Process

Regulatory reform should reduce rulemaking burdens to promote effective agency action.

Model Adjudication Rules provide agencies with a guide for improving their own procedures.

Experts highlight new model adjudication rules and recent recommendations to improve governmental processes.

Marchand’s argument questions key regulatory processes and ignores the net benefits of regulation.

EPA exemplifies how agency rulemaking pushes the boundaries of lawful policymaking.

Commentators debate central questions about the role of regulations in society.

GAO is wrong to think that Congress can use the CRA to overturn agency guidance.

Critics of national injunctions should not stretch the meaning of key words in the APA.

Agencies should boost penalties for fatal rule violations to match the value of a statistical life.

Judge Kavanaugh’s views on Chevron may create more uncertainty than exists under the current doctrine.

Judge Kavanaugh’s past opinions reveal a commitment to clarifying deference rules and increasing predictability.

In his D.C. Circuit cases, Judge Kavanaugh tends to disfavor most agency interpretations of statutes.