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Effective EPA Advocacy authored by Richard Stoll, provides a practical perspective on conducting effective advocacy before the federal Environmental Protection Agency (EPA) in both the rulemaking process and the (equally if not more important) decision-making processes outside the rulemaking context, such as the issuance of interpretative memoranda, guidance documents, and letter rulings.
Based on the author's observations and insights from eight years in the EPA's Office of General Counsel and twenty seven years in the private sector representing clients in matters before the EPA, Effective EPA Advocacy explains what goes on behind-the-scenes in the making of important national laws (regulations are, after all, laws). This book also includes summary coverage of the fundamentals of major environmental statutes and a brief overview of the federal rulemaking and judicial review processes.
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Reviews
"This is an invaluable insider's guide for anyone interested in how the regulatory process really works. In highly readable prose, replete with useful examples and web citations, Stoll focuses primarily on the U.S. Environmental Protection Agency's process for issuing regulations and 'sub-regulatory' guidance, and provides a roadmap for interested stakeholders who wish to participate effectively in that process. More broadly, his lessons apply to virtually any federal regulatory program. Just as important, he opens a window into the 'informal' rulemaking process and shows just how arduous and overly complex it has become."
--Jeffrey S. Lubbers
Professor of Practice in Administrative Law
Washington College of Law, American University
(Author of: A Guide to Federal Agency Rulemaking)
"A clear, plain English guide to rulemaking at the EPA and how to be an effective advocate before the agency. Richard Stoll has represented many regulated firms since leaving the EPA and he is not shy about expressing his opinions about the 'burdens' of EPA rules. But even if you are an environmentalist like me, don't let that put you off. If you are interested in being more effective in convincing the EPA to adopt rules that help your clients, whether business or environmental groups, this book will be a big help."
--David G. Hawkins
Director, Climate Programs Natural Resources Defense Council
"With practical insight and crisp accessibility, Stoll provides a wonderfully useful volume for practitioners hoping to effectively represent clients and understand the regulatory environment of the EPA."
--Daniel E. Ho
Professor of Law and Robert E. Paradise Faculty Fellow for Excellence in Teaching and Research, Stanford Law School
"A must read for anyone preparing to engage in rulemaking before EPA, or any other agency for that matter."
--William S. Morrow, Administrative and Regulatory Law News
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