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 I On four prior occasions, this matter has been before
 i this Court° Each time, the Court ordered a remand_ The agency's
 errors have been glaring and egregious° It refused to accept the
 I petition for filings seH NOP_L v. Inqersoll, 497 F.2d 654 (D.Co
 Cir_ 1974)_ failed to comply with the referral and hearing re-
 quirements of the CSA, see NORML Vo DEAs 559 Fo2d 735 (D.C. Cir.
 1977); N QP_L v. DEA, No. 79-1660 (DoCo Ciro Oct° 16_ 1980) s and
 adopted a legal standard that was fatally flawed by the inclusion
 I of requirements that were logically impossible to satisfy. See
 ACT v. DEA_ 930 F.2d 936 (DoC. Cir. 1991). The previously
 identified procedural errors have been corrected, and the
 i particular substantive requirements held invalid have been
 eliminated. But the Administrator's decision is nevertheless
 I fundamentally unsound because it rests on an artificial and
 logically irrational standard.
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 III. THE ADMINISTRATOR'S STANDARD IS PROCEDURALLY FLAWED
 I Petitioners _ opening brief demonstrated that the
 I Administrator committed procedural error by failing to reopen the
 record after his interpretation of the controlling statutory
 l language had been published in the Federal Register° Pet. Br. at
 i 32_37° As a consequence; Petitioners were deprived of the oppor-
 tunity to submit evidence designed to meet the Administrator's
 I standard. Petitioners _ brief also noted that the lapse of time
 between the closing of the record and the issuance of the deci-
 I sion warranted reopening of the record in light of the statutets
 i command for a finding regarding a drug's _currentl_ accepted
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