Under this standard, the Trump administration's decision to change the rules of a government program funding free and low-cost reproductive health services for poor people is indefensible. Clinics receiving grants under the Title X program will now no longer be able to recommend abortion providers. The rules also forbid Title X services and abortion providers from sharing offices — which has the effect of disqualifying the Planned Parenthood centers that provide more than 40 percent of Title X services.
Contrary to the daft claims of the U.S. Department of Health and Human Services, these changes will decrease access to health care for poor people, especially in rural areas. That alone means they can't be justified as based on "reasoned analysis."
The real rationale is plain: The administration is heeding the anti-abortion advocates who are a key part of President Donald Trump's political coalition. That is the "relevant data" here.