My time zone letter ran in The Republic (Columbus, Indiana)

Date: Sat, 24 Sep 2005 00:15:17 -0500 (published Thursday, 13 October 2005)
To: "Harmon John -- letter to the editor"
Subject: Favor Central Time

I still favor the DOT putting all of Indiana into a single time zone. Central still appears to be the best choice to me.

Eastern proponents prefer to have the latest sunset (nominally 7:32 pm) extended 103 minutes later than Local Mean Time (LMT) to 9:15 pm and prefer to have the earliest sunset in December no earlier than 5:20 pm. They value these later sunset times enough to tolerate having the sunrise extended to as late as 8:15 am just before we go back to standard time for the winter in early November (starting 2007).

On the other hand, most Central proponents value either an earlier winter morning sunrise, a not quite so late summer sunset, or both, and therefore prefer a more modest 43-minute extension of the latest sunset (compared to LMT) from 7:32 pm to 8:15pm (as we have had with year-round EST / CDT since the 1960's). To achieve this, they are willing to tolerate sunsets as early as 4:20 pm in December.

There is not really a right or wrong side. It primarily comes down to individual preference and would perhaps best be decided by some sort of statewide referendum.

I see the major benefit of Daylight Saving Time (DST) to Indiana commerce as not primarily due to a specific time zone into which the DOT could decide to put Indiana, but as primarily due to almost everyone else in the U.S. always knowing exactly how many hours different their time is from any given city in Indiana.

With about 394 miles of Indiana bordering the Central time portions of Illinois and Kentucky and about 393 miles bordering the Eastern time portions of Michigan, Ohio, and Kentucky, there would be approximately as many people having to adjust to having neighbors an hour different across the state line whether Indiana were placed entirely on Central or Eastern, so I don't see that as a significant factor favoring either time zone.

Business in the rest of the country is already accustomed to dealing with Indiana on Central Daylight during the 7 summer months of the year and on Eastern Standard the remaining 5 months, so year-round Central should require a slightly smaller adjustment for our business partners than year-round Eastern.

Being on Central time would serve the convenience of commerce by putting Indiana at most two hours away from all businesses in the continental U.S., rather than being up to three hours different from the west coast on Eastern time.

The Indiana Chamber of Commerce points out that 39 percent of Indiana's exports are with states that observe Eastern time. This implies that the remaining 61 percent is with states that lie west of Indiana, with whom our time difference would be one hour less on Central time.

Regardless of which time zone the state may end up in, individual business executives are still free to operate their businesses on whichever schedule provides the greatest competitive advantage, as they always have been. It is already common practice to ask employees to plan their work week around a very early or very late conference call with a business several time zones away.

Some Eastern proponents express concern that it might not seem worthwhile to observe DST if Indiana is on Central time. This is a valid question that deserves evaluation. Let us compare Indianapolis with other cities across the country that are about midway between the middle and eastern edge of a standard time zone, like Indiana.

Indianapolis is about 15 minutes earlier than the center (90 degrees) of the nearest standard time zone. Other major U.S. cities which are also located 10 to 20 minutes east of their nearest standard time zone meridian include Spokane WA (10 minutes), Nashville TN (13), Boston (16), and Las Vegas (19).

The most benefit from DST is received in late July, when the sun passes overhead the latest in the day, and the maximum shift of sunlight occurs from before noon to after. The accompanying table shows how many more minutes of daylight are received after noon than before. As the table shows, Indianapolis would receive approximately as much benefit from DST on Central Time as these other similarly-situated cities.

The benefit received by Indiana from DST on Central time is nearly identical to that received by Boston on Eastern time (which lies almost exactly one standard time zone to our east). We don't hear about Boston's residents asking to be in the next time zone to their east (Atlantic Time) because they don't think they get enough benefit from DST.

City	More minutes pm than am
Las Vegas	94
Boston	101
Indy (Central)	102
Nashville TN	107
Spokane WA	112
Indy (Eastern)	222

The Republic

Not Yours to Give

Words of wisdom from Congressman Dave Crockett and constituent Horatio Bunce:

Originally published in "The Life of Colonel David Crockett," by Edward Sylvester Ellis.

we must not permit our respect for the dead or our sympathy for part of the living to lead us into an act of injustice to the balance of the living. I will not go into an argument to prove that Congress has not the power to appropriate this money as an act of charity. Every member on this floor knows it.

We have the right as individuals, to give away as much of our own money as we please in charity; but as members of Congress we have no right to appropriate a dollar of the public money...

We cannot without the grossest corruption, appropriate this money as the payment of a debt. We have not the semblance of authority to appropriate it as charity. Mr. Speaker, I have said we have the right to give as much money of our own as we please...

the Constitution, to be worth anything, must be held sacred, and rigidly observed in all its provisions. The man who wields power and misinterprets it is the more dangerous the honest he is...

In the first place, the government ought to have in the Treasury no more than enough for its legitimate purposes. But that has nothing with the question. The power of collecting and disbursing money at pleasure is the most dangerous power that can be entrusted to man...

there is not a man in the United States who can ever guess how much he pays to the government. So you see, that while you are contributing to relieve one, you are drawing it from thousands who are even worse off than he.

If you had the right to give anything, the amount was simply a matter of discretion with you, and you had as much right to give $20,000,000 as $20,000. If you have the right to give at all; and as the Constitution neither defines charity nor stipulates the amount, you are at liberty to give to any and everything which you may believe, or profess to believe, is a charity and to any amount you may think proper. You will very easily perceive what a wide door this would open for fraud and corruption and favoritism, on the one hand, and for robbing the people on the other. 'No, Colonel, Congress has no right to give charity.

'Individual members may give as much of their own money as they please, but they have no right to touch a dollar of the public money for that purpose...

'The people have delegated to Congress, by the Constitution, the power to do certain things. To do these, it is authorized to collect and pay moneys, and for nothing else. Everything beyond this is usurpation, and a violation of the Constitution.

'So you see, Colonel, you have violated the Constitution in what I consider a vital point. It is a precedent fraught with danger to the country, for when Congress once begins to stretch its power beyond the limits of the Constitution, there is no limit to it, and no security for the people...

There are in that House many very wealthy men - men who think nothing of spending a week's pay, or a dozen of them, for a dinner or a wine party when they have something to accomplish by it. Some of those same men made beautiful speeches upon... the insignificance and worthlessness of money... Money with them is nothing but trash when it is to come out of the people. But it is the one great thing for which most of them are striving, and many of them sacrifice honor, integrity, and justice to obtain it.

Not Yours to Give

My DOT post of 2 Oct 2005 favoring Central Time for Indiana

Title: Time Zone Boundaries in the State of Indiana
Docket: OST-2005-22114
- dms.dot.gov/search/searchResultsSimple.cfm?numberValue=22114&searchType=docket

To: Joanne Petrie
via "http://dms.dot.gov/submit/"
Office of the General Counsel (C-50)
400 7TH ST SW
WASHINGTON DC 20590-0001

PETITION FAVORING CENTRAL TIME (supplement)
===========================================
From following the time zone issue, I think some people probably have a hard time putting Indiana's geographic location into perspective, as it relates to our time zone.

Chris's post of 23 September 2005 (OST-2005-22114-445) gave me an idea of how to put this into very simple terms.

Indianapolis is 11.3 degrees west of the Eastern time zone meridian. Buffalo, New York is 11.3 degrees east of the Central meridian. Given our geographic location, putting Indiana on Eastern time makes about as much sense as putting Buffalo on Central.

Howard Trexler, columnist for the St. Petersburg (Florida) Times, has recently made note of the five-week extension of Daylight Saving Time coming up in 2007, and its implications for late sunrises the first week of March and November.

Now might be the time for Central Standard

Based on sunrises as late as 7:48 in March and 7:46 in November, he proposed in July that the Florida legislature consider exempting itself from Daylight Saving Time (sounds familiar). But now, Trexler reports, Jeff Stabins, county commissioner and former Florida state legislator, has proposed moving the entire state of Florida to Central time.

"After all, Stabins points out, part of Florida's Panhandle already lies in the Central zone. We would be unifying our state, while putting the sunrise back where it ought to be." (sounds familiar too)

St. Petersburg, at 82.7 degrees, is the same longitude as central Ohio (also 82.7). Florida, like Ohio, is bisected by the 82.5-degree midpoint between the Eastern and Central standard meridians.

Trexler's proposal is analogous to a columnist from Columbus, Ohio proposing that the whole state of Ohio should consider observing Central time in order to avoid these extreme late sunrises when Daylight Saving Time is extended, starting 2007.

If Trexler thinks 7:46 and 7:48 am sunrise in St. Petersburg sounds extreme, just imagine how he would feel about 8:07 or 8:20 am those same two days in Indianapolis on Eastern Daylight Time.

Sincerely, Bill Starr
Bartholomew County resident
Sun, 2 Oct 2005

Document OST-2005-22114-496

My DOT post of 18 Sep 2005 favoring Central Time for Indiana

Title: Time Zone Boundaries in the State of Indiana
Docket: OST-2005-22114-401

To: Joanne Petrie
via "http://dms.dot.gov/submit/"
Office of the General Counsel (C-50)
400 7TH ST SW
WASHINGTON DC 20590-0001

PETITION FAVORING CENTRAL TIME (supplement)
===========================================
I just wanted to add one more little bit of data for your consideration in deciding whether to issue a notice of proposed rulemaking (NPRM) on any proposed time zone changes for Indiana.

The following table compares the earliest summer sunrise and earliest winter sunset times for Indianapolis with several other major cities approximately evenly spaced across the U.S., which also fall between the 38th and 42nd parallels (lines of latitude) like Indiana.

I have shown two entries for Indianapolis, illustrating where we would fall in the range depending on the time zone to which Indiana is eventually assigned.

As you can see, if Indiana remains in the Eastern Time Zone when we begin to observe Daylight Saving Time, our earliest summer sunrise and winter sunset would be 13-to-66 minutes later than all of these other major cities at our latitude.

Whereas if we are moved back to the Central Time Zone, we are near the early end of the range (although not the earliest), but still within 0-to-47 minutes of all of the other cities in this list.

City Earliest sunrise (mid-June) Earliest sunset (early Dec)
==== =========================== ===========================
Providence RI 5:10am 4:15pm
Chicago 5:15am 4:20pm
Indy (Central) 5:16am 4:20pm
New York 5:24am 4:28pm
Denver 5:31am 4:35pm
Reno NV 5:31am 4:35pm
Saint Louis MO 5:36am 4:40pm
Sacramento CA 5:41am 4:45pm
Washington DC 5:42am 4:46pm
Pittsburgh PA 5:49am 4:53pm
Kansas City MO 5:52am 4:56pm
Salt Lake City UT 5:56am 5:00pm
Columbus OH 6:03am 5:07pm
Indy (Eastern) 6:16am 5:20pm

Ref: http://aa.usno.navy.mil/data/docs/RS_OneYear.html (U.S. Naval Observatory sunrise/set times)

Sincerely, Bill Starr
Bartholomew County resident
Sun, 18 Sep 2005

My DOT post of 18 Sep 2005 favoring Central Time for Indiana

My DOT post of 16 Sep 2005 favoring Central Time for Indiana

Title: Time Zone Boundaries in the State of Indiana
Docket: OST-2005-22114-391

To: Joanne Petrie
via "http://dms.dot.gov/submit/"
Office of the General Counsel (C-50)
400 7TH ST SW
WASHINGTON DC 20590-0001

PETITION FAVORING CENTRAL TIME (supplement)
===========================================
I think it is helpful to make one final wrap-up of what I see as the pros and cons of Central time versus Eastern time.

The baseline to which I mentally compare our two alternative time zones is Indianapolis local mean time (LMT).

There is a pretty good definition of LMT at "http://en.wikipedia.org/wiki/Local_mean_time". This page defines LMT in part as follows. "Local mean time was used from the early nineteenth century... until standard time was adopted..."

In other words LMT is the time Indianapolis would have observed before the the U.S. Standard Time Act first established the four continental U.S. standard time zones in 1918. LMT is similar to apparent local time, but corrected for the inherent 15-minute-per-year or so variation of the sun's east-to-west position in the sky.

With LMT and without any daylight time, the earliest sunrise of the year in Indianapolis would be 4:32 am about June 14. The latest sunrise would be 7:22 am about January 5. The earliest sunset would be 4:35 pm about December 7 and the latest sunset would be 7:32 pm about June 28. These are the baselines against which we compare the shift in time by observing Central or Eastern standard time.

I perceive that the major benefit of Daylight Saving Time (DST) to Indiana commerce is not due to the specific time zone into which the DOT decides to put Indiana, but is primarily due to nearly all of Indiana being on a single time, and everyone else in the U.S. who observes DST always knowing exactly how many hours different their time is from any particular city in Indiana. If the DOT ends up putting all, or nearly all, of Indiana in a single zone, this would obviously make it even easier for anyone in the U.S. to know the time almost anywhere in Indiana any day of the year.

With about 394 miles of Indiana bordering the Central time portions of Illinois and Kentucky and about 393 miles bordering the Eastern time portions of Michigan, Ohio, and Kentucky, there are going to be approximately as many people having to adjust to having neighbors across the state line on a different time whether Indiana is on Central or Eastern, so I don't think that is a significant factor favoring either time zone.

I believe that so many Hoosiers feel so strongly about the time because with our particular north-south latitude we have such a wide variation in the amount of sunlight over the course of a year. At the summer solstice (about June 21), the longest day is about 14.99 hours in Indianapolis. At the winter solstice (about December 22), the shortest day is only 9.35 hours. This is about 5½ more hours of daylight to figure out how to distribute most conveniently in June compared to December, when we start being concerned about people getting safely to their destinations in the morning or evening darkness or dusk.

Although couched in the preferred DOT criteria of "convenience of commerce", I believe that a lot of the passion on the issue, particularly away from the border counties of the state, mainly comes down to the following individual preference.

The Eastern proponents prefer to have the latest sunset (nominally 7:32 pm) extended 103 minutes later than LMT to 9:15 pm and prefer to have the earliest sunset in December no earlier than 5:20 pm. They value these later sunset times enough to tolerate having the sunrise extended those same 103 minutes to as late as 8:15 am just before we go back to standard time for the winter in early November (starting 2007).

On the other hand, I believe most Central proponents value either a not quite so late winter morning sunrise, a not quite so late summer sunset, or both, and therefore prefer a more modest 43-minute extension of the latest sunset (compared to LMT) from 7:32 pm to 8:15pm (as we have had with year-round EST / CDT since the 1960's). To achieve this, they are willing to tolerate sunsets as early as 4:20 pm in December (15 minutes earlier than we would have with LMT).

As I mentioned in a previous comment, this is virtually the same amount of additional sunlight that several other parts of the country are seemingly content to achieve with Daylight Saving Time, including a number of other major U.S. cities such as Spokane WA, Las Vegas NV, Nashville TN, Montgomery AL, and Boston MA.

In my opinion, neither side is objectively right or wrong. It just comes down to individual preference and would perhaps therefore best be decided eventually by some sort of statewide referendum.

It appears to me that collective individual preference should have greater weight than the collective voice of the business owners and executives. The reason I say this is that regardless of which time zone the state ends up in (and I hope that it does end up predominantly in a single zone), individual business owners and executives are still free to operate and manager their businesses on whichever schedule provides them the greatest competitive advantage, as they always have been.

They don't need to be in a particular time zone to ask an employee to work whatever shift is needed for best communication with business associates in other time zones. It is already common practice for U.S. businesses to ask employees to plan their workday or work week around a very early or very late conference call with a business several time zones away.

I hope that helps to bring the emotions on this issue into a little better perspective.

Sincerely, Bill Starr
Fri, 16 Sep 2005, 11:49pm EST / CDT

My DOT post of 16 Sep 2005 favoring Central Time for Indiana

My DOT post of 14 Sep 2005 favoring Central Time for Indiana

Title: Time Zone Boundaries in the State of Indiana
Docket: OST-2005-22114-130

To: Joanne Petrie
via "http://dms.dot.gov/submit/"
Office of the General Counsel (C-50)
400 7TH ST SW
WASHINGTON DC 20590-0001


PETITION FAVORING CENTRAL TIME (supplement)
===========================================
I have noticed that quite a few proponents of Eastern time express a concern that it would not be worthwhile observing Daylight Saving Time if Indiana is in the Central zone.

This is certainly a valid concern that deserves evaluation against solid facts. I find that it is helpful to compare how much additional evening daylight we would have on Central Daylight Time with other places in the country that are about midway between the middle and eastern edge of a standard time zone, like Indiana.

Indianapolis is a handy city to use for reference, since it is almost exactly the geographic center of Indiana, as well as the state capitol. According the the U.S. Naval Observatory website, the longitude of Indianapolis is 86.13 degrees. This puts us 3.87 degrees east of the nearest standard time zone meridian, which is at 90 degrees (Central time). The other standard time zone meridian lines for the continental U.S. are at 75 (Eastern), 105 (Mountain), and 120 (Pacific).

Being 3.87 degrees east of the nearest meridian means that the sun sets in Indy about 15 minutes earlier than at the center of the nearest standard time zone. Other major U.S. cities which are also located 10 to 20 minutes east of their nearest standard time zone meridian include Spokane WA (10 minutes east), Nashville TN (13 minutes east), Boston (16 minutes east), and Las Vegas (19 minutes east).

The following table illustrates the additional number of minutes of daylight each of these comparably-situated cities enjoys after noon than before, for four representative dates in 2006. The sunrise and sunset times used to make this calculation are from the U.S. Naval Observatory website (with one hour added for Daylight Time April through October).

http://aa.usno.navy.mil/data/docs/RS_OneYear.html

The first date (January) is mid-winter, about midway through the standard time period. The following three dates are representative of the beginning (April), middle (July), and end (October) of the daylight saving time period. On January 15, although the evening and morning daylight is about equal, the parentheses indicate that there are a few more minutes of sun in the morning than in the evening that time of year (when not observing Daylight time).

MORE MINUTES OF SUN AFTER NOON THAN BEFORE

1/15 4/15 7/15 10/15
===== ===== ===== =====
Spokane WA (2) 100 110 70
Nashville TN (7) 95 105 65
Indianapolis (12) 90 101 60
Boston (12) 90 100 60
Las Vegas (19) 82 93 53

As the table shows, the facts give little basis for concern that Indiana will not still receive the benefit of significant additional evening sunshine while observing Central Daylight Saving Time (just as we effectively have for the past few decades on EST). Daylight Saving Time gives a substantial shift of daylight from morning to evening throughout the daylight saving period.

The amount of extra evening daylight is in the same general range enjoyed by other areas of the U.S. which are also located midway across the eastern half of a standard time zone like Indiana.

In fact, the table shows that the benefit to Indiana from Daylight Saving on Central time is nearly identical to that of Boston on Eastern time (which lies almost exactly one full standard time zone -- 15 degrees -- to our east). I don't see anything in the news about Boston's wanting to be in the next time zone to its east (Atlantic Time) because it doesn't think it's getting enough benefit from Daylight Time.

Sincerely, Bill Starr
Bartholomew County resident
14 Sep 2005

My DOT post of 14 Sep 2005 favoring Central Time for Indiana

My DOT post of 11 Sep 2005 favoring Central Time for Indiana

Title: Time Zone Boundaries in the State of Indiana
Docket: OST-2005-22114

To: Joanne Petrie
via "http://dms.dot.gov/submit/"
Office of the General Counsel (C-50)
400 7TH ST SW
WASHINGTON DC 20590-0001

PETITION FAVORING CENTRAL TIME
==============================
I request that the Department of Transportation issue a notice of proposed rulemaking (NPRM), which will solicit public comment, and schedule public hearings on the proposed time zone change for Indiana.

I respectfully petition the DOT to seriously consider moving Bartholomew County and the entire state of Indiana back to the Central time zone. When time zones were first enacted by Congress (Standard Time Act of 1918), the Central-Eastern line bisected Ohio, so the western half of Ohio and virtually all of Michigan and Kentucky fell within the natural boundaries of the Central time zone. All of Indiana was located in the Central time zone. This was because, with longitude ranging from 85 to 88 degrees, it falls well within the 15-degree range for Central time from 82.5 to 97.5 degrees longitude.

I think it would be less confusing for Indiana residents, as well as for the rest of the country, if as many Indiana counties as possible all observe the same time. Central time appears the most logical choice to me, from business as well as personal perspectives.

The primary selling point that Governor Daniels made for Indiana's switch to daylight saving time was to put Indiana in sync year-round with most of the rest of the United States. From this perspective, either Eastern or Central time would be equally advantageous -- we would still change our clocks with the rest of the country twice per year, and always be the same number of hours different from just anywhere else in the U.S. that observes Daylight Saving Time.

And the rest of the country is already accustomed to dealing with Indiana businesses on both Central and Eastern time for about six months of each year, so neither zone should require more of an adjustment for our business partners than the other.

Since 1963 or so, most of Indiana has been three hours ahead of the west coast from October through April, and two hours ahead through the summer. We have observed year-round Eastern Standard Time (UTC -0500), which based on our longitude, is equivalent to year-round Central Daylight Saving Time.

Being on Central time would serve the convenience of commerce by putting Indiana businesses at most two hours away from all of our customers and suppliers in the continental U.S., rather than being up to three hours different from the rest of the country on Eastern time. This would expand opportunities for business with the west coast, without harming our relations with the east coast, which is already accustomed to being one hour ahead of us half the year anyway.

Kevin Brinegar, President, Indiana Chamber of Commerce, points out that 39 percent of Indiana's exports are with states that observe Eastern DST. This implies that the remaining 61 percent is with states that lie west of Indiana, with whom our time difference would be the one hour less if we observed Central time.

Another argument for Central time is to align ourself most closely with the population center of the country. The mean center of population of the United States is in Missouri, and moving westward with every census.

One argument for Eastern time is that Indiana borders more states that are in the ETZ than the CTZ. However, counting states gives only a superficial assessment. Michigan, Ohio and part of Kentucky are in the ETZ. Illinois and the western part of Kentucky are in the CTZ. The shared border with ETZ states is approximately 400 miles, while the border shared with those in CTZ is approximately 390 miles. A difference of only ten miles makes this argument nearly pointless. And, even those parts of Michigan, Ohio, and Kentucky that currently observe eastern time where they border Indiana actually fall within the Central time zone according to their longitude as well.

Obviously, wherever a time zone boundary occurs, residents living near that boundary have to learn to live with it, so I see no compelling argument for or against Indiana's observing either time zone. It's just a question of whether residents on the west and south or those on the north and east sides of the state need to make the adjustment, and there are about as many miles of border affected either way.

Some worry that if Indiana is on Central time that we will not enjoy the benefit of Daylight Saving Time, but by observing year-round Eastern time while lying geographically in the Central zone, we were effectively already enjoying year-round Daylight Saving Time and would not lose out on the additional hour of summer evening sunlight by observing Central Daylight Saving Time. On Central time, we will continue to enjoy the same additional sunlight in the summer evenings -- about 1.5 hours more evening sun than morning sun per day on average, while gaining one hour additional morning sunlight during the late fall and winter months of the school year.

Some Indiana business people like being an hour behind when the stock markets in New York close, so they can leave work an hour earlier and spend more time with their family.

Drive-in theater owners also favor Central time because families can get home an hour earlier after a night at the movies.

After we have begun to observe Daylight Saving Time in 2007 on Sunday, March 11, it appears much more sensible to be on Central time and have the sun rising in Indianapolis at 7am rather than 8am and setting at 6:50pm rather than 7:50pm. This gives motorists commuting to work, and schoolchildren walking and catching buses to school, in the morning an additional hour for well-lit safe travel compared to Eastern Time.

In addition to the concern about children waiting outside in the dark for their school buses in the morning, many argue that sending children to bed while it's still daylight can be difficult and might even affect a child's performance at school.

Some point out that having to stay up later to watch television shows will be an inconvenience for many people, possibly even affecting their performance at work the following day.

On Central Daylight Time, we would still have 1.8 hours more evening sun than morning sun on March 12. Shifting the time by one hour is intended to give a net two surplus hours in the evening versus the morning, and this is about what we would have with Central Daylight Time. Eastern Daylight Time would effectively be double daylight time, with almost two hours shifted from morning to evening, giving 3.8 hours more evening sun than morning sun.

When the time zones were initially established in the United States, they were approximately 15 degrees wide, centered every on every even multiple of 15 degrees longitude. This layout had the effect of putting local mean time for every point in the country within 30 minutes of the standard time for its time zone.

Indianapolis is about 15 minutes east of the 90-degree central meridian for the Central zone, but about 45 minutes from the 75-degree central meridian for Eastern, making Central the obvious choice for the whole state.

If Indiana remains in the Eastern zone, I understand that we would be the only state in the U.S. that lies completely within the mathematical boundaries of one time zone (Central) and yet observes a different time zone.

Sincerely, Bill Starr
Bartholomew County resident
http://hoosiersforcentraltime.com
Sun, 11 Sep 2005

http://dms.dot.gov/search/document.cfm?documentid=345026&docketid=22114