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Memorandum of Guidance › Administrative Procedure

Foley Hoag LLP - Environmental Law

Regulating Guidance As Though It Were Regulation

Foley Hoag LLP - Environmental Law on

I’ve been complaining about guidance for most of the 33 years I’ve been in practice. The summary of the issue provided in Appalachian Power v. EPA in 2000 still has not been bettered: Congress passes a broadly worded...more

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