The release of Project 2025 sent ripples through the climate and environmental community—and for good reason. With Donald Trump now our President-elect and Lee Zeldin poised to lead the Environmental Protection Agency, I finally took the time to dive into this conservative playbook for the next U.S. presidential transition, and reviewed Trump’s past actions with an eye to potential impacts on climate litigation and accountability.
As my colleagues have already laid out, this 920-page document proposes a sweeping policy agenda to push the United States backward on climate action, environmental protection, and social justice. Building on the first Trump administration’s efforts to dismantle federal climate initiatives, Project 2025 is a blueprint for federal policies to favor and promote fossil fuels and weaken the federal government’s ability to regulate emissions. While the proposals are sobering and the potential impacts are hard to imagine, it’s essential to remember that the White House was never our only hope in the fight for climate accountability.
Science under siege
Effective climate governance, from policy to litigation, must be grounded in rigorous science. Project 2025, however, threatens this foundation by undermining scientists and the data they produce, a continuation of actions taken during Trump’s first term. The plan’s recommendations include policy changes that would stifle scientific research, sideline critical climate assessments, and discredit science as a guiding force for public policy.
For instance, it proposes directing the President to “critically analyze” and potentially reject assessments from the U.S. Global Change Research Program (USGCRP)—the body responsible for the National Climate Assessment, a key scientific resource. The USGCRP was established under a 1990 Act of Congress and provides a crucial scientific underpinning to help the nation understand and respond to climate change. It is specifically not policy prescriptive in its work. Labeling these findings as “political” risks concealing climate realities from decision-makers who need accurate, independent science to make informed and accountable decisions. By casting doubt on established science, Project 2025’s agenda does more than distort policy; it feeds the disinformation machine.
Further, the plan targets the Office of Oceanic and Atmospheric Research (OAR) within the National Oceanic and Atmospheric Administration (NOAA), dismissing it as a source of “climate alarmism” and calling for cuts. This mirrors efforts during the first Trump administration to dismantle advisory committees and limit agency expertise, for example disbanding the National Climate Assessment Advisory Committee, impeding vital research. NOAA’s high-quality, transparent data, which I and many others in climate accountability work rely on, is crucial for understanding and preparing for climate risks. My colleagues at UCS also use this data for analyzing risks to coastal communities from accelerating sea level rise, for example.
The implications of these policies extend beyond federal agencies. Such policies risk chilling the broader climate science landscape by pressuring institutions to self-censor or redirect research priorities. Preserving the freedom of scientists to produce unfiltered, meaningful research is essential for the legal and policy decisions needed to effectively address the climate crisis and hold responsible parties accountable.
A fossil fuel boost in Project 2025
At its core, Project 2025 aims to reinstate fossil fuels at the center of U.S. energy policy. Among its proposals are calls to dismantle the Office of Fossil Energy and Carbon Management (FECM) and to roll back carbon reduction initiatives. By sidelining these programs, Project 2025 equates “energy security” with fossil fuels – a continuation of policies from Trump’s first term. During his last term, the Trump administration systematically slashed research funding for renewable energy.
This approach would turn back the clock on recent progress toward sustainable energy and improved public health. Statements like “Stop the war on oil and natural gas” attempt to cast fossil fuel interests as under siege, flipping the narrative on who really bears the burdens of fossil-fuel reliance. But the truth is clear: fossil fuels are the largest contributors to climate change, and continued reliance on them will only exacerbate environmental and public health harms, especially in overburdened communities already facing high levels of pollution.
This agenda also brings to mind the deep-rooted connections between the fossil fuel industry and political leadership. During his previous administration, Trump appointed Rex Tillerson, then CEO of Exxon Mobil, as Secretary of State—a move that exemplified the administration’s close ties to fossil fuel interests. And during his victory speech after the election, Trump commented on Americans’ supply of “liquid gold.” And earlier this week Trump announced Lee Zeldin for EPA head who has already promised to roll back regulations on “day one,” strengthening Project 2025’s fossil fuel agenda and push for deregulation and fossil fuel expansion over environmental protections. Project 2025’s fossil-fuel-centric agenda reflects a similar alignment, prioritizing industry profit over environmental and public health protections and human and Indigenous rights.
The threat of reshaping the courts
Project 2025’s approach to reshaping the judiciary builds on Trump’s prior efforts to establish a more radical, deregulation-friendly bench. In his first term, Trump appointed 234 federal judges, including three Supreme Court justices who played a key role in shifting the court’s stance on issues like abortion rights and overturning the Chevron Decision. With a majority in the Senate, Republicans now have the leverage to confirm more ideologically aligned justices, potentially solidifying a majority that could restrict regulatory powers and limit climate-related rulings. This focus on judicial appointments prioritizes nominees inclined to curtail the authority of federal agencies, posing direct challenges to future climate litigation.
Reduced agency authority leads to fewer regulations across sectors, directly impacting the legal grounds for climate litigation. Regulations provide the essential benchmarks and standards that litigants use to demonstrate that companies, industries, or governments are falling short of legal obligations. With fewer or weakened regulations, plaintiffs may find it much harder to establish violations or hold parties accountable for environmental harm.
This shift away from regulatory accountability risks creating a legal landscape in which the responsibility to protect public health and the environment increasingly falls on state policymakers and attorneys general, or to communities and individuals who often lack the resources and legal standing to confront large-scale climate issues on their own. If this vision is realized, Project 2025 may establish a judiciary resistant to climate justice, reinforcing corporate interests at the expense of community health, environmental protection, and human and Indigenous rights.
Subverting science in the Department of Justice
The Department of Justice’s (DOJ) involvement in climate litigation can be pivotal, as illustrated by a recent Supreme Court request for the DOJ to weigh in a case brought by Honolulu against major oil and gas companies. This case, which accuses fossil fuel companies of deceiving the public about the climate impacts of their products, could set a major precedent for holding the industry accountable. The DOJ’s position, delivered by the Solicitor General, may help determine whether cases like Honolulu’s can proceed under state law, potentially leading to trials that confront fossil fuel companies over climate disinformation and bring additional evidence of corporate misconduct into the public domain.
Under the Trump administration, the DOJ took steps that limited the role of science in decision-making across environmental cases, aligning itself with industry interests and discouraging litigation that challenged regulatory rollbacks or lack of enforcement of existing laws. Project 2025 proposes a fundamental redirection of the DOJ, aiming to deprioritize cases it deems “special interests,” which could include those related to climate and environmental protection. This would continue the previous Trump administration’s pattern of downplaying scientific evidence that could support environmental protections.
For states, municipalities, tribes, youth groups and environmental justice advocates bringing lawsuits against fossil fuel companies, the DOJ’s support or opposition can shape whether their cases advance or are hindered. Without a DOJ committed to supporting these accountability efforts, plaintiffs may face steeper legal challenges, potentially undermining a growing movement for climate justice in the U.S.
Moving forward with realism and determination
Yes, Project 2025 is a devastating roadmap for deregulation and fossil fuel expansion, but it does not spell defeat. It’s a wake-up call—this agenda represents a particular worldview, and while it may influence federal policy, it will not entirely determine the course of climate action. During Trump’s first term, we witnessed the judiciary push back against anti-science actions, even under pressure to limit regulatory powers. As individuals, advocates, and communities, we have the power to shape our energy future and foster climate accountability —regardless of who sits in the White House. We are already starting to see plans to resist these changes. Democratic governors and attorneys general are strengthening state-level defenses against anticipated deregulation, signaling a readiness to uphold climate and social protections regardless of national policy trends
Even if federal support is reduced, climate litigation remains a growing and evolving field that doesn’t hinge on one source of data. State agencies, for example, have their own environmental standards and science departments, many of which can serve as substitutes or complements to federal resources. Municipalities and states are also increasingly involved in climate litigation, and innovative legal arguments—such as those centered around consumer protection or corporate fraud—may not require federal backing to proceed. Project 2025 could impact the flow of federal resources, but it does not mean an end to climate litigation.
Now is the time to reaffirm our commitment to a multi-layered approach to climate action. With a resilient and realistic outlook, we can continue to drive progress and expand the strategies that promote accountability. Project 2025 may aim to steer the conversation, but we hold the tools to push for accountability and continue building a climate-resilient future powered by clean energy that works for everyone.