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MAHA, Means, Money

With Robert F. Kennedy, Jr. at the helm of the Department of Health and Human Services (HHS), the Make America Healthy Again (MAHA) movement, a self-proclaimed wellness effort, has gained significant influence over the US health care system.

MAHA’s key leaders eschew traditional medicine as too aligned with corporate interests, but commonly push products and therapies connected to their own network of businesses and brands.

Recent MAHA gains also propelled Big Wellness—a now trillion-dollar industry[1] that encompasses nutritional supplements and fitness products, and increasingly overlaps with non-science-based health beliefs[2]—into a position of unprecedented influence. Secretary Kennedy has begun to pursue policies that could further entrench wellness industry interests.

This report focuses on several individuals at the nexus of Big Wellness and MAHA: Dr. Casey Means, a wellness influencer and entrepreneur who is President Trump’s nominee for Surgeon General;[3] Dr. Means’ brother Calley Means, a senior advisor to Secretary Kennedy;[4] and Dr. Mark Hyman, a social media influencer and business partner to the Means siblings. We also briefly profile CMS administrator Mehmet Oz and meat influencer/entrepreneur Paul Saladino.

These individuals have not just advocated for alternative health treatments that often lack scientific support, they have profited from them. In other words, they exhibit the same sorts of conflicts of interest they denounce in traditional medicine. For example, we found that in many cases, Dr. Means may have failed to adequately disclose her sponsorship relationship with companies when promoting their products, which may be a violation of Federal Trade Commission (FTC) rules on influencer marketing.

Our key findings include:

  • While MAHA wellness influencers lambast conventional medicine, they have amassed their own wellness empires built on selling products and ideas based on distorted views of public health.
  • Surgeon General nominee Casey Means has substantial conflicts of interest that may jeopardize her ability to serve the role effectively. Dr. Means’ metabolic testing company may have already benefitted from Secretary Kennedy’s promotion of wearable health tracking devices.
  • Means has also potentially violated FTC rules on influencer marketing by failing to adequately disclose sponsorship relationships in dozens of web and social media posts promoting wellness products. In total, she failed to disclose her relationship 79 out of 140 (56%) times she promoted products from companies with which she has financial relationships.
  • HHS senior advisor Calley Means, who has repeatedly used his platforms to promote dangerous and false health information, founded the company TrueMed which relies on a legally dubious business model.
  • Leading MAHA figure Mark Hyman, who has close financial and personal ties to Kennedy, Mehmet Oz, and the Means siblings, oversees a wellness empire that stands to benefit significantly from HHS policies under Kennedy.

These influencers-turned-policy leaders’ espousal of principles of transparency and disentangling health from corporate greed are belied by their own business activities in the wellness industry. Their record as influencers suggests not that they will turn HHS away from undue corporate influence, but simply to undue influence from a different set of corporate actors.

Surgeon General Nominee Dr. Casey Means is Unqualified and Mired in Conflicts

President Trump’s nominee for Surgeon General, Dr. Casey Means, is both unqualified for the position and mired in conflicts of interest tied to the wellness industry that further highlight her unsuitability.

Dr. Means never completed her surgical residency, did not become a board-certified physician,[5] and her medical license is listed as inactive as of January 2026.[6]

After dropping out of her surgical residency due to stress, according to the former chair of her residency program, Dr. Means became an influencer and entrepreneur known for her distrust of traditional health care providers.[7]

For example, she has said that birth control pills are overprescribed and signal a “disrespect of life.”[8] She has challenged the safety of childhood vaccines,[9] including questioning why babies get hepatitis vaccines after birth.[10] And she has declined to distance herself from anti-vaccine positions espoused by Secretary Kennedy and refused to say if she thinks vaccines are effective.[11]

While Dr. Means has railed against modern medicine and health care providers as conspiring to profit off of keeping people sick, she has built her own wellness empire based on selling products and ideas based on her inaccurate views of public health.[12]

Dr. Means’ Company Levels Produces Products Generally Endorsed by HHS Secretary Kennedy

Dr. Means co-founded and serves as chief medical officer and advisor to Levels, a membership-based health tech and wearables company that provides continuous glucose monitoring and lab testing for metabolic health markers, such as blood sugar and cholesterol.[13] Levels is not marketed to people who have diabetes, the typical population wearing glucose monitors, but instead focuses on people who want to “optimize their health.”[14]

These types of products are a focus of Secretary Kennedy, who has vociferously promoted wearables and announced “one of the biggest advertising campaigns in HHS history” to encourage their use. Kennedy told the House Committee on Energy and Commerce that his “vision is that every American is wearing a wearable within four years.”[15]

Kennedy specifically cited glucose monitoring wearables as having “utterly changed” the lives of some of his friends. After Kennedy’s statements, glucose-monitoring device makers saw a jump in their share price.[16]

Medical experts generally consider wearables to be useful in chronic disease management, but even in such cases, there are serious privacy concerns about the volume of data collected and how it is used. MAHA, however, suggests the universal use of wearables in ways that medical experts do not support.[17]

Levels charges customers as much as $1,499 per year for lab panels, glucose monitoring, health coaching, and related services.[18] Customers have the option to purchase Levels testing kits tax free through their Health Savings Accounts/Flexible Spending Accounts (HSA/FSAs) from Dr. Means’ brother Calley Means’ company TrueMed (which Dr. Means is also invested in[19]).[20]

Dr. Means’ investment in Levels could be worth as much as $500,000, according to her financial disclosure.[21] In addition to her role as a co-founder and advisor to Levels, Dr. Means also collects fees for promoting Levels on her platforms. Levels paid Dr. Means almost $24,000 in sponsorship fees in 2024 and 2025.[22] Dr. Means has stated that she will resign from her position with Levels and divest her holdings upon confirmation.[23]

Dr. Means Failed to Disclose Sponsorship Relationships in Advertisements More than Half of the Time, Potentially in Violation of FTC Rules

In addition to her role with Levels, Dr. Means is a prolific influencer, maintaining a website, weekly newsletter, and robust social media presence where she posts about wellness and promotes wellness products. She has 200,000 newsletter subscribers, 852,000 followers on Instagram, 86,300 followers on TikTok, and 230,200 followers on X/Twitter.[24] She is also co-author of New York Times best-selling book Good Energy, which she wrote with her brother Calley Means.[25]

In required ethics and financial filings to the U.S. Office of Government Ethics (OGE), Dr. Means has disclosed receiving hundreds of thousands of dollars in sponsorship and affiliate fees from product sales generated through her newsletter and social media platforms, including from companies in which Dr. Means is also an investor and/or advisor. Some of those companies also have close financial relationships with her brother Calley Means’ company TrueMed, in which she is also an investor.

In many cases, she failed to adequately disclose her sponsorship relationship with these companies, which may be a violation of Federal Trade Commission (FTC) rules guiding influencer marketing.[26]

FTC’s influencer marketing guidelines are meant to safeguard consumers’ right to know when they are being advertised to. They provide standards for endorsement disclosure so that if a person is receiving compensation to promote a product, they must note the paid relationship in the social media post where they are promoting it.[27]

Public Citizen’s review of Dr. Means’ website, newsletter, and social media feeds found that for the almost two dozen companies from which Dr. Means reported receiving affiliate fees, Dr. Means disclosed her financial relationship inconsistently and ambiguously. In total, she failed to disclose her financial relationship 79 out of 140 (56%) times she promoted affiliated products.

We reviewed posts made on Dr. Means’ website, newsletter, Instagram, and TikTok during the period between January 1, 2024 to August 8, 2025. This is the same period covered by Dr. Means’ OGE financial filings. However, it is not possible to know exact timing of her affiliate marketing arrangements vis-à-vis her posts based on the information that is publicly available. Public Citizen identified the first instance in which Means publicly disclosed a financial relationship between herself and the company, and calculated total product mentions beginning at that date.

For example, Dr. Means disclosed that Momentous supplements was a sponsor for the first time on November 12, 2024 in her newsletter.[28] She had promoted Momentous products on her platforms six times before that, but we excluded those instances from our tally because they occurred prior to the initial disclosure. This methodology means that our estimated rate of failed disclosure is likely conservative.

Making matters worse, some of the companies for which Means failed to disclose her financial relationship with have questionable records on safety or have settled with the government for making false claims.[29]

  • Means is an investor in lab testing platform Function Health (described below) and has also collected $59,847 in newsletter sponsorship and partnership fees from the company. Despite this, she disclosed her sponsorship agreement with Function Health less than a third of the times she promoted the company on her website and social media platforms (4 out of 13 times).[30]
  • Genova Diagnostics, a home testing company, paid Dr. Means a total of $20,000 for book tour and sponsorship fees.[31] Of the nine times Dr. Means promoted Genova testing products on her platforms, she disclosed the company’s sponsorship only twice.[32] Genova previously paid a historic $43 million settlement to resolve allegations of billing government health programs for medically unnecessary testing.[33]
  • Means also took $12,000 from Daily Harvest, Inc., a meal kit company that paid $23 million last year to settle a class action lawsuit alleging hundreds of cases of food-born illnesses related to one of its products.[34] Of the 14 times Dr. Means promoted Daily Harvest on her platforms, she mentioned her paid partnership only three times.[35]
  • Means also reported taking $832 in partnership fees from WeNatal Inc.[36] In a blog post dated September 24, 2024 she noted that she has “no financial relationship to the company, just a big fan.”[37] In another blog post dated October 29, 2024 she promoted WeNatal under a header that says “not sponsored, just love these products.”[38] However, as early as March 2024 Dr. Means was using affiliate links to WeNatal in her newsletter and posting TikTok videos tagged as paid partnerships.[39]
  • Means promoted Zen Basil edible basil seeds, which paid her a combined $22,104 for newsletter sponsorship and partnership fees.[40] Dr. Means disclosed the sponsorship only two out of 13 times she promoted Zen Basil on her platforms.[41]

Other payments include: $27,431 from ENERGYbits, Inc.,[42] an algae supplement provider, which was first featured on Shark Tank but rejected for investment partly due to insufficient evidence of its efficacy;[43] $16,174 from Branch Basics,[44] a cleaning product company that has also promoted raw milk;[45] $27,000 from Pendulum Therapeutics,[46] a probiotic company that partners with TrueMed;[47] and $39,086 in from supplement maker Momentous, whose protein powder, “100% Plant Protein,” was found to contain between 400 and 600 percent of the daily acceptable lead limit.[48]

Table 1: Marketing, partnership, advisory/consulting, and sponsorship fees

CompanyTypeIncome TypeIncome Amount (and/or Investment Value)Not DisclosedDisclosedTotal Mentions
Amazentis, SA (dba Timeline)SupplementsNewsletter Sponsorship and Partnership Fees; Book Tour Sponsorship$134,1667815
ApothekarySupplementsNewsletter Sponsorship$12,00022
Branch BasicsCleaning productsNewsletter Sponsorship; Sponsorship and Partnership Fees$16,17422
Brigid TitgemeierFunctional medicine influencerPartnership Fees$3,37733
Daily HarvestDirect-to-consumer meal kitsNewsletter Sponsorship$12,00011314
ENERGYbitsAlgae supplementsNewsletter Sponsorship and Partnership Fees$27,43122
Farmers JuiceJuiceAdvisor/Consulting Fees$13,500112
FlorasophyFiber supplementsNewsletter Sponsorship and Partnership Fees$16,46111
Function HealthLab testing platformNewsletter Sponsorship and Partnership Fees$59,8479413
Genova Diagnostics (dba Genova Connect)At-home testing productsBook Tour and Newsletter Sponsorship$20,000729
Laird SuperfoodFood products, supplementsNewsletter Sponsorship$10,000167
LevelsMetabolic health appPartnership fees; Advisor/Consulting Fees$45,145

Investment value: $250,001 - $500,000
9413
LivOnSupplementsNewsletter sponsorshipInvestment value: $1,001 - $15,00022
MomentousSupplementsPartnership Fees$39,086167
Pendulum TherapeuticsProbiotic supplementsNewsletter Sponsorship$27,00033
PiqueTeas, supplements, elixirsNewsletter Sponsorship$46,00041014
Pure and Simple Wellness, Inc., Mariza SnyderMarketing for wellness eventEvent Marketing Fee$32311
SeatopiaDirect-to-consumer seafood deliveryNewsletter Sponsorship and Partnership Fees$18,77122
WeNatalPrenatal supplementsPartnership Fees$83214115
Zen BasilBasil seedsBook Tour Sponsorship; Newsletter Sponsorship and Partnership Fees$22,10411213
Grand Total7961140

Table is based on data disclosed in Table 2 (“Filer’s Employment Assets & Income and Retirement Accounts”) of OGE 278E filing for Casey Means and includes all income related to newsletter sponsorship, book tour sponsorship, event marketing fees, advisory/consulting fees, and sponsorship and partnership fees. Excludes honoraria, course instructor fees, speaking fees, and royalties. Some companies were listed multiple times in Table 2 of the filing and consolidated here. See Appendix here for full sourcing.

HHS Advisor Calley Means’ Company Has a Legally Dubious Business Model

Dr. Means’ brother Calley Means is a senior advisor to Secretary Kennedy. He was initially hired as a top aide to Secretary Kennedy serving as a time-limited Special Government Employee (SGE) in March 2025.[49] He reportedly stepped down around late September – months later than the 130-day term SGE designation allows if Means was working full time.[50] While Calley Means never formally announced his departure, he told the New York Times that he had taken time off earlier in the year and left the White House when his term ran out.[51]

Then on November 18, 2025 Calley Means’ name quietly reappeared on HHS’ website, and a department representative confirmed to press that he had been formally hired as a political appointee within Secretary Kennedy’s office. The department official also said that Means will divest his holdings in his company TrueMed.[52]

Calley Means’ initial status as an SGE has so far allowed him to avoid public disclosure of his financial interests, but publicly available information about Means’ business interests raises conflict of interest concerns.[53]

In addition, Means has repeatedly used his platforms to promote dangerous and false health information. He has stated that “Fluoridation in water is an attack on lower income kids, as the [National Institutes of Health] NIH has now concluded it lowers childhood IQ”[54] (citing inconclusive research[55]) and that “covid vaccines are a war crime.”[56] He has also stated that “Kids should be drinking more raw milk and less juice.”[57] Means’ wife, Leslie Vorhees Means, runs a raw-milk-based smoothie company.[58]

Calley Means drinking raw milk with MAHA influencer Paul Saladino (source: Instagram post by Leslie Vorhees Means, December 22, 2024)

TrueMed (aka True Medicine) was founded by Calley Means to help users take tax-free money from their HSAs and FSAs to pay for things that wouldn’t normally qualify for HSA/FSA expenditures, such as homeopathic medicine and supplements.

Means has publicly touted TrueMed’s role as routing federal funds from government health care programs like Medicare and Medicaid into HSAs.[59]

Dr. Means is an investor in TrueMed. Her investment is listed as having a value of up to $50,000 on her financial disclosure.[60] She has stated that she will divest her holdings in TrueMed upon confirmation.[61] (Dr. Means’ co-founder at Levels, Sam Corcos, is a DOGE representative and serves as Chief Information Officer for Department of the Treasury, which has oversight over FSAs and HSAs through the IRS.[62] According to his LinkedIn profile, Corcos still serves on the board of Levels.[63] In his role at Treasury, Corcos has used his time at Treasury to cut contracts worth about $1.5 billion from the IRS budget.)[64]

TrueMed’s business model is legally dubious. One of TrueMed’s services is producing “letters of medical necessity” (LMNs) for customers to demonstrate their medical need for wellness products, many of which are available for purchase on TrueMed’s website.[65] Customers fill out an online survey, which a physician evaluates to determine HSA/FSA eligibility. If a customer is deemed eligible, they are prompted to pay a $30 fee, after which the physician issues an LMN. The process means that there is usually no real-time communication between the TrueMed user and the doctor evaluating their medical needs.[66]

In 2024, the IRS issued an alert that such letters based on self-reported health information are not usable, writing “Beware of companies misrepresenting nutrition, wellness and general health expenses as medical care for FSAs, HSAs, HRAs and MSAs.”[67] While the IRS did not name any specific companies in its alert, reporting at the time cited TrueMed as an example of the type of company the IRS alert was targeting.[68]

TrueMed co-founder and CEO Justin Mares told press that the company is “in full alignment” with IRS guidelines.[69]

Many of the products available to purchase tax free through TrueMed are not regulated or approved by the Food and Drug Administration (FDA) – including red-light masks, $900 luxury bidets, $8,000 saunas, and capsules filled with desiccated organ meat.[70] TrueMed also helps customers buy meat. A New York Times reporter got a letter through TrueMed supporting his tax-free purchase of meats from meat supplier Force of Nature, a TrueMed partner, after declaring that he was overweight.[71]

Despite the questionable legality of TrueMed’s business model and conflicts of interest related to Calley Means’ HHS role, Means stated to the press that his government work has not dealt with matters affecting TrueMed.[72]

Calley Means at TP USA America Fest conference, December 20, 2024 (source: “FULL SPEECH: Healing a Sick Culture Panel at TPUSA’s America Fest Conference: Day Two – 12/20/24,” YouTube.)

Meanwhile, multiple sections of Trump’s One Big Beautiful Bill Act expand HSA eligibility[73] in ways that directly benefit TrueMed. For example, annual contribution limits for HSAs will effectively double, and multiple provisions expand who can use HSA/FSAs to people who were not previously eligible.[74] Additionally, Congressional MAHA Caucus members have in recent months called for even bigger expansions to HSA/FSAs as an alternative to extending Affordable Care Act subsidies, including Senate MAHA Caucus co-founders Roger Marshall (R-Kan.)[75] and Rick Scott (R-Fla.),[76] and House-side co-chair Rep. Lloyd Smucker (R-Pa.).[77]

Dr. Casey Means has collected partnership fees and related payments from multiple companies that sell their products through TrueMed, which has its own paid partnerships with the brands, including Apothekary supplements, Seatopia seafood delivery, and Momentous protein powder.[78]

Other Dr. Means-promoted products available on TrueMed are ENERGYbits algae supplements, WeNatal supplements, Timeline Nutrition’s Mitopure Urolithin A supplements, and Pendulum probiotic supplements.[79]

Close Means and Kennedy ally Dr. Mark Hyman stands to reap benefits from HHS policies

While not a member of the administration, the influence of Dr. Mark Hyman on the MAHA cohort within HHS cannot be overstated.

Hyman is a MAHA influencer/entrepreneur and friend and ally to HHS Secretary Kennedy, the Means siblings, and CMS administrator Mehmet Oz.[80] He has featured all four on his podcast, The Dr. Hyman Show.[81] Hyman served as an advisor and guest co-host on The Dr. Oz Show and is on the board of Oz’s HealthCorps.[82] He is invested in Calley Means’ business, TrueMed.[83]

Mark Hyman pictured to the right of Secretary Kennedy in photo posted by @HHSGov on X.com, May 19, 2025. (source)

Hyman founded Function Health, a health testing and tracking platform launched in 2023 which bills itself as the “fastest-growing health platform in the US.”[84] For $499/year, the company provides customers access to 100+ lab tests.[85]

Dr. Means is an investor in Function Health, with equity that could be worth as much as $500,000, according to her financial disclosure.[86] She also received sponsorship and affiliate fee payments for promoting Function Health on her website, including payments reaching almost $60,000 in the 12 months leading up to her disclosure filings.[87]

Another leading Function Health investor is Andreessen Horowitz,[88] the venture capital firm led by close Trump ally Marc Andreessen.[89]

Hyman is also a leading voice for health movement/trend “functional medicine” and served as the founding director for the Center for Functional Medicine at the Cleveland Clinic. He is no longer the director but remains a senior advisor.[90]

Critics of functional medicine point out that the focus on performing numerous and untargeted tests is a pipeline to the kind of health anxiety that sells supplements.[91] Indeed, in addition to an AI-generated report of a customer’s lab results, Function Health’s offerings include supplement recommendations based on those results.[92]

Conveniently, Hyman also sells supplements on his website.[93] The UltraWellness Center, a functional health clinic that Hyman founded, also provides a variety of wellness services, including medically unnecessary IV therapies for between $150-$450 per treatment.[94]

Hyman also founded the non-profit Food Fix Campaign, which purportedly advocates for changes in the food industry (as of December 2025 the organization’s website is listed as “under construction”).[95] According to tax filings, the organization’s highest paid consultant is a business entity registered to Scott Hatch,[96] son of former Senator Orrin Hatch (R-Utah). Sen. Hatch paved the way for the explosion of the supplements industry by blocking meaningful FDA regulation.[97] Food Fix paid the Hatch-affiliated entity almost $1.7 million for consulting services between FY 2021-2023.[98]Aside from Food Fix’s tax filings, Scott Hatch does not appear to have any public affiliation with Food Fix.

Dr. Mehmet Oz and iHerb

Dr. Mehmet Oz is administrator for the Centers for Medicare and Medicaid Services (CMS). Previously Oz hosted a daytime TV show from 2009 to 2022, when he quit to run for the Senate in Pennsylvania and lost.[99] Throughout his career he has repeatedly promoted controversial medical treatments and products; for example, he has touted treating COVID-19 with hydroxychloroquine, an anti-malaria drug supplied by companies he invests in.[100]

Oz’s business holdings prior to his confirmation presented abundant conflicts of interest, and it is unclear whether he remains conflicted through his family’s holdings. As a condition of his confirmation to lead CMS, Oz agreed to divest from some of his companies.[101]  While a spokesman for CMS has confirmed that Oz completed the required divestitures, one of these divestitures involved selling a company (ZorroRX) to a trust controlled by his son, who also serves as the company’s COO.[102]

Another questionable financial relationship was Oz’s relationship with iHerb, an herb and supplement company. While both iHerb and CMS have said Oz has fully divested from the company, CMS has not responded to press inquiries about whether Oz transferred his iHerb holdings to his son or another relative.[103]

Public Citizen also previously raised Oz’s potential violations of FTC policy related to influencer marketing in a December 2024 letter to the FTC.[104]

Dr. Paul Saladino (aka Carnivore MD)

Paul Saladino has been a MAHA influencer, vocal carnivore diet proponent, and peddler of organ-meat-based nutritional supplements.[105]

Saladino made headlines when he interviewed Secretary Kennedy at the White House for his podcast.[106] In the video for the podcast, Saladino’s proprietary meat snack brand Lineage Provisions is displayed prominently between himself and Secretary Kennedy as they toast and down raw milk shooters together.[107] He later appeared doing pull-ups with Secretary Kennedy and Transportation Secretary Sean Duffy at Washington’s Reagan National Airport to promote the administration’s “Make Travel Family Friendly Again,” which he claims to have inspired with an Instagram post.[108]

Secretary Kennedy and Paul Saladino drink raw milk shots in the White House, May 2025 (source: “RFK Jr. on the REAL Cause of the Chronic Disease Epidemic,” YouTube.)

Saladino has also appeared on panels and podcast beside the Means siblings, including sharing the stage with Mr. Means at a Turning Points USA conference and interviewing Dr. Means on his podcast.[109]

Saladino’s wellness company Heart & Soil is also a featured partner of TrueMed.[110]

Heart & Soil promises to “unlock the power of organs” with capsules filled with desiccated organ meat marketed as nutritional supplements. Its products include “Her Package,” a “female health” supplement made up of cow ovaries, uteruses, and fallopian tubes that claims to “improve cramping, PMS-related symptoms, and infertility” and provide “Strategic support for women struggling with reproductive health, menopause and perimenopause.”[111]

Conclusion

MAHA influencers strike a chord with many Americans because they accurately identify that much of the US health care system is beholden to corporate interests like Big Pharma and the insurance industry. But rather than fighting to lower drug prices, ensure safety for patients, or build a more equitable health system for all, they sell consumers on their own version of the grift: excessive testing, unproven and underregulated health supplements, and assurances that only their products hold the key to better health.

If confirmed, Dr. Casey Means should at minimum be required to commit to remove any additional conflicts of interest that could jeopardize her ability to serve effectively. This includes:

  • Divest any remaining potential conflicting financial interests.
  • Fully recuse herself from all matters that could directly or indirectly impact the financial interests of herself, her family, her former clients, and employers, as long as she serves as Surgeon General.
  • Commit not to seek compensation from a company that she interacted with while in government, for at least four years after leaving office.
  • Commit not to engage in lobbying activity for four years after leaving office.
  • Commit to complete transparency on her activities as Surgeon General.

Additionally, Calley Means should not be shielded from transparency in his role as HHS advisor. He should be required to disclose information about his business holdings and previous actions as a special government employee to ensure he did not wield his position for personal gain. This includes disclosing his involvement in HHS’ Make America Healthy Again report and the Make Our Children Healthy Again strategy, and committing to uphold ethical standard for anyone in the White House or HHS who advises on health policy.

Given MAHA’s purported focus on transparency and disentangling health from corporate greed, these commitments should be self-evident and represent the bare minimum for the MAHA cohort, or anyone else, to serve effectively as health care leaders.

Sources

[1] Sands, Roger. “Global Wellness Tourism Surges Toward The $1 Trillion Mark.” Forbes, January 16, 2025. https://www.forbes.com/sites/rogersands/2025/01/16/global-wellness-tourism-surges-toward-the-1-trillion-mark/.

[2] Suleta, Katie. Beware the Virtuous MAHA Movement. American Council on Science and Health. July 2, 2025. https://www.acsh.org/news/2025/07/02/beware-virtuous-maha-movement-49587.

[3] Pager, Tyler. “Trump Withdraws Surgeon General Nomination and Announces New Choice.” New York Times, May 7, 2025. https://www.nytimes.com/2025/05/07/us/politics/casey-means-surgeon-general.html.

[4] Blum, Dani. “Calley Means Returns to Kennedy’s Side as Senior Adviser.” New York Times, November 18, 2025. https://www.nytimes.com/2025/11/18/well/calley-means-rfk-jr-hhs.html.

[5] Simmons-Duffin, Selena, and Will Stone. “Casey Means’ Confirmation Hearing for Surgeon General Postponed.” NPR, October 30, 2025. https://www.npr.org/2025/10/30/nx-s1-5589127/casey-means-confirmation-hearing-surgeon-general.

[6] Oregon Medical Board License Verification Details as of January 5, 2026. https://omb.oregon.gov/Clients/ORMB/Public/VerificationDetails.aspx?EntityID=1530903

[7] Jarvie, Jenny. “Trump’s Pick for Surgeon General Quit Medical Residency Due to Stress, Former Department Chair Says.” Los Angeles Times, May 8, 2025. https://archive.ph/nGPnF#selection-2529.0-2529.11.

[8] Rogin, Ali, Doug Adams, and Taylor Bowie. “The Background and Career of Casey Means, Trump’s Pick for Surgeon General.” PBS News, May 21, 2025. https://www.pbs.org/newshour/show/the-background-and-career-of-casey-means-trumps-pick-for-surgeon-general.

[9] Means, Casey. Newsletter #35: 🇺🇸 My Health Wishlist for the next Administration. Casey Means, MD. May 7, 2025. https://www.caseymeans.com/learn/newsletter-35.

[10] Semuels, Alana. “Inside the Health Views of Casey Means, Trump’s Surgeon General Nominee.” Time, May 8, 2025. https://time.com/7284235/dr-casey-means-surgeon-general-nominee-trump/.

[11] Cueto, Isabella. “With Boost from RFK Jr. and Tucker Carlson, Two Chronic Disease Entrepreneurs Vault into Trump’s Orbit.” STAT, October 7, 2024. https://www.statnews.com/2024/10/07/calley-means-casey-means-conservative-voices-of-chronic-disease-crisis/.

[12] Podcast Video: On the Failure of the U.S. Medical System & Big Pharma’s Influence – Dr. Casey Means on The Mighty Pursuit Podcast. Casey Means, MD. August 25, 2025. https://www.caseymeans.com/learn/podcast-mighty-pursuit.

[13] “Meet the Levels Advisors.” Levels.Com, May 9, 2025. https://www.levels.com/blog/levels-advisors.

[14] Chesak, Jessica. “How to Get a CGM without Diabetes and What You Can Learn.” Levels.Com, September 23, 2024. https://www.levels.com/blog/how-to-get-a-cgm-without-diabetes-and-what-you-can-learn.

[15] See: RFK Jr. Tells Lawmakers That “Wearables Are A Key To The MAHA Agenda.” Forbes Breaking News, June 24, 2025. https://www.youtube.com/watch?v=X_fqH8rGtlE; and Singh, Puyaang. “US Health Secretary Kennedy Says HHS to Launch Campaign to Encourage Wearable Devices.” Reuters, June 24, 2025. https://www.reuters.com/business/healthcare-pharmaceuticals/us-health-secretary-kennedy-says-hhs-launch-campaign-encourage-wearable-devices-2025-06-24/.

[16] Arias, Pilar. “RFK Jr to Encourage Americans to Use ‘wearable’ Tech to Track Their Health.” Fox News, June 25, 2025. https://www.foxnews.com/health/rfk-jr-encourage-americans-use-wearable-tech-track-health?utm_source=chatgpt.com.

[17] Robert H. Shmerling, MD, “Is blood sugar monitoring without diabetes worthwhile?,” Harvard Health Publishing, April 23, 2024. https://www.health.harvard.edu/blog/is-blood-sugar-monitoring-without-diabetes-worthwhile-202106112473

[18] Levels website, https://support.levels.com/article/355-139-how-much-does-levels-cost. Accessed December 2, 2025.

[19] Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) for Casey Means, August 7, 2025, pg. 23.

[20] TrueMed website, “Levels Health,” accessed December 2, 2025. https://www.truemed.com/shop/partners/levels-health

[21] Means OGE 278E, pg. 13. Assets in financial disclosures include ranges for value. Means disclosed the value of her Levels stake to be between $250,000 and $500,000.

[22] Means OGE 278E, pg. 11.

[23] Nominee Ethics Agreement for Casey Means (Ethics Agreement), September 10, 2025. https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/C5E4DF1B8DFC12CC85258D04002C21EF/%24FILE/Means%2C%20Casey%20%20finalEA.pdf pg. 4.

[24] See: Casey Means’ newsletter, Instagram, TikTok, and X/Twitter.

[25] Casey Means, MD website: https://www.caseymeans.com/goodenergy. Accessed December 2, 2025.

[26] Swenson, Ali, and Michelle Smith. “Takeaways from AP’s Report on the Business Interests of Trump’s Surgeon General Pick.” AP, June 6, 2025. https://apnews.com/article/surgeon-general-trump-casey-means-affiliate-conflicts-b0b774dbbb6ea0b5b4bdd0f9f78fbfd5.

[27] Federal Trade Commission Disclosures 101 Social Media Influencers, https://www.ftc.gov/system/files/documents/plain-language/1001a-influencer-guide-508_1.pdf.

[28] See here: https://www.caseymeans.com/learn/newsletter-37

[29] See, e.g., U.S. Department of Justice, “Testing Laboratory Agrees to Pay Up to $43 Million to Resolve Allegations of Medically Unnecessary Tests,” April 27, 2020. https://www.justice.gov/archives/opa/pr/testing-laboratory-agrees-pay-43-million-resolve-allegations-medically-unnecessary-tests.

[30] Appendix: Public Citizen analysis of fees disclosed in OGE 278E filing as well as website, newsletter, and social media posts.

[31] Means OGE 278E, pg. 11 and 13.

[32] See Appendix.

[33] U.S. Department of Justice, “Testing Laboratory Agrees to Pay Up to $43 Million to Resolve Allegations of Medically Unnecessary Tests,” April 27, 2020. https://www.justice.gov/archives/opa/pr/testing-laboratory-agrees-pay-43-million-resolve-allegations-medically-unnecessary-tests.

[34] See: Watwe, Shweta. “Daily Harvest Agrees to Settle Lentil Meal Suit for $23 Million.” Bloomberg Law, May 3, 2024. https://news.bloomberglaw.com/product-liability-and-toxics-law/daily-harvest-agrees-to-settle-lentil-meal-suit-for-23-million; and U.S. Food and Drug Administration, “Investigation of Adverse Event Reports: French Lentil & Leek Crumbles (June 2022),” https://www.fda.gov/food/outbreaks-foodborne-illness/investigation-adverse-event-reports-french-lentil-leek-crumbles-june-2022.

[35] See Appendix.

[36] WeNatal is listed twice in table 2 (“Filer’s Employment Assets & Income and Retirement Accounts”) of Dr. Means 278E filing: $536 and $296 in partnership fees. See pg. 12 and 14.

[37] “Newsletter #29: 💊 Supplements 101: Choosing and Dosing Vitamins + Minerals.” Casey Means, MD, September 24, 2024. https://www.caseymeans.com/learn/newsletter-29.

[38] “Newsletter #34: ⌛️ Reorienting the ‘Longevity’ Conversation.” Casey Means, MD, October 29, 2024. https://www.caseymeans.com/learn/newsletter-29.

[39] See, e.g., newsletter here and TikTok posts here and here.

[40] See page 12 and 14 of Means OGE form 278E.

[41] See Appendix.

[42] Means OGE 278E, pg. 11.

[43] Sierra-Mohamed, Sarah. “Energybits: Here’s What Happened After Shark Tank.” Food Republic, April 18, 2024. https://www.foodrepublic.com/1564983/energybits-shark-tank-now/.

[44] Branch Basics is listed as The Power of Pure LLC on Means’ OGE filings. See Means OGE 278E, pg. 10.

[45] See, e.g., Instagram post, October 5, 2024. https://www.instagram.com/reel/DAwnHOUSgFL/?hl=en

[46] Means OGE 278E, pg. 11

[47] TrueMed website, “Supplements Are Medicine: How the Right Nutrition Can Transform Your Health,” September 27, 2024. https://www.truemed.com/blog/supplements-are-medicine-how-the-right-nutrition-can-transform-your-health.

[48] Martineau, Paris. “Protein Powders and Shakes Contain High Levels of Lead.” Consumer Reports, October 14, 2025. https://www.consumerreports.org/lead/protein-powders-and-shakes-contain-high-levels-of-lead-a4206364640/.

[49] Reuters. “White House Names Kennedy Ally Means as Health Adviser, Source Says.” March 18, 2025. https://www.reuters.com/world/us/white-house-hires-calley-means-special-government-adviser-bloomberg-news-reports-2025-03-18/.

[50] Golinger, Jon. “Isn’t That Special? The Trump Administration’s Use of ‘Special Government Employees’ Raises Conflict-of-Interest and Ethics Risks That Go Way Beyond Elon Musk.” Public Citizen, April 17, 2025. https://www.citizen.org/article/isnt-that-special/.

[51] Mueller, Benjamin. “Calley Means, a Kennedy Adviser, Has Left the White House.” New York Times, October 30, 2025. https://www.nytimes.com/2025/10/30/health/calley-means-kennedy-adviser-departure.html.

[52] Blum, Dani. “Calley Means Returns to Kennedy’s Side as Senior Adviser.” New York Times, November 18, 2025. https://www.nytimes.com/2025/11/18/well/calley-means-rfk-jr-hhs.html.

[53] Conflicts of interest discussed below. See also: “Auchincloss and Schiff Probe Top RFK Jr. Advisor Calley Means.” Office of Congressman Jake Auchincloss, October 31, 2025. https://auchincloss.house.gov/media/press-releases/auchincloss-and-schiff-probe-top-rfk-jr-advisor-calley-means.

[54] See X/Twitter, April 9, 2025.

[55] Caryn Rabin, Roni. “Study Links High Fluoride Exposure to Lower I.Q. in Children.” New York Times, January 8, 2025. https://www.nytimes.com/2025/01/08/health/fluoride-children-iq.html; Basilio, Humberto. “Fluoride in Tap Water Not Linked to Lower Child IQ, Massive Study Finds.” Scientific American, November 19, 2025. https://www.scientificamerican.com/article/massive-study-debunks-one-of-rfk-jrs-biggest-claims-about-fluoride-in-tap/; Taub, Rob. “Fluoride in Drinking Water Doesn’t Strain Children’s IQ Levels: Study.” The Hill, November 26, 2025. https://thehill.com/policy/healthcare/5622965-fluoride-drinking-water-children-iq-study/. Centers for Disease Control and Prevention statement on the evidence regarding the safety and benefits of community water fluoridation, May 15, 2024: https://www.cdc.gov/fluoridation/about/statement-on-the-evidence-supporting-the-safety-and-effectiveness-of-community-water-fluoridation.html  

[56] See X/Twitter, October 31, 2024. Covid-19 vaccines have been shown to be safe and effective. See e.g., here and here.

[57] See X/Twitter and Instagram, December 22 and 23, 2024. Raw milk has been found to pose serious health risk. See, e.g., US FDA statement, “The Dangers of Raw Milk: Unpasteurized Milk Can Pose a Serious Health Risk,” May 30, 2024. https://www.fda.gov/food/buy-store-serve-safe-food/dangers-raw-milk-unpasteurized-milk-can-pose-serious-health-risk 

[58] Instagram profile for Shakeup Superfoods. Bio reads “Protein | Raw Milk | Superfoods.” https://www.instagram.com/shakeupsuperfoods/. Accessed December 2, 2025.

[59] See: Michaels, Jillian. Revealing How Big Food and Big Pharma Target Our Kids! Keeping It Real Podcast with Jillian Michaels. August 5, 2024. https://www.youtube.com/watch?v=n8FvxPrsVAM&t=4858s.

; and X/Twitter, November 5, 2024.

[60] Means OGE 278E, pg. 23.

[61] Means Ethics Agreement. https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/C5E4DF1B8DFC12CC85258D04002C21EF/%24FILE/Means%2C%20Casey%20%20finalEA.pdf pg. 4.

[62] Sweet, Jacqueline. “New DOGE Staffer Has Ties to a Sanctioned Russian Oligarch.” Rolling Stone, March 7, 2025. https://www.rollingstone.com/politics/politics-features/doge-staffer-corcos-wife-ties-russian-oligarch-1235291673/.

[63] LinkedIn profile for Sam Corcos, accessed January 5, 2025. https://www.linkedin.com/in/samcorcos/

[64] Lawder, David. “Trump DOGE Executive Claims $1.5 Billion Savings from IRS Technology Budget.” Reuters, March 20, 2025. https://www.reuters.com/world/us/trump-doge-executive-claims-15-billion-savings-irs-technology-budget-2025-03-21/.

[65] Leiber, Ron, and Benjamin Mueller. “A Kennedy Aide’s Start-Up Can Get You a Tax Break on a $9,000 Sauna.” New York Times, July 18, 2025. https://www.nytimes.com/2025/07/18/business/truemed-fsa-hsa-calley-means-maha.html.

[66] TrueMed website, “Welcome to Truemed: How It Works,” https://support.truemed.com/en/articles/3488705#your_qualification_survey_link. Accessed December 2, 2025.

[67] See: “IRS alert: Beware of companies misrepresenting nutrition, wellness and general health expenses as medical care for FSAs, HSAs, HRAs and MSAs,” Internal Revenue Service, March 6, 2024. https://www.irs.gov/newsroom/irs-alert-beware-of-companies-misrepresenting-nutrition-wellness-and-general-health-expenses-as-medical-care-for-fsas-hsas-hras-and-msas#:~:text=Some%20companies%20mistakenly%20claim%20that,this%20documentation%20actually%20doesn’t ; and Perrone, Matthew. “RFK Jr. Aide Attacks U.S. Health System as Corrupt While Running Company That Promotes Alternatives.” AP, June 10, 2025. https://www.pbs.org/newshour/nation/rfk-jr-aide-attacks-u-s-health-system-as-corrupt-while-running-company-that-promotes-alternatives#:~:text=Many%20of%20the%20items%20sold,transactions%20made%20using%20their%20platforms.

[68] See, e.g.: Anahad O’Connor, “Why the IRS doesn’t believe your doctor’s note for tax-free health items,” Washington Post, March 6, 2024. https://archive.is/20240307002953/https://www.washingtonpost.com/wellness/2024/03/06/irs-hsa-fsa-eligible-food/#selection-321.0-321.13; and Dani Blum, “You Have F.S.A. Dollars to Burn. Everyone Wants Them.,” New York Times, December 23, 2024. https://www.nytimes.com/2024/12/23/well/fsa-account-health-care-deadline.html

[69] Perrone, Matthew. “RFK Jr. Aide Attacks U.S. Health System as Corrupt While Running Company That Promotes Alternatives.” AP, June 10, 2025. https://www.pbs.org/newshour/nation/rfk-jr-aide-attacks-u-s-health-system-as-corrupt-while-running-company-that-promotes-alternatives#:~:text=Many%20of%20the%20items%20sold,transactions%20made%20using%20their%20platforms.

[70] See TrueMed website: red-light masks, $900 luxury bidets, saunas, and capsules filled with desiccated organ meat. Accessed December 2, 2025.

[71] See: Leiber, Ron, and Benjamin Mueller. “A Kennedy Aide’s Start-Up Can Get You a Tax Break on a $9,000 Sauna.” New York Times, July 18, 2025. https://www.nytimes.com/2025/07/18/business/truemed-fsa-hsa-calley-means-maha.html.; and Force of Nature website, “Meat is (Officially) Medicine,” https://forceofnature.com/pages/truemed. Accessed December 2, 2025.

[72] Matthew Perrone, “Takeaways from AP’s report on financial interests of RFK Jr. adviser who runs wellness platform,” AP, June 10, 2025. https://apnews.com/article/calley-means-rfk-maha-wellness-ethics-8bbe34cb952f31bb8b6002144bb2b975

[73] See: Sec. 71307, “Allowance of bronze and catastrophic plans in connection with health savings accounts.” ; Sec. 71306, “Permanent extension of safe harbor for absence of deductible for telehealth services.”; and Sec. 71308, “Treatment of direct primary care service arrangements.” https://www.congress.gov/bill/119th-congress/house-bill/1/text

[74] KFF, “Health Provisions in the 2025 Federal Budget Reconciliation Bill,” July 8, 2025. https://www.kff.org/health-costs/tracking-the-health-savings-accounts-provisions-in-the-2025-budget-bill/

[75] See, e.g.,: CNN interview November 11, 2025, https://www.youtube.com/watch?v=q0kCN6Dn3Fg; NewsNation interview November 9, https://www.youtube.com/watch?v=wQ2H9coFdQU; Sen. Marshall press release, November 19, 2025, https://www.marshall.senate.gov/newsroom/press-releases/senator-marshall-insurancecompanies-wrote-obamacare/.

[76] See: Fox News interview, November 14, 2025, https://www.rickscott.senate.gov/2025/11/in-case-you-missed-it-sen-rick-scott-to-fox-news-obamacare-is-broken-let-s-fix-it-to-actually-lower-costs-for-americans.

[77] Rep. Smucker letter to Pennsylvania Insurance Department, November 10, 2025, https://smucker.house.gov/media/press-releases/rep-smucker-calls-out-pennsylvania-insurance-department-misleading-claims-aca

[78] See: Apothekary, Seatopia, and Momentous.

[79] See: ENERGYbits, WeNatal, Mitopure, and Pendulum.

[80] See: Borrell, Brendan. “He Built a Wellness Empire While Adventuring With Robert F. Kennedy Jr.” New York Times, December 18, 2024. https://www.nytimes.com/2024/12/18/health/mark-hyman-rfk-jr-functional-medicine.html; Mark Hyman Twitter/X post, May 8, 2025, https://x.com/drmarkhyman/status/1920569015178834082; “Calley Means: The Obesity Crisis, Ozempic, ADHD and Food Industry Lies.” Mark Hyman, MD, January 31, 2024. https://drhyman.com/blogs/content/podcast-ep848; and Mehmet Oz Facebook post, July 17, 2018. https://www.facebook.com/droz/posts/in-the-latest-episode-of-the-dr-oz-podcast-i-sit-down-with-my-friend-mark-hyman-/10151078304959995/

[81] Mark Hyman, “Calley Means: The Obesity Crisis, Ozempic, ADHD and Food Industry Lies,” The Dr. Hyman Show, January 31, 2024. https://drhyman.com/blogs/content/podcast-ep848; Mark Hyman, ” Food: The Root Causes of Our Healthcare, Economic and Social Crises with Robert F. Kennedy Jr.,” The Dr. Hyman Show, January 15, 2025. https://drhyman.com/blogs/content/podcast-ep999; Mark Hyman, ” Mastering Your Metabolism,” The Dr. Hyman Show, December 16, 2024. https://drhyman.com/blogs/content/podcast-ep988; Mark Hyman, “A Personal Conversation with Dr. Oz,” The Dr. Hyman Show, September 12, 2018. https://drhyman.com/blogs/content/podcast-ep18

[82] Dr. Mark Hyman profile, Ultrawellness Center, accessed November 18, 2025.  https://www.ultrawellnesscenter.com/mark-hyman-md-ifmcp/

[83] TrueMed website, accessed November 18, 2025. https://support.truemed.com/en/articles/3214529

[84] Function Health. “Function Emerges as the Fastest-Growing Health Platform in the US with Unique Approach That Starts with 100+ Lab Tests.” PR Newswire, June 25, 2024. https://www.prnewswire.com/news-releases/function-emerges-as-the-fastest-growing-health-platform-in-the-us-with-unique-approach-that-starts-with-100-lab-tests-302181616.html.

[85] Function Health partners with Quest Diagnostics to perform the labs. See: https://www.functionhealth.com/how-it-works

[86] Means OGE 278E, pg. 23. Assets in financial disclosures include ranges for value. Means disclosed the value of her Levels stake to be between $250,000 and $500,000.

[87] Means OGE 278E, pg. 11.

[88] Function Health. “With a $2.5B Valuation, Function Becomes the New Standard for Health and Launches Medical Intelligence Lab.” PR Newswire, November 19, 2025. https://www.prnewswire.com/news-releases/with-a-2-5b-valuation-function-becomes-the-new-standard-for-health-and-launches-medical-intelligence-lab-302620193.html.

[89] “DOGE Agent: Marc Andreessen.” Revolving Door Project, February 21, 2025. https://therevolvingdoorproject.org/doge-andreessen-marc/.

[90] Institute for Functional Medicine, “Educator Profile: Mark Hyman, MD,” https://www.ifm.org/educator/mark-hyman.

[91] Jarry, Jonathan. “Functional Medicine Is a Pipeline to Alt Med.” McGill Office for Science and Society, June 12, 2025. https://www.mcgill.ca/oss/article/medical-critical-thinking-pseudoscience/functional-medicine-pipeline-alt-med.

[92] Function Health website, accessed November 18, 2025. https://www.functionhealth.com/testimonials

[93] Mark Hyman, MD website: https://drhyman.com/collections/supplements. Accessed December 2, 2025.

[94] UltraWellness Center website: https://www.ultrawellnesscenter.com/wellness-therapies/. Accessed December 2, 2025; Sara Youngblood Gregory, “IV Vitamin therapy: Understanding the lack of proven benefit and potential risks of this health fad,” Mayo Clinic, October 2, 2024. https://mcpress.mayoclinic.org/living-well/iv-vitamin-therapy-understanding-the-lack-of-proven-benefit-and-potential-risks-of-this-health-fad/; Alejandra Marquez Janse , Sarah Handel , Mary Louise Kelly, “The FDA has raised alarms about wellness IV treatments at unregulated med spas,” NPR, January 5, 2024. https://www.npr.org/2024/01/05/1223193931/the-fda-has-raised-alarms-about-wellness-iv-treatments-at-unregulated-med-spas.

[95] “Food Fix Uncensored.” Mark Hyman MD, n.d. https://drhyman.com/pages/food-fix; FoodFix.org “under construction” as of December 16, 2025: https://www.foodfix.org/

[96] Fix Food 990 filings list consultant payments to Siren Advisors, with address 5222 FISHER ISLAND DR 2209 MIAMI BEACH, FL33140. Florida corporate filings for Siren Advisors name Scott Hatch as the entity’s authorized member.

[97] “Senator Orrin Hatch Recognized for His Commitment to Dietary Supplement Consumers.” Council for Responsible Nutrition, January 2, 2018. https://www.crnusa.org/newsroom/senator-orrin-hatch-recognized-his-commitment-dietary-supplement-consumers.

[98] Annual 990 filings between FY 2021-2023 via ProPublica.

[99] Levy, Mark. “TV Show Host Dr. Oz Announces Senate Run in Pennsylvania.” AP, November 30, 2021. https://www.pbs.org/newshour/politics/tv-show-host-dr-oz-running-for-senate-in-pennsylvania; Ximena, Bustillo. “Democrat John Fetterman Beats Trump-Backed Dr. Oz in Pennsylvania Senate Race.” NPR, November 9, 2022. https://www.npr.org/2022/11/09/1131245958/fetterman-dr-oz-pennsylvania-senate-midterm-results.

[100] Gabriel, Trip. “‘Magic’ Weight-Loss Pills and Covid Cures: Dr. Oz Under the Microscope.” New York Times, December 26, 2021. https://www.nytimes.com/2021/12/26/us/politics/dr-oz-medical-advice.html; Schwartz, Brian. “Dr. Oz Owns Shares of Companies That Supply Hydroxychloroquine, a Drug He Has Backed as a Covid Treatment.” CNBC, September 7, 2022. https://www.cnbc.com/2022/09/07/dr-oz-has-ties-to-hydroxychloroquine-companies-as-he-backs-covid-treatment.html..

[101] Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) for Mehmet Oz, February 16, 2025. https://extapps2.oge.gov/201/Presiden.nsf/PAS+Index/F871A5EF2296E46285258C3600320A25/$FILE/Oz%2C%20Mehmet%20%20AMENDEDfinalEA.pdf

[102] See: Paige Winfield Cunningham, “What happened when Dr. Oz took charge of a wonky health agency,” Washington Post, January 4, 2025. https://archive.is/20251214202731/https://www.washingtonpost.com/health/2025/12/13/mehmet-dr-oz-cms-leadership/#selection-263.0-263.62 ; ZorroRX website, https://www.zorrorx.com/about. Accessed January 5, 2026.

[103] Paige Winfield Cunningham, “What happened when Dr. Oz took charge of a wonky health agency,” Washington Post, January 4, 2025. https://archive.is/20251214202731/https://www.washingtonpost.com/health/2025/12/13/mehmet-dr-oz-cms-leadership/#selection-263.0-263.62 ; Kristina Fiore, “Does FDA’s Leucovorin Decision Meet the Bar for Gold-Standard Science?,” MedPage Today, September 29, 2025. https://www.medpagetoday.com/pediatrics/autism/117631

[104] Public Citizen letter to FTC: Investigate Dr. Oz’s Potential Violations of Influencer Marketing Standards, December 3, 2024. https://www.citizen.org/article/letter-to-ftc-investigate-dr-ozs-potential-violations-of-influencer-marketing-standards/

[105] See, e.g.: Saladino, Paul. The Carnivore Code: Unlocking the Secrets to Optimal Health by Returning to Our Ancestral Diet. First edition. With Mark Sisson. Fundamental Press, 2020. https://www.amazon.com/Carnivore-Code-Unlocking-Returning-Ancestral/dp/1734640707; Heart & Soil webstore (meat-based supplements), accessed December 2025. https://heartandsoil.co/our-story/

[106] Dickson, EJ. “RFK Jr. Did Raw-Milk Shooters in the White House.” The Cut, May 30, 2025. https://www.thecut.com/article/rfk-jr-celebrated-his-maha-report-with-raw-milk-shooters.html.

[107] “RFK Jr. on the REAL Cause of the Chronic Disease Epidemic,” Paul Saladino MD, June 3, 2025. https://www.youtube.com/watch?v=Ue1OSQ8Phk0

[108] Balogh, Klaudia. How Paul Saladino Helped Inspire a $1 Billion Plan to Put Mini-Gyms in Airports. n.d. https://www.muscleandfitness.com/athletes-celebrities/news/how-paul-saladino-helped-inspire-a-1-billiion-plan-to-put-mini-gyms-in-airports/#google_vignette.

[109] “FULL SPEECH: Healing a Sick Culture Panel at TPUSA’s America Fest Conference: Day Two – 12/20/24,” Right Side Broadcasting Network,  https://www.youtube.com/watch?v=0R4Qcx52d9E&t=814s ; “The Root Cause of Metabolic Dysfunction w/ Dr. Casey Means,” Paul Saladino MD Podcast, November 3, 2024. https://www.paulsaladinomd.com/psmd-podcast/the-root-cause-of-metabolic-dysfunction-w-dr-casey-means

[110] Heart and Soil website, accessed December, 2025. https://heartandsoil.co/our-story/ ; TrueMed website, accessed December 2025: https://www.truemed.com/shop/partners/heart-&-soil-supplements

[111] Heart and Soil website, accessed December 2025 https://shop.heartandsoil.co/products/her-package?irclickid=VDtyKmWguxycUCnw9WSmN0UIUkp3aM1VyS6t3Y0&sharedid=&irpid=6051622&irgwc=1&utm_source=impact&utm_medium=affiliate&utm_campaign=6051622&utm_term=VDtyKmWguxycUCnw9WSmN0UIUkp3aM1VyS6t3Y0

Letter to FTC: Investigate Casey Means’ Potential Violations of Influencer Marketing Standards

February 4, 2026

Chris Mufarrige
Director, Bureau of Consumer Protection
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580

Dear Chris Mufarrige:

I am writing to urge the Bureau of Consumer Protection to investigate whether Dr. Casey Means has violated Federal Trade Commission (FTC) policy on undisclosed endorsements and product advertisements (“influencer marketing”) and take appropriate action.

As you know, a longstanding, core principle of fair advertising law in the United States is that people have a right to know when they are being advertised to. With that knowledge, consumers can hopefully apply the appropriate emotional and intellectual filters to advertisements, discounting puffery and claims of authenticity. By contrast, disguised advertisements are inherently deceptive, because consumers do not know to apply appropriate screens. The issue is acute with disguised ads featuring paid endorsements, where deceived consumers believe admired celebrities are making genuine, self-directed and enthusiastic endorsements of brands, not realizing that those celebrities are instead paid and may not even use the touted brand.

Public Citizen has long been concerned about the issue of undisclosed product advertisements, particularly in the era of social media and influencer marketing, where everyone from neighbors to celebrities may be paid to promote products and services in their social media feeds. In 2016, with colleague organizations, we highlighted dozens of cases of undisclosed influencer marketing, leading to more than 90 notices from the FTC to influencers.

The FTC has elucidated clear standards for endorsement disclosure in its endorsement guidelines. The guidelines are clear that endorsement disclosures must be made in every promotion, not just generically. Specifically, if a person is using their social media account to promote a product or service in exchange for compensation, they must note the paid relationship in social media post, not just in their biography. From example 9(i) of the endorsement guidelines:

An influencer who is paid to endorse a vitamin product in their social media posts discloses their connection to the product’s manufacturer only on the profile pages of their social media accounts. The disclosure is not clear and conspicuous because people seeing their paid posts could easily miss the disclosure.

The logic of this rule is clear: Because most people will miss the disclosure in the profile page, that disclosure does not adequately inform consumers and enable them to contextualize the advertisement they are seeing as an advertisement.

The agency’s “Disclosures 101 for Social Media Influencers” – a plain language presentation of the guidelines — makes the rules and rationales very clear:

  • The disclosure should be placed with the endorsement message itself.
  • Disclosures are likely to be missed if they appear only on an ABOUT ME or profile page, at the end of posts or videos, or anywhere that requires a person to click MORE.
  • Don’t mix your disclosure into a group of hashtags or links.
  • If your endorsement is in a picture on a platform like Snapchat and Instagram Stories, superimpose the disclosure over the picture and make sure viewers have enough time to notice and read it.
  • If making an endorsement in a video, the disclosure should be in the video and not just in the description uploaded with the video. Viewers are more likely to notice disclosures made in both audio and video. Some viewers may watch without sound and others may not notice superimposed words.

Dr. Casey Means is a wellness influencer and entrepreneur. She is President Trump’s nominee for Surgeon General.

Dr. Means founded and is the chief medical officer of Levels, a membership-based continuous glucose monitoring technology company, and is co-author of New York Times best-selling book Good Energy.

Dr. Means also maintains a website, weekly newsletter, and robust social media presence where she posts about wellness and promotes wellness products. She has 200,000 newsletter subscribers, 852,000 followers on Instagram, 86,300 followers on TikTok, and 230,200 followers on X/Twitter.

In required ethics and financial filings to the U.S. Office of Government Ethics (OGE), Dr. Means has disclosed receiving hundreds of thousands of dollars in sponsorship and affiliate fees from product sales generated through her newsletter and social media platforms, including from companies in which Dr. Means is also an investor and/or advisor.[1]

In her TikTok and Instagram profiles, Dr. Means notes her affiliation with Levels and her book. The “About” section on her website also references her book and affiliation with Levels.

However, Public Citizen’s review of Dr. Means’ website, newsletter, and social media feeds found that for the almost two dozen companies from which Dr. Means reported receiving affiliate fees, Dr. Means disclosed her financial relationship inconsistently and ambiguously. In total, she failed to disclose her financial relationship 79 out of 140 (56%) times she promoted affiliated products.

Our analysis is based on posts made on Dr. Means’ website, newsletter, Instagram, and TikTok during the period between January 1, 2024 to August 8, 2025. This is the same period covered by Dr. Means’ OGE financial filings. However, it is not possible to know exact timing of her affiliate marketing arrangements vis-à-vis her posts based on the information that is publicly available. Public Citizen identified the first instance in which Means publicly disclosed a financial relationship between herself and the company and calculated total product mentions beginning at that date.

For example, Dr. Means disclosed that Momentous supplements was a sponsor for the first time on November 12, 2024 in her newsletter.[2] She had promoted Momentous products on her platforms six times before that, but we excluded those instances from our tally because they occurred prior to the initial disclosure. This methodology means that our estimated rate of failed disclosure is likely conservative.

Other instances of failed disclosures include her promotion of lab testing platform Function Health. Dr. Means is an investor in lab testing platform Function Health and has also collected $59,847 in newsletter sponsorship and partnership fees from the company. Despite this, she disclosed her sponsorship agreement with Function less than a third of the times she promoted the company on her website and social media platforms (4 out of 13 times).[3]

Genova Diagnostics, a home testing company, paid Dr. Means a total of $20,000 for book tour and sponsorship fees.[4] Of the nine times Dr. Means promoted Genova testing products on her platforms, she disclosed the company’s sponsorship only twice.[5]

Dr. Means also took $12,000 from meal kit company Daily Harvest, Inc. Of the 14 times Dr. Means promoted Daily Harvest on her platforms, she mentioned her paid partnership only three times.[6]

Dr. Means also reported taking $832 in partnership fees from WeNatal Inc.[7] In a blog post dated September 24, 2024 she noted that she has “no financial relationship to the company, just a big fan.” In another blog post dated October 29, 2024 she promoted WeNatal under a header that says “not sponsored, just love these However, as early as March 2024 Dr. Means was using affiliate links to WeNatal in her newsletter and posting TikTok videos tagged as paid partnerships.

Most egregious is her promotion of Zen Basil edible basil seeds, which paid her a combined $22,104 for newsletter sponsorship and partnership fees.[8] Dr. Means disclosed the sponsorship only two out of 13 times she promoted Zen Basil on her platforms.[9]

These are just a few of the companies that Dr. Means promoted on her platforms with inconsistent disclosures. It is thus essential that the FTC investigate Dr. Means’ potential violations of influencer marketing policies, especially given that Dr. Means could soon have substantial influence over the healthcare market in which she and many of her financial partners operate.

We have included a table in an appendix to this letter which lists the companies named in Dr. Means’ OGE filings and provides links to instances where she failed to disclose a paid partnership with those companies.

Thank you for your consideration of this issue.

Sincerely,

Eileen O’Grady
Public Citizen

____________________________________________________

[1] Means OGE form 278E.

[2] See here: https://www.caseymeans.com/learn/newsletter-37

[3] Appendix: Public Citizen analysis of fees disclosed in OGE 278E filing as well as website, newsletter, and social media posts.

[4] Means OGE 278E, pg. 11 and 13.

[5] See Appendix.

[6] See Appendix.

[7] WeNatal is listed twice in table 2 (“Filer’s Employment Assets & Income and Retirement Accounts”) of Dr. Means 278E filing: $536 and $296 in partnership fees. See pg. 12 and 14.

[8] See page 12 and 14 of Means OGE form 278E.

[9] See Appendix.

 

 

 

 

 

 

 

Support Legislation to End Forced Arbitration

Fact Sheet

Overview

Many Americans assume that they have a Constitutional right to their day in court, only to discover that predispute forced arbitration clauses take away the right to have their claims heard in a public court. The ability to access the courts is critical for individuals to seek relief for corporate or government wrongdoing. Pursuing claims in the judicial system, however, has become increasingly difficult for consumers and employees because corporations have worked hard to shield themselves from accountability, including by inserting forced arbitration clauses in a wide array of consumer and employment contracts.

  • Forced arbitration clauses are provisions inserted in contracts that specify that any future disputes with the company must be addressed by an arbitration firm and cannot be brought in court. These clauses are ubiquitous in a large variety of nonnegotiable contracts, including many employment agreements, credit-card agreements, cellphone agreements, and countless other types of contracts. Forced arbitration clauses also typically include language prohibiting the worker or consumer from bringing any future claims as class actions, making it easier for companies to get away with unlawful or unfair practices that harm many people but would not be efficient to challenge individually.
  • Arbitration proceedings are notoriously secretive. Proceedings and decisions are, with few exceptions, not made public or required to be reported to state or federal courts or agencies. Arbitrators are not required to follow state and federal court procedures, and traditional rules of discovery do not apply. Arbitration firms generally lack diverse arbitrators, making it especially difficult for consumers of color and consumers from disadvantaged communities to be heard by an arbitrator with similar life experiences.
  • Forced arbitration clauses typically leave consumers and employees with no dispute-resolution alternatives and favors corporations. Forced arbitration clauses often name a specific arbitration firm, and because arbitration firms rely on return-business to make a profit, arbitrators have an incentive to rule in favor of the corporation to cultivate a happy return-customer relationship.
  • Corporations can, and often do, update their terms of service with limited or no prior notice to the consumer or employee. Sometimes, corporations will update their terms of service in anticipation of a legal dispute, allowing them to adopt more favorable terms for themselves.

Public Citizen has a long history of fighting companies’ use of forced arbitration in contracts with consumers and employees and  advocating for legislation that would give employees and consumers the right to decide in what forum to bring their claims.  Congress has taken some steps to limit the use of forced on vulnerable communities. For example, in 2022 Congress enacted legislation protecting victims via the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act, which allowed individuals alleging sexual assault or harassment to choose between pursuing claims in court or arbitration.

The FAIR Act

The Forced Arbitration Injustice Repeal (FAIR) Act would amend Title 9 of the United States Code to prohibit forced arbitration for employment, consumer, antitrust, and civil rights disputes. When enacted, the FAIR Act would make it possible for employees and consumers to pursue their cases in public court if they choose.  The FAIR Act would similarly prohibit bans on class actions that interfere with the right of individuals, workers, and small businesses to band together to bring lawsuits, allowing people with low-dollar claims a means of seeking redress. At the same time, the FAIR Act would allow parties to choose arbitration after a dispute arises. On September 15, 2025, the FAIR Act was  reintroduced  in the House by Rep. Johnson (D-GA) (H.R. 5350 ) and in the Senate by Sen. Blumenthal (D-CT) (S. 2799).

Other Arbitration Legislation Public Citizen Supports

Protecting Older Americans Act 2025 (S. 2703, Gillibrand (D-NY), & H.R. 5115, Lawler (R-NY)), would prohibit the enforcement of predispute arbitration agreements and predispute joint-action waivers in employment agreements, with respect to disputes involving age discrimination.

Ending Forced Arbitration of Race Discrimination Act of 2023 (S. 1408, Sen. Booker (D-NJ), & H.R. 6172, Rep. Bell (D-MO)), would make pre-dispute arbitration agreements unenforceable in cases concerning race discrimination.

Investor Choice Act of 2024 (S. 3715 , Merkley (D-OR) & H.R. 7168 Foster (D-IL)), would prohibit broker-dealers and investment advisers from including mandatory arbitration, forum selection restrictions, or restrictions on which court(s) or arbitration providers can hear a claim, and would also prohibit bans on class action suits in customer or client agreements. The bill would also prohibit issuers of securities from including forced arbitration provisions in shareholder agreements. (This bill has not yet been reintroduced in the 119th Congress.)

Members of Congress must take action to address the problem of forced arbitration and we urge them to support proposals to increase access to the courts.

Contact
Martha Perez-Pedemonti
Access to Justice and Consumer Rights Counsel
Congress Watch, Public Citizen
mperezpedemonti@citizen.org

Third Letter Sent to OMB Urging the Suspension and Removal of Grok from Federal Agencies

The most recent letter comes after Grok created nonconsensual sexualized images of women and apparent minors

Director Russell Vought
Office of Management and Budget
Executive Office of the President
725 17th Street, NW
Washington, DC 20503

Re: Third Follow-Up on Federal Procurement of Grok AI

Dear Director Vought,

We write to follow up on our August 28, 2025 and October 29, 2025 coalition letters urging the Office of Management and Budget (OMB) to suspend the federal deployment of Grok, the large language model developed by xAI. It is deeply concerning that the federal government would continue to deploy an AI product with system-level failures resulting in generation of nonconsensual sexual imagery and child sexual abuse material. Given the administration’s executive orders, guidance, and the recently passed Take It Down Act supported by the White House, it is alarming that OMB has not yet directed federal agencies to decommission Grok.  The General Services Administration has continued to make Grok available government-wide under its OneGov contract. This continued deployment is inconsistent with Executive Order 14319 and OMB’s binding AI safety and neutrality guidance.

Grok has demonstrated persistent and escalating failures related to accuracy, neutrality, and safety — including the generation of racist, antisemitic, conspiratorial, and false content, as well as sexually exploitative outputs. These failures are extensively documented and widely reported. Elon Musk himself has said Grok is “very dumb,” committed a “dumb error” resulting in the AI bot being banned on X, and at times “too compliant to user prompts.” This level of corporate conduct and system failures are patently incompatible with the Administration’s own requirements for federally procured AI systems. Under OMB’s guidance, systems that present severe and foreseeable risks that cannot be adequately mitigated must be discontinued. Grok meets that standard.

This letter reiterates our prior concerns, documents new and disqualifying failures, and underscores that Grok’s behavior directly contradicts Executive Order 14319 and OMB M-25-21 and M-25-22.

Grok Violates the Administration’s Own AI Rules

Executive Order 14319 and OMB’s implementing guidance requires that AI systems procured by the federal government be truth-seeking, accurate, ideologically neutral, and subject to effective risk mitigation. OMB M-25-21 and M-25-22 require agencies to discontinue use of an AI system if proper risk mitigation is not possible. OMB M-25-22 further requires that any acquisition of AI conform to the standards in M-25-21. This language in totality argues for the complete removal of Grok from the OneGov contract.

Sexual Exploitation, Nonconsensual Imagery, and Child Harm

In December 2025, Grok began producing sexually exploitative content involving minors and nonconsensual sexualized imagery of women at an alarming rate. Public demonstrations and reporting show Grok responding to prompts explicitly seeking to generate sexualized images of real or hypothetical individuals without consent, including images involving children. On December 28, 2025 alone, Grok reportedly generated approximately one nonconsensual sexual deepfake per minute.

These outputs include sexually explicit and sexually suggestive images and narrative descriptions generated in response to user requests, including attempts to convert images into child sexual abuse material. The production of any such content is incompatible with federal procurement, federal child protection policy, and OMB’s AI safety framework.

These are not isolated incidents. They reflect systemic failures in xAI’s ability to enforce baseline protections against sexual exploitation, child harm, and nonconsensual abuse. As we warned in our prior letters, Grok’s architecture and content moderation safeguards are insufficient to prevent foreseeable and severe harms, particularly to women and children.

Under OMB Memorandum M-25-21, agencies are required to discontinue the use of AI systems when foreseeable risks of severe harm cannot be adequately mitigated. The continued production of sexualized content involving minors and nonconsensual sexual imagery demonstrates that such mitigation has not been achieved. These failures independently require immediate suspension and investigation of Grok’s federal deployment.

An AI system capable of generating sexualized depictions of minors or facilitating nonconsensual sexual imagery cannot meet the minimum safety threshold for federal use. Grok’s continued availability under the OneGov contract therefore represents a direct violation of OMB’s binding risk mitigation requirements.

AI Director Michael Kratsios Testimony on Executive Order 14319

During September 10, 2025 testimony Director Kratsios confirmed that AI systems procured by the federal government must be truth-seeking, accurate, and compliant with Executive Order 14319 and OMB’s implementing guidance. In his testimony Director Kratsios further confirmed that models producing antisemitic content, Holocaust denial, conspiratorial outputs, or ideological bias are in violation of those requirements.

The behaviors documented from Grok fall squarely within the conduct the executive order and OMB memoranda were designed to prohibit. Grok’s outputs, as publicly reported and previously detailed, are inconsistent with the standards required for federally procured AI systems. The continued federal deployment of Grok in light of these acknowledged violations is indefensible.

Required Actions

OMB must take immediate action to bring federal AI procurement into compliance with Executive Order 14319 and OMB Memoranda M-25-21 and M-25-22. Specifically, OMB must:

  • Immediately suspend the federal deployment of Grok under the GSA OneGov contract pending a full compliance determination.
  • Initiate a formal investigation into Grok’s safety failures and the procurement and oversight processes that permitted its federal deployment, including whether required risk assessments, mitigation measures, and compliance determinations were conducted and appropriately reviewed.
  • Publicly clarify whether Grok has been evaluated for compliance with Executive Order 14319’s truth-seeking and neutrality requirements and whether it was determined to meet OMB’s risk mitigation standards.
  • Require disclosure of all safety testing, red-teaming results, and risk assessments conducted on Grok as a condition of any continued consideration for federal use.
  • Account for the legal basis on which Grok remains available to federal agencies despite documented violations of OMB’s binding guidance.

OMB is entrusted with ensuring that AI systems procured by the federal government meet the highest standards of safety, truth-seeking, accuracy, and neutrality. OMB has declared to uphold public trust in AI systems while delivering government efficiency and innovation. Grok has not only repeatedly failed to meet these standards, but has demonstrated escalating and disqualifying harms, including the generation of nonconsensual sexual imagery and content involving the sexual exploitation of minors. This is deeply damaging of public trust in the government’s AI deployment and use. As Director Kratsios has acknowledged, such conduct is precisely the type of behavior Executive Order 14319 and OMB’s binding guidance were designed to prevent.

Continuing to deploy Grok in the federal government is wholly inconsistent with OMB’s own safety mandates, the Administration’s AI Action Plan, and the core commitments of Executive Order 14319. We therefore urge OMB to take immediate corrective action to suspend Grok’s deployment, investigate how these failures occurred, and prevent further erosion of public trust, institutional integrity, democratic governance, and national security.

 

Respectfully submitted,

Public Citizen
Center for AI and Digital Policy (CAIDP)
AFT
Autistic Women & Nonbinary Network
Asian Americans Advancing Justice
Center for Biological Diversity
Center for Economic Justice
Center for Oil and Gas Organizing
Center for Progressive Reform
Color Of Change
Common Cause
Consumer Federation of America
Demand Progress
Distributed AI Research Institute
Government Information Watch
Indivisible
Memphis Community Against Pollution
Mossville Environmental Action Now (MEAN)
MPower Change
National Association of Voice Actors
Open MIC
Oxfam America
People Power United
Presente.org
Stand.earth
The Leadership Conference on Civil and Human Rights
The Value Alliance
UltraViolet
United Church of Christ Media Justice Ministry
Welcoming America

 

CC:

U.S. Government Accountability Office
U.S. House of Representatives Oversight Committee
U.S. Office of Science and Technology Policy
U.S. Senate Oversight Committee
U.S. Federal Trade Commission

Product Recalls: December 17, 2025 – January 14, 2026

Health Letter, February 2026

Note: Never stop taking a drug that appears on the product recall list without first talking to your doctor or pharmacist. Most recalls are limited to a single manufacturer and may not be related to the version of a particular drug you are taking. If a recall does relate to the version of the drug you are taking, you should not stop taking the drug until you discuss an alternative treatment with your doctor or pharmacist.

For Class 1 recalls, there is a potential for serious injury or death.

For Class 2 recalls, there is a potential for serious adverse events but a lower chance of the drug causing serious injury or death than in a Class 1 recall.

CLASS I

CLASS II

baclofen tablets, 10 mg, 1,000-count bottles. Marketed by: GSMS, Incorporated. Lot #: GS065762.

ondansetron ODT tablets, 4 mg, 1×10 unit dose tablets or 3 blistercards each containing 10 tablets. Manufactured by: Glenmark Pharmaceuticals Limited. Lot #: J1325J or I1725P, exp. date: 4/30/2027; Lot #: 19251311, exp. date: April 2027.

oxycodone and acetaminophen CII tablets, 10 mg/325 mg or 7.5 mg/325 mg, 100 tablets. Manufactured by: SpecGx LLC. Lot #: 0523J23904, exp. date: 05/2027; Lot #: 0523J24426 or 0523J24427, exp. date: 06/2027; Lot #: 0522J23493, exp. date: 03/2027.

For more information about the drug recalls listed above, please visit http://www.accessdata.fda.gov/scripts/ires/index.cfm.

CONSUMER PRODUCTS

For a list of recent recalls of consumer products, please visit the Consumer Product Safety Commission website at http://www.cpsc.gov/en/Recalls/.

Outrage of the Month: CDC Funding of a Troubling Guinea-Bissau Hepatitis B Vaccine Study

Health Letter, February 2026

By Robert Steinbrook, M.D.
Director, Public Citizen's Health Research Group

If you’re not outraged, you’re not paying attention!

Read what Public Citizen has to say about the biggest blunders and outrageous offenses in the world of public health, published monthly in Health Letter.

In December 2025 the Centers for Disease Control and Prevention (CDC) awarded a single-source, unsolicited $1.6-million grant to the University of Southern Denmark to conduct a five-year “comparable study of the optimal timing and delivery of monovalent Hepatitis B vaccinations on newborns in Guinea-Bissau.”

The Danish researchers have ties to Tracy Beth Høeg, a top Food and Drug Administration official, who is also the agency’s representative to the CDC’s Advisory Committee on Immunization Practices (ACIP). One of the researchers was recently appointed to an ACIP work group.

Additional funding for the research comes from the Pershing Square Foundation, which is led by billionaire hedge fund manager Bill Ackman. Ackman shares Health Secretary Robert F. Kennedy Jr.’s vaccine skepticism and supported his 2024 presidential campaign.

Everything is wrong with the study and the CDC funding, including the approval process, concerns about conflict of interest, and the dubious ethics of the research. The CDC should not fund a study that would be unethical to conduct in the United States.

After reports in January that the study had been cancelled, federal health officials doubled down, dismissed concerns about ethical violations, and said the research would proceed as planned. Days later, however, public health officials in Guinea-Bissau blocked the study, stating that it had received inadequate ethical review and perhaps had not been reviewed at all. It is also uncertain whether the study has been evaluated by an institutional review board at the University of Southern Denmark or in the United States. No credible institutional review board in Europe or the United States would approve the study.

Guinea-Bissau is a country in West Africa with a population of about 2 million and a high prevalence (about 20%) of chronic hepatitis B infection. Guinea-Bissau is also one of the world’s least developed nations and one of the world’s 10 poorest countries.

In 2027 Guinea-Bissau plans to implement a universal hepatitis B vaccine policy for newborns, as recommended by the World Health Organization and, until recently, by the ACIP and the CDC. Without such a policy, many babies exposed to the hepatitis B virus at birth will continue to become chronically infected and eventually die of hepatitis B-related liver failure or liver cancer.

During 2026 the researchers planned to randomize newborns to receive the hepatitis B vaccine at birth (the 2027 policy) or no hepatitis B vaccine at birth (the current policy). All children were to receive the hepatitis B vaccine at 6, 10 and 14 weeks after birth, under Guinea-Bissau’s current vaccination program. Thus, half of the children were to receive an additional dose of hepatitis B vaccine at birth.

Even if Guinea-Bissau has yet to transition to a universal birth dose of the hepatitis B vaccine, it is ethically and medically wrong to randomize children to an inferior vaccination schedule. The benefits of the birth dose of the hepatitis B vaccine are fully established and extend throughout life; they are not limited to five years after birth.

As discussed in Public Citizen’s Health Letter in January, the ACIP and the CDC senselessly undermined the success of hepatitis B vaccination in the United States by recommending replacing the universal birth dose of the vaccine with individual-based decision-making, a change that the American Academy of Pediatrics promptly condemned.

The CDC should come to its senses. The Guinea-Bissau hepatitis B vaccine study should be permanently cancelled and the funds used to help the country make a birth dose of the hepatitis B vaccine available to all newborns.

Public Citizen Comments to the Public Utility Commission of Texas Regarding the Texas Backup Power Program

To: Chairman Gleeson and Commissioners 

Submitted via online portal. 

From: Kamil Cook and Kaiba White, Public Citizen, kcook@citizen.org and kwhite@citizen.org, 512-477-1155 

Re:  Texas Backup Power Program docket 59024 

On behalf of 30,000 members and supporters in Texas, Public Citizen appreciates the opportunity to provide comments to the Public Utility Commission of Texas relating to Docket #59024 and the Texas Backup Power Program (TBPP).  

Executive Summary from Public Citizen:  

  • A cost-sharing of 10% should be required of for-profit entities. Cost-sharing is not recommended for non-profit and government entities. 
  • Add pharmacies and all grocery stores to the list of critical facilities 
  • Allow entities to calculate their critical load to use for calculating back-up system requirements 
  • Require a minimum of12 hours of battery backup for critical loads 
  • Allow for systems that can’t recharge from solar in 6 hours if on-site space is not available 
  • Allow ERCOT to call on TBPP awardees during grid emergencies to use their backup power on-site to reduce total load on the grid.  
  • Allow TBPP installations to supplement existing back-up power systems, where need is demonstrated 
  • Encourage projects that serve Texans who are under the poverty line.  

Question 1: Should the commission require TBPP awardees to contribute a dollar amount towards the total TBPP cost as a condition of the award of a loan or a grant (the “cost-share”)? If yes, what is an appropriate cost-share amount for the applicant? Should the cost-share be expressed in nominal dollars, on a dollar-per kilowatt basis, or some other metric? 

 Cost-sharing would help ensure that awardees make a full effort to obtain competitive vendor prices. However, nonprofit and governmental entities may not have access to funds to enable a cost share. Therefore, we recommend that for-profit awardees be required to contribute 10% of the total project cost. Non-profit and government entities should not need to cost-share, since profit is not motivating their application and requiring cost-sharing in these sectors may unfairly limit access to back-up power.  

Public Citizen has no comments on Questions 2 & 3.  

Additions to the List of Critical Facilities 

Section b) 1) C) (ii) should be amended to “a medical facility, pharmacy, or facility providing hospice, nursing, assisted living, or end-stage renal disease treatment and dialysis;” 

Section b) 1) C) (iv) should be amended to “an evacuation route fuel station or a gas station” and a new subsection to b) 1) C) read “grocery store;” 

We recommend including all grocery stores as critical infrastructure. Few grocery stores currently have backup power. Even in areas with good access to grocery stores during normal operating conditions, those areas are still without any access during grid emergencies. Also, deliveries are often interrupted and delayed during grid outages, so having more local supply of food that is able to stay fresh would be beneficial and help avoid shortages.  

Identify Critical Loads and Adjust Minimum Battery and Solar Energy Requirements  

Section B) 3) a) (vii) should be amended to “be able to produce energy from the battery storage component sufficient to serve the critical facility’s calculated critical load/demand for 12 hours and produce energy from photovoltaic panels sufficient to recharge the battery storage component within six hours, unless the applicant demonstrates a lack of space on the site suitable for solar energy that isn’t occupied by trees or other equipment. ” 

An additional subsection should be added following section B) 3) a) (vii) that defines calculated critical demand as such:  

  • Calculated critical demand is the demand from essential infrastructure that would be running during a grid emergency. This would be self-calculated, and checked by a representative from the PUC, to confirm that all the infrastructure that needs to be powered is essential. Calculated critical demand can be the entire demand of a facility, or may be less, if non-critical loads can be identified.  

Many facilities can reduce energy usage during an emergency by eliminating non-essential activities and equipment. For example, assisted living facilities may have heated pools that can be turned off during emergencies. It’s more cost-effective to provide backup power only for what is truly needed during emergencies.  Including calculated critical demand allows for more flexibility for facilities as well as wider distribution of funds to more entities.  

One hour of battery backup is far too little to require. Even minor local outages often last longer than an hour, and the proposed rule requires each system to be able to provide at least 48 hours of backup power. We recommend that a minimum of 12 hours of backup of critical load be provided by the battery to ensure that batteries are a substantial contributor to each installation and the program as a whole.  

Regarding the recharge time requirement, we recommend including a variance for sites where there may not be sufficient roof space or other space on the property to support sufficient solar to recharge a battery that can back the facility up for 12 hours within 6 hours. If there isn’t enough solar to recharge the battery, solar should be maximized on the property without making major adjustments to the property or facility.  

Allow ERCOT to Utilize TBPP Installations to Avoid Outages 

Section b) 3) B) the following should be added to this section: “ERCOT may call upon TBPP awardees to use their backup power for onsite use during an Energy Emergency Level 2 or 3, thus reducing total load on the grid.” 

Allow for Co-Locating TBPP installations with Existing Solar, Batteries and Generators 

Section d) 1) D) should be amended to “Grant or loan funds received under this section must not be used for a facility that installs a source of backup power that does not follow the design and use standards of a TBPP, unless those noncompliant backup power systems were installed separately from the TBPP project. Sites with existing backup power systems must demonstrate that the additional capacity proposed for the TBPP is needed to meet critical loads, even with the existing system(s).  

Sites with existing onsite batteries and solar should not be excluded from receiving TBPP funding to supplement those systems if there is a demonstrated need.  

Include considerations for historically under-invested areas 

Section f) 2) A) should amended to include a section (viii) “the facility’s ability to serve low-income residents. Facilities that serve predominately low-income residents or are located in a community where more than 20 percent of residents are living below the federal poverty line will receive priority.”  

Facilities serving low-income residents may be less well equipped to respond to grid emergencies or invest in backup power for the community’s benefit and should therefore be prioritized in the TBPP. 

Critical Conflicts: Trump Subsidizes Dirty Mining at the Expense of Public Lands

Key Findings

  • The Trump administration is working with some of the world’s largest mining corporations — based in Australia, Canada, Chile and the United Kingdom — to ramp up mineral extraction on or near millions of acres of America’s public lands. This new gold and minerals rush gives away public lands, skirts environmental standards, overrides tribal interests, and confers massive benefits on Trump insiders and allied billionaires.
  • 13 companies seeking to mine on national public lands — including several Australian and Canadian corporations  — spent more than $8.4 million to lobby the federal agencies and Congress in 2024 and 2025 alone. 
  • The Trump administration’s use of taxpayer money to buy ownership stakes in mining projects that the federal government also regulates sets up a fundamental conflict of interest, providing an incentive for the government to push mining without proper environmental, ethical and community input standards. So far, the Trump administration has signed six equity and loan deals for mining and minerals processing projects.
  • Billionaires and corporate executives have already seen the value of their holdings in mining companies soar over the past year after the federal government took stakes in mining firms, leading some corporate executives and directors to sell off their shares and earn millions.
  • To advance their agenda in the nation’s capital, mining companies have hired lobbying firms with close Trump connections, including a firm run by Trump’s former Interior Secretary, David Bernhardt and a firm run by former Republican National Committee Chair Reince Priebus. 

Introduction: Dirty, Deadly Mining Titans Eye America’s Public Lands

The mining industry is one of the world’s dirtiest and most exploitative corporate sectors, with a lengthy track record of environmental and human rights abuses. In the United States, the mining sector operates under outdated laws that have been largely unchanged for 150 years and provide scant public protections. Under Trump’s sweeping deregulatory agenda, the industry is getting an easier path to pollute public lands without paying a dime in royalties to compensate taxpayers and even taxpayer-funded investments to prop up mining companies themselves. Now, to an extraordinary extent, global mining companies are allying with the second Trump administration to threaten iconic American national parks, forests and monuments in the service of private profit.

The Trump administration has been relentless in its push to open up mining and drilling on public lands, threatening scenic views, water quality and wildlife migration in national parks, forests and monuments. The Trump administration has short-circuited environmental reviews, shut out the public, rushed through permits and promoted the privatization of public lands, making it far easier for corporate interests to mine and drill on America’s most treasured and iconic places, including many sacred to Indigenous tribal nations. 

Interior Secretary Doug Burgum is a key player in the Trump administration’s pro-mining agenda. Burgum’s agency administers our national parks and public lands, including the Bureau of Land Management, which oversees 245 million acres, and the 85 million acres of the National Park System. 

At his confirmation hearing in January 2025, Burgum made clear that America’s treasured places are ripe for exploitation and extraction. A former software executive, real estate and fossil fuel investor turned politician, Burgum referred to America’s public lands and waters as “America’s balance sheet,” telling Senate lawmakers, “Not every acre of federal land is a national park or a wilderness area.” 

Over the summer, Burgum claimed to “care deeply” about conservation and public lands but also said they should be used for private profit. “We have western states that are being choked because they have so much public land and there’s so much overreach by the federal government,” Burgum said, while also accusing the Biden administration of “chasing an idealism around climate extremism.”

Months later, Burgum issued permits for a more than 200-mile road across pristine Alaska wilderness over the objections of Alaska Native tribes, hunters, anglers and conservation groups. Mining companies have long sought the road, known as the Ambler Access Project, to reach deposits of copper, zinc, lead and other minerals. The long-controversial proposed road, denied by the Biden administration, would cross 26 miles of Gates of the Arctic National Park and Preserve, harming wildlife migration and harming Indigenous communities that rely on caribou for subsistence hunting. 

The Alaska project is being developed by Ambler Metals, a joint venture between Canadian mining firm Trilogy Metals and Australian mining firm South 32 Limited. The managing director of the joint venture, Kaleb Froehlich is the former chief of staff to Sen. Lisa Murkowski (R-Alaska) and works for law and lobbying firm Holland and Hart, where he has worked for numerous mining clients. 

Trump’s corporate-controlled administration is pushing an aggressive pro-extraction agenda that is rapidly removing protections for public lands, clean air and clean water. Americans are being put at higher risks of impacts from mining’s toxic pollution so that billionaires and mining executives can profit, an astonishing demonstration of corruption. 

Public Lands Suffer as Government Props Up Mining Companies

The second Trump administration has broken strongly with longstanding Republican orthodoxy, making direct government investments in private companies that would have been unthinkable for prior Republican administrations.  “We should take stakes in companies when people need something. I think we should take stakes in companies. Now, some people would say that doesn’t sound very American. Actually, I think it is very American,” Trump told the Wall Street Journal “Now, some people would say that doesn’t sound very American. Actually, I think it is very American.” 

Trump’s federal interventions include an $8.9 billion purchase of Intel Corp stock, a $400 million investment in rare earths miner MP Materials and several other mining and minerals processing investments — with more to come. The Trump administration’s pro-mining, anti-regulation stance — combined with the extraordinary speed of the government’s actions – raises important ethical, governance, and environmental concerns. 

Government investment into private companies in exchange for equity and public benefit could foster jobs and environmental protection under a progressive green industrial strategy. But to be successful, such strategies require strict ethics guardrails and environmental protections, which are sorely lacking under Trump. 

Under Trump’s mining policies, public funds are being directed toward highly speculative companies with little transparency around how companies are chosen, with decisions made in private with no clear criteria or public disclosure. This lack of visibility creates opportunities for favoritism, combined with lax regulation and weak oversight. For example, the Trump administration fired the inspector general for the Export-Import Bank, a move that raises serious questions about accountability and oversight for mineral financing programs such as the Ex-Im Bank’s $50 million loan to a gold mining project in Nevada.

A White House executive order from March set the stage for this massive mining intervention. It specified that, in federal lands with mineral deposits and reserves, the Interior Secretary must prioritize mining as “the primary land uses in these areas” — indicating that the Trump administration plans to tilt the scale against other public lands uses, such as outdoor recreation. The order also waived caps on Pentagon financing for mineral production and pledged to expand public investment in domestic and foreign mining through several federal agencies, including the Export-Import Bank, Development Finance Corporation and Department of Energy. 

The White House even granted the mining industry a regulatory favor, requiring federal agencies to waive disclosure requirements requiring mining companies to provide detailed evidence showing that their investments are economically feasible. And under the Republicans’ One Big Beautiful Bill Act, mining companies are eligible for $12.9 billion in direct government grants, according to an analysis by Earthjustice Action, as well as $355 billion in loans under several government programs. 

Mining companies receiving this support include Trilogy Metals, Lithium Americas, and MP Materials, and potentially more, giving opportunity for executives at these companies to turn quick profits. For example:

Trilogy Metals: Executives and directors at the Canadian mining firm made about $8.7 million in profit by exercising stock options during the immediate share price spike after the October 6 announcement that the Pentagon would purchase nearly $36 million in company stock, according to Securities and Exchange Commission filings. Trilogy Metals’ chief financial officer, Elaine Sanders, exercised stock options and sold off shares for a profit of $3.15 million shortly after news of the federal investment broke, sending shares of the company to above $10 per share, up from 57 cents before Trump’s election.

MP Materials: James Litinsky, CEO of the Las Vegas-based rare earths mining firm,  has sold off about $40 million in shares in fall 2025 after the federal investment, fetching share prices above $60, double the share price in June. Ryan Corbett, the company’s chief financial officer, sold off about $3.4 million in stock.

Writing for the Council on Foreign Relations, William Henagan and Ely Sandler describe the Trump administration’s approach as similar to an aggressive Wall Street investor. “The current administration behaves like a hedge fund: actively identifying, backing, and intervening in individual firms that it believes can become national champions,” they wrote, noting that this sort of government intervention offers many potential avenues for corruption and could be subject to legal challenge. “State intervention, particularly at the level of an individual firm, is inherently vulnerable to abuse,” they wrote. “The president and members of the cabinet can decide the fate of individual companies rather than a whole sector or strategic industry. That power can create immense wealth almost overnight.”

Treasury Secretary Scott Bessent has blamed environmental groups U.S. for rare earths supply problems and mocked the need for environmental regulations. “This rare earths problem was decades in the making, every past administration should be ashamed,” Bessent told CNBC. “President Trump tried to solve it in his last term but the environmentalists threw a fit, so here we are.”

In response, libertarians and even some elected Republicans are concerned about the Trump administration’s decision to take equity stakes in companies. Sen. Lisa Murkowski (R.-Alaska), a strong supporter of mining, has questioned whether government ownership will lead to shortcuts and favoritism. “All projects need to be able to stand on their own and be able to meet the tests that we put in place in terms of the regulations and the environmental hurdles,” Murkowski said, according to Alaska Public Media. 

Despite such concerns, administration officials say they plan to make more direct investments in mining companies. Trump told reporters with characteristic bluster, in announcing a rare earths agreement with Australia: “In about a year from now, we’ll have so much critical mineral and rare earths that you won’t know what to do with them.” 

Table 1: Trump Administration Mining, Critical Minerals Investments 

Date Company Name Project (Location) Mineral/Facility Deal Terms
7/10/25 MP Materials Mountain Pass (California)  Rare Earths Defense Department purchased a $400 million stake in MP Materials, which owns the only active rare earths mine in the U.S., becoming the company’s largest shareholder. The Pentagon also made a $150 million loan to the company in order to expand capacity at its mine in California.
10/1/25 General Motors/Lithium Americas Thacker Pass (Nevada) Lithium Energy Department took a 5% stake in Lithium Americas and a 5% stake in the Lithium Americas-GM joint venture, restructuring a prior Biden administration loan deal 
10/6/25 Trilogy Metals Ambler Mining District (Alaska) Copper, zinc, lead, gold silver  Pentagon agreed to invest nearly $36 million in Alaska mining by taking a 10% stake in Vancouver-based Trilogy Metals, with the right to acquire an additional 7.5% of the previously obscure company. 
11/3/25 Vulcan Elements, ReElement  North Carolina Rare earths manufacturing Defense Department and Commerce Department announced a plan to provide $670 million in public loans and equity investments to manufacture rare earth magnets, along with $550 million in private investment.
12/15/25 Korea Zinc Clarksville, Tenn. Critical minerals processing Korea Zinc, Department of Commerce, and Department of Defense and private investors partner on a $7.4 billion critical minerals smelter in Clarksville, Tenn.
1/26/26 USA Rare Earth Inc. Texas, Oklahoma Rare earths mining and manufacturing Commerce Department agreed to provide a $1.3 billion loan and a $277 million investment for a total of $1.6 billion in federal funding for a mine in Texas and a manufacturing facility in Oklahoma. 
Source: Trump administration, company statements, Public Citizen research

Federal investment in minerals and mining companies often causes a quick and dramatic increase in their stock price. As such, billionaires and CEOs with ties to Trump stand to reap immense profits from the government’s intervention in the mining sector. The following are examples:

JOHN PAULSON: The billionaire investor made $15 billion betting against the subprime mortgage market in the late 2000s, then saw his hedge fund’s fortunes suffer while becoming a close adviser and ally of Trump. In 2024, Paulson hosted a fundraiser at his Palm Beach, Fla home that raised more than $50 million for Trump and the Republican National Committee. Paulson was considered as a potential Treasury Secretary under the second Trump administration but withdrew his name.

After years of poor returns, Paulson closed his hedge fund to outside investors in 2020 and now manages his family’s money. But his fortunes have turned around amid a massive surge in gold prices and the Trump administration’s mining-friendly agenda. Paulson has long been bullish on gold as an investment, both in commodity prices and investments in mining companies themselves. “We really shifted our focus to mine development because that’s where you can get your biggest bang for the buck,” Paulson told the Wall Street Journal. “You don’t need the gold price to go up to receive high returns.”

In October 2025, the Trump administration announced a plan to invest nearly $36 million in Trilogy Metals, a previously obscure Canadian mining firm planning to mine in Alaska under a joint venture partnership with Australian mining firm South32, which sold a portion of its shares in Trilogy Metals to the U.S. government. The Defense Department acquired a 10% stake in Trilogy Metals, along with the right to purchase an additional 7.5% stake. News of the deal tripled the share price of Trilogy Metals, benefiting Paulson, who has long owned more than 14 million shares in the company. 

In September 2025, another company backed by Paulson, Perpetua Resources, received final signoff from the U.S. Forest Service to mine for gold and antimony — a mineral used in military applications, and for  batteries and solar panels. That project is located in central Idaho’s Payette National Forest in an open mining pit that had been abandoned since the 1990s. It was approved at the end of the Biden administration amid concerns about the Chinese domination of the sector. The Biden administration provided $60 million in Pentagon funding for the project.

Perpetua said in October that it broke ground on the project. It was opposed by conservation and environmental groups as well as the Nez Perce Tribe, which has sued the Forest Service over the plan, arguing it violates their treaty rights. During the Biden administration, Perpetua touted the use of antimony for use in a “breakthrough long-duration grid storage battery” and signed a partnership with a battery firm, Ambri, which filed for Chapter 11 bankruptcy in 2024, despite funding from Paulson and Bill Gates. Ambri has since re-emerged from bankruptcy. Citing the need for antimony to produce bullets, nuclear weapons, missiles and batteries, the conservative Heritage Foundation has labeled the lack of domestic supply a “crisis” and a key defense priority.

In yet another investment, Paulson and another billionaire investor, Thomas Kaplan, teamed up to buy Barrick Gold’s stake in a gold mine in western Alaska, with Paulson spending $800 million for a 40% stake in NovaGold Resources. NovaGold owns the Donlin gold project in western Alaska — a project that could become one of the largest gold mines in the world. It has long been opposed by tribal nations and environmental groups alike, with six tribes in southwest Alaska challenging the project. In June 2025, a federal judge ordered the government to study the risks of a proposed dam designed to contain toxic mining waste amid fears that such a spill could cause widespread environmental damage.

LUKSIC/FONTBONA FAMILY: Little-known in the U.S., the wealthiest family in Chile controls a vast business empire encompassing mining, banking, hotels, and other enterprises. One of its flagship holdings, Antofagasta Plc, controls the proposed Twin Metals copper and nickel mine in northern Minnesota just outside the Boundary Waters Canoe Area Wilderness. This project, which the second Trump administration is trying to advance, has long been controversial over concerns that toxic waste could contaminate one of the country’s most pristine and heavily used wilderness areas. The company has also faced environmental damage allegations in Chile, where the government sued mining companies, including Antofagasta in 2022, alleging irreparable damage to one of the most important aquifers in the Antofagasta region.

In 2017, the Wall Street Journal revealed that Ivanka Trump and husband Jared Kushner rented a six-bedroom home in an elite Washington, D.C., neighborhood from a company controlled by Chilean billionaire Andrónico Luksic, part of the family that controls Antofagasta and related companies. The family’s matriarch, Iris Fontbona and other family members inherited the company in 2005 and remain in control, with her son Jean-Paul Luksic serving as Antofagasta’s chairman. 

Antofagasta has a substantial D.C. lobbying presence, spending $490,000 in lobbying in the first three quarters of 2025 and $680,000 in 2024, according to data from OpenSecrets. The company’s lobbyists include former Sen. Tom Daschle (D-S.D) as well as former Trump Interior Secretary David Bernhardt’s lobbying firm, which employs several former Interior Department officials. House Republicans, especially Rep. Pete Stauber (R-Minn.), are enthusiastic proponents of the mining plan. Stauber and other Republicans have sent investigative letters to three environmental groups claiming that they improperly met with Biden administration officials while suing the government over the mine. In January 2026, Stauber and Congressional Republicans were working to advance a repeal of a Biden decision to impose a 20-year ban on mining in the area.

GINA RINEHART: The richest person in Australia and a supporter of right-wing politicians at home and abroad, Gina Rinehart is a major investor in mining projects around the world, under the umbrella of her company, Hancock Prospecting. Hancock Prospecting is now the largest private shareholder in the American rare mining and refining company MP Materials, owning 14.9 million shares of the company, worth nearly $1 billion as of fall 2025, according to a Securities and Exchange Commission filing. Her company has invested in Trump’s social media company, Truth Social, boosting her investment in the company by nearly 70% in the second quarter of 2025. Hancock Prospecting is also the second-largest shareholder of a major Australian minerals producer, Lynas Rare Earths, which in 2023 received $258 million in Defense Department funding for a rare earths processing facility in Texas. 

In Australia, Rinehart is an outspoken advocate of Trump-style deregulation and a critic of climate policies. “We need to cut government tape, regulations, governments’ wastage and tax burdens across Australia,” Rinehart has said. “We need a USA-style DOGE that delivers action, one that helps to return dollars to our pockets and investment back to Australia. “Don’t be frightened to call for ‘make our bank accounts great again’.” She has railed against climate action, claiming that, “Many of our farmers and their families and farms are already suffering from net zero ideology,” she said. “They have more than enough to worry about with devastating droughts, floods, fires” — an oddly revealing acknowledgement of climate change damage.

A staunch supporter and ally of Trump, Rinehart was spotted at Trump’s Great Gatsby-themed Halloween party in Mar-A-Lago fall 2025. Rinehart also has posed next to Trump’s second daughter, Tiffany Trump at Trump’s election-night party and bought full-page U.S. newspaper advertisements (below) praising Trump before his second inauguration. 

Rinehart and several other executives at her company, Hancock Prospecting, also traveled to the U.S. for Trump’s inauguration, The Australian reported. According to Federal Election Commission records, Carlos De Miguel III, general manager of Hanrine Exploration and Mining, a copper mining company in Ecuador owned by Hancock Prospecting, donated $250,000 to Trump’s inaugural committee. De Miguel  listed his address as being in Naples, Fla.

Rinehart and other MP Materials investors saw their shares soar in value after the Pentagon, seeking a secure supply of magnets used in F-35 fighter jets (a goal also sought under the Biden administration), invested $400 million in the rare earths company, followed by a $500 million investment from Apple

Public funding from the Trump administration is intended to revive rare earths processing at the Mountain Pass rare earths mine in California, where the Molybdenum Corporation of America (Molycorp) began extracting rare earth elements in 1952. CEO James Litinsky, a 47-year-old hedge fund trader, became a billionaire after buying $20 million in bonds issued by Molycorp, which filed for bankruptcy, leaving Litinsky the sole owner of the defunct mine, which he restarted and took public in 2020. 

The company is working to expand its rare earth magnet production capacity in Fort Worth, Texas. MP Materials also plans to build a rare earths refinery in Saudi Arabia with funding from the Pentagon and a Saudi mining company. However, in a conference call with investors, Litinsky sounded a general cautionary note about investor speculation in the mining sector. “The vast majority of projects being promoted today simply will not work at virtually any price,” Litinksy said. 

James Litinsky’s brother, Andy Litinsky, has a personal relationship with Trump, but apparently a rocky one. Andy Litinsky was a candidate on Trump’s reality TV show (The Apprentice), Trump’s television producer and one of the founders of Trump’s social media site, Truth Social after pitching Trump the idea for the site in 2021. After a falling out with Trump led to a lengthy litigation battle, Andy Litinsky and another Truth Social cofounder sold their stake in the company in 2024.

RANDALL ATKINS: The CEO of Ramaco Resources, Randall Atkins, has won several favorable policy moves from the Trump administration and congressional Republicans. The Kentucky-based company mines for metallurgical coal used to produce steel and is developing a rare earths mine in Wyoming

Ramaco and other companies in the metallurgical coal industry were unexpected winners of the Republican tax and budget industry in summer 2025, with coal producers receiving a generous production tax credit as well as lowered royalties for coal production. Atkins also waged a successful campaign to have metallurgical coal named a critical mineral by the Interior Department

During the first Trump administration, Ramaco benefited from a favorable regulatory move by the Interior Department. The company won approval of a protection plan for a threatened crayfish impacted by the Ramaco underground coal mine near a river in West Virginia. A Trump administration official bragged at the time that the move rescued the coal project “from bureaucratic entanglement,” calling that outcome “pretty rewarding,” even though it amounted to a political official working outside official review channels for endangered species protection.

Speaking on CNBC, Atkins said he welcomed the government’s help. “We have got some discussions going on in back-channel with the Defense Department,” he said. “Government involvement at this point in the game is necessary.” Ramaco hired a Trump administration official from the White House’s National Energy Dominance Council, Joe Stopper, who told Cowboy State Daily, “It’s clear that the government is willing and able to support this industry as it becomes more U.S.-based.”

However, Ramaco’s critical minerals mining plans in Wyoming have come under fire from geologists and a well-known Wall Street short seller, who questions the company’s claim to be sitting on a $37 billion deposit of rare earths and argues it will be impossible for the company’s Brook Mine to operate profitably. David Hammond, a Colorado mineral economist, told Cowboy State Daily that Ramaco’s Brook Mine project in Wyoming is “so over the top as far as its level of misleading us, and just really bogus numbers in there that no one should put any credibility on it.” 

MARK CHALMERS: Mark Chalmers, the Chief Executive Officer of Energy Fuels Inc., came to the company after managing the Kayelekera uranium project in Malawi for Paladin Africa Ltd., a subsidiary of the Australian minerals conglomerate Paladin Energy. The project was the site of a long record of environmental violations, including dumping wastewater sludge into a river that drains into Lake Malawi, a world heritage site, as well as a host of alleged labor and human rights violations. Then the operation went bust, as Paladin filed for insolvency in 2017. Chalmers has emphasized the company’s stock market performance. “The shares went from less than a penny to eleven dollars. It was the most meteoric rise in the history of the Australian stock market,” Chalmers told Energy Fuels investors in 2018.  “There were a lot of people that rode that up and made a lot of money.”

After Paladin, Chalmers moved on to Energy Fuels, which has started mining and processing uranium in Arizona and Utah. Energy Fuels is a Canada-based uranium and critical mineral corporation with its corporate offices located outside Denver in Lakewood, Colorado. Energy Fuels operates the Pinyon Plain mine within the boundaries of a newly protected national monument near the Grand Canyon — a place of deep importance to tribal nations in the southwest that is now under threat from the Trump administration. It also operates a uranium mill just outside Bears Ears National Monument in Utah. 

While speaking on an investing podcast, Chalmers said that government support is welcome to support domestic rare earths producers to compete with China. “We have always built our company around that we didn’t need government support but let’s put it this way, it certainly would be appreciated, for the right support.”

A Mushrooming Attack on Public Lands

The Trump administration has already moved to eliminate or weaken protections on nearly 88 million acres of national public lands, an analysis by the Center for American Progress found. Another CAP analysis found that eliminating national monuments would put the drinking water sources of more than 13 million people at risk,  threatening 21,000 miles of rivers and streams. Many iconic public lands under threat from mining projects also provide enormous economic benefits, from outdoor tourism and recreation to providing a spawning ground for the world’s largest salmon fishery.

U.S. law is already extremely favorable to the mining industry — even more so than for oil and gas interests. Mining companies have long shortchanged the public, profiting off the public sphere without fair compensation for taxpayers. Under a law enacted in 1872, mining companies extract natural resources, including gold, silver, platinum and copper, without paying royalties to American taxpayers for the privilege of exploiting publicly owned resources and only paying nominal fees. The law, which contains no cultural or environmental protections, still governs public lands mining today, and is a longstanding legacy of exploitation of Indigenous lands and resources.

Under this system, which is in dire need of reform, individuals and entities can assert the right to extract minerals from national public lands simply by making a mining claim. Many such claims are located inside or near national parks and monuments, putting treasured landscapes in the western U.S. and Alaska at risk of exploitation. An April 2025 analysis by the National Parks Conservation Association found more than 3,700 mining claims inside national parks or monuments, and more than 120,000 claims on national public lands within 30 miles from a park or monument.

As a result of this outdated law, mining corporations have been able to remove more than $300 billion in minerals from public lands over the past 150 years without paying their fair share to the government. This staggering giveaway to the mining sector exceeds even the largesse the U.S. government extends to the oil and gas sector, which recently won a rollback of a royalty and fee increases passed during the Biden era. 

In May 2025, the Trump administration set the stage for what is likely to be a massive turnover of public lands to the private sector, declaring that the president can open up land for private sector exploitation by revoking national monument designations established by former presidents to protect significant natural sites.

The Trump Justice Department’s 50-page opinion on the Antiquities Act of 1906 flies in the face of established law and gives Trump carte blanche authority to rescind national monument designations, which have often led to the creation of new national parks. Burgum has claimed that the Antiquities Act is limited in scope, testifying in January 2025, that the act “states very clearly that the smallest possible area to protect those objects, be protected. Its original intention really was to protect antiquities, areas like, I would say, Indiana Jones-type archeological protections.” In reality, the Antiquities Act has been interpreted broadly by many presidents, starting with Teddy Roosevelt, who in 1908 established a national monument protecting 800,000 acres of the Grand Canyon.

While Burgum professes to admire Roosevelt’s conservation legacy, several important national monuments are at risk of being abolished or shrinking dramatically. That includes public lands in Arizona near the Grand Canyon protected in 2023 after years of advocacy from tribal nations and public lands advocates, as well as Bears Ears and Grand Staircase-Escalante in Utah, which Trump attempted to shrink in his first term.

Table 2: National Public Lands Under Threat From Mining

State Threatened Lands  Total Acreage of National Public Lands Near Project  Company/Mine Name Mineral(s)
Alaska Bristol Bay watershed 12,500,000 Northern Dynasty (Pebble Mine) Copper, gold, rare earths
Alaska  Gates of the Arctic National Park & Preserve 8,500,000 Trilogy Metals/South 32 (Ambler Metals Upper Kobuk Mineral Project) Copper, zinc, cobalt
Arizona Tonto National Forest (Oak Flat/Chi’chil Bildagotee) 2,900,000 Rio Tinto/BH Group (Resolution Copper) Copper
Arizona Grand Canyon National Park,

Baaj Nwaavjo I’tah Kukveni/Ancestral Footprints of the Grand Canyon National Monument

1,200,000 (Grand Canyon)

918,000 (Baaj Nwaavjo)

Energy Fuels Resources, EnCore Energy. others Uranium
California Death Valley National Park 3,400,000 K2 Gold (Conglomerate Mesa) Gold
California Mojave National Preserve 1,600,000 Dateline Resources Ltd, (Colosseum Mine)  Rare earths
Colorado Dolores Canyons National Monument (proposed) 400,000 Anfield Energy (West Slope Project) Uranium/Vanadium
Idaho Payette National Forest 2,300,000 Perpetua Resources (Stibnite Gold) Gold, Antimony
Minnesota Boundary Waters Canoe Area Wilderness 1,100,000 Antofagasta (Twin Metals) Copper, Nickel
New Mexico Cibola National Forest and National Grasslands 1,900,000 Energy Fuels Resources, 

Laramide Resources

Uranium
Utah Bears Ears National Monument  1,360,000 Energy Fuels Resources, Iso Energy; Atomic Minerals, Anfield Energy Uranium
Source: Public Citizen research 

Mining Companies Jockey for Influence With Trump

In the get-richer, quicker culture of Trump 2.0, minerals and mining firms are rushing to cozy up to the Trump administration. A Reuters review found that at least 12 mining firms have signed up with Washington lobbyists since the start of the year. Former Trump administration officials or those in Trump’s orbit have been able to sign numerous mining industry clients, including Ballard Partners, the former firm of White House Chief of Staff Suzie Wiles and Attorney General Pam Bondi.

In spring 2025, David Bernhardt, who was Trump’s second Interior secretary in his first term, launched a new lobbying firm, Bernhardt Group, along with numerous former officials from the first Trump administration, including Bernhardt’s former chief of staff. Bernhardt Group quickly signed 11 new mining clients, including Antofagasta Plc, Barrick Mining, Trigg Minerals and USA Rare Earth, which received $1.6 billion in federal loans and investments in January 2026 and spent $390,000 on lobbying in 2025. Once the U.S. government started giving money away earlier this year, every minerals boardroom in America started to think, ‘What about us?'” Ken Hoffman, a commodity strategist with Red Cloud Securities and a former mining industry consultant, told Reuters,

Dateline Resources Limited, an Australian company, is seeking to restart the Colosseum Mine, a gold and silver mining operation in California’s Mojave Desert National Preserve, created before public lands there were protected. Dateline employs the lobbying firm Michael Best Strategies, led by Reince Priebus, Trump’s first White House chief of staff and former Republican party chair. One of Dateline’s lobbyists in 2025 is Brittan Specht of Michael Best Strategies. Specht is a former House Republican aide and a former colleague of Emily Domenech, the executive Director of Trump’s National Permitting Council. Another lobbyist for the Colosseum Mine, John Sobel of Telegraph Advisors, is a former Republican Capitol Hill aide who in 2015 described presidentially-designated national monuments as “second-rate monuments, because they lack the adequate support of locals and of Congress.”

Table 3: Federal Lobbying By Companies Mining US Public Lands 

Company Corporate Headquarters 2024 2025 Total
Rio Tinto Group London; Melbourne, Australia  $1,330,000 $1,100,000 $2,430,000
Antofagasta plc London; Santiago, Chile  $680,000 $490,000 $1,170,000
MP Materials Las Vegas, Nevada $520,000 $420,000 $940,000
BHP Group Melbourne, Australia  $410,000 $480,000 $890,000
Perpetua Resources Boise, Idaho $340,000 $430,000 $770,000
South32 Ltd Perth, Australia $152,000 $284,000 $436,000
Lithium Americas Vancouver, Canada $0 $400,000 $400,000
Dateline Resources Sydney, Australia  $190,000 $170,000 $360,000
Northern Dynasty Minerals Vancouver, Canada $0 $350,000 $350,000
Ambler Metals (Joint venture of Trilogy Metals/South32 ) Anchorage, Alaska  $160,000 $120,000 $280,000
Donlin Gold Anchorage, Alaska  $120,000 $90,000 $210,000
Ramaco Carbon Lexington, Kentucky $90,000 $45,000 $135,000
Resolution Copper Co (Joint Venture of Rio Tinto/ BHP Group) Superior, Arizona $0 $60,000 $60,000
Totals $3,992,000 $4,439,000 $8,431,000
Source: OpenSecrets, Public Citizen research

Doug’s Dash for Dominance (and Prominence)

Under Doug Burgum, the Interior Department is working overtime to sell off and exploit public lands. Trump’s nominee to lead the Bureau of Land Management, former GOP Rep. Steve Pearce of New Mexico, is a longtime proponent of privatizing public lands. Pearce authored several pieces of legislation designed to undermine and exploit public lands for corporate interests and advocated for the sale of public lands as a deficit-reduction measure.

In general, Burgum appears far more focused on his position as chair of the newly created National Energy Dominance Council — an interagency group designed to grant the wishes of extractive industries – than he is on the traditional job of Interior Secretary, where his duties are to protect America’s natural resources and cultural heritage. Burgum appears to have morphed his job into that of an international fossil fuel salesman, mining promoter and an artificial intelligence enthusiast, claiming that maximizing U.S. resource extraction is crucial for America’s economy, regardless of the environmental consequences and launching off-base attacks on the fastest-growing forms of energy: wind and solar. 

To do so, Burgum and other Trump administration officials have taken numerous deregulatory steps to promote mining interests, including fast-tracking permits, eliminating regulations, planning a strategic mineral reserve and guaranteeing a minimum price for rare earth elements. Steps like these could indeed make sense under a progressive green industrial policy. But under Trump, they lack any semblance of environmental, labor and social standards, compensation for taxpayers or proper consultation with tribal nations.

More recently, the Trump administration has made several direct investments in mining firms, turning U.S. mining companies into a red-hot stock market investment, and partnered with the government of Abu Dhabi and a New York private equity firm on a $1.8 billion global investment fund for critical minerals.

In November, the Interior Department added 10 new minerals, including copper, lead, metallurgical coal (used for steel production), potash and uranium on its “critical minerals” list run by the U.S. Geological Survey. Inclusion on one several critical minerals lists run by federal agencies has numerous benefits for extractive corporations. Those include making mining companies eligible for federal funding, a streamlined permitting process and a shield against foreign competition due to steep import tariffs.

For example, the CEO of copper producer Freeport McMoRan told Reuters that adding copper to a federal critical minerals list would provide more than $500 million per year in tax credits to the company, the largest U.S.-based copper producer. In another favor for the industry, Trump’s Environmental Protection Agency granted a two-year exemption to copper smelters, allowing them to avoid complying with a Biden-era pollution rule intended to limit the amounts of lead, arsenic, mercury, benzene and dioxins from copper production. 

The addition of uranium to the list is especially controversial. As the Center for Western Priorities has pointed out, the addition of uranium to the critical minerals list contradicts existing federal law, which specifies that minerals used for fuel cannot be included on the critical minerals list. However, the Interior Department cited a White House executive order directing the U.S. Geological Service to consider whether uranium should be on the list. 

Digging for Rare Earths

Over several months, the Trump administration has gradually rolled out plans to encourage and subsidize the mining sector, especially “rare earth” elements, which are used by military contractors and technology firms for magnets commonly used in electronics products and wind turbines. Chinese domination of this market is indeed a longtime concern of both Republican and Democratic administrations, but the Trump administration’s chaotic trade policies and ongoing trade war with China have intensified the existing rare earths supply problem. 

After Trump hiked tariffs in April, China retaliated with a slew of measures that included limiting the exports of rare earth magnets — a potential crisis for U.S. companies. By fall, Trump had inked a new deal with China that somewhat de-escalated the conflict, including a pause on rare earth controls. But tensions remain high. China still may limit rare earths exports to U.S. aerospace companies and other military contractors. 

The Trump administration has also been pursuing critical minerals agreements with countries around the world, including a “strategic partnership agreement” related to rare earth minerals between the United States and the Democratic Republic of the Congo. These trade deals, negotiated in secret, often impose obligations only on Global South countries while giving the U.S. free reign, threatening Global South countries’ ability to oversee their resources and assert labor and environmental standards, These deals raise serious concerns about transparency, human rights, worker and environmental exploitation and sovereignty, especially in places such as the DRC and in Indonesia.

While the Biden administration initiated numerous programs to incentivize the mining of minerals, its primary goal was mainly to promote the transition to electric vehicles and renewable energy. The Trump administration is altering those programs and expanding them, primarily for military benefit, since rare earths are used to produce missiles, fighter jets, submarines and weapons systems.

Numerous Trump officials or people in Trump’s orbit have personal ties and investments to the mining industry, making it hard to determine if Trump’s policy is based on their policy goals or on the personal financial interests of administration insiders. A brief list follows:

  • Commerce Secretary Howard Lutnick’s former Wall Street firm, Cantor Fitzgerald has numerous mining interests. The firm has been lead underwriter for Northern Dynasty’s Pebble Mine, a proposed gold and copper mine near Alaska’s pristine Bristol Bay. Under Lutnick, the Commerce Department has invested $1.6 billion in USA Rare Earth to launch a Texas rare earth mining project and an Oklahoma manufacturing facility.. As part of this deal Cantor Fitzgerald, now led by Lutnick’s two sons, Brandon and Kyle Lutnick, helped arrange $1.5 billion private financing for the Oklahoma-based company. Cantor Fitzgerald also holds a stake in Critical Metals Corp., which is targeting Greenland, the Danish territory Trump has sought to purchase, for rare earths mining.
  • White House Chief of Staff Susie Wiles, Trump’s current chief of staff, lobbied for the Pebble project while working for Ballard Partners, the top-billing lobbying firm in D.C. Wiles herself recruited the Pebble project’s developers as a lobbying client, the New York Times reported
  • White House Deputy Chief of Staff Stephen Miller was, until August, the owner of shares in MP Materials, a rare earths company that received $400 million investment from the Defense Department under a deal announced in July. 
  • Karen Budd-Falen: A longtime critic of federal land management policies and Wyoming rancher with extremist, far-right views, Budd-Falen is a top Interior Department adviser whose husband Frank Falen, owns property in Nevada and in 2018 sold a $3.5 million water rights contract to Lithium Americas’ Thacker Pass lithium mine project in Nevada. That project is now part-owned by the U.S. government after the Trump administration restructured a Biden-era loan to the project.
  • National Security Council staffer David Copley: A top adviser for minerals and supply chain policy on Trump’s National Security Council, David Copley is a former executive with Colorado-based Newmont, the world’s largest gold miner. 
  • Donald Trump Jr., the president’s son, is a partner in 1789 Capital, a venture capital firm tied to prominent conservatives that invested in a rare earths firm, Vulcan Elements, that received federal support months after it was backed by 1789 Capital.

Trump’s Nuclear Dreams Put Public Lands, Tribes at Risk

The nuclear power industry, which relies on uranium for fuel, is also in line for Trump administration handouts. The Trump administration is trying to spark a revival of new nuclear power construction, driven by hopes that nuclear plants will provide always-on energy for artificial intelligence data centers. The Trump administration is touting a new public-private partnership to build nuclear plants under which the government plans to speed permitting and arrange financing, including potential government loans. The U.S. government could even become a shareholder in the initial public offering of nuclear plant builder Westinghouse, if all goes according to plan. Westinghouse intends to start construction on the first of 10 new reactors in the U.S. by 2030. However, nuclear energy is an expensive power source plagued with massive cost overruns and lengthy delays. It remains to be seen whether the nuclear power industry’s much-hyped, long-predicted renaissance will actually result in a significant number of new reactors. 

Though the U.S. has imported most of its uranium supply since the early 1990s, the Trump administration has focused on building domestic production. This push for an enhanced nuclear supply chain puts public lands and tribal nations at risk of harm — including people who live on the same tribal lands that were contaminated with radioactive mining waste several decades ago.

Under Trump and Burgum, the concerns of communities are secondary. In May 2025, the Interior Department approved Anfield Energy’s Velvet-Wood uranium and vanadium mine in Utah under a special 14-day review process under an energy “emergency” declared by Trump — a process that would normally take an entire year. Canada-based Anfield reopened the mine in November 2025 for the first time in 40 years and expects to start production in 2026. Burgum claimed that the mine would help with “reducing dependence on foreign adversaries and ensuring our military, medical and energy sectors have the resources they need to thrive.” However, Burgum’s lofty rhetoric conveniently ignored the fact that the review process left almost no time for public input, shutting out neighboring communities. Anfield has also applied to state officials to restart another mine in Colorado and reopen a now-dormant uranium processing facility in Utah. Former Rep. Jeff Duncan (R-S.C.), a longtime nuclear energy proponent, was appointed to Anfield Energy’s board in 2025, along with several other nuclear companies

Key Public Lands Mining Controversies

Boundary Waters Canoe Area Wilderness, Minnesota, (Twin Metals)

This proposed underground copper and nickel mine is located in one of the most unspoiled wilderness areas in the country, just outside the Boundary Waters Canoe Area Wilderness in Minnesota. It has long been controversial amid fears that the mine would leak toxic waste into a pristine wilderness used for recreation by millions of people every year. In 2022, the Biden administration blocked the project, then barred mining on the site for 20 years, reversing the first Trump administration’s approvals. In June 2025, Burgum and Agriculture Secretary Brooke Rollins said the government would start the process of lifting the Biden-era restrictions and allow mining on the site, though critics such as Sen. Tina Smith (D-Minn.) questioned whether the Trump administration performed any scientific analysis to back up its decision.

Grand Canyon Region, Arizona (Pinyon Plain Mine)

The Grand Canyon area has long been targeted for exploration by uranium miners. In the 1950s and 1960s, the Grand Canyon itself housed a significant uranium mining operation directly on the canyon’s iconic South Rim, which now attracts millions of visitors per year. In 2023, former President Joe Biden designated large tracts of land directly north and south of the Grand Canyon as a national monument. Biden’s monument designation: Baaj Nwaavjo I’tah Kukveni-Ancestral Footprints of the Grand Canyon National Monument made permanent a 20-year moratorium on new uranium projects put in place in 2012 under President Barack Obama.

Energy Fuels’ Pinyon Plain mine is within the boundaries of the new Baaj Nwaavjo monument, located south of the Grand Canyon’s entrance. The mine was grandfathered into the monument and still allowed to operate, as the monument’s protections only impact future leases or claims. Nevertheless, Energy Fuels was still critical of the designation. A company spokesman told the Arizona Republic, “At a time when the Biden Administration is working to reduce carbon emissions and punish Russia’s aggression in Ukraine… permanently locking off America’s best uranium deposits seems like a bad idea that runs contrary to many Administration priorities.”

Energy Fuels had pre-existing mining claims and an operational uranium mine, the Pinyon Plain project, about 10 miles south of the Grand Canyon, which had been in development before the moratorium. A global surge in uranium prices increased hopes of a revival in nuclear power. The improved economic prospects of uranium led Energy Fuels to pull uranium ore out of the ground in December 2023 for the first time since the mine was approved in 1986. Environmental groups and the Havasupai tribe have long warned that the mine poses a threat to groundwater in the area near the Grand Canyon.

Arizona Attorney General Kris Mayes has requested that the U.S. Forest Service perform a new environmental impact study to determine whether the mine is safe for groundwater in the area. Mayes noted that the 40-year-old original study does not properly account for environmental risks that are now better understood due to technology advances. Energy Fuels’ Mark Chalmers has downplayed the risks, telling the Associated Press, “there will be some people that will say … ‘uranium mining has contaminated the water in Grand Canyon already… It is false. Natural contamination from the uranium is already in the system. Mother Nature put it there.” Energy Fuels also wants to open several additional uranium mines to the north of the Grand Canyon. Chalmers told E&E News in 2023 that the project was taking too long. “It’s the most litigated mine in the history of the United States mining industry, and it has always persevered for all the right reasons in that it wasn’t going to damage the environment,” Chalmers said. “It followed due process over the decades.”

Under an agreement between Energy Fuels and the Navajo tribal government, up to 12 trucks per day carrying uranium ore are allowed to roll through the Navajo Nation, where some tribal communities have already stopped practicing cultural traditions, like collecting medicinal plants, due to fears of contamination. The Navajo Nation has long coped with the impacts of uranium mining since the 1940s, including elevated cancer levels and 500 abandoned mines. Federal research into the impacts of uranium exposure found that about a quarter of more than 780 Navajo women screened in a study had high levels of uranium exposure in their system.

Bears Ears National Monument, Utah

In 2016, President Barack Obama established the Bears Ears National Monument, preserving one of the most spectacular sites in southeast Utah. Since then, the monument has been the subject of intense fighting. In 2017, one year after the monument’s designation, Trump slashed the size of Bears Ears and Grand Staircase-Escalante national monuments by 85 percent. “Some people think that the natural resources of Utah should be controlled by a small handful of very distant bureaucrats located in Washington,” Trump said at the time. “And guess what? They’re wrong.” The Washington Post later revealed that Energy Fuels pushed the first Trump administration to shrink the monument, hiring as a lobbyist Andrew Wheeler, who then joined the Trump administration as EPA administrator. President Joe Biden reversed the Trump administration’s move and restored Bears Ears and Grand Staircase-Escalante to their prior status. Both of those monuments could be under threat from the Trump administration.

One mile outside Bears Ears, Energy Fuels operates the White Mesa mill, the only functioning conventional uranium processing facility in North America. Many tribes have fought the White Mesa mill and the disposal of radioactive uranium waste in the area. “I’m against this mill. I’ll always be against it,” Ute Mountain Ute Tribal Councilman Conrad Jacket told Grand Canyon Trust. “This waste comes from all around the world to right here…and when they dump it here, you see the wind’s blowing. And it’s headed east. And it’s blowing into Colorado. That’s how it’s connected to everywhere. It’s not just our issue. It’s everybody’s issue.” 

Bristol Bay, Alaska (Pebble Mine)

The massive Pebble Project, a proposed copper, gold and rare earths mine in the pristine Alaska Bristol Bay watershed, home to one of the world’s premier salmon fisheries. The Canadian mining firm, Northern Dynasty Minerals, has long battled with environmental groups over the project, which both of Alaska’s Republican senators, Lisa Murkowski and Dan Sullivan, have opposed, but Alaska Gov. Mike Dunleavy has supported in a federal lawsuit. The proposed project is located on Alaska state land, but the Environmental Protection Agency ruled in 2023 that water pollution created by developing “would have unacceptable adverse effects on certain salmon fishery areas in the Bristol Bay watershed,” and called the area “an area of unparalleled ecological value, with salmon diversity and productivity unrivaled anywhere in North America” resulting in the permanent loss of nearly 100 miles of fish streams and 2,100 acres of wetlands. 

Unlike most extractive projects, there has been tension in Trumpworld over the issue, and public disagreement between Trump and his son Donald Trump Jr., an avid fisherman. The first Trump administration initially acted to speed the project’s approval, then reversed course and denied the project, amid opposition from Donald Trump Jr. and conservative commentator Tucker Carlson, who told E&E News “It’s like the Grand Canyon or something; it’s like the Tetons—this is something that’s unusual that we should preserve.” So far, the second Trump administration has stuck with its decision to block the project, but the U.S. Chamber of Commerce and National Mining Association, normally close Trump allies, have filed briefs in support of the giant mine.

Mojave Desert National Preserve, California (Colosseum Mine)

The Colosseum Mine on the California-Nevada border is the site of a formerly active gold and silver mining operation in California’s Mojave Desert National Preserve. Australia-based Dateline Resources wants to reopen the project and continue the extraction of gold, though it also believes the project also could produce rare earth elements as a byproduct.

In April 2025, the Interior Department said it “recognized the Colosseum Mine in California can continue mining operations under its existing mine plan of operations with the Bureau of Land Management.” In doing so, Interior relied on a 40-year-old document and avoided requiring the company to submit a new mining plan. That move came after a long-running standoff between the National Park Service and Dateline, which claimed it had the right to mine there under a plan submitted to the Bureau of Land Management more than 40 years ago by the mine’s prior owner. The National Park Service argued that the company was operating illegally and ordered the company to stop exploring on the site and pay more than $200,000 in damages.

In June, Burgum went on Fox News and touted the Colosseum project, saying, “we have to get back in the game in a serious way around critical minerals.” In addition, Dateline CEO Stephen Baghdadi met with Burgum and senior Trump administration officials. In a letter to Burgum, Democratic lawmakers criticized the Trump administration’s claim to have approved the restart of mining within Mojave National Preserve. “This action appears to violate federal law, disregards National Park Service (NPS) authority, and sets a dangerous precedent for industrial development in lands that Congress has designated as worthy of inclusion in the National Park System,” they wrote.

Oak Flat/Chi’chil Bildagoteel, Arizona (Resolution Copper)

Resolution Copper is a joint venture owned by the two largest mining companies in the world. The British-Australian Rio Tinto Group, owns 55% stake in the venture and Australia’s BHP Group, the world‘s largest mining company, owns 45%. The Resolution Copper mine is located on a six-square-mile stretch of land in rural Arizona about 60 miles east of Phoenix called Oak Flat, or Chi’chil Bildagoteel, where native tribes have held ceremonies for centuries. The underground mine is expected to ultimately collapse and create a two-mile-wide, 1,000-foot-deep crater, destroying the San Carlos Apache Tribe’s ceremonial site. The Trump administration has aggressively backed Resolution Copper, with Trump and Burgum meeting with Rio Tinto and BHP executives in the White House. 

Though the U.S. Forest Service has agreed to trade Resolution Copper the property in exchange for other environmentally sensitive properties, the actual land swap, which Congress approved more than a decade ago, has been stalled by litigation. In June 2025, the U.S. Forest Service, following an executive order from Trump to expedite the project, put out an environmental review to pave the way for the land transfer. However, a federal court issued an emergency order in August 2025 temporarily blocking the transfer. Trump then attacked tribal opponents of the project in August, calling them “Anti-American, and representing other Copper competitive Countries.“ In a Facebook post, Terry Rambler, Chairman of the San Carlos Apache Tribe said, “This proposed mine is a rip-off, will destroy a sacred area, decimates our environment, threatens our water rights, and is bad for America.”

Resolution Copper has spent more than $2 billion on the construction of the mine to reach deposits with an estimated value of $270 billion, more than a mile underground, though no copper has been extracted so far. The project has been underway for several years and has been the subject of numerous legal battles. The San Carlos Apache Tribe argued that the transfer of sacred tribal land to Resolution Copper in exchange for other land violated its religious freedom. The Supreme Court declined to hear this case despite objections from Justices Neil Gorsuch and Clarence Thomas. 

Conclusion 

Around the globe, the mining industry has been characterized by grievous human rights and environmental abuses and violations of Indigenous peoples’ rights. The rush to bring rare earths mining to the U.S. to compete with China should not be an excuse to relax standards in the U.S. Instead, they must be made stricter. 

In seeking to encourage mining, the Trump administration is prioritizing speed over corporate accountability and societal safeguards, and putting up public lands up for sale In particular, the Trump White House’s executive order removing requirements for mining companies to demonstrate proven mineral deposits before receiving federal funds departs from due diligence practices and exposes taxpayer dollars to risky projects that may never materialize. 

However,  recently introduced Senate legislation threatens to exacerbate these problems, rather than correct them. For example, the bill would authorize an additional $2.5 billion in taxpayer dollars for critical minerals projects and would explicitly permit a Trump-selected corporate board to take equity stakes in mining companies without public transparency or independent oversight. This board would be able to assist the Trump administration’s efforts to take power away from public agencies and invest in dirty mining projects. The bill also omits a long-overdue rewrite of the U.S. mining law, enacted in 1872, and fails to impose meaningful environmental standards or policies to protect sensitive environments and sacred Indigenous sites and require fair compensation for taxpayers.

Properly designed, federal minerals policy could help secure critical resources while minimizing risk. However, its effectiveness depends on strong governance and clear environmental, human rights and tribal consultation standards, which are sorely lacking under Trump.

Public Citizen Comments to the Texas Commission on Environmental Quality Regarding Public Participation Rulemaking

Good morning, Commissioners.

I’m Kathryn Guerra, with Public Citizen’s Texas office. Public Citizen is a nonprofit consumer advocacy organization with over 1M members and supporters that champions public interest in the halls of power.

We were disappointed that, despite numerous environmental advocacy organizations submitting relevant comments that would have strengthened this rule and aligned it with the Sunset Advisory Commission’s recommendation, the agency rejected or refuted every comment they provided. Instead, the agency has amended the rule from its original draft to acquiesce to industry. 

If these comments sound familiar, it’s because I delivered them two weeks ago during the most recently adopted rulemaking on Compliance Histories. Unfortunately, they still apply here because the underlying problem at this agency remains. 

Today, the TCEQ will adopt its public participation rulemaking by rejecting all of the public’s participation.

This rulemaking was intended to correct a failure identified by the Sunset Advisory Commission: that the TCEQ does not adequately incorporate the interests of the communities it serves. Instead of addressing that failure, this rulemaking reinforces it. TCEQ staff rejected 51 – 100% – of the comments provided by community and environmental advocates. Many were dismissed as “outside the scope of the rulemaking”. 

You have designed a system that pretends to consider public input while structuring rulemaking in a way that excludes community voices. These rule proposals are drafted by the same TCEQ staff that the Sunset Commission found lacked sufficient consideration of the community’s interests to begin with. Any comments that address the commission’s inadequacies are summarily dismissed as “outside the scope of the rulemaking” because the rules are drafted without consideration of the needs of communities across Texas, and the agency has no intention of addressing them.

That is not meaningful engagement. That is a closed feedback loop.

Public participation in governmental decisions is not optional. It is our legal right and essential to public trust.

Consider the imbalance of influence on display here. While 51 comments from community advocates were dismissed, 15 industry comments were accepted, including those that weakened the agency’s initially proposed rule and rolled back the proposed provisions that would have improved transparency, public notice and accountability. 

That is not neutral decision-making. That’s prioritizing polluters over people’s health. 

If this commission’s leadership were serious about restoring public trust, this rulemaking would look very different. What we see here, instead, is an agency that continues to require external oversight and accountability. We will continue to monitor and document these agency deficiencies and challenge efforts to narrow public participation or create rules that serve industry interest at the expense of the environment and the public.

Public Citizen Comment for the 2026 Special 301 Review

Every year as part of its Special 301 Review process, the Office of the United States Trade Representative (USTR) solicits “written comments that identify acts, policies, or practices that may form the basis of a country’s identification as a Priority Foreign Country or placement on the Priority Watch List or Watch List” in the Special 301 Report.

Our comments establish minimum principles to which the Special 301 process should adhere in order to protect policies that advance the public interest and support access to medicines.

Read our full comment here.