Does the statute of limitations bar a substantive challenge to the validity of the regulations themselves?

The statute of limitations also bars any substantive challenge by Plaintiffs to the validity of the regulations themselves. "After the six-year limitations period has expired, a challenge to the validity of an agency's rule can only be attacked in two ways: (1) through an 'as applied' challenge requesting judicial review of the agency's adverse application of the rule to the particular challenger, or (2) by petitioning the agency for amendment or rescission of the rule and then appealing the agency's decision." Oksner v. Blakey, 2007 WL 3238659, at *6 (N.D. Cal. Oct. 31, 2007) (citing Wind River Min. Corp. v. United States, 946 F.2d 710, 715 (9th Cir. 1991)).