See the review Comments Schwartz.
Key Statements:
(1) “…the APA was not the product of lofty social views,”
(2) “These lawyers preferred generic procedural reform because that introduced a much greater amount of lawyering into the entire federal administrative process than there had been before.”
(3) “In brief, the more procedure there is and the more due process there is, the more money for lawyers there is.”
The activities the author were reviewing took place nearly 75 years ago. That said:
With respect to (1) above is a more in-depth analysis of McNollgast and Schwartz warranted to ascertain the presence, if any, of biases in the APA?
With respect to (2) above is this conclusion applicable to current regulatory reform efforts?
With respect to (3) above is the same conclusion regarding due process relevant to proposals to have OIRA prepare a docket describing each and every person who had an impact, however small, on a regulation as a result of its interagency review of rules?