It's like all of the alphabet agencies.....all had to have been created by amendment. None were. A man by the name of G.R. Mobley has done much work on this and many other issues. Instead of going to the Federalist and Anti-Federalist papers (arguments by interested individuals), he has dug deeply into the Ratification Debates where we get to see how and why THEY argued, discussed, and finally agreed on the various parts of the Constitution. He and others have created First Amendment petitions that are directed to and through our county legislators regarding the State Legislatures’ failure to hold the federal government accountable for numerous violations of our Constitution. If this interests you, this is the location of the petitions: http://reclaimingtherepublic.org/petitions.html