MEMORANDUM OPINION
ELLEN SEGAL HUVELLE, District Judge.
The National Association of Home Builders and its member associations, Southern Arizona Home Builders Association ("SAHBA") and Home Builders Association of Central Arizona ("HBACA") (collectively "NAHB"), have filed suit on behalf of themselves and their members, seeking judicial review under the Administrative Procedure Act ("APA"), 5 U.S.C. §§ 701 et seq., of a determination...
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