Project 2025 on the Department of Energy (DoE) and Environmental Protection Agency (EPA)1

Climate change is a very real threat to the survival of all plant and animal life on the planet.  Yet the goals of the conservative Project 2025 are to ignore all of the scientific evidence and proceed with reckless abandon down the path of increased fossil fuel production and consumption.

People Magazine in its website article by Kylor Alvord dated July 11, 2024 states that:

“Heritage Foundation President Kevin Roberts writes in the manifesto’s foreword that environmental protections are “anti-human” and part of a “pseudo-religion” that puts the “god of nature” above human activity.  Project 2025 translated that argument into policy by suggesting that the Environmental Protection Agency be shrunk and that three offices in the Department of Energy be closed to stop investing in clean and renewable energy. Instead, the mandate suggests, the U.S. should “stop the war on oil and natural gas” by resuming oil drilling in the Arctic, expanding existing drilling projects and expanding coal mining to the western U.S.  The Trump administration would be encouraged to cut off funding of any “woke” climate change prevention efforts, pulling back from the 2015 Paris Climate Agreement.” They repeatedly claim that there is a war on oil and natural gas, even though the U.S. subsidized fossil fuels to the tune of $757 billion in 2022, according to the International Monetary Fund.2

Read more below.

 

Project 2025 Statements on the Department of Energy (DoE) and Environmental Protection Agency (EPA)

Department of Energy1(Page 363-416)

“A conservative President must be committed to unleashing all of America’s energy resources and making the energy economy serve the American people, not special interests. This means that the next conservative Administration should:

  • Support repeal of massive spending bills like the Infrastructure Investment and Jobs Act (IIJA) and Inflation Reduction Act (IRA), which established new programs and are providing hundreds of billions of dollars in subsidies to renewable energy developers, their investors, and special interests, and support the rescinding of all funds not already spent by these programs.
  • Unleash private-sector energy innovation by ending government interference in energy decisions.
  • Stop the war on oil and natural gas.
  • Refocus FERC on ensuring that customers have affordable and reliable electricity, natural gas, and oil and no longer allow it to favor special interests and progressive causes.

Note:  FERC is the Federal Energy Regulatory Commission.

“Eliminate special-interest funding programs. Many DOE energy funding programs are not targeted on fundamental science and technology; instead, they focus more on commercialization and act as subsidies to the private sector for government-favored resources. The DOE Office of Clean Energy Demonstrations (OCED); Office of State and Community Energy Programs; ARPA-E; Office of Grid Deployment (OGD); and DOE Loan Program should be eliminated or reformed. If they continue to exist, FECM, NE, OE, and EERE should focus on fundamental science and technology issues, particularly in relation to cyber and physical threats to energy security, rather than subsidizing and commercializing energy resources.

Eliminate political and climate-change interference in DOE approvals of liquefied natural gas (LNG) exports. In addition, Congress should reform the Natural Gas Act to expand required approvals from merely nations with free trade agreements to all of our allies, such as NATO countries.

Focus the Federal Energy Management Program (FEMP) on ensuring that government buildings and operations have reliable and cost-effective energy. FEMP should stop using taxpayer dollars to force the purchase of more expensive and less reliable energy resources in the name of combating climate change.

Focus on energy and science issues, not politicized social programs. The next Administration should stop using energy policy to advance politicized social agendas. Programs that sound innocuous, such as “energy justice,” Justice40 and DEI can be transformed to promote politicized agendas.”

“Eliminate applied programs. OE administers grant programs for things like energy storage and the testing of grid-enhancing technologies (GETs). These programs should be eliminated. The next Administration should work with Congress to eliminate all DOE applied energy programs including OE (except perhaps those related to basic science for new energy technology).”

“In recent years, the Office of Fossil Energy (FE) has been transformed from its statutory role of improving fossil energy production to one that is focused primarily on reducing the carbon dioxide emissions from fossil fuel extraction, transport, and combustion. This change is reflected in the office’s new name, the Office of Fossil Energy and Carbon Management (FECM), effective as of July 2021, and FECM’s mission: “to minimize the environmental impacts of fossil fuels while working towards net-zero emissions.” Needed reforms include:

Eliminate carbon capture utilization and storage (CCUS) programs. Despite the recent expansion of the 45Q tax credit for carbon capture utilization and storage (CCUS) to $87 per ton, most carbon capture technology remains economically unviable, although private-sector innovations are on the horizon. CCUS programs should be left to the private sector to develop.35 If the office continues any CCUS research, that research should be focused more on innovative utilization.

  • Pursue the processing of critical minerals. Development of domestic critical material sources is important for national security, as the vast majority of critical materials are mined or processed (or both) in Russia and China.36 The processing of critical materials from fossil fuel waste products (primarily coal) has shown some potential and, in view of our vast domestic reserves of coal and abundant waste from coal mining and combustion, should be pursued.”

The new policies suggested include “Eliminate FECM” or “Rename FECM (if it cannot be eliminated) under its original designation as the Office of Fossil Energy and with its original mission: increasing energy security and supply through fossil fuels. They also want to “ensure that LNG export approvals are reviewed and processed in a timely manner.” The infrastructure to export LNG out of the US is often sited in lower-income communities and communities of color. It also contributes significantly to climate change by burning methane (85 times more potent than carbon dioxide in the first ten years) at every step of the process, from extraction, to processing, to shipping.3

When it comes to the Office of Energy Efficiency and Renewable Energy (EERE), Project 2025 wants reform it by “end(ing) the focus on climate change and green subsidies” and “Eliminat(ing) energy efficiency standards for appliances” The new policies, include “eliminat(ing) EERE” or “reduc(ing) EERE funding”.

“Under the IIJA, “the Clean Energy Corps is charged with investing more than $62 billion to deliver a more equitable clean energy future for the American people[.]” The Corps says that it will “focus on deploying next generation clean energy technology” to “help America meet its goals of a carbon-free power sector in 2035 and a decarbonized economy in 2050.” The one new policy suggested is “Eliminate the Clean Energy Corps by revoking funding and eliminating all positions and personnel hired under the program.”

“Oppose “climate reparations.” During the November 2022 United Nations climate conference in Egypt, the Biden Administration and other “developed” countries agreed to provide “climate reparations” to developing countries for the harm allegedly caused by the developed countries’ use of fossil fuel.76 A reparations slush fund administered by a non-U.S. organization provides no assurance that U.S. interests will be protected and should not be supported in any form.”

Within the Arctic Energy Office (AE), they propose:

  • “Ensure that AE is clearly focused. In particular, this means identifying U.S. energy interests in the Arctic Circle, identifying foreign government and commercial interests and activity in the region, and ensuring that the United States does not forgo important energy and national security interests in the Arctic.
  • Expand AE’s operations in Alaska. AE’s operations in Alaska should be expanded to encompass broader national energy security interests in the region including rare earths, oil, and natural gas. AE should also be the lead for DOE Antarctic operations as a counter to growing Russian and Chinese interest in Antarctic resources.”

It also states, “Needed Reforms There is a growing problem with the electric grid’s reliability because of the increasing growth of subsidized intermittent renewable generation (like wind and solar) and a lack of dispatchable generation (for example, power plants powered by natural gas, nuclear, and coal), especially during hot and cold weather”. You may remember Texas during the winter of 2021, when over 200 lives were lost because of the state’s aging fossil fuel plants, but republicans blamed renewables”.4 Reforms include:

Limit the impact of subsidized renewables on price formation. Subsidized renewable resources are undermining electric reliability in RTOs. The increase in subsidized, intermittent resources is undermining the ability of RTOs’ pricing models to support the reliable dispatchable generation that is needed to serve the grid at all times.” There is no mention of the subsidies that fossil fuel has received for decades.

Regarding natural gas pipelines, they state that they “are vital for the economy, manufacturing, heating, and electric generation. Opposition from “Keep it in the ground” environmentalists has made it harder to gain approvals for natural gas pipelines.” From this idea, they suggest the following new policies:

Recommit itself to the NGA’s purpose of providing the American people with access to affordable and reliable natural gas.

  • Limit its NGA decision-making on natural gas pipeline certificates to the question of whether there is a need for the natural gas.
  • Limit its NEPA analysis to the impacts of the actual pipeline itself, not indirect upstream and downstream effects.

 

Environmental Protection Agency1(418-448)

“Not surprisingly, the EPA under the Biden Administration has returned to the same top-down, coercive approach that defined the Obama Administration. There has been a reinstitution of unachievable standards designed to aid in the “transition” away from politically disfavored industries and technologies and toward the Biden Administration’s preferred alternatives. This approach is most obvious in the Biden Administration’s assault on the energy sector as the Administration uses its regulatory might to make coal, oil, and natural gas operations very expensive and increasingly inaccessible while forcing the economy to build out and rely on unreliable renewables.1 This approach has also been applied to pesticides and chemicals as the Biden Administration pushes the “greening” of agriculture and manufacturing among other industrial activities.”

“Although the U.S. environmental story is very positive, there has been a return to fear-based rhetoric within the agency, especially as it pertains to the perceived threat of climate change. Mischaracterizing the state of our environment generally and the actual harms reasonably attributable to climate change specifically is a favored tool that the Left uses to scare the American public into accepting their ineffective, liberty-crushing regulations, diminished private property rights, and exorbitant costs. In effect, the Biden EPA has once again presented a false choice to the American people: that they have to choose between a healthy environment and a strong, growing economy.”

“To implement policies that are consistent with a conservative EPA, the agency will have to undergo a major reorganization. The Deputy Chief of Staff for Policy position within the Administrator’s office should be renamed the Deputy Chief of Staff for Regulatory Improvement. This position would oversee a reorganization effort that includes the following actions:

  • Returning the environmental justice function to the AO, eliminating the stand-alone Office of Environmental Justice and External Civil Rights.
  • Using enforcement to ensure compliance, not to achieve extrastatutory objectives.
  • Developing a plan for relocating regional offices so that they are more accessible to the areas they serve and deliver cost savings to the American people.
  • l Reviewing the grants program to ensure that taxpayer funds go to organizations focused on tangible environmental improvements free from political affiliation.
  • Resetting science advisory boards to expand opportunities for a diversity of scientific viewpoints free of potential conflicts of interest.”

“Day One Executive Order. 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. The order should set up “pause and review” teams to assess the following:

  • Major Rules and Guidance Materials. Identify existing rules to be stayed and reproposed and initiate rule development in appropriate media offices.
  • Pending Petitions. Grant new petitions for rule reconsideration and stays of rules.
  • Grants. Stop all grants to advocacy groups and review which potential federal investments will lead to tangible environmental improvements.
  • Legal Settlements. Reassess any “sue and settle” cases and develop a new policy to establish standard review and oversight, including public notification and participation.
  • Employee 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.
  • Budget Review. Develop a tiered-down approach to cut costs, reduce the number of full-time equivalent (FTE) positions, and eliminate duplicative programs. EPA should not conduct any ongoing or planned activity for which there is not clear and current congressional authorization, and it should communicate this shift in the President’s first budget request.
  • Risk Management Policy. Revise guidance documents that control regulations such as the social cost of carbon; discount rates; timing of regulatory review (before options are selected); causality of health effects; low-dose risk estimation (linear no-threshold analysis); and employment loss analysis.”

In order to get appointees working on day 1, “appointees in consideration for Senate-confirmed positions (excluding the Administrator) should be prepared to serve as a Deputy or Principal Deputy to get into the agency on Day One while their nomination and affiliated confirmation processes proceeds.”

Policy-Specific Actions include:

  • “EPA adopted by regulation a goal of restoring natural visibility by 2064. The statute does not require this, and EPA should consider whether a longer timeline is less disruptive or more realistic. Regional haze rules should be revised to prevent subsequent “planning periods” from being abused to compel the shutdown of disfavored facilities.
  • 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.
  • Streamline the process for state and local governments to demonstrate that their federally funded highway projects will not interfere with NAAQS attainment.
  • Adopt policies to prevent abuse of EPA’s CAA “error correction” authority.20 EPA historically has used this to coerce states into adopting its favored policies on pain of imposition of a Federal Implementation Plan (FIP).
  • Limit EPA’s reliance on CAA § 30121 general rulemaking authority to ensure that it is not abused to issue regulations for which EPA lacks substantive authority elsewhere in the statute.
  • 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.
  • Establish a system, with an appropriate deadline, to update the 2009 endangerment finding.
  • Establish a significant emissions rate (SER) for greenhouse gases (GHGs).
  • Repeal Biden Administration implementing regulations for the AIM Act that are unnecessarily stringent and costly.
  • Refrain from granting petitions from opportunistic manufacturers to add new restrictions that further skew the market toward costlier refrigerants and equipment.
  • Establish GHG car standards under Department of Transportation (DOT) leadership that properly consider cost, choice, safety, and national security.
  • 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.
  • Stop the use of the International Civil Aviation Organization (ICAO) to increase standards on airplanes.
  • Reconsider the Cleaner Trucks Initiative to balance the goal of driving down emissions without creating significant costs or complex burdens on the industry.
  • Restore the Trump EPA position on Once-In, Always-In (that major sources can convert to area sources when affiliated emissions standards are met).
  • Restore the position that EPA cannot regulate a new pollutant from an already regulated source category without making predicate findings for that new pollutant.
  • Institute automatic withdrawal of any proposed rule that is not finalized within the statutorily prescribed one-year period.
  • Unregulated point or non-point source (fugitive emissions) of an already regulated hazardous air pollutant do not require a Maximum Available Control Technology (MACT) standard.
  • Ensure that cost-benefit analysis is focused on a regulation’s targeted pollutant and separately identify ancillary or co-benefits.
  • Revise groundwater cleanup regulations and policies to reflect the challenges of omnipresent contaminants like PFAS.
  • Revisit the designation of PFAS chemicals as “hazardous substances” under CERCLA.
  • Ensure that decision-making is risk-based rather than defaulting to precautionary, hazard-based approaches like the Integrated Risk Information System (IRIS).
  • Focus the scope of chemical evaluations on pathways of exposure that are not covered by other program offices and other environmental statutes, and eliminate scope creep to ensure that evaluations can be completed in a timely manner consistent with the statutory requirements.
  • For new chemicals, reset the program to ensure that reviews are completed on a timeline that is consistent with the statute. This includes revising the regulations governing the reviews of new chemicals.
  • Transition the Safer Choice program to the private sector.
  • ESA reform for pesticides is necessary. When approving pesticides, FIFRA allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA does not allow for any consideration of the beneficial effects of pesticides. In order to meet ESA obligations, pesticide uses are severely restricted, leaving growers with limited tools for crop protection.”

They also list the Day One Priorities:

“Notify Congress that EPA will not conduct any ongoing or planned science activity for which there is not clear and current congressional authorization. This priority should be underscored in the President’s first budget request.

  • The new President’s Inauguration Day regulatory review/freeze directives should avoid exceptions for EPA actions. This freeze should explicitly include quasi-regulatory actions, including assessments, determinations, standards, and guidance, that have failed to go through the notice-and comment process and may date back years.
  • Pause for review all contracts above $100,000 with a heavy focus on major external peer reviews and regulatory models.
  • Call for the public to identify areas where EPA has inconsistently assessed risk, failed to use the best science, or participated in research misconduct.
  • Eliminate the use of unauthorized regulatory inputs like the social cost of carbon, black box and proprietary models, and unrealistic climate scenarios, including those based on Representative Concentration Pathway (RCP).
  • Quickly nominate a reform-minded Assistant Administrator for Research and Development.
  • Suspend and review the activities of EPA advisory bodies, many of which have not been authorized by Congress or lack independence, balance, and geographic and viewpoint diversity.”

 

Finally, some important legislative reforms they want to implement include:

  • “Revisit and repeal or reform outdated environmental statutes. A high priority should be the repeal or reform of the Global Change Research Act of 1990,50 which has been misused for political purposes.
  • Repeal Inflation Reduction Act programs providing grants for environmental science activities.”

 

References:

  1. https://static.project2025.org/2025_MandateForLeadership_FULL.pdf
  2. https://www.eesi.org/papers/view/fact-sheet-proposals-to-reduce-fossil-fuel-subsidies-january-2024
  3. https://www.nrdc.org/stories/liquefied-natural-gas-101#concerns
  4. https://earth.org/texas-energy-crisis-why-is-the-states-power-grid-so-fragile/