Administrative Law/Regulatory - Administrative Rulemaking
Crowell & Moring attorneys participate in rulemaking proceedings before most federal administrative agencies, many state agencies and the European Union. Where necessary, we represent clients challenging or defending final rules in court. We represent our clients' interests in the rulemaking arena by:
- Working with agency officials before a rule is proposed
- Preparing written comments on proposed rules and responses to comments submitted by others
- Providing oral testimony at public hearings
- Seeking administrative or judicial stays of rules
- Challenging rules in court or intervening in support of rules in judicial proceedings brought by others
Our attorneys have many years of experience in rulemaking, ratemaking and supply allocation proceedings, including tariff matters affecting common carriers and the unbundling of energy services. Other examples of our rulemaking representations include: preparing comments on behalf of a major US airline and monitoring submissions of other parties in an extended rulemaking on computer reservations systems; preparing comments and participating in litigation on regulations affecting health care providers, health care plans participating in the Medicare program, academic medical centers and research institutions affected by regulations governing clinical trial research; environmental rulemakings involving air, water, wetlands, mining regulations and reclamation, and occupational safety and health for general industry and construction (OSHA) and for mining (MSHA).