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I agree with the 1st two CRD's and they should be adopted into the
ARB's guidelines.
The 3rd CRD should reduce the filter testing so that if a unit can
be run without a filter, only that configuration should be tested. 
If it can not be run without a filter, then the least reactive form
of filter should be tested.  There is limited value in testing with
and without filters when the worst case is almost always without
filters.
Thanks