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C*ase 1:08-cv-01624-WJM-NRN Document 166 Filed 03/18/19 USDC Colorado Page 7 of 12 <br /> DOE completed the necessary environmental review." CEC //, 302 F. Supp. 3d at 1255 <br /> (citing CEC /, 819 F. Supp. 2d at 1224). <br /> In opposing DOE's current Motion to Dissolve, Plaintiffs once again argue that <br /> DOE bears a heavy burden of showing changed circumstances. (ECF No. 162 at 4.) <br /> The Court again rejects this argument, for the reasons just stated. Although DOE bears <br /> the burden in this procedural posture, it is simply a burden to show that it has materially <br /> complied with the Court's instructions. <br /> Ill. ANALYSIS <br /> A. Whether a New or Supplemental Administrative Record is Needed <br /> DOE attached its supplemental BA and FWS's response to its Motion to Dissolve <br /> (ECF Nos. 160-1 , 160-2), but has not submitted any other documents generated during <br /> the re-consultation process the Court ordered in CEC //. Plaintiffs' primary challenge is <br /> that DOE cannot move to dissolve the injunction without first assembling and lodging a <br /> new or supplemental administrative record, comprising all documents related to the re- <br /> consultation. (ECF No. 162 at 5-6.) <br /> The parties have not cited, nor has the Court located, any authority establishing <br /> that a government agency must, in all instances, assemble and disclose a full <br /> administrative record before seeking a Court's approval of its administrative action. The <br /> case law assumes that an administrative record will be assembled, but without <br /> discussing it as some sort of categorical or jurisdictional requirement. <br /> Despite the paucity of case law on the topic, judicial review of administrative <br /> action will, by nature, nearly always require an administrative record. Under the unique <br /> circumstances presented here, however, the Court finds that DOE committed no error, <br /> 7 <br />