Int. J. Environ. Res. Public Health 2012, 9 2010 and has articulated an adequate explanation for its action” ([78], p. 247, internal quotation marks omitted). Indeed, most courts will grant an agency considerable deference for its “scientific procedures as long as there has been sufficient evidence in the record and sufficient explanation for the action, even though different inferences might have been drawn from the same data and theories and even though courts themselves sometimes suggest they might have drawn different conclusions” ([11], p. 377). Courts have explained and illuminated the scope of judicial review in the face of administrative decision-making where, as in the case of cumulative risk assessment, the process contains inherent technical judgment and complexity. In the 2008 case, Northwest Coalition for Alternatives to Pesticides vs. EPA, the 9th Circuit Court of Appeals majority opinion quoted the dissenting opinion of a 1985 D.C. Circuit case: “Although the ultimate scope may be narrow, the depth must be sufficient for us to be able to comprehend the agency’s handling of the evidence cited or relied upon. The purpose of this in-depth review is to educate ourselves so that we can properly perform our reviewing function: determining whether the agency’s conclusions are rationally supported. …[W]here the agency’s reasoning, although complex, is rational, clear, and complete, we must affirm. Contrarily, where the agency’s reasoning is irrational, unclear, or not supported by the data it purports to interpret, we must disapprove the agency’s action” ([79], p. 1052 n.7). Other recent cases provide examples of different courts acting on the principle of applying this “extreme” or “considerable” deference to Federal agency decisions in the scientific context. In Coalition of Battery Recyclers Ass’n vs. EPA (2010), the D.C. Circuit upheld EPA’s shift in focus from blood lead levels in the original 1978 NAAQS for lead to IQ decrements in children in the revised lead NAAQS. In support of its ruling, the court noted that EPA explained in both the proposed and final rule that current scientific evidence no longer recognized a safe blood level for lead, that epidemiological studies of cognitive effects and lead exposure commonly used IQ scores, and that the scientific literature supported the conclusion that lead exposure causes IQ loss in children ([80], pp. 618–619; [81–83]). In Tucson Herpetological Society vs. Salazar (2009), the 9th Circuit Court of Appeals upheld the Department of Interior’s assessment of threats to a lizard’s habitat in its decision not to list the species as threatened under the Endangered Species Act [84]. In explaining that the merits of the challengers’ and the agency’s conflicting scientific studies are not a proper subject for the court to resolve, the court cited a 2007 ruling in which it noted that courts must defer to an agency’s interpretation of complex scientific data ([84], pp. 881–882, citing [85], p. 1150). The court also cited a 1989 Supreme Court opinion explaining that when specialists express conflicting views, an agency must have discretion to rely on the reasonable opinions of its own qualified experts even if, as an original matter, a court might find contrary views more persuasive ([84], p. 882, citing [86], p. 378). In Miami-Dade County vs. EPA (2008), the 11th Circuit Court of Appeals found that EPA’s risk assessment methodology and results bore a rational relationship to the characteristics of the data to which it was applied ([87], pp. 1063–1071). The court upheld the Underground Injection Control Program rule that the risk assessment at issue supported against varying challenges that EPA’s risk assessment both underestimated and overestimated actual risks ([87], pp. 1063–1071). The court explained that where a “statute is precautionary in nature, the evidence is difficult to come by, uncertain, or conflicting because it is on the frontiers of scientific knowledge, the regulations designed