Beyond the APA: Rulemaking in the Real World

Abstract

Cornelius M. Kerwin has updated his 1994 exposition, Rulemaking: How Government Agencies Write Law and Make Policy. The 1999 edition provides practical insights into the real process of agency rulemaking and takes practitioners far beyond the basics of the federal Administrative Procedure Act (APA). However, the public's contribution to rulemaking remains a murky aspect of the rulemaking process, undermining some of Kerwin's conclusions.

Keywords: administrative law, rulemaking, Administrative Procedure Act, APA, book review, public participation