Bureaucratic Work Arounds

Because it is guidance and intended to clarify exisitng regulations, it is not subject to notice and comment requirements of the Administrative Procedures Act. This is a workaround for Agencies that want to extend their power and authority without the interference of Congress. I thought this had been addressed in Sackett v. EPA and West Virginia v. EPA. If Congress didn't specifically give you the power in the written law, you don't have it. Do the courts have to specifically address every damn agency individually?

FDA Bans Farmers from Caring for Their Own Animals Without Costly Vet Approval