(A three-part series)
The controversial 922-page “Project 2025: Presidential Transition Project, the Heritage Foundation blueprint for a far-right Trump government is a political prescription for various reforms of energy and environmental programs in the Department of Energy, the Interior Department, and the Environmental Protection Agency.
While Donald Trump has tried to distance himself in the fallout from the turmoil and pushback the document has created, that’s not a believable stance. It is virtually certain that, should Trump recapture the White House, he would move swiftly to try to implement the blueprint. Many of its authors were appointees in his administration and likely would lead his government beginning in 2025.
The basic concept behind the recommendations for the EPA is to create a smaller agency with a more narrowly defined mission, giving states more power to influence agency policies, procedures, and priorities. The chapter calls for “open-source science,” although it is sketchy about what this might mean in practice and how federal courts might interpret it. It appears to be a criticism of climate science, as the report challenges EPA’s 2009 finding that carbon dioxide and five other greenhouse gases are pollutants that fall under the regulatory authority of the Clean Air Act.
The chapter asserts: “The EPA has been a breeding ground for expansion of the federal government’s influence and control across the economy. Embedded activists have sought to evade legal restraints in pursuit of a global, climate-themed agenda, aiming to achieve that agenda by implementing costly policies that otherwise have failed to gain the requisite political traction in Congress. Many EPA actions in liberal Administrations have simply ignored the will of Congress, aligning instead with the goals and wants of politically connected activists.”
The author of the EPA chapter is lawyer Mandy Gunasekara, 39, a Mississippi native who has long been an active climate skeptic. She was an aide to Oklahoma Republican Sen. Jim Inhofe (1934-2024) before Trump appointed her to the EPA, then headed by Scott Pruitt. She was acting head of EPA’s air and radiation office. Gunasekara takes credit for helping lead the Trump administration’s controversial exit from the 2015 Paris climate agreement. She left EPA in 2019 but rejoined the agency in 2020 as chief of staff to EPA Administrator Andrew Wheeler.
A year ago, Gunaseekara ran in a Republican primary for a seat on the Mississippi Public Service Commission, but was tossed off the ballot when the state supreme court ruled she did not meet the ballot residency requirements. State law requires residency for at least five years. She voted in D.C. in November 2018, just falling short of the residency rule. An appeal to the U.S. Supreme Court on its “shadow docket” failed.
Among the recommendations for EPA:
* “To initiate the review and reorganization, a Day One executive order should be drafted for the incoming President with explicit language requiring reconsideration of the agency’s structure with reference to fulfilling its mission to create a better environmental tomorrow with clean air, safe water, healthy soil, and thriving communities.”
* As part of that Day One review, “Determine the opportunity to downsize by terminating the newest hires in low-value programs and identify relocation opportunities for Senior Executive Service (SES) positions.”
“Establish a system, with an appropriate deadline, to update the 2009 endangerment finding.” — Mandy Gunasekara
* On climate, “Establish a system, with an appropriate deadline, to update the 2009 endangerment finding.” Also, “Remove the Greenhouse Gas Reporting Program (GHGRP) for any source category that is not currently being regulated. The overall reporting program imposes significant burdens on small businesses and companies that are not being regulated. This is either a pointless burden or a sword-of Damocles threat of future regulation, neither of which is appropriate.”
* On National Ambient Air Quality Standards issues, “Under the Good Neighbor Program/Interstate pollutant transport program, review Biden-era regulations to ensure that they do not “overcontrol” upwind states in violation of the statute as construed by the U.S. Supreme Court. Reverse the program’s 2022 expansion beyond power plants.”
* On mobile sources of air pollution, “Establish GHG car standards under Department of Transportation (DOT) leadership that properly consider cost, choice, safety, and national security.” Also, “Include life cycle emissions of electric vehicles and consider all of their environmental impacts…. Restore the position that California’s waiver applies only to California specific issues like ground-level ozone, not global climate issues…. Ensure that other states can adopt California’s standards only for traditional/criteria pollutants, not greenhouse gases.”
* On radiation: “Assess and update the agency’s radiation standards so that they align with those of other agencies, including the Nuclear Regulatory Commission, Department of Energy, and Department of Transportation, as well as international standards…. Level-set past, misleading statements regarding radiological risk and reassess the Linear Non-Threshold standard.”
–Kennedy Maize