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.
This publication is designed to provide general information on pertinent legal topics. The statements made are provided for educational purposes only. They do not constitute legal or financial advice nor do they necessarily reflect the views of Holland & Hart LLP or any of its attorneys other than the author(s). This publication is not intended to create an attorney-client relationship between you and Holland & Hart LLP. Substantive changes in the law subsequent to the date of this publication might affect the analysis or commentary. Similarly, the analysis may differ depending on the jurisdiction or circumstances. If you have specific questions as to the application of the law to your activities, you should seek the advice of your legal counsel.