
Alaska Professional Hunters Association, Inc. v. Federal Aviation Administration
United States Court of Appeals for the District of Columbia Circuit
177 F.3d 1030 (1999)
Relevant factsFree
For thirty years, the FAA's Alaskan Region consistently told hunting and fishing guide pilots they weren't subject to commercial-pilot regulations, based on the agency's own precedent; the FAA then issued a "Notice to Operators" reversing that position without going through notice-and-comment rulemaking, and guide organizations (plaintiffs) petitioned for review, arguing the change should have gone through APA procedures.
IssueFree
Whether an agency may change its longstanding interpretation of a regulation without providing regulated parties an opportunity for notice and comment.
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