Project 2025 - The Evolution of the Heritage Foundation from Favoring to Trashing EPA’s Science
Thank you for tuning in to Environmental Protection News. Today’s feature comes from Dr. Bernard D. Goldstein — former EPA Assistant Administrator for Research and Development and EPN volunteer. He explains the Heritage Foundation's plan for undermining EPA science by prioritizing political appointees over experts. Dr. Goldstein also offers historical context regarding the Heritage Foundation's changing stances and warns the current approach politicizes EPA processes, resembling authoritarian control. - Steven Fantes, EPN Public Affairs Manager
Project 2025 - The Evolution of the Heritage Foundation from Favoring to Trashing EPA’s Science
By Bernard D. Goldstein
The scientific recommendations for the Environmental Protection Agency (EPA) proposed in Project 2025, the Heritage Foundation’s blueprint for a conservative government, differ dramatically from the recommendations the foundation made in 1984 in anticipation of Ronald Reagan’s re-election. While the foundation criticized the administration for its selection of a less conservative EPA administrator, it did not seek to undermine agency science as it is wholeheartedly doing today.
My vantage point on the change in this conservative viewpoint is firsthand, having served under Ronald Reagan as head of the congressionally-mandated Clean Air Scientific Advisory Committee (CASAC) and then as EPA Assistant Administrator for Research and Development. More recently, I closely reviewed the impact of the Trump administration on EPA’s science.
The EPA science recommendations in Project 2025 conform to what was attempted and, to some extent, accomplished during the previous conservative administration before being reversed by the Biden administration or by adverse court decisions. These include the reversal of the Trump administration’s policy that forbade EPA from obtaining external scientific advice from scientists who had received competitive grant funding from EPA even though these awards were based on their demonstrated expertise in a subject. Yet, those who EPA had determined to be less expert would still be eligible to give advice.
In 1984, the Heritage Foundation chastised Reagan for having replaced EPA Administrator Ann Gorsuch with the more liberal William Ruckelshaus. Its sole criticism of Gorsuch was for her lack of support for EPA’s science, which the foundation then thought was necessary for a conservative approach to environmental concerns. While Gorsuch, in many ways, ignored EPA’s scientific mission, I can attest that she did not actively interfere with processes used by EPA to obtain scientific advice related to setting Clean Air standards. This cannot be said of the Trump administration’s EPA leadership.
Under Trump, EPA systematically replaced the consensus-based norms long used by both political parties to obtain an accurate understanding of current science and technology. Instead, EPA leadership substituted the advocacy-based norms that govern law and politics. Advocates work hard to obtain courts or juries that will support their views. In contrast, scientists who serve on advisory committees are judged by their peers on how closely they adhere to science. As these are the same peers who review their grants for funding and manuscripts for publication, there is heavy peer pressure to get their science right.
Under Trump, EPA‘s rules for obtaining unbiased science advisory committees were reversed, including choosing as head of CASAC an industry consultant who had recently published an op-ed in the Wall Street Journal arguing against a causal relation between reductions in ozone and better public health. EPA leadership also dismantled subcommittees that provided invaluable advice on specific air pollutants. The expertise of these groups was particularly needed for reviews related to the ozone and fine particulate standards, for which there was evidence suggesting more stringent standards would be required to protect public health. Other documented changes were noted in a GAO report finding that during the Trump administration, there was an increase in industry and consultant members of EPA scientific advisory committees and a decrease in academics compared to the GW Bush or Obama administrations for which the figures were similar.
Historically, advice on major EPA issues has been sought from the National Academy of Sciences (NAS), which is a world leader in developing and using consensus processes; under Trump’s EPA, the NAS was largely frozen out of this role. Project 2025 specifically advises EPA to ignore NAS unless it changes its approach to obtaining scientific consensus to that used for the Trump EPA’s decision processes.
There is one major difference between the former Trump administration’s EPA and a recommendation of Project 2025 that calls for the immediate selection of the Assistant Administrator for Research and Development. Trump is the only president who did not nominate anyone for this critical position, which requires Senate confirmation. Following a major theme, Project 2025 recommends no fewer than six senior political appointees be recruited to oversee and reform EPA’s research and science activities, all of whom would be chosen for their management, oversight and execution skills “as opposed to personal scientific output.” While previous administrations looked for management skills in their nominees, this was in addition to, not as opposed to scientific skills. In part, this is a continuation of the previous conservative administration’s EPA in which a position was specifically created to be the interface between science and any EPA policy-making. That position was filled by someone with minimal scientific credentials who was the former head of environmental affairs for Koch Industries, a background not mentioned on EPA’s website.
Rather than following the appropriate way EPA science was conducted under Republican administrators such as William Ruckelshaus, Lee Thomas, William Reilly and Christie Todd Whitman, the Project 2025 recommendations are closer to the administrative approaches to science used originally by the Politburo of the Soviet Union, and now by China, in which every scientific organization has a group of powerful overseers who ensure conformity with political positions.
About Bernard D. Goldstein: Dr. Goldstein is a Professor Emeritus and Dean Emeritus at the University of Pittsburgh Graduate School of Public Health. He is a former EPA Assistant Administrator for Research and Development (1983-1985) and Chair of the EPA Clean Air Scientific Advisory Committee. A volunteer with EPN, Dr. Goldstein has extensive experience in environmental health and public policy, contributing significantly to EPA's scientific advisory and regulatory efforts.
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