T started a rulemaking process to define "fake news" that could be prohibited and sanctioned. Using its agency Twitter feed, T announced a proposal to define "fake news" as any news that cannot be confirmed by two sources that are independent of each other. One of the sources has to be identified. T also put this proposal on its agency website. T did not publish the proposal anywhere else. T stated that interested persons could make comments about the proposal using T's Facebook page, but the comments had to be received within 20 days. Comments could not be sent any other way. Many journalists opposed this proposal because they believed that anonymous sources and government leaks were valid ways to report on corruption. T adopted the final rule with the same language as the proposed rule and rejected the journalists' comments. The rule was published on the T agency website but nowhere else. There was no explanation or rationale for the published rule.

What is rulemaking? What are federal APA requirements for rulemaking? Has the T agency properly followed the first two requirements of notice and comment procedure prior to adoption of the rule? Has the T agency properly followed the last two requirements for rulemaking procedure including statement and publication at the adoption stage of the rule?