A Slip of the Congressional Pen

Agweb notes a delay in the dairy disaster signup, because FSA had to do regulations.
Normally in farm legislation Congress exempts USDA from complying with the usual requirements for getting public input--i.e., issuing a notice in the Federal register asking for comments, or at least doing an interim rule with provision for amending it in the final rule. Why is that important?

For speed. Requiring comment slows down the implementation process several ways:

1. First, if the regulations have to be done before the implementation, rather than concurrently with it, it's like the difference between serving concurrent sentences of 10 years versus consecutive.
2. Second, if you get comments and really consider them (two big "ifs"), then you likely end up making changes. While the change may improve the program, it's likely to slow the development of forms and software.
3. Third, distractions. Usually in FSA the same people who are working on the forms and instructions for the field are also the ones who do the regulations. That's good for coordination but poor for single-minded concentration on implementation.

Why my parenthetical in no. 2? The nitty-gritty of most farm programs is not of interest to most people. So comments often come from the usual suspects--the farm organizations which pushed the legislation in the first place. If you're trying to implement their program, then you already are trying to follow their intentions (because that's the intentions of the members of Congress), so comments don't do much. [Note: Statement true as of 10 years ago--might have changed in the interim, but I doubt it.]