“Driving a dagger straight into the heart of the climate change religion,” is how Lee Zeldin, the current Administrator of the Environmental Protection Agency (EPA), characterized his March 12, 2025 announcement that thirty-one federal regulations protecting citizens from air and water pollution, greenhouse gas emissions, and hazardous substances will be curtailed or abandoned over the next 12 months. Whether or not this represents, as Zeldin crowed in his press release, “the biggest deregulatory action in U.S. history,” the effects will be dire. Many of the deregulations dismantle the Clean Air Act, one of the most consequential and sweeping pieces of federal environmental legislation ever enacted. The mandate of the EPA at its founding was to protect the environment from the dangers of industrial overreach. Now, the institution’s power is being gutted from the inside.
Some argue we could have seen this coming, not only by assessing the damage done by the industry lobbyists in charge of the EPA during the first Trump administration, but in the guidelines for dismantling the agency laid out in Project 2025. Uncanny similarities between the conservative playbook designed to transform the federal government (published in 2023) and Trump’s actions in his first 100 days in office include targeting the EPA’s environmental justice workers, lowering fuel economy standards, and revoking Biden’s 2021 order to improve public health and the environment and use science to inform responses to the climate crisis.
For over fifty years, in the extreme conservative mindset, environmentalism has stood for not only the dampening of industrial growth, but a dangerous, seeping liberalism.
I suggest we cast our glance further back to recognize what is behind the present undoing of U.S. environmental policy. Project 2025 is produced by the right-wing conservative think tank, The Heritage Foundation. Founded in 1973, Heritage has, since the early 1980s, sought to shape federal policy in its image: a deeply ideological, hyper-partisan, free-enterprise machine. In an Executive Memorandum dated 17 March 1983, bearing the all-caps title, “Time to Decentralize EPA,” Heritage called for transferring federal power to states and local governments, auditing EPA-issued grants, and encouraging private sector programs to manage pollution, among other ideas (see Appendix 1). For over fifty years, in the extreme conservative mindset, environmentalism has stood for not only the dampening of industrial growth, but a dangerous, seeping liberalism:
Another indication of the liberalism that has engulfed environmental groups is their ever expanding liberal agenda. Environmentalism now transcends the simple desire to protect the environment. It has been expanded to encompass an entire outlook of broad political and social affairs.
This was the “specter” of environmentalism, as a Republican Study Committee report called it in 1982; and it was consolidated in the EPA.
In this short essay, I consider the enduring conservative vitriol toward the EPA as a pathway into the theme of this series, Illiberalism and Environmental Politics. I suggest that the seeds of illiberalism in environmental politics were planted with the founding of the EPA in 1970. Since that time, the institution has been undermined by political opponents and business interests. To understand current patterns of illiberalism requires an understanding of how the conditions of illiberalism have been put in place over time, and particularly how these conditions were “sold” to the public through a program of strategic communication.
The seeds of illiberalism in environmental politics were planted with the founding of the EPA in 1970.
Illiberalism and Environmentalism
Before making this argument, I want to rehearse current interpretations of “illiberalism.” As Laruelle points out, illiberalism is not only an emergent concept in academic study; it is also a fuzzy concept that is operationalized differently in different public spheres.
Laruelle makes the important observation that liberalism is both “an intrinsic part of the debate over illiberalism” and, practically speaking, “the default mode of Western societies and the international order.” This means that liberalism is at once normative and “the starting point for political analysis.” As such, it sets up a hierarchy of values by which Western nations are more progressive, closer to ideal achievement, the template to which non-Western nations must aspire.
In the current political context, however, liberalism appears broken. As John Gray observes in the New Statesman, “At present, liberalism is not so much a political philosophy as a chronic form of cognitive dissonance.” Far from being what everybody ought to want, liberalism has been recast as exclusionary instead of pluralist; elitist instead of egalitarian; oppressive instead of rights-based. The most interesting, if devastating, outcome of the downgrading of liberalism has been that the blame has fallen on liberals themselves. The (re)turn of political leaders towards extreme nationalism, populism, and anti-institutionalism in the American context appears as a rebalancing. In this context, not everyone agrees with Laruelle that the label “illiberal” should be understood as “a deviation from what should be the obvious norms of our society and the international community.” At the same time, liberalism and illiberalism are wielded as epithets, honed into sharpness by whoever throws the knife. Progressive political and media platforms attack the “illiberal right” and the maneuvers of the current U.S. government, while conservative media pundits and politicians attack the “liberal left” and its elitism. Each frames the other as carrying out an attack on freedom. But they do not agree on what this freedom looks like; or even what kind of freedom is undermined. Political, economic, and cultural freedoms are collapsed into general antagonisms, further entrenching partisan interpretations.
Illiberalism in the United States today is at least partially the product of a historical project that has involved undermining the ideals of liberalism over a fifty-year period.
Laruelle argues that a robust definition of illiberalism needs to contain within it not merely institutional norms but a set of ideological underpinnings. To this end, I want to suggest that the current manifestation of illiberalism in the United States is at least partially the product of a historical project that has involved undermining the ideals of liberalism over a fifty-year period. The architects of this project include political leaders, industry magnates, trade associations, lobby groups, and think tanks, all managed and coordinated via legal and public relations counsel. The ideological slant of this integrated network is contained in Lewis F. Powell’s infamous Memorandum of 1971, “Attack on American Free Enterprise System.” In this memo, written at the behest of the U.S. Chamber of Commerce, Powell lays out the blueprint for a coordinated, national-scale information and influence campaign, coordinated by political and business leaders, to take back the major institutions of society—universities, media, religious centers, and the courts—from the “control” of “liberal thought.”
If the ostensible ideology of the Powell Memorandum was to restore the tenets of free enterprise, in practice its ramifications went deeper: to create a network of corporate and political power that would undo the “liberalism” of social and public policy. This network was invested in undermining the authority of societal institutions, inserting doubt into established science (and social science), distorting progressive values, and undercutting professional expertise. To understand these practices and their effects, one can look to the work of Jane Mayer, W. Lance Bennett and Steven Livingston, Reece Peck, David Sirota, and others.
While to some, this may appear as an opposition of social liberalism to economic liberalism, I think something different is going on. One issue is the distinct power of the corporation as a political institution. Corporate power does not fit the logic of either social or market liberalism. As John Powell and Stephen Menendian write, corporate power goes beyond public versus private conceptions of politics, economics, or legal rights:
Corporations today enjoy never intended constitutional rights and protections. They exercise authority, power and influence that threaten not just democratic accountability, environmental safety and the rights of workers, but individual freedom, personal privacy, and civil and human rights.
David Ciepley goes even further, arguing that corporations “are not of liberalism and cannot be satisfactorily assimilated to its categories.” One task, therefore, is to consider the implications of the corporation for political theory and to sort out the relationship between corporate power, liberalism, and illiberalism.
A second issue is that the network of business and political power that has appeared for so long as “merely” the pursuit of free enterprise has been constantly accompanied by the will to mislead. It is a network of third-party allies, front groups, “astroturf” social movements, underwritten sponsored allies, and an endless supply of propaganda. The consistent, long-term application of deceptive communication, the mimicry of pluralist participation, and the distortion of the public interest by this network inform my understanding of illiberalism in environmental politics.
I turn now to an account of the founding of the EPA in 1970 that demonstrates how, since its earliest days, the agency was undermined by its opponents; with implications for environmental policy in the years to come.
A New Quality of Life in America
In 1970, President Nixon proposed a new quest for the United States: “a quest not for a greater quantity of what we have, but for a new quality of life in America.” It was this same year that saw the EPA grudgingly brought into being by the Nixon administration. Nixon was not an environmentalist. But he was, like all political manipulators, sensitive to public opinion, and public opinion was strongly in favor of environmental protections. The prior two decades had been punctuated by unmistakable signs of industrial overreach, from smog-filled urban zones to workplace toxins and agricultural pesticides. On January 28, 1969, eight days after Nixon’s inauguration, a massive oil spill devastated marine life off the coast of Santa Barbara, California. It was clear that the Administration had to act. Announced with great pomp and circumstance, the EPA’s creation was therefore a PR win for Nixon, all the more so because it required very little from the White House in terms of spending or staff. The EPA was old wine in new bottles: “Its 5,650 employees all came from existing agencies, its $1.4 billion budget taken from existing programs, the only difference being that these previously scattered centers of authority were now directly controlled from the White House.”
Nevertheless, the EPA’s founding augured a vast transformation in the legislative authority of the federal government. Along with the key 1970 policy programs of the National Environmental Policy Act (NEPA) and the Clean Air Act, the EPA signaled that the U.S. government was willing to take responsibility for the quality of natural surroundings. To this end, these policies invested new power in nonprofit organizations as well as individuals to bring forward complaints and participate in legal and regulatory proceedings to ensure the agency’s mandate was upheld. As such, the EPA symbolized not only a new way to protect the environment but also a new means of legitimacy for civic engagement. It moved the idea of the public from a beneficiary of environmental action to an active participant in its outcome and preservation, giving new meaning to the notions of public participation and the public interest.
The EPA moved the idea of the public from a beneficiary of environmental action to an active participant in its outcome and preservation, giving new meaning to the notions of public participation and the public interest. This new power in environmental politics posed an immediate problem for adherents to free enterprise.
This new power in environmental politics posed an immediate problem for adherents to free enterprise, who also had the ear of the Nixon Administration. And this is why, with much less fanfare, Nixon set up a shadow organization alongside the EPA: the National Industrial Pollution Control Council (NIPCC), a White House advisory group made up of representatives of major companies from the petroleum, chemical, transport, coal, and electricity sectors, among others (see Appendix 2). The primary function of the NIPCC was to keep tabs on the EPA, a fact telegraphed by the decision to put the council under the supervision of Commerce Secretary Maurice Stans, “a proud enemy of environmentalism.” Its secondary function was to influence federal policymaking on environmental issues; and to control the public perception of this influence.
If the EPA stood for the institutionalization of public participation, the NIPCC represented its antithesis: the “conquest of segments of formal state power by private groups and associations.” Organized into industrial sectors, the NIPCC allowed representatives of member enterprises including General Motors, Ford, DuPont, Procter & Gamble, Exxon, PepsiCo, Westinghouse Electric, and US Steel, to review “any environmental policy or program which specifically affects their enterprise activity” and to make their concerns known to federal decision-makers, functioning as a de facto lobbying organization.
The executive orders regulating industry advisory committees required the NIPCC to record its meetings and provide verbatim transcripts to members of the public; to represent all segments of relevant industries; and to stay in its lane—that is, to function in an advisory capacity only. The NIPCC ignored all three of those rules. When, after some negative press, the NIPCC conceded to provide summary meeting minutes, the group began to “circulate draft summaries of the minutes to members of the sub-councils, who are invited to make editorial changes, with the consequence that all damaging, and some useful, information has disappeared from the public record.” Even as it twisted itself into knots explaining why closed door meetings were necessary, the NIPCC allowed trade association executives to join as “observers.” Sub-council meetings were attended by observers from the American Petroleum Institute, the American Mining Congress, the American Meat Institute, and several others whose corporate members’ fortunes depended on quelling the EPA.
The NIPCC is only one node in a network of “alternative” expertise and influence, strategically devised to carry out the premises of the Powell Memo. Between 1968 and 1980, Washington experienced a massive consolidation of corporate political power. The number of trade associations, lobbyists and lawyers, PR and public affairs counselors, and business journalists ballooned, as did their budgets. As David Vogel puts it, “The number of individuals employed by the ‘private service industry’ exceeded the number of federal employees for the first time since before the New Deal.” The Heritage Foundation and similar think tanks functioned as what Jane Mayer calls “sub-rosa corporate arsenals,” sponsoring companies and trade groups so they could intervene in policy without raising suspicions of undue influence.
Liberal Institutions, Illiberal Objectives
A longer treatment of this network and the twists and turns that helped amalgamate its power is beyond the scope of this essay. The point here is that this power contained illiberal elements from the start, reinforced not only by the “potential abuses of the industry advisory process” (see Sheila Jasanoff’s The Fifth Branch) but also by the campaigns of disinformation that accompanied it. The NIPCC published pamphlets and studies; gave interviews to journalists; and advocated further public-private environmental partnerships; all lauding the work of the NIPCC and its member companies. After the NIPCC disbanded in 1975, industry influence over the EPA continued in the form of corporate membership on its Science Advisory Boards, emerging trade groups like the Business Roundtable, and “environmental” PR firms like the E. Bruce Harrison Company. These groups worked together to forge a common cause among member companies and unify policy positions against the EPA. Through coordinated campaigns of disinformation in the media, in scientific bodies, and in national and international forums, they undermined its research programs and questioned the quality of scientific and technical information about the environment. The impact on the public health and environmental policy landscape has been far-reaching.
The story of the EPA teaches us that corporate political power in America makes use of liberal institutions to achieve illiberal objectives. This power relies on both persuasion and mobilization; on rhetorical manipulation and on structural transformation, to build communities of support for its objectives. The key to its continued strength over decades is its political, economic, and social resonance, which allows it to grow its membership through various promises and incentives, however disingenuous or ulterior. Moral opposition must become similarly networked, discursively and materially, to respond to its antagonism. In the realm of environmental politics, this must involve resisting common cause with industrial sponsors. Continuing to make space for the influence of corporations and their allies will maintain environmentalism in its trap of opponents’ irresponsibility and limited liability, where regulation appears antithetical to the public interest.
The story of the EPA teaches us that corporate political power in America makes use of liberal institutions to achieve illiberal objectives.
Appendix 1: A Forty-Year Plan. Comparing Heritage Foundation Executive Memo of 1983 with Heritage Foundation Project 2025
| Theme | Heritage Foundation Executive Memorandum, “Time to Decentralize EPA,” 1983 | Project 2025, Chapter 13: “Environmental Protection Agency,” 2023 |
| Shrink federal intervention into EPA | “Conservatives favor a policy that eliminates unnecessary federal government intervention imposing enormous costs with little benefit…” | “The EPA has been a breeding ground for expansion of the federal government’s influence and control across the economy.” “As a consequence of [the Biden Administration’s] approach, we see the return of costly, job-killing regulations that serve to depress the economy and grow the bureaucracy but do little to address, much less resolve, complex environmental problems.” |
| Decentralize federal state authority | “Conservatives favor a policy… that shifts services and functions to state and local governments.” | “A conservative U.S. Environmental Protection Agency (EPA) will take a more supportive role toward local and state efforts.” |
| Eliminate EPA policy and research divisions | “Eliminate the media (air, noise and radiation; water; solid waste and emergency response and pesticides and toxic substances) divisional policy research offices.” (N.B. In 2025, the “emergency response” office is called the Office of Land and Emergency Management, or OLEM.) | “Several ORD [Office of Research and Development] offices and programs, many of which constitute unaccountable efforts to use scientific determinations to drive regulatory, enforcement, and legal decisions, should be eliminated.” “Eliminate or consolidate the regional laboratories and allow OLEM to use EPA, other government, or private labs based on expertise and cost.” “Eliminate the Office of Emergency Management [a suboffice of OLEM] and reassign its functions.” |
| Reduce authority of EPA | “Congress should move quickly to redesign the agency, transfer more powers to the states, where rules would fit reality, and limit EPA itself to overseeing broad national standards implemented by the states.” | “The EPA needs to be realigned away from attempts to make it an all-powerful energy and land use policymaker and returned to its congressionally sanctioned role as environmental regulator.” |
| Control EPA legal interpretation of environmental problems | “Revoke the ‘Memorandum of Understanding’ between EPA and the Justice Department, whereby Justice has responsibility for litigating EPA cases.” “Transfer all but 40 of the Washington Headquarters’ attorneys to the regions where they are needed.” (N.B. In a pre-email era, this would have limited the ability for discussion of alternative interpretations of the law.) | “Establish a policy of legally speaking with one voice…It is unacceptable for the agency to have inconsistent legal positions, particularly with respect to key interpretative issues. All attorneys with authority to represent EPA—not necessarily all attorneys—should therefore be housed in OGC.” “Review OGC resources to consider reorganization of other attorney functions and leadership for consolidation into a Cross-Cutting Issues Law Office.” |
| Audit/cancel environmental grants from EPA | “Audit every grant issued by the agency during the Reagan administration. This includes Carter-era grants whose reimbursements were made by this Administration…The list of grantees and the subjects of their research might provide clues for further reform.” | “Review[] the grants program to ensure that taxpayer funds go to organizations focused on tangible environmental improvements free from political affiliation.” “Stop all grants to advocacy groups and review which potential federal investments will lead to tangible environmental improvements.” “…ensure to the maximum extent possible that grants and funding are provided to state regulatory entities and not to nonprofits.” |
| Reduce/weaken EPA risk assessments and precautionary protection measures | “Establish an aggressive legislative strategy for streamlining the nation’s environmental laws to remove costly contradictions and discouragement of local initiative in developing disposal and protection techniques.” | “Reject precautionary default models and uncertainty factors…EPA should implement an approach that defaults to less restrictive regulatory outcomes.” |
| Privatize environmental management | “Encourage profitable uses of wastewater, sludge and other pollutants by permitting environmentally safe private sector alternatives to government programs.” | “Transition the Safer Choice program to the private sector.” “Eliminate or consolidate the regional laboratories and allow OLEM to use EPA, other government, or private labs based on expertise and cost.” |
| Restructure EPA | “Appoint a bipartisan council to review the entire EPA administration and field structure to determine what precise format will best serve America’s needs into the next decade.” | “Duplicative, wasteful, or superfluous programs that do not tangibly support the agency’s mission should be eliminated, and a structured management program should be designed to assist state and local governments in protecting public health and the environment.” “To implement policies that are consistent with a conservative EPA, the agency will have to undergo a major reorganization.” |
Appendix 2: NIPCC Sub-councils. Compiled from Figurski 1971. Companies in boldface were Heritage Foundation financial sponsors in the early 1980s
| Subcouncil | Chair |
| Airlines and Aircraft | Trans-World Airlines |
| Automotive | General Motors |
| Beverages | Pepsi |
| Building Materials | Ideal Basic Industries |
| Chemicals | Union Carbide |
| Coal | Consolidation Coal |
| Construction | Morrison-Knudsen |
| Containers: Cans | American Can |
| Containers: Glass & Plastic | Owens-Illinois |
| Containers: Paper | Container Corporation of America |
| Detergents | Procter & Gamble |
| Electric & Nuclear | Westinghouse Electric |
| Fertilizers and Agricultural Chemicals | American Cyanamid [Pfizer] |
| Food: Dairy, Fish & Other | General Foods |
| Food: Grain-based Products | General Mills |
| Food: Poultry & Animal-Based Products | Swift & Co. |
| General Manufacturing | R. J. Reynolds |
| Heavy Equipment | Combustion Engineering |
| Leisure | Outboard Marine |
| Mining & Non-Ferrous Metals | Kennecott Copper |
| Paper | U.S. Plywood – Champion Papers, Inc. |
| Petroleum & Gas | Standard Oil (NJ) [Exxon] |
| Process & Systems Engineering | Bechtel |
| Railroads & Rail Equipment | Southern Pacific |
| Rubber | Goodyear Tire & Rubber |
| Shipping | Lykes-Youngstown |
| Steel | Bethlehem Steel |
| Utilities | Pacific Gas & Electric |
| Wholesale, Retail & Services | U.S. Chamber of Commerce |
Melissa Aronczyk is Professor of Media Studies at Rutgers University. She is the co-author, with Maria I. Espinoza, of A Strategic Nature: Public Relations and the Politics of American Environmentalism (2022). Her published work can be found at melissaaronczyk.com
