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By letter dated February 4, 1994, OSM-AFO responded to the <br />DMG response to the TDN. See Exhibit B. In its letter, OSM-AFO <br />determined that the DMG response to alleged violations 1 and 3 of <br />3 of the TDN were appropriate under the Federal regulations at 30 <br />C.F.R. ~ 842.11. OSM-AFO made the correct decision when it <br />accepted DMG's response to alleged violations 1 and 3 as <br />appropriate because DMG had shown that the alleged violations did <br />not exist and had thus shown "good cause" for failing to take <br />"appropriate action" to cause the violations to be corrected. <br />See 30 C.F.R. ~ 842.11 (b)(1)(ii)(B)(4)(i). DMG's response to the <br />alleged violations in the TDN was well-reasoned, based on <br />plausible interpretations of the State program, and supported <br />with documentation. As such, DMG's response could not be <br />considered "arbitrary and capricious" under 30 C.F.R. <br />~ 842.11(b)(1)(ii)(B)(2). Since DMG's response was not arbitrary <br />and capricious, OSM-AFO was obligated, under the Federal <br />regulations, to accept the State's action as appropriate and <br />refrain from ordering a Federal inspection. Id. It should be <br />remembered that, under the arbitrary and capricious standard, OSM <br />did not have to agree with the State's response to the TDN in <br />order to find it appropriate. To find the State's response <br />appropriate, the response simply had to demonstrate that the <br />State had based its decision on a defensible interpretation of <br />the State program and that the State had considered all the <br />relevant factors in arriving at it. See Lois J. Armstrong, 130 <br />29 <br />