Manual reviewers are people. You'll still need guidelines to determine what's minimal. People are points of failure... Will be hard to determine what really is minimal.
It's not too hard to measure what might be considered a "minimal" page, if he means simple, uncluttered web pages.
Here is what you do; number-of-CSS-blocks + number of images + javascript-dependencies + some magic function involving unique HTML elements in pages = minimal#
The lower the minimal# the better.
You can also throw in some weight products as well, to skew the results and penalize specific components (say flash=1000, gif=300, java-applet=1000, real-media=2000, etc.)
Here is what you do; number-of-CSS-blocks + number of images + javascript-dependencies + some magic function involving unique HTML elements in pages = minimal#
The lower the minimal# the better.
You can also throw in some weight products as well, to skew the results and penalize specific components (say flash=1000, gif=300, java-applet=1000, real-media=2000, etc.)