Even when Congress delegates power to administrative agencies, it may wish to retain control of agency action. Like the delegation of power, congressional retention of power raises separation of powers concerns.

 I. Congressional Appointment of Officers 

Suppose Congress wishes to create a new administrative agency. In creating the agency, may it also decide who'll run the agency, or fill other agency positions? The answer is no. In Buckley v. Valeo, the Supreme Court held that...