23
Oct
Commentary: Expected Trump Blueprint, Project 2025, To Subvert Environmental Law as Crises Mount
(Beyond Pesticides, October 23, 2024) The stark contrast of two political parties emerged around this summer’s reporting of the Project 2025 blueprint—created by extreme right-wing conservatives—that proposes the gutting of environmental and public health policy and implementation. Many political observers say “Project 2025 Presidential Transition Project,” formally titled “Mandate for Leadership: The Conservative Promise,” will be embraced by a second Trump Administration, despite denials that are challenged by insiders as outright lies. While the public became aware of Project 2025 plans to gut the U.S. Environmental Protection Agency (EPA) and many other agencies, the Biden Administration was announcing the emergency ban (see also August 6 announcement), finalized yesterday, of the weed killer Dacthal, exercising an EPA authority that has not been used in 45 years since the banning of 2,4,5-T (50% of the mixture of Agent Orange). With this decision, EPA set an important precedent for proclaiming (i) an unacceptable harm, (ii) its inability to mitigate the pesticide’s hazards with typical risk mitigation measures, and (iii) the availability of alternatives that made the chemical unnecessary. In dramatic contrast, the Trump supporters behind Project 2025 are intent on politicizing science to undermine governmental structures and laws established to protect public health and the environment. The blueprint, if followed, will surely allow the existential health, biodiversity, and climate crises to spiral out of control—ensuring that a sustainable future will suffer a deadly setback, given the urgency of the crises.
Published by the conservative Heritage Foundation and 140 former Trump administration staffers, Project 2025 lays out a plan for a hypothetical second Trump administration on a range of environmental, public health, and social issues. The document has sections devoted to EPA, the U.S. Department of Agriculture (USDA), and the Department of the Interior (DOI).
If all the plans detailed in the document were to become policy, any control over pesticides, fossil fuels, industrial chemicals, metals like lead and arsenic, and carbon dioxide emissions would evaporate like volatile gases. This is not an exaggeration. Every brake on agricultural chemicals, resource extraction, and industrial pollution, including oil, gas and coal, will be removed. The document is unapologetic and deeply radical in intent. The New York Times reported that the head of the Heritage Foundation, Kevin Roberts, said, “We are in the process of the second American Revolution.”
Project 2025 alternates between aggressively hostile terms for civil servants and environmental advocates on the one hand and insincere, benevolent-sounding statements that say one thing and mean something else. The document’s overall polemic tone makes it sound as if EPA is riddled with crazy “Leftists” who have been imposing their distorted vision on the nation by wrapping all economic activity in choking ribbons of red tape and illegally incorporating attempts to cope with climate change into every policy. To anyone who has tried to convince EPA to take urgent steps to prevent and eliminate exposures to harmful chemicals—glyphosate, for example, or dicamba, chlorpyrifos, or DDT (Dacthal, for sure)—this line of rhetoric is laughable.
Project 2025 will change the definition of pollutants and hazardous chemicals, which will likely dilute actions to control, for example, perfluoroalkyl and polyfluoroalkyl compounds (PFAS), the “forever chemicals” often contained in pesticides and as flame retardants in almost everything else. See Beyond Pesticides’ analysis of a recent Environmental Health Perspectives commentary on PFAS present in the active ingredients of pesticides.
Project 2025’s supposed concern for safe food and Americans’ health includes a call for “reform for pesticides. . .When approving pesticides, FIFRA [the Federal Insecticide, Fungicide and Rodenticide Act] allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA [Endangered Species Act] does not allow for any consideration of the beneficial effects of pesticides.”
In a statement regarding EPA’s Office of Pesticide Programs that George Orwell would single out as perfect Newspeak, or purposefully ambiguous and confusing language, Project 2025 asserts that pesticide manufacturers feel the program is underfunded:
Manufacturers are also willing to pay higher fees to the fee-based portion of the program. However, grower groups have been disappointed by EPA’s actions and have significant concerns about EPA’s ability to conduct science-based risk assessments and take risk management actions that appropriately balance benefits and risks as required by FIFRA.
Project 2025’s real opinion is nowhere more evident than in its treatment of science, for example in its proposal to “[s]hift responsibility for evaluating misconduct away from its Office of Scientific Integrity, which has been overseen by environmental activists, and toward an independent body.” It says EPA’s “scientific enterprise, including the ORD [Office of Research and Development], has rightly been criticized for decades as precautionary, bloated, unaccountable, closed, outcome-driven, hostile to public and legislative input, and inclined to pursue political rather than purely scientific goals.”
One of the most bizarre aspects of Project 2025’s approach to pesticides is its use of the word “transparency” regarding scientific data. Rather cryptically, the document states:
“[W]hen pesticides undergo registration review every 15 years, EPA relies on publicly available data with differing levels of quality and transparency. Data standards are needed to ensure that information relied on by EPA is made available to the agency at a similar level as the original testing data conducted by registrants to ensure that EPA can conduct a robust review and analysis of the data.”
This is code for a return to what critics call the “Censoring Science” rule, or EPA’s “Strengthening Transparency in Pivotal Science” policy proposed by then-EPA administrator Scott Pruitt in 2018 during the Trump administration. The rule was both finalized by EPA and vacated by a Montana federal judge in 2021.
The rule was an attempt by the chemical industry to repeat the ploys used by the tobacco industry, which “attacked the methodology of underlying epidemiologic research and called for the inclusion of non-peer-reviewed and industry-sponsored literature into the final assessment,” according to a powerful analysis in the Annals of the American Thoracic Society. This rule was scathingly criticized by all kinds of scientists; its effects would have been to allow non-peer reviewed literature into final reviews and bar any science that did not make its raw data public, posing severe threats to the privacy of individuals in epidemiological studies and pollution exposure surveys. The Washington Post explains that the rule would “actually restrict the EPA from using some of the most consequential research on human subjects because it often includes confidential medical records and other proprietary data that cannot be released because of privacy concerns.” Restoration of the policy is the real goal of the “transparency” language.
Project 2025’s hypocrisy is staggering. The document attacks the present policies and staff of EPA and USDA. It claims EPA is riddled with “politically connected” and “embedded” activists, pushing “vendetta-driven enforcement,” using “fear-based rhetoric” about climate change, which 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.”
The document repeatedly complains about bureaucratic delays, too many confusing and far-flung offices, and the injection of political motives into what it says it values—pure science. Yet Project 2025 recommends placing political appointees in almost every office of EPA. As to the agency’s risk management policy, Project 2025 states that “each office will need a political chief of staff, senior advisers designated to run suboffices, and energized assistants. Teams should be balanced with technical knowledge, legal expertise, and political exposure.”
It further proposes to centralize authority in such a way as to give all control to appointees with explicit political skills rather than to experienced technical and scientific experts. It will:
“Appoint and empower a Science Adviser reporting directly to the Administrator in addition to a substantial investment (no fewer than six senior political appointees) charged with overseeing and reforming EPA research and science activities. Qualifications for these positions should emphasize management, oversight, and execution skills (including in leading state environmental agencies) as opposed to personal scientific output.”
In other words, Project 2025 will make EPA even more politicized and less scientifically sound than it is now.
Regarding USDA, Project 2025 has less to say about specific chemical or pesticide policies, but advocates shrinking the agency and removing its authority to regulate wetlands associated with farmland. It accuses USDA of trying to force farmers to adopt organic practices and of placing “ancillary issues like climate change ahead of food productivity and affordability.” It will eliminate USDA dietary guidelines. Regarding genetic engineering, Project 2025 will repeal the federal labeling law.
In the Department of the Interior (DOI), Project 2025’s environmental agenda is to open up all land everywhere to fossil fuel exploitation: “[N]o other initiative is as important for the DOI under a conservative President than the restoration of the department’s historic role managing the nation’s vast storehouse of hydrocarbons, much of which is yet to be discovered.” The document also takes aim at the Endangered Species Act and calls the National Environmental Policy Act (NEPA) a “tree-killing, project-dooming, decade-spanning monstrosity.” Project 2025 will eliminate NEPA’s authority to consider the cumulative impacts of multiple stressors from weather disasters to chemical exposures to social determinants of health, roll back lead regulations, and gut numerous other helpful EPA programs.
The problem with this sweeping, agency-by-agency approach is that issues like health effects from exposure to pesticides, industrial chemicals, toxic metals, and their legacy residues permeate all life, and have relevance in every activity from the military to fish farming. Acknowledging their harms and eliminating their use to the greatest extent possible with replacement practices and products would be the fastest way to accomplish true health and safety for everyone. Instead, Project 2025 proposes to simply open the floodgates to an expansion of all these kinds of pollution beyond anything previously experienced.
There are many aspects of environmental regulation in the U.S. that are far from perfect, but EPA, USDA, DOI, and other agencies beat the alternative of no regulation whatsoever. Some of the “reforms” in Project 2025 could actually improve regulatory function by reducing the time it takes for an agency to make a decision, to clarify murky rules, arrive at equitable specifics, and so on. But much of the delay and murkiness result from industry influence in the decision-making process, not from “radical” environmentalists. See Beyond Pesticides’ 2023 Daily News for further analysis of conflicts of interest in chemicals regulation and our 2021 Daily News regarding 37 environmental groups’ letter to EPA demanding reform of the Office of Pesticide Programs. An award-winning 2021 report by Sharon Lerner in The Intercept, “The Department of Yes: How Pesticide Companies Corrupted the EPA and Poisoned America” reveals industry’s meddling in granular detail.
In another ironic twist, there is good evidence that most Americans actually approve of environmental regulations; Mongabay reports on a new survey showing that support for wildlife conservation and the environment among American adults has risen from 80 percent in 2020 to 87 percent this year. In particular, 82 percent of Republicans say this value is part of their voting decision this year compared to 68 percent in 2020—a 14-point jump in four years. This suggests that Project 2025’s obsession with dismantling environmental protections is misplaced and out of sync with the public, since the document proposes to remove conservation protections—one of conservatives’ favorite environmental values—by delisting the grizzly bear and the gray wolf under the Endangered Species Act and giving states control over the greater sage grouse.
The environmental sections of Project 2025 constitute a very clear authoritarian agenda laying out the intention to entirely dismantle environmental policy in the United States. In a most-likely insincere rhetorical ploy, the document claims to want to preserve the federal agencies most involved with environmental health, agriculture and conservation. But this is disingenuous. The intended method is to impose something like the process of fossilization: when an organism fossilizes, its biological tissues are replaced by minerals in the exact configuration of the original, so the structure looks the same, but the function is destroyed. This is what Project 2025 aims to do: not to “drown [the government] in the bathtub” and totally dismantle the agencies, but to keep their shells visible while it hands our entire environment over to industry and corrupt politicians.
Throughout the document, Project 2025 pits private property and states’ rights against all the federal agencies’ efforts to clean up past environmental degradation caused by economic activities and to protect the health of American citizens from ongoing and combined threats. While property ownership is a basic right guaranteed by the U.S. Constitution, it is not an appropriate standard by which environmental issues should be assessed, because it completely disregards the basic facts of how ecosystems work. The truth is that Earth’s surface is mostly fluid—air and water—and anything that gets into either can and often does move far beyond political boundaries, following instead wind patterns, river drainages, temperature gradients, and many other dynamics of Earth’s systems.
The most striking proof of this is climate change, mitigation of which Project 2025 means to abandon altogether. The integration of the biosphere means that what happens in a field in Iowa, or a mine in Nevada, or a pesticide plant in Louisiana, does not necessarily stay there, so leaving environmental decisions entirely to individuals, states, or a second Trump administration will result in exactly the kind of devastation the nation experienced before there were any regulations at all. This would be a tragedy—just when we are attempting to correct our previous mistakes in time to save ourselves.
Sources:
Mandate for Leadership: The Conservative Promise (Project 2025)
The Heritage Foundation 2023
https://static.project2025.org/2025_MandateForLeadership_FULL.pdf
Science on “Forever Chemicals” (PFAS) as Pesticide Ingredients and Contaminants Documented
Beyond Pesticides, July 31, 2024
https://beyondpesticides.org/dailynewsblog/2024/07/science-on-forever-chemicals-pfas-as-pesticide-ingredients-and-contaminants-supports-need-for-immediate-action-to-end-their-use/
Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation
Beyond Pesticides
December 15, 2023
Int’l Group of Scientists Calls for Restraints on Conflicts of Interest in Publications and Regulation
Groups Tell EPA’s Pesticide Program It’s a Failure, Call for Immediate Reforms
Beyond Pesticides, October 26, 2021
https://beyondpesticides.org/dailynewsblog/2021/10/groups-tell-epas-pesticide-program-its-a-failure-calls-for-immediate-reforms/
Project 2025 Means More Toxic Chemicals. We’ll Fight Back.
Earthjustice
September 24, 2024
https://earthjustice.org/article/project-2025-means-more-toxic-chemicals-well-fight-back
Project 2025 Would Make It Easier for Big Corporations To Dump Dangerous Toxins That Poison Americans
Center for American Progress
August 7, 2024
https://www.americanprogress.org/article/project-2025-would-make-it-easier-for-big-corporations-to-dump-dangerous-toxins-that-poison-americans/
Project 2025 Plan for Trump Presidency Has Far-Reaching Threats to Science
Scientific American
July 19, 2024
https://www.scientificamerican.com/article/project-2025-plan-for-trump-presidency-has-far-reaching-threats-to-science/
