Understanding DC Circ.'s Agency Rule Withdrawal Debate

By Steven Gordon (August 11, 2022, 3:53 PM EDT) -- The Administrative Procedure Act, or APA, requires notice and public comment before an agency repeals an existing rule, or regulation, as well as when it promulgates a new rule. But an agency can withdraw a proposed or draft rule before it takes effect without going through the notice and comment process....

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