Prof. Richard J. Pierce
Vol. 88, Issue 3
88 Texas L. Rev. See Also 113
In this Response, Professor Richard J. Pierce, Jr. states that he is a proponent the presidential-control model, and that he disagrees with Criddle on various points. First, Pierce suggests that Criddle inappropriately emphasizes the role of the judiciary in agency policy making. Second, Pierce argues that Criddle's proposal of increasing the scope of notice-and-comment rulemaking and hard-look judicial review would exacerbate and already ossified and expensive system. Finally, Pierce criticizes Criddle's insistence on transparency in some areas in government that ought to remain veiled.