Milliken & Co. v. FTC, 439 U.S. 958, 99 S.Ct. 362, 58 L.Ed.2d 351 (1978); United States v. W.H. Hodges & Co., Inc., 533 F.2d 276 (5th Cir.1976) (per curiam), and submission to investigation preliminary to regulatory action, see Environmental Defense Fund v. Costle, 636 F.2d 1229 (D.C.Cir.1980), each of which has been held not to require notice and comment. Indeed, the impact of the inspection plan before us falls well short of the regulation in Guardian Federal Savings & Loan Association v. Federal Savings & Loan Insurance Corp., 589 F.2d 658 (D.C.Cir.1978), where the court held that agency provisions for selecting, among other things, auditors and auditing criteria did not have substantial impact. Id. at 664—68; see also Associated Dry Goods Corp. v. EEOC, 720 F.2d 804 (4th Cir.1983) (<HOLDING>). East would have the APA’s procedures
holding act qualifies as exemption statute under exemption 3 holding that an agencys informal interpretation of a statute it administers is entitled to deference to the extent it has the power to persuade holding that names of private individuals appearing in files within the ambit of exemption 7c are categorically exempt from disclosure unless disclosing such information is necessary in order to confirm or refute compelling evidence that the agency is engaged in illegal activity holding that disclosure rule regulating access to agencys investigative files was within procedural rules exemption from informal rulemaking holding that names and address of private individuals appearing in files within the ambit of exemption 7c  are exempt from disclosure