Michael Manin, an airline pilot, was twice convicted of disorderly conduct, a minor misdemeanor. To renew his flight certification with the NTSB, Manin filed an application that asked about his criminal history. He did not disclose his two convictions. When they came to light more than 10 years later, Manin argued that he did not know that he was required to report convictions for minor misdemeanors. The NTSB's policy was to consider an applicant's understanding of the information a question sought before determining whether an answer was false. But without explanation, the agency departed from this policy, refused to consider Manin's argument, and revoked his certification. Was this action arbitrary or capricious? Explain. Manin v. National Transportation Safety Board, 627 F.3d 1239 (D.C. Cir. 2011).