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Tag: rulemaking

Inter-Agency Comments Left out of FCC’s 5G Auction Public Docket

November 17, 2021 Laura Montgomery

This is really getting in the weeds, but some of us find the view at ground level (or under water)…

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Posted in: uncategorized Filed under: docket, rulemaking

Scope and Logical Outgrowth

March 14, 2019 Laura Montgomery

No, this is not a discussion of yucky medical issues dealing with scopes and growths.  Why would you even think…

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Posted in: uncategorized Filed under: rulemaking

How Does Rulemaking Work?

January 16, 2019 Laura Montgomery

Someone asked me for a short primer for her students on how rulemaking works, preferably something that could be understood…

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Posted in: uncategorized Filed under: rulemaking

Regulatory Proposals, Comments, Showing Your Work

November 21, 2018 Laura Montgomery 1 Comment

Admit it.  Each and every one of you is as excited as I am to see what the FAA comes…

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Posted in: uncategorized Filed under: rulemaking

Space Law, Separation of Powers, and Henry VIII

October 23, 2017 Laura Montgomery

I don’t know a lot about UK law.  That won’t stop me from talking about it, of course, especially when…

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Posted in: uncategorized Filed under: drafting, regulation, rulemaking

Demonstrating Compliance with a Performance Standard

March 25, 2017 Laura Montgomery

Performance standards are the new* “in” thing in the regulatory world. Everyone wants them. Everyone notes how they offer greater…

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Posted in: uncategorized Filed under: APA, drafting, regulation, rulemaking

An Agency’s Rulemaking Priorities for Space Transportation

October 7, 2016 Laura Montgomery

An agency’s notice of proposed rulemaking (an NPRM) does not get written overnight. An agency must identify a problem, come…

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Posted in: uncategorized Filed under: FAA, rulemaking, teach a man to fish

How to Learn about the FAA’s Risk Criteria and Calculations

September 23, 2016 Laura Montgomery

I received a question from someone interested in what literature might be available for understanding the FAA’s risk criteria for…

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Posted in: uncategorized Filed under: preambles, risk, rulemaking, teach a man to fish

Are There Two Regimes for Commercial Space Transportation?

August 26, 2016 Laura Montgomery

I received a question in response to Monday’s post that raised foundational issues: why are there are two regimes to…

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Posted in: uncategorized Filed under: CFR, FAA, non-delegation doctrine, rulemaking, USC

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Recent Posts

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  • LUNA LACUNA in Space Force Anthology
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  • Space is Vast. So is the Administration’s Mission Authorization Proposal
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