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EPA’s Proposal to Eliminate Its Office of Research and Development Will Affect You

By frey

[Updated 6/22/25] This blog is a one-stop shop related to the political proposal to eliminate EPA’s Office of Research and Development.

What Does EPA Say About Eliminating ORD?

On March 18, 2025 , the New York Times reports that political leadership at the U.S. Environmental Protection Agency (EPA) is proposing to eliminate EPA’s Office of Research and Development (ORD).

On Tuesday, March 25, 2025, EPA Administrator said that some ORD scientists could be reassigned to help reduce a “massive backlog” in the new chemicals program of the Office of Chemical Safety and Pollution Prevention (OCSPP), and that other researchers would also be relocated to other headquarters offices, although no final decision has yet been made. The implications of these potential reassignments of ORD staff to OCSPP and the Office of Water (OW) are described below.

On April 15, 2025, as reported by E&E News, acting EPA Deputy Administrator Chad McIntosh told an industry audience at the American Chemistry Council’s GlobalChem conference that “You’re going to hear a lot about reforms in OCSPP and ORD” and that the Trump leadership team at EPA will be “looking … really hard” at so-called “dueling toxicity systems” used by OCSPP versus ORD,” referring to the long-standing Integrated Risk Information System program in ORD created in 1985 and the TSCA risk evaluation program in OCSPP.

Other developments in the last few days include an announcement that EPA will vacate office space in the Ronald Reagan Building, where ORD has its headquarters offices, and that an April 15, 2025 meeting of the EPA’s Board of Scientific Counselors, which advises ORD, was cancelled.

On May 2, 2025, via an op ed piece in Newsweek, EPA Administrator Zeldin announced the following:

EPA is improving its structure by integrating scientific staff directly into our program offices instead of siloed in the Office of Research and Development, which will better ensure that research directly advances statutory obligations and mission-essential functions. In the administrator’s office, there will be a new Office of Applied Science and Environmental Solutions, which will elevate research efforts, put science at the forefront of the agency’s rulemaking, and enhance technical assistance service for states and local partners.

The National Review had posted the slide deck (but then took it down, so it isn’t there anymore!) for the restructuring of EPA that was presented to ORD staff at an all-hands meeting at the end of the day (May 2, 2025).  The bottom line is that ORD staff can compete for about 1/3 the number of current positions that are being moved to other offices.

According to GreenWire, ” EPA Administrator Lee Zeldin has heralded a downsizing to Reagan-era staffing levels.” However, during the Reagan administration, EPA had the Office of Research and Development and ORD’s workforce was about 10% of the Agency’s.

Yet, Administrator Zeldin and his leadership team, including acting Deputy Administrator Chad McIntosh, assistant deputy administrator Travis Voyles, as well as OCSPP principal deputy assistant administrator Nancy Beck, and embedded DOGE operatives are taking steps to eliminate ORD. Other than Zeldin, none of these political appointees are Senate-confirmed.  In fact, the only Senate confirmed official at EPA at this time is the Administrator. DOGE operatives who have previously been reported to be at EPA include Kathryn Loving, Erica Jehling, and Cole Killian.

three ORD employees said that while no office [ORD] funding requests have been denied, many requests have not been approved.

“We’ve sent multiple requests for new expenses to them, and they just sit on them,” one of the staffers said. “But they never officially cancel or deny anything. It’s like a pocket veto.”

As reported in the Washington Post on 5/11/25

Contrary to the Administrator’s statement, EPA is not “improving its structure” by eliminating ORD. Here’s why:

  1. Given the lack of clarity from this Administration, it is unclear what research, if any, would actually take place in the program offices.
  2. Secondly, while no details are provided here, it seems likely that there will be duplicative entities in the program offices that are better managed by a centralized scientific organization, which is why ORD was created in the first place.  The program offices do not have sufficient expertise, experience, or – in some cases – understanding of scientific research to know how to run a true scientific research enterprise. The dispersement of science into individual program offices is an extreme form of siloing, because the program offices are siloed by media (air, water, land) or statute (e.g., the chemicals office operates only under TSCA, FIFRA, whereas the air office operates only under the CAA, etc.).  Environmental challenges that are inherently cross-media and interdisciplinary cannot be addressed effectively in this type of siloed environment.
  3. Third, having a bunch of small research enterprises siloed inside of program offices implies a lack of critical mass of expertise to effectively address key challenges that face the agency.
  4. Fourth, EPA’s primary mission essential function is “to prevent, limit, mitigate or contain chemical, oil, radiological, biological, and hazardous materials during and in the aftermath of an accident, natural or man-made disaster in the United States, and provide environmental monitoring.”  This type of work is inherently cross-media, interdisciplinary, and requires holistic and integrated approaches.  Such approaches are not possible by shrinking ORD and divvying up the scraps into siloed program offices.
  5. Fifth, ORD has developed and delivered research to meet statutory obligations and mission essential functions for decades.
  6. Sixth, placing research inside of policy-focused program offices sets the stage for introduction of bias into scientific work, since the scientific staff will be reporting within a management structure that is likely, especially in the current administration, to prioritize policy outcomes over best scientific practices.  Expect to see an increase in infringements on scientific integrity.
  7. Seventh, moving the remains of ORD — after cuts and after portions are siloed into program offices — into the Administrator’s office likewise makes the remnants of the scientific enterprise subject to the political leadership of the Administrator.  The AO is infused with political appointees, and likewise the science will be infused with politics.
  8. Eighth: ORD historically has been comprised almost entirely of career staff experts in science and administration and management of a scientific organization, which has enabled ORD to be crown jewel of the Agency as a world-class scientific organization.  Today’s announcement relegates ORD to a historical footnote.
  9. Ninth:  Make no mistake, Administrator Zeldin and his team are going to do less than nothing to “enhance technical assistance for states and local partners” – such assistance has been critically dependent on being able to reach back into an adequately staffed and resourced research organization that has the myriad of scientific skill sets, experience, expertise, and knowledge to provide meaningful evidence-based help to states, territories, Tribes, local governments, and others.  In fact, ORD has excelled at this for many years.  Cutting ORD’s budget, shrinking its workforce, siloing the remainder of its workforce will degrade and curtail, not enhance, this capability.
  10. Tenth:  The next effect of today’s announcement, which is rooted in an ideological and political attack on U.S. science writ large as embodied in rhetoric from Project 2025, is that the public can no longer trust EPA, a science-based agency, to fulfill its mission to protect human health and the environment.  The critical information necessary for the Agency to fulfill that mission is from the science developed and translated by ORD.

But, wait, there’s more (less)… Administrator Zeldin goes on to state:

The Office of Chemical Safety and Pollution Prevention will gain more than 130 scientific, bioinformatic, technical, and information technology experts to address the substantial backlog of new chemical and pesticide reviews from the previous administration. This influx of expertise will accelerate our ability to evaluate risk exposure while also allowing us to gain the tools needed to advance new priorities like a PFAS (chemicals that persist in the environment and may cause negative health affects) testing strategy—an issue I’ve championed since my days in Congress.

For a response to this, please see: Does it Make Sense to Reassign ORD Scientists to the OCSPP New Chemicals Program?

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“ORD is the scientific foundation for EPA’s work,” Frey said. “Without it, the agency won’t have the independent, credible science it needs to develop defensible regulations.” (WRAL news coverage, 3/18/25)

 

 

Science is Critical to EPA
Science is Critical to EPA

What Does the President’s Budget Say About ORD?

On May 2, 2025, Russell T. Voight, director of the Office of Management and Budget, provided a letter to Senator Susan Collins, chair of the Committee on Appropriations of the U.S. Senate, to convey “President Trump’s recommendations on discretionary funding levels for fiscal year (FY) 2026. The letter from an OMB director contains unusually strident partisan and politically charged language with a conspiratorial undertone based on rhetoric and opinion that is not supported by evidence. On page 15 of the letter, Mr. Voight proposes on behalf of the President to cut $235 million from ORD’s budget, which is a reduction of nearly 1/2.  This large of a reduction implies massive cuts to ORD’s workforce and loss of scientific and technical capability to support its mission to develop and translate science to inform decisions of EPA program and regional offices, as well as states, territories, Tribes, local governments, and others.  The “brief description of program and recommended reduction or increase” contains the following :

The President is committed to Making America Healthy Again. This framework includes ensuring that the American people have clean air and water, and is making investments that benefit human health. The Budget puts an end to unrestrained research grants, radical environmental justice work, woke climate research, and skewed, overly-precautionary modeling that influences regulations— none of which are authorized by law. Instead, the Budget provides $281 million for statutorily required research in support of core mission areas that help the American people

This text echoes Project 2025 which is heavy on ideological rhetoric and weak on evidentiary support. In the first Trump administration, the President’s budget proposals were dead on arrival each of the four years for FY18, FY19, FY20, and FY21.  The Trump Administration in 2017-2021 proposed draconian cuts to ORD that Congress did not support. It remains to be sign how Congress will respond, if at all, to the FY26 President’s budget.  This large of a disinvestment would severely undermine the ability of EPA to develop and use the best available science required under many federal statutes.

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What do the Courts Say About Trump/DOGE Efforts to Eliminate ORD?

On May 9, 2025, the U.S. District Court for the Northern District of California, in Case 3:25-cv-03698-SI, issued a temporary restraining order against President Donald Trump and other defendants, including the Environmental Protection Agency, and the administrations attempts to act on a February 11, 2025 executive order that claims to focus on “eliminating waste, bloat, and insularity.” The court notes that “to make large-scale overhauls of federal agencies, any president must enlist the help of his co-equal branch and partner, the Congress.” The conclusion in the order is that if the President is seeking changes to executive branch agencies, the President must do so in “lawful ways and, in the case of large-scale reorganizations, with the cooperation of the legislative branch. Many presidents have sought this cooperation before; many iterations of Congress have provided it. Nothing prevents the President from requesting this cooperation—as he did in his prior term of office. Indeed, the Court holds the President likely must request Congressional cooperation to order the changes he seeks, and thus issues a temporary restraining order to pause large-scale reductions in force in the meantime.”

As reported by InsideEPA the court found that “Plaintiffs are likely to succeed on their claims that the EO constitutes presidential overreach, “as the president has neither constitutional nor . . . statutory authority to reorganize the executive branch in this way,” Illston said during arguments. “The administrative agencies are creatures of statutes, and many past presidents, including President Trump in his first term, have recognized that they need Congress to initiate major agency reorganizations.”

On May 22, 2025, the U.S. District Court for the Northern District of California, in Case 3:25-cv-03698-SI, issued a preliminary injunction against President Donald Trump and other defendants, including EPA.  “By 3:00 p.m. (PDT) on Friday, May 30, defendants shall file a declaration verifying that all defendants have been given notice of this order and have taken steps to comply.”

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What is ORD?

ORD is the independent science arm of EPA. ORD was founded pursuant to the 1978 Environmental Research, Development, and Demonstration Authorization Act, which required EPA to “establish a separately identified program to conduct continuing and long-term environmental research and development”. ERDDAA expressed Congressional intent that EPA establish “a national environmental laboratory, or a system of such laboratories, to assume or supplement the long-term environmental research functions” and that “the research efforts of the Agency reflect the needs and priorities of the regulatory program offices, while maintaining a high level of scientific quality.”  Thus, Congress called for a program separate from that of the regulatory program offices to develop science relevant to their needs under a concept now recognized as “best available science“.

To fulfill requirements of statutes such as the Clean Air Act, the Clean Water Act, and numerous others, EPA must develop and apply science to inform its decisions. ORD does this by developing and translating science specific to the mission and decisions of EPA, as well as of EPA partners. ORD comprises a team of world-class scientists, engineers, and support staff, with collective scientific and technical expertise covering the full spectrum of life, physical, computational, and social sciences, and engineering. ORD engages with partners―including EPA programs and regions, states, Tribes, and communities―to identify the most pressing research needs to protect human health and the environment and to develop a comprehensive research portfolio to address them.

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Why Should You Care?

Science underlies just about all decisions made by EPA and by EPA partners, including states and Tribes, that are aimed at protecting human health and the environment.  Examples of decisions include rule-making, permitting, cleanups, emergency response, enforcement, planning, and funding priorities.  Without scientific evidence-based decision making, decisions would be arbitrary and capricious. If untethered to science, decisions can be highly political or ideological. Furthermore, without a scientific evidence base, over time decisions are subject to whiplash from one administration to another, which is bad for business. Scientific evidence helps assure that decisions can be as effective in possible, given other constraints, in protecting human health and the environment. This helps prevent you from dying prematurely because of exposures to chemicals in the environment, or your dog from dying because of a swim in a lake with toxic harmful algal blooms, or a child getting sick from playing with soil at a contaminated site. Science-based decisions have economic benefits as well – these benefits include reductions in premature death and illness that economists can translate into monetary values, as well as the recreational and other economic benefits of reducing degradation of visibility in a place such as the Grand Canyon or in a local lake where people would prefer to swim or fish.  A 2011 study found that the benefits of the Clean Air Act – just one of the statutes under which EPA makes decisions, provided benefits of $2 Trillion versus compliance costs of $65 Billion, a ratio of 30:1 for benefits to costs.

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What Was My Experience at ORD?

As a recent Assistant Administrator of the Office of Research and Development (ORD), I know personally that ORD is comprised of great people focused on the mission of developing and translating credible and independent science to, and for the benefit of, EPA program offices (OAR, OCSPP, OECA, OITA, OLEM, OW). ORD is a “core” office in the Agency’s Action Development Process (ADP) to assure that independent science is at the table in regulatory decision making. ORD has a robust regional science program with all ten of EPA’s regions.

Dr. Chris Frey
Dr. Chris Frey Addressing the U.S. Senate Environment and Public Works Committee During His Confirmation Hearing, October 27, 2021

Additionally, ORD currently has 124 research products that meet the needs of state partners, in the spirit of cooperative federalism, and 64 reseach products that meet the needs of Tribal partners, as part of the Nation-to-Nation relationship. ORD works closely with states via the Environmental Council of States and the Environmental Research Institute of the States, and coordinates with Tribes via the EPA Tribal Science Council. ORD’s research portfolio is based on partner engagement and needs of EPA headquarters offices, EPA regional offices, states, Tribes, local governments, and communities, as documented in Strategic Research Action Plans for each of its six National Research Programs – programs that have been in place for decades under Congressional appropriations.

ORD science is subject to rigorous independent external scientific expert peer review. ORD’s scientific work and how it manages this work is informed by advice from the EPA Board of Scientific Counselors and the National Academies of Sciences, Engineering, and Medicine.

ORD is the scientific ‘go to’ for EPA and partners when there is a crisis, e.g., 9/11, Deepwater Horizon, COVID, etc. EPA is obligated to use the best available science under its various statutory authorities (e.g., CAA, CWA, CERCLA,FIFRA, FQPA, MPRSA, NEPA, RCRA, SDWA, TSCA, and others).

ORD is unique among federal scientific organizations in developing and translating science that is relevant to the decision needs of EPA. ORD is also unique in performing “assessment science”, which involves holistic reviews and synthesis of literature and research to provide decision-relevant information.

ORD is the home of the Agency’s scientific integrity program, Science to Achieve Results (STAR) grants program, and Small Business Innovation Research program, and supports the cross-Agency Science and Technology Policy Council that coordinates Agency science policy.

ORD is a leader in the federal family on participatory science and open science.

ORD also has a culture of continuous improvement – it has to, because ORD has been underfunded for decades relative to the scientific needs of its partners. The need for trusted, credible, independent science, developed with scientific integrity and relevant to the decision-making needs of EPA and external partners, is only increasing.

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What’s Wrong with Eliminating ORD?

Eliminating ORD would deprive the American public of a rational and evidentiary basis for decision making for rulemaking, permitting, cleanup, and emergency response that affects the lives of all people in the United States. Literally, lives are at stake, because the work that ORD does is about understanding what is in the environment, how to measure it, who is exposed to it, what effect does it have, and what can be done to reduce risk. Without a credible independent organization that can answers these questions with integrity, there is not a foundation for decision making that leads to effective solutions.

Because ORD is separate from policy offices in EPA, there is a firewall between scientists and policymakers that helps ensure that ORD produces unbiased research.

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ORD’s Role in Emergency Response

“Past ORD research has been used to study the smoke in downtown Manhattan, New York after 9/11, the environmental effects of oil in the Gulf of Mexico following the Deepwater Horizon blowout, and the water crisis in Flint, Michigan, said Christopher Frey, former Assistant Administrator of ORD.” –Dissolving EPA’s research arm may jeopardize toxic chemical protections (The New Lede, 3/24/25)

Example of EPA Emergency Response Research
Chemical warfare agents (CWA) remain a threat to the United States and abroad. EPA’s Operational Testing and Evaluation of Chemical Remediation Activities (OTECRA) field study was conducted to assess lab-based advances in CWA environmental response at a full-scale facility consisting of offices and a studio apartment. The results of this field study are intended to advance the preparedness of the EPA, and its Federal, State, Tribal and Local partners, to respond to and recover from CWA incidents.

“EPA’s emergency response and homeland security research provides science & technology needed to effectively respond to and recover from disasters. Natural and human-made disasters, whether intentional or unintentional, can result in contamination that threatens human health, the environment, and our economy. Communities must be resilient to avoid such catastrophes. Resilience requires scientific information to support good decisions..” – Source:  EPA.

ORD’s emergency response research and technical expertise supports EPA’s Regional Offices, as well as EPA headquarters offices, other federal agencies, and state and local agencies in responding to local emergencies, and to planning for, and enhancing recovery from, future emergencies.

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ORD’s Role in Supporting States

State Engagement Focus Product Portfolio (Fiscal Year 2023-2026)
ORD’s State Engagement Focus Product Portfolio (Fiscal Year 2023-2026) contains 124 research products that are closely aligned with state interests

State environmental agencies look to ORD for leadership on science to inform state decisions. ORD’s State Engagement Focus Product Portfolio (Fiscal Year 2023-2026) contains 124 research products that are closely aligned with state interests. These products were identified based on state research needs from the 2022 ERIS States’ Research Need Survey Summary, as well as feedback from states and territories during various meetings and engagements held over recent years, including “ground truthing” meetings with state partnership groups held in spring 2022. Key research topic clusters include: PFAS, climate, wildland fires, cumulative impacts, chemicals of emerging concern, infrastructure and resilience, and drinking water.

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ORD’s Role in Supporting Tribes

ORD’s Tribal Consultation Commitment Product Portfolio (Fiscal Year 2023-2026) contains 65 research products across ORD’s six national research programs that are aligned with Tribal interests. These products are based on ORD’s engagement with Tribal partners including listening sessions, pre-consultation engagement, and formal Nation-to-Nation consultation with Tribes. ORD held listening sessions in 2021 to hear from Tribes on their most pressing technical challenges and science needs to inform development of the StRAPs. Key research topics identified through the various engagements and Tribal consultation included climate, wildland fires, chemicals of immediate and emerging concern including PFAS and 6PPD-quinone, solid waste, and emergency management.

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ORD’s Role in Scientific Research Grants

On 4/21/25, the journal Science reported that a “termination order involves grants from nine programs, including the investigator-initiated Science to Achieve Results (STAR); a university student research effort called People, Prosperity and the Planet (P3); and support of the Health Effects Institute (HEI), a nonprofit that studies air pollution. “It’s basically the entirety of EPA’s research grant portfolio,” says a source within the agency.”

Anecdotal conversations within the scientific community regarding principal investigators receiving grant termination orders align with the 4/21/25 report in Science.  For example, DOGE recently cancelled a University of Washington scientist’s grants, “saving” a mere $866.   DOGE is disregarding any benefits that accrue from these cancelle research efforts. Other cancellations have had far larger impact on existing projects, and the cancellations extend to projects that were selected for award but for which awards had not yet been processed as of the end of the Biden administration term. These EPA STAR grants are selected via a lengthy and rigorous process that involves development of a Request for Applications taking into account prioritized science needs of the Agency, the RFA itself, scientific peer review of submitted applications, and a relevancy review of those applications recommended for funding.

By canceling grants, not only is DOGE wasting the time of the principal investigators who applied for the grants, but they are wasting the time of the numerous federal employees involved in the development and administration of the RFA development and review process and those who administer the awarded grants, as well as the external scientists who participated in peer review of the grant applications.  Moreover, the termination of grants while they are underway is maximally disruptive and unnecessarily punitive not only to the Principal Investigator of the grant, but to co-investigators, undergraduate students, graduate students, and postdocs who may be working on the grant.

What is the desired goal of canceling research grants?  The rhetoric from the Trump Administration is that this is about ‘fraud, waste, and abuse.’  What is fraudulent, wasteful or abusive about a scientific research grant?  Some of the grant cancellations seem to focus on an ideological attack on anything perceived by Administration officials as “woke” or related to “climate“, “DEI“, or “EJ” across many federal agencies; however, the impacts extend well beyond an ideological purge to destabilization of “eight decades of government support for science”.  The U.S. federal investment in research since World War II has propelled the U.S. as the global leader in science and technology and been the foundation of economic growth and improved quality of life.  The sudden reversal of this 80 year commitment, in just 100 days, without any national debate regarding its implications, is unprecedented and is an act of destruction of U.S. science capacity at a scale that not even an adverse foreign power would be able to achieve.  This begs the question of what is the purpose and endgame of the destruction of the U.S. federal science enterprise?

Canceling research grants sends the following clear signals:  (1) the Trump Administration not only does not value scientific research, but views it as something to be punished; (2) the federal government is indicating that students should forget about pursing STEM higher education because of the mercurial disinterest of the federal government in STEM; (3) the U.S. has somehow done too much science and needs to step aside to allow other countries, especially China, to emerge as the global leader in STEM.

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Effect of an ORD Shutdown on Specialized Research Facilities Unique to EPA?

EPA’s Office of Research and Development has specialized research assets at its laboratories across the country. Even a temporary shutdown of ORD while ORD’s status might be litigated in court could have long-term adverse consequences for EPA’s scientific research enterprise.

For example, there are two large wind tunnels in Research Triangle Park, North Carolina used for air quality, chemical safety, and homeland security research. The RTP laboratories have many other unique and specialized facilities, such as a pilot scale system for testing thermal destruction of PFAS, a climate-

EPA/ORD Aerosol Wind Tunnel in RTP, NC
Data gathered from the EPA/ORD wind tunnel in Research Triangle Park, NC can be used to improve air quality models, which can assist decision makers, particularly within complex urban settings. Shwon here is a visualized plume over lower Manhattan topography based on the 9/11 attack.

controlled light duty vehicle dynamometer, and numerous systems for high throughput toxicology, among others. The ORD lab in Narragansett, RI has facilities to conduct research on the ecology of oceans, estuaries, and watersheds. At the ORD lab in Gulf Breeze, FL, scientists use a unique 14,000 square-foot wet laboratory to evaluate the impact of stressors on freshwater and saltwater species under controlled conditions to better understand hypoxia in the Gulf that creates “dead zones.” ORD’s Duluth, MN laboratory, on the shore of Lake Superior, specializes in research related to the effect of chemicals, bacteria, and land use changes on Great Lakes water quality, freshwater species, and other freshwater resources. Scientists conduct this research at a unique facility where numerous sentinel freshwater species are grown in Lake Superior-sourced water so stressor-effects can be evaluated under controlled conditions. ORD’s Ada, Oklahoma laboratory specialized in groundwater, and includes laboratories, field equipment, and test wells that investigate groundwater contaminant transport, and develop and assess technologies for remediating groundwater contamination. Researchers at EPA’s Corvallis, Oregon, facility investigate the freshwater and coastal ecosystems in the Pacific Northwest and across the country. The Corvallis laboratory has unique capabilities that include a stable isotope analysis research laboratory that can trace the path of chemicals moving through the environment. ORD’s Cincinnati, OH laboratory has numerous and extensive specialized facilities for drinking water and wastewater treatment systems to support work on corrosion control, disinfection, lead pipe scales, and more.

In addition to research instrumentation and apparatuses, ORD handles a wide range of research samples that require special handling and storage to comply with quality assurance project plans for safety and scientific validity. These include air, water, and soil samples, as well as biomarker samples such as blood and urine from humans or other samples form fish, frogs, earthworms, and other animals. These samples typically require specialized freezers and refrigerators and can be contaminated or lost if there is even a short power interruption or lack of attention to their status. For example, the failure of just one specialized research refrigerator can lead to the loss of $100,000 worth of samples. This is why ORD has installed networked temperature sensors to continuously monitor cold storage devices nationally to provide immediate notification and corrective action as needed.

Many ORD experiments take place over extended periods of time, ranging from weeks to months to years; thus, any precipitous shutdown would result in substantial loss of ongoing scientific studies, which would not only be wasteful but would raise scientific integrity concerns.

Specialized research assets, laboratories, field equipment, and scientific computation tools, and sample handling and storage facilities, are complex and unique resources that ORD is well-equipped to select, install, operate, maintain, and repair.  By having all of these research assets operate under one headquarters office, EPA realizes operational and cost efficiencies. Most importantly, these assets are essential to the Agency’s ability to develop and translate science directly related to its mission in a manner that is responsive to partner needs, of high quality, and timely.

Proposals to dissolve ORD so far have failed to address what would be the fate of these specialized assets and the research associated with them.  For example, an idea floated by EPA Administrator Lee Zeldin to move 100 ORD scientists to the chemicals office fails to account for what happens to the numerous specialized high throughput toxicology laboratories in RTP?  EPA’s policy-oriented offices have limited to no experience with managing these types of resources and not at the scale with which they exist in ORD. Are these to be abandoned, leading to a waste of resources and loss of mission critical scientific research capability? EPA leadership has been silent on these issues.

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Does it Make Sense to Reassign ORD Scientists to the OCSPP New Chemicals Program? 

On Tuesday, March 25, 2025, at the semi-annual meeting of the Environmental Council of States, EPA Administrator Lee Zeldin confirmed that the EPA is considering reorganizing ORD staff that would remain after massive lay-offs into other program offices. Pointing to the New Chemical Review program under the Toxic Substances Control Act (TSCA), Zeldin stated that there is a backlog of 14,000 applications, further stating that:  “well, if we … were able to get 100 people from the Office of Research and Development to come assist with this work, we would be able to get this backlog down… Okay, I don’t know who those 100 people are, I don’t know what they are doing currently, but if it makes sense to have 100 people from [ORD] work with the chemicals office to get the backlog down, I’ll take that feedback”.

ORD Research Supporting New Chemicals Program
Existing and Ongoing ORD Research Supporting New Chemicals Program

The Administrator’s statement reveals lack of knowledge about ORD, what does, and the capabilities of its workforce. Administrator Zeldin should ask for and take a briefing from ORD to learn about ORD’s work before making any decisions.

With regard to new chemical reviews, Administrator Zeldin should familiarize himself with a plan developed collaboratively between ORD and the Office of Chemical Safety and Pollution Prevention (OCSPP) to bring innovative science to new chemical reviews, modernize the approaches used, and increase the transparency of the human health and ecological risk assessment process, as announced by the EPA on February 24, 2022.  This plan has five major elements:

  • Updating OCSPP’s approach using data from structurally similar chemicals to determine potential risks from new chemicals, also known as read-across. This will increase the efficiency of new chemical reviews promoting the use of the best available data to protect human health and the environment.
  • Digitizing and consolidating information on chemicals to include data and studies that currently only exist in hard copy or in disparate TSCA databases. The information will be combined with publicly available sources to expand the amount of information available, enhancing chemical reviews and enabling efficient sharing of chemical information across EPA. Safeguards for confidential business information will be maintained as appropriate in this process.
  • Updating and augmenting the models used for predicting a chemical’s physical-chemical properties and environmental fate/transport, hazard, exposure, and toxicokinetics to provide a suite of models to be used for new chemicals assessments. The goal of this effort is to update the models to reflect the best available science, increase transparency, and establish a process for updating these models as science evolves.
  • Exploring ways to integrate and apply New Approach Methods (NAMs) in new chemicals assessments, reducing the use of animal testing. As this effort evolves, the goal is to develop a suite of accepted, fit-for-purpose NAMs that could be used by external stakeholders for data submissions under TSCA as well as informing and expanding new chemical categories.
  • Developing a decision support tool that integrates the various information streams specifically used for new chemical risk assessments. The decision support tool will more efficiently integrate all the data streams (e.g., chemistry, fate, exposures, hazards) into a final risk assessment and transparently document the decisions and assumptions made. Simply put, this will facilitate the new chemicals program tracking decisions over time and evaluating consistency within and across chemistries.

This plan is documented in an agency report that was reviewed by the EPA Board of Scientific Counselors. However, due to funding cuts to both OCSPP and ORD in the last Congress, this work has not had adequate resources to move forward as aggressively as it could if it were adequately resourced.

The bottom line is that it makes far more sense to engage ORD scientists to develop and translate the science needed to help OCSPP read-across, predictive models, NAMs, and decision support tools than it does to pull world class principal investigators and senior researchers off of this foundational work to perform administrative functions.  Moreover, the completion of the New Chemicals Collaborative Research Program will enable OCSPP to more rapidly assess and reach decisions on new chemicals via improved science, methods, processes, and data, which would not only address the current backlog but enable OCSPP to more efficiently conduct new chemicals reviews for years to come.

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Does it Make Sense to Assign ORD Scientists to the Office of Water?

At a March 25, 2025 session with the Environmental Council of States, EPA Administrator Lee Zeldin indicated he is taking feedback “regarding per- and polyfluoroalkyl (PFAS) work in the Office of Water, where he’s hearing “they can use more assistance from scientists who are currently inside” ORD [Source: InsideEPA].

Administrator Zeldin should request and receive a briefing from ORD regarding its extensive PFAS research program that serves the needs of the Office of Water (OW) as well as the Office of Air and Radiation (OAR), Office of Chemical Safety and Pollution Prevention (OSCPP), Office of Land and Emergency Management (OLEM), Office of Enforcement and Compliance Assurance (OECA), as well as the needs of states, Tribes, local governments, and communities. ORD’s research portfolio is already informed by extensive engagement with OW regarding the scientific information that they need to inform decision, as documents in ORD’s Strategic Research Action Plans (StRAPs).

ORD Research Supports Drinking Water Systems
ORD Research, Including Research on Treatability of PFAS, Supports Drinking Water Systems

PFAS research in ORD is a cross-cutting issue with strong Congressional support. The water-related PFAS research that ORD is not only in support of OW but also in support of other EPA partners. The scientific capabilities and skills in ORD that are the foundation of ORD’s research that addresses OW needs, such as for development of hazard identification and toxicity assessments, are not unique to either PFAS or OW and thus, in a cost effective and efficient way, serve multiple needs of the Agency and its partners. ORD’s research on PFAS treatment in drinking water connects not only with OW, but also with EPA regional offices, states, Tribes, local governments, and communities.  OW does not have experience or capabilities to run specialized research assets associated with ORD’s PFAS research program.  Furthermore, dividing ORD’s PFAS research program into media-specific components that are transferred into media-specific headquarters offices would create silos and lead to duplication of support functions that are more efficiently handled within a research organization that is experienced at doing world class research.

ORD also has a strong culture of providing scientific technical support as needed and does so on many topics, including PFAS.  ORD and OW have a strong collaborative relationship in which ORD is conducting technology demonstration and evaluation, and development of applications, models, tools, and websites, to assist drinking water treatment systems with identifying sustainable and cost-effective treatment strategies for PFAS and other emerging contaminants. ORD scientific expertise on PFAS and drinking water treatment is world-class and unmatched. ORD is the lead on working with specific local drinking water systems in status such as New Hampshire, North Carolina, South Carolina, Florida, Alabama, Tennessee, Ohio, Michigan, Wisconsin, and others and the technical efforts in this partnership with OW, based on its experiences.  This program is working effectively and would be disrupted by any reduction of staffing or loss of scientific capacity in ORD, to the detriment of drinking water systems across the country.

Dismantling ORD, firing most of its staff, and moving remaining staff into headquarters program offices will have many adverse implications for EPA and the American public, as noted here and elsewhere on this page.

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Statutory Requirements for ORD and for EPA to Use the Best Available Science

EPA is required by statute to conduct research.

Under 33 USC 1254: Research, investigations, training, and information, “The Administrator shall establish, equip, and maintain field laboratory and research facilities, including, but not limited to, one to be located in the northeastern area of the United States, one in the Middle Atlantic area, one in the southeastern area, one in the midwestern area, one in the southwestern area, one in the Pacific Northwest, and one in the State of Alaska, for the conduct of research, investigations, experiments, field demonstrations and studies, and training relating to the prevention, reduction and elimination of pollution. Insofar as practicable, each such facility shall be located near institutions of higher learning in which graduate training in such research might be carried out” and “the Administrator shall conduct research and technical development work, and make studies, with respect to the quality of the waters of the Great Lakes” and other provisions.

The 1978 Environmental Research, Development, and Demonstration Authorization Act (ERDDAA) requires that “The Administrator of the Environmental Protection Agency shall establish a separately identified program to conduct continuing and long-term environmental research and development.”

ORD has a critical role in assuring that the EPA has access to the best available science, as required by statutes under which EPA has decision-making authority. In many cases, ORD conducts intramural research to develop the decision-relevant science that is not available anywhere else, using a wide range of scientific methodologies that include bench-top laboratory studies, pilot-scale laboratory studies, use of specialized research assets (e.g., wind tunnels, aquatic stream simulators, water security testbed, and others), field measurements of air, water, and land contaminants, validation of new measurement methods, computational methods, and stakeholder engagement.  ORD conducts collaborative research to leverage the resources and expertise of other federal agencies, industry, academia, and nonprofits. ORD sponsors extramural research via its STAR grants program to support the longer-term development of best available science for future use.  ORD research is often collaborative with partners in EPA headquarters offices, EPA regional offices, states, territories, Tribes, local governments, and communities. Furthermore, ORD is unique expert at “assessment science”, which involves holistic systematic reviews of the literature to synthesize policy relevant scientific information.

Integrated Science Assessments
EPA’s Office of Research and Development independently develops interdisciplinary Integrated Science Assessments to satisfy Clean Air Act Section 108 requirements to establish scientific criteria for air pollutants to inform National Ambient Air Quality Standards

Examples of statutes that require EPA to use the best available science are:

  • Section 108 requires that “Air quality criteria for an air pollutant shall accurately reflect the latest scientific knowledge useful in indicating the kind and extent of all identifiable effects on public health or welfare which may be expected from the presence of such pollutant in the ambient air, in varying quantities”  Source, US Code.  Air pollutants may have implications for cross-media impacts (e.g., deposited air pollution can affect water or soils).
  • 1996 amendments to the Safe Drinking Water Act “require that EPA consider a detailed risk and cost assessment, and best available peer-reviewed science, when developing” standards, according to EPA. (InsideEPA)
  • 2016 amendments to the Toxic Substances Control Act requires EPA to “use scientific information and approaches in a manner that is consistent with the requirements in TSCA for the best available science” when evaluating risks of “existing” chemicals. (InsideEPA)
  • Environmental Research, Development and Demonstration Authorization Act, which authorized funding for EPA to conduct research as required by certain statutes the agency implements. (InsideEPA)

Additionally, Congress appropriates funding for ORD’s national research programs, including Air, Climate, and Energy; Chemical Safety for Sustainability, Homeland Security, Health and Ecological Risk Assessment, Safe and Health Communities, and Safe and Sustainable Water Resources.  Appropriations are laws enacted by Congress are legally binding and must be followed by the government.

Federal courts have reinforced the need for EPA to use the best available science.

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Why is this happening?

ORD has enjoyed tremendous support over the decades from Congress, from most White House administrations, and from Agency and external partners (including states and Tribes). ORD regularly partners with industry in its research, as well as with universities, federal agencies, state agencies, local agencies, Tribal Nations, other types of organizations, and communities.

However, the nature of ORD’s work is that it occasionally addresses issues that are of great interest to potentially regulated parties, particularly industry. While not all companies engage in these practices, there are some companies and trade groups that engage in disinformation and misinformation campaigns aimed at influencing policy decisions.

In the late 1960s, a new corporate strategy emerged, in the context of the tobacco industry, of fomenting doubt about science even when scientific findings were based on appropriate methods and had been subject to external independent expert scientific peer review: “Doubt is our product since it is the best means of competing with the ‘body of fact’ that exists in the mind of the general public”  Science denialism has been a strategy in response to emerging science in a variety of other areas as well, most notably with regard to climate change.

Today, some industry groups engage in public relations initiatives aimed at undermining assessments develop by EPA on a variety of chemicals and their hazards.  Another phenomenon is the emergence of ‘astroturf’ (as compared to ‘grassroots’) groups that are funded by industry and that engage lobbyists and lawyers, rather than scientists, to provide comments on EPA’s draft science products.

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Is This Related to Project 2025?

Project 2025, which appears to be the playbook that is running policy in the current administration, has this to say about ORD:  “EPA’s scientific enterprise, including ORD, has rightly been criticized for decades as precautionary, bloated, unaccountable, closed, outcome-driven, hostile to public and legislative input, and inclined to pursue political rather than purely scientific goals.”  Is this a fair or even accurate characterization?

Project 2025
Project 2025’s chapter on EPA’s Office of Research and Development is a biased diatribe that is unsupported by evidence.
  • “rightly been criticized for decades” – some stakeholders have criticized ORD for decades. Many stakeholders rely upon ORD for the best available science to inform decisions.  This is true, for example, of many states, which do not have the capability to conduct their own research.  ORD’s work has been subject to rigorous external review for decades.  In some cases, external advisory groups have recommended substantial improvements to particular programs at ORD – for example, National Academies of Sciences, Engineering, and Medicine (NASEM) recommendations in 2011 regarding the Integrated Risk Information System (IRIS) program. However, ideological critics of ORD, such as Project 2025 authors, completely ignore that in cases like this ORD has been highly responsive, has made improvements, and is now lauded for its exemplary work, as indicated in NASEM’s 2022 review of the IRIS Handbook and the NASEM’s 2023 review of the IRIS formaldehyde assessment.
  • “precautionary” – ORD does not make policy decisions.  Agency policy decisions vary but it is not the case that they are inherently precautionary. The U.S. legal framework for environmental regulation is more accurately described as ‘utilitarian’ than ‘precautionary’.  This adjective may be intended to refer to science policy related to how to deal with and interpret uncertainties in the context of agency guidance regarding toxicity assessment, but such guidance has been informed by numerous National Academy panels. Even so, ORD continues to explore probabilistic alternatives for dose-response assessment.
  • “bloated” – please see above regarding efficiencies
  • “unaccountable” –
    • ORD has to justify its budget requests to examiners in the Office of Management and Budget and in briefings or hearings with various Congressional committees, and additionally in the context of Administrator briefings to the “four corners” Congressional committees during the appropriations processes.  In this way, ORD is accountable to the public.
    • ORD’s research portfolio is partner-driven. This means that ORD seeks input from EPA headquarters offices, regional offices, states, Tribes, local governments, and community, and various representative groups, such as the Environmental Council of States, the Environmental Research Institute of the States, the EPA Tribal Science Council, media-specific (e.g. air, water, land, chemicals) associations of state and local agencies, and others.
    • ORD measures its success based on providing quality, relevant, and timely research products to its partners, based on surveys of partners who receive the products
    • ORD science is routinely and regularly subject to independent external scientific expert peer review to assure scientific quality
  • “closed”
    • See “unaccountable”
  • “hostile to public and legislative input”
    • ORD values collaboration and has many collaborations with industry, academic, other federal agencies, state agencies, Tribal governments, local governments, communities, and others.
    • Any science advisory entity subject to the Federal Advisory Committee Act (FACA), such as the Board of Scientific Counselors, Science Advisory Board, Clean Air Scientific Advisory Committee, and others that review ORD work, must provide an opportunity for public comment.
    • ORD is accountable to Congress – see “unaccountable” above.
    • ORD’s focus is on developing independent credible science – thus, it should and must not be subject to political interference in how the science is conducted.
    • Occasionally, public and input from members of legislative bodies pertain to topics that are out of ORD’s scope (e.g., ORD does not make policy decisions) or that are contrary to rigorous processed by which ORD develops and translates science.
  • “inclined to pursue political rather than purely scientific goals”
    • ORD research priorities are developed to respond to the needs of its partners.
    • As administrations change, Agency priorities change.
    • ORD scientists and staff have the expertise and capabilities to reprioritize research to respond to new priorities.

Thus, the Project 2025 characterization is not fair nor is it accurate.

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What are the Implications of Eliminating ORD?

Eliminating ORD will:

  • demonstrate the Agency’s hostility to following the science, a core foundational principle set forth by EPA’s first administrator, William Ruckelshaus, who was appointed in 1970 by President Nixon.
    NYC Then and Now
    Although we have come a long way in improving our environment and human health, we also have a long way to go.
  • demonstrate that the Agency’s political leadership is following Project 2025, which is an ideological document that mischaracterizes and misunderstands science generally and ORD specifically
  • demonstrate the Agency’s lack of commitment to evidence-based decision making that follows the law, given that the many statutes that provide its statutory authority and that pertain to its operation that require the agency to follow the best available science and to do so a consistent manner.
  • deprive the Agency of an organization that independently develops and translates science to inform its own decisions, in accordance with statutory requirements that the Agency use best available science
  • call into question the credibility, legitimacy, and integrity of science that is developed within, rather than apart from, its regulatory program offices, given the potential for conflicts of interest regarding policy outcomes to bias scientific work
  • deprive EPA regional offices of access to science that pertains to regional science needs
  • deprive Agency partners, including states, Tribes, local governments, and communities, of access to science that they need to inform their decisions.
  • reduce efficiencies of having one office with support staff, facilities, processes, procedures, and other resources to support the scientific enterprise
  • eliminate a core office that is critical to the Agency’s Action Development Process for regulatory decision making, thereby silencing an independent scientific voice in deliberations that inform Administrator decisions.
  • undermine cooperative federalism, because states are heavily reliant on ORD science.  There are 124 ORD research products in the current Strategic Research Action Plans that are partly in response to state needs (they also meet Agency needs). These needs are identified by ORD in collaboration with the Environmental Council of States and the Environmental Research Institute of the States.
  • undermine the Nation-to-Nation relationship with Tribal nations.  There are 64 ORD research products in the current Strategic Research Action Plans that are partly in response to state needs (they also meet Agency needs).
  • lead to legal vulnerabilities for any regulatory decisions of this Administration if it is unable to demonstrate that it followed the best available science according to well established principles and processes
  • deprive the Agency of a ‘one stop’ source of scientific technical assistance on a wide range of issues that come up frequently either inside the agency or among states, Tribes, local governments, and others
  • deprive the Agency of a ‘one stop’ source of scientifically-based emergency response assistance, that has served the public in crises including 9/11, Deepwater Horizon, the COVID-19 pandemic, and others
  • generally undermine the ability of the EPA to fulfill its mission to protect public health and the environment based on best available science, in accordance with applicable statutes

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What Would it Mean to Return EPA and ORD to “Reagan levels”?

Current EPA Administrator Lee Zeldin is framing reductions in force for EPA as a return to Reagan staffing levels. The actions of Administrator Zeldin and the DOGE operatives embedded in EPA is a continued reduction in ORD, whether through the firing of probationary workers, creating a hostile work environment that is intended to incentivize employees to voluntarily separate from EPA, choking of the supply of appropriated dollars for ORD (which is likely illegal), or offering deferred resignation programs that place workers on administrative leave through 9/30/25, at which point they are terminated. While EPA has recently announced opportunities for new positions in other parts of the Agency via the Talent Hub portal, the nature of these positions is not sufficiently specified for current employees to make a well-informed choice to apply.

In this context, what would it mean if EPA were to return to “Reagan levels”? The Reagan Administration submitted budgets during eight fiscal years, ranging from FY82 to FY89.

During the Reagan administration, the EPA budget for Research and Development, in equivalent 2025 dollars, ranged from a low of $730M in FY83 to a high of $1B in FY89. ORD’s workforce in FY87, FY88, and FY89 was over 1800 “workyears”. Although EPA did see budget cuts especially in FY83 compared to prior years, the controversy and incompetence of EPA’s leadership at the time led to the forced resignation of Administrator Ann Gorsuch and for President Reagan to appoint William Ruckelshaus as Administrator to reset the agency (see a timeline). With Reagan’s support, Administrator Ruckelshaus returned the agency to a focus on its mission to protect human health and the environment by following the science, following the law, and being transparent.

ORD’s workforce was typically around 1900 full time equivalent (FTE) for many years. For example, in FY 2010, ORD’s budget was equivalent to $870M in 2025 dollars with 1911.3 FTE.

Compare that with the FY23 budget for ORD: the FY23 enacted was the best of the 4 years of the Biden administration for ORD at $600M in 2025 dollars with 1526.7 FTE.

Overall, if Administrator Zeldin is serious about a return to Reagan levels, he will increase the budget and the workforce for ORD to levels seen in the last few years of the Reagan Administration, after President Reagan learned from and corrected the mistakes of the first two years of his administration.

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What is the Effect of Eliminating ORD on Students and STEM Workforce?

ORD has 12 locations, all of which employ students, postdoctoral fellows and visiting researchers from local, regional universities, and national universities.  Examples include but are not limited to:  (a) The RTP Campus has student services contractors and postdoctoral research fellows from Duke, NC Central University, NC State University, and UNC-Chapel Hill and other universities; (b) the Atlantic Coastal Environmental Sciences Division (ACESD) Laboratory in Narragansett works closely with the University of Rhode Island and others; (c) The  Robert S. Kerr Environmental Research Center in Ada, Oklahoma, which includes ORD’s Groundwater Characterization and Remediation Division, has a close relationship with East Central University in Ada and with the University of Oklahoma and Oklahoma State University, among others; (d) ORD’s research labs in Cincinnati, OH support students from the University of Cincinnati and other area institutions; (e) ORD’s Athens, GA office is located near the University of Georgia; (f) ORD’s Great Lakes Toxicology and Ecology Division in Duluth, MN supports students from area universities including in the University of Minnesota and University of Wisconsin systems; (g) ORD’s Pacific Ecological Systems Division (PESD) laboratories in Corvalis, OR and Newport, OR are located near Oregon State University and benefit from student engagement and collaboration with OSU. In addition to involving students from local universities as on-side student services contractors, ORD supports student opportunities via the ORAU/ORISE programs and various fellowship programs. Many now senior scientists and other staff in ORD and elsewhere started their careers at an ORD laboratory while a student.

UPDATE 5/13/25:  EPA has terminated the ORAU/ORISE student services contract — EPA research contractors prep to end work Wednesday (E&ENewsPM, 5/13/25)

Additionally, ORD has grants programs that support students. One is the Annual P3 Awards: A National Student Design Competition Focusing on People, Prosperity and the Planet.  ORD also administers research grants, including the Science To Achieve Results (STAR) grants. Research grants often include funding to support students as research assistants.  Thus, these are a mechanism by which students become engaged on research relevant to the Agency mission as part of their degree program at their home institution.

UPDATE 4/21/25:  EPA HAS TERMINATED ALL STAR GRANTS AND THE P3 PROGRAM. EPA orders staff to begin canceling research grants | Science | AAAS

EPA Supports Student Learning via the People< Prosperity, and Planet (P3) Program
EPA Supports Student Learning via the People< Prosperity, and Planet (P3) Program

While there is not an exact count of how many people have worked at, with, or because of ORD on research as students, in 2023 there were over 400 Oak Ridge Institute for Science and Education (ORISE) fellows and Oak Ridge Associated University (ORAU) student services contractors in ORD.  ORISE Fellows work in all of ORD’s scientific areas. ORAU Contractors work across all of ORD’s scientific areas as well as business operations.

ORD also has STEM engagement programs at its RTP and Cincinnati locations that engage K-12 students.  ORD confers the Patrick H. Hurd Sustainability Award in recognition of high school student research projects presented at the Regeneron International Science and Engineering Fair (Regeneron ISEF).

Thus, ORD has a portfolio of opportunities, activities, and efforts that engage students and promote their career development. These programs would be lost if ORD were dismantled, which is contrary to eight decades of federal commitment since World War II to development of science and technology leadership in the U.S. to promote economic development, national security, and societal benefits.

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What Others Saying About the Implications of Eliminating ORD

  • “With no ORD, then you really have the door open to biasing what science will be considered in setting a regulation in order to achieve the kind of outcome that you’re looking for,” Jennifer Orme-Zavaleta, acting ORD chief in the first Trump administration. Source:  InsideEPA
    Jennifer Orme-Zavaleta on CBS New
    Former Senior Career Leader of EPA’s Office of Research and Development, Jennifer Orme-Zavaleta, Speaks on CBS News
  • “ORD’s research continues to be helpful for the implementation of existing regulations such as arsenic, as well as the newer regulations such as PFAS” and lead rules, Roberson continued. “In drinking water, EPA’s corrosion control treatment research has been considered the ‘gold standard.'” Alan Roberson is executive director at the Association of State Drinking Water Administrators.  Source:  InsideEPA
  • Regarding PFAS:  “It was ORD who was able to come up with this really great way of categorizing those 15,000 chemicals into much fewer categories, so that you can have industry and EPA ORD test one representative chemical whose values then represent the toxicity and persistence of, you know, 2000 or more chemicals with a similar chemical structure,” – Betsy Southerland, a former top official in EPA’s water office. Source: InsideEPA
  • If the Environmental Protection Agency cannot research the health risks from pollutants, it cannot fulfill its Congressional responsibility to protect people against harmful pollution.” – Geoff Gisler, Director, Southern Environmental Law Center (SELC). Source: InsideEPA
  • “The states greatly benefit from the science that’s been done in EPA. They do not, in most states, have the resources to do that on their own” – Betsy Southerland, a former top official in EPA’s water office. Source: InsideEPA
  • “a decimated EPA means less scrutiny for another Flint water crisis, less eyeballs on Superfund sites, and limited ability to investigate toxic contamination after train derailments, such as the incident two years ago in East Palestine, Ohio. He added, “And we have a Great Lakes research vessel that tests the water across all the lakes. It’s important for drinking water, tourism, and fishing. If we get crippled, all that goes into question.” ”  Source: UCS
  • “ORD is a crown jewel of EPA, and it provides indispensable scientific information that forms the underpinnings of a lot of regulatory decisions,” – Richard Revesz, Former Director, Office of Information and Regulatory Affairs, Office of Management and Budget, Source:  E&E News.
  • Placing the NAAQS process within the science office “ensures that the assessments can be developed independent of their use by EPA’s program and regional offices to set national standards and make environmental decisions.” – EPA’s website
  • “ORD was a major part of providing those updates for us on a regular basis” – Chet Wayland, speaking regarding the need for research to solve future problems.  Source:  E&E News.
  • “Gutting EPA’s research capabilities directly harms states’ ability to ensure we have clean air and clean water, because we rely on the EPA for scientific expertise and capacity that i’s rarely available at the state level,” – former Secretary of the NCDEQ, Elizabeth Biser, Source:  GreenWire.
  • “I regularly collaborate with Kerr Lab. Eliminating the Office of Research and Development would shame Kerr’s legacy and deprive Oklahomans and Americans from needed groundwater research” – Christine Pappas
  • “We’re not going to able to do the science that is detecting all of the harmful things that we want to try to remove from the environment,” – a probationary worker who left ORD.
  • “Making America healthy will require cleaner air and the expertise of ORD to conduct rigorous science, independently of politics, to safeguard the millions of American lives.” – American Thoracic Society.
  • ” they are not following any process and they’re not talking to anyone” – an ORD worker.
  • Protestors in Duluth, MN called upon “the federal government to reconsider cuts to the EPA’s science and research arm, a shortsighted move that not only threatens water quality but the 150 employees who work at the Duluth lab and the $15 million a year the facility contributes to Minnesota’s economy.” (Duluth News Tribune).
  • On April 16, 2025, the Environmental Council of States (ECOS) issued a public statement on the importance of federal research and U.S. EPA’s Office of Research and Development.  ““States are not resourced or equipped to perform such work,” referring to scientific research needed to inform state decision-making.

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Current Status of FY26 Budget

  • The Trump Administrations “skinny” budget released on May 2, 2025 proposed a 46%, or $235M, cut to EPA’s Office of Research and Development.
  • On May 30, 2025, EPA released a more detailed FY26 budget proposal. This budget cuts five of ORD’s six national research programs, including the following (based on Science & Technology (S&T) appropriations):
    • Air and Energy (formerly Air, Climate, and Energy) by 65%;
    • Chemical Safety for Sustainability by 24%;
    • Health and Environmental Risk Assessment by 36%;
    • Homeland Security by -5% (slight increase);
    • Safe and Sustainable Water Resources by 29%; and
    • Sustainable and Health Communities by 56%.
    • Some of these programs also receive funds from other appropriations.  For example, Environmental Programs & Management (EPM) funding for CSS is proposed to be cut by 56% and EPM funding for SHC is proposed to be cut by 51%.

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Related News

5/5/25:  “The net loss of ORD federal employees, onsite grantees and contractors, as well as offsite grantees and contractors contributes to the national toll of scientists and support staff who have, until now, contributed to excellence of the federal research enterprise,” Frey said. “They join tens of thousands of others punished by the administration for doing science.”

5/13/25: “It’s essentially like lobotomizing our agency.” – The Intercept.

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Expressions of Support for ORD

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What Members of Congress are Saying

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Critical Evaluation of EPA Talking Points about Eliminating ORD

According to The Hill, an EPA spokesperson is quoted by “While no decisions have been made yet, we are actively listening to employees at all levels to gather ideas on how to better fulfill agency statutory obligations, increase efficiency, and ensure the EPA is as up-to-date and effective as ever” (bold added).  So, this sounds really good, right?

Wrong.

Question 1:  Is EPA really actively listening to employees at all levels?

Answer:  No.  There is no transparent or inclusive process by which career employees were involved in formulating the proposal to eliminate ORD.

Question 2: Will eliminating ORD help EPA better fulfill agency statutory obligations?

Answer: No. EPA’s statutory obligations include developing and making use of the best available science to inform decisions. Firing 50% to 75% of ORD staff, as reported by the NYT, would not enhance EPA’s ability to do so. Rather, it knee-caps that ability.

Question 3:  Will eliminating ORD increase efficiency?

Answer:  No. There are many explanations to this question:

ORD itself represents efficiency.  ORD combines EPA research functions into one organization to avoid duplication of effort with regard to research administration, support staff, facilities, processes, and procedures.

ORD reorganized itself in 2019 to reduce the number of internal units and managers and to increase the ratio of staff to manager.  Thus, ORD is already an efficient organization.  While improvements may be possible, such improvements (if any) would be surgical.

The residual staff currently in ORD who would not be fired would be shuffled off to other parts of the agency.  This creates the inefficiency of duplicating whatever scientific research functions would remain over multiple program offices.

“efficiency” isn’t the only question, whatever the Agency spokesperson may think “efficiency” means. What about credibility?  Moving scientists formerly in the independent ORD into policy shops, that focus on making policy, risks interference that biases the science.

Question 4:  Will eliminating ORD ensure the EPA is as up-to-date and effective as ever?

Answer:  No.

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