Drafting Regulations under the APA
The APA
The Administrative Procedure Act ("APA") [City Code, General Provisions, Title 4] was passed in 2020 and amended in 2021 and 2023. The APA requires City regulations to be submitted for review and approval before they can be posted for public comment or declared legally effective.
This page provides links to the resources needed to draft proposed regulations in the format required by the APA.
Does the APA apply?
The APA only applies to agency rules that regulate public behavior or affect public rights. It does not regulate statements, policies, or procedures that pertain to the internal management or operations of an agency, such as an agency’s organizational affairs or its employee rules of conduct.
For more information on content that may be subject to the APA, please contact DLR and the Law Department.
Guiding you through the drafting process
The APA requires that COBRA regulations are drafted in the same style required by the Code of Maryland Regulations (COMAR) with a few modifications. To guide you in the drafting process:
- Review the State Style Manual for Regulations.
- View regulations in COMAR format in the COBRA section on the City Codes website.
- Review the COBRA Table of Contents to determine your Agency's title.
- Questions about the APA drafting style may be emailed to Hanna Naugle, City Regulations Lead.
- Questions about the legality of a proposed regulation may be emailed to Michele Toth, Assistant City Solicitor.