This post was originally published on Legal Planet. Reprinted with permission.
The Project 2025 report is 920 pages long, but only a few portions have gotten much public attention. The report’s significance is precisely that it goes beyond a few headline proposals to set a comprehensive agenda for a second Trump administration. There are dozens of significant proposals relating to energy and the environment. Although I can’t talk about all of them here, I want to flag a few of these sleeper provisions.
But does Project 2025 even matter, you might ask? It’s true that Trump disavowed the report. Yet it comes with the imprimatur of a host of conservative organizations and involves many people with ties to Trump. It also echoes Trump’s priorities.
With all that in mind, here are six Project 2025 proposals that you probably haven’t heard much about. They involve reduced protection for endangered species, eliminating energy efficiency rules, blocking new transmission lines, changing electricity regulation to favor fossil fuels, weakening air pollution rules, and encouraging sale of gas guzzlers.
#1. Undermining endangered species protections
Project 2025 portrays the Fish & Wildlife Service as “the work of the Fish and Wildlife Service is the product of ‘species cartels’ afflicted with group think, confirmation bias, and a common desire to preserve the prestige, power, and appropriations of the agency that pays or employs them.” (Obviously they couldn’t just be underpaid public servants doing their best to implement the law.) In any event, the solution is to “reform” the Endangered Species Act so that it won’t stand in the way of real estate interests or economic development, by “restoring the rights of states over their wildlife populations” and ensuring that species preservation will take the backseat to development interests. Short of congressional action, the report advocates a bevy of administrative changes to weaken endangered species protections. [pp. 633-634]
#2. Axing energy efficiency programs
Project 2025 explains the Department of Energy’s energy efficiency programs very clearly: “Pursuant to the Energy Policy and Conservation Act of 1975 as amended, the agency is required to set and periodically tighten energy and/or water efficiency standards for nearly all kinds of commercial and household appliances, including air conditioners, furnaces, water heaters, stoves, clothes washers and dryers, refrigerators, dishwashers, light bulbs, and showerheads.” [pp. 378-379] Those standards save the average household about $320 per year. Given that there are about 130 million U.S. households, this means total consumer savings from DOE standards are around $46 billion a year. Project 2025 is opposed to those consumer savings, apparently.
#3. Stymying new transmission lines
Congress and the Federal Energy Regulatory Commission (FERC) have both taken actions to expand transmission, especially the big lines needed to redistribute energy generated in one state to users in other states. Since expanding would help even out fluctuations in local renewable energy generation, Project 2025 hates the whole idea. Letting more wind farms in Iowa sell electricity to Ohio, and the like, would make it “less economical” for “coal, nuclear, and natural gas to stay operational.” [pp. 404-406] That’s because the renewables would be cheaper. Despite Project 2025’s repeated references to grid reliability, the issue falls to the wayside when improving reliability would go hand in hand with expanded use of renewables. This is understandable given the report’s zeal for “American energy dominance” – Trumpian code for producing and using as much fossil fuel as humanly possible.
#4. Abolish energy markets or adjust them to favor fossil fuels
Conservatives used to believe in the free market, but Project 2025 seems quite skeptical of the idea of competitive electricity markets. It complains that, just as in ordinary product markets, the price is set by the most expensive producer in the market, rewarding those with cheaper production. Project 2025 views this as a bad idea because renewable generation gets to charge the same price as natural gas generators, which are pricier. The deeper problem, according to Project 2025, is with having competitive markets at all, as opposed to the more traditional scheme where utilities are controlled by state public utility commissions. [pp. 403-404] Short of returning to the good old days of monopolistic utilities, FERC should adjust prices to disfavor renewables because of their supposed lack of reliability. That will have what the report considers to be the happy consequence of giving fossil fuels an economic edge. [pp. 402-404]
#5. Crippling air pollution control
Given its passion for fossil fuels, it shouldn’t be a surprise that Project 2025 takes a dim view of pollution control. Consequently, it has a series of proposals to weaken limits on air pollution, especially from power plants, refineries, and cars. In general, Project 2025 maintains, “EPA’s structure and mission should be greatly circumscribed.” [p. 420] Specifically, the report calls for weakening protections against interstate air pollution [pp. 424-425] and toxic air pollution [427].
#6. Embracing gas guzzlers
Project 2025 calls for rolling back CAFE fuel efficiency standards to 2020 levels (35 mpg). Those standards are issued by the Department of Transportation. Since a 2007 U.S. Supreme Court decision, EPA has been charged with issuing CO2 standards for cars and trucks, which in effect require less fuel use. Project 2025 wants to change this. Standards for cars should be set by the Department of Transportation alone; EPA should limit itself to regulating emissions from automobile air conditioning systems. California should not be allowed to limit CO2 from cars either. [pp. 627-629] And the federal government should stop funding mass transit. [p. 636] I probably missed it, but I didn’t notice any reference to the fact that cars and trucks cause pollution.
Showing 2,833 results
Daniel Farber | October 24, 2024
The Project 2025 report is 920 pages long, but only a few portions have gotten much public attention. The report’s significance is precisely that it goes beyond a few headline proposals to set a comprehensive agenda for a second Trump administration. There are dozens of significant proposals relating to energy and the environment. Although I can’t talk about all of them here, I want to flag a few of these sleeper provisions. They involve reduced protection for endangered species, eliminating energy efficiency rules, blocking new transmission lines, changing electricity regulation to favor fossil fuels, weakening air pollution rules, and encouraging sale of gas guzzlers.
Robin Kundis Craig | October 15, 2024
The U.S. Supreme Court will test how flexible the EPA and states can be in regulating water pollution under the Clean Water Act when it hears oral argument in City and County of San Francisco v. Environmental Protection Agency on October 16. This case asks the court to decide whether federal regulators can issue permits that are effectively broad orders not to violate water quality standards, or instead may only specify the concentrations of individual pollutants that permit holders can release into water bodies.
Alice Kaswan, Catalina Gonzalez | October 9, 2024
Around the country, in blue states and red, policymakers are engaging in climate action planning, guided by a far-seeing Inflation Reduction Act funding program — the Carbon Pollution Reduction Grant (CPRG) program — which has devoted $250 million to state, metropolitan, and Tribal planning efforts. A new report from the Center for Progressive Reform, Environmental Justice in State Climate Planning: Learning from California, offers critical insights to help policymakers and advocates working on these plans translate climate goals into action and advance environmental justice.
Joseph Tomain | September 24, 2024
T.S. Eliot was wrong. April is not the “cruellest month.” June is. In slightly over two weeks at the end of June 2024, the United States Supreme Court made mass murder easier, criminalized homelessness, partially decriminalized insurrection, ignored air pollution and climate change by curtailing agency actions, made it more difficult to fine securities and investment frauds, and deregulated political corruption while failing to affirmatively protect women with possibly fatal pregnancies. To this list, add the Court’s July 1, 2024, ruling effectively giving Donald Trump a pathway to an authoritarian presidency by delaying his criminal trials and then, as extralegal protection, effectively immunizing him from the worst of possible crimes. How did we get here? Rena Steinzor's new book, American Apocalypse, makes an important contribution to the literature examining the Right by bringing together several movements that have landed us where we are today.
James Goodwin | September 19, 2024
A government that recognizes that it has an affirmative responsibility to address social and economic harms that threaten the stability of our democracy. An empowered and well-resourced administrative state that helps carry out this responsibility by, among other things, collaborating with affected members of the public, particularly members of structurally marginalized communities, while marshaling its own independent expertise. We believe that these are some of the core principles that should make up a progressive vision of an administrative state.
Sophie Loeb | September 17, 2024
On September 17, the Center for Progressive Reform published a new policy brief, Rising to the Challenge: How State Public Utilities Commissions Can Use the Inflation Reduction Act to Advance Clean Energy. This brief examines the ability of public utilities commissions (PUCs) to incorporate Inflation Reduction Act (IRA) funding into their energy planning processes in order to expand the uptake of renewable energy resources at a lower cost to consumers.
Minor Sinclair, Spencer Green | September 12, 2024
The summer of 2024 will be remembered for many things, but here at the Center for Progressive Reform, what most struck us was that it was the year that the administrative state broke through into public consciousness. From the unexpected virality of, and backlash against, Project 2025 — a massive right-wing legal manifesto as aggressive as it was arcane — to the Supreme Court regulatory rulings that made headlines for weeks, this year’s political news drove home that the work we do to protect the environment, the workforce, and public health matters very much to we, the people when these things are under attack. In this context, we approach the task of inviting new members to join us in our work with seriousness, but also with much excitement. This spring, we reviewed nearly two dozen exceptional candidates from the fields of law and public policy. Today, we are pleased to announce that we have a cohort of three excellent scholars to add to our ranks.
Grayson Lanza | August 8, 2024
Eastern North Carolina’s landscape is pocked with artificial lagoons holding a noxious liquid that causes suffering both for local residents and the global climate. The liquid? Hog manure, held in giant, open-air pits that are used by large-scale industrial facilities called concentrated animal feeding operations (CAFOs), In CAFOs, operators raise large numbers of animals in confined spaces that allow for easier feeding and waste management — and higher profits.
Federico Holm, Johan Cavert, Nicole Pavia | August 1, 2024
Building clean energy infrastructure quickly will be critical to avoiding the worst impacts of climate change while bolstering grid resilience and flexibility. Much of the discourse portrays infrastructure deployment as plagued by bureaucratic and legal holdups that should be eliminated or drastically curtailed in service of faster development — with the National Environmental Policy Act (NEPA) often taking sole blame for these delays. But is that really where the problem is? Our analyses suggest that solely blaming NEPA for permitting delays overlooks other contributing factors.