Project 2025’s Assault on EPA, Human Health and the Environment Must Never Be Put into Action

Dismantling the EPA

The Heritage Foundation’s blueprint—Project 2025—to dramatically alter the US Environmental Protection Agency should concern you. It does me.

Water Pollution and Orcas

This summer my family vacationed in Vancouver, BC, Canada where we had the good fortune of going on a whale watching trip and seeing majestic orcas. I’ll never forget witnessing how a family moved around hunting their prey—sea lions—and celebrated by springing out of the water.

The trained marine biologist guides shared that water pollution in the Pacific Ocean and local bay have contributed to the population’s decline, and they talked about what is being done to improve it. As it turns out, most orcas’ first-borns are miscarried. Why? Because they sit at the top of the food chain, and the toxic load in their systems needs to be expelled somehow. Nature has created a system, through their offspring, to expunge it.

Chemical-related Diseases

This made me think of the increasing numbers of people of all ages in my life and in communities across the country suffering from diseases linked to toxic chemicals. PFAS is shorthand for a class of “forever chemicals” that persist in the environment indefinitely. This, along with many other chemicals, like diesel particulates and ground-level ozone that form soot and smog, and metals like lead in paint and drinking water, are regulated by the EPA to keep us safe. Project 2025 takes aim at all those protections.

Dismantling the EPA

The Blueprint would institute a major reorganization at the EPA that would slash full time positions, cut entire departments and programs deemed “duplicative, wasteful or superfluous.” Parts of EPA that historically had been run by career experts would instead be run by political appointees making decisions based on ideology, rather than science.

Further, the Blueprint calls for rotating headquarters senior executives to regions in several places. And, there is the overarching specter of the next administration working to implement a new category of executive, Schedule F, and moving many existing staff into it, stripping them of their civil service protections, undermining career civil servants who provide continuity of leadership and allow the next administration to replace them with political appointments. If you’ve ever lived through a major shift in management, you know how much it affects the organization’s ability to deliver on the mission—and in the case of the EPA, that mission is crucial to protecting the health of people across the nation. This transition plan would be moving not only desks, but floors, ceilings, windows, and fire exits.

Impact on Grants

Project 2025 takes aim at grants, as well. Grants are an important tool that agencies have used for decades to support environmental progress, such as for cleaning up waterways and contaminated land from legacy pollution, delivering safe drinking water, and limiting air pollution.

For one thing, many regulatory functions are delegated to the state, tribal, and local levels. It shifts management of the office that oversees grants administration to a political appointee whose motivations would no doubt be more about political expediency than fiscal responsibility.

It also suggests that funds going to nonprofits that support implementation of laws, especially in places where there are disproportionately high concentrations of pollution, such as from vehicle emissions or industrial activities, should instead be given to states. A move like this would erode the ability of civil society to participate in every level of government’s processes, all of which depend on meaningful involvement from the people to have durability.

Science at Risk

Almost all of EPA’s core work to help protect our health and the environment requires science and legal analysis to set a strong, fact-based foundation for its actions. Much of this could grind to a halt if the next administration follows through on the plan’s suggestion to narrowly and harmfully limit the science EPA can do under laws passed by Congress.

Instead of allowing the agency’s scientific experts to determine how best to conduct science that would help meet laws, Project 2025 imposes a requirement that all science itself must be explicitly congressionally mandated. And the plan takes specific aim at the standards for critical air pollutants that are covered by under the National Ambient Air Quality Standards—ones—that were specifically driven by science—suggesting that somehow, Congress would have the expertise or the time to set up the rigorous scientific processes that it would take to update these national standards at the frequency required to keep the public safe.

Project 2025 also calls for EPA’s Science Advisory Board and other advisory bodies to be reformed to “ensure independence, balance, transparency, and geographic diversity.” This suggestion is puzzling when you consider that EPA’s advisory committees are already made up of the country’s foremost experts from a variety of sectors. And let’s not forget who drafted the blueprint: people from the oil and gas, chemical and other industries. Adding their favored representatives with potential conflicts of interest to a process set up to protect the public interest is problematic.

Alarmingly, the notion of scientific integrity itself, which people from all political affiliations should support, is also under fire. The blueprint recommends shifting responsibility for evaluating misconduct away from EPA’s Office of Scientific Integrity to an unnamed “independent body.”

Human Health on the Chopping Block

Remember the “forever chemicals” that are known carcinogens? EPA recently passed drinking water standards to protect 100 million people from per- and polyfluoroalkyl substances, or PFAS, contamination for the first time ever. The designation of PFAS chemicals as “hazardous substances” would be revisited through Project 2025. That’s despite the fact that these substances not only cause cancer but are also associated with liver and immune system damage, among other things.

According to Breathing Easy, a recent assessment by the Environmental Protection Network, the ten air pollution rules issued since 2021 with “the most significant quantified health impacts” would prevent:

• 202,632 all-cause premature mortalities.
• 107 million symptomatic asthma incidents.
• 94 million minor-restricted activity days.

Project 2025 calls for all of these regulations to be reexamined. I’m not sure about you, but I am grateful that EPA is doing its job so that my kids and I can spend more time outdoors without fear of shortening our lifespans or suffering respiratory distress.

What’s more, when one pollutant is reduced, there are other benefits associated, and EPA used these associated benefits as a way to justify appropriately strong health-based safeguards. Moving forward, in making the case for stronger standards for any pollutants, the “co-benefits” of regulating a pollutant would be separated out from the cost-benefit analysis that accompanies regulatory packages. In other words, the cost to industry to reduce their emissions would show up much greater than any overall societal benefit of reducing pollution.

In addition, the Project 2025 recommendations would weaken public health safeguards by prohibiting the EPA from using studies to set regulations unless the underlying raw data, which would include private medical records, is revealed. Recall that for privacy reasons, health data is kept confidential, and is only available aggregated at the county level, at best. Scientists often model localized risks. If this data is precluded, the EPA would likely wind up with much weaker regulations that would benefit polluters—presumably the intent of this proposal. The communities that suffer the most pollution tend to be those that are low-income and communities of color.

Climate Change

EPA has been a key agency to help cut greenhouse gases contributing to human-caused climate change and its harmful impacts on people and the environment. Oil and gas industry backed “scientists” who contest the scientific consensus have been engaged in a disinformation and misinformation campaign that unfortunately is slowing down important action.

If the people who wrote this Blueprint were given prominent positions at the EPA, they would surely seek to overturn EPA’s finding that greenhouse gases (GHGs) endanger public health and the environment, which was critical to allowing EPA to regulate GHGs. If anything, since the original 2009 Endangerment Finding was issued, the science on climate change has only become more dire, as have the observed impacts of costly and harmful climate damages.

Perhaps because overturning this finding, which has been upheld by the U.S. Supreme Court, could be challenging if not impossible, Project 2025 also calls on the next administration to reconsider all the regulations that reduce GHGs, including vehicle and power plants standards.

In addition, the EPA should revise or scrap the social cost of carbon (SCC), according to the Blueprint. The SCC is the accepted estimate made by experts in dollars, of the economic damages that result from emitting one additional ton of carbon dioxide into the atmosphere. It is a central piece of the economics to substantiate the cost of regulations today when it is future generations who will bear the brunt of inaction.

The Blueprint also recommends that the EPA greatly reduce the number of industries required to report their GHG emissions. As the EPA explains: This data can be used by businesses and others to track and compare facilities’ greenhouse gas emissions, identify opportunities to cut pollution, minimize wasted energy, and save money. States, cities, and other communities can use EPA’s greenhouse gas data to find high-emitting facilities in their area, compare emissions between similar facilities, and develop common-sense climate policies. In addition, without this data, it would be it extremely hard to report whether the United States has met its emissions reduction commitments under the Paris climate agreement.

Conclusion

All in all, Project 2025 would undermine and decimate an important tool in the US government’s arsenal to protect human health and the environment now and for generations to come. It turns an agency that was set up to prevent pollution into one that can only clean up or remediate it after it’s done its damage. Everyone in the United States should be taking this document very seriously and speaking out to ensure that none of these recommendations come to pass and none of the authors are put into positions of power to bring about these changes. There is simply too much at stake.

SDGs, Targets, and Indicators

1. Which SDGs are addressed or connected to the issues highlighted in the article?

SDG 3: Good Health and Well-being

The article discusses the impact of toxic chemicals, such as PFAS, on human health and the need for regulations by the EPA to keep people safe.

SDG 6: Clean Water and Sanitation

The article mentions water pollution in the Pacific Ocean and local bay contributing to the decline of orcas, highlighting the importance of improving water quality to protect marine life.

SDG 11: Sustainable Cities and Communities

The article discusses the potential impact of Project 2025 on air quality and waste management in cities, emphasizing the need to reduce adverse environmental impacts in urban areas.

SDG 13: Climate Action

The article mentions the role of the EPA in cutting greenhouse gas emissions and regulating climate change, highlighting the potential consequences of Project 2025 on climate action efforts.

SDG 14: Life Below Water

The article discusses the impact of water pollution on orcas and marine life, emphasizing the need to prevent and reduce marine pollution from land-based activities.

2. What specific targets under those SDGs can be identified based on the article’s content?

Target 3.9: By 2030, substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water, and soil pollution and contamination

The article highlights the link between toxic chemicals and diseases, emphasizing the importance of reducing the adverse health effects of pollution.

Target 6.3: By 2030, improve water quality by reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials, halving the proportion of untreated wastewater, and increasing recycling and safe reuse globally

The article discusses the impact of water pollution on marine life and the need to improve water quality to protect ecosystems and human health.

Target 11.6: By 2030, reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management

The article highlights the potential impact of Project 2025 on air quality and waste management in cities, emphasizing the need to reduce adverse environmental impacts in urban areas.

Target 13.2: Integrate climate change measures into national policies, strategies, and planning

The article discusses the potential consequences of Project 2025 on climate action efforts, emphasizing the importance of integrating climate change measures into policies and planning.

Target 14.1: By 2025, prevent and significantly reduce marine pollution of all kinds, in particular from land-based activities, including marine debris and nutrient pollution

The article highlights the impact of water pollution on marine life and emphasizes the need to prevent and reduce marine pollution, particularly from land-based activities.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

Yes, the article mentions or implies several indicators that can be used to measure progress towards the identified targets:

• Indicator 3.9.1: Mortality rate attributed to household and ambient air pollution
• Indicator 6.3.2: Proportion of bodies of water with good ambient water quality
• Indicator 11.6.2: Annual mean levels of fine particulate matter (e.g. PM2.5 and PM10) in cities (population weighted)
• Indicator 13.2.1: Number of countries that have integrated mitigation, adaptation, impact reduction, and early warning measures into national policies, strategies, and planning
• Indicator 14.1.1: Index of coastal eutrophication and floating plastic debris density

4. Table: SDGs, Targets, and Indicators

Source: blog.ucsusa.org