Process

Agencies should include severability clauses in rules to minimize legal uncertainty.

ACUS collaborated with agency officials to identify inefficiencies in the PRA approval 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.

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

Limiting judicial deference to agencies would strengthen environmental policy and democratic accountability.

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.

A one-size-fits-all approach to cost-benefit analysis won’t necessarily ensure better policy.