Add to ORKGAgencies, courts, and academics agree that notice-and-comment rulemaking is not a referendum. But that conceptualization presents a challenge when an agency is confronted with mass comments. If agencies are not counting but reading comments, and if mass comments are duplicative and often devoid of content beyond a strong expression of values or preference, then what do they add
Falsely generating comments to influence public policy is an old political game. Even in Shakespeare...
On February 1, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided National...
In 2012, the Government Accountability Office surprised many administrative law specialists by repor...
Agencies, courts, and academics agree that notice-and-comment rulemaking is not a referendum. But th...
I am grateful to the Michigan Journal of Environmental & Administrative Law for the opportunity to r...
As technology improves, public participation in the notice-and-comment rulemaking process becomes mo...
The Administrative Conference of the United States (ACUS) adopted Recommendation 2021-1 to improve a...
When the U.S. Congress enacted the Administrative Procedure Act (APA) in 1946 one of its most innova...
The notice and comment process was designed—and over time has been understood and touted as a means—...
The notice and comment rulemaking process is a fundamental part of how agencies write regulations. W...
The Administrative Procedure Act requires agencies to give the public an opportunity to submit comme...
“Apolitical”—or being disinterested and uninvolved in politics—is a naïve, anachronistic description...
Executive branch agencies typically use a process of notice-and-comment to permit the public to re...
A number of technological and political forces have transformed the once staid and insider dominated...
Since the public commenting process for proposed federal regulations became primarily web-based, the...
Falsely generating comments to influence public policy is an old political game. Even in Shakespeare...
On February 1, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided National...
In 2012, the Government Accountability Office surprised many administrative law specialists by repor...
Agencies, courts, and academics agree that notice-and-comment rulemaking is not a referendum. But th...
I am grateful to the Michigan Journal of Environmental & Administrative Law for the opportunity to r...
As technology improves, public participation in the notice-and-comment rulemaking process becomes mo...
The Administrative Conference of the United States (ACUS) adopted Recommendation 2021-1 to improve a...
When the U.S. Congress enacted the Administrative Procedure Act (APA) in 1946 one of its most innova...
The notice and comment process was designed—and over time has been understood and touted as a means—...
The notice and comment rulemaking process is a fundamental part of how agencies write regulations. W...
The Administrative Procedure Act requires agencies to give the public an opportunity to submit comme...
“Apolitical”—or being disinterested and uninvolved in politics—is a naïve, anachronistic description...
Executive branch agencies typically use a process of notice-and-comment to permit the public to re...
A number of technological and political forces have transformed the once staid and insider dominated...
Since the public commenting process for proposed federal regulations became primarily web-based, the...
Falsely generating comments to influence public policy is an old political game. Even in Shakespeare...
On February 1, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided National...
In 2012, the Government Accountability Office surprised many administrative law specialists by repor...