“One of the basic procedural requirements of administrative rulemaking is that an agencymust give adequate reasons for its decisions.” Encino Motorcars, 136 S. Ct. at 2125. Thus, whenan agency reverses a prior decision, it must “provide a reasoned explanation for the change.” Id.That explanation need not be “more detailed . . . than what would suffice for a new policy createdon a blank slate,” but it must address the “facts and cir stances that underlay or wereengendered by the prior policy,” including any “serious reliance interests.” Id. at 2125–26 (quotingFCC v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009)); see also id. at 2126 (“[A]n‘unexplained inconsistency’ in agency policy ‘is a reason for holding an interpretation to be anarbitrary and capricious change . . . .’” (alterations and citation omitted)).