Organizational Process, Rulemaking Pace, and the Shadow of Judicial Review
All Publications
From Beginning to End: An Examination of Agencies' Early Public Engagement and Retrospective Review
My testimony reviews the problems necessitating the practices required by your legislation and addresses and examines each bill’s requirements and impacts. It concludes with some crosscutting comments and observations.
DOE's Energy Conservation Program for Appliance Standards
In a notice of proposed rulemaking (NPRM), DOE is proposing to “update and modernize the Department’s current rulemaking methodology titled, ‘Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products’ (‘Process Rule’).”
Early but Not Often: A Look into the Use of ANPRMs in Rulemaking
Agencies can use an advance notice of proposed rulemaking (ANPRM) to engage the public early in the rulemaking process before a rule change is in motion.
Statutory Clarity and Judicial Review of Regulatory Impact Analysis
A key element throughout many of these recent legislative proposals for regulatory reform has been enhanced judicial review of agency rulemaking.
In this rulemaking, the EPA and Army Corps are attempting to bring clarity to the muddy debate over the scope of federal regulatory jurisdiction under the CWA.
IRS's Qualified Business Income Deduction
Section 199A of the Tax Cuts and Jobs Act of 2017 reduced the maximum corporate income tax rate from 35 percent to 21 percent.