1. The agencies that oversee permit requirements form a branch of government not contemplated by the Constitution, run by officials who do not answer to voters. Americans spend much time and energy arguing over who should be elected to Congress or sent to the White House;E G See;HOW THE RULING CLASS TURNS OUR FREEDOMS INTO PRIVILEGES AND WHAT WE CAN DO ABOUT IT,2016
2. Manning was the first academic to challenge the Supreme Court's settled doctrine;See John F. Manning, Constitutional Structure and Judicial Deference to Agency Interpretations of Agency Rules, 96 COLUM. L. REV,1996
3. The Supreme Court and the APA: Sometimes They Just Don't Get It, 10 ADMIN;Robert A Anthony;L. J,1996
4. The Role of Guidances in Modern Administrative Procedure: The Case for De Novo Review;Richard A Epstein;J. LEGAL ANALYSIS,2016