Project 2025 at 100 Days: Part I

This post is the first of a three-part series.

The extent of harm that the Trump administration inflicted over its first 100 days was nothing short of breathtaking. That it accomplished much of this by transforming our regulatory system into a tool of authoritarian rule speaks to the influence that the Heritage Foundation’s Project 2025 has had on this agenda, despite Trump’s half-hearted attempts to disavow the playbook on the campaign trail.

Here at the Center, we were among the first to sound the alarm on precisely these risks that Project 2025 — and especially its nearly 1,000-page policy blueprint called Mandate for Leadership — posed. That’s why we joined our colleagues at Governing for Impact in setting up a comprehensive tracker for monitoring the Trump administration’s progress in implementing Project 2025’s recommendations for domestic policy executive actions covering 20 different agencies.

Looking back over the last 100 days, the major topline is that the Trump administration has achieved a remarkable amount of progress in advancing the Project 2025 playbook in a relatively short period of time. According to our analysis, the administration has undertaken or completed 28 percent of the more than 530 recommended domestic policy executive actions that we’re tracking. (To put that in perspective, 100 days is only 6.84 percent of a four-year presidential term.)

To appreciate the extent of the real harm to real people that these numbers represent, however, you have to drill down into the specific. Some of the administration’s most high-profile actions thus far are straight from Project 2025. These include Trump’s executive order directing the Department of Education to wind down the Title I funding program, which provides additional financial resources to low-income school districts across the country. They also include the administration’s sustained attacks on the transgender community, such as the executive order that purports to banish “gender ideology extremism” from federal policy.

The Trump administration’s predilection for stirring up outrage and controversy has enabled other actions to slip somewhat beneath the radar for most members of the public. For example, the Department of the Interior issued a relatively obscure Solicitor’s Opinion that reinterprets the Migratory Bird Treaty Act as only applying to affirmative acts that harm covered bird species. Needless to say, this change in policy will leave many bird species — including many endangered species — at increased risk of preventable harm.

Or consider the Environmental Protection Agency’s (EPA) dismissal of all the members of its Clean Air Scientific Advisory Committee, a body that has historically provided the agency with independent, cutting-edge expertise to inform its decision-making on setting national air pollution standards. With that body gone, it will be easier for the EPA to evade its statutory responsibility to set the standards at levels necessary to protect public health — saving corporate polluters millions of dollars in compliance costs in the process.

But it is also important to put these developments into context. In this post, we begin by tracing Project 2025’s origin story. In our second and third posts, we consider how the numbers from our tracker might obscure the extent of Project 2025's influence on Trump’s second term so far.

Properly understood, Project 2025 began life as a “transition” report. Putting these together for potential incoming presidents has long been a quaint quadrennial tradition for Beltway think tanks and advocacy organizations. While the vast majority end up collecting dust on obscure bookshelves, uncelebrated and barely thumbed through, Project 2025 became the notable exception, obtaining legitimate viral status.

Project 2025 quickly began to gain attention as word spread across social and legacy media detailing its radically conservative recommendations on such hot button issues as abortion access, the death penalty, immigration, LGTBTQ+ rights, and diversity, equity, and inclusion policies in schools and businesses. What made Mandate especially striking was the exquisite detail it offered for putting these recommendations into place: they weren’t just extreme; they were also plausible. It wasn’t just that they were promising to do bad things; it was that those bad things could be so easily accomplished (or difficult to stop).

Unsurprisingly, public opinion around Project 2025 tanked — it was less popular than socialism according to one poll — and candidate Donald Trump quickly, if meekly, disavowed it. (To be sure, this reaction probably had less to do with its unpopularity and more to do with Trump’s refusal to share credit with others over defining his policy agenda.)

That no one took this disavowal seriously became apparent when the immediate reaction to Trump’s reelection was open speculation about whether and to what extent Project 2025 would define the governing blueprint for this administration. The Trump transition team wasted little time rewarding this speculation by quickly nominating several key Project 2025 figures for high-ranking positions, including, most notably, Russell Vought to serve a second stint as Director of the powerful Office of Management and Budget.

If there were any doubts remaining about the status of Project 2025 in this administration, they were resolved before the dust had settled on inauguration day. President Trump signed several executive orders and memoranda that bore the unmistakable imprint — if not the precise language — of Project 2025. According to one analysis, nearly two-thirds of the 26 Day One executive orders drew from Mandate’s recommendations.

As we’ve seen, the Trump administration spent the ensuing 99 days implementing still other Project 2025 recommendations.

In our follow-up posts, we’ll explore the various factors that make the administration’s progress in instituting Project 2025 all the more remarkable.