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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.

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.

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.

Since our last update (April 7), we have seen some important developments regarding Congressional Review Act (CRA) resolutions. In addition to the two resolutions signed into law on March 15 (easing protections that will mostly benefit the fossil fuel industry), one more resolution has become law.

During the night of April 9, President Donald Trump continued his administration’s radical assault on our nation’s critical system of regulatory safeguards with three new executive orders and a separate memorandum. These actions build on several previous ones that target regulatory safeguards, and they traffic in a lot of the same false rhetoric about the essential role our regulatory system plays in our society. But what makes these actions different is the manner in which they trample on administrative law and the procedural protections that it is meant to uphold.