Scheduling the James Webb Space Telescope (JWST) requires modeling and minimizing the buildup of angular momentum of the spacecraft. Accounting for momentum management is expected to be a major driver of spacecraft efficiency and lifetime. We develop a heuristic that reduces momentum buildup and show how the heuristic can be used in a simulation of the operations concept for JWST scheduling. Through experimental data we show how the heuristic improves momentum usage while maintaining high spacecraft efficiency on a representative science mission for JWST. Finally, we explore how the momentum heuristic closely mirrors the strategies required to efficiently schedule the Hubble Space Telescope.