There’s a playbook for how a second Trump administration could pull back climate regulations.
The EPA chapter of the much-vaunted Project 2025 blueprint is stocked with ideas for how political appointees could use a second Trump term to remake agency org charts, defang enforcement and disperse Washington-based staff to regional offices. But the document — spearheaded by the conservative Heritage Foundation — also catalogs tactics for relaxing regulation in ways that might reverberate beyond the next four years.
Former President Donald Trump has distanced himself from the initiative — a sprawling guide on how executive branch authorities and agencies could serve a conservative agenda. But many of its authors served in the first Trump administration and are likely candidates for a second one.
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 They were rescinded under President Joe Biden or overturned in court.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.”
Maximizing cost, minimizing benefits
Many of the regulatory proposals target EPA practices around cost-benefit analysis. There’s a reason for that: It’s generally harder for an agency to justify standards if their costs exceed their benefits.
Meiburg said the Reagan-era move to embrace cost-benefit analysis gave cost considerations the upper hand.
“Costs are specific and tend to be more quantifiable, and benefits tend to be more diffuse and less quantifiable, even though, in aggregate, they are larger,” said Meiburg.
Project 2025 proposes that EPA issue a rule to ensure “consistent and transparent consideration of costs.” Gunasekara said this would likely be a “very similar rule” to one introduced by the first Trump EPA, which was later voided by the Biden administration.
The rule promulgated under Wheeler was the first of its kind, and some experts say it could face longer odds now, when courts defer less to agencies on policy.
The EPA chapter also instructs the agency to “use appropriate discount rates, focus on the benefits of reducing the pollutant targeted by Congress, identify ‘co-benefits’ separately, and acknowledge the uncertainties involved in quantifying benefits.”
Discount rates are applied to future benefits that come at a present cost — such as avoided climate risk stemming from near-term emissions reductions.
“Basically, the higher the discount rate, the less argument there is for making investments now, because why would you spend money on this when you could make that money get a higher return doing something else?” said Meiburg.
During the Trump administration, discount rates were high, so the value of avoiding future climate change was low — somewhere between $1 and $7 per ton of carbon dioxide.
Project 2025 urges the agency to “revise guidance documents” for the so-called social cost of carbon, while another chapter proposes ending its use altogether.
Co-benefits — a rule’s health and environmental advantages that aren’t tied directly to reducing a targeted pollutant — have been persona non grata with conservatives for years. But the Trump EPA did count them in its climate rules — which showed minuscule benefits due in part to low social cost values for greenhouse gases.
Jason Schwartz, policy director at the Institute for Policy Integrity, said sidelining benefits could make rules less legally durable.
“I think that the court says have been clear in a number of cases that it would actually be arbitrary for an agency to ignore — or to really treat differently — co-benefits or indirect costs,” he said.
Gunasekara said co-benefits would still be analyzed.
“But it should be very clear, if EPA is going after one pollutant, what are the relative costs and benefit of [reducing] that one pollutant?” she said.
The goal, she said, should be “to ensure that there is increased transparency and understanding to the American public about cost-benefit justifications for the reduction of various pollutants.”
Transparency
Transparency is one of the chapter’s prevailing themes. That’s how the document frames its bid to require the data from all scientific studies underpinning regulation to be made public — effectively barring research that utilizes anonymous datasets.
But critics warn that many of its suggestions would create information gaps that would make it harder for EPA to maintain inventories of the greenhouse gas emissions — and ultimately to regulate them.
“It’s basically like two blades of a scissors,” said Goodwin of the Center for Progressive Reform. “These cost-benefit analysis rules are demanding more information. But the other blade is making it harder for EPA to get that information in the first place. And you can see how they come together.”
EPA currently requires 41 high-emitting sectors to report their greenhouse gas emission each year. About 8,000 facilities within those sectors — chosen because they exceed certain emissions thresholds — is the basis of EPA’s annual greenhouse gas inventory. The data has numerous purposes, including as an input for EPA regulatory decisions.
But Project 2025 would limit reporting to the few sectors currently being regulated for greenhouse gas emissions — such as power plants and oil and gas production. It would exempt major emitters in other sectors, such as municipal landfills, iron, steel and cement manufacturing, and carbon capture and storage.
The chapter said this would eliminate costly requirements borne by small businesses.
“This is either a pointless burden or a sword-of-Damocles threat of future regulation, neither of which is appropriate,” the document states.
But suspending annual greenhouse gas reporting for the four years of a second Trump term could delay regulation of new sectors during a subsequent administration by depriving it of needed data. It would reduce the scope of information available to scientific agencies that track emissions.
It could also make it impossible for the U.S. to fulfill its obligations as a party to the United Nations Framework Convention on Climate Change (UNFCCC), which requires an annual accounting of emissions and carbon sinks. The Senate formally ratified the treaty in 1992 and the U.S. remained a party to it under Trump, even as the administration moved to withdraw from the Paris Agreement.
Gunasekara said she’d urge “the next conservative administration” to withdraw from the UNFCCC as well as Paris, which she said required the U.S. to make painful cuts while giving other countries “a free pass.”
