Project 2025 is a Scorched Earth Attack on EPA and its Mission
Thank you for tuning in to Environmental Protection News. Our final Project 2025 feature comes from David Coursen — former attorney in EPA’s Office of General Counsel. Coursen discusses the radical changes Project 2025 proposes for the EPA, aiming to dismantle environmental protections and replace career experts with political appointees, focusing on reducing polluters' costs. The plan would roll back greenhouse gas regulations, weaken environmental justice efforts, and undermine EPA’s science-based decision-making, leading to severe environmental and economic consequences. -Steve Fantes, EPN Public Affairs Manager
Project 2025 is a Scorched Earth Attack on EPA and its Mission
By: David Coursen
The EPA section of presidential transition Project 2025, the notorious roadmap for a conservative administration, launches a radical assault on the agency and its historic commitment to protecting the people’s health and the environment. Much has been written by former EPA senior officials and others on the specific areas of the agency’s work that would be undermined and undercut by this dangerous plan. But the overall plan, which covers almost every aspect of EPA’s job, is nothing less than devastating. Its implementation would accelerate global warming, increase air pollution, destroy millions of clean energy jobs, slow the economy, and cripple environmental enforcement and efforts to address environmental injustice. It would replace EPA career civil servants working to protect the environment with political appointees working to advance a polluter-friendly agenda.
Its centerpiece is the root and branch destruction of EPA’s program to control greenhouse gas (GHG) pollution, a principal cause of the catastrophically warming climate. It proposes to eliminate clean energy incentives, block regulations, and “update” –i.e. reverse– EPA’s 2009 finding that greenhouse gas pollutants endanger public health. That finding provides the legal basis for EPA GHG regulation and reversing it is a virtual Holy Grail for climate deniers that would terminate existing regulatory measures to address GHG emissions and block future ones. Project 2025 offers no legal or scientific rationale for reversing the finding, and ballooning evidence of the “worsening” effects of a warming climate suggests that the danger has increased, an inconvenient fact unlikely to deter climate denial “true believers” from proceeding, possibly hoping for the approval of an increasingly conservative judiciary.
Project 2025’s anti-GHG provisions would have staggering consequences. They would add billions of tons to annual GHG emissions and enough new non-GHG air pollution to produce six thousand extra premature deaths in 2030. And implicit claims that the plan would have economic benefits are baseless. One source estimates it would wipe out almost 4 million jobs (even after accounting for new fossil fuel production jobs), reduce U.S. GDP by $770 billion, and increase household energy costs by $40 billion by 2030.
Project 2025 also eliminates EPA’s environmental justice and enforcement offices, dispersing their functions and staff across the agency, inevitably reducing their effectiveness. That change flies in the face of no evidence that serious environmental violations are widespread, with a relative handful of facilities responsible for a large share of the pollution and much of the brunt falling on disadvantaged communities. Effective enforcement and environmental justice are essential for combating widespread violations and finding and addressing disproportionate burdens.
More generally, Project 2025 would transform EPA’s mission from controlling pollution to reducing polluters' costs. It suggests tolerating widespread and deadly groundwater contamination from toxic PFAS “forever chemicals” and focusing EPA research on pollution not caused by industry. It would reverse the “precautionary principle,” which protects the public from exposure to potential harms that are uncertain, effectively giving polluters the benefit of the doubt; relieving them of the costs of precautions shifts the risks of uncertainty onto the public.
Project 2025 also includes sweeping attacks on EPA’s science program, which provides states and EPA with the reliable information about pollution and its impacts that EPA statutes require to support regulatory decisions. Absent EPA science, information might come largely from industry experts who have built-in conflicts of interest from their economic incentives to reduce regulatory costs. The EPA section also advocates removing mainstream scientists from advisory bodies and making room for more “diverse” viewpoints, potentially including cranks, quacks, and crackpots, along with more industry scientists. EPA Project 2025 includes implausible claims, such as sweeping assertions, unsupported by evidence or examples, that “much of” EPA’s science “work has not been authorized by law,” and that EPA “experienced massive growth” during the Obama administration (when EPA full-time staff fell from 17,049 to 15,408).
A cornerstone of Project 2025 is the wholesale replacement of career civil servants with political appointees, placing loyalty to the president over competence. The EPA section recommends placing political appointees in scientific and technical positions, where they may lack competence to do the work properly and could be well-positioned to suppress or manipulate data to support politically preferred outcomes. The EPA plan also calls for more top-down decision-making, with less room for input from career professional staff, and endorses measures to encourage senior staff resisting a political agenda to leave the agency, reducing the organization’s integrity, expertise and institutional memory.
Project 2025 claims to “deconstruct the Administrative State.” But pretentious academic jargon cannot put lipstick on this pig: the Project 2025 EPA plan is a blast of toxic nihilism to demolish informed regulatory governance and replace it with polluter-friendly authoritarianism. It must be rejected.
About David Coursen: David Coursen is an expert in the Clean Air Act, Environmental Justice, and Constitutional and Administrative Law. He formerly served in the EPA Office of General Counsel.
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