Inside Agency Statutory Interpretation: Survey Appendix
12 Pages Posted: 19 Aug 2014 Last revised: 9 May 2015
Date Written: August 16, 2014
This appendix reproduces a 195-question survey of federal agency rule drafters that covers a variety of topics related to agency rule-drafting and statutory interpretation. The survey is modeled on the path-breaking empirical work Lisa Bressman and Abbe Gluck have conducted on congressional drafting, though it differs in substantial respects. The author administered the survey over a five-month period in 2013 at seven executive departments (Agriculture, Commerce, Energy, Homeland Security, Health and Human Services, Housing and Urban Development, and Transportation) and two independent agencies (Federal Communications Commission and Federal Reserve). Of the 411 officials sent the survey, 128 responded for a 31% response rate.
The findings from this survey will be reported in a series of papers, starting with Chevron Inside the Regulatory State: An Empirical Assessment, 83 Fordham L. Rev. 703 (2014) (invited contribution to Chevron at 30 symposium), available at http://ssrn.com/abstract=2483760, and Inside Agency Interpretation, 67 Stan. L. Rev. 999 (2015), available at http://ssrn.com/abstract=2501716.
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