EPA Science Under a Second Trump Term
Plans from Trump's Allies Would Demolish Environmental Protections
A second term of Donald Trump as president could begin with swift and clear direction on science at the Environmental Protection Agency (EPA). In summary, “Off with her head!”
While the Trump 2024 campaign has not publicly posted any formal policy plans, a roadmap has been crafted for him - led by the Heritage Foundation - should he win the 2024 election. Project 2025 is a collection of policy proposals that would reshape the Executive Branch - agency staff, offices, and policy priorities - in the event Trump wins the 2024 election. Crafted by several nonprofits, Project 2025 cannot endorse a political candidate, but its authors include several former Trump advisers. Reviews of Project 2025’s environmental policy plans thus far include:
“If enacted, it could decimate the federal government’s climate work, stymie the transition to clean energy and shift agencies toward nurturing the fossil fuel industry rather than regulating it.” – Scott Waldman, E&E News
“It’s a potential future that horrifies experts.” – Dharna Noor and Oliver Milman, The Guardian
“This sort of approach on climate is not acceptable to the next generation.” – Benji Backer, American Conservative Coalition
“I think it would be devastating.” Michael Gerrard, Sabin Center for Climate Change Law
The policy plan for the EPA was written by Mandy M. Gunasekara - the EPA Chief of Staff under former President Trump. I read all 32 pages of the policy proposal for EPA and break down the plans for science at the agency below. Should Trump win the 2024 election and follow this roadmap, it will demolish environmental science at the agency.
Restricting science EPA can use
Falsely calling for transparency to restrict science-based policy making
Project 2025’s proposed plans for EPA discuss making science fully transparent. But what do they mean by transparent?
Under the former Trump administration, “transparency” was used as a guise to restrict the science the EPA could rely on for rules and regulations. The “Strengthening Transparency in Pivotal Science” rule called for data, including raw data from individuals in public health studies, relied on by the EPA in rulemaking to be made publicly available. Of course, those proposing this rule knew full well that EPA cannot, by law, make individual health information available. So, in essence, this rule was a means to restrict the science EPA could use in rulemaking.
The proposed plan for EPA in Project 2025 suggests using the same strategy calling for all data resulting from taxpayer-funded activities to be made publicly available. Project 2025’s proposed plans for EPA repeat a long-standing tactic that would severely restrict the ability of the EPA to make sense-based decisions under the guise of supposed public access to science. In claiming the plan is for greater “transparency” in government, the tactic comes directly from the tobacco industry’s playbook in fighting regulations on second-hand smoke.
To be clear, science shouldn’t be kept secret. Scientists often share published materials freely, and in many cases are mandated to make underlying analyses and data available if receiving funding from a government agency. But requiring the raw data underlying a study’s analyses to be publicly available just doesn’t make sense for confidentiality purposes and because non-experts wouldn’t be able to use the data. This is why we have a peer-review system in science so that experts can vet data analyses in the study before it is published.
If Trump wins the election and follows this roadmap, I fully expect us to see another attempt by the EPA to pass a rule that will restrict the scientific research the agency can use in rulemaking. If passed, it would be a major blow to regulating toxic emissions hazardous to public health, and it would be especially harmful to EJ communities.
Using public comments to restrict science and delay rules
Project 2025’s EPA plan suggests taking comments on all scientific studies and analyses that support regulations. The plan also recommends deputizing the public to scrutinize agency science. Sounds sensible and “transparent” right? But it isn’t. It’s another old zombie tactic for delay touted by polluting industries.
Nearly everyone has access to the internet nowadays, but this does not make everyone an expert. Opening a comment period on all scientific studies and analyses for every regulation would be a huge waste of time. The rulemaking process is already extraordinarily slow - this strategy would slow it down even further. But that’s likely the intended outcome.
There already is a system of peer-review in-place so that scientific research and analyses can be vetted by other experts. Introducing non-experts into the mix wouldn’t make sense - what could they possibly add? Would you want someone walking in and performing the extraction of your wisdom teeth because they “watched enough videos on YouTube?” No. You would not. There are lots of opportunities for the public to engage with scientists and with science-informed policies - scrutinizing scientific studies and analyses that serve as the bedrock of critical government regulations is not one of those opportunities.
Tossing out scientists
Restructuring scientific advisory committees
Across the government, agencies rely on the independent advice of scientific advisory committees which are made up of experts on a particular issue area. For example, the Food and Drug Administration’s Vaccines and Related Biological Products Advisory Committee (VRBPAC) played a vital role in ensuring the COVID-19 vaccines were effective and safe. These committees are important bodies of experts that make sure agency decisions are informed by sound science.
Under the Trump administration, scientific advisory committees were constantly under attack. The former president even passed an executive order to cut advisory committees by one-third - an arbitrary number. The administration also restructured the makeup of committees including more industry representatives as compared to the makeup of committees in prior years.
The plans in Project 2025 seem to adopt the same strategies as described above. The plans mention resetting science advisory boards to “expand opportunities for a diversity of scientific viewpoints.” The plan also calls for the suspension and review of EPA advisory bodies. If these strategies are executed, policy decisions by agencies will likely be based more on what helps industry make more money rather than what science says keeps people healthy.
Downsizing the scientific workforce
Because of the former administration’s disdain for science, many agency scientists left their positions either through quitting or retiring. As I previously wrote in an op-ed for The Hill: “These losses are frightening because these scientists do critical work on issues like COVID-19 vaccine development, protections for clean air and water and our ability to combat climate change. In other words, these decisions affect all of us.”
The EPA lost 672 scientists, or approximately 6% of their scientific workforce, under four years of Trump. But the agency has rebuilt that workforce during the past four years to similar numbers seen under President Obama, which were already lower than in prior years. If the EPA is to effectively fulfill its mission of protecting public health and the environment, and tackling dire issues like the climate crisis, then it needs a robust and healthy scientific workforce.
Project 2025’s plans suggest that EPA’s workforce should be downsized. The plan mentions cutting new hires in “low-value programs” and relocating SES employees (another tactic used by the former administration to remove scientists and their work). The plan takes issue with EPA’s Office of Research and Development’s (ORD) 2023 request to expand its scientific workforce suggesting the office’s request is a “dramatic increase.” The plan also recommends relocating all of EPA’s regional offices – a strategy used before at two offices within the Department of Agriculture (ERS and NIFA) which led to a 75% decrease in staff and the delayed publication of dozens of research reports.
Under a second Trump term, I suspect that the scientific workforce would be significantly downsized, especially at the EPA. This would mean that an agency that is already overburdened with important scientific work would be further limited by capacity. At a critical time that EPA is needed to help tackle the climate crisis, a dwindling scientific workforce means the agency won’t be able to do much.
Stop certain scientific research and funding
The first week of the Trump administration saw a freeze placed on all grant funding. Later investigations reported that senior leaders at EPA ordered a halt on funding any and all grants that mention “the double C word.” Ongoing research on the safety of fossil fuel use that the National Academies of Science, Engineering, and Medicine was commissioned to conduct were halted - an unprecedented action. The administration was cherry picking research that it wanted the government to undertake, and removing the research that they didn’t see as a priority.
Project 2025’s EPA proposal doesn’t mention specific scientific research, but it takes issue with agency research that hasn’t been given the stamp of approval by Congress. But Congress should not be in control of what agency research needs are - only the scientists themselves would best understand those needs. We shouldn’t be blocking agency scientists from conducting research that they know is needed for the EPA to fulfill its mission. Congress doesn’t have the time nor the authority to conduct such oversight.
If Congress were given the authority to determine what science should be prioritized by agencies, our world’s scientific needs would be greatly delayed. Depending on the makeup of Congress, they could deem all climate change research as not needed. Unfortunately, such a scenario may not be too far from realistic as the Supreme Court decides the fate of Chevron Deference this year.
Remove Scientific Integrity
A failed response to the COVID-19 pandemic with nearly 400,000 deaths as Trump left office drove the Biden administration to quickly initiate a process to strengthen scientific integrity across government. A common definition for scientific integrity was adopted by an interagency task force as well as a framework to be utilized by all federal agencies in developing or updating scientific integrity policies. An already strong policy from the EPA was updated and now offers even stronger protections for scientists and their work.
Project 2025 calls for scientific integrity cases to be handled by an independent body other than the Office of Scientific Integrity. But here’s the thing is that there are other bodies independent of the EPA’s Office of Scientific Integrity that do weigh-in, if needed, on misconduct cases including the Office of Inspector General as well as the National Science and Technology Council’s subcommittee on scientific integrity. Another independent body would be redundant, and who would they be, who would choose them? The administration? Seems like that would be a huge conflict of interest. Scientific integrity officials are deeply steeped in the issue spending years studying scientific integrity, adjudicating cases, and discussing the issue with other agencies. Let these experts do their job.
Same strategies in a new year
In conclusion, there really isn’t anything new here, but these strategies would destroy EPA science and the policies that depend on that science. We know this as we’ve seen it happen before. And maybe it’s just four years of attacks on science, but the damage that is done takes another four years to undo, at least. With some science-based issues, like the climate crisis, four years is a lot of time to not make progress.
The prior Trump administration was mired in controversy, but it’s expected that this won’t be the case if Trump sits at the helm again in 2025. The training wheels will be off. And that’s scary for science because it means that the attacks will likely be more effective. The result will be a sicker public and environment.
I appreciate the focus on the EPA, but I fear these issues will affect science-based agencies across the federal government at a time when we can least afford it.