Vol. 72, Issue 1, 2009January 01, 2009 EDT
RULEMAKING WITHOUT RULES: AN EMPIRICAL STUDY OF DIRECT FINAL RULEMAKING
RULEMAKING WITHOUT RULES: AN EMPIRICAL STUDY OF DIRECT FINAL RULEMAKING
Michael Kolber,
direct final rulemaking Administrative Procedure Act FDA notice-and-comment rulemaking regulatory agencies Administrative Conference
Michael Kolber, RULEMAKING WITHOUT RULES: AN EMPIRICAL STUDY OF DIRECT FINAL RULEMAKING, 72 Albany Law Review (2009).