> Notice and comment is required by the Administrative Procedure Act for rule-makings, not so the agency can solicit peoples' opinions, but to gather relevant l

> Notice and comment is required by the Administrative Procedure Act for rule-makings, not so the agency can solicit peoples' opinions, but to gather relevant legal and policy arguments and data. That's interesting. So does "we got a lot of comments from people noting how they've experienced what looks like monopolistic behavior in isolated instances that might inform whether can can expect this behavior to increase/decrease if we rule for/against the action?" count as or towards a policy argument? Legal arguments I can see being fairly specific, but policy (to my mind at least) is much more open to interpretation. Or is there some specific legal definition of policy argument they must adhere to here?