Analyze and recommend whether a federal agency should issue rules as substantive rules during the rule making process.

• Discuss the impact of a federal agency decision to issue the rules as substantive rules
• Include in the impact analysis a discussion of all the types of rulemaking procedures the federal agency may use in promulgating a substantive rule
• Include in the impact analysis a discussion of the type of rulemaking procedures that would result in an invalid rule if a federal agency promulgated a substantive rule
• Apply legal reasoning must support your recommendations and conclusions.