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" ... The Herculean task of creating those portals as a first approximation was arguably alleviated at the outset by E.O. 13891’s call for agencies-wide rescission of guidance that “should no longer be in effect.” The order discussed actively “rescinding” guidance documents, but those not added to the database would apparently nonetheless be void. (There is and remains a case to be made for lenience or a safe-harbor for those who had come to rely on a particular deleted guidance where great uncertainty may otherwise have prevailed, but that would have represented a mere growing pain.) ... "