Sophia Lee, plans to explore the role of the APA in opening avenues for participation in governance by African Americans and the advancement of civil rights, in ways not anticipated by the APA’s creators. Bremer will air grievances with the APA and identifies a few things Congress arguably got wrong. She focuses upon the provisions related to ratemaking and rulemaking hearings, with some attempt to show that the reasoning in Florida East Coast Railway is not entirely awful—or, at least, that some of the errors are Congressional. Nicholas Parrillo will provide commentary on these topics. THIS SESSION IS NOT ELIGIBLE FOR CLE CREDIT.