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Section of Administrative Law and Regulatory Practice

Interstate Compacts APA Project

Welcome to the webpage of the Interstate Compact Administrative Procedure Act Project sponsored by the Section of Administrative Law and Regulatory Practice of the American Bar Association.

The goal of the project is to produce a resolution for introduction by the Section to the ABA House of Delegates for adoption as official ABA policy. The resolution would urge Congress to enact an interstate compact APA (based on the guidelines produced by the project) for application to future congressionally-approved compact agencies that under interstate compact precedent are subject to neither the Federal APA nor any State APA. The resolution would also recommend that existing compact agencies (Congressionally approved or not) and/or signatories adopt a compact APA to the extent no other APA applies.

The Project was initiated at the Section’s 2003 Fall Administrative Law Conference. The papers presented there and at subsequent programs form the basis of the Interstate Compacts Committee’s final draft of Report and Recommendations and Blackletter Statement of Interstate Compact Agency Administrative Law.

At this time, the Committee is seeking comments on the final draft. The Committee will take into consideration any and all comments before finalizing its report and recommendations to the Section Council. To comment on the Recommendations and/or contribute to the Blackletter Statement, please click here.

The co-chairs wish to thank the following authors for their contributions to the project: Bernard W. Bell, Shaun M. Gehan, Molly Klapper, Ron Levin, Eric McDaniel, Christopher B. McNeil, Robert Alan Wake, John Hardin Young.

Join Our Committee

If you are interested in joining the committee, please click here.

Committee Leadership

Kent W. Bishop, Co-Chair
Jeffrey B. Litwak, Co-Chair
William S. Morrow, Jr., Co-Chair

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