Section 3.4: Environmental Protection Agency
“Mission Statement: Creating a better environmental tomorrow with clean air, safe water, healthy soil, and thriving communities.”
Right away, we’re off to a disingenuous start, considering that every single policy posited by the Heritage Foundation authors thus far would result in the exact opposite of all of those things.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“There has been a reinstitution of unachievable standards designed to aid in the “transition” away from politically disfavored industries and technologies and toward the Biden Administration’s preferred alternatives. This approach is most obvious in the Biden Administration’s assault on the energy sector as the Administration uses its regulatory might to make coal, oil, and natural gas operations very expensive and increasingly inaccessible while forcing the economy to build out and rely on unreliable renewables.”
I go into painstaking detail in Section 3.3 with regard to how renewables actually work, so I won’t repeat myself here.
Is the Biden administration making coal, oil, and natural gas operations expensive and inaccessible? No. In fact, U.S. oil production is at an all-time high under Joe Biden. It is true, however, that having to comply with environmental regulations does cost fossil fuel industries money. Hence the Heritage Foundation’s push for deregulation. They’re being pushed by the oil industry. In fact, Trump attempted to bribe 20 heads of the fossil fuel industry with deregulation and tax favors in exchange for a billion dollars for himself.
“The totality of…Trump, the fossil-fuel industry and a [conservative thinktank] Heritage Foundation blueprint advocate will put a dagger through efforts to avoid catastrophic warming,” said Joe Romm, a senior research fellow at the University of Pennsylvania’s Center for Science, Sustainability and the Media.
“Trump promises to undo every constraint on global warming. Trump has pushed more lies and disinformation about climate change than anyone ever has.”
More:
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“As a consequence of this approach, we see the return of costly, job-killing regulations that serve to depress the economy and grow the bureaucracy but do little to address, much less resolve, complex environmental problems.”
As I point out in the previous section, renewables add billions to the economy and create jobs.
“Making the switch from fossil fuels to renewable energy sources could boost the economy. For example, according to a Labor Energy Partnership analysis, the passage of the Inflation Reduction Act alone is expected to create more than 1.5 million new jobs in the U.S. over the next decade.
Additionally, according to the International Renewable Energy Agency (IRENA) 2023 Renewable Energy and Jobs annual review, an estimated 13.7 million direct and indirect global renewable energy jobs existed in 2022, up from 7.3 million in 2012. Many millions more are expected in the coming years.”
But do environmental regulations cost the fossil-fuel industry jobs, as she claims here? A University of Chicago research project says no:
“A robust literature uses reduced-form empirical methods to evaluate the impact of existing regulations on employment levels in regulated industries. Berman and Bui (2001) compare Los Angeles (LA) refineries to other US refineries and find no evidence of changes in employment from increased regulation in LA refineries. Morgenstern, Pizer, and Shih (2002) examine the link between environmental spending and employment across four energy-intensive industries (pulp and paper mills, plastic manufacturing, petroleum refining, and iron and steel mills) and find that increased environmental spending is associated with a small increase in employment.“
“Hafstead and Williams (2018) use a highly stylized two-sector model to show that the effect of environmental taxation is largely a reallocation of jobs (from more-polluting to less-polluting industries) with very little net job loss. Among other implications, this suggests that prior difference-in-difference studies have substantially overestimated job losses in regulated industries and overestimated net job losses by even more.”
Gunasekara is either outright lying, or bothered to do zero research prior to making these claims.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“Pursuit of this globally focused agenda has distracted the agency from fulfilling its core mission, thereby creating a backlog of missed statutory deadlines, and at times has even led to preventable environmental disasters. During the Obama Administration, for example, the U.S. experienced two of the worst environmental disasters in decades, including the Flint, Michigan, water crisis in 2014 and the Gold King Mine spill in 2015.”
She’s blaming the Flint, Michigan water crisis of 2014 and the Gold King Mine spill in 2015 on climate change activism in the EPA, claiming that a focus on global goals inhibited them from stopping these preventable disasters. This is an absolutely ludicrous accusation. The ONLY accurate piece of this claim is that both disasters were indeed preventable.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“In effect, the Biden EPA has once again presented a false choice to the American people: that they have to choose between a healthy environment and a strong, growing economy.”
Biden’s economy is thriving by all traditional markers.
According to the Joint Economic Committee:
“The U.S. economy improved more during President Joe Biden’s first year in office than in the first 12 months of any other president in the past 50 years. Job growth, economic growth, retail sales and business creation are all up, while unemployment and unemployment insurance claims are down significantly” [Source]
Moreover, the economy always does better under Democratic presidential administrations than Republican administrations.
In particular, the report finds that since 1949:
- Annual real GDP growth is 1.2 percentage points faster during Democratic administrations than Republican ones (3.79% versus 2.60%).
- Total job growth has averaged 2.5% annually during Democratic administrations, while it is barely over 1% annually during Republican administrations. Applied to today’s total workforce, this would imply nearly 2.4 million more jobs created every year under Democratic administrations.
- The Democratic advantage is even larger in private job growth than it is for total job growth. Notably, business investment is higher during Democratic administrations, with investment growth running at more than double the pace than it does during Republican ones.
- Average rates of inflation—both overall and “core” measures that exclude volatile food and energy prices—are slightly lower during Democratic administrations.
- Families in the bottom 20% of the income distribution experience 188% faster income growth during Democratic administrations.
“Economic performance is much stronger when Democrats hold the White House,” said Josh Bivens, EPI chief economist and author of the report. “But it is our sense that the simple facts on real-time economic performance during Democratic and Republican administrations aren’t particularly well known. These facts constitute important information people should have during this time of rampant misinformation.”
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“Remove the Greenhouse Gas Reporting Program (GHGRP) for any source category that is not currently being regulated. The overall reporting program imposes significant burdens on small businesses and companies that are not being regulated. This is either a pointless burden or a sword-of-Damocles threat of future regulation, neither of which is appropriate.”
The GHGRP, established by the EPA in 2009, requires large emitters of greenhouse gases (GHGs) to report their emissions. The program primarily covers facilities that emit 25,000 metric tons or more of CO2 equivalent per year. The purpose of the program is to collect accurate data on GHG emissions, which is essential for understanding emission trends, informing policy decisions, and guiding regulatory measures to reduce emissions.
Getting rid of collecting statistics is another example of the Bruno Strategy. “If we stop collecting data about greenhouse emissions, they don’t exist any more!” All this does is deprive policy makers of the ability to make informed decisions, in the absence of any data to review.
In terms of the program representing a significant burden for small businesses, this is an outright lie. THE GHGRP DOES NOT APPLY TO MOST SMALL BUSINESSES. It targets large emitters of GHGs, such as power plants, industrial facilities, and large manufacturing operations. The threshold of 25,000 metric tons of CO2 equivalent per year is set high enough that small businesses typically fall below this limit and are not required to report.
The “sword of Damocles” argument is creative, but misleading at best. The existence of a reporting program does not guarantee future regulation, but it does provide policymakers with the necessary information to make informed decisions. In any regulatory system, monitoring data is essential for understanding the scope of the issue and evaluating the effectiveness of any future measures.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“ESA reform for pesticides is necessary. When approving pesticides, FIFRA allows for cost-benefit balancing, recognizing that pesticides are effective precisely because they harm pests. However, the ESA does not allow for any consideration of the beneficial effects of pesticides. In order to meet ESA obligations, pesticide uses are severely restricted, leaving growers with limited tools for crop protection.”
Here’s a case where using the acronyms for the agencies involved obscures the horror a bit. This statement is an argument for reforming the Endangered Species Act (ESA) to allow more flexibility in the approval and use of pesticides, particularly by integrating the cost-benefit balancing approach used in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
Under FIFRA, the Environmental Protection Agency (EPA) balances the costs and benefits of pesticides, acknowledging that pesticides are designed to harm pests and can have positive effects (e.g., crop protection and increased yields).
The ESA, on the other hand, does not permit cost-benefit analysis. It requires the protection of endangered species without considering the broader benefits that pesticides may provide for agriculture.
The argument suggests that the ESA should be reformed to allow more flexibility in how pesticides are regulated, potentially allowing the use of pesticides even when they pose risks to endangered species, as long as the overall benefits (e.g., crop protection and food production) are deemed to outweigh those risks.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“A top priority should be the immediate and consistent rejection of all EPA ORD and science activities that have not been authorized by Congress.”
If the EPA’s Office of Research and Development (ORD) and other science activities were limited only to those explicitly authorized by Congress, as this statement suggests, the consequences could be significant and potentially harmful to environmental protection efforts.
ORD’s research often addresses emerging environmental threats, such as new pollutants, climate change impacts, or novel industrial processes. Limiting research to only what is specifically authorized by Congress could reduce the agency’s ability to respond quickly to emerging issues and technological advancements.
Waiting for Congress to authorize specific research would likely introduce significant delays in responding to urgent environmental or public health crises. If an issue arises, such as the discovery of a harmful pollutant, the EPA would not be able to investigate or develop solutions unless Congress formally approves it. This could lead to a slower response to serious threats, including toxic spills, contamination, air and water quality issues, and climate-related disasters.
Furthermore, if the EPA’s scientific research is subject to congressional approval, it would almost certainly (and possibly by design) become politicized. Research might be influenced by political agendas or lobbying, rather than being driven by scientific priorities or actual environmental needs.
Limiting the EPA’s ability to conduct broad scientific research would likely undermine public trust in environmental regulation (which is also 100% by design in this case.) If people believe that the agency’s research is being dictated by political agendas rather than unbiased scientific inquiry, confidence in the EPA’s findings and regulations will erode.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.
“Instead of allowing these efforts to be misused for scaremongering risk communications and enforcement activities, EPA should embrace so-called citizen science and deputize the public to subject the agency’s science to greater scrutiny, especially in areas of data analysis, identification of scientific flaws, and research misconduct.”
Let’s break this one down. The phrase “scaremongering risk communications” implies that the EPA may be exaggerating environmental risks (e.g. pollution, climate change, toxic chemicals) to justify its regulatory actions. Gunasekara is suggesting that the EPA is using its scientific findings to instill fear in the public, leading to enforcement activities that are based on overstated risks.
“Citizen science” refers to the involvement of non-professional scientists (the general public) in collecting, analyzing, or interpreting scientific data. The suggestion is that the public should be more involved in scrutinizing the EPA’s scientific work, playing a watchdog role in ensuring the accuracy and reliability of the agency’s data and research. This is another form of “my opinion is just as good as your expertise”, which is prevalent throughout this project and not only untrue, but a dangerous mindset.
Throughout Project 2025, its authors have argued with staffing the government with loyalists to the agenda rather than actual experts. This adds an extra layer of stupidity – now we’re bringing in citizen non-scientists to “watchdog” a government agency that’s supposed to adhere to scientific principles. I can see Earl Schmo on the news now, testifying that he’s “been using harmful pesticides for years, and nothing bad has happened to him, so they must be safe.” Meanwhile, he’s riddled with cancer he’s not aware of.
I’m all for engaging the public in science. It encourages scientific literacy. But elevating public critique to the level of institutional oversight is the stupidest thing I’ve ever heard. It will lead to misinterpretation of complex data, because scientific research involves specialized knowledge that laypeople mostly do not have.
It also increases the risk of disinformation, also almost certainly by design. Citizen science efforts that aim to find flaws in scientific research could be exploited by special interest groups who oppose certain regulations (e.g., fossil fuel or chemical companies). This could lead to a flood of misinformation or deliberate attempts to discredit legitimate environmental science, using public skepticism to weaken regulations. If individuals with limited understanding of scientific methods are empowered to challenge science, there is a risk that conspiracy theories or false claims about environmental issues could gain traction, especially when amplified by social media. Perhaps the author is counting on this, because this is directly in the service of deregulation efforts. This one is more nefarious than most, because it’s taking the long road to deregulation by gradually and falsely convincing the public that regulations aren’t necessary.
She goes on to argue that Congress should provide incentives to the public for identifying scientific flaws and research misconduct, which roughly translates to “pay the public to spread disinformation.” This is on page 470, paragraph 4.
Full contextual analysis of Section 3.4: Environmental Protection Agency here.