ELR Citation: ELR 20556
No(s). IP 88-194-C (S.D. Ind. Dec 5, 1989)

The court holds that an internal Environmental Protection Agency (EPA) memorandum that imposes new and more stringent Clean Air Act duties on the paper coating industry violates the Administrative Procedure Act because it was not subject to notice and comment rulemaking. The memorandum provides that...