As procedures governing the rulemaking process have proliferated since the Administrative Procedure Act was enacted, the potential procedural pitfalls have multiplied. This 6th edition brings the Guide up-to-date with respect to recent cases and changes introduced during the latter half of the Obama Administration and the early years of the Trump Administration.
About the Author: Jeffrey S. Lubbers is a Professor of Practice in Administrative Law at American University's Washington College of Law, where he has also served as a Fellow of Law and Government. He has also taught at the University of Miami School of Law, Georgetown University Law Center, and Washington and Lee University School of Law, the University of Ottawa, and Ritsumeikan University Law School in Kyoto, Japan. He has degrees from Cornell University and the University of Chicago Law School and is a member of the bars of the State of Maryland and the District of Columbia. Prior to joining the Washington College of Law, he served in various positions with the Administrative Conference of the United States (ACUS), the U.S. government's advisory agency on procedural improvements in federal programs--prior to the agency's shutdown by the 104th Congress in 1995. From 1982 to 1995 he was ACUS's Research Director--a position in the Senior Executive Service. In this position, he developed ideas for new studies, hired outside consultants (mostly law professors) to conduct the studies, reviewed reports, supervised staff attorneys, and assisted ACUS committees in developing recommendations from the studies on a wide variety of administrative law subjects. He worked with congressional committees and agencies to seek implementation of ACUS recommendations and served as Team Leader for Vice President Gore's National Performance Review team on Improving Regulatory Systems in 1993. He was a contributing author for ACUS of the first edition of A Guide to Federal Agency Rulemaking and revived the publication for the ABA with the third edition in 1998. With the welcome re-establishment of ACUS in 2010, hewas appointed a Special Counsel to the "new ACUS." Mr. Lubbers has published numerous articles on the administrative process, participated frequently in training programs for government officials in the United States and overseas, with over a dozen trips to China for that purpose, and has won several prestigious honors for his work in administrative law, including the Presidential Rank of Meritorious Executive and special awards from both the American Bar Association and Federal Bar Association.