Project 2025 and the AEC Industry
Marcel Harmon
Research & Development Lead, Associate Principal at BranchPattern, Applied Anthropologist, Applied Evolutionist, Engineer
As a blueprint, Project 2025 is hostile to many interest groups, riddled with inaccurate details, and based on underlying modeling errors. It definitely isn’t something our nation should build from.
Politics can be defined as the art and science of government and influencing government policy, often focusing on the activities of achieving and maintaining control of the government. As such, politics is ubiquitous. Governing, code adoptions, the development of standards, project related decision-making, etc., are all intertwined to varying degrees with politics.
Despite this, in the AEC Industry (and the professional world in general) we trend to avoid discussing politics in our day-to-day, at least directly. That’s understandable to a degree. We must work with colleagues, clients, partners, and government officials with political views that conflict with our own. Because of the ubiquitous nature of politics, though, I think it valid to ask if society would be less dysfunctional were we to have more political and political adjacent discussions with those inside and outside of our bubbles and in multiple spheres of our lives.
And at some point, for some issues, one must simply take a stand.
In my opinion the 2024 elections represents one of those points in time, for so many reasons (most underlain by the far right extremist, conspiracy-theory laden, authoritarian MAGA movement capture of the Republican party). But here I’ll focus on Project 2025’s likely impact on the AEC (architecture, engineering, and construction) Industry.
For those few who may still not know what Project 2025 is, this is the conservative Heritage Foundation’s blueprint for aggressively capturing and remaking the administrative state to concentrate MAGA Republican power and embed its ideology within our institutions. Somewhat ironically titled “Mandate for Leadership,” it’s almost 900 pages of comprehensive policies, training programs, and a 180 day action plan focused on downsizing and defunding the federal government and changing it’s focus across multiple sectors. A database of potential partisan personnel is also included to aid in replacing existing civil servants and their breadth and depth of knowledge and experience.
And despite Trump and his campaign trying to distance themselves from Project 2025, as New York Times Opinion columnist Carlos Lozado pointed out:
… with so many former Trump officials among its contributors, so much praise for him throughout its pages (he is mentioned some 300 times, compared with once for Nikki Haley) and such clear affinity between Trump’s impulses and the document’s proposals, it is easy to imagine “Mandate for Leadership” wielding influence in a second Trump term.
There’s also significant overlap (with some differences) when you compare Project 2025 to Trump’s past policies and the campaign’s Agenda 47, from blasting climate policy and rolling back DEI to increasing executive power and tax breaks for the wealthy (while eliminating the IRA’s tax credits). PBS and the AP have provided a comparison of the two. Trump’s attempts to distance himself from Project 2025 are disingenuous.
So, how could it impact the AEC Industry?
AEC Industry Jobs
Stan Kolbe, executive director of government and political affairs at the Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) recently stated that “Probably no industry in the nation in recent decades has benefitted more than the construction industry from the bipartisan legislative packages passed on Capitol Hill since 2021.” While not specifically noted, he’s presumably referring to the Inflation Reduction Act (IRA), the Infrastructure Investment and Jobs Act (IIJA), and the CHIPS and Science Act.
Some clarification on the “bipartisan” statement is needed. The IRA was definitely not bipartisan, and passage of the other two bills was dependent on unanimous or nearly unanimous support from the Democrats. The voting record for each is listed below (excluding those few Senate and House members who didn’t vote or voted present).
Per the Center for American Progress, the IRA and IIJA have already helped create more than 334,500 new clean energy jobs. Policies within each Act have also helped ensure that those jobs have good wages and benefits through support of project labor agreements (PLAs) and prevailing wage and registered apprenticeship requirements. Note that the federal registered apprenticeship system has been around for almost a century, providing an important pathway to the middle class for many Americans. They also benefit employers as well as workers, increasing retention rates / reducing turnover, increasing worker loyalty and productivity, and providing access to a skilled workforce.
We’ve seen a resurgence in apprenticeships and the trades (many in building construction) over the last decade as more emphasis has been placed on them as a viable career path for students post pk-12. Project 2025 (pp. 594-596), however, proposes creating a lower-quality parallel program by reviving the failed Trump administration’s Industry-Recognized Apprenticeship Program (IRAP) and modifying it to add religious organizations as eligible providers of apprenticeship programs. This will eliminate PLAs (Project 2025, p. 604), undermine prevailing wage requirements (Project 2025, p. 604), undermine registered apprenticeship requirements (Project 2025, p. 594), and undermine existing apprenticeship programs and their oversight (Project 2025, p. 594).
In addition, stopping grid-planning and expansion to accommodate renewables (Project 2025, pp. 380-381), shifting the management of transportation infrastructure funding to the states (Project 2025, p. 621), defunding grid deployment programs (Project 2025, pp. 380-381), eliminating the Department of Energy’s (DOEs) Loan Programs Office (LPO) (Project 2025, pp. 383-384), eliminating IRA tax credits (Project 2025, p. 696), including those for green energy companies, and cutting critical Office of Clean Energy Demonstrations (OCED) programs (Project 2025, pp. 382-383) will collectively have the impact of reducing construction projects (especially green-related construction projects) and their associated economic benefits.
As reported by Net Zero Investor, a recent Rhodium Group report stated that since the passage of the IRA, business and consumer investment in clean technologies has seen a 71% increase, totaling $493 billion. And the OCED’s oversight of the IRA / IIJA $6 billion funding of the DOE’s Industrial Demonstrations Program has targeted decarbonizing the industrial sector (responsible for almost a third of U.S. carbon emissions), increasing private investment and related construction / renovation projects. Project 2025 would reduce or eliminate continued progress along these lines.
And reducing construction projects further reduces jobs (construction and consulting) and, in this case, some of the associated demand for design and construction expertise in sustainable / Net Zero, regenerative, and healthy infrastructure. Nor would these jobs be significantly offset by small gains in fossil fuel related jobs (promoted by Project 2025). As reported in the Guardian, an analysis by Energy Innovation estimates that by 2030, Project 2025 will have resulted in a loss of 1.7 million clean energy related jobs (many of these would be in or adjacent to the AEC Industry).
Decarbonizing the Built Environment
The above analysis, as reported in the Guardian, also estimates that the Project 2025 outcomes listed above, along with others, will increase the U.S.’s carbon emissions by 2.7 billion metric tons above the current 2030 trajectory (“an amount comparable to the entire annual emissions of India”). And that, of course, would prevent the U.S. from meeting its 2030 goal of cutting emissions by half, in part by reducing the AEC Industry’s ability to contribute to that target, greatly hamstringing (likely eliminating) our ability to limit global warming to 1.5 degrees Celsius.
In general, large segments of Project 2025 are at odds with the various existing building certification systems focused on sustainability and health/wellness. Relative to energy and decarbonization, Project 2025 (p. 368) is focused on moving away from decarbonizing the American economy and funding the commercialization of energy technologies, including ending the use of taxpayer dollars to fund policies related to the decarbonization of the electricity sector, the industrial sector, transportation, buildings, and the agricultural sector (Project 2025, p. 378).
In addition to what’s already been mentioned in the AEC Industry Jobs section (which will also have significant negative impacts on decarbonizing the built environment), this also includes eliminating energy and water efficiency standards for appliances (Project 2025, pp. 378, 379) and stopping the “war” on oil and natural gas (Project 2025, p. 365). While there isn’t a discussion of city ordinances banning the use of natural gas (that I could tell), the pro-natural gas / fossil fuel nature of Project 2025 (including statements along the lines of protecting our access to natural gas) suggest that its authors would be fairly hostile to such municipal actions. And this would be aligned with the actions of several Republican controlled state legislatures that have passed bills preventing such local actions, including Kansas where I live.
Referring to USGBC’s LEED v5 (currently in its second round of public comments), Project 2025 increases the resistance to achieving multiple energy / water efficiency and carbon related prerequisites and credits. Two of these include:
DEI and Environmental Justice
Project 2025 intends to limit or eliminate programs and departments that focus on DEI, energy justice, and environmental justice (Project 2025, pp. 370, 421, 441-442). Related to this is Project 2025’s general disparagement of ESG (environmental, social, and governance) (Project 2025, pp. 363-364). It further calls for the removal of ESG considerations from ERISA (the Employee Retirement Income Security Act of 1974, the federal tax and labor law establishing minimum standards for pension plans in private industry) (Project 2025, pp. 606-608).
It also calls for the Federal Trade Commission (FTC) to “… set up an ESG/DEI collusion task force to investigate firms—particularly in private equity—to see if they are using the practice as a means to meet targets, fix prices, or reduce output” (Project 2025, p. 873). All of this, as reported by Bloomberg Law, is intended to curb (scare) corporate adoption of ESG, corporate social responsibility (CSR), DEI, social justice, socially responsible investing (SRI), or commongood capitalism policies and initiatives (and limit any federal or investor group pressure to do so).
While Project 2025 targets multiple minorities in different ways as part of it’s anti-DEI focus, transgender individuals are singled out and disparaged at least 13 times within the document. This includes promoting active discrimination by directing agencies to “… rescind regulations interpreting sex discrimination provisions as prohibiting discrimination on the basis of sexual orientation, gender identity, transgender status, sex characteristics, etc.“ (Project 2025, p. 584) and “… focus their enforcement of sex discrimination laws on the biological binary meaning of ‘sex’” (Project 2025, p. 585).
This ignores the realities of gender and biological sex that extend well beyond the basic binary. Project 2025 (p. 584) also calls for restricting applications of the Supreme Court’s Bostock v. Clayton County decision. It wants to just apply Title VII’s “… sex discrimination protections to sexual orientation and transgender status in the context of hiring and firing [only],” ignoring other issues, such as bathrooms, locker rooms, dress codes, etc.
Referring to USGBC’s LEED v4/4.1, USGBC’s LEED v5 (currently in its second round of public comments), and the IWBI’s WELL Equity Standard, Project 2025 increases the resistance to achieving multiple occupant and equity related prerequisites, credits, preconditions, and features, and is completely at odds with the whole WELL Equity Standard. Here are three examples.
Estimating Social Costs / Benefits
Project 2025 also calls for the elimination of government efforts to estimate the social cost of carbon (SCC) (Project 2025, pp. 61, 422, 436). At a minimum, a Trump administration would lower it, likely substantially, from where it’s currently at by calling for “appropriate discount rates” (Project 2025, p. 423). This is code for using higher discount rates (as done under the first Trump administration) to lower the SCC value. The discount rate is used by the underlying model to translate future economic damages into present-day dollars.
Essentially the model and its discount rate are saying that, given the inputs, emitting one additional ton of CO2 in the present year will create a stream of economic damages into the future valued at, on average, X dollars (present day). The higher the discount rate value used, the less weight is being given to future damages, and the smaller the resulting SCC value.
The SCC provides a quantitative value for incorporation into LCCAs (Life Cycle Cost Analyses), LCAs (Life Cycle Analyses) and other cost/benefit analyses evaluating policy changes, laws, ordinances, code updates, design standards, design decisions for large portfolio projects, etc. If the costs (per ton of estimated emissions reduced) associated with their implementation don’t exceed the SCC, they’ll pay for themselves within our free market economic framework, driving actions and decision-making that ultimately help address climate change.
Note that the U.S. government currently uses a value of $51 per ton, with the EPA proposing a value of $190 per ton (and some research calling for even higher values). Lower values (such as the first Trump administration’s value between $1 and $7 per ton) create less incentives for desired decision-making (such as equitably decarbonizing the built environment) among federal agencies and other various government entities, developers, corporations, and other organizations.
To my knowledge, no LEED credit or WELL feature, pilot or otherwise, seeks to incorporate some value of the SCC within any LCCA or LCA efforts. However, comments have been made suggesting the SCC be incorporated within LEED, specifically relative to USGBC’s LEED v5 (currently in its second round of public comments). This, of course, would be at odds with Project 2025’s goal of eliminating or reducing the SCC value used by the federal government.
An ultimate performance basis (related directly to climate risk and mitigation) would be to apply a realistic and scientific social cost of carbon (e.g., ~$200 / tCO2e) to the life-cycle analysis in terms of present value of GHG emissions associated with a project. But, that may be better as a future step toward a performance-based approach to LEEDv5 credit system and public policy evaluation in general. This would answer the question, what design decisions today would optimize mitigation of future climate risk in terms of costs and resources available today to achieve it (or accelerate it as a basis for increasing credits for the investment made and performance achieved).
Creating Healthy Built Environments
Project 2025 (pp. 423, 427) further exacerbates the targeting of the SCC discussed above with its intention to downplay, limit, or outright prevent federal agencies from assessing the “co-benefits” associated with targeting various pollutants. In other words, the health and environmental benefits that result from a linked reduction of a secondary pollutant that wasn’t a rule’s, policy’s, or regulation’s focus either shouldn’t be accounted for or accounted for separately and given less weight.
Many of these combined benefits end up being quite large, certainly larger than focusing on the target pollutant only. Limiting the use of co-benefits by federal agencies reduces the strength of the arguments for various climate action, renewable energy, pollution reduction, and environmental justice related regulations and policies. But that’s also the intent, to slow down our movement to an equitable, decarbonized American economy (and the types of built environments necessary to achieve that).
As reported by Yale Climate Connections, Project 2025 will also weaken and eliminate varying aspects of the EPA’s (Project 2025, pp. 417-448) and Department of the Interior’s (DPI’s) (Project 2025, pp. 517-544) environmental oversight capabilities, including tracking methane emissions, managing environmental pollution (such as air pollution), setting emissions standards, restricting fossil fuel project permits, and conducting climate change research.
Included within this is the elimination of the Endangerment Finding portion of the Clean Air Act (Project 2025, p. 425), which is “… the legal mechanism that requires the EPA to curb emissions and air pollutants from vehicles and power plants, among other industries.” According to the analysis reported on by the Guardian, the resulting fossil fuel pollution would “… cause several thousand extra premature deaths by the end of the decade due to worsened air pollution.” Though some researchers would argue those negative health impacts are likely greater than this due to the Endangerment Finding being out of date with the latest science.
Referring to USGBC’s LEED v5 (currently in its second round of public comments), and the IWBI’s WELL Building Standard v2, Project 2025, by limiting federal efforts to monitor and regulate air pollution, as well as comprehensively account for all of the benefits of reducing air pollution, indirectly increases the difficulty of achieving various air quality related credits and features. Here are two examples.
Call to Action
There are many other aspects of Project 2025 impacting the AEC Industry in general, as well as the implementation of various building certification systems. Some of what I haven’t covered includes a reduction in affordable housing funding and shrinking the U.S. Department of Housing and Urban Development (HUD), elimination of the National Flood Insurance Program, and gutting our existing civil service (and the wealth of experience it represents). But now you should at least have a better understanding of the negative impacts Project 2025 would have on the AEC Industry and it’s ability to help society equitably mitigate and adapt to climate change, while still creating healthy environments.
ENR does point out that it remains unclear how much of Project 2025 could actually be enacted by a Trump administration. Many Republican controlled states have seen significant benefits from the IRA, IIJA, and Chips and Science Act. Enacting some of Project 2025’s policies may not be that popular with many of these states’ Republican constituents (we’ve seen many Senate and House Republicans taking credit with their constituents for these bills they didn’t vote for). Many of the policies would also be moving against the market to varying degrees. Regardless, even a partially enacted Project 2025 and Agenda 47 could have devastating impacts on continued efforts to equitably decarbonize and create healthy built environments.
I should also note, as Yale Climate Connections pointed out, that, while the MAGA-ification of the Heritage Foundation and the Republican party have exacerbated this in general, Project 2025 (and Agenda 47) is simply continuing a Republican tradition that stretches back to the Reagan and Nixon administrations. This tradition consists of sabotaging government and making it hard for it to do its job, then pointing out how bad a job government is doing, and using that as justification for scaling government back and privatizing its services. Since moving back to Kansas in 2005, I’ve seen this play out over and over again in our Republican controlled legislature (exacerbated when we have a Republican governor). It’s past time to recognize these actions for what they are.
I know there will be readers who think that, at least in their professional circles, they shouldn’t take a public stance and appear neutral. Perhaps some are thinking I shouldn’t be stirring things up by writing this. But as Lucy Avraamidou clarified, neutrality is an illusion. "Scientists [and other experts] refraining from engaging with socio-political issues [especially related to their expertise] in a not-neutral world is not neutrality. It is a political position that avoids responsibility to society."
C&EN editorial staff, defending Scientific American’s right to endorse Kamala Harris (only the second time in the magazine’s 179-year history that its editors endorsed a candidate for president), quoted Tom Nichols of the Atlantic in a piece he wrote for Scientific American in 2017:
Experts cannot withdraw from a public arena increasingly controlled by opportunistic demagogues who seek to discredit empiricism and rationality… Experts must continue, as citizens, to advocate for those things they believe to be in the public interest.
Licensed, professional engineers and architects are also ethically bound to hold paramount the safety, health, and welfare of the public. As stated by the National Society of Professional Engineer's past President, Robert Green, P.E., F.NSPE, "A PE is ethically obligated to protect the health, safety, and welfare of the public. We put the public’s interest before all other interests, including our own personal interests or that of our company or organization.” This is a responsibility we have to society.
It should be fairly clear that for those of us working in the AEC Industry, who are experts in varying aspects of high performance building design, building science, commissioning, sustainability (including building certification and ESG), and human factors (including indoor environmental quality, neurodiversity, and social/cultural factors), that implementation of Project 2025 (and Agenda 47) would not be in the public interest. This is not a blueprint we want to build from.
There are many reasons to vote Democrat up and down the ticket this year (democracy itself being one of them). But the impacts of Project 2025 on the AEC Industry, and the general public by extension, is one area we can speak to with authority. As citizens and experts in our various fields, we have a civic duty to advocate against Project 2025 while advocating for the Harris/Walz ticket (and other Democrats).
As I write this there are 20 days left before the election (less now by the time you read this). Early voting has already started. So, if you haven’t, get out there and do what you can to support Democrats. Call, door knock, donate, talk to your colleagues, friends, neighbors, and family. Write an op-ed. Post on social media. Share your expertise.
Not saying anything is, well, it’s still saying something. And probably not what you want to say.
References
What I Learned When I Read 887 Pages of Project 2025: https://www.nytimes.com/2024/02/29/opinion/project-2025-trump-administration.html
Hundreds of proposals in Project 2025 match Trump's policies: https://www.cbsnews.com/news/project-2025-proposals-trump-policies/
Trump’s protests aside, his agenda has plenty of overlap with Project 2025: https://whyy.org/articles/elections-2024-trump-harris-project-2025-maga/
Trump, Harris, and Project 2025: impacts on energy transition investors: https://www.netzeroinvestor.net/news-and-views/trump-and-project-2025-what-are-the-implications-for-energy-transition-investors
Project 2025 promises billions of tonnes more carbon pollution – study: https://www.theguardian.com/environment/article/2024/aug/14/trump-project-2025-climate
The Second Half Of The Decisive Decade: Potential U.S. Pathways On Climate, Jobs, And Health: https://energyinnovation.org/publication/the-second-half-of-the-decisive-decade-potential-u-s-pathways-on-climate-jobs-and-health/
What Project 2025 would do to climate policy in the US: https://yaleclimateconnections.org/2024/07/what-project-2025-would-do-to-climate-policy-in-the-us/
How Project 2025 would treat Helene survivors: https://www.eenews.net/articles/how-project-2025-would-treat-helene-survivors/
How Project 2025 Threatens the Inflation Reduction Act’s Thriving Clean Energy Economy: https://www.americanprogress.org/article/how-project-2025-threatens-the-inflation-reduction-acts-thriving-clean-energy-economy/
Noting Election's High Stakes, Environmental, Clean Energy Supporters Line Up for Kamala Harris: https://www.enr.com/articles/59307-noting-elections-high-stakes-environmental-clean-energy-supporters-line-up-for-kamala-harris
Project 2025 Would Undermine Registered Apprenticeship System and Put Corporations Over Workers: https://www.americanprogress.org/article/project-2025-would-undermine-registered-apprenticeship-system-and-put-corporations-over-workers/
What Heritage Foundation’s Project 2025 could mean for architects and planners: https://www.archpaper.com/2024/07/heritage-foundation-project-2025-architects-planners-climate-activists/
Climate Change Resilience in the Built Environment - World Green Building Council: https://viewer.ipaper.io/worldgbc/climate-change-resilience-in-the-built-environment-2022/?page=1
At Climate Forward Event, World Leaders and Scientists Discuss Our Warming Planet: https://www.nytimes.com/live/2024/09/25/climate/goodall-weather-change
Vote for Kamala Harris to Support Science, Health and the Environment: https://www.scientificamerican.com/article/vote-for-kamala-harris-to-support-science-health-and-the-environment/
Editorial: Scientific American has every right to endorse a presidential candidate: https://cen.acs.org/policy/Editorial-Scientific-American-right-endorse/102/web/2024/09
Statements by scientific organizations can, and should, shape society: https://www.science.org/doi/10.1126/science.ado7084
And here's your moment of humor, a short, Schoolhouse Rock-ish overview of Project 2025: The Project 2025 Song! (written, animated and performed by Jason Kravits)
Research & Development Lead, Associate Principal at BranchPattern, Applied Anthropologist, Applied Evolutionist, Engineer
3 周Your vote is your voice, via Katharine Hayhoe: https://www.dhirubhai.net/posts/katharine-hayhoe_cop16-cop29-climate-activity-7259233729024262144-ILBW?utm_source=combined_share_message&utm_medium=member_desktop_web
Research & Development Lead, Associate Principal at BranchPattern, Applied Anthropologist, Applied Evolutionist, Engineer
3 周If you haven't voted yet, please take the time today to exercise your right to vote. So much at stake today, with local to global implications.
Research & Development Lead, Associate Principal at BranchPattern, Applied Anthropologist, Applied Evolutionist, Engineer
3 周What the Ocean Loses if Trump Wins, via Ayana Elizabeth Johnson: https://www.dhirubhai.net/pulse/episode-6-what-ocean-loses-trump-wins-ayana-elizabeth-johnson-y9uic?utm_source=share&utm_medium=member_ios&utm_campaign=share_via, https://ayanaelizabeth.substack.com/p/episode-6-what-the-ocean-loses-if-trump-wins
Research & Development Lead, Associate Principal at BranchPattern, Applied Anthropologist, Applied Evolutionist, Engineer
3 周The Chips Act would be at risk under a Trump administration and Republican controlled House (repealed or negatively modified): https://www.forbes.com/sites/antoniopequenoiv/2024/11/01/johnson-suggests-republicans-may-repeal-chips-act-then-quickly-walks-back-comment/.
?? Master of Wordcraft ?? Artificial Intelligence Ethicist ?? Educator Extraordinaire
1 个月The Bile of Cowardice https://www.dhirubhai.net/posts/aimastery_the-bile-of-cowardice-destroying-america-activity-7256991869513916416-Ewkn?utm_source=share&utm_medium=member_android