Ain't gonna work.
My $.02.

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.

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.