422 F.Supp.2d 75, 85 (D.D.C.2006) (internal quotation marks omitted). Here, by contrast, the injury for which UPMC seeks redress is not the lack of notice and comment itself, but rather the Board’s allegedly erroneous denial of UPMC’s interest claim. By virtue of that injury, UPMC uncontestedly has standing to challenge the Board’s decision as “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). UPMC’s argument in support of that challenge — that the Board erroneously applied a regulatory provision that was amended in violation of the APA — does not constitute a separate claim for which UPMC must independently dem onstrate standing. See FCC v. Sanders Bros. Radio Station, 309 U.S. 470, 477, 60 S.Ct. 693, 84 L.Ed. 869 (1940) (<HOLDING>); Charles Allen Wright & Arthur R. Miller,
holding that the court must find that the agency entirely failed to consider an important aspect of the problem offered an explanation for its decision that runs counter to the evidence before the agency or the decision is so implausible that it could not be ascribed to a difference in view or the product of agency expertise holding an agency decision is not final during the time the agency considers a petition for review holding that a party who had demonstrated an injury sufficient to confer standing to appeal from an agency decision could raise  any relevant question of law in respect of the order of the agency holding that a draft of a proposed letter from an area director of a government agency to a municipal administrative agency was properly excluded because it did not represent an agency finding holding that a court of appeals should remand a case to an agency for decision of a matter that statutes place primarily in agency hands