The Environmental Historians Action Collaborative, an EDGI working group, annotated select chapters and sections of Project 2025 related to the environment, providing important context and fact-checking for the public. See the project summary and other Project 2025 annotations here.
The authors of this annotation are Scout Blum and Christopher Sellers.
VIEW ANNOTATIONS: Click on the text that is highlighted in yellow below; the relevant annotations will appear on the right side of the browser window.
COUNCIL ON ENVIRONMENTAL QUALITY (CHAPTER 2 EXCERPT)
The Council on Environmental Quality is the EOP component with the principal task of administering the National Environmental Policy Act (NEPA) by issuing regulations and interpretive documents and by overseeing the processes of individual permitting agencies’ own NEPA regulations, including categorical exclusions. The CEQ also coordinates environmental policy across the federal government, and its influence has waxed and waned across Administrations.
The President should instruct the CEQ to rewrite its regulations implementing NEPA along the lines of the historic 2020 effort and restoring its key provisions such as banning the use of cumulative impact analysis. This effort should incorporate new learning and more aggressive reform options that were not included in the 2020 reform package with the overall goal of streamlining the process to build on the Supreme Court ruling that “CEQ’s interpretation of NEPA is entitled to substantial deference.” It should frame the new regulations to limit the scope for judicial review of agency NEPA analysis and judicial remedies, as well as to vindicate the strong public interest in effective and timely agency action.
The Federal Permitting Improvement Steering Council (FPISC), of which the CEQ is a part, has been empowered by Congress through significant new funding and amendments to FAST-41. The President should build on this foundation to Executive Office of the President of the United States further empower the FPISC by making its Executive Director an EOP appointee with delegated presidential directive authority over executive branch permitting agencies. For instance, the implementation of Executive Order 13807’s One Federal Decision revealed many ways that the systems established by EO 13807 can be improved. The new President should seek to issue a new executive order to create a unified process for major infrastructure projects that includes giving project proponents more control of any regulatory clocks.
The President should issue an executive order establishing a Senior Advisor to coordinate the policy development and implementation of relevant energy and environment policy by officials across the EOP (for example, the policy staff of the NSC, NEC, DPC, CEQ, and OSTP) and abolishing the existing Office of Domestic Climate Policy. The Senior Advisor would report directly to the Chief of Staff. The role would be similar to the role that Brian Deese and John Podesta had in the Obama White House. This energy/environment coordinator would help to lead the fight for sound energy and environment policies both domestically and internationally.
The President should eliminate the Interagency Working Group on the Social Cost of Carbon (SCC), which is cochaired by the OSTP, OMB, and CEA, and by executive order should end the use of SCC analysis.
Finally, the President should work with Congress to establish a sweeping modernization of the entire permitting system across all departments and agencies that is aimed at reducing litigation risk and giving agencies the authority to establish programmatic, general, and provisional permits.