by judy.pino@ncla.legal | Mar 16, 2020 | Kara Rollins, Uncategorized
NCLA’s examples document that recommendations that examine whether the current modes of rulemaking, enforcement and adjudication do not always comply with the Administrative Procedure Act (APA) and the U.S. Constitution. These examples are drawn from real cases—mostly...
by NCLA | Jan 9, 2020 | Adi Dynar, Uncategorized
Pursuant to Rule 28, Ariz. R. Sup. Ct., the New Civil Liberties Alliance (“NCLA”) petitions this Court to amend Arizona Rule of Procedure for Judicial Review of Administrative Decisions 3 (“JRAD Rule 3”). NCLA is a nonprofit civil-rights organization and...
by NCLA | Dec 21, 2019 | Kara Rollins, Uncategorized
The New Civil Liberties Alliance (NCLA) submits the following commentary in response to the Department of Energy’s (DOE) request for comment on NCLA’s August 2, 2019 petition for rulemaking. See Regulations Prohibiting Issuance, Reliance,or Defense of Improper Agency...
by nclaadmin | Nov 6, 2019 | Michael P. DeGrandis, Uncategorized
Re: FCC 19-86, EB Docket No. 19-214: Procedural Streamlining of Administrative Hearings Document No. 2019-20568 In NCLA’s view, The Streamlining Rule proposes to convert live-testimony hearings into written-record proceedings. Such a conversion would fundamentally...
by nclaadmin | Oct 21, 2019 | Caleb Kruckenberg, Uncategorized
Re: Revisions to Safety Standard for Infant Bath Seats, Docket Number CPSC-2009-0064In NCLA’s view, the Proposed Rule continues an odious trend of incorporating private standards into the law only by reference, thereby hiding the binding law behind a paywall. The...
by nclaadmin | Oct 21, 2019 | Harriet Hageman, Uncategorized
Re: Updating Regulations on Water Quality CertificationDocket ID No.: EPA-HQ-OW-2019-0405NCLA commends EPA’s efforts to provide more certainty and stability in relation to implementing Section 401 of the Clean Water Act. While NCLA appreciates the importance of state...
