We need to start sanctioning alphabet agency administrators who take license with their legal authorities. If an administrator stretches the meaning of what they are legitimately allowed to do (like defining “refugee” to mean anyone who crosses the border, or defining “land use” to mean not using the land), then they should be held personally liable. That means taking their pensions, homes, boats, you name it, just like they now personally sanction oligarchs in the name of foreign policy aims.
I like your thinking.