There’s no meaningful difference between the plan and the CP.
Bremer 22 – Professor of Law at the University of Notre Dame, J.D. from New York University.
Emily S. Bremer, “Introducing Incorporation by Reference,” The Regulatory Review, 08-24-2022, https://www.theregreview.org/2022/08/24/bremer-introducing-incorporation-by-reference/
Through the practice of incorporation by reference, government agencies enact into law the standards developed by private organizations—often without giving the public free, easy access to what those private standards say. It is a modest caricature to say that incorporation by reference allows government officials to shortcut their work by imposing on individuals and businesses the relatively secret dictates of private actors. Introduced this way, incorporation by reference should pique the interest of professional students and anyone interested in the rule of law.