This Comment analyzes Union of Concerned Scientists v. Pruitt by providing relevant background and then examining the four specific claims put forth in the suit. Ultimately, based upon this analysis, the Comment concludes that Pruitt’s conflict-of-interest policy is arbitrary and capricious. As such, the conflict-of-interest policy contained in Pruitt's October 31, 2017, directive should be vacated, declared arbitrary and capricious, remanded to the Agency for coherent explanation, and any Agency actions based upon it enjoined.