Test learners' ability to apply administrative law standards to challenges to agency rulemaking by analyzing fact patterns to (1) determine whether Chevron deference applies and perform step-one/step-two analysis; (2) evaluate substantive review under the APA’s arbitrary-and-capricious (hard-look) standard; and (3) assess procedural sufficiency of notice-and-comment rulemaking. Expect short-answer application questions requiring identification of controlling tests, reasoned conclusions, and recommended remedies.