OPINION OP THE COURT
BECKER, Circuit Judge.
Under Title I of the Petroleum Marketing Practices Act, (“PMPA”), 15 U.S.C. §§ 2801-06, an oil company that terminates or fails to renew a franchise for a permissible business purpose unrelated to the franchisee’s misconduct must make a “bona fide offer” to sell to the franchisee the leased property used by the franchisee in his business. §§ 2802(b)(2)(E)(iii)(I); 2802-(b)(3)(D)(iii)(I). This appeal from the judgment of the district court, 626 F.Supp. 1223, following a bench trial, in favor of appellee Amoco Oil Company and against one of its franchisees, appellant John Slatky, requires us to decide what this “bona fide offer” provision requires the oil company (hereinafter “distributor”) to do and in what manner courts should scrutinize the distributor’s offer in determining its bona fides.
The district court found that Amoco sincerely believed its offer price, derived from its internal business practices, was at fair market value and that the offer had a reasonable basis in fact because its procedures were reasonable, notwithstanding that the price was substantially higher than the estimate of independent appraisers retained by Slatky and by Amoco itself. We conclude that the district court erred in failing to insist that the offer be objectively reasonable, i.e., that it approach fair market value. We therefore reverse and remand for further proceedings.
I. The Statutory Scheme
Title I of the PMPA generally regulates the relationship between distributors of motor fuel, principally oil refiners, and their franchisees, principally retail gas station operators, many of whom lease their stations from the distributors. Evidence at Congressional hearings indicated that distributors had been using the threat of termination or nonrenewal to compel franchisees to comply with the distributor’s marketing policies. See S.Rep. No. 731, 95th Cong., 2d Sess. 17-19, reprinted in [1978] U.S.Code Cong. & Ad.News 873, 875-77 (hereinafter “Senate Report”). In addition, Congress found that franchisors had used their superior bargaining power and the threat of termination to gain an unfair advantage in contract disputes. Id.
In passing the PMPA, Congress determined that franchisees had a “reasonable expectation ]” that “the [franchise] relationship will be a continuing one.” Senate Report at 18, U.S.Code Cong. & Ad.News 1978, at 876. The PMPA’s goal is to protect a franchisee’s “reasonable expectation” of continuing the franchise relationship while at the same time insuring that distributors have “adequate flexibility ... to respond to changing market conditions and consumer preferences.” Senate Report at 19, U.S.Code Cong. & Ad.News 1978, at 877. To accomplish these purposes, the PMPA works principally by limiting the grounds on which distributors may terminate or fail to renew a franchise. 15 U.S.C. § 2802. The PMPA also provides various notification requirements, some of which guarantee a franchisee an opportunity to correct any improper conduct with which he has been charged. See §§ 2802, 2804.
Most of the grounds for termination or nonrenewal involve some form of franchisee misconduct. For example, a distributor may terminate for a franchisee’s failure to pay sums due under the franchise agreement, see § 2802(b)(2)(C) (incorporating § 2802(c)(8)), or for a franchisee’s “fraud or criminal misconduct ... relevant to the operation” of the property, § 2802(b)(2)(C) (incorporating § 2802(c)(1)). A distributor may fail to renew because of [479]*479numerous “bona fide customer complaints" about the franchisee’s operations of the property, see § 2802(b)(3)(B), or because of a franchisee’s failure to operate a property "in a clean, safe, and healthful manner,” see § 2802(b)(3)(C).
To assure distributors' market flexibility, however, the Act also permits termination or nonrenewal because of certain distributor business decisions. So long as a franchisee has received or been offered at least a three year franchise agreement, a distributor may terminate or fail to renew a franchise agreement if it decides “in good faith and in the normal course of business” to withdraw from the relevant geographic market area. See § 2802(b)(2)(E).1
In addition, for three-year franchisees, a distributor may fail to renew the agreement of a franchisee who leases a property from the distributor if the distributor determines “in good faith and in the normal course of business:
(I) to convert the leased marketing premises to a use other than the sale or distribution of motor fuel,
(II) to materially alter, add to, or replace such premises,
(III) to sell such premises, or
(IV) that renewal of the franchise relationship is likely to be uneconomical to the franchisor [distributor] despite any reasonable changes or reasonable additions to the provisions of the franchise which may be acceptable to the franchisee.”
§ 2802(b)(3)(D)(i).
Whenever a distributor terminates or fails to renew a franchise relationship for one of these business purposes, however, he must meet several other requirements. First, the distributor may not terminate or fail to renew in order to convert the property to direct management by its own employees or agents. See § 2802(b)(2)(E)(ii), 2802(b)(3)(D)(ii). Second, the distributor must either make a “bona fide offer” to sell the property or, if applicable, provide the franchisee a right of first refusal on an offer made by another. See §§ 2802(b)(2) (E)(iii)(I); 2802(b)(3)(D)(i).2 The meaning of the “bona fide offer” requirement under the nonrenewal subsection, § 2802(b)(3)(D)(i), is the principal issue in this case.
II. Facts and Procedural History
For several years, Slatky was an Amoco franchisee, leasing a gasoline station in York, Pennsylvania. In May, 1985, following a year in which Slatky’s sales volume started to decline, Amoco determined not to renew Slatky’s franchise on the ground that renewal would be uneconomical despite any reasonable changes or additions to the franchise relationship to which Slatky might agree. Amoco gave proper notice, and because it based its nonrenewal on § 2802(b)(3)(D)(i)(IV), it proceeded, in a letter dated June 28, 1985, to offer to sell Slatky the station for $306,300.00 without the underground tanks and pumps. The testimony reveals that Amoco arrived at this price through a two-step process.
First, Amoco’s employee Melvin O’Dell evaluated the land alone in early May, 1985. O’Dell based his appraisal on three allegedly comparable properties, which had been sold several years before. He testified, however, that he made no effort to verify his information about these “comparables” or to find other reports on other properties. O’Dell further testified that his best comparable was a property that he later found had been understated in land area by 40% and that was not suitable as a basis of comparison because of its loca[480]*480tion.3 Based on this analysis, O’Dell appraised the value of the land at $155,000.
Following the land appraisal, another Amoco employee, Charles Bogdanowicz, performed an initial appraisal of the property improvements. Bogdanowicz had no formal appraisal experience but had built stations for Amoco in several parts of Pennsylvania. He estimated the replacement cost of the improvements, including tanks and lines, to be $121,300.
Based on these two estimates, Amoco’s real estate manager, Eugene O’Brien, recommended a price of $276,300 to the district manager, Lemuel Warfield. Although he did not disagree with any of the conclusions used to come up with the appraisal, Warfield sent a note back to O’Brien stating, “costs as they are today and the improvements that we have on the property, I would believe the appraisal would be more reasonable at $350,000, less tanks and lines.” Warfield asked O’Brien to review the figure, and O’Brien passed this request to O’Dell.4
O’Dell then reviewed his appraisal and came up with a land value of $185,000, $30,000 higher than the first estimate. In a letter to Warfield, O’Brien stated that this new figure was “about as far as we think it should go.” Warfield then offered to sell the station to Slatky for $306,300 ($185,000 for the land plus $121,300 for the improvements), explicitly stating that this figure did not cover the tanks and pumps. After Slatky filed his complaint in this case, Warfield sent Slatky a letter explaining that the exclusion of the tanks and pumps was mistaken and offering the property for $256,300 plus $50,000 for the tanks and pumps.
Slatky’s suit seeks damages and an injunction ordering Amoco to sell the property to him at fair market value. He did not challenge the grounds for nonrenewal but claimed that Amoco’s offer of $306,300 was not a bona fide offer because it was not at fair market value. Two certified appraisers hired by Slatky valued the property respectively at $158,200 (including pumps and tanks) and $145,000 (not including pumps and tanks). An independent appraisal eventually commissioned by Amoco for this litigation appraised the property at $221,000 also not including pumps and tanks.
After a bench trial, the district court held that Amoco had fulfilled its obligation to make a bona fide offer. The court accepted as a general standard the requirement that the offer be “sincere and have a reasonable basis in fact.”5 The court found the sincerity standard met because Amoco had followed its “general” procedure for determining the selling price of property and because it believed its offer price to be at fair market value. The court also found that Amoco’s offer had a reasonable basis in fact because, although its appraiser had not followed formal appraisal techniques, “the procedures used by them were reasonable” and hence the “offer was not arbitrarily made.” The district court made no finding whether the offer actually approached fair market value, as Slatky claimed the statute required, or whether the offer was a reasonable estimate of fair market value. This appeal followed.
III. Amoco’s Subjective Good Faith Standard
A.
Amoco’s principal contention is that we should interpret the term “bona fide” to require that a distributor make its offer only in subjective good faith. Amoco grounds this argument on an analogy between the distributor’s determination of an [481]*481offer price and its original determination not to renew a franchise because of a business reason permitted under § 2802(b)(3)(D). The statute requires only that the latter decision be made “in good faith and in the normal course of business.” Id. The Senate Report states:
These tests provide adequate protection of franchisees from arbitrary or discriminatory termination or non-renewal, yet avoid judicial scrutiny of the business judgment itself. Thus, it is not necessary for the court to determine whether a particular marketing strategy, such as a market withdrawal, or the conversion of leased marketing premises to a use other than the sale of distribution of motor fuel, is a wise business decision.
Senate Report at 37, U.S.Code Cong. & Ad.News 1978, at 896. Contending that the decision about an offer price is essentially the same kind of business judgment as a decision not to renew the franchise, Amoco claims that the same good faith standard designed to prevent second-guessing of a distributor’s business judgment should apply.
We reject Amoco’s suggestion for several reasons. First and fundamentally, we disagree with Amoco’s basic analogy between a nonrenewal decision on the one hand and the determination of a bona fide offer price on the other. We have noted that Congress wished distributors to have the flexibility to respond to changing market conditions: when making a nonrenewal decision under § 2802(b)(3)(D), distributors make such a marketing decision. So long as nonrenewal was truly based on such a marketing decision, Congress precluded courts from examining its merits. Congress did not, however, preclude courts from scrutinizing the merits of termination or nonrenewal decisions that result from a franchisee’s misconduct. Whether a franchisee has truly created health or safety violations or violated a term of the franchise agreement is a question the courts may examine freely. Congress thereby distinguished between decisions involving general business matters and decisions turning on a right created by the PMPA.
Like a termination or nonrenewal decision for franchisee misconduct, the determination of an offer price is not a business decision. It is not a decision that the distributor decides on its own to make. Rather, the distributor sets a bona fide price only because the statute requires it to do so. Indeed, when a distributor fails to renew a franchise because of a decision to convert a property to a different use, or to alter the premises, see § 2802(b)(3)(D)(i)(I), (II), selling the property will interfere with its business plans. The determination of an offer price therefore represents something we may call a “compliance judgment,” a judgment about how best to protect the company's interests while complying with the statute. Congress did not instruct the courts to defer to such decisions.
The legislative history reveals this distinction. Under H.R. 1300 (94th Cong), the predecessor to Title I of the PMPA, a franchisee could not obtain injunctive relief if the franchisor failed to renew on the basis of “a determination made by the franchisor in good faith and in the normal course of business” even if such nonrenewal was prohibited under the bill. H.R. 1300 § 105(e)(1)(A). But such nonrenewal decisions were remediable with money damages, which would have compensated the franchisee for the loss of its reasonable expectation of renewal. Id. § 105(e)(2).
Under H.R. 1300, the distributor could mitigate damages by making a bona fide offer. Responding to the pleas of the major oil companies, see, e.g., Hearings on H.R. ISO, Senate Subcomm. on Energy Conservation and Regulation of the Energy and Natural Resources Committee, Publ. No. 95-61, 250 (95th Cong., 1st Sess.) (statement of Duval Pickey, Vice President of Marketing for Exxon), the next Congress made a bona fide offer a surrogate for damages, H.R. 130 (95th Cong.), and that provision became law. Under either bill, however, Congress treated the bona fide offer requirement not as a statutory recognition of a business judgment but as a form of compensation to the franchisee for the harm resulting from the [482]*482distributor’s valid business judgment. We would misread that legislative history and permit distributors to “eat their cake and have it too” if we were to defer not only to the business merits of the distributor’s business judgment but also to the distributor’s sense of the fairness of its offer of compensation.
Second, even assuming the correctness of the analogy between nonrenewal decisions and offer price decisions, Amoco confuses procedural restrictions with substantive ones. The substantive restriction on the nonrenewal decision comes from the limitation on the distributor’s grounds for renewal. The “good faith and normal course of business” requirement is essentially a procedural direction to the courts about how to judge whether the distributor has abided by the substantive restrictions and failed to renew only because of one of the statutorily permissible reasons. Thus, what the court decides in a challenge to a nonrenewal decision is not whether the distributor determined not to renew according to some elusive notion of good faith but whether it sincerely made a decision to sell the property or to alter it or to accomplish some other business purpose permitted under the statute. See Senate Report at 37, U.S.Code Cong. & Ad.News 1978, at 896 (“good faith test is meant to preclude sham determinations”).
Amoco’s suggestion that the statute only requires a distributor to determine an offer price in “good faith” takes this procedural standard of judicial scrutiny and turns it into a substantive restriction on the distributor’s behavior. But a mere requirement to make an offer “in good faith” is essentially without content. Failing to suggest what a distributor must sincerely decide, it suggests only some kind of floating goodwill. Because it is so ephemeral, a franchisee would virtually never be able to show its absence. Even if we were to accept Amoco’s analogy between the offer price decision and a decision not to renew a franchise, we would therefore adopt the “good faith” standard only as a standard of judicial scrutiny. In order to decide whether the distributor had made the offer price in good faith, we would still have to decide what kind of offer price the statute requires.
B.
Apart from its analogy between the bona fide offer provision and the decision not to renew a franchise, Amoco claims that a subjective good faith standard is consistent with the general purposes of the statute. According to Amoco, the statute seeks only to prevent “arbitrary and discriminatory” terminations and nonrenewals while otherwise leaving the distributor unfettered discretion to pursue its own economic self-interest. By requiring only that a distributor make an offer in good faith, Amoco claims, courts can prevent discriminatory conduct while otherwise allowing distributors to act in accordance with their self-interest.
This reading of the statute’s requirements, however, trivializes Congress’s goals. Distributors have no reason to mistreat franchisees out of simple spite, and Congress did not attribute any such motivation to them. The Senate Report makes clear that the “arbitrary and discriminatory” terminations and nonrenewals Congress wished to stop were those aimed at forcing the franchisee to accept marketing practices not set out in the franchise agreement. Senate Report at 12-19, 36-37, U.S. Code Cong. & Ad.News 1978, at 873-877, 894-896. Obviously, Congress found that distributors had been using their power over franchisees to further their own self-interest. In remedying this “disparity in bargaining power” by limiting the grounds for termination and nonrenewal, Congress protected the franchisee’s interests by curbing those of the distributor. Senate Report at 18, U.S.Code Cong. & Ad.News 1978, at 876.
Other provisions also quite explicitly restrict a distributor’s self-interest in favor of franchisees. In particular, Congress proscribed a distributor from terminating or failing to renew a franchise for the purpose of transferring a property to direct management by its own employees. See § 2802(b)(2)(E)(ii), § 2802(b)(3)(D)(ii). [483]*483These provisions in part address Congress’ fear that major distributors were engaging in predatory pricing to drive independents out of business. See Cong.Rec. S12761-62 (daily ed. May 5, 1978) (statement of Sen. Durkin). But these provisions also reflect Congress’ concern that the major distributors’ desire to operate their own stations resulted in their pressing franchisees to sell out or face stiff increases in rent. See 123 Cong.Rec. H10,385 (daily ed. April 5, 1977) (statement of Rep. Conte). By protecting in this way the franchisee’s interest in continuing to earn a livelihood from the franchise property, Congress limited the ability of the distributor to shift to more profitable direct management.
As these specific provisions illustrate, the very act of passing the PMPA indicated Congress’s rejection of the view advanced by the major gasoline retailers that remedial legislation was unnecessary because the interests of distributors and franchisees were in harmony. See, e.g., Senate Hearings, supra, at 319-22 (statement of Kenneth E. Curtis, Vice-President of Marketing for Amoco). While a subjective good faith standard would probably enable distributors to pursue their own, unfettered self-interest, the statute does not generally guarantee distributors that right. We therefore reject this goal as a guiding principle for interpreting the bona fide offer provision.
IV. The Role of Fair Market Value
Having rejected Amoco’s proffered definition of a bona fide offer, we must now derive the correct one. The starting point of all statutory analysis is the words of the statute themselves. Our review of the many statutes in which Congress has used the term “bona fide” reveals that while Congress uses the phrase in contexts in which good faith intent helps reveal and may even help determine genuineness, the term is also used to convey an objective notion of actuality.6 For example, immigration statutes provide special privileges variously for a “bona fide student,” 8 U.S. C. § 1101(a)(15)(F)(i), for a father with a “bona fide parent-child relationship” with a child, 8 U.S.C. § 1101(b)(1)(D), for a “bona fide member of the crew” of a vessel, 8 U.S.C. § 1287, or for employees of a “bona fide United States incorporated nonprofit organization,” 8 U.S.C. § 1430(c). While the purposes of those who claim to fit into these categories may be relevant to a determination of their bona fides, the status of each would seem to turn at least substantially on objectively verifiable characteristics.
Bona fide occupational qualifications for employment, which serve as exceptions to our employment discrimination laws, see 29 U.S.C. § 621, 42 U.S.C. § 2000e-2(e), work similarly. For a qualification to be bona fide, an employer must show not only that it is necessary but the facts must support its “reasonable necessity” and the inability to accomplish the same purpose through a less discriminatory means. See Dothard v. Rawlinson, 433 U.S. 321, 329, 97 S.Ct. 2720, 2726, 53 L.Ed.2d 786 (1977) (interpreting Title VII); Western Air Lines v. Criswell, 472 U.S. 400, 105 S.Ct. 2743, 2751-53, 86 L.Ed.2d 321 (1985) (interpreting Age Discrimination in Employment Act).
A review of the fourteen code sections that use the phrase “bona fide offer” does not provide a definite meaning. Some refer to a “bona fide offer of employment,” providing for special relocation benefits to those who have accepted such an offer under certain circumstances, see 29 U.S.C. § 1653; 19 U.S.C. § 2298(b), or denying benefits to those who have rejected them, see 42 U.S.C. § 607(b). In these contexts, Congress does not appear to use the phrase in connection with any notion of price level.
In many other contexts, however, Congress uses the phrase “bona fide offer” in tandem with some specified notion of market value. See, e.g., 16 U.S.C. § 544f(o) (conservation area rules limiting use of property do not apply to unpurchased land for which owner has made “bona fide of[484]*484fer” to sell to government; offer “shall not be considered bona fide” if owner refuses consideration equal to the fair market value); 45 U.S.C. § 748(e) (in complicated statutory scheme governing abandonment of rail-line by bankrupt railroad company, company must sell if it receives “bona fide offer” for 75% of appraised value of line); 10 U.S.C. § 9512(e)(2)(D) (Secretary of Defense may reimburse private owner of aircraft modified to be able to serve as cargo plane if needed by government if resale of plane pursuant to “bona fide, arm’s length transaction made to the highest bidder” is for a price less than fair market value of non-modified plane). We acknowledge that the coupling of “bona fide offer” with some particular statement of value could suggest that “bona fide” conveys a solely independent meaning. We believe, however, that we read these statutes more fairly by deducing that Congress generally intends the bona fides of an offer to be determined in accordance with some level of fair market value.
Section 3604 of Title 42 U.S.C., which does not explicitly define bona fide in some relation to “fair market value,” supports this view. That section makes it illegal “to refuse to sell or rent after the making of a bona fide offer ... a dwelling to any person because of race, color, religion, sex, or national origin.” Because a property owner who refused to rent or sell a property because of a below-market price would not engage in discrimination, an offer that did not meet the market price would assumedly not be a bona fide offer.
Notwithstanding the helpful guidance of these sections, they primarily establish that the phrase “bona fide” gains meaning from its statutory context. We must therefore derive the meaning of bona fide offers to sell under the PMPA from that statute’s legislative purpose.
As we have discussed, the overriding purpose of Title I of the PMPA is to protect the franchisee’s reasonable expectation of continuing the franchise relationship. Because of the distributor’s need to adjust to changing market conditions, however, Congress permitted distributors to end the franchise relationship for legitimate business reasons. Yet in doing so, distributors still deprived franchisees of their reasonable expectations. The bona fide offer provision therefore serves as a second, and distinct, layer of protection, assuring the franchisee an opportunity to continue to earn a livelihood from the property while permitting the distributor to end the franchise relationship.
Permitting the distributor to set an offer price as high as it wished would not provide this second layer of protection because the distributor’s business plans may lead it to wish to retain the property. Distributors would set offer prices that compensated them fully for the loss of their business plans. Alternatively, distributors would set an even higher price if they thought the franchisee would pay it. The special desire of a franchisee to maintain the property with which he has worked is exactly what produces the distributor’s general bargaining advantage. Either price, a price reflecting the distributor’s desire to pursue its business plans or a price reflecting the franchisor’s special commitment to the property, might fail to compensate the franchisee for the loss of his reasonable expectation of renewal.
To protect the interests of franchisees, we believe that the statute effectively requires the distributor to set an offer price ignoring both its own alternative business plans and the special needs of a franchisee to hold on to the property. Rather, the statute requires the distributor to make an offer as if it “actually” wanted to sell the property (not necessarily to the franchisee but to someone). With such a desire, however, the distributor would set an offer price at fair market value. That, by definition, is the highest price a willing buyer would pay, and an offer at fair market value protects the franchisee’s reasonable expectation of being able to make a living with the franchise property.
Having stated this requirement, we must now decide in what manner courts should scrutinize the distributor’s offer to deter[485]*485mine whether it complies with the requirement. In Robertson v. Mobil Oil Corp., 778 F.2d 1005, 1008 (3d Cir.1985), we defined “bona fide” in the context of the PMPA provision permitting nonrenewal of a franchise because of “bona fide customer complaints” to mean “sincere and having a reasonable basis in fact.” We similarly here are guided by Congress’s decision not actually to use the term “fair market value” but instead the term bona fide, which suggests some degree of deference. That choice indicates, we believe, a recognition that “the word 'value’ almost always involves a conjecture, a guess, a prediction, a prophecy.” Amerada Hess Corp. v. Commissioner, 517 F.2d 75, 83 (3d Cir.1975) (quoting other cases). “[Tjhere is no universally infallible index of fair market value.” Id. There may be a range of prices with reasonable claims to being fair market value. Were we to mandate that courts determine whether the distributor’s offer actually was at fair market value, distributors could rarely rest comfortably that their offer would eventually be determined by the court to be fair market value.
On the other hand, a standard of scrutiny that simply focused on whether the distributor believed its offer to represent fair market value would leave the franchisee open to injury through sloppiness or mere error. Such a focus might also prove difficult to apply, for intentions are always difficult to discern, especially when we deal not with the intentions of individuals but of organizations.
We therefore believe that courts should scrutinize the distributor’s offer in a manner similar to that we adopted in Robertson. Courts should determine first if file distributor believed its offer price represented fair market value. Even if the distributor did have that sincere belief, however, courts should also determine whether the estimate was objectively reasonable. i.e., whether the offer approached fair market value.7
V. The Need for Remand
In this case, our disagreement with the district court is narrow. The district court found that Amoco sincerely believed its offer to be at fair market value. Slatky has pointed to considerable evidence that might support a contrary finding, in particular to apparently sloppy appraisal methods and to pressures placed on the appraisal department by the district manager, Lemuel Warfield, that resulted in a higher price. However, the district court’s finding on the sincerity of Amoco’s belief is not clearly erroneous.
The district court also found that the “procedures” used by the Amoco employees were reasonable, and upon this finding, it apparently risked its judgment that the offer had a reasonable basis in fact.8 The mere following of reasonable procedures, however, does not necessarily result in a reasonable estimate. To determine whether the estimate was reasonable, the district court must focus on the specific facts used by the appraisers in their valuation and the inferences made from them.
Slatky presented evidence that the land appraisal was based on out-of-date and inappropriate comparables and that the improvements appraisal did not represent local costs. Slatky also presented the testimony of independent appraisers that disa[486]*486greed markedly with the evaluations of Amoco. Indeed, Amoco’s own appraiser, apparently hired for trial preparation, valued the property $31,000 less than the amount offered by Amoco. The district court should have evaluated these specific challenges. In the face of an apparent congruence of independent appraisals that Amoco’s estimate was considerably too high, the court had an obligation to state clearly why it found the Amoco estimate objectively reasonable.9
Because the district court failed to find objective reasonableness (in addition to a belief that the property was offered to the franchisee at fair market value), the judgment of the district court will be reversed and the case remanded for further proceedings consistent with this opinion. The district court will have to make further fact findings. We leave it to the discretion of the district court whether to reopen the record.