Image

 ![Coastal research landscape used as the Northmoor University hero image.](/sites/default/files/styles/large/public/2026-01/camilo-botia-k4vFDPJoDZk-unsplash.1600x1200.jpg.avif?itok=HDjpTqA_)

 

 



Subhead

Three students presented analysis on a permitting rule, and found in the process that the agency had lost part of its own record.



 

Publish date

Thu, 5 Mar 2026 - 15:00

 

Author

[Dr. Nathaniel Brooks](/person/dr-nathaniel-brooks)

 

Three students from the marine policy clinic testified at a state hearing in February, presenting analysis of a proposed change to coastal permitting on behalf of a community organization.

The clinic takes casework for organizations and small agencies that cannot afford analysis. In this instance the client had standing, a strong position and no capacity to document it.

Preparing the testimony required reconstructing the administrative record behind the existing rule, and the students discovered partway through that a portion of it was missing from the agency's own files. Two of the documents were eventually located in a legislative archive.

"That is the part of this work you cannot teach in a seminar," said Nathaniel Brooks, who runs the clinic. "The written rule is one thing. What an agency can actually produce when asked is another, and the distance between them is most of my field."

The testimony was entered into the record and the rule remains under consideration.

The clinic is open to undergraduates in the BA in Marine Policy and to graduate students in both master's programs. Clinic students have previously drafted comment letters that changed a final rule.



People

[Dr. Nathaniel Brooks](/person/dr-nathaniel-brooks)

 

 

Departments

[Department of Marine Policy and Economics](/department/department-of-marine-policy-and-economics)

 

 

Programs

[Marine Policy](/program/marine-policy)

[Marine Resource Management](/program/marine-resource-management)