Administrative Procedure Act (APA) (Past Projects)

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This study focused on the many legal issues that arise in e-Rulemaking, including how agencies may use software to determine that submitted comments are identical or nearly identical, and whether agencies can (and should) destroy paper copies of comments scanned to electronic form. The resulting recommendation identifies approaches that agencies can lawfully use to reduce costs and improve...


Recommendation 2011–2, Rulemaking Comments, recognizes innovations in the commenting process that could promote public participation and improve rulemaking outcomes. The recommendation encourages agencies (1) to provide public guidance on how to submit effective comments; (2) to leave comment periods open for sufficient periods, generally at least 60 days for significant regulatory...