Federal regulators are supposed to let citizens know when they are about to issue an edict. Then they are supposed to give people an opportunity to respond to the proposed regulation before it is finalized. The whole process is known as "notice of proposed rulemaking" -- or, in bureaucratese, "NPRM."

Experts say that it is not illegal for agencies to skip the notice-and-comment phase, but they had better have a good reason -- such as the obvious need for immediate action -- or they do so at their own peril.

The General Accounting Office reports that some serious skipping has been going on.

• The GAO found that about half of final regulatory actions never involved a notice-and-comment phase last year.

• While a number of the rules were relatively unimportant, at least 11 of 61 major regulatory actions that cost more than $100 million annually to implement, or had far-reaching social implications, became final without initial notice and comment.

• The GAO found some of the rationales for not issuing NPRMs less than convincing -- some agencies, for example, protested that they had no time to solicit comment, even though they had already missed statutory deadlines for issuing the rule by more than one year.

• One agency didn't want to delay a rule that would facilitate travel to and from Slovenia, and another said it wasn't taking comments because "disasters continue to occur" -- although the disasters the rule addressed occurred one to two years before the rule was published.