If Schedule F returns, EPA workforce ‘particularly susceptible,’ former officials warn

Much of the EPA workforce is already eligible for retirement, and may decide to retire before the incoming Trump administration, former EPA officials say.

President-elect Donald Trump’s campaign promise to easily fire large swaths of the federal workforce may have an outsized impact on employees at the Environmental Protection Agency, according to former EPA officials.

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

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

“Part of the challenge by doing this, by politicizing the workforce and having a number of the people involved in rulemaking — and there are a lot — at-will, if we lose that workforce, if they are dismissed because they’re not following a particular direction and jumping as high as they’re being asked to jump, and I think that’s something that even the Trump administration recognized the first go-around,” Orme-Zavaleta said.

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

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

On the campaign trail, Trump and his supporters promised to resurrect Schedule F, an executive order signed late in 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President Joe Biden rescinded Trump’s Schedule F executive order during his first week in office. And earlier this year, the Office of Personnel Management finalized a regulation that would make it harder for any subsequent administration to resurrect Schedule F.

Federal workforce experts, however, expect OPM’s actions would, at best, slow down — but not prevent — the Trump administration from bringing Schedule F back into effect.

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

Mandy Gunasekara, a former EPA chief of staff under the Trump administration and the author of Project 2025’s chapter on the EPA, told members of the House Oversight and Accountability Committee in September that she “absolutely” supports bringing back Schedule 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 50,000-employee Schedule F estimate is likely an undercount.

“I think there are more civil servants that should be gone, because the growth of the federal bureaucracy actually gets in the way of agencies fulfilling 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 that will be enacted in a way to unleash the power of American businesses, while at the same time maintaining the higher environmental standard, including the cleanest air and water on the planet,” Trump wrote in a Nov. 11 statement. 

But beyond Schedule F, the Trump administration may 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 the Trump transition team have discussed relocating the EPA headquarters out of Washington, D.C.

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

“You can’t see all that and not expect an atmosphere of fear and uncertainty,” Orme-Zavaleta said. “At the heart of the latest rhetoric, it’s really an effort to undermine America’s systems of checks and balances by bypassing Congress, as well as intimidating EPA employees, in the 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 going, and there may be some who have decided, ‘I don’t have enough energy to go another round of this administration,’ so they may choose to go ahead and retire,” she said. “I think we’re just going to have to see how the numbers play out over the next couple months.”

Predictions of a mass exodus of retirement-eligible federal employees have persisted across multiple administrations, but a “retirement tsunami” has yet to occur. Federal employees didn’t retire 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 past their date of retirement eligibility — and added she stayed at the agency 12 years after she was eligible to retire.

Career EPA employees often bring an incoming presidential administration up to speed on the decisions new agency leaders will need to make within the first 100 days, as well as ensure continuity of government operations.

Each new administration typically sends landing teams into each agency that receive briefings from career officials.

“If people were to leave, they would lose that historical knowledge, and then that would further hinder EPA to be 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 participated in transition meetings with the outgoing Clinton administration.

“We had spent months putting together a briefing presentation, and she asked a lot of questions. It was her opportunity to not only hear from us, but also set us to work answering questions that she wanted answered,” he said.

The Trump transition team, however, has yet to 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’s nothing typical about this transition,” Symons said.

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

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

“He got a list of rules that he was going to going to roll back from them, and then announced that to us,” Sutherland said. “With Scott Pruitt, we had no opportunity to brief him and to try to explain why a number of our rules needed to stay in place as they were and defend against the claims that he had heard from political donors,” Sutherland said.

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