Editors' Summary: Florida's APA was significantly revised in 1996 and 1999 to impose stringent qualifications on agency authority to promulgate regulations. Many of the amendments echo proposed reforms to the federal APA and the Florida "model" has also been said to be a useful precedent for "reform" of other states' APAs. In this Article, Prof. Jim Rossi analyzes the amendments and describes their ramifications as far-reaching and adverse. He asserts that they will, in addition to hindering the ability of regulatory agencies to promulgate regulations, make environmental regulation less flexible and produce other results likely never desired by proponents of the revisions. In addition, Professor Rossi contends that the amendments risk damaging the already fragile relationship between EPA and state administrative agencies. The Article concludes that the Florida revisions will not satisfy the legislative goal of improving the extent to which agencies are accountable for their environmental standards, and should not serve as a model for other jurisdictions.