STEPHEN F. WILLIAMS, Senior Circuit Judge, concurring. I join the opinion for the court. We remand the recordkeeping and reporting elements of the 2002 rule because of EPA’s failure to explain its decisions on these elements. Maj. Op. at 33-36. As I understand the remand, the agency’s obligation is to analyze the trade-off between compliance improvement and the burdens of data collection and reporting. In mak…
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