In April of 2023, The Heritage Foundation, along with a number of other conservative think tanks, published Mandate for Leadership: The Conservative Promise, a compendium of policy recommendations for a the next conservative president. It is popularly known as Project 2025. Commentators have suggested that Project 2025 is an attempt to avoid repeating the dysfunctional presidential transition of 2016, when Donald Trump unexpectedly won the White House. At that time, no serious transition plans were in place. This delayed any attempt by the new administration to affect public policy changes. Conservatives saw it as a missed opportunity -- one they would not repeat. I read much of Project 2025 on an 11 hour flight to Copenhagen. I doubt I would have read so much of it were I not trapped on that flight, but what I read was quite revealing.
Project 2025 is composed of 30 chapters detailing policy recommendations for a long list of executive departments and regulatory agencies. Its authors include former Trump Administration staff members, advisors, and allies across a galaxy of conservative organizations. Many of the recommendations call for the reinstatement of the Trump Administration's policies that were reversed by the Biden Administration. Other recommendations call for policies the Trump Administration was unable to implement. Some even go well-beyond what the Trump Administration envisioned. In nearly every respect, it is undoubtedly an extraodinarily conservative manifesto. Democrats have successfully exposed it for what it is. Enough so that Trump and his campaign are insisting that it does not represent a blueprint for their agenda, but the extent to which the report advocates core Trump Administration policies reveals their disingenuousness.
At the same time, the Trump campaign is establishing closer relations with another, less-prominent conservative policy shop: The America First Policy Institute (AFPI). The Trump team has appointed the chair of the AFPI, Linda McMahon, to the Trump transition team. I understand that the AFPI has authored its own policy report for a new conservative president. Reporting suggests that the Heritage Foundation and the AFPI are on quite unfriendly terms. Whether this means their policy prescriptions are significantly different or that they are simply separately ambitious policy advisors isn't clear to me, but the best evidence is that their recommendations are quiet similar, if not all but identical in the most important aspects.
Project 2025 is divided into five sections titled, (1) Taking the Reigns of Government, (2) The Common Defense, (3) The General Welfare, (4) The Economy, and (5) Independent Regulatory Agencies. The first section is perhaps the most significant.
In "Taking the Reigns of Government," Project 2025's authors believe that staff members hired in non-political, professional positions (career civil servants) have become entrenched in their offices and wield authority over policy that reflects only their own interests. Consequently, career civil servants are thought to constitute an unelected fourth branch of government. This is particularly worrying for the authors in that they believe career civil servants are overwhelmingly liberal and will not conscientiously implement the policies of a conservative president.
Following the maxim, "personnel is policy," the authors recommend instituting rules that will allow the president to replace career civil servants in a host of departments and agencies with political appointees dedicated to the conservative president's policy agenda. In the final months of his term in office, Trump signed an executive order (known as "Schedule F") which would reclassify many career civil servants and bring them under the direct control of the President. Notably, Schedule F was the brainchild of James Sherk who later came to work for the AFPI. Shortly after his election, Biden rescinded Trump's executive order.
The authors of Project 2025 also propose the elimination or consolidation of a number of agencies and offices along with a drastic reduction in funding and staff in those that remain. Together, these strategies are aimed at disempowering regulatory agencies by depriving them of resources and ensuring that they are staffed by people hostile to government regulation. It is ironic that these proposals are described as an effort to de-politicize the civil service, as though promoting a conservative policy agenda under the direct control of a conservative president is apolitical.
Were the recommendations in "Taking the Reigns of Government" put in place, the power of the president would significantly increase. The role of the president would become that of a "unitary executive," wielding more or less direct authority over every agency in the executive branch, regardless of the charge those agency received upon their creation by Congress. In most instances, the work of regulatory agencies is to implement the will of Congress as expressed in necessarily vague legislation. This often requires technical expertise that would be undermined by the political agenda of the sitting president's political appointees.
According to Project 2025, presidential control over the executive branch should extend even to the Department of Justice which historically has maintained a degree of independence from the White House. The loss of that independence would turn our justice system into a tool for political power and erode the basic rule of law. In light of the recent Supreme Court ruling in Trump v. the United States which has made the president immune from prosecution when exercising "core powers" of the presidency, direct control over the Justice Department would be an extraordinary expansion of presidential power. It would provide presidents with a legal sword to complement their recently acquired legal shield and would create extraordinary powers no president has ever had.
The main thrust of "Taking the Reigns of Government" is the expansion and consolidation of power in the hands of the president. Given the weakness of Congress over the last sixty years, it's hard to argue that the balance of power would be improved by a stronger executive. Of course, the authors of Project 2025 argue that their prescriptions have less to do with division of power between branches of government and more to do with the un-elected fourth branch of government: "the deep state;" but in light of the rise of authoritarian movements in the U.S. and in Europe, a stronger executive is precisely the tool that these movements would use to undermine our democratic traditions.
The latter five sections of Project 2025 drill down to offer specific proposals for the restructure and even the elimination of Cabinet departments and agencies. Furthermore, they go beyond making structural recommendations to propose specific public policies commonly advocated by the extreme rightwing of our body politic.
Much of the content here is deep, deep, deep in the weeds of government and would require highly specialized, professional expertise to assess its consequences, but some things do stand out even for lay readers. My own interest in the climate crisis prompted me to read the chapters on the Department of Energy, the Department of the Interior, and the Environmental Protection Agency. It is clear that the main thrust of these chapters is to promote the production of fossil fuel energy in whatever way possible. Lip service is given to alternative energy sources, but Project 2025 comes just barely shy of baldly asserting the slogan "drill, baby, drill." Primary goals are to expand the production and export of liquid natural gas (liquid methane), to open up additional federal lands for oil and gas exploration, and to weaken regulations protecting against environmental harms from fossil fuel production and the extraction industries.
The last of these goals deserves special attention. Project 2025 envisions a significantly reduced role for the Environmental Protection Agency (EPA). The EPA would, at most, become a junior partner to state environmental protection offices. By giving state environmental offices the primary decision making authority in regulatory environmental matters, the fossil fuel industry and other extraction industries would be in a strong position to ensure that specific states would accommodate their interests.
Weakening the EPA in this manner dovetails with two recent Supreme Court rulings. In 2023, the Court ruled in Ohio v. EPA to block an air emission requirement known as "the Good Neighbor Rule," which protects downwind states from pollutants originating from upwind states. Later, in 2024, the Supreme Court ruled in Loper Bright Enterprises v. Raimondo to sharply reduce the authority of regulatory agencies under the "Chevron deference" doctrine, named after the landmark court case Chevron v. NRDC. Chevron deference recognized the expertise of regulatory agencies in interpreting legislation. Loper gutted deference to the agencies and elevated the standing of industry plaintiffs. Consequently, decision making that often requires highly technical expertise now lies in the hands of judges who often are not equipped to adjudicate the facts.
Between blocking the Good Neighbor Rule and enfeebling the Chevron deference, the Court has significantly weakened the EPA. It would be a final, fatal blow to environmental protection were a unitary executive to make the EPA a junior partner to state environmental offices. Opponents of the EPA have long sought these policies. Some have even suggested eliminating the EPA out right. In 2017, freshman Congressmember Matt Gaetz introduced a bill to do just that. Indeed, the extent to which Project 2025 intends to limit the authority of the EPA, along with proposed significant budget and personnel cuts, amounts to the Agency's near elimination.
Despite his denials, a future Trump administration is likely to adopt, at very least, the main thrust Project 2025. Much of Project 2025 is critical of diversity, equity, and inclusion efforts in the executive branch. It calls for eliminating the Department of Education, reversing FDA approval of mifepristone used in medical abortions, prohibiting the mail delivery of abortion medication, equipment, and other materials, ending birthright citizenship, deporting millions of immigrants, and numerous other extreme policies. Trump can be expected to follow through on those plans.
In a recent speech in Wisconsin, Trump expressly proposed reforms that would bring the Department of Justice under the direct control of the President and firing civil servants charged with carrying out policies he disagrees with. Trump also announce that he would appoint Elon Musk to head a new government efficiency commission "tasked with conducting a complete financial and performance audit of the entire federal government and making recommendations for drastic reforms." He went on to criticize federal agencies of committing fraud and making costly improper payments. His criticism of waste in government (without identifying specific examples) are consistent with Project 2025's justification for merging separate executive office, reducing their funding and staffs, and in many cases eliminating offices entirely.
While the aims of Project 2025 are consistent with -- even identical to -- Trump's aims, the document should not be read simply as Donald Trump's platform. The Heritage Foundation and the galaxy of conservative think tanks and academics who authored Project 2025 have given us the clearest picture of the rightwing agenda in American politics. Furthermore, the close alignment of Trump's policies with Project 2025 and his embrace of the AFPI, suggest that America's rightwing is broadly unified around this agenda. It would behoove political analysts to dig deep into the weeds in Project 2025 to understand the political terrain of the decade ahead, regardless of the results of November's election.
