1. A week or so after the brutal shock of the 2016 election, I ran into someone I will call Frank. It was a chance meeting in the lively Washington plaza shared by the EPA headquarters, where Frank was a career employee, and the Woodrow Wilson International Center for Scholars, where I work on climate issues. I knew Frank from my stint at EPA years before. It wasn’t long before we began commiserating about the election. It wasn’t long after that that we began to speculate about what this new administration might do to EPA. And that made us start to think about how to fight back.

Donald Trump and people in his circle had made clear their antagonism toward environmental protection. They were intent on shredding EPA. They had not yet appointed then-Oklahoma Attorney General Scott Pruitt (who described himself as the “leading advocate against the EPA’s activist agenda”) as administrator, but their transition team, particularly Myron Ebell from the Competitive Enterprise Institute, clearly were not sympathetic to environmental regulation.

Anticipating, as we all did, rough going for EPA, Frank said it was time to revive a Reagan-era effort called “Save EPA.” He had been among the career EPA staff who quietly participated in a 1980-82 behind-the-scenes effort to build support, particularly on Capitol Hill, to protect EPA from that era’s full-frontal attack.

By the time we reached the next turn in our routes, ideas were forming in my mind. Similar thoughts were lighting up the vast network of retired and former EPA career staff.

By January 27, 2017, only a few days after the inauguration, a group composed mostly of former EPA career staff and others from the DC environmental community met in my living room to discuss creating an organized response to Trump. The expertise in the room represented many hundreds of years of EPA experience, notably including Terry Davies, who in 1970, as a consultant to President Nixon’s Advisory Council on Executive Organization, co-authored the plan that created EPA. Terry had last worked at EPA in the first Bush Administration. His deep commitment to the agency and its mission, like that of everyone who showed up for that meeting, had not wavered in the intervening years.

That meeting started a dialogue about how best a group with our background and expertise could act to protect EPA. The result was the creation of the Environmental Protection Network.

Sadly, our fears were entirely justified. Over the next four years, career staff at EPA were effectively shut out of agency decision-making, and the Trump appointees sought to implement a series of mistaken policies undercutting EPA’s role as steward of clean air and clean water for the American public. And Trump’s assault on government went well beyond EPA: Professionals at the State Department, the Department of Justice, the Agriculture Department, all across the government, were marginalized and excluded.

Americans who were appalled by the new Administration’s policies resisted in many different ways. EPN, which I helped form, used information strategically. Intimate knowledge and experience with EPA were deployed to fact-check the Trump version of environmental protection and to defend the integrity of the agency and its personnel. We provided this information to reporters, environmental organizations, and Capitol Hill. And we ended up playing a significant role in illuminating the Trump Administration’s wrecking-ball approach to environmental protection and distaste toward a well-functioning federal government. Within months of that first meeting, we would shine an informed light on the implications of the Trump Administration’s budget plans for EPA. Later, our cadre of retired EPA science gurus led the charge when Trump’s appointees tried to slim the role of informed science in EPA decision-making. The Trump Administration is thankfully in the past, but it is not beyond imagination that these attacks could start again. What we did, our theory of change, can offer lessons for future efforts to protect the integrity of government action, particularly if there is a need to defend other specialized, technical, science-based units of government.

EPA Basics—How Environmental Protection Gets Done

Defending, or even explaining, environmental protection is hard because it involves many highly technical issues. Congress tasked EPA to manage a variety of laws that protect air, water, and land. Pollution is ubiquitous, an across-the-board threat, albeit often worse in low-income communities. It is EPA’s job to contain, as best as possible, the threats posed by pollution to human health and the natural world. This means controlling contamination that finds its way to air and water; mitigating the harm from the application of pesticides and use of toxic substances; managing the disposal of waste; and restoring land poisoned by earlier bad practices.

Like many laws emerging from Congress, environmental laws are at the same time both very specific and quite unclear. They require interpretation when applied to specific situations. Each of those interpretations is likely to be challenged in the courts or questioned by Congress because ultimately, there is a cost, either in human health or because someone must invest to install and run pollution control equipment or to clean up a dirty industrial site.

To carry out this huge mandate, the agency is staffed with people in almost every imaginable relevant specialization—from engineers to toxicologists to epidemiologists, along with the usual array of lawyers, economists, and managers. And then, rotating in and out depending on who is elected President, political appointees join for a relatively limited time to manage and direct the overall process.

Daily work at EPA was and is very technical and specialized. An expert at EPA might spend her entire career working on a particular provision of the Clean Air Act. There may be no other person in the United States who understands that particular provision as deeply and fully. And yet that air expert may have little or no contact with or understanding of how, for example, the water authorities are managed.

One major task assigned to EPA by Congress is to write regulations implementing the basic laws. For example, the Clean Water Act requires entities discharging wastewater to use the “best available technology” that is “economically achievable.” EPA experts must design regulations that fit the multiple realities of a diverse group of dischargers. The kinds of pollutants, the amounts, how they are produced, and where they end up can be entirely different across the industrial spectrum. Separate standards must be developed for synthetic rubber manufacturers, for example, as opposed to the pharmaceutical sector. This is an arduous process that can take years to complete. The results are routinely subject to legal challenge and sometimes political pushback.

After that, EPA or a state that has demonstrated its willingness and capacity to take primary responsibility for implementing EPA programs must write permits to connect the requirements with specific facilities. A permit for water discharges from a plant manufacturing paint will look very different from a permit for a copper mine. This is by no means a pro forma duty; it requires a deep understanding of the industry, of available technology to control the pollutants, of the law and regulations, and of the very process of issuing permits. The people writing the permits must consider factors like the age of the equipment and facilities involved, manufacturing processes, how various control technologies are engineered, costs, and more. None of this is easy. And EPA, in partnership with states, is responsible for enforcing the rules—another set of complex functions involving lawyers and scientists. Enforcement is never popular. Polluters chafe at being caught. Communities that bear the brunt of the bad air or water press for more aggressive action. And it can be tedious, detailed work.

This isn’t all that EPA staff does, but it’s a representative chunk of it. This heavy lift requires continuity and stability, which have mostly held through EPA’s existence. Career employees take direction from political appointees, but with the exception of the Trump era, there is a genuine give-and-take between temporary and permanent staff. Most political appointees understand and appreciate the expertise and institutional memory that career staffers bring to the process. Despite the significant challenges inherent in any process of environmental management, EPA worked steadily along even as leadership rotated from party to party. When corrected by courts or by Congress, everyone took a deep breath, regrouped, and continued to do their job.

All this is to give some context to the disconnect between EPA’s understanding of itself and its mandate and the apparent decline in public support, fed especially by Republican rhetoric that environmental threats are an economic burden and liberal bogeyman.

A widening gulf between, on the one hand, a lot of people who took clean air and clean water for granted and, on the other, those who began to develop an unease around government regulation has much to do with our current quandary. At its 1970 start, EPA enjoyed a halo effect. The pollution it battled was obvious and highly visible. The results of regulation were easy to understand. Over time, people became accustomed to a relatively clean environment. EPA moved from a somewhat revolutionary idea to the new normal.

Today’s environmental threats are equally dangerous but mostly only understood through science and complex data. Instead of the terrible air that residents of Pittsburgh and Los Angeles could literally see and then rightly connect with the uncomfortable tightness in their chests, pollution today is associated with invisible particulate matter that will cause health effects years later, or with parts per million concentrations of greenhouse gases that will make the world gradually less habitable over the coming decades.

And over time, regulated industries and businesses became more aggressive in challenging EPA and putting up a fight to ward off controls. There is an imbalance rooted in the reality that the costs of controls are particular and placed on the polluter, while the benefits are more general, spread around the general public and often relatively invisible. Perhaps as a result, the louder, more insistent voices these days are not the communities, like Love Canal, that were flooded with toxic waste. They are the industries that must put controls in place or the farmers and ranchers who must change long-standing practices in order to keep animal waste and fertilizer run-off from harming the rivers and creeks that eventually provide drinking water to distant cities.

No one has argued this system is perfect. The laws are flawed because they emerged from congressional compromises. The process of applying those laws routinely requires years of effort and a molasses-slow process of developing consensus. EPA was tasked with making unenviable decisions, for example: How much exposure to a particular chemical is okay, and how much is risky? It’s an extended minuet dictated by the procedural formalities of the Administrative Procedure Act and, ultimately, by how democracy itself works, but it’s the best we’ve got.

Into this snarl of contradictions stepped the Trump Administration. In one candidate debate, Trump called EPA the enemy, promising, “We are going to get rid of it in almost every form.” Once elected, the new White House took direct aim at EPA.

Putting EPN on the Map

The Trump Administration presented a dramatic inflection point. The normal transition from administration to administration is one of degree. Some administrations were more aggressive; others more cautious. Reagan’s initial attempt to tamp down EPA ended in scandal and was resolved when Bill Ruckelshaus, who had been the agency’s first administrator in the early 1970s and was highly respected in the environmental community, agreed to return for a second term. Even Reagan’s first set of EPA appointees were a more mixed group, some hostile, some just on the conservative side of mainline environmental debates. In contrast, from the moment they named a transition team hostile to the agency, the Trump Administration signaled outright antagonism and a general distaste for government. Environmental protection ceased to be a bipartisan objective. This was the situation that EPN, a minimally resourced organization dependent almost entirely on volunteer labor, without any national base, was envisioned to address.

The first step was to figure out how best to proceed in an unprecedented situation. How could we be effective while staying true to our skills and experience? EPN built its power by understanding that public advocacy was a distinct skill that was not taught or even valued at EPA. What was valued at EPA was deep knowledge about the vast, complicated responsibilities that Congress entrusted to the agency.

As a result, EPN did something absolutely unique. We drew on that reservoir of information and institutional history, on volunteers who could speak very specifically to the untruths and unsubstantiated regulatory proposals presented by the Trump EPA. If the Trump Administration said its objective was to improve “transparency” in the science that EPA relied on to make rules, EPN could explain the lie behind that mesmerizing word. If Trump’s EPA said that its proposed actions were improving the health and safety of the American public, or that its actions were supported by legal authority, we could authoritatively explain when they were not.

In normal times, the debate that led to reasoned answers to questions about EPA’s broad, deeply technical, and complex responsibilities could take place within EPA in an ongoing dialogue that involved career staff and political appointees. Congressional staffers, the press, and the world in general could be sure that someone would officially or unofficially answer the phone when they needed information. That changed when the Trump Administration handcuffed and muzzled career staff at EPA. Under Trump, career personnel were excluded from the decision-making process and put in fear for the future of their careers. EPN’s volunteers stepped in to fill the void, to become that accessible repository of essential information.

Our first plunge into this role came when the Trump Administration proposed its first budget in March 2017. Before EPN, EPA’s annual budget process was an inside game; even EPA’s outside supporters shied away from the details. Why is debatable, but one can surmise that budgets (and numbers in general) are pedestrian, not compelling to funders or, in normal times, likely to generate headlines. And even before Trump, EPA’s appropriation was steadily declining in real terms. Trump’s first budget would have put that decline on steroids, cutting EPA’s funding by 31 percent, or $2.6 billion, from its then level of $8.2 billion. EPN stepped into the breach. We launched a deep dive into the EPA budget process, led by volunteers who had worked in the part of EPA that manages the arcana of the budget. We were able to make some subtle but critically important points. Notably, we drew attention to the importance of looking at the component parts of the appropriation, not just the total number or bottom line. This is because often the pot intended for the agency is diverted to specific activities favored by a particular representative or senator. These were generally important environmental efforts, but what EPA really needed (and where it had no natural advocates or supporters) was core support, and not just funding for, for example, protecting and restoring the Great Lakes or the Chesapeake Bay. EPA needed robust and sustained support to carry out its rule-making responsibilities, to enforce, and to do the science that was the core of its decision-making.

This was a great message, but we had no obvious platform for sharing it. Getting our insights out to the right audiences the first time required ingenuity. The Combined Defense Project, a then under-the-radar coalition of the major, well-funded environmental organizations, came to the rescue with press contacts that we added to my personal list of journalists. Our first outreach was a phone-based press conference, using their platform, to share what we had learned. It attracted a lot of attention in the environmental community and put EPN on the map.

EPN’s biggest continuous success would be as a resource to journalists, a substitute for access to the agency itself. Our initial challenge was to convince journalists and green groups that EPN could be a resource—or even to let them know that the network existed. This involved many one-on-one conversations on the phone and in coffee shops, mining my and other founders’ sets of contacts and networking toward new ones, all to explain who the EPN volunteers were and what they had to offer. Inevitably, my pitch included our compelling origin story: that we were a temporary organization, there to address what we all hoped would be a temporary situation. I felt this signaled that we were there to be partners, not rivals, to the longstanding green groups.

As our reputation and credibility grew, we no longer needed the help of established groups to access the press. Reporters started coming directly to us, and we grew a communications Rolodex. Later, with funding from individuals and philanthropic foundations, EPN hired a communications consultant who, along with an EPN volunteer who had expertly managed public outreach for one of EPA’s regional offices, brokered relationships with newspapers and other media organizations and shopped stories.

When it became clear that everything EPA had accomplished was under siege, there was a sudden demand for details about programs that had previously faded into the woodwork. In normal times, there were rarely stories about the Superfund program in the national news. But if Superfund was rumored to be under threat, suddenly the purpose and history of the program assumed a new level of urgency. EPN drew on the professionals who had set up the many EPA programs, and run them, to provide tutorials that became background to critically important reporting.

Defending Science at EPA

If there was a single issue where we had the greatest impact, it was likely in the defense of unbiased science at EPA. Science at EPA was one of the background functions everyone, including reporters and the green groups, had long taken for granted—until Trump’s second EPA administrator, Andrew Wheeler, tried to dismantle it. Among other things, he and his predecessor, Scott Pruitt, tried to stack the decks at science advisory boards by adding industry-biased members and marginalizing the independent scientists, proposed to reduce the advisory role of those boards, and tried to exclude from consideration in agency decision-making significant scientific studies that were inconvenient for various industries.

We fought these attacks on many fronts, but two examples will suffice. One was our support for congressional staffers. Almost from the beginning, under the leadership of an EPN volunteer with considerable Capitol Hill experience, we offered our expertise to Republicans and Democrats on the Hill. Only Democrats responded. Interest in what we had to offer ramped up significantly when the 2018 midterms were in sight and Democrats saw that they might reclaim the House. House Democratic staffers, particularly on the Energy and Commerce Committee and the Science Committee, asked us to visit.

This led to committee brainstorming meetings with our experts, who had been watching with horror the decimation of their decades of embedding good independent science at EPA. All that preparation was quickly put to work when Democrats swept the midterms and assumed leadership in House committees. The majority was then able to hold hearings and call witnesses. A highlight was a June 2019 hearing featuring four former administrators—one from a Democratic administration, three from Republican ones—who had served in normal times. EPN had rounded them up and facilitated a joint public letter with more of their fellow ex-administrators. They spotlighted the importance of science in EPA decision-making and the dangers of the Wheeler approach.

The second involved a rule-making that both Pruitt and Wheeler pursued to undermine independent science in EPA decision-making. For years, industry had fought EPA’s reliance on devastating epidemiological studies that documented the health impacts of air pollution. Industry argued that the research should be excluded unless the underlying raw data was made publicly available. Of course, the data included the medical records of patients who had been guaranteed confidentiality and could suffer real-life consequences if their personal information was made public. EPN volunteers who had been science leaders during their EPA tenure provided significant leadership, showing how Wheeler’s rule-making was essentially doing the bidding of industry, which was trying to avoid responsibility for two pollutants—lead and fine particulate matter—that aggravate childhood asthma and cause chronic lung and cardiac disease.

It would take the length of a book to give full justice to the drama of this fight and all of its nuances. The short story is that the 127 pages of detailed criticisms of the Wheeler proposal that our volunteers filed to the rule-making docket were rooted in decades of intimate experience with this very issue. They demolished Wheeler’s rationale—and proved influential with our many environmental and health organization partners. Those same EPN volunteers stepped forward to testify in public hearings, write op-eds (including one that made it into The New York Times), and brief reporters. The upshot was that a formerly obscure EPA function—unbiased science—got written up in major publications.

Fortunately, Wheeler was sloppy in his handling of the issue. The rule-making was legally weak and procedurally defective. As always, Wheeler’s cronies failed to consult with career staff, who could have kept them out of trouble. The final rule was immediately challenged in court. A federal district court quickly ruled that EPA’s process was legally shaky and hinted strongly that the rule would fail also on substantive grounds. Thus ended the Pruitt-Wheeler effort to deliver a knock-out punch to science as an essential underpinning to EPA action.

This issue played directly to the strengths of our organization, drawing on volunteers who spent decades directing EPA science and the lawyers who represented them.

How Does a Tiny, Unfunded Organization “Defend” EPA?

For a volunteer organization born almost overnight, the path was never going to be easy. One challenge was straightforward: We needed resources. We needed people reliably to track down the appropriate expertise when a reporter’s request came in; to be available to answer phone inquiries that could come in at any time of the day or night; to maintain the website; to proofread and format multipage comments on rule-makings; and to monitor work so that deadlines were met. The way to do this is to hire a small core staff. That requires money and the expertise to find and develop funders, something which government experience does not remotely provide. In the government, there will almost always be money—the only question is how much or how little. In the NGO world, nothing is guaranteed.

Other challenges had to do with adapting the strengths and skills of our volunteers to a world that was very different from the one where they had achieved great success. Decades of successfully navigating the EPA bureaucracy to get things done and competence in the highly ritualized process of government decision-making do not necessarily train you up for success in the non-governmental organization world or to so publicly support the work of journalists.

EPA employees are accustomed to working in a very hierarchical format, at a deliberate pace. But immediate demands required that EPN move quickly, and EPN’s model turned Orwell on its head with the idea that all animals were equal and no pigs were more equal than others. Critically, the EPA pecking order is institutionalized in the General Schedule (GS) and Senior Executive Service (SES) systems, which define the authority and salaries of most federal civilian employees. A GS-15 level employee takes orders from above and not from a GS-14. At the top of the pecking order is the SES. Some formerly high-ranking EPA alumni were offended by getting directions from people who would have been of a lower status had they all still worked in the agency. A few dropped out entirely.

A related problem was the need to come to a unified EPN conclusion in documents that went public. If the task was to produce written comments on a rule proposal, for example, teams of volunteers self-organized, predicated on having the right expertise. Those volunteers could have been at any level when they were government employees. Working out who had the final say when there were differences of opinion proved challenging for people who formerly took issues up the chain for resolution.

We also faced more fundamental questions about what our role was—and, just as critically, what it wasn’t. One of the great temptations from the beginning was to try to rectify poor public understanding and develop a public constituency to support EPA. Historically, EPA has been effectively precluded from using government resources to toot its own horn or influence public opinion. Mainline green groups that should have been natural supporters mostly complained about EPA and sued the agency when its actions were, in their view, too timid. On the other side, industry sued, lobbied, made big campaign contributions, and complained loudly about overreaching “big government.”

As EPN debated its capacities and strategies, a few volunteers wanted to try to reverse the public perception that made EPA a punching bag from all sides. EPN put a toe in those waters by developing short papers that touted the benefits of many little-known EPA programs. These became a resource for journalists, but we lacked the kind of platform, the communication tools, and probably the skills necessary to engage in a nationwide program that could repackage EPA for the disillusioned or the ill-informed.

Similarly, we had to decide what EPN’s role would be when our volunteers interacted with journalists. For instance, when we provided information to journalists who covered the full range of EPA’s responsibilities, EPN was forced to consider whether it should take organizational positions or merely serve as a matchmaker between incoming inquiries and volunteer expertise. And what was EPN’s responsibility if its volunteers fell short? We developed the policy that individuals spoke on their own behalf, not for EPN. But EPN was the source of these experts. If people we put forward as experts erred—by being inaccurate, inflammatory, or partisan, or simply being unprofessional in some way—likely that would affect our reliability as a source. Keeping this balance was a daily challenge.

Ultimately, the trust others had in us was our greatest resource, and one we had to protect carefully. One critical lesson was how hard it was—almost a daily battle—to stick to what we knew best and what made us credible. Take the galloping media interest in climate change. For the most part, EPA does not set broad climate policy. Climate science is largely done elsewhere. What EPA uniquely does is a very boring but necessary job—regulate greenhouse gas emissions. EPN volunteers were understandably passionate about confronting climate change. Holding that line, speaking only on core EPA responsibilities, was part of assuring that EPN retained credibility. But telling a New York Times reporter to ask elsewhere took huge self-control.

Even more fundamentally, it was critical to our credibility that we remained bipartisan and avoided advocacy. Our active volunteers included people who had held Senate confirmation-level positions at the agency in both Democratic and Republican administrations. For a while, we discouraged involvement by Obama Administration veterans for fear of being labeled disgruntled losers. This was a hard line to maintain, and moving forward depended on everyone acting responsibly. For press interactions, we provided limited training and then crossed our fingers.

Lessons for the Next Resistance?

Can this form of resistance happen again, if it becomes necessary? Our experience was encouraging: Starting soon after the 2017 inauguration, we were able to attract volunteers. We sustained the energy through the 2020 election; some continue on with the organization even as EPA normalcy has been restored. We were frugal but we did have sufficient resources. Indeed, often funders sought us out.

But I worry that we had advantages that future movements won’t have. I believe EPN functioned at the level it did because most of us could reasonably hope that Trump was a temporary situation. A second round of Trump, or a Trump alternative who better understands how to work the levers of government, could mean that we have misread our own country, that there is a sustained national appetite for such destructive behavior. This might make it harder to organize, to find people willing to put in the time and effort to fight what might feel like an irreversible tide. Or it might push activists toward a different model of resistance.

We believed in the power of truth. That might be naïve and somewhat old-fashioned as disinformation abounds and the political divide deepens. It was because of this commitment to facts that we invested heavily in the time-consuming process of writing comments to challenge mistaken and poorly documented rule-makings. In taking that on, we assumed that EPA would continue to make decisions based on documented facts and science, and be held to account by reviewing courts. We also assumed that courts would remain sympathetic to the idea that the basic environmental laws are flexible enough to be applied to previously unaddressed environmental challenges that reveal themselves over time.

But the rules as we understood them are changing before our eyes. Now we are learning that the very process of evidence-based decision-making may not survive the scrutiny of a Supreme Court at least suspicious of the powers of the executive branch and perhaps on a warpath to eliminate the administrative state. In EPA v. West Virginia, the Supreme Court, in the words of dissenting Justice Elena Kagan, stripped EPA “of the power Congress gave it to respond” to climate change under the existing Clean Air Act. Despite language that has always been understood to provide EPA with the authority to regulate substances that cause or significantly contribute to air pollution and “may reasonably be anticipated to endanger public health or welfare,” the majority said the “major questions” doctrine compelled them to decide that EPA needed to point to “clear congressional authorization” to address new issues. One doesn’t have to be very cynical to know that the current highly dysfunctional Congress is likely incapable of giving such specific and clear instructions, despite climate change now evolving into what can honestly be characterized as a crisis situation. Given where the Supreme Court is heading these days, the very nature of how EPA and other executive branch regulatory agencies do their work could be radically changed. The kind of expertise we offered could prove far less relevant.

We wanted to make it safe for career civil servants to resume the role they had played over many decades providing expert knowledge and experience to the process of implementing the laws passed by Congress. We thought this was a bedrock principle of how the U.S. government worked. Current reports suggest that some potential Republican presidential candidates (including Trump) are contemplating a plan to make it easier to purge civil servants deemed disloyal to their prospective administrations. If the very existence of an independent civil service is in jeopardy, so is basic environmental protection and perhaps democracy itself.

Inadequate resources could also sink future EPN-like efforts. Funders are a fickle group, but funding is essential. No large foundation ever expressed interest in us in the Trump years, but we did attract a nice mosaic of smaller funders who were imaginative enough to support an untested concept. How funders might respond to EPN 2.0 under changed circumstances is an open question.

Lastly, our efforts were supercharged in the 2018 midterms when Democrats regained the House of Representatives. This burst of excitement—a big psychological boost—opened the door for EPN to collaborate with House committee staffers. In the future, it might not be realistic to expect a legislative cavalry to come in and fix a new set of problems. That could make dreaming—and volunteer recruitment—harder.

Despite clear challenges going forward, I remain confident that another generation will take up this fight if it proves necessary. People generally work for EPA because they believe strongly in its mission, even if they might differ about implementation details; protecting the agency is part of that identity. EPN may well be replicable and modified to meet future needs. In fact, EPN to some extent built on the Reagan-era Save EPA. The approach was different, as was the audience, but Save EPA’s success demonstrated that strategic engagement could make a difference, and EPN confirmed that.

Engagement also had personal benefits. Certainly for me, it proved a therapeutic balm against what might easily have become unrelenting despair. Rather than lament and mourn, the EPN volunteers kept the flame alive and, equally important, helped lay the foundation for the current resurgence. They formed a community, and they signaled to their former colleagues still in the government that they would not be forgotten and that their work ethic and commitment were respected. Continuity has been a hallmark of how EPA functions, and EPN was an important bridge over a temporary break.

I would hope this record of achievement might also stimulate alumni of other federal agencies to engage if their own alma maters come under attack. We have seen how, at critical moments, career staff at agencies like DOJ have stepped up to fight for the rule of law and democratic procedures within the walls of their departments.

EPA was badly beaten up during the Trump years, and not all the scars have healed. For now, for the most part, EPA’s very capable new leadership and its mission-driven career staff can speak for themselves. They are heard and respected by the Biden Administration. The battles today are “normal” battles about forward movement and new evidence, not about overt attacks and retrenchment. EPA will win some and lose others, as it always has.

But if the bosses at EPA once again stack the deck against career staff and the environmental protection enterprise, another generation may consider a fight. Some of what we learned resisting Trump’s assault on environmental protection might prove pertinent, but I fear it could be a struggle of very different dimensions.