Blurred Lines: The Importance of Delineation Between Legislative and Non-legislative Rules Under the APA
Vermont Law
FEBRUARY 8, 2015
In March of 2014, the EPA and the Army Corps of Engineers issued an “interpretive rule” regarding section 404 of the Clean Water Act, circumventing a notice and comment period. Under the Administrative Procedure Act (APA), “interpretive rules” are merely advisory and do not carry the force of law. Summary. :
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