Project 2025 Update II

Project 2025 April 8th Update

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Project 2025 Is Here.

With Trump’s presidency, Project 2025, a 920-page blueprint for authoritarianism in the U.S., is becoming a reality, affecting all Americans and people around the globe.

More than 100 far-right organizations support this plan for autocracy. Dozens of members of the new administration have direct ties to the effort.

The document calls for dismantling federal agencies, rolling back civil rights protections, gutting environmental regulations, and concentrating executive power. Read GPAHE’s full analysis of Project 2025 and the groups behind it.

GPAHE tracks how Project 2025 and Christian nationalism are becoming a reality under Trump, and their impact on the American people and democracy, and advocates for ways to stop the implementation of authoritarianism in the U.S.

This week, we look at at Trump’s firing of Attorney General Pam Bondi for failing to prosecute his enemies list fast enough, six cabinet officials stripping Endangered Species Act protections from every creature in the Gulf of Mexico,  the record number of deaths in detention under Project 2025’s mass deportation policies, and the Education Department targeting schools that dared to protect transgender students.

You’re Fired: Project 2025’s Weaponized DOJ Wasn’t Weaponized Enough

Project 2025’s 28-page Department of Justice chapter laid out two goals: end the department’s independence from the White House, and end the ability of its individual divisions to exercise their own judgment. Gene Hamilton, a close Stephen Miller ally, wrote the chapter. It demanded a “vast expansion” in political appointees, complaining that the first Trump term had not installed enough loyalists to “promote the President’s agenda.” Fourteen months into the second term, that expansion is underway, and on April 2, President Trump fired Attorney General Pam Bondi.

A source close to the president told Axios the firing of Bondi had nothing to do with the Epstein files debacle and everything to do with Trump’s enemies list. Her Department of Justice had secured indictments against former Federal Bureau of Investigation Director James Comey and New York Attorney General Letitia James, opened criminal investigations into Federal Reserve Chair Jerome Powell and former Central Intelligence Agency Director John Brennan, and gone after six Democratic lawmakers. But a federal judge tossed the Comey and James cases because the prosecutor who brought them, Lindsey Halligan – another former Trump personal attorney – had been unlawfully appointed. Grand juries refused to bring new charges against James. A separate grand jury in Washington declined to indict six Democratic members of Congress over a video in which they urged military personnel to refuse illegal orders. A federal judge quashed Department of Justice subpoenas to the Federal Reserve as part of the Powell investigation.

In a since-deleted Truth Social post, Trump addressed Bondi by name. “Pam: I have reviewed over 30 statements and posts saying that, essentially, ‘same old story as last time, all talk, no action. Nothing is being done. What about Comey, Adam “Shifty” Schiff, Leticia??? They’re all guilty as hell, but nothing is going to be done.’” He added, “We can’t delay any longer, it’s killing our reputation and credibility. They impeached me twice and indicted me (5 times!), OVER NOTHING. JUSTICE MUST BE SERVED, NOW!!!” Administration officials told Rolling Stone the post resembled how Trump typically texts, suggesting it was a private message to Bondi accidentally posted publicly. Deputy Attorney General Todd Blanche, Trump’s former personal criminal defense lawyer, has taken over as acting attorney general. Environmental Protection Agency administrator Lee Zeldin is reportedly the frontrunner for a permanent replacement.

Playing God with Extinction: How Project 2025 Paved the Way for the Gulf’s Endangered Species Wipeout

Florida manatees nuzzle canoes. They roll over for belly scratches from snorkelers and follow kayakers like half-ton puppies. That trusting nature nearly killed them off. By the 1970s, hunting and boat strikes had reduced the population to a few hundred animals. Florida started protecting them in 1893. The federal government listed them as endangered in 1967, six years before the Endangered Species Act even existed. Florida and the feds have spent 130 years working to bring the species back. They designated spring sanctuaries, enforced speed zones for boats, funded rescue teams, and restored seagrass habitat. The population has since climbed to more than 8,000, with around 5,000 on the Gulf side. In a 16-minute meeting, six Trump cabinet officials voted to strip every one of those protections from the Gulf of Mexico.

Manatees weren’t alone. Scientists didn’t even realize the Rice’s whale was a unique species until 2021. It is the only baleen whale that lives year-round in the Gulf of Mexico, and fewer than 50 are left. The 2010 Deepwater Horizon spill killed about 17 percent of them. Five species of sea turtles nest on Gulf beaches and feed in Gulf waters, including the Kemp’s ridley, the most endangered sea turtle on earth, which breeds almost exclusively on Gulf shores. Decades of painstaking work, from tagging programs on Padre Island to hatchery corrals to shrimp trawl regulations, pulled the Kemp’s ridley back from near-extinction in the 1980s, when fewer than 250 nests were recorded in a single year. None of that history counted for anything on March 31.

Congress created the Endangered Species Committee in 1978 as a safety valve. It is a panel of cabinet officials who could override species protections when no alternative existed. Known as the “God Squad,” six political appointees sit around a table and decide which species live and which ones go extinct.

In 48 years, the committee granted exactly one real exemption, for a dam in Wyoming’s whooping crane habitat. A second, for spotted owl timber sales in Oregon, was withdrawn after a federal appeals court found the first Bush White House had pressured committee members. That was 1992.

The committee didn’t meet again until March 31, 2026, when it voted 6-0 to exempt every oil and gas operation in the Gulf of Mexico from the Endangered Species Act. Not one project. Not one drilling lease. The entire industry, across the entire body of water, for as long as it keeps pumping.

Project 2025’s Interior Department chapter, written by William Perry Pendley, treats endangered species protections as regulatory barriers to energy production. Pendley wanted critical habitat designations weakened and wildlife managers blocked from reintroducing species to suitable habitats. He also pushed for cost-benefit calculations in listing decisions, something the law’s original authors wrote the statute to prevent.

The vote itself took 16 minutes. Interior Secretary Doug Burgum convened the panel and made it official, exempting all oil and gas drilling in the Gulf of Mexico from the Endangered Species Act, with no public testimony or scientific review.

Pendley’s chapter went further than the God Squad vote. He dismissed the ESA’s track record as “dismal” and called the Fish and Wildlife Service’s scientists “species cartels” riddled with groupthink. His blueprint directed a future administration to rescind Biden-era ESA rules on critical habitat and force wildlife managers to weigh economic costs in listing decisions, which the law’s original authors expressly forbade. Pendley didn’t even write the energy section himself. He delegated it to Kathleen Sgamma, president of the Western Energy Alliance, a trade group that represents 200 oil and gas companies.

Trump started implementing that vision on Day One. His January 20, 2025, executive order declared a “national energy emergency” while the U.S. was already the world’s top oil producer and directed the Interior Secretary to convene the God Squad at least quarterly and hunt for ESA “obstacles” to energy development. The Fish and Wildlife Service proposed four rules rolling back ESA protections last fall. Two of them implement specific Project 2025 recommendations on critical habitat. By January, the conservation organization Center for Western Priorities found that more than half of the nine ESA-related actions Project 2025 called for were already underway.

Defense Secretary Pete Hegseth requested the exemption on March 13, claiming environmental lawsuits threatened national security by making it harder for oil companies to plan drilling operations. He invoked the Iran war and the closure of the Strait of Hormuz.

The Endangered Species Act has never blocked a single oil or gas permit in the Gulf. Deepwater production has increased over 10 percent annually, on average, since 1985. The Gulf of Mexico accounts for about 15 percent of U.S. crude and just two percent of natural gas. The U.S is already exporting 30 percent of what it pumps. Former Interior Secretary Sally Jewell noted that the national security risk the administration cited wouldn’t exist at all if Trump hadn’t started the Iran war himself.

On April 3, a coalition including the Sierra Club, Earthjustice, Friends of the Earth, Healthy Gulf, and Turtle Island Restoration Network sued in the U.S. District Court for the District of Columbia. The Natural Resources Defense Council (NRDC) filed a separate challenge. Pat Parenteau, the Vermont Law professor who helped write the original exemption provision, called the administration’s legal rationale weak. The God Squad process was designed for specific, irreconcilable conflicts between a single project and a single species, not blanket industry-wide carve-outs justified by a war the president chose to start. Vanderbilt law professor J.B. Ruhl, who has worked on endangered species law for four decades, said he’d never seen anything like it.

Trump has complained for years that offshore wind turbines kill whales, a claim federal scientists have found no evidence to support. But when the last 50 Rice’s whales on earth stood between the oil industry and the exemption Pendley’s chapter laid the groundwork for, his administration held a 16-minute meeting and exempted every oil rig, every seismic survey, and every drilling ship in the Gulf from the law that kept those whales alive.

Dying Inside and Out: Project 2025’s Mass Deportation Policy Reaches Record Deaths

The last known footage of Nurul Amin Shah Alam alive shows him stepping out of a white Border Patrol van into the empty parking lot of a closed Tim Hortons coffee shop in Buffalo, New York. It is February 19. He is 56 and nearly blind. He speaks no English. He is a Rohingya refugee who came to the United States legally, one of the few who survived what the United Nations has characterized as genocide against the Rohingya in Myanmar. He has five sons and grandchildren overseas. The Rohingya have been hunted, burned out of their villages, and stripped of citizenship in Myanmar for decades. Shah Alam fled to Malaysia in 2002.

He is wearing the orange booties the county jail gave him. He pulls his hood close against the cold air and walks into the dark. The agents drive away. Five days later, a passerby near the arena where the Buffalo Sabres hockey team plays spots him on the sidewalk, moving, around 5:30 p.m. She calls 911 hours later when she returns to find him motionless. He is dead, five miles from where the Border Patrol left him when they realized he could not be legally detained.

Shah Alam came to Buffalo on Christmas Eve in December 2024 with his wife and two of his five children. On February 15, 2025, he got lost and wound up in someone’s backyard in the Riverside neighborhood, and broke a shed door. The homeowner called 911. Body-camera footage from the arrest captured a confused Shah Alam speaking Rohingya and Malay to a circle of Buffalo cops, none of whom understood a word. They tased him. He pleaded guilty to two misdemeanors and spent a year locked up.

On February 19, his family arrived at the Erie County Holding Center to finally bring him home. They sat in the waiting room, but he never walked out. The sheriff’s office had flagged his release to Border Patrol, which had lodged an immigration detainer after Shah Alam’s arrest. Notifying the feds when he was due out was standard procedure. Agents found he could not be deported, so they drove him to a Tim Hortons doughnut shop that U.S. Customs and Border Protection (CBP) later called a “warm, safe location” near his last known address. His family had moved a year earlier, the restaurant was closed, and no one told his family where he was.

On April 1, the Erie County Medical Examiner ruled his death a homicide. The cause: complications of a perforated duodenal ulcer, precipitated by hypothermia and dehydration. County Health Commissioner Dr. Gale Burstein explained what happened inside his body. Cold and dehydration cut blood flow to his gastrointestinal tract. Acid ate through the wall of his small intestine until it burst. Without emergency surgery, it was unsurvivable. CBP called the coverage “another hoax.” Erie County District Attorney Mike Keane opened an investigation.

Border Patrol couldn’t deport Shah Alam, so they left him at a closed coffee shop. He never made it inside the detention system. For the people who did, the death rate under Project 2025’s immigration blueprint is accelerating. Twenty-five people have died in U.S. Immigration and Customs Enforcement (ICE) custody since October 2025. As of mid-February, the agency was holding more than 68,000 people.

Camp East Montana, the government’s biggest new detention center, went up inside Fort Bliss outside El Paso in August 2025. It features desert tents with a capacity of 5,000 and is operated under a $1.3 billion contract by Acquisition Logistics LLC, a Virginia company with no detention experience. Three detainees died in six weeks in early 2025.

On January 3, guards pulled 55-year-old Cuban national Geraldo Luna Campos out of a medication line and put him in segregation. The Department of Homeland Security (DHS) said he’d experienced “medical distress.” A fellow detainee told the Washington Post he watched guards choke Luna Campos to death. The medical examiner ruled it a homicide: asphyxia from compression of the neck and torso. No one has been charged. The government moved to deport the two detainees who talked to reporters about what they saw.

Eleven days later, Nicaraguan national Victor Manuel Diaz died at Camp East Montana in what DHS called a suicide. His family told NPR they did not believe it, and his attorney said no one has explained why Diaz was alone in a clinic room when he died. ICE inspectors found 49 violations of detention standards. Among them: staff who could not be bothered to document the checks meant to keep people from hanging themselves.

In Florida, 19-year-old Royer Perez-Jimenez was found dead in his cell at the Glades County Detention Facility on March 18, less than a month after ICE took custody of him. The agency called it a presumed suicide. The Adelanto ICE Processing Center, in the California desert, has seen five deaths since September 2025. Jose Guadalupe Ramos-Solano, 52, was the most recent. He had lived in the U.S. since he was four. Other detainees called the Immigrant Defenders Law Center hotline after his death and said they watched Ramos-Solano gasping on his bunk while guards did nothing. He died at a Victorville hospital on March 25. The facility faces a federal lawsuit alleging systematic medical neglect.

Tom Homan contributed to Project 2025’s immigration chapter and now runs the deportation apparatus as border czar. Project 2025’s blueprint called for gutting the very DHS civil rights offices that investigated detention deaths, and those offices have since lost hundreds of staff. Eleven people died in ICE detention in 2024. In 2025, that number hit 33. Six months into fiscal year 2026, 25 people have already died in custody.

The Education Department’s Civil Rights Office Is Now Targeting the Schools That Protect Trans Kids

Project 2025 devoted its first four pages on family policy to a single goal: deleting “the terms sexual orientation and gender identity” from “every federal rule, agency regulation, contract, grant, regulation, and piece of legislation that exists.” On April 6, the Trump Education Department terminated six civil rights settlements that had protected transgender students at five school districts and a community college in Delaware, Pennsylvania, Washington State, and California. The agreements, some a decade old, required schools to comply with Title IX by honoring students’ preferred names and pronouns, granting bathroom and locker room access consistent with gender identity, and training faculty on gender-based discrimination. Assistant Secretary for Civil Rights Kimberly M. Richey called the settlements part of a “radical transgender agenda.”

No previous administration had ever done this. Education Department officials acknowledged there was no precedent. But Project 2025 called for removing the words “sexual orientation” and “gender identity” from every federal regulation, and the administration is working through that checklist, settlement by settlement.

The Delaware Valley School District in rural northeastern Pennsylvania shows how. In 2016, a transgender student complained that the district refused to honor a legal name change and forced the student into bathrooms that didn’t match the student’s gender identity. The Obama-era Office for Civil Rights negotiated a settlement requiring new policies and faculty training. That agreement survived all four years of Trump’s first term. It did not survive his second. The Southeastern Legal Foundation, a conservative legal group in Georgia, wrote to Richey in November, urging termination. By February, the department ordered the district to scrap every policy from the settlement or lose federal funding. In March, the school board voted to comply, even though the move puts the district at odds with Pennsylvania’s own anti-discrimination laws.

At Taft College, about 120 miles north of Los Angeles, a transgender student filed a civil rights complaint three years ago. The Office for Civil Rights worked out a settlement: train faculty on preferred names and pronouns, and on how refusing could create a hostile campus. Interim president Leslie Minor said the college held the training sessions and satisfied every term. Richey’s office terminated the agreement on April 6. Project 2025 recommended barring schools from honoring any name or pronoun that doesn’t match a student’s birth certificate, and Richey’s office is not going to leave a federal agreement on file that required the opposite.

Six settlements are a fraction of it. The Education Department has opened at least 40 civil rights investigations into schools that protect transgender students and sued state education departments in California and Minnesota over trans athlete policies. Project 2025 proposed amending Title IX so “sex” means only biological sex at birth. The administration hasn’t waited for Congress; it is rewriting the law’s meaning through enforcement actions, one district at a time.

At the state level, things are rawer. On February 26, Kansas’s SB 244 took effect after the legislature overrode Governor Laura Kelly’s veto. The law voided every state-issued driver’s license whose gender marker didn’t match the holder’s birth sex. About 1,700 people lost their valid IDs overnight with no grace period. The law also created a “bathroom bounty” allowing anyone to sue a person they suspect of being trans and using a government restroom that doesn’t match their birth sex, for $1,000. On March 31, Idaho Governor Brad Little signed a law making it a misdemeanor to use a public restroom matching a person’s gender identity, with a second offense carrying a felony and up to five years in prison. That law covers private businesses, too. In Ohio, the House passed a bill criminalizing drag performance outside adult cabarets, with language broad enough to cover any trans person who uses a gendered locker room.

Several of these laws carry criminal penalties that could put trans people behind bars according to their birth sex. The Bureau of Prisons in February banned gender-affirming care for more than 1,000 trans people in federal custody, replacing hormones with antidepressants. Former Bureau of Prisons (BOP) officials compared the new policy to harmful conversion therapy. Meanwhile, ICE has rewritten contracts at six detention facilities to gut protections for trans detainees, including safeguards against rape. The State Department separately finalized a visa rule requiring applicants to identify by birth sex. Trans immigrants whose documents don’t match now face additional scrutiny, denial, or deportation proceedings.

Twenty-seven states have now restricted trans athletes in school sports. Heritage Foundation President Kevin Roberts has endorsed outlawing gender-affirming care for adults. The settlements that Richey’s office destroyed on April 6 existed because real students filed federal discrimination complaints. On April 6, Richey’s office terminated all six. Project 2025 wanted those agreements gone. Forty more investigations remain open.

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