The good people behind Scotusblog have said that they have a hard time posting daily between July and October, when the Supreme Court spends much of its time lecturing in Europe.  At least Supreme Court buffs have Jeffrey Toobin to kick around.  Consider the plight of the DC Circuit afficianado.  No exposes about that court in the offing (though there was a marriage), and no opinions since August 24.  New clerks are coming in, summers are taken off, but I think the lesson for agencies is clear: time your interim final rule for July, and revel in at least three months of pre-opinion effectiveness.

Rumor has it that it is possible that EPA has already learned this lesson.

Loose Ends

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