Now that President-elect Donald Trump and Republicans have gained control of the Oval Office and both chambers of Congress, the conservative playbook called Project 2025 may be closer to becoming a reality. It includes a chapter whose author has ties to Virginia’s energy laws and regulation creation process, and that calls for major overhauls to the U.S. Department of Energy, including repealing clean energy funding sources, increasing oil and gas production and streamlining the nuclear approval process. 

The Heritage Foundation, a conservative think tank, put together Project 2025 in anticipation of a Trump presidency that will begin Jan. 20, 2025. The energy chapter was written by Richmond-based McGuireWoods lobbyist Bernard McNamee, who did not return requests for comment on this article. 

Trump denied connections to Project 2025 on the campaign trail. Karoline Leavitt, a spokesperson for Trump and Vice President J.D. Vance’s transition team, told The Mercury Nov. 14 “no policy should be deemed official unless it comes directly from President Trump.” On Friday, Trump announced North Dakota Gov. Doug Burgum would not only be Secretary of the Interior, but also chairman of a “newly formed” National Energy Council that will “oversee a path to U.S. ENERGY DOMINANCE.”

Here, we provide an overview of the energy and environmental implications of Project 2025, should it come to pass.  

Repealing landmark federal legislation

The 54-page  energy chapter of Project 2025 calls for repeals to the Bipartisan Infrastructure Law and Inflation Reduction Act, which have funneled millions to Virginia for a range of initiatives.

McNamee proposes to “Support repeal of massive spending bills like the Infrastructure Investment and Jobs Act (IIJA) and Inflation Reduction Act (IRA), which established new programs and are providing hundreds of billions of dollars in subsidies to renewable energy developers, their investors, and special interests, and support the rescinding of all funds not already spent by these programs.” 

According to filings with the State Corporation Commission, which regulates Virginia’s utilities, Dominion Energy, the largest provider of electricity in the state, has applied for about $769 million in BIL and IRA funding. 

While noting all that funding hasn’t been awarded, the utility said “Any incremental credit or grant that the Company receives as a result of the IRA or IIJA will be passed on to customers through lower project costs.”

Appalachian Power Company, the state’s second largest utility, has applied for about $79 million, while noting it would submit an application for funding provided by the BIL to support the development of a small modular reactor.  

On Thursday, that pursuit of SMR funding took a step forward with Appalachian Power Company announcing it identified a site for the smaller form of a nuclear reactor on company-owned property in Campbell County. The company, “plans to apply for part of the U.S. Department of Energy’s $900 million grant program to accelerate the deployment of SMRs and help reduce customer costs,” a release on the announcement stated.

Other recent examples of federal funding flowing to Virginia include the Wednesday announcement that Microporous, a battery parts manufacturer, committed to opening a plant in Pittsylvania County after receiving a $100 million grant from the U.S. Department of Energy with funding from the BIL. The company picked the location over other southeastern states. 

Over the summer, city of Richmond Public Schools received $15 million to improve buildings’ energy efficiency and improve air quality in schoolhouses, which suffered from visible signs of mold, according to the Richmond Times-Dispatch.

Promoting fossil fuels

Another core premise of the chapter is the goal to increase  fossil fuel use, which Republicans and utilities say is needed  amid growing energy needs, but scientists and environmental professors say is counter intuitive.

McNamee recommends a change to the Office of Fossil Energy and Carbon Management, if it can’t be eliminated, to “increasing energy security and supply through fossil fuels.” The author also wants the Federal Energy Regulatory Commission to “recommit itself to the (National Gas Act)’s purpose of providing the people with access to affordable and reliable natural gas.” The National Gas Act, or NGA was passed to regulate natural gas.

“The new energy crisis is caused not by a lack of resources, but by extreme ‘green’ policies,” McNamee wrote.

Paul Bubbosh, adjunct professor at George Mason University, wrote the “energy crisis” that the author purports isn’t real, citing information from the Energy Information Agency.

“According to the U.S. Energy Information Administration, crude oil prices will remain flat for 2024 and 2025,” wrote Bubbosh in a blog post on the school’s website. “Further, the U.S. is setting records in crude oil production. Natural gas prices may have a slight increase in the same time frame (2024-2025), but prices are well below crises markers.”

Scientists say climate change is propelled by human-created emissions from fossil fuel use. Cale Jaffe, director of the environmental law and community engagement clinic at the University of Virginia, published an article in the Georgetown Environmental Law Review citing a 2015 Department of Defense analysis under the administration of President Barack Obama that said climate change is “present security threat.”

“It highlighted that climate change will ‘aggravate existing problems — such as poverty, social tensions, environmental degradation,’” Jaffe wrote. “For this reason, the Department of Defense labeled climate change as a ‘threat multiplier.’ Studies from the National Academy of Sciences and the Union of Concerned Scientists have further highlighted the national security risks associated with climate change.”

Increasing nuclear 

A third pillar of the playbook’s energy plan suggests easing the path to bringing more nuclear resources online, seen by some Virginia policy makers as critical to meet energy demands, but that also come with their environmental concerns.

McNamee wants to “increase the level of private-sector responsibility for the disposal of nuclear waste,” and continue with Yucca Mountain being a central repository of waste after that idea was halted amid state pushback.

He also called for reforms under the Office of Nuclear Energy to “reduce regulatory obstacles,” and for the Nuclear Regulatory Commission to “expedite the review and approval of license extensions of existing reactors, which will require the NRC to streamline and focus its (National Environmental Policy Act) review process.”

Virginia, being at the epicenter of data center development in the country, is faced with skyrocketing energy demands, prompting discussion about using carbon-free small modular reactors to maintain a reliable grid while achieving emission reduction goals. 

Youngkin has pushed for SMRs since the unveiling of his “All-of-the-Above” energy plan in 2022. This past year, the Democratic-controlled legislature passed  bills with bipartisan support that would allow Virginia’s two largest utilities to recover from ratepayers the pre-construction costs to bring an SMR online.

House Republican spokesperson Garren Shipley reiterated to the Mercury leading stances from GOP lawmakers this past session: that solar and wind can’t provide enough electricity on its own. Shipley also noted that Germany’s decommissioning of nuclear power plants was met with reactivating coal plants, though those are now being again shut down.

“Reliability is a major concern for any system that relies on wind and solar for their baseload power,” Shipley said. “Energy demand doesn’t stop when the wind calms or the sun goes down.”

Some Democrats have supported a diverse energy mix that includes nuclear, including Del. Alfonso Lopez, D-Arlington.

“But…there are significant problems with SMRs” he said, pointing to costs and waste, when discussing a failed bill by Del. Israel O’Quinn, R-Washington. The bill would’ve changed approval of the technology to a streamlined Virginia Department of Environmental Quality process instead of at the SCC level.

Lopez also pointed out that “…we don’t have a solution for spent fuel rods,” acknowledging that waste from the existing, traditional nuclear power station at North Anna can be stored at that location, but Yucca Mountain isn’t available. 

“You’re talking about SMRs dotted across the Commonwealth in a perfect world…that’s got significant unintended consequences, in terms of drinking water, clean water, and what do you do with the spent fuel rods?”

Virginia congressional representatives support federal funding

Enacting parts of Project 2025’s energy chapter and Trump’s stance on energy would require action from Congress. 

Trump repeatedly urged the country to “drill baby drill” for more oil during his campaign, and made statements in a Chesapeake rally that correlated offshore wind with whale deaths, though scientists attribute other reasons for the fatalities.

Democratic Sen. Mark Warner, in the minority of the incoming Senate, supports federal funding sources for clean energy, like the IRA signed by President Joe Biden.

“One of the things you’ve got to give the Biden administration credit on is the IRA funding, whether it’s battery technology, or whether it is solar panels,” Warner said during a press briefing. “Most of that has gone to states that voted, in many cases overwhelming for President Trump. You’re going to shut down those manufacturing facilities?”

U.S. Rep. Jen Kiggans, a newly-re-elected Republican representing the Virginia Beach area where Dominion Energy is building the nation’s largest offshore wind farm, couldn’t be reached for comment, but earlier this year, she signed on to a letter sent to Republican House Speaker Mike Johnson of Louisiana, urging him not to repeal tax credits in the IRA, which have gone to businesses in her district. 

Warner, a proponent of nuclear power generation, said not pursuing offshore wind power generation as carbon-free source “would be a mistake.”

“Think about the manufacturing components that go into offshore wind, we can be the country’s leader,” Warner said. “This is where the future of energy in the world is headed, and we need to have American competitors and American players in that sector.”

State level impact

A press secretary for Gov. Glenn Youngkin declined to comment on the administration’s support for Project 2025’s energyplan or any policy proposals that may be introduced in the upcoming legislative session that align with it or Trump’s energy stances.

Youngkin has pushed for re-evaluations of the Virginia Clean Economy Act, a 2020 law seeking to decarbonize the grid by mid-century, and promoted both a proposed natural gas facility and Dominion’s Offshore Wind farm to meet energy demands.

Virginia Energy Director Glenn Davis, a former Republican legislator who was appointed by Youngkin to his current position, said in an interview he expects to see a “resurgence of choice for people’s energy supply.”

“Additionally, I think you’re going to see a focus on ensuring that we have an All-of-the-Above policy,” Davis said. “I think it’ll be more of a focus on data and in reality, as opposed to a feel good scenario.”

But with Democrats in control of the state legislature, the impacts of the chapter and Trump’s federal agenda becoming a reality may be difficult to weather in Virginia.  Del. Rip Sullivan, D-Fairfax, a patron of the VCEA, previously said he sees “no reason” to stray away from the goals of the law.

Some environmental advocates and a conservative policy group see the VCEA as a roadblock to Project 2025’s energy chapter being implemented in the commonwealth — but for different reasons.

“Virginia has already committed to decarbonization — for example through the Virginia Clean Economy Act that requires our major utilities to be carbon free by 2045 or 2050 with limited exception,” said Nate Benforado, a senior attorney with the Southern Environmental Law Center. He added Virginia also has the “Virginia Environmental Justice Act on the books” to make sure the state is “protecting environmental justice and fenceline communities.”

Steve Haner, a senior fellow for environment and energy policy at the Thomas Jefferson Institute for Public Policy, stated in a recent post that Dominion’s Coastal Virginia Offshore Wind project that is set to be complete in 2026 would “likely retain” IRA benefits, because removing them “greatly increase the ultimate cost to consumers for building and maintaining the turbines.”

But the VCEA mandates will continue the transition to renewable sources, increasing costs to ratepayers, Haner added. Despite reports of the cost of renewable energy decreasing, Hanerr said natural gas still looks “attractive,” with solar and onshore wind as “reasonable choices” that have limited use.  

“Ultimately, Virginia’s voters need to demand a change in direction in Richmond to match the return to sanity in Washington,” Haner wrote.