Notice-and-comment procedures are required for all agency rule-making, both substantive and process-oriented rules.

Name: Notice-and-comment procedures are required for all agency rule-making, both substantive and process-oriented rules.
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Notice-and-comment procedures are required for substantive (legislative) rule-making but not necessarily for procedural rules, which often are exempt from these requirements under the Administrative Procedure Act (APA).

Notice-And-Comment Procedures Are Required for All Agency Rule-Making, Both Substantive