dissenting.
When Congress enacts a generous program to provide relief for the victims of a natural disaster, the Secretary of Agriculture has a duty to implement that program in the spirit which motivated its enactment even if he believes a more parsimonious policy will serve the national interest. On January 2, 1974, Congress enacted such a program to benefit, among others, the Florida farmers who had suffered serious losses as the result of a disaster that the President had declared on May 26,1973. Pub. L. 93-237. On the date the statute was enacted, as well as the date of the disaster and the date of the President’s declaration, regulations were in place that required the Department to give appropriate notice to the State Director, the appropriate county officials, the agricultural lenders in the area, and the public. See 7 CFR § 1832.3(a) (1973). Ante, at 930-931, n. 1. The regulations plainly stated that effective notice should be given “immediately.”
The District Court found — and the Court does not disagree — that the Secretary failed to comply with § 1832.3(a). For several weeks after the enactment of the statute, the Secretary took no public action. On February 27, he promulgated a new announcement — which was explicitly intended to “supplement” the existing notice regulations — requiring that advice be given to the news media. Pursuant to that announcement, an ambiguous and uninformative news release was prepared and distributed. The Court nevertheless holds that (1) the release complied with the supplementary regulation issued on February 27 and (2) the supplementary regulation somehow superseded the specific § 1832.3(a) notice provisions which were already in place when the *944statute was enacted. These holdings, I submit, misread the regulations and are not faithful to the intent of the Congress that enacted the governing statute.
Before explaining in greater detail why I agree with the District Court and the Court of Appeals’ findings concerning the Secretary’s flagrant violation of the notice regulations, I shall briefly comment on the timeliness of the action and the Court’s correct rejection of the Government’s primary challenge to the propriety of that remedy.
i — I
This litigation was commenced on August 19,1976. In the Court of Appeals, the Secretary contended that the action was not timely because the emergency loan program authorized by Pub. L. 93-237 expired on April 2, 1974. The Court of Appeals held, however, that “where, as here, exigent circumstances beyond the farmers’ control precluded intended beneficiaries from applying for loans, the agency had the power to extend the loan period and the District Court was within its power in ordering the agency to do so. To hold otherwise would allow the FmHA to totally fail to provide notice to congressionally intended potential beneficiaries and avoid being called to task for such conduct.” Payne v. Block, 714 F. 2d 1510, 1517 (CA11 1983).1 In this Court, the Secretary has abandoned his claim that he had no power to extend the deadline for loan applications. Ante, at 935, n. 5.
The Secretary has argued, however, that the remedy ordered by the District Court was improper because it rested on an equitable estoppel theory. The Court today correctly — and unanimously — rejects this argument, thus answering the central question of law that prompted it to grant *945certiorari in a way that completely repudiates the submission of the Solicitor General.2 Thus, neither the doctrine of estoppel nor the passage of time since the emergency loan program’s administrative deadline was authorized has any bearing on the question that controls the outcome of the case. That question is whether the Secretary provided the intended beneficiaries of the emergency loan program with the notice that was required by law. The question is best answered after briefly describing the historical context in which it arose.
II
In 1972 and 1973, the Secretary of Agriculture took the position that he was not obligated to implement emergency loan programs authorized by Congress if he thought it was unwise *946to do so.3 His position was consistent with administration policy concerning other programs authorized by Congress at that time. See Train v. City of New York, 420 U. S. 35 (1975); Berends v. Butz, 357 F. Supp. 143 (Minn. 1973). As a consequence of this fundamental disagreement between the Secretary and Congress, two legislative measures were adopted that provide the background for this case. First, in response to the Secretary’s view that the then existing emergency loan programs were too generous, Congress made three important changes in the programs effective on April 20, 1973. It increased the interest rates from one percent to five percent; it denied eligibility to farmers who could obtain credit elsewhere; and it discontinued the practice of forgiving $5,000 of the principal indebtedness. Thus, after April 20, 1973, the emergency loans were considerably less attractive than they had been before.
Second, after several months of uncertainty as to whether the old or the new terms applied to disasters during the period in which this case arose, Congress adopted Pub. L. 93-237 for the specific purpose of making the earlier, more generous loan terms available to a specific class of farmers, including those in northern Florida, who suffered severe crop losses as a result of a specific disaster. Thus, respondent farmers had two opportunities to apply for emergency loans — between May 26, 1973, and January 2, 1974, at the higher rate, and between January 2, 1974, and April 2, 1974, at the more favorable rate.
Throughout this period — and for several years thereafter — the Secretary’s regulations provided a detailed procedure for giving notice “immediately” to the appropriate County Supervisors and requiring the State Directors to *947make “such public announcements as appear appropriate.”4 The District Court found, and the Court of Appeals agreed, that the Secretary not only failed to comply with this provision, but actually disseminated a good deal of misinformation. Thus, for example, the State Director advised the County Supervisors, in information intended for public release, that applications had to be filed prior to July 30, 1973 — which was correct for loans relating to physical damage — but totally omitted any reference to the fact that the deadline for production loss loans was several months later. In my opinion, however, the more important violations were those that occurred during the second application period — after January 2,1974, when Congress authorized loans at an interest rate of one percent and on terms that it is difficult to believe any informed and eligible farmer would have refused.
M hH J — I
The notice regulations that were in effect during the first application period remained in effect during the 90 days after the enactment of Pub. L. 93-237 on January 2, 1974.5 Not*948withstanding the dramatic change in the loan terms authorized by that Act, no notice of any kind was published in the Federal Register — or anywhere else — until February 27, 1974, when two-thirds of the reopened application period had already expired. This complete silence for a period of almost two months was unquestionably a plain violation of the regulations’ command — if the regulations were, in fact, applicable — that the “State Director will notify the appropriate County Supervisors immediately . . . and will make such public announcements as appear appropriate.” 7 CFR § 1832.3(a)(1) (1973) (emphasis added).
On February 27, 1974, the Secretary did publish the conditions of the new program in the Federal Register, and also supplemented the existing notice regulation with the publication of staff instructions that State Directors and County Supervisors should inform the news media of the provisions of Pub. L. 93-237. See 39 Fed. Reg. 7569-7571.
It is thus perfectly clear that the Secretary did not comply with the § 1832.3(a) notice regulations that were in effect when Pub. L. 93-237 was enacted. The Court does not disagree with this conclusion. Rather, it takes the remarkable position that the failure to follow those notice provisions is irrelevant because the Secretary did comply with the instructions promulgated in February. This reasoning is severely flawed.
First, the Court’s conclusion does not accord with the language and structure of the February 27 notice provisions. Nothing in these new staff instructions stated or implied that they were intended to replace or to withdraw any of the preexisting notice procedures. Instead, the published notice explicitly stated that the publication of the new provisions “supplements and modifies” the existing regulations, including § 1832.3(a). 39 Fed. Reg. 7569 (1974). “Supplementing” and “modifying” are hardly words that suggest the kind of wholesale obliteration envisioned by the majority.6
*949Second, under the Court’s own logic, § 1832.3(a) should have been fully applicable for the first two months of the second loan period. If, as the Court suggests, it was the February 27 Federal Register publication that superseded the existing regulations with respect to Pub. L. 93-237, then presumably the earlier regulations were fully in force until then. Yet the Court flatly states that § 1832 simply was inapplicable in the second loan period — even for the significant amount of time in which the “superseding” regulation was not in place.
Finally, the Court’s analysis conflicts with the obvious purpose of Congress in passing Pub. L. 93-237. If the new instructions are given the construction that the Court accepts today, they enabled the Secretary to defy or ignore the will of Congress just as effectively as when he simply refused to make emergency loans on the terms authorized by Congress. Given the fact that regulations requiring adequate notice were in effect at the time Congress adopted a special statute to benefit the victims of specific disasters already declared by the President, surely the Secretary had a duty to comply with the pre-existing regulations during the 90-day period specified in the Act. To conclude otherwise, as the Court does, has an anomalous result. Under the Court’s analysis, Congress, in liberalizing and extending the loan program, also created some kind of Bermuda Triangle that made blatant violations of the longstanding § 1832.3(a) notice requirements mysteriously disappear and have no legal effect. Indeed, the incongruous consequence of the Court’s reasoning is that, if Congress had never passed the new statute, the Secretary would have continued to be bound by the extensive *950§1832.3 notice provisions in January and February 1974. For those months would have been within the original loan period. By extending the period and making the terms more favorable, however, Congress somehow vitiated — or permitted the Secretary to vitiate — those notice provisions for the months and program in question.
Thus, the majority’s conclusion that § 1832.3(a) did not apply to the Secretary’s administration of Pub. L. 93-237 is erroneous.
I also disagree with the majority’s conclusion that the Secretary’s efforts satisfied the February 27 notice requirements, which were later codified at 7 CFR § 1832.82 (1975). Those duly promulgated requirements unequivocally stated a mandatory obligation: “State Directors and County Supervisors will inform the news media including newspapers, radio, and television in the affected counties of the provisions of P. L. 93-237.” 39 Fed. Reg. 7570 (1974). The Secretary does not argue that the single publication of the emergency loan terms in the Federal Register itself constituted compliance with this duty. His claim of compliance during the second application period also rests on the preparation and distribution of a news release. That release, however, did not disclose the loan terms that were authorized by Pub. L. 93-237. Indeed, the only reference to the new statute, the “provisions” of which the Department had a mandatory obligation to explain, was the following: “These loan applications will be taken under the terms of a new law (P. L. 93-237) enacted January 2, 1974.” App. to Pet. for Cert. 57a.
An instruction to inform the news media “of the provisions of P. L. 93-237” surely should be construed to require that the news media be informed of the loan terms that the statute authorized.7 Such a construction would reflect, not an inter*951pretation that “runs roughshod over the established proposition that an agency’s construction of its own regulations is entitled to substantial deference,” ante, at 939, but a simple adherence to the regulation’s “plain language.” Cf. Young v. Community Nutrition Institute, post, p. 974. It is therefore clear that the new § 1832.82 requirements also were not followed.
In short, the Secretary followed neither the pre-existing §1832.3 requirements nor the newly promulgated §1832.82 requirements. The effect was predictable. Although thousands of farmers were eligible for the program, no more than four received loans. As a result, although Congress had shown its intense commitment to this program by repeatedly legislating and by honing the program in an attempt to overcome executive intransigence, the sustained congressional efforts went for naught.8
*952IV
In my opinion, the Court’s holding allows an executive agency far too much discretion to disregard the plain intent of Congress. The Secretary did not implement the program authorized by Pub. L. 93-237 in the spirit in which it was enacted. “As conceived and passed in both Houses, the legislation was intended to provide a firm commitment of substantial sums within a relatively limited period of time in an effort to achieve an early solution of what was deemed an urgent problem. We cannot believe that Congress at the last minute scuttled the entire effort by providing the Executive with the seemingly limitless power to withhold funds from allotment and obligation.” Train v. City of New York, 420 U. S., at 45-46. The failure to advise the farmers of the congressionally mandated loan provisions was merely a variant of the theme repudiated in Train.
I would affirm the judgment of the Court of Appeals.
In a footnote, the Court of Appeals added:
“We emphasize that Congress had previously invoked, and ‘expected’ FmHA would invoke, a similar reopening remedy in 93-237 when potential beneficiaries of the program were confused as to the program’s terms.” 714 F. 2d, at 1517, n. 26.
The only “Question Presented” by the Solicitor General in the Government’s certiorari petition was the following: “Whether the Secretary of Agriculture may be equitably estopped from enforcing a valid regulation establishing a deadline for filing of applications for Farmers Home Administration emergency loans on the ground that the agency’s news release announcing the availability of loans did not specify the generous terms of the program.” Pet. for Cert. I (emphasis added).
To its credit, in rejecting the Government’s equitable estoppel argument, the Court belatedly acknowledges that it unnecessarily prolonged this litigation by vacating the first judgment entered by the Court of Appeals in 1983 and remanding for further consideration in the light of our decision in Heckler v. Community Health Services, Inc., 467 U. S. 51 (1984). See Block v. Payne, 469 U. S. 807 (1984).
In light of the possible incongruity of considering this challenge 13 years after the natural disaster that triggered the loan obligations, moreover, it is important to emphasize that there has been no suggestion of dilatoriness by respondents. For unexplained reasons, the case took five years before it reached trial. Since then, it has been the Government that has prolonged the proceedings every step of the way — by appealing to the Court of Appeals; by asking this Court to dispose of the case in light of an equitable estoppel case; and by seeking certiorari again after the Court of Appeals correctly noted the inapplicability of the estoppel doctrine. Thus, the unusual length of time between the original program and our Consideration of it is irrelevant; to the extent that it is relevant, the Government bears the responsibility for almost all of the delay.
See Impoundment of Appropriated Funds by the President: Joint Hearings before the Ad Hoc Subcommittee on Impoundment of Funds of the Senate Committee on Government Operations and the Subcommittee on Separation of Powers of the Senate Committee on the Judiciary, 93d Cong., 1st Sess., 532 (1973) (testimony of Secretary Butz).
At all relevant times the Code of Federal Regulations contained the following provisions:
“(a) . . . The State Director [of the FmHA] will notify the appropriate County Supervisors immediately and instruct them to make EM loans available under § 1832.13. His notification will be confirmed by State requirements issued as soon as possible. The State Director will also notify the State USDA Defense Board Chairman and will make such public announcements as appear appropriate.
“(1) Immediately upon receiving notice about the counties under his jurisdiction, the County Supervisor will notify the appropriate County USDA Defense Board Chairman and make such public announcements as appear appropriate about the availability of EM loans under §1832.13. Also, the County Supervisor will explain to other agricultural lenders in the area the assistance available under this program.” 7 CFR § 1832.3(a)(1) (1973).
Although the majority concludes that the regulation did not apply to Pub. L. 93-237, it does not contest that the § 1832.3 regulation, detailing the required procedure for administering emergency loans, remained in effect during the pertinent period.
Indeed, as the Court points out, ante, at 941-942, another of the requirements promulgated on February 27 specifically referred to the *949§ 1832.3 requirements. See 39 Fed. Reg. 7575 (1974), codified at 7 CFR § 1832.92 (1975) (“Instructions for handling new designations will be forthcoming. In the meantime, natural disasters should be reported and designation requests submitted in accordance with the procedure set forth in § 1832.3”). Far from “confirm[ing]” that the § 1832.3 requirements were now inapplicable to already designated disasters, that regulation supports a view that the new regulations were intended merely to supplement the pre-existing § 1832.3 requirements.
Because Pub. L. 93-237 authorized the generous terms by reference to the earlier statute in which they were spelled out in detail rather than by repeating them in the text of Pub. L. 93-237 itself, the Court states that *951the press release “though not a model of clarity, was no less informative than were the ‘provisions’ of the Act the release was endeavoring to describe.” Ante, at 939. This is a disturbingly cavalier approach to the duty to give appropriate notice to the farmers that Congress was trying to help. Moreover, it is not even accurate because the release did not mention the fact that the program that had been available under prior legislation was again being made available. Without either a mention of the actual terms or the fact that the earlier program was being revived, the press release was virtually meaningless, and certainly less informative than the statute itself.
In view of the majority’s statement that the “Court of Appeals specifically disclaimed any reliance on 7 CFR § 1832.3(a)(1) (1973)... to support its affirmance of the District Court’s judgment,” ante, at 939, it bears emphasis that the Court of Appeals disclaimed such reliance only because it found the violation of § 1832.82 so patent:
“FmHA failed to comply with federal regulations specifically designed to transmit notice of available emergency loan programs to the public. FmHA made no loans during the initial application period and only a handful during the renewed period. . . .
“In light of FmHA’s failure to comply with specific prescriptions for notice, we find it unnecessary to determine whether FmHA provided ‘such public announcements as appear appropriate’ or whether in fact such a requirement is judicially reviewable. We do note, however, the paucity of *952public announcement during both the initial and reopened application periods. Especially is this continual dearth of public notice noteworthy where the state director testified that he and his staff were ‘flabbergasted’ at the lack of response to the emergency loan program. . . .
“Our review of the record convinces us that the district court was not clearly erroneous in its six pages of findings of fact and that it was correct in its ultimate conclusion of insufficient notice.” Payne v. Block, 714 F. 2d 1510, 1519-1520 (CA11 1983) (footnote omitted).