Give OGC, not OCIR, the authority to assert EPA legal positions to Congress

Research notes

• One search covered the whole cluster of Office of General Counsel asks on pp. 441–443.
• A search of the EPA Federal Register notices we keep and search for “delegation”, “congressional” or “general counsel” found no delegation-of-authority notice in the window; EPA, unlike the State Department, does not publish its delegations manual changes in the Federal Register.
• Reviewed 2026-09-06; EPA’s Delegations Manual could not be found. Status unchanged. The earlier guess was that the Delegations Manual is withheld from automated reading. That is not the finding. It is not published at all: nine candidate epa.gov addresses do not exist, epa.gov/irmpoli8 — the manual’s old home — now serves the Office of Finance and Administration’s IT/IM directives index, and EPA’s site search is a JavaScript shell returning a byte-identical 12,097-byte page for a real query and a nonsense one, so it cannot even be used to look. The full list of addresses tried and the Federal Register delegation search are written up under #1120, which needs the same document. EPA simply does not publish its delegations manual; DOE, by contrast, publishes a searchable Delegations Library and a Delegations Flowdown.
• What that reading did settle about this ask’s object: OPM’s PLUM listing (data as of 2026-06-15) shows the Office of Congressional and Intergovernmental Relations staffed with an Associate Administrator, a Principal Deputy and five Schedule C advisers, and the Office of General Counsel with a Senate-confirmed General Counsel, a noncareer Principal Deputy and eight career Associate General Counsels including the Cross-Cutting Issues Law Office. Both offices are staffed and neither’s reported position titles say anything about who asserts EPA’s legal positions to Congress, which is what the Quote reallocates. That is a check, not a Status move.