; and (B) may not be revised, updated, or replaced pursuant to the standards, guidelines, and procedures established pursuant to paragraph (1) before the expiration of the 36-month period beginning upon such certification. (3) Exemption from rulemaking Until such time as the Administrator promulgates regulations implementing paragraphs (1) and (2) of this subsection, the Administrator may adopt policies and procedures, notwithstanding any other provisions of law, necessary to implement such paragraphs without undergoing notice and comment rulemaking and without conducting regulatory analyses otherwise required by statute, regulation, or executive order. .