• Title/Summary/Keyword: the rules of origin

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A Study on the Family communication and Power in Functional View. (가족의 커뮤니케이션과 勸力에 관한 기능적 이론의 접근)

  • 조은경
    • Journal of Families and Better Life
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    • v.5 no.2
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    • pp.127-144
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    • 1987
  • The purpose of this study is to explore the family communication and power. Communication is a symbolic, transactional process in functional view . To say tat communication is a process implies a continuous interaction of an indefinite large number of variables with a concomitant, continuous change in the values taken by these variables. Finally the process implies change. Family functions include the primary functions of cohesion and adaptability and supporting functions of family images, themes, boundaries, and biosocial issues, The primary functions reveal concepts integrated family interaction and supporting functions, along with those of cohesion and adaptability, give shape of family life. The message system is the major element of communication process and influences both the form and the content of thier relationship and create and share meanings. The family-of-origin issues influence all aspects of family communication and account for many of the communication patterns, rules and networks. Power does not belong to an individual. rather it is a property of a relationship between two or more persons, Power, a system property is the ability of an individual to change the behavior of other members in a social system. Power operate transactionally in a family and any power maneuvers within it have a system wide effect. In order to study power in families , it is necessary to examine 1) family power operations 2) development of family power and 3) the communication of power strutegies. The research presented indicated that a rigid power structure, characterized by dominance and little sharing, restricts family flexibility reduce cohesion, and adversely affects satisfaction in families. power constantly changes as a family grows and develops within its system. Although power changes may be more obvious in children as they mature and more from a independent stated to an independent one, each of the parents experience egual or greater. Communication and activities take place that either enhance positively or negatively the images, themes, and degree of unity of cohesion the family desires. Power operated within a dynamic, growing, changing, interdependent transactional family system. Power struggle may develop when as issue becomes important to one or more family member. When this happens, and the rational exploration of alternatives ceases, various one-up power maneuvers usally follows, This affect family intimacy. a vital element in meaningful relationships . To resolve differences and not become the victim of another's power , one need to engage in constructive conflict since the ability to clearly and comfortably repudiate another is part of the achievement of intimacy.

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The Disputes of FTA Preferential Duty Treatment : The Implications of the U.S Customs Case Laws (한·미FTA 특혜관세분쟁을 대비한 미국판례의 동향과 함의)

  • Ha, Choong Lyong
    • International Commerce and Information Review
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    • v.17 no.3
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    • pp.203-222
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    • 2015
  • Papers in FTA research have mostly focused on the legal interpretation of the FTA treaties. In this research, more focus was put on the customs laws and related cases delivered in the U.S. federal courts, by which we can analyze the Korea-U.S. FTA in more practical manner to derive the enterprises' solutions to cope with the disputes of FTA preferential duty. The Tariff Act of 1930 is the U.S. customs law to govern FTA preferential duties. The administrative practices with customs duties are coordinated with the FTA rules. The most controversial issue in the U.S. customs law lies in the classification of imported goods for imposition of the customs duties, based on Harmonized Tariff Schedule of the United States. It was found that the U.S. federal courts had been quite favorable to the CBP(U.S. Customs and Border Protections) in litigation with the private importers and exporters. The reason seems to be that the CBP has been dealing with the customs cases so many times, accumulating much experience in execution of the U.S. customs laws, which is likely to make their decisions on customs duties almost free of errors. Therefore, the Korean exporters need to collect the CBP's past cases on the denial of preferential treatment on imported goods and be fully informed of the CBP's policies on the FTA preferential duty treatment.

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Research about Global Positioning of Korean Cosmetic Industry through Trade Network analysis : Focusing on the China-Korea FTA (무역네트워크 분석을 통한 한국 화장품 산업의 국제적 위상에 관한 연구 - 한중 FTA 사례를 중심으로 -)

  • Kim, Yong-Jin;Kim, Young-Jin;Lee, Duk-Hee
    • Korea Trade Review
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    • v.41 no.5
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    • pp.63-87
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    • 2016
  • Despite its rising labor costs these days, China still serves the role as 'World's Factory' thanks to a great deal of foreign direct investment, still remaining one of the world's highest, and the global companies, which have been willingly establishing foreign subsidiaries in China. While enjoying the benefits from the Chinese market, these global companies can now take advantages of another market; the one of Korea. If a product produced by a certain global company is actually manufactured in the local factory in China and the product meets specifications of Rules of Origin, the product shall receive preferential treatment under China-Korea FTA. In the perspective of global market, therefore, it is found that China-Korea FTA may have negative effects on chemical industry in Korea, which is considered one of the representatives of China-Korea FTA. This study examines such risks by network analysis, with several cases of 'Beauty or Make-up Preparations (HS Code 3304).' Analysis shows that Korea is classified as the marginal country group but not main country group when it comes to beauty products family. So this can be a great chance to the global cosmetic companies with local factories in China in the sense that they can increase their sales towards the market of Korea based on the China-Korea FTA. Under these concerns, this study suggests two policy alternatives for the chemical industry in Korea to deal with current challenges rising from China-Korea FTA. The suggested alternatives are: to actively attract the global chemical corporations which are yet to directly enter the Chinese market; and to invest on chemical products with high potential of growth as a priority.

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Comprehensive review about alien plants in Korea (국내 외래식물의 현황)

  • KANG, Eun Su;LEE, Soo-Rang;OH, Seung Hwan;KIM, Dong-Kap;JUNG, Su-Young;SON, Dong Chan
    • Korean Journal of Plant Taxonomy
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    • v.50 no.2
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    • pp.89-119
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    • 2020
  • Species invasions have rapidly increased due to the substantial growth of global trade in the recent past. As the awareness of the negative effects on natural ecosystems derived from alien species has grown, many countries and lawmakers have enacted rules and policies on the conservation of indigenous plants. Unfortunately, in Korea, research on species invasion is seriously lacking despite the growing number of alien species. In the current study, we report alien plants that have intentionally and/or unintentionally been introduced in Korea and also presented a checklist of invasive plants found both in the literature and in field surveys. We reviewed all documented records of alien plants, i.e., scientific papers, illustrated books, and annual reports. We also categorized alien plants by origin, time of introduction, naturalization, and the rate of their spread. The results revealed that there are 619 alien plant taxa (96 families, 353 genera, 595 species, 6 subspecies, 11 varieties, 1 forma, and 6 hybrids) occurring in Korea. Among these, 30 taxa are archaeophytes (Arc.), 214 are potentially invasive plants (PIPs), and 375 are invasive alien plants (IAPs). In addition, IAP taxa consist of grades 5 (widespread, WS) to 1 (potential spread, PS) of alien plants according to the rate of spread in Korea. Our results suggested that the number of alien plants is likely to keep growing; thus, the distribution should be regularly monitored and the list of alien plants must be updated.

Changes of the Abductive Inquiry Performance in Outdoor Geological Fieldwork (야외 지질 답사 교육에서 나타난 귀추적 탐구 수행 특성 변화)

  • Jung, Chanmi;Shin, Donghee
    • Journal of the Korean earth science society
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    • v.41 no.5
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    • pp.531-554
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    • 2020
  • In order to provide explanations of the practice of the abductive inquiry-based outdoor geological fieldwork education, this study examined the characteristics of students' performance in geological fieldwork before and after the introduction of explicit learning of geologic knowledge and inquiry. To this end, a 21st-class program was developed in the order of pre-evaluation, initial fieldwork, explicit learning of geologic knowledge and inquiry, and post-evaluation and applied to nine middle school students. As research data, outdoor geological fieldwork class recording data and students' activity sheets were collected and analyzed qualitatively. As a result, during the initial fieldwork, students caught clues of low geological importance and used everyday experience and/or general scientific knowledge as a rule when asked to generate hypotheses about the origin of the clues. Also, students evaluated their hypotheses by the scientific accuracy of the rule or their own criterion. Meanwhile, during the final fieldwork, students frequently caught key clues in geologic perspectives and generated geological event hypotheses related to the clues by borrowing geologic knowledge as a rule. Furthermore, students scientifically evaluated their hypotheses based on the consistency of evidence and rules. Combining these results, the effects of learners' geological knowledge and inquiry (abduction) abilities as a path model were presented in order to help students carry out a proficient abductive inquiry in geological fieldwork.

An Exploratory Study on Logistics Infrastructures in Cambodia : Current Issues and Future Solutions (캄보디아의 물류 기반시설에 관한 탐색적 연구 : 그 쟁점과 해결방안)

  • Long, Dannsoleilnay;Kim, Jong-Chill
    • International Commerce and Information Review
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    • v.16 no.4
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    • pp.333-362
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    • 2014
  • This study uncovered some issues that have constrained the development of logistics performance in Cambodia. Firstly, literature review was narrowed down to include studies involving the relationship between Logistics and transportation, the relationship between the infrastructure and economic growth and the important role of logistics on economic growth and poverty reduction. Then the next step the study identified some issues related to transport infrastructure that were assumed to cause the enhancement of logistics sector. Moreover, a case study about cost and time analysis was used to address some issues of logistics cost in Cambodia comparing to its neighboring countries: Thailand and Vietnam. Based on the time and cost analysis, it revealed that the logistics cost in Cambodia is much high than Thailand and Vietnam. In addition, some logistics issues were found through other two case studies about the export and trade facilitation. The participants raised some issues related to issuance of certificate of origin, the availability of information about agreements, laws, rules, and regulations, checkpoints along the corridor and opening hours of logistics service providers and slow processes. Then the authors suggested some appropriate solutions to answer to the current issues related to transport infrastructure and logistics sector in Cambodia.

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A Comparative Review on Civil Money Penalties in Aviation Law (항공 과징금 제도의 비교법적 검토)

  • Lee, Chang-Jae
    • The Korean Journal of Air & Space Law and Policy
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    • v.34 no.1
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    • pp.3-38
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    • 2019
  • In 1984, Congress enacted a new measure of administrative sanctions which is a civil money penalty program for violations of Aviation Act and its implementing regulations. This civil money penalty system has been in operations in lieu of suspending or revoking certificates issued by Korean government, Ministry of Land, Infrastructure, and Transport. According to the rules of Aviation Business Act or Aviation Safety Act, where the Minister of Land, Infrastructure and Transport should order an air carrier to suspend operation because of her violation under certain rules, in which case the suspension of operation is likely to cause serious inconvenience to consumers of air transport services or to harm public interest, the Minister of the department may impose an administrative monetary penalty in lieu of the suspension of operation. In this regard, airline related civil money penalties are somewhat different from those of fair trade, which is the origin of the money penalties system in Korea. Civil money penalties in the field of fair trade are imposed on executive duty violations that undermine the value of the market economy order, and focus on reimbursement of profits due to violations and compensation for unfair spending by consumers. However, in the aviation sector, breach of duty by a business operator does not simply cause the property loss of the public, but it has a direct impact on life or property of the public. In this respect, aviation penalties are more likely to be administrative sanctions or punitive measures than refunds of unfair benefits, compared to penalties in the field of fair trade. In general, civil money penalties have been highly preferred as administrative sanctions because they are subject to investigations by administrative experts and thus, efficiency can be ensured and execution is quicker than judicial procedures. Moreover, in Korea, because punitive civil damages cannot awarded by the courts, the imposition of civil money penalties is recognized as a means of realizing social justice by recognizing the legal feelings of the people. However, civil money penalties are administrative sanctions, and in terms of effectiveness, they are similar to criminal fines, which are a form of punishment. Inadequate legislation and operation of penalties imposition may cause damage to the value of Constitution. Under the above recognition, this paper has been described for the purpose of identifying the present status of the civil money penalties imposition system and operating status in the area of air transport under the laws and regulations in Korea. Especially, this paper was focused on exploring the problem and improvement direction of Korean system through the comparative study with foreign laws and regulations.

A Study on the Characteristics and Changing Patterns of Shell-and-Bone Inscriptions during Early Western Zhou (서주(西周)초기 갑골(甲骨)의 특징과 그 변화양상 고찰)

  • Park, Jaebok
    • (The)Study of the Eastern Classic
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    • no.68
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    • pp.173-208
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    • 2017
  • This study sorted out the political methods of the typical shell-and-bone inscriptions during early Western Zhou, the shapes and arrangements of Chan, Chak, and Jak, and the characteristics and description methods of shell-and-bone characters and also investigated the formation backgrounds and changing patterns of shell-and-bone inscriptions with a focus on the transmitted literature and actual shell-and-bone inscriptions. First, the transmitted literature contained records saying that Gogongdanbu told fortunes by burning tortoise shells during Proto-Zhou, but no Bokgap from those days had been excavated yet. The content of the divination focused on the periods of Kings Wen, Wu, and Cheng of Zhou, and the shell-and-bone characters of Juwon contained much content about Jugong those days. Second, there were some differences in the processing methods between Bokgap and Bokgol, but their origin could basically be found in the Joyeongjang form during middle Shang. In addition, it was found that they directly accepted the Bukchon type of Seomseo during late Shang and the divination method of the Proto-Zhou culture. Third, all of Bokgaps had a set of square Chan and rectangular Chak installed on the back, whereas all of Bokgols had a set of circular Chan and vertically thin Chak and were in the shape of a cat's eye. In terms of the Chan, Chak, and Jak arrangement, the Bokgaps were similar to those of Yinxu during late Shang, whereas the Bokgols had the characteristics of the Joyeongjang type during middle Shang. Finally, there were differences in the description methods of shell-and-bone characters according to the arrangement methods of shell-and-bone inscriptions. Some rules were found according to each of the parts. Bokgaps were placed horizontally so that Gapsu would face sideways. The middle sections of Bokgols were mostly placed horizontally with the Byeongbu and Seonbu facing downwards at Golgu to write downwards from right to left. This method was estimated to have something to do with "Sigo" in the divination process in The Rites of Zhou. It was inferred that the perceptions of divination changed in the process of arranging the rites and music institutions during early Western Zhou.

DEVELOPMENT OF STATEWIDE TRUCK TRAFFIC FORECASTING METHOD BY USING LIMITED O-D SURVEY DATA (한정된 O-D조사자료를 이용한 주 전체의 트럭교통예측방법 개발)

  • 박만배
    • Proceedings of the KOR-KST Conference
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    • 1995.02a
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    • pp.101-113
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    • 1995
  • The objective of this research is to test the feasibility of developing a statewide truck traffic forecasting methodology for Wisconsin by using Origin-Destination surveys, traffic counts, classification counts, and other data that are routinely collected by the Wisconsin Department of Transportation (WisDOT). Development of a feasible model will permit estimation of future truck traffic for every major link in the network. This will provide the basis for improved estimation of future pavement deterioration. Pavement damage rises exponentially as axle weight increases, and trucks are responsible for most of the traffic-induced damage to pavement. Consequently, forecasts of truck traffic are critical to pavement management systems. The pavement Management Decision Supporting System (PMDSS) prepared by WisDOT in May 1990 combines pavement inventory and performance data with a knowledge base consisting of rules for evaluation, problem identification and rehabilitation recommendation. Without a r.easonable truck traffic forecasting methodology, PMDSS is not able to project pavement performance trends in order to make assessment and recommendations in the future years. However, none of WisDOT's existing forecasting methodologies has been designed specifically for predicting truck movements on a statewide highway network. For this research, the Origin-Destination survey data avaiiable from WisDOT, including two stateline areas, one county, and five cities, are analyzed and the zone-to'||'&'||'not;zone truck trip tables are developed. The resulting Origin-Destination Trip Length Frequency (00 TLF) distributions by trip type are applied to the Gravity Model (GM) for comparison with comparable TLFs from the GM. The gravity model is calibrated to obtain friction factor curves for the three trip types, Internal-Internal (I-I), Internal-External (I-E), and External-External (E-E). ~oth "macro-scale" calibration and "micro-scale" calibration are performed. The comparison of the statewide GM TLF with the 00 TLF for the macro-scale calibration does not provide suitable results because the available 00 survey data do not represent an unbiased sample of statewide truck trips. For the "micro-scale" calibration, "partial" GM trip tables that correspond to the 00 survey trip tables are extracted from the full statewide GM trip table. These "partial" GM trip tables are then merged and a partial GM TLF is created. The GM friction factor curves are adjusted until the partial GM TLF matches the 00 TLF. Three friction factor curves, one for each trip type, resulting from the micro-scale calibration produce a reasonable GM truck trip model. A key methodological issue for GM. calibration involves the use of multiple friction factor curves versus a single friction factor curve for each trip type in order to estimate truck trips with reasonable accuracy. A single friction factor curve for each of the three trip types was found to reproduce the 00 TLFs from the calibration data base. Given the very limited trip generation data available for this research, additional refinement of the gravity model using multiple mction factor curves for each trip type was not warranted. In the traditional urban transportation planning studies, the zonal trip productions and attractions and region-wide OD TLFs are available. However, for this research, the information available for the development .of the GM model is limited to Ground Counts (GC) and a limited set ofOD TLFs. The GM is calibrated using the limited OD data, but the OD data are not adequate to obtain good estimates of truck trip productions and attractions .. Consequently, zonal productions and attractions are estimated using zonal population as a first approximation. Then, Selected Link based (SELINK) analyses are used to adjust the productions and attractions and possibly recalibrate the GM. The SELINK adjustment process involves identifying the origins and destinations of all truck trips that are assigned to a specified "selected link" as the result of a standard traffic assignment. A link adjustment factor is computed as the ratio of the actual volume for the link (ground count) to the total assigned volume. This link adjustment factor is then applied to all of the origin and destination zones of the trips using that "selected link". Selected link based analyses are conducted by using both 16 selected links and 32 selected links. The result of SELINK analysis by u~ing 32 selected links provides the least %RMSE in the screenline volume analysis. In addition, the stability of the GM truck estimating model is preserved by using 32 selected links with three SELINK adjustments, that is, the GM remains calibrated despite substantial changes in the input productions and attractions. The coverage of zones provided by 32 selected links is satisfactory. Increasing the number of repetitions beyond four is not reasonable because the stability of GM model in reproducing the OD TLF reaches its limits. The total volume of truck traffic captured by 32 selected links is 107% of total trip productions. But more importantly, ~ELINK adjustment factors for all of the zones can be computed. Evaluation of the travel demand model resulting from the SELINK adjustments is conducted by using screenline volume analysis, functional class and route specific volume analysis, area specific volume analysis, production and attraction analysis, and Vehicle Miles of Travel (VMT) analysis. Screenline volume analysis by using four screenlines with 28 check points are used for evaluation of the adequacy of the overall model. The total trucks crossing the screenlines are compared to the ground count totals. L V/GC ratios of 0.958 by using 32 selected links and 1.001 by using 16 selected links are obtained. The %RM:SE for the four screenlines is inversely proportional to the average ground count totals by screenline .. The magnitude of %RM:SE for the four screenlines resulting from the fourth and last GM run by using 32 and 16 selected links is 22% and 31 % respectively. These results are similar to the overall %RMSE achieved for the 32 and 16 selected links themselves of 19% and 33% respectively. This implies that the SELINICanalysis results are reasonable for all sections of the state.Functional class and route specific volume analysis is possible by using the available 154 classification count check points. The truck traffic crossing the Interstate highways (ISH) with 37 check points, the US highways (USH) with 50 check points, and the State highways (STH) with 67 check points is compared to the actual ground count totals. The magnitude of the overall link volume to ground count ratio by route does not provide any specific pattern of over or underestimate. However, the %R11SE for the ISH shows the least value while that for the STH shows the largest value. This pattern is consistent with the screenline analysis and the overall relationship between %RMSE and ground count volume groups. Area specific volume analysis provides another broad statewide measure of the performance of the overall model. The truck traffic in the North area with 26 check points, the West area with 36 check points, the East area with 29 check points, and the South area with 64 check points are compared to the actual ground count totals. The four areas show similar results. No specific patterns in the L V/GC ratio by area are found. In addition, the %RMSE is computed for each of the four areas. The %RMSEs for the North, West, East, and South areas are 92%, 49%, 27%, and 35% respectively, whereas, the average ground counts are 481, 1383, 1532, and 3154 respectively. As for the screenline and volume range analyses, the %RMSE is inversely related to average link volume. 'The SELINK adjustments of productions and attractions resulted in a very substantial reduction in the total in-state zonal productions and attractions. The initial in-state zonal trip generation model can now be revised with a new trip production's trip rate (total adjusted productions/total population) and a new trip attraction's trip rate. Revised zonal production and attraction adjustment factors can then be developed that only reflect the impact of the SELINK adjustments that cause mcreases or , decreases from the revised zonal estimate of productions and attractions. Analysis of the revised production adjustment factors is conducted by plotting the factors on the state map. The east area of the state including the counties of Brown, Outagamie, Shawano, Wmnebago, Fond du Lac, Marathon shows comparatively large values of the revised adjustment factors. Overall, both small and large values of the revised adjustment factors are scattered around Wisconsin. This suggests that more independent variables beyond just 226; population are needed for the development of the heavy truck trip generation model. More independent variables including zonal employment data (office employees and manufacturing employees) by industry type, zonal private trucks 226; owned and zonal income data which are not available currently should be considered. A plot of frequency distribution of the in-state zones as a function of the revised production and attraction adjustment factors shows the overall " adjustment resulting from the SELINK analysis process. Overall, the revised SELINK adjustments show that the productions for many zones are reduced by, a factor of 0.5 to 0.8 while the productions for ~ relatively few zones are increased by factors from 1.1 to 4 with most of the factors in the 3.0 range. No obvious explanation for the frequency distribution could be found. The revised SELINK adjustments overall appear to be reasonable. The heavy truck VMT analysis is conducted by comparing the 1990 heavy truck VMT that is forecasted by the GM truck forecasting model, 2.975 billions, with the WisDOT computed data. This gives an estimate that is 18.3% less than the WisDOT computation of 3.642 billions of VMT. The WisDOT estimates are based on the sampling the link volumes for USH, 8TH, and CTH. This implies potential error in sampling the average link volume. The WisDOT estimate of heavy truck VMT cannot be tabulated by the three trip types, I-I, I-E ('||'&'||'pound;-I), and E-E. In contrast, the GM forecasting model shows that the proportion ofE-E VMT out of total VMT is 21.24%. In addition, tabulation of heavy truck VMT by route functional class shows that the proportion of truck traffic traversing the freeways and expressways is 76.5%. Only 14.1% of total freeway truck traffic is I-I trips, while 80% of total collector truck traffic is I-I trips. This implies that freeways are traversed mainly by I-E and E-E truck traffic while collectors are used mainly by I-I truck traffic. Other tabulations such as average heavy truck speed by trip type, average travel distance by trip type and the VMT distribution by trip type, route functional class and travel speed are useful information for highway planners to understand the characteristics of statewide heavy truck trip patternS. Heavy truck volumes for the target year 2010 are forecasted by using the GM truck forecasting model. Four scenarios are used. Fo~ better forecasting, ground count- based segment adjustment factors are developed and applied. ISH 90 '||'&'||' 94 and USH 41 are used as example routes. The forecasting results by using the ground count-based segment adjustment factors are satisfactory for long range planning purposes, but additional ground counts would be useful for USH 41. Sensitivity analysis provides estimates of the impacts of the alternative growth rates including information about changes in the trip types using key routes. The network'||'&'||'not;based GMcan easily model scenarios with different rates of growth in rural versus . . urban areas, small versus large cities, and in-state zones versus external stations. cities, and in-state zones versus external stations.

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The Meaning of Extraordinary Circumstances under the Regulation No 261/2004 of the European Parliament and of the Council (EC 항공여객보상규칙상 특별한 사정의 의미와 판단기준 - 2008년 EU 사법재판소 C-549/07 (Friederike Wallentin-Hermann v Alitalia) 사건을 중심으로 -)

  • Kim, Young-Ju
    • The Korean Journal of Air & Space Law and Policy
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    • v.29 no.2
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    • pp.109-134
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    • 2014
  • Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing common rules on compensation of assistance to passengers in the event of denied boarding and of cancellation or long delay of flights (Regulation No 261/2004) provides extra protection to air passengers in circumstances of denied boarding, cancellation and long-delay. The Regulation intends to provide a high level of protection to air passengers by imposing obligations on air carriers and, at the same time, offering extensive rights to air passengers. If denied boarding, cancellation and long-delay are caused by reasons other than extraordinary circumstances, passengers are entitled for compensation under Article 7 of Regulation No 261/2004. In Wallentin-Hermann v Alitalia-Linee Aeree Italiane SpA(Case C-549/07, [2008] ECR I-11061), the Court did, however, emphasize that this does not mean that it is never possible for technical problems to constitute extraordinary circumstances. It cited specific examples of where: an aircraft manufacturer or competent authority revealed that there was a hidden manufacturing defect on an aircraft which impacts on safety; or damage was caused to an aircraft as a result of an act of sabotage or terrorism. Such events are not inherent in the normal exercise of the activity of the air carrier concerned and is beyond the actual control of that carrier on account of its nature or origin. One further point arising out of the court's decision is worth mentioning. It is not just necessary to satisfy the extraordinary circumstances test for the airline to be excused from paying compensation. It must also show that the circumstances could not have been avoided even if all reasonable measures had been taken. It is clear from the language of the Court's decision that this is a tough test to meet: the airline will have to establish that, even if it had deployed all its resources in terms of staff or equipment and the financial means at its disposal, it would clearly not have been able - unless it had made intolerable sacrifices in the light of the capacities of its undertaking at the relevant time - to prevent the extraordinary circumstances with which it was confronted from leading to the cancellation of the flight.