EPA said the guidance is intended to support earlier, more coordinated input during federal environmental reviews, including project scoping and the preparation of environmental assessments and environmental impact statements.

Under the memo, EPA comment letters are to be focused, succinct and helpful. The agency directs staff to identify specific statutory or regulatory requirements that apply to a proposed action and provide concrete recommendations when an environmental review lacks adequate analysis or support.

The guidance identifies several areas that may be relevant to EPA comments, including air quality, water quality, drinking water, hazardous materials, waste management and toxic substances. The memo specifically cites authorities under the Clean Air Act, Clean Water Act, Safe Drinking Water Act, Resource Conservation and Recovery Act and Toxic Substances Control Act, among others.

EPA also directs staff to distinguish between comments on the adequacy of an environmental impact statement and concerns about a project’s compliance with environmental laws administered by the agency. The memo states that comment letters should avoid broad policy preferences or requests for analysis unrelated to EPA’s applicable statutory authorities.

The agency emphasized that EPA is generally an advisor in these reviews, not the lead agency or final decisionmaker. Lead federal agencies retain responsibility for preparing environmental impact statements and making final decisions on proposed actions.

For coatings, chemical manufacturing and other industrial projects that involve federal environmental review, the policy could affect the form and timing of EPA input during permitting and project-development processes. The memo itself does not revise Clean Air Act, NEPA, TSCA or other environmental requirements. It is internal guidance for EPA staff and does not create enforceable rights.