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Though the law does not require that all officials of a large agency 'react similarly or interpret regulations identically' in every case, Puerto Rican Cement Co. v. EPA, 889 F.2d 292, 299 (1st Cir.1989), it does prohibit an agency from adopting significantly inconsistent policies that result in the creation of 'conflicting lines of precedent governing the identical situation.' Shaw's Supermarkets, Inc. v. NLRB, 884 F.2d 34, 37 (1st Cir.1989) (citation omitted). The purpose of this doctrine, as explained 'to prevent the agency itself from significantly changing [its] policies without conscious awareness of, and consideration of the need for, change.' Puerto Rican Cement Co., 889 F.2d at 299.


This is not to say that an agency, once it has announced a precedent, must forever hew to it. Experience is often the best teacher, and agencies retain a substantial measure of freedom to refine, reformulate, and even reverse their precedents in the light of new insights and changed circumstances. See Rust v. Sullivan, 500 U.S. 173, 186-87, 111 S.Ct. 1759, 1768-69, 114 L.Ed.2d 233 (1991); Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto Ins. Co., 463 U.S. 29, 42, 103 S.Ct. 2856, 2866, 77 L.Ed.2d ...

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