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.
