norml23 - Page 76

 administrative record that was before the Secretary at the time he made
 his decision, in addition, the court imposed the following, and
 unprecedented, requirements:
 [S]ince the bare record may not disclose the
 factors that were considered or the Secretary's
 construction of the evidence it may be necessary
 for the District Court to require some exp4anation
 in order to determine if the Secretary acted within
 the scope of his authority and if the Secretary's
 action was justifiable under the applicable
 standard.
 The court may require the administrative
 officiams who participated in the decision to give
 testimony explaining their action. Of course, such
 inquiry into the mental processes of administrative
 decisionmakers is usually to be avoided. United
 States Vo Norgan, 303 U.S. 409, 422 (1941 ). And
 where there are administrative findings that were
 made at the same time as the decision, as was the
 case in Norgan, there must be a strong showing of
 bad faith or improper behavior before such inquiry
 may be made. But here there are no such formal
 findings° and it may be that the only way there can
 be effective judicial review is by examining the
 decisionmakers themselves. See Shaughnessy v.
 Accordi, 349 U.S. 280 (1955). Jd. at 420.
 AJmost simultaneously with the Supreme Court's decision in Overton
 Park, the Court of Appeals for the District of CoJumbia reached
 virtually the same resuJt, but expressed its conclusion in far more
 explicit terms. Since the court spoke so eloquently for itself,
 it would serve no purpose to paraphrase its Janguage here. The Court
 stated as follows:
 We stand on the threshold of a new era in the
 history of the Jong and fruitful collaboration of
 administrative agencies and reviewing courts. For
 many years, courts have treated administrative
 policy decisions with great deference, confining