "the fuels that run almost all." In later chapters, however, notably that on the Department of Interior, the ethics of "stewardship and conservation" are hard to find.

That this lead Project 2025 defines environmentali extremism sm as "anti-human" seems curiously consonant with asides depicting "the left" as not actually human, mere "beasts." Such framings leave little room or sympathy for how so many environmental policies actually center concern for all life on the planet, including human life. Conservative causes like the anti-vaccine movement and restricting women's health options, though, are fundamentally detrimental to human life.

No evidence is given for this statement, but environmentalists have long recognized that poor and communities of color suffer disproportionately from the burdens of pollution and environmental crises. https://exhibits.lib.unc.edu/exhibits/show/we-birthed/item/7444 https://nyupress.org/9781479861781/toxic-communities/ The very construction of white as "clean" and people of color as "dirty" has its roots in racism and constructions of types of work and living. https://nyupress.org/9781479826940/clean-and-white/

In addition, civil rights activists have for over a century dedicated their focus to improving environmental conditions. Black women worked to educate neighborhoods about germs and the dangers of flies and to clean up neighborhoods during the Progressive Era. In the 1968, black workers in Memphis, Tennessee organized a strike against poor working conditions for sanitation workers. In the late 1970s and early 1980s, a neighborhood in Houston, Texas organized against a pending sanitary landfill. Not long after, citizens in Warren County, North Carolina mobilized against construction of a landfill. https://upittpress.org/books/9780822958994/ https://www.rutgersuniversitypress.org/transforming-environmentalism/9780813546780/

Under Ronald Reagan, the GAO conducted a nationwide study which confirmed activists' complaints. The report, https://www.gao.gov/products/rced-83-168, found that of four landfills that accepted hazardous waste, 3 of them were located in majority African American communities. All four communities had at least a 26% poverty rate.

Attempts to alleviate environmental injustice have been taken under both Republican and Democratic administrations in the past. In 1990 under George H.W. Bush, the EPA created the Environmental Equity Workgroup, which he elevated to the Office of Environmental Equity. Under William Clinton, the office name was changed to the Office of Environmental Justice in 1994 and he also directed all federal agencies to work toward policies to alleviate the issue through executive order. https://www.archives.gov/files/federal-register/executive-orders/pdf/12898.pdf<br /> More recently, under Barack Obama, the EPA worked to make data about environmental justice more transparent through EJSCREEN.

This comment distorts Bonhoeffer's views and lacks context. Bonhoeffer formulated the notion of "cheap grace" in his 1937 The Cost of Disciplineship in Nazi Germany, in important part to criticize the complacency of German Christians who attempted to legitimizethe Nazi state. He opposed "cheap grace" to its "costly" counterpart, involving not just statements of Christian belief but actions in accordance with those beliefs. Elsewhere, Bonhoeffer also offered an acutely moral analysis of how Nazism worked that better suggests how his concepts might be applied today: "petty tyrants... destroy a nation at its core…They slip through your fingers when you want to grab them, for they are smooth and cowardly. They are like a contagious disease. When such a tyrant sucks the vital strength from his victim he simultaneously infects him with his spirit; and as soon as this tyrant's victim gets hold of the least bit of power himself, he takes revenge for what has happened to him. But this revenge--this is the horror—is not directed against the guilty, but against the innocent, defenseless victims." https://www.jstor.org/stable/23917808

This comment points out one of the foundational ironies of the document. Out of the list of 36 authors and editors for Project 2025, 4 have Ph.Ds (2 from Harvard); 1 has a medical degree; 20 have law degrees; and 13 masters degrees. The list of universities where they've been educated reads like a who's who of the world's most elite institutions - Oxford, the Sorbonne, MIT, Harvard, Yale, University of Virginia, George Washington, Columbia. They represent a highly educated, elite group. Yet here, Project 2025's lead author claims that people educated at such institutions lack the knowledge necessary for good governance.

In addition, the authors of Project 2025 comment on matters where they clearly lack expertise. The vast majority are either lawyers, economists, political scientists, or policy analysts. None are scientists, environmental or otherwise, unless you count Benjamin Carson, a medical doctor. The only one with an advanced degree in history is Dustin J. Carmack, who received a masters degrees from Tel Aviv University.

These comments signal a historically significant departure in the conservative agenda vis-a-vis corporations . In the neoconservative agenda from the 1970s-early 2010s, they and allied "hedge fund managers" were portrayed as iconic exemplars of market freedom, with former hedge fund manger Mitt Romney receiving the Republican nomination for president in 2012. Now the alleged corporate embrace of a "woke agenda" and dependence on "foreign investors" provide grounds for turning on them and "their sense of superiority." Instead, this new "populist" version of conservativism itself borrows from the rhetoric of the labor movement, seeking to align its cause with "workers who shower after work instead of before."

These conservatives' turn against the modern corporate world also proceeds along another front. Rather than seeing corporations as valid actors in their own right, the authors now present "woke" companies as duped or manipulated in some way by a shadowy "Left" to adopt "illegitimate" values. According to this line of critique, those running corporations lost the ability to make legitimate decisions.

To reduce funding for EPA's extramural research as well as for NGOs addressing environmental justice, the author proposes an initial halt and "review" of all bigger ongoing grants. Ironically, the author's solution to allegedly "radical" environmental research "driven by ideology" is to put a political appointee in charge of EPA research enterprises. Is that person really going to enable grant distribution to "those who are in most need and towards projects that will tangibly improve the environment"? Only if judgements about need and tangibility reflect demonstrably scientific realities more so that conservative ideological blinders that so often skew and slant the proposals in this chapter.

The author has argued that a conservative EPA will take its cues from the states, even turn leadership in pollution control over "to the states." The regional offices mentioned here are the agency's primary vehicle for engaging with the states. But this recommendation advocates greater headquarters control over these regional offices, which conflicts with the earlier-expressed desire to work more collaboratively with the states. The author's jarring swerve here toward calling for centralization stems from what is apparently a higher goal: stymying or eliminating any efforts toward environmental justice within the agency.

Once again, the author is framing environmental justice as a priority only of the Biden administration. Civil rights and environmental justice have been long-standing concerns at the EPA, beginning under Republican leadershipl, when President George Bush first established an Office of Environmental Equity in 1991.

See comment #70 above as well others on the Foreword section of the document.

The author's failure to offer specific examples of how the Biden administration has "broadened" the EPA's use of Title VI, or to specify "long-standing understandings of the legal limits of that authority" reflects the speciousness of this argument. In the 1970s and 1980s, the EPA  circumscribed its statutory obligations under the Civil Rights Act of 1964 and the Fair Housing Act of 1968. President Clinton's Executive Order 12898 of 1994 along with the creation of the Office of Environmental Justice within EPA (from an earlier Office of Environmental Equity established under Bush), were important efforts to bring the agency into compliance with federal law.

https://academic.oup.com/jah/article-abstract/111/1/71/7695574?redirectedFrom=fulltext

The Inflation Reduction Act invests $1.5 million to provide support for basic science research at the national laboratories.  https://www.energy.gov/science/articles/fact-sheet-inflation-reduction-act-supporting-future-doe-science#:~:text=As%20part%20of%20the%20Inflation,and%20national%20laboratory%20infrastructure%20projects.

Precautionary models, including assumptions of "low-dose linear nonthresholds," have been central to EPA risk assessments since risk assessment itself began at the agency in the late 1970s.  Doing away with them would radically alter the EPA's safety levels for all chemicals known or suspected to cause cancer, for endocrine disruptors, and alll substances otherwise well-established as having no safe level  of exposure, such as lead.  Rejection of such models, apparently because of the "opaque decisions" and "disportionate economic impacts" they are accused of causing, flies in the face of consensual statements of public health professionals like the article below, which hold that "hazard and risk assessments should not assume existence of a 'safe' or 'no-risk' level of chemical exposure in the diverse general population."    https://doi.org/10.1186/s12940-022-00930-3.

Precisely what the Trump administration sought to do, by trying to forbid those with EPA grants from serving as well as appointing more members who were corporate scientists-for-hire (working for regulated companies or corporate consulting firms), or also scientists working environmental agencies in Texas and other red states. https://www.npr.org/sections/thetwo-way/2018/02/14/583972957/top-epa-science-adviser-has-history-of-questioning-pollution-research https://www.eenews.net/articles/boards-add-industry-and-state-officials-drop-scientists/ https://envirodatagov.org/an-embattled-landscape-federal-environmental-science-integrity-in-the-united-states-a-three-part-series-part-1-targeting-scientific-influence-on-policy/

Scientific advisory committees play a crucial and cost-effective role in making available to the EPA the best in contemporary knowledge in environmental sciences and policy to inform agency decision-making. For what the Trump administration actually did to these, see charts 1-3 in https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Most all the criticisms tallied here come from conservative and industry-allied critics.  EPA's scientific programs were targeted by severe cuts during the Trump Administration, which through the intervention of Congress were limited to actual cuts of 14% to 35.6% between FY2016 and FY2019.  See among other charts #s 2, 4, 8-10 in  https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Only the second call that more--not fewer--resources need to be devoted to an EPA program.   But during the Trump administration, research into "chemical safety for sustainability" was reduced by 35.6% between FY2016 and FY2019, surpassing the cuts in all other EPA research programs. See esp. chart 9 in https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Recent studies of the health effects of pesticides are sobering. Researchers investigated what happened in several rural counties where White-Nose Syndrome caused a sharp decrease in the number of bats, who eat insects. Pesticide use on nearby farms went up by 30% -- and infant mortality in those same counties went up by almost 8%. Cost-benefit balancing must include the most recent research on costs as well as benefits of these powerful chemicals.  https://www.science.org/doi/10.1126/science.adg0344

Yet another plan that will further strip the agency of scientific capacity, going beyond what was done in the Trump years.https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Given this emphasis on "productivity" in OLEM, it is worth noting how the Trump administration, the first to introduce ELMS to the agency, actually did on the Superfund front.  Between December 2016 and December 2019, the EPA office in charge of Superfund had lost 14.5% of its staff.  https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/ In 2019, "the EPA cleaned up the fewest sites of any year before the 1980s, as site backlogs were reaching a 15 year high." https://apnews.com/article/c1d827364ac630d53848ac3ec489788d

This is a repeat of the Trump administration's unsuccessful effort to sharply limit the waters to which the Clean Water Act is applicable.  In 2019, the Trump administration proposed a rule that would have removed protections for 1 in 5 river miles and 50% of wetlands previously protected.  That rule was replaced by a new rule finalized in 2023 that restored many of the earlier protections, though a Supreme Court decision in Sackett vs. EPA that same year struck down a wider definition of protected waters.   https://www.americanprogress.org/article/debunking-trump-administrations-new-water-rule/ https://www.epa.gov/newsreleases/epa-and-army-finalize-rule-establishing-definition-wotus-and-restoring-fundamental https://www.supremecourt.gov/opinions/22pdf/21-454_4g15.pdf For context, see chapter 3 in https://www.hup.harvard.edu/books/9780674979970.

Political appointees to the EPA have been confined to leadership of the Administrator and program offices at the headquarters, along with regional office leadership.   Making political appointments to head these scientific wings of the agency could deepen a new administration's interventions into the agency's ongoing scientific work, going beyond the severe cuts and de-prioritization of agency science during the Trump administration.  https://envirodatagov.org/an-embattled-landscape-federal-environmental-science-integrity-in-the-united-states-a-three-part-series-part-1-targeting-scientific-influence-on-policy/ https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

The 2009 endangerment finding, completed by the Obama Administration EPA in response to a court order, gathered the abundant evidence available by 2011 to declare that the EPA could regulate greenhouse gas emissions as threats to public health and welfare under the Clean Air Act. https://www.apeoplesepa.org/home/climate Ever since, it has been a dream of many in the conservative movement to reverse this finding, thereby pulling the legal rug out from any regulation of greenhouse emissions.  While some  in the Trump Administration resisted such a move, including this chapter's author, others did undertake a last minute unsuccessful move to try and overturn it.  It appears that Project 2025 authors would now like to take another crack at the finding, at least to "update" it.  https://www.eenews.net/articles/inside-the-trump-epas-final-moves-on-climate/

Current EPA reporting requirements for greenhouse emissions only apply to about 8,000 facilities in the US. While these cover about 85-90% of U.S. greenhouse emissions, most genuinely small businesses are already exempted from having to report these. https://www.epa.gov/ghgreporting US firms' reportage of greenhouse emissions has been falling behind that of "global peers" according to MSCI Sustainbility Institute https://www.msci-institute.com/insights/us-firms-fall-further-behind-global-peers-on-climate-disclosure/

Members of Congress cannot be expected to have the requisite expertise, as Congress itself acknowledged through its broad framing of the Clean Air Act. Highlighting "the growth in the amount and complexity of air pollution," calling for "a national research and development program to achieve the prevention and control of air pollution," it generally authorized the Executive Branch "to protect and enhance the quality of the Nation's air resources so as to promote the public health and welfare and the productive capacity of its population." Nowhere does the Act suggest an expectation that the authorized agency come back to Congress for the standard-settting needed to accomplish such a goal. https://www.govinfo.gov/content/pkg/USCODE-2013-title42/html/USCODE-2013-title42-chap85-subchapI-partA-sec7401.htm

Here and elsewhere, this author evinces a special animus against the many programs set up by the Biden EPA to fund and otherwise support community-based organizations addressing the pollution and other environmental impacts facing disadvantaged communities, under the Justice40 initiative led by the Biden White House https://www.epa.gov/environmentaljustice/justice40-epa

Best Available Control Technology, a higher standard than "reasonably available" should remain the standard to protect public health. For more on when each standard is currently applied, see https://www.epa.gov/clean-air-act-overview/setting-emissions-standards-based-technology-performance

Currently, “co-benefits” — benefits from a regulation that are ancillary to its intended purpose — must be considered alongside direct benefits for there to be an accurate cost-benefit analysis. For instance, when the EPA adopted its mercury rule to limit toxic mercury emissions from coal- and oil-fired power plants, the agency rightly included the co-benefits from reductions in fine particulate matter that would result from the installation of pollution control equipment used to reduce mercury emissions. Legalistically excluding the co-benefits of a rule, on the other hand, would make it harder for EPA to justify that rule, and stymie its ability to move against the multiple public health threats faced by many communities. https://www.americanprogress.org/article/reckoning-conservatives-bad-faith-cost-benefit-analysis/#:~:text=The%20demise%20of%20regulatory%20cost,conflicts%20with%20their%20deregulatory%20goals.

On the actual state of the scientific study of climate change at the time of the passage of the Clean Air Act, suggesting greehouse emissions were relevant to original ntent of the act, see https://www.ecologylawquarterly.org/print/climate-change-and-the-clean-air-act-of-1970-part-i-the-scientific-basis/ From the abstract: "In Massachusetts v. EPA, the Supreme Court held that the 1970 Clean Air Act granted the Environmental Protection Agency (EPA) the authority to regulate greenhouse gases as air pollution. But, while the Court found the Act to 'confer the flexibility necessary” to respond to “changing circumstances,' the Justices expressed skepticism that legislators in 1970 would have been familiar with the climate-altering effects of CO2 and other heat-trapping gases. At the time of the Clean Air Act’s passage, the Court wrote, 'the study of climate change was in its infancy.' That statement was misleading. By the late 1960s, scientists knew that greenhouse gases, derived from fossil fuel combustion, could alter the global climate with potentially serious and deleterious ensuing effects."

Auguring a more sophisticated effort to accomplish more of what a first Trump administration tried to do but was partly stymied by Congress: greatly reduce EPA budgets and staff. See charts 8 and 11-15 here: https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Auguring a more sophisticated effort to accomplish more of what a first Trump administration tried to do but was partly stymied by Congress: greatly reduce EPA budgets and staff.  For documentation, see for instance charts 4, 6, 9, 11 here: https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Targeting the several grant programs set up during the Biden administration to funnel more funding support to organizations representing "environmental justice" communities. For instance, https://www.epa.gov/environmentaljustice/environmental-justice-thriving-communities-grantmaking-program

Here, "diversity of scientific viewpoints," a rhetoric honed by Trump-appointed EPA political leadership, codes for diminishing the voice of academic scientists on these boards.  The previous Trump adminstration sought to undermine these boards by barring membership for academics with EPA grants, while expanding their membership share of corporate or consultancy (science-for-hire) experts.  See charts 1-3 here: https://envirodatagov.org/an-embattled-landscape-federal-environmental-science-integrity-in-the-united-states-a-three-part-series-part-1-targeting-scientific-influence-on-policy/

The Trump Administration targeted the Office of Children's Health, set up to better ensure environmental protection of children, are more vulnerable to many environmental threats such as lead and other toxics.  Undermining the OCH's leadership, the Trump EPA reduced staff by 40%.  This proposal to remove it from the overarching Administrator's Office and split it across or move it into one of the "media offices" is likely to reduce its influence still further.  https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8713602/#:~:text=The%20EPA%20established%20the%20Office,science%2C%20programs%2C%20and%20policy.

The first Environmental Education Act, passed in 1970, was a bi-partisan effort. Public school education on environmental issues has proven effective in helping children both understand environmental crises as well as develop a sense of agency towards solving them.

The Trump Administration sought to curb environmental education efforts by the agency,  from this office to its websites to the information it provided for public comments on its proposed rule changes.  Most audaciously, it sought to scrub mentions or discussions of climate change from its websites. https://envirodatagov.org/publication/the-new-digital-landscape-how-the-trump-administration-has-undermined-federal-web-infrastructures-for-climate-information/

Proposal is nearly identical to what  Anne Gorsuch did to EPA enforcement during the first two years of the Reagan Administration, as part of a far-reaching assault against the EPA's basic mission.  She and others in that administration also proposed cutting the agency's budget by one-third; though public outcry by 1983 drove her out of office and led the Reagan White House toward a more supportive approach.  Whereas the Trump administration was able to "achieve" a historic drop in EPA enforcement efforts without resorting to this measure, apparently a second Trump administration may draw from the early Reagan playbook.   https://pubmed.ncbi.nlm.nih.gov/29698097/ On the Trump admnistration's successes in cutting agency enforcement work without this measure, see https://envirodatagov.org/publication/a-sheep-in-the-closet-the-erosion-of-enforcement-at-the-epa/

Pollution and hazardous wastes have disproportionate negative health consequences in communities of color, on Tribal lands, and in low-income neighborhoods around the nation, from Flint, Michigan, to the Louisiana Gulf Coast. Beneficial environmental amenities, such as parks, green spaces, and recreation areas, which promote human health, are also unevenly distributed. In response to these documented disparities, the Office of Environmental Justice and External Civil Rights (OEJECR), which Project 2025 seeks to eliminate, was first established in 1992 as the Office of Environmental Equity by Republican President George H.W. Bush. The OEJECR now anchors the EPA’s efforts to remedy these longstanding inequalities. The OEJECR works to ensure that everyone has “equitable access to a healthy, sustainable, and resilient environment” and to protect people from adverse human health and environmental burdens, including those attributable to climate change, cumulative exposures, and “the legacy of racism or other structural or systemic barriers.” https://www.epa.gov/aboutepa/about-office-environmental-justice-and-external-civil-rights Since environmental racism was identified as a serious national problem in the 1980s, progress has been halting, but the OEJECR represents a significant commitment to address environmental inequalities. Politicizing federal agencies by reorganizing departments and by replacing experienced civil service experts with political appointees stands out as a key element of the Project 2025 plan. Eliminating the OEJECR would reduce environmental protections for all. For a history of this office and its fate during the Trump Administration, see https://www.liebertpub.com/doi/abs/10.1089/env.2021.0012

Already, all peer-reviewed findings can receive scrutiny and comment in the public record.  What this rhetoric of "transparency" targets for exclusion are studies of people who are actually exposed to environmental chemicals, which often draw on medical records whose privacy would be compromised by this "transparency." See comment and links at annotation #2 above of this chapter.

The EPA has long had a compliance program, as it should, but as many studies of EPA enforcement have shown, a lack of strong enforcement will lead to more violations that put public health and the environment at risk. https://www.journals.uchicago.edu/doi/abs/10.1093/reep/req017 https://envirodatagov.org/publication/a-sheep-in-the-closet-the-erosion-of-enforcement-at-the-epa/

Ordinarily "tangible" would be taken as meaning, among other things, scientifically demonstrable. Yet the aversion here to acknowledging the science of how intensifying storms or droughts have been worsening through climate change suggests otherwise. Instead, "tangible" seems to refer only to those problems that authors of this report and their allies--none of them scientists themselves--are willing to acknowledge as perceptible and real, without necessarily listening to what any scientists say.

States lack the budgets, enforcement authority, and breadth of expertise that the federal agency can provide.

They can also be susceptible to regulatory capture--a major reason why the state-based patchwork of pollution controls prior to the EPA was widely considered to have failed. For just one instance, see this analysis of the mining/smelting industry in Idaho. https://upittpress.org/books/9780822964483/

Rescusitates this slogan from Scott Pruitt, Trump's first appointee as EPA administrator. Before resigning under a cloud of multiple scandals, he claimed his vision for the agency to harken back to an earlier EPA, when its agenda was more "basic" and its relationships with states more harmonious. For a critical look by an actual historian at what Pruitt's vision missed, see this piece by Leif Fredrickson: https://www.washingtonpost.com/news/made-by-history/wp/2017/07/14/scott-pruitt-is-wrong-about-the-origins-of-the-epa/

False; the EPA's workforce size and budget trends do not support this claim. Employment at the EPA, which actually peaked in 1999, shrank during the Obama administration. https://federalnewsnetwork.com/unions/2023/02/epa-employees-voice-concerns-about-low-pay-understaffing-burnout/ Also see charts 4 and 11 here which actually show slow declines in EPA's budget and staff over the Obama years: https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

Project 2025’s goal of devolving environmental regulation to the states would undermine longstanding federal policies that enjoy bipartisan support and have proved remarkably effective in improving public health. For example, the 1987 Montreal Protocol on Substances that Deplete the Ozone Layer, negotiated and signed during the Reagan administration, required participating countries to curb the release of chlorofluorocarbons (CFCs) that were damaging the ozone layer. Rules implementing global treaties are of necessity federal regulations. The international agreement, signed by all of the world’s countries, worked because signatories agreed to reduce their output of CFCs by one-half within ten years. As a result, worldwide use of CFCs dropped by 80 percent in the first eight years. Thirty years later, the ozone hole was the smallest recorded. https://www.unep.org/news-and-stories/story/thirty-years-what-montreal-protocol-doing-protect-ozone The result: improvements in public health due to reductions in UV radiation, which can cause skin cancer and eye damage. https://www.epa.gov/sites/default/files/2015-07/documents/achievements_in_stratospheric_ozone_protection.pdf<br /> September 16, 2024, marks the International Day for the Preservation of the Ozone Layer.

A critical aspect of the origins of the EPA is not stated here: States and localities had anti-pollution laws in place prior to the EPA's creation, but those laws were either inadequate or weakly enforced. Anti-pollution laws also existed at the federal level, but these were primarily designed to fund and otherwise assist states and localities. This system, however, failed to protect public health and the environment. The EPA, and the much stronger federal laws that were created in conjunction with it, constituted a historic response to these regulatory as well as market failues. A Republican President, with bipartian support from Congress, created a national agency and laws that could control pollution far more effectively than the preexisting system. States had a role, and would be given more authority if they proved they would effectively implement environmental laws. This document argues for a return to "state leadership," precisely what by 1970s was widely agreed to have poorly controlled the nation's pollution problems. https://ajph.aphapublications.org/doi/full/10.2105/AJPH.2018.304396

"...perceived threat...": another side-step from the scientific consensus about threats from climate change.

The EPA's failures in Flint are exactly the failures that Project 2025's state devolutionary approach would compound. The Grist article cited here by this Project 2025 author explains the EPA's failure differently from what is here implied, in the following way:

"The [Office of Inspector General] report cites five possible oversight actions that the EPA could have taken under the Safe Drinking Water Act, including alerting Flint residents about possible harms and acting in the place of state authorities when there is 'substantial endangerment' to human health." https://grist.org/article/the-epa-failed-flint-now-we-know-exactly-how/

But in almost every case, officials deferred to their state counterparts, rather than using their legal authority to step in. As the report’s authors note, such oversight tools — like most tools out there — are “only effective when used.”

Additionally, the Flint water crisis was the consequence of decades of deliberate underfunding of Detroit's water system. During the Nixon and Ford administrations, the EPA failed to allocate sufficient funds, through its Municipal Wastewater Construction Grants Program, to the Detroit Water and Sewer Department. This refusal worsened a municipal debt spiral that would eventually contribute to the Flint water crisis. Moreover, the EPA failed to adequately ensure DWSD's compliance with agreed-upon treatment standards and deadlines. For more on Detroit and the EPA's Construction Grants Program, see:

https://uncpress.org/book/9781469665764/toxic-debt/

https://academic.oup.com/jah/article-abstract/111/1/71/7695574?redirectedFrom=fulltext

Across both liberal and conservative administrations, there have been tensions between Congress and the Executive Branch over the EPA. But the most notorious case happened during the conservative administration of Ronald Reagan, when a bi-partisan Congress held Reagan's appointees accountable for their malfeasance and attempts to undermine the mission of the agency. As a result, Reagan was forced to re-install the original EPA administrator, William Ruckelshaus, to revive the agency's legitimacy and fend off a growing backlash from Congress and the public. In 2017, Ruckelshaus (a Republican) criticized the Trump administration for again undermining the basic mission of the EPA. https://www.nytimes.com/2017/03/07/opinion/a-lesson-trump-and-the-epa-should-heed.html; https://ajph.aphapublications.org/doi/full/10.2105/AJPH.2018.304396

Needing context: EPA staff levels actually peaked in 1999. Despite declining budgets and staff over the Obama years, largely driven by conservatives in Congress rather than the Obama White House, the Trump administration (of which this author was a part) repeatedly proposed draconian budget cuts for the agency, as much as 32%. Though Congress restored much of this money, both the agency's budget and staff declined significantly over the Trump years. https://www.apeoplesepa.org/home/origins https://envirodatagov.org/embattled-landscape-series-part-2b-the-declining-capacity-of-federal-environmental-science/

The argument that EPA has been coopted by the Left is a long-standing canard of the Republican party. In reality, Republican presidents have been the leaders in appointing partisan operatives to head and staff the agency, especially in more recent times. While Reagan appointed Anne Gorsuch early in his presidency, the public outcry against her actions, led the Reagan White House to reverse course after two years. And from the return of William Ruckelshaus, the well-respected first leader of the agency, in 1983 through the appointment of former New Jersey Governor Christine Whitman by George W. Bush in 2001, Republican presidents did appoint EPA administrators who were committed the agency's basic mission. But the Republican Party turned more aggressively anti-environmental stances by the 2010s lead to Republican appointees during the Trump administration who actively opposed and sought to undermine much of this agency's mission and ongoing work. https://pubmed.ncbi.nlm.nih.gov/29698097/

"Open-source" science is code language for conservative efforts to undermine the work of scientists and the role of science in the regulatory process. It is the most recent variation on calls for "sound science," which was a talking point for EPA Administrator Scott Pruitt at the start of the Trump administration. Calls for "open source" or "sound science" seek to limit the kinds of scientific research that can be used in regulatory decisionmaking. In particular, they seek to eliminate any studies that draw upon sensitive healthcare records. https://fivethirtyeight.com/features/the-easiest-way-to-dismiss-good-science-demand-sound-science/

This "open-source science" agenda would exclude from regulatory considerations practically all the burgeoning science done over the past two decades centering on actual people who are exposed to toxic pollutants, including what are considered by scientists to be the best and most conclusive studies in epidemiology. That's because all these studies involve confidential medical records the laws like HIPA make impossible to fully release to the public without violating patients' privacy. https://nyuelj.org/2021/06/transparency-in-regulatory-science-for-whom/