motor
vehicle
mfrs
assn
state
farm
argued
april
decided
june
national
traffic
motor
vehicle
safety
act
act
directs
secretary
transportation
issue
motor
vehicle
safety
standards
shall
practicable
shall
meet
need
motor
vehicle
safety
shall
stated
objective
terms
issuing
standards
secretary
directed
consider
relevant
available
motor
vehicle
safety
data
whether
proposed
standard
reasonable
practicable
appropriate
particular
type
motor
vehicle
prescribed
extent
standards
contribute
carrying
purposes
act
act
authorizes
judicial
review
administrative
procedure
act
orders
establishing
amending
revoking
motor
vehicle
safety
standard
national
highway
traffic
safety
administration
nhtsa
secretary
delegated
authority
promulgate
safety
standards
rescinded
requirement
modified
standard
new
motor
vehicles
produced
september
equipped
passive
restraints
automatic
seatbelts
airbags
protect
safety
occupants
vehicle
event
collision
explaining
rescission
nhtsa
maintained
longer
able
find
modified
standard
issued
automatic
restraint
requirement
produce
significant
safety
benefits
nhtsa
assumed
airbags
installed
new
cars
automatic
seatbelts
became
apparent
automobile
manufacturers
planned
install
automatic
seatbelts
approximately
new
cars
overwhelming
majority
seatbelts
easily
detached
left
way
permanently
thus
precluding
realization
lifesaving
potential
airbags
requiring
type
affirmative
action
stumbling
block
achieving
high
usage
manual
belts
reason
nhtsa
concluded
longer
basis
reliably
predicting
modified
standard
lead
significant
increased
usage
restraints
hence
nhtsa
view
automatic
restraint
requirement
longer
reasonable
practicable
moreover
given
high
expense
implementing
requirement
limited
benefits
arising
therefrom
nhtsa
feared
many
consumers
regard
modified
standard
instance
ineffective
regulation
petitions
review
nhtsa
rescission
passive
restraint
requirement
appeals
held
rescission
arbitrary
capricious
grounds
nhtsa
conclusion
reliably
predict
increase
belt
usage
standard
insufficient
basis
rescission
nhtsa
inadequately
considered
possibility
requiring
manufacturers
install
nondetachable
rather
detachable
passive
belts
agency
failed
give
consideration
requiring
compliance
standard
installation
airbags
found
congressional
reaction
various
versions
standard
raised
doubts
nhtsa
rescission
necessarily
demonstrates
effort
fulfill
statutory
mandate
therefore
agency
obligated
provide
increasingly
clear
convincing
reasons
action
held
nhtsa
rescission
passive
restraint
requirement
modified
standard
arbitrary
capricious
agency
failed
present
adequate
basis
explanation
rescinding
requirement
must
either
consider
matter
adhere
amend
standard
along
lines
analysis
supports
pp
rescission
occupant
crash
protection
standard
subject
standard
judicial
review
arbitrary
capricious
standard
promulgation
standard
judged
petitioner
motor
vehicle
manufacturers
association
contends
standard
used
judge
agency
refusal
promulgate
rule
first
place
act
expressly
equates
orders
revoking
establishing
safety
standards
association
view
render
meaningless
congress
authorization
judicial
review
orders
revoking
safety
standards
agency
changing
course
rescinding
rule
obligated
supply
reasoned
analysis
change
beyond
may
required
agency
act
first
instance
scope
review
arbitrary
capricious
standard
narrow
substitute
judgment
agency
agency
nevertheless
must
examine
relevant
data
articulate
satisfactory
explanation
action
reviewing
explanation
must
consider
whether
decision
based
consideration
relevant
factors
whether
clear
error
judgment
pp
appeals
correctly
found
arbitrary
capricious
standard
judicial
review
applied
rescission
agency
regulations
erred
intensifying
scope
review
based
upon
reading
legislative
events
agency
interpretation
statute
may
confirmed
ratified
subsequent
congressional
failure
change
interpretation
even
unequivocal
ratification
passive
restraint
requirement
connote
approval
disapproval
nhtsa
later
decision
rescind
requirement
decision
remains
subject
arbitrary
capricious
standard
pp
first
reason
finding
nhtsa
rescission
modified
standard
arbitrary
capricious
apparently
gave
consideration
modifying
standard
require
airbag
technology
utilized
even
nhtsa
conclusion
detachable
automatic
seatbelts
attain
anticipated
safety
benefits
many
individuals
detach
mechanism
acceptable
entirety
standing
alone
justify
amendment
standard
disallow
compliance
means
one
technology
provide
effective
passenger
protection
cast
doubt
need
passive
restraint
requirement
upon
efficacy
airbag
technology
airbag
policy
alternative
passive
restraint
requirement
technology
alternative
within
admit
existing
standard
pp
nhtsa
quick
dismiss
safety
benefits
automatic
seatbelts
explanation
rescission
passive
restraint
requirement
sufficient
enable
conclude
rescission
product
reasoned
decisionmaking
agency
took
account
critical
difference
detachable
automatic
seatbelts
current
manual
seatbelts
failed
articulate
basis
requiring
nondetachable
belts
thus
failed
offer
rational
connection
facts
judgment
required
pass
muster
arbitrary
capricious
standard
pp
white
delivered
opinion
brennan
marshall
blackmun
stevens
joined
parts
vi
burger
powell
rehnquist
joined
rehnquist
filed
opinion
concurring
part
dissenting
part
burger
powell
joined
post
together
consumer
alert
et
al
state
farm
mutual
automobile
insurance
et
al
department
transportation
et
al
state
farm
mutual
automobile
insurance
et
also
certiorari
solicitor
general
lee
argued
cause
petitioners
briefs
assistant
attorney
general
mcgrath
deputy
solicitor
general
geller
edwin
kneedler
robert
kopp
michael
hertz
frank
berndt
david
allen
enid
rubenstein
eileen
leahy
lloyd
cutler
argued
cause
petitioners
briefs
john
pickering
william
perlik
andrew
weissman
william
richardson
milton
andrews
lance
tunick
william
crabtree
edward
good
henry
nolte
otis
smith
charles
sharp
william
weber
raymond
momboisse
sam
kazman
ronald
zumbrun
filed
briefs
petitioners
james
fitzpatrick
argued
cause
respondents
cases
brief
respondents
state
farm
mutual
automobile
insurance
et
al
michael
sohn
john
quinn
merrick
garland
robert
abrams
attorney
general
new
york
robert
hammer
assistant
attorney
general
peter
schiff
martin
minkowitz
milton
freedman
filed
brief
respondent
superintendent
insurance
state
new
york
raymond
rasenberger
lawrence
merthan
jerry
cox
lowell
beck
filed
brief
respondents
national
association
independent
insurers
et
fn
briefs
amici
curiae
urging
affirmance
filed
dennis
barbour
american
college
preventive
medicine
et
al
nathan
lewin
american
insurance
association
philip
collins
thomas
mcgrath
automotive
occupant
protection
association
alexandra
finucane
epilepsy
foundation
america
et
al
katherine
hall
center
auto
safety
et
al
simon
lazarus
iii
mothers
drunk
drivers
john
quinn
john
hardin
young
national
association
insurance
commissioners
justice
white
delivered
opinion
development
automobile
gave
americans
unprecedented
freedom
travel
exacted
high
price
enhanced
mobility
since
motor
vehicles
leading
cause
accidental
deaths
injuries
americans
died
motor
vehicle
accidents
hundreds
thousands
maimed
injured
consensus
exists
current
loss
life
highways
unacceptably
high
improving
safety
admit
easy
solution
congress
decided
least
part
answer
lies
improving
design
safety
features
vehicle
much
technology
building
safer
cars
undeveloped
untested
changes
automobile
design
mandated
effectiveness
changes
studied
costs
examined
public
acceptance
considered
task
called
considerable
expertise
congress
responded
enacting
national
traffic
motor
vehicle
safety
act
act
stat
amended
et
seq
ed
supp
act
created
purpose
reduc
ing
traffic
accidents
deaths
injuries
persons
resulting
traffic
accidents
directs
secretary
transportation
delegate
issue
motor
vehicle
safety
standards
shall
practicable
shall
meet
need
motor
vehicle
safety
shall
stated
objective
terms
supp
issuing
standards
secretary
directed
consider
relevant
available
motor
vehicle
safety
data
whether
proposed
standard
reasonable
practicable
appropriate
particular
type
motor
vehicle
extent
standards
contribute
carrying
purposes
act
act
also
authorizes
judicial
review
provisions
administrative
procedure
act
apa
orders
establishing
amending
revoking
federal
motor
vehicle
safety
standard
authority
review
today
whether
nhtsa
acted
arbitrarily
capriciously
revoking
requirement
motor
vehicle
safety
standard
new
motor
vehicles
produced
september
equipped
passive
restraints
protect
safety
occupants
vehicle
event
collision
briefly
summarized
hold
agency
failed
present
adequate
basis
explanation
rescinding
passive
restraint
requirement
agency
must
either
consider
matter
adhere
amend
standard
along
lines
analysis
supports
regulation
whose
rescission
issue
bears
complex
convoluted
history
course
approximately
rulemaking
notices
requirement
imposed
amended
rescinded
reimposed
rescinded
originally
issued
department
transportation
standard
simply
required
installation
seatbelts
automobiles
fed
reg
soon
became
apparent
level
seatbelt
use
low
reduce
traffic
injuries
acceptable
level
department
therefore
began
consideration
passive
occupant
restraint
systems
devices
depend
effectiveness
upon
action
taken
occupant
except
necessary
operate
vehicle
two
types
automatic
crash
protection
emerged
automatic
seatbelts
airbags
automatic
seatbelt
traditional
safety
belt
fastened
interior
door
remains
attached
without
impeding
entry
exit
vehicle
deploys
automatically
without
action
part
passenger
airbag
inflatable
device
concealed
dashboard
steering
column
automatically
inflates
sensor
indicates
deceleration
forces
accident
exceeded
preset
minimum
rapidly
deflates
dissipate
forces
lifesaving
potential
devices
immediately
recognized
substantial
experience
devices
estimated
nhtsa
passive
restraints
prevent
approximately
deaths
serious
injuries
annually
fed
reg
department
formally
proposed
standard
requiring
installation
passive
restraints
fed
reg
thereby
commencing
lengthy
series
proceedings
agency
revised
standard
include
passive
protection
requirements
fed
reg
agency
amended
standard
require
full
passive
protection
front
seat
occupants
vehicles
manufactured
august
fed
reg
interim
vehicles
built
august
august
carry
either
passive
restraints
lap
shoulder
belts
coupled
ignition
interlock
prevent
starting
vehicle
belts
connected
review
agency
decision
require
passive
restraints
found
supported
substantial
evidence
upheld
chrysler
department
transportation
preparing
upcoming
model
year
car
makers
chose
ignition
interlock
option
decision
highly
unpopular
led
congress
amend
act
prohibit
motor
vehicle
safety
standard
requiring
permitting
compliance
means
ignition
interlock
continuous
buzzer
designed
indicate
safety
belts
use
motor
vehicle
schoolbus
safety
amendments
pub
stat
amendments
also
provided
safety
standard
satisfied
system
seatbelts
submitted
congress
vetoed
concurrent
resolution
houses
effective
date
mandatory
passive
restraint
systems
extended
year
august
fed
reg
june
secretary
transportation
william
coleman
initiated
new
rulemaking
issue
fed
reg
hearing
testimony
reviewing
written
comments
coleman
extended
optional
alternatives
indefinitely
suspended
passive
restraint
requirement
although
found
passive
restraints
technologically
economically
feasible
secretary
based
decision
expectation
widespread
public
resistance
new
systems
instead
proposed
demonstration
project
involving
cars
installed
passive
restraints
order
smooth
way
public
acceptance
mandatory
passive
restraints
later
date
department
transportation
secretary
decision
concerning
motor
vehicle
occupant
crash
protection
app
coleman
successor
secretary
transportation
disagreed
within
months
assuming
office
secretary
brock
adams
decided
demonstration
project
unnecessary
issued
new
mandatory
passive
restraint
regulation
known
modified
standard
fed
reg
cfr
modified
standard
mandated
phasing
passive
restraints
beginning
large
cars
model
year
extending
cars
model
year
two
principal
systems
satisfy
standard
airbags
passive
belts
choice
system
install
left
manufacturers
pacific
legal
foundation
department
transportation
app
cert
denied
appeals
upheld
modified
standard
rational
nonarbitrary
regulation
consistent
agency
mandate
act
standard
also
survived
scrutiny
congress
exercise
authority
legislative
veto
provision
amendments
next
several
years
automobile
industry
geared
comply
modified
standard
late
july
nhtsa
reported
road
experience
thousands
vehicles
equipped
air
bags
automatic
safety
belts
confirmed
agency
estimates
benefits
systems
cars
equipped
automatic
crash
protection
systems
year
estimated
lives
saved
tens
thousands
serious
injuries
prevented
nhtsa
automobile
occupant
crash
protection
progress
report
app
cadc
hereinafter
ii
statement
explaining
rescission
nhtsa
maintained
longer
able
find
automatic
restraint
requirement
produce
significant
safety
benefits
notice
judgment
reflected
change
opinion
effectiveness
technology
change
plans
automobile
industry
agency
assumed
airbags
installed
new
cars
automatic
seatbelts
became
apparent
automobile
manufacturers
planned
install
automatic
seatbelts
approximately
new
cars
reason
lifesaving
potential
airbags
realized
moreover
appeared
overwhelming
majority
passive
belts
planned
installed
manufacturers
detached
easily
left
way
permanently
passive
belts
detached
required
type
affirmative
action
stumbling
block
obtaining
high
usage
levels
manual
belts
reason
agency
concluded
longer
basis
reliably
predicting
standard
lead
significant
increased
usage
restraints
view
possibly
minimal
safety
benefits
automatic
restraint
requirement
longer
reasonable
practicable
agency
view
requirement
require
approximately
billion
implement
agency
believe
reasonable
impose
substantial
costs
manufacturers
consumers
without
adequate
assurance
sufficient
safety
benefits
accrue
addition
nhtsa
concluded
automatic
restraints
might
adverse
effect
public
attitude
toward
safety
given
high
expense
limited
benefits
detachable
belts
nhtsa
feared
many
consumers
regard
standard
instance
ineffective
regulation
adversely
affecting
public
view
safety
regulation
particular
poisoning
popular
sentiment
toward
efforts
improve
occupant
restraint
systems
future
state
farm
mutual
automobile
insurance
national
association
independent
insurers
filed
petitions
review
nhtsa
rescission
passive
restraint
standard
appeals
district
columbia
circuit
held
agency
rescission
passive
restraint
requirement
arbitrary
capricious
app
observing
rescission
unrelated
agency
refusal
take
action
first
instance
concluded
case
nhtsa
discretion
rescind
passive
restraint
requirement
restricted
various
forms
congressional
reaction
passive
restraint
issue
proceeded
find
rescission
standard
arbitrary
capricious
three
reasons
first
found
insufficient
basis
rescission
nhtsa
conclusion
reliably
predict
increase
belt
usage
standard
held
insufficient
evidence
record
sustain
nhtsa
position
issue
well
justified
refusal
seek
evidence
render
rescission
second
majority
panel
concluded
nhtsa
inadequately
considered
possibility
requiring
manufacturers
install
nondetachable
rather
detachable
passive
belts
third
majority
found
agency
acted
arbitrarily
capriciously
failing
give
consideration
whatever
requiring
compliance
modified
standard
installation
airbags
allowed
nhtsa
days
submit
schedule
resolving
questions
raised
th
opinion
subsequently
agency
filed
notice
proposed
supplemental
rulemaking
setting
forth
schedule
complying
mandate
august
appeals
issued
order
staying
compliance
date
passive
restraint
requirement
september
requested
nhtsa
inform
whether
compliance
date
achievable
nhtsa
informed
october
based
representations
manufacturers
appear
practicable
compliance
achieved
september
november
granted
certiorari
november
appeals
entered
order
recalling
mandate
iii
unlike
appeals
find
appropriate
scope
judicial
review
troublesome
question
cases
act
amendments
concerning
occupant
crash
protection
standards
indicate
motor
vehicle
safety
standards
promulgated
informal
rulemaking
procedures
administrative
procedure
act
agency
action
promulgating
standards
therefore
may
set
aside
found
arbitrary
capricious
abuse
discretion
otherwise
accordance
law
citizens
preserve
overton
park
volpe
bowman
transportation
freight
system
believe
rescission
modification
standard
subject
test
section
act
procedural
judicial
review
provisions
administrative
procedure
act
shall
apply
orders
establishing
amending
revoking
federal
motor
vehicle
safety
standard
suggests
difference
scope
judicial
review
depending
upon
nature
agency
action
petitioner
motor
vehicle
manufacturers
association
mvma
disagrees
contending
rescission
agency
rule
judged
standard
use
judge
agency
refusal
promulgate
rule
first
place
standard
petitioner
believes
considerably
narrower
traditional
test
reject
view
act
expressly
equates
orders
revoking
establishing
safety
standards
neither
act
apa
suggests
revocations
treated
refusals
promulgate
standards
petitioner
view
render
meaningless
congress
authorization
judicial
review
orders
revoking
safety
rules
moreover
revocation
extant
regulation
substantially
different
failure
act
revocation
constitutes
reversal
agency
former
views
proper
course
settled
course
behavior
embodies
agency
informed
judgment
pursuing
course
carry
policies
committed
congress
least
presumption
policies
carried
best
settled
rule
adhered
atchison
wichita
bd
trade
accordingly
agency
changing
course
rescinding
rule
obligated
supply
reasoned
analysis
change
beyond
may
required
agency
act
first
instance
holding
fully
recognize
egulatory
agencies
establish
rules
conduct
last
forever
american
trucking
atchison
agency
must
given
ample
latitude
adapt
rules
policies
demands
changing
circumstances
permian
basin
area
rate
cases
forces
change
always
necessarily
point
direction
deregulation
abstract
reason
presume
changing
circumstances
require
rescission
prior
action
instead
revision
even
extension
current
regulation
congress
established
presumption
judicial
review
start
presumption
contrary
petitioners
views
safety
regulation
changes
current
policy
justified
rulemaking
record
removal
regulation
may
entail
monetary
expenditures
costs
enacting
new
standard
accordingly
may
easier
agency
justify
deregulatory
action
direction
agency
chooses
move
alter
standard
judicial
review
established
law
department
transportation
accepts
applicability
arbitrary
capricious
standard
argues
standard
reviewing
may
set
aside
agency
rule
rational
based
consideration
relevant
factors
within
scope
authority
delegated
agency
statute
disagree
formulation
scope
review
arbitrary
capricious
standard
narrow
substitute
judgment
agency
nevertheless
agency
must
examine
relevant
data
articulate
satisfactory
explanation
action
including
rational
connection
facts
found
choice
made
burlington
truck
lines
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cars
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belts
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infra
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alone
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bag
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belt
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technology
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safety
design
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chrysler
department
transportation
statute
agency
defer
industry
failure
develop
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cars
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technology
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cars
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public
reaction
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reasons
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reasons
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petitioners
submission
courts
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appellate
counsel
post
hoc
rationalizations
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action
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truck
lines
well
established
agency
action
must
upheld
basis
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chenery
american
textile
mfrs
institute
donovan
petitioners
also
invoke
decision
vermont
yankee
nuclear
power
natural
resources
defense
council
though
talisman
agency
decision
definition
unimpeachable
specifically
submitted
require
agency
consider
alternative
essence
dictate
agency
procedures
follow
petitioners
misread
vermont
yankee
misconstrue
nature
remand
order
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yankee
held
may
impose
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upon
agency
require
today
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man
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plans
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belts
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reg
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justify
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well
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seek
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render
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app
petitioners
object
conclusion
view
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support
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noted
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choice
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truck
lines
supra
generally
one
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justification
rescinding
regulation
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search
evidence
cases
agency
explanation
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passive
restraint
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view
facts
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limitations
record
supporting
agency
decision
start
accepted
ground
used
seatbelts
unquestionably
save
many
thousands
lives
prevent
tens
thousands
crippling
injuries
unlike
recent
regulatory
decisions
reviewed
industrial
union
dept
american
petroleum
institute
american
textile
mfrs
institute
donovan
safety
benefits
wearing
seatbelts
doubt
challenged
benefits
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monetary
costs
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standard
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next
fact
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evidence
support
agency
finding
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belts
predicted
yield
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evidence
record
consisting
surveys
drivers
automobiles
equipped
passive
belts
reveals
doubling
usage
rate
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manual
belts
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rulemaking
statement
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controversy
cases
centers
conclusions
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studies
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ignition
interlocks
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reg
statements
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factor
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usage
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motorists
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wear
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belts
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costs
well
benefits
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conclusion
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prediction
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regulation
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specifically
agency
fears
public
may
resent
paying
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belt
systems
expressly
dependent
assumption
detachable
automatic
belts
produce
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safety
benefits
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findings
likely
increase
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judgment
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monetary
costs
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judgment
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mind
congress
intended
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factor
act
committee
intends
safety
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overriding
consideration
issuance
standards
bill
committee
recognizes
secretary
necessarily
consider
reasonableness
cost
feasibility
adequate
leadtime
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standards
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technological
ability
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well
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economic
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vehicle
safety
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purpose
bill
standard
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continuous
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agency
failed
offer
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suggest
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egress
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belts
general
motors
obtained
agency
approval
install
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spool
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reg
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egress
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belts
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agency
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belt
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interlock
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app
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public
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television
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cert
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agency
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vacate
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remand
cases
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matter
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consideration
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ordered
footnotes
senate
committee
commerce
reported
promotion
motor
vehicle
safety
voluntary
standards
largely
failed
unconditional
imposition
mandatory
standards
earliest
practicable
date
course
commensurate
highway
death
injury
toll
secretary
general
authority
promulgate
safety
standards
act
delegated
administrator
national
highway
traffic
safety
administration
nhtsa
cfr
opinion
use
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nhtsa
agency
interchangeably
referring
national
highway
traffic
safety
administration
department
transportation
secretary
transportation
early
process
assumed
passive
occupant
protection
meant
installation
inflatable
airbag
restraint
systems
see
fed
reg
however
agency
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sixth
circuit
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issue
submitted
congress
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house
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affirmatively
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majority
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bag
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gorham
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rev
see
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automobile
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reg
amendments
prohibited
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simply
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comments
chrysler
docket
notice
app
chrysler
corp
memorandum
proposed
alternative
changes
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docket
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app
general
motors
corp
response
dept
transportation
proposal
occupant
crash
protection
docket
notice
may
app
see
also
chrysler
department
transportation
department
transportation
expresses
concern
adoption
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new
notice
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even
need
decide
question
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cause
rescind
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manufacturers
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comply
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permissible
agency
temporarily
suspend
passive
restraint
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airbag
mandate
studied
explain
text
option
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revoked
volkswagen
sold
approximately
rabbits
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detachable
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ignition
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chevettes
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believes
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rabbits
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belts
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reg
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commissioned
number
surveys
public
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better
understand
people
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belts
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react
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surveys
reveal
public
opposed
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belts
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wear
belts
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people
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constraints
vermont
yankee
nuclear
power
natural
resources
defense
council
respondents
maintain
appeals
simply
stayed
effective
date
standard
validly
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required
mandatory
passive
restraints
new
cars
september
need
choose
views
agency
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standard
pending
consideration
required
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justice
rehnquist
chief
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powell
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join
concurring
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opinion
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seatbelt
explicitly
approved
standard
agency
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explain
declined
leave
requirements
intact
case
agency
gave
explanation
course
agency
provide
rational
explanation
may
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decision
rescind
entire
standard
believe
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view
detachable
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seatbelts
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agency
adequately
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standard
insofar
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statute
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secretary
transportation
issue
motor
vehicle
safety
standards
also
requires
ach
standard
shall
practicable
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meet
need
motor
vehicle
safety
supp
rejects
agency
explanation
conclusion
substantial
uncertainty
whether
requiring
installation
detachable
automatic
belts
substantially
increase
seatbelt
usage
agency
chose
rely
study
showing
substantial
increase
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cars
equipped
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interlock
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equipment
consumers
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ante
reasonable
agency
decide
study
support
conclusion
concerning
effect
automatic
seatbelts
installed
cars
whether
consumer
wants
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ignition
interlock
system
rejects
explanation
seem
grounds
believe
seatbelt
use
occasional
users
substantially
increased
detachable
passive
belts
ante
agency
adequately
explain
rejection
grounds
seems
agency
explanation
means
model
adequate
agency
acknowledged
probably
increase
belt
usage
concluded
increase
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worth
cost
mandatory
detachable
automatic
belts
fed
reg
agency
obligation
articulate
rational
connection
facts
found
choice
made
ante
quoting
burlington
truck
lines
believe
met
standard
agency
explicitly
stated
increase
educational
efforts
attempt
promote
public
understanding
acceptance
use
passenger
restraint
systems
fed
reg
also
stated
initiate
efforts
automobile
manufacturers
ensure
public
automatic
crash
protection
technology
available
succeed
agency
consider
regulatory
action
assure
last
decade
enormous
advances
crash
protection
technology
lost
agency
changed
view
standard
seems
related
election
new
president
different
political
party
readily
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members
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brought
people
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agency
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agency
remains
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bounds
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congress
entitled
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records
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priorities
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philosophy
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course
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administration
may
refuse
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statutory
standards
carrying
regulatory
functions
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correctly
concludes
ante
congress
required
agency
require
passive
restraints