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adjudication Administrative Law Administrative Procedure Act adopted agency action agency's Amendment American Bar Association analysis Appeals apply argued attorney authority benefits Boyden Gray challenge Chevron deference claims Co-Chairs Commission Committee Congress constitutional cost-benefit cost-benefit analysis Council Counsel D.C. Circuit decision Delegates due process Editor effect enforcement environmental executive federal agencies FERC interest interpretation Interstate Compact involved issue judges judicial review Justice Justice Scalia Law and Regulatory Law School lawyers legislative litigation Medicare Meeting ment Michael Asimow Michael Herz National Office OIRA Ombuds panel participation peer review plaintiffs Professor of Law proposed Protection regulation Regulatory Law Regulatory Practice section requirements rulemaking School of Law Section Chair section member price Section of Administrative separation of powers Service standards statement statute statutory Supreme Court tion tive violation Washington