Demystifying deossification: Rethinking recent proposals to modify judicial review of notice and comment rulemaking
M Seidenfeld - Tex. L. Rev., 1996 - HeinOnline
Tex. L. Rev., 1996•HeinOnline
Articles lamenting the recent" ossification" of notice and comment rulemaking seem to be the
fashion in administrative law scholarship today.'The term" ossification" refers to the
inefficiencies that plague regulatory programs because of analytic hurdles that agencies
must clear in order to adopt new rules. 2 To a large extent, developments in administrative
law over the past two decades that were meant to expand public
fashion in administrative law scholarship today.'The term" ossification" refers to the
inefficiencies that plague regulatory programs because of analytic hurdles that agencies
must clear in order to adopt new rules. 2 To a large extent, developments in administrative
law over the past two decades that were meant to expand public
Articles lamenting the recent" ossification" of notice and comment rulemaking seem to be the fashion in administrative law scholarship today.'The term" ossification" refers to the inefficiencies that plague regulatory programs because of analytic hurdles that agencies must clear in order to adopt new rules. 2 To a large extent, developments in administrative law over the past two decades that were meant to expand public
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