Review OGC telework policies and off-site attorney duty stations

Research notes

• One negative search covered the Office of General Counsel asks on pp. 441–443. A Federal Register full-text search of EPA documents for “telework” found none.
• Attempted and not partial: a directive with no documented EPA implementing action is attempted, not partial, and the duty-station half is untouched.
• Checked again 2026-09-06, with a negative result. Status unchanged. EPA publishes no telework policy: the page epa.gov/careers/telework no longer exists, no telework page appears under epa.gov/aboutepa or the Office of Finance and Administration’s policy index at epa.gov/irmpoli8 (which is now the IT/IM directives index and carries records, security, web and information-management directives only), and EPA’s site search cannot be used to look because it returns a byte-identical 12,097-byte page for a real query and a nonsense one. The Office of General Counsel’s own page describes its law offices and regional counsel offices and says nothing about telework or duty stations.
• The duty-station half was tested against the one listing that records duty stations: OPM’s PLUM database (data as of 2026-06-15) gives a Washington, DC duty station for all sixteen of EPA’s reported Office of General Counsel positions, including every Associate General Counsel. That is a genuine finding about OGC’s senior layer and it does not reach the ask, which is about attorneys generally — the PLUM listing covers policy and supporting positions, not staff attorneys, and EPA’s Offices of Regional Counsel report no positions to it at all. The sixteen are not the office.
• So the item stays attempted on the government-wide Return to In-Person Work memorandum alone, and the negative states its reach: it covers the Federal Register, EPA’s published pages and OPM’s appointee reporting, and it cannot reach EPA’s internal telework policy or the duty stations of career attorneys, neither of which is published anywhere.