Re: Photo: PRR Boxcar 515355 (1912)
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The procedures for granting an exemption or extension back in the day would have been dictated by the ICC, most likely in their rules of practice. Since 1946, those procedures have been governed by the Administrative Procedures Act. In today's environment, the regulator often reaches out to industry for assistance setting out the standards that they will enforce by rule. Looks like that principle of consent and comment of the governed operated in the setting of the standards 110 years ago.
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On Friday, September 11, 2020, 01:24:07 AM EDT, Dave Parker via groups.io <spottab@...> wrote:
Well, Guy, I knew if I stuck my foot in it on this one, and the trap got sprung, it would probably be by you. As always, I have learned something both interesting and important.
Just curious: is there a convenient reference for the granting of these extensions? I didn't see one in the archival versions of your explanation.
Also, can we safely assume that new-car construction was never exempt once we hit the 7/1/11 implementation data?
Last, did the ARA provide any data to make their case to the ICC that each successive deadline could not be met? I am wondering what fraction of the pre-1911 cars had been properly refitted by 1915, 1917, etc. I don't think the photographic evidence from that period is nearly extensive enough to give us any clues as to the proportion of compliant vs noncompliant cars.
As always, thanks for the history lesson!
With best regards.
(PS, I hope Idaho is not as crazy as it is up and down the coastal states right now. It's apocalyptic here)
Swall Meadows, CA