ONE OF THE SUBJECTS I TEACH IS ADMINISTRATIVE LAW, and I always have the students draft comments on a proposed regulation, which are then actually filed with the agency in question and become part of the rulemaking docket. I don’t tell them what position to take, but just grade them on the quality of their work, which is often very good. (One of my students some years ago actually got a job offer out of her comments.)

The topic from last year (well, year-before-last now, I guess) was hours-of-service regulations for truckers. Now the new rules have been released and InstaPundit reader (and trucker) Gerald Dearing observes:

They slipped this in “under the radar”, so to speak, while we were all distracted by other events. But these are not as bad as the Clinton era reform proposals that had the whole industry up in arms.

Of course the teamsters complain. That’s what they do. But their routes are negotiated by contract, and I don’t see their routines changing much.

And of course the “safety experts” will bitch. That’s what they do, too. Will the average truckers life change? Very little. I rarely take just an eight hour break. When I stop, it’s often for ten or twelve hours.

And I don’t hit the maximum ten driving hours every day. Now I won’t hit the eleven maximum every day. The big limitation is the “Seventy Hours in Eight Days” rule, and that’s virtually unchanged. (If you take 34 hours off, you then have hours to run anyway. Why bother!) I don’t foresee the savings in lives predicted by the D.O.T. nor do I foresee the dramatically increased carnage forecast by the “safety groups”.

Notice that there is still no requirement that the driver actually sleep. Ten hours playing Video Poker (or ‘net surfin’) makes one eligible to drive another eleven hours. ;-)

“Net Surfin’?” Hmm. InstaPundit: Menace of the motorways!

UPDATE: Reader Skip Oliva emails:

I think it’s great you have your students submit actual comments to the agencies. I pretty much draft public comments for a living (more on agency consent orders than rulemaking) and I find a lot of ignorance even among the bar about this process. I’m always looking for law students to help with research and writing, but most of the students I have spoken to didn’t even realize there are public comment processes in administrative proceedings.

Yeah, I’m surprised how many lawyers don’t realize this — or, even if they do know it at some level, don’t act on it. I drafted comments on a matter I was interested in back when I was a law student (not as part of a class, just on my own) and learned a lot from the process. Then I did a lot of work relating to the rulemaking process when I was in law practice, where I found that useful. That led me to try this out when I first started teaching Administrative Law, and it’s worked well enough that I’ve kept it up.