the party seeking supplementation must “put forth concrete evidence that the documents it seeks to ‘add’ to the record were actually before the decision-makers.” Marcum, 751 F.Supp.2d at 78. Conclusory statements will not suffice; rather, the plaintiff “must identify reasonable, non-speculative grounds for its belief that the documents were considered by the agency and not included in the record.” Id. (quoting Pac. Shores Subdivision Cal. Water Dist. v. U.S. Army Corps of Eng’rs, 448 F.Supp.2d 1, 6 (D.D.C.2006)) (internal quotation marks and emphasis omitted). “If an agency did not include materials that were part of its record, whether by design or accident, then supplementation is appropriate.” Id.) see also Natural Res. Def. Council, Inc. v. Train, 519 F.2d 287, 291 (D.C.Cir.1975) (<HOLDING>). A separate standard governs extra-record
holding that because here the statutes in issue provide for judicial review via citizen suit provisions yet do not set forth a standard for that review judicial review is limited to apa review on the administrative record holding that judicial review of decisions of military correction boards is review of the administrative record conducted under the administrative procedure act holding that error in taking judicial notice of a prior ease was harmless where the entire record of the prior case although not introduced into evidence was made part of the record on appeal and no prejudice was shown holding that in its review of the irs exercise of discretion the court is limited to a review of the administrative record holding that review of a partial and truncated record by the district court was error and case remanded for review on the entire administrative record