EPA 550/9-77-200
EPA ANALYSIS
OF THE
AMENDMENT TO DELETE
"ENGINE BRAKE" DECELERATION TESTING
FROM THE
MEDIUM AND HEAVY TRUCK NOISE REGULATION
May 1977
U.S. ENVIRONMENTAL PROTECTION AGENCY
Washington, D.C. 20460
-------
TECHNICAL REPORT DATA ,
(Please read Instructions on the reverse before completing/
1. REPORT NO.
EPA 550/9-77-200
2.
3. RECIPIENT'S
4. TITLE AND SUBTITLE
EPA Analysis of the Amendment to Delete "En-
gine Brake" Deceleration Testing from the Me-
dium and Heavy Truck Noise Regulation.
s. REPORT PATE
6. PERFORMING ORGANIZATION CODE
7. AUTHORiS)
Environmental Protection Agency
Office of Noise Abatement and Control
8. PERFORMING ORG/
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Standards and Regulations Division
Office of Noise Abatement and Control
Washington, D, C. 20460
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERJQB COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT •
A presentation of the questions posed and an assessment of the issues
related to the consideration of the amendment to delete deceleration
testing from the medium and heavy truck noise regulation (40 CFR 205)
is reported. Although noise emissions from engine brake operation are
unique in character, it appears that noise control using engine
exhaust muffling for the vehicle acceleration mode also reduces engine
brake deceleration sound levels. Economic impacts of vehicle decelera-
tion testing using engine brakes appear minimal if engine brakes are
installed at the point of manufacture.
The report contains EPA Regulatory Docket No. QNAC 77-3 exhibiting
all comments submitted by interested parties.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COS AT I Field/Group
Economic cost effects; Federal reg-
ulations; heavy trucks; medium
trucks; population noise exposure;
vehicle noise emission; standards;
vehicle engine brakes.
8. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
88.
20. SECURITY CLASS (This page)
22. PRICE
EPA Form 2220-1 (9-73)
-------
EPA 550/9-77-20Q
EPA ANALYSIS
OF THE
AMENDMENT TO DELETE
"ENGINE BRAKE" DECELERATION TESTING
FROM THE
MEDIUM AND HEAVY TRUCK NOISE REGULATION
May 1977
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF NOISE ABATEMENT AND CONTROL
WASHINGTON, D.C. 20460
-------
TABLE OF CONTENTS
Paqe
INTRODUCTION 1
THE ISSUES 3
ASSESSMENT OF THE ISSUES 5
SUMMARY 13
REFERENCES 23
APPENDIX A Docket No. ONAC 77-3 A-l
APPENDIX B Letter from Jacobs Manufacturing Company
dated July 25, 1974 B-l
APPENDIX C Transcription of Voice on Region VIII
United States Environmental Protection
Agency Demonstration Tape Recording of
Engine Brake Operational Noise from an
Unmuffled Kenworth Truck C-l
-------
LIST OF FIGURES
Figure Title Page
1 Acceleration Mode Sound Levels versus
Deceleration Mode (with Engine Brake)
Sound Levels (SAEJ366b Tests) for Heavy
Trucks ............. 15
2 Acceleration Mode Sound Levels versus
Deceleration Mode (with Engine Brake)
Sound Levels (SAEJ366b Tests) for
Intercity Buses. . 16
3 Level Recordings of Vehicle Pass-By Noise:
Noise Event 1 ( Reference 3)......... 17
4 Level Recordings of Vehicle Pass-By Noise:
Noise Event 2 (Reference 3) 18
5 Level Recordings of Vehicle Pass-By Noise:
Noise Event 3 (Reference 3) 19
6 Level Recordings of Vehicle Pass-By Noise:
Noise Event 4 (Reference 3) 20
7 Level Recordings of Vehicle Pass-By Noise:
Noise Event 5 (Reference 3) 21
LIST OF TABLES
Table Title Page
I Sound Level Data for Engine Brakes (Testing
Procedure Not Explicitly Stated) 22
IV
-------
INTRODUCTION
This report presents the issues and an assessment of the
issues of the amendment to 40 CFR Part 205 (Transportation
Equipment Noise Emission Controls, Medium and Heavy Trucks)
striking 40 CFR § 205.54-l(c) (1) (iv) and 205.54-l(c) (2) (iv) .
The amendment deletes the requirement for conducting noise
emission tests using a deceleration test mode for medium
and heavy trucks equipped with engine brakes.
The Agency's analysis of the amendment is based upon cur-
rently available information (1)* related to noise emissions
from engine brake operation and associated economic and
health and welfare impacts of the proposed amendment.
Engine brakes are one type of engine retarder system. They
are typically installed on heavy diesel-powered trucks and
provide an alternate braking system that is used for going
down long, steep grades in mountainous areas. The most
cited advantages of engine brakes are that they save wear
and tear on the regular braking system and that they are a
safety factor in that an alternate braking system is avail-
able should the regular braking system fail.
Appendix A of this report presents the notice of the amend-
ment and comments submitted to Docket No. ONAC 77-3 during
the public comment period. Appendix B presents a letter
submitted to EPA/ONAC prior to the public comment period
and Appendix C presents graphic interpretations of sound
level recordings of engine brake noise emissions.
* Numbers in ( ) denote references listed at the end of
this report.
-------
THE ISSUES
The major issue with respect to the decision to delete or
include deceleration noise emission testing for medium and
heavy trucks equipped with engine brakes is:
Will vehicles equipped with engine brakes,
if tested in the deceleration mode, as
required by the existing regulation, exceed
the noise emission standards applicable to
vehicles tested in the acceleration mode?
If so, by how much, why, and under what
conditions?
Ancillary issues also addressed are:
(a) Noise Control Technology: Can the noise
resulting from engine brake operation be
controlled effectively?
(b) Health/Welfare Impacts: What effect do
the noise emissions from engine brake
operation have on the health/welfare impact
assessment for medium and heavy trucks?
(c) Noise Emissions from Engine Retarders:
Should engine brakes be identified explic-
itly or should deceleration testing be re-
quired for all engine compression decelerat-
ing devices?
(d) Economic Impact: Will deceleration testing
have a severe economic impact on manufac-
turers of engine brakes? Are there substi-
tutes for engine brakes that will have a
market advantage if deceleration testing
is required?
(e) Safety Considerations: Will engine brakes
not be used where, for safety reasons, they
should be used?
-------
ASSESSMENT OF THE ISSUES
The Major Issue
For a medium or heavy diesel-engine truck, the A-weighted
sound level reported under SAEJ366b testing specifications
appears to be lower for deceleration tests than accelera-
tion tests if the vehicle is equippe'd with mufflers. For
vehicles operating without mufflers or with worn mufflers,
the A-weighted sound level reported under SAEJ366b testing
appears to be significantly higher for the deceleration mode
than for the acceleration mode. In either case (i.e., muf-
fled or unmuffled diesel engine trucks), the almost pure
tone low frequency "popping" noise generated by the opera-
tion of an engine brake results in a characteristic noise
spectrum uniquely associated with engine brake operations.
To evaluate the relative magnitudes of sound levels emitted
by medium and heavy trucks equipped with Jacobs engine brakes,
published test data (2) was reviewed and analyzed. Figure 1
presents a plot of dBA sound levels for vehicle acceleration
mode (vertical axis) versus dBA sound levels for vehicle de-
celeration mode (horizontal axis) . These data indicate thai;
unmuffled engines emit higher deceleration sound levels than
acceleration sound levels. The data also indicate that
vehicles equipped with mufflers generally exhibit lower de-
celeration sound levels than acceleration sound levels.
The Agency conducted SAEJ366b vehicle noise emission tests
under the bus noise regulatory development program. One bus
model with standard transmission (two vehicles) was tested
both for acceleration and for deceleration. During the de-
celeration tests, the vehicles were operated using Jacobs
engine brakes. These data are presented in Figure 2. The
-------
acceleration sound level is the vertical axis and the decel-
eration sound level is the horizontal axis. The deceleration
sound levels are from 1 to 5 dBA higher than the acceleration
sound levels.
Additionally, the EPA Region VIII office conducted field demon-
stration noise emission tests on an unmuffled Kenworth truck
equipped with a Jacobs engine brake (3). This demonstration
and the resulting data were not taken under SAEJ366b test
conditions but are considered to be typical of field condi-
tions. Measurement distances were 50 feet for deceleration
tests and 62 feet for acceleration tests.
Figures 3 through 7 present level recorder output (sound level
versus time) for the five vehicle pass-by noise tests conduct-
ed for this demonstration. Three-level recordings are pre-
sented for each event. The top level recording for each event
presents the linear (no frequency weighting) sound level versus
time. The middle level recording presents the C-weighted sound
level versus time. The lower, level recording presents the A-
weighted sound level versus time. These level recordings are
presented to illustrate the quite significant level-duration
differences between sound levels using frequency weighting for
engine brake noise emissions. All the level recordings indi-
cate peak level differences between dBC and dBA values of
approximately 5 to 8 dB (dBC levels higher) . Of more impor-
tance however, is the duration of higher dBC levels over the
entire record (typically 10 dB). The dBC levels — it is
believed — represent more closely the characteristic "popping"
sounds of the engine brake operation than the dBA levels.
(The complete voice transcription and data for the vehicle
pass-by events contained on the demonstration tape recording
are presented in Appendix C to this report.)
-------
(a) Noise Control Technology
It appears that — based upon available test data — the de-
celeration sound levels resulting from engine brake operation
can be significantly decreased using existing muffler tech-
nology (2). For comparison, typical vehicle acceleration
sound levels for unmuffled vehicles appear to be 93 to 95
dBA while for muffled vehicles the levels appear to be around
85 dBA (see Figure 1). For engine brake operation during
truck deceleration conditions, unmuffled vehicles exhibited
average sound levels of 101.5 dBA and muffled vehicles ex-
hibited average sound levels of 84 dBA.
The vehicles cited above are diesel-engine heavy trucks
tested under SAEJ366b conditions (2, p. 28). This data
does not indicate whether the characteristic low frequency
"popping" resulting from the operation of an engine brake
is significantly altered. Test data (4, p. 8) and commentary
(4, p. 8), (5) indicate that muffling engine exhaust noise
for an acceleration test mode may not necessarily result in
optimum exhaust, noise muffling for the deceleration mode
using engine brakes.
In the petition of Jacobs Manufacturing Company (6, p.16
and Exhibit D) to the Agency for reconsideration of medium
and heavy truck noise emission regulations, additional sound
level data were reported. The data reported are presented
in Table I and indicate that vehicle noise emission levels
can be reduced below 80 dBA for both the acceleration test
mode and the deceleration test using an engine brake if the
vehicle is equipped with appropriate mufflers (see Table I) .
-------
(b) Health/Welfare Impact
Analysis of the health/welfare impact assessment for medium
and heavy duty trucks, including noise generated by opera-
tion of engine brakes, considered the following:
(i) The existing data available to the Agency
indicate that sound levels resulting from
vehicle deceleration using engine brakes
are not significantly different from vehicle
acceleration levels if the vehicles are
equipped with proper mufflers (under the
existing applicable EPA test procedures).
(ii) The percentage of vehicles in the 1972 national
fleet equipped with engine brakes was relatively
small, approximately 2 percent (less than 75,000
trucks) of the national fleet (6, p. 17). Engine
brake usage is quoted as 3 to 5 percent of ve-
hicle engine hours with the engine brake activ-
ated every 3 to 8 miles of vehicle movement (6,
Exhibit F) .
In 1974, it was indicated (2, p. 1 and 4, P- 1)
that 120,000 to 140,000 Jacobs engine brakes
were operational in the U. S. Additionally,
Jacobs Manufacturing Company indicated that in
1974, 25 percent of the heavy trucks on the west
coast of the U. S. were equipped with engine
brakes (5, see Appendix B). It appears, there-
fore, that between 1972 and 1974 the number or
trucks equipped with engine brakes either in-
creased by 60 percent or the engine brakes were
distributed to vehicle types other than medium
and heavy trucks.
Consequently, for a health and welfare assessment
on a national basis, the impacts due to engine
brake operation are very small due to the rela-
tively small number of trucks equipped with
engine brakes. However, in those areas where
engine brakes are heavily concentrated, the
health and welfare impacts could be significant.
(iii) The distribution of land use and hence popula-
tion densities associated with engine brake opera-
tion is difficult to assess, based upon existing
data.
-------
(iv) An Leq descriptor based upon the A-weighted sound
level is not necessarily appropriate to assess
the low frequency "popping" sound characteristic
of engine brake operation in order to evaluate
potential adverse health/welfare impacts, espec-
ially if averaged over a daily or an annual basis.
A more appropriate descriptor is conceivably an
Leq value based upon the C-weighted sound level.
The Agency is presently evaluating the appropri-
ateness of other than the A-weighted sound level
for use in assessing potential health/welfare
effects, with respect to certain noise sources.
The noise emitted by engine brakes will be further
evaluated in this regard.
(v) Additionally, it is perhaps appropriate to con-
sider a single event noise impact analysis to
evaluate effects from engine brake operation
in relation to determining potential health/
welfare benefits.
(vi) The noise from engine brake operation is, sub-
jectively, unique in character and readily iden-
tifies the source as a "Jake Brake." The empirical
assessment as to how much, if any, additional
human annoyance or activity disruption results
from this noise, as opposed to the overall noise
from the truck, is not known at this time.
(c) Noise Emissions from Engine Retarders
Engineering sound level data associated with engine retard-
ers other than engine brakes is not currently available.
Therefore, it was not possible to compare sound levels of
engine brakes with other engine retarders such as exhaust
brakes or other engine compression devices that are similar
to engine brakes.
(d) Economic Impact
The costs associated with all noise abatement testing for
medium and heavy trucks (deceleration testing included) are
minimal. The costs range from $0.38 to $0.57 per vehicle
(7, p. A-5-14).
-------
If engine brakes are installed after the vehicle has been
assembled by the manufacturer and delivered to a dealer or
distributor, the potential requisite testing could result
in the imposition of more substantial costs. The person
or organization responsible for testing would then be dif-
ferent than for other normal noise testing of trucks. This
factor could discourage persons in organizations other than
the manufacturer from installing engine brakes.
The demand for engine brakes appears to be relatively in-
elastic. Demand for engine brakes is based on reduced oper-
ating costs and safety features (2, p. 26-17; 8). It ap-
pears that between 1972 and 1974 the number of vehicles
equipped with engine brakes increased significantly (see
(b) above) . It is unclear as to whether there exists a
substantially expanding market for engine brakes. Data in-
dicate (2, p. 26-27) that the engine brake can pay its cost •
compared to brake relining costs — at the 105,000 mile op-
eration point (1974 data). Based upon an average annual
mileage of 54,000 miles for a heavy diesel truck, the engine
brake could pay for itself in approximately 2 years. Thus,
the use of engine brakes for. other than exclusively safety
reasons is apparent.
The Agency is aware of other engine retarding systems that
may potentially substitute for engine brakes. These systems
comprise exhaust brakes and electromagnetic retarders (at-
tached to the vehicle drive train). Data are not presently
available, however, to quantify both the safety features
and economic advantages of potential substitutes for engine
brakes. If no comparable braking systems are available,
the demand for engine brakes should remain essentially un-
changed. If the same mufflers are used for trucks with or
10
-------
without engine brakes, no price increase is expected due to
the regulatory requirement of a deceleration test for engine
brake noise emissions.
(e) Safety Considerations
Based on their highly desirable economic and safety appeal,
it appears likely that truck owners would continue to pur-
chase engine brakes if deceleration noise testing was re-
quired. However, the fact that very large numbers of trucks
operating frequently in mountainous terrain are not so equip-
ped indicates that the safety-related value and cost-
effectiveness of engine brakes are not favorably viewed by
large numbers of the truck purchasing community.
11
-------
SUMMARY
Although the distinct "popping" noise characteristics asso-
ciated with engine brake operation can be an annoying sound
of intermittent nature, the data available indicate that
significant noise reduction is achieved for both accelera-
tion and deceleration vehicle modes if trucks with engine
brakes are properly muffled.
Currently available data indicate that exhaust system muf-
fling is an adequate noise control measure for deceleration
noise from trucks equipped with engine brakes. Decelera-
tion noise levels (with engine brake), in general, are
lower than acceleration noise levels on the same truck
when muffled. In addition, it should be noted that the
sound level standards imposed by the Medium and Heavy Truck
Noise Regulation (40 CFR 205) cannot be met without the
installation of advanced mufflers that are more effective
than those presently available. The Agency is committed
to vehicle noise reduction and, as such, will continue to
monitor regularly the noise generated by engine retarders
installed on all types of vehicles. To this end, in the
future, the Agency plans to conduct deceleration testing
on newly manufactured trucks equipped with engine brakes.
Noise emissions from engine brake operation are unique and
characteristic in nature. Likewise, a health/welfare im-
pact assessment of engine brake noise must be unique to
this source. At this time, it is not evident that such a
unique assessment would result in significant differences
when compared to the health/welfare analysis conducted for
medium and heavy trucks.
13
-------
Economic impacts of deceleration noise emission testing are
minimal if the primary manufacturer of the vehicle installs
the engine brake and there are no substitute systems avail-
able.
14
-------
SUMMARY
Although the distinct "popping" noise characteristics asso-
ciated with engine brake operation can be an annoying sound
of intermittent nature, the data available indicate that
significant noise reduction is achieved for both accelera-
tion and deceleration vehicle modes if trucks with engine
brakes are properly muffled.
Currently available data indicate that exhaust system muf-
fling is an adequate noise control measure for deceleration
noise from trucks equipped with engine brakes. Decelera-
tion noise levels (with engine brake), in general, are
lower than acceleration noise levels on the same truck
when muffled. In addition, it should be noted that the
sound level standards imposed by the Medium and Heavy Truck
Noise Regulation (40 CFR 205) cannot be met without the
installation of advanced mufflers that are more effective
than those presently available. The Agency is committed
to vehicle noise reduction and, as such, will continue to
monitor regularly the noise generated by engine retarders
installed on all types of vehicles. To this end, in the
future, the Agency plans to conduct deceleration testing
on newly manufactured trucks equipped with engine brakes.
Noise emissions from engine brake operation are unique and
characteristic in nature. Likewise, a health/welfare im-
pact assessment of engine brake noise must be unique to
this source. At this time, it is not evident that such a
unique assessment would result in significant differences
when compared to the health/welfare analysis conducted for
medium and heavy trucks.
13
-------
Economic impacts of deceleration noise emission testing are
minimal if the primary manufacturer of the vehicle installs
the engine brake and there are no substitute systems avail-
able.
14
-------
REFERENCE: Greig, J.C., "The Jacobs Engine Brake", Institute of
Mechanical Engineers, paper C5/74, Conference Publi-
cation 1 1974 (England)
105
100
3>
I
_!
Jj
a:
Q
D
o
a;
r>
95
90
85
80
LEGEND
MUFFLED VEHICLES
UNMUFFLED VEHICLES
80
85
90
95
100
SAE J366b DECELERATION MODE SOUND LEVEL, dBA
(JACOBS ENGINE BRAKE ENGAGED)
Figure 1 - ACCELERATION MODE SOUND LEVELS VERSUS DECELERATION MODE
(WITH ENGINE BRAKE) SOUND LEVELS
(SAEJ366b TESTS) FOR HEAVY TRUCKS
105
15
-------
REFERENCE :
Anon; "Noise Levels of New MCI Buses",
Booz-Allen Applied Research, USEPA Contract
68-01-3509 October 1, 1976
90
CO
-o
UJ
s=»
LU
85
w 80 U
C_3
«c
75
SAE J366b
TEST DATA
80 85
DECELERATION LEVEL (dBA)
90
95
* Vehicle S/N S12322
STREET SIDE
O Vehicle S/N S12322
CURB SIDE
8 Vehicle S/N S12323
STREET SIDE
n Vehicle S/N S12323 ;
CURB SIDE
F DENOTES FRONT REFERENCE
LEVEL
R DENOTES REAR REFERENCE
LEVEL
Figure 2 - ACCELERATION MODE SOUND LEVELS VERSUS DECELERATION MODE (WITH ENGINE BRAKE)
SOUND LEVELS (SAEJ366b TESTS) FOR INTERCITY BUSES
-------
NOISE EVENT 1
0 5 10
TIME, SEC.
I.H. TRANSTAR
DOWN HILL
TOO
90
80
70
60
50
------' C WEIGHTING i_.-^--.
AUTO
- UP HILL_: ~ :
UNIDENTIFIED , I
SOUNDS - --£
100
90
80
70
60
,n AUTO
bo UP HILL
A WEIGHTING
I.H. TRANSTAR
DOWN HILL -"..---"-"-—-"--"
Figure 3 - LEVEL RECORDINGS OF VEHICLE PASS-BY NOISE: NOISE EVENT ] (Reference 3}
-------
NOISE EVENT 2
0 5 10
100
TIME, SEC.-
LINEAR
DOWN HILL/NO BR/.CING _ "SCOUT"
DOWN HILL —
60
50
ENGINE BRAKING APPLIED £-_-—
1/3 MILE FROM MIC.
CO
— DOWN HILL/NO BRAKING
Q
2
O
50
TOO
90
80
70
60
50
ENGINE BRAKING APPLIED
1/3 MILE FROM MIC.
j_ A WEIGHTING .zi^-^i^z.-——:=.—:
ENGINE BRAKING APPLIED
1/3 MILE FROM MIC.
KENWORTH
r-— DOWN HILL/NO BRAKING
Figure 4 - LEVEL RECORDINGS OF VEHICLE PASS-BY NOISE: NOISE EVENT 2
CR-e-Fer-ence 3 }
-------
LU
—I
O
z
ZD
O
100
90
80
70
60
50
LINEAR
NOISE EVENT 3
0 5 10
I i i t i I i i i i 1
TIME, SEC.—»»
KENWORTH DOWN HILL
~4 CYL. BRAKING APPLIED
"ABEAM" OF MIC.
C WEIGHTING
60 =
50 —
KENWORTH DOWN HILL
4 CYL. BRAKING APPLIED
"ABEAM" OF MIC.
A WEIGHTING
o
z:
rj
o
TOO
90
80
70
KENWORTH DOWN HILL
4 CYL. BRAKING APPLIED
"ABEAM" OF MIC.
Figure 5 - LEVEL RECORDINGS OF VEHICLE PASS-BY NOISE:
(Reference 3)
NOISE EVENT 3
19
-------
NOISE EVENT 4
0 5 10
\_ i i i j I ii i i J
TIME, SEC.—*>
TOO
90
80
70
LINEAR
o — - KENWORTH DOWN HILL
1/1 CONTINUOUS ENGINE BRAKING
60 : :——:
50
100
90
80
70
60
50
C WEIGHTING -
KENWORTH DOWN HILL
- -CONTINUOUS ENGINE BRAKING
g
=>
o
100
90
80
70
60
50
A WEIGHTING
KENWORTH DOWN HILL
CONTINUOUS ENGINE BRAKING"''
Figure 6 - LEVEL RECORDINGS OF VEHICLE PASS-BY NOISE: NOISE EVENT 4
(Reference 3)
20
-------
NOISE EVENT 5
0 5 10
I i i i i I i i i i I
TIME, SEC.-*-
60
50
todV*9^
4 CYL. BRAKING APPROACHING MIC.
6 CYL. BRAKING "ABEAM" OF MIC.
60
4 CYL. BRAKING APPROACHING MIC.
6 CYL. BRAKING "ABEAM" OF MIC.
50 -
TOO
A WEIGHTING
90 —
5 80
70
60
50
- KENWORTH DOWN HILL"' --
-4 CYL. BRAKING APPROACHING MIC.
6 CYL. BRAKING "ABEAM" OF MIC.
Figure 7 - LEVEL RECORDINGS OF VEHICLE PASS-BY NOISE: NOISE EVENT 5
(Reference 3)
-------
TABLE I
SOUND LEVEL DATA FOR ENGINE BRAKES
(TESTING PROCEDURE NOT EXPLICITLY STATED)
Data from Reference 6 page 16
Overall Exhaust
Noise Level (dB(A))
(Approximate Values)
( Deceleration Test with 102
Unmuffled | Engine Brake
(Straight Pipe) Acceleration Test 95
( Deceleration Test with 76
-. f,, , ( Engine Brake
Muffled . ^
( Acceleration Test 78
Comment: This data appears to have been extracted from
Reference 4, Figure 3, page 8= The data in Reference 4
are octave band sound pressure levels at a 50~foot measure-
ment distance. The above values are presumably derived from
the octave band spectra.
Data From Reference 6, Exhibit D (Freightliner Corporation
test data)
DRIVE-BY JAKE BRAKE
S/N ENGINE LEVEL LEVEL DATE
112526 DDE 8V92T 84 dBA 80 dBA 8-4-75
114602 NTC 290 83 dBA' 77 dBA 8-6-75
114241 DDE 8V71T 82 dBA 79 dBA 8-7-75
22
-------
REFERENCES
1. Rudder, F.F., and Colonna, C.; "Analysis of the Proposed
Amendment to Delete Deceleration Testing from the Medium
and Heavy Truck Noise Regulation," Report to U.S. Envi-
ronmental Protection Agency, Office of Noise Abatement
and Control, May 18, 1977.
2. Greig, J.C.; "The Jacobs Engine Brake," Institute of Me-
chanical Engineers, Conference Publication 1, Paper C5/74,
1974.
3. Bryant, William; "Demonstration Tape Recording of Engine
Brake Operational Noise of an Unmuffled Kenworth Truck,"
Recorded by Region VIII, U.S.E.P.A. personnel, Boulder,
Colorado, April 13, 1977 (See Appendix C)
4. Morse, W.H.; "The Jacobs Engine Brake ("Jake Brake") Re-
viewed, " Presented to Technical Session on Engine Retard-
ers, SAE Automotive Engineering Congress and Exposition,
Cobo Hall, Detroit, Michigan, February 25, 1975.
5. Letter from Mr. R.B. Price, Project Engineer, Jacobs Man-
ufacturing Company to Dr. Alvin F. Meyer, Deputy Assistant
Administrator, Office of Noise Abatement and Control, En-
vironmental Protection Agency: Dated July 25, 1974 (See
Appendix B)
6. Kintner, E.W., et. al.; "Petition of Jacobs Manufacturing
Company for Reconsideration of Medium and Heavy Truck
Noise Emission Regulations," Submitted to the Administra-
tor, Environmental Protection Agency, June 4, 1976; Arent,
Fox, Kintner, Plotkin & Kahn, 1815 H Street, N. W., Wash-
ington, D. C., Counsel for Petitioner.
7. Anon.; "Background Document for Medium and Heavy Truck
Noise Emission Regulations," U.S. Environmental Protec-
tion Agency Report EPA-550/9-76-008, Washington, D.C.,
March 1976.
8. Weaver, L.S.; "Product Improvement Test of Brake System
for Trucks, 5-Ton, 6x6, XM809) Series"; Report No. APG-
MT-3813; U.S. Army Tank Automotive Command, Aberdeen
Proving Ground, Maryland, April 1971.
23
-------
APPENDIX A
DOCKET NO. ONAC 77-3
-------
APPENDIX A
DOCKET NO. ONAC 77-3
DOCKET INVENTORY
(Continued)
DATE
INTERNAL #
INDEX
PAGE NO.
3-15-77
77-3-001
3-15-77
77-3-002
3-15-77
77-3-003
3-15-77
77-3-004
3-22-77
77-3-005
3-22-77
77-3-006
Notice of Amendment to
40 CFR Part 205 - Trans-
portation Equipment Noise
Emission Controls, Medium
and Heavy Trucks • A-5
Ford Motor Company
The American Road
Dearborn, Michigan 48121
W. E. Schweider A-7
Mack Trucks, Inc.
P.O. Box 1761
Allentown, Pa. 18105
John H. Humpton, Jr.
Executive Engineer - Vehicle
Regulations and Standards
A-9
American Trucking Associations, Inc.
1616 P Street, N.W.
Washington, D. C. 20036
William J. K. Gibson
Automotive Engineer A-ll
Department of California
Highway Patrol
P. O. Box 898
Sacramento, California 95804
G. B. Craig
Commissioner A-13
Freightliner Corporation
4747 N. Channel Avenue
P. O. Box 384-9
Portland, Oregon 97208
Roger W. Sackett
Environmental Protection Agency
Region VIII
1860 Lincoln
Denver, Colorado 80295
Robert A. Simmons, Supervisor
Noise Control Program (8 AH-WM) A-17
A-15
A-l
-------
DOCKET NO. 77-3
APPENDIX A
DOCKET INVENTORY
(Continued)
DATE
INTERNAL #
INDEX
PAGE NO,
4-20-77
4-20-77
4-26-77
4-26-77
5-3-77
4-6-77
77-3-007
77-3-008
77-3-009
77-3-010
77-3-011
77-3-012
Department of Environmental
Quality
1234 So Wo Morrison Street
Portland, Oregon 97205
John Hector, Supervisor
Noise Pollution Control Section A-21
Montgomery County, Maryland
Room 340
6110 Executive Boulevard
Rockville, Maryland 20852
Richard J. Peppin
County Acoustical Engineer A-23
International Harvester
P- 0. Box 1109
Fort Wayne, Indiana 46801
N. A. Miller, Staff Engineer
Sound & Energy
Kern Valley Trucking
3901 Medford Street
Los Angeles, California 90063
J. L. Chase^ President
A-2
A-25
A-27
U. S. Department of the Interior
Office of the Secretary
Washington, D. C. 20240
Heather L. Ross
Deputy Assistant Secretary of
the Interior (Acting) A-29
City of Boulder
Boulder, Colorado 80302
James V. Adams
Environmental Protection Officer A-31
-------
DOCKET MO. 77-3
APPENDIX A
DOCKET INVENTORY
(Concluded)
DATE
INTERNAL #
INDEX
PAGE NO,
5-12-77
4-18-77
3-10-77 !
77-3-013
77-3-014
77-3-015
Arent, Fox, Kintner, Plotkin
& Kahn
Federal Bar Building
1815 H Street, N. W.
Washington, D. C. 20006
Marc L. Fleischaker
Counsel for Jacobs Manu-
facturing Company
Freightliner Corporation
P. O. Box 3849
Portland, Oregon 97208
Roger W. Sackett
Department of Noise Control
California State Department
of Health
2151 Berkeley Way
Berkeley, California 94704
A. E. Lowe
A-33
A-37
A-39
A-3
-------
Title 40—Protection of Environment
CHAPTER 1—ENVIRONMENTAL PROTECTION AGENCY
[FPL 684-6]
FART 205—TRANSPORTATION EQUimENT NOISE EMISSION CONTROLS
Medium and Heavy Trucks
This notice amends 40 CFR Part 205 by striking 40 CFR S205.54-l(c) (1) (iv)
and 205.54-1(c)(2)(iv). The amendment, which will'take effect May 31, 1977,
is made in response to a petition for reconsideration submitted by the Jacobs
Manufacturing Company.
In subpart B of 40 CFR Part 205 the Environmental Protection Agency (Em)
established noise emission standards for medium arid heavy trucks„ (See 41 FR
15538, April 13, 1976.) The test method which accompanies those standards was
was developed from a test method, used by the truck manufacturing industry, SAE
J366b, which included a requirement that all trucks equipped with engine brakes
must be subjected to an extra passby test with the engine brake engaged. This
requirement was incorporated in the federal noise emission standards,, 40 CFR
S205.54-l(c) (1) (iv) , 205.54-1(c)(2)(iv). On June 4, 1976, the Jacobs Manufac-
turing Company, manufacturer of engine brakes, petitioned the EPA to delete
these provisions on the grounds that the additional test burden would likely
induce truck manufacturers to stop offering engine brakes on their products,
eliminating the safety and economic benefits attributable to engine brakes, and
that there would be little environmental benefit because of the limited use and
low noise levels of engine brakes. The petition included additional information
which had not been considered during the development of the regulation„
Having studied the information and petition submitted by Jacobs Manufac-
turing Company, the Administrator has determined that it is appropriate to grant
the petition and delete 40 CFR S205.54-l(c) (1) (iv) and 205-54-1(c)(2)(iv). The
evidence indicates that at the levels at which Effi has set the noise emission
standards, 83 dBA (1978) and 80 dBA (1982), the noise contributed by engine
brakes during deceleration is not high enough to be a contributing factor,, and
therefore the additional passby with the brake engaged adds nothing to the test.
This being the case, there is no environmental benefit to offset any additional
burden which the requirement may impose.
The Administrator finds no evidence to support the Jacobs Manufacturing
Company's assertion that the incremental cost of the additional passby test will
cause truck manufacturers to cease offering engine brakes on any of their models,,
The' minimal amount by which this would add to the cost of testing makes such a
result unlikely.
As stated on April 13, 1976 (41 FR 15543) the Administrator is considering
lowering the standard for a future date beyond 1982. When this occurs, the noise
from engine brakes may become a factor, and it will be necessary to consider
whether the engine brake passby test should be instituted at that time. Accord-
ingly, the Administrator's conclusions will be reviewed in full at that time
based on all information then available.
A-5
-------
Public Coronent; This amendment will not take effect for ninety days (May
31, 1977). The Administrator has determined that the public should be given an
opportunity to comment on the deletion of 40 CFR S205.54-l(c) (1) (iv) and 205.54-1
(c)(2)(iv). Accordingly, all interested parties are invited to submit comments
on this amendment, including specifically the conclusions of the Administrator
with respect to economic impacts of the requirement, its environment benefits, and
.the contribution of engine brakes to truck noise levels during testing according
to EEft test procedures. Comments must be received by EEft no later than March 14,
1977.* Unless information is received which merits the withdrawal of this amend-
ment before its effective date, the amendment will take effect without further
notice from EPA.
Comments should be submitted, with 5 copies when possible, to: Director,
Standards and Regulations Division, Office of Noise Abatement and Control
(AW-471), Attention: Docket Ho. ONAC 77-3, U.S. Environmental Protection Agency,
Washington, D.C. 20460.
The Jacobs Manufacturing Company petition and all related information
together with copies of all responses received in response to this notice will be
available for public inspection at the EF& Public Information Center, Waterside
Mall, 4th and M Streets, S.W., Washington, D.C.
(Sec. 6 and 13, Rib. L. 92-574, 86 Stat. 1234 et seq. (42 U.S.C. 4905,
4912).)
Dated February 23, 1977.
John Quaries,
Acting Administrator.
40 CFR Patt 205 is revised, effective May 31, 1977, as follows:
S205.54-1 [Amended]
40 CFR S205.54-l(c) (1) (iv) and 40 CFR S205.54-l(c) (2) (iv) are revoked.
(PR Doc.77-5979 Filed 2-28-77; 8:45 am]
%ote: The deadline ofterchJ^J.977 for receipt of public comments has been
extended to AprilZO, 1977jDV_Fedej:al Register notice dated Ti^FcH"2TrT9T77~'
-------
77-3-001
Ford Motor Company The American Road
Dearborn, Michigan 48121
March 11, 1977
Director
Standards and Regulations Division
Office of Noise Abatement and
Control (AW-471)
Attention: Docket No. ONAC 77-3
U.S. Environmental Protection Agency
Washington, D.C. 20460
Sir:
Ford Motor Company, a manufacturer of medium and heavy trucks,
some of which have gross vehicle weight ratings in excess of
10,000 pounds and employ engine brakes, supports the proposed
revocation of 40 CFR § 205.54-l(c)(1)(iv) and 40 CFR § 205.54-1
(c)(2)(iv). Ford recommends the following additional editorial
changes in 40 CFR § 205.54-1 (c) to remove all other references
to deceleration testing and engine brakes:
. In §§ 205.54-1 (c) (1) and 205. 54-1 (c) (2) , change "Full
throttle acceleration and closed throttle deceleration
tests are to be used." to "Full throttle acceleration
tests are to be used.", and delete "Closed throttle
deceleration tests are required only for those vehicles
equipped with an engine brake."
. In § 205.54-1 (c) (3) (ii) , change "The meter shall be
observed during the period while the vehicle is
accelerating or decelerating." by deleting "or
decelerating."
Sincerely,
W. E. Schwieder
i3 A-7
tr\
-------
77-3-002
. ,, ,„„ 5VJACK TRUCKS,
March 11, 1977 One of The Signal Companie
Director
Standards and Regulations Division,
Office of Noise Abatement and Control (AW-471)
U.S. Environmental Protection Agency,
Washington, D.C. 20460.
Gentlemen:
Attention; Docket No. ONAC 77-3
Mack Trucks, Inc., a manufacturer of heavy duty trucks of
26,000 Ibs. GVW and greater, is pleased to submit the following
comments for inclusion in Docket No. ONAC 77-3.
Mack Trucks presently offers an optional engine brake, on
Mack.turbocharged diesel engines, identified as a "DYNOTARD"
engine brake. A review of the results of our current and ongoing
noise evaluation program indicates that noise levels measured
during the deceleration pass-by test (engine brake actuated) are
lower than those measured during the conventional acceleration
pass-by.
In view of the above, we concur completely with,, and support
the action taken by, the Administrator in deleting the deceleration
pass-by requirement for trucks equipped with engine brakes, as
"being of little environmental benefit because of the limited use
and low noise levels of engine brakes".
Very truly yours,
MACK TRUCKS, INC.
i-ftt
John H. Humjrton, Jr.
Executive Engineer-
Vehicle Regulations and
Standards
jcb
A-9
o
o
fc
•*.~2 .
-3
.D HEADQUARTERS: Engineering Division • P.O. Box 17B1 • Allcntown. Pa. 10105 • (215) 439-3011 - Tnlcx: OU4-7/1;'
-------
77-3-003
TtCHNICAL SFRVICI-S DIVISION
AMERICAN RKhjr.lH.II,,,,!,,!,!.
Managing Dircdor
TRUCKING
ASSOCIATIONS, INC. ,««,.,«;
1616 P Street, N.W., Washington, D. C. 20036 (202) 797-5391
March 11, 1977
Director
Standards and Regulations Division
Office of Noise Abatement and Control
U.S. Environmental Protection Agency
Washington, DC 20460
Docket FRL 684-~6 - PART 205 - Transportation
Equipment Noise Emission Coi trols - Medium
and Heavy Duty Trucks
Dear Sir:
American Trucking Associations, Inc. (ATA) files these
comments in response to the Notice of Proposed Rulemaking
in the above-styled proceedings, appearing in the Federal
Register, March 1, 1977 (42 Fed. Reg. 11385).
ATA is the national organization of the trucking industry,
representing all types of for-hire and private motor
carriers of property. As the national representative, ATA
is a regular participant in proceedings before the National
Highway Traffic Safety Administration, the Interstate
Commerce Commission, and the courts. It is a non-stock,
non-profit corporation organized and existing under the laws
of the District of Columbia, with offices at 1616 P Street,
N.W., Washington, DC 20036,
Many of the trucking companies whom ATA represent, particu-
larly those operating in the western states, are quantity
users of the Jacobs Engine Brake. The Technical Advisory
Group (TAG) to the ATA SCORE Committee, at its last meeting
unanimously agreed that ATA should support the petition of
the Jacobs Manufacturing Company and the proposed deletion
of Section 205.54-1 (c) (1) (iv) and 205.54 (c) (2) (iv) from
40 CFR Part 205, Certainly we can agree that with the
engine brake properly installed and with the requisite
attention being paid to adequate muffling by the vehicle
manufacturer, the noise created by the engine brake during
o
cv»
A-ll
fc
A tiitional Federation Having an Affiliated Association in fach Stale
-------
77-3-003
Page 2
deceleration is not high enough to be a contributing factor
at the proposed 83 and 80 dBA new truck noise levels, and
therefore, the present requirement for deceleration tests
on vehicles fitted with such brakes is superfluous in that
it would have no environmental or other benefit e
We cannot speak to the attitude of the vehicle manufacturers
and the assertion by Jacobs Manufacturing that the require-
ment for the additional test procedure and the incremental
costs involved would inhibit the truck manufacturers from
offering the engine brake. It is, however,, obvious to us
that such additional costs would be very real and would have
to be passed on to the consumer - the truck operators in one
form or another. Over the last 4 years, the cost of the
trucks we must purchase to perform our function has increased
by at least 50% and thus we most strongly oppose any unneces-
sary regulation or facet of a regulation which would serve
no useful environmental purpose and would •. -arry with it an
adverse cost penalty.
It can also be agreed that the retention of the present
additional test requirement with its potential for discour-
agement of the fitment of engine brake would have adverse
safety implications «, To indirectly exclude the engine
brake from those long downgrade operations where it serves
a most beneficial safety purpose would throw an additional
burden on the vehicles foundation brakes , and increase the
potential for brake fade with possibly disastrous consequences.
We commend EPA on their realistic appraisal of the Jacobs
petition and support this proposed rulemaking.
Very truly yours ,
s* r /,'*•**•' *- /
William J. -K. Gibson
Automotive Eng/neer
Engineering(Department
A-12
-------
77-3-004
E OF CALIFORNIA-BUSINESS AND TRANSPORTATION AGENCY tDMUND G BROWN JR., Gov.mor
»ARTMENT OF CALIFORNIA HIGHWAY PATROL
BOX 898
AMENTO, CALIFORNIA 95304
16) 445-1865
March 10, 1977
File No.: 1.A2781.A3579
Director, Standards and
Regulations Division
Office of Noise Abatement
and Control (AW-471)
Attention: Docket No. ONAC 77-3
U.S. Environmental Protection Agency
Washington, DC 20460
Gentlemen:
We offer the following comments for your consideration on the
March 1, 1977, Notice of Amendment (FRL 684-6) to Part 205,
Transportation Equipment Noise Emission Controls.
California has had no recent problems with exhaust noise from
Jacobs brakes. We agree that deceleration noise tests are not
always necessary on every vehicle with engine brakes and could
be an unnecessary testing expense if conducted on every new
vehicle model „ However, there may be a few engine designs or
future types of engine brakes that could produce excessive
deceleration noise.
We recommend that EPA regulations retain authority to run the
deceleration test only on special systems that may be suspected
of being loud on deceleration as observed when the truck is operated
preparatory to other testing. If the deceleration test is
completely eliminated, there would be no limit on total noise that
a truck could emit on deceleration, with or without an engine brake.
We take exception to the extremely short period allowed for
comments. The Notice was dated February 23 but was not printed
in the Federal Register until March 1. The Register did not reach
Sacramento in the mail until March 7, leaving only four working-
days for a reply.
Very ?truly^yours,
G. B. CRAIG
Commissioner
A-13
-------
77-3-005
FREIGHT-LINKK CORPORATION
4747 N CHANNEL AVENUE
P. O. BOX 3849
PORTLAND. OREGON 972O8
_ (503) 283-8020
ROOER W. SACHETT
Vice President-Engineering
March 14, 1977
Director,
Standards and Regulations Division
Office of Noise Abatement and Control (AW-471)
Attention: Docket No. ONAC 77-3
U.S. Environmental Protection Agency
Washington, D.C. 20460
SUBJECT: Response to Notice of Amendment to Part 205,
Transportation Equipment Noise Emission Controls
REFERENCE: Federal Register 42 F.R.11836, March 1, 1977
Dear Sir:
Freightliner Corporation hereby submits its comments to the amendment
to Part 205 which would eliminate an extra passby test with the engine
brake applied.
Freightliner is in favor of the amendment. We would, however, like
to point out three additional references to testing with engine brakes
that were omitted from the amendment, probably inadvertently.
The amendment deletes the following:
1.) 205.54-l(c)(l)(iv)
2.) 205.54-l(c)(2)(iv)
In addition, references to testing vehicles with engine brakes are made
in the following:
3.) 205.54-l(c)(l), last sentence: "Closed throttle deceleration
tests are required only for those vehicles equipped with an
engine brake."
4.) 205.54-l(c)(2), last sentence: (Same as (c)(l), above).
5.) Table IV: "Test data: deceleration test:" and section
headed "Deceleration test with exhaust brake applied."
s A~15
fc
-------
77-3-005
Director
March 14, 1977
Page 2
Items 3, 4, and 5 should be modified if items 1 and 2 are deleted,
Yours truly,
FREIGHTLINER CORPORATION
Roger W. Sackett
RWSrskw
A-16
-------
77-3-006
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: Mar 14, 1977
SUBJECT: Proposed Deletion of 40CFR Section 205.54-1C14 and Section 205.54-1C24
FROM: Robert A. Simmons, Supervisor
Noise Control Program (8AH-WM)
T0: Director, Standards and Regulations/(AW-471)
Office, of Noise Abatement and Control
ATTN: Docket Number ONAC 77-3
There is a very significant environmental benefit resulting from
the proper muffling of engine brake noise. Region VIII experiences
with the deleterious effects of noise resulting from the operation
of engine brakes indicates that such devices do make a significant
contribution to truck noise levels during their operation in the
field and would hope that such contributions would be reflected by
our EPA standards and test procedures.
Engine brakes are an essential safety requirement for the operation
of heavy trucks on mountainous and hilly roads, and are therefore
very common to this Region.
Following are additional general comments relating to the deleterious
environmental impact of the noise produced by the operation of engine
brakes and an indication of the environmental benefit which would
be produced by the control of such noise.
1) Engine brake noise is a source of predominant complaints
received from the public by states and municipalities in Region
VIII having or seeking to develop noise control programs and also
by this Region Office. Engine brake noise complaints often exceed
truck acceleration noise complaints. Some explanations for this
phenomenon are listed below.
2) Community noise control officers in Region VIII in the
process of routine enforcement do find trucks for which the engine
brake noise in their deceleration test is greater than the noise
produced by the same vehicle during maximum acceleration tests.
3) The frequency distribution and time modulated amplitudes
of the engine brake noise during deceleration is significantly
different from the exhaust noise produced by the truck during
acceleration. Truck mufflers can be designed to address one or
both of these frequency distributions. A truck muffler designed
for optimum performance for the acceleration noise may very well
not provide the attenuation desired for the frequency distribution
of the engine brake noise, therefore suggesting the need to provide
noise control standards and testing for both modes of operation.
o
• «
tr\
EPA Form I3?0 6 IRpv. 3 7A>
A-17
-------
77-3-006
4) Engine brake noise per decibel creates more deleterious
effects on the health and welfare of individuals than does truck
acceleration noise. The predominant effects experienced -in Region
VIII are annoyance, sleep interference, speech interference, and
startle reflexes. This higher environmental impact of engine
brake noise is attributed to the more unique characteristics of the
sound produced by the truck in the engine brake mode of operation
and by the ambient conditions experienced by receivers of the noise
when the engine brake noise is present. More specifically, engine
brake noise in comparison to engine acceleration noise contains
higher frequencies, more repetitive and cyclic sound characteristics
relating to the "sharp5 sticatto patterns" of noise produced,
and the more abrupt onset of the noise experienced when the engine
brake becomes fully engaged. The ambient sound levels experienced
by receiving individuals located near portions of the roadway
where engine brake noise in the deceleration mode is experienced
are normally considerably lower than the ambients experienced by
steady state cruise-by or by acceleration mode portions of road-
ways. This reduced ambient increases the environmental insult
of the engine brake noise when an engine brake abruptly becomes
and remains engaged, thereby creating a significant potential for
annoyance, sleep interference, speech interference, and other
physiological and psychological effects associated with startle
phenomenon.
5) Although engine brakes are an essential safety feature
for heavy trucks operating on long, steep descents, they are not
necessary, from a safety standpoints within communities which do
not have such descents. Howevers use of engine brakes within our
communities is commonplace and significant numbers of people are
affected by their use. The truck operator must remember to throw
the off-switch in his cab in order to disengage the engine brake
and must remember to turn it back on again during long, steep de-
celerations where the engine brake is necessary for safety purposes.
Many truck operators either forget to turn the switch off when
it is not necessary for safety purposes or find it convenient to
leave it on. Therefore, the use of engine brakes in the portions
of the country where engine brakes are used is not limited, but
can be extensive. Some truck operators may desire, purposely,
to leave the engine brake on when operating on level streets within
communities or elsewhere in order to allow them to accelerate
through the gears faster since the engine brake allows the engine
speed to reduce quicker thereby providing a slight decrease in
the time required to perform a shift from a lower gear to a higher
one. It is also possible that some operators may like to hear
engine brake noise—it does something for their genes. These
habits are not safety related and can provide a significant en-
vironmental noise insult to significant numbers of people.
A-18
-------
77-3-006
6) The observations and concerns mentioned above suggest that
the pass-by test in the engine brake mode of operation should be
retained and this Agency should consider reducing the sound pressure
level standard for that pass-by test to more restrictive levels
than those required by the maximum acceleration mode of operation.
There has not been adequate time for public comment on this proposed
deletion and there appears to be considerable interest in this mat-
ter in Region VIII; therefore, we respectfully request a 45-day
extension of the public comment period to allow adequate time for
preparation and submission of such comments by the public, community
and state officials, and of more specific comments from this Regional
Office. The Region VIII Noise Control Program received several
phone calls from interested community officials on March llth and
14th, expressing concern about the proposed deletion and their
desire to provide EPA with comments, further indicating that the
current public comment period was not adequate to provide them
with the necessary time to provide EPA with su^h input. Apparently
most state, local and Regional noise control officials have re-
ceived written notice of this proposed deletion in their offices
on March 10th and March llth, with final comments due to EPA the
following Monday, March 14th. In most cases, these officials were
notified of this action by the March 7th issue of Noise Control
Report which was received in their offices on March 10th or llth.
We thank you in advance for consideration of our hastily prepared
comments and invite you to seek additional clarification if desired.
cc: John M. Ropes (A-104)
A-19
-------
ROBERT W. STRAUB
COvitNOa
77-3-007
Department of Environmental Quality
1234 S.W. MORRISON STREET, PORTLAND. OREGON 97205 Telephone (503) 229- 6085
April 15, 1977
Mr. Henry Thomas
Director, Standards and Regulations
Division
Office of Noise Abatement and Control
(AW 471)
U.S. Environmental Protection Agency
Washington, D.C. 20460
Re: Docket No. ONAC 77-3
Dear Mr. Thomas:
Following are the comments of the Oreqon Department of Environmental
Quality regarding the proposal to rescind the requirements that engine
brakes be subject to the test provisions specified in the medium and
heavy duty truck noise regulations:
Immunity from state and local regulation has been established for various
truck noise sources, including exhaust-engine brakes. These are, instead,
Federally regulated under the interstate motor carriers noise standards.
The preemption provisions of these regulations provide for exclusive Federal
control unless identical regulations have been adopted at the state or local
level, or an exception to preemption has been granted under the provisions
for "special local determinations." For all practical purposes then, local
or state control in this area is precluded. If protective standards are
to be implemented, it must be done at the Federal level, or not at all,
This latter possibility concerns us.
We believe that operation of exhaust-engine brakes, installed on new
trucks otherwise required to comply with Federal new truck regulations,
should be included in the testing procedure used to establish that vehicle's
noise rating for purposes of certification. If these sources are regula-
ted under the in-use standards, it seems reasonable that they should also
be subject to the new vehicle standards.
Oregon receives many complaints concerning the operation of "Jake
Brakes." The state presently requires new trucks equipped with "exhaust
brakes" to be tested with the brakes in full use during the deceleration
portion of the test as part of certification. This has not caused adverse
comment to be received from truck manufacturers. However, the requirement
has had a positive impact on the number of complaints received due to
exhaust brake operation.
o
fc
A-21
-------
77-3-007
Mr. Henry Thomas
Page 2
April 15, 1977
In conclusion, to discontinue control of exhaust brakes on new trucks
subject to Federal preemption would be unwise. Including exhaust brakes
has not placed an unreasonable burden on truck manufacturers, yet dis-
continuance would have the effect of increasing the number of people dis-
turbed by this source while preventing state or local jurisdictions from
filling the enforcement gap thus created. Approval of this proposal would
not be a step in the right direction.
Thank you for the opportunity to submit our comments,
Sincerely,
WILLIAM H. YOUNG
Director
John Hector
Supervisor
Noise Pollution Control Section
NDS:dro
A-22
-------
77-3-008
Department ol Environmental Protection
Division ot Resource Protection
MONTGOMERY COUNTY, MARYLAND
ROOM 340, 6110 EXtCUTIVE BOULEVARD, ROCKVIUE, MARYLAND 20U52
1 14, 1977
Henry E. Thomas, Director
Standards and Regulations Division
Office of Noise Abatement and Control
(AW-471) Attention: Docket #ONAC77-3
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Thomas:
The proposed amendment to 40 CFR Part 205 omitting 40 CFR S205.54-1(c)(l)(IV)
and 205.54-1(c)(2)(IV) is well taken. We concur with the action of the Environ-
mental Protection Agency in response to the petition for reconsideration submitted
by the Jacobs Manufacturing Company.
As long as the noise levels produced by the engine brakes are significantly
less than the other major noise sources, the addition of the engine brake test is
not important. However, when engine brakes do become major truck noise sources,
when compared to the rest of the noise producing elements of vehicles, the engine
brake tests should be reinstituted. We question how EPA will determine at what
point the engine brake will become a major noise source and what is to prevent
manufacturers from neglecting noise controls (if required) on engine brakes if
there is no federal regulation and/or test procedure to control/measure the noise
produced by the brakes.
Sincerely yours
Engineer
Noise Control Section
Richard J. Peppin
County Acoustical
Air Pollution and
RJP:sdc
3
S
A-23
-------
77-3-009
1MTERNAT10MAL HARVESTER
April 20, 1977
Mr. H. E. Thomas
Director, Standards & Regulations Div.
Office of Noise Abatement and Control (AW-471)
Environmental Protection Agency
Crystal Mall, Bldg. 2
1921 Jefferson Davis Highway
Arlington, Virginia 20460
Dear Mr. Thomas:
In response to Docket Number ONAC 77-3, which calls for deletion of
40 CFR Paragraphs 205.54-l(c)(1)(iv) and 205.54-l(c)(2)(iv), Interna-
tional Harvester offers the following comments. Deletion of these
paragraphs would remove the necessity for performing deceleration tests
on all medium and heavy duty trucks during Selective Enforcement Audits
when such trucks are equipped with exhaust brakes. International
Harvester supports the deletion of these paragraphs. It has been our
experience that vehicles equipped to meet the 1978 Federal Noise require-
ments during acceleration testing create no more noise during the deceler-
ation test; therefore, the deceleration testing is an unnecessary
burden on the manufacturer and provides no benefit for the community arid/or
our customers.
In order to support this position we submit the following data on 10
vehicles tested both under the acceleration and deceleration procedure.
These vehicles were equipped with exhaust and cooling systems typical of
those that will be produced after January 1, 1978.
Accel Minus Decel
Vehicle Model Engine 8 Pass Average
1 Paystar
2 Paystar
3 Paystar
4 Conventional
Transtar
5 Conventional
Transtar
6 Conventional
Transtar
7 Conventional
Transtar
8 Conventional
Transtar
9 Transtar II
10 Transtar II
AVERAGE
Cummins
Cummins
Cummins
Detroit
8V92T
Detroit
8V92T
Cummins
Formula
NTC-350
NTC-350
NTC-350
Diesel
Diesel
-350
Cummins NTC-350
Cummins NTC-350
Cummins NTC-350
Cummins NTC-350
+ .7
-.1
+1.3
+ .1
-.2
-.2
—. 3
4-1.1
+1.3
+3.2
+ .69
Jfk
TRUCK DIVISION ENGINEERING 2911 Moyer Road Fort Wliyno. Indiana 46S03 Phono 219 401 M28
Address reply lo P.O Box 1109 Fort Wnyne. Indiana 46001
A-25
-------
77-3-009
Mr. H. E. Thomas 2 April 20, 1977
This sample is somewhat limited due to the number of vehicles with
exhaust brakes that were available. The data provided is the arithmetic
average of 8 passes for each vehicle. We feel this is a most accurate
method of evaluation for comparing procedures. As the table indicates,
noise produced from the acceleration test on the average was more than
1/2 dB(A) higher than that produced during the deceleration test. In no
case did the average noise value from the deceleration test exceed .3
dB(A) more than the noise obtained from the acceleration test. Since .3
dB(A) is well within experimental error, the negative values do not
indicate that noise from the deceleration test was higher than that from
the acceleration test.
Our experience has shown that in the case of vehicles with overall truck
noise levels higher than 83 dB(A) where fan and exhaust noise are pre-
dominant, that noise levels during the deceleration test can be higher
than those from the acceleration test. Our experience has also shown,
as the data above indicates, that once the truck noise level is reduced
to meet the Federal 1978 and 1982 Standards, the deceleration noise
levels are equal to or lower than the acceleration levels. Therefore,
International Harvester supports EPA's conclusion that, "...the noise
contributed by engine brakes during deceleration is not high enough to
be a contributing factor, and therefore the additional passby with the
brake engaged adds nothing to the test. This being the case, there is
no environmental benefit to offset any additional burden which the
requirement may impose."
I hope that the above is helpful in justifying the deletion of the
paragraphs in question. If we can be of further assistance, please
don't hesitate to contact me or Mr. R. F. Ringham, Corporate Vice
President, Technical Affairs (202-296-7890).
Very truly yours,
N
-------
Phones:
os Angeles 268-9901
okenfield 323-6053
ulore 686-8578
"Specialized Service" «t Freight Rates
77-3-010
Pnones:
Fresno 268-0139
Stockton 462-7720
Sacramenfo 442-7617
COMMON CARRIER
3901 Medford Street
Loi Angelej, California 90063
April 20, 1977
Director, Standards and Regulations Division
Office of Noise Abatement and Control (AV.r-k7D
Attention: Docket No. GIJAG 77-3
U.S. Environmental Protection A^ ^r c-y
VJashinfton, D.C. 20lj.60
Dear 5ir:
\':j comment on the Jacobs Brake are that thin was and is
the greatest equipment to put on equipment.
Many trucks in the years before this Jacob ^.rake wn a
manufactured would lose breaking power due to heat on the
braking drums and then brake lining catching fire. In
many of these cases bad accidents resulted from no control
of the equipment.
Our company runs over the ridge route end this is where I
have seen what happened. I know there -oust be many hills
greater than this route.
I believe that this J?cob 3rake should not be used in the
cities unless necessary as they ^re noisey and in most cases
not needed.
The cost factor is anot^e^ advnntare to truckin.r sc the
brake lining is very costly and ties equipment u^ while
doin" a job that would not hnvn to be done HIT much-. In fact
we get 3 times more us of the brake lining.
For many years truckinp had been lookinp for somethinp to
help runaways. Please do not take it away.
Sincerely your?
J.L. OKI TO
Pros! don!;
Korn VnMov
A-27
-------
77-3-011
United States Department of the Interior
ER 77/348
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
APR ,; ; 1977
Dear Sir:
We have reviewed your notice, dated February 23, 1977,
concerning noise emission standards for medium and heavy
trucks, which proposes to amend 40 CFR Part 205 by
deleting 205.54-l(c)CD(iv) and 205.54-lCc)C2)Civ). We
have no other comment accept to note that the determination
of the Administrator to presently delete these sections and
to consider the engine brake issue when future, more strin-
gent noise standards are considered, appears to be techni-
cally sound and reasonable.
We appreciate the opportunity to comment on this amendment.
Sincerely yours,
' '."fit Secretary of the Interior
Director, Standards and
Regulations Division
Office of Noise Abatement
and Control (AW-471)
Attention: Docket No. ONAC 77-3
Environmental Protection Agency
Washington, D. C. 20460
A-29
-------
77-3-012
OF BOULDER, COLORADO 8O3O2
March 31, 1977
Director, (Standards and Regulations Division
U.S. Environmental Protection Agency
*K)1 K. St. S.W.
V.'ashington, D.C. 2C460
Ee: Jacobs Manufacturing Company Request for Deletion of Deceleration Test.
(40 CFR Section 205.5^-1C14 and Section 205.54-1C24)
Dear Sir:
The test in question is a most critical one here in )ur mountainous area
where the necessity of the Jacobs Brake fpr safety is an absolute must.
Most large trucks in this area are equipped with this device and most drivers
use it, not only to achieve a retarding engine action on long downhill grades;
but also to assist in achieving a downshift in the transmission while driving in
town. In both of these uses the Jake Brake causes the exhaust note of the
engine to shift in frequency and, if not properly muffled, to emit sound levels
which are intolerable.
I have had occasion to issue a noise violation summons to a truck decelerating
with the Jake Brake in our City emitting a level of 97 dBA at a distance of 75'.
The vehicle was equipped with a muffler, although an inadequate one. On the
installation of a proper muffler, this truck was tested and the following
levels were recorded.
At 25' accelerating in first gear (under 55 rr.ph) 87 dBA.
At 25* accelerating in second gear (under 55 mph) 86 dBA.
At 25' decelerating from 35 mph using the Jake Brake 8? dBA.
The summons was dismissed. The truck, when properly muffled,can perform as
quietly in the decelerating^mode as in the accelerating mode. It should not
be considered a hardship on the manufacturer to provide an adequate muffler
on his product that will accomplish the necessary control of noise. Also,
it should not be considered a hardship to test these components in operation
to assure that noise control is accomplished.
In the Jacobs Company request to delete the test no mention was made of the
truck under test being properly muffled. In order to really determine if a
vehicle ia properly muffled, tests in the acceleration and deceleration :rio.-ies,
clue to the frequency shift of the exhaust note, c.ust be performed. Once an
expropriate muffler is found for that vehicle, then the toot v.-ould not be
r.v 7essary on every vehicle :...v.nuf'Vcturcd as lonj 'nj the t'j-pro^riate muffler
v.-'is s:/ecified and used.
A-31
-------
two
77-3-012
The requirement of an appropriate muffler on every truck, including those
equipped with a Jake Brake, will cause an immediate improvement in the
environment of many small mountain communities that do not have an enfor-
ceable effective noise ordinance. Also, this action v/ill assist the E.P.A.
to achieve the desired eventual goal of an Ldn of 55
I request that the deceleration test for trucks equipped with Jacobs Brakes
not be deleted in it's entirety,
Very truly yours,
I/
James V. Adams,
wironmental Protection Officer
ccj Robert V.'estdyke, City Manager
Andy Hollar, Director, Public Facilities
Fete Hansel, Director, Operations
Charles L. Elkins, D.A.A. O.N.A.C. U.^.E.P.A.
John A. Green, Regional Administrator, U.S.E.P.A. Region VIII
Kobert A. Simmons, Supervisor, Eegion VIII Noise Office
A-3 2
-------
77-3-013
Arent.Fox.Kintner, Plotkin&Kahn R.cj(.
_ _-kM,H C. OOLOMAM JOM« c
i. C*LL1GABO
»C"H P ORI'
f f COLt
TMOS SCMATjtrtpitLO JOSEPH M faif%
MABH M..IOCL»On CM>M(.(n B >* U T T ff (.
ALIEN o anort o
-------
77-3-013
Mr. Henry E0 Thomas - 2 - May .12, 1977
Two commentors supporting the deletions correctly
stated that 40 C.F.R. *§§205 . 54-1 (c) (1) ; 205.54-1(c) (2) ; 205.54-
l(c)(3)(ii), and Table IV also should be amended to reflect
the changes in the testing regulations. Jacobs concurs in
these conforming recommendations .
Only two comments opposed the deletion of the test-
ing requirements with the engine brake engaged. Neither of
these comments, however, justifies a change in the agency's
action.
First, the State of Oregon Department of Environ-
mental Quality opposes the change because it "would have the
effect of increasing the number'of people disturbed by this
source while preventing state or local jurisdictions from
filling the enforcement gap thus created." This conclusion,
however, is invalid for two reasons. First, the Noise Control
Act does not preclude states from regulating the operation
of trucks with engine brakes. It provides only that new
trucks need not be tested with the engine brake engaged in
order to be certified under Federal rules. It does not pre-
vent states from regulating the use, operation or movement
of trucks. Second, Oregon appears to ignore the fact that
the positive power muffling required under the Federal test
procedure will assure that the use of engine brakes does
not result in excessive noise. This is a critical fact that
will assure the effectiveness of the Federal test without
the engine brake engaged„
The only other comment opposing the deletion was
filed by Robert A, Simmons, Supervisor of the EPA Noise Con-
trol Program in Region VIII. Jacobs1 response to each of
Mr. Simmons' points is as follows:
(1) Mr. Simmons states that engine brake noise
complaints often exceed truck acceleration
noise complaints. However, the data presented
on Page 16 of the Petition of Jacobs Manufac-
turing Company for Reconsideration of Medium
and Heavy Truck Noise Emission Regulation,
dated June 4, 1976 (hereinafter referred to
as "Jacobs Petition"), contradict this state-
ment. Additional data are supplied in Table
5.2 of Appendix B in the said Petition. Greig,
"The Jacobs Engine Brake," Retarders for Com-
mercial Vehicles (1974). These data show that
a_vehicle which is properly muffled for posi-
tive power operation, i.e. acceleration, is
also properly muffled for the reduction of
any engine brake generated noise.
:" -34
-------
77-3-013
Mr. Henry E. Thomas - 3 - May 12, 1977
(2) Mr. Simmons asserts that community noise con-
trol officials do find trucks for which the
engine brake noise is greater than the noise
produced by the same vehicle at maximum accel-
eration. This comment, however, fails to set
forth the actual magnitude of the maximum ac-
celeration noise. Jacobs has conceded that
improperly muffled vehicles may produce engine
brake noise greater than the positive power
noise. These occasions have been investigated
by Jacobs. The vast majority of such cases
occur when the vehicle contains only straight
pipes. Again referring to Page 16 of the Jacobs
Petition, it is obvious that the installation
of a sound muffler, which is now required under
Federal regulations, has a dramatic effect
on both engine brake and acceleration noise,
Consequently, it would appear that the vehicles
referred to by Mr. Simmons were not properly
muffled for maximum acceleration power,,
(3) Mr. Simmons in this comment refers to the fre-
quency distribution and amplitude of the engine
brake noise, and states that truck mufflers
with good acceleration muffling may not have
good deceleration muffling. However, Exhibit B,
Figure 5.11 attached to the Jacobs Petition
clearly demonstrates that the magnitude and
frequericy of engine brake noise energy is
consistent in form with the positive power
noise energy. The contention of a significant
difference between the two is not supported
by data. Trucks produce positive power noise
along the full spectrum of hearing. The data
indicate that the majority of this noise energy
is in the frequency range of 60 - 2000 Hertz.
The same is true for the engine brake. In
fact, since engine brake noise results from
the release of compressed gases at distinct-
points in the engine cycle, and since positive
power noise is also .created by the release
of compressed gases during the engine cycle,
there should be no real difference in the fre-
quency distribution of the two noise energies.
Neither the frequency nor amplitude of the
noise energy differs significantly between
the brake and positive power noise emissions.
A muffler which is good for one is very obviously
good for the other.
A-35
-------
77-3-013
Mr. Henry E. Thomas - 4 - May 12, 1977
(4) In this comment Mr„ Simmons contrasts the char-
acteristic sounds of engine brake noise with
the characteristic sounds of positive power
noise. The comment implies that on the down-
grade of the hill people do not expect to hear
noise and are more perturbed by the engine
brake than they are if they live on the upgrade
side of the hill and expect to hear accelera-
tion noise. This comment is completely sub-
jective and unsupported by data. Moreover,
of course, it should be noted that for each
truck going down the grade there is another
one in the opposite lane going up the grade.
Therefore, the implication that receiving in-
dividuals who are located at different loca-
tions should be treated differently has little
merit.
(5) Lastly, Mr. Simmons refers to the driving habits
of truck operators and the apparent enjoyment
they receive from operating their engine brake
in unlikely places. Like the above comment,
this is entirely subjective, it is not substan-
tiated by data, and it should be rejected.
In any event, inappropriate operation of ve-
hicles can, of course, be corrected by state
and local regulation.
The comments mentioned in this letter are the only
ones which have been submitted for the public record. Most
support the deletion of the engine brake test requirements,
and the other two contain no substantive data that question
it. None of the comments questions the significant safety
benefits of the engine brake.
For these reasons, as well as those stated in the
Jacobs Petition and the March 1 Federal Register, Jacobs Man-
ufacturing Company believes that the deletion of 40 C.F.R.
§§205.54 (c) (1) (iv) and 205. 54-1 (c) (2) (iv) was correct, and
that the amendment should take effect as scheduled on May 31,
1977.
Respectfully submitted
Marc L. Fleischaker
Counsel for
Jacobs Manufacturing Company
cc; J\H Parties of Record
A-36
-------
77-3-014
FREIGHTJ.INKR CORPORATION
4747 N. CHANNEL AVENUE
P. O. BOX 3849
PORTLAND. OREGON 972O8
„ _.- „ BO3) 283-8020
ROOER Vf. SACKETT
Vice President-Engineering
April 18, 1977
Director,
Standards and Regulations Division
Office of Noise Abatement and Control (AW-471)
Attention: Docket No. ONAC 77-3
U.S. Environmental Protection Agency
Washington, D.C. 20460
SUBJECT: Comments on Amendment to Delete Test Requirement
REFERENCE: Part 205, Transportation Equipment Noise Emission
Control Controls
Dear Sir:
This letter responds to the notice which appeared In the Federal
Register (Vol. 42, No. 40, 11836) on Tuesday, March 1, 1977,
amending the subject standard and inviting comments with respect
to the effect of engine brake noise during vehicle deceleration.
Freight!iner Corporation is in favor of the amendment.
Freight!iner experience supports the findings of the Jacobs
Manufacturing Company as reported in the notice and the deter-
mination by the Administrator that noise caused by engine
braking during deceleration is substantially lower than the noise
emitted by the same vehicle under full throttle acceleration.
Freightliner has tested two general classes of heavy duty diesel
engines with respect to this subject:
1. 8 cylinder, V type, two cycle, turbocharged, in both
300 and 400 horsepower configurations.
2, 6 cylinder, in-line, four-cycle, turbocharged, in a
290 horsepower version.
The two-cycle engines (1) emitted 3 to 4 dBA lower noise levels in
engine brake deceleration tests than in comparable full throttle
acceleration tests.
The four-cycle engines (2) emitted 6 decibels lower in engine
braking
fcf
-------
77-3-014
Di rector
April 18, 1977
Page 2
In all tests discussed here, the noise emission levels under
engine braking deceleration were 80 dBA or lower. All such tests
were run under the conditions specified by Part 205.
It is our conclusion that for the types of turbocharged diesel
engines used in heavy duty vehicles, the contribution of noise
emitted by the Jacobs engine brake is of such a low order of
magnitude compared to the noise emitted by the same engine under
full power acceleration that the special passby test would
serve no useful purpose in testing for compliance under the present-
standards. For this reason} Freight!iner supports the amendment
to delete the deceleration passby test.
Yours truly,
FREIGHTLINER CORPORATION
Roger W. Sackett
RWS:skw
A-38
-------
77-3-015i
j
Mailgran
1-016507M069 03/10/77 ICS IPMBLSA BERK WSHA
01022 MGM BERKELEY CA 380 03-10 225P PST
CHARLES L ELKINS, US ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF NOISE ABATEMENT AND CONTROL AW (471
WASHOC 20460
FOLLOWING -SENT 3-10-77
JOHN QUARLES ACTING ADMINISTRATOR ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DC 20460
REFERENCE YOUR NOTICE DATED FEBRUARY 23, 1977 AMENDING 40 CFR
PART 205 STRIKING 40 CFR 205.54-1 (C) (1) (IV) AND
205.54 (C) (2) (IV). (FEDERAL REGISTER, VOL. 42, NO 40? MARCH
if 1977.)
IT is WIDELY RECOGNIZED AND IT HAS LO-NG BEEN THE OBSERVATION OF THIS
OFFICE- THAT COMMUNITY REACTION TO TRUCK DECELERATION NOISE IS GR>-
EATLY EXACERBATED WHEN SOME ENGINE BRAKES SYSTEMS ARE APPLIED,, THIS-
MAY BE DUE TO THE IMPULSIVE CHARACTER OF THE NOISE BUT THE PHEN-
OMENON NEEDS ELUCIDATION. ALSO, WHILE AVAILABLE DATE SHOW THAT
ENGINE BRAKE DECELERATION NOISE LEVELS ARE USUALLY i
OR 2 DB LESS THAN MAXIMUM ACCELERATION NOISE LEVELS DETERMINED BY
SAE J366B TEST, COMPLAINTS TO THIS OFFICE INDICATE THAT AT LOWER
RATES OF ACCELERATION AND DECELERATION (CITY TRAFFIC CONDITIONS)
WNGINE BRAKE DECELERATION NOISE IS MUCH MORE OFFENSIVE,,
AGAIN, ELUCIDATION IS 'NEEDED. DISPARITY BETWEEN 'PUBLIC REACTION
TO ENGINE BRAKF. DECELERATION NOISE AND NOISE LEVELS DETERMINED
BY SAE J366B TEST SUGGESTS THAT THE TEST MAY BE AN
INAPPROPRIATE MEANS OF EVALUATING THE OFFENSIVENESS OF THIS
PARTICULAR NOISE. UNTIL SUCH ANOMALIES ARE RESOLVED, DELERT10N OF
THE DECELERATION TEST IS UNWARRANTED AND UNWISE. RATHERo THE
TEST SHOULD BE REFINED AND MADE TO CORRELATE WITH THE
OFFENSIVENESS OF THE NOISE IT PROPOSES TO ASSESS,
PUBLIC REACTION SUGGESTS THAT ENGINE BRAKE DECELERATION
NOISE LEVELS- PROBABLY SHOULD BE LESS THAN ACCELERATION LEVELS
FOR EQUAL ACCEPTABILITY, CALIFORNIA LAW REQUIRES A DECELERATION
TEST WHENEVER DECELERATION NOISE APPEARS EXCESSIVE. THE DEPARTMENT
OF HIGHWAY PATROL FINDS THIS PROVISION A VALUABLE AND
USEFUL MEANS OF EVALUATING DECELERATION NOISE WHETHER DUE
TO ENGINE BRAKES OR OTHER CAUSES. SUBJECT AMENDMENT WOULD
PREEMPT THIS REQUIREMENT AND DENY OUR CITIZENS ITS PROTECTION,,
IN VIEW OF THE FOREGOING, THE OFFICE OF NOISE CONTROL*
CALIFORNIA STATE DEPARTMENT OF HEALTH, URGENTLY RECOMMENDS
THAT THE AMENDMENT BE RESCINDED AND THAT EPA CAUSE AN
INVESTIGATION TO BE MADE TO DETERMINE THE RELATIVE OFFENSIVENESS
OF ENGINE BRAKE DECELERATION NOISE, TO DEVISE AN APPROPRIATE
TEST PROCEDURE FOR EVALUATING SUCH NOISE, AND TO ESTABLISH LEVELS
FOR SUCH NOISE WHICH SHOULD NOT OE EXCEEDED
TO lit PI. Y HY MAII.OflAM, STL: P.( VI MSI .',11)1 I Oil V/l '.,1 I UN UNIOII'T, 1OI I - I RU I'lK'.NI NUMMIH',
A-39
-------
f
/;> 77-3-015
xlCTES POSt, «
„ * ^g. V
!££!£Marigram'r£!
%-p * —- «
*******
A E LOWE, CHIEF OFFICE OF NOISE CONTROL CALIFORNIA STATE
DEPARTMENT OF HEALTH
2151 BERKELEY WAY BERKELEY CA
18:15 EST
MGMCOMP MGM
TO REPLY BY MAII GRAM, '.(.f iirvmsi: MD(- i on wr^Tcnn union-; ion. - rnce pnofjr
A-40
-------
APPENDIX B
LETTER FROM JACOBS MANUFACTURING CO
DATED July 25, 1974
-------
/
WEST HARTFORD, CONNECTICUT O6IIO U.S.A.
July 25, 197li
Dr. Alvin F. Meyer
Deputy Assistant Administrator
Office of Noise Abatement and Control
Mail Code AW 5?1
Environmental Protection Agency
U01 M-Street, S.W.
Washington,D.C. 201*60
Dear Dr. Meyer:
The Jacobs Manufacturing Company is the only manufacturer of compression
retarders. Twenty five per cent of the large trucks on the West Coast
use compression retarders. Compression retarders can contribute signi-
ficantly to total vehicle noise during deceleration and must be accounted
for in noise tests. The Jacobs Engine Brake is used to control vehicle
speed down long grades and to help decelerate vehicles_ to a stop. If a
vehicle is permitted to emit excessive noise during these periods it will
have a detrimental effect on our environment.
The Jacobs Manufacturing Company is interested in amending or changing
Section 202.13 of the Environmental Protection Agency's Part 202 of Title
hO of the Code of Federal Regulations establishing noise emission standards
for motor carriers engaged in interstate commerce. The change would be to
incorporate the measurement of noise with the vehicle in a stationary
position when the engine is decelerated from governed speed to idles which
will effectively measure the Jacobs Engine Brake noise. We propose the
following additional wording be added to Section 202.13:
a) No person shall operate a motor vehicle which is powered by an
•engine with engine speed governor which generates more noise than
88 DB(A) measured at 50 feet from vehicle centerline when that
engine is accelerated from idle with wide open throttle to govern
speed, remaining at govern speed for three to five seconds _the_n
decelerating from govern speed to idle with throttle closgci with
the vehicle stationary, transmission in neutral, and clutch engaged,
Section 202.11 regulates the noise generated by the Jacobs Engine Brake
during deceleration of the vehicle. Jacobs feels that omitting the
stationary deceleration test was an oversight or inaccurate assumption that
stationary deceleration would always produce less noise than the stationary
run up condition, but this is not always the case. Jacobs has data available
B-l
-------
/he (Jacob- OtjcMiu/acluivny
Page 2 of 2 pages
July 25,
illustrating that it is possible in the stationary test to have a 10,DBA
increase in the engine deceleration portion of the test with the Jacobs
Engine Brake actuated over the engine acceleration portion of the test,,
This is possible because some particular types of mufflers attenuate engine
acceleration or power noise but do nothing to attenuate Jacobs Brake noise.
The above offenders could be detected in a highway operation (Section 202.11)
but not in the stationary test (Section 202.13) as proposed. It is also our
understanding that the proposed S.A.E. procedure of the stationary test
includes a deceleration phase»
Jacobs believes, in the long ranges it is in our best interest to have
mufflers that properly attenuate compression brake noise, installed on all
vehicles that are equipped with Jake Brakes.
We would like to plan. 2 trip to Washington in the near future to meet with
you and/or members of your staff at your earliest convenience to discuss
the possibility of the proposed regulation change. I will be contacting
you in the near future by phone to set up a meeting.
R.Bo Price
Project Engineer
RBP; eg
cci Mr? Henry Thomas, Acting Director of Standards
fi and Regulations Division
Mr.__David Weiner, Office of Noise Abatement and
Control
W.H. Morse
A.P. Papanek
GeEi Jerome
D.B. Sandstrom
F. Stawski
B-2
-------
APPENDIX C
TRANSCRIPTION OF VOICE ON REGION VIII
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DEMONSTRATION TAPE RECORDING OF ENGINE BRAKE
OPERATIONAL NOISE FROM AN UNMUFFLED KENWORTH TRUCK
-------
APPENDIX C
TRANSCRIPTION OF VOICE ON REGION VII
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DEMONSTRATION TAPE RECORDING OF ENGINE BRAKE
OPERATIONAL NOISE FROM AN UNMUFFLED KENWORTH TRUCK*
Recorded: Boulder, Colorado
April 13, 1977
Full Track Recording
VOICE #1 (William Bryant; Region VIII USEPA)
"This recording features the noise of an engine brake on a heavy truck.
All of the original tape except the final segment was recorded on two
tracks with a Nagra Model IV-SJ tape recorder with channel 2 attenuated
20 dB more than channel 1. The final segment was recorded full track-
on a Nagra Model IV-D tape recorder. For level calibration, a 1000
Hertz signal will follow at 92.8 dB on track 1 and 112.8 dB on track 2
Recalibration will be required before the final segment of the tape."
CALIBRATION SIGNAL*
VOICE #2:
"Two vehicles and three instruments used in this demonstration of heavy
truck engine brake noise were made available by the Environmental Pro-
tection Office of the city of Boulder. Colorado. The demonstration was
observed by representatives of the United States Environmental Protection
Agency, Office of Noise Abatement and Control, and the resulting sound
levels were recorded by Region VIII personnel of the United States En-
vironmental Protection Agency."
"Instrumentation included 3 GenRad llocle! 1933 sound analysis systems
using 1 inch electret microphones. One Model 1933, with flat weighting,
provided a signal to a Nagra Model IV-SJ analog tape recorder with flat
weighting. A second Model 1933 with A-weightirig provided input to a
Hewlett-Packard Model 7155A strip chart recorder; and a third, with
flat weighting, was used in the cab of the principal truck as input
* Level recordings for unweighted (linear), C-weighted, and A-weighted
sound levels of the data presented in Noise Events 1 through 5 are
presented at the end of the transcription.
c-i
-------
VOICE #2 (Continued)
for a Nagra Model IV-D analog tape recorder. Excepting the verbal com-
ments and, as will be noted later, the in-cab recording, all levels on
the original tapes are believed to be in true relation to the calibra-
tion signal within +_ 1 or perhaps 2 dB."
"There is some non-linearity at the peak sound levels. For the road-
side recordings, the microphones were 4 feet above the ground on tripods
and 50 feet from the downhill lane of the access road to the National
Center for Atmospheric Research at Boulder, Colorado. The microphones
were 62 feet from the uphill lane. This added distance of 12 feet
should account for nearly 2 dB of attenuation from uphill traffic rela-
tive to downhill traffic noise. The road surface was dry asphalt and
its grade was a nearly constant 9%, or about 5 ."
"The microphone surroundings, within acoustic range, were relatively
flat and unobstructed. The ground surface was thinly covered with na-
tive grasses and small rocks. Temperatures ranged from 7 to 15 C.
Wind varied from 5 to 11 kilometers per hour. Most of the recorded
sounds of concern were generated by an 18,500 pound Kenworth truck
pulling a 9,500 pound flat-bed semi-trailer. It was powered by a 262
cubic inch Cummins diesel engine, governed at 2150 rpm, and it had a
15-speed transmission system. The truck was equipped with an engine
brake capable, at the driver's option, of braking with 2, 4 or 6 cyl-
inders. The exhaust was a single four and one-half inch straight pipe,
8 feet high on the right hand side of the vehicle, with a turbo-charger
chamber and no muffler."
"Another truck, referred to later as a water truck, was a 37,000 pound
International Trans-Star with a 262 cubic inch Cummins diesel engine
governed at 2100 rpm. It had a 15-speed transmission system, no en-
gine brake, and dual three inch exhaust pipes with Donaldson mufflers.
Downhill speeds in this exercise were approximately 35 miles per hour.
The first example of truck noise was recorded as the Kenworth acceler-
ated uphill, past the microphone at 20 miles per hour, full throttle,
and 2000 rpm. Transmission was in second gear and over. The sequence
C-2
-------
VOICE #2 (Continued)
of events is an automobile going uphill, peaking a"t 63 dBA; the water-
truck going downhill peaking at 79 dBA, and then the Kenworth going
uphill, peaking at 83 dBA. (Ed. Comments - There appears to be a ve-
hicle pass-by and distant truck braking sounds during the last 16 to
20 seconds of event. These sound levels are in the range of 55 to 65
dBA.)
NOISE EVENT 1
VOICE #3:
"Next we hear the Kenworth going downhill at 1900 rpm without engine
brake. The Kenworth peaking at 79 dBA is followed by a Scout-type
vehicle sputtering at about 63 dBA. A few seconds later we hear the
engine brake applied one third of a mile away. That's 59 dBA at the
microphone."
NOISE EVENT 2
VOICE #4:
"The next downhill passage, in third gear direct at 2150 rpm, 4 cyl-
inders of the engine brake were engaged abeam of the microphone., peak-
ing at 97 dBA."
NOISE EVENT 3
VOICE #5:
"Here comes the Kenworth using the engine brake all the way down the
hill. 97 dBA at the passage."
C-3
-------
NOISE EVENT 4
VOICE #6:
"During the following passage3 the Kenworth applies 4 cylinders of
braking before arrival and, abeam of the microphone, shifts to 6 cyl-
inders peaking at 97 dBA."
NOISE EVENT 5
VOICE #7:
"Now that we have heard something of the impact of an improperly muf-
fled engine on the environment, let's have a brief example of the truck
driver's workplace while braking with 4 cylinders en route downhill.
First we must recalibrate the sound level. A 1000 Hertz signal is re-
corded at 112.8 dB."
CALIBRATION SIGNAL
VOICE #8:
"During the following ride in the Kenworth's cab, the right side window
is opened and closed twice, but you'll know when. The level is 95 dBA
with window closed and 107 dBA with window open. At the end of the run
the driver shifts from 4 cylinder braking to 6."
NOISE EVENT 6
VOICE #9:
"In conclusion, the following remarks are offered by Jim Adams, Environ-
mental Protection Officer of the city of Boulder, Colorado."
Adams:
"The dynamic engine brake is an absolute necessity for safe mountain
C-4
-------
VOICE #9 - Adams (Continued)
operation of heavy trucks. The demonstration tape you have just heard
is without a muffler and with a turbo-charger chamber. The aural com-
parison of the decelerating engine noise alone, without a muffler and
then the addition of the dynamic engine brake makes it quite obvious
the extreme impact of the device on the noise level generated by the
truck."
"In conclusion, the dynamic engine braking device must be properly
muffled."
-------
-'= LINEAR
90 r^r* -
5 80
_t
I 70
60
50
ff
100
C WEIGHTING
90 ' ~—=Z
5 80
_j
o
I 70
oo
60
50
100
IT A WEIGHTING
90
UJ
80
70
60
50
CALIBRATION SIGNAL
-------
o
I
NOISE EVENT 1
0 5 10
I i i i i I i t i , I
TIME, SEC.-*-
100
UJ
_l
a
I.H. TRANSTAR
DOWN HILL
TOO
90
80
70
60
_n AUTO
50 UP HILL
A WEIGHTING
-------
NOISE EVENT 2
0 5 10
100
90
80
70
60
50
TIME, SEC.
— LINEAR
KENWORTH
DOWN HILL/NO BRAKING'
"SCOUT"
= DOWN HILL
—r-^r^ziiTrr-— ENGINE BRAKING APPLIED
— 1/3 MILE FROM MIC.
100 -—
90
80
70
60
50
TOO
90
C WEIGHTING
DOWN HILL/NO BRAKING
ENGINE BRAKING APPLIED
1/3 MILE FROM MIC.
A WEIGHTING
ENGINE BRAKING APPLIED
1/3 MILE FROM MIC.
KENWORTH
DOWN HILL/NO BRAKING
-------
60
50
LINEAR
NOISE EVENT 3
0 5 10
t i ii i i i i
TIME, SEC.-
KENWORTH DOWN HILL
-- 4 CYL. BRAKING APPLIED
— "ABEAM" OF MIC.
C WEIGHTING
60 r=
50 =
KENWORTH DOWN HILL
4 CYL. BRAKING APPLIED
"ABEAM" OF MIC.
A WEIGHTING
KENWORTH DOWN HILL
CYL. BRAKING APPLIED
"ABEAM" OF MIC.
C-9
-------
WISE EVENT 4
0 5 10
l_ I I I l..l_l_J-J-jU
TIHES SEC.-~*>»
a
z
I
80
70
60
50
KENWORTH DOWN HILL
-CONTINUOUS ENGINE BRAKING
100
C WEIGHTING "JT ————— - - ----- -_
70
60
50
KENWORTH DOWN HILL
^CONTINUOUS ENGINE BRAKING
TOO
A WEIGHTING
8
KENWORTH DOWN HILL
, CONTINUOUS ENGINE BRAKINi
60 -rr
50
C-10
-------
UJ
>
UJ
TOO
90
80
70
60
50
NOISE EVENT S
0 5 10
I i i i i I i i i i I
TIME, SEC.—#-
LINEAR
4 CYL. BRAKING APPROACHING MIC.
6 CYL. BRAKING "ABEAM" OF MIC.
100
O
I
~ C WEIGHTING _
90
80
70
60
50
4 CYL. BRAKING APPROACHING MIC.
6 CYL. BRAKING "ABEAM" OF MIC.
100
90
80
70
60
50
A WEIGHTING z:..--.v__-_ rjrr.—~^~-:
KENWORTH DOWN HILL"
-—^4 CYL. BRAKING APPROACHING MIC.
_-—'6..CYL. BRAKING "ABEAM" OF MIC. , —
------- |