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  • Project 2025’s roadmap for a Trump presidency aims to reduce funding for the EPA, eliminate climate programs and environmental justice initiatives, expand oil and gas drilling and challenge PFAS rules.
  • Michigan may be able to fight these rollbacks with state laws and investments in environmental programs, but it could be difficult to compensate for the loss of significant federal funding.
  • Experts also worry that Trump’s history of undermining the democratic process could threaten advocates’ efforts to use democracy to address environmental problems.

Trump allies are pushing a new plan that environmental groups say would reverse progress on climate action, cripple enforcement, gut environmental justice initiatives, roll back pollution regulations and broadly cut environmental funding.  

The policy roadmap, called Project 2025, was developed by the Heritage Foundation, a hard-right think tank.

Specifically, environmental experts told Planet Detroit that the plan could threaten Michigan’s climate goals and efforts to address PFAS pollution.  And environmental rollbacks are just one point of concern with a candidate who promised to be a “dictator,” albeit only on “day one,” raising fears he could undermine the democratic process and local efforts to resist his policies.

Donald Trump claimed to have “nothing” to do with Project 2025 and called parts of it “absolutely ridiculous and abysmal.” Yet, staffers from his previous administration wrote large portions of the plan and the former president’s record showed a similar willingness to fight environmental regulation. His administration loosened 125 environmental rules and provisions, while Trump referred to climate change as a “hoax.” The Trump campaign did not respond to Planet Detroit’s request for comment.

Project 2025 also proposes eliminating the Office of Environmental Justice and External Civil Rights, signaling a reversal of Biden-era efforts to address the disproportionate harm from pollution in low-income areas and communities of color in Michigan.

“I would expect that the climate change programs would be significantly impacted. I think there will be no environmental justice programs,” Tim Whitehouse, a former attorney for the EPA and executive director for the nonprofit Public Employees for Environmental Responsibility, said of a future Trump administration. “There will be no effort to focus on communities that are most impacted by pollution, and many of those are located in Michigan.”

Project 2025 targets billions for Michigan climate action

The Heritage Foundation and several authors of Project 2025 have deep ties to the fossil fuel industry and the plan looks to eliminate several clean energy programs and offices within the Department of Energy. It also proposes increasing oil and gas drilling on federally owned lands and waters.

The increase in fossil fuel production and emissions would come just as United Nations climate scientists say global fossil fuel emissions need to peak and then rapidly decline to head off the worst impacts of climate change.

Michigan, along with 21 other states, has official clean energy goals that could allow it to continue cutting emissions, advancing its own climate plan and targets for decarbonizing the energy sector. But state-level climate action would provide little protection against unchecked global emissions. Trump previously pulled the U.S. out of the Paris climate agreement.

“In the absence of American leadership, global efforts to reduce carbon emissions and avoid catastrophic warming will likely fail,” Michael Mann, Presidential Distinguished Professor of Earth & Environmental Science at the University of Pennsylvania, told the Sierra Club magazine in May.

Project 2025 also recommends repealing the Inflation Reduction Act and bipartisan infrastructure law, which would jeopardize investments in clean energy and transit.

The IRA was set to give Michigan $5.3 billion over the next eight years for transitioning to carbon-free energy production, increasing energy efficiency and electrifying transit, a report last year by the consulting firm 5 Lakes Energy and other groups found. 

Weakening PFAS rules and enforcement

Project 2025 proposes revisiting the “designation of PFAS chemicals as ‘hazardous substances’,” a move that could also endanger Michigan’s efforts to get a handle on the toxic PFAS pollution that’s contaminated thousands of sites statewide and impacted drinking water in cities like Ann Arbor and Wyandotte.

“They’ve made it clear that they will weaken EPA’s ability to review the safety of new and existing chemicals, particularly PFAS,” Whitehouse said.

This year, the EPA adopted drinking water standards for several PFAS chemicals and committed billions in funding to address PFAS in communities. Yet, reining in pollution from the highly mobile chemicals is extremely difficult. And there are an estimated 15,000 types of PFAS chemicals, only a few of which are regulated.

A Trump administration could undermine this limited progress and new uses for PFAS may be added, Whitehouse said. During Trump’s first administration, watchdog groups criticized the EPA for being too close to industry and watering down or delaying rules to prevent the public from PFAS contamination.

Project 2025 also deprioritizes enforcement, Whitehouse said, which could allow companies manufacturing PFAS and other harmful substances to dodge accountability even if regulations remain in place.

“You’ll see an unlevel playing field develop where industries know they will get away with certain things and so the compliance rates will be lower,” he said.

Michigan environmental funding may dry up under Trump and Project 2025

Cuts to the EPA budget included in Project 2025 would compound the disinvestment that dogged the agency for the last five decades, according to David Coursen, a former EPA attorney and a member of the nonprofit Environmental Protection Network. And federal cuts would trickle down to the state level, reducing the funding that accounted for 43% of EGLE’s budget in 2023-2024, with roughly 35% coming from the EPA. 

According to a report by EPN, the EPA’s inflation-adjusted spending decreased by 50% between 1980 and 2019 while the U.S. population increased by 44%.

EPA funding continued to fall short under Biden, failing to keep up with inflation at the beginning of his administration, only to see a modest increase of roughly 6% in 2023 and then a 10% cut in 2024. However, federal legislation helped pick up some of the slack, with the bipartisan infrastructure law providing billions for the Superfund program, which cleans up heavily polluted sites.

Weakening or repealing the IRA and bipartisan infrastructure bill would take away this support and imperil state investments in things like drinking water and stormwater infrastructure.

“In the case of Michigan, we’re really just starting to have the money to be able to rebuild our water infrastructure for the first time in a long time,” said Sean McBrearty, Michigan director for the nonprofit Clean Water Action. In Fiscal Year 2023-2024, Michigan received more than $250 million from the bipartisan infrastructure law for low-interest loans for drinking water and clean water projects.

Can states fight back?

Project 2025 is just one factor that could influence environmental outcomes if Trump is elected. Congress, the Michigan Legislature, and the courts would all play a role in what environmental policy remains.

“I don’t know that they’re going to have as much success as they hoped to in undoing the Inflation Reduction Act,” Coursen said, noting federal investments for public works projects like those in the IRA and bipartisan infrastructure law are often very popular.

Michigan may also counterbalance rollbacks at the federal level with state legislation and increases in environmental funding.

“I think the states that have strong public support for their programs and have support from their general assemblies for environmental protection laws and climate laws can weather a Trump administration,” Whitehouse said, although he added that it would be financially difficult.

Yet, if Trump performs well in Michigan, McBrearty said it could affect down-ballot races and make it difficult for Democrats to maintain control of the state legislature. 

McBrearty added that Trump’s “goal of dismantling our democracy” ran counter to his organization’s objective of “making democracy work for our environment.”

Trump and those involved with Project 2025 have both telegraphed a willingness to use violence and undermine the democratic process, with the former president pressuring a Georgia official to “find” votes in 2020 and routinely referring to that election as “stolen.”

Although states and cities run their own elections, partisan actors in Michigan tried to steal the 2020 election. The state charged 15 Michiganders with submitting false electoral votes

for Donald Trump and a state investigator identified Trump and several of his associates as unindicted co-conspirators in the scheme.

McBrearty said Michigan has recent experience with what happens when democracy is undermined, pointing out that it was a state-appointed emergency manager who made the decision to switch to improperly treated Flint River water that led to widespread lead poisoning in the city.

“The Flint water crisis really showed what happens when you take democracy away from the people and then put unaccountable, unelected bureaucrats in charge,” he said.

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Brian Allnutt is a senior reporter and contributing editor at Planet Detroit. He covers the climate crisis, environmental justice, politics and open space.