Periodic Inspection Must Be Done Under Stable Lab Conditions
To challenge the CFS expert's position that inconvenient data should be excluded for the purpose of calculating precision.
To obtain an admission that the local police service is not properly assessing accuracy and precision during periodic inspections because they are not assessing under stable conditions.
To illustrate the importance of an O'Connor order requiring production of officer's contemporaneous documentation at the time of the inconvenient data to determine the cause of the data that the CFS expert seeks to exclude, rather than speculating that the data is caused by something other than drift in accuracy and precision.
To consider the possibility that the recorded simulator temperatures (all exactly 3400) might be wrong and that there is a serious problem with documentation of simulator temperature.