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David Fischer Authored Article on Agency Guidance Practices for Environmental Regulations

Keller and Heckman Counsel David Fischer authored the Natural Resources & Environment journal article, “Guidance on Guidance: OMB’s Bulletin for Agency Good Guidance Practices.” The article discusses how, for a number of years, the Executive Office of the President's Office of Management and Budget (OMB) has had significant concerns with the uneven manner in which guidance documents have been designed and implemented by federal agencies. In an effort to ensure that agency guidance practices are more transparent, fair, and accountable, OMB issued the Final Bulletin for Agency Good Guidance Practices on January 25, 2007. 

To read the full article, please click here (subscription required).