Move over, Project 2025.
The policy blueprint from the conservative Heritage Foundation has drawn significant attention from the media and from Democrats on the campaign trail. But another conservative think tank that’s packed with Trump administration alumni and has a policy agenda of its own is poised to have even more sway over an incoming Trump administration.
It’s the America First Policy Institute — and the group recently got a big boost from former President Donald Trump, who long has espoused an America First approach to politics and foreign policy.
Trump, the Republican presidential nominee, announced recently that Linda McMahon — who helped launch the America First Policy Institute — would co-chair his presidential transition team along with Howard Lutnick, chair and CEO of financial services giant Cantor Fitzgerald.
The move propels into the spotlight the America First Policy Institute and its team loaded with ex-Trump officials, including former Interior Secretary David Bernhardt and former Energy Secretary Rick Perry. And it gives McMahon and her group a powerful role in setting policy, crafting executive orders and hiring thousands of employees to staff a possible second Trump term.
The decision also is another blow for the Heritage Foundation, which has spent two years vying for exactly that type of role through its Project 2025 proposal.
In a statement, Trump said he had “absolute confidence the Trump-Vance administration will be ready to govern effectively on Day 1” with McMahon and Lutnick leading the transition team. Among the policies put forward by the America First Policy Institute are ways to boost oil and gas production and more easily fire federal employees.
Trump and his campaign have spent months trying to distance the former president from Project 2025, even though it was written by a number of his former administration officials.
Campaign officials celebrated when its director was forced to step down. Democrats have seized on the plan as a vehicle to use in their Trump attacks and have read from it every night at the Democratic National Convention.
“The Trump people feel that the Heritage project was mishandled and was harmful, and so they’re not inclined to reinforce the whole 2025 project,” said Newt Gingrich, the former House speaker who is on the board of directors of the America First Policy Institute. “On the other hand, I think they believe that the America First Policy Institute has been consistently sophisticated, very, very pro-Trump and has been a reliable developer of positive ideas.”
The Trump and Biden campaigns did not respond to requests for comment. The Heritage Foundation also did not respond to inquires from POLITICO’s E&E News.
Mandy Gunasekara, who wrote the EPA section of Project 2025, told E&E News in July that the policies in that guidebook “are designed for the next conservative administration to consider and provide strategic thought on how to achieve them. What is ultimately pursued is the prerogative of the president.”
Her comments came after Trump publicly distanced himself from the policy road map, saying he had “no idea who is behind it,” although Gunasekara and other contributors served in senior roles in his administration.
The Heritage Foundation, which coordinated with more than 100 other conservative groups to produce Project 2025, laid out reams of federal policy proposals in a 900-page volume that included sections on breaking up and downsizing NOAA, neutering government climate science and turning the federal government into a booster for the fossil fuel industry.
By contrast, the America First Policy Institute released a relatively slim 250-page document that outlines similar energy priorities but in far less specific terms.
Unlike the Heritage Foundation, which has been drafting conservative policy blueprints for decades, the America First Policy Institute was founded as a Trump-centric think tank in 2021 by former administration officials McMahon, Larry Kudlow and Brooke Rollins. Kudlow and Rollins worked in the Trump White House.
Since then, the group has been preparing policy plans and lists of potential political appointees for a prospective administration eager to tear down the Biden administration’s work.
“Since its inception three and a half years ago, the America First Policy Institute’s team of nearly 200 policy experts, including nine former Cabinet members, 20 White House Senior Staff, and nearly 50 Senior Administration officials have been quietly focused on helping current and future leaders at the local, state, and national level enact policies to reverse the damage caused by the radical left and put the interests of the American people first,” said Hilton Beckham, a spokesperson for the think tank.
In addition to Gingrich, the group’s board of directors include wealthy Church of Scientology supporter Trish Duggan; Goya Foods CEO Bob Unanue and Tim Dunn, a billionaire Texas oil mogul and top Trump donor who has spent at least $5 million this election cycle, according to the group’s latest tax return.
Dunn is influential in Texas politics and has spent $30 million to elect conservatives in Texas and shift state policy further right. He is a prominent backer of the Texas Public Policy Foundation, which rose to national prominence in the first Trump administration. Both Rollins and Heritage President Kevin Roberts formerly headed the Texas group.
The America First Policy Institute is a dark money organization that does not disclose its donors, but its most recent public tax returns for 2022 show that almost a third of its revenue came from a single source. Additionally, more than a fifth of its revenue came from a single organization in 2021.
The group hauled in almost $15 million in 2021, then grew that to $23 million in 2022, the tax records show.
When asked about the group’s funders, Gingrich said “no” and then hung up on a reporter.
‘Trump really likes her’
Before McMahon helped establish the America First Policy Institute, she served as administrator of the Small Business Administration under Trump. And before that, she was a former chief executive officer of what’s now called WWE.
Sean Spicer, who served as White House press secretary under Trump, called her an obvious choice for the job.
“Everybody likes her. She’s obviously got a ton of personal experience in the business world,” Spicer said. “She served in the administration with distinction. Trump really likes her. She’s the perfect candidate for this.”
He said he views think tanks’ policy agendas as starting points, rather than prescriptions.
“Going into a restaurant and getting a menu doesn’t mean that’s what you’re eating,” Spicer said. “It’s like, those are your choices. You could even walk out of the restaurant.”
The America First Policy Institute has an extensive menu.
The group has pushed some of the same policies that Project 2025 proposes. That includes a plan that would make it easier to fire government career officials in order to replace them with Trump loyalists.
The think tank also has “begun more than 50 draft executive orders to counter the radical progressive policies of the current administration, and another 100 are in development,” its website says. And it’s “drafting strategic legislative packages and coordinating with key stakeholders.”
The energy agenda urges the elimination of “inefficient” energy subsidies, regulations and financial regulations. It also calls for an expedited rehabilitation of decommissioned power plants and exemptions for the energy sector from “logistical and supply chain constraints imposed by outdated legislation.”
The America First Policy Institute also zeroes in on the Inflation Reduction Act and other climate priorities from the Biden administration. It criticizes a “top-down approach” to the “green” energy revolution, and urges the next president to “halt all new discretionary regulatory policy activity and actions that would disproportionately target one sector at the expense of another.”
The group has also called for a national uranium reserve to support nuclear power, increased oil and gas drilling on federal lands, more offshore drilling, more funding for nuclear technology development and opening up the Arctic National Wildlife Refuge to drilling. It also includes a goal of increased domestic mining for critical minerals and rare earth elements.
In addition, America First wants to weaken a series of key public health protection laws long targeted by the energy industry. That includes the Clean Air Act; Clean Water Act; National Environmental Policy Act; Energy Policy and Conservation Act; Endangered Species Act; and Comprehensive Environmental Response, Compensation and Liability Act.
The America First Policy Institute is better positioned to implement Trump’s policies throughout the government because its leaders understand what he will want — rather than forcing their vision for a second term on him, said Gingrich, author of the book “Understanding Trump.”
“They understand that their job is to develop policies for him, not to try to sell him on their policies,” he said. “They also understand that you have to win before you get to do anything.”
