Project 2025 is infiltrating the Trump administration already

President-elect Donald Trump has repeatedly distanced himself from Project 2025, a 900-page opus of conservative policy recommendations published by the Heritage Foundation, a right-wing think tank. But he has nominated two of the document’s co-authors to Cabinet-level positions, and many others served in his first administration, which suggests the document may be a window into what the next four years could bring. 

On Monday, Trump nominated Brendan Carr, who wrote Project 2025’s chapter on the Federal Communications Commission (FCC), to head the agency. He has also appointed Tom Homan, a Heritage Foundation fellow named as a contributor to Project 2025, as his so-called “border czar.” 

Eighteen of the 40 co-authors and editors of the report served in the first Trump administration. Among them are Ken Cuccinelli, former acting deputy secretary of Homeland Security; Christopher Miller, former acting Defense secretary; and Russell T. Vought, former director of the Office of Management and Budget. Vought is reportedly being considered for another top post in the coming administration. 

During the 2024 campaign, Democrats sought to tie Trump to Project 2025 — a policy agenda they decried as “dangerous” and “shockingly radical” — framing it as a blueprint for his second term that is much more detailed than the GOP’s 28-page platform. The document focuses on proposals to expand presidential power, gut the federal bureaucracy, enact the priorities of the religious right, deregulate, and more. 

Trump at one point claimed to have “no idea who is behind it” and denied any connection with it when asked about it at the September presidential debate: “I have nothing to do with Project 2025. I haven’t read it. I don’t want to read it purposely. I’m not going to read it.”

However, since Trump’s reelection, some of his allies have suggested that the document was always intended to be the playbook for his second term. Trump’s nominations of Carr and Homan seem to support that idea. Neither will require additional Senate confirmation to take on their roles; through them, they will be in a position to advocate for Project 2025’s ideas on communications and immigration, respectively.  

Here’s what we know about Carr and Homan and the ideas relevant to their posts outlined in Project 2025. 

Brendan Carr

Carr, a pick approved by Trump’s billionaire backer Elon Musk, currently serves as the senior Republican on the FCC and was previously its general counsel. Now, he is set to take the helm, steering the commission toward a hardline stance against Big Tech and what he describes in Project 2025 as its “attempts to drive diverse political viewpoints from the digital town square.” 

Among his key proposals in Project 2025 is ending legal immunities for internet platforms hosting user-generated content under Section 230 of the Communications Decency Act. That would require stricter content moderation on the part of these platforms or cutbacks to the degree to which users can contribute content, fundamentally changing the way people interact online. 

At the same time, he wrote in Project 2025 that he wants to ensure that “Internet companies no longer have carte blanche to censor protected speech.” That echoes some of Trump’s other Cabinet picks who are seeking to crack down on “wokeness” in their respective agencies. 

Carr also supports efforts to block TikTok in the US, identifying it, along with the Chinese smartphone producer Huawei, as a national security threat. He claims in Project 2025 that TikTok is part of a Chinese “foreign influence campaign by determining the news and information that the app feeds to millions of Americans.” However, there are reasons to believe that a TikTok ban would, as Vox previously reported, have “serious consequences for online expression,” which include shutting down what has proved a hub for activism.

Carr may have some difficulty enacting his agenda initially, however. The commission will have a 3-2 Democratic majority until next June when Trump will be able to nominate a new member. 

Tom Homan

Homan isn’t named as an author of a particular chapter of Project 2025 but as an overall contributor — and some of his stated hardline views on immigration and the border are reflected in the report.

He started out as a Border Patrol agent in the 1980s and worked his way up through the immigration agencies, becoming the head of US Immigration and Customs Enforcement’s removal operations arm under former President Barack Obama. There, he presided over the most immigrants ever deported in a single year, exceeding 400,000. Under Trump, Homan served as acting director of ICE but was never confirmed to the position permanently by the Senate.

Homan’s new role as “border czar” appears to involve far-reaching responsibilities. Those include overseeing the implementation of Trump’s mass deportations policy — the centerpiece of the former president’s immigration agenda. 

That means Homan’s responsibilities will likely intersect with many of the numerous immigration priorities outlined in Project 2025. Here is a non-exhaustive list of what’s included:

• Expanding the use of a legal authority known as “expedited removal” to quickly deport immigrants who crossed the border without authorization.
• Deporting immigrants even in currently protected, sensitive zones like churches.
• Ending large-scale parole programs that the Biden administration has relied upon as a deportation shield for individuals from certain countries, including Cuba, Haiti, Nicaragua, and Venezuela. 
• Ending programs like the Deferred Action for Childhood Arrivals program, which has protected hundreds of thousands of undocumented immigrants who came to the US as children from deportation.
• Creating a new legal authority akin to the Title 42 policy, which was implemented by Trump and maintained by Biden to rapidly expel immigrants arriving on the US southern border on the dubious public health grounds of stopping the spread of Covid-19. 

Homan has yet to indicate whether he or Trump fully endorses these policies. But unlike Trump, who claims to have never read Project 2025, Homan put his name to the document, and could draw from it in his new role.