For the past year or so, I've been working on a project for the Administrative Conference of the United States on best practices for drafting regulatory preambles in light of recent developments in judicial review. The draft report is now available here: papers.ssrn.com/sol3/papers.... 1/
papers.ssrn.com
This is a draft report to the Administrative Conference of the United States on best practices for drafting regulatory preambles in light of recent developments