The former head of Project 2025 believes an “unchained” President Donald Trump has made immense progress during the first 100 days of his second term toward undoing liberal gains dating back to Franklin D. Roosevelt.
But Paul Dans — who led the effort to produce a detailed conservative transition plan and policy blueprint that was at the center of last year’s presidential election — believes the president needs an influx of new attorneys to fight for his policies in court. Those battles, Dans told NBC News, will shape the next 100 days.
“If Roosevelt had the New Deal, this is what I would think of as Trump’s real deal,” Dans said. “This is deconstructing the administrative state and walking back a lot of this progressive architecture that had been built up by FDR.”
“What’s coming next is really a squaring off with the courts,” Dans said, adding, “This is going to reach, certainly, a boiling point, and so look to that getting resolved.”
The Dans-led Project 2025 was an effort overseen by the Heritage Foundation ahead of the 2024 campaign, which began with the basic premise of setting up a future right-wing administration to govern on Day 1 with more preparation and planning than Trump had for his first term. Much of Project 2025 centered on plans for radically restructuring the civil service, as well as providing a database of potential MAGA-inspired hires in a new administration.
But it was a 900-plus-page memo, outlining many policy positions a future administration should consider, that garnered the most attention, as Democrats put it at the center of their campaign. Even though many of the policies included in the document mirrored policies Trump pledged to enact in his own plan, Agenda47, the president and his campaign distanced themselves from Project 2025 on the trail. And Dans, who worked in Trump’s first administration, was forced out of his position over the summer as anger from the campaign intensified.
After Trump won, however, he hired multiple authors of the report to key positions, including Office of Management and Budget Director Russell Vought, immigration czar Tom Homan, top trade adviser Peter Navarro and Federal Communications Commission Chairman Brendan Carr, among others. NBC News reported during the transition that the transition team was utilizing the Project 2025 database of potential hires, too.
The blueprint ultimately foreshadowed plenty of what Trump has enacted or attempted once in power. An independent tracker found that the administration has completed or taken action on roughly 40% of the material in Project 2025’s blueprint. That includes everything from cutting research grants to universities to readying cuts for climate research, stripping some immigrants of Temporary Protected Status, and an all-out assault on diversity programs in government.
With that in the foreground as Trump hits the 100-day mark, Dans spoke with NBC News in a pair of interviews in recent days. He doesn’t believe measuring Trump’s actions against Project 2025’s plan “is really accurate,” adding, “these are, to be sure, President Trump’s own policies, many of which were embodied in Project 2025.”
“It’s with great excitement that I read what’s going on every day and see a new step that they’re taking,” Dans said. “But to be sure, this has to get implemented. At this point, a lot of the executive orders and the like are policy pronouncements, and the real rubber is going to meet the road when it comes to implementing all these directives.”
With a tightly divided Congress passing few new laws, though, a number of Trump’s executive initiatives — whether they be on immigration, the civil service or federal funding — are tied up in court battles that will be key in determining just how far the president is able to go.
“Many of us always saw this as the ultimate end game, that this is where the two sides would meet,” Dans said. “It comes down to having the right people. Ultimately, you need to have zealous advocates for MAGA in position and ready to face off with their counterparts. … To be sure, this is where all the eyes are going to go next.”
“He needs additional reinforcements on his team,” Dans said, “as this kind of slows down into a war of attrition with the deep state, particularly on the legal front.” He added: “As much as he can continue to get his team on the field, that’s imperative.”
Personnel is policy
On his Truth Social platform Monday, Trump posted that his administration has so far hired to fill more than 80% of political appointee positions in some of the largest agencies, including the departments of Justice, State, Defense and Treasury. Those positions make up a small number of the jobs in each agency, but Trump recently moved to reclassify a whole host of federal workers to make them easier to replace.
The administration has already suffered some setbacks in court. The fallout over Kilmar Abrego Garcia’s deportation to El Salvador began when the administration said in court filings that he was deported because of an “administrative error.” Last week, the administration replaced its lawyers in a case challenging New York City’s congestion pricing, after the U.S. attorney’s office in Manhattan said it mistakenly filed a memo that detailed weaknesses in the administration’s argument and strategy.
“This is where the worry comes in,” Dans said. “Is there enough of a MAGA elite among the top legal minds to meet” the administration’s needs?
“I think it’s really incumbent on the administration to get a lot of these good lawyers who are out in the 50 states, get them to Washington and press them into service,” Dans continued.
Enhancing MAGA staffing has been front of mind for Dans for a long time, given how central deconstructing the existing federal bureaucracy was to Project 2025. That mission has been carried out by Trump and Elon Musk, the billionaire adviser who’s overseen the effort dubbed the Department of Government Efficiency.
“What’s elementally important is that Project 2025 identified the administrative state as the major blockade to effectuating change for the better,” Dans said.
The Trump administration hasn’t “fired enough people, to be sure,” he added, describing how difficult it is to do so under existing regulations. With Trump recently moving on the policy known as Schedule F — the reclassification of some career government employees to make them easier to remove — Dans said he expects to see “a lot more of this taking place.”
Dans had plenty of praise for Musk and his effort, as the tech titan announced this month that he will soon dedicate more time to his business interests and decrease how much time he’s spending in government.
“Without DOGE, I don’t believe any of this would be able to be accomplished at the pace it has been,” Dans said, adding its structure remains necessary to achieve Trump’s goals in the months to come. “This is a great 100-day mark, a watershed moment in history. This is the slamming of the door on the progressive era.”
But Dans did offer some caution on artificial intelligence policy, as Trump has sought to loosen restrictions around AI via executive orders while Musk and DOGE have implemented AI programs at some federal agencies.
“AI has produced this MRI of the blob, and now we can actually make connections that would have been impossible before, in a matter of a weekend, that might have taken two years of study,” Dans said, adding, “But I do believe that AI needs to be carefully policed by the administration.”
‘Short-term pain, but all for long-term gain’
As Trump hits the 100-day mark of his administration, polling is flashing several warning signs for him on signature issues, like immigration and the economy, as deportations to a prison in El Salvador and the president’s global tariffs garner headlines.
Dans, though, says Trump is on target and maintains a mandate for “sweeping change.”
“This is Trump, unchained and able to do what he promised the American people,” he said. “There’s no playbook out there for restoring the country. Much of this is intuitive to him and to others. There are going to be ups and downs. It’s a long-term proposition. So there will be some short-term pain, but all for long-term gain.”
Moving forward, Dans said he’s eager to see more reforms at the Defense Department, including a “large repurposing” of the agency as it sharpens its focus on Asia, which he believes is coming once there’s a settlement in Ukraine. He also wants to see Trump take action on a policy he proposed during the campaign but has gotten little attention in recent months: the construction of 10 “freedom cities” on federal land.
“I always thought that was an intriguing Trump idea,” Dans said. “It captures the imagination of everybody to build something new. He’s a builder. So the first part of building is demolition, but he’s going to get on to the construction phase pretty soon.”
Looking ahead to 2028, Dans said there won’t be a need for a Project 2029.
“We have President Trump in power now, he has a team,” Dans said. “The premise of Project 2025 was that we needed, as conservatives, to get together. We were a herd of cats, often scratching at one another, and we needed to kind of start marching in the line. And that’s what Project 2025 did.”
“And I think, not only our initiative, but other presidential transition projects really put this forward that time was of the essence,” Dans continued. “And President Trump has certainly come out and played with an urgency that is 100% correct.”
