Administrative decisions can often be made without corresponding rulemaking actions. Even when a rule is made the 90 day comment period (normally 60 days after

Administrative decisions can often be made without corresponding rulemaking actions. Even when a rule is made the 90 day comment period (normally 60 days after the Notice of Proposed Rulemaking and 30 after the Final Rule) is more of a guideline. You could call it strongly encouraged by several Executive Orders, most recently E.O. 13563.