13. Environmental Protection Agency · Minor
Require OAR approval before regional air enforcement actions
Printed page 428 13. Environmental Protection Agency
“Require regional air offices to receive approval from OAR before moving forward with enforcement actions in order to ensure that enforcement is meeting the requirements established by regulations and is not going beyond them.”
What has happened
- Not started
Regional air offices still do not need the air office's sign-off. EPA did add a headquarters check in March 2025: an enforcement memorandum to every regional administrator requires advance approval from the Assistant Administrator for Enforcement and Compliance Assurance before an enforcement action that would shut down or significantly disrupt energy production or power generation, and concurrence for actions resting on cumulative pollution risk. That approval runs through the enforcement office, not the Office of Air and Radiation, and it is limited to energy-related cases rather than to whether enforcement is going beyond the regulations.
Research log
What was searched, and what didn’t count as evidence
Research notes
- The March 2025 enforcement memorandum is the closest instrument and it routes approvals to the wrong office. It requires advance approval or concurrence from the Assistant Administrator for the Office of Enforcement and Compliance Assurance — the enforcement office the Mandate wants abolished at #1044 — for enforcement that would shut down or significantly disrupt energy production or power generation, and for actions resting on cumulative pollution risk. The Quote asks for approval by the Office of Air and Radiation, the standard-setting office.
- Progress is measured on this ask: a headquarters check that runs through a different office, and only for energy-related matters, is not the one the Quote describes. The memorandum is on the event as Evidence so a reader can see what does exist.
- Action
- restrict
- Object
- regional air office enforcement actions
- ID
- 1104