Here's the thread I did on the draft report. Not much has changed. I look forward to discussing the judicial review committee's proposed recommendations, which grew out of the report, at ACUS's 85th Plenary Session in June! bsky.app/profile/dtde...
Dan Deacon
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/
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
