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 I disposes of this argument as well: "[W3e think imposition of
 such a burden on the challenger is normally inappropriate where
 the agency has completely failed to comply with § 553 [of the
 APA]°" 838 Fo2d at 1324o Even if prior notice of the standard
 was not required, however, the argument should be rejected. It
 is unreasonable to expect Petitioners to identify the "specific
 evidence" they would have found and produced had they known what
 to look for°
 i Finally_ Respondent cavalierly invites Petitioners and
 Intervenors simply to file a new petition if they want to
 introduce new evidence. Respo Bro at 26. This proposed course
 of action provides little comfort, in light of the agency;s track
 record in this proceeding -- another i0 to 15 years could elapse
 N before a hearing is convened. Moreover_ starting again from
 scratch would be an extraordinary and unnecessary waste of
 i resources_ given the voluminous record already compiled. It may
 U be that a remand will "give petitioner[s one more procedural
 bite of the appleg but it is the first bite of the quality to
 i which [they were] entitled from the starts" McLouth Steel_ 838
 F.2d at 1324.
 In its attempt to defend the Administrator's decision
 i from Petitioners _ charges that the decision was unfair and
 reflected the DEA's longstanding prejudice against this petition;
 Respondent drastically mischaracterizes that decision. Further
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