The BORS is considering the following regulation: “Hospitals, educational institutions, and scientific development companies may engage in human cloning for the purposes of research and development of drugs for pets and farm animals.”

Instructions: Prepare an office memorandum that addresses the following:

(1) whether the proposed regulation is substantive or interpretive and why;
(2) whether the BORS would be required to publish a notice of proposed rulemaking (NPRM) and allow for comments if the regulation is determined to be substantive, and

cite to the relevant provisions of the Administrative Procedure Act to support your conclusions
3) whether the BORS would be required to publish a notice of its proposed rulemaking and allow for comments if the regulation is determined to be interpretative, and

cite to the relevant provisions of the Administrative Procedure Act to support your conclusions.

Sample Solution