as the PRA outlines (and the article goes through), publishing notice to the Federal Register does not suffice to get around the PRA, it is just a step in the process.

It is just "notice" of their intention to do it. They still have to do the other pieces, including getting their OMB control number.

Of course, as the article points out, all of this is pretty moot, if they're going to get the police to drag you away and not let you fly, irrespective of the position in law.