Assess understanding of the administrative rulemaking process with emphasis on notice-and-comment requirements under the APA (content and timing of notices, comment procedures, exceptions and good-cause justification, and the administrative record) and the standards courts use in judicial review (arbitrary-and-capricious, substantial evidence, abuse of discretion, Chevron/Skidmore deference, remedies like remand or vacatur). Testers should evaluate ability to identify procedural defects in short fact patterns and predict likely judicial outcomes.