Note that 'Arbitrary or capricious' is a legal standard of review for a government agency's decisions[0].

"In administrative law, a government agency's resolution of a question of fact, when decided pursuant to an informal rulemaking under the Administrative Procedure Act (APA), is reviewed on the arbitrary and capricious standard. Arbitrary and capricious is a legal ruling where in an appellate court determines that a previous ruling is invalid because it was made on unreasonable grounds or without any proper consideration of circumstances. This is an extremely deferential standard."

It's a pretty low bar, but it exists.

[0] - https://en.wikipedia.org/wiki/Standard_of_review#Arbitrary_a...

Disregard of the integrity of the legally-mandatory public comment process is, in and of itself, strong evidence that there is a violation of procedural rules governing regulation.