Agency had previously endorsed the inertia theory, but failed to apply it to the automatic seatbelts analysis; court is preventing gaps in an reasoning agency’s decision not to initiate rulemaking only National Customs Brokers – overturned “for compelling cause, such as plain error of law or a fundamental change in factual premise for changes in agency policy, no more rigorous review; suffices that policy is Fox – “new permissible under the statute, there are good reasons for it, and agency believes it is better”
Agency had previously endorsed the inertia theory, but failed to apply it to the automatic seatbelts analysis; court is preventing gaps in an agency’s reasoning National Customs Brokers – decision not to initiate rulemaking only overturned “for compelling cause, such as plain error of law or a fundamental change in factual premise Fox – for changes in agency policy, no more rigorous review; suffices that “new policy is permissible under the statute, there are good reasons for it, and agency believes it is better”