&gt; <i>the black hole that is the DOT approval process</i><p>Once one reads a number of successful and unsuccessful applications and their interpretation and implementation (including the substantive laws&#x2F;rules, procedural laws&#x2F;rules, and administrative court precedents), I think the DOT approval process would be rather clear. These processes are usually extremely verbose and pedantic for this reason. Once again I think lack of access to the law (e.g., lack of access to court decisions ala PACER) is a fundamental contributing cause underlying your claim.