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Full-Text Articles in Law
Safe At Any Speed: Robert Ahdieh’S Take On Cost-Benefit Analysis In Financial Markets, Jack M. Beermann
Safe At Any Speed: Robert Ahdieh’S Take On Cost-Benefit Analysis In Financial Markets, Jack M. Beermann
Shorter Faculty Works
When I saw the title of Robert Ahdieh’s recent article, Reanalyzing Cost-Benefit Analysis: Toward a Framework of Function(s) and Form(s), I thought, “oh no, not another article about CBA.” Knowing Professor Adhieh’s work, I took a flyer and read it anyway, and boy was I happy with my decision. This is a great article which should be of interest to anyone involved in administrative law, securities regulation and policy analysis more generally. Cost-benefit analysis has become an important regulatory tool, and Professor Adhieh’s article makes a valuable contribution to the literature on the special analysis required under Section 106 …
Rethinking Notice, Jack M. Beermann
Rethinking Notice, Jack M. Beermann
Shorter Faculty Works
APA § 553 (b)(3) requires agencies engaged in informal rulemaking to provide notice of "either the terms or substance of the proposed rule or a description of the subjects and issues involved." In most cases, agencies publish the complete text of their proposed rules, together with a preamble describing the need for the rule and the major considerations of policy and law that are raised by the proposal. Comments often convince agencies to make changes to their proposed rules. This, of course, is the whole point of the process. Difficulties arise, however, when, in reaction to comments, agencies promulgate rules …