In emergencies, federal agencies can avoid cumbersome rulemaking procedures. Uses of the “good cause” exception following 9/11 and the outbreak of the coronavirus offer insights relevant to the current cybersecurity threats to critical infrastructure.
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A little over a week ago, the law firm Sidley Austin LLP submitted its "Independent Review Relating to APA Ethics Guidelines, National Security Interrogations, and Torture" to the APA Board of Directors. Today, the report was released to the public along with a story in the New York Times summarizing its contents.