You’re not arguing the PRA and APA - both Federal laws.
If your arguments are making the case that the data in contention is not subject to PRA and APA, it seems lacking.
These are legal issues.
“APA”
The APA applies to rule making as I understand it.
Rules might be internal (use red ink and capital letters to mark documents classified) or external (Code of Federal Regulations).
“Rule...a principle or regulation governing conduct or procedure, etc....”
my dictionary
As I understand things, Trump was merely giving an order (tear down these posters) versus a rule (tear down all posters not printed by union printers until further notice).
“5 U.S. Code § 553 - Rule making
(a)This section applies, according to the provisions thereof, except to the extent that there is involved—
...a matter relating to agency management or personnel or to public property”
Hopefully, I got the right law.