Trust me, if that form came into the place where I work, 40 hours would be the tip of the iceberg. No novel regulatory request would get a response without comp

Trust me, if that form came into the place where I work, 40 hours would be the tip of the iceberg. No novel regulatory request would get a response without compliance and legal review and interpretation. In any case, this isn't a decision on the merits. It's just saying that the plaintiff has a reasonable chance of succeeding at trial; the "irreparable harm" occurs when the government forces you to incur unrecoverable compliance costs for something that isn't legally required - that's just the law. The government could've avoided this by going through the actual hoops necessitated by the Paperwork Reduction Act, notice and comment etc. rather than creating the requirement as an "emergency".