Reading Project 2025, part 6: the interior, justice, and labor

How might a likely second Trump administration impact higher education?  How can academics plan for and anticipate that major event, should it occur?

This week we continue our reading of Project 2025, a key document in understanding the near- and medium-term future of American politics.  This is an online, open, and distributed reading and anyone can participate. Here’s a post explaining how it works.  You can find all of our Project 2025 posts here.

In today’s post I’ll summarize this week’s reading, which continues under the header we’ve been working through for three weeks, “The General Welfare,” found on pages 517-617.    I’ll draw out the bits which bear directly on higher education. Next I’ll add some reflections and then several discussion questions.  At the end I’ll add some more resources.  Please join in with comments below – for examples of that, you can see good comments at the end of our first post.

Summary overview

With this section the book turns to the Departments of the Interior (DOI), Justice (DOJ), and Labor (DOL).

Project 2025 coverWilliam Perry Pendley, who ran the DOI’s Bureau of Land Management for the Trump administration, fiercely criticizes the department for being openly partisan (“A department that has twice engaged in covert domestic election interference and propaganda operations—the Russian collusion hoax in 2016 and the Hunter Biden laptop suppression in 2020—is a threat to the Republic”). To undo that alleged damage, Pendley would cut back the Endangered Species Act, remove Biden’s 30×30 conservation plan, give some Alaskan lands to development, reduce judicial reviews of some regulations, and turn over publicly held land for logging and other commercial uses.

Next, Gene Hamilton tackles the Department of Justice, urging it to redouble efforts against violent crime.  This can lead to DOJ intervening in local and state jurisdictions:

Where warranted and proper under federal law, [DOJ should] initiate legal action against local officials—including District Attorneys—who deny American citizens the “equal protection of the laws” by refusing to prosecute criminal offenses in their jurisdictions. This holds true particularly for jurisdictions that refuse to enforce the law against criminals based on the Left’s favored defining characteristics of the would-be offender (race, so-called gender identity, sexual orientation, etc.) or other political considerations (e.g., immigration status).

He wants the FBI to focus more on international crime and immigration, ending any work on misinformation, and to launched an overall assessment of just about everything the FBI does.  International topics include strengthening the Mexico border and ramping up efforts against China, including relaunching the first Trump administration’s China Initiative. On more domestic matters, Hamilton wants the DOJ to step back from scrutinizing abortion protestors, to devote more resources to going after protestors opposing anti-abortion projects, and to block abortion pills sent through the mail. He also wants the department to do more about voter fraud and illegal immigrants.

The third chapter in this week’s reading, written by Jonathan Berry, covers not only the Department of Labor, but also “the Equal Employment Opportunity Commission (EEOC), the National Labor Relations Board (NLRB), the National Mediation Board (NMB), the Federal Mediation and Conciliation Service (FMCS), and the Pension Benefit Guaranty Corporation (PBGC).”  It is also perhaps the most religiously themed section of Project 2025, starting off with this in its first paragraph: “The Judeo-Christian tradition, stretching back to Genesis, has always recognized fruitful work as integral to human dignity, as service to God, neighbor, and family.”  The chapter includes a call to firm up overtime pay for work on the Sabbath: “God ordained the Sabbath as a day of rest, and until very recently the Judeo-Christian tradition sought to honor that mandate by moral and legal regulation of work on that day.”

At the same time, the texts wants to make it easier for employers to pay less overtime otherwise, especially “in lower-cost regions (e.g., the southeast United States”. (592). As 25andme summarizes this last point:

Project 2025 on overtimeAs with other chapters we’ve read, this one would end DEI training, practice, and data gathering for these agencies, including by “[e]liminat[ing] disparate impact as a valid theory of discrimination for race and other bases under Title VII and other laws”. Similarly, it would roll back Biden-era gender regulations, asking for a new president to ” [r]escind regulations prohibiting discrimination on the basis of sexual orientation, gender identity, transgender status, and sex characteristics.”  It would also seek to restrict employers’ support for employees’ abortion access.  Berry wants to expand religious belief protections in the commercial sphere.  He would also give states the ability to sidestep federal labor rulings.

What does this mean for higher education?

The DOJ section asks for colleges and universities to play a role in the anti-China push:

key goals for the China Initiative that included development of an enforcement strategy concerning researchers in labs and universities who were being coopted into stealing critical U.S. technologies, identification of opportunities to address supply-chain threats more effectively, and education of colleges and universities about potential threats from Chinese influence efforts on campus.

Further, there’s a research angle for the DOJ, an anti-academic one: “The National Institute of Justice… should fund high-quality, unbiased research on the topics of greatest interest to everyday Americans and policymakers rather than agenda-driven research desired by advocates or academics.”

The Department of Labor section might apply to higher education by reducing overtime regulations. At a broader level Berry’s chapter wants to boost apprenticeships, mostly likely in competition with college and university study. (594-5) This section also calls on Congress to end college degree requirements for federal positions. (597)

Reflections

These chapters carry on some consistent themes from the rest of the book, namely undoing Biden-era DEI measures, opposing China, and stopping illegal immigration.

Once more there’s the contradiction between devolving federal authority to states and localities, while at the same time calling for more federal power – most notably in asking for the DOJ to intervene in local authorities’ actions.

Again I’m struck by the civics of Project 2025, the sheer detail and ambition of its efforts to revise government. This week includes an extensive amount of agency, policy, and legal wonkery.

Questions

  1. How would the policy changes expressed in this week’s chapters impact your professional and personal lives?
  2. Do you see Trump as likely to attempt what this week’s reading describes?
  3. How might the world change if these global policies take effect?
  4. If you oppose what these three chapters call for, what opposition strategy and tactics would best resist it?
  5. Having read this far, what do you anticipate from the rest of the book?

Resources

…and that’s it for this week’s reading.  For next Monday, September 2nd, we’ll finally conclude “The General Welfare” then dive into “The Economy,” all found on pages 619-715.

Please do comment in the boxes below this post.  If you’d prefer to share your reactions on other platforms, tag me or otherwise let me know about those comments so I can include them in our next post.  If you want to respond but are worried about what people could make of your reactions, feel free to contact me here without the web knowing.

Comment away!  And on to the next tranche of Project 2025.

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2 Responses to Reading Project 2025, part 6: the interior, justice, and labor

  1. GLEN MCGHEE says:

    I am struggling to understand the new DOL regulations that just went into effect regarding exempt employees.
    HOWEVER, using DOL’s counter-intuitive logic, the Project 2025 page 592 appears to be grossly inaccurate — lending support to my claim that the authors of Project 2025 have no idea how our government works. NO idea whatsoever.
    Glen

    QUESTION: True or false: raising the overtime pay threshold in usa means fewer workers qualify for overtime pay?
    Perplexity says:
    False. Raising the overtime pay threshold in the USA means more workers qualify for overtime pay, not fewer[1][3][4].
    Here’s why:
    ## Current Overtime Rule
    The Fair Labor Standards Act (FLSA) requires employers to pay overtime (1.5 times the regular hourly rate) to employees who work more than 40 hours in a week, unless they are exempt. To be exempt, employees must:
    1. Be paid a salary
    2. Meet certain job duties tests
    3. Earn at least the salary threshold

    ## New Overtime Rule Changes
    The U.S. Department of Labor’s new rule raises the salary threshold for exemption in two phases:
    – July 1, 2024: Increases from $35,568 to $43,888 per year
    – January 1, 2025: Increases to $58,656 per year[1][3]

    ## Impact on Worker Eligibility
    By raising the salary threshold:
    – More workers will fall below the new threshold
    – These workers will no longer qualify for exemption
    – They become eligible for overtime pay when working over 40 hours per week

    The Department of Labor estimates:
    – About 1 million workers will be impacted by the July 2024 change
    – An additional 3 million workers will be impacted by the January 2025 change[4]

    ## Employer Options
    Employers have several options to comply with the new rule:
    1. Raise salaries above the new threshold to maintain exemption
    2. Reclassify affected employees as non-exempt and pay overtime
    3. Limit workers’ hours to 40 per week to avoid overtime[4]

    In conclusion, raising the overtime pay threshold expands overtime protections to more workers, *not* fewer.

    Citations:
    [1] https://www.shrm.org/topics-tools/employment-law-compliance/overtime-rule-raised-threshold
    [2] https://www.inside.iastate.edu/article/2024/04/25/flsa
    [3] https://www.sidley.com/en/insights/newsupdates/2024/04/us-dol-issues-final-rule-increasing-salary-thresholds-for-certain-flsa-overtime-exemptions
    [4] https://www.paychex.com/articles/compliance/flsa-new-overtime-rule
    [5] https://www.nelsonmullins.com/insights/blogs/the-hr-minute/all/dol-announces-rule-increasing-minimum-salary-threshold-for-exempt-employees
    [6] https://www.pillsburylaw.com/en/news-and-insights/labor-salary-increase-overtime-exemptions.html
    [7] https://www.dol.gov/newsroom/releases/whd/whd20240423-0
    [8] https://www.dol.gov/agencies/whd/overtime/rulemaking

  2. sibyledu says:

    I think you are spot on in your articulation of major themes of the report: opposition to China, rollbacks of diversity initiatives, opposition to illegal immigration (which seems, to the Project 2025 authors, to have a much greater impact on a much broader swath of the nation than is demonstrated in available data), and using the rhetoric of “power to the people” to cloak attempts to grab more power for the federal government. It is also clear that Project 2025 has repudiated the Republican rhetoric (which goes back past Reagan to the anti-New Deal era) that small government is better government, but takes an instrumental view: more federal power is good when pursuing Republican goals, but bad when pursuing Democratic goals.

    I wanted to comment on your second question. I do not think that candidate Trump is eagerly awaiting his opportunity to order his administration to carry out these plans. Rather, I think that the Project 2025 authors have designed this document to be ready to go, so that cabinet and sub-cabinet officials can simply carry out this agenda as soon as they are appointed or confirmed, without waiting for express instruction. The authors have observed Trump’s characteristic insouciance about details, and written the document to play into that particular executive style. If Gene Hamilton, for example, who served in the Trump DOJ and DHS, is appointed to a leadership position at the DOJ, he can simply proceed with the actions he describes, without explicit instruction. And it doesn’t even matter that Trump has publicly repudiated the agenda, because he won’t notice when his DOJ does these things.

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