Dave Banks, a former Trump climate adviser, said the document would serve more as a wishlist for past and future officials than a reflection of the president’s own priorities.
“I think the big question is, are the people who wrote it going to be back in?” he said. “And I think there’s a strong likelihood that a lot of the folks who worked on Project 2025 will end up in a Trump 2.0, if that happens.”
Mandy Gunasekara, the Trump EPA chief of staff who penned the project’s chapter on EPA, left open the possibility that she might return to the William Jefferson Clinton Building that serves as the agency’s headquarters.
“That’s a question for the president to ask, and an answer for me to give with my husband and family,” she said. “And we’re not there yet.”
Most of the regulatory policies included in her 28-page chapter seem cut from the same cloth as those EPA attempted in the first Trump administration. They were rescinded under President Joe Biden or overturned in court.
But some are new, like a proposal to shrink the pool of industries required to report their greenhouse gas emissions each year to EPA.
Just the fact that the policies are being explored in a widely circulated document marks a departure from 2016. The Trump EPA transition team that formed after his surprise victory eight years ago was famously long on infighting and short on planning. Political appointees were slow to arrive and key components of Trump’s deregulatory agenda were thrown out in court.
Project 2025 would revive some of those rules. For example, the EPA chapter advises the agency to “make public and take comment on all scientific studies and analyses that support regulatory decision-making.” That dovetails with a Trump-era “secret science” rule that was vacated in 2021.
Gunasekara said an incoming EPA team could avoid similar outcomes by “applying lessons learned” from the first Trump term.
“It’s very different regulating from the inside versus applying oversight from the outside,” said Gunasekara, one of several Trump EPA officials who came to EPA from congressional committees. Gunasekara was a staffer on the Senate Environment and Public Works Committee under the late Sen. James Inhofe (R-Okla.), as was Trump’s second EPA Administrator, Andrew Wheeler.
Gunasekara blamed first term policy failures in part on resistance from career staff — something Project 2025 would take pains to root out through extensive structural and workforce changes. She also acknowledged that the Trump administration sometimes cut corners — something she said wouldn’t be repeated.
“The biggest difference is we have a plan from Day One, we’re going to start implementing it, and we won’t be as susceptible to process problems that really sunk a couple of those final regulatory proposals and actions we took at the tail end of the administration,” said Gunasekara, who spoke by phone with POLITICO’s E&E News as she attended the Republican National Convention in Milwaukee.
Gunasekara said four Trump-era political appointees helped write the chapter: David Harlow, Scott Mason IV, Justin Schwab and Clint Woods. Schwab declined to comment, and the others did not respond to requests for interviews.
The bulk of the chapter is devoted to reshaping EPA — “an agency that has long been amenable to being coopted by the Left for political ends” — into an entity suited to carry out a “conservative vision.”
The sections devoted to regulation ricochet between improbable suggestions and superspecific head-scratchers.
“It does have this kind of spaghetti-against-the-wall approach,” said James Goodwin, policy director at the Center for Progressive Reform. “Literally everything and the kitchen sink is in there.”
For example, the chapter proposes that EPA “update” the 2009 finding that greenhouse gases endanger public health and the environment. That’s the bedrock finding behind all Clean Air Act climate regulations, and has been targeted by some of the conservative groups behind Project 2025 — such as the Heartland Institute — since the finding’s inception.
But reversing it would be a legally tricky — and potentially more complicated after last month’s Supreme Court decision curtailing agency authority.
The Trump administration’s own EPA lawyers rejected a petition by a conservative think tank to reconsider the endangerment finding. They noted in emails obtained by E&E News that it remained consistent with scientific assessments by federal research bodies.
“If they were to revisit the endangerment finding based on the latest science, it is only more dire,” said Rachel Cleetus, climate policy director at the Union of Concerned Scientists.
“If anything, the 2009 endangerment finding is softballing the kind of impacts that are now already clear around us,” she said, referring to the effects of climate change.
But the chapter also provides a menu of wonky-sounding proposals that could narrow the scope of regulations, including for climate pollutants.
“This goes beyond many of the things that they did in the first Trump administration,” said Stan Meiburg, a former EPA acting deputy administrator. “It certainly is a very ambitious document, and incorporates ideas that go all the way back to the Reagan administration.”
If movie script writers created a villain that proposed to do what P2025 is describing, I would probably have rolled my eyes at such a ridiculous character.