id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjel-3731	Packard, Lauren	Michigan: An Intrusive Inquiry into EPA’s Rulemaking Process	2019	45	.pdf	application/pdf	17586	1028	54	In her dissent, Justice Kagan pointed out that the agency had considered costs at the implementation stage of the rulemaking process and criticized the majority for its “micromanagement” of EPA’s rulemaking process.6 This Note will argue that Michigan reflects, for the first time, a presumption in favor of cost considerations by the Court. Although cost considerations do not require cost-benefit balancing per se, agencies should consider framing considerations as such 1.	cache/cjel-3731.pdf	txt/cjel-3731.txt