Another book about rulemaking has crossed my desk this week, and it caught my eye because it focuses on environmental rulemaking at the federal level.  Effective EPA Advocacy: Advancing and Protecting Your Client’s Interests in the Decision-Making Process, by Richard G. Stoll, focuses on practical advice for conducting advocacy during the rulemaking and sub-regulatory decision making process. Sometimes, when questions of interpretation or applicability of regulations arise, the EPA

[I]ssues clarifications and interpretations outside the rulemaking context, in the form of manuals, “guidance” documents, directives, interpretative memoranda, letter rulings, and other types of documents under different rubrics.  Some of these documents may cover a broad range of activity and affect numerous facilities, while others may affect only one or a few particular factual situations.

Chapters four through eight were of particular interest because they focused on the sub-regulatory process:

• Chapter 4 Sub-Regulatory Decisions: What Are They? And How Can You Find Them?
• Chapter 5 Influencing Regulatory Decision-making: Going Way Beyond Official Written Comments
• Chapter 6 Preparing Effective Written Comments
• Chapter 7 Influencing and Securing Sub-Regulatory Guidance
• Chapter 8 Perpetual Rulemaking Campaigns: Three Examples

In summary, at only 170 pages, Effective EPA Advocacy is a quick read, and worth looking at if EPA rulemaking and sub-regulatory decisions and guidance are topics that are of interest to you.