The Fertilizer Institute (TFI) is a trade organization that represents members of the fertilizer industry. TFI filed suit in U.S. District Court against the EPA, contesting the agency’s decision to list nitrate compounds on the toxic release inventory that is compiled by the EPA pursuant to the “Emergency Planning and Community Right to Know Act of 1986.” The EPA listed these compounds because there was evidence that they posed a chronic health threat to human infants. TFI argued that the record did not support the EPA’s decision. What evidence would the trial court need to conclude that the EPA had acted arbitrarily in reaching its decision? Why?