No. Although EPA expects EPA Actions and Promising Practices to aid EPA in its implementation of Executive Order 12898 with regard to permitting.
EPA Actions and Promising Practices are not an interpretation of environmental statutes, nor do they add or change interpretations of statutory obligations regarding permitting contained in existing regulations. They create no legal obligations and in no way change the legal landscape of the EPA permitting process. To the contrary, the only legal requirements applicable to EPA regional offices and permit applicants throughout the permitting process are those contained in the EPA’s environmental statutes, implementing regulations, the Administrative Procedure Act, applicable anti-discrimination laws, and other applicable statutes and regulations.