Only Congress can violate 1st Amendment imo. This is evidenced by the fact that the Founding States made the first numbered clauses in the Constitution, Sections 1-3 of Article I, to clarifiy that all federal legislative powers are vested in the elected members of Congress. So Congress has a constituton monopoly on federal legislative powers whether it wants it or not.
In other words, constitutonally undefined "independent federal regulatory agencies" like the NLRB, EPA, etc., shouldn't even exist imo. Such agencies not only wrongly protect unelected federal bureaucrats who exercise regulatory powers, powers which the Constitution prohibits them from having, from the wrath of the voters in defiance of the statutes referenced above, but consider the following. Such agencies can also be regarded as a smoke-and-mirrors way for corrupt Congress to unconstitutionally expand its powers by wrongly ignoring its Article V requirement to petition the states for specific new powers via constitutional amendments. After all, the states have never delegated to Congress the specific power to regulate labor as the NLRB is doing, or to regulate environment as EPA is doing.
Well said, I couldn't agree more!