One thing I think is important to note is that once again we see that those pushing against climate action are not just aligned with those attacking trans rights, racial justice, labor rights and reproductive rights, but are in the same organizations, being funded by the same universe of backers. (above, click to enlarge)
The complete Project 2025 manifesto is 900 pages (?!!), which might explain why it sometimes feels like we’re hearing about this thing all the time yet don’t know much about it. I haven’t quite finished it yet, but I have managed to get to page 500, including Chapter 13, in which the plan for the Environmental Protection Agency is laid out.
The first thing I noticed is the chapter’s author: Mandy Gunesakara. Today, Gunesakara is a visiting fellow in the Heritage Foundation’s Center for Energy, Climate, and Environment and senior policy analyst for the Independent Women’s Forum, a conservative women’s organization funded by the Bradley Foundation, Sarah Scaife Foundation, and the Koch-backed donor-advised fund Donors Trust.
A lawyer by training, Gunesekara has previously been a member of the CO2 Coalition (you might recognize her as the Republican witness during Rep Jamie Raskin’s 2019 Subcommittee on Civil Rights and Civil Liberties’ hearing on “The Oil Industry’s Efforts to Suppress the Truth about Climate Change”), worked for Trump’s EPA (first as principal deputy assistant administrator at the EPA’s Office of Air and Radiation and then as chief of staff to EPA Administrator Andrew Wheeler), where she claims to have been “the chief architect of the Paris Accord withdrawal and the repeal of the Clean Power Plan”, and was famously the Senator James Inhofe staffer who handed him a snowball during a 2015 hearing in which he claimed the existence of snow meant global warming wasn’t a problem. She was Majority Counsel for Inhofe, and led committee actions and policy development on Clean Air Act and climate change issues.
It would not be remotely surprising to see Gunasekara tapped as EPA chief in a Trump administration. Following is a rundown of her key proposals. It’s a long read, but not 32-pages long, so…you’re welcome?
First, the broad strokes. A Trump EPA would:
- Cut any program focused on climate (including climate czars);
- Limit the agency’s ability to regulate under both the Clean Air Act and Clean Water Act;
- “Pause for review” (aka cut) anything that references “environmental justice” (because “reverse racism”) and eliminate the stand-alone Office of Environmental Justice and External Civil Rights;
- Push through the “Secret Science” proposal that didn’t quite make it last time around, which specifically targets the long-term epidemiological studies that linked air pollution to shorter lives and were used to justify air-quality regulations;
- Politicize the agency, giving all authority to political appointees over scientists;
- Shrink and de-fund the agency;
- Cut EPA funding of university research
- Move away from anything supporting energy transition
- Move away from regulating pesticides and agrichemcials
Climate and Air Pollution Go Hand in Hand
I’ve written before about Steve Milloy, the tobacco and coal lobbyist, and his longtime war on air pollution regulations. This proposal has his fingerprints all over it. Which makes sense for a few reasons: First, Gunasekara has no scientific background whatsoever, so she’d need someone like Milloy to outline a plan like this. Milloy got a BA in natural sciences and then a masters in biostastics from Johns Hopkins University. Although he’s never actually worked as a scientist, those qualifications still make him uniquely science-y in the climate denier-sphere. Milloy went to Georgetown law school after Johns Hopkins, had a brief stint at the Securities Exchange Commission and then got a job with infamous industry lobbyist Jim Tozzi after he “ran into” him one day. “He had an unusual lobbying practice where he lobbied regulatory agencies, so he hired me to work on risk issues because of my background in biostatistics and law,” Milloy told me.
Gunasekara and Milloy have both been visiting fellows at the Heritage Foundation, and Milloy was on the Trump EPA transition team when Gunasekara was an early appointee for the agency. “I was the only person on the team with a background in EPA science, so I was brought on to write the science part of the transition plan,” Milloy told me in 2020.
That “background in EPA science” came during the 90s, when Milloy was between stints as the science policy director for the National Environmental Policy Institute, a lobbying group funded by Occidental Petroleum and a handful of other oil companies that aimed to roll back EPA Superfund rules, and working as the director of the The Advancement of Sound Science Coalition (TASSC), an organization Tozzi worked with PR firm APCO to create for Philip Morris that aimed to poke holes in the science linking smoking, and particularly secondhand smoke, to cancer.
In between those gigs, “I got a big contract from DOE to study whether EPA science was based on science or politics,” Milloy said. That was the DOE’s Regulatory Impact Project, Inc., which had hired Milloy to work on other studies, too. “I got the contract under Bush and finished under Clinton, and when the report was done and I sent it up the line to DOE, which was now all Clinton appointees. They said I couldn’t publish it, because I said regulations were based on politics and not science. So, I decided to cut my contract and publish it on my own. It got picked up in the Wall Street Journal and that’s what sort of launched me into whatever I am today.”
He’s never stopped trying to reshape the EPA the way he initially recommended in that report, back in the mid-1990s. And he’s never stopped fighting air pollution regulations either, or warning conservatives and fossil fuel executives that regulating air pollution “is the most important backdoor science scheme for regulating fossil fuel emissions,” as he put it to me. Both of these crusades factor heavily into Gunasekara’s Project 2025 EPA chapter.
In it, she proposes that the EPA embrace “true transparency” and “open-source science,” clear nods to Milloy’s “secret science” proposals for anyone who’s ever read them. To accomplish this, Gunasekara says the EPA must:
- “Shift responsibility for evaluating misconduct away from its Office of Scientific Integrity, which has been overseen by environmental activists, and toward an independent body.”
- “Work (including with Congress) to provide incentives similar to those under the False Claims Act for the public to identify scientific flaws and research misconduct, thereby saving taxpayers from having to bear the costs involved in expending unnecessary resources.”
- Avoid proprietary, black box models for key regulations. Nearly all major EPA regulations are based on nontransparent models for which the public lacks access or for which significant costs prevent the public from understanding agency analysis.
She goes after air pollution regulations from multiple angles too (all while proclaiming that a “conservative EPA” will provide cleaner air, water and soil, mind you), proposing reforms for the Office of Air and Radiation—where she once worked, during the Trump administration—as well as changes to National Ambient Air Quality Standards (NAAQS) and the Clean Air Scientific Advisory Committee that helps to set them, and proposing limits to the application of the Clean Air Act.
I’ll just go with the tl;dr that says every single component of Project 2025 is bad.