IJ Comments on Proposed Administrative Rules
Federal laws are seldom written by Congress. Similarly, some state statutes reflect little more than state legislators’ aspirations. Instead, Americans increasingly must abide by administrative rules prepared by officials in executive branches in Washington D.C. and state capitols. These rules control many aspects of life and are as binding as any statute until legislators enact superseding legislation.
Administrative agencies at the federal and state levels make laws through a process of “notice and comment.”
Consistent with its commitment to liberty, IJ engages in the development of administrative law in select, strategic ways. In addition to litigating against adopted rules, IJ attorneys submit comments on proposed rules in fields about which IJ knows from its research, litigation and legislative advocacy.
Recent Petitions for Rulemaking
Monitoring Locations of Commercial Vehicles
IJ submitted a comment letter in response to the Advanced
Notice of Proposed Rulemaking that the Federal Motor Carrier Safety Administration published, seeking feedback on whether it should require every commercial motor vehicle
to install an electronic device that would wirelessly transmit identifying information to law enforcement on demand.
Cosmetology Training Hours Required in Virginia
IJ submitted a comment on the Virginia proposed rule that reduces the education required to become a licensed cosmetologist from 1,500 to 1,000 hours. The Institute for Justice supports the reduction as an important step toward greater opportunities for aspiring beauty-service providers.