Originally Posted by hoffmang
You keep trying to wager on the OAL petition with stakes that the OAL is not going to rule on.
I'm willing to bet that if OAL accepts the petition then it is either 280'ed by DOJ or OAL calls Alison's letter an underground regulation.
Those are likely outcomes. I realize there's no need for OAL to squarely decide whether the competing interpretation has any merit which makes it difficult to come up with a bet about it.