Ain't gonna work.

My $.02.

Wink

This method has been used to combat unpopular agency actions since the Administrative Procedure Act was passed in 1946...

Oh, yeah?

Please show us how; citations, etc..

My $.02.

Wink

Really? One recent example is when the Electronic Privacy Information Center got a ruling from the D.C. Circuit that DHS violated the Administrative Procedure Act by implementing body scanners as a primary screening method without first undertaking public notice and comment rule-making.

http://www.cadc.uscourts.gov/internet/opinions.nsf/B3100471112A40DE852578CE004FE42C/$file/10-1157-1318805.pdf