Rubio seemingly purporting to exempt immigration regulations and policy from notice and comment rulemaking requirements

[Wiz Imp]

1. This appears to be illegal

https://www.gao.gov/federal-rulemaking

Expedited rulemaking. Federal agencies are usually required to publish a proposed rule in the Federal Register and solicit public comments before finalizing regulations. However, there are exceptions to expedite rulemaking in certain circumstances, such as for an emergency or other “good cause.” Although agencies often request public comments on rules they’ve expedited, they do not always respond to these comments.

I'm sure they'll argue it's for emergency or other "good cause" but I'm not sure that holds up in court.