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Administrative Law in a Global Era: Progress, Deregulatory Change, and the Rise of the Administrative Presidency

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Administrative Law in a Global Era: Progress, Deregulatory Change, and the Rise of the Administrative Presidency Maurer School of Law: Indiana University Digital Repository @ Maurer Law Articles by Maurer Faculty Faculty Scholarship 1988 Administrative Law in a Global Era: Progress, Deregulatory Change, and the Rise of the Administrative Presidency Alfred C. Aman Indiana University Maurer School of Law, [email protected] Follow this and additional works at: https://www.repository.law.indiana.edu/facpub Part of the Administrative Law Commons, and the President/Executive Department Commons Recommended Citation Aman, Alfred C., "Administrative Law in a Global Era: Progress, Deregulatory Change, and the Rise of the Administrative Presidency" (1988). Articles by Maurer Faculty. 848. https://www.repository.law.indiana.edu/facpub/848 This Article is brought to you for free and open access by the Faculty Scholarship at Digital Repository @ Maurer Law. It has been accepted for inclusion in Articles by Maurer Faculty by an authorized administrator of Digital Repository @ Maurer Law. For more information, please contact [email protected]. ADMINISTRATIVE LAW IN A GLOBAL ERA: PROGRESS, DEREGULATORY CHANGE, AND THE RISE OF THE ADMINISTRATIVE PRESIDENCY Alfred C. Aman, Jr.t TABLE OF CONTENTS I. Judicial Review of Agency Regulation .................. 1108 A. Judicial Deference in the New Deal-APA Era ....... 1109 1. The New Deal Constitution and the Relationship of Constitutional Law To Administrative Law in the New Deal-APA Era .. 1111 2. The Nature of the Agencies-Agencies as Independent Experts and the Means of Institutionalizing Reform ....................... 1116 3. The Nature of the Regulatory Discourse and the Inevitability of Regulatory Growth ............. 1121 4. The Nature of the Regulation-A Producer Perspective .................................... 1126 B. The Hard Look Approach-Judicial Activism in an Interdependent Era ................................ 1131 1. The Relationship of Constitutional to Administrative Law in the Environmental Era... 1134 2. The Nature of the Issues-Absolutism .......... 1135 3. The Nature of the Regulation-A Consumer Perspective .................................... 1139 C. The Nature of the Agencies-Conflicts of Interest . 1141 1. Judicial Supervision and Agency Rationality- The Common Law Roots of the Hard Look D octrine ....................................... 1143 0 1989 by Alfred C. Aman, Jr. t A.B. Univ. of Rochester, 1967; J.D. University of Chicago, 1970. Professor of Law, Cornell Law School. I wish to thank those who read and commented on this manu- script in various degrees of completion. In particular I wish to thank Professors Gregory Alexander, Paul Craig, Yvonne Cripps, Cynthia Farina, Donald Gjerdingen, Carol Greenhouse, Alfred E. Kahn, Peter Kountz, William Mayton, D. Marie Provine, E.F. Roberts, Peter Strauss, Robert Summers, and David A. Webster. In addition, this manu- script benefitted from the helpful comments I received from my colleagues at a Cornell faculty workshop. This Article is part of a larger, book length manuscript now in the process of completion. 1101 1102 CORNELL LA W REVIEW [Vol. 73:1101 2. A Common Law Approach to Agency Changes . 1145 3. A Constitutional Approach To Judicial Review of Agency Action .............................. 1149 II. Judicial Review of Agency Deregulation ................ 1153 A. The Discourse of Deregulation .................... 1154 B. Deregulation at the Agency Level .................. 1158 1. The Forms of Deregulation .................... 1158 2. Agency Deregulation from a Normative Perspective .................................... 1159 C. Judicial Approval of Agency Deregulation-The Application of Traditional Deference .............. 1164 D. Judicial Rejection of Agency Deregulation-The Application of the Hard Look Doctrine ............ 1174 1. The United States Court of Appeals for the District of Columbia-The Judge as a Literary C ritic .......................................... 1180 2. The Supreme Court Majority-A Hard Look Without the Rhetoric .......................... 1185 3. The Dissent-Presidential Deference and A New Discourse of Change ........................... 1188 III. Administrative Law in a Global Era: The Administrative Presidency and the Politics of Efficiency ................ 1191 A. A Global Perspective-Deregulation, Technology, and the Politics of Efficiency ....................... 1192 1. Regulation, Deregulation, and A Constitutional Hard Look Approach to the Doctrine of Separation of Powers .......................... 1201 2. Formalism as a Means of Constitutionalizing Executive Control Over Administrative Discretion ..................................... 1204 3. The Non-Delegation Doctrine Cases and the Rise of Political Rationality ..................... 1218 B. Deferring to Executive Deregulation--Chevron v. NRDC ........................................ 1222 1. Chevron-An Overview ......................... 1223 2. A Critique ..................................... 1228 C. The Rise of the Administrative Presidency and the Relative Decline of Congress and Expertise ........ 1236 Conclusion ................................................. 1242 1988] ADMINISTRATIVE LAW IN A GLOBAL ERA 1103 When President Reagan took office in January, 1981, one of his first official acts was to decontrol completely the price of domestic crude oil.' Due to the peculiarities of the Emergency Petroleum Al- location Act,2 this power was fully within his authority.3 With a sin- gle stroke of the pen he brought to a close a complex, costly, presumably "temporary" governmental program that, in one form or another, had operated for more than eleven years. 4 The Reagan Revolution had begun. Though the decontrol movement began much earlier,5 decon- trol fever swept Washington during the Reagan Administration. Washington law firms no longer appeared to be quite the growth industry they once were. 6 Pennsylvania Avenue was awash with re- sumes, particularly those of government lawyers made redundant in their respective regulatory agencies. 7 Government in the form of bureaucracy, command-control rules, and regulations, was no longer viewed as an appropriate means of solving societal problems-and neither were the lawyers, formerly necessary for promulgating, interpreting and enforcing these regulations. Gov- ernment in and of itself was seen as a fundamental problem.8 "Less government" became the prescribed solution for problems ranging from civil rights to the price of natural gas at the wellhead. 9 Most Reagan regulatory appointees adhered to this philosophy. Some publicly proclaimed that their primary goal was to close down the agencies they were chosen to head.' 0 1 See Exec. Order No. 12,287, 3 C.F.R. 124 (1981), reprinted in 15 U.S.C. § 757 (1982). 2 15 U.S.C. §§ 751-56 (1976). 3 See 15 U.S.C. § 753(a) (1976). President Carter had already used this authority to begin deregulating the price of oil. President Reagan accelerated the process. See Aman, Institutionalizingthe Energy Crisis: Some Structuraland ProceduralLessons, 65 CORNELL L. REv. 491, 493 (1980). 4 For a procedural and substantive case study of this regulatory program, see Aman, supra note 3. 5 Deregulatory proposals were made during Ford's administration and deregula- tion also was vigorously pursued during the Carter Administration. For a history and analysis of the deregulation that occurred in the trucking, airline, and communications industries, see M. DERTHICK & P. QUIRK, THE POLrrIcs OF DEREGULATION (1985). 6 See, e.g., Washington Lawyers Seeing Signs That The Boom Times Have Passed, Wall St. J., Mar. 18, 1982, at 29, col. 4. 7 See, e.g., Needfor Lawyers in CapitalCut, N.Y. Times, June 1, 1981, at D1, col. 3. 8 See, e.g., Program for Economic Recovery-Address BeforeJoint Session of Con- gress, 17 WEEKLY COMP. PRES. Doc. 130, 136 (Feb. 18, 1981); Program for Economic Recovery-White House Report, 17 WEEKLY COMP. PRES. Doc. 130, 138 (Feb. 18, 1981). 9 See Deregulation CarriedOut With Zeal, N.Y. Times, Jan. 10, 1982, § 12 (Magazine), at 32. See also, CarterJudicialReview of the Reagan Revolution, 65 JUDICATURE 458 (1982). 10 See Workers Wait Numbly For Probable Oblivion, N.Y. Times, Nov. 26, 1981, at B8, col. 5. The head of the Department of Energy noted that he wished to "work [him]self out of a job." Id. 1104 CORNELL LA W REVIEW [Vol. 73:1101 But revolutions are not made in a day. The Reagan Administra- tion's increased reliance on deregulation punctuated a long cultural, political, and legal process." This Article examines some of the continuities and discontinuities of this process by defining three dis- tinct eras of administrative law: (1) the New-Deal APA Era; (2) the Environmental Era; and (3) the Global-Deregulatory Era. 12 It ar- gues that, particularly in the Global-Deregulatory Era under Presi- dent Reagan, not only has the substance of regulation changed, but the processes of change themselves also have been redefined, giving rise to the doctrine of presidential deference and to new perceptions of the relationships among courts, agencies, the executive, and Con- gress. Moreover, these developments are increasingly at odds with a more deliberative conception of administrative law, one that em- phasizes incremental change based on reasoned decisionmaking that reflects the policy goals enunciated by Congress. The concep- tion of administrative law underlying deregulatory change often dif- fers, at least in degree, in several important ways from a more deliberative approach. It tolerates more abrupt change, driven by the President and the executive branch rather than by Congress
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