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decisions concerning reclamation measures. See Gas Appliance Mfrs. Ass'n, Inc. v. DOE, 998 <br />F.2d 1041, 1044-45 (D.C. Cir. 1993) (concluding that similar language used in federal statute <br />required agency to perform cost-benefit analysis unless the agency could provide "a very careful <br />justification" for prioritizing other considerations); cf. also McGowan v. Mississippi State Oil & <br />Gas Bd., 604 So. 2d 312, 322, 324 (Miss. 1992) (where board was required by law to develop <br />"reasonable rules, regulations, and orders" concerning both waste of oil and gas as well as <br />protection of drinking water, board must expressly weigh relative trade-offs between <br />accomplishing those different objectives for its decision to be supported by substantial evidence). <br />If an agency is required to perform a cost-benefit analysis as part of its regulatory <br />decision-making process, then the agency must undertake a competent effort and a failure to do <br />so will render the agency's decision arbitrary and capricious and/or deprive the agency's <br />decision of the support of substantial evidence. See Gas Appliance, 998 F.2d at 1046-51 (an <br />agency "may not tolerate needless uncertainties in its central assumptions when the evidence <br />fairly allows investigation and solution of those uncertainties") (citation omitted); see also <br />Center for Bio. Diversity v. N.H.T.S.A., 538 F.3d 1172, 1198-1203 (9th Cir. 2008) (an agency <br />performing cost-benefit analysis "cannot put a thumb on the scale by undervaluing the benefits <br />and overvaluing the costs of more stringent standards ..."). While agencies are entitled to <br />deference on matters of their "relevant scientific or technical expertise" in this context, "that <br />does not authorize [the Court] to gloss over the critical steps of the [agency's] reasoning <br />process," Gas Appliance, 998 F.2d at 1046, nor may the agency engage in poorly supported <br />speculation about future events so as to skew its calculation of costs and benefits. See Missouri <br />Pub. Serv. Comm'n v. F.E.R.C., 337 F.3d 1066,1073-75 (D.C. Cir. 2003). <br />23