(concurring):
I concur in the opinion of Judge Wil-key, directed as it is to the record before us, shaped by the findings of the board.
I wish to add my observation that this is not inconsistent with the possibility that suspension might have been sustainable, even on the evidence actually presented, if the board had proceeded on a different theory, giving notice of that theory to the appellant, and had carefully presented supporting findings.
For example, counsel representing the board in court laid stress on the reasonableness of inferences that might legitimately be drawn from the close relationship between the sign and maintenance companies, in terms of physical proximity and their interlocking presidency. Such considerations, reinforced by the *222doctrine permitting the burden of coming forward with evidence on a particular point to be placed on the party having better access to the facts, might well have allowed the board to conclude, absent proof to the contrary, that the maintenance company’s proceeding with the electrical work on its own was ascribable in realistic measure to Belsin-ger’s belief that his master electrician specialist license, while not giving him the legal right to have his maintenance company perform work beyond its scope, made that company’s action only a minor and not a major transgression. That Belsinger believed himself capable of the pump work was inferable from Kolb’s testimony.
If the board had proceeded on such a theory, with due notice to Belsinger so that he could have been alerted to adduce whatever evidence there was to the contrary, there might well have been available a reasonable assumption of a connection between the license and the illegal installation.
To put it crisply, the board could have found that it was unlikely that the maintenance company would have undertaken even simple electrical work if it had not had available an official with a respectable electrician’s license. With such a connection, suspension in the public interest might have been justified.
The board’s appellate counsel tried to impart this gloss to the case, but of course subsequent rationalizations of counsel cannot take the place of findings made concurrently with the order.1
All this underscores the importance of Judge Wilkey’s observations regarding the need for various local agencies, previously used to informal procedures, to obtain the advice of trained counsel before they chart their course. The need for reflective findings conjoins with the need for articulated standards, assuring evenhanded application of the law,2 rather than whim or misplaced zeal. This need has if anything been accentuated by the District of Columbia Administrative Procedure Act, D.C.Code §§ 1-1501 -1-1510 (Supp. III, 1970).
. NLRB v. Metropolitan Life Ins. Co., 380 U.S. 438, 443-444, 85 S.Ct. 1061, 13 L.Ed.2d 951 (1965); Braniff Airways, Inc. v. CAB, 126 U.S.App.D.C. 399, 411, 379 F.2d 453, 465 (1967); National Air Carriers Assn. v. CAB, No. 23,012, 141 U.S.App.D.C. -, at — -, 436 F.2d 185, at 195 (May 28, 1970).
. Am-Chi Restaurant, Inc. v. Simonson, 130 U.S.App.D.C. 37, 38, 396 F.2d 686, 687 (1968).