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DEPARTMENT OFCOMMERCE
Thomas F. Gilman

T

he Department of Commerce is charged with promoting economic growth,
innovation, and competitiveness while providing the data that Americanbusinesses need to succeed. Intended to serve with clarity of purpose as
the voice of business in any President’s Cabinet, the Department of Commerce has
suffered from decades of regulatory capture, ideological drift, and lack of focus. One
long-standing joke maintains that the department, with its lack of coherence, is aholding company for the parts of the federal government that could not be housed
elsewhere. Thus, in the 1990s, calls emerged to abolish the department and either
spin off, zero-out, or consolidate its functions among other entities.1
At the same time, the department has a higher profile now than perhaps everin its history. It possesses key tools to address decades of poor decision-making
in Washington and is central to any plan to reverse the precipitous economic
decline sparked by the Biden Administration and to counter Communist China.
Both assertions can be equally true, that the department possesses the expertise,programs, and authorities that will be crucial to the success of a conservative
presidency and that its role in the federal bureaucracy would benefit fromstreamlining and reform.
Many programs at the Department of Commerce overlap in whole or part withother governmental programs, and consolidating and streamlining these could
increase both accountability and return on taxpayer investment. Any exercise ingovernment-wide budgeting and reform should review the department with an eye
toward consolidation, elimination, or privatization that examines the efficiency,
effectiveness, and underlying philosophy of each individual component. Though— 663 —

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not an exhaustive set of proposals, the next conservative President should consider whether:
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The International Trade Administration (ITA) and parts of the Bureau ofIndustry and Security (BIS) should be streamlined and moved to the Officeof the U.S. Trade Representative (USTR), along with the Development
Finance Corporation; the U.S. Trade and Development Agency; the Export–
Import Bank; and other trade-related programs spread across the federal
government—as well as considering whether many of these programs
should exist within the federal government;
The Economic Development Administration’s grant programs, which
are among a broad set of duplicative and overlapping federal economic
development grant programs, should be consolidated with other programs
and/or eliminated;
The Bureau of Economic Analysis and Census Bureau, as well as the
Department of Labor’s Bureau of Labor Statistics, should be consolidated
into a more manageable, focused, and efficient statistical agency;
The U.S. Patent and Trademark Office (USPTO) should be made into a
performance-based organization under the Office of Management andBudget (OMB);
Alternatively, the USPTO should be consolidated with the National
Institute of Standards and Technology (NIST) in a new U.S. Office ofPatents, Trademarks, and Standards, with all non-mission-critical researchfunctions eliminated or moved to other, more focused, federal agencies; andThe National Oceanographic and Atmospheric Administration (NOAA)
should be dismantled and many of its functions eliminated, sent to otheragencies, privatized, or placed under the control of states and territories.

Almost every element of the department can be viewed through this lens, butwith today’s political reality and multiple competing congressional committee
jurisdictions, drastic structural change to the department is neither imminent
nor likely. Thus, this chapter largely accepts the baseline of today’s department
and proposes a bold, but achievable, set of proposals for an incoming conservative
Administration.
Whatever the imperfections of the Department of Commerce, it is blessed withmany quality civil servants and strong statutory authorities that, directed properly,— 664 —

2025 Presidential Transition Project

can help ensure U.S. success in 2025 and beyond. With that in mind, this chapter
focuses primarily on policy, strategy, and occasionally tactics that are either immediately implementable under strong leadership or are critical to mission success.
OFFICE OF THE SECRETARYThe Office of the Secretary (OS) is somewhat of a misnomer, as very few of thethousands of employees working in the office are dedicated to staffing the secretary
and implementing Administration priorities. Rather, OS’s budget and full-time
equivalents have increasingly been allocated to fulfill financial, human resources,
administrative, information technology, contracting, and facilities functions, using
outdated and inefficient systems. The Trump Administration began implementing key changes, such as updating financial management tools, but more must be
done to digitize and modernize the department’s processes to free resources for
secretarial and presidential priorities.
The above drain on resources leaves the Secretary of Commerce to rely upona few dozen direct support staff, supplemented with detailees and indirect funding from each of the bureaus to execute the President’s agenda and manage thediverse functions of the department. This structure empowers career staff in eachbureau and makes it harder to mandate change. As such, it is vitally importantthat an incoming Administration fully staff OS with political appointees, send
all existing detailees back to their home bureaus on Day One, and replace thosedetailees with trusted and knowledgeable career staff on an as-needed basis.
Department of Commerce leadership should also fight to restore direct funding and additional political appointee positions to OS and its constituent parts
involved in implementing and communicating the Commerce Secretary’s andPresident’s policy priorities.
Administration, Budget, and Appropriations. Recent practice has been forcareer staff to serve as gatekeepers between department leadership and externalbudget and appropriations partners at the OMB and on Capitol Hill. By serving
not just as a central point of contact but as the sole staff-level communicators of
departmental priorities, these career officials can, have, and will slow down—andeven stop—changes in policy, even at the line-office level.
Although the following is true at all agencies, it is particularly important at the
Department of Commerce that political leadership be immediately installed at the
Office of the Chief Financial Officer (CFO) and Assistant Secretary for Administration (ASA), and that political appointees receive a mandate to communicate withexternal partners alongside career staff at every stage of the budget and appropriations process. Political appointees must also monitor internal CFO operations
down to the operating division level to ensure that funds are not being diverted
to programs that do not align with Administration priorities, as has regularly happened in years past.

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Advisory Committees. Due to the nature of the Department of Commerce’s
portfolio, many of its advisory committees are populated by activists from organizations openly hostile to conservative principles who use the committees to impedeconservative policy. Upon entering office, all such committees should be reviewed
regarding whether they are required by statute and abolished if they are not. Membership of the remaining committees should be reconstituted to ensure they aresources of genuine expert advice and productive contributions to the policy-making
process. Federal Advisory Committee Act (FACA) compliance and awareness of
any ways the committees have been written into regulations should be considered.
INTERNATIONAL TRADE ADMINISTRATIONThe International Trade Administration is centrally placed to craft andimplement U.S. trade policy. Core to ITA’s mission is the expansion of trade andinvestment and the fostering of job creation, innovation, and economic growth,
while also providing research and analysis that support USTR’s trade negotiations.
ITA carries out this mission on behalf of American workers, ranchers, and families.
As discussed elsewhere, historically, conservatives have argued that many federal government trade and investment-oriented functions amount to corporate
welfare or protectionism. There is a growing counterargument within the conservative movement contending that, in a world in which managed trade is the norm
rather than the exception, and in which authoritarian governments, especiallyChina, continually seek to undermine U.S. interests, the U.S. cannot unilaterally
disarm. To do so would harm the cause of free trade in the long term, and, in any
event, Congress is not likely to drastically change the composition or authorization of the ITA. Thus, a policy and management agenda that serves conservative
priorities is crucial.
In a conservative Administration, the ITA should operate with the following priorities:lCounter the malign influence of China and other U.S. adversaries;l

Enforce agreements vigorously and defend against trade violations;lSecure access to critical supply chains and technology; andlEnable the private sector to drive innovation and remain globally competitive.

It is important to note that a deeply entrenched set of career Senior Executive
Service officials have managed the ITA for over a decade. While most are truly
non-partisan civil servants, some are not. Political leadership must manage accordingly. Strong political leadership is needed in ITA’s policymaking positions from— 666 —

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Day One to ensure the bureau is fully implementing Administration policy. An
incoming Administration should ensure that Assistant Secretary and Deputy Assistant Secretary positions are staffed by appointees as quickly as possible.
Enforcement and Compliance. Strong enforcement of trade agreements is
an indispensable function of the ITA carried out by Enforcement & Compliance(E&C). Free and fair trade is impossible without energetic enforcement of existing agreements and without strong defense against dumping and illegal subsidies.
Many free trade advocates consider antidumping and countervailing duty laws
(AD/CVD) to be protectionist and thus antithetical to the conservative free market
position. In their view, AD/CVD laws are overused, abused by certain industries,
and harmful to American economic competitiveness by increasing costs to downstream industries.
Other conservatives maintain that AD/CVD tariffs are not conventional tariffs,
but rather corrective actions meant to address anti-free market activities by othergovernments—a scalpel, not a hammer. In the short term, this may mean higher
costs for U.S. businesses and consumers on a limited number of products from certain offending countries, but those higher prices correct existing price distortionsin the marketplace and ultimately ensure the healthy operation of market forcesin the long term and a level playing field for U.S. manufacturers.
Whatever the case, improvements to the current system must be made to bothprotect U.S. consumers and companies from improperly applied duties and defend
against trade-distorting actions by other governments. Procedures governing the
day-to-day administration of proceedings, as well as policies driving critical decisions in proceedings, require a fresh look. Ultimately, E&C’s mandate is to conduct
a rigorous but also fair, objective, and balanced review of the record in each proceeding and to make decisions without bias.
It is exceedingly unlikely that Congress would abolish or limit the activity of
E&C. Therefore, the proposals below are made under the assumption that anincoming Administration will operate E&C within its current legal, institutional,
and political confines and set a path forward to wield E&C’s considerable power toachieve the goals of a conservative Administration. These proposals can be broken
into three categories: process, policy, and addressing China.
ProcessllRe-establish and expand suspended in-person pandemic-related
verifications, particularly regarding the People’s Republic of China. Ensurethat verifications are rigorous.
Implement advanced analytics and artificial intelligence to identify
opportunities for self-initiation, detect circumvention, and prevent bad
actors from gaming the system.

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Accelerate front-end work on reviews as opposed to constantly pushingagainst statutory deadlines.
Work with Customs and Border Protection (CBP) and other relevant
agencies to address circumvention and duty evasion, and promote policies
that encourage full duty collection to ensure the integrity of AD/CVD andcircumvention orders.
Work with CBP, the Department of Justice, the Department of Treasury,
and other relevant agencies to aggressively pursue importers of record andother beneficiaries for unpaid duties, and consider policy changes to reduce
uncollected duties in the future.
Work, pursuant to the above, with interagency partners in AD/CVD cases toeither require foreign importers of record (IORs) to make cash deposits far inexcess of established duty rates at the time of entry of AD/CVD merchandise,
require IORs to register sufficient U.S. assets to ensure timely payment of
duties, or otherwise prohibit IORs from importing AD/CVD merchandise.
Conduct a regulatory capture audit and put guardrails in place to address
improper exercise of bureaucratic prerogative.
Policyllll

Ensure senior policy and decision-making positions are always held bypolitical appointees.
Reverse the practice of giving the benefit of the doubt to foreign companies
versus U.S. companies in AD/CVD proceedings.
Establish a policy for addressing companies that invest heavily in the U.S.
and thus have large import volumes, exposing them to AD/CVD petitions.
Establish an effective, fair, and objective process for self-initiation of AD/
CVD proceedings when industry lacks the resources or ability to act.
Addressing Chinal

Revive the China-specific non-market economy unit.

lProvide transparency in the surrogate country list development process.

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2025 Presidential Transition ProjectlDevelop a new methodology to determine normal values in Chinese antidumping cases because—given China’s size, economic might, and stateintervention in the economy—there is no comparable surrogate country to
use as a proxy for production costs.

In addition to these changes, continued support for steel and aluminum market
analysis and import monitoring remains crucial to the U.S. defense industrial baseand the health of global manufacturing. Without these functions, it is difficult toaddress massive subsidization, overcapacity, and dumping by China.
Industry and Analysis. Industry and Analysis (I&A) consists of a team of economists and industry experts that provides important analysis to partners acrossthe government, including the White House and USTR, as well as the public.
As the Department of Commerce’s Committee on Foreign Investments in the
United States (CFIUS) lead, I&A performs crucial work to ensure that the proper
economic impact/supply chain analysis is brought to national security risk assessments. This analysis is needed for CFIUS to be an effective tool in preventing China
and other adversaries from exploiting the U.S.’s open investment climate.
I&A also provides impact assessments and economic modeling for policy
options under Administration consideration; plays a critical role in identifying
trade barriers and providing industry-specific expertise for USTR during free trade
agreement (FTA) negotiations; and does indispensable work ensuring cross-border data flows, particularly with Europe, remain open and relatively unrestricted.
However, outside of these functions, implementation of I&A’s mission as anintellectual engine for U.S. trade and investment policy can often lack energy andfocus. For instance, the Top Market Reports that represent a large volume of I&A
work do not serve a specific strategic function and could be better replaced byindustry competitiveness assessments in critical sectors of the economy.
Strong and capable leadership is needed in I&A to ensure Administration priorities permeate the organization and that staff support Administration priorities.
I&A produces a mandatory report to Congress regarding the Miscellaneous Tariff
Bill, which focuses solely on U.S. capacity in the goods being considered for tariff
exclusions and does not include highly relevant information on capacity among
FTA partners and close allies. The resulting final report has thus been used to lobby
for tariff reductions on thousands of imports from China without concern for any
other factors. This lack of priority given to FTA partners is troubling.
Going forward, I&A should be permanently restructured to perform supply-chain
analysis on an ongoing basis for the U.S. government, identifying potential vulnerabilities like those exposed by the pandemic and resulting shortages in everythingfrom semiconductors to baby formula. Furthermore, permanent standing teams
should be established and staffed by properly aligned political appointees and trusted
career staff to analyze and spur action on the following priority policy issues:— 669 —

Mandate for Leadership: The Conservative PromiselStrategic decoupling from China;lDefense industrial base strength;lCritical supply chains (e.g., pharmaceuticals, medical devices, food); andlEmerging technologies (e.g., rare earth minerals, semiconductors, batteries,
artificial intelligence, quantum computing).

Global Markets and the U.S. and Foreign Commercial Service. For morethan a decade, strategic planning at Global Markets (GM) and the U.S. and Foreign Commercial Service (CS) has been consistently undermined by increased
costs associated with overseas staff and flat or reduced budgets. The Trump
Administration introduced crucial, long-overdue business practices such as theimplementation of software to manage and track workflow, but a further strategic
overhaul of resource allocation is needed to set GM and the CS on a firm footing.
Currently, CS manages staff spread over 106 domestic offices in 77 countries
around the world. Abroad, several “partner posts” utilize interagency staff andregionally located CS officials to offer services without a permanent physicalin-country CS presence. Given the rapidly rising costs imposed by the State Department on CS posts overseas, a drastic expansion of this model is likely needed.
CS resources should be distributed according to the following set of priorities:lValue in countering the malign influence of adversaries, particularly China;lValue in fostering U.S. innovation;lValue in maintaining access to critical supply chains and technology;llDifficulty for U.S. companies in gaining market access without CS
involvement; andPotential untapped export market size and likelihood of expansion.

Ultimately, difficult decisions must be made about the value of CS posts andwhether individual posts can be justified given current resources and the above
criteria. If the State Department deems the diplomatic value of a permanent
in-country CS post to be vital to the national interest, then State should bear moreof the cost of maintaining that post.
Global Markets should also consolidate and elevate the Advocacy Center andSelectUSA as relatively low-cost tools to drive large-scale export transactions— 670 —

2025 Presidential Transition Project

and foreign direct investment (FDI). SelectUSA is a low-cost and effective tool in
attracting FDI to the U.S. and to re-shore manufacturing and research and development. In a world in which corruption is rampant, these are among the mosteffective tools in leveling the playing field for U.S. communities and companies
seeking to engage with governments and potential overseas investors.
Given the value placed on senior-level engagement by many governments andcompanies, this consolidated Office of Trade and Investment Advocacy should beheaded by a Deputy Assistant Secretary. The new office should also seek congressional authorization to utilize its FDI-promotion tools to encourage reshoring by
U.S. businesses.
BUREAU OF INDUSTRY AND SECURITY

During the past two decades, technology transfer from America and its allies hashelped accelerate adversaries’ technological and weapons capabilities. This technology transfer on a massive scale has occurred because of adversaries’ exploitationof the U.S.’s open economy and education system through both commercial transactions and university and government research programs. Examples include thePeople’s Republic of China’s dramatic leaps forward in semiconductor design andfabrication, battery energy storage, nuclear weapons capabilities, artificial intelligence, space and aerospace engineering, and hypersonic weapons deployment.
At the same time, the U.S. has systematically failed to protect critical assets.
Rather than promulgate policies to better prevent technology transfer, the U.S.
government has either ignored the problem or, worse, from 2008 through 2016
instituted a government-wide “Export Control Reform” process to loosen the
Export Administration Regulations (EAR) governing exports of dual-use items
to facilitate technology transfer to adversaries, either directly or indirectly throughthird-country transfers.
Those reforms still present in the Department of Commerce’s EAR must be
reversed. The United States needs stronger rules to protect technology transfer
to adversaries while promoting technology integration and interoperability withallies. Further, U.S. export control regulations should be utilized to prevent theftof personally identifiable information and to encourage U.S. companies to shift
production out of China and further diversify their supply chains to better advance
U.S. national security interests.
For all the below recommendations, BIS needs to move unilaterally while itworks with allies to implement complementary export control policies. Waiting
to act until allies are ready to move in lockstep is not an option while America’s
national security is at risk.
Emerging and Foundational Technologies. The Export Control Reform Act
of 2018 (ECRA) gave BIS permanent statutory authority to regulate exports ofdual-use items (goods, software, and technology). ECRA also mandated that BIS— 671 —

Mandate for Leadership: The Conservative Promise

regulate exports of emerging and foundational technologies. Although the scopeof such technologies is vast, to date BIS has only controlled just over 40 of thesetechnologies. This does not meet the clear statutory intent of Congress that ECRA
be leveraged to ensure that the United States maintains a technological advantage
in technologies bearing upon national security interests.
Currently, BIS self-identifies technologies that merit control under the EAR withminimal input from other federal agencies. This mechanism should be improved.
BIS should create an open, transparent rulemaking process by which any industry
participant, private entity, or branch of the government may, at any time, submit
nominations for emerging/foundational technologies for control. Then, on a quarterly
basis, BIS should make public such recommendations (while holding the identityof the submitter confidential) for public input, followed by an explanation about its
ultimate decision to control or not control the items, its reasons, the level of controls
applied (stringent or permissive), and the relevant Export Control Classification
Number (ECCN) under the Commerce Control List. Commerce should also institute a
mechanism whereby its decisions can be challenged, including on a confidential basis.
Licensing Procedures: Adjudication and Transparency. Currently, if the
Departments of Defense, State, Commerce, and Energy disagree on an export
license decision, the disagreement may be escalated to the Operating Committee—and subsequently to the Advisory Committee on Export Policy led by BIS’s
Assistant Secretary for Export Administration. The Assistant Secretary does notneed to lead the dispute resolution, and this process should be revised by giving leadauthority to BIS’s Under Secretary, who is better able to account for diverging views.
Moreover, BIS’s authority to overrule other agency votes should be changed.
Each agency should have one equal vote and, if a licensing dispute remains unresolved, the final decision should be elevated to the National Security Advisor andthe Secretaries of Defense, State, Commerce, and Energy.
Additionally, to improve congressional oversight of BIS’s license adjudication
process, BIS should provide specific congressional committees with data from theAutomated Export System on a quarterly basis. Electronic files should contain
U.S. exporter by name; product description (e.g., harmonized system code and
ECCN/U. S. Munitions List designation); end user and destination country; andwhen a license was required, whether the license was granted or denied. BIS currently denies just 1.2 percent of export licenses. These data reporting requirements
can help Congress better determine whether BIS is adequately protecting national
security through appropriate use of export controls or whether additional direction
from Congress is required.
Improve End-Use Checks. The integrity of the export control system may bevalidated only through adequate end-use checks. BIS must deny export licenses
to countries that do not permit adequate end-use checks (e.g., China/Russia) by
U.S. authorities. BIS should also strengthen the forensic audit capabilities of its— 672 —

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Export Enforcement officers through improved and frequent training so they areable to detect export-control violations.
EAR Revisions. The U.S. Government needs a new export control modernization effort to tighten the EAR policies governing licenses to countries of concern,
including China and Russia (specifically, revise and/or reverse the 2008 through2016 policies).
When authoritarian governments explain what they plan to do, believe them unlesshard evidence demonstrates otherwise. Case in point: China’s and Russia’s statedcivil–military fusion policies demand central government command-and-control
style systems in which every private entity serves the interests of the state and isforced to provide technology, services, capacity, and data to the central government and the military. Through this structure, commercial activities are routinely
weaponized by authoritarian regimes that repeatedly identify the U.S. as an enemy.
Accordingly, U.S. export control policies must be updated to reflect these realities
and the associated threats to national security.
Key priorities for EAR modernization for countries of concern should be:llEliminating the “specially designed” licensing loophole;
Redesignating China and Russia to more highly prohibitive export licensing
groups (country groups D or E);lEliminating license exceptions;lBroadening foreign direct product rules;

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Reducing the de minimis threshold from 25 percent to 10 percent—or 0
percent for critical technologies;
Tightening the deemed export rules to prevent technology transfer toforeign nationals from countries of concern;
Tightening the definition of “fundamental research” to address exploitationof the open U.S. university system by authoritarian governments throughfunding, students and researchers, and recruitment;
Eliminating license exceptions for sharing technology with controlled
entities/countries through standards-setting “activities” and bodies; andImproving regulations regarding published information fortechnology transfers.

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The next few years will prove or disprove the assertion that the U.S. stands on
the precipice of a Cold War with China. Many believe that a Cold War has alreadybegun; if so, then strategic decoupling from China is necessary and, fundamentally,
any exports of goods, software, and technology to countries of concern, whether
directly or indirectly, should be prohibited or controlled in the absence of goodcause (e.g., humanitarian and medical aid, food aid).
Entity List and Sanctions. There are currently just over 500 Chinese and over
500 Russian companies on the Department of Commerce’s Entity List, which regulates exports of controlled and uncontrolled items to designated entities. Given
China’s Civil–Military Fusion Strategy and Russia’s massive war efforts facilitated by a broad range of the Russian economy, BIS must add more entities to the
Entity List and apply a license review “policy of denial” that prohibits exports tothese entities.
Entity List parties that violate export controls should be placed on the BIS
Denied Persons List (and thereby lose export privileges) and, if the violations are
significant enough, they should also be sanctioned by the Department of Treasury.
Data Transfer and Apps Used for Surveillance. Department of Commerce
leadership should work across government agencies to address privacy and data
concerns arising out of “big tech” from national security and export control perspectives. In particular, they should draft and implement an executive order (EO)
based on the International Emergency Economic Powers Act, which expands export
control authority beyond ECRA’s scope (goods, software, technology) to regulate andrestrict exports of U.S. persons’ data to countries of concern. The EO should establish
a framework for the types of personal data subject to export controls and licensing
policy by country, and the BIS should implement the EO through regulations.
BIS should additionally designate app providers (such as WeChat and
ByteDance/TikTok) known for undermining U.S. national security through datacollection, surveillance, and influence operations, to the Entity List. This listing
would prevent app users from program updates, which would quickly make theseapps non-operational in the United States.
NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION

Break Up NOAA. The single biggest Department of Commerce agency outsideof decennial census years is the National Oceanic and Atmospheric Administration,
which houses the National Weather Service, National Marine Fisheries Service,and other components. NOAA garners $6.5 billion of the department’s $12 billion
annual operational budget and accounts for more than half of the department’s
personnel in non-decadal Census years (2021 figures).
NOAA consists of six main offices:l

The National Weather Service (NWS);— 674 —

2025 Presidential Transition Projectl

The National Ocean Service (NOS);lThe Oceanic and Atmospheric Research (OAR);l

The National Environmental Satellite, Data and Information Service (NESDIS);lThe National Marine Fisheries Service (NMFS); andl

The Office of Marine and Aviation Operations and NOAA Corps.

Together, these form a colossal operation that has become one of the main
drivers of the climate change alarm industry and, as such, is harmful to future
U.S. prosperity. This industry’s mission emphasis on prediction and management
seems designed around the fatal conceit of planning for the unplannable. That is
not to say NOAA is useless, but its current organization corrupts its useful functions. It should be broken up and downsized.
NOAA today boasts that it is a provider of environmental information services,a provider of environmental stewardship services, and a leader in applied scientificresearch. Each of these functions could be provided commercially, likely at lower
cost and higher quality.
Focus the NWS on Commercial Operations. Each day, Americans rely on
weather forecasts and warnings provided by local radio stations and colleges thatare produced not by the NWS, but by private companies such as AccuWeather.
Studies have found that the forecasts and warnings provided by the private companies are more reliable than those provided by the NWS.2
The NWS provides data the private companies use and should focus on its
data-gathering services. Because private companies rely on these data, the NWS
should fully commercialize its forecasting operations.
NOAA does not currently utilize commercial partnerships as some otheragencies do. Commercialization of weather technologies should be prioritized
to ensure that taxpayer dollars are invested in the most cost-efficient technologies for high quality research and weather data. Investing in different sizes ofcommercial partners will increase competition while ensuring that the government solutions provided by each contract is personalized to the needs of NOAA’s
weather programs.
The NWS should be a candidate to become a Performance-Based Organization
to better enforce organizational focus on core functions such as efficient deliveryof accurate, timely, and unbiased data to the public and to the private sector.3
Review the Work of the National Hurricane Center and the National
Environmental Satellite Service. The National Hurricane Center and National
Environmental Satellite Service data centers provide important public safety and— 675 —

Mandate for Leadership: The Conservative Promisebusiness functions as well as academic functions, and are used by forecasting agencies and scientists internationally. Data continuity is an important issue in climate
science. Data collected by the department should be presented neutrally, without
adjustments intended to support any one side in the climate debate.
Transfer NOS Survey Functions to the U.S. Coast Guard and the U.S. Geological Survey. Survey operations have historically accounted for almost half the
NOS budget. These functions could be transferred to the U.S. Coast Guard and U.S.
Geological Survey to increase efficiency. NOS’ expansion of the National Marine
Sanctuaries System should also be reviewed, as discussed below.
Streamline NMFS. Overlap exists between the National Marine FisheriesService and the U.S. Fish and Wildlife Service. Overly simplified, the NMFS handles
saltwater species while the Fish and Wildlife Service focuses on fresh water. The
goals of these two agencies should be streamlined.
Harmonize the Magnuson–Stevens Act with the National Marine Sanctuaries
Act. Under the auspices of NOS, marine sanctuaries (including no-fishing zones)
are being established country-wide, often conflicting with the goals of the Magnuson–Stevens Act fisheries management authorities of NOAA Fisheries, regional
fishery management councils, and relevant states.
Withdraw the 30x30 Executive Order and Associated America the Beautiful Initiative. The 30x30 Executive Order and the American the Beautiful Initiative arebeing used to advance an agenda to close vast areas of the ocean to commercial
activities, including fishing, while rapidly advancing offshore wind energy development to the detriment of fisheries and other existing ocean-based industries.
Modify Regulations Implementing the Marine Mammal Protection Act and theEndangered Species Act. These acts are currently being abused at a cost to fisheries
and Native American subsistence activities around the U.S.
Allow a NEPA Exemption for Fisheries Actions. All the requirements for robust
analysis of the biological, economic, and social impacts of proposed regulatory
action in fisheries are contained with the Magnuson–Stevens Act, the guiding Act
for fisheries. NEPA overlays these requirements with onerous, redundant, andtime-consuming process requirements, which routinely cause unnecessary delaysin the promulgation of timely fisheries management actions. The Departmentof Commerce and the Council on Environmental Quality should collaborate to
reduce this redundancy.
Downsize the Office of Oceanic and Atmospheric Research. OAR provides
theoretical science, as opposed to the applied science of the National Hurricane
Center. OAR is, however, the source of much of NOAA’s climate alarmism. The
preponderance of its climate-change research should be disbanded. OAR is a large
network of research laboratories, an undersea research center, and several joint
research institutes with universities. These operations should be reviewed withan aim of consolidation and reduction of bloat.

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Break Up the Office of Marine and Aviation Operations and Reassign
Its Assets to Other Agencies During This Process. The Office of Marine andAviation Operations, which provides the ships and planes used by NOAA agencies,
should be broken up and its assets reassigned to the General Services Administration or to other agencies.
Use Small Innovation Prizes and Competitions to Encourage High-Quality Research. Lowering the barriers of entry for startups and small businesses will
also provide greater innovation without excessive increases in spending. Reaching
beyond traditional partnerships for innovative engagement tools that encourage
entrepreneurial innovation will allow NOAA’s research programs to adapt more
quickly to the world’s changing needs. Multiple competitions should take place incities to attract a variety of innovators and investors to propel innovation forward
in a way that benefits the needs of NOAA.
Ensure Appointees Agree with Administration Aims. Scientific agencies
like NOAA are vulnerable to obstructionism of an Administration’s aims if political
appointees are not wholly in sync with Administration policy. Particular attention
must be paid to appointments in this area.
Elevate the Office of Space Commerce. The Office of Space Commerce isthe executive branch advocate on behalf of the U.S. commercial space industry.
This office should be the vehicle for a new Administration to set a robust andunified whole-of-government commercial space policy that cements U.S. leadership in one of the most crucial industries of the future. The Office’s current
mission has been lost owing to its position within NESDIS, which sees no rolefor itself in advancing the industry and the space economy, including ensuring
global competitiveness. OSC is, by law, the Department of Commerce’s lead on
space policy and must therefore link directly to all the bureaus and other organizations within the department. The Office needs to be returned to OS, within
which it existed for the first two decades of its existence. From OS, the Office
could serve as a coordinating entity for the whole-of-government commercial
space policy desperately needed to secure America’s place as the global leader
in commercial space operations.
There presently exists no unified U.S. government policy on commercial space
operations, with the Federal Communications Commission largely responsible
for establishing space policy by default through its regulation of radio spectrum
licenses. Now that routine space operations are commercially viable, it is criticalthat a new Administration establish reasonable government policies that ensure
the U.S. will continue to be the flag of choice for commercial space activities. The
President should, by executive order, direct the Office of Space Commerce, working
with the National Space Council, to establish a whole-of-government policy forlicensing and oversight of commercial space operations.

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Mandate for Leadership: The Conservative Promise

BUREAU OF ECONOMIC ANALYSIS AND THE OFFICE OF
THE UNDERSECRETARY FOR ECONOMIC AFFAIRSThe Office of the Under Secretary for Economic Affairs is charged with conducting
economic analysis, promoting business and commerce, guiding data-driven decision-making and evidence-building activities, and increasing access to government
data while ensuring privacy and confidentiality. The office coordinates economic
analysis needs across the Department of Commerce, leads the department’s initiatives and programs related to data, data policy, and data management, and provides
policy direction and oversight for the Bureau of Economic Analysis (BEA) and the
Census Bureau. In addition to the Under Secretary for Economic Affairs, key staff
roles in the office include the Chief Economist and the Chief Data Officer.
The office could be an effective tool for a new Administration if it focuses its
efforts on supporting the Department’s mission to ensure the conditions for economic growth and opportunity—conducting economic analysis and producing
data for key departmental policy initiatives, as well as working across agencies tosupport broader Administration goals. As the office charged with providing policy
direction and oversight for BEA and the Census Bureau, new leadership shouldtake an early and active role within both bureaus.
BEA is a federal statistical agency under the Office of the Undersecretary for
Economic Affairs. BEA’s mission is to promote a better understanding of the U.S.
economy by providing timely, relevant, and accurate economic accounts data in
an objective manner. BEA is responsible for producing economic indicators suchas the U.S. gross domestic product (GDP), state and local GDP estimates, foreign
trade and investment statistics, industry data, and consumer spending numbers.
The data produced by BEA are used by government and business decision-makers to understand the state of the nation’s economy. A new Administration should
ensure that BEA conducts its statistical analysis in a consistent and objective
manner, with the Undersecretary for Economic Affairs taking a strong interest in
BEA’s operations and data products.
A new Administration should also study the feasibility of merging all statisticalagencies (Census Bureau, Bureau of Economic Analysis, and the Department ofLabor’s Bureau of Labor Statistics, etc.) under one bureau to increase efficiency
and better coordinate cross-departmental issues.
CENSUS BUREAUThe Census Bureau’s core mission is to execute the executive branch’s constitutional mandate to conduct a census every 10 years, but its activities have steadilygrown and shifted to include the economic census, American Communities Survey,
and further functions outside of its core mission.
An incoming conservative Administration should focus on three areas: day-today management, the decennial census, and other programs. Each of these will

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2025 Presidential Transition Projectneed to be addressed at every stage of the transition and policy implementation
process and will require that both committed political appointees and like-minded
career employees are in immediately put in place to execute a conservative agenda.
These will need to be placed both in the Census Bureau and in key department-level
managerial positions, such as those in the CFO/ASA’s office.
Day-to-Day Management
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Command and control. Strong political leadership is needed to increase
efficiency and align the Census Bureau’s mission with conservative
principles. Personnel is key to ensuring that a new Administration can guidepreparations for the 2030 census and oversee the continued operationof the Bureau’s many surveys. To move bureaucracy on key priorities,
appointed staff should be in place at the Bureau as early as feasible after
a new President takes office. This will require the Office of Personnel
Management to allocate additional political appointee positions to the
Census Bureau.
Financial management, information technology, and humanresources. The new Administration must immediately conduct a review
to identify ways to better control costs and reverse recent failures ofinvestments intended to upgrade the financial management, information
technology, and human resources systems of the Census Bureau.
Leveraging technology. The Census Bureau should focus on continuing
to incorporate technology into its day-to-day operations, as well as theexecution of its surveys, to reduce costs and provide more accurate andtimely data to the American public.
Prioritizing cybersecurity and protection of confidential information.
Because much of the data collected by the Census Bureau include personaland confidential information, a focus on protecting data and implementing
proper data protocols is necessary to ensure compliance with the legal
requirements of Title 13.

Decennial CensuslFully vet existing planning and budgeting from Day One. Planningand budgets for the 2030 decennial census will be finalized in fall 2025,
including many decisions on how to use, develop, and administer the count.
An incoming Administration should immediately audit the lifecycle costestimate (LCCE) for the 2030 census and conduct a new LCCE if necessary.
This will ensure that budget requests are accurate and up-to-date and— 679 —

Mandate for Leadership: The Conservative Promise

allow the new Administration to understand the decennial process ingreater detail.
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Remove duplicative functions to increase efficiency. As part of theabove review, ensure the decennial operational plan eliminates current
duplication among ongoing census operations (annual surveys, etc.) anddecennial operations in information technology, human resources, etc. Thisoverlap has been estimated to waste billions of dollars in the years leading
up to each decennial census.
Review the partnership program. This program, designed to promoteresponsiveness to the census by employing trusted voices in various
communities, deserves careful scrutiny. A new Administration should workto actively engage with conservative groups and voices to promote responseto the decennial census. Promoting response to the decennial census will
ensure that the most accurate counts are conducted, leading to a moreaccurate apportionment of congressional representation and allocationof federal funds. In 2020, lack of conservative participation was one factor
in an undercount in some areas of the country, affecting representation ofcertain states.
Add a citizenship question. Despite finding that the Trump
Administration’s addition of the citizenship question to the 2020 decennial
census violated the Administrative Procedures Act, the Supreme Court
held that the Secretary of Commerce does have broad authority to add acitizenship question to the decennial census. Any successful conservative
Administration must include a citizenship question in the census. Asking a
citizenship question is considered best practice even by the United Nations.
By law, the Census Bureau must deliver the decennial census subjects/
topics to Congress three years before Census Day (in this case, by April 1,2027). Questions must be presented to Congress two years before Census
Day (April 1, 2028).
Review forthcoming changes to race and ethnicity questions. The
current Administration has announced its intent to change data collection
methods regarding race and ethnicity by combining the two questions
on the decennial questionnaire and increasing the number of available
options. A new conservative Administration should take control of thisprocess and thoroughly review any changes. There are concerns amongconservatives that the data under Biden Administration proposals could be
skewed to bolster progressive political agendas. Government data should be— 680 —

2025 Presidential Transition Project

unbiased and trusted—and an incoming conservative Administration should
ensure that is the case. This work must be coordinated with the Office ofManagement and Budget, which governs federal data collection standards
via its statistical directives.
lReevaluate all decennial census questions. Determine how best to
optimize use of the decennial census to determine whether current or
additional questions provide added value in coordination with otherdepartments that utilize the information. Overly intrusive questions or lesscrucial data should either be moved to another survey or removed from
Census programs entirely.

Other Census Programslll

The American Communities Survey. After the decennial census, the next
biggest statistical survey conducted by the Census Bureau is the American
Communities Survey (ACS). As with the decennial census, each question
should be carefully reviewed to ensure the data are useful and that thequestions are not overly intrusive. There should be collaboration with otherdepartments that use the information collected on these surveys (e.g., theDepartments of Labor, Health and Human Services, Homeland Security,etc.) to determine how to optimize the use and collection of particular
information.

The Economic Census. This is the official five-year measurement ofAmerican business and the economy. The first Economic Census in a new
Administration will take place in 2027 and have a major effect on federal
spending and policy determinations. This survey collects business data thatare a key input for ongoing government statistics such as BEA’s GDP reports.
As with the decennial census and ACS, it should be carefully examined
to ensure the Economic Census is not overly intrusive. Additionally, theCensus Bureau should work with other federal agencies to determine
when data collection can be supplemented by industry and other federal
business indicators.
Pulse surveys. During the government’s early response to the COVID-19
pandemic, the Census Bureau began experimental pulse surveys. These
were designed to obtain data closer to real-time than typical census surveys.
These data could be a useful tool to the Department of Commerce andother partners across government and provide a model for improving datacollection techniques or reducing the overall footprint of the Census Bureau.

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Mandate for Leadership: The Conservative PromisellSupplemental Poverty Measure. The Census Bureau should review the
Supplemental Poverty Measure (SPM) to consider whether it provides anaccurate measure for use by the Council of Economic Advisers and others.
The findings from this review should also be taken into consideration whenconstructing the Current Survey and other supplemental surveys, so that
the SPM can be better tracked on a trend basis and support better policy
decisions over time. This information would be particularly helpful indetermining how to combat homelessness in conjunction with Department
of Health and Human Services programs.
Abolish the National Advisory Committee and reevaluate all othercommittees. The Census Bureau National Advisory Committee on Racial,
Ethnic, and Other Populations (NAC) was established by the Obama
Administration in 2012 and rechartered by the Biden Administration in
2022. The committee is a hotbed for left-wing activists intent upon injecting
racial and social-justice theory into the governing philosophy of the Census
Bureau. The NAC should immediately be abolished by the incoming
Administration. The NAC charter gives the Secretary of Commerce theauthority to terminate the committee. Since the Secretary of Commerceestablished the NAC in 2012 under the FACA, the Secretary is authorized
to terminate the NAC. The new Administration should also reevaluate
and potentially abolish all non-statutory standing committees within the
Census Bureau, including the Census Scientific Advisory Committee.

ECONOMIC DEVELOPMENT ADMINISTRATIONThe Economic Development Administration (EDA) is charged with investing in
local communities to encourage and enable growth and innovation in the private
sector, with particular focus on distressed or underserved areas. Over time, it has
also served as a distribution mechanism for emergency relief funds (e.g., Hurricane
Maria and COVID-19).
In the Trump Administration, the EDA served an important role for the CARES
Act. It successfully disbursed approximately $1.5 billion in funding beginning inMay 2020 and throughout the COVID-19 pandemic. However, this task revealed
EDA’s shortcomings. On a capability level, EDA lacked the technical and financial
systems and skills to disburse these funds in a compliant manner and required
external contracts for advisory support to hire the personnel needed to accomplish its goals.
Historically, EDA was a small bureau with an annual budget for $350 million
in Public Works grants annually. EDA’s decision-making is decentralized to its
six regional offices, which delayed the release of CARES Act funding by months.
But more broadly, EDA is an impediment to coordinated campaigns that advance— 682 —

2025 Presidential Transition Project

Administration priorities. Rather than implementing the new Department Organization Orders required to put conservative governance in place, it would be more
efficient to abolish EDA and reallocate its funding to other overlapping federal
grant programs.
If that proves unachievable, as has historically been the case due to politicalconsiderations in Congress, EDA would benefit from:
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Consolidation of decision-making to the Assistant Secretary’s office tobetter align funding with conservative political purposes. For example,
funding initiatives in rural communities destroyed by the Biden
Administration’s attack on domestic energy production would be wellwithin the scope of EDA’s mission.
Leveraging of the direct hire authorities established in the Trump
Administration for special initiatives or disaster/recovery funding. Leaving
these programs to entrenched career employees with their ties to theregional offices will do little to advance the conservative agenda.
Continuation of disaster funding with better coordinated capabilities anddecision-making in accordance with the points above (e.g., maintaining
contract vehicles for staff augmentation as needed).
Building on the initial success of Opportunity Zones, which incentivizedover $75 billion in private sector investment in distressed communities by
the end of 2020 with little up-front cost to the taxpayer.

MINORITY BUSINESS DEVELOPMENT AGENCY

The Minority Business Development Agency (MBDA) is the only federal agency
solely dedicated to the growth and competitiveness of minority-owned businesses.
The Minority Business Development Act of 2021 was signed into law as part of the
Bipartisan Infrastructure Investment and Jobs Act. This legislation made MBDA apermanent federal agency, created a Senate-confirmed Under Secretary position,and expanded programs and outreach. The Act:ll

Authorizes the creation of regional offices and rural business centers,
increasing the number and scope of existing grant programs supporting
MBDA business centers;
Mandates grants to minority serving institutions to cultivate future
generations of minority entrepreneurs; and— 683 —

Mandate for Leadership: The Conservative PromiselEstablishes a Minority Business Advisory Council to advise the Under
Secretary on supporting minority-owned businesses.

MBDA was established in 1969 by President Richard Nixon under Executive
Order 114584 as the Office of Minority Business Enterprise and the Advisory
Council for Minority Business Enterprise. Its purpose was to strengthen andpreserve minority business enterprises (MBEs) and to coordinate among
MBEs and other groups such as state and local governments and trade associations. For over 50 years, the MBDA operated under executive order without
clear congressional authorization, but was regularly recognized and promoted
by every subsequent president, including Presidents Ronald Reagan and
Donald Trump.5
MBDA has the appearance, on its face, of perpetuating racial bias by focusing
on minority advancement rather than economic need or other criteria. This is
why the Trump Administration proposed eliminating funding for the agency in2017. Many conservatives ask why the government is funding this activity, which
often amounts to business and management consulting services offered by private
sector entities. Eventually, the Trump Administration changed course and proposed that MBDA continue to exist as a permanently authorized entity focusedon policy rather than offering services. Despite this change, many conservatives
understandably see MBDA as problematic on a philosophical level.
Nonetheless, Congress has spoken recently on this issue and is unlikely tochange its position in the near term. In 2017, MBEs represented one-third of all
U.S.-owned businesses, with almost 9 million employees, generating $1.7 trillion
for the U.S. economy.6 As such, a conservative Administration is best served byapproaching MBDA as a tool to be leveraged in the fight to deliver economic opportunity to all Americans and to produce an economy centered on equal opportunity,
free markets, innovation, and growth.
Conservative leadership at MBDA should focus the organization on:lll

Conducting policy analysis on the benefit of free markets, the evilsof socialism and Communism, and the destructive effect of taxes andregulations on minority businesses;
Ensuring MBDA business centers operate efficiently with strict oversight offunding, clear metrics for success, and consequences for poor performance;
Creating policy-level operational priorities geared toward private sector
action over government action with public–private partnerships serving as anecessary middle ground;— 684 —

2025 Presidential Transition Project

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Establishing MBDA as a data and research clearinghouse for minority
business enterprises and policymakers;
Coordinating amongst Cabinet agencies, state and local government, andtrade associations to best leverage resources and encourage growth andinnovation; andEvaluating the harmful effects of unfair trade practices on minority-owned
businesses and their employees.

U.S. PATENT AND TRADEMARK OFFICEThe U.S. Patent and Trademark Office carries out a core constitutional mandate from Section 8, Article 1: “The Congress shall have Power...[t]o promote theProgress of Science and useful Arts, by securing for limited Times to Authors
and Inventors the exclusive Right to their respective Writings and Discoveries.” Strong intellectual property (IP) protections form the bedrock of Americanbusiness and are a key factor in making the U.S. economy the most innovativein the world. As such, a conservative Administration must constantly work tostrengthen IP rights and combat the incorrect view that strong IP rights somehow limit innovation.
Political leadership in a new conservative Administration should:
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Support like-minded countries as candidates for leadership in the WorldIntellectual Property Organization and build strong relationships withinternational partners to strengthen intellectual property rights.
Re-examine patent eligibility requirements in Section 101 of the Patent Act7
and support internal and/or legislative reforms to enable U.S. leadershipin critical and emerging technologies such as quantum computing, 5G, andartificial intelligence.
Take a balanced approach to the Patent Trial and Appeal Board andprioritize rapid and transparent processing of applications and appeals.
Work with Administration partners and Congress to find and punish
trademark infringers and counterfeiters.
Oppose efforts to provide intellectual property waivers for cutting-edge
technologies, including for COVID-19 vaccines and therapeutics, throughthe World Trade Organization’s Trade-Related Aspects of Intellectual
Property Rights agreement or any other mechanism.

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Mandate for Leadership: The Conservative Promise

NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGYThe National Institute of Standards and Technology is charged with promoting
U.S. innovation and competitiveness by “advancing measurement science, standards,
and technology.”8 NIST carries out cutting edge research, helps industry establish
standards and best practices, and is the nation’s foremost authority on measurements.
NIST’s atomic clock, for instance, maintains the official time of the United States.
An incoming Administration should evaluate the federal government’s civilian
research footprint and consolidate those functions while ensuring that any research
conducted with taxpayer dollars serves the national interest in a concrete way inline with conservative principles. Beyond this, an incoming Administration should:
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Privatize the Hollings Manufacturing Extension Partnership. The
Hollings Manufacturing Extension Partnership (MEP) establishes andmanages a network of centers focused on advising small- and medium-sized
manufacturers in order to improve processes and thereby strengthen the
U.S. industrial base. When Congress created the program, MEP centers wereintended to transition to self-sustaining private institutions after using
government funds to begin operations, but the prohibition on long-term
funding was abolished in 1998. MEP’s business advisory services would be
more properly carried out by the private sector. The next Administration
should propose legislation to zero out this $150 million program and fully
privatize existing MEP centers.
Transfer the Baldridge Performance Excellence Program. This
program’s “process” assists companies in improving management andoperations, a function more properly and effectively carried out by theprivate sector. This program operates at a cost to taxpayers, despite
thousands of dollars in fees charged to each participating company or entity
and long-term plans to make the program self-sufficient. Maintenance andoperation of the program should be entirely handed over to the Baldridge
Award Foundation to be run by non-government staff via fees.
Increase value to taxpayers. NIST should reinvigorate the Technology
Transfer and ROI (return on investment) initiatives begun under the Trump
Administration. These initiatives help speed the process of commercializing
science funded by the federal government.
Reestablish U.S. dominance in international standards. NIST should
explore ways to incentivize broader U.S. participation in standards-setting
bodies and the exclusion of participants from adversaries like China. Standards
are set to facilitate trade in countries that utilize those standards: Countries— 686 —

2025 Presidential Transition Projectthat do not allow open access to their markets should not be setting thestandards for markets that do allow open access. The incoming Administration
should consider increased government-sponsored participation by privatecompanies and government employees with relevant expertise.
NATIONAL TELECOMMUNICATIONS AND INFORMATION SERVICE

The independent National Telecommunications and Information Service(NTIS) is charged with ensuring that federally funded research and data areaccessible to the public. NTIS operates through user fees but is largely obsolete
due to modern usage of the internet by federal agencies and researchers. NTIS’s
functions should be moved to NIST and consolidated with the Tech Transfer andROI initiatives.
NATIONAL TELECOMMUNICATIONS AND
INFORMATION ADMINISTRATIONThe National Telecommunications and Information Agency (NTIA) is the executive branch’s statutory lead on telecommunications and information policy. It
focuses on broadband access, spectrum utilization, and other issues that are crucial
to the high-tech economy. For decades, NTIA has suffered from organizationalmalaise and will require strong and energetic leadership by political appointees
to implement conservative policies. The next Administration will face the primarychallenge of rapidly deploying 5G without compromising other priorities. Further
recommendations include:
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Support free speech and hold big tech accountable. Immediately
conduct a thorough review of federal policy regarding free speech online
and provide policy solutions to address big tech’s censorship of speech.
Utilize new tools to eliminate threats to national security. Fully
implement the Trump Administration’s Information and Communications
Technology and Services (ICTS) Executive Order authorities in a waythat ensures long-term success and the legal viability of this new national
security tool.9
Expand utilization of federal spectrum. Begin short term, temporary
leasing of government allocated spectrum to ensure optimum utilization
while preserving federal agency use rights.
Support the commercial space industry. Advocate for licensing decisions
at the Federal Communications Commission that continue to enable U.S.
dominance in the commercial space industry.

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Mandate for Leadership: The Conservative Promise

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Defend U.S. interests in international bodies. Strong representation at
the International Telecommunication Union should protect the interestsof both private and government users of spectrum. The U.S. has differingneeds from many other countries, for instance, because of U.S. government
satellites and commercial space industry. NTIA should work with the U.S.
delegation to ensure maximum adoption of the U.S. position.
Set fresh priorities in broadband grant programs. Reevaluate
broadband grant programs and, when possible, establish Administration
priorities in how each grant is structured. First and foremost, widespread
deployment of infrastructure is needed for 5G adoption in rural and exurban
areas, which will be a key factor in future economic competitiveness forthese under-served communities.
Review FirstNet. Evaluate the performance and long-term value
proposition of FirstNet in view of modern technologies that will render
it obsolete.

CONCLUSION

The above policies, strategies, and tactics will set a new Administration on
firm footing that allows the Department of Commerce to assist the President in
implementing a bold agenda that delivers economic prosperity and strong national
security to the American people. While many of the department’s functions falloutside the remit of the federal government, its unique authorities in diverse areas
provide critical tools that can and should be brought to bear in implementing a
conservative governing philosophy that keeps Americans safe and provides opportunity for all.

AUTHOR’S NOTE: This chapter includes invaluable input from over a dozen alumni of the Department ofCommerce and numerous other members of the 2025 Presidential Transition Project. All contributors to thischapter are listed at the front of this volume, but James Rockas, Nazak Nikakhtar, Louis Heinzer, Robert Burkett,Iain Murray, Michael Gonzalez, David Legates, and Kristen Eichamer deserve special recognition. The author alone
assumes responsibility for the content of this chapter, and no views expressed herein should be attributed to any
other individual.

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2025 Presidential Transition Project
ENDNOTES

1.

2.

3.

4.
5.
6.

7.
8.
9.

Commerce Department Termination and Government Reorganization Act of 1995, S. Rep. 104–164, 104th
Cong., 1st Sess., October 20, 1995; Angela Antonelli, “Five Good Reasons to Close Down The Departmentof Commerce,” Heritage Foundation Backgrounder No. 1181, May 20, 1998, https://www.heritage.org/
budget-and-spending/report/five-good-reasons-close-down-the-department-commerce; and Competitive
Enterprise Institute, “Shrinking Government Bureaucracy: Reorganizing the Executive Branch to Boost
Economic Growth and Freedom,” August 2017, https://cei.org/shrinking-government-bureaucracy/ (accessed
December 16, 2022).
News release, “Latest Study of 120 Million Forecasts Proves AccuWeather Forecasts Are More Accurate,”
AccuWeather, January 14, 2020, https://www.prnewswire.com/news-releases/latest-study-of-120-millionforecasts-proves-accuweather-forecasts-are-most-accurate-300986848.html (accessed December 16, 2022).
In general, performance-based organizations are established to set forth clear measures of performance,
hold the head of the organization accountable for achieving results, and grant the head of the organization
authority to deviate from government rules if needed to achieve agreed-upon results.
Federal Register, Vol. 34, No. 45 (March 7, 1969), pp. 4935–4938.
U.S. Department of Commerce, Minority Business Development Agency, “The History of the MBDA,” https://www.mbda.gov/about/history (accessed March 15, 2023).
Ashley Winston, The Contribution of Minority Business Enterprises to the U.S. Economy, U.S. Departmentof Commerce, Minority Business Development Agency, September 2021, p. 7, https://www.mbda.gov/sites/
default/files/2021-09/The%20Contribution%20of%20MBEs%20to%20US%20Economy%20Report%20%20-%20September%202021.pdf (accessed March 2, 2023).
35 U.S. Code § 101.
National Institute of Standards and Technology, “About NIST,” https://www.nist.gov/about-nist (accessed
December 16, 2022).
Donald J. Trump, “Executive Order on Securing the Information and Communications Technology and Services
Supply Chain” Executive Order No. 13873, May 15, 2019, https://trumpwhitehouse.archives.gov/presidentialactions/executive-order-securing-information-communications-technology-services-supply-chain/ (accessed
March 20, 2023).

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