US ELECTIONS: Project 2025 blueprint envisions major rollbacks on US energy, climate policy

The Heritage Foundation's 900-page policy blueprint for a future Republican US presidential administration contains scores of regulatory rollbacks on energy and climate policies.

The plan, known as Project 2025, would go beyond rollbacks attempted during former President Donald Trump's term, most of which were rejected by the courts or reversed by the Biden administration. It would also curb executive branch authority over climate actions and eliminate federal offices and programs central to the Biden administration's clean energy agenda.

The conservative think tank's comprehensive policy guide, released in April 2023, is also designed to avoid a repeat of the chaotic transitional period following Trump's election in 2016. Project 2025 supporters are already building a "conservative LinkedIn network," with over 14,000 individuals vetted for senior policymaking roles, according to JP Morgan Chase & Co. analysts.

If implemented, the plan would transform the US Energy Department, Environmental Protection Agency and Federal Energy Regulatory Commission, among other agencies. The policy blueprint also calls for a dramatic shift in US international climate policy and reinstatement of the Trump-era "energy dominance" agenda, including the Interior Department holding more frequent lease sales for fossil fuel production on federal land.

Trump, now seeking a second term, has publicly distanced himself from Project 2025. But the project's contributors include dozens of former senior officials from the Trump administration and individuals affiliated with Trump's campaign.

"Project 2025 does not speak for any candidate or campaign," a Heritage Foundation spokesperson said in a statement. "We are a coalition of more than 110 conservative groups advocating for policy and personnel recommendations for the next conservative president."

Climate agreements

Shortly after taking office in January 2021, President Joe Biden recommitted the US to the Paris Agreement's goal of limiting global warming to 1.5 degrees C above preindustrial levels. Under the accord, the US aims to reduce economywide greenhouse gas emissions by 50% to 52% from 2005 levels by 2030.

Project 2025 recommends that the US again withdraw from the Paris Agreement and also exit the agreement's underlying treaty: the United Nations Framework Convention on Climate Change (UNFCC), ratified by the US Senate in 1992.

Withdrawing from the framework would have far-reaching implications for US negotiations on international climate policy, said Anna Mosby head of global climate policy at S&P Global Commodity Insights. "If you withdraw from the UNFCC, there's also a lot of legal dispute about how you would get back in," Mosby said.

Even when accounting for historic energy and climate investments under the Inflation Reduction Act, signed into law by Biden in 2022, the US is still expected to fall 23% to 37% short of its 2030 emission reduction goal without more stringent GHG rules for the power and transportation sectors, according to Climate Action Tracker, an independent research project.

EPA changes

Project 2025 calls for a "Day 1" executive order directing a "pause and review" of all major Biden EPA rules and guidance materials, similar to an order Biden signed in January 2021 regarding Trump administration actions.

One such rule could be the tailpipe emissions rule the EPA finalized in March that set an industry-wide average target for the light-duty fleet of 85 g/mile of CO2 by 2032, representing a nearly 50% cut in emissions from model year 2026 passenger cars and light trucks. The EPA has said that, under the rule, auto manufacturers "may choose" to produce electric vehicles for 30%-56% of new light-duty vehicle sales. A month later, the EPA finalized a rule requiring existing coal-fired power plants and new gas plants to achieve 90% carbon capture by 2032. Both rules are facing legal challenges before the US Court of Appeals for the District of Columbia Circuit.

Project 2025 said a review of the existing vehicle standards is needed to ensure they are "actually achievable." It also recommends waging a new legal battle with California over its long-held Clean Air Act waiver to set its own vehicle standards, which can be stricter than federal rules. California fought with the Trump administration over its plans to prohibit the sale of gasoline-powered passenger cars starting in 2035 — rules up to 17 states could choose to follow.

Project 2025 also advocates for a highly technical reading of the Clean Air Act that would hamper the EPA's ability to regulate power plants for carbon emissions under Section 111 of the statute, as the Obama and Biden administrations have sought to do. It said the EPA's 2009 endangerment finding for GHGs should be revisited, the EPA's Greenhouse Gas Reporting Program for unregulated sources of emissions be eliminated, and the public health co-benefits in Clean Air Act rulemakings should be considered separately.

"These are across-the-board efforts to enfeeble the institution and the sources of scientific, technical, and economic information that environmental laws require," David Doniger, a senior adviser to the Natural Resources Defense Council Action fund, said in an interview.

Changes at DOE, FERC, Interior

Project 2025 also outlines major organizational and philosophical changes at the DOE and FERC.

It advocates for the elimination of the DOE's Office of Energy Efficiency and Renewable Energy and Office of Clean Energy Demonstrations and ending the DOE Grid Deployment Office's role in power grid planning "for the benefit of renewable developers." It also endorses ending any new loans or loan guarantees from the DOE's Loan Programs Office, sunsetting the office's loan authority and eventually eliminating it.

At FERC, the plan said the independent agency needs to ensure that electric transmission planning and interconnection processes "are resource neutral." The plan said FERC also needs to direct regional grid operators to set new market rules that would reward dispatchable generators, such as fossil fuel-fired units, or require intermittent renewable resources to procure backup power for when they are unavailable.

In gas proceedings, Project 2025 said FERC should "recommit itself" to the Natural Gas Act by limiting review of pipeline applications to the question of whether there is a need for the gas. The plan argued that the commission should limit its National Environmental Policy Act reviews to a pipeline itself and ignore GHG emissions from upstream or downstream activities.

The policy document proposes eliminating "political and climate-change interference" in DOE approvals of LNG exports and argues that FERC "should not use environmental issues like climate change as a reason to stop LNG projects."

At the Interior Department, numerous secretarial orders from the Trump administration would be reinstated to hold more frequent lease sales, streamline environmental reviews of oil and gas infrastructure and boost fossil fuel production in Alaska.

While the Biden administration approved a scaled-down development of the Willow project by ConocoPhillips in Alaska's National Petroleum Reserve, the Project 2025 document would expand approval from three to five drilling pads and revert to a 2020 environmental impact statement for the project.

The plan also would lift the suspension of leases in the Arctic National Wildlife Refuge and reinstate the 2020 National Petroleum Reserve-Alaska Integrated Activity Plan.

A new president "should work with Congress on legislation, such as the Lease Now Act" and other measures to increase energy production on federal land, according to the document. The Lease Now Act — which would prohibit a president from canceling or delaying energy and mineral leasing activities without congressional approval — is a 2022 bill introduced in the Senate that has not advanced beyond introduction.

Project 2025 also calls for a new administration to develop a new five-year offshore oil and gas leasing plan and work with Congress to reform the Outer Continental Shelf Lands Act "by eliminating five-year plans in favor of rolling or quarterly lease sales."