13. Environmental Protection Agency · Minor
Require OGC approval of legal positions taken by Regional Counsel offices
Printed page 442 13. Environmental Protection Agency
“To the extent that legal positions are taken by the ORCs and/or regional staff, they should be coordinated and approved by OGC and the appropriate regional leadership.”
What has happened
- Not started
No approval requirement was published. The Offices of Regional Counsel remain separate from headquarters on OGC's own page, which links to them rather than listing them among its ten law offices, and the FY2026 reorganization addendum contains no OGC or regional-counsel entry. The one headquarters concurrence requirement created in the window is narrower and belongs to a different office: EPA's June 2026 environmental-review guidance reserves to the Associate Administrator for Policy and Regulatory Management the concurrence on regional written comments carrying an unsatisfactory finding under Clean Air Act section 309. That is a policy sign-off on NEPA comments, not OGC approval of regional legal positions.
- About the Office of General Counsel (OGC) — leadership, law offices and the Offices of Regional Counsel
- EPA FY2026 Congressional Justification addendum: EPA Consolidations, Reorganizations, Realignments, or Other Transfer of Resources
- Roles and Responsibilities for NEPA Section 102(2)(C) and CAA § 309 Reviewers — issued by the Office of Policy and Regulatory Management, Federal Activities Division
Research log
What was searched, and what didn’t count as evidence
Research notes
- One negative search covered the Office of General Counsel asks on pp. 441–443.
- The regional environmental-justice action plans the Quote uses as its example are gone with the offices that wrote them (#1043), which removes the occasion for the inconsistency without creating the approval mechanism the Quote asks for.
- Evidence is attached to the not started event so the near miss is visible on the page rather than buried in notes: action on the ask’s subject that does not satisfy it is still cited.
- Action
- restrict
- Object
- legal positions of the Offices of Regional Counsel
- ID
- 1190