Interpretive Rules in Practice
A new ACUS recommendation on interpretive rules largely aligns with a prior one on policy statements.
The National Injunction and the Administrative Procedure Act
Critics of national injunctions should not stretch the meaning of key words in the APA.
The Regulatory Accountability Act and the Obsolescence of Formal Rulemaking
Administrative agencies should not be required to use a process that has been obsolete for decades.
An Independent Commission Should Suggest, Not Determine, Rule Rescissions
Proposed regulatory review commissions would circumvent procedural safeguards.