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Replying to your first point, here's the relevant law (FAA 702): http://www.law.cornell.edu/uscode/text/50/1881a



That's a quite long quote, and it partly contradicts your assertions with statements like

> The procedures adopted in accordance with paragraph (1) shall be subject to judicial review pursuant to subsection (i).

... and the actual contents of subsection (i). You have to be more specific.




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