Handbook on Compiling Administrative Records for Informal Rulemaking

In Recommendation 2013-4, the Administrative Conference offered best practices for preserving, compiling, and certifying records for judicial review of informal rulemaking. The Conference also encouraged agencies to issue guidance to aid personnel in implementing those best practices. The Office of the Chairman convened a Working Group in 2019 to develop materials to assist agencies in developing such guidance.

The Working Group brought together representatives from the public and private sectors to develop a handbook that agencies can use to develop the guidance called for in Recommendation 2013-4. The resulting Handbook on Compiling Administrative Records for Informal Rulemaking, published in January 2022, addresses a wide range of legal, policy, technological, organizational, and personnel matters related to preserving, compiling, and certifying rulemaking records.

Working Group Members and Associated Individuals

Staff Counsel/Reporter: Jeremy Graboyes, Attorney Advisor, Administrative Conference of the United States


  • James Barton, Senior Associate, WilmerHale

  • Reeve T. Bull, Research Director, Administrative Conference of the United States

  • Daniel Cohen, Assistant General Counsel for Regulation, Department of Transportation

  • Peter Constantine, Associate Solicitor, Office of Legal Counsel Department of Labor

  • Kelly P. Dunbar, Partner, WilmerHale

  • Andrew Emery, President, The Regulatory Group

  • Claire J. Evans, Partner, Wiley Rein

  • Cynthia R. Farina, William G. McRoberts Research Professor in Administration of the Law, Emerita, Cornell Law School

  • Noelle Green, Attorney-Advisor, Office of General Counsel, Environmental Protection Agency

  • Allyson N. Ho, Partner, Gibson, Dunn & Crutcher

  • Lane Nemirow, Attorney-Advisor, Office of the Solicitor, Department of the Interior

  • Connor Raso, Senior Counsel, Office of General Counsel, Securities and Exchange Commission

  • Melissa Rifkin, Attorney, Office of General Counsel, Pension Benefit Guaranty Corporation

  • Peter Robbins, Attorney, Office of General Counsel, Department of Commerce

  • Adina Rosenbaum, Attorney, Public Citizen Litigation Group

  • Adam White, Senior Fellow, Antonin Scalia Law School

  • Matthew L. Wiener, Vice Chairman and Executive Director, Administrative Conference of the United States

  • Eric Womack, Assistant Director, Federal Programs Branch, Civil Division, Department of Justice