Below, I’m pasting a copy of the outline of the comments I plan to make, time permitting, at today’s time zone hearing in Logansport. I haven’t edited it yet, and it might undergo some refinements, but in case anyone is interested, here they are. Also, once again, I’ll plug my submission to the USDOT from September. My apologies for the formatting.
A. Designed for ordinary time zone requests.
B. Indianaâ€™s situation unique
1. Past 30 years – 7 months in central; 5 months in eastern.
2. DST act squeaked by – forced one or the other; question is which
3. Default is eastern through technicality.
a. 1961 – central;
b. 1961 – 1968 half central/half eastern;
c. 1968 – Desire for year round CDT. Instead got year round EST.
4. Result has been a process unnecessarily stacked in favor of Eastern.
a. Burden is on central time proponents.
b. Smaller the scope, tougher the burden.
c. Example – if burden on each household – couldnâ€™t be met.
d. USDOT chosen to place the scope of review @ county level.
e. Proper level of review is state wide.
1. Time zone lines at the state line, less disruptive.
2. State wide change has been implemented in DST.
3. As a matter of geography/geometry – line is in Ohio.
C. USDOT has the authority & perhaps duty to conduct review @ state level.
1. 15 USC 261 provides the only real guidance on time zones.
a. Standard time of eastern zone based on mean solar time of the 75th degree of longitude; central zone on the 90th.
b. Convenience of commerce;
c. Junction points of common carriers.
2. First concern should be longitude – 15 degrees per zone. Adjust for convenience of commerce. Further away from appropriate zone; the greater the inconvience to commerce should be to justify change.
3. No requirement that a request c0me from state or local officials; Secâ€™y of Transportation has wide discretion.
4. Laundry list of convenience of commerce criteria appears to be internal policy of USDOT; not mandated by law or rule.
5. Indiana is a narrow state, 140 miles wide. Doesnâ€™t have the same justification for dividing into separate time zones you find in Tennessee or KY.
6. County-by-county review confined to commerce criteria without substantial regard for Indianaâ€™s longitude is not required by the law and not appropriate under the circumstances; urge USDOT to reconsider its approach.
A. White County should be in central, but no strong justification under the criteria laid out by USDOT.
B. Most commerce goes through Lafayette, in eastern.
1. On the state level, some 61% of exports go to the central time zone or points west. Central time gives us more business hours in common with our trading partners.
2. Just over half of our border is with the central zone.
C. However, the standard non-commerce arguments apply.
1. Weâ€™re 225 miles west of where the time line ought to be, somewhere around Mansfield Ohio at 82.5 degree longitude.
2. No sunrise until 8:30 a.m. in mid-November.
3. Sunsets at around 10 p.m. in mid-July.
4. Noon – sun directly overhead wonâ€™t occur until 2 p.m. (post meridian) during some parts of the year.
5. Limited sunlight is an unfortunate fact of the northern hemisphere. Studies have shown earlier sunlight on average provides helps fend off Seasonal Affective Disorder more effectively than later sunlight.
6. Others will likely mention the standard arguments about kids waiting for school buses in the dark and television schedules.
A. Urge you to reconsider the nature of your review; standard procedure is not appropriate for Indianaâ€™s unique situation. The current procedure pre-ordains the conclusion and the Secretary of Transportation has the authority, and I would argue, the duty to consider the bigger picture from a state wide perspective rather than from a county-by-county perspective.
B. Sympathies for the Dept. of Transportation and, particularly Ms. Petrie who has had to deal with the Indiana time question for at least 20 years. The latest battle was dropped unnecessarily in the laps of both the Department and county commissioners because of a lack of leadership in Indianapolis which is where the decision really should have been made.