‘Project 2025’ Would Be Disastrous for Our Nation and Our Climate

June 14, 2024 | 10:20 am
Allison Cain/UCS
Rachel Cleetus
Policy Director

The Heritage Foundation’s “Project 2025” is a dangerous and detailed guide to undermining our democracy and a broadside attack on our health and well-being, not to mention our economic prosperity. Among other things, it takes specific aim at the federal government’s ability to address the climate crisis and instead doubles down on actions to worsen it. Anyone sobered by the relentless rise in global average temperatures and the spate of devastating and costly extreme weather and climate disasters we’ve been experiencing, anyone who thinks policies to benefit the public should be informed by robust, independent science, should take this threat very, very seriously.

Project 2025 has four pillars: a policy agenda, a Presidential Personnel Database, a Presidential Administration Academy, and a (yet to be released) playbook for the first 180 days of the next Administration. For the purposes of this blogpost, I will focus on the policy agenda.

So, what’s in this 920-page monstrosity of a document?

The first thing that strikes one as one reads the policy agenda document is that it is rooted in opposition to many hard-fought social gains, especially advances in civil rights, and instead panders to the interests of the rich and powerful. The document is littered with harmful mischaracterizations and attacks against the rights of Black, Brown and Indigenous people, women, LGBTQ+ people, people forced to migrate, and more. While claiming to uphold the interests of ordinary people, the document seeks to eviscerate protections crucial to guarding against money and power being the ultimate arbiters of policy decisions.

Another strong undercurrent is the attack on multilateral organizations and our nation’s interest in, and responsibility for, helping to solve global challenges through diplomacy and fair, joint agreements. Instead, an insular and militaristic approach emerges from the document—one that would take us back to a nasty, brutish world order, completely out of step with what this moment in time calls for. In a deeply interconnected world with complex global challenges—including the threat of autocratic governments and the dangerous proliferation of misinformation and disinformation—rising above short-sighted self-interest and working together with other nations is essential to our shared well-being.

Quite simply, the recommendations, which are listed agency-by-agency, are designed to undermine the institutions and governance structures our democracy relies upon to protect the public interest. If implemented, “Project 2025” would make addressing issues like climate change—which touches practically every aspect of our lives and is an urgent, collective global challenge—practically impossible.

Cliched phrases like “woke agenda” and “climate fanaticism” are used liberally throughout the document, demonstrating the unseriousness of the proposals and the intended targets of this destructive agenda.

Below are a few specific examples that highlight the harms, using direct quotes from the document (Fair warning: these quotes contain highly misleading or downright false information!):

  1. Attacks on the process of advancing climate science to inform policymaking

In a blatant effort to politicize climate science, Project 2025 states that ‘The President should also issue an executive order to reshape the U.S. Global Change Research Program (USGCRP) and related climate change research programs… The next President should critically analyze and, if required, refuse to accept any USGCRP assessment prepared under the Biden Administration. Downsize the Office of Oceanic and Atmospheric Research…’ And then it goes on to spread disinformation: ‘OAR is, however, the source of much of NOAA’s climate alarmism. The preponderance of its climate-change research should be disbanded.’

Here are the facts: The USGCRP is tasked by Congress (under the 1990 Global Change Research Act, passed under the Bush administration) to produce regular updates on the state of climate science via the National Climate Assessment (NCA), with the Fifth NCA being released last year. As my colleague Rachel Licker and former UCS-er Andrew Rosenberg point out in this blogpost, the NCA provides exactly the kind of information policymakers need, without being policy-prescriptive. The NCA is produced through the work of hundreds of scientists, relying on research done by thousands more. It is not a political document. Suggesting that a new President “critically analyze” the work of scientists or reject their work just because it was done under a different administration is a blatant attempt to politicize science and would leave us all worse off.

NOAA scientists are doing essential work to keep us safe, including generating the science we need to understand and prepare for the rapidly worsening impacts of climate change. Good governance and leadership require facing hard facts—like the reality of climate change—head-on and taking decisive action to address problems rather than pretending they don’t exist.

2. A polluting fossil-fueled energy agenda

Unsurprisingly, Project 2025 also pushes for more fossil fuels, with statements like ‘Affirm an “all of the above” energy policy…’  and ‘Support repeal of massive spending bills like the Infrastructure Investment and Jobs Act (IIJA) and Inflation Reduction Act (IRA).’ And in an appalling twist on reality, it includes a call to ‘Stop the war on oil and natural gas’—when in fact, it is big oil and gas corporations that are waging a war on our climate and health.  

The facts are clear that fossil fuels—coal, oil and gas—are the leading cause of climate change and also cause air, water, and soil pollution that imposes an enormous public health and environmental burden. Yet the authors of this policy document are intent on promoting fossil fuels and protecting the massive profits of the fossil fuel industry at any cost. Rolling back the IIJA and the IRA—which are already delivering tremendous benefits to working people around the country while boosting clean, affordable energy, in red states and blue— is just plain perverse. A transition to a clean energy economy is not just good for the climate, it’s good for our economic prosperity and well-being, as our research shows.

3. Attacks on the National Environmental Policy Act (NEPA)

Project 2025also launches a broadside attack on our nation’s bedrock environmental law, NEPA: ‘The President should instruct the CEQ to rewrite its regulations implementing NEPA along the lines of the historic 2020 effort and restoring its key provisions such as banning the use of cumulative impact analysis.’

The National Environmental Policy Act (NEPA) was originally signed into law by President Nixon in 1970 and is considered the Magna Carta of federal environmental laws, as my colleague David Watkins writes. And consideration of cumulative impacts has been part of it dating back to at least 1997.  This must remain the case. Public health science and the lived experience of overburdened communities shows that the combined effect of pollution from multiple sources accumulating over time and concentrated in communities is much more harmful to health and the environment than any single pollutant or source measure would indicate. Cumulative impacts analyses and policies better reflect reality—and they can be more efficient in capturing the impacts of multiple sources and pollutants than addressing them one by one.

The 2020 actions to gut NEPA, including by removing mention of cumulative impact analysis, were far from being historic and might more accurately be called infamous. They were also completely at odds with long-standing bipartisan support of this bedrock protective law. The CEQ has recently restored those provisions and updated NEPA in line with requirements of the bipartisan permitting reform rule passed last year. Reversing these changes would once again set back progress on protecting people’s health and the environment and would quite simply be a massive giveaway to polluting companies and a waste of taxpayer resources.

4. Attacks on international climate finance aligned with climate and development goals

On the global dimensions of the climate crisis, Project 2025 completely distorts the facts and cynically pits the imperative to alleviate poverty against the twin imperative to limit the disproportionate impacts of the climate crisis on those who have the fewest resources: ‘The Biden Administration’s extreme climate policies have worsened global food insecurity and hunger. Its anti–fossil fuel agenda has led to a sharp spike in global energy prices.’

Global energy prices have little to do with climate policies and instead price spikes and volatility are driven by global supply and demand factors, weather, and geopolitics (e.g., in the recent past, events like Russia’s unjust war on Ukraine and the macroeconomic impacts of COVID-19). Meanwhile, devastating climate impacts—including multi-year drought, extreme heat and flooding—have had significant impacts on people’s health, livelihoods, and food and water availability around the world, including for people in Africa (which the document repeatedly references). The latest IPCC report shows that these impacts are likely to worsen as climate change accelerates.

Addressing poverty and climate change together, instead of pitting these goals against each other, is vital. Setting up this false dichotomy exposes how little the authors truly care about or understand what’s needed to protect the well-being of people who are at risk of being driven further into poverty by the ravages of climate change, as research from the World Bank and the International Monetary Fund show. According to the World Bank’s estimates, “Climate change could drive 68 million to 135 million into poverty by 2030. Climate change is a particularly grave threat for countries of Sub-Saharan Africa and South Asia — the regions where most of the global poor are concentrated.”

As the largest historical contributor to global heat-trapping emissions, and a relatively rich country, the U.S. bears responsibility for providing climate finance to help lower income nations cope with climate impacts and transition away from fossil fuels. Addressing these issues domestically, too, in a fair way is critical. Within the U.S., it is the relatively rich who are most responsible for carbon emissions and have benefitted the most from the fossil fuel-dependent economy. They should help ensure a just and equitable transition to clean energy that protects the well-being of fossil fuel-dependent workers and communities and frontline communities overburdened by pollution from fossil fuels.

5. Eliminating the Use of the Social Cost of Carbon (SCC)

In yet another blatant attempt to prop up the fossil fuel industry and pretend away the reality of climate change, Project 2025 says that ‘The President should eliminate the Interagency Working Group on the Social Cost of Carbon (SCC), which is cochaired by the OSTP, OMB, and CEA, and by executive order should end the use of SCC analysis.’

Climate change is costly, there’s no question about that. Right now, those costs are borne by all of us, not the fossil fuel industry that’s profiting from its climate-destroying products and its decades of deception that have delayed the transition to clean energy. The social cost of carbon is a widely accepted economic metric that puts a dollar value on the damage caused per ton of carbon, allowing us to set policies that take those costs into account. In economist-speak, this is just a commonsense way to correct a market failure and internalize the externality costs of fossil fuels. The National Academies of Sciences has advocated for updates to the social cost of carbon, and the Environmental Protection Agency has recently undertaken an update to the SCC based on the latest science and economics. The EPA’s update has undergone rigorous independent external peer review.

Trashing all this careful work and ending the use of the SCC does not change the fact that climate change is expensive. Just ask anyone who’s lost their home to an extreme wildfire or to coastal flooding exacerbated by sea level rise—risks that are set to accelerate with fossil-fueled climate change. Or think about the millions of dollars at risk in lost wages or health costs for outdoor workers on extreme heat days. Burying the facts doesn’t change them but it can adversely affect policies we must enact to cut the heat-trapping emissions driving climate change. Again, we lose, and the fossil fuel industry wins if the SCC is eliminated.

6. Prohibitions on Treasury and SEC actions to account for the financial risks of climate change

Project 2025 is more interested in promoting fossil fuels and protecting the profits of the fossil fuel industry and its allies, rather than protecting the financial stability of our economy, as these excerpts show:

‘The next Administration should use Treasury’s tools and authority to promote investment in domestic energy, including oil and gas. It should reverse support for international public- (and private-) based efforts promoting Environmental, Social, and Governance and Principles for Responsible Investment, both of which have badly damaged U.S. energy security.’ And: ‘Congress should: Prohibit the SEC from requiring issuer disclosure of social, ideological, political, or “human capital” information that is not material to investors’ financial, economic, or pecuniary risks or returns.’.

Once more, the intent could not be clearer: rather that ensure that fossil fuel companies disclose the material risks their products pose to our climate and economy, and investors’ exposure to those risks, the report’s authors prefer to protect short-term corporate profits over the stability of the financial system. As my colleague Laura Peterson writes, opposition to ESG mandates is ‘largely whipped up by dark money groups connected to the fossil fuel industry.’

SEC-mandated climate disclosure for public companies was long overdue, and the final rule fell short of what is needed. Yet opponents including the US Chamber of Commerce sued to block the rule, and the SEC has recently paused enforcement. A group of legislators is nevertheless urging the SEC to move forward in as robust and expeditious a way as possible, noting that ‘Investors need access to climate risk disclosures that are reliable, standardized, and easily accessible to properly assess the risks associated with their investments. Climate change is transforming the economy, increasing mitigation and resilience costs and risks from weather and supply chain disruptions for all businesses.

There is so much more that is egregious in the Project 2025 policy agenda, it’s quite honestly stomach-churning to contemplate. Let’s hope it never gets beyond a theoretical exercise in how to destroy our country and leave our children’s futures dark and uncertain. Fortunately, science, democracy and justice provide a much better path forward.