Project 2025 Tracker / What’s done, what’s next

13. Environmental Protection Agency · Minor

Streamline ARAR determinations across Superfund sites

Not started

431 13. Environmental Protection Agency

“Streamline the process for determining Applicable or Relevant and Appropriate Requirements based on commonalities across sites as opposed to making such determinations on a site-by-site basis.”

What has happened

  1. Not started

    No action was taken on the ARAR process, and the OLEM directive that would carry one is unchanged. Nothing in the window changes how Applicable or Relevant and Appropriate Requirements are determined, and no cross-site or generic ARAR approach was published. OLEM's Superfund Program Implementation Manual — the office's own implementation directive, and the place a generic or cross-site approach would be set out — mentions ARARs once in 17,042 lines and does not touch the determination process; the version EPA offers as current on a page updated 3 June 2026 is still FY 2025, signed in December 2024 and so before the window.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • One negative search covered the OLEM and Superfund asks on pp. 431-433.
  • A Federal Register search of EPA documents since 2025-01-20 for “applicable or relevant and appropriate requirements” → one hit, the 2026-04-13 coal combustion residuals Legacy/CCRMU proposal, which uses the phrase in passing and does not change the determination process.
  • Checked again 2026-09-06. Status unchanged. The OLEM directive in question was found and read: the Superfund Program Implementation Manual, epa.gov/superfund/superfund-program-implementation-manual → https://semspub.epa.gov/src/document/HQ/100003577, read. “ARAR” appears once. The remedy-decision guidance index at epa.gov/superfund/superfund-policy-guidance-and-laws was also opened; its ARAR material sits under “Remedy decisions” and carries no document issued in the window.
  • The manual is dated 18 December 2024, so it fails the evidence gate as a pre-window document; the page offering it as current on 2026-06-03 is what is cited. This item previously carried no Evidence at all, which made it look the same as an ask nobody had researched; it now carries Evidence whether or not the Status ever moves.
  • Shared read with #1118, #1119, #1123 and #1127 — one reading of the manual covers all five.
Action
other
Object
Applicable or Relevant and Appropriate Requirements (ARARs) process
ID
1124