Heidi Heitkamp actually said...

If we were in compliance before doing what we are doing, then how can we so dramatically be out of compliance right now?

Being guidance is not enforceable.

To simply unilaterally, without comment or process, change the rules does not seem to be what a guidance should do.

A guidance should not hurt you, right. A guidance should only help you be able to meet the requirements that are set out in the statute and ...