Article
Let the People Speak: Notice and Comment Rulemaking (Lessons from the Controversial New Source Review Proposal of the Clean Air Act
ENVIRONMENTAL LAW REPORTER
(2004)
Abstract
Public Comments to APA "Informal" Section 553 Rule-making are potentially very important instruments in shaping law and regulation, particularly in environmental law. However, there have been relatively few articles discussing how one should craft these comments, given the legal environment surrounding administrative law. By using the controversial New Source Review proposal of the CAA from the Bush EPA, the four authors, environmental and administrative law experts independently craft comments, and then specify lessons and best practices for sec. 553 comments generally.
Keywords
- administrative law,
- environment,
- clean air act,
- rulemaking,
- notice and comment,
- administrative procedures act,
- section 553,
- new source review,
- nsr
Disciplines
Publication Date
2004
Citation Information
Victor Flatt, Michael M. O'Hear, Mark Squillace and Robert R.M. Verchick. "Let the People Speak: Notice and Comment Rulemaking (Lessons from the Controversial New Source Review Proposal of the Clean Air Act" ENVIRONMENTAL LAW REPORTER Vol. 34 (2004) Available at: http://works.bepress.com/robert_verchick/23/