Thanks for this info! Interesting to hear how the sausage is made LOL. The public comments thing is just a sham to make the little people think they have some say in government.

I used to think the administrative state was just a natural progression, sort of a side effect of a country that got much bigger and more populous over two centuries. I now believe that it has become behemoth by design. We are now a country of men and not laws. When you think of the millions and millions of pages of rules now in place, who isn't "guilty" of something? The rainwater on your driveway is undoubtedly in violation of some EPA reg. All they have to do is decide who they don't like, find the violation, and bury the target in litigation. The punishment is the process.