Problem
Write 3-5 sentences discussing whether the expansion of expedited removal should have gone through Notice and Comment before being implemented. You may want to consider the following questions: (i) Are you persuaded that the good cause exception to N&C applies? (in other words, that it would be impractical, unnecessary, or contrary to the public interest to go through N&C?); (ii) Is DHS's "discretionary" request for comments after making the change effective an adequate substitute?