905R78001
EPA'S Rulemaking Program and Strategies
for Reducing Surface Transportation Noise
Presented by
William E. Roper
U.S. Environmental Protection Agency
before
1978
Society of Automotive Engineers
Congress and Exposition
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SAE CONGRESS AND EXPOSITION
WILLIAM E. ROPER
MARCH 3, 1978
DETROIT, MICHIGAN
Good Afternoon:
It's a pleasure to be here today to give a you progress report on the
U.S. Environmental Protection Agency's Noise Regulatory Program for
surface transportation vehicles. The last such report was given in
October at the 1977 NOISE-CON. Since then the program has moved ahead
considerably on almost all fronts. In just a few days EPA will publish
the proposed regulatory package for new motorcycles and their replace-
ment mufflers. I will discuss this particular program in a few minutes.
Those of you who have followed EPA's interstate railroad noise program
are aware that the Agency is working almost night and day to revise the
initial regulation by the Court-imposed deadline of August 23, 1978.
I will have more to say about the progress we have made here a little
later. While the intent today is to highlight the motorcycle and rail-
road noise programs, I want to try to cover at least cursorily each of
the nine other Surface Transportation Regulatory Programs we currently
have underway. At the end, I would be glad to take questions about
specific programs to fill any gaps.
Before beginning the progress report, I would first like to briefly
cover some of the history and strategy behind the Agency's implementa-
tion of the provisions in the Noise Control Act regarding surface
transportation noise control. It has been more than five years since
the Act has passed, overwhelmingly I might add, by the Congress. Three
sections of the Act spell out EPA's responsibilities for requiring by
regulation the reduction of noise from products in the surface transpor-
tation category. Sections 17 and 18 impose, respectively, specific
deadlines on EPA for regulating noise from interstate railroads and
motor carriers. The third applicable section, Section 6, is broader.
It does not identify specific transportation products for regulation
but charges EPA to identify major noise sources in the environment,
including transportation products, and proceed to regulate them. There
are other differences between Sections 6 and 17 and 18. Whereas Section
6 limits noise regulation to newly manufactured products at the time of
their sale, Sections 17 and 18 were written by Congress to apply to the
in-use operation of both existing and new motor carrier and railroad
equipment. Furthermore, Congress did not specify deadlines in Section
6 for the major sources EPA was required to identify. Rather, the
Congress included timetables for the development of regulations once
the specific products were selected.
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Initial regulations under Sections 17 and 18 have been published. But
a Federal court has sent EPA back to the drawing board for interstate
railroads because, in the Court's opinion, EPA misinterpreted the statu-
tory mandate of Section 17.
Our efforts under Section 6 to identify and regulate major noise sources
are still underway. It is under this section that the majority of EPA's
surface transportation noise control programs fall. The general strategy
the Agency has adopted to regulate major noise sources has been to identify
the most serious ones first and then regulate them, if possible, in that
order. Thus, medium and heavy trucks were the first surface transportation
products to receive the full attention of the Agency. Following closely
behind are buses and motorcycles. Other programs underway concern automo-
biles and light trucks, snowmobiles, motorboats, and guided mass transit
systems. In the midst of these product-oriented programs, EPA has also
undertaken limited regulatory studies for mufflers and tires — components
responsible for a sizable portion of the noise from surface transportation
vehicles. Though they are not crucial to today's discussion, the Agency
also has underway programs designed to aid state and local governments
in in-use control of several types of surface transportation noise.
INTERSTATE MOTOR CARRIERS
In front of all our surface transportation programs is our regulation
for interstate motor carriers, which was made final in October 1974 and
effective on October 15, 1975. The standards, which apply to vehicles
over 10,000 pounds that are operated by motor carriers engaged in
interstate commerce, are 88 dBA for stationary runup, 86 dBA up to and
including 35 miles-per-hour, and 90 dBA over 35 miles-per-hour. The
Department of Transportation's Bureau of Motor Carrier Safety and several
state and local governments are currently enforcing the standards.
In the first enforcement year, DOT found about 10 percent of the trucks
tested were in violation of the standards. In the second enforcement
year, that figure was down to about one percent. Clearly, the inter-
state carrier standards appear to be having their intended but limited
effect — to get the worst noise offenders off the highways.
As of January 1, 1978, all trucks over 10,000 pounds have been subject
to the new time-of-sale medium and heavy truck noise emission standards.
These new standards will do much more to reduce the noise generated on
the nation's highways. However, the medium and heavy truck noise standard
is not an in-use operational standard. Therefore, EPA has embarked on
a program to revise the existing interstate motor carrier regulation to
include an in-use standard of possible equivalent stringency to the new
medium and heavy truck regulation. Data on noise emission levels as a
function of use, age, and maintenance are now being compiled to deter-
mine the appropriate level of such a standard. Twenty-five brand new
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representative vehicles will be followed carefully for a period of at
least one year, or a distance of 200,000 miles, whichever comes first.
Once the studies are completed, we should have sufficient noise degrada-
tion data to set an operational standard for post-1977 vehicles operated
by interstate carriers which will limit the extent to which these trucks'
noise can increase over the levels they had when new.
Several issues regarding this regulation are currently being studied by
EPA. One is the possible development of an additional operating standard
which would be applicable only under conditions where the road grade is
within a specified tolerance, and where rapid acceleration or deceleration
may not be necessary. Such a standard, referred to as a "level street
standard," would apply to vehicles operating not closer than some speci-
fied distance from an intersection and where the road grade is less than
plus or minus one percent.
Another issue being studied by EPA is whether it would be advantageous
to change the present regulation's 35 miles-per-hour speed breakpoint.
Several states and cities have requested that EPA raise it to 40 to 45
miles-per-hour. Without a commensurate adjustment in the allowable
noise level, this would, of course, amount to increasing the effective
stringency of the overall regulation.
A final issue being considered is the question that has been raised
over calibration procedures for testing site pads. Information
submitted to the public docket indicated that the correction factor
used in a changeover from soft to hard testing sites need further
evaluation. The hard-site correction factor is currently being studied
and changes are anticipated. The minimum distance for measurement
may also be changed. This would permit state and local enforcement at
more sites in urban areas.
MEDIUM AND HEAVY TRUCKS
EPA's first noise regulation to be issued under Section 6 of the Noise
Control Act was the one published nearly two years ago for new medium
and heavy trucks. The first of three phased standards became effective
on January 1 of this year. The present required level is 83 dBA for
all new trucks over 10,000 pounds. By January 1, 1982, a reduced level
of 80 dBA will be required. The EPA plans a third step to take effect
during the mid-1980s, but has yet to determine what the exact level will
be.
The EPA's Noise Enforcement Division is responsible for enforcing the
medium and heavy truck regulation. Production verification reports
collected thus far generally indicate that manufacturers have had no
difficulties meeting the first step of the truck standard. In fact, the
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reports show that some new trucks sold after January 1, 1978, already
meet the upcoming 1982 standards of 80 decibels, still four years
away. Chart 1 gives a representative sampling of measured dBA levels
documented for a number of vehicle configurations by several manufac-
turers.
Several weeks ago the EPA decided to terminate an interagency arrange-
ment with the Department of Transportation to jointly test new
technology for quieting large new trucks. The Agency will instead
implement a quiet truck demonstration program to provide the information
necessary for supporting regulations to achieve noise levels below 80
dBA.
BUSES
After medium and heavy trucks, buses were the next major transporta-
tion product to receive EPA's regulatory attention under Section 6 of
the Noise Control Act. A proposed rule was published in the Federal
Register on September 12, 1977, and hearings were held in October and
November in Washington, D.C., and San Francisco. Since then, the Agency
has been reviewing hearings and testimony and comments submitted to
the public docket in preparation for issuing a final rule later this
year.
The proposed rule, if made final, would apply generally to three types
of newly manufactured buses: intercity, transit, and school buses.
Two types of noise would be regulated: interior and exterior noise.
The first step of the three-stage standard would become effective
January 1, 1979. Bus exterior noise could be no greater than 83 dBA,
interior noise to 80 dBA, interior noise no more than 86 dBA. After
January 1, 1983, exterior noise to would be limited to 80 dBA, interior
noise to 83 dBA. After January 1, 1985, the exterior and interior
levels would be reduced to 77 and 80 dBA, respectively.
Of the numerous issues raised at the hearings or sent to the docket, I
would briefly like to cover four. First, manufacturers questioned the
engine brake deceleration test employed in developing the regulation
and the policy of engaging demand-controlled fans during testing. These
points of contention are being assessed by EPA and will be resolved
soon.
A second issue brought up by manufacturers concerns EPA's authority
and rationale for instituting an Acoustical Assurance Period and Sound
Level Degradation Factor. This issue has proven common to all Section
6 regulations EPA has developed, not just for surface transportation
products, but for other categories of products as well. Briefly, the
Agency considers the AAP concept necessary because if a new bus is not
built to stay at this quieted level for at least part of its working
life, providing it is properly used and maintained, and the manufacturers'
noise control components are not tampered with, then the regulation
itself becomes a nullity and the anticipated health and welfare benefits
become illusory. The AAP provision falls far short, however, of imposing
a useful life standard, of course. The AAP for new buses is 2 years or
200,000 miles, whichever comes first, not the full life of a bus.
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A third issue concerns whether school buses should be regulated.
Manufacturers questioned primarily whether the health and welfare
benefits were worth the costs. While the Agency recognizes the cost
involved, it believes that certain unique aspects of school-bus use may
warrant regulation. For example, school buses, more than any other
category of bus, are operated predominantly in neighborhood areas. Two,
if school buses were not regulated, and all other urban noise sources
are, then school buses will eventually become the single loudest surface
transportation noise source in urban communities.
A fourth issue that surfaced during the hearings is the need for EPA
to review with the Urban Mass Transportation Administration the design
specifications for the proposed Transbus and Advance Design Bus.
During the development of the Agency's noise regulation for buses,
technology assessments were based on DOT's then current policy decision
to defer institution of the Transbus Program because of high costs.
However, the new Administration revived the concept, and will soon
implement it, thus obliging EPA to reassess the technology available
to quiet the Transbus to the already proposed regulatory levels. These
studies are moving ahead, and EPA will coordinate closely with UMTA
prior to final bus noise rules being issued.
MOTORCYCLES
Probably the most complicated noise regulation the EPA has thus far
developed is the one that was recently published in the Register for
new motorcycles and replacement exhaust systems. Chart 2 lists the
proposed noise levels and effective dates. This is the first noise
regulation EPA has had to break up significantly into parts. The
reason for this complexity is that the motorcycle noise problem is
not as simple or as easily addressed as other noise problems.
Unlike other current transportation noise problems, the problem of
motorcycle noise is more a problem of people, or owners, than one
of originally noisy equipment. Many new bike owners are under the
mistaken impression that they can achieve better performance by tam-
pering with their new bikes' muffler system. What is usually achieved
is merely more noise — not just for the rider, but for everyone else.
Then there are many motorcyclists who simply desire noisier bikes than
they can nowadays buy brand new. As a result, a large market has grown
up over the years dealing in the manufacture and sale of replacement
mufflers considerably less effective than original muffler equipment.
Will regulation solve the problem or is instead, a public education
program needed? The answer is both. From a regulatory standpoint,
we have devised a scheme that will hopefully limit the modification
problem. Half of the regulation is a standard Section 6 rule directed
at newly manufactured replacement exhaust systems. EPA is also requiring
that both motorcycles and new muffler systems manufactured to be used
on Federally regulated motorcycles be labeled. This labeling requirement
would certify for consumers that new bikes have been quieted and should
help local enforcement personnel control motorcycle noise and the
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attendant modification problem in the field. Of course, much of the
effectiveness of the regulation will depend on the willingness of
state and local governments to control motorcycle noise from their
end. In this area more than most, there is only so much the Federal
Government can do. We are optimistic, however, that this rule will
give state and local officials the tools they have been needing to
control motorcycle noise in their communities.
I mentioned earlier that several categories of motorcycles would be
regulated. The reason for this subdivision is that motorcycles are built
differently to do different things. An all-encompassing standard would
ignore these subtleties and could easily be unduly restrictive or lenient,
depending on the type of motorcycle in question. Street motorcycles, for
instance, will be required to meet a phased standard different from the
moped standard and different, to some extent, from the standards off-
road vehicles will be required to meet. The street motorcycle category
will not be further subdivided, but the off-road category will be composed
of two subclasses of bikes, the division being made on the basis of engine
size.
LIGHT MOTOR VEHICLES
Next to medium and heavy trucks, buses, and motorcycles, which have
been identified as major sources under Section 6, are automobiles
and light trucks, which have not. But we're working on them and expect
to make a decision soon. For much of 1977, the Agency's light motor
vehicle regulatory program was located on an asphalt testing pad in
Marana, Arizona, where we were endeavoring to develop a light motor
vehicle noise testing procedure of our own. We undertook this project
largely because existing voluntary standards did not meet our regulatory
needs. The test we eventually developed differs substantially from the
existing SAE J986 or ISO R362 test procedures. Ours specifies a rate of
acceleration corresponding to partial throttle operation as opposed to
the full throttle operation specified by existing procedures. The milder
rate of acceleration is extended to be representative of the way light
motor vehicles are actually operated.
In the second phase of the Marana Program, approximately 70 representa-
tive automobiles and light trucks were tested under the urban noise
test developed in phase one. As discussed at NOISE-CON in October, the
results of this testing have reinforced our concern about the effect
that recently mandated fuel economy standards may have on noise levels
in America's urban areas. Our test data show that today's four-cylinder
cars are on the average 3 dBA noisier than the average eight-cylinder
car. Apparently, this is a result of the smaller cars having to operate
at higher engine speeds to stay abreast of the traffic flow. With fuel
economy now a major factor in the marketplace, the American public is
being heavily marketed to and is buying the four-cylinder engine cars
in increasing numbers. We expect this effort on the vehicle manufac-
turers' part to be intensified in the future. Thus, four-cylinder cars
may become an ever-increasing percentage of total new vehicle sales.
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The test data also show that light motor vehicles equipped with diesel
engines are consistently at least 5 dBA noisier during acceleration
than the average gasoline engine automobiles. Because fuel-efficient
diesel engine is now sold in five different passenger cars, including
the 1978 QVI Oldsmobile Delta 88, and the 1978 W Rabbit, in addition
to Opel, Mercedes and Peugeot, which have had diesels in limited numbers
in the United States for some time. GM, Ford, and Chrysler are offering
diesel engines in their 1978 model year pickup trucks.
As the data in Chart 3 show, the fuel economy and diesel engine concerns
are legitimate ones. In the absence of light vehicle noise regulation,
just the mere increase in light vehicle noise due to dieselization and
the trend to more four-cylinders will virtually wipe out the benefits
anticipated from Federal motorcycle noise control. With fairly stringent
regulation of light motor vehicle noise, the expected 3 or 5 dBA degrada-
tion in diesels and four-cylinders can probably be erased and some actual
noise reduction from current levels possibly achieved.
At this time EPA is preparing for the EPA Administrator a report on
its light motor program to brief him on the issues involved in a decision
that would be his to make within the next few months. I would hope that
the automobile and light truck manufacturing industry will know EPA's
verdict shortly thereafter.
TIRES
Another program closely related to most of our other surface transporta-
tion regulations is our tire noise program. Tires are currently being
studied to determine whether they should be regulated and/or labeled.
In early October of last year EPA held an informal tire noise meeting
at our light motor vehicle testing site in Arizona. The session was a
chance to meet tire industry representatives and advise them of the
status of our program. We described in detail the testing procedures
the Agency is using and gave demonstration runs at the Marana test site
for the industry representatives to observe. We also made clear to them
some of the concerns we have about the possible noise levels of some tire
designs now under study to meet fuel economy goals.
The next step of our tire noise program will be the publication of an
initial tire noise study, which is nearing completion. We plan to give
a detailed report of the results of this study later this month at
NOISEXPO in Chicago. I would, though like to say a few things about the
study here today that might be of interest and assistance to those of you
involved in tire noise testing.
As a result of this program, several useful acoustical properties of
tire noise have been measured. First, customary coast-bys in front of
a single microphone at 50 feet for various speeds were conducted and the
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noise levels of 19 sets of tires determined. Second, directivity
patterns of these tires were calculated from coast-bys through a field
of eight microphones. And, finally, spectral analyses of many of the
measured sounds were made.
The tire noise study also has enlightened us on some procedural ques-
tions involved in tire noise testing, such as, "how important is it
to ensure that proper tire pressure inflation levels are maintained
throughout testing?," and, "how long should the break-in period for new
tires be to ensure that extraneous manufacturing mold marks are removed
and that the tire is properly seated on the wheel rim?" These are the
kinds of questions we faced early on and had to grapple with before
undertaking the actual testing.
To address the tire pressure question, we tested two makes of automobiles
by varying tire pressures above and below the manufacturer-prescribed
"control" pressure after 10-mile warm-up runs were made. Using the
control pressure as a reference point, the data in Chart 4 show that
coast-by noise levels increase with increasing inflation pressure.
Variations in A-weighted levels are small but noticeable and consistent.
Between the highest and lowest tire pressure, the variation in sound
level averaged 2 dBA for one make and 1 dBA for the other. On the basis
of this information, we concluded it is essential that tire pressures be
closely checked throughout testing to verify that proper levels are
cont inuously ma inta ined.
In order to determine the extent to which tires must be broken in to
ensure that irregularities are removed, a series of tests was conducted
in which the coast-by sound level was measured for a set of tires at
different stages of break-in. The data presented in Chart 5 suggest
that minimal tire break-in is necessary prior to performance of coast-by
noise measurements. However, to ensure that tires were properly condi-
tioned, each set of tires tested was subjected to a 50-mile (or 81-KM),
break-in under actual highway driving conditions before any coast-by
noise measurements were performed. EPA found this break-in distance to
be more than adequate.
MUFFLER LABELING
Also related to all of EPA's surface transportation regulatory programs
is our muffler labeling program. In mid-October of last year the Agency
co-sponsored an exhaust noise symposium in Chicago to gather information
on developing a noise bench test for mufflers that could be made inde-
pendent of the vehicle, whether it be an automobile, motorcycle, bus,
or truck. The test potentially is of great value to dealers, repair
facilities, and enforcement officers, not to mention original equipment
manufacturers, and, of course, EPA — largely because it could easily be
standardized and thus reduce everyone's time, trouble, and costs.
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What we found from the symposium is that developing a noise bench test
suitable to all parties, particularly EPA, will be a difficult task.
Of the many test procedures considered, all were found by EPA to be
sufficiently flawed to prevent their general use by both industry and
government. It may be possible, however, to combine the best parts of
several procedures and develop one master test procedure that could meet
our regulatory needs and possibly the manufacturing needs of industry as
well. This is what we are currently trying to determine.
Also under study by EPA are two European replacement muffler certifica-
tion programs. Under both the French and German tests, new replacement
mufflers must meet the required sound level of original muffler equipment
or they cannot be certified or used on European-^nanufactured motor
vehicles. European Community muffler manufacturers can take their
choice of which test procedure to undergo, as only one need be passed for
Community-wide certification. As with American procedures, the two
European tests differ slightly. The French test utilizes an acoustical
sound source while the German test is made with the muffler attached to a
compatible engine.
Once these initial reviews of both domestic and European testing proce-
dures are completed, we will move into a second phase of the program,
consisting of actual testing for reliability and repeatability of com-
bination procedures that we have developed. At the conclusion of this
testing, EPA will then choose the best overall procedure and recommend
it to industry for future use. If our program proceeds according to
schedule, I would hope that we would be able to recommend a procedure
by early summer.
INTERSTATE RAILROADS
I would now like to discuss EPA's Interstate Railroad Noise Program
and the revision we are now writing for the standards promulgated in
December 1975. But first some background. Last August, the U.S. Court
of Appeals for the District of Columbia Circuit completed its review of
the suit brought by the Association of American Railroads and ordered
the EPA to establish much more far-reaching standards than we had orig-
inally imposed. Our existing standards for locomotives and trains were
not challenged.
The Court charged that EPA interpreted its Congressional Mandate to
regulate interstate carriers in a manner which best suited the Agency.
The Court said EPA had no latitude to make such an interpretation because
the intent of the Congress was clear — and that is, that the railroads
should and must have comprehensive Federal protection from different
state and local ordinances — not only the railroads' interstate equip-
ment, which moves from one locale to another, but all fixed facilities
and equipment as well.
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We have heeded the Court's order and are moving to implement its instruc-
tions and promulgate a final regulation by the August 23, 1978, deadline.
One year is very little time in which to plan what is essentially a
full-scale regulatory program and see it through to completion. But this
is what the Court has required us to do. It is a bit of an understate-
ment to say that the Agency is operating under a severe time constraint
with this particular regulatory program.
In order to satisfy the Court and still get a regulation published in
time, the Agency is considering requiring both property line standards
and some point source standards for fixed railroad equipment and facili-
ties. Adopting property line standards is simpler than promulgating
source standards, probably equally effective, and certainly more cost-
effective. However, because some fixed railroad noise sources may be
too noisy to ignore, given the Court's ruling, source standards may be
unavoidable in some cases. Currently EPA is conducting acoustical surveys
at 8 railroads around the country to better characterize railroad equip-
ment and yard noise. These 8 are listed in Chart 6. In the next few
weeks, we will have added two more railyards to our study. I might
add that the Association of American Railroads and the railroad industry
have been most cooperative in this effort.
The Agency is also conducting studies of the potential health and
welfare benefits of further railroad noise reduction and of the best
technology currently available to reduce various types of railyard
noise. I should mention that we have broadened somewhat the regulatory
definition of best available technology under this particular regulatory
program to encompass changes in railroad operations. Thus, it may turn
out that quieting railroad noise is best accomplished by moving equipment
about or by shifting operating hours rather than by requiring technologi-
cal changes in fixed equipment and facilities.
The bulk of these studies should be completed fairly soon. By May the
Agency hopes to have published a proposed revision to the Interstate
Railroad rule, leaving us several months to produce a final rule and,
thus, meet the terms of the Court order.
SNOWMOBILES
Moving on, let me cover briefly three remaining surface transportation
programs underway at EPA. First in line is our snowmobile noise study
program. No decision has yet been made on whether to accord snowmobiles
the major noise source status. However, the last major element of the
study was recently completed — the operator noise exposure study — and
the final decision should be made soon. Preliminary results from this
study indicate that the Leq for snowmobilers without head coverings during
the 2-3 hour duty cycle is about 95 dBA. Chart 7 indicates the range in
testing values. The yearly Leq for 45-100 hours of operation over a
three-month winter period is about 74 dBA. We have also found that
helmets worn by snowmobilers can reduce noise by as much as 12 dBA or
amplify it by as much as 2 dBA, depending on the type of helmet worn.
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If EPA decides not to identify snowmobiles as major noise sources, the
Agency will consider establishing a noise labeling program instead.
The snowmobile manufacturing industry, which appears to have responded
quite admirably to state and local pressure to quiet snowmobiles, already
has a self-imposed labeling program, but it contains several weaknesses
that a more consumer-oriented EPA program would avoid. First, because
some manufacturers do not belong to the International Snowmobile Industry
Association, the organization behind the self-imposed program, not all
manufacturers are labeling their new products. Second, the labeling
program only requires manufacturers to certify that their vehicles meet
the industry's 78-dBA, new-product standard; it does not require manufac-
turers to list the new products' actual decibel levels. An EPA program
would go this one step further and require sound levels to be included
on the labels. Since approximately 25 percent of the new snowmobiles
on the market surpass the 78 dBA standard, such comparative information
could be a great boon to noise-conscious consumers and to state and local
governments interested in controlling snowmobile noise once the vehicles
are off the showroom floor and on the snow. Some could even construe the
industry labeling program as a "restraint of trade" mechanism to remove
noise reduction as a competitive element in the snowmobile manufacturing
industry.
MOTORBOATS
The EPA's noise program for motorboats has just recently begun. Pre-
liminary studies were initiated four months ago to provide us with the
necessary information to determine whether motorboats should be identi-
fied and, hence, whether we should commence a full-scale regulatory
program.
GUIDED MASS TRANSIT
Virtually the same can be said for the Agency's Guided Mass Transit
program. Studies are underway and no decisions have been made about
the program's future.
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CHART 6
RAIL YARDS MEASURED TO DATE
YARD LOCATIONS
ROSEVILLE, CA
RICHMOND, CA
BARSTOW, CA
MACON, GA
SAVANNAH, GA
NEW ORLEANS, LA
HOUSTON, TX
MEMPHIS, TN
SP
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MP
ICG
DESCRIPTION
OLD LARGE HUMP YARD
BUSY FLAT YARD
LARGE AUTOMATED HUMP YARD
MEDIUM HUMP YARD
NEW AUTOMATED FLAT YARD
LARGE FLAT YARD
MEDIUM FLAT YARD
CROWDED FLAT YARD
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10
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