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Features of the orginal document layout such as columns, tables, line and letter spacing, pagination, and margins will not be preserved in the text version. If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. As you suggested at the hearing, I submit for your consideration this supplemental memorandum on my analysis of the OGC document and the issues that it raises. See 175 F.3d at 1034. Based on my personal staff's further analysis, set forth below, I conclude that the Commission's interpretation of its authority to designate services for support under the program likely runs afoul of American Trucking.