How Project 2025 Could Impact Public Lands

So, let's start with the basics.

What Exactly is Project 2025?

To understand Project 2025, we need to start with the Heritage Foundation, a conservative think tank founded in 1973 to promote conservative policies and legislation. Starting in the 1980s with Ronald Reagan's first term, the Heritage Foundation began publishing its “Mandate for Leadership,” essentially a wish list of laws and legislative actions it hoped to have enacted during presidential terms.

The first edition was a sprawling, 3000-page document with over 2,000 suggestions on how to reshape the government toward its goals. It was instrumental in shaping the policies of the Reagan administration. Mandates like these are a fairly common practice among think tanks and advocacy groups designed to shape policy in America. For instance, The Society For Conservation Biology has continued to publish a document called “Governance Principles for Wildlife Conservation in the 21st Century.”

Over the years, several new editions of the Mandate have been published. In 2016, the 7th edition was published just after Donald Trump's election. The Heritage Foundation claims that 60% of their proposals were used in Trump’s administration in some way. In April 2023, the ninth edition, Mandate for Leadership 2025: The Conservative Promise, also known as Project 2025, was published. For reference, the entire document can be seen on their website here.

The Trump campaign recently disavowed the project and its director has stepped down. But it’s still worth diving into for what it might tell us about the future of the Republican public lands agenda.

Who is Involved with Project 2025

In drafting Project 2025, the Heritage Foundation partnered with a vast array of other right-leaning think tank groups and cites on their author and contributor list a number of people who have been long at odds with public lands conservation.

What makes Project 2025 different than its predecessors, however, is that while those earlier mandates were more focused on specific policies, Project 2025 envisions a dramatic reshaping of how the machinations of our federal government work. Perhaps the most consequential of these goals is the plan to replace long-time agency staffers with people they believe to be loyal to the administration’s agenda.

According to the Project 2025 website: “our goal is to assemble an army of aligned, vetted, trained and prepared conservatives to go to work on day one to deconstruct the administrative state.” The “Personnel” section of their website offers a myriad of training courses as well as an application portal to be included in a roster of ideologically aligned hopefuls eager to work in the next conservative administration should this plan be put into effect.

At its heart, Project 2025 is a road map for politicizing even the most mundane of civil service positions within federal government agencies. Chris Marshall, a spokesperson for Accountable.US, expressed concern that this was a “concentration of power into the executive branch, and an erosion of the system of checks and balances.”

Project 2025 and Federal Employment

This is how we get to the potential impacts of Project 2025 on our public lands. Our public lands are held in trust and managed for us by various federal government agencies. These agencies are staffed by civil servant employees, clerks, biologists, scientists, foresters, and people working in other specialized trades and professions. Agencies like the Bureau of Land Management, US Forest Service, and US Fish and Wildlife Service have long been among the largest employers of resource professionals in the country.

In addition to concerns about politicizing these roles of scientists and staffers, there is a worry that this could send agencies into a tailspin after hemorrhaging workers and dissuading future resource professionals from pursuing careers in forestry or biology for fear of losing their jobs with changing administrations. These are positions designed to be life-long careers attained through merit, not jobs that change with whatever way the political breeze is blowing.

There is talk of a real risk of unforeseen consequences this could have on our resources, our taxpayers, and the people who work in these fields. Ryan Busse, the Democratic candidate for governor in Montana, says that if Project 2025 is brought to fruition, it will be “an unmitigated disaster for public lands and wildlife. Experienced career professionals, including many biologists and scientists, would be replaced with people who are loyal to a person instead of the resource.”

Project 2025 is divided into five major sections, with chapters in each dedicated to outlining The Heritage Foundation’s plans for restructuring government agencies, from the Department of Defense to the Federal Communications Commission and everything in between. The three chapters poised to have the most impact on public lands and conservation are those of the USDA, DOI, and EPA.

Department of the Interior Chapter

The chapter most concerning is chapter 16 regarding the Department of the Interior (DOI), authored by the notorious “sagebrush rebel” and former acting deputy director of the Bureau of Land Management, William Perry Pendley. Pendley has been a long-time advocate for the disinvestment of federal lands, and just last month, he published an op-ed pontificating on how we could solve the housing crisis by selling off our public lands.

However, explicit mention of these divestment and selloff plans seems conspicuously absent from the document. Instead, Pendley and The Heritage Foundation seem to focus on regulation, or more accurately, de-regulation in favor of resource extraction. Pendley himself admits to enlisting the help of oil and gas industry executives like Kathleen Sgamma, the president of Western Energy Alliance, to write the section pertaining to oil and gas extraction on public lands.

Pendley begins his chapter by laying out a list of grievances against the DOI before diving into his specific policy goals and agendas, some of which have merit. For instance, he talks of the need for wild horse and burro reforms, which has long been an uncomfortable topic but is something that needs to be addressed if we are serious about protecting habitat for native and vulnerable species in the arid west. Additionally, there is equally uncomfortable but necessary talk of some of the language around the Endangered Species Act (ESA) and what successful recovery looks like for species like the grizzly bear and grey wolf.

Grizzly bear delisting has been a bit of a political football over the last few years. It briefly was delisted in 2017 before the Supreme Court reversed that decision in 2018. Since then, the case continues to be made that both the Greater Yellowstone Ecosystem and Northern Continental Divide Ecosystem populations should be delisted. Pendley leaves out any discussion of other grizzly bear recovery zones and simply calls for the delisting of the two places where they have arguably met or exceeded recovery goals.

Some of his ESA proposals are fairly surgical and precise, like the grizzly bear delisting. But, others seem needlessly broad, such as calling for a delisting of wolves across the continental United States. There is justification for pursuing delisting across several population segments of wolves, but a nationwide delisting is much harder to defend. He goes even further and risks throwing out years of collaborative, bipartisan work in favor of granting western states jurisdiction over greater sage grouse management. Sage grouse populations have long been hovering at concerning levels, and management has been a thorn in the side of some oil and gas industry lobbyists. Pendley demands that sage-grouse conservation should not “interfere with public access to public land and economic activity.”

Other policies, however, are fairly alarming and have raised hackles across the conservation sphere. Most of the policies are aimed at streamlining oil and gas development, from calling for expanding drilling in the Arctic National Wildlife Refuge, fast-tracking lease approvals, reducing royalty fees and bonding requirements for leaseholders, and broadly increasing both on and offshore oil and gas lease sales. “This is a huge deregulatory handover of our public lands to the oil and gas industry.” Chris Marshall, at Accountable.US, said. “We are handing the keys to our public lands over to industry.”

Many of the people who have been tasked to write this document have already been influential in the management decisions made in Trump’s first term. Kathleen Sgamma and the Western Energy Alliance, for instance, were behind the bulk of the recommendations that made it into Trump’s policies regarding sage grouse management. In a letter to Trump during his first year in office, Sgamma wrote a letter claiming that the accepted, bipartisan sage grouse management plan would cost the oil and gas industry 9,000 jobs and up to $2.4 billion in revenue. It was later found out that Trump officials accepted 13 of the 15 proposals put forward in that letter.

Pendley aggressively and unsurprisingly goes after national monument designations, demanding a downgrade in size of designations, a review of all current monument decrees, and then calls for the Antiquities Act to be dismantled (p. 532), which caused Utah Governor Spencer Cox to bristle in a recent press conference. “I don’t support a complete repeal, I think the Antiquities Act has value,” Cox stated before expressing some concern with how it has been used recently.

In a section regarding the “30x30” plan, Pendley seeks to dismantle the entirety of the “America the Beautiful” initiative by calling for a new president to “vacate that order.” In addition to reviewing resource management plans to eliminate management decisions that “advance the 30x30 agenda,” Pendley also asks that the new president reinstate a Trump-era rule that requires state and local governments to approve of federal land acquisitions purchased using Land and Wildlife Conservation Fund dollars. If a private landowner were interested in selling or donating a property to the federal government as part of an LWCF project, both the governor and county officials would need to sign off in support of an otherwise private real estate transaction.

What may be most damning of all isn’t what is written in the plans for Project 2025, but what isn’t. “This plan only contains prescriptions for resource development and none for conservation,” Chris Seager, an advisor to Accountable.US said. “Not that extraction and conservation are incompatible, but it’s telling that there is nothing about conservation in here.” The plan explicitly aims to shift public lands management away from a system of balanced multiple uses, towards one of maximum yield with minimal oversight and low return to taxpayers.

Other items of concern in the section on the DOI include:

• Abandoning the withdrawals of lands from leasing in the Thompson Divide of the White River National Forest, Colorado; the 10-mile buffer around Chaco Cultural Historic National Park in New Mexico, and the Boundary Waters area in northern Minnesota (p. 532)
• Relocating the BLM headquarters to Grand Junction, Colorado (p. 524)
• Expand the controversial Willow Project in Alaska (p. 530)
• Rescind the Roadless Rule in Alaska’s Tongass National Forest (p. 531)
• Approve the Ambler road in Alaska’s Brooks Range (p. 530)
• Reinstating 2020 era Environmental Impact Statement regarding oil drilling on the Alaska National Wildlife Refuge (p. 530)

Most of the items concerning hunters and anglers fall within the chapter on the DOI, but the chapters on the USDA and EPA also carry proposals that stand to have an effect on our wild places.

Department of Agriculture Chapter

The chapter on the Department of Agriculture (USDA), written by Daren Bakst, the director of the Competitive Enterprise Group, focuses mainly on farm subsidies, SNAP benefits, and school lunch programs, but it does contain some elements affecting hunters and conservation. The US Forest Service, which falls under the umbrella of the USDA and is one of the largest land management agencies in the country, is only briefly mentioned. The section highlights the risks of wildfires and ties that to a need for increased timber harvests.

An alarming section in the chapter calls for the complete elimination of permanent federal conservation easements. This affects “our best conservationists, the landowners,” said Whitney Tawney, executive director of Montana Conservation Voters.

Large-scale landscape conservation measures like easements and acquisitions are some of the most important and effective ways of partnering with private landowners to protect wildlife habitats in rural and front-range communities. An “attack on protecting places has a larger effect than on just the land,” she said. As much as they protect landscapes, these easements allow farmers and ranchers to keep their lands in their family and in production as working farms or timberlands, and inserting state and local government control into these agreements introduces a level of uncertainty that is worrying.

Most striking of all, however, is where Bakst states the need to “champion the elimination of the Conservation Reserve Program.” The CRP is one of America’s longest-running and most successful private land conservation programs. The CRP is a cost-share and rental program where farmers are incentivized to take certain lands out of agricultural production and leave them as cover providing diverse, native habitat for wildlife and often access for hunters.

Bakst writes that farmers should “not be paid in such a sweeping way to not farm their land.” But in many agricultural areas, CRP lands provide the only islands of intact native habitat such as hedges, native grasses, and shade trees in an otherwise sea of mono-crop farmlands.

Environmental Protection Agency Chapter

The chapter pertaining to the Environmental Protection Agency (EPA) was written by Mandy Gunasekera, Trump’s former chief of staff at the EPA. Gunasekera has previously cited resistance from career staff within the EPA and unpreparedness within the administration as major hurdles to enacting policy goals from Trump’s first term. She lays out a clear vision for creating what she calls a “conservative EPA” by establishing a framework for downsizing the agency she once led through eliminating the standalone Office of Enforcement and Compliance Assistance, “terminating newest hires in low-value programs, and removing or consolidating a number of offices under the EPA umbrella.” She also focuses on gutting regulations on air quality standards, greenhouse gas reporting, and pollutants.

Under the EPA, the Office of Water is tasked with safeguarding drinking water and maintaining oceans, watersheds, and aquatic ecosystems. It also implements the Clean Water Act and Safe Drinking Water Act. Gunasekera takes umbrage with the perceived infringements on private property rights under the CWA and Waters of the US rule.

Within her list of new policy proposals, she asks for a new WOTUS rule that includes a far narrower interpretation of what a “navigable” waterway is than what is currently accepted. It’s not clear if that narrower reading of the definition of “navigable” could affect stream access laws across the states. She then goes so far as to ask that the next president codify the definition in the Rapanos v. United States decision, which would eliminate protections for ephemeral water bodies such as prairie potholes.

She also aims to further weaken the CWA by not allowing the EPA to consider potential future threats to waterways when issuing discharge permits, not requiring discharge permits to be issued at all for discharge into non-navigable waters, as well as imposing a timeline for monitoring the discharge of point source pollution into waterways.

Trump’s Actual Agenda?

While this list of goals and the intentions behind it are certainly concerning, there isn’t any guarantee that these policies will happen. This document serves as a wishlist for a cadre of think tanks and lobby groups, many of whom do enjoy a level of closeness with the former president. But these suggestions are not part of any official policy within the Trump campaign or the Republican party platform.

Trump has disassociated himself from Project 2025, writing on Truth Social, “I have not seen it, have no idea who is in charge of it, and, unlike our very well received Republican Platform, had nothing to do with it.”

However, a recent Washington Post article shows an image of the former president in a private jet with Heritage Foundation President Kevin Roberts. The jet was en route to a Heritage Foundation conference where Trump delivered the keynote address and said “they’re [the Heritage Foundation] going to lay the groundwork and detail plans for exactly what our movement will do."

The Washington Post also reported that Trump campaign staffers have become “furious” that the Heritage Foundation has continued to promote Project 2025, and the think tank is getting the message. The project’s director recently stepped down, and Heritage says they’re winding down their policy operations.

Trump strategist Chris LaCivita has said that people involved in the project will be barred from a second Trump administration.

Still, according to CNN, at least 140 people who have worked for the former president are involved, including six former cabinet secretaries. Given Trump’s history of deference on policy and staffing to groups like The Heritage Foundation and oil and gas interests, conservationists are understandably concerned that at least some of these people, and some of these policies, may find a home in a second Trump administration.