detained 1,200 vessels from 2000 to 2012 — supports their argument that the order was arbitrary and capricious. Pis.’ Opp. & Cross-Mot. at 20-21. They argue the order reflects a “dramatic departure from customary agency practice and precedent,” which required the Coast Guard to provide a specific legal and factual basis for its actions. Pis.’ Reply at 10, citing New York Cross Harbor R.R. v. Surface Transp. Bd., 374 F.3d 1177, 1183 (D.C.Cir. 2004). They contend the agency failed to provide the legal and factual basis for its actions. Id., citing AR 1-2, AR 188-190, AR 432-435, AR 487, AR 496-508. Plaintiffs cite precedent that holds that an agency may not reverse course in the face of existing precedent without providing a reasoned analysis. New York Cross Harbor R.R., 374 F.3d at 1181 (<HOLDING>) (internal citations omitted). But this case
holding that it is not holding that an agency acts arbitrarily and capriciously if it reverses its position in the face of a precedent it has not persuasively distinguished holding that an agency acts arbitrarily and capriciously if it entirely failed to consider an important aspect of the problem holding that when an agency has not reached an issue the proper course is to remand to the agency to address it in the first instance holding that an agency acts arbitrarily and capriciously if it entirely failed to consider an important aspect of the problem or offered an explanation for its decision that runs counter to the evidence before the agency