What does the APA require a federal agency to include in its rules?

The Administrative Procedure Act (APA) mandates that federal agencies provide a clear statement of the bases and purposes of their rules. This requirement is essential for ensuring transparency and accountability in the rulemaking process. By articulating the rationale behind a rule, agencies help the public understand the objectives they aim to achieve and the underlying reasons for the regulatory actions.

This requirement facilitates public engagement and allows stakeholders to assess how proposed rules align with their interests and needs. A comprehensive statement also enables courts to evaluate the legality and appropriateness of the agency's actions should the rules be challenged later.

In contrast, while a review process and a public comment period may be beneficial aspects of rulemaking, they are not specifically mandated in every circumstance by the APA. Similarly, compliance with state laws is not a requirement under the APA when a federal agency is developing its rules, as federal law can preempt state law. Thus, the APA's emphasis on providing a statement of the bases and purposes ensures a transparent process that can uphold both public trust and legal scrutiny.