Federal contracts, property, works, officers, employees, budgets, or funds, including the provisions of chapters 5 and 7 of title 5 [the APA], shall apply to the exercise of the powers of the Postal Service.” 39 U.S.C. § 410(a). The Postal Service claims that the well-established presumption favoring judicial review of administrative action is overcome here by the explicit terms of § 410(a). We disagree. The Postal Service assumes that any right that appellees have to judicial review must arise under the APA. This assumption is mistaken. There is no doubt that § 410(a) exempts the Postal Service from the strictures of the APA in cases involving the APA’s procedural requirements. See, e.g., Nat’l Easter Seal Soc’y for Crippled Children & Adults v. USPS, 656 F.2d 754, 766 (D.C.Cir.1981) (<HOLDING>). It is also established that, in PRA, Congress
holding that substantive changes made by administrative agencies in regulations are required to comply with certain notice and comment requirements which include publication of a notice of proposed rulemaking in the federal register an opportunity for interested persons to comment on that notice and after consideration of these comments publication of the final rule with a general statement of its basis and purpose citing 5 usc  553b c holding that requiring notice and comment is not required where the record demonstrates that the agency in fact has had the benefit of petitioners comments holding a county police civil service board violated officers due process rights by failing to follow its own procedures in their termination proceedings holding that although notice and comment procedures are not required to trigger chevron deference such procedures are significant  in pointing to chevron authority holding that the postal service was not required to follow notice and comment rulemaking procedures