If Schedule F returns, EPA workforce is “particularly sensitive,” former officials warn

President-elect Donald Trump’s campaign promise to easily lay off large parts of the federal workforce may have a huge impact on Environmental Protection Agency employees, according to former EPA officials.

Former agency officials from several administrations told reporters during a call hosted by Environmental Protection Network that Trump’s pledge to bring back Schedule F and make federal employees in policymaking roles at-will hires would likely include a significant portion of the EPA’s approximately 15,000-person workforce.

Jennifer Orme-Zavaleta, an EPN board member and former acting assistant administrator of the EPA’s Office of Research and Development, told reporters that the EPA workforce is “particularly susceptible” to the return of Program F, “as are other agencies from all over the world. government.”

“Part of the challenge in doing this is the politicization of the workforce and the fact that a number of people involved in making the rules — and there are many — willingly, if we lose that workforce, if they’re fired for not following a certain direction and jump as high as they’re asked to jump, and I think that’s something that even the Trump administration has recognized as the first fix,” Orme-Zavaleta said.

Jeremy Symons, a senior adviser to the EPN and former climate policy adviser for the EPA’s Office of Air and Radiation, said federal scientists at the EPA will also likely fall under Schedule F.

“Trump is trying to paint a narrative of crooked bureaucrats, and the public health scientists at EPA are not the poster child for that narrative,” Symons said. “So Program F is the same situation with scientists across the agency.”

During the campaign, Trump and his supporters made promises revive Program Fan executive order signed at the end of his first term that would have reclassified tens of thousands of government workers as at-will employees exempt from civil service protections.

President Joe Biden revoked Trump’s Schedule F executive order during his first week in office. And earlier this year, the Office of Personnel Management completed a regulation that would make it harder for any subsequent administration to revive Schedule F.

Federal workforce experts, however, expect OPM’s actions would have, at at best, it slows down – but doesn’t prevent — the Trump administration since reinstating Program F.

It’s unclear how broadly Schedule F would impact career federal employees. Initial estimates showed that up to 50,000 federal employees in policy-related roles would fall under Appendix F.

Mandy Gunasekara, former EPA chief of staff under the Trump administration and author of Project 2025’s chapter on EPA, told members of the House Oversight and Accountability Committee in September that she “absolutely” supports bringing back Program F.

Gunasekara, who wrote the book, “Y’all Fired: A Southern Belle’s Guide to Restoring Federalism and Draining the Swamp,” told the House committee that the estimate of 50,000 employees in Schedule F is likely an underestimate.

“I think there are more public servants who should be gone, because the growth of the federal bureaucracy is hindering agencies that do their important missions, like protecting public health and the environment,” Gunasekara said.

Trump announced he will nominate former Rep. Lee Zeldin (R-N.Y.) to serve as EPA administrator.

“He will ensure fair and swift deregulatory decisions are made in a way that unleashes the power of American business while maintaining a higher environmental standard, including the cleanest air and water on the planet,” he wrote Trump in one Statement of November 11.

But beyond Schedule F, the Trump administration can rely on other means to shrink the size of the federal workforce — including at the EPA. The New York Times recently reported some members of Trump’s transition team discussed moving the EPA headquarters from Washington, DC

During Trump’s first term, many D.C. federal employees who worked at the Bureau of Land Management and parts of the Department of Agriculture left their agencies rather than move to Grand Junction, Colorado or Kansas City, respectively.

“You can’t see all of this and not expect an atmosphere of fear and uncertainty,” Orme-Zavaleta said. “At the heart of the latest rhetoric is really an effort to undermine America’s checks and balances systems by bypassing Congress as well as intimidating EPA employees in hopes that they will quit their jobs.”

Orme-Zavaleta said much of the EPA workforce is already eligible for retirement and may decide to retire before the incoming Trump administration. The end of each calendar year is a popular time for federal employees to retire.

“We normally expect to see people leave, and there may be some who have decided, ‘I don’t have enough energy to do another round of this administration,’ so they may choose to go ahead and retire.” , she said. “I think we’ll have to see how the numbers play out over the next couple of months.”

Predictions of a mass exodus of retirement-eligible federal employees have persisted across several administrations, but a “retirement tsunami” has yet to materialize. Federal employees did not are retiring in greater numbers under the first Trump administration or at the height of the COVID-19 pandemic.

Orme-Zavaleta said EPA employees tend to stay on the job for about five years after their retirement eligibility date — and added that she stayed with the agency 12 years after becoming eligible for retirement.

Career EPA employees often brief an incoming presidential administration on the decisions new agency leaders will need to make in their first 100 days, as well as ensuring continuity of government operations.

Each new administration typically sends landing teams to each agency that receive input from career officials.

“If people left, they would lose that historical knowledge, and then that would further hinder the EPA from being able to do what it needs to do,” Orme-Zavaleta said.

Symons said the George W. Bush administration and former EPA administrator Christie Todd Whitman attended transition meetings with the Clinton administration at last.

“We had spent months preparing an informational presentation, and she asked a lot of questions. It was her opportunity to not only hear from us, but to put us to work to answer the questions she wanted answered,” he said.

Trump’s transition team, however, has yet to do so sign memorandums of understanding with the General Services Administration or the White House that would allow some of these routine transition procedures to begin.

“The reality is there is nothing typical about this transition,” Symons said.

Elizabeth Sutherland, an EPN volunteer and former director of the Office of Science and Technology in the EPA’s Office of Water, said that during the first Trump administration, former EPA Administrator Scott Pruitt did not agree to any regulatory briefing in the part of career officials before taking office.

Instead, she said Pruitt received information from Republican election committee officials.

“He got a list of rules that he was going to cancel and then he let us know,” Sutherland said. “With Scott Pruitt, we didn’t have an opportunity to brief him and try to explain why some of our rules needed to stay in place as they were and to defend ourselves against the claims he was hearing from political donors,” said Sutherland.