 um we ought to have a de novo standard of review what is that it means that there's no deference at all we don't even really care it's totally up to the courts to decide now is this what congressional intent was the agencies are sort of cut out of this they are still executing the law they still have a role but then you know opining over things that they created and then deciding that that's what's going to be moving forward that has to end entirely thirdly