Professor David Freeman Engstrom is quoted in The Washington Post:

David F. Engstrom, a law professor at Stanford University, said there are several justifications for such challenges under the Administrative Procedures Act. In this case, Feldman granted the preliminary injunction after deciding that the oil companies would probably prevail in their arguments that Interior's actions were "arbitrary and capricious" and that they were being harmed irreparably by the moratorium. Under that standard, Feldman -- and the appeals court that will review his order -- must decide whether there is "a rational connection between the facts that the agency found and the action that it took," Engstrom said.