One strategy they have used is to attempt to invoke the APA's formal rulemaking procedures.

他们采用的一种战略是尽力援引《行政程序法》规定的正式规则制定程序。

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Commentators have criticized formal rulemaking as a costly, cumbersome process that contributes little to the quality of decision.

评论家们批评正式规则制定为昂贵麻烦的程序，对裁定的质量毫无贡献。

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On the other hand, the reason for the formal rulemaking process is to allow public participation in the crafting of those rules.

FORBES: As Dairy Cliff Approaches, Consumers May See Milk and Cheese Prices Double

If you conclude that you are required to proceed with implementation, we urge that you proceed in a thoughtful and deliberate manner using the formal rulemaking process.

FORBES: As Dairy Cliff Approaches, Consumers May See Milk and Cheese Prices Double

So should the USDA skip the formal rulemaking process?

FORBES: As Dairy Cliff Approaches, Consumers May See Milk and Cheese Prices Double