The San Diego Parachute Club practiced their parachute exercises every weekend, and usually they did so in the air space approaching the San Diego, California, international airport.
The airport management never objected to the parachute club, but asked the Federal Aviation Agency (FAA) to block the parachuting in the airport air space.
The FAA issued an Administrative Rule that did not require publication that prohibited the parachuting in the air space.
The San Diego Parachute Club immediately challenged the rule saying it should have been a Substantive Rule that had to be published, and giving them the opportunity to protest the rule.
The FAA agreed and published the Substantive Rule in the Federal Register; The San Diego Parachute Club filed a written objection.
Consider the rights the San Diego Parachute Club have going forward.
What are their initial rights in protesting the FAA Substantive Rule forbidding their parachuting at the San Diego Airport?
What additional rights can they pursue if the FAA continues to move forward on the restriction?
Include the details of the parachute club's rights to protest all the way into the Federal Court System?