The EPA’s Office of Air and Radiation (“OAR”), responsible for most of the EPA’s major air regulatory and policy efforts, will be restructured in the months to come. This shakeup comes on the heels of the EPA’s announcement in March that it will be reconsidering over a dozen significant air regulations. We trace these changes in the EPA landscape through their potential impacts on three important issues named in EPA’s reconsideration announcement:

• Regulation of hydrofluorocarbons (“HFCs”) in refrigeration;
• New Source Performance Standards and Emission Guidelines for oil and gas; and
• Regional Haze planning.

Regulation of HFC Refrigerants:

Since Congress passed the American Innovation and Manufacturing Act in 2020, the EPA has issued a suite of regulations addressing commonly used HFC refrigerants. These regulations affect retail refrigeration, comfort cooling, and refrigerated transport, among various other industries. The EPA has been busy implementing measures to phase down HFC imports and production, manage the use (including leaks) of HFCs, and force transitions in technology through, for instance, limits on the global warming potential of refrigerants that can be used in various systems and appliances.

It’s this last measure, the Technology Transition Rule, that the EPA has announced it will be reconsidering. As of now, the EPA has not mentioned plans for its rules addressing the HFC phasedown or the Management Rule, which mandates leak detection and repair for HFC systems, among other requirements.

All of these regulations were originally prepared by the EPA’s Stratospheric Protection Division, the same office that regulated HFC’s predecessors, ozone depleting substances. The Stratospheric Protection Division is part of the Office of Atmospheric Protection, which the EPA reportedly intends to eliminate. This office also houses EPA’s divisions of Clean Air and Power, Climate Protection Partnerships, and Climate Change.

The EPA has not said where this HFC work will go with the potential elimination of the Office of Atmospheric Protection, but its March reconsideration suggests it will not disappear. In the meantime, the EPA’s HFC regulations remain on the books and compliance deadlines are in force and approaching.

Standards for Oil and Gas:

Other regulations on the EPA’s March reconsideration list include new source performance standards regulating greenhouse gas and other emissions from the oil and gas industry (“NSPS OOOOb”) and emission guidelines for states to develop plans to address emissions from existing oil and gas sources (“EG OOOOc”). These regulations address various potential sources of emissions across the industry from well sites to gas plants and transmission compressor stations.

To date, these regulations have come out of the EPA’s Office of Air Quality Planning and Standards, another office the EPA reportedly intends to disband. Many of the staff who have worked on these regulations have deep institutional knowledge of oil and gas regulations, dating back to the promulgation of NSPS OOOO over a decade ago, and other similar regulations. Where this reorganization will leave this institutional knowledge and these rules are open questions.

These changes come in the middle of the EPA’s reconsideration of certain issues in these standards as described in a rule the EPA proposed in January 2025 but has yet to finalize. Industry and states should coordinate with EPA contacts as compliance and state planning deadlines approach under the current regulations.

Regional Haze:

Regional haze presents a slightly different picture. In its March announcement, the EPA indicated it would be “restructuring the Regional Haze Program.” The Clean Air Act’s regional haze program seeks to protect visibility in certain areas that include national parks and wilderness (referred to as “Class I” areas). States develop plans in ten-year planning periods to show how they will make progress towards visibility goals for Class I areas. Historically, rules governing the state planning process, like the 2017 Regional Haze Rule, have come from the Office of Air Quality Planning and Standards, which again is reportedly being eliminated in the EPA’s planned reorganization.

When the EPA says it is restructuring the regional haze program, that likely includes the 2017 Regional Haze Rule. In 2018, the EPA announced similar efforts to overhaul regional haze planning in the Regional Haze Reform Roadmap. While some efforts of the Roadmap came to pass during President Trump’s first administration, the rule revisions did not. The EPA’s March announcement likely revives these efforts amid this office shuffling.

Even though the EPA’s OAR (specifically the Office of Air Quality Planning and Standards) has typically been responsible for setting national regional haze policy, decisions on approval or disapproval of actual state plans come from one of the EPA’s ten regional offices. These lines of EPA decision-making are already blurring. For instance, EPA Region 3 recently announced a change in regional haze policy when it proposed approving West Virginia’s state implementation plan for the second implementation period on April 18, 2025. There, the EPA announced a new agency policy that when visibility conditions for Class I areas are below the uniform rate of progress and a state has considered the four statutory factors, the state has presumptively demonstrated reasonable progress. This seemingly new national policy was then applied in EPA Region 8’s proposal to approve South Dakota’s plan on May 14.

New Offices, New Names

While the EPA works out all the concrete details of its reorganization of the OAR (and at least three other offices, including the Office of Water), it has announced the creation of two new offices within the OAR:

• Office of State Air Partnerships; and
• Office of Clean Air Programs.

The EPA explains that the Office of State Air Partnerships will focus on state implementation plans and air permitting to ensure national consistency. This could mean that decisions historically left to regional offices, like regional haze plan approvals, could become much more centralized in this new office. The EPA explains that the new Office of Clean Air Programs will “align statutory obligations and mission essential functions based on centers of expertise to ensure more transparency and harmony in regulatory development” but the exact work of this office remains to be seen.