In the wake of Donald Trump’s electoral victory Wednesday, climate policy in the United States enters an uncertain new era. Some themes are already apparent: Trump has pledged to scale up domestic fossil fuel production while making a broader push to deregulate industry. He also seems intent on scaling back the Inflation Reduction Act, the groundbreaking spending bill that has already built out clean-tech infrastructure and added thousands of green jobs (mostly in politically conservative states).
But how far will Trump go, and how exactly will his administration’s anti-environmental stance play out? That remains to be seen — and will surely depend on the counsel of senior staffers in his orbit. It’s too soon to say who those key appointees will be, and, as Heatmap’s Robinson Meyer points out, their policy positions won’t be monolithic. Just look at Elon Musk, the key Trump campaign ally and megadonor who appears poised to play an influential role in the White House, who also happens to be CEO of a famous EV company.
Yet judging from Trump’s track record and recent statements, antipathy toward environmental regulations and decarbonization incentives seems an all-but-certain theme. And many of Trump’s first-term appointees — including some potentially poised to return to power — have histories of active climate crisis denial and delay. Former Trump officials spent the past four years lobbying for energy companies (including those they had recently regulated) and contributed to the Heritage Foundation’s “Mandate for Leadership” document, the foundation of the now-notorious Project 2025 initiative. The Heritage-led effort, despite the once and future president’s feigned disavowals, features key contributions from his former staffers, including in sections that suggest dismantling the parts of government most focused on addressing climate change and environmental injustice.
Here are the individuals and organizations that may do the most to help shape the incoming administration’s energy and climate-related moves as well as the environmental policy priorities that Project 2025 outlines for each executive branch agency.
Key individuals
Andrew Wheeler: After leaving office as Trump’s second U.S. Environmental Protection Agency administrator, Wheeler spent much of his post-Trump tenure working for Virginia Republican Gov. Glenn Youngkin. But in April, Wheeler left government and joined the law firm Holland & Hart, which touted the benefits Wheeler could bring for its “energy and natural resources clients.”
During his stint leading the EPA, Wheeler came under fire for overseeing “favorable decisions” for his past lobbying clients, including fossil fuel giants like coal company Murray Energy and the utility Xcel Energy. The New York Times tracked over 100 environmental rules rolled back by the EPA under Trump, the majority on Wheeler’s watch.
Long before he took over the EPA, Wheeler worked for Sen. James Inhofe, R-Okla., a notorious climate denier. During his 2019 nomination hearing, which followed the resignation of Trump’s first EPA chief, Scott Pruitt, Wheeler said he would “not use the ‘hoax’ word myself” to describe climate change, but added he would also “not call it the greatest crisis.” Mandy Gunasekara, a Project 2025 co-author, backed a Wheeler return for Trump’s second term in a Nov. 1 New York Times interview.
David Bernhardt: A long-time oil lobbyist, Bernhardt replaced Ryan Zinke as Trump’s Secretary of the Interior in April 2019. “It’s not so much who has he helped; it’s who hasn’t he helped in industry so far,” Bobby McEnaney, a Natural Resources Defense Council analyst, told the Guardian in 2018 during Bernhardt’s nomination hearings.
In 2019, Bernhardt told Congress he hadn’t “lost any sleep” over rising greenhouse gas levels on his watch. He also shrank the Bears Ears and Grand Staircase-Escalante national monuments in southern Utah to allow drilling and mining (a move later reversed by President Joe Biden), called in National Park Service police to tear-gas peaceful civil rights protesters at Washington, D.C.’s Lafayette Square, undercut protections for endangered species — and much more.
In 2021, Bernhardt returned to Brownstein Hyatt Farber Schreck, the same law firm where he had worked for oil industry clients before joining the Trump administration. His past lobbying clients include the Independent Petroleum Association of America, the Freeport LNG Expansion, Targa Resources, Noble Energy, Halliburton and a host of other fossil fuel industry companies. Bernhardt is rumored to be a candidate for a “senior post” in the incoming Trump administration, according to E&E News.
Mandy Gunasekara: The former Environmental Protection Agency chief of staff under Wheeler, Gunasekara helped to drive environmental priorities for the Trump-Pence administration; in her bio on X, she has claimed to be Trump’s “top environmental person.” After leaving office, she became director of the Center on Energy and Conservation at the Independent Women’s Forum, a think tank with a history of taking obstructionist stances on climate progress.
Her career after government also included work as a senior fellow at the Texas Public Policy Foundation, the think tank that current Heritage Foundation CEO and Project 2025 mastermind Kevin D. Roberts spent much of his career leading. Gunasekara wrote Project 2025’s chapter on the EPA, where she accused the agency of saddling industry with “costly, job-killing regulations,” and proposed rolling back greenhouse gas emissions standards and reporting protocols as well as a sweeping agency reorganization that includes axing the office overseeing environmental justice. She also wrote “Y’all Fired,” a forthcoming book proposing to reshape federal oversight using mass layoffs.
Bernard McNamee: The author of Project 2025’s plans for the Department of Energy and “related commissions,” McNamee was first nominated to serve as one of five Federal Regulatory Energy Commission (FERC) commissioners by Trump in 2018. After leaving FERC in September 2020, McNamee returned to the law firm McGuireWoods where, according to his LinkedIn profile, he now “assists clients with rulemakings before federal agencies, including FERC, USDOE and EPA.” While most of those clients aren’t publicly known, they appear to include Dominion Energy, a utility company that still runs on coal, natural gas and oil. McNamee has been registered as a lobbyist for the company in Virginia since December 2023. (Dominion denied any involvement in Project 2025 in a statement to Virginia Public Media in August.)
It’s not McNamee’s first time spinning through the revolving door between regulator and industry. Before arriving at FERC, he spent 10 months as a deputy general counsel at the Department of Energy. Upon leaving that job, he ran the Texas Public Policy Foundation’s pro-fossil fuel Life:Powered initiative for about four months — then returned to DOE, where he briefly directed the office of policy.
“There’s an organized propaganda campaign against fossil fuels,” McNamee said in 2018, speaking at a Texas Public Policy Foundation event, according to video unearthed by the Energy and Policy Institute. “You talk to people in corporate boardrooms now. They’re all buying into this.”
Key organizations
In the sections of Project 2025’s “Mandate for Leadership” that deal directly with climate, staffers from a handful of organizations play an outsize role — suggesting their influence within conservative politics, and their likely relevance to the incoming administration. The organizations that specifically helped to craft Project 2025’s climate agenda include several tracked by DeSmog, especially:
The Heritage Foundation: Forty-seven of Project 2025’s 233 contributors gave their Heritage Foundation affiliation, including contributors to sections on the Department of Energy, Interior, Transportation, Commerce and the Treasury — all of which push for climate-related policy changes.
Heritage Foundation president Kevin Roberts wrote the foreword to the Project 2025 Mandate for Leadership. Roberts was CEO of the Texas Public Policy Foundation, another long-time part of the Koch network with a history of climate denial, before he took the helm at Heritage in 2021. “We are in the process of the second American Revolution, which will remain bloodless if the left allows it to be,” Roberts said on Steve Bannon’s radio show in July.
In 2016, Heritage was nicknamed Trump’s “Shadow Transition Team.” Their 2024 directors include Diana Furchgott-Roth, author of a 2022 Forbes post on climate change, in which she claimed that “some research shows little change.”
Competitive Enterprise Institute: Eight Project 2025 contributors listed their Competitive Enterprise Institute affiliations, making CEI the third-most represented organization in Project 2025’s plans for the incoming Trump administration.
CEI’s representatives contributed to Project 2025’s sections on the Department of Energy, the Treasury, the Department of Commerce and trade policies — all of which discuss climate change or carry implications for the climate.
In 2016, CEI’s then-leader Myron Ebell (who spent nearly 25 years at CEI before retiring this year) led Trump’s EPA transition team. “CEI questions global warming alarmism,” the organization wrote in 2016, as DeSmog notes in the group’s Climate Disinformation Database profile, adding that it opposed “EPA regulation of greenhouse gas emissions.”
Today, CEI calls itself “instrumental in fighting decades of climate alarmism.” The organization credits itself with leading coalitions that defeated ratification of the Kyoto Protocol in 1997, stopping a major cap-and-trade bill in 2009, and “convincing President Trump to withdraw from the 2015 Paris climate treaty.”
Texas Public Policy Foundation: Brent Bennett, policy director of TPPF’s Life:Powered initiative, contributed to Project 2025’s Energy Department discussion. In addition to its long-running ties to the Koch network, TPPF has also been funded by major oil corporations, including Shell (which funded many other groups involved in Project 2025, DeSmog revealed in August) and ExxonMobil.
At a TPPF event this summer, Benny Peiser, the director of the Global Warming Policy Foundation, “claimed that net-zero ‘requires governments to become authoritarian,’” DeSmog reported in June.
Institute for Energy Research: The Institute for Energy Research’s long-time leader Tom Pyle, who also runs the advocacy group American Energy Alliance, was one of the contributors to Project 2025’s section on the Department of Energy. IER’s Dan Kish is also acknowledged as a contributor to Project 2025’s discussion of the Interior Department.
“Both Pyle and his firm have lobbied for the National Petrochemical & Refiners Association (now the American Fuel & Petrochemical Manufacturers, or AFPM) and for Koch Industries,” DeSmog’s profile on Pyle notes.
Pyle previously worked to shape the first Trump administration’s energy policies as head of Trump’s transition energy team, as DeSmog reported in December 2016.
Trump went on to pursue many of the goals called for in Pyle’s 2016 “Trump Administration Energy Plan,” including backing out of the Paris Agreement, increased oil and gas leasing on federal lands, and rolling back fuel economy standards, which was a major priority of Pyle client AFPM.
Western Energy Alliance: In the footnotes to Project 2025’s chapter on the Department of the Interior, author William Perry Pendley reveals that “Kathleen Sgamma, Dan Kish, and Katie Tubb wrote the section on energy in its entirety.” Sgamma is president of the Western Energy Alliance. (Tubb is a former Heritage Foundation policy analyst, and Kish, as noted above, is with IER.)
Western Energy Alliance is an oil and gas trade group. It calls itself “the unified voice and backbone for independent oil and natural gas companies in the West,” and the group represents hundreds of oil and gas companies. Under the first Trump administration, the Western Energy Alliance was involved with a possible plan to move control of oil and gas development on federal lands to the states.
Other groups contributing to Project 2025 chapters that discuss climate change include the Koch-linked Americans for Prosperity, Reason Foundation and Mercatus Center.
Policy priorities
So what exactly do many of these groups want from a second Trump term? Project 2025’s Mandate for Leadership plan organizes its demands for rolling back environmental protections and preventing climate action into chapters, each covering its plans for executive branch agencies, including:
The Environmental Protection Agency: (Section author: Mandy Gunasekara, see above) Project 2025’s plan for the EPA would effectively “cut any program focused on climate, limit the agency’s ability to regulate under both the Clean Air Act and Clean Water Act,” slash environmental justice programs, revive the ‘secret science’ proposal from Trump’s first term, undercut the Inflation Reduction Act and more, as Drilled’s Amy Westervelt summarized it.
And that’s not all. Project 2025 also seeks to gut the National Environmental Policy Act (or NEPA, one of the nation’s bedrock federal environmental laws) as well as the Endangered Species Act. “The President should instruct the [White House council on environmental quality] 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,” Gunasekara wrote, referring to Trump’s bid to single-handedly slash permitting regulations just before the 2020 election.
Department of Energy and Related Commissions: (Section author: Bernard L. McNamee, see above) “End the focus on climate change and green subsidies,” McNamee wrote in the mandate. “Eliminate energy efficiency standards for appliances.”
“End grid planning,” he added, faulting DOE’s electricity grid planning as working “for the benefit of renewable resources or supporting low/carbon generation.”
Project 2025’s DOE recommendations also include dismantling efforts to combat racism in the energy sector and unfair impacts from pollution on communities of color, dismissing energy justice as “politicized social agendas.”
DOE’s Office of Fossil Energy should be revived, it adds, “with its original mission: increasing energy security and supply through fossil fuels.”
Not all of Project 2025’s plans are likely to draw support across the oil and gas industry, however. McNamee also proposed scrapping the controversial 45Q carbon capture tax credit, whose biggest expected beneficiaries include oil and gas companies such as Occidental and BP.
Treasury: Project 2025’s section on the Treasury was co-authored by Steven Moore, a Heritage Foundation senior fellow and co-author with Sgamma of a pro-fracking book titled “Fueling Freedom: Exposing the Mad War on Energy.”
“The next Administration should eliminate the Climate Hub Office and withdraw from climate change agreements that are inimical to the prosperity of the United States,” Project 2025’s section on the Treasury Department proposes.
Interior: Written mostly by Pendley (who, a federal court found in 2020, illegally ran the Bureau of Land Management under Trump), Project 2025’s Interior Department section covers major federal agencies with big impacts on oil, gas and coal. That includes agencies such as the Bureau of Safety and Environmental Enforcement, which is tasked with regulating offshore oil and gas drilling to prevent oil spills and protect worker safety, the Office of Surface Mining Reclamation and Enforcement, U.S. Fish and Wildlife, and the U.S. Geological Survey.
“Given the dire adverse national impact of Biden’s war on fossil fuels, no 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,” Project 2025 claims. (Under Biden, the United States became the world’s top exporter of liquefied natural gas and the top producer of oil globally.)
Department of Transportation: In a chapter written by Diana Furchgott-Roth, Project 2025 calls for making cars less fuel efficient by unwinding fuel economy requirements, preventing the EPA from playing a role in carbon dioxide emissions from vehicle engines and revoking California’s unique ability to set stricter fuel economy standards.
Department of Commerce: The National Oceanic and Atmospheric Administration is a Commerce Department agency that houses the National Weather Service and many climate, environmental and ocean research offices — and Project 2025 has a simple plan for NOAA: elimination.
The agency “should be dismantled and many of its functions eliminated, sent to other agencies, privatized, or placed under the control of states and territories,” Project 2025 says.
International Development Agency: “USAID should cease its war on fossil fuels in the developing world and support the responsible management of oil and gas reserves as the quickest way to end wrenching poverty and the need for open-ended foreign aid,” Project 2025’s plan demands. “The agency should cease collaborating with and funding progressive foundations, corporations, international institutions, and NGOs that advocate on behalf of climate fanaticism.”
Securities and Exchange Commission: If Project 2025’s backers have their way, the SEC will be required to “oppose efforts to redefine the purpose of business in the name of social justice; corporate social responsibility (CSR); stakeholder theory; environmental, social, and governance (ESG) criteria; socially responsible investing (SRI); sustainability; diversity; business ethics; or common-good capitalism.”
Department of Justice and the Federal Communications Commission: In addition to direct attacks on climate policies, the new administration is expected to “turn the Department of Justice and the Federal Communications Commission against the media, which will entail a raft of leak investigations, the politicization of broadcast licenses and antitrust litigation, and the potential indictment of journalists for espionage,” according to the Columbia Journalism Review. “Reporters covering protests and immigration enforcement will face detention from not just local police, but the Department of Homeland Security. It’s possible that Trump may even seek congressional action to reform libel laws or otherwise criminalize dissent.”
Project 2025 urges the Justice Department to “use all of the tools at its disposal to investigate leaks” while its FCC chapter calls for the unwinding of media ownership rules designed to keep the press independent by limiting the number of broadcast stations that one corporation can own.
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