This post is the third of a three-part series. Read Parts I and II here and here.
In two previous posts, we discussed the major findings of the Project 2025 tracker we created along with our partners at Governing for Impact for monitoring the Trump administration’s ongoing efforts to implement its recommendations over its first 100 days. We also began offering some insights into making sense of these findings and how to interpret them.
The basic finding was that the administration has fulfilled more than a quarter of Project 2025’s recommended executive actions affecting domestic policy. This raises a natural follow-up question: Is that a lot? In this post, we continue to provide analytical tools for answering that question.
Another important contextual factor to bear in mind is the procedural constraints that the Trump administration is operating under. While the administration has sought to cut corners on some of those constraints — clearly violating the law in many cases — many aspects of the Project 2025 agenda involve some degree of predicate process prior to completion.
Put differently, the procedural constraints create a kind of “sequential logic” to Project 2025’s implementation. Unsurprisingly, any of the actions that the administration has checked off the Project 2025 to-do list so far have taken the form of executive orders which, despite not carrying the weight of legally binding actions, do define policy priorities and are often used by federal agencies as justification for management decisions that fall in line with the overarching priorities of the president.
A clear example is land management agencies, like those within the Department of the Interior and the Department of Agriculture, which enjoy wide latitude to unilaterally implement management decisions that affect vast swaths of the American landscape. Recent actions to open public lands to increased oil and gas extraction, as well as timber harvesting, can be made unilaterally without going through a lengthy administrative process. Another “signature move” has been the declaration of “emergencies” to circumvent some of the guardrails enshrined in existing laws and regulations, making this push for implementation even more expeditious.
In contrast, more elaborate or ambitious projects, such as the DOGE-led agency reorganizations, involve some self-imposed process. And beyond this, the recommendations to rescind certain regulations must go through the Administrative Procedure Act’s notice-and-comment procedures, a process that can stretch for many years. (Even here, though, the administration has become increasingly audacious in its attempts to short-circuit these procedures.)
On the environmental and climate fronts, for example, Project 2025 called for rulemaking actions to repeal or redefine crucial elements that underpin much of our regulatory and governance landscapes. Following the recommendations in Mandate, federal agencies have taken steps to rescind the definition of "harm" under the Endangered Species Act (which would also remove the inclusion of the degradation of habitat to qualify as a "take" under the law) and to challenge the climate pollution endangerment finding of 2009.
The upshot is that we can expect the implementation of Project 2025 to come in discrete waves. We’ve already witnessed the first with respect to the early executive orders. Similar waves in the form of agency reorganization plans and final rulemakings will likely begin to appear in the weeks and months ahead.
In light of the various contextual factors, monitoring the administration’s progress in implementing Project 2025 in a precise and rigorous way is far from straightforward. Nevertheless, it is still a task that is well worth undertaking. For one thing, it is essential for informing and supporting the ongoing efforts to resist the Trump administration’s efforts to implement Project 2025’s recommendations. After all, Trump cannot credibly claim a mandate for these actions, given Project 2025’s broad, bipartisan unpopularity and his concerted efforts to disavow it, particularly during the presidential campaign.
For another thing, Project 2025 still represents a fairly good proxy for understanding the conservative movement’s stance on many controversial policy issues, including abortion access, LGBTQ+ rights, economic equality, and immigration. Regardless of their particular views on Project 2025 — whether they’re for or against it — voters will benefit from information like this when they head to the polls in 2026. Even Heritage Foundation president Kevin Roberts seemed to concede the potential significance of Project 2025’s aggressive implementation for the upcoming elections when he wrote in the forward to Mandate, “Conservatives have just two years and one shot to get this right.... Time is running short.”
This may be the truest statement in all of Mandate. If U.S. democracy is to survive at all, the way our constitutional system responds to the authoritarian threat posed by Project 2025 over these next two years will be crucial.
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Federico Holm, James Goodwin | May 7, 2025
In two previous posts, we discussed the major findings of the Project 2025 tracker we created along with our partners at Governing for Impact for monitoring the Trump administration’s ongoing efforts to implement its recommendations over its first 100 days. We also began offering some insights into making sense of these findings and how to interpret them. The basic finding was that the administration has fulfilled more than a quarter of Project 2025’s recommended executive actions affecting domestic policy. This raises a natural follow-up question: Is that a lot? In this post, we continue to provide analytical tools for answering that question.
Federico Holm | 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.
Federico Holm, James Goodwin | May 6, 2025
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.
Federico Holm, James Goodwin | May 5, 2025
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.
Robert L. Glicksman | May 1, 2025
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.
James Goodwin | April 30, 2025
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.
Bryan Dunning, Federico Holm | April 29, 2025
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.
Federico Holm | April 28, 2025
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.
Daniel Farber | April 24, 2025
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.