Can you identify absolute minimum data requirements and margin for auditor judgments to minimize petitions for deficient data?

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No. The amount of data that is sufficient to develop a baseline will depend on the individual case. The baseline auditor does have some flexibility in using their judgment to determine what is appropriate, but the rationale and detailed discussion of the situation must be provided in a petition to EPA.(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)