Opinion by Judge SCHWARZER; Dissent by Judge KLEINFELD

John Foss, a Civil Service employee with the Indian Health Service (IHS), lost his job during a reduction in force (RIF). He complained of discrimination on the basis of race, sex, and age when his position was abolished and he failed to obtain another position through the Civil Service bumping process. After unsuccessfully challenging his separation from federal service before the Merit System Protection Board (MSPB) and appealing his discrimination claims to the Equal Employment Opportunity Commission (EEOC), Foss filed this action in the district court. We must decide whether the district court correctly granted summary judgment on the ground that Foss failed to make a prima facie case of sex, race, or age discrimination.

STATEMENT OF FACTS

At the time of his separation, Foss was a sixty-two year old white male employed for more than twenty years as a social worker at the IHS’s Portland Area Office (PAO). In 1996, the PAO planned a reorganization responsive to federal administrative reduction directives and tribal contracting and compacting. As a part of the reorganization, the PAO planned a RIF which would eventually abolish five Civil Service positions. One of those positions was Foss’s social worker position, some of its functions having been assumed by the business office and others being no longer required. In February 1996, Foss received a notice from the PAO that he would be separated from federal service as a result of the RIF.

In compliance with RIF regulations, the PAO created a retention register which listed all Civil Service employees’ competitive levels and service computation dates (seniority), and accounted for excepted service tenure groups and Indian preferences. Because Foss, a GS-0185-12 Social Worker, was the only person in his competitive level, abolition of his position released him from his competitive level.

During a RIF, a person whose position is abolished has a right to bump into a position for which he is qualified if the position is held by another person less senior. Foss sought to bump into Martha Stuker’s position. Her position, created in 1990, was classified in 1993 as a Managed Care Coordinator/Nurse Specialist. The applicable job'description stated that “[i]t is desirable that the incumbent possess a minimum of [a] Bachelor of Science in Nursing degree.” Because Foss did not have a nursing degree, the PAO denied his request to bump Stuker. 1

In April 1996, Foss received notice of his separation from employment. Two other employees also were separated in the RIF: Richard Palmer, a Native American man, and Michelle Stevens, a Native American woman. J. Mike Wood, a Native American man, also held a position that was abolished. He avoided separation by applying for a vacant position at a lower Civil Service grade. Foss sought only assignment to the two positions described above and did not apply for a vacant position.

PROCEDURAL BACKGROUND

Foss filed a complaint with the MSPB. An Administrative Law Judge affirmed the agency’s action, and the MSPB denied Foss’s petition for review. Foss appealed his discrimination claims to the EEOC, which rejected them. Foss then filed the instant action in the district court and the court granted defendant’s motion for summary judgment. We have jurisdiction of the appeal pursuant to 28 U.S.C. § 1331 and 28 U.S.C. § 1291 and affirm.

We review the summary judgment de novo. See Washington v. Garrett, 10 F.3d 1421, 1428 (9th Cir.1993). Viewing the evidence in the light most favorable to Foss we must determine whether there *1134 exists any genuine issue of material fact and whether the district court correctly applied the relevant substantive law. See id.

DISCUSSION

I. DELEGATION OF AUTHORITY

The district court upheld the decision of the MSPB as not arbitrary or capricious and supported by substantial evidence. Foss does not challenge that ruling. On appeal he contends only that the PAO exceeded its delegation of authority when it separated Foss without giving the agency headquarters the thirty days’ notice required by the delegation letter. Because he did not raise this issue in the district court, we will not for the first time consider it on appeal. See Marbled Murrelet v. Babbitt, 83 F.3d 1060, 1063 (9th Cir.1996).

II. DISPARATE TREATMENT BASED ON RACE AND AGE

Foss contends that he produced evidence showing that the PAO intentionally discriminated against him on the basis of race and age. First, Foss asserts that the PAO placed a similarly situated Indian male, J. Mike Wood, in a vacant position and, second, that he was denied his election for an early buy-out by a manager who knew his position would be abolished.

With respect to the first claim, Foss concedes that he did not seek any position other than the two described above. Wood, in contrast, applied for and was assigned a vacant position. The transfer required Wood to take a demotion from GS-14 to GS-13. Foss, who was only a GS-12, was not eligible for the position taken by Wood and concedes that the two men were not competitors for that position. What Foss’s claim comes down to is that he, unlike Wood who was a Native American, was not told that he could apply for a vacant position. But Foss does not contend, and there is no evidence, that information about vacant positions was not available to the employees and that he himself had no knowledge of them.

As for the early buy-out claim, Foss submitted an application a year before the RIF. The evidence, viewed in the light most favorable to Foss, establishes that Daniel Madrano, who was in charge of personnel, told him headquarters had turned down his request but that Madrano did not know why. Any inference that the decision was motivated by age or race animus would be pure speculation.

Because Foss has presented no facts to indicate that others outside of his protected class were treated more favorably, he has failed to make out a prima facie case of age or race discrimination. Cf Garrett, 10 F.3d at 1434 .

III.GENDER DISCRIMINATION

A Disparate Impact

The PAO denied Foss’s request to bump into the Managed Care Coordinator position occupied by Martha Stuker because he did not possess a nursing degree. Foss contends, first, that because men are statistically less likely to have a nursing degree than women, the requirement has a disproportionately negative impact on men, and, second, that the nursing degree requirement is unnecessary for the position. Because his first contention fails to support a prima facie case, we do not reach the second.

The district court, while acknowledging that the majority of nurses are women, held that the proper analysis turns on the percentage of men and women who are otherwise qualified but lack a nursing degree. It found that because Foss failed to come forward with the requisite statistics, he did not make out a prima facie case.

We agree with the district court’s analysis. It is well established that to make out a prima face case of disparate impact, the proper comparison is based on the “composition of the qualified ... population in the relevant labor market.” Wards Cove Packing Co. v. Atonio, 490 U.S. 642, 650 , 109 S.Ct. 2115 , 104 L.Ed.2d 733 (1989) (alteration in original) (quoting *1135 Hazelwood Sch. Dist. v. United States, 433 U.S. 299, 308 , 97 S.Ct. 2736 , 53 L.Ed.2d 768 (1977)); see also New York City Transit Authority v. Beazer, 440 U.S. 568, 585-86 , 99 S.Ct. 1355 , 59 L.Ed.2d 587 (1979) (rejecting plaintiffs’ statistic because “it tells us nothing about the class of otherwise-qualified applicants and employees”); Moore v. Hughes Helicopters, Inc., 708 F.2d 475, 482-83 (9th Cir.1983) (“If special skills are required for a job, the proxy pool must be that of the local labor force possessing the requisite skills.”); Cerrato v. San Francisco Cmty. Coll. Dist., 26 F.3d 968, 976-77 (9th Cir.1994). While Dothard v. Rawlinson, 433 U.S. 321 , 97 S.Ct. 2720 , 53 L.Ed.2d 786 (1977), accepted general population statistics as evidence of the discriminatory impact of height and weight requirements on women, the Court later noted that evidence showing that such figures might not accurately reflect the pool of qualified job applicants undermines the significance of such figures. Beazer, 440 U.S. at 586 n. 29, 99 S.Ct. 1355 .

Foss does not directly address this issue on appeal. In his brief he argues that approximately 90% of IHS employees on GS levels 4 through 17 in the 610 Nurse series were females; in the levels eligible to bump into the position, approximately 91% were females. He concludes that the nursing degree requirement makes it “highly unlikely” that the person bumping into the position would be male. Foss’s showing, however, leaves it conjectural whether among the pool of those qualified for the Managed Care Coordinator position, the gender disparity resulting from the nursing degree requirement would be sufficiently significant to support a prima facie case. See Bouman v. Block, 940 F.2d 1211, 1225 (9th Cir.1991). Foss also contends that he himself was qualified (but for the lack of a nursing degree) but his qualification is not relevant to the issue. Finally, he argues that the only qualification needed to bump into the position was a GS-12 to GS-15 rating, but the argument is belied by the Managed Care Coordinator position description, which recites the extensive knowledge and experience requirements.

B. Disparate Treatment

Foss also contends that the nursing degree requirement was specifically imposed to discriminate against him. The requirement was added in 1993 when the position was advertised to replace its first occupant, who was a nurse. This action took place three years before the RIF, without reference to Foss or any other male applicant for the job. Thus, the PAO’s action raises no inference of discriminatory animus.

CONCLUSION

For the reasons stated, the judgment is affirmed.

AFFIRMED.

. The PAO also denied Foss’s request to bump into Susan Sheoships' position of Business Office Manager. Foss concedes that Sheo-ships had seniority over him and does not challenge this decision.