Project 2025 is already notorious for promoting a rapid implementation of its suggested policies. “The tone and tempo of an administration are often determined on January 20” (MFL* pg. 24).
Among the most publicly unsettling of the suggested immediate actions are those curtailing immigration. Broad immigration reform will require Congressional action, but the Trump Administration will have several options for increasing enforcement. Project 2025 helpfully outlines which actions it feels are legal for the executive branch to take immediately, although most of them would almost certainly be fought in courts if enacted.
The following are Project 2025 immigration enforcement measures that we might see immediately implemented by the Trump Administration:
An order for Immigrations and Custom Enforcement (ICE) “to stop closing out pending immigration cases” (MFL pg. 141);
Directing ICE to take custody of all undocumented immigrants with felony or violent crime records, including “previous removals” (MLF pg. 141);
Rescinding “sensitive zones” where ICE was previously cautioned from operating (MLF pg. 142);
Ordering ICE to “make full use of existing Expedited Removal (ER) authorities” within 100 miles of the border (MLF pg. 142);
Require immigration applicants “rejected for any benefit or status adjudication” to leave the U.S. immediately (MLF pg. 146);
“Mandate that ICE use all detention space […] and provide authority for low-level temporary capacity (for example, tents)” (MLF pg. 151);
“Prohibit the use of Notices to Report” and “the use of parole” (MLF pg. 151);
Grant USCIS access to national security and law enforcement databases (MLF pg. 152).
These proposals, if enacted, would result in numerous additional and longer-term detentions, potentially causing the need for so-called “tent cities” to form at detention sites.
To get these recommendations implemented as quickly as possible, Project 2025 also recommends the following personnel measures:
Use of “acting” categories in key positions within the Department of Homeland Security (MFL pg. 136);
Rotating D.C.-based U.S. Citizenship and Immigration Services employees to offices across the U.S. (MFL pg. 147);
Relocating all law enforcement personnel from office positions to the field (MFL pg. 137).
Rapid enactment of these personnel measures will signal that additional immigration measures are forthcoming.
more “Day One”…
Project 2025 offers “Day One” recommendations in a number of areas.
The first to be on the look-out for are issuing or reinstating Executive Orders regarding the labor force, including reinstating E.O. 13839, which was rescinded by Biden. This order would exempt Senior Executive Service (SES) and other policy-affecting civil service positions from competitive hiring rules, and instead administratively file them under a “Schedule F” hiring authority. There are thousands of SES employees in the executive branch. This order would give Trump the ability to choose his own army of leading policymakers outside of the normal federal hiring process.
Some other explicit “Day One” agenda items include:
Replace all current National Security Council detailees (MLF pg. 52);
Dismiss “the entirely of the CISA Cybersecurity Advisory Committee (MLF pg. 155);
Issue an executive order to “pause and review” several components of the EPA and ending all EPA science activity that is not explicitly required by Congress (MLF pg. 422 and pg. 436);
“Appoint new EEOC and NLRB general counsels” (MLF pg. 615);
Dismantle the Gender Policy Council (MLF pg. 62);
“signal [its] intent to enter the rulemaking process to restore the Trump Administration’s Title IX regulation, with the additional insistence that ‘sex’ is properly understood as a fixed biological fact” (MLF pg. 334).
*MFL = Mandate for Leadership, Project 2025’s set of policy proposals.