Rules on Rulemakings

This project addresses whether and when agencies should adopt rules setting forth the procedures the agencies follow when engaging in informal rulemaking. These procedures can include internal approval requirements for proposed rules. They also can cover various aspects of the rulemaking process throughout the lifecycle of the rule, from initiating a new rule (e.g., petitions for rulemaking) to reassessing existing rules (e.g., retrospective review). The project will not seek to dictate the precise types of rulemaking procedures agencies should adopt, but it will explore the potential costs and benefits of a single rule or set of rules that sets forth an agency’s informal rulemaking practices.


Committee Chair
Edward B. Shils Professor of Law and Professor of Political Science; Director, Penn Program on Regulation
University of Pennsylvania Law School
Staff Counsel and In-House Researcher
In-House Researcher
(202) 480-2092
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