How can the next administration use agency rulemaking to put its policies into practice quickly?

I asked Perplexity's AI some questions about this

A lot of “law” gets made by executive agencies, which have been allowed to interpret the laws Congress passes with great leeway. The agencies issues rules and regulations (the terms are interchangeable) to carry out Congress’ laws. Changing agency interpretations of the existing laws may be the easiest way to get changes in policy, without requiring Congress to pass new laws.

The agencies are normally required to issue comment periods before issuing new rules or revoking old ones. The process could take several months or longer.

A proposed EPA agency rule required slaughterhouses to build their own wastewater treatment facilities, which is expected to shut some down, further restricting the amount of meat that can be processed in the US—most likely this rule was promulgated as part of the green agenda.

A new USDA rule to require dairy cattle, some beef cattle and bison to be tagged with electronic RFID tags was due to go into effect 5 days ago. NCLA sued the USDA, and I do not know whether the rule was stayed pending a court ruling or where this is. Clearly, a Trump administration that wishes to roll back surveillance might want to act before a great deal of expensive electronic infrastructure has been purchased by ranchers to comply with the new rule.

https://www.perplexity.ai/search/what-fda-rules-apply-to-raw-da-_0chewixQUmzUMgviGjf7Q

The FDA prohibits the interstate sale and distribution of raw milk and raw milk products for human consumption. This regulation is based on the agency’s authority under the Public Health Service Act and the Food, Drug, and Cosmetic Act to prevent the spread of communicable diseases across state lines.

But raw milk is not a communicable disease. Yet FDA has been adamant for 40 years in enforcing this law, sometimes with guns drawn. Congress never passed a law banning raw milk. This could be changed with a new administration. But how fast?

See below. Because one can make the argument in both cases above that rescinding the rules could be beneficial to health, I think a good cause exception could be made that these rules should be changed very quickly and do not require a comment period.

https://www.perplexity.ai/search/do-us-federal-agencies-need-to-Y7tENKECTeapvNKKNdD0hw

US federal agencies generally need to follow a notice-and-comment process before revoking regulations, with some exceptions. Here are the key points:

General Rule: Notice-and-Comment Required

The Administrative Procedure Act (APA) requires agencies to use the same rulemaking procedures for rescinding or modifying existing rules as they do for issuing new rules.

This means:

1. The agency must issue a notice of proposed rulemaking (NPRM)

2. Allow for a public comment period

3. Consider the comments received

4. Issue a final rule with a justification

Exceptions and Special Cases

There are some situations where agencies may bypass the full notice-and-comment process: Good Cause Exception: Agencies can skip notice-and-comment if they find it would be “impracticable, unnecessary, or contrary to the public interest”

Frequency of Use

• A 2012 Government Accountability Office (GAO) study found that between 2003 and 2010, federal agencies issued about 35% of major rules and 44% of non-major rules without a notice of proposed rulemaking

• Of those rules issued without notice and comment, agencies most often justified their action by invoking the good cause exception

https://www.everycrsreport.com/reports/R44356.html

The Good Cause Exception to Notice and Comment Rulemaking: Judicial Review of Agency Action

January 29, 2016 R44356

While the Administrative Procedure Act (APA) generally requires agencies to follow certain procedures when promulgating rules, the statute’s “good cause” exception permits agencies to forgo Section 553’s notice and comment requirement if “the agency for good cause finds” that compliance would be “impracticable, unnecessary, or contrary to the public interest” and bypass its 30-day publication requirement if good cause exists. Federal courts reviewing this agency practice have varied in their analysis, resulting in confusion as to precisely what constitutes “good cause.” In addition, some courts have indicated that these are two distinct standards; others do not always distinguish between the two.