Administrative Law Keyed to Lawson
Air Transport Association of America v. Department of Transportation
The FAA dispensed with notice and comment procedure before promulgating its Penalty Rules, claiming that they fell under the Section:553(b)(A) exception and were exempt from those requirements. Air Transport Association of America (Petitioner) contended that the Penalty Rules were invalid because the FAA failed to comply with the notice and comment requirements of the APA.
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