norml02 - Page 32

 In any event, petitioners have made no showing that they were
 adversely affected by the Administrator's use of either the eight
 or five factor tests. Petitioners also claim to have been
 of an to submit evidence
 "deprived
 opportunity
 designed
 to
 satisfy DEA's standards _' Pet° 32, but they have not described
 specific evidence that they would otherwise have produced. See,
 I e._.e Zaharakis v° Heckle______K, 744 Fo2d 711_ 7!4 (9th Cir. 1984)
 (appellant failed to show that he would Aave pursued an
 I alternative course of conduct had the interpretation been
 published). Given the extensive record in this matters it is
 I difficult to imagine what evidence the petitioners could have
 i omitted.
 The petitioners_ joined by the intervenors_ also assert that
 I the passage of five years and the accumulation of additional
 evidence justify the reopening of the record° Petitioners
 I seeking judicial intervention in a closed administrative
 i proceeding face a heavy burden of demonstrating changed
 circumstances sufficient to merit such an action° United Church
 I of Christ v. Federal Communications Commissions 911 Fo2d 813, 818
 (i990). Mere anecdotal data and collected statements supporting
 the petitioners' positions such as the petitioners and
 i intervenors offer heros not constitute _'significant evidence" to
 justify judicial intervention. See id. The proper course of
 actions which the petitioners and intervenors are free to pursue,
 is to file a new petition with the Administrator and present any
 news relevant evidence at that time.
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