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All Jurisprudence based

0 tracked cards Political and Public International Law

An agency admits that notice of a proposed rule and an opportunity for interested views were practicable, and no different law controls. It gives neither, then argues that later final-rule publication necessarily substitutes for Section 9(1)’s pre-adoption participation. Which is best?

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The statute prohibits consultation. Section 9(1)’s practicable notice-and-views process is distinct from later publicity of the adopted rule. Public participation means the agency must accept every suggestion. Only private donors may submit views.

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