Chief Judge WALD dissents from the panel’s judgment.
RUTH BADER GINSBURG, Circuit Judge:The law offices of Seymour M. Chase petition for review of an order of the Federal Communications Commission (FCC or Commission) disqualifying Chase from appearing as counsel for one of the applicants in a comparative broadcast licensing proceeding. See In re Owens, 104 F.C.C.2d 848 (Rev.Bd.1986), reprinted in Joint Appendix (J.A.) at 2, review denied, 2 F.C.C. Red 38 (1987) (Commission Order), reprinted in J.A. at 1. I conclude that an order disqualifying an attorney from appearing as counsel in an FCC proceeding is currently unreviewable in court when the petition for the judicial review is filed by the attorney rather than his client. This conclusion, I believe, is impelled by the reasoning underlying the Supreme Court’s decision in Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 105 S.Ct. 2757, 86 L.Ed.2d 340 (1985). I therefore vote to dismiss the petition without reaching the merits of Chase’s challenge to the Commission order.
I.
In April 1985, Liberty Broadcasting Corporation (Liberty) represented by Chase, a member of the District of Columbia bar, filed an application with the FCC for a new television station in Bakersfield, California. One of the competing applicants in the ensuing comparative broadcast licensing proceeding for the Bakersfield station was Harold L. Mullican. In October 1985, an application filed by Chase on behalf of an individual client for a new television station in Newton, New Jersey was amended to name Newton Television, Inc. (NTI) as the corporate applicant for the Newton station. The amendment, filed by Chase in his capacity as NTI’s corporate counsel, indicated that Dr. Samuel Walters was an 18.67% nonvoting stockholder of NTI. On November 21, 1985, Chase, as counsel to Liberty, learned that Mr. Mullican had amended his application in the Bakersfield proceeding to specify a limited partnership, Mullican, Limited Partnership (Mullican), listing Walters as its 70% limited partner. As of the end of November 1985, then, Chase found himself involved in two application proceedings before the FCC — in the Newton proceeding he represented a corporation in which Walters was a shareholder, in the Bakersfield proceeding he opposed a limited partnership in which Walters was a partner.
On May 10,1986, nearly six months after he became aware of the state of affairs with respect to Walters, Chase, acting on behalf of Liberty, sought to depose Walters in the Bakersfield proceeding. At the beginning of the deposition session, Chase indicated that he represented NTI in the Newton proceeding. Mullican’s counsel objected to Chase deposing Walters and Walters refused to testify. On May 12, Chase terminated his representation of NTI but did not withdraw from representing Liberty in the Bakersfield proceeding. On May 14, Mullican filed a motion to disqualify Chase as Liberty’s counsel contending that “Chase’s simultaneous representation of Liberty and NTI unavoidably involves the firm in representing differing and discordant interests.” Motion to Disqualify Counsel to Liberty Broadcasting at tí 13, reprinted in J.A. at 32.
Upon hearing argument of Mullican’s motion on May 19, the presiding Administrative Law Judge (AU) immediately made an oral ruling; he granted the motion and disqualified Chase. On May 22, pursuant to 47 C.F.R. § 1.301(a)(5) (1985), the ALJ issued an order postponing the Bakersfield *519proceeding until September 16, 1986;1 the following day a memorandum opinion was released explaining the AU’s disqualification order. The ALT determined that a conflict of interests existed because Chase could have used confidential information concerning Walters obtained in the course of Chase’s representation of NTI in the Newton proceeding to cross-examine Walters in the Bakersfield proceeding; such use, the ALT maintained, could unfairly harm Mullican in relation to Chase’s representation of Liberty.
Liberty appealed the order disqualifying Chase to the Review Board which affirmed the ALJ’s ruling. In re Owens, 104 F.C.C.2d 848 (Rev.Bd.1986), reprinted in J.A. at 2. On August 27,1986 Chase (not Liberty) filed an application for Commission review of the Board’s decision.2 During the pend-ency of Chase’s application to the Commission, Liberty, having secured other counsel, entered into a settlement agreement with the other applicants in the Bakersfield proceeding. The agreement was released on October 10, 1986. On December 23, 1986, the Commission denied Chase’s application for review; the order to that effect was released on January 8, 1987. In re Owens, 2 F.C.C.Rcd 38 (1987). Chase promptly sought this court’s review of the Commission’s disqualification order.
At oral argument the panel stated its concern about the reviewability of Chase’s petition and instructed the parties to submit supplemental briefs responding to the question:
Is the disqualification ruling addressed in the petition a judicially reviewable order under 28 U.S.C. § 2342 and 47 U.S.C. § 402(a)? See Richardson-Merrell, Inc. v. Koller, 472 U.S. 424 [105 S.Ct. 2757, 86 L.Ed.2d 340] (1985).
Instruction of January 4, 1988. In their respective briefs, both Chase and the FCC maintain that the disqualification order is judicially reviewable under the cited legislative prescriptions. Mindful of the close consideration that should attend a disposition opposed by both sides to an appeal, I reluctantly conclude that the FCC order disqualifying Chase, under current Supreme Court instruction, is not subject to judicial review in the posture in which the ruling appears before us.
II.
Our authority to review FCC orders is predicated upon 28 U.S.C. § 2342(1) (1982) and 47 U.S.C. § 402 (1982).3 These statutory provisions empower courts of appeals to review final orders of the FCC. See, e.g., Illinois Citizens Comm. for Broadcasting v. FCC, 515 F.2d 397, 402 *520(D.C.Cir.1975); Bethesda-Chevy Chase Broadcasters, Inc. v. FCC, 385 F.2d 967, 968 (D.C.Cir.1967). An order disqualifying an attorney from serving as counsel in a pending trial court proceeding is, when issued, an interlocutory order. See Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 430, 105 S.Ct. 2757, 2761, 86 L.Ed.2d 340 (1985) (“An order disqualifying counsel in a civil case is not a final judgment on the merits of the litigation.”). The same characterization generally attends an order disqualifying an attorney from serving as counsel in a pending administrative proceeding. See, e.g., 16 C.F.R. § 3.23 (1987) (appeal to Federal Trade Commission from an AU’s suspension of “an attorney from participation in a particular proceeding” is an “interlocutory appeal”); 17 C.F.R. § 10.101 (1987) (appeal to Securities Exchange Commission from an AU’s suspension of “an attorney from participation in a particular proceeding” is an “interlocutory appeal”); 17 C.F.R. § 10.109 (1987) (same); 17 C.F.R. § 12.309 (1987) (same); 47 C.F.R. § 1.301 (1986) (FCC “ruling removing counsel” from a hearing is an “interlocutory ruling”). See also Community Broadcasting of Boston, Inc. v. FCC, 546 F.2d 1022 (D.C.Cir.1976) (characterizing, by analogy to district court orders, agency denial of motion to disqualify as interlocutory and not immediately appealable).
Both the FCC and Chase, however, rely on 47 C.F.R. § 1.301(a)(5) (1986), which affords “counsel on his own behalf” a right of appeal from a presiding officer’s disqualification order. Disposition by the Review Board and the Commission of such a disqualification order, both parties maintain, converts the original interlocutory ruling into a final order of the Commission; the order thus finalized, the parties assert, is reviewable by this court under 28 U.S.C. §§ 2342(1), 2344 (1982) even though the petitioner is counsel proceeding solely for himself on a grievance independent of his client’s claim or defense in the proceeding in which the disqualification order was entered. As the FCC puts it, “[w]hen the attorney personally invokes [47 C.F.R. § 1.301(a)(5)], the agency has effectively allowed the attorney to become a party to a disqualification proceeding with a life of its own.... The question thus becomes whether Chase is a ‘party aggrieved’ by a ‘final order’ of the Commission within the meaning of [28 U.S.C. §§ 2342(1), 2344 (1982) ].”4 FCC Supplemental Brief at 6-7. The Commission answers that question in the affirmative, although acknowledging that its counsel “have not discovered a case with analogous facts.” Id. at 7. Nor has the dissent uncovered any such case.
I reject the parties’ argument for this reason: we have no discretion to allow an agency, simply and solely by crafting internal rules, to “grant[]” or “create[] a cause of action,” see Dissent at 522, 526, and thereby enlarge the appellate authority of our court. Leaving aside the FCC’s internal rule dispensation, the Supreme Court has instructed us that an attorney situated as Chase is may not obtain court of appeals review of an order disqualifying him from participating in a hearing.
In Richardson-Merrell, 472 U.S. at 426, 105 S.Ct. at 2759, the Supreme Court held that “orders disqualifying counsel in a civil case are not collateral orders subject to immediate appeal.” Most significantly for the case at hand, the Court stated that this holding effectively denies a judicial review remedy to “an attorney whose reputation has been egregiously injured by the trial court’s disqualification decision,” id. at 435, 105 S.Ct. at 2763, “when the client is satisfied with the judgment obtained by substitute counsel.” Id. See also id. at 435 n. 2, 105 S.Ct. at 2763 n. 2 (observing that misconduct of a judge “for which no judicial remedy is available” may be made the subject of a plea for an administrative remedy from the Circuit Judicial Council).5 Nota*521bly, this court in Koller v. Richardson-Merrell, Inc., 737 F.2d 1038 (D.C.Cir.1984), rev’d, 472 U.S. 424, 105 S.Ct. 2757, 86 L.Ed.2d 340 (1985), while making the decision ultimately reversed by the Supreme Court that a disqualification order in a civil case is subject to immediate (interlocutory) appeal, apparently shared the High Court’s view that an attorney has no independent right to appeal a disqualification order at any stage of the proceeding: “In the event that plaintiffs were satisfied with the final verdict obtained by substitute counsel, the disqualified attorneys could be left with no means whatsoever of vindicating their own important interests on appeal from a final judgment.” Id. at 1053.
Neither the Supreme Court nor this court elaborated on the conclusion each recited in dictum that no judicial remedy is available to a disqualified attorney independent of the remedies available to his client. See also Duncan v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 646 F.2d 1020, 1027 (5th Cir. Unit B June 1981) (asserting, without accompanying explanation, that there is no independent judicial remedy for the disqualified attorney). The passages from Richardson-Merrell just quoted, however, reveal that both courts envisaged the very question presented to us: whether a disqualified attorney can independently seek judicial review of his disqualification after a final disposition of the episode-in-controversy satisfactory to his ex-client. Both the Supreme Court and this court indicated that the question of the appealability of the disqualification order by the attorney himself does not turn on the timing of the appeal. No judicial remedy is available on the solo plea of the disqualified attorney, Richardson-Merrell counsels, whether the attorney seeks immediate (interlocutory) appeal or awaits the conclusion, by final judgment, of the underlying proceeding from which the attorney was disqualified.6
Were agency regulations governing appeals of rulings within the agency permitted to determine the scope of review or the qualification of parties to seek review before the federal courts,7 this anomalous *522situation would arise: attorneys disqualified in district court proceedings would have no recourse to a judicial remedy while attorneys disqualified in administrative proceedings before agencies such as the FCC that afford counsel an independent right of administrative review would have a judicial remedy. In view of the constant and closer supervisory authority federal courts of appeals exercise over district courts within the circuit, such a dichotomy would be all the more incongruous.
In sum, we are currently counseled by Richarson-Merrell that an attorney cannot independently pursue an appeal from a disqualification order made by a district court.8 We have no more warrant to accord such a right to an attorney held disqualified by an agency’s order. Nor can we cede to each particular administrative agency the decision whether an attorney disqualified by that agency will have access to judicial review. The FCC surely can confer an independent right of administrative appeal upon an attorney in Chase’s situation. But the Commission cannot thereby confer upon the attorney a right “on his own behalf” to judicial review.
Conclusion
For the reasons stated, I vote to dismiss Chase’s petition as unreviewable and I intimate no view on the merits of the Commission’s disqualification order.9
. 47 C.F.R. 1.301(a)(5) (1986), under the heading "Appeal from presiding officer’s interlocutory ruling,” provides:
A ruling removing counsel from the hearing is appealable as a matter of right, by counsel on his own behalf or by his client. (In the event of such ruling, the presiding officer will adjourn the hearing for such period as is reasonably necessary for the client to secure new counsel and for counsel to familiarize himself with the case).
. 47C.F.R. § 1.301(a)(5) (1986) gives both client and counsel a right of appeal from a presiding officer’s ruling removing counsel from a proceeding. See supra note 1.
. 28 U.S.C. § 2342 (1982) provides, in relevant part:
The court of appeals has exclusive jurisdiction to enjoin, set aside, suspend (in whole or in part), or to determine the validity of—
(1) all final orders of the Federal Communications Commission made reviewable by section 402(a) of title 47....
47 U.S.C. § 402(a) (1982) provides:
Any proceeding to enjoin, set aside, annul, or suspend any order of the Commission under this chapter (except those appealable under subsection (b) of this section) shall be brought as provided by and in the manner prescribed in chapter 158 of Title 28.
The specific rights of appeal set out in 47 U.S.C. § 402(b) (1982) are inapplicable to Chase’s petition.
In addition to these final order provisions specifically addressing judicial review of FCC orders, section 10(c) of the Administrative Procedure Act (APA) includes a general final judgment rule for agencies:
Agency action made reviewable by statute and final agency action for which there is no other adequate remedy in a court are subject to judicial review. A preliminary, procedural, or intermediate agency action or ruling not directly reviewable is subject to review on the review of the final agency action.
5 U.S.C. § 704 (1982).
. 28 U.S.C. § 2344 (1982) provides, in relevant part:
Any party aggrieved by the final order [of the agency] may, within 60 days after its entry, file a petition to review the order in the court of appeals wherein venue lies.
. Prompted by the Supreme Court’s statement in Richardson-Merrell that
[e]ven when the client is satisfied with the judgment obtained by substitute counsel, an attorney whose reputation has been egregiously injured by the trial court's disqualification *521decision might be able to obtain relief from the Circuit Judicial Council pursuant to 28 U.S.C. § 332(d)(1)[,]
472 U.S. at 435, 105 S.Ct. at 2763, I note the Review Board's suggestion that the matter in question be examined by the Committee on Professional Responsibility of the Federal Communications Bar Association. See In re Owens, 104 F.C.C.2d 848, 858 n. 7 (Rev.Bd.1986). I further note the possibility of enlisting the aid of the D.C. Bar’s Legal Ethics Committee. Attorneys confronting significant questions of professional responsibility may seek an advisory opinion from that Committee; Chase might have sought such an opinion when he became aware, in November 1985, of the potential conflict in his representation of Liberty and NTI, and indeed he might do so even now. See D.C. Bar Legal Ethics Comm. R. C-1, C-2. Moreover, it might be in order for an agency such as the FCC, which itself possesses no particular expertise on matters of an attorney’s professional responsibility, to address recurring questions to the Committee outside the confines of a specific case, see D.C. Bar Legal Ethics Comm. R.F; D.C. Bar Legal Ethics Comm. Op. No. 92 (request of D.C.Corp.Counsel), or perhaps even at the time the issue arises during a proceeding. See D.C. Bar Legal Ethics Comm. R. C-4 (limiting but not eliminating the possibility of rendering opinions on specific issues involved in pending litigation). This latter course could be analogized to our practice of certifying to state tribunals dispositive questions of local law when no current precedent indicates the answer. See, e.g., Penn Mut. Life Ins. Co. v. Abramson, 837 F.2d 484, 485 (D.C.Cir.1987) (certification of novel question of D.C. law to D.C. Court of Appeals pursuant to D.C. Code Ann. § 11-723 (Supp.1987)).
. Despite the obvious reputational and possible financial interests at stake for a disqualified attorney, see Meese v. Keene, — U.S. -, 107 S.Ct. 1862, 1867, 95 L.Ed.2d 415 (1987) (adverse impact on professional reputation constitutes "distinct and palpable” injury), the unarticulated intuition behind the courts’ dicta in Richardson-Merrell may be that the right to appear before a tribunal vests in the client not in the attorney. While the right to be represented by counsel of one’s choice is an aspect of the general right, this subsidiary right also vests in the choosing client and not the chosen counsel. Thus, one might reason that only the client should be allowed to initiate a plea for a judicial remedy for the loss of his chosen counsel.
. By its citation to United States v. Erika, Inc., 456 U.S. 201, 207 n. 7, 102 S.Ct. 1650, 1653 n. 7, 72 L.Ed.2d 12 (1982), the dissent reveals its pervasive error: the dissent constantly equates, blends or confuses an appeal right within an agency with a right to seek judicial review. An agency surely may “grant" or "create” the former right. See Dissent at 522, 526. The dissent strides into uncharted territory, however, in suggesting that the agency may also open (or shut) the court’s door at its will.
. Unlike the case of a federal question raised by a state court litigant who does not meet Article III limitations on access to federal court, see Phillips Petroleum Co. v. Shutts, 472 U.S. 797, 804, 105 S.Ct. 2965, 2971, 86 L.Ed.2d 628 (1985) (“Standing to sue in any Article III court is, of course, a federal question which does not depend on the party's prior standing in state court.”); Doremus v. Board of Education, 342 U.S. 429, 434, 72 S.Ct. 394, 397, 96 L.Ed. 475 (1952) (Article III limits on federal jurisdiction apply to appeals from state courts), I see no constitutional impediment to the recognition of a right on the part of counsel independently to appeal a disqualification order. Cf. Lipscomb v. Wise, 643 F.2d 319, 320 (5th Cir. Unit A Apr. 1981) (lawyers’ claims to fees are “cognizable under Article III because they have ‘alleged such a personal stake in the outcome of the controversy as to assure that concrete adverseness which sharpens the presentation of issues’”), quoting Baker v. Carr, 369 U.S. 186, 204, 82 S.Ct. 691, 703, 7 L.Ed.2d 663 (1962).
I note, furthermore, that the centrality of the interest of the parties to a legal proceeding does not imply that no other interests in such a proceeding merit discrete recognition for purposes of appeal. For example, recalcitrant witnesses cited for civil contempt pursuant to 28 U.S.C. § 1826 (1982) have an independent right of appeal. Thus, I believe that the federal courts, in accord with the FCC, could recognize the interests — both reputational and financial— of disqualified attorneys as independently appeal-worthy. But Richardson-Merrell is our current guide, and it points us away from such recognition.
. Under United States v. Munsingwear, Inc., 340 U.S. 36, 40, 71 S.Ct. 104, 107, 95 L.Ed. 36 (1950), we routinely vacate first instance dispositions when appellate review “was prevented through happenstance.” Although the Munsingwear doctrine extends to administrative orders, Mechling Barge Lines, Inc. v. United States, 368 U.S. 324, 82 S.Ct. 337, 7 L.Ed.2d 317 (1961), that doctrine does not permit us to vacate the Commission’s order in this case.
The Chase disqualification order would have been reviewable in court in the context of a petition by Chase’s client, Liberty, seeking review of an adverse FCC decision in the licensing proceeding. Liberty’s decision to settle, however, was a decision to "decline[ ] to pursue its appeal.” See Karcher v. May, — U.S. -, 108 S.Ct. 388, 395, 98 L.Ed.2d 327 (1987) (refusing to apply Munsingwear). The application of Munsingwear requires that, but for an intervening happenstance, such as the settlement in this case, the issue on appeal would have been reviewable if presented by the very party appealing. But I am compelled to conclude, confronted with Richardson-Merrell, that no petition filed by Chase contesting the disqualification order on his own behalf (and not on behalf of Liberty) would have been reviewable.