Second, the Court has shown that it is willing to rely upon alternative rationales to achieve the same result "as would a more robust nondelegation doctrine rationale". This approach is significant because in theory, such a rationale could endanger previously accepted delegations to the executive. Roy E. Brownell II criticized the Clinton administration for its exercise of the Line Item Veto Act, charging that it should have restricted its cancellation powers only to statutory provisions that remain in the realm of national security. He argued that had the Clinton administration limited its use of the Line Item Veto Act in this fashion, it would have ensured that when the constitutionality of the Act was inevitably challenged, the challenge would have been based on terms most favorable to the Executive. Brownell suggested that a test case brought forth on the grounds of national security would have likely acknowledged the existence of "National Security Rescission", "a narrow statutory construction limiting the area of presidential cancellation power to within the field of national security. Such a result ... would have assured that the President maintained cancellation authority over a sixth of the federal budget." Steven G. Calabresi argued that although the Court had denied this, the instant decision was really a "Nondelegation doctrine case masquerading as a bicameralism and presentment case". He also suggested that this decision was "the blockbuster separation of powers case of the Rehnquist years". Subsequent developments Though the Supreme Court struck down the Line Item Veto Act in 1998, President George W. Bush asked Congress to enact legislation that would return the line item veto power to the Executive. First announcing his intent to seek such legislation in his January 31, 2006 State of the Union address, President Bush sent a legislative proposal Legislative Line Item Veto Act of 2006 to Congress on March 6, 2006, urging its prompt passage. Senator Bill Frist, Senator John McCain, and Republican Whip Senator Mitch McConnell jointly introduced this proposal. On that same day, Joshua Bolten, the Director of the Office of Management and Budget, gave a press conference on the president's line-item veto proposal. Bolten explained that the proposed Act would give the President the ability to single out "wasteful" spending and to put such spending on hold. While the spending line-item is on hold, the President can send legislation to Congress to rescind the particular line-item. The proposal would then be