CRA By the Numbers 2025: Update for May 6, 2025

Since our last update (April 28), we have seen some important developments regarding Congressional Review Act (CRA) resolutions. In the past week, we have seen legislators take up new resolutions for a vote, address the controversial issue of the California Clean Air Act waivers, and send new resolutions to the president to be signed into law. Things seem to be accelerating in Congress (and especially in the Senate), as legislators are approaching the CRA cutoff date.

In the first part of this series, we introduced the major findings of the tracker we built with our colleagues at Governing for Impact for monitoring the Trump administration’s progress in implementing Project 2025’s comprehensive policy blueprint, Mandate for Leadership. Specifically, we found that over its first 100 days, the administration pursued or completed 28 percent of the more than 530 recommended domestic policy executive actions that we included in our tracker. The post went on to provide context for these findings by tracing Project 2025’s circuitous route from obscure presidential transition report to controversial playbook for the Trump administration. Here, we provide further context for our findings by examining some factors that shed light on how significant this progress really is.

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.

Many risks to public health, safety, and the environment are insufficiently understood. Indeed, what some scholars have referred to as “ignorance of mechanism” may be the defining characteristic of many of the nation’s most pressing environmental problems. The U.S. Congress has understood the significance of this uncertainty ever since the birth of modern environmental law in the United States around 1970.

A helpful way to think about the “Mandate for Leadership”—the radical policy blueprint laid out as part of the Heritage Foundation’s Project 2025—is as a kind of “political time capsule” reflecting the world as conservatives saw it in April 2023, when the document was first published. Bearing this in mind is important, because that world was very different from the one 19 months later, when President Donald Trump secured his reelection—or even the one on his second Inauguration Day, nearly two years after the mandate was released.

In April, the Trump administration published an executive order (EO) boosting the coal industry in hopes of a grand revival for an energy source that has been in stark decline since more cost-effective sources, including gas and renewables, drove it from its peak nearly two decades ago. Included in this order was a two-year exemption to a rule that would have required some of the country’s most polluting power plants to reduce emissions of mercury and other hazardous air pollutants that harm our health.

Since our last update (April 21), we have seen some important developments regarding Congressional Review Act (CRA) resolutions. So far, three resolutions have become law and four more have cleared both chambers. Although we have not received any information that these will be sent to the president’s desk in the coming days, we continue to monitor their status as they could soon be on the move. The most consequential development is the announcement that House Republicans will press ahead and vote on three resolutions that target waivers granted by the U.S. Environmental Protection Agency (EPA) to the state of California to develop vehicle emissions guidelines.

It’s a tribute to the significance of state climate policies that President Donald Trump devoted an entire executive order to excoriating them as “fundamentally irreconcilable” with his own, fossil fuel-promoting energy policy. Yet, despite all the drama in DC, state governments have continued to make quiet progress in their efforts to expand clean energy and phase out fossil fuels. These states are focused on tangible steps forward, not on capturing online clicks, so their efforts may escape notice. But the cumulative effect of these month-by-month, smaller-scale initiatives is significant.

On April 23, the Trump administration formally published a rulemaking proposal in the Federal Register that would lay the legal groundwork for creating a new category of civil service personnel called “Schedule Policy/Career” — better known as “Schedule F.” Long anticipated, this policy would strip civil service employees of century-old employment protections, effectively making them “at will” employees, much like a president’s political appointees.