The Federal Maritime Commission approved the charter for an inter$-$island ferry service in Hawaii but did so without a study of the environmental impact of adding the ferry service. Federal agencies are required to determine environmental impacts of all actions. The airlines that fly between the islands wish to challenge the ferry approval by the Maritime Commission. What grounds could they use?

a$.$ arbitrary and capricious

b$.$ failure to comply with statutory procedures

c$.$ favoritism

d$.$ none of the above