This series of posts consists of excerpts from Mandate for Leadership: The Conservative Promise, a project led by the Heritage Foundation that outlines policy goals for a second Trump term. Mandy Gunasekara is the author of Chapter 13: The Environmental Protection Agency. Gunasekara was Chief of Staff to EPA Administrator Andrew Wheeler from March 2020 – January 2021. She previously served the Trump Administration as the EPA’s Principal Deputy Assistant Administrator for the Office of Air and Radiation.
While Donald Trump may not pursue all the policies advanced by the Heritage project, these policies are being proposed by individuals who support Trump’s overall approach to governing, many of whom also worked under the first Trump administration. So I’m thinking the Heritage project offers a pretty good idea of what to expect should there be a second Trump administration.
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Excerpts* from Chapter 13
The mission of EPA is to protect human health and the environment. EPA works to ensure that:
Americans have clean air, land and water;
National efforts to reduce environmental risks are based on the best available scientific information;
Federal laws protecting human health and the environment are administered and enforced fairly, effectively and as Congress intended;
Environmental stewardship is integral to U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy;
All parts of society--communities, individuals, businesses, and state, local and tribal governments--have access to accurate information sufficient to effectively participate in managing human health and environmental risks;
Contaminated lands and toxic sites are cleaned up by potentially responsible parties and revitalized; and
Chemicals in the marketplace are reviewed for safety.
Not surprisingly, the EPA under the Biden Administration has returned to the same top-down, coercive approach that defined the Obama Administration.
Beyond creating such immediate and tangible harm in various communities, an EPA led by activism and a disregard for the law has generated uncertainty in the regulated community, vendetta-driven enforcement, weighted analytics, increased costs, and diminished trust in final agency actions.
Although the U.S. environmental story is very positive, there has been a return to fear-based rhetoric within the agency, especially as it pertains to the perceived threat of climate change.
EPA’s structure and mission should be greatly circumscribed to reflect the principles of cooperative federalism and limited government.
Regulatory efforts should focus on addressing tangible environmental problems with practical, cost-beneficial, affordable solutions to clean up the air, water, and soil.
EPA should consider and reduce as much as possible the economic costs of its actions on local communities to help them thrive and prosper.
EPA should foster cooperative relationships with the regulated community, especially small businesses, that encourage compliance over enforcement.
Day One Executive Order…The order should set up “pause and review” teams to assess the following:
Stop all grants to advocacy groups and review which potential federal investments will lead to tangible environmental improvements.
Determine the opportunity to downsize by terminating the newest hires in low-value programs and identify relocation opportunities for Senior Executive Service positions.
Develop a tiered-down approach to cut costs, reduce the number of full-time equivalent positions, and eliminate duplicative programs. EPA should not conduct any ongoing or planned activity for which there is not clear and current congressional authorization.
To the extent that the Inflation Reduction Act remains in place, ensure to the maximum extent possible that grants and funding are provided to state regulatory entities and not to nonprofits.
Remove the Greenhouse Gas Reporting Program 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.
Establish a system, with an appropriate deadline, to update the 2009 endangerment finding. [The Endangerment Finding is a 2007 EPA determination that greenhouse gases in the atmosphere endanger both the public health and the environment for current and future generations.]
Ensure that other states can adopt California’s standards only for traditional/criteria pollutants, not greenhouse gases.
Eliminate the use of unauthorized regulatory inputs like the social cost of carbon, black box and proprietary models, and unrealistic climate scenarios, including those based on Representative Concentration Pathway (RCP) 8.5.**
Reject precautionary default models and uncertainty factors***.
Repeal Inflation Reduction Act programs providing grants for environmental science activities.
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* Punctuation occasionally revised for aesthetics and readability. I added acronyms or full names for acronyms that weren’t in the original text. My intention in this series of posts is informational, so I’m keeping my opinions to myself. For now.
** Per the Brookings Institution The social cost of carbon is an estimate of the cost, in dollars, of the damage done by each additional ton of carbon emissions. It also is an estimate of the benefit of any action taken to reduce a ton of carbon emissions. Blackbox models refer to machine learning models that give a result or reach a decision without explaining or showing how they did so. These models are complex and difficult for humans to interpret, which can undermine trust in them. However, these models have been found to have high predictive accuracy, because they are able to identify intricate patterns in the data that people might not be able to see. Representative Concentration Pathway (RCP) 8.5 is a hypothetical trajectory for atmospheric greenhouse gases, which often served as the basis for worst-case climate change scenarios. It was based on what proved to be an overestimation of projected emissions and is now thought to be very unlikely.]
***The precautionary principle provides guidance in environmental decision making. It has four central components: take preventive action in the face of uncertainty; shift the burden of proof to the proponents of an activity; explore a wide range of alternatives to possibly harmful actions; and increase public participation in decision making”. Per the European Parliament Think Tank, the “precautionary principle enables decision-makers to adopt precautionary measures when scientific evidence about an environmental or human health hazard is uncertain and the stakes are high.”
Reference:
Mandate for Leadership: The Conservative Promise/2025 Presidential Transition Project. Edited by Pauls Dans and Steven Groves. Chapter 13: Environmental Protection Agency by Mandy M. Gunasekara.