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Prof. Jeffrey Lubbers Esq.


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December 2005: '"Guidance is a good thing," said Jeffrey Lubbers , fellow in law and government at the American University Washington College of Law . "The problem comes in when agencies treat them as binding on the public without notice and comment." He added that there is a natural tension between agencies using the practice for good reasons and them abusing it by avoiding the real rulemaking process.'

http://www.washingtonpost.com/wp-dyn/content/article/2005/12/19/AR2005121901663.html

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RoleNameTypeLast Updated
Employee/Freelancer/Contractor (past or present) Washington College of Law (WCL) Organization Dec 20, 2005

Articles and Resources

Date Fairness.com Resource Read it at:
Dec 20, 2005 Finding a Way to Better Guidance

QUOTE: ...accepted practice in which many agencies issue policy statements and other documents as "guidance" to interpret their rules and set out expectations for compliance. Unlike traditional rulemaking, guidance is not subject to notice and comment procedures or judicial review. It's faster to issue and, normally, not reviewed by the OIRA. Though not legally binding, guidance is sometimes considered practically binding by regulated industries, a sort of "backdoor" rulemaking.

 Washington Post