Guide to Executive Branch Agency Rulemaking


Policy, Procedure, Participation, and Post-Promulgation Appeal (Manual 6) (Softcover, 295 pages)

Executive branch agencies often legislate more pages of law than legislatures do. Agency staff almost own guaranteed lifetime jobs. State sovereign immunity, civil service laws, and public-sector unions protect them. With delegated executive, legislative, and judicial powers, thousands of state agencies, millions of employees, and billions of dollars per year, they form the fourth branch of government. They are the Administrative State.

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Society depends upon them. Citizens cannot un-elect them. You cannot fire them. Courts presume their actions to be correct. Legislatures bow to their technical expertise. Few private interests can pay the financial or political costs of resisting the Administrative State.

Guide to Executive Agency Rulemaking is a terrific primer on how to influence rulemaking by the fourth branch of government as its tens of thousands of agencies, with millions of state employees, spend billions of dollars per year to regulate almost every aspect of modern life.
Executive Vice President, Campus Operations and Public Affairs
Austin Community College District
Professor of Practice, The University of Texas at Austin

However, while none can interfere with agencies acting within their powers, good lobbying may influence them. Carefully following Guide to Executive Branch Agency Rulemaking—Policy, Procedure, Participation, and Post-Promulgation Appeal can nudge agencies toward legislating rules that fulfill their mission statements, improve society by refining its regulatory processes, and promote accountability, responsiveness, and inclusiveness by and within the Administrative State.

Administrative lawyers, law students, public policy professionals, and anyone trying to influence executive agency legislating will find this practice manual invaluable. Keep it close by as its a perfect roadmap for navigating the multi-party, highly–detailed administrative rulemaking process.
General Counsel (former)
Florida Department of Health
President (current)
Florida Justice Reform Institute
Tallahassee, Florida

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