409, 421, 61 S.Ct. 999, 1004, 85 L.Ed. 1429, 1435 (1941). Notwithstanding, a rulemaking is different from a contested case and follows a different standard for disqualification. Ass’n of Nat’l Advertisers, Inc. v. FTC, 627 F.2d 1151, 1165-70 (D.C.Cir.1979); accord Lead Indus. Ass’n v. EPA, 647 F.2d 1130, 1179 (D.C.Cir.1980). This different standard is based on the broad distinctions between rulemaking and a contested case proceeding, as well as the different due process concerns. In a rulemaking, agencies are expected to “allocate resources more efficiently, act with greater speed, and give specific notice to industries of the scope” of the proposed rule. Ass’n of Nat’l Advertisers, 627 F.2d at 1166; see also Nat’l Petroleum Refiners Ass’n v. FTC, 482 F.2d 672, 690-91 (D.C.Cir.1973) (<HOLDING>). “The legitimate functions of a policymaker,
recognizing that breach of contract cause of action accrues at time of the breach recognizing the efficiency that accrues to rulemaking proceedings holding that the right to recover statutory damages accrues at the moment the privacy act was violated holding that a cause of action for breach of contract accrues at the time of the breach holding that state liability only accrues as expressly authorized by law