During the summer of 2022, congressional Democrats were pushing through the nation’s most significant climate legislation. Simultaneously, President Joseph R. Biden Jr. underscored the urgent threat of global warming to the United States, calling it a “clear and present danger.”
Yet, even as these efforts gained momentum, four former Trump administration officials were secretly devising plans to dismantle federal climate initiatives, anticipating a Republican return to power in Washington. This strategy has been uncovered through documents seen by The New York Times and conversations with numerous individuals close to the situation.
Among these individuals were Russell T. Vought and Jeffrey B. Clark, both prominent allies of Donald Trump. Mr. Vought, known for his strong opposition to “climate alarmism,” and Mr. Clark, who once described climate regulations as a “Leninistic” scheme to control the economy, were busy drafting executive orders aimed at dismantling climate efforts for the next Republican presidency.
The other two strategists were Mandy Gunasekara and Jonathan Brightbill, conservative attorneys with extensive backgrounds opposing climate policies. Ms. Gunasekara, a former aide to a leading climate change skeptic in the Senate, and Mr. Brightbill, who previously challenged Obama-era climate rules in court, amassed what they termed an “arsenal of information” to undermine the scientific consensus on global warming, as detailed in various documents.
Their meticulous planning is now yielding results. The Environmental Protection Agency is poised to repeal a crucial determination that has served as the foundation for the federal government’s climate change efforts since 2009.
This scientific conclusion, known as the “endangerment finding,” established that greenhouse gases like carbon dioxide and methane contribute to escalating extreme weather events—including severe storms, wildfires, droughts, heat waves, and rising sea levels—thereby endangering public health and welfare. Consequently, it mandated federal regulation of these gases, primarily generated by burning fossil fuels like oil, gas, and coal.
By revoking this finding, the Trump administration would effectively eliminate existing limitations on greenhouse gas emissions from vehicles, power plants, and various industries contributing to planetary warming.
This move goes beyond typical shifts in federal policy between administrations; nullifying the endangerment finding could severely impede any future administration’s ability to regulate greenhouse gas emissions.
“We are on the brink of total victory,” stated Myron Ebell, a figure instrumental in establishing the first Trump administration’s EPA operations and a long-standing critic of climate science and policy.
Ebell noted that numerous conservative activists, legal experts, scientists, and others had dedicated years to building a case against the endangerment finding. However, he specifically credited Vought, Clark, Brightbill, and Gunasekara for crafting the intricate plans of attack that the current Trump administration has largely adopted.
“Without those four individuals—Russ, Jeff, John, and Mandy—no amount of external public support would have made a difference,” he emphasized.
Building an “Arsenal” of Opposition
When the EPA first introduced the endangerment finding during President Barack Obama’s tenure, conservative organizations and businesses immediately mobilized to challenge it.
However, as they faced legal setbacks and public awareness of global warming increased, many corporations gradually disengaged from the fight. By the time Mr. Trump first entered office in 2017, hundreds of American businesses, including prominent oil companies and manufacturers, had acknowledged the scientific reality of climate change.
Even top advisers within the Trump administration initially pushed back against the most radical demands from those seeking to dispute climate science. In fact, just days before Trump’s first term concluded in January 2021, his EPA rejected a petition from Ebell’s group to revisit the endangerment finding.
“There was simply no appetite for such an aggressive stance among the established institutions,” explained Michael McKenna, who advised the White House on energy matters during Trump’s initial term.
Nevertheless, certain conservative activists, convinced that the climate change threat was exaggerated, persisted in their efforts throughout the Biden administration.
Among these dedicated figures was Ms. Gunasekara, who had been EPA chief of staff during Trump’s first term and authored the EPA section of Project 2025—a comprehensive guide of conservative policy proposals for a potential second Trump presidency. Mr. Brightbill, a partner at Winston & Strawn, also played a role, having previously served in the Justice Department’s environment division during the first Trump administration.
Ms. Gunasekara is famously remembered in Washington for an incident in February 2015 when she handed a snowball to her then-boss, Senator James M. Inhofe of Oklahoma. He, in turn, presented it on the Senate floor as “proof” that global warming was not a serious concern.
Meanwhile, Mr. Brightbill gained public recognition for prosecuting the “Tiger King” zoo owners. Yet, his primary focus as a federal attorney was defending the first Trump administration’s dismantling of Obama-era climate regulations, most notably a pivotal rule designed to limit greenhouse gas emissions from power plants.
In summer 2022, while President Biden and Democratic legislators accelerated their climate initiatives, Gunasekara and Brightbill reportedly sought $2 million for a covert operation to eliminate the endangerment finding. This information comes from a funding proposal acquired by Fieldnotes, an oil and gas industry watchdog.
Their proposal requested funds to create regulatory documents that a future administration could utilize to overturn the endangerment finding. They also intended to commission research papers from scientists who reject the established principles of climate physics.
In their funding pitch, Gunasekara and Brightbill asserted that the endangerment finding had enabled Democrats to pursue a “war on fossil fuels.” They argued for the necessity of a comprehensive strategy to reverse this finding “on Day 1” of the subsequent Republican administration.
The campaign was designed to operate confidentially, “to prevent media and other biased sources from shaming participants and undermining the work before its completion.”
The Heritage Foundation ultimately provided some funding for this project, though whether they supplied the entire $2 million remains unconfirmed, according to two sources close to the situation. A spokesperson for the Heritage Foundation, where Ms. Gunasekara served as a visiting fellow from September 2022 to December 2024, declined to comment.
In a text message, Ms. Gunasekara expressed immense pride in her contributions and those of her colleagues at the Heritage Foundation, aiming “to rebut junk science and expose the Green New Scam.” She noted that her work there contributed to “Cooling the Climate Hysteria,” a book of essays from academics who challenge mainstream climate science, notably featuring a melting ice cube on its cover.
Ben Dietderich, a spokesperson for the Energy Department, declined interview requests for Mr. Brightbill but stated via email that “Jonathan Brightbill possesses a profound understanding of energy and environmental issues, making him exceptionally qualified for his position.”
Sealing “Total Victory”
Although many conservatives opposed the endangerment finding from its inception, Mr. Clark began challenging its fundamental principles years prior.
In 2005, while serving as a 38-year-old Justice Department lawyer in the George W. Bush administration, Mr. Clark contended in federal court that the Clean Air Act did not grant the EPA authority to regulate greenhouse gases. This argument was decisively rejected by the Supreme Court in the pivotal 2007 case, Massachusetts v. EPA, which subsequently paved the way for the agency to issue the endangerment finding two years later.
This setback was a stinging defeat that Mr. Clark was determined to overturn, a fact corroborated by individuals familiar with the situation and his public statements on various platforms.
His next chance emerged in 2022 when he joined the Center for Renewing America, a conservative research group led by Mr. Vought from a Capitol Hill rowhouse, where he reportedly bemoaned pigeon infestations. From this base, Vought formulated extensive plans for a second Trump administration.
Under Vought’s guidance, Mr. Clark drafted executive orders designed to allow a future president to quickly dismantle Biden’s climate policies. He also developed legal strategies that the incoming administration could employ to revoke the endangerment finding, according to sources close to the matter.
According to former colleagues, Mr. Clark’s primary motivation was not merely to reduce corporate compliance costs for environmental laws, but rather to combat what he perceived as excessive government intervention through climate policies.
Mr. Clark has characterized climate initiatives as part of a scheme to “control” Americans and weaken the U.S. economy. He has publicly labeled environmentalists a “crazy climate cult,” drawing parallels to the oppressive pig characters in George Orwell’s novel “Animal Farm.”
Richard Lazarus, a Harvard Law School professor specializing in environmental law and author of “The Rule of Five: Making Climate History at the Supreme Court”—a book featuring Mr. Clark prominently—described him as “an ideologue with very, very strong views that EPA shouldn’t regulate greenhouse gases.”
“For individuals like Russell Vought and Jeff Clark, this issue has been a deeply personal crusade,” Lazarus observed.
When Mr. Clark was brought on by Mr. Vought, he was concurrently under criminal investigation related to Mr. Trump’s attempts to reverse Georgia’s 2020 election results. President Trump issued a preemptive pardon for Mr. Clark in November, leading to the dismissal of the Georgia case.
Upon Mr. Trump’s return to the White House last year, Mr. Clark assumed the role of the government’s chief regulatory official, serving as the acting head of the White House Office of Information and Regulatory Affairs. Meanwhile, Mr. Vought resumed his position as the White House budget director, becoming Mr. Clark’s superior.
In their current capacities, both officials have prioritized eliminating green initiatives across the government. Clark, in particular, has pressed EPA lawyers to bolster their legal arguments for repealing the endangerment finding, as confirmed by two informed sources.
Allie McCandless, a spokesperson for the White House Office of Management and Budget, declined requests to interview Mr. Clark or comment on his activities. She issued a statement asserting that Trump administration officials are “working in lock step to execute on the president’s deregulation agenda.”
Neil Chatterjee, a Republican who headed the Federal Energy Regulatory Commission during the first Trump administration, observed that conservative activists maintained their opposition to the endangerment finding even after many businesses withdrew from the battle.
“This isn’t about corporate interests,” Chatterjee explained. “It’s about dedicated ideological activists who genuinely believe climate change is a fabrication, seeing it as a means to redistribute wealth, advance socialism, undermine renewable energy, and promote left-wing agendas.”
“This is their long-awaited moment,” Chatterjee declared.
Steven J. Milloy, a former Trump transition adviser and operator of a website promoting climate change skepticism, suggested that the years of conservative activism might have been fruitless had a different Republican won the presidency. Instead, these activists found a highly receptive audience in Mr. Trump, who famously dismissed climate change as a “hoax” and a “con job.”
He emphasized that the next critical step is to ensure that the repeal of the endangerment finding withstands legal challenges in court.
“We’ve successfully kept skepticism alive,” Milloy remarked, adding, “I sincerely hope we don’t squander this chance. I’m uncertain when, or if, such an opportunity will ever arise again.”
Coral Davenport contributed reporting.