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The Administrative Procedure Act states that none of its provisions 'limit or repeal additional requirements imposed by statute or otherwise recognized by law.' 5 U.S.C. § 559. Thus, even though an agency is not required to comply with §§ 556 and 557 of that Act, it is required to accord the 'hearing' specified in § 1(14)(a) of the Interstate Commerce Act. 


The term 'hearing' in its legal context undoubtedly has a host of meanings. See 1 K. Davis, Administrative Law Treatise, § 6.05 (1958). Its meaning undoubtedly will vary, depending on whether it is used in the context of a rulemaking-type proceeding or in the context of a proceeding devoted to the adjudication of particular disputed facts. It is by no means apparent what the drafters of the Esch Car Service Act of 1917, 40 Stat. 101, which became the first part of § 1(14)(a) of the Interstate Commerce Act, meant by the term. Such an intent would surely be an ephemeral one if, indeed, Congress in 1917 had in mind anything more specific than the language it actually used, for none of the parties refer to any legislative history that would shed light on the intended ...

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