Law360, New York ( May 20, 2011, 3:53 PM EDT) -- The Administrative Procedures Act (APA) generally requires state and regional agencies to provide public notice and an opportunity for public comment before adopting a regulation. However, it is not always clear when a "policy" is a regulation and, even when it is clearly a regulation, whether it falls within an exception to the Administrative Procedures Act's notice and comment requirements....
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