BEEZER, Circuit Judge:
San Diego Air Sports Center, Inc. ("SDAS") challenges a letter from the FAA that says parachuting will no longer be allowed in the San Diego Terminal Control Area. An agency determination is reversed if it is "arbitrary, capricious, an abuse of discretion or not otherwise in accordance with law." 5 U.S.C. § 706(2)(A); see Garrett v. Lehman,
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