13. Environmental Protection Agency · Minor
Revise RACT cost guidance to reflect actual regulatory burden
Printed page 423 13. Environmental Protection Agency
“Review and revise Reasonably Available Control Technology (RACT) cost guidance to ensure that calculations are accurate and reflect the actual regulatory burden, including costs of air rules implementation and compliance.”
What has happened
- Not started
EPA has kept processing state RACT submissions and has not touched the cost guidance behind them. The guidance is in two places and neither moved. The Air Pollution Control Cost Manual, which EPA describes as providing "guidance for the development of accurate and consistent costs for air pollution control devices", is mid-way through a Seventh Edition required by the 2014 Consolidated Appropriations Act, and every chapter EPA lists as updated is dated 2017 to 2019 with spreadsheet errata to December 2024 — nothing revised inside the window, and the outstanding chapters carry expected completion dates of 2028 and 2029. The Control Techniques Guidelines, the documents that actually define VOC RACT, run from 1975 to the 2000s with no addition or revision in the window. Every RACT document in the Federal Register in this window is an approval or disapproval of one state's plan; none reopens how the cost of reasonably available control technology is calculated or adds the implementation and compliance costs the Quote says are missing.
- EPA, Cost Reports and Guidance for Air Pollution Regulations — the Air Pollution Control Cost Manual, Seventh Edition in progress; listed chapter updates run 2017–2019, with chapters expected in 2028 and 2029
- EPA, Control Techniques Guidelines and Alternative Control Techniques — "CTGs are used to help determine VOC RACT"; the listed documents date from 1975 onward, none from this window
Research log
What was searched, and what didn’t count as evidence
Research notes
- Negative search (2026-08-27): a search of EPA’s final and proposed rules in the Federal Register, among the federal records we keep and search, for “RACT” returns only state implementation plan actions — Pennsylvania, New Jersey, Michigan, Ohio, Arizona — approving or disapproving individual state RACT submissions. None revises EPA’s cost guidance.
- Checked again 2026-09-06. Status unchanged. Both pages in question were opened and read in full. The landing page epa.gov/economic-and-cost-analysis-air-pollution-regulations was last updated 2026-03-18 and the cost-guidance page beneath it carries the actual document list. The finding is not merely that no revision was found: it is that the Seventh Edition of the Cost Manual is a long-running statutory update whose remaining chapters are scheduled for 2028 and 2029, so the revision the Quote asks for is neither done nor in prospect within the window.
- Evidence is now attached to the not started event, where it previously had none: action on the ask’s own object that does not satisfy it is cited. The Cost Manual and the CTGs are the ask’s own object, dated, Primary and on EPA’s own host; showing that they stand unrevised is a stronger negative than a Federal Register count, because this guidance was never going to appear in the Federal Register in the first place.
- The negative reaches EPA’s published cost guidance and its Federal Register RACT actions. It does not reach how individual regional offices apply the guidance when reviewing a state submission, which is unpublished.
- Action
- other
- Object
- Reasonably Available Control Technology (RACT) cost guidance
- ID
- 1063