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Abstract

Agencies, courts, and academics agree that notice-and-comment rulemaking is not a referendum. But that conceptualization presents a challenge when an agency is confronted with mass comments. If agencies are not counting but reading comments, and if mass comments are duplicative and often devoid of content beyond a strong expression of values or preference, then what do they add?

Document Type

News Article

Publication Date

12-21-2021

Source Publication

The Regulatory Review

Keywords

ACUS, Agency Transparency, notice-and-comment, Participation, Public Comment

Disciplines

Administrative Law | Law

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