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Introduction
Effective Monday, October 20, 2025, the U.S. Environmental Protection Agency (EPA) issued furlough notices to its largest group of employees to date. Since the start of the shutdown on October 1, the agency has operated on reduced staff using carryover funds that bridged the October 1 funding deadline. Initially, ten days into the shutdown, EPA began a phased furlough approach, affecting just the first wave of a relatively small share of employees.
Impacts
Staffing
This latest round will affect most career staff, including some
career leaders. As a result, a skeleton crew of senior political
appointees, top career leadership, and attorneys will maintain
operations by the agency. If the agency fully implements its shutdown contingency plan, nearly 90 percent
of its workforce would be furloughed.
Regulations & Rulemaking
Work on regulations and rulemaking will slow as the agency
concentrates on essential functions—protecting human health,
responding to emergencies (including Superfund actions posing
imminent risks), supporting law enforcement and disaster response,
and safeguarding EPA property. In the case of Superfund special
accounts, it is possible work that is funded by a special account
can continue, but EPA has not been consistent on this in the past
so stakeholders should check with EPA.
Programs
During the shutdown, EPA will not issue new grants, permits, or
regulations, and civil enforcement inspections without imminent
threats will be paused. Certain programs funded by fees or
dedicated revenues—such as those tied to the Superfund tax,
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), and
Pesticide Registration Improvement Act (PRIA)—can continue in
limited form. However, these resources could be at risk if
unallocated federal funds are redirected to support military
pay.
What You Should Do
State and local programs can also be affected with work slowed down or altogether stopped in certain cases. Awareness of whether a state project will be impacted as the shutdown progresses can help you prioritize your work with a state or local agency. Holland & Hart's Federal Affairs team helps clients develop strategic action plans to effectively navigate potential paths forward during the government shutdown.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
