UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CENTER FOR REGULATORY REASONABLENESS, Plaintiff, v. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY, et al. Civil Case No. 16-1435 (RJL) Defendants, and MINNESOTA POLLUTION CONTROL AGENCY, and MINNESOTA CENTER FOR ENVIRONMENTAL ADVOCACY, \_/V\./V\-/\/\/VV\/V\/\./\/\_/WVVV Defendant-Intervenors. §€@ MEM_QRANDUM oPINloN (March§? , 2019 [Dia. ## 38, 421 The Center for Regulatory Reasonableness (“CRR”) is a coalition of municipal and industrial entities from around the United States lthat seeks to ensure that regulatory requirements are scientifically founded, publicly vetted, and cost-conscious Compl. at ‘H ll [Dkt. # l]. On behalf of its Minnesota members, CRR brought this action against the Environmental Protection Agency and Region V of the Agency (collectively, “EPA” or “Agency”) challenging EPA’S (l) approval under the Clean Water Act (“CWA” or “Act”) of certain Water quality criteria promulgated by the Minnesota Pollution Control Agency (“MPCA”), and (2) refusal to Withdravv approval in response to CRR’s administrative petition for reconsideration Icz’. at jj 2. CRR alleges that EPA’s approval and denial of reconsideration were arbitrary and capricious and/or otherwise in violation of the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(2). Id. at W 88~112. MPCA and the Minnesota Center for Environmental Advocacy 4(“l\/ICEA”) have intervened to defend the challenged EPA actions. See [Dl