Recent press reports tell of rumors of impactful (some fear catastrophic) budget cuts to the U.S. Environmental Protection Agency (EPA). Politically, priority on reducing EPA’s climate programs, along with budget and personnel cuts, are not surprising given the election results. Recent rumors include chatter that the EPA Office of Research and Development (ORD) might be eliminated and/or its staff redistributed, with a specific target on the back of ORD’s Integrated Risk Information System (IRIS).
In recent years, the IRIS program has skirted controversy particularly aimed at its underlying assessment methods and assumptions used in its reports about chemical exposures. In theory the program is an attempt to have a single hazard assessment act as a platform of sorts, for the individual media program offices across EPA (air, water, waste, and toxics) to then present an integrated approach to chemical risks. This singular assessment would then facilitate a cross-media, integrated approach that is easier to implement. Like so many ideas that are good on paper, fulfilling this goal has proven difficult over time (see the tortured history of the IRIS formaldehyde assessment).
Other forums have and will continue to discuss EPA science and assessment methods, both important issues for understanding and achieving EPA’s objectives. Yet what is also interesting is the long-standing, and much less noticed, discussion of EPA’s organizational structure and the ideas for changing the structure first created over five decades ago.
For the record, EPA was created by then-President Nixon in 1970. He had signed Reorganization Plan No. 3, calling for the establishment of EPA in July 1970. After conducting hearings that summer, the House and Senate approved the proposal. The Agency’s first Administrator, William Ruckelshaus, took the oath of office on December 2, 1970. Two days later, President Nixon issued EPA Order 1110.2 — Initial Organization of the EPA.
The original “organization” of EPA was a mix of existing programs, agencies, and departments — dispersed elements of the government working on environmental issues. A November 29, 1990, press release from EPA describes “EPA’s genesis” as “an executive order dealing with a pastiche of 15 programs from 5 agencies involving 5,800 employees and a $1.4 billion budget.
The organization of EPA, and how that organization impacts its effectiveness, has been an issue since its founding. From its earliest days, there have been proposals for making EPA a cabinet-level Department. During the H.W. Bush Administration, to knit together the programs and statures more coherently, the EPA policy office developed a comprehensive draft of possible ways to reorganize the underlying environmental legislation and a parallel EPA structure.
In August of 2006, the EPA Office of Inspector General (OIG) issued a report titled “Studies Addressing EPA’s Organizational Structure.” The objective of the report is to summarize 13 studies’ pertinent findings in a single, “informational document that provides perspectives on what has been problematic and what EPA may need to change regarding its organizational structure.” The OIG review includes research studies, articles, publications, and reports that address the EPA’s organizational structure and provide suggestions to improve performance. The report’s evaluation focuses especially on cross-media management, regional offices, “reliable information,” and “reliable science.”
Most recently, and perhaps most important given the current Administration’s efforts at government reform, the subject of “reorganizing” EPA is included as a chapter in the Project 2025 report. That chapter has led to fears from many that budget and personnel cuts are part of a larger plan to upend the Agency.
Recent press reports (like The Washington Post’s March 27, 2025, article, “Internal White House document details layoff plans across U.S. agencies”) indicate that the “plan” for EPA is to cut 10 percent of its workforce — which would seem less than some aggregated possibilities discussed in the Project 2025 chapter but could still include “firing up to 1,115 people” from ORD alone. Project 2025 suggests large cuts to regional offices, the elimination of the afore-mentioned IRIS program, a “reorganization” of the enforcement office and environmental justice programs, and other changes which would seem to add up to less than a 10 percent cut to the workforce. Attrition rates alone are estimated to be an average of 6 percent, and early retirements accelerated by, among other things, the fear of possible cuts, would likely add up to 10 percent or more.
Does this spell out some kind of preferential treatment for EPA? Unlikely, given the overall rhetoric of this Administration’s efforts. It may be that the larger target savings at EPA are the significant sums included for climate protection grant programs appropriated during the Biden Administration. Or it may be that the workforce cuts at EPA as a percentage contribute less to some unknown target of reducing the overall government payroll. While a 10 percent cut would result in a large impact on EPA capabilities, it is less than other programs eliminated altogether, or the announced 20 percent cut in staff at the Department of Health and Human Services (HHS) or 50 percent cut at the Department of Housing and Urban Development (HUD).
But the goal of reforming, reorganizing, or reducing the workforce is neither a new idea nor one lacking merit. EPA’s organizational structure has been under review since its inception. In the present moment, however, the lack of a cohesive or consistent approach leaves significant questions not only about the underlying motivation but also about the final impact of the effort. “Less bureaucracy” does not necessarily equate to reduced numbers of staff. And as some government functions will now contend with seemingly disorganized staff reductions, public resentment about “the bureaucracy” may only increase. Something to think about as we wait (and hope) to get our social security check or passport – or pesticide registration – on time