In late July, Secretary of Agriculture Brooke Rollins released a memo previewing the Trump administration’s plan to “reorganize” the US Department of Agriculture (USDA). Though details are sparse, the plan would relocate most USDA staff currently working in Washington, DC, and its suburbs to as-yet undisclosed locations, as well as vacating a major USDA building in DC and a research facility in Maryland, presumably as a prelude to the administration selling them off. These moves would further disrupt services that farmers and consumers rely on while hollowing out the agency’s scientific capacity.
Rollins designated her deputy, Stephen Vaden, to fill in the details and implement the plan. Not coincidentally, Vaden presided over a damaging, discriminatory, and likely illegal relocation of USDA research staff in the first Trump administration in 2019, when he was the department’s General Counsel. The USDA cannot afford a repeat of that debacle.
Already, Rollins has done serious damage in just over six months. After giving a speech to employees about public service on her first day at the USDA back in February, she made a mockery of those words, canceling grants, burying science, and abetting Elon Musk and the so-called Department of Government Efficiency in driving out more than 16,000 USDA employees. A recent White House budget request, if passed by Congress, would cut billions from the USDA, further chipping away at its ability to support farmers, protect our food supply, and ensure that everyone in this country can eat.
With this reorganization plan, Rollins seems committed to finishing the job of dismantling the department she is supposed to serve.
Of course, all of this isn’t happening in isolation. Across the government, the Trump administration has been cutting other valuable government functions indiscriminately and treating highly skilled federal employees as “waste” to be eliminated from agency balance sheets. At the Union of Concerned Scientists, we’ve written about how we’re all put at risk from efforts to fire scientists and dismantle science at the Environmental Protection Agency and the National Oceanic and Atmospheric Administration. Now it’s apparently the USDA’s turn to take the hit.
After stakeholders including members of Congress from both parties reacted to the Rollins reorganization memo with surprise and alarm, she indicated that the department would accept public comments on the plan through late August. It appeared to be an afterthought, and it bypassed the normal notice and comment requirements of the Administrative Procedure Act. Senators have continued to object to the rushed and secretive nature of the process and have called for more time and transparency for public review and input. The USDA quietly extended the comment deadline to September 30, but comments from stakeholders—likely including many Big Ag corporations and lobby groups—remain hidden from public view.
Although the USDA’s invitation for feedback appears more symbolic than substantive, we submitted the following comments and are sharing them here to put our concerns on record.
August 26, 2025
The Honorable Stephen Vaden
Deputy Secretary of Agriculture
U.S. Department of Agriculture
1400 Independence Ave SW
Washington, DC 20250
Dear Deputy Secretary Vaden:
On behalf of the Union of Concerned Scientists (UCS) and its more than 600,000 supporters nationwide, I am writing to comment on the USDA reorganization plan laid out by Secretary of Agriculture Brooke Rollins in Secretary Memorandum: SM 1078-015on July 24, 2025.
We urge USDA to:
- Withdraw SM 1078-015 and suspend further staff relocations or reductions in force.
- Engage stakeholders transparently, including Congress, farmers, and USDA employees, in any future reorganization discussions.
- Prioritize mission-critical capacity—including science, technical assistance, and inspection—over arbitrary cuts.
Farmers, rural communities, and consumers depend on USDA’s expertise. Relocations that drive out seasoned scientists and other skilled staff weaken the department’s capacity, undermine its mission, and shortchange taxpayers. We urge you to change course before more damage is done.
UCS is a national science-based non-profit organization working for a healthy environment and a safer world. We combine independent scientific research and citizen action to develop innovative, practical solutions to secure responsible changes in government policy, corporate practices, and consumer choices.
We value the mission of the USDA to support farmers, protect our food supply, and ensure that everyone in this country can eat, and we are troubled by the likelihood that this reorganization will undermine that mission by driving out scientists and other dedicated public servants.
Prior forced relocations of USDA staff hurt the department and its mission
In her confirmation hearing, Secretary Rollins told the Senate Committee on Agriculture, Nutrition, and Forestry that “[a]ll Americans are important. But the farmer . . . is the American important to all Americans.” And in a speech to USDA employees on her first day on the job, she spoke about the principles of public service that she valued in USDA employees, and that would guide her leadership of the department. However, this reorganization plan is not in keeping with those statements.
Public service requires public servants. Yet by mid-April, as many as 16,000 of those public servants—more than one in six USDA employees—had reportedly departed. Many were illegally fired, some were reinstated under court order but expected to be fired again, and after all this chaos and reported abuse, many thousands reluctantly resigned under so-called deferred resignation programs (DRPs). Despite the magnitude of these losses, the forced relocations at the heart of this reorganization plan appear designed to drive thousands more public servants out of the department.
As you know, there is ample evidence of this from your time as USDA General Counsel in the first Trump administration. In 2019, you and then-Secretary of Agriculture Sonny Perdue carried out an abrupt relocation of scientists and staff at the USDA’s two science agencies—the Economic Research Service (ERS) and the National Institute of Food and Agriculture (NIFA)—from USDA headquarters in DC to Kansas City, Missouri. Chaos ensued, as documented by a report from the USDA’s own inspector general and two others from the Government Accountability Office (here and here): the relocation violated the law, was based on faulty data, and ultimately hobbled these science agencies, as some 75% of their employees eventually left their jobs rather than uproot their lives and families. The USDA lost hundreds of experienced scientists, spending millions at the expense of taxpayers and farmers who count on USDA services, with little to no benefit.
That relocation was clearly not planned with the needs of USDA science, farmers or taxpayers in mind; it squandered millions of dollars and stalled hundreds of important studies and grants. It was a serious setback for science and taxpayers, and a disservice to the farmers, rural communities, and consumers the USDA serves. Yet now, the reorganization plan Secretary Rollins has tasked you with implementing seems to double down on this past grievous error.
Gutting the USDA’s staff (again) is bad for farmers and all Americans
Secretary Rollins told the Wall Street Journal in April that proposed job cuts would not disrupt services—for example, reporting and forecasting about the farm economy—that farmers rely on. But how can it not? Empty chairs don’t crunch data. They also do not:
- Help farmers make climate-informed planting decisions—The USDA’s Climate Hubs provide much needed regionalized research and technical assistance for farmers facing increased climate challenges. Combined with the president’s budget proposal, which would zero out funding for these centers, further staff losses would harm farmers’ efforts to increase their resilience and protect future harvests.
- Keep invasive crop pests away from US farms—As many as 700 employees of the USDA’s Plant Protection and Quarantine division had departed by mid-April. These scientists, skilled workers, and senior administrators were tasked with inspecting fruit and vegetable shipments to intercept foreign pests and acting to limit damage from pests already present on US farms and forest land.
- Detect and limit new bird flu outbreaks—The layoff of scientists, inspectors, and critical office staff in early 2025 proved to be ill-conceived and damaging for the implementation of Secretary Rollins’ strategy to curb avian influenza as several fired employees were essential to her plan and needed to be rehired. The USDA is still leading the battle against the avian influenza strain that reached the United States in 2022 and further disruptions to staffing would impair their ability to respond to new threats.
- Inspect our food for safety—By early May, 555 employees at the USDA’s Food Safety and Inspection Service had accepted a deferred resignation offer. These highly trained public servants were responsible for ensuring the safety of our meat, poultry, and egg products through inspections at slaughtering and packaging establishments.
Just as with the administration’s dangerous cuts to public health and medical research, all of this amounts to self-sabotage. Secretary Rollins herself seemed, albeit belatedly, to understand that when she sent urgent emails in April to some employees who had accepted, or were considering, early resignation under the latest DRP, asking them to reconsider.
With the current reorganization memo, the Secretary seems to be reversing course again and indicating that maintaining mission-critical staff is not a priority of the administration.
Conclusion
US farmers and consumers already face substantial uncertainty as a result of global trade chaos, worker deportations, rising costs for farm inputs and food, and a climate crisis that the administration seems determined to deny. As we have noted above, too many USDA scientists and staff have already been driven from their important jobs helping farmers and the public navigate these challenges.
The USDA can ill afford another exodus of talented public servants. Further losses will undermine the agency’s ability to provide vital programs and technical support to farmers and rural communities who need them, at a time when their ability to stay afloat is already strained. We urge USDA to change course.
Sincerely,
Karen Perry Stillerman
Deputy Director, Food and Environment Program
Union of Concerned Scientists