The Department of Homeland Security Has Proposed a New Rule

The Department of Homeland Security has proposed a new rule that would require those born outside the United States to be subject to additional security clearance steps at the airport.The proposed rule does not include a study that such persons pose additional risks for air travel.How can the regulation be challenged?​

A) ​The absence of a study means that the agency has not complied with the requirements of the APA.
B) ​The rule cannot be challenged until the comment period is over and there has been promulgation.
C) The rule does not require study of the agency has information that creates a national security emergency.
D) All of the above statements are true.