Blurred Lines: The Importance of Delineation Between Legislative and Non-legislative Rules Under the APA
Vermont Law
FEBRUARY 8, 2015
. : Not all agency rules have the force of law. 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. However, the content of this new rule implies otherwise. _. section 533 of the APA.
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