Assume that the United States Department of Agriculture (USDA) administers a school lunch subsidy program that provides federal funds to schools that comply with certain federal statutory and regulatory requirements regarding school lunches. Assume that the program is not a grant or benefits program as defined by the Administrative Procedure Act, Section 553(a)(2). A number of groups collectively file a rulemaking petition with the USDA asking the USDA to adopt a rule that requires schools to serve at least four vegetarian meals per month. In response to the rulemaking petition, the USDA published a "Notice of Vegetarian Meal Requirements" in the Federal Register inviting comments by all interested parties on the request in the rulemaking petition. A number of groups file comments with the agency, some in favor, and some against the proposal. The Beef Producers Association files a comment with the agency opposing any requirement of having vegetarian lunches. After receiving comments and reviewing its current legal authority, the USDA denies the rulemaking petition and publishes a separate "Policy Statement" in the Federal Register that states in relevant part that the agency interprets its current regulations to allow the agency to require vegetarian meals, and that the agency will