EPA-5 50/9-76-008
BACKGROUND DOCUMENT
FOR
MEDIUM AND HEAVY TRUCK
NOISE EMISSION REGULATIONS
MARCH 1976
U.S. Environmental Protection Agency
Washington, D.C. 20460
-------
TECHNICAL REPORT DATA
(Picase read In .sLructions on the reverse before completing)
2.
REC1PIENT S ACCESSIOFNO.
tfor Medium and Heavy
RegulationS
5. REPORT DATE
March 1976
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
Agency, Office
and Control
ADDRESS
Protection Agency
Abatement and Control
10. PROGRAM ELEMENT NO.
if AA Y/GRANTNO .
.
ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Final
16. u i
On March 31, 1976, the Environmental Protection Agency issued a
regulation governing noise emissions front medium and heavy trucks.
That regulation was issued under Section 6 of the Noise Control Act
of 1972.
This document presents and discusses the background data used by
the Agency in setting the standards contained in the regulation. Pre-
sented here is a comprehensive exposition on the most up—to—date
available information on the environmental, technological, and economic
aspects of medium and heavy truck noise.
17. KEY WORDS AND DOCUMENT ANALYSiS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
C. COSATI Field/Group
[ conomic cost, effects; Federal
regulations; heavy trucks; popu—
lation exposure; medium trucks;
noise emission; standards
—
18. DISTRIBUTION STATEMENT
.
Unlimitcd
19. SECURITY CLASS (ThLvReport)
Unclassified
20. SECURITY CLASS (This page)
21. NO. OF PAGES
422
22. PRICE
EPA Form 2220-1 (9.73)
-------
EPA-5 50/9-76-008
BACKGROUND DOCUMENT
FOR
MEDIUM AND HEAVY TRUCK
NOISE EMISSION REGULATIONS
MARCH 1976
U.S. Environmental Protection Agency
Washington, D.C. 20460
This document has been approved for general
availability. It does not constitute a standard,
specification or regulation.
-------
PREFACE
On March 31, 1976, the Environmental Protection Agency issued a regulation
governing noise emissions from medium and heavy trucks. That regulation was issued under
Section 6 of the Noise Control Act of 1972.
This document presents and discusses the background data used by the Agency in
setting the standards contained in the regulation. Presented here is a comprehensive
exposition on the most up-to-date available information on the environmental, techno-
logical, and economic aspects of medium and heavy truck noise.
1
-------
TABLE OF CONTENTS
Page
INTRODUCTION
STATUTORY BASIS FOR ACTION
OUTLINE AND SUMMARY OF BACKGROUND DOCUMENT.
REFERENCES
Section 2 THE TRUCK INDUSTRY
GENERAL DESCRIPTION OF MEDIUM AND HEAVY TRUCKS.
Section 4 PUBLIC HEALTH AND WELFARE BENEFITS FROM
REGULATIONS
INTRODUCTION
Measures of Benefits to Public Health and Welfare
Regulatory Options
Outline of Section 4
REDUCTION IN THE IMPACT FROM TRAFFIC NOISE.
Description of .Traffic Noise Impact
Urban Street Traffic Noise
Vehicle Noise Levels in Urban Street Traffic
Reduction of Average Urban Street Traffic Noise Levels.
Reduction in Noise Impact from Urban Street Traffic.
Freeway Traffic Noise
Vehicle Noise Levels in Freeway Traffic
Reduction of Average Freeway Traffic Noise Levels
Reduction in Noise Impact from Freeway Traffic
Total Noise Impact from Urban Street and
Freeway Traffic
ACTIVITY INTERFERENCE BY INDIVIDUAL (SINGLE-
EVENT) TRUCK PASSBY NOISE
Activity Interference Levels
Maximum Activity-Interference Distances
Section 1
1 —1
1—1
1-2
1-5
2-1
2-2
DISTRIBUTION OF TRUCKS BY CATEGORIES.
TRUCK MANUFACTURERS
MOTOR TRUCK USERS
REFERENCES
Section 3 BASELINE NEW TRUCK NOISE LEVELS
STATE AND LOCAL REGULATIONS
REFERENCES
2-3
2-9
2-11
2-12
3-1
3-4
3-8
4-1
• 4-1
- . 4-1
• . 4-2
• 4-2
• . 4-3
• . 4-5
• 4-6
• . 4-6
4-12
4-13
4-17
4-18
4-21
4-21
4-24
4-27
4-28
4-29
111
-------
TABLE OF CONTENTS (Continued)
Page
REFERENCES
Engine.
Fan .
Intake
• • 4-33
• . • 4-34
• . • 4-35
• • • 4-36
4-41
4-42
• . 4-43
5-1
5-1
5-I
5-3
5-6
5 -7
5 - 8
5-9
5-10
5-il
5-i l
5-12
5-13
5-14
5-14
5-14
5-14
5-15
5-15
5-Is
5-15
5-16
5-16
5-16
6-i
• . . 6-i
IN-CAB NOISE
Existing In-Cab Noise Levels
In-Cab Noise for Quieted Trucks
SAE J366b Exterior and Interior Levels .
Interior SAE J366b Levels and Levels for Normal
Openting Conditions
In-Cab Noise Levels for Regulated Trucks
Section 5 TECHNOLOGY .
COMPONENT NOISE CONTROL
Exhaust
TOTAL TRUCK NOISE CONTROL
83 dBA Regulatory Level .
80 CIBA Regulatory Level •
78 CIBA Regulatory Level .
75 dBA Regulatory Level .
BEST AVAILABLE TECHNOLOGY
Engineering Information
Engine Noise Treatment
Fan Noise Treatment
Exhaust Noise Treatment .
Treatment of Other Sources of Noise
Summary
Demonstration (The 72 cIBA Truck)
Applièability of Quieting Techniques
Mass Production
Time Allowed for Design Cycle
Conclusions
REFERENCES
Section 6 COSTS OF COMPLIANCE
INCREASES IN TRUCK PRICES
iv
-------
TABLE OF CONTENTS (Continued)
NOISE CONTROL TREATMENTS AND COSTS
Cooling System
Exhaust System
Engine and Cab
Air Intake
Other Sources
AVERAGE TRUCK PRICE iNCREASES
Projections of Truck Prices with Improved Technology
and Reduction in Production Costs
Truck Price Increases with Fan-Off Compliance
Testing
CHANGES IN OPERATING COSTS
Costs of Changes in Rates of Fuel Consumption
Effect of Noise Treatment on Rates of Fuel
Consumption
Changes in Fuel Costs
CHANGES IN COSTS FOR MAiNTENANCE
Exhaust System Treatments
Engine and Cab Treatments
Average Annual Operating Costs
Total Increase in Truck User Costs
REFERENCES
Section 7 ECONOMIC IMPACT’
PRICE AND QUANTITY IMPACTS
Initial Costs and Demand Reductions
83-dBA Regulatory Level
80-dBA Regulatory Level
78-dBA Regulatory Level
75-dBA Regulatory Level
Summary
Operating Costs
Total Costs .
IMPACT ON TRUCK AND ENGINE MANUFACTURERS
IMPACT UPON TRUCK-FREIGHT COMPANIES . . . *
Current Status of Trucking Industry
Intermodal Competition
Outlook for 1976
Financial Status of ICC Regulated Carriers
Page
• . . 6-2
• . . 6-2
6 -6
6-7
• . . 6-9
• . . 6-10
• . . 6-10
• . . 6-12
• . . 6-13
6-14
• . . 6-14
6-21
6-23
6-25
6-25
6-25
6-26
6-28
6-32
7-1
7-1
7-1
7-1
7-3
7-4
7-4
7-5
7-6
7-6
7-10
• . 7-17
7-17
7-19
• . 7-26
7-26
V
-------
TABLE OF CONTENTS (Continued)
Page
7-8
7-8
• . . • 7-29
• • .. 7 -33
• • . . 7-33
• • . 7-33
Financial Impact on the Trucking Industry .
Assumptions Used in Assessing Impact
Rate Increases for ICC Regulated Carriers
Example for ICC Regulated Carriers
Possible Rate Increases for ICC Regulated Carriers
Impact on Particular Segments of the Carrier Industry
Impact on U ers of Transportation Services
Impact on Truck Purchases
REFERENCES
7-37
7 -37
741
Section 8 ENFORCEMENT
GENERAL
PRODUCT VERIFICATiON
ASSEMBLY PROCESS TESTING
ENFORCEMENT ACTION.
REMEDIES
LABELING
IN-USE COMPLIANCE .
Section 9 ENVIRONMENTAL EFFECTS
8-i
8-i
8 -1
8 -2
8-2
8-3
8-3
8-3
9-1
9-1
9- 1
9-1
9-4
9- 5
AIR
WATER AND SOLID WASTE
ENERGY AND NATURAL RESOURCE CONSUMPTION
LAND-USE
REFERENCES
Appendix A-i INTRODUCTION TO DOCKET ANALYSIS
Appendix A-2 SUMMARY OF COMMENTS
TRUCK MANUFACTURERS.
Chrysler Corporation
Crane Carrier Company .
Ford Motor Company
Freightilner Corporation .
General Motors
International Harvester Company
Mack Trucks, Inc.
Oshkosh Truck Corporation
A-I-i
A-2-i
A-2-1
A-2-l
A-2-2
• . A-2-2
A-2-5
A-2 -6
A-2-ll
A-2- 13
A-2-14
v i
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TABLE OF CONTENTS (Continued)
Page
INDUSTRY .
Cummins Engine Company, Inc.
Donaldson Company, Inc
B.F.Goodrich
Koeliring Company
Rexnord
Schwitzer Engineering Components
Walker Manufacturing
Horton Manufacturing Company, Inc..
Bendix Heavy Vehicle Systems Group
Buckeye Equipment Company
TRUCK USERS
American Trucking Associations, Inc.
Construction Machinery Company
Gifford-Hill Company
W.S. Hatch Company
Overdrive Magazine
PROD (Professional Drivers)
Regular Common Carrier Conference
PRIVATE CITIZENS
ILL. Atkins
Lawrence Auerbach
Citizens Against Noise
Friends of the Earth and Sierra Club
Alan Parker
George Wilson
A-2-15
A-2- 16
A -2-l7
A-2-17
A-2-18
A-2-19
A-2-19
A-2- 19
A-2- 19
A-2-20
A-2-2 0
A-2-20
A-2-21
A-2-2 1
A-2-2 1
A-2-22
A-2-23
A-2-23
A-2-23
A -2-24
A-2-24
A-2-24
A-2-24
A-2-25
A-2-25
A-2-25
A-2-25
A-2-25
A-2-26
A-2-26
A-2-26
A-2-26
A-2-27
A-2-29
A-2-30
A-2-3 0
Paccar, Inc
White Motor Corporation
MANUFACTURERS RELATED TO THE TRUCK
GOVERNMENTAL AGENCIES (STATE, LOCAL AND
FEDERAL AGENCIES)
California Highway Patrol
City of Chicago, Department of Environmental Control
Delaware
Department of Transportation
City of Des Plaines, Illinois
Council on Wage and Price Stability
District of Columbia
vii
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TABLE OF CONTENTS (Continued)
Page
Federal Highway Administration, Ohio
State of Illinois, Environmental Protection Agency
Indiana
Louisiana
Los Angeles County
Mississippi
Minnesota
New Mexico
New York State
National Organization to Insure Sound Controlled
Environment (NOISE)
San Diego County
San Francisco, Noise Control Task Force
Texas
Virginia
TRADE AND MANUFACTURING ORGANIZATIONS
American Road Builders Association
Associated General Contractors of Colorado . .
Automotive Exhaust Systems Manufacturers Committee
Chamber of Commerce
Construction Industry Manufacturers’ Association
Motor Vehicle Manufacturers’ Association . .
National Solid Wastes Management Association
Recreation Vehicle Industry Association
Appendix A-3 BENEFITS TO PUBLIC HEALTH AND WELFARE
BENEFITS TO PUBLIC HEALTH
Hearing Damage
Safety
BENEFITS TO PUBLIC WELFARE
Need for Additional Study
Accuracy of EPA Predictions
Needed Benefits
Benefits from More Lenient Regulations .
IMPACT OF OTHER TRAFFIC NOISE SOURCES
Mobile Homes
Truck Tires
Buses
Environmental Impact Statement
A-2-30
• . • A-2-31
• . . A-2-31
A-2-31
A-2-31
A-2-31
• . . A-2-32
A-2-32
A-2-32
A-2-33
A-2-33
A-2-33
A-2-33
• • . A-2-34
• • . A-2-34
A-2-34
A-2-34
A-2-35
A-2-35
A-2-35
A-2-36
A-2-36
A-2-36
A-3-l
A-3-1
A-3-l
A-3-2
A-3-2
A-3-2
• . . A-3-4
A-3-11
A-3-12
A-3-21
• A-3-21
A-3-21
A-3-23
A-3-24
vi ”
-------
TABLE OF CONTENTS (Continued)
Page
Fan Treatment
REQUIREMENTS FOR TRUCK NOISE CONTROL.
Cooling System
Exhaust System
Engine
Air Intake System
Other Sources
DESiGN TOLERANCE
Manufacturing and Test Variables
Degradation of the Effectiveness of Treatment
AVAILABILITY OF THE TECHNOLOGY REQUIRED
FOR COMPLIANCE
General Availability of Technology
Freightliner DOT Quiet Truck
Performance Compromises
Tire Noise Reduction
OTHER ISSUES
Second Stage Manufacturers
Buses .
Losses in Revenue
Changes in Rates of Fuel Consumption
Fuel Savings for Fan Clutches .
Changes in Maintenance Costs . *
COSTS OF COMPLIANCE TESTING.
A-4-l
A-4-l
A-4-1
A-4-l
A4-2
A4-2
A-4-2
A-4-3
44-3
44-4
A44
A-4-5
A-4-7
A-4-lO
A-4-lO
• . . . A-4-1l
• . . • A-4-ll
• • . . A-4-12
Appendix A4 TECHNOLOGY
ACCURACY OF COMPONENT SOURCE LEVELS
Fan Noise
HRBDG Levels
Engine Noise
EFFECTIVENESS OF NO 1SE CONTROL TREATMENTS
Engine Quiet Kits
Radiator Shutters
A-4-13
A-4- 13
A-4- 17
A-4-20
A4-22
A-4-23
A4-23
A-4-23
Appendix A-S COSTS OF COMPLIANCE
INCREASES ON TRUCK PRICES
Estimates of Truck Price Increases
Future Price In creases
CHANGES IN OPERATING COSTS
A-S - I
A-S-i
A-S-i
A-S-8
A-S-9
A-5-9
A-S - IC
A-5-ll
A-5-12
A-5-13
ix
-------
TABLE OF CONTENTS (Continued)
Page
Regulations on the Noise Source
Treatmet t of Noise Path
Control of Truck Use
REGULATORY STRATEGY
NEED FOR STRICTER REGULATIONS
A-6-1
A-6-l
A-6-7
A-6-7
A-6-8
A-6-8
A-6-9
A-6-1O
A-6-1l
A-7-l
A-7-l
A-7-2
A-7-3
A-7-4
A-7-4
A-7-5
A-7-6
Profits
Small and Independent Truckers Position
IMPACT ON TRUCK MANUFACTURERS
IMPACT ON STATE HIGHWAY NOISE TREATMENT
PROGRAMS
IMPACT ON NATIONAL ECONOMY
Inflation
Inflation Impact Statement
Total Costs of EPA Proposed Regulations
Cumulative Costs of All Federal Regulations
Research and Development Costs
SECOND-STAGE MANUFACTURERS
Motor Homes
Specialty Trucks
OTHER ISSUES
Impact on Local Areas
Impact on Postponing Regulatory Levels
A-7-6
A-7 -7
A-7-7
A-7-8
A-7-8
A-7-1I
A-7- 12
A-7-12
A-7-12
‘. A-7-13
A-743
A-7-13
A-7-14
A 8-l
A-8-I
A-8-I
A-8-2
A-8-3
Appendix A-6 COSTS VERSUS BENEFITS
JUSTIFICATION OF COSTS AND BENEFITS
OTHER REGULATORY APPROACHES .
Stricter Enforcement of Existing Regulations
Appendix A-7 ECONOMIC IMPACT
CURRENT ECONOMIC SLUMP
SUPPLY OF QUIET ENGINES
SHIFTS IN BUYING HABITS
IMPACT UPON TRUCKING COMPANIES.
Appendix A-8 TEST PROCEDURE
Introduction
Critique of Basic Test Procedure . .
Need for Stationary or Other Simpler Test
Test Site Specifications and Certification
x
-------
TABLE OF CONTENTS (Continuedi
Page
Corrections to Standard Conditions
Engine Operating Temperature
Operation of Thermostatic Fans and Radiator Shutters
Deceleration Test
Instrumentation
Repeat Measurements, Tolerances, and Round-Off
Meter Responses
CLASSIFICATION
Different Regulatory Levels for Different GVWR
Categories
Vehicle Under 10,000 LBS GVWR
Motor Homes
Special Purpose Equipment
Buses
A-8-3
A-8-4
A-8-4
A-8-5
A-8-5
A-8-6
A-8-6
A-9-l
A-9-l
A-9-l
A-9-2
A-9-2
A-9-2
Appendix B
REFERENCES FOR APPENDIX A
PREDICTIONS OF TRAFFIC POPULATION MIXES
Traffic Population Predictions for Trucks
Traffic Population Predictions for Automobiles
Traffic Population Predictions for Motorcycles
Traffic Population Predictions for Buses .
Predictions of Traffic Mixes
A- f l -)
B-I
B-i
B- s
B-6
8-6
8-6
REFERENCES FOR APPENDIX B
B-li
Appendix A-9
Appendix A- b
Appendix A-I I
A-l0-1
ENFORCEMENT
MISCELLANEOUS
Effective Dates . ..
Highway Noise Treatment by States
Representation of Trucking Industry
Availability of Equipment and Acoustical Engineers
Labeling
High Speed Standard
A-li-I
• . . A-li-i
- . A-Il-I
#1 1-2
A-lI-2
* * • * A-11-3
A-l1-3
xi
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TABLE OF CONTENTS (Continued)
Page
Appendix C THE ELASTICITY OF DEMAND FOR MEDIUM AND
HEAVY TRUCKS C-i
SUPPLY ELASTICITY C-2
REFERENCES FOR APPENDIX C C-3
Appendix D COSTS OF COMPLIANCE IN 1975 DOLLARS D-i
REFERENCES FOR APPENDIX D D-3
Appendix E A COMPUTER MODEL TO DETERMINE ECONOMIC COST
OF NOISE REGULATION E-i
Appendix F NET OPERATING INCOME DEFINED F-i
REFERENCES FOR APPENDIX F F-2
Appendix G METHOD FOR COMPUTING IMPACT ON A SPECIFIC
SECTOR OF THE TRUCKING INDUSTRY G-I
Summary G-3
REFERENCES FOR APPENDIX G G-6
Appendix H COST ANALYSIS OF PRODUCTION VERIFICATION AND
SELECTIVE ENFORCEMENT AUDITING FOR THE
MEDIUM AND HEAVY DUTY TRUCK INDUSTRY H-I
Appendix I SUMMARY OF FAN CLUTCH FIELD TESTS I-i
xii
-------
LIST OF ILLUSTRATIONS
Figure Tide Page
2-1 Truck with Short Conventional Cab 2-4
2-2 Truck with Long Conventional Cab 2-5
2-3 Truck with Low Deck Cab-Over-Engine . . . . 2-6
2-4 Truck with High Deck Cab-Over-Engine 2-7
3- 1 Test Site for SAE Standard J366b 3-2
3-2 Histogram of New Diesel Truck Noise Levels 3-3
3-3 Noise Level Histograms of Gasoline-Powered Trucks 3-4
3-4 Cumulative Distribution of New Diesel Truck Noise Levels 3-5
3-5 Noise Level Histograms of Gasoline-Powered Medium and Heavy
New Trucks 3-6
4-I Estimated Number of People in Residential Areas Currently
Subjected to Traffic Noise Above L j = 55 dB 44
4-2 Noise Environment Adjacent to Urban Freeway . 4-24
4 -3 Percent Reduction in Total Equivalent Number of People Impacted
by Urban Traffic Noise (Urban Street or Freeway) — Without
Reductions in Noise from Noritruck Vehicles 4-31
44 Percent Reduction in Total Equivalent Number of People Impacted
by Urban Traffic Noise (Urban Street or Freeway) — With a 4 dBA
Reduction in Noise from Nontruck Vehicles 4-32
4-5 Urban Population vs Outdoor Traffic Noise Level in 1983 4-33
4-6 Urban Population vs Outdoor Traffic Noise Level in 1985 4-34
4 -7 Urban Population vs Outdoor Traffic Noise Level in 1990 4-35
4-8 Urban Population vs Outdoor Traffic Noise Level in 2000 4-36
4-9 Maximum Activity-Interference Distances for Normal Conversion
Indoors With Windows Closed 4-38
4-10 Maximum Activity-Interference Distances for Thought Process
Indoors With Windows Closed 4-38
4-1 1 Maximum Activity-Interference Distances for Thought Process
Indoors With Windows Open and Normal Conversation Outdoors . 4-39
4-12 Maximum Activity-Interference Distances for Sleeping Indoors
With Windows Closed 439
4-13 Maximum Activity-Interference Distances for Sleeping Indoors
With Windows Open 440
4-14 Maximum Activity-Interference Distances for Thought Process
Outdoors 440
4-15 Exterior and Interior Noise Levels Observed Under SAE J366b
Test Conditions 4-41
x l i i
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LIST OF ILLUSTRATIONS (Continued)
Figure
5-1
5-2
7-1
7-2
7-3
A- il
A-3.2
A-3.3
A-3.4
A-3.5
A-3.6
A-3.7
A-3.8
A-3.9
A-3.10
A-S. !
1—1
1-2
Page
• . . 5-2
• . . 5- 5
• • . 7-17
• • • 7-18
7-23
• . • A-3-6
A-3-7
A-3-8
• . . A-3-11
Domestic Freight Transportation Market, 1970
Truck Designation by GVWR (Pounds)
Total Truck Population, 1972
A-3-13
A-3-14
A-3-l5
A-3-16
A-5-4
1-4
1-4
Title
Engine Noise as a Function of Horsepower
Truck Fan Noise Levels as a Function of Engine Horsepower
Intercity Truck Tonnage
Relationship Between Trucking and GNF
Size of 1CC-Regulated General Freight Carriers: X 10,597.28
Comparison of EPA, GM, and DOT Estimates of Average Urban
Street Traffic Noise Reductions Due to New Truck Regulations
Comparison of EPA, GM, and DOT Estimates of Average Freeway
Traffic Noise Reductions Due to New Truck Regulations
Comparison of EPA and GM Predictions of Maximum Activity-
interference Distances for Thought Process indoors
Comparison of EPA and GM Predictions of Maximum Activity-
Interference Distances for Sleeping indoors
Comparison of EPA and GM Predictions of Maximum Activity-
Interference Distances for Normal Conversation Outdoors
Comparison of EPA and GM Predictions of Maximum Activity-
Interference Distances for Thought Process Outdoors
Predictions of Average Traffic Noise Reductions for 100 Percent and
90 Percent Compliance to the EPA Proposed Regulations
Predictions of eq for 100 Percent and 90 Percent Compliance to the
EPA Proposed Regulations
Predictions of Average Traffic Noise Reductions with Regulations on
New Medium and Heavy Trucks
Predictions of eq with Regulations on New Medium and Heavy
Trucks
Estimates of Truck Price increases
Operating Time for On-Off Fan Clutch
Operating Time for Modulated Fan Clutch
LIST OF TABLES
Title
A-3-9
A-3-l0
Table
2-1
2-2
2-3
Page
2- 1
2-2
2-3
xiv
-------
LIST OF TABLES (Continued)
Table Title Page
2-4 Percent of Diesel Trucks to Total Trucks by Categories for
Selected Years, 1966-1 972 2-8
2-5 New Truck Production, 1972 2-8
2-6 Number of New Trucks by Manufacturer, 1972 2-9
2-7 Financial Characteristics of Truck Manufacturer’s Parent Company,
1972 ($ Millions) 2-10
2-8 Distribution of Trucks by Major Users, 1972 2-1 1
3-1 State and Local Noise Regulations on New Medium and Heavy Trucks . 3-7
4-1 Regulatory Options for Medium and Heavy Trucks 4.3
4-2 Assumed Passby Noise Levels for Vehicles in Urban Street Traffic . . . 4-7
4-3 Reduction in Urban Street Traffic Noise — Without Reductions in
Noise from Automobiles, Motorcycles and Buses 4-13
4-4 Reduction in Urban Street Traffic Noise — With 4 dBA Reduction
in Noise from Automobiles, Motorcycles and Buses 4-14
4-5 Distribution of Urban Population at or Greater Than a Specified
Ldn 4-17
4-6 Calculation of Equivalent Number of People Impacted by Urban
Street Traffic Noise 4-18
4-7 Equivalent Number of People Impacted (Peg) by Urban Street
Traffic Noise — Without Reduction in Noise from Automobiles,
Motorcycles, and Buses 4-19
4-8 Equivalent Number of People Impacted (Peq) by Urban Street
Traffic Noise — With a 4 dBA Reduction in Noise from Automobiles,
Motorcycles, and Buses 4-20
4-9 Assumed Passby Noise Levels (dBA) for Vehicle in Freeway Traffic . 4-20
4-10 Reduction in Freeway Traffic Noise — Without Reductions in
Noise from Automobiles 4-22
4-I I Reduction in Freeway Traffic Noixe — With a 4 dBA Reduction in
Noise from Automobiles 4-23
4-1 2 Calculation of Equivalent Number of People (In Millions) Impacted
by Freeway Noise 4-25
4-13 Equivalent Number of People Impacted (Peq) by Freeway Traffic
Noise — Without Reduction in Noise from Automobiles . 4-25
4-14 Equivalent Number of People Impacted (Peq) by Freeway Traffic
Noise — With a 4 dBA Reduction in Noise from Automobiles . . . 4-26
4-1 5 Total Equivalent Number of People Impacted (Peq) by Urban
Traffic Noise (Urban Street or Freeway) — Without
Reductions in Noise from Nontruck Vehicles 4-27
xv
-------
LIST OF TABLES (Continued)
4-19
4-20
5-1
5-2
5-3
5-4
5-5
5-6
6-1
6-2
6-3
6-4
6-5
6-6
6-7
6-8
6-9
6-10
6-1 1
6-12
6-13
• 4-30
• • 4-37
• . 4-37
• • 5-7
• • 5-9
• • 5-10
• 5-11
• . 5-12
• . 5-13
• . 6-3
• . 6-4
6-9
6-11
• . 6-13
6-13
• . 6-14
• • 6-16
• . 6-20
• . 6-21
• . 6-22
• • 6-23
• • 6-24
Table
4-16
4-17
4-18
Page
• . 4-28
• . 4-29
Title
Total Equivalent Number of People Impacted (Peq) by Urban
Traffic Noise (Urban Street or Freeway) — With a 4 dBA Reduction
in Noise from Nontruck Vehicles
Percent Reduction in Total Equivalent Number of People Impacted
by Urban Traffic Noise (Urban Street or Freeway) — Without
Reduction in Noise from Nontruck Vehicles
Percent Reduction in Total Equivalent Number of People Impacted
by Urban Traffic Noise (Urban Street or Freeway) — With a 4 dBA
Reduction in Noise from Nontruck Vehicles
Noise Levels from Truck Passbys That Interfere with Activities
Percentile Noise Levels for Individual Truck Passbys
Exhaust Noise Levels for Present Exhaust Systems
Component Source Levels for an 83 dBA Regulatory Level
Component Source Levels for an 80 dBA Regulatory Level
Component Source Levels for a 78 dBA Regulatory Level .
Component Source Levels for a 75 dBA Regulatory Level •
Major Truck Noise Components
Estimated Increase in Prices for Medium and Heavy Trucks which
Comply with Not-to-Exceed Noise Emission Regulations •
Key to Noise Treatments and Costs for Table 6-1
Estimation of Price Increase for Cab Treatment d2 on Diesel
Trucks
Percent Increases in Truck Prices Due to Noise Emissions
Regulations
Estimated Increases in Prices for Regulated Trucks, Assuming that
all Engines can be Quieted
Estimated Increases in Prices for Regulated Trucks, Assuming that
all Engines can be Quieted and Manufacturing Costs will Decrease
with Increased Production
Estimated Increases in Truck Prices Assuming Fan-Off Compliance
Testing
Change in Physical Properties of Trucks with Noise Treatments
Dimensions and Weights for Cab Treatments d 1 and d2
Effect of Truck Properties on Rate of Fuel Consumption • .
Effect of Noise Treatment on Rate of Fuel Consumption • .
Estimates of Changes in Rates of Fuel Consumption
Annual Mileage and Fuel Prices by Type of Truck
xvi
-------
LIST OF TABLES (Continued)
Table Title Page
6-14 Estimates of Changes in Average Increases in Annual Fuel Costs,
Including Savings from more Efficient Fans and Fan Clutches . . . . 6-24
6-1 5 Estimates of Changes in Average Increases in Annual Fuel Costs,
Excluding Savings from more Efficient Fans and Fan Clutches . . . . 6-24
6-16 Changes in Annual Maintenance Costs Caused by Noise
Treatments 6-26
6-17 Estimates of Changes in Annual Maintenance Costs 6-27
6-1 8 Estimates of Changes in Annual Operating Costs, Including Savings
from more Efficient Fans, Fan Clutches and Exhaust Gas Seals . . . . 6-27
6-19 Estimates of Changes in Annual Operating Costs, Excluding Savings
from more Efficient Fans, Fan Clutches and Exhaust Gas Seals . . . . 6-28
6-20 Percent Increases in Operating Costs Due to Noise Emission
Regulations 6-28
6-21 Average Annual Truck Mileage 6-30
6-22. Present Value of Total Costs with Fan-On Testing and Credit for
Costs and Savings for more Efficient Fans, Fan Clutches and Exhaust
Gas Seals 6-30
6-23 Present Value of Total Costs with Fan-On Testing and Without Credit
for Costs and Savings for more efficient Fans, Fan Clutches and Exhaust
Gas Seals 6-31
6-24 Present Value of Total Costs with Fan-Off Testing and Credit for Costs
and Savings for more Efficient Fans, Fan Clutches and Exhaust Gas
Seals 6-31
6-25 Present Value of Total Costs with Fan-Off Testing and Without Credit
for Costs and Savings for more Efficient Fans, Fan Clutches and
Exhaust Gas Seals 6-31
7-1 Estimated Reduction in Truck Sales due to Noise Control (First Year
of Each Standard) 7-2
7-2 Forecast Sales Adjusted for Decrease in Demand 7-2
7-3 Percent Demand Reduction due to 80-dBA Regulatory Level 7-3
7-4 Percent Demand Reduction due to 78-dBA Regulatory Level 7-4
7-5 Percent Demand Reduction due to 75-dBA Regulatory Level 7-5
7-6 Incremental Price Increases for 83-, 80-, 78-, and 75-dBA
Regulatory Levels 7-6
7-7 Savings in Average Operating Expenses with Use of Thermostatically
Controlled Fans 7-7
7-8 Total Annual Costs Without Credit for Costs and Savings for more
Efficient Fans, Fan Clutches and Exhaust Gas Seals 7-8
xvii
-------
LIST OF TABLES (Continued)
Table
7-9
7-10
7-11
7-12
7-13
7-14
7-15
7-16
7-17
7-18
7-19
7-20
7-21
7-22
7-23
7-24
7-25
7-26
7-27
7-28
7-29
7-30
9-1
• . 7-10
• • 7-12
• . 7-13
7-15
• • 7-15
• • 7-20
• . . 7-21
7-22
• • . 7-24
• - 7-24
• . 7-25
• . 7-26
• . 7-30
• . . 7-31
• 7-31
• 7-32
• • 7-32
• 7-34
• . 7-36
• 7- 8
• 7-39
• 9-2
Title Page
Total Annual Costs With Credit for Costs and Savings for more
Efficient Fans, Fan Clutches and Exhaust Gas Seals 7-9
Labor Output Ratios
Suppliers of Diesel Engines Used by Truck Manufacturers, 1972
Percent Market Share of New Trucks by Manufacturers, 1972
First-Year Sales of Trucks (Millions of 1975 $) under Adjusted
Forecast of Demand with Cost of Noise Controls
Sales of Trucks (Millions of 1975 $) under Baseline Forecast of
Demand at Original Cost Without Noise Control in the First Year of
the Regulation
Modal Comparison of Rai’ and Truck Intercity, 1969-1974
Highway-Rail Distribution by Shipper Group, Percent Distribution
Based on Tons
Change in Numbers of Carriers, 1971 to 1974
Percentage of Trucking Total
Percentage of Market Revenues of the Top Four (4) Carriers
Measured by Revenue, 1974
Market Share of the Top Four Carriers
Current Position of 1CC-Regulated U.S. Trucking
Revenue Projections for Trucking (Millions of Dollars)
Revenue Discounted at 10 Percent to 1977 (Millions of 1975
Dollars)
Costs for Particular Years Discounted at 10 Percent to 1977
(Millions of 1975 Dollars)
Projected Noise Control Costs in Selected Years as a Percentage of
Revenue
Projected Noise Control Costs in Selected Years as a Percentage of
Operating Income
Operating Ratios: Means and Standard Deviations for ICC
Regulated Companies
Current Sample Position of U.S. General Freight Trucking
Companies
Truck Transportation Costs per Dollar of Final Demand in Various
Industries (Fan Savings Are Included as Rates Would Be Adjusted to
Allow for These)
Percent of Size Class in Each Industry Category
Fuel Savings, Gallons Per Mile Per Unit of Accessory Horsepower
xviii
-------
LIST OF TABLES (Continued)
Table Page
9-2 . 9-2
9-3 . . . 9-3
9-4 . - - 9-3
A-3.l
A-3- 17
A-3.2 . . . A-3- 18
A-33 . . . A-3-20
A-5.I
• . . A-5-2
A-5.2
• . . A-5-3
A-6.l • • A-6-2
A-6.2
• . . A-6-4
A-6.3
• . • A-6-5
A-6.4
• . • A-6-5
A-6 .5
• . . A-6-6
A-7.1 . • • A-7-9
B-i • • . B-2
11-2 . . B-3
B-3 . . . B4
ff4 . • • B-5
B-S B-7
B-6 • • . . B-8
B-7 B-8
B-S - • . B-9
B-9
B ID s -iD
B-li B-ID
B-l2 B-ID
B-l3 B-li
B-14 B-Il
D- 1 . . . . D-2
D-2 . . . . D-3
Ti tie
Annual Mileage, Gallons Per Mile Per Unit of Accessory Horsepower
Trucks in Use in 1990
Decrease in Accessory Power Requirements
Equivalent Noise Levels Used in EPA and GM Estimates of Noise
Reductions in Urban Street Traffic
SAE J366b Truck Noise Levels
Noise Levels Recorded on GM Truck Noise Film
Estimates of Truck Price Increases Presented by Truck
Manufacturers
EPA Estimates of Average Truck Price Increases for Proposed
Regulations
EPA Estimates of Costs and Benefits
Comparison of EPA and General Motors Estimates of Costs and
Benefits
Estimates of Truck Price increases Used in the DOT Analysis of
Costs vs. Benefits
Estimates of Truck Price Increases Used in the Costs-Benefit
Analysis by the Council on Wage and Price Stability
Estimates of Truck Price In creases Used in the Cost-Benefit
Analysis by EPA
GM Forecasts Compared With EPA Forecasts of Total Costs
Annual Production by Type of Truck
Percentage of Trucks Surviving as a Function of Age
Annual Mileage per Truck
Percentage of New and Old Automobiles and Motorcycles
Percentage of Noise-Treated and Untreated Buses
Urban Street Traffic Mix for Medium Trucks
Urban Street Traffic Mix for Heavy Trucks
Urban Street Traffic Mix for Gasoline Trucks .
Urban Street Traffic Mix for Diesel Trucks
Urban Street Traffic Mix for Automobiles
Urban Traffic Mix for Motorcycles
Urban Street Traffic Mix for Buses
Freeway Traffic Mix for Trucks
Freeway Traffic Mix for Automobiles
Price Indexes Used for Adjusting Truck Prices and Other Costs
Average Price of Trucks (1975 Dollars)
xix
-------
LIST OF TABLES (Continued)
Table Title Page
D-3 Average Changes in Maintenance Costs with Credit for Savings
for Exhaust Gas Seals (1975 Dollars) D-3
D-4 Average Changes in Fuel Costs with Credit for Savings for More
Efficient Fans and Fan Clutches (1975 Dollars) D-3
D-5 Average Changes in Fuel Costs without Credit for Savings for More
Efficient Fans and Fan Clutches (1975 Dollars) D-4
E-1 Sequence of Options E-2
G-l Total Annual Costs by Truék Type G-2
G-2 Baseline Sales Projection Resulting Truck Mix . G-3
G-3 Adjustment Factors for the For-Hire Sector, Using 1990
Baseline Mix G-3
G-4 Total Annual Costs for the For-Hire Sector Adjusted for Truck-Mix
and Market Share in 1990 and 2000
G-5 Total Annual Costs as a Percentage of Revenues for the For-Hire
Sector . G-5
G-6 Total Annual Costs as a Percentage of Operating Income G-5
G-7 Medium and Heavy Truck Mix by Sector G-5
H-I Explanatory Notes H-2
H-2 Production Verification and Selective Enforcement Auditing H-3
I-i Fan Clutch Installations, DOT Fan Clutch Program 1-2
xx
-------
Section 1
INTRODUCTION
STATUTORY BASIS FOR ACTION
Through the Noise Control Act of 1972 (86 Stat. 1234), Congress established a
national policy “to promote an environment for all Americans free from noise that jeop-
ardizes their health and welfare.” In pursuit of that policy, Congress stated, in Section 2
of the Act, “that, while primary responsibility for control of noise rests with State and
local governments, Federal action is essential to deal with major noise sources in com-
merce, control of which requires national uniformity of treatment. “As part of that essen-
tial Federal action, subsection 5(b)( 1) requires the Environmental Protection Agency
(EPA), after consultation with appropriate Federal agencies, to publish a report or series
of reports “identifying products (or classes of products) which in his judgment are major
sources of noise.” Further, Section 6 of the Act requires the EPA to publish proposed
regulations for each product, which is identified or which is part of a product class identi-
fied as a major source of noise, where in his judgment noise standards are feasible and fall
into various categories of which transportation equipment (including recreational vehicles
and related equipment) is one.
Pursuant to subsection 5(b)( 1), the Administrator has published a report which
identifies new medium and heavy trucks as a major source of noise liii. As required by
Section 6, EPA shall prescribe regulations on the noise emissions from new medium and
heavy trucks which are “requisite to protect the public health and welfare, taking into
account the magnitude and conditions of use of new medium and heav3 trucks, the degree
of noise reduction achievable through the application of the best available technology, and
the cost of compliance.”
In October 1974, EPA published proposed regulations on new medium and heavy
trucks [ 21. Interested parties were given opportunities to participate in the final regulations
by submitting comments on the proposed regulations. Comments were made in the form
of written responses in Docket ONAC 74-1 and in Public Hearings held on 19—20 February
1975 in Arlington, Virginia and on 27 February 1975 in San Francisco, California. Discus-
sions of the public comments are continued in Appendix A.
After the effective date of a regulation on noise emissions from a new product,
Section 6 of the Noise Control Act requires that no State or political subdivision thereof
may adopt or enforce any law or regulation which sets a limit of noise emissions from such
new product, or components of such new product, which is not identical to the standard
1—1
-------
prescribed by the Federal Regulation. Subsection 6(e)(2), however, provides that nothing
in Section 6 precludes or denies the right of any State or political subdivision thereof to
establish and enforce controls on environmental noise through the licensing, regulation or
restriction of the use, operation or movement of any product or combination of products.
The noise controls which are reserved to State and local authority by subsection 6(e)(2)
include, but are not limited to the following:
I. Controls on the manner of operation of products
2. Controls on the time in which products may be operated
3. Controls on the places in which products may be operated
4. Controls on the number of products which may be operated together
5. Controls on noise emissions from the property on which products are used
6. Controls on the licensing of products
7. Controls on environmental noise levels
To assist EPA in enforcing regulations on noise emissions from new products, State
and local authorities are encouraged to enact regulations on new products offered for sale
which are identical to Federal regulations.
OUTLINE AND SUMMARY OF BACKGROUND DOCUMENT
Background information used by EPA in developing regulations limiting the noise
emissions from new medium and heavy trucks is presented in this document. An outline
and summary is given below.
Section 2 — The Truck Industry. General information on medium and heavy truck,
their manufacturers and users are contained in this section.
Section 3 — Baseline New Truck Noise Levels. The method of measurement of noise
emissions from medium and heavy trucks used in obtaining most of the data on the new
truck noise levels presented in this document is discussed in Section 3. Noise levels for
existing new medium and heavy trucks is presented. A summary of current State and
local regulations on new medium and heavy trucks is given.
Section 4 — Health and Welfare. This section discusses the benefits to be derived from
the various regulatory options. It discusses the concepts of fractional noise impact, the
1-2
-------
procedures for computing the reduction in average traffic noise levels and equivalent num-
ber of people impacted by urban traffic noise. Annoyance resulting from an individual
truck passby is also presented.
Section 5 Technology. This section provides information on the noise control
technology required to bring trucks into compliance with not-to-exceed regulatory levels
of 83, 80, 78 and 75 dBA. A discussion of the noise reduction achievable through the
application of the best available technology is provided in Section 5.3. Criterion for
determining the levels to which trucks can be quieted are set forth and are evaluated with
respect to the lead time necessary to produce complaint vehicles.
Section 6 — Cost of Compliance. This section provides estimates of the costs to bring
medium gasoline, heavy gasoline, medium diesel and heavy diesel trucks into compliance
with not-to-exceed regulatory levels of 83, 80, 78 and 75 dBA. Estimates of changes in
fuel and maintenance cost caused by noise control treatments are also presented.
Section 7 — Economic Analysis. This section examines the impact of different regula-
tory options on the reduction in truck sales, employment and supplies of quiet engines and
noise treatment hardware. The economic impact on the trucking industry, consumer prices
and different sectors of the national economy are also considered.
Section 8 — Enforcement. This section discussed Assembly Process Testing as the
primary method of assuring that the new trucks will conform to the regulation. The various
enforcement actions open to EPA are also stated, should they be needed when a manufac-
turer is found to be producing noncompliant vehicles. -
Section 9 — Environmental Effects. For this section, the effects of truck noise
regulations on air and water pollution, solid waste disposal, energy and natural resource
consumption and land use are considered.
Appendix A — The Docket Analysis. Appendix A examines in detail all of the
written public comments submitted to Docket ONAC 74-1 and presented in Public Hearings
in Arlington, Virginia and San Francisco, California. Public comments are summarized and
organized according to contributor. Analyses of comments on issues in the following areas
are given.
• Benefits to public health and welfare
• Noise control technology
• Costs of compliance
• Costs versus benefits
• Economic impact
1-3
-------
• Test procedure
• Enforcement
• Classification
Action taken in response to public comment on each issue is discussed.
Appendix B — Predictions of traffic population mixes used in estimating benefits to
public health and welfare are presented and discussed.
Appendix C — The elasticity of demand for medium and heavy trucks is considered.
Appendix D — The estimated costs of compliance are given in terms of 1975 dollars.
Appendix E — The computer model used to determine total costs for different regula-
tory options is discussed. Computer printouts for all options considered by the Agency are
presented.
Appendix F — The net operating income is defined.
Appendix G — The method for computing the economic impact on a specific sector
of the trucking industry is discussed.
Appendix H — Estimates of the costs of testing are presented.
Appendix I — Summary of Fan Clutch Field Tests.
1-4
-------
REFERENCES
111 ENVIRONMENTAL PROTECTION AGENCY. Identification of products as major
sources of noise. Federal Register 39: 121, 22297—222999 (June 21, 1974).
[ 21 ENVIRONMENTAL PROTECTION AGENCY. Transportation equipment noise
emission controls, proposed standards for medium and heavy duty trucks. Federal
Register 39: 210 (Part II), 38338—38362 (October 30, 1974).
1 -5
-------
Section 2
THE TRUCK INDUSTRY
Of the major means by which goods are transported, Table 2-1 implies that trucks are
not the least expensive; yet, because of convenience, trucks account for over 80 percent of
the total dollars spent on moving domestic freight.
The cost per ton-mile (approximately 17 cents) is considerably more expensive than
the cost (approximately 1 .5 cents per ton-mile) for shipping by rail, the next largest car-
tier of goods. However, as can be inferred from Table 2-1, trucks on the average carry
more goods over shorter distances, and provide a flexibility that cannot be achieved by
other modes of transportation.
Over the period 1967 to 1972, total new truck sales increased 1.3 times as fast as the
gross national product; new heavy truck sales increased more than 2.5 times as fast [ 1].
The trend over the past several years has been for more goods to be moved by truck. it is
expected that this trend will continue and that each year there will be more trucks on the
nation’s freeways, highways, and city and residential streets.
Table 2-1
Domestic Freight Tranportation Market, 1970
Mode
Transportation
Tons
Ton-Miles
Revenue Dollars
Millions
Percent
Millions
Percent
Millions
Percent
Truck
Rail
Water*
Pipeline ... .
Air
Total
$1,684
1,572
867
790
3
$4,916
34.2
32.1
17.6
16.1
0.0
100.0
$412,000
771,000
595,000
431,000
3,400
$2,212,000
18.7
34.8
26.9
19.5
0.1
100.0
$69,084
11,869
1,902
1,396
720
$84,971
81.3
14.0
2.3
1.6
.8
100.0
*Includes Domestic Deepsea, Great Lakes and Inland Waterways.
Source: Transportation Facts and Trends, TAA Quarterly Supplement, April 1973.
2-1
-------
GENERAL DESCRIPTION OF MEDIUM AND HEAVY TRUCKS
Medium and heavy trucks are defined as trucks with a gross vehicle weight ratings
(GVWR) greater than 10,000 pounds. There is a wide range of types of medium and heavy
trucks. At one extreme of the vehicle characteristics are gasoline-powered 2-axle single
vehicles with 4 tires and GVWR of less than 13,000 pounds. At the other extreme there
are 11-axle combination vehicles with 42 tires, turbocharged diesel engines and a gross
combination weight rating in excess of 130,000 pounds.
Medium and heavy trucks can be described in terms of the following attributes: the
GVWR, the major use, the number of axles, the type and size of engine, and the style of
the cab.
Designation in terms of GVWR for medium and heavy trucks has been defined by the
Motor Vehicle Manufacturers Association [ 2] and is shown in Table 2-2.
Table 2-2
Truck Designation by GVWR (Pounds)
GVWR Category
GVWR Group
Range of GVWR
Medium trucks
(10,001-26,000 ibs)
1
2
3
4
10,001 - 14,000
14,001 - 16,000
16,001 - 19,500
19,501-26,000
Heavy trucks
(over 26,000 Ibs)
5
6
26,001 - 33,000
over 33,000
There are three types of truck designs which reflect the major uses for medium and
heavy trucks. A ruggedly built cab-chassis unit for mounting dump beds, concrete mixers,
etc., is often referred to as a construction truck while a light cab-chassis unit for mounting
van bodies, etc., is designated as a delivery truck. A truck-tractor for pulling trailers is
called a line-haul truck.
The number of axles by which engine power is transmitted to the road surface can
also be used for truck designation. For trucks with two axles, one of which drives the
truck (as in an automobile), the designation is 2 x 4; i.e., two out of the four wheels (dual
tires count as one wheel) are driving. Similarly, a tandem axle, truck-tractor is designated
as a 4 x 6 and an all-wheel drive truck is a 4 x 4 or a 6 x 6.
In terms of engine type, trucks can be designated simply as having either a gasoline
engine or a diesel engine. The horsepower rating of the engine can also be used for truck
classification purposes.
2-2
-------
Trucks can also be designated by the style of the truck cab. The two main styles of
cabs are the conventional cab (sometimes termed a “fixed” cab) style and the cab-over
engine (COE) style. In a conventional cab, the driver sits behind the engine. Conventional
cab styles may be either “short” (Fig. 2 -I) or “long” (Fig. 2-2), depending on the length of
the hood. In the COB style, the driver is positioned above and to the side of the engine.
The COB style may be either “low” (Fig. 2-3) or “high” (Fig. 2-4), depending on the dis-
tance of the deck, or floor, of the cab above the ground.
DISTRIBUTION OF TRUCKS BY CATEGORIES
A statistical analysis of the census data on the characteristics and uses of the truck
population in the United States, which was collected and made available to EPA by the
Bureau of the Census, provides an estimate of the total truck population in the United
States in 1972. The total truck population with GVWR in excess of 10,000 pounds in 1972
was estimated to be 3,533,000 trucks. The distribution of these trucks by GVWR category
and type of engine is shown in Table 2-3 [ 1].
Table 2 3
Total Truck PopulatIon, 1972
GVWR
Categéry
Gasoline Engine
Diesel Engine
Total
Trucks
.
Number
Percent
.
Number
:
Percent
Medium .
Heavy
2,335,000
509,000
98
44
41,000
648,000
2
56
2,376,000
1,157,000
Total
2,844,000
80
689,000
20
3,533,000
Table 24, a breakdown for diesel engine trucks by GVWR for selected years between
1966 and 1972, shows a trend toward fewer medium trucks being powered by diesel
engines and a trend toward increased use of diesel engines for heavy trucks, particularly
the larger GVWR group 6 trucks
The distribution of new truck production in 1972, according to GVWR category and
group as well as type of engine, is shown in Table 2-5 j I ]. Over 90 percent of the new
trucks produced are used in domestic truck transportation.
2-3
-------
Figure 2-1. Truck With Short Conventional Cab
2-4
-------
Figure 2-2. Truck With Long Conventinal Cab
IJJ
I
-------
-‘
Figure 2-3. Truck With Low Deck Cab-Over-Engine
a
, —.. .
•1,
‘PT
a r
2-6
-------
Figure 2-4. Truck with High Deck (‘ ib-Over Engine
2-7
-------
Table 2-4
Percent of Diesel Trucks to Total Trucks by Categories
fox Selected Years, 1966-1972
Year
Medium Trucks Heavy Trucks
GVWR Group
Total
GVWR Group
Total
1
2
3
4
5
6
1966
1968
1970
1972
0%
0
0
0
0%
0
0
0
1%
0
0
0
3%
2
3
1
4%
3
3
1
5%
4
4
3
19%
21
28
30
24%
25
32
33
Source: MVMA 1973 Motor Truck Facts.
Table 2-5
New Truck Production, 1972
GVWR
Category
Gasoline Engine
Diesel Engine
Tot
Trucks
Number
Percent
Number
Percent
Medium 227,263 98 5,045 2 232,308
Heavy 41,994 23 138 O44 ____ 77. 180,038
Total 269,257 65 143,089 35 412,346
GVWR
Group:
1 44,221 100 0 0 44,221
2 9,397 98 215 2 9,612
3 26,330 100 31 0 26,371
4 147,315 97 4,789 3 152,104
5 25,364 65 13,563 35 38,927
6 16,630 12 124,481 88 141111
Total 269,257 65 143,089 35 412,346
2-8
-------
TRUCK MANUFACTURERS
The number of new trucks produced by the major truck manufacturers in 1972 are
shown in Table 2-6 [ 1]. Four truck manufacturers, General Motors (including its
Chevrolet Division), Ford, International Harvester and Dodge, produce almost 98 percent
of all medium trucks and approximately 60 percent of the heavy trucks.
The financial characteristics of the parent companies of the major truck manufacturers
is shown in Table 2 7 [ 1]. Of these parent companies, the five that are considered large,
have sales and assets in excess of $1 billion; two have sales or assets between $500 million
and $1 billion; and four smaller companies have less than $100 million in sales and assets.
- Table 2-6
Number of New Trucks by Manufacturer, 1972
Truck
Manufacturer
Medium_Trucks
Heavy Trucks
Gasoline
Diesel
Total
Gasoline
Diesel
Total
Chevrolet
Diamond Reo
Dodge
FWD
Ford
GMC
IHC
Mack
White
Others
53,722
37
45,042
4
63,544
25,568
39,064
0
0
282
135
—
278
8
3,010
446
1,165
0
0
0
53,857
37
45,320
12
66,554
26,014
40,229
0
3
282
1,602
1,044
3,623
301
13,952
8,126
12,230
25
753
338
3,696
3,207
1,480
606
18,824
16,017
29,311
26,331
21,854
16,718
5,298
4,251
5,103
907
32,776
24,143
41,541
26,356
22,607
17,056
Total
227,263
5,045
232,308
41,994
138,044
180,038
2-9
-------
Table 2-7
Financial Characteristics of Truck Manufacturer’s
Parent Company, 1972 ($ Millions)
Parent Company
of
Net
Net
Truck Manufacturer
Sales
Income
Assets
Worth
Comments
General Motors Corporation $30,435 $2,163 $18,273 $11,683 Truck producing divisions are Chevrolet and
GMC.
Ford Motor Company 20,194 870 11,634 5,961 For year ended 10/31/72.
Chrysler Corporation 9,759 221 5,497 2,489 Truck producing subsidiary is Dodge
Trucks, Inc.
International Harvester 3,527 87 2,574 1,198
Company
The Signal Company (Mack) 1,481 41 1 ,328 653 Truck producing subsidiary is Mack. Including
Brockway, a Division of Mack, had consoli-
dated sales of $713 million and net income of
$35 million.
White Motor Corporation 943 9 573 222 Truck producing divisions are Autocar, White,
Freightliner and Western Star. Total truck
sales of these groups were $61 I million with
earnings of $27 million in 1972.
Pacaar, inc. 595 30 268 170 Truck producing subsidiaries are Kenworth
and Peterbilt. On and off-highway trucks
produced by Peterbilt, Kenworth and Dart
represents about 75% of sales.
Diamond Reo Trucks, inc. 83 7 30 5
Hendrickson Manufacturing 44 Not 23 1 5 Sales include trucks, special truck equipment,
Co. Available and truck modifications.
FWD Corporation 28 0.4 25 6 Sales primarily trucks, year end 9/30/72.
FWD is a subsidiary of Ocwen Corporation,
and investment company.
Oshkosh Truck Corporation 22 i 0.3 14 Sales primarily trucks.
-------
MOTOR TRUCK USERS
A listing of the major users of trucks to move goods is given in Table 2-8 [ 31. As
shown, the. agricultural industry is the largest user of medium trucks and for-hire industry
is the largest user of heavy trucks.
Table 2-8
Distribution of Trucks by Major Users, 1972
Major User of Trucks
Medium
Heavy
Total
Agriculture
32.5%
10.3%
26.3%
Wholesale and retail trade
19.8
18.3
19.4
Construction
11.1
19.1
13.4
For-hire
6.3
30.6
13.4
Services
9.5
2.5
‘7.5
Personal transportation
9.0
1 .0
6.7
Manufacturing
3.6
8.5
5.0
Utilities
3.4
1.9
2.9
Forestry and lumbering
1.7
3.6
2.3
Mining
.6
1.9
1.0
All other
3.0
2.3
2.1
2-11
-------
REFERENCES
[ 1] KEARNEY, INC, A.T. A study to determine the economic impact of noise emission
standard in the medium and heavy truck industry (EPA Contract No. 68-01-1 54),
A.T. Kearney, Inc. (1974)
[ 2] MOTOR VEHICLE MANUFACTURERS ASSOCIATION, INC., 1973, Motor Truck
Facts (1973).
[ 31 U.S. BUREAU OF CENSUS, Truck inventory and use survey, 1972, census of trans-
portation, Washington, D.C. (1972).
2-12
-------
Section 3
BASELINE NEW TRUCK NOISE LEVELS
The baseline noise levels for different truck categories as well as the test procedure
used to determine the noise levels are presented in this section.
TEST PROCEDURE USED
The most widely used test in the United States for measuring noise levels for medium
and heavy trucks is the Society of Automotive Engineers (SAE) Standa* J366b test
entitled “Exterior Sound Level for Heavy Trucks and Buses.” In April 1973, the test was
revised, making it an SAE Standard (J366b) rather than an SAE J366a Recommended
Practice. The majority of the truck noise level data in this document was measured using
the SAE J366a recommended practice test procedure. No significant changes in the test
procedure were made in this SAE J366b revision. Accordingly, the previous new truck
noise level data based on J366a are used herein as the baseline noise levels for current
production trucks. A brief description of the SAE J366b test procedure follows.
The test site for performing the SAE J366b exterior truck noise level test is illustrated
in Figure 3-1. A microphone is located 50 feet from the centerline of the truck passby.
The truck approaches the acceleration point with the engine operating at about two thirds
of maximum rated or governed engine speed. At the acceleration point, the accelerator is
rapidly and cully depressed. The truck engine must reach the maximum rated or governed
RPM within the end zone of the acceleration lane. Several runs are performed in different
directions and the average of the two highest A-weighted sound levels, which are within
2dBA of each other and measured on the noisiest side of the vehicle, are reported. During
the test, the truck never exceeds 35 mph. Since tires are relatively quiet at low speed, the
J366 test results are primarily an indicator of engine-related noise, which includes noise
from the cooling fan, air intake, engine, exhaust, transmission, and rear axle.
NOISE LEVELS FOR NEW TRUCKS
A histogram of the noise levels of new diesel trucks, measured according to the SAE
J366 test procedure, is shown in Figure 32 [ 1]. For the total of 384 diesel trucks mea-
sured, the mean noise level was 84.7 dB(A) with a standard deviation of 2.24 dB(A). The
trucks measured included trucks from the eight truck manufacturers which produced
approximately 85 percent of the new diesel trucks sold in 197 1. Not included in this total
3-1
-------
are experimental trucks such as those developed under the Quiet Truck Program of the
Department of Transp rtation or those trucks developed by various truck manufacturers
without government sponsorship.
Data on the noise levels of new trucks with gasoline engines are presented in the histo-
gram shown in Figure 3-3 [ 1]. For the total of 18 trucks measured, the mean level was
83.5 dB(A) ‘jth a standard deviation of 2.35 dB(A). The difference between the mean
noise level of gasoline and diesel powered new trucks is 1 .2 dB(A).
A cumulative distribution of the new diesel truck noise levels is shown in Figure 3-4 [ 1].
Approximately 1 percent of newly manufactured 1973 trucks produce 80 dB(A) or less, 30
percent produce under 83 dB(A), and 86 percent produce less than 86 dB(A). Several new
trucks did produce noise levels in excess of 90 dB(A).
Histograms of the noise levels measured for new gasoline-powered medium and heavy
trucks are shown in Figure 3-5 [ 11. The mean noise level for medium trucks appears to be
less than 2 dB(A) lower than the mean noise level for heavy, gasoline powered new trucks.
Figure 3-1. Test Site for SAE Standard J366b
3-2
-------
SOUND LEVEL (dBA)
Figure 3-2. Histogram of New Diesel Truck Noise Levels
Total Trucks: 384
Mean Level: 84.7 dBA
Standard Deviation: 2.24 dBA
100
80
60
(I ).
C-)
I—
U-
0
U i
z
40
20
78 80
82
86 88 90 92
3-3
-------
Total Trucks: 18
Mean Level: 83.5 dB(A)
Standard Deviation: 2.35 dB(A)
1- 5-
7O T5 80 90
SOUND LEVEL (dBA)
Figure 3-3. Noise Level Histograms of Gasoline-Powered Trucks
STATE AND LOCAL REGULATIONS
Summaries of existing State and local regulations on new medium and heavy trucks
that will be preempted by Federal regulations are given in Table 3-1. Note that some States
(California and Maryland) have required medium and heavy trucks to meet an 83 dBA
standard since as early as 1975. Although the Federal 83 cIBA regulation is more stringent
due to a tighter enforcement program, manufacturers have been supplying medium and
heavy trucks which comply with an 83 dBA regulation.
85
34
-------
Figure 3-4. Cumulative Distribution of New Diesel Truck Noise Levels
_1
w
>
w
-J
2
0
C /)
0
—I
w
0
I.-
0
C.)
I-
U-
0
I-
2
w
0
w
0
30
5
2
1
80
84
SOUND LEVEL (dBA)
88
3-5
-------
10
5—
MEDUIM
Total Trucks: 11
Mean Level: 82.9 dB(A)
Standard Deviation: 2.63 dB(A)
10 11ETh
0-
70 75 80
SOUND LEVEL (dBA)
10 -
HEAVY
Total Trucks: 7
Mean Level: 84.7 dB(A)
Standard Deviation: 1.33 dB(A)
5-
0 I i 1.-i
70 75 80
SOUND LEVEL (dBA)
Figure 3-5. Noise Level Histograms of Gasoline-Powered Medium
and Heavy New Trucks
85
I
90
I
90
C ’,
0
D
I-
U-
0
w
2
C I )
C-,
I-
0
w
z
85
3-6
-------
State and Localities
Year
1972
or
1973
1974
1975
1976
1977
1978
1979
1980
1981
1983
earlier
California
88
86
83
80
70
Colorado
88
86
Florida
86
83
80
75
Maryland
86
83
80
75
Minnesota
88
86
Nebraska
88
86
84
80
Nevada
88
86
Oregon
86
83
80
Pennsylvania
90
Washington
86
Barrington, Illinois*
88
86
84
75
Boston, Massachusetts
88
86
84
75
Chicago, Illinois
86
84
75
Des Plaines, Illinois
86
84
75
Grand Rapids, Michigan
88
86
84
75
Madison, Wisconsin
88
Cook County, Illinois
86
84
75
All standards based upon SAE J366 test procedure.
*Standards measured at 25 feet.
Table 3-1
State and Local Noise Regulations on New Medium and Heavy Trucks
a)
a)
F.’.,
0
Ir
Ca
a)
I-
Ca
a)
CI
I-
Ca
Ca
‘I- .
-------
REFERENCES
[ 1 1 BENDER, E.K., W. N. PATTERSON, and G.E. FAX. The technology and cost of
quieting medium and heavy trucks, BBN Report 2710. Bolt, Beranek, and
Newman, Inc., Cambridge, Mass. 02138 (October 30, 1974).
3 -S
-------
Section 4
PUBLIC HEALTH AND WELFARE BENEFITS FROM REGULATIONS
INTRODUCTION
The Environmental Protection Agency (EPA) has proposed [ 1] noise emission regula-
tions on new medium and heavy trucks. The proposed cegulations specify not-to-exceed
levels of 83 dBA in 1977,80 c IBA in 1981, and 75 dBA in 1983, as measured according
to the SAE J366b test procedure, and are intended to control engine-related truck noise.
Tire noise will be the subject of separate, future regulations.
Predictions of both costs and benefits involved are required to define the tradeoffs for
various options for the regulatory levels. In this analysis, predictions of the potential health
and welfare benefits for a range of possible regulatory programs of new truck noise emissions
are presented. Costs of compliance and economic impact for different regulatory programs
are discussed in sections 6 and 7, respectively.
Because of inherent differences in individual responses to noise, the wide range of
traffic situations and environments, and the complexity of the associated noise fields, it is
not possible to examine all traffic situations accurately. Thus, in this predictive analysis,
certain stated assumptions have been made to approximate typical or average situations. The
approach taken to determine the benefits associated with the truck noise regulation is,
therefore, statistical in that an effort is made to determine the order of magnitude of the
population that may be affected for each regulatory option. There may exist some uncer-
tainties regarding individual cases or situations. However, such effects cannot be completely
accounted for; thus, a statistical approach is necessary.
Measures of Benefits to Public Health and Welfare
The phrase public health and welfare, as used here, includes personal comfort and well-
being as well as the absence of clinical symptoms such as hearing damage.
Reducing noise emitted by trucks will produce the following benefits [ 28]:
• Reduction in average traffic noise levels and associated cumulative long-term im-
pact upon the exposed population.
• Fewer activites disrupted by individual (single-event) truck passby noise.
4-1
-------
• Associated reduction of noise in truck cabs, which should reduce annoyance,
speech interference, and possible hearing damage.
Predictions of vehicle noise levels under various regulatory options are presented in
terms of the energy-average of the peak noise levels associated with a continuous sequence of
passbys. The passby noise levels are weighted according to traffic populations or mixes before
averaging. Reductions in average of the passby noise levels from current conditions (i.e.,
with no noise emission regulations) are presented for 14 regulatory options on new medium
and heavy trucks, both with and without reductions in the noise emission from other
traffic noise sources. Projections of the population impacted as well as the relative
reductions in impact from current conditions are determined from reductions in
average passby noise levels.
The reduction in the energy-average of the passby levels for a mix of vehicles in traffic
does not adequately describe the annoyance produced by a single truck passby for all
situations, since the average noise level tends to average out the disruptive and annoying
peak noise level produced by a single passby. In addition, annoyance frequently depends
on the activity and location of the individual. As an additional measure of benefits,
noise levels that produce annoyance or interference in eight activityJiocation scenarios are
compared to the noise levels from single passbys for trucks that are regulated at different
levels. Truck passby distances from an observer at which annoyance or interference with
activities occur are calculated for regulated trucks. These distances’ are compared to
distances determined for existing trucks, after correcting appropriately for propagation and
building transmission losses.
Regulatory Options
Predictions of traffic noise reductions and the population impacted are presented for
both freeway and urban street traffic conditions under the 14 regulatory options shown in
Table 4-1. For predictions of health and welfare benefits with concurrent reductions in
emission from new automobiles, motorcycles, and buses, an effective date for the regulations
of January 1, 1976, is assumed. In addition, the EPA Interstate Motor Carrier Regulations
apply to all trucks as of October 1, 1975
Outline of Section 4
The predictions of the reduction in average passby noise levels and the population impacted are
contained in the following discussion. Both freeway (high speed—55 mph) and urban street
(low speed—27 mph) traffic conditions are treated, and the sum of the number of people
impacted is given. The traffic mixes used in this discussion are presented in Appendix B.
4-2
-------
Table 4-1
Regulatory Options for Medium and Heavy Trucks
Regulatory Options
Not-to-Exceed Regulatory Level — dBA
CY1978
CY1982
CY1984
CY1986
CY1988
A
83
80
75
—
—
B
83
80
—
75
—
C
83
80
78
—
—
B
83
—
78
—
—
E
83
80
—
—
—
F
83
—
80
—
—
G
83
—
—
—
—
H
-
—
—
—
—
I
83
—
80
—
75
J
83
—
—
75
—
K
83
80
75
78
(gas)
(diesel)
L
83
80
75
(gasonly)
M
83
80
75
78
(medium)
(heavy)
N
83
80
75
(medium only)
In the next discussion, predictions of changes in annoyance or interferences with activi-
ties resulting from different regulatory levels are determined for a range of different activity!
location situations.
Reduction of in-cab noise levels is discussed in the final portion of this section.
REDUCTIONS IN THE IMPACT FROM TRAFFIC NOISE
Projections of reductions in average traffic passby noise levels are presented for scenarios
of both urban street traffic, where the average vehicle speed is assumed to be 27 mph, and
freeway traffic, where the average vehicle speed is assumed to be 55 mph. Note, however, that
the benefits accrued from the regulatory programs for new trucks considered here will be less for
freeway traffic than for urban street traffic for the following reasons:
• The number of people exposed to freeway traffic noise is less than the number of
people exposed to urban street traffic noise.
• The reductions in traffic noise levels resulting from the regulations on new trucks
will be less in freeway traffic than in urban street traffic.
As depicted in Figure 4-1, the number of people currently exposed to outdoor noise
levels that are greater than Ldn = 55 dBA dominated by urban street traffic noise is signifi-
cantly higher than the number exposed to freeway traffic noise (93.4 million as opposed to
4-3
-------
93.4
— URBAN TRAFFIC NOISE
90
FREEWAY TRAFFIC NOtSE
80
U )
2
0
10 -
-J
60’ 59.0
50-
2
0
R 40 -
.1 (
-J
0-
o 30-
0. 24 .3
20- 1
10 ’ I 6.9
Ldfl (dB)
Figure 4-1. Estimated Number of People in Residential Areas Currently
Subjected to Traffic Noise Above Ldn = 55 dB.
4.9 million). Thus, reducing urban street traffic noise will benefit significantly more
people than will similar reductions in freeway traffic noise.
The new truck regulations considered are based on truck noise emissions measured in
accordance with the SAE J366b test procedure. In the SALE 1366b test procedure, truck
noise emissions are measured with the truck speed less than 35 mph and the truck engine
fully loaded. Since, in general, engine-related noise emissions increase with engine speed
and load, and noise generated by tires increases with vehicle speed, the SALE J366b test
procedure is designed so that maximum engine-related noise levels are measured. The noise
generated by tires under SAE J366b test conditions is significant. Therefore, the new
truck regulations considered here should have little effect in reducing truck tire noise.
At freeway speeds, truck tires contribute significantly to the overall passby noise levels.
Therefore, the reduction of engine-related noises produced by the new truck regulations will
be partially masked by tire noise in freeway traffic. Because vehicle speeds are lower in
4-4
-------
urban street traffic, tire noise contributes less to the overall noise emissions. Thus, reduc-
tions in overall truck noise levels by lowering engine-related noise emissions will be less af-
fected by tire noise.
Reduction of tire noise levels will be necessary before the benefits from new truck
regulations can be fully realized in freeway traffic. The EPA has expressed its intent to
regulate tires in the future [ I].
Description of Traffic Noise Impact
To perform the analysis described in this discussion, a noise measure is utilized that
condenses the information contained in the noise environment into a simple indicator of
quantity and quality of noise. This measure correlates well with the overall long-term effects
of noise on the public health and welfare [ 21 and was developed as a result of the Noise
Control Act of 1 972, which required EPA to present information on noise levels “requisite
to protect the public health and welfare witl1 an adequate margin of safety.”
EPA has chosen the equivalent A-weighted sound level in decibels as its general
measure for environmental noise [ 3]. The general symbol for equivalent level is Leq and
its basic definition is:
Leq = 10 log 10 ( 2 1 Jt2 P(t ) dt) (4-1)
where t 2 — t 1 is the interval of time over which the levels are evaluated, P(t) is the time
varying magnitude of the sound pressure, and P 0 is a reference pressure, standardized at 20
micropascal. The Leqwill be used to describe traffic noise emissions. When expressed in
of A-weighted sound level, LA, the equivalent A-weighted sound level, Leq is defined
Leq = 10 log 10 5 t 2 10 [ LA(t)/10J
t 2 —t 1 ti
In describing the impact of noise on people, the measure called the day-night sound
level (Ldn) is used. This is a 24-hour measure with a weighting applied to nighttime noise
levels to account for the increased sensitivity of people to intruding noise associated with the
decrease in background noise levels at night. The Ldn is defined as the equivalent noise level
during a 24-hr period, with a I 0-dB weighting applied to the equivalent noise level during the
nighttime hours of 10 p.m. to 7 a.m. This may be expressed by the following equation [ 31:
4-5
-------
Ldn 10 log 10 L [ 15 (i 0 Ld/10) + 9 (lOn+10)/10)1 (4-2)
24 [
where Ld is the daytime equivalent level obtained between 7 a.m. and 10 p.m. and L is the
nighttime equivalent level obtained between 10 p.m. and 7 a.m.
Urban Street Traffic Noise
Two averages are taken to predict the average noise level from urban street traffic. First,
an energy average is taken of the noise emissions from several passbys of each type of noise
source. Next, the average traffic noise level is then computed by energy averaging the d,jived
passby levels for each vehicular source, after appropriate weighting for the number of each
type of vehicle in urban traffic.
Vehicle noise levels in urban street traffic
The following noise sources are considered in modeling urban Street traffic noise:
• Noise treated and untreated automobiles, motorcycles and buses
• Medium and heavy trucks that are unregulated, regulated by the Interstate Motor
Carrier regulations and regulated by not-to-exceed levels of 83, 80, 78 or 75 dBA.
For a population of instantaneous noise levels observed at equally spaced time intervals
that has a normal (Gaussian) distribution, the energy-average of the noise levels over time (see
equation 4-1) is given by [ 3, 41
Leq= L 0 +0.115u . (43)
where L 0 is the median noise level and is the standard deviation. It is assumed that the
distribution of roadside passby noise levels for each type of vehicle is approximated by a normal
(Gaussian) distribution and that there is a steady stream of closely spaced passbys. This
assumption permits calculation of the energy-average of the f3ssby noise levels from median
passby noise levels in a manner similar to the computation of Leq in Equation 4-3; that is
LaL 50 +0.115a 2 (4.4)
4-6
-------
where La is the energy-average of the passby levels, L 50 is the median level and a is the
standard deviation of vehicle passby noise levels. As Equation 4-4 demonstrates, vehicle
passby noise depends on both median level and the variability of these levels. The median
levels and standard deviations used for each type of noise source in computing the traffic noise
levels are given in Table 4-2.
Table 4-2
Assumed Passby Noise Levels for Vehicles in Urban Street Traffic
Type of Vehicle
Urban Street — 27 mph
dBA
L 50
U
La
I. Heavy Trucks
(a) Unregulated 85.0 3.7 86.6
(b) Interstate Motor Carrier Regulations 82.0 3.0 83.0
(c) 83 dBA New Truck Regulation 77.3 2.0 77.8
Cd) 80 cIBA New Truck Regulation 74.6 2.0 75.1
(e) 78 dBA New Truck Regulation 73.0 2.0 73.5
(t) 75 dBA New Truck Regulation 70.8 2.0 71.3
2. Medium Trucks
(a) Unregulated 77.0 3.7 78.6
(1,) Interstate Motor Carrier Regulations 77.0 3.7 78.6
(c) 83 dBA New Truck Regulation 77.0 2.0 77.5
(d) 80 dBA New Truck Regulation 74.6 2.0 75.1
(e) 78 dBA New Truck Regulation 73.0 2.0 73.5
(1) 75 dBA New Truck Regulation 70.8 2.0 71.3
3. Automobiles
(a) Untreated 65.0 3.7 66.6
(b) Treated 61.0 2.0 61.5
4. Buses
(a) Untreated 79.0 3.7 80.6
(b) Treated 75.0 2.0 75.5
5. Motorcycles
(a) Untreated 82.0 3.7 83.6
(b) Treated 78.0 2.0 78.5
The data in Table 4-2 demonstrate that regulating the noise emissions from vehicles
lowers the median noise levels as well as the variability of the noise levels within each
vehicle class. This is because all the vehicles within each class are subject to the same regula-
tory level, which tends to decrease the spread in the noise levels.
4-7
-------
Median Noise Levels for Trucks
Levels for Current Trucks
Since most medium trucks are powered by gasoline engines and most heavy trucks by
diesel engines [ 51, medium trucks are generally quieter than heavy trucks. Therefore,
medium and heavy trucks will be treated separately.
In a survey of truck noise emissions t61 trucks were classified by number of axles rather
than vehicle weight or engine type. A median level of about 76 dBA was reported for trucks with
two axles in speed zones less than 35 mph when measured at grassy sites 50 ft from the street.
A characteristic of many urban street sites, however, isa hard surface between the truck
and the observation point. A hard surface will usually increase the observed truck noise
levels over those that would be expected at a grassy site. Some medium trucks have more
than two axles and, therefore, were grouped with trucks having higher reported median
levels. Given these factors, it is assumed that medium trucks at typical sites will emit a
median level approximately 1 dBA higher than that reported for two-axle trucks near grassy
sites. Thus, a level of 77 cIBA observed at 50 ft was selected as the median noise level for
medium trucks.
A median level of approximately 84 dBA measured at a distance of 50 ft over grassy
areas is reported for trucks with 5 axles at speeds less than 35 mph [ 6]. Because many urban
sites have hard surfaces between the truck and observer, a median level of 85 dBA is selected.
Levels for Regulated Trucks
The Interstate Motor Carrier regulations are in-use standards specifying maximum per-
missible noise emissions for old and new medium and heavy trucks. At low speeds, the
regulation states that the roadside levels generated by trucks shall not exceed 86 cIBA. This
regulation will not significantly impact medium trucks that currently emit a median level of
77 cIBA. However, the current median roadside level for heavy trucks is approximately 85
cIBA. Therefore, so that most heavy trucks can comply with the Interstate Motor Carrier
regulations, a median level of 82 dBA has been assumed.
The median roadside passby levels for regulated i w trucks will actually be below the
specified regulatory levels for the following reasons:
• Trucks will be designed and built with median test noise levels below the not-to-ex-
ceed regulation levels, so that most of the trucks of a given model will comply
with the regulation.
• Less noise is produced under tyr ical road operating conditions than under test
conditions.
4-8
-------
• There are differences between roadside sites and test sites so that the observed
noise levels will often be lower at roadside sites.
Since the regulations prescribe levels not to be exceeded, trucks must be designed and
built so that the measured levels will fall below the prescribed level. If the desired median
level is set two standard deviations below the regulatory level, 97.7 percent of the trucks
should be below the regulatory level.
In the selective enforcement auditing procedure in the regulations, 10 percent
of the tested vehicles are allowed to exceed the regulatory level, so that a median level
two standard deviations below the regulatory level should be low enough for compliance, if
design tolerances and uncertainties in measured levels are ignored. Available noise control
technology for trucks does not permit a designer to confidently hit a median noise level
goal exactly [ 71. That is, some uncertainty should be related to the variation in the
noise levels.
A design tolerance, or safdty factor, on the median level of one standard deviation is as-
sumed. Therefore, a median level of three standard deviations below the regulatory level is
assumed sufficient to account for design tolerances and variations in noise levels from differ-
ent trucks of one configuration. The standard deviation of noise levels measured from 30
nominally identical trucks tested at the same site, with the same instrumentation and in ac-
cordance with SAE J366b test procedures, was approximately 0.5 dBA [ 8]. Therefore, a
level approximately 1.5 dBA below the regulatory level should be adequate to compensate
for design tolerances and variation in the noise levels.
Measurement uncertainties associated with the test site and measurement instrumenta-
tion will be approximately 1.0 c IBA. Thus, a median level of 2.5 c IBA below the regulatory
level should be sufficient to account for variations in noise emissions and measurement un-
certainties. The 2.5-dBA factor is in agreement with most of the comments received from
truck manufacturers in response to the proposed regulations.
The SAE J366b test procedure is designed to measure maximum engine-related noise.
However, because the engine will not always be at maximum load and speed for trucks in
urban street traffic, observed noise levels for typical operating conditions on urban streets
will be lower than the levels measured in accordance with the SAE J366b test procedure.
The average difference between the noise levels measured according to SAE J366b pro-
cedure and the levels measured during typical city startup conditions for 15 heavy diesel
trucks is approximately 1.0 cIBA [ 91. However, little data is available regarding the differ-
ences between SAE J366b measured noise levels and the passby noise levels of the tested
trucks cruising at speeds of less than 35 mph. In addition, little data exists regarding driving
cycles of trucks to show the amount of time trucks are accelerating or cruising.
4-9
-------
For predicting typical roadside noise levels, cruising trucks are assumed to emit levels
3.0 dBA below the SAE J366b noise level. Further, it is assumed that trucks cruise 80
percent of the time and accelerate 20 percent of the time while in urban street traffic.
Weighting according to this assumption on the driving cycle, the average roadside level for
trucks is estimated to be 2.5 dBA below the median SAE J366b test level.
In the test procedure required in the EPA proposed regulations, a hard surface between
the truck and measurement point is required. Many roadside sites have grassy surfaces be-
tween the truck and an observer 50 ft from the truck passby. Therefore, some of the noise
will be absorbed by the soft grassy surface, so that the observed noise levels will be lower
than the levels that would be observed at sites similar to the required test site. The differ-
ence in the noise levels observed at sites with concrete or sealed asphalt between the trucks
and the observer and the levels observed at sites with grass between the trucks and the ob-
server is approximately 2 dBA [ 91. By assuming that, about half of the urban street sites
have a soft surface, the median level of the observed noise emitted by trucks in urban street
traffic will be approximately 1 .0 dBA below those observed at test sites for the same trucks
and operating conditions.
By considering all of the preceding factors, the median noise level of the engine-re-
lated noise 50 ft from an urban street is assumed to be 6.0 dBA below the regulatory level.
The 6.0 dBA represents a summation of the following factors:
• Designing 2.5 dBA below the regulatory level.
• Typical operating conditions producing noise levels 2.5 dBA below the test noise levels.
• A reduction of 1.0 dBA due to differences in test and roadside sites.
The data in Table 4-2 for the median level of regulated new trucks are the energy sum
of engine-related noise and tire noise. The tire noise is assumed to have a level of 66 dBA at
50 ft for speeds of 27 mph, which is representative of ribbed tires [ 101.
Median Noise Levels for Automobiles
A median roadside noise level of 65 cIBA is given in Table 4-2 for untreated auto-
mobiles with speeds below 35 mph as observed at 50 ft from the centerline of the automobile
passby. This level represents the average of the following published survey data: 68 dBA
[ 111,68 dBA [ 12], 64.4 dBA [ 131, 61.4 dilA [ 141,62 dBA [ 15), and 64.2 dBA [ 16].
The lowest of these levels (61.4 dBA) is the average of the noise emitted from eight new
automobiles operated at a constant speed of 35 mph [ 14]. Selection of 61 dBA as a median
passby level for new noise-treated automobiles was based on the assumption that treating
automobiles will lower the median level of new automobiles operated on urban streets to the
current average level for new automobiles operating at constant speed. This is one of the
quietest of normal operating conditions.
4 -10
-------
Median Noise Levels for Buses
The 79-dBA median level for untreated buses, shown in Table 4-2, represents the
average noise emission level for buses operating in urban street traffic [ 1 71. This level is 2
dBA higher than the median level assumed for medium trucks and 6 dBA lower than the
median level assumed for heavy trucks. Treated new buses are assumed to have passby
levels of 4 dBA lower than untreated buses. This reduction in passby levels for buses is
identical to the reduction assumed for automobiles.
Median Noise Levels for Motorcycles
The 82-dBA median level for untreated motocycles, shown in Table 4-2, represents
the average level for motorcycles operating in urban street traffic [ 17]. This level is 3 dBA
below the median level assumed for heavy trucks. It is assumed that treating new motor-
cycles will reduce roadside levels by 4 cIBA, which is identical to the reductions assumed for
automobiles and buses.
Standard Deviations
The average of the standard deviations for the roadside noise Levels from trucks at
speeds of less than 35 mph is approximately 3.9 dBA [ 6J. The California Highway Patrol
found a 2.8-dBA standard deviation for trucks cruising at speeds less than 35 mph [ 12]. A
standard deviation, 4.0 dBA, is given by Olson [ 13]. The average standard deviation for
trucks calculated from the preceding data is 3.6 dBA. For automobiles, a standard devia-
tion of 3.7 cIBA was reported by the California Highway Patrol [ 181. For motorcycles,
values of 4.4 c IBA (19) and 3.0 cIBA 1201 have been reported. Averaging these values gives
3.7 dBA as a representative standard deviation for motorcycles. From this data, it appears
that the standard deviation of typical roadside noise levels does not significantly vary for
different types of motor vehicles. Thus, a typical standard deviation of 3.7 ElBA is assumed
for all untreated vehicles.
For regulated new trucks, a standard deviation of 2.0 dBA is assumed. This value is
higher than the expected 0 ,5-ElBA standard deviation of SAF J366b measured noise levels
because it also includes the effects of variations in operating conditions and roadside site
characteristics. By assuming that the standard deviation for the roadside noise levels of
regulated trucks is 2.0 cIBA, only the noise levels exceeding the median level by more than
three standard deviations would be higher than the regulatory level, since the median road-
side level is assumed to be 6.0 cIBA below the regulatory level.
4- Il
-------
Thus, assuming that the noise levels for trucks do not change with truck age, only a
small percentage (less than 0.1 percent) of the regulated trucks would be capable of produc-
ing noise levels above the regulatory level and, therefore, would have been out of compliance
with the regulations when they were new.
A standard deviation of 2.0 dBA is also assumed to apply to new noise-treated automobiles,
motorcycles, and buses. Since the Interstate Motor Carrier regulations are applicable to both
old and new trucks, a larger variation in roadside noise levels is anticipated for trucks
complying with these regulations than for the trucks complying with the new truck regula-
tions. Thus, a standard deviation of 3.0 dBA is assumed for heavy trucks regulated by the
Interstate Motor Carrier regulations. Note that this standard deviation is higher than the
2.0 dBA standard deviation assumed for trucks subject to the new truck regulations and is
lower than the 3.7 dBA standard deviation assumed for unregulated trucks.
Reduction of average urban street traffic noise levels
From the figures regarding traffic population percentage in urban street traffic pre-
sented in Appendix B and the average passby noise levels given previously, average passby
noise level for urban street traffic noise levels ( 1 a) may be computed using the following equation
La = 10 log 10 . 7 (4-5)
where is the fraction of the total traffic population for the ith type of noise source (see
tables in the Appendix B) and L 1 a is the average passby noise level for the ith type of noise
source (see Table 4-2).
The reduction in the average passby noise levels relative to existing average passby noise
levels are presented in Tables 4-3 and 4-4 for the years 1978, 1982, 1984, 1986, 1991 ,and
2001, for each of the regulatory programs for new trucks given in Table 4-1. In Table 4-3,
it is assumed that automobiles, motorcycles, and buses are not treated so that the new truck
regulations are supported only by the Interstate Motor Carrier regulations. The effectiveness
of the Interstate Motor Carrier regulations will decrease as a larger portion of the trucks become
subject to new truck regulations that reduce the noise emissions to levels below the levels
specified in the Interstate Motor Carrier regulations. In Table 4-4, it is assumed that new
truck and Interstate Motor Carrier regulations are supported by treatment of new automobiles,
motorcycles, and buses, that reduce their roadside noise levels by 4 dBA.
For the purposes of these computations, it is assumed that the total population of urban
street vehicles remains constant. This assumption should have little impact on the relative
4-12
-------
Table 4-3
Reduction in Urban Street Traffic Noise — Without Reductions
in Noise from Automobiles, Motorcycles and Buses
Reduction in ‘Average Noise — dBA at 50 Ft
Regulatory
Option
Calendar Year
1978
1982
1984
1986__ — .
1991
2001
A
0.7
1.2
1.6
2.1
2.7
3.0
B
03
1.2
1.6
1.9
2.6
3.0
c
0.7
1.2
1.6
2.0
2.4
2.6
D.
0.7
1 ,2
1.4
1.8
2.4
2.6
E
0.7
1.2
1.6
1.9
2.2
2.3
F
0.7
1.2
1.4
1.7
2.1
2 ,3
G
0 ,7
1.2
1.4
1.4
1.6
1.6
H
0.7
03
Q.7
0.7
0.7
0.7
j
0.7
1.2
1.4
1.7
2.4
3.0
j
0.7
1.2
1.4
1.4
2.4
2.9
K
L
0.7,
03
1.2
1.2
1.6
1.6
2.0
2.0
2.6
2.6
2.9
2.9
M
0.7
1.2
1.6
2.0
2.6
2.9
N
0.7
1.2
1.6
2.0
2.6
2.9
magnitudes of urban street traffic noise levels, because the average noise levels for all of
the regulatory programs will be affected equally by changes in total vehicle population.
Reduction in noise impact from urban street traffic
To assess the impact of traffic noise, a relation between the changes in traffic noise
just discussed and the responses of the people exposed to the noise is needed. The responses
may vary depending upon previous exposure, age, socioeconomic status, political cohesive-
ness, and other social variables. In the aggregate, however, for residential locations, the
avenge response of groups of people is related to cumulative noise exposure as expressed in
a measure such as Ldn. For example, the different forms of response to noise, such as hear-
ing damage, speech or other activity interference, and annoyance, were related to Leq or
Ldn in the EPA Levels Document [ 31. For the purposes of this study, criteria based on Ldn
presented in the EPA Levels Document are used. Furthermore, it is assumed that if the
outdoor level of Ldn = 55 dB, which is identified in the EPA Levels Document as requisite
4-13
-------
Table 4-4
Reduction in Urban Street Traffic Noise — With a 4 dBA Reduction in Noise from
Automobiles, Motorcycles and Buses
Reduction in Average Noise — dBA at 50 Ft
Calendar Year
Regulatory
Option
1978 1982 1984 1986 1991 2001
A
B
C
D
E
F
G
H
1
J
K
L
M
N
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
1.1
2.5
2.5
2.5
2.5
2.5
2.5
2.5
1.9
2.5
2.5
2.5
2.5
2.5
2.5
3.7
3.7
3.7
3.3
3.7
3.3
3.3
2.4
3.3
3.3
3.7
3.7
3.7
3.7
5.0
4.6
4.8
4.4
4.6
4.2
3.8
2.7
4.2
3.8
4.9
4.9
4.9
I
6.3
6.2
5.8
5.7
5.2
5.1
4.0
2.7
5.7
5.8
6.2
6.2
6.2
6.2
7.1
7.1
6.3
6.3
5,5
5.5
4.1
2.7
7.0
6.9
6.9
6.8
9
6.8
to protect the public health and welfare, is met, no adverse impact in terms of general an-
noyance and community response exists.
The intelligibility of sentences (first presentation to listeners) drops to 90 percent when
the level of the noise environment is increased approximately 19 dB above the level iden-
tified in the EPA Levels-Document and to 50 percent when the level is increased approxi-
mately 24 dB. The intelligibility of sentences (known to listeners) drops to 90 percent when -
the level is increased approximately 22 dB above the identified level and to 50 percent when
the level is increased approximately 26 dB [ 5]. Thus, since normal conversation contains
a mixture of some new and some familiar material, it is clear that when the level of environ-
mental noise is increased more than 20 dB above the identified level, the intelligibility of
conversational speech deteriorates rapidly with each decibel of increase. For this reason, a
level 20 dB above the identified level is considered to result in 100 percent impact On the
people exposed. For environmental noise levels that are between 0 and 20 dB above the
identified level, the impact is a ssumed to vary linearly with level; i.e., a 5-dB excess consti-
tutes a 25 percent impact and a 10-dB excess constitutes a 50 percent impact.
4-14
-------
A similar conclusion can be drawn from the community reaction and annoyance data
contained in Appendix B of the Levels Document [ 31. The community reaction data show
that the expected reaction to an identifiable source of intruding noise changes from “none”
to “vigorous” when the day-night sound level increases from 5 dB below the level existing
without the presence of the intruding noise to 19.5 dB above the level before intrusion. Thus,
20 dB is a reasonable value to associate with a change from 0 to 100 percent impact. Such
a change in level would increase the percentage of the population that is highly annoyed by
40 percent of the total exposed population [ 31. Further, the data in the Levels Document
suggest that within these upper and lower bounds the relationship between impact and level
varies linearly; that is, a 5-dB excess (60 Ldn) constitutes a 25 percent impact and a 1 0-dB ex-
cess (65 Ldn) constitutes a 50 percent impact.
For convenience of calculation, percentages of impact may be expressed as Fractional
Impact (Fl). A F! of 1 .0 represents an impact of 100 percent, in accordance with the fol-
lowing formula:
(L-55) for L> 55
Fl = , (4-6)
0 forL 55
where L is the observed or measured Ldn of the environmental noise. Note that Fl can
exceed unity for exposures greater than Ldn = 75 dB.
The magnitude of the impact associated with a given level of traffic noise (Lh ) may
be assessed by multiplying the number of people exposed to that level of traffic noise by the
fractional impact associated with the level as follows:
P q = (F 1 1 )P 1 , (4-7)
where Pq is the magnitude of the impact on the population exposed to traffic noise Ld
and is numerically equal to the number of people, all of which would have a fractional
impact equal to unity (100 percent impacted). Fl 1 is the fractional impact associated with
a day-night noise level of Ldh over 55 dB, and P is the population exposed to this level of
traffic noise.
When assessing the total impact associated with traffic noise, the observed levels of
noise decrease as the distance between the source and receiver increase. The magnitude of
the total impact may be computed by determining the number of people exposed at each
level and summing over the resulting impacts. The total impact is given in terms of the
equivalent number of people impacted by the following formula:
4-15
-------
eq = P FI , (4-8)
i
where Fli is the fracti9nal impact associated with L n and P is the population associated
with In this study, the mid-level of each 5-dBA sector of levels above Ldn = 55 dB will
be used for in computing eq
The change in impact associated with regulations on the noise emissions from traffic
vehicles may be assessed by comparing the magnitude of the impacts, both with and without
regulations, in terms of the percent reduction in impact (h), which is calculated from the fol-
lowing expression:
= 100 [ Peg ( before) — ‘ eg (after) ]
eq (before)
The population figures (Pt) in Equation 4-7 are based on a survey in which the total popula-
lion exposed to outdoor noises of Ldn above 55 dB was estimated from measurements
taken at 100 sites throughout the United States [ 211. The sites were selected far enough
from freeway traffic and airports so that these sources of noise were not significant contri-
butors to the measured outdoor noise levels. Thus, urban street traffic was a dominant
noise source for each of the survey sites. Results from this study are given in Table 4-5.
Using the data contained in Table 4-5, a eq for existing traffic conditions of 34.6
million is calculated, as shown in Table 4-6. The Peqs associated with the previously calcu-
lated reductions in the average passby noise levels for urban street traffic presented in Tables
4-3 and 4-4 are predicted by shifting (reducing) the values of Ldn in Table 4-5 by the average
passby noise reduction of interest and performing computations similar to those shown in
Tal le 4-6. In following this procedure for estimating eq it is assumed that
• Reductions in the average passby noise level in urban street traffic will produce
equal reductions in the Ldn for the outdoor noise.
• The population in urban areas will remain constant.
The projected values of eq for urban street traffic noise are presented in Tables 4-7
and 4-8 for the years 1978, 1982, 1984, 1986, 1991, and 2001, for each of the regulatory
programs for new trucks given in Table 4-1. The results, as depicted in Table 4-7, pertain to
the noise red ictions presented in Table 4-3, in which no noise treatment of new automobiles,
motorcycles, and buses are assumed. Likewise, the results in Table 4-8 pertain to the noise
reductions presented in Table 4-4, in which the new truck regulations are assumed to be
4-16
-------
Table 4-5
Distribution of Urban Population at or Greater Than a Specified Ldn
Ldn
Cumulative
(in Millions of People)
Ldn
Cumulative
(in
Millions of People)
55
93.427
70
6.853
56
87.665
71
5.155
57
81.237
72
3.826
58
74.222
73
2.776
59
66.738
74
1,963
60
58.997
75
1.347
61
51.234
76
0.889
62
43.668
77
.
.559
63
36.542
78
.332
64
30.061
79
.187
65
24.320
80
.093
66
19.352
81
.039
67
15.200
82
.012
68
11.791
83
.002
69
9.046
84
.0
complimented by a 4 dBA reduction in passby noise levels from automobiles, motorcycles,
and buses.
Freeway Traffic Noise
The same methodology used to predict reductions in the average passby noise in urban
street traffic noise is used to predict reductions in freeway traffic noise levels.
4-17
-------
Table 4-6
Calculation of Equivalent Number of People Impacted by Urban Street Traffic Noise
.
L
Population Exposed to
L i or Higher
Pi
C
(millions)
Population Exposed to Levels
Between Ljj and Lijii’
Pi = — P ;
Fractional Impact
to Mid-Level
F l 1
Equivalent Number of
People Impacted
F 1 1 P 1
i?
60
65
70
75
80
93.4
59.0
24.3
6.8
1.3
0.1
34.4
34.7
17.5
5.5
1.2
0.1
0.125
0.375
0.625
0.875
1.125
1.375
4.3
13.0
10.9
4.9
1.4
0.1
(req = 34.6 million)
Vehicle noise levels in freeway traffic
The following types of noise sources are included in the freeway traffic noise prediction
model;
• Noise — treated and untreated automobiles.
• Unregulated medium and heavy trucks.
• Medium and heavy trucks regulated by the Interstate Motor Carrier regulations.
• Medium and heavy trucks regulated at not-to-exceed levels of 83, 80, 78, or 75
dBA as measured in accordance with SAE J366b test procedure.
The assumed median noise levels, standard deviations, and average passby noise levels
for each type of noise source are given in Table 4-9. The average passby noise levels are
computed using Equation 4-4.
Median Noise Levels for Trucks
For purposes of predicting freeway traffic noise, medium and heavy trucks are grouped
together. The median level for medium and heavy truck passbys is approximately 85.5 dBA
when the average speed is 57 mph [ 61. The Interstate Motor Carrier regulations are assumed
to lower the median passby level for existing trucks by 1.0 dBA. The median levels for
trucks subject to new truck regulations are computed by adding tire noise levels at 55 mph to
4-18
-------
Table 4-7
Equivalent Number of People Impacted (req) by Urban Street Traffic Noise —
Without Reductions in Noise from Automobiles, Motorcycles and Buses
— Millions
Calendar Year
RegulatoryOption
A
B
C
D
E
F
G
1978
3.1.4
31.4
31.4
31.4
31.4
31.4
31.4
1982
29.3
29.3
29.3
29.3
29.3
29.3
29.3
1984
27.6
27.6
27.6
28.4
27.6
28.4
28.4
1986
25.6
26.4
26.0
26.8
26.4
27.3
28.4
1991
23.3
23.5
24.4
24.4
25.2
25.6
27.6
2001
22.0
22.0
23.5
23.5
24.8
24.8
27.6
H
1
J
K
L
M
N
31.4
31.4
31.4
31.4
31.4
31.4
31.4
31.4
29.3
29.3
29.3
29.3
29.3
29.3
31.4 .
28.4
28.4
27.6
27.6
27.6
27.6
31.4
27.3
28.4
26.0
26.0
26.0
26.0
31.4
24.4
24.4
23.5
23.5
23.5
23.5
31.4
22.0
22.5
22.5
22.5
22.5
22.5
the median levels for engine-related noise from trucks cruising in urban street traffic. The
engine-related median noise level is assumed to be 6.5 dBA below the regulatory level.
The 6.5 dBA factor includes 2.5 dBA for designing below the regulatory level, 3.0
dBA for differences in testing and typical cruising conditions, and 1.0 dBA for differences
in test and typical roadside sites. An 81 -dBA median tire noise level is assumed [ 7], cor-
responding to the peak level observed at 50 ft for a single unit (two-axle) loaded truck
with half-worn tires passing by at 55 mph [ 101. No corrections for the differences in test
and roadside sites are assumed for tire noise, since most of the tire noise is generated at
points near the road surface, so that the noise suffers few reflections from the surface be-
tween the truck and observer.
Median Noise Levels for Automobiles
A median roadside noise level of 75 dBA is given in Table 4-9 for untreated auto-
mobiles in freeway traffic observed at 50 ft from the centerline of the automobile passby.
This level is an average computed from the following levels as reported in studies on
4-19
-------
Table 4-8
Equivalent Number of People Impacted ( 1 eq) by Urban Street Traffic Noise —
With a 4 dBA Reduction in Noise from Automobiles, Motorcycles and Buses
1 ’eq — Millions
Calendar Year•
Regulatory Option
1978
1982
1984
1986
1991
2001
A
B
C
D
E
F
G
H
1
J
K
L
M
N
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
29.7
24.0
24.0
24.0
24.0
24.0
24.0
24.0
27.3
24.0
24.0
24.0
24.0
24.0
24.0
19.7
19.7
19.7
21.0
19.7
21.0
21.0
24.4
21.0
21.0
19.7
19.7
19.7
19.7
15.4
17.0
16.3
17.5
17.0
17.9
19.4
23.3
17.9
19.4
15.7
15.7
15.7
15.7
12.0
12.3
13.4
13.6
15.0
15.2
18.7
23.3
13.6
13.4
12.3
12.3
12.3
12.3
9.9
9.9
12.0
12.0
14.1
14.1
18.4
23.3
10.2
10.5
10.8
10.8
10.8
10.8
Table 4-9
Assumed Passby Noise Levels (dBA) for Vehicle in Freeway Traffic
Type of Vehicle
Freeway — 55 mph
L 50
a
La
1. Medium and Heavy Trucks
(a) Unregulated
(b) Interstate Motor Carrier Regulations
(c) 83 dBA New Truck Regulation
(d) 80 dBA New Truck Regulation
(e) 78 cIBA New Truck Regulation
(1) 75 dBA New Truck Regulation
2. Automobiles
(a) Untreated
(b) Treated
85.5
84.5
82.3
81.7
81.5
81.2
75
71
3.5
3.0
2.0
2.0
2.0
2.0
3.5
2.0
86.9
85.5
82.8
82.2
82.0
81.7
76.4
71.5
4-20
-------
automobile passby levels in freeway traffic: 74.2 dBA [ 11], 78.9 dBA [ 12], 78.6 dBA [ 22],
73 dBA [ 13], 71.5 dBA [ 13], and 72.6 dBA [ 18]. Assuming that the median level for
treated new automobiles will be at least as low as the lowest of the reported values, a
median 1 vel of 71 dBA is used for treated automobiles.
Standard Deviations
A standard deviation of 3.5 dBA given in Table 4-9 for untreated vehicles in free-
way traffic is taken from the same study [ 1 8] that reported a standard deviation for
passby noise of 3.7 dBA for vehicles in urban street traffic. For treated vehicles, a stan-
dard deviation identical to those used for urban street noise is used for freeway noise levels.
Reduction of average freeway traffic noise levels
From the traffic population percentage data for freeway traffic given in Appendix B
and from the average passby noise levels given in Table 4-9, the average passby noise level
for freeway traffic noise levels are computed using Equation 4-5. Reduction of the
average passby noise levels from average passby noise levels for existing freeway traffic are
presented in Tables 4-10 and 4-li for the years 1978, 1982, 1984, 1986, 1991, and 2001
for each of the regulatory programs given in Table 4-1. In Table 4-10 it is assumed that
automobiles are not treated. Thus, the new truck regulations are assumed to be comple-
mented only by the Interstate Motor Carrier regulations. In Table 4-1 1, it is assumed
that new truck and Interstate Motor Carrier regulations complemented by noise treatments
on new automobiles, which will reduce their passby noise levels by 4 dBA.
For purposes of predicting the impact of freeway traffic noise, the total . vehicle popu-
lation is assumed to remain constant. This assumption is anticipated to have little effect on
the predictions, since changes in the total vehicle populations should have an equal effect on
all of the predictions shown in Tables 4-10 and 4-11.
Reduction in noise impact from freeway traffic
The equivalent number of people impacted (Peq) by freeway traffic noise is computed
using Equation 4-8. The population exposed to different levels of freeway noise, expressed
in terms of Ldn, is estimated from predictions of noise levels as a function of distance and
population densities near freeways.
421
-------
Table 4-10
Reduction in Freeway Traffic Noise —. Without Reductions in Noise from Automobiles
Regulatory Option
Reduct
ion in Average Noise c iBA at 50 Ft
Calendar Year
1978
1982
1984
1986
1991
2001
A
0.7
1.2
1.5
1,7
2.0
2.1
B
0.7
1.2
1.5
1.7
2.0
2.!
C
0.7
1.2
1.5
1.7
1.9
2.0
D
0.7
1.2
1.4
1.6
1.9
2.0
E
0.7
1.2
1.5
1.7
1.8
1.9
F
0.7
1.2
1.4
1.6
1.8
1.9
G
0.7
1.2
IA
1.6
1.7
1.8
H
0.7
0.7
0.7
0.7
0.7
0.7
1
0.7
1.2
1.4
1.6
1.9
2.1
j
0.7
1.2
1.4
1.6
1.9
2.1
K
0.7
1.2
1.5
1.7
2.0
2.1
L
0.7
1.2
1.5
1.7
2.0
2.1
M
0.7
1.2
1.5
1.7
2.0
2.1
N
0.7
1.2
1.5
1.7
2.0
2.1
For existing freeway traffic, the distances (in miles) from freeways at which different
noise levels occur are computed according to Equation 4-10. Equation 4-10 was derived from
the data shown in Figure 4-2, which was derived from design data for freeways [ 281.
L j = 30— 30 log di. (4-10)
Differences in the distances (. d ) for levels above Ldn = 55 dB and 5 dB apart are computed.
In computing a minimum distance of 70 ft (0.013 mi) is used, since it is assumeri that
there are no residents closer than 70 ft from freeways. Assuming that
1. There are 8000 miles of freeways in urban areas [ 231,
2. People are exposed on both sides of freeways,
3. The .. average population density in residential urban areas is 5000 people/mi 2
[ 24], and
4. One-half of urban areas are residential,
4-22
-------
Table 4-1 1
Reduction in Freeway Traffic Noise With a 4 dBA Reduction in Noise from Automobiles
Regulatory Option
Reduction in Average Noise —
cIBA at 50 Ft
Calendar Year
1978
1982
1984
1986
1991
2001
A
1.0
2.5
3.5
4.3
4.8
5.0
B
1.0
2.5
3.5
4.2
4.8
5.0
C
1.0
2.5
3.5
4.3
4.7
4.8
D
1.0
2.5
3.4
4.2
4.6
4.8
E
1.0
2.5
3.5
4.2
4.6
4.7
F
1.0
2.5
3.4
4.2
4.6
4.7
G
1.0
2.5
3.4
4.0
4.3
4.4
H
1.0
1.8
2.2
2.6
2.6
2.6
I
1.0
2.5
3.4
4.2
4.7
5.0
J
1.0
2.5
3.4
4.0
.
4.7
5.0
K
1.0
2.5
3.5
4.3
4.8
5.0
L
1.0
2.5
3.5
4.3
4.8
5.0
M
1.0
2.5
3.5
4.3
4.8
5.0
N
1.0
2.5
3.5
4.3
4.8
5.0
the following equation is used to calculate the number of people living within 5 dB sectors
above Ldn = 55 dB near freeways:
= d (80O0)(2)(50c 0)(0.5), (4-Il)
which equals 40.0 ( d ) million people.
Using Equations 4-10 and 4-1 Ito calculate Peq for existing freeway traffic results in a
value of 2.72 million, as shown in Table 4-12. Using data on the population exposed to different
levels of outdoor noise derived from measurements of outdoor noise taken near freeways [ 211, a Peq
of 2.77 million was computed, which is in agreement with the value computed in Table 4-12.
Predictions of associated with the freeway traffic noise reductions presented in
Tables 4-10 and 4-1 1 are computed following the methodology just discussed, with the fol-
lowing modification of Equation 4-10:
L 11 — 30 —30logd , (4-12)
4-23
-------
80
2
0.02 0.03 0.05 0.07 0.10 0.20
DISTANCE F ROM RIGHT-OF-WAY MILES)
Figure 4-2. Noise Environment Adjacent to Urban Freeway.
where represents the reduction in the average passby noise levels in freeway traffic of interest
and d ’ is the distance from the freeway where the level — occurs. The predicted values
of Peq for freeway traffic are presented in Tables 4-13 and 4-14 for each of the regulatory
options for new trucks given in Table 4-1. The data included in Table 4-13 are derived from
the noise reduction data in Table 4-10, in which it is assumed that automobiles are not treated.
The results presented in Table 4-14 are derived from the noise reductions given in Table 4-1 1,
in which the new truck regulations are assumed to be supported by noise treatment of new
automobiles.
Total noise impact from urban Street and freeway traffic
The total noise impact in urban areas due to urban street and freeway traffic is de-
rived by adding the equivalent numbers of people impacted by urban street and by freeway
traffic noise. Combining the data contained in Tables 4-7 and 4-12 yields the total noise
impact shown in Table 4-15 for different regulatory programs on new trucks, when it is
assumed that the noise emissions of other types of vehicle are not reduced.
La 30 30Iogd
70 -
0
60
7200 vph
10% TRUCKS
90% AUTOS
55 mph
0.01
I I I I I I I I
4-24
-------
Table 4-12
Calculation of Equivalent Number of People (In Millions)
Impacted by Freeway Noise
Population Exposed to Levels
d• ‘=10 30- 6 - Between and L J I Fractional Impact Equivalent Number of
1 30 Mi’ Pj to Mid-Level People Impacted
(miles) 1 (millions) 2 F l 1 FIjP 1
55 0.147 0.047 1.88 0.125 0.24
60 0.100 0.032 1.28 0.375 0.48
65 0.068 0.022 0.88 0.625 0.55
70 Q.046 0.014 0.56 0.875 0.49
75 0.032 0.010 0.40 1.125 0.45
80 0.022 0.007 0.28 1.375 0.38
85 0.015 0.002 0.08 1.625 0.13
90 0.013 — — — —
eq = 2.72
‘Stop d 1 ’at 70 ft = 0.013 ml.
= dj(8000 mi of freeway) X 2 sides X (5000 people/mi 2 ) X 0.5 = 40 X 106 Mi.
Table 4-13
Equivalent Number of People Impacted (req) by Freeway
Traffic Noise — Without Reductions in Noise from Automobiles
Regulatory Option
A
B
C
D
F
F
G
1 eq — Millions
Calendar Year
1978
2.56
2.56
2.56
2.56
2.56
2.56
2.56
1982
2.40
2.40
2.40
2.40
2.40
2.40
2.40
1984
2.32
2.32
2.32
2.35
2.32
2.35
- 2.35
1986__—
2.29
2.29
2.29
2.30
2.29
2.30
2.30
1991
2.21
2.21
2.23
2.23
2.25
2.25
2.29
2001
2.19
2.19
2.21
2.21
2.23’
2.23
H
I
J
K
L
M
N
2.56
2.56
2.56
2.56
2.56
2.56
2.56
2.56
2.40
2.40
2.40
2.40
2.40
2.40
2.56
2.35
2.35
2.32
2.32
2.32
2.32
2.56
2.30
2.30
2.29
2.29
2.29
2.29
2.56
2.23
2.23
2.21
2.21
2.21
2.21
2.25
2.56
2.19
2.19
2.19
2.19
2.19
2.19
4-25
-------
Table 4-14
Equivalent Number of People Impacted ( 1 eq) by Freeway
Traffic Noise — With a 4 dBA Reduction in Noise from Automobiles
“eq — Millions
Regulatory Option
Calendar Year
1978
—_1982
1984
1986
1991
2001
A
2.49
2.10
1.86
1.73
1.65
1.62
B
2.49
2.10
1.86
1.75
1.65
1.62
C
2.49
2.10
1.86
1.73
1.66
1.65
D
2.49
2.10
1.92
1.75
1.68
1.65
E
2.49
2.10
1.86
1.75
1.68
1.65
F
2.49
2.10
1.92
1.75
1.68
1.65
G
2.49
2.10
1.92
1.79
1.73
1.71
H
2.49
2.25
2.17
2.08
2.08
2.08
I
2.49
2.10
1.92
1.75
1.66
1.62
J
2.49
2.10
1.92
1.79
1.66
1.62
K
2.49
2.10
1.86
1.73
1.65
1.62
L
2.49
2.10
1.86
1.73
1.65
1.62
M
2.49
2.10
1.86
1.73
1.65
1.62
N
2.49
2.10
1.86
1.73
1.65
1.62
Assuming that the noise emissions from vehicles other than medium and heavy trucks
are reduced by 4 dBA, the total noise impact due to both urban street and freeway traffic is ob-
tained by summing the data in Tables 4-8 and 4-14 to yield the results shown in Table 4-16.
The percent reductions in the “eq for existing urban traffic (37.3 million) in Tables 4-15 and
4-16 are given in Tables 4-17 and 4-18, respectively. For a graphic comparison, the results
in Tables 4-17 and 4-18 are plotted in Figures 4-3 and 4-44. For the calendar years 1984,
1986, 1991, and 2001, the total population in urban areas exposed to different outdoor
traffic noise levels is given for each option in Figures 4-5 through 4-8.
Increasing the lead time by 2 years (regulatory option A to B, or E to F) produces
losses in benefits ‘of approximately 1 to 2 percent in 1 991. Larger increases in lead times
(regulatory options A to I) produce higher losses in benefits of 2.9 to 4.5 percent in 1991.
Dropping the 75-dBA regulation (regulatory option A to E) shows losses of 6.1 to 8.8 per-
cent in 1991. Relaxing the 75-dBA regulation to 78 dBA (regulatory option A to C)
produces about half these losses (2.9 to 4.0 percent) in 1 991. The relaxation of the 75-dBA
regulation to 78 dBA yields losses similar to the losses associated with the longer lead times
in option 1. Dropping the 80-dBA regulation (regulatory option E to G) results in losses of
6.7 to 9.9 percent in 1991, which are slightly higher than the losses associated with dropping
4-26
-------
Table 4-15
Total Equivalent Number of People Impacted (req) by Urban Traffic Noise
(Urban Street or Freeway) — Without Reductions in Noise from Nontruck Vehicles
Regulatory Option
1 eq — Millions
Calendar Year
1978
1982
1984
1986
1991
2001
A
34.0
31.7
29.9
27.9
25.5
24.2
B
34.0
31.7
29.9
28.7
25.7
24.2
C
34.0
31.7
29.9
28.3
26.6
25.7
D
34.0
31.7
30.8
29.1
26.6
25.7
E
34.0
31.7
29.9
28.7
27.4
27.0
F
34.0
31.7
30.8
29.6
27.8
27.0
G
34.0
31.7
30.8
30.7
29.9
29.8
H
34.0
34.0
34.0
34.0
34.0
34.0
i
34.0
31.7
30.8
29.6
26.6
24.2
j
34.0
31.7
30.8
30.7
26.6
24.7
K
34.0
31.7
29.9
28.3
25.7
24.7
L
34.0
31.7
29.9
28.3
25.7
24.7
M
34.0
31.7
29.9
28.3
25.7
24.7
N
34.0
31.7
29.9
28.3
25.7
24.7
the 75-dBA regulation. Eliminating the 80-dBA regulation in regulatory option C to produce
option D results in small losses in benefits (0.0 percent to 0.5 percent) in 1991. Total losses for
regulatory option D relative to option A are 2.9 to 4.5 percent in 1991. Eliminating the 80-
dBA regulation in regulatory option B to produce option J results in losses of 2.4 to 3.2
percent in 1991. These losses are larger than the losses associated with the elimination of the
80-dBA regulation from option C.
Because medium gasoline trucks are regulated at 75 dBA in 1983 in regulatory options
K, L, M and N and they comprise a majority of the medium and heavy truck population in
low speed traffic, the benefits for these options are nearly the same as the benefits for
option A. For example, losses in benefits of 0.5 to 0.8 percent occur for option K, L, M
andNin 1991.
ACTIVITY INTERFERENCE BY INDIVIDUAL (SINGLE-EVENT) TRUCK PASSBY NOISE
The activity interference produced by noise from single events depends upon the type
of activity in which the observer is engaged as well as the location of the observer. For
4-27
-------
Table 4-16
Total Equivalent Number of People Impacted ( 1 eq) by Urban Traffic Noise
(Urban Street or Freeway) — With a 4 dBA Reduction in Noise from Nontruck Vehicles
Regulatory Option
1 eq — Millions
Calendar Year
1978
1982
1984
1986
1991
2001
A
32.2
26.1
21.6
17.1
13.6
11.5
B
32.2
26.1
21.6
18.8
13.9
11.5
C
32.2
26.1
21.6
18.0
15.1
13.6
D
32.2
26.1
22.9
19.3
15.3
13.6
E
32.2
26.1
21.6
18.8
16.7
15.7
p
32.2
26.1
22.9
19.7
16.9
15.7
G
32.2
26.1
22.9
21.2
20.4
20.1
H
32.2
29.5
26.6
25.4
25.4
25.4
I
32.2
26.1
22.9
19.7
15.3
11.8
J
32.2
26.1
22.9
21.2
15.1
12.1
K
32.2
26.1
21.6
17.4
13.9
12.2
L
32.2
26.1
21.6
17.4
13.9
12.4
M
32.2
26.1
21.6
17.4
13.9
12.2
N
32.2
26.1
21.6
17.4_—
13.9
12.4
purposes of this analysis, interference with activities caused by single events is assumed to
occur when the noise level exceeds by 10 dBA the maximum acceptable ambient noise level
for the specified activity [ 3]. Acceptable ambient noise levels for different indoor and
outdoor activities have been identified [ 5]. Thus, to characterize the unacceptability of
sin 1e-truck passbys, it is necessary to determine the minimum acceptable distance from
truck passbys to an observer at which the truck noise levels are 10 dBA above the acceptable
ambient noise level for specified activities, for both unregulated and regulated trucks.
Activity Interference Levels
Three activities are considered in this analysis: normal conversation, thought process,
and sleeping. Acceptable ambient noise levels for these activities, both indoors and out-
doors, are shown in Table 4-19. For activities indoors, noise attenuation due to transmission
through exterior structures is considered for both opened and closed windows. With win-
dows closed, an attenuation of 25 dBA is assumed, and with windows open, an attenuation
of 15 dBAis assumed [ 5, 25].
4-28
-------
Table 4-17
Percent Reduction in Total Equivalent Number of People Impacted by Urban Traffic Noise
(Urban Street or Freeway) — With a 4 dBA Reduction in Noise from Nontruck Vehicles
Regulatory Option
1 Calendar Year
1978
1982
1984
1986
1991
2001
A
8.8%
15.0%
19.8%
25.2%
31.6%
35.1%
B
8.8
15.0
19.8
23.0
31.1
35.1
C
8.8
15.0
19.8
24.1
28.7
31.1
D
8.8
15.0
17.4
22.0
28.7
31.1
E
8.8
15.0
19.8
23.0
26.5
27.6
F
8.8
15.0
17.4
20.6
25.5
27.6
G
8.8
15.0
17.4
17.7
19.8
21.1
H
8.8
8.8
8.8
8.8
8.8
8.8
1
8.8
15.0
17.4
20.6
28.7
35.1
j
8.8
15.0
17.4
17.7
28.7
33.8
K
8.8
15.0
19.8
24.1
31.1
33.8
L
8.8
15.0
19.8
24.1
31.1
33.8
M
8.8
15.0
19.8
24.1
31.1
33.8
N
8.8
15.0
19.8
24.1
31.1
33.8
Maximum Activity-Interference Distances
In this context, Maximum Activity-Interference Distance is the distance between a truck
producing noise and an observer, when the truck passby produces a noise level at the observer
that is 10 dBA in excess or the acceptable levels for various outdoor or indoor activities
specified in Reference 5. By assuming that the noise level from an individual truck decreases
6 dBA with each doubling of distance, the maximum activity-interference distance (dm)
is computed from the following equation:
Lj — 20 log 50 = L + Na + 1OdBA = Lc (4-13)
where Lj is the truck passby noise level at 50 ft, L is the acceptable noise level given in
Table 4-19, Na is the noise attenuation for indoor situations and L is the activity-interfer-
ence level.
Activity-interference distances from truck passbys are determined only at low speeds
(urban street). The differences in the noise levels for unregulated and regulated trucks at
high speeds are small enough that little differences in activity-interference distances are ex-
pected for trucks in freeway traffic.
4-29
-------
Table 4-18
Percent Reduction in Total Equivalent Number of People Impacted by Urban Traffic
Noise (Urban Street or Freeway) — With a 4 dBA Reduction in Noise From Nontruck Vehicles
Regulatory Option
A
B
C
D
E
F
G
Calendar Year
1978
13.7%
13.7
13.7
13.7
13.7
13.7
13.7
1982
30.0%
30.0
30.0
30.0
30.0
30.0
30.0
1984
42.1%
42.1
42.1
38.6
42.1
38.6
38.6
1986
54.2%
49.6
51.7
48.2
49.6
47.2
43.2
1991
63.5%
62.7
59.5
59.0
55.2
543
45.3
2001
69.2%
69.2
63.5
63.5
57,9
579
46.1
31.9
68.4
67.6
67.3
66.8
67.3
66.8
H
I
j
K
L
M
N
13.7
13.7
13.7
13.7
13.7
13.7
13.7
20.9
30.0
30.0
30.0
30.0
30.0
30.0
28.7
38.6
38.6
42.1
42.1
42.1
42.1
31.9
47.2
43.2
53.4
53.4
53.4
53.4
31.9
59.0
59.5
62.7
62.7
62.7
— 62.7
Table 4-20 shows the median passby noise levels for low speed trucks. For existing
trucks and trucks subject to the Interstate Motor Carrier regulations, the median levels
given in Table 4-2 are weighted according to the truck population of 1 percent heavy and 6
percent medium trucks. For trucks subject to not-to-exceed new truck regulatory levels of
83, 80, 78, and 75 dBA, the median passby levels for accelerating trucks are used in com-
puting the levels given in Table 4-20. That is, the engine-related noise levels are assumed to
be 4.5 dBA below the regulatory levels. The 4.5 dBA difference includes 2.5 dBA for design-
ing below regulatory levels, 1.0 dBA for differences in test and typical acceleration conditions
and 1.0 dBA for differences in test and typical roadside sites. The median truck passby
levels shown in Table 4-20 are derived by adding a 66-dBA tire noise level to the engine-re-
lated noise. The level used for the 83-dBA trucks is the weighted average of the levels de-
rived for accelerating heavy and medium trucks. Predictions of the 10, 1, and 0.1 percen-
tiles for truck passby levels are computed from the median levels by assuming that the
levels have a Gaussian distribution with a standard deviation of 1.5 dBA. A standard devia-
tion of 1.5 dBA for accelerating trucks is selected so that the difference in the median road-
side level and regulatory level is equal to three standard deviations.
Using the passby truck noise levels contained in Table 4-20 and the acceptable activity-
interference levels contained in Table 4-19, the maximum activity-interference distances for
4-30
-------
O
w
I-
w
-J
0
w
U-
0
w
I—
‘U
-J
>
0
‘U
z
2
0
I-
C-)
0
U i
I-
2
w
0
L U
0
CALENDAR YEAR
Figure 4-3. Percent Reduction in Total Equivalent Number of
People Impacted by Urban Traffic Noise (Urban Street or
Freeway) — Without Reductions in Noise from Nontruck Vehicles
the eight situations are computed using Equation 4-12. Figures 4-9 through 4-14 present
the largest distances over which disruption of activities occurs. Because homes are assumed
to be situated at least 70 ft from the centerline of the truck passby, data depicted in
Figures 4-9 through 4-14 are truncated at 70 ft.
Observation of the results in Figures 4-9 through 4-14 indicates that the distances
requisite to preclude activity-interference should be reduced almost in half by the
1978 1982 1984 1986 1991 2001
4-31
-------
LU
I —
0
LU
-J
0
0
LU
a-
U-
0
uJ
z
I-
z
LU
-J
>
5
C
LU
0
0
0
U i
I-
LU
0
LU
a-
CALENDAR YEAR
Figure 4-4. Percent Reduction in Total Equivalent Number of People
Impacted by Urban Traffic Noise (Urban Street or Freeway) —
With a 4 dBA Reduction in Noise from Nontruck Vehicles
Interstate Motor Carrier Regulations. The changes in the distances with reductions in the
new truck regulatory levels diminish for levels 80 dBA and below. Results for trucks at
high speed and cruising trucks at low speeds will show smaller differences in the maximum
distances for new trucks regulated at levels below 83 dBA.
1978 1982 1984 1986 1991
2001
4-32
-------
CALENDAR YEAR 1984
OPTION
80 4 —o A,B,C,E,K,L,M+N
d o-—-——o D,F,G,I+J
70.
o
1
U.
O
60-
\\\
“I .
-J
“,
—50.
2
2
I—.
40 - \ k
O
0 .
U i
30 -
20-
10 —
‘S
‘ 5’
C I I
55-60 60-65 65-70 70-75 75-80 80-85
OUTDOOR TRAFFIC NOISE LEVEL t dn
Figure 4-5. Urban Population vs Outdoor Traffic Noise Level in 1984
IN-CAB NOISE
Reductions in exterior truck noise are expected to produce reductions in the noise
inside the truck cab. These expected reductions in in-cab noise should reduce the threat
to operator hearing damage and should decrease disruption of
• Speech communication
• Reception of warning signals
• Listening to music or a radio.
4-33
-------
90
80
10
60
50
40
w
-J
a.
0
w
a.
U.
0
U)
z
0
-J
-
z
0
I
Figure 4-6. Urban Population vs Outdoor Traffic Noise Level in 1986
In addition, reductions in the noise in the cabs of new trucks will decrease the effort
required to comply with Bureau of Motor Carrier Safety noise exposure regulations.
Existing tn-Cab Noise Levels
The equivalent noise levels estimated Using measured data taken near the operator’s
right ear in three heavy diesel trucks with the windows closed under normal operating
conditions 9J are 84, 88, and 86 dBA over periods of about 9, 7, and II hours, respectively.
CALENDAR YEAR 1986
OPTI ON
p A K,L.M+N
O—--—-—O Bi-E
0- .OC
A —AD
A AG+J
OH
55-60 60-65 65-70 70-75 75-80
OUTDOOR TRAFFIC NOISE LEVEL (Ldn)
80-85
4-34
-------
90
80
70
60
50
w
-J
0
uJ
a-
U-
0
‘1,
2
0
-J
z
0
F°
Figure 4-7. Urban Population vs Outdoor Traffic Noise Level in 1991
In-cab noise levels for gasoline trucks are expected to be lower by approximately 5 dBA
or more. These data indicate that levels inside most medium and heavy trucks will probably
be higher than the level of Leq(8) 75 dBA identified by EPA as requisite to protect hearing [ 3].
In-Cab Noise for Quieted Trucks
With the following relations, it would be possible to estimate the average interior noise
levels under normal operating conditions for quieted trucks with known SAE J366b exterior
noise levels.
CALENDAR YEAR 1991
OPTION
\
0 .0
A
A
p p
A
B, K, L, M+N
c+J
0+I
E
F
G
H
30
20
\
55-60
60-65 65-70 70-75
OUTDOOR TRAFFIC NOISE LEVEL (Ldfl)
4-35
-------
go
w
-J
0-
0
I L ’
&
U.
0
U,
z
0
-J
-3
z
0
I-
C
- 3
a-
0
a-
0
LU
U)
o
a.
x
LU
80
70
80
50
40
A’
\
1
Figure 4-8. Urban Population vs Outdoor Traffic Noise Level in 2001
• Relation between exterior noise levels measured in accordance with the SAE
1366b test procedure and interior noise levels observed during tests.
• Relation between interior noise levels observed under SAE J366b test conditions
and levels under normal operating conditions.
SAE J366b exterior and interior levels
Data taken concerning exterior and interior noise levels for heavy trucks operated in
accordance with the SAE J366b test procedure are plotted in Figure 4-15 . Most of the data
CALENDAR YEAR 2001
OPTION
0 -o
A.
p
A+B
CI-D
E+F
G
H
J, K,L,M+N
‘ C
55-60 60-65 65-70 70-75 75-80
OUTDOOR TRAFFIC NOISE LEVEL (Ldfl)
80-85
4-36
-------
Table 4-19
Noise Levels from Individual Truck Passbys That Interfere With Activities
Situation
Acceptable Outdoor
Ambient Noise
Level (La)
Noise
Reduction
(Na)
Annoyance
Criteria
Individual Truck Passby
Noise Levels That
Interfere With Activities
at 50 Ft (La)
Normal conversation
Indoors — windows closed
Normal conversation
Indoors — windows open
Thought process
Indoors — windows closed
Thought process
Indoors — windows open
Sleeping
Indoors — windows closed
Sleeping
Indoors — windows open
Normal conversation
Outdoors
Thought process
Outdoors
60 dBA
60 dBA
45 dBA
45 dBA
40 dBA
40 dBA
60 dBA
51 dBA
25 dBA
15 dBA
25 dBA
15 dBA
25 dBA
15 dBA
0 dBA
OdBA
10 dBA
10 dBA
10 dBA
10 dBA
10 dBA
10 dBA
10 dBA
IOdBA
95 dBA
85 dBA
80 dBA
70 dBA
75 dBA
65 dBA
70 dBA
61 dBA
Table 4-20
Percentile Noise Levels for Individual Truck Passbys
Truck Type
Percentile Passby Noise Levels
c
L 50
L 10
L 1
L 0 . 1
Existing trucks
Interstate motor carrier trucks
83 dBA regulated trucks
80 dBA regulated trucks
78 dBA regulated trucks
75 dBA regulated trucks
83.5 dBA
78.2 dBA
77.2 dBA
76.0 dBA
74.2 dBA
71.8 dBA
88.2 dBA
82.0 dBA
79.1 dBA
77.9 cIBA
76.1 dBA
73.7 dBA
91.8 dBA
84.9 dBA
80.5 dBA
79.3 dBA
77.5 dBA
75.1 dBA
94.9 dBA
87.5 dBA
81.8 dBA
80.6 dBA
78.8 dBA
76.4 dBA
3.7 dBA
3.0 dBA
1.5 dBA
1.5 cIBA
1.5 dBA
1.5 dBA
in Figure 4-15 are for existing unquieted trucks [ 91 and show little correlation between ex-
terior and interior levels. Only three of the data points in Figure 4-15 are for quieted trucks.
The reduction in the exterior noise levels for the Freightliner DOT Quiet Truck from 88 to
75 dBA was accompanied by a reduction in the interior noise level from 93 to 74 dBA [ 26].
4-37
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NORMAL CONVERSATION—INDOORS—WINDOWS OPEN
190
170 -
150 -
130
110 -
90
70
50
0 EXISTING TRUCKS —
0—— ——0 INTERSTATE MOTOR
CARRIER TRUCKS, 83,
80, 78. AND 75 cIBA
TRUCKS
L 50 L 10 L 1 L 01
PERCENTILE TRUCK NOISE LEVELS
Figure 4-9. Maximum Activity-Interference Distances for Normal
Conversation Indoors With Windows Closed
THOUGHT PROCESS—INDOORS—WINDOWS CLOSED
L 50 L 10 L 1 L 01
PERCENTILE TRUCK NOISE LEVELS
Figure 4-10. Maximum Activity-Interference Distances for Thought
Process Indoors With Windows Closed
I I I - I
U i
0
z
1<
>0
— w
I-c)
- Ii.
XW
< I-
270
230
ui 190
1- 0
150
Ui
U-
XW
<1-
70
310
0 —OEXISTINGTRUCKS
0— ———o INTERSTATE MOTOR
CARRIER TRUCKS
A- - —A 83 ,BO,78AND75dBA
TRUCKS
I I I I I I I
4-38
-------
800 -
700 -
600 -
500
400
300
200
100 -
0
THOUGHT PROCESS—INDOORS—WINDOWS OPEN
NORMAL CONVERSATION—OUTDOORS
,0
I I I I I
L 50 L 10 L 1 L 01
PERCENTILE TRUCK NOISE LEVELS
Figure 4-11. Maximum Activity-Interference Distances for Thought Process Indoors
With Windows Open and Normal Conversation Outdoors
SLEEPING—INDOORS—WINDOWS CLOSED
-Q EXISTING TRUCKS
0— — — —O INTERSTATE MOTOR
CARRIER TRUCKS
83dBATRUCKS
A ———— A 8OdBATRLJCKS
D 78 dBA TRUCKS
3——-——C 75dBATRUCKS
Figure 4-12. Maximum Activity-Interference Distances for Sleeping Indoors
With Windows Closed
0 EXISTING TRUCKS
o.— — — —o INTERSTATE MOTOR
CARRIER TRUCKS
A- iA 83dBATRUCKS
A————iA 8OdBATRUCKS
0 0 78dBA TRUCKS
D————0 75dBATRUCKS
w
0
z
1<
—w
xw
U i
C.)
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1<
>0
—Ui
1-0
0 z
. UJ
w
LI
XLU
-------
° — —0 EXISTING TR ]
INTERSTATE MOTOR I
CARRIER TRUCKS I
A— —.A83dBATRUCKS I
80 dBA TRUCKS I
• —a 78 dBA TRUCKS
0-—..__. _75dBATPU J
Figure 4-13. Maximum Activity-Interference Distances for Sleeping Indoors
With Windows Open
0 —0 EXISTING TRUCKS
O-—__. INTERSTATE MOTOR
CARRIER TRUCKS
A— —a 83dBATRIJCKS
-———- 8OdBATRUCKS
— —0 78 dBA TRUCKS
0---— .a 75dBATRUCKS
Figure 4-14. Maximum Activity-Interference Distances for Thought Process Outdoors
La
0
XLU
I-
La
C.,
II
10 1 0.i
PERCENTILE TRUCK NOISE LEVELS
PERCENTILE TRUCK NOISE LEVELS
4-40
-------
I 0 FREIGI-ITLINER DOT QUIET TRUCK (REF 26)
92 WHITE MOTORS DOT QUIETTRUCK (REF 27)
[ a UNQUIETED TRUCKS (REF 9 )
90 - ________________________________________
-j
88- A 0
A
86.
78.
76
0
74 I I I I I I I I I I
72 74 76 78 80 82 84 86 88 90 92 94 96
INTERIOR SAE J366b NOISE LEVEL — WINDOWS CLOSED (dBA)
Figure 4-15. Exterior and Interior Noise Levels Observed Under
SAE J366b Test Conditions
On the White Motors DOT Quiet Truck, the reduction in exterior noise from 84 to 79 dBA
produced a reduction in interior noise from 92 to 78 dBA [ 27]. However, a further
reduction in exterior noise from 79 to 76 dBA resulted in an increase in the interior noise
level from 78 to 90 dBA [ 271. Therefore, data from the DOT Quiet Truck Program does
not show a good correlation between exterior and interior noise levels.
Interior SAE J366b levels and levels for normal operating conditions
On the average, the interior levels under SAE J366b test conditions were found to be
approximately 1 dBA higher than the interior levels observed with the engine at maximum
speed (high idle) and the truck stationary [ 9]. On three heavy diesel trucks, the interior
level at high idle was approximately 4 dBA higher than the average level observed under
normal operating conditions [ 9]. These limited amounts of data indicate that the interior
level under SAE J366b test conditions is approximately 5 dBA higher than the average
4-41
-------
in-cab noise level under normal operating conditions. Applying this 5-dBA factor to the three
interior noise levels given in Figure 4-15 for the quieted trucks shows that in two cases the
average interior levels under typical operating conditions would probably be less than 75
dBA.
In-Cab Noise Levels for Regulated Trucks
The paucity of data from which relations between exterior and interior noise levels
can be drawn prevents reliable estimates of the in-cab noise levels for medium and heavy
trucks complying with the EPA regulations. However, the data indicates that some reduc-
tions will result from decreases in exterior noise.
4-42
-------
REFERENCES
[ 1] Transportation Equipment Noise Emission Controls, Proposed Standards for Medium
and Heavy Duty Trucks, Federal Register, 39 210 Part II: 38338-38362.
[ 2] ENVIRONMENTAL PROTECTION AGENCY. Public health and welfare criteria
for noise, EPA Report 550/9-73-002. Office of Noise Abatement and Control,
Washington, D.C. 20460 (July 1973).
[ 31 ENVIRONMENTAL PROTECTION AGENCY. Information on levels of environ-
ment 1 noise requisite to protect public health and welfare with an adequate margin
of safety, EPA Report 550/74-004. Office of Noise Abatement and Control, Washing-
ton, D.C. 20460 (March 1974).
[ 41 JOHNSON, D. R. A note on the relationship between noise exposure and noise n
bability distribution, NPL AERO Report Ai40 (May 1969).
[ 51 ENVIRONMENTAL PROTECTION AGENCY. Background document for proposed
medium and heavy truck noise regulations, EPA Report 550/9-74-0 18. Office of
Noise Abatement and Control, Washington, D.C. 20460 (October 1974).
[ 61 SHARP, B. H. A Survey of Truck Noise Levels and the Effect of Regulations, Wyle
Report WR 74-8. (December 1974).
[ 7] DEPARTMENT OF TRANSPORTATION. Comparative benefits and costs projected
for proposed new medium and heavy-duty truck noise emission standards, DOT in-
formation brief. (April 10, 1975).
[ 81 ENVIRONMENTAL PROTECTION AGENCY. Supplemental Response of
International Harvester Company to Proposed Noise Emission Regulations for Me-
dium and Heavy Duty Trucks, Docket ONAC-74.. 1, Th04 1. Office of Noise Abate-
ment and Control, Washington, D.C. 20460 (March 14, 1975).
[ 9] CLOSE, W. H. and R. M. CLARKE. Interior and exterior A-weighted sound levels
of typical highway trucks, DOT Report Truck Noise-Il. Department of Transporta-
tion, Washington, D.C. (July 1972).
[ 101 DEPARTMENT OF TRANSPORTATION. Peak A-weighted sound levels due to truck
tires, DOT Report Truck Tire Noise I. (September 1970).
4-43
-------
[ ill CALIFORNIA HIGHWAY PATROL. Passenger Car Noise Study, California Highway
Patrol, Sacramento, Calif. (January 1970).
[ 121 CALIFORNIA HIGHWAY PATROL. Noise Survey of Vehicles Operating on Cali-
fornia Highways, California Highway Patrol, Sacramento, Calif. (July 197 1).
[ 13] OLSON, N. Survey of Motor Vehicle Noise. J Acoust Soc Amer 52: 1291 (1973).
11141 GENERAL MOTORS. Conference on Motor Vehicle Noise. G. M. Desert Proving
Ground (April 1973).
[ 15] VARGOVICK, R. J. Noise Source Definition-Exterior Passenger Vehicle Noises, SAE
Paper 720274 (January 1972).
[ 161 DIETRICH, C. W. and N R. PAULHUS. Noise Test Scores Clean Air Car Race,
BBN Report No. 2065. Bolt Beranek and Newman, Cambridge, Mass. (August 1970).
[ 17] ENVIRONMENTAL PROTECTION AGENCY. Comparistn of alternative strategies
for identification and regulation of major sources of noise, EPA Report, Office of
Noise Abatement and Control, Washington, D.C. 20460 (February 1975).
18] STATE OF CALIFORNIA. Motor vehicle noise, Annex A-2. State of California
(February 1973).
[ 19] PAULLIN, L. and H. B. SAFUR, Motor vehicle noise generation and potential
abatement, SAE Paper 720273. (January 1972).
[ 201 SEREDIPITY INCORPORATED. A study of the magnitude of transportation noise
generation and potential abatement, Report No. OST0NA714. (November 1970).
[ 211 GALLOWAY, W. J., K. McK. ELDRED, and M. A. SIMPSON, Population Distribu-
tion of the United States as a Function of Outdoor Noise Level, EPA Report 550/
9-74-004. Office of Noise Abatement and Control, Washington, D.C. 20460 (June
1974).
[ 22] FOSS, R. N. Vehicle noise study — final report. University of Washington, Applied
Physics Laboratory, (1972).
[ 23] KUGLER, B. A., D. E. COMMINS, and W. J. GALLOWAY. Design guide for highway
noise prediction and control, BBN Report No. 2739, Volume 1, Bolt Beranek and
Newman, Cambridge, Mass. (November 1974).
4-44
-------
[ 24] U. S. CENSUS BUREAU. 1970 U. S. census data. Department of Commerce, Wash-
ington, D.C.
[ 251 House Noise — Reduction Measurements for Use in Studies of Aircraft Flyover Noise,
SAE Report AIR 1081. (October 1971).
[ 26] KAYE, M. C. and E, E. UNGAR. Acoustic and performance test comparison of
initial quieted truck with contemporary production trucks, Truck Noise 111-B, DOT
Report No. TST-74-2 (September 1973).
[ 27] WILLIAMS, G., R. L. GIVENS, and F. SAARI. Noise reduction tests and develop-
ment performed on the White Motor Corporation quieted truck, Truck Noise V-A,
DOT Report No. TST-75-61 (January 1975).
[ 28] BURROUGHS, C. B. Public health and welfare benefits from regulations on
new medium and heavy truck noise emissions, BBN Tech memo W275
(Revised), Bolt Beranek and Newman, Cambridge, Mass. (15 January 1976).
4-45
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Section 5
TECHNOLOGY
COMPONENT NOISE CONTROL
The most significant of the truck components contributing to total truck noise levels
at low speeds are the engine, fan, intake, and exhaust. The relative importance of each of
these sources varies according to the truck model and type of truck operation. This section
describes noise abatement techniques for reducing the component source levels.
Engine
Internal combustion engines convert the chemical energy of fuel to mechanical energy
through the controlled combustion of fuels in a cylinder. The motion of engine components
and the sudden increase in cylinder pressure occurring during combustion excites the engine
structure, causing vibration of the external surfaces and attendant sound radiation. The
magnitude of the radiated noise depends more on engine type and design than on engine
size orpower [ II].
Gasoline-fueled engines tend to be quieter than diesel-fueled engines. The reason is that
in present production diesel engines, the combustion forces are greater especially in the mid
to high frequencies where resonant structural modes are present in the engine.
Possible noise control treatments include modifications to the engine and modifica-
tions to control the path of engine structural noise radiating to the exterior. The choice of
methods depends on the degree of noise reduction required, cost, lead time, and any associ-
ated penalties in performance.
Reduction of combustion-related noise is particularly desirable for diesel engines.
However, reducing this noise by reducing combustion power would also entail a reduction in
engine output power. An alternative approach is to smooth out the rapid rise in pressure
[ 11. One method is to control the fuel delivery rate, but with present production toler-
ances in the injection system this would be difficult. Another method is to use a turbo-
charger on 4-stroke diesel engines. Turbocharging increases peak cylinder pressures while
decreasing the rate of pressure rise. Still another technique is to redesign the combustion
5-1
-------
U,
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0 ________ ________ ________ ________ ________ ________ ________
(I,
0
0
0
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>
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0
0
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2
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• GASOLINE ENGINE
O DIESEL ENGINE
Figure 5-1. Engine Noise as a Function of Horsepower
chamber and injector spray pattern [ 21. At present, all these solutions are being tested by
the major engine manufacturers. One major manufacturer is phasing out of production all
naturally aspirated engines and replacing them with turbocharged models.
Control of machinery-related forces (e.g., oscillating pistons slapping the cylinder
walls [ 3] ) in present engines is aimed primarily at changing or reducing the structural
response of the engine. Investigators are experimenting with better ways to support the
piston in the cylinder and are trying to obtain better balance and closer tolerances in pro-
duction engines. This technique (in combination with turbocharging) was used by one
manufacturer to reduce the overall noise of a diesel-powered truck to 75 dBA.
0
-0---
.
0
0
8
0
0
0
0
0
0
0
-o I
.
-0
0
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0
00
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90
80
70 —
100
200 300
ENGINE FLYWHEEL HORSEPOWER
400
5-2
-------
Several engine manufacturers are presently marketing engine quieting kits that at-
tenuate engine structural noise by altering its transmission path. Depending on the particu-
lar quieting kit and truck configuration, engine’noise reduction ranges from 0 to 4 cIBA,
with most kits providing about a 2 to 3 dBA reduction. The kits generally consist of covers
for the sides of the engine block and oil pan, vibration isolation of the valve covers or air-
intake manifolds and crossovers, and possibly, damping treatment on sheet metal covers [ 41,
Then [ 51 reports that a close-fitting enclosure extending over the entire engine structure
provided about 15 to 20 cIBA reduction in engine noise. Discussions with one major engine
manufacturer indicated that such enclosures could reduce the overall truck noise by 10 to 15
cIBA. However, the engine manufacturers also indicated that these enclosures are not
presently acceptable for production utilization because problems with cooling and service
access have yet to be resolved.
To obtain the lowest possible overall truck noise level, most engine manufacturers
appear to prefer an enclosure built into the truck cab rather than fitted onto the engine.
Under DOT contracts, three truck manufacturers (International Harvester, White and
Freightliner) have investigated enclosure designs for cab-over engine trucks. The enclosures
involved a tunnel configuration with the cooling fan at the enclosure entrance. Air flows
through the enclosure and around the engine, exiting through openings in the rear of the
enclosure. The partial engine enclosure reduced engine noise on the Freightliner truck by
10.5 dBA [ 81. On the International Harvester truck, the partial enclosure reduced engine
noise by 7 cIBA. The difference between the reductions for the enclosures used on the Freight-
liner and International Harvester trucks may be partly attributed to the use of thicker layers
of absorption material on the Freightliner enclosure. The use of a partial enclosure allowed
an overall noise reduction for the White Motors truck of over 10 cIBA [ 61.
Fan
Truck cooling fans have been designed with primary emphasis on purchase price
rather than on aerodynamic efficiency or noise abatement. Accordingly, most fans have
been made of stamped sheet metal blades riveted to a hub that is turned by means of a belt
and pulley arrangement connected to the engine. The fans tend to be small and operate at
high speeds leading to high noise levels, since fan noise generation is proportional to fan
speed. The fan cross-section is not aerodynamically shaped, and the blade pitch angle
often does not vary with radius as it should if it is to properly develop uniform flow through
all portions of the radiator. In order to minimize tractor length, it appears that manufac-
turers tend to squeeze the fan between the engine and radiator. Under favorable conditions,
the fan would move air axially; in the usually cramped engine compartment, the flow is
mostly radial, with a nonuniform velocity distribution.
5-3
-------
Noise data for various truck fans are shown in Figure 5-2 as a function of engine fly-
wheel horsepower. The brackets on the five points in the 300 to 400 hp region designate
limits of uncertainty resulting from 0.5 dBA levels of uncertainty in the measurements used
to estimate the fan noise levels. Fan noise on gasoline-powered trucks tends to be nearly
equal to levels on diesel-powered trucks because the greater heat rejection of the combustion
process in gasoline engines is compensated for by higher surface area-to volume ratios.
Neither cab type nor engine power appear to have a significant effect of diesel-powered
truck fan noise.
The control of fan noise must be viewed in terms of total cooling system design.
Some noise reduction can be achieved by modifying the radiator, radiator shutters, fan
shroud, and fan. Radiator design is closely related to fan performance and noise. Radiators
designed with low airflow requirements allow the use of slower turning and, thus, quieter
fans. The amount of noise reduction achievable through modifications to the radiator de-
pends on the initial design, but even well-designed cooling systems can often be quieted by
2 to 3 dBA through modifications to radiator design [ 7].
Thermostatically controlled shutters are used on many trucks to regulate air flow
through the radiator. The primary purpose of the shutters is to prevent cold water from
overcooling the engine. Shutters significantly influence fan noise. When the shutters are
closed and air flow to the fan is substantially reduced, the fan blades stall and generate more
noise.
Shrader and Page [ 7] report a 5 dBA increase in fan noise as a result of closed shutters.
One manufacturer reported approximately a 2 to 3 dBA increase in total truck noise when
shutters were closed. Several manufacturers feel that shutters could be replaced by thermo-
stats and bypass tubing.
The fan shroud, which ducts air from the radiator to the fan, is important in maximiz-
ing fan effectiveness and preventing recirculation of hot air back through the radiator.
Shrouds that do not channel this air smoothly into the fan can lead to stalled blade tips
with an attendant increase in noise. Shrader and Page [ 7] claim that improved shroud
designs can produce a 3 to 5 dBA reduction in fan noise levels.
The fan itself can often be changed to reduce noise. One of the most effective changes
is to increase fan diameter and decrease fan speed. A 2- to 3-inch increase in fan diameter
typically allows a 3 to 5 dBA reduction in noise for a constant volume flow rate. The
extent that the fan diameter may be increased is limited by the configuration of the radiator
and essential structural members of the truck.
5-4
-------
85
80
75
0
70
-J
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>
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O
z
0
C’,
60
500
Figure 5-2. Truck Fan Noise Levels as a Function of Engine Horsepower
The Cab Over Engine (COE) tractor is particularly suitable for a large, slow fan. Be-
cause of the large, blunt front on the COE, the forward motion of the truck tends to develop
a high pressure rise in front of the radiator that supplements the flow created by the fan.
With this type of cab and a large radiator with a frontal area of 2,000 square inches,
Freightliner was able to use a 31-inch fan to reduce the fan noise level by 14 dBA [ 81.
The fan (thermostatically controlled) operates for about 1 percent of the time. For the re-
mainder of the time, the forward motion of the truck is able to force sufficient cooling air
through the radiator. On the White Motors truck, fan noise was reduced by 6 to 8 dBA by
replacing the original 28-inch fan with a 30-inch fan of better design [ 6]. International
Harvester reported changes in a noise level of 3 dBA by using fans of the same size but of
different design ?‘
200 300 400
NET FLYWHEEL HORSEPOWER
T RANGE OF CONFIDENCE FOR
.1 ± 0.5 dB MEASUREMENT ERRORS
• COEDIESEL UGASOLINE
0 CONVENTIONAL DIESEL
5-5
-------
The data in Figure 5.2 indicates that many fans generate less than 80 dBA.
Those that are noisier can be replaced by a slightly different fan model and fan/engine speed
ratio. Reduction of fan noise of 74 dBA should be possible with the use of better radiator,
fan, and shroud designs without increasing fan or radiator size. Levels can be reduced to 64
dBA with larger radiator cores, larger and slower fans, careful design of fan shrouds, and a
thermostatically controlled fan clutch that is phased with a shutter thermostat to prevent
fan operation while the shutters are closed.
The Department of Transportation (DOT), during its Quiet Truck Program, has inves-
tigated many cases of thermostatically controlled radiator fan clutch systems. These systems
require the fan to operate only when the extra cooling is needed; the fan does not operate
when sufficient ram-air is provided by the forward motion of the truck, or if the truck engine
is not heavily loaded.
Data shown in Appendix I demonstrates the time that the fan actually does operate.
It shows that, for the on-off units, the annual average total fan-on time is less than 3 per-
cent. For both types of clutches the annual average significant time on (from a noise point
of view) is below 1 percent.
Intake
Air intake systems supply truck engines with the continuous flow of clear air needed
for fuel combustion. These systems can range in size and complexity from a simple air
ifiter mounted on top of a carburetor to an external air filter with ducts leading to the
engine and a cab mounted snorkel unit. Noise is generated by an unsteady flow of air into
enginecylinders. Supercharged engines with Rootes blowers also exhibit tones associated
with the lobe-passage frequency of the blowers; Turbochargers tend to smooth flow ir-
regularities associated with cylinder charging.
The majority of air intake systems have noise levels less than 72 dBA with a few as
low as 57 dBA [ 9]. It is expected that few trucks will require air intake system treat-
ment to comply with not-to-exceed regulatory levels of 83 or 80 dBA. To comply
with a 78 or 75 dBA regulatory level, it may be necessary to add an air intake silencer. A
6 dBA reduction in air intake noise was reported by International Harvester for an air intake
silencer [ 101.
5-6
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Exhaust
Exhaust outlet noise emanates from the exhaust system terminus and is generated by
the pressure pulses of exhaust gases from the engine. Shell-related exhaust noise consists
of radiation from the external surfaces of the pipes and mufflers of the exhaust system. It
is generated by two mechanisms, the transmission and subsequent radiation of engine vibra-
lion to the exhaust system and the transmission of internal sound to the exterior of the pipe.
Hunt et al. [ 141 found that the source levels of unmuffled outlet noise for diesel engines
can range from 82 to 105 dBA at 50 feet, with the levels from 2-stroke diesel engines about
10 dBA higher than the levels for 4-stroke diesel engines. The exhaust noise levels for
present exhaust systems given in Table 5-1 are derived from data presented by Hunt et al.
Table 5-1
Exhaust Noise Levels for Present Exhaust Systems
Diesel Engine
Average Level
Lowest Level
Naturally aspirated, 4-stroke
Turbocharged, 4-stroke
Naturally aspirated, 2-stroke .
Turbocharged, 2-stroke
79.4 C iBA
80.2 dBA
84.0 dBA
82.5 dBA
71 CIBA
70 dBA
77 dBA
76 c IBA
[ 131 and Donnelly et al. [ 9]. For 4-stroke diesel engines, exhaust systems are available
which reduce exhaust noise to below 73 dBA. The exhaust systems with the lowest noise
levels re not always the most costly [ 14]. For 2-stroke diesel engines, the present exhaust
system noise levels are 2 to 5 dBA higher on the average than for 4-stroke diesel engines. All
of the levels reported by Hunt and Donnelly for 2-stroke diesel engines are above 75 c IBA.
Since exhaust gases pass through turbochargers, some additional attenuation of exhaust
noise is expected. Attenuation on the order of 5 to 10 dBA have been reported. The data
in Table 5-1 indicate that present exhaust systems on 4-stroke diesel engines do not take ad-
vantage of the additional attenuation provided by turbochargers.
Almost all of the noise control efforts in the trucking industry have centered on the
diesel truck. Consequently, little information is available on exhaust source levels for
gasoline trucksi Muffled exhaust noise levels of about 80 cIBA have been measured on present
gasoline trucks. This is similar to the present muffled levels for 4-stroke diesel engines (See
Table 5-1). It is expected that the exhaust treatments required to bring gasoline trucks into
compliance with noise emissions regulations will be similar to treatments required for the
4-stroke diesel engines.
5-7
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Noise control techniques for exhaust noise consist of muffling exhaust outlet noise,
sealing exhaust leaks, and using double-wall construction on pipes and mufflers to reduce
exhaust shell noise. Exhaust systems with high backpressure will increase the work the
engine must expend for pushing exhaust gases out of the exhaust port resulting in the de-
gradation of overall engine performance. A comparison of the backpressure developed by
several muffler systems shows that some quiet systems have the same backpressure as noisier
ones. There are systems available, therefore, that have low muffled exhaust noise levels that
do not degrade engine preformance.
In the DOT Quiet Truck Program, several exhaust system noise treatments proved ef-
fective in reducing exhaust outlet and shell noise. The use of stack silencers and larger
mufflers reduced the exhaust outlet on the Freightliner DOT Quiet Truck from 82 dBA to
70 dBA [ 12]. Sealing exhaust leaks reduced exhaust shell noise from 75 dBA to 71 dBA
[ 8]. The manifold muffler used had an insertion loss of approximately 7 dBA.
The use of larger wrapped mufflers on the International Harvester DOT Quiet Truck
reduced the exhaust noise from 83 dBA to 72.5 dBA [ 101. The International Harvester truck
was the only truck in the DOT Quiet Truck Program to have a 2-stroke diesel engine pro-
ducing, in general, more exhaust noise than the 4-stroke diesel engines. Most of the exhaust
noise from the quieted exhaust system on the International Harvester truck was the exhaust
shell noise which was not reduced below 72 dBA. The use of double wall piping (where the
two walls were in contact with each other) was found to be ineffective by International Harveste:
in reducing shell noise. Isolating the walls from each other would probably improve the re-
duction of pipe shell noise.
On the White Motors DOT Quiet Truck, the exhaust noise was reduced from 76 dBA
to 67 dBA with a larger muffler [ 6]. Stack silencers and exhaust resonators were found to
be ineffective on the White Motors truck.
TOTAL TRUCK NOISE CONTROL
The component noise control measures described may be combined in a variety of
ways to meet specified limits for overall truck noise. In general, the noise control strategy
is determined by the source level of the noisiest and most difficult-to-control component,
usually the engine. Gasoline and diesel trucks are discussed separately because of the dif-
ference in their engine source levels.
The combinations of source levels suggested for achieving specified overall truck levels
are intended to be representative cf practical examples. In some cases, a manufacturer may
prefer to have one source level higher and another lower than suggested. As required in the
5-8
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new truck noise emission regulations, in order that the noise emission levels from most trucks
of a single configuration are below the regulatory level, component levels are selected so
that the median overall truck noise level will be at least 2 to 3 dBA below the regulatory
level.
83 dBA Regulatory Level
Present production medium and heavy diesel trucks display the following ranges of
measured source levels (in dRA) under prescribed test conditions:
Engine Fan Exhaust
75-85 75-85 75-85
All manufacturers are currently able to reach an 86 dBA overall level with off-the-
shelf hardware with apparent concentration on quieting the noisiest production trucks
first. Thus, trucks having engines with source levels of 80 to 85 dBA have quieter fans and
exhaust systems than trucks with quieter engines.
The source levels measured in gasoline trucks are (in dBA)
Engine Fan Exhaust
75-77 80-85 80
Table 5-2 shows one combination of source levels that will yield a production line truck
Table 5-2
Component Source Levels for an 83 dBA Regulatory Level
Component
Noise Level, dBA
Engine
Fan
Exhaust
Air intake
All others
77
73
73
72
70
Total
80.6
that generates an overall noise level of less than 80.6 dBA. The use of better-designed, slower
turning fans with shrouds, the best mufflers presently being produced, and available engine
5-9
-------
quieting kits should be sufficient to bring all but the noisiest diesel trucks into compliance with
the 83 dBA regulatory level. For the noisiest of the presently available diesel engines, noise side-
shields may be required.
For gasoline trucks, modifications to the cooling fan and use of better available mufflers
should be sufficient for compliance to a 83 dBA regulation. No engine treatment is needed.
80 dBA Regulatory Level
Component source levels which will bring trucks into compliance with the 80 dBA regulatory
level are shown in Table 5-3. In most diesel trucks, the required noise treatment of the cooling system
will include larger slower-turning fans, fan shrouds and thennostatically controlled fan clutches. On
most diesel trucks advanced exhaust mufflers will be needed that are similar to those demonstrated
in the DOT Quiet Truck Program but not presently being mass-produced. Engine noise side shields
and an underpan should be adequate to reduce the noise from most presently available diesel
engines to 74 cIBA. The noisiest of the presently available diesel engines may require partial engine
enclosures. However, the lead time for the 80 dBA regulation should be adequate to allow engines
Table 5-3
Component Source Levels for an 80 dBA Regulatory Level
Component
Noise Level, dBA
Engine
74
Fan
70
Exhaust
69
Air intake
69
All others
70
Total
77.5
to be quieted so that the partial enclosures will be eliminated. Side shields should be adequate
to allow gasoline trucks to comply with the 80 dBA regulatory level.
Additional cooling system treatment of the fan, fan shroud and/or radiator can be used to
reduce fan noise from 73 to 70 dBA for the 80 dBA regulatory level. To reduce exhaust noise to
69 dBA, longer, more advanced mufflers should be sufficient.
5-10
-------
78 dBA Regulatory Level
In Table 5-4, the component levels suggested for a 78 dBA regulation are given. Addi-
tional engine noise treatment, such as larger side shields and underpans, can be used to reduce
engine noise an additional 2 dBA from the engine noise design level used for the 80 dBA
regulatory level.
Larger fans and radiators with engine-mounted shrouding should be sufficient to reach
cooling system noise levels of 64 dBA or below. The same exhaust system treatments dis-
cussed under the 80 dBA regulatory level apply here. Air intake silencers can be employed
to reduce air intake noise to 65 dBA or below.
75 dBA Regulatory Level
Table 5-4 shows a combination of component levels that will produce a truck which
complies with a regulatory level of 75 cIBA.
Table 5-4
Component Source Levels for a 78 dBA
Regulatory Level
Component
Noise Level, dBA
Engine
71
Fan
64
Exhaust
69
Air Intake
65
All Others
70
Total
75.6
Additional engine noise treatment is necessary to reduce the engine noise level given in
Table 5-4 for a 78 dBA regulatory level to the level given in Table 5-5 for a 75 dBA regulatory
level. Most existing diesel engines will require engine enclosures and special engine mounts to
achieve engine noise levels of 68 dBA. The noisiest of the existing diesel engines will need
quiet kits in addition to engine enclosures. However, modifications to diesel engines is expec-
ted to lower engine noise enough that the use of both enclosures and quiet kits will not be
necessary for a 75 dBA regulation. For gasoline trucks, side shields and an underpan should
be sufficient to reduce engine noise to 68 dBA or below.
5-1 1
-------
Exhaust system treatments necessary to reach levels of 65 dBA or below for most
trucks include manifold mufflers, advanced mufflers, muffler jackets and double-wall
exhaust piping.
Silencers on the air intake should be adequate to reduce the air intake noise on diesel
trucks to low enough levels so the truck can comply with the 75 dBA regulatory level. All
sources other than the engine, fan, and exhaust will be 65 dBA or below with transmission
noise treated by the engine enclosure. Tire noise should be below 65 cIBA under test condi-
tions and the noise from the rear axle below 60 dBA on most trucks.
Table 5 -5
Component Source Levels for a 75 dBA Regulatory Level
Component
Noise Level, dBA
Engine
Fan
Exhaust
Air intake
All others
68
64
6 5
65
65
Total
72.6
BEST AVAILABLE TECHNOLOGY
The Noise Control Act requires that in setting noise emission standards for products
distributed in commerce, the administrator take into account the level achievable through
application of the “best available technology.” The term “best available technology” is
not defined. Based upon caselaw precedent relating to identical or similar language under
other statutes, EPA believes that this term, as applied to the mass production of quiet
products, refers to levels which can be achieved by application of conventional techniques
and materials. Further, these levels need not be levels routinely achieved by products already
on the market. At the same time, they cannot be levels EPA has arrived at by crystal baIl
inquiry.
Accordingly, as applied to new medium and heavy trucks, EPA believes that the level
achievable through application of the best available technology is the level which it can be
reliably predicted, through the exercise of sound engineering analysis, that assembly line
trucks of all classes subject to the standard will be able to meet by the effective date,
through application of currently known noise attenuation techniques and materials.
5-12
-------
On this basis EPA has determined that, given a lead time of 8 years, the not-to-exceed
regulatory level achievable by application of the best available technology is 75 dBA. The
sources of truck noise have been isolated, and have been found to be reducible in even the
noisiest trucks to levels which, when combined, will result in a truck which produces 72.9 dBA.
The techniques used for reducing to these levels are commonly known, and are applicable to
all classes of medium and heavy trucks. Furthermore, the noise reduction applications can be
readily integrated into the assembly line process. Finally, the 2.1 dBA margin beyond the 75
dBA regulatory level is sufficient to account for the design tolerance necessary in translating
to a population of mass-produced trucks.
The achievability of the 75 dBA regulatory level has been demonstrated by the DOT
quiet truck program, where one manufacturer successfully built a 72 dBA truck which has
been operating in regular line-haul service for over one year. This truck applies the conven-
tional quieting techniques discussed by EPA in developing these standards, the same kinds of
applications which EPA has said are transferable to the general truck population. Moreover,
this experience has shown that a previously noisy truck can be quieted without impairing
its performance capabilities or its utility to the user.
Engineering Information
The design of quiet trucks involves the application of established acoustical principles.
The body of this type of information is large and, since truck quieting is relatively new,
enough time has not yet elapsed for this reservoir of knowledge to be properly tapped. The
future should bring additional quieting techniques not presently available. It is necessary,
however, to confine the discussion to methods utilized today. Over the years information
has been collected on mufflers, fans, and transmission of sound through barriers, which can
be applied to the truck noise reduction problem. The most recent and directly applicable
data was obtained in the DOT Quiet Truck Program. In this effort, quieting techniques were
studied and applied to an existing model truck. Analysis of component test data show that
the major noise sources in a truck (tested according to SAE-366b) can be reduced to the
levels in Table 5-6. The individual sources are briefly discussed.
Table 5-6
Major Truck Noise Components
Source
Level dBA
(366b Test)
Reference
Engine
Fan
Exhaust
All Other
Total
65
64
70
66
72.9
[ 8]
[ 81
[ 8], [ 10]
[ 8], [ 10]
5-13
-------
Engine noise treatment
The noise level of a heavy-duty diesel engine currently in production is around 75 dBA
[ 1 51 so that the technology exists to design and build diesel engines with noise levels of
75 dBA. With a 75 dBA engine, the use of a partial enclosure providing a noise reduction of
10.5 dBA [ Ill will give engine noise levels around 64.5 dBA. Full enclosures and two-stage
engine mounts are available techniques and have been applied to reduce engine noise from
84 to 59 dBA [ lii. These techniques could be used to reduce the noise levels from all other
engines to levels below 65 dBA. The technology required to redesign truck cabs to accom-
modate engine enclosures and additional cooling for the enclosed engine is solved routinely.
It involved routine engineering design, such as enlarging cab space and rearranging equipment.
Fan noise treatment
The installation of a larger, slower-turning, well-designed fan has been demonstrated to
reduce fan noise from 83 to 64 dBA [ 11] allowing the truck to comply with the 75 dBA
regulation.
Exhaust noise treatment
On a 4-stroke diesel engine, the exhaust outlet noise was reduced to 61 dBA using a
manifold muffler and larger exhaust mufflers [ 11]. The exhaust shell noise was reduced to 68
dBA using available muffler jackets and pipe joint seals [ 8]. On a 2-stroke diesel engine,
the outlet noise was reduced to 64.5 dBA and the shell noise to 72 dBA without wrapping
the exhaust piping [ 121. Wrapping the exhaust piping has been shown to reduce exhaust
shell noise by more than 4 dBA 1101. Therefore, the technology has been demonstrated
that will bring exhaust noise levels down to 70 cIBA for both 2- and 4-stroke diesel engines.
Gasoline engine exhaust noise treatment is similar to 4-stroke diesel engine exhaust treat-
ment.
Treatment of other sources of noise
Other noise sources include tires, transmission, rear axles and air intakes. Ribbed tires,
on the Freightliner DOT Quiet Truck, had a noise level below 61 dBA under test conditions
[ 81. The noise level from the rear axle was measured at approximately 58 dBA [ 8]. The
treatment of noise from transmissions is included in the engine enclosures, Air intake silen-
cers have been used to reduce air intake noise to below 63 dBA [ 10], [ 81. Therefore, the noise
from sources other than the engine, exhaust, and fan can be reduced to 66 dBA or below
using demonstrated technology.
5-14
-------
Summary
On the basis of individual source levels, the discussion indicates that a total level of
72.9 dBA or less is achievable. For a “not to exceed” standard of 75 dBA, this leaves a
margin of 2.1 dBA or more, which should be adequate to account for variations in noise
levels from trucks of a single configuration and measurement uncertainties.
Demonstration (The 72 dBA Truck)
The Freightliner Corporation has built a heavy diesel truck using the discussed tech-
nology and the overall noise level reduced from 88 dBA to 72 dBA [ 101 is low enough to
comply with the 75 dBA regulatory level allowing for a tolerance of 3 dBA. This 72 dBA
truck has completed 100,000 miles of linehaul service. It was employed in normal fleet
operations for aperiod of 1 year. No unusual maintenance problems were observed and the
noise abatement components have performed generally quite well [ 13]. It should also be
noted that the introduction of the noise reduction hardware produced no oddities in the
appearance of the truck. To the casual viewers, it appeared no different from other trucks.
Applicability of Quieting Techniques
A careful review of the Freightliner acoustical treatment indicates that all of
the techniques employed on this truck are transferrable to other trucks, if appropriate
routine engineering precautions are observed.
Mass Production
All of the elements involved in the noise reduction system are conventional structures.
Some of the noise reduction items are:
Larger, slower-turning fans,
Fan clutches
Wrapped exhaust system piping, and
Engine enclosures.
If the truck and the production process are properly designed, trucks containing the
required noise treatments should be mass-producible.
5-15
-------
lime Allowed for Design Cycle
The shortest time interval considered for the achievement of a 75 dBA level is 8 years.
The General Motors Corporation in their docket submission of April 10, 1974, included a
detailed bar chart illustrating the steps in noise control development and the production
cycle. The total time span of the cycle is 4 years. International Harvester has stated in their
docket submission that any major redesign takes 2 and 3/4 years. On the basis of GM’s and
IH’s statements, it is reasonable to deduce that they (and other manufacturers) would be
able to meet the required level inside the 8-year time period allotted by the regulation.
A somewhat more extensive discussion of the “lead time” question is given in refer-
ence 12.
Conclusions
Perusal of the preceding text reveals the criteria presented earlier are satisfied. Therefore,
it is concluded that technology is available to permit the design and mass production of
trucks complying with a 75 dBA regulation inside the shortest prescribed time interval
considered (i.e., 8 years).
REFERENCES
[ 11 TIEDE, D. A. and D. F. KUBELE. Diesel engine noise reduction by combustion
and structural modifications, Paper No. 730245. Society of Automotive Engi-
neers (1973).
[ 2] PRIEDE, T., et a!. Combustion-induced noise in diesel engines — presented at
the general meeting of the Institute of Marine Engineers (1967).
[ 3] UNGAR, E. E. and D. ROSS. Vibrations and noise due to piston-slap in recipro-
cating machinery. J Sound Vib 2 (1965).
[ 4] JENKINS, S. H. and H. K. KUEHNER. Diesel engine noise reduction hardware
for vehicle noise control, Paper No. 73058.1. Society of Automotive Engineers
(1973).
[ 5] THIEN, G. E. The use of specially designed covers and shields to reduce diesel
engine noise, Paper No. 730244. Society of Automotive Enginerrs (1973).
5-16
-------
[ 61 WILLIAMS, G., R. L. GIVENS, and F. SAARI. Noise reduction tests and develop-
ment performed on the White Motor Corp. Quieted Trucks, Truck Noise V-A, Report
No. DOT-TST-75-6 1 (January 1975).
[ 71 SHRADER, J. 1. and W. H. PAGE. The reduction of cooling system noise on heavy
duty diesel trucks, Truck Noise IV-C, Report No. DOT-TST-74-22 (May 1974).
[ 8] KAYE, M. C. and E. K. BENDER. Final configuration of Freightliner quieted truck,
Truck Noise Ill-F, Report No. DOT-TST-75-23 (October 1974).
[ 9] DONNELLY, T., J. TOKUR, and W. WAGNER. A baseline study of the parameters
affecting diesel engine intake and exhaust silencer design, Truck Noise VI-B, Report
No. DOT-TSC-OST-73-38 (January 1974).
[ 101 SHRADER, J. T. and N. PRIADKA. The reduction of intake and exhaust system
noise on heavy duty diesel trucks, Truck Noise IV-D, Report No. DOT-TST-75-14
(October 1974).
[ 11] BENDER, E. K., W. N. PATTERSON, and G. E. FAX. The technology and cost of
quieting medium and heavy trucks, BBN Report 2710 (October 30, 1974).
[ 12] BENDER, E. K., W. N. PATTERSON, and M. C. KAYE. Source analyses and exper-
iments with noise control treatments applied to Freightliner quiet truck, Truck
Noise Ill-C, Report No. DOT-TST-74-20 (January 1970).
[ 131 CLOSE, W. H., DOT quiet truck program, Inter-Noise 1974 Proceedings (September
30 - October 20, 1974) p. 473.
[ 14] HUNT, R. E., K. C. KIRKLAND and S.P. REYLE. Diesel exhaust and air intake
noise, Truck Noise VI-A, Report No. DOT-TSC-OST-73-12 (July 1973).
5-17
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Section 6
COSTS OF COMPLIANCE
In complying with noise emission regulations on medium and heavy trucks, increases in
cost will be accrued by the truck user in the following areas:
1. Increases in truck prices, and
2. Increases in truck operating costs
Estimates of the increases in truck prices and increases in operating costs associated with
noise treatment are considered in this section.
The estimates given are estimates of the costs of compliance with not-to-exceed regula-
tory levels. [ 19] In deriving the estimates presented, estimates given in the BBN Report No.
2710 [ 1] and the background document for the proposed regulations [ 2] are revised to
include the following:
1. Information made available since the publication of the BBN Report No. 2710 and
the background document for the proposed regulations.
2. Costs of compliance with a 78-dBA regulatory level, that were included in some of
the regulatory options considered by EPA in response to public comments on the
proposed regulations.
INCREASES IN TRUCK PRICES
Table 6-1 gives the anticipated customer price increases associated with the reduction
of noise levels from the engine, fan, exhaust, and air intake to levels below those given at the
top of the table. The key for the noise treatments in Table 6-1 is given in Table 6-2. The
estimates of price increases are given in terms of 1973 dollars and are based on cost esti-
mates presented in the DOT Quiet Truck Program, manufacturers’ estimates of the costs for
similar noise treatment hardware, and, when hardware is currently in production, list
prices. All of the component noise levels in Table 6-1 are design levels low enough to allow
medium and heavy trucks to comply with not-to-exceed regulatory levels. Except where
6-1
-------
noted, all noise levels are with the truck operated in accordance with the SAE J366b test
procedure at a site with a hard surface between the truck and measurement point.
Because the cost for quieting trucks is largely dependent on the initial engine and ex-
haust noise levels, derived from the engine model used in the truck, Table 6-1 has been
organized according to engine model instead of truck model. The range of engine noise
levels are given for each engine model with the engine inside the truck cab and at maximum
speed and load.
The design levels for each regulatory level were selected to minimize the costs. Because
engine noise is usually more costly to reduce, design levels have been selected for the engine
that are higher than the levels for other sources. For the 80- and 78-dBA regulatory levels,
it was found that the costs for some engine models could be appreciably reduced by select-
ing one of the two sets of design levels given at the top of Table 6-I.
Finally, to provide additional insight into the relative impact on the increase in purchase
price associated with each regulatory level, Table 6-1 shows the approximate percentages of
the total truck population comprised of medium or heavy trucks powered by the indicated
engine model [ 2]. In estimating the percentages for medium-duty engines, it is assumed that
heavy-duty engines are used only in heavy trucks.
NOISE CONTROL TREATMENTS AND COSTS
Cooling System
Since the noise from untreated cooling systems will depend on the configuration of the
tnick cab and engine compartment, the treatment associated with each engine model in
Table 6-1 will be different for different truck models. Therefore, the average of the noise
reductions required to reach the design level is used in estimating the required fan treatment
and associated costs in Table 6-1.
A fan noise level of 73-dBA is suggested for the 83-dBA regulatory level. In àrder to
reach this level, fan noise treatment #1 is given in Table 6-1. The average of the fan noise
levels as reported in the DOT Quiet Truck Program [ 3], [ 5] — [ 61 and Appendix C of BBN
Report No. 2710 [ 1] is 78-dBA. Therefore, on the average, a ieduction in fan noise of
approximately 5-dBA should be required to achieve the 73-dBA design level. Reductions of
6- to 8-dBA were obtained on the White Motors DOT Quiet Truck by improving the fan and
fan shroud design [ 3]. The price increase for these design substitutions is estimated at $10.
Ten dollars is not unreasonable because the fan and fan shroud used in the final (64-dBA) cooling
system treatment on the Freightliner DOT Quiet Truck produced a price increase of $13.50 [ 7].
6-2
-------
Table 6-1
Estimated Increase in Prices for Medium and Heavy Trucks which Comply with Not-to-Exceed Noise Emission Regulations
Medium Ganoline = $35
Heavy Gasoline 135
Medium Diesel =426
Hcuvy Diesel =387
AVERAGES
Mcdirm. Gasoline = 180
Heavy Gasoline 290
Medium Diesel = 865
Heavy Diesel =715
Medium Gasoline -330
Heavy Gasoline = 480
Medium Diesel = 1 )1 59
Heavy Diesel — 976
AS’ERAGES
Medium Gasoline 665
Heavy Gasoline =815
Medium Diesel 1624
Heavy Diesel = 454
L)
ENGINE MODEL
TRUCK
TYPE
“
°
—
83 6BA Regulatory Level
Engine 77 8BA
Fan 73 8BA
Exhaust 73 8BA
Air Intake 72 dBA
15 1 Others 70 dBA
— TOTAL 806 CIBA
-
TOTAL
Fan Exhaust Engine Cab Intake
80 884 Regulatory Level
Engine 73 4BA 74 184
Furs 70 8BA 70 884
Exhaust 69 884 OR 69 dBA
Air Intake 69 dBA 658184
All Others 70 8BA 70 CIBA
TOTAL 77.5 d8A 77.5 dBA
78 dIlA Regulatory Level
Engine 11 dBA 728134
Faa. 64 dBA 64 4BA
Exhaust 69 dBA 69 dBA
Air Intake 65 nBA 65 CIBA
All Others 70 CIBA 65 dBA
TOTAL 75.6 cIBA 75.1 ditA
75 dEA Regulatory Level
Engine 68 8BA
Fan 64 aBA
Exhaust 63 8BA
Air Intake 65 8BA
All Others 65 CIBA
Fan
Exhaust
Ca b
TOTAL
Fan
Exhaust
Engine
tate
TOTA%
Far
Exhaust Engin
Cub
8BA
TOTAL
Gasoline
Medium duty (I)
75-77 dIIA (2)
Medium
Heavy
55.1%’
10.2%
aI
$10
al
$110
bt
$25
lit
$25
-
$35
a2
525
a2
125
8.2
550
b2
550
- ( II
$100
dl
$ioo
—
$5
el
$5
el
$5
$180
$280
$683
a3
$50
a3
$200
8.2
$50
8.2
Sso
b2
$155
cI
$100
ci
$100
dl
$100
dl
$100
e2
$30
eZ
$30
•iso
$480
$50
a3
52000
5260
8.3
5260
5325
d2
$325
2
830
e2
$30
5665
$815
$1370
Di es et-2$trok e, nuturallyavpiratvd
Heavy duty
Manufacturer A
78-79484
Heavy
12.0%
al
5110
lit
$80
—
d l
$1 150
$290
$563
$665
—
a2 b2 —
135 $t55
d2
$400
aS
$200
—
82
$500
el
$30
$885
a3
$125
8.3
$365
—
d3
$850
e2
$30
Diesel .4 stroke, naturally aspirated Medium
Medium duty
Manufacturer B
83-SSdltA Heavy
0.79%
521%
at
510
al
$110
bI
555
lii
d2
$500
82
$500
u2
$25
a2
125
b2
$105
8.2
$105
43
$850
d3
5850
e2
530
e2
530
$1010
$1115
aS
550
sI
— ;i—
$105
8.2
sios
— - -—
— $1075
d4
$1075
$30
e2
$30
.
=1260
$1335
$50
a3
5125
—i;i-—
$315
b3
5315
$275
Cl
$1075
84
$27551075
$30
e2
530
$1745
$1820
Die sel-4xtroke,turbo chaeged
Heavy duty
Manufacturer B
8l-83CIBA
Heavy
Heavy
6.0%
al lit 82
$110 $55 — 5400
al 8.! dl
5110 $30 — $100
$565
$240
a2
12$
8.2
$105
s12
$500
e2
$30
$760
a3
$125
b2
$105
d3
$850
e2
$30
51110
a3
$125
b3
5315
d4
$1075
e2
$313
$1545
Diesel - 4 stroke. lurbocharged
Heavy duty
Manufacturer c
76-7 ICIBA
4.8%
a2
125
8.2
555
dl
$200
r2
$30
5.410
u3
$200
8.2
$55
82
$500
e2
$30
e3
$125
b3
$265
d3
$850
e2
$30
$270
Diesel -4 sLrsrke. naturally aspirated Medium
Medium duly
Manufacluren D
S0dBA Heavy
0.29%
1.91%
al
$10
aS
$110
1.1
$55
bi
$55
$100
dl
$100
$165
$265
a2
$25
a2
$125
1.2
3105
8.2
5105
42
$500
42
550
el
$5
cI
$5
‘
aS
$50
aS
5200
1.2
$105
b2
5105
—
82
$500
82
8500
e2
$30
e2
$30
$685
835
aS
550
aS
5125
8.3
$315
8.3
5315
44
$1075
84
$1075
e2
530
e2
$30
$1470
$1545
Diesel -4 stroke, lurbocharged
Heavy duty
Manufacturer D
76-73dBA
Heavy
1.5%
31
$110
bI
$55
dl
$100
$265
a2
$123
b2
$105
dl
$200
e2
$30
$484
aS
$200
8.2
$105
42
$500
eT
$30
3
$125
8.3
$315
83
8850
e2
$30
5320
Diesel-i slroke, 12 cylinder
Heavy duty
Manulacturee A
79-81884
Heavy
0.9%
.
a!
SIlO
bI
$80
dl
$200
a2
$125
b2
$155
—
—
d2
$500
—
el
$5
—
a3
$200
—
1.2
$155
—
uS
5200
—
d2
5500
—
e2
530
—
085
51
—
aS
$125
.——-
8.3
$365
84
$1075
e2
SIt)
51545
Diesel -4 stroke, naturally aspirated
Medium duly
Manufacturer I
78-798184
t3ic sel-4stroke,naturullyaspirated
Heavy duly
Manufacturer C’
78-79 dEA
Medium
Heavy
0.10%
0.67%
al
$10
al
$110
bI
$30
bI
$30
dl
$100
dl
$100
$140
$240
a2
$25
a2
St25
1.2
$55
b2
$55
cI
$175
sr I
$115
dl
$200
dl
$200
el
$5
ci
$5
5460
$560
a3
$50
aS
5200
1.2
$55
b2
$55
d2
$500
d2
$500
e2
$50
e2
$30
$635
e 85
aS
$30
=5
8.3
$265
b3
$265
d3
$850
83
$850
e2
$30
e2
$30
$1195
$1270
Heavy
0.47%
al
SILO
bi
$30
dl
$100
5240
a2
$125
8.2
$55
ci
$173
dl
$200
el
$5
el
85
s o
a3
$200
b2
555
82
1500
e2
$30
e2
$30
aS
$125
bS
$265
d3
$850
e2
$30
$1270
D iese l-4s lrokc,naturallyaspirated
Heavy duty
Manufacturer I-
78-79dItA
Heavy
at lit dl
0.225% $110 $55 — $100
— —
0.02% al bI dl
$10 $55 — $100
aS bI dl
0.15% $110 $55 — $100
— — —
aS bi
0.015% $110 $30 — —
—
5265 a2
$125
‘1.2
8105
Cl
$200
dl
$ 00
$635
a3
5200
8.2
8105
d2
5500
835
a3
5125
b3
$515
43
$850
e2
$30
$1320
DiescI -4 stroke, naturally aspirated Idedium
Medium duty
Manufacturer. C
78-79dBA heavy
— —
a2
$25
$265 aS
$125
— —
$140 a2
$125
1.2
$105
b2
$105
ci
$150
cI
$150
dl
$200
dl
$200
el
85
I
55
5485
$585
a3
$50
a3
S200
8.2
5105
b2
$105
82
8500
82
$500
e2
$30
e2
530
aS
$50
aS
$125
8.3
$315
1,3
$315
d3
$850
13
$850
e2
$30
e2
$30
$1245
$1320
D inseI-4stro l se,tnrbochargesj
Heavy duty
Manufacturer H
75 il8A
Heavy
b2
$55
dl
8100
et
$5
$285
a3
$200
b2
$55
dl
$200
e2
$30
85
$200
1 ,3
5265
42
5500
e2
$30
II) Medium Duty and Heavy Duty refer to the severity of service
for 11w engine, 1.0110 inc weight class of the truck,
(2) Engine levels are for engines inside the truck as measured
accoeding to SAE J366b test pencedure.
AVirRAGES
AVERAGES
-------
0 \
Table 6-2
Key to Noise Treatments and Costs for TABLE 6-1
aaasrals
code for
.
t’iOtSt
n
.
Descnption of
Noise Control Treatment
.
Increase in Truck Purchase Price
Design
source Level
of Noise
Reduction
Fan
at
a2
a3
Improved fan and fan shroud design.
Tlsermostatically controlled fan clutch
on heavytrucks to allow removal of
radiator shutters.
Advanced system with improved fan
design, fan shroud and radiator design.
Includes fan clutch on heavy trucks.
Best system possible using available
technology; includes larger radiator
which requires redesigned cab on
heavy trucks.
$ 10 - Design substitutes for similar equipment.
$110 - Design substitutes ($10) plus net increase for replacing
radiator shutters with fan clutch ($100).
$ 25 - Net price increase for replacing radiator, fan and fan
shroud with ones of improved design.
$125 - Improved radiator, fan and fan shroud ($25) and fart clutch ($100).
$ 50 - Radiator, fan and fan shroud of improved design ($25) and
larger fan and radiator (525).
$125 - Radiator, larger fan and fan shroud of improved design ($25), and
and fan clutch ($100). Costs for larger radiator and rede.
signed cab are included in cab treatment d3 or d4
$200 - Radiator, fan and fan shroud of improved design ($25), larger
fan and radiator ($25), redesigned cab ($50) and fan clutch ($100).
73 ti M
70 dBA
64 dRA
Exhaust
b I
b2
b3
Best of presently available mufflers
and seals for exhaust leaks.
Advanced mufflers better than present-
ly available on 4-stroke engines;
manifold muffler and best of available
mufflers on 2-stroke engines. Seals
for exhaust leaks.
.
Best system possible uarn available
technology; includes advanced
mufflers, exhauat seals, double-wall
piping and muffler wrapping.
525-75 - Net price increase for replacing existing mufflers. Depends on
unsnuffled noise level; on 4-stroke engines $25-SO and on 2-stroke
engines $75,
$50-ISO - On 4-stroke engines; net increase for advanced mufflers, twice
increased for beat available mufflers (S 25-75), depends on
unmuffled noise level.
-
5260-360 . Advanced mufflers (550-150) depending on unmuffled noise
. .
level), manifold muffler ($150), muffler jackets ($30) and
insulated double-wall exhaust piping ($30).
For diesel trucks, add $5 for exhaust gas seals.
73 dbA
69 tiM
65 dilA
Engine
ci
Engine quieting kits - close fitting
covers and isolated or damped.
extenor parts - supplied by engine
manufacturer.
S 150-275 - For Diesel engines, estimates based on engine manufacturers’
prices for available kits.
$100 - For Gasoline engines.
2-3 dBA
Noise Reduction
Cab
d l
d l
d3
d4
Underhood treatment, such as acoustic
absorbing material, side shields and
recirculating panels.
Underisood treatment and underpan.
Partial (open front and back) engine
enclosure and special engine mounts.
Full engine enclosure and special
engine mounts.
$ 100-200 - For Diesel trucks; based on truck manufacturers’ estimates.
. Depends on needed noise reduction; 2-3dllA ($100) and 4dM
($200).
$50-ZOO - For Gasoline trucks.
$400-S00 - For Diesel trucka;underhood treatment (5100-200) plus underpan
($300),
$27 5-325 - For Gasoline trucks.
$850 - Partial engine enclosure ($715) and special engine mounts ($75).
Includes costs for Larger radiator and redesigned cab.
$1075 - Average of truck manufacturers’ estimates for full engine
losuse (5775-1300) and special engine mounts ($75).
Includes costs for larger radiator and redesigned cab.
2 -4 dBA
5-9 dRA
Noise Reduction
10-11 dRA
Noise Reduction
12-15 dRA
Noise Reduction
Air •
l istate ’
ci
e l
Improve air intAke design
Air intake silencer and unproved air
$ 5 - Design substitute for similar equipment.
$ 30 - Air intake silencer ($25) and design substitute for similar
equipment ($5).
69 dBA
65 CIBA
-------
On trucks equipped with radiator shutters, the fan usually stalls when the shutters are
closed, increasing fan noise levels. With a thermostatically controlled fan clutch, the radiator
shutters can be removed. The change in truck price for replacing the radiator shutters and
conventional fan hub with a fan clutch is $96 [ 7]. Adding the cost for replacing the fan and
fan shroud with ones of better design gives an approximate price increase for fan treatment
al of $110. Currently, radiator shutters are not widely used on medium trucks, therefore,
the costs of fan clutches are not included in price increases for medium trucks.
For the 80-dBA regulatory level, fan treatment a2 is used in Table 6-1 to reach a design
level of 70-dBA. In fan treatment a2, an improved radiator is added to fan treatment a 1 to
reduce the noise level from 73-dBA to 70-dBA. Using a radiator with the same frontal area
but more heat transfer area should be adequate to provide the 3-dBA of additional fan noise
attenuation [ 8]. The addition of an improved radiator, such as the serpentine type used in
automobiles, should not increase truck prices significantly. Production costs for a serpentine
radiator should be similar to those for a tube and fin radiator, which include the costs of
some hand assembling. In some trucks, it may be possible to optimize the fan-to-radiator
distance to achieve nearly the same reduction in fan noise [ 8]. An estimated price increase
of $25 for replacing the fan, fan shroud, and radiator with ones of better design is used for
fan treatment a2 (Table 6-1). For heavy trucks, the cost of $100 for a fan clutch is added.
A design level for fan noise of 64-dBA is selected for the 78- and 75-dBA regulatory
level. With the attenuation provided by engine noise shields, the use of a well-designed fan
shroud and larger slower-turning fan should be adequate to achieve a 64-dBA fan nOise level
[ 5]. The larger fan will require a larger radiator in most trucks. A $25 price increase is
given for replacing the existing radiator with one with a larger frontal area. For medium
trucks, the radiators are usually small enough so that larger radiators can be used without
requiring enlargement of the engine compartment. In addition, a fan smaller than the 31-
in-diameter fan used on the Freightliner DOT Quiet Truck should be adequate for most
medium trucks, since the cooling requirements are usually less than those for heavy trucks.
Therefore, the total price increase for fan treatment a3 in medium trucks is $50, which
includes the costs for cooling system design substitutions and a larger radiator.
On heavy trucks, where cooling requirements are usually greater, original equipment
radiators are larger than on medium trucks. For a square radiator, a frontal area of 1200
sq in should be adequate to accommodate the larger fan in treatment a3. This frontal area
represents an average increase in radiator size for h avy trucks of approximately 200 sq.
in. On the Freightliner DOT Quiet Truck, the net increase in cost for the 2000-sq-in radi-
ator over the cost for the standard I 200-sq-in radiator was estimated by Freightliner as
approximately $150. Based on this estimate, an increase in frontal area of about 200 sq
in would increase the price of a truck by $37.50. To accommodate an increase in radiator
size on most heavy trucks some modifications to the cab will be required to provide
6-5
-------
additional frontal area. The increase in price for tile larger radiator and the cab which had
room for a larger radiator and engine on the Freightliner DOT Quiet Truck is $300 [ 7]. Sub-
tracting $150 for the larger radiator yields a price increase of $1 50 for the larger cab. However,
since only the front part of the cab will need to be modified and radiators smaller than the
one used in the Freightliner truck will probably be sufficient, the increase in price for this
cab modification is $50. Adding the costs for design substitutions, a larger radiator and fan
clutch brings the total price increase to $200 for treatment a3. On heavy trucks where
partial or full enclosures are required for treatment of engine noise, the cost for the larger
radiator and additional space in the truck cab is included in the cost for cab treatment. The
costs for the larger radiator is included with the costs for cab treatments d3 and d4, where
applicable, since larger radiators will be required to provide additional cooling for enclosed
engines. In these cases, the price increase of $ 1 25 is used for fan treatment a3.
In estimating the costs for fan treatments, it is assumed that fans equipped with
thermostatically-controlled clutches will be required to be on during testing. If the fan clutch
is permitted to be disengaged during testing, then the costs for fan treatment (other than for
fan clutches), can be avoided.
Exhaust System
An exhaust system noise level of 73-dBA is given in Table 6-I for the 83-dBA regulatory
level. In order to reach this level, exhaust system noise treatment bi is used. The noise
levels for exhaust systems with the best mufflers currently being manufactured are 73-dBA
or below El]. The retail price for these mufflers range from about $40 to $80. Incremental
prices for $25 to $50 are used for replacing the existing mufflers with the best mufflers
currently being manufactured. A price increase of $50 is used for the 4-stroke diesel engine
models which have higher unmuffled exhaust noise levels. The unmuffled noise levels for
2-stroke diesel engines are about 10-cIBA higher than the unmuffled levels for the 4-stroke
engines [ 1]. Therefore, more attenuation of exhaust noise will be required on 2-stroke
engines in order to reach the 73-dBA design level. Mufflers, which are similar to the mufflers
used on the Internationa l Harvester DOT Quiet Truck should provide sufficient attenuation
to reduce exhaust noise lesrel to 73-dBA or below [ 91. Since the mufflers used in treatment
a 1 on 2-stroke engines provide more attenuation, their costs will probabLy be higher than the
costs for mufflers on 4-stroke engines which reduce exhaust noise levels to 73-dBA. Therefo’’,
the increase in truck price of $75 is given for treatment a 1 for 2-stroke engines. To reduce
noise from exhaust leaks, exhaust gas seals are used in treatment a 1 on diesel engines. The
price increase for exhaust seals should be approximately $5 [ 7].
An advanced system (Code b2) should be needed to reduce exhaust noise to the design
level of 69-cIBA for the 80- and 78-cIBA regulatory levels. This treatment will probably
6-6
-------
involve the construction of longer, wider mufflers, possibly with double wall construction to
reduce shell noise. The cost of these muffle rs will probably be more than the costs of the
best available mufflers. For purposes of estimating the price increases in Table 6-1, the
incremental price increases for the best available mufflers (Code bi) are doubled and
treated as conservative (i.e., high) estimates. The rationale is that mufflers typically provide
10-20 dBA attenuation, While two mufflers in series will not provide twice the attenuation
of one, 4-10 dBA of additional attenuation can be expected [ 1]. Accordingly, the price
increase estimates for Code b2 are $50-150.
A design level of 65-dBA for exhaust noise is given in Table 6-1 for the 75-dBA regula-
tory level: In order to reach this level, a manifold muffler, muffler jackets, and insulated
double-wall exhaust piping are added to the mufflers used in Code b2. The manifold muffler
used in the “Final Selection” exhaust system on the Freightliner DOT Quiet Truck reduced
the exhaust noise level from 70 to 65. .5-dBA [ 51. The manufacturer’s cost for a manifold
muffler is estimated at $100 [ 7]. Using a scaling factor of 1.5, the estimated price increase
for a manifold muffler is $150. Price increases of $30 are used for the muffler jackets [ 7],
and $30 for insulated double-wall exhaust piping. Using these estimates, the price increases
given in Table 6-1 for Code b3 are obtained by adding $2 10 to the price increases for the
advanced mufflers (Code b2).
Engine and Cab
In order to determine the reduction of engine noise needed to reduce the engine level
to the given design noise level, the difference between the engine noise design level and the
highest of engine noise levels given for each engine model is determined. By using the highest
of engine noise levels, the noise treatment used in Table 6-1 should be adequate to reduce
the noise from all engines of a given model enough to allow trucks to comply with the given
regulatory level.
Engine quieting kits are available for many diesel engines. These kits consist of close-
fitting covers and isolated or damped exterior panels. The estimated prices for these kits are
based on prices quoted by engine manufacturers and range from $100 to $275. When the
total required engine noise reduction is less than 3 dBA, underhood treatment (Code d 1)
is used since it is less costly. Engine quiet kits are used in some cases to obtain an additional
2-3dBA attenuation avoiding the need for the more costly underpan or providing additional
attenuation beyond the 1 5-dBA for full engine enclosures.
One truck manufacturer estimated that the increase in truck price for the application
of underhood treatment will be about $100 [ 1] for a truck equipped with a diesel engine.
This price is used to achieve the 2-3 dBA of engine noise attenuation. When noise reduction
6-7
-------
of 4-dBA is required for diesel engines larger side shields may be needed. In this case, an
estimated price for Code dl of $200 is used in Table 6-1. The $200 is the price increase for
“Shields” only [ 5], plus a price increase for “Interior Cab Treatment,” [ 3].
Because gasoline engines have half the side surface area as diesel engines, the size of
the engine side shields needed to provide the same noise attenuation for gasoline engines will
be about half the size of the shields used for diesel engine noise. Accordingly, the price
increases for treatment dl of $ 50-100 (estimated for smaller shield size) are used for gasoline
engines.
An underpan between the truck frame rails, acting as a barrier to engine noise radiated
from underneath the truck cab, is added to the underhood treatment (Code dl) providing
total engine noise reduction of 5-9 dBA [ 10]. Based on the Freightliner DOT Quiet Truck
[ 51, the price increase for the underpan is estimated at $300 as shown in Table 6-3. An
underpan of about 5 feet in length is used in making this estimate since a 5-foot underpan
should be adequate to cover the length of the engine (Table 6-9) so that engine noise reduc-
tions of 4-9 dBA can be achieved. As shown in Table 6-3, the $300 estimate is added to the
price estimates for the underhood treatment (Code dl) arriving at estimated prices of $400
to $500 for the cab treatment d2. A price increase of $400 is used for engine noise reduc-
tions of 5-6 dBA and $500 for 7-9 dBA noise reductions.
Since gasoline engines are, in general about a foot shorter than diesel engines (Table 6 9),
obviously the underpans used on gasoline trucks will be about 1 foot shorter. Using the
same procedure as in Table 6.3, price increases for treatment d2 of $275 to $325 is derived
for gasoline trucks.
When engine noise reductions of 10-15 dBA are needed, special engine mounts and a
partial or full enclosure is used (Table 6-2). A partial enclosure, (open in front and back),
is usec.i with special engine mounts (Code d3) to obtain 10-11 dBA of engine noise red uc
tion J5]. The increase in truck price with special engine mounts and a partial enclosure is
estimated at $850 [ 7] This estimate includes the costs for a cab with a larger engine com-
partment which may be necessary to accommodate the engine enclosure and for a larger
radiator to provide additional cooling for the enclosed engine. A full engine enclosure and
special engine mounts (Code d4) are used in Table 6-1 when 12-15 dBA of attentuation is
required. Price increases for full enclosures will depend on the initital truck cab configura-
tion. The estimated price increases for full engine enclosure made by truck manufacturers
range from $775 to $1300 [ 1]. For purposes of estimating the increases in truck prices
the average of the estimated price increase of $1,000 is used for full engine enclosures. The
price increase of $75 for special engine mounts [ 7]is added to the price increase for full
enclosures to obtain the estimated price increase of $1075 for Code d4. For the 75-dBA
regulatory level, two engine models require attenuation of 15 cIBA or more. For these
engines, an engine quieting kit (Code ci) along with a full enclosure (Code d4) are used.
6-8
-------
Table 6-3
Estimation of Price Increase for Cab Treatment d2 on Diesel Trucks
Cab Treatment d2
Purchase Price
Partial enclosure with 9-foot underpan and side shields
773
Side shields
267*
9-foot underpan (difference of I and 2, above)
506
5-foot underpan (5/9 of 3, above)
300
Side shields (S 100- 5200) and 5-foot underpan
5400-5500
* The side shields used on the Freightliner DOT Quiet Truck were part of the partial enclosure
which enclosed the engine and transmission and were therefore larger than the engine side
shields cafled for in treatments dl and d2 in step 5.
Air Intake
Of the 34 air intakes tested on diesel engines, a majority had noise levels below 72-dBA
[ 13]. Therefore, noise treatment should not be necessary for trucks complying with the
83-dBA regulatory level. However, some treatment may be necessary for the other regula-
tory levels. A design level of 69-dBA for the air intake noise should be low enough to allow
most trucks to comply with the 80-dBA regulatory level. Replacing the rain cap on the air
intake opening with one of better design reduced the air intake noise on the International
Harvester DOT Quiet Truck from 72- to 69-dBA [ 9]. Thus, it should be possible to quiet
most existing systems by replacing equivalent parts with parts of a better design (Code el).
The price has been estimated at $5.
For the 78- and 75-cIBA regulatory levels, a design level for air intake noise of 65-dBA
is used in Table 6-1. In addition, it was found that by reducing the air intake noise to 65-
dBA on some trucks complying with the 80-dBA regulatory level, a savings could be realized
by relaxing the required engine noise treatments. An air intake silencer should be sufficient
to provide the additional 4-dBA of attenuation [ 9] needed to reduce air intake noise to
65-dBA or below. An average estimated price of $25 is used in Table 6-I for air intake
silencers, so that the total estimated price increase for Code e2 is $30. In some cases, air
intake noise can be reduced to 65-dBA or below at a savings by using a non-snorkle air
intake [ 71
6-9
-------
Other Sources
The noise from sources other than the engine, fan, exhaust, and air intake (such as
transmissions, tires, and rear axles) should combine to generate a noise level of less than
70-dBA without treatment. Transmission noise levels for medium and heavy trucks are
approximately 70-cIBA or below. Maximum transmission noise levels of 68- to 70-dBA are
reported for the White Motors DOT Quiet Truck [ 3], using measurement positions at the
same distance (50 feet) specified in the SAE J366b test method, but at different orienta-
tions relative to the truck. The transmission noise levels reported for the International
Harvester DOT Quiet Truck were below 70-dBA [ 6], while the truck was in the measure-
ment zone defined for the SAE J366b test procedure. Therefore, few truck transmissions
should require noise treatment in complying with the 83-, 80- or 78-dBA regulatory levels.
For the 75-dBA regulatory level, the treatment of transmission noise is included in the
partial or full enclosures used to treat engine noise. Hence, the levels of the “other sources”
category is reduced to 65 dBA. In cases where enclosures were used in Table 6-1 to comply
with the 78-dBA regulatory level, the reduction of transmission noise produced by the
enclosure is included in the design levels. In one case, the savings associated with the use of
a partial enclosure instead of a full enclosure was realized.
The level of noise from ribbed truck tires at SAE J366 test speeds (below 3 5mph) are
approximately 65-dBA or lower [ 4]. On the Freightliner DOT Quiet Truck, a tire noise
level of 62-dBA was measured [ 5]. On the International Harvester DOT Quiet Truck, the
tire noise was 65-dBA or below [ 61. Therefore, tires should not need treatment in order for
trucks to comply with any of the regulatory levels considered in Table 6-1.
For the rear axle, the noise level reported for the Freightliner DOT Quiet Truck is
58-dBA [ 51. No noise treatment for the rear axle is included in the estimates of increases
in truck prices.
AVERAGE TRUCK PRICE INCREASES
The average price increases for medium and heavy gasoline and diesel trucks are given
at the bottom of Table 6-1. In computing the average price increases for diesel trucks, the
price increase associated with each engine model is weighted by the percentage of total truck
population for each engine model.
The average truck prices for 1973 presented in Table 6-4 can be obtained by multiply-
ing the 1972 prices [ 2] by the ratio of wholesale prices for trucks of 1.016 [ 161.
6-10
-------
Using average truck prices for 1973 [ 2] , presented in Table 6-4 and the average increases
in truck prices in Table 6-1, the percent increases in truck prices are computed for each truck
type. In computing the averages of price increases for all trucks for each regulatory level,
the truck price increases are weighted according to truck population figures [ 2].
Table 6-4
Percent Increases in Truck Prices due to Noise Emissions Regulations
Type of Truck
Average
Truck
Price
Percentage
of New Truck
Population
Percent Increase in Truck Price
Associated with Given Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline . -. .
Heavy gasoline . . . .
Medium diesel . . . .
Heavy diesel
Average for all trucks .
$ 5,836
$11,613
$ 7,360
$25,608
—
55.1%
10.2%
1.2%
33.5%
—
0.6%
1.2%
5.8%
1.5%
1.0%
3.1%
2.4%
11.8%
2.8%
3.0%
5.6%
4.1%
14.4%
3.8
4.9%
11.4%
7 ‘
22
9.
The price increases in Table 6-1 should be considered as conservative or worst-case
estimates for the following reasons:
• The demand for some of the noisy diesel engines should decrease. Manufacturer B
has indicated that the sales of their noisiest engine has already begun to decrease
[ 14]. In addition, the increased demand for quieter engines will encourage design
changes to quiet engines. A decrease in the population of noisy engines will reduce
the average price increases given in Table 6-1.
• Most of the estimates of price increase are based on data given in the DOT Quiet
Truck Program. In this program, existing heavy diesel trucks were quieted with-
out using major cab or engine modifications; this approach leads to greater costs
than would be incurred if such modifications were incorporated in the early
design stages. Where cost data was not available, conservative (i.e., high) estimates
were made. In addition, cost savings resulting from improvements in noise con-
trol technology were not considered.
• Savings due to high volume production of noise control hardware, probably
• necessary to meet the demand generated by noise emission regulations on trucks,
has been ignored.
6-1 1
-------
The sensitivity of estimations of truck price increases to the above assumptions is
briefly explored.
Projections of Truck Prices with Improved Technology
and Reduction in Production Costs
There are several areas where improvements in the noise reduction technology demon-
strated in the DOT Quiet Truck Program may occur in the production of new trucks comply-
ing with noise emission regulations. One of these areas is the reduction of engine noise by
modifying the engine itself. Modification of the engine was outside the scope of the DOT
Quiet Truck Program.
It should be possible to reduce the noise levels from all diesel engir es to 77-dBA and
the levels from all gasoline engines to 75-dBA without significant increases in manufacturing
costs per engine. Truck gasoline engines are presently available which have noise levels of
75-dBA. A heavy-duty diesel engine is currently manufactured with an average noise level
of approximately 77-dBA. This engine is given in Table 6-1 as the turbocharged heavy-duty
diesel engine from manufacturer D. This engine model comprises over 4 percent of the
truck diesel engine market and is priced comparable to noisier engines of similar size.
By assuming that all diesel engine noise levels are 77-dBA and all gasoline engine noise
levels are 75-dBA, the average price increases given in Table 6-5 can be derived by applying
the same procedure used in deriving the average increases presented in Table 6-1.
If, in addition to the assumption that engines can be quieted, it is assumed that the costs
of noise control hardware currently in production (e.g., fan clutches and exhaust mufflers)
will be reduced by 10 percent as a result of increased production and the costs of hardware
not currently in production (e.g., manifold mufflers, and cab side-shields and underpans)
will be reduced by 50 percent when demand forces full production, the increases in the
truck prices given in Table 6-1 are obtained.
The above assumptions used in estimating the price increases given in Tables 6-5 and
6-6 are not based on published information on past experience in quieting trucks, but repre-
sent projections of possible applications of available technological principles in the produc-
tion of quiet trucks and predictions of future cost reductions. Therefore, these estimated
price increases are not supported by published data on noise treatment costs, as are the
estimated price increases given in Table 6-1. However, the estimated price increases in
Table 6-1 are conservative and the price increases given in Tables 6-4 and 6-5 indicate the
savings which may be achieved by quieting engines and degree to which the estimated price
increases in Table 6-1 may be overstated.
6-12
-------
Truck Price Increases with Fan-Off Compliance Testing
On trucks equipped with fan clutches, the fan should be turned off a large percentage
of the time during normal operation, so that the contribution to environmental noise from
the fan would be significantly reduced. If trucks equipped with fan clutches are permitted
to be compliance tested with the fans off, then these trucks can be designed with the
assumption that there will be no noise contribution from the cooling system. Eliminating
the fan noise in the design levels given at the top of Table 6-1, raising the engine noise
design levels by 1 dBA, and using only a $100 fan clutch as the most costly cooling system
treatment, the price increases in Table 6-1 can be reduced to give the average price increases
presented in Table 6-7. The largest savings occur for heavy trucks which will use fan clutches
Table 6-5
Estimated Increases in Prices for Regulated Trucks,
Assuming that all Engines can be Quieted*
Type of
Truck
Regulatory Levels
83dBA
8OdBA
78dBA
75dBA
Medium Gasoline ...
Heavy Gasoline
Medium Diesel
Heavy Diesel
$ 10
110
63
170
$130
230
256
370
$230
380
515
677
$ 540
690
891
1055
*Djesel = 77dBA, and gasoline = 75dI lA
Table 6-6
Estimated Increases in Prices for Regulated Trucks,
Assuming that all Engines can be Quieted and Manufacturing
Costs will Decrease with Increased Production
Type of
Truck
Regulatory Levels
83dBA
8OdBA
78dBA
75dBA
Medium Gasoline....
Heavy Gasoline
Medium Diesel
Heavy Diesel
$ 9
99
57
153
$ 90
180
171
271
$161
276
344
318
$368
484
511
636
6-13
-------
Table 6-7
Estimated Increases in Truck Prices Assuming
Fan-Off Compliance Testing
Typeof
Truck
Regulatory Levels
83dBA
8 OdBA
78dBA
75dBA
MediumGasoline....
Heavy Gasoline
Medium Diesel
Heavy Diesel
$ 35
125
426
356
$180
255
850
589
$ 330
380
1059
860
$ 665
715
1624
1363
even if testing is done with the fan on. If for reasons other than noise reduction trucks are
equipped with fan clutches before the effective date of the 83dBA regulatory level, then
the net price increase for fan clutches ($100) can be saved on heavy trucks.
CHANGES IN OPERATING COSTS
Noise treatments affect the operating costs of medium and heavy trucks by (1) chang-
ing the truck performance which affects the rate of fuel consumption, and (2) changing the
ease and amount of required maintenance.
Costs of Changes in Rates of Fuel Conswnption
In this section, the changes in fuel costs per truck-mile are predicted for each engine
model, regulatory level, and noise treatment by:
1. Estimating the changes in truck operating properties produced by noise treatments
which affect the rate of fuel consumption,
2. Estimating the sensitivity of the rate of fuel consumption to the changes in truck
properties, and
3. Multiplying the product of the changes in truck operating properties and the
factors of fuel consumption sensitivity by average fuel costs.
6-14
-------
Changes in Truck Operating Properties
Table 6-8 shows the estimates of the changes in truck tare (empty) weight, exhaust
backpressure and required accessory power for each of the noise treatments used in Table 6-1.
The derivation of these estimates are described.
Cooling System Treatments
Design Substitutes (Code a])
This cooling system treatment involves the substitution of the existing fan and fan
shroud with ones of better design, so that the fan speed can be reduced without loss in
volumetric air flow. The change in weight is negligible. Medium trucks are assumed not to
use fan clutches. Without fan clutches, the average power saving for medium diesel trucks
is estimated at 5 hp. The maximum power savings with fan and fan shroud substitutions,
other than fan clutches, for the trucks in the DOT Quiet Trucks Program were approximately
5.5 hp [ 3], [ 7] and [ 9]. For medium diesel trucks, the maximum savings should be fairly
close to the average savings, since diesel engines are designed to run close to maximum rated
speed at all loads. For medium gasoline trucks, the lower power requirements are assumed
to cause the average speed to be approximately 75 percent of the rated speed, yielding
approximately half the power savings (2.5 hp).
The only available data on fan power requirements relate to diesel engines. To estimate
the requirements for gasoline engines, it should be noted that two competing effects occur
in going from diesel to gasoline engines. The net heat rejection into the block for gasoline
engines is higher than that for diesel engines [ 11]. On the other hand, the surface area-to-
volume ratio is higher for gasoline engines, as well as the clearances between the engine and
surrounding structures. -These lead to higher heat rejection effectiveness for gasoline
engines [ 11]. It is therefore assumed that for a given rated engine horsepower, cooling
fans on gasoline and diesel engines require the same power input.
For heavy trucks, fan clutches are used to replace radiator shutters. The extra weight
of the fan clutch hub is approximately 20 pounds, but this is almost exactly balanced by the
weight of the removed shutters [ 7]. Because the fan clutch should be disengaged most of
the time [ 1 2], virtually all of the power needed to drive the fan will be saved. The power
requirements for the fan reported in the DOT Quiet Truck Program for heavy diesel
trucks with engines at the governed speed of about 2100 rpm were between 17 and
19.5 hp [ 8] and [ 7]. Since both gasoline and diesel engines are typically operated at
speeds near 2000 rpm, the average power savings with the fan off should be near the maxi-
mum power requirements reported in the DOT Quiet Truck Program. Therefore, the
average power savings with fan clutches is assumed to be 15 hp for heavy trucks.
6-15
-------
Table 6-8
Change in Physical Properties of Trucks with Noise Treatments
Noise
Treat-
ment
Increase in
Truck Weight
Increase in
Exhaust
Back
Pressure
or Air Intake
Decrease in Accessory
Power Requirements
Medium Truck
Heavy
Gasoline
Diesel
Code
Description
Trucks
Trucks
Restriction
Gasoline
Diesel
Truck
(Pounds) (Pounds) (Inches of hp) hp) Oip)
H 2 0)
4- 2-
Stroke Stroke
a! Fan design substitutes without
fan clutch 0 0 2.5 5
Fan design substitutes with
fanclutch 0 0 — — 15
a2 Advanced system without
fan clutch 0 0 4.5 9 —
Advanced system with fan
clutch o 0 15
a3 Best available technology sys-
tem without fan clutch 10 10 6 12 —
Best available technology sys-
tem withfanclutch 10 10 — — IS
bi Best available mufflers 25 25,50 or 0 0 —
100(2)
b2 Advanced mufflers 50 50,100 or 0 2
150(2)
b3 Best available technology
system 135 135,185 or 2 20
23 5(2)
c i Engine quiet kit 12 25
dl Underhood treatment and side
shields 25 55 — —
d2 Treatment dl with underpan 60 120 — —
d3 Partial engine enclosure — 500 — —
d4 Full engine enclosure — 500 — —
ci Air intake design substitutes 0 0 0 0
e2 Air intake silencer and design
substitutes o 0 0 0
(1) The treatment ha no effect or is not used on this type of truck.
(2) Depending on uninuffled level — highest weight for 2-stroke diesel engines.
6-16
-------
Advanced System (Code a2)
This treatment consists of improvements in the fan, fan shroud and radiator design to
reduce the fan speed without reducing volumetric air flow. Improvements in the fan, fan
shroud and radiator designs, and optimization of radiator-to-fan distance are included in the
treatment. Increasing the fan size enough to require a larger radiator is not included in this
treatment. On medium trucks, a fan clutch is not used. The power savings on medium
diesel trucks is expected to be nearly 9 hp [ 8]. On medium gasoline trucks, half the savings
(4.5 hp) is used in Table 6-7. As discussed above, the fan clutches on heavy trucks should
provide a power savings of about 15 hp without significantly increasing the weight of the
truck.
Best A vailable Technology (Code a3)
The principal feature of this treatment is a larger fan which should require a radiator
with a larger frontal area. The increase in weight for the larger radiator should be small (less
than 11 pounds, [ 5]), since the increase in frontal area is accompanied by a decrease in radia-
tor thickness. A value of 10 pounds is given in Table 6-8. Without the fan clutch, the power
savings for medium diesel trucks should be about 12 hp [ 12]. Half the savings is assumed for
medium gasoline trucks. The fan clutch on heavy trucks should provide power savings of
nearly 15 hp.
Exhaust System Treatments
Best of Currently Available Mufflers (Code bi)
This treatment consists of replacing stock mufflers with currently available mufflers
which provide the highest noise attenuation. The net increase in weight for the mufflers used
on the Freightliner DOT Quiet Truck was approximately 50 pounds [ 7]. Therefore, for
4-stroke engines with unmuffled noise levels similar to the Freightliner truck, a net increase
in weight of 50 pounds is given. A net increase in weight of 25 pounds is used for 4-stroke
engines with lower unmuffled noise levels. Since the unmuffled noise levels for 2-stroke
diesel engines are higher than the levels for 4-stroke diesel engines, larger heavier mufflers
will probably be needed to achieve the same muffled exhaust noise level. The mufflers used
on the 2-stroke diesel engine in the International Harvester DOT Quiet Truck were 130
pounds heavier than the original equipment mufflers [ 9]. However, these mufflers pro-
vided more attenuation than needed for treatment b 1. Therefore, the mufflers for treatment
b 1 on 2-stroke diesel engines should be lighter. Accordingly, a net increase in weight of 100
pounds is given in Table 6-8.
6-17
-------
A comparison of the backpressures developed by several systems shows that systems
with mufflers which provide higher noise attenuation have nearly the same backpressure as
systems with mufflers which provide less attenuation [ 1]. Therefore, insignificant increases
in backpressure are expected for exhaust systems with the best available mufflers (Code b 1).
Advanced Mufflers (Code b2)
For exhaust treatment b2 on 4-stroke engines, the weight increase of twice the increase
for treatment b I is given in Table 6-8. For exhaust treatment b2 on 2-stroke diesel engines,
50 pounds is added to the weight increase of treatment b 1. These increases in weight should
result from the use of larger heavier mufflers than used in treatment b 1.
For treatment b2 on 4-stroke engines, the backpressure is not expected to increase
significantly over the backpressure for treatment bl, since larger mufflers will be employed.
However, an increase in bacRpressure for 2-stroke diesel engines similar to the 2-inch increase
for the “Final-Selection” exhaust system on the Freightljner DOT Quiet Truck [ 7] is
expected.
Best A vailable Technology System (Code b3)
In going from treatment b2 to b3, a manifold muffler, double-wall exhaust piping and
muffler wraps are added. The net increase in weight for the manifold muffler is 50 pounds
[ 7], and the muffler wraps 20 pounds [ 71. The net weight increase for the double-wall
exhaust piping is estimated at 15 pounds. Therefore, a total of 85 pounds is added to the
weight increases for treatment b2 in estimating the weight increases for treatment b3. The
weight increases in Table 6-8 for treatment b3 are nearly equal to the weight increases of
140 and 160 pounds reported for the exhaust system with a manifold muffler used on the
Freightliner DOT Quiet Truck [ 7].
The increase in backpressure of 2 inches of H 2 0 is given in Table 3-8 for treatment b3
on 4-stroke engines. This is similar to the increase in backpressure for the “Final-Selection”
system used on the Freightliner DOT Quiet Truck [ 7]. For 2-stroke diesel engines, increases
in backpressure of about 20 inches of H 2 O are expected. These increases are similar to the
increases produced by the mufflers used on the International Harvester DOT Quiet Truck
[ 9]. The addition of double wall piping and muffler wraps should not increase backpr ssure.
6-18
-------
Engine Treatments
Engine Quiet Kits (Code ci)
The engine quiet kit used on the Freightliner DOT Quiet Truck increased the truck
weight by 20 pounds [ 7]. On the White Motors DOT Quiet Truck, the engine quiet kit
weighed 25 pounds [ 3]. Thus, a conservative estimate of the average increase in the weight
of diesel trucks with the addition of quiet kits is 25 pounds. For gasoline engines, no com-
mercial kits are presently available. Because gasoline engines have approximately half the
surface area of diesel engines (see Table 6-9 L the weight for quiet kits for gasoline engines
is estimated at 12 pounds.
Cab Treatments
The cab treatments consist of baffles and panels attached to the cab structure to pro-
vide shielding from engine noise. The first two treatments (d 1 and d2) are designed to baffle
only the engine block. Therefore, the size and weight of these treatments will depend on the
size of the engine. Since there is a significant difference in the size of diesel and gasoline
engines, separate estimates of weights for treatments d 1 and d2 will be given for diesel and
gasoline engines. The other treatments (d3 and d4) are not used on trucks with gasoline
engines, so that weight estimates are given only for diesel trucks.
Underhood Treatment and Side Shields (Code d l) and Underpan (Code d2)
The rationale for deriving the weights of treatments d 1 and d2 is as follows [ 11].
First, the dimensions of a typical engine block were obtained from catalog information. Then,
the dimensions of the smallest rectangular prism were obtained which would enclose the
engine on its sides, top and bottom were estimated. These dimensions are given in Table 6-9.
This prism includes the turbocharger where appropriate, but not the air intake. The dimen-
sions of this prism are multiplied by a factor of 1.5 to allow for clearances and overhang at
the ends. On the basis of the Freightliner DOT Quiet Truck design, the underhood treatment
was assumed to cover the top of this prism and one-third of the side area. Similarly, side
shields were assumed to cover one-sixth of the side area, and the underpan was assumed to
cover the bottom of the prism and the lower one-third of the side area. The remaining one-
sixth of the side area was assumed to be taken up by the frame mils. By this means, the
dimensions of the underhood treatment, the side shields and the underpan given in Table
6-9 were established.
6-19
-------
To obtain weights, the area of the underhood treatment, which should require no
structural members, is multiplied by an area density of 1-lb/ft 2 to account for the installa-
tion of sound absorbing materials [ 7]. This procedure gives the weights shown in Table
6-9. From Table 6-9, rounding the weights up to the nearest 5 pounds, the weight esti-
mates given in Table 6-8 for treatments dl and d2 can be obtained.
Engine Enclosures (Codes d3 and d4)
Engine enclosures should not be required on gasoline trucks to comply with regulatory
levels of7 5-dBA or above. The weight of the partial enclosure on the Freightliner DOT
Quiet Truck was 455 pounds [ 7] , including the weight increase for a cab with a larger
engine compartment. The full engine enclosure on the Freightljner DOT Quiet Truck in-
creased the truck weight by 463 pounds [ 7]. These weight increases are rounded to the
nearest 50 pounds to allow for additional structural modifications which may be required in
trucks with conventional cabs.
Table 6-9
Dimensions and Weights for Cab Treatments dl and d2
Diesel Engine (Overall Engine Dimensions: 50” long x 50” high x 30” side) ’
Treatment
Area (ft 2 )
Density (lb/ft 2 )
Weight (Ib)
Underhood
Side shields
Underpan
33
9
33
1
2
2
33
18
66
Total 117
Gasoline Engine (Overall Engine Dimensions: 35” long x 30” high x 25” wide) (2)
Treatment
Area (ft 2 )
Density (lb/ft 2 )
Weight (ib) —
Underhood
Side shields
Underpan
16
4
16
1
2
2
16
8
32
Total 56
(1) Source: Catalog Information from Cummins and Catapillar
(2) Source: Chrysler catalog information
6-20
-------
Air Intake Treatments
Design Substitutes (Code el) and Silencer (Code e2)
On the International Harvester DOT Quiet Truck, it was possible to apply treatment to
the air intake without increasing the air intake restriction. On the Freightliner DOT Quiet
Truck, a reduction in the air intake restriction was reported for the quieter non-snorkie air
intake. No air intake treatment was needed on the White Motors DOT Quiet Truck. There-
fore, on the average, treatments of air intake noise should not decrease engine performance.
Increases in truck weight with air intake treatments are expected to be negligible.
Effect of Noise Treatment on Rates of Fuel Consumption
The change in the rate of fuel consumption (in gallons per mile) are given in Tables 6-10
per unit increase in truck weight, exhaust backpressure and accessory horsepower [ 1]. Both
4-stroke and 2-stroke engines have approximately the same sensitivity to exhaust backpres-
sure [ 15]. To determine the change in the rate of fuel consumption for each noise treatment
presented in Table 6-2, changes in truck weight, exhaust backpressure or accessory power,
(given in Table 6-8), are multiplied by the appropriate coefficients in Table 6-10. The
products are summed for each treatment to yield the results presented in Table 6-11.
Following the procedure used in Table 6-1, the data in Table 6-il can then be used to com-
pute the average changes in the rates of fuel Consumption given in Table 6-12. By comparing
the rates of fuel consumption given in Table 6-1 1 with the mtes in Table 6-12, it can be
Table 6-10
Effect of Truck Properties on Rate of Fuel Consumption
Increase in Fuel Consumption
Type of Truck
Per Unit
Increase in
Weight
(GPM/lb)
Per Unit
Increase in
Backpressure
(GPM/m H 2 0)
Per Unit
Increase in
Accessory
Power (GPMfhp)
Medium gasoline.
Heavy gasoline..
Medium diesel ..
Heavy diesel....
3.25x10 6
3.25x10 6
1.77x10 6
1.77x10
0
0
3.6xlcr 5
1.5xlO M
3.5x10 3
1.9x10 3
1.9x10 3
1.0x10 3
6-21
-------
Table 6- 1 1
Effect of Noise Treatment on Rate of Fuel Consumption
Noise
Change in Rate of Fuel Consumption (Gallons/Mile)
Medium
Heavy
Medium
Heavy
Treatment
Gasoline
Gasoline
Diesel
Diesel
al -8.75x10 3 —2.85x10 2 —9.5xl0 3 —l.50x10 2
a2 —l.58xl0 2 —2.85x10 2 —1.71x10 2 —1.50x10’ 2
a3 -2 .lxlO —2.85xl0 2 -2.28x10 2 —l.50x10 2
bi 8.1x10 5 8.lxlO 5 4 .4xl0 5 4.4xl0 5
8 .8x10 5 8.8x10 5
1.8xl0 4 l .8x10 4
12 l .6x10 4 l.6x 10 4 8.8x10 5 8.8x10 5
l.8x11t 4 1.8xltY 4
2.6xl0 4 5.6xl0 4
b3 4.4x1O 4 4.4xl0 4 3.lxIO 4 5.4x1tY 4
4.Ox lO 4 6.3x10 4
4.9xIOM 3.4x10 3
ci 3.9xl0 5 3.9x 10 5 4.4xlO 5 4.4xlO
dl 8.lxlO ’ 5 8.lxlO 5 9.7x11t 5 9.7xl0 5
d2 2.Ox lO 4 2.0x10 4 2.lxlOM 2.1x10 4
d3 8. Sx IO M 8.8x 10 4
d4 8. SxlO 4 8.8x10 4
el 0 0 0 0
e2 0 0 0 0
observed that the changes in the rate of fuel consumption are dominated by the decrease in
fuel consumption associated with the decrease in accessory power which results from fan
treatments.
6-22
-------
Changes in Fuel Costs
By multiplying the figures in Table 6-12 by fuel costs per gallon and annual truck
mileage, the change in annual fuel costs can be determined. Using the average fuel costs
per gallon for 1973 and the average annual mileages given in Table 6-13 11], the savings
in average annual fuel costs given in Table 6-14 are determined.
Noise emission regulations on trucks will encourage the use of more efficient fans and
fan clutches. However, other considerations, such as fuel savings, are also factors presently en-
cow-aging the use of more efficient fans and fan clutches and will probably continue to en-
courage their use in the absence of noise emission regulations. Therefore, to credit all of the
savings from more efficient fans and fan clutches on all trucks to noise emission regulations
may not be realistic. If credit for the savings from more efficient fans and fan clutches is not
taken, the change in average annual fuel costs given in Table 6-15 are computed.
Table 6-12
Estimates of Changes in Rates of Fuel Consumption
Type of Truck
[ Changes in Rate of Fuel Consumption (Gallons/Miles)
83dBA
SOdBA
78dBA
75dBA
Medium gasoline.
Heavy gasoline ..
Mediumdiesel ..
Heavy diesel ....
—8.7xl(r 3
—2 ,84x1(r 2
—9.4xlIP
-l.4 lxlcr 2
—l.56xlT 2
—2.83xl(r 2
—l.62xl1r 2
—1.44x10 2
—2.08x10 2
—2.83x10 2
—2.l9xlcr 2
—l.42xl1r 2
—2.04x1 IF 2
—2.79xl(r 2
—2.15x10 2
—l.24x11r 2
Since the assumptions used in deriving the truck price increases in Tables 6-5, 6-6 and
6-7 do not effect fan treatments and the power savings from fan treatments are the dominant
factor in determining the changes in fuel costs giten in Table 6-14, these assumptions are not
expected to significantly impact fuel costs. Therefore, the fuel costs given in Table 6-14
and/or derivable from Table 6-12 can be used with price increases in Table 6-5, 6-6 or 6-7.
6-23
-------
Table 6-13
Annual Mileage and Fuel Prices by Type of Truck
Type of Truck
Annual Mileage
(10 mi/yr)
Fuel Price
(s/gal)
Medium gasoline
Heavy gasoline
Medium diesel
Heavy diesel
10
18
21
54
0.50
.50
.30
.30
Table 6-14
Estimates of Changes in Average Increases in Annual Fuel Costs,
Including Savings from More Efficient Fans and Fan Clutches
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline . . . .
Heavy gasoline
Medium diesel
Heavy diesel
$ ( 44)
(256)
( 59)
(238)
$ ( 78)
(255)
(121)
(233)
$ (104)
(255)
(138)
(230)
$ (102)
(251)
(135)
(201)
Table 6-15
Estimates of Changes in Average Increases in Annual Fuel Costs,
Excluding Savings from More Efficient Fans and Fan Clutches
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline . .. .
Heavy gasoline
Medium diesel
Heavy diesel
$ 0
1
2
4
$ I
2
6
10
$ 1
2
6
12
$ 3
6
10
41 —
6-24
-------
CHANGES IN COSTS FOR MAINTENANCE
Changes in costs for maintenance will probably occur as a result of the addition of
engine noise shields or enclosures, and improved exhaust systems. No appreciable changes
in maintenance costs are expected for treatment of cooling system or air intake noise. The
added maintenance cost for fan clutches is expected to be offset by the decrease in main-
tenance cost for the removed radiator shutters. [ 7]. Estimates of the changes in annual
maintenance costs are shown in Table 6-16 for each exhaust, engine and cab treatments.
The derivations of these estimates are described below.
Exhaust System Treatments
The changes in maintenance costs given in Table 6-16 for exhaust system treatments are
based on replacing the mufflers three times in 8 years [ 1 1. For diesel trucks, credit for the
labor savings of 3 man-hr/yr. at an hourly rate of $10 and for $25 per year savings in material
costs associated with the use of exhaust gas seals [ 7} is subtracted from the increased main-
tenance costs attributed to muffler replacements.
Engine and Cab Treatments
The estimate in Table 6-16 for the engine quiet kit is based on an increase in maintenance
labor of 1.25 man-hr/yr at $10 per man-hour and $60 costs per year for additional materials.
These are the estimates given for the quiet kit used on the Freightliner DOT Quiet Trucks [ 7].
No increase in maintenance costs a-re given for the underhood treatment and side shields
used on the Freightliner truck. For the partial enclosure, an increase in labor àf 6 man-hr/yr.
is estimated. For the full enclosure, 32 man-hr/yr of increased maintenance labor is reported.
No added material costs were required for maintenance of either type of enclosure [ 7].
Using a labor rate of $10 per man-hr., the increased maintenance costs given in Table 6-16
are obtained. Increases in maintenance costs similar to the costs for the partial enclosure are
used for treatment d2, since the removal of the underpan in both treatments should be the
source of most of the maintenance costs.
6-25
-------
Table 6-16
Changes in Annual Maintenance Costs Caused by Noise Treatments
Noise
Treatment
Description
Change in Annual
- - - - Maintenance Costs
bi
Best available mufflers
Medium
Gasoline
Heavy
Gasoline
Medium
Diesel
Heavy
Diesel
$ 9
$19
$ (46)
$ (36)
b2
Advanced mufflers
19
38
(36)
(17
b3
Best available technology system
38
76
(17)
21
•
ci
Engine quiet kit
72
72
72
72
di
Underhood treatment and side shields
0
0
0
0
d2
Treatment dl with underpan
60
60
60
60
d3
Partial engine enclosure
—
—
60
60
d4
Full engine enclosure
—
—
320
320
The average changes in maintenance costs can be derived using the same procedure used
in Table 6-1 2 for estimating the changes in rates of fuel consumption. Instead of the changes
in rates of fuel consumption, the annual changes in maintenance costs in Table 6-1 6 are used.
The results are presented in Table 6-17. When credit for the savings in maintenancecosts for
exhaust gas seals are not taken, $55 is added to the costs given in Table 6-17 for diesel trucks.
The total change in maintenance costs on the Freightliner DOT Quiet Truck during
112,000 miles of linehaul service was $250 [ 17]. With an average annual mileage of 54,000
miles, the average change in maintenance costs would be $1 20/year. This figure is lower
than the estimate given in Table 6-17 for heavy diesel trucks that comply with the 75-dBA
regulatory level.
Average Annual Operating Costs
By adding the average annual maintenance costs in Table 6-17 to the average changes in
annual fuel costs presented in Table 6-14, the average changes in annual operating costs in
Table 6-18 ire obtained. Using the results for changes in fuel costs in Table 6-15, where savings
from more efficient fans and fan clutches are not included, the average changes in annual
operating costs given in Table 6-19 are obtained.
6-26
-------
The average operating costs for Class I Common Carriers of general freight are $0.1 29
per truck mile [ 20]. This cost estimate includes costs for fuel, tires and tubes, repairs and
service, but it does not include state and federal fuel taxes. Using the average annual mileage
figures in Table 6-13, one can compute the estimates of the average annual operating costs
per truck given in Table 6-20. The percent increases in the operating costs, when credit for
savings from noise treatments is not taken, are computed from the average annual operating
costs and the changes in operating costs in Table 6-19. In computing the averages of the
percent changes in operating costs, we weighted the percent changes in operating costs accord-
ing to the truck population figures in Table 6-4.
Table 6-17
Estimates of Changes in Annual Maintenance Costs
.
Type of Truck
Changes in Annual Maintenance Costs
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline ....
Heavy gasoline
Medium diesel
Heavy diesel
$ 9
19
( 6)
(20)
$ 19
(38
25
32
$ 91
110
195
85
$ 98
136
277
180
Table 6-18
Estimates of Changes in Annual Operating Costs, Including Savings
from More Efficient Fans, Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline .. . .
Heavy gasoline
Medium diesel
Heavy diesel
$ ( 35)
(237)
( 65)
(258)
$ ( 54)
(217)
( 96)
(201)
$ ( 13)
(145)
57
(145)
$ ( 4)
(115)
142
( 21)
6-27
-------
Table 6-19
Estimates of Changes in Annual Operating Costs, Excluding Savings
from More Efficient Fans, Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline ... .
Heavy gasoline
Medium diesel
Heavy diesel
$ 9
20
51
39
$ 20
40
86
97
$ 92
112
256
152
$ 101
142
342
276
Table 6-20
Percent Increases in Operating Costs Due to Noise Emission Regulations
Type of Truck
Average Annual
Operating Costs
Per Truck
Percent Increase in Operating Costs
Without Credit for Savings from More Efficient
Fans, Fan Clutches, and Exhaust Gas Seals
83 dBA
80 dBA
78 dBA
75 cIBA
Medium gasoline. . .
Heavy gasoline . . . .
Medium diesel • . .
Heavy diesel
Average of all
trucks
$ 1290
2322
2709
6966
—
0.7%
0.9
1.9
0.6
0.7%
1.6%
1.7
3.2
1.4
1.6%
7.1%
4.8
9.4
2.2
5.2%
7.8%
6.1
12.6
4.0
6.4%
Total Increase in Truck User Costs
The total change in costs to the user of a truck which complies with noise emission
regulations can be expressed in terms of the present value of the changes in the costs incurred
6-28
-------
during the life of the truck. In computing the present value of the total change in costs per
truck, we discounted the changes in the costs attributed to noise treatments during each year
of the truck life at a specified rate of return according to the following equation [ 7].
n0 (11-i)
where,
C is the present value of the total change in costs per truck,
£ Rfl is the change in costs in the 11 th year of the truck life,
m is the total life of the truck in years, and
i is the rate of return on invested capital.
In equation (1) i R 0 is the increase in purchase price, n 1, 2, : , rn-I is the change
in annual operating costs (a negative value of L R indicates savings), and Rm is the change
in annual operating costs minus the resale value of the noise treatments on the truck after
the mth year of service.
In computing the present value of the total change in costs per truck, we used the
following assumptions.
1. The average life of trucks is 10 years [ 21; thus, m 10 in equation (1). At the end
of 10 years, the value of the noise treatments is zero.
2. During the 10-year life, the average annual mileages for each type of truck is as
presented in Table 6-21 (2].
3. For the trucking industry, the rate of return on capital before taxes is 10 percent
[ 18]. Thus,i0.1 in equation (1).
With the above assumptions, the present values given here are changes in the total costs or
savings before taxes over the life of the truck.
In Table 6-22, the present value of the total change in costs per truck for regulated
trucks is presented with fan-on testing and credit for costs and savings for more efficient
fans, fan clutches and exhaust gas seals included. If credit for more efficient fans, fan
clutches and exhaust gas seals is not included, the present values of the total change in costs
per truck in Table 6-23 can be computed. The present values given in Tables 6-24 and 6-25
6-29
-------
assuming fan-off testing permitted are estimated by subtracting the differences in the price
increases in Tables 6 -1 and 6-8 from the present values given in Tables 6-22 and 6-23.
With the average truck prices in Table 6-4, the estimated operating costs of $0.1 29
per truck mile [ 201,and the annual truck mileages in Table 6-2 1, one can use equation (1)
to estimate the present value of the total costs per truck; e.g., for medium gasoline trucks
— $16,779, heavy gasoline trucks — $28,384; medium diesel trucks — $23,760, and heavy
diesel trucks — $67,628. The results in Tables 6-22 through 6-25 can be compared to
these estimates of total costs to indicate the relative increase in costs per truck associated
with noise emission regulations.
Table 6-21
Average Annual Truck Mileage
Age of
Truck
(Years)
Medium
Gasoline
(10 miles)
Heavy
Gasoline
(10 miles)
Medium
Diesel
(l0 miles)
Heavy
Diesel
(10 miles)
1
2
3
4
6
7
8
9
10
23
20
16
13
11
10
9
8
7
7
33
29
25
21
18
16
15
13
12
10
30
27
24
22
19
17
15
13
12
11
73
67
61
55
50
45
40
37
34
31
Table 6-22
Present Value of Total Change in Costs per Truck with Fan-On Testing
and Credit for Costs and Savings for More Efficient Fans,
Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dB A
Medium gasoline
Heavygasoline
Medium diesel
Heavy diesel .
$ -283
-1594
33
-1169
$ -365
-1333
286
—489
$ 7
-690
1422
1fj
$ 402
-162
2512
1346
6-30
-------
Table 6-23
Present Value of Total Change in Costs per Truck with Fan-On Testing
and Without Credit for Costs and Savings for More Efficient Fans,
Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Levels
83dBA
8OdBA
78dBA
75dBA
Medium gasoline
Heavy gasoline
Medium diesel
Heavy diesel
$ 80
149
724
511
$ 280
403
1373
1180
$ 848
970
2475
1729
$1243
1494
3595
3015
Table 6-24
Present Value of Total Change in Costs per Truck with Fan-Off Testing
and Credit for Costs and Savings for More Efficient Fans,
Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Levels
83dBA
8OdBA
78dBA
75dBA
Medium gasoline
Heavy gasoline
Medium diesel
Heavy diesel
$ -283
-1604
33
-1200
$ -365
-1357
271
615
$ 7
-790
1422
-5
$ 4 3
-262
2512
1255
Table 6-25
Present Value of Total Change in Costs per Truck with Fan-Off Testing
and Without Credit for Costs and Savings for More Efficient Fans,
Fan Clutches and Exhaust Gas Seals
Type of Truck
Regulatory Level
83dBA
8OdBA
78dBA
75dBA
Medium gasoline
Heavygasoline
Medium diesel
Heavy diesel
$ 80
139
724
480
$ 280
377
1348
1054
$ 848
870
2475
1613
$1243
1394
3595
2924
6-31
-------
REFERENCES
[ 1 BENDER, E. K, W. N. PATTERSON and G. E. FAX. The technology and cost of
quieting medium and heavy trucks, BBN Report 2710. Bolt Beranek and Newman,
Cambridge, Mass. (October 30, 1974).
[ 21 ENVIRONMENTAL PROTECTION AGENCY. Background document for proposed
medium and heavy truck noise regulations, EPA550/974Ml3. Office of Noise
Abatement and Control, Washington, D. C. 20460 (October 1974).
[ 3) WILLIAMS, G., R. L. GJVENS, and F. SAARI. Noise reduction tests and development
performed on the White Motors Corp. quieted truck, Truck Noise V-A Report
No. DOT-TST-7 5-61 (January 1975).
[ 41 Peak A-Weighted Sound Levels Due to Truck Tires, Truck Noise I, Report No.
OST-ONA-71-9 (September 1970).
[ 51 BENDER, E. K., W. N. PATTERSON, and M. C. KAYE. ‘Source analysis and expert-
ments with noise control treatments applied to Freightliner quieted truck, Truck
Noise Il l-C, Report No. DOT-TST-74-20 (January 1974).
[ 61 SHRADER, J. T. Identifying the sources of noise on a heavy duty, diesel truck,
Truck Noise IV-B, Report No. DOT-TST-75-109 (May 1975).
[ 7] FAX, C. E. and M. C. KAYE. The economics of quieting the Freightliner cab-over-
engine diesel truck, Truck Noise lIl-D Report No. DOTTST-75-22 (October 1974).
181 SHRADER, J. T. and W. H. PAGE. The reduction of cooling system noise on heavy
duty diesel trucks. Truck Noise IV-C, Report No. DOTTST..74-22 (May 1974).
[ 9] SHRADER, J. T. and N. PRIADKA. The reduction of intake and exhaust system
noise on heavy duty diesel trucks, Truck Noise IV-D, Report No. DOT-TST-75 -14
(October 1974).
1101 GENERAL MOTORS. Proceedings of Conference on Motor Vehicle Noise, GM
Desert Proving Ground, April 3-4, 1973.
[ 11 ] FAX, G.E., revisions of table D12 in report 2710, BBN Internal Memo to C.
Burroughs/J , Singh, (12 June 1975),
6-32
-------
[ 12] MICHAEL C. KAYE and ERICH K. BENDER. Final configuration on Freightliner
quieted truck, Truck Noise Ill-F, Report No. DOT-TST-75-23 (October 1974)
[ 131 DONNELLY, T., J. TOKAR and W. WAGNER. A baseline study of the parameters
affecting diesel engine intake and exhaust silencer design, Truck Noise-VI-B, Report
No. DOT-TSC-OST-73-38 (January 1974).
[ 14] PATTERSON, W. N., P. RENTZ, and E. K. BENDER. Specialty construction trucks,
noise and cost of abatement, BBN Report 2566e. Bolt Beranek and Newman, Cam-
bridge, Mass. September 28, 1973.
[ 15] Effect of Exhaust System on Engine Performance. Acoustic Technical Bulletin,
Donaldson (March 15, 1968).
[ 16] Employment and Earnings, U.S. Department of Labor, Bureau of Labor Statistics.
[ 171 BENDER, E. K. and M. C. KAYE. Field Test of Freightljner Quieted Truck. Truck
Noise III-G, Report No. DOT-TST-76-29 (September 1975).
[ 18] TRINC TRANSPORTATION CONSULTANTS. TRINC’s Blue Book of the Trucking
Industry, published by TRINC Transportation Consultants, Djyj jo of Dun & Bradstreet,
Inc.
[ 19] BURROUGHS, C. B., Costs of Compliance for regulations on new medium and
heavy truck noise emissions, BBN Tech Memo No. 272, Bolt Beranek and Newman,
Inc., Cambridge, Massachusetts (January 15, 1976).
[ 20] AMERICAN TRUCKING ASSOCIATIONS INC., American Trucking Trends, 1974.
6-33
-------
Section 7
ECONOMIC IMPACT
This section considers the economic impact of alternate standards and the impact of
the time phasing of these standards. Section 6 has already considered the cost per truck.
In assessing the impact of 83-, 80-, 78-, and 75-dBA regulatory levels, examined are the ex-
pected demand reductions and total cost for the adjusted sales volume for each of the four
levels (Price and Quantity Impacts); impact upon truck manufacturers and major suppliers
(Impact on Truck and Engine Manufacturers); and, the impact of price and operating cost
changes on common carriers and other truck-using sectors (Impact upon Truck-Freight óm-
panies and Financial Impact on the Trucking Industry).
PRICE AND QUANTITY IMPACTS
Price and quantity impacts are given for each successively more stringent noise stan-
dard. In each case, the price increases are for the year of proposed enforcement over the
1973 levels. Demand reductions are based on an assumed demand elasticity of O.7* for
all truck types. Tables 7-1 and 7-2 give the reduction in number of units sold and adjusted
sales forecast for the first year for each proposed standard. The impacts of the various stan-
dards are discussed separately, first, on an initial cost and demand-reduction basis, and then
in terms of operating costs. As will be seen, the greatest impact is on the medium diesel
truck market; this, however, is the smallest of the four markets being considered.
Initial Costs and Demand Reductions*
Prices used were arrived in Section 6 using a markup of 1.5 x manufacturing cost.
83-dBA Regulatory Level
If a regulated level of 83 dBA is established and testing is permitted with the fan off,
the average price increase for medium and heavy gasoline-powered trucks will be $35 each —
a 0.6 percent increase over the current price for medium gasoline trucks and $125 for heavy
gasoline trucks — 1 . 1 percent increase over the current price for heavy gasoline trucks. For
medium and heavy diesel-powered trucks, the average prices will increase by $426 (or 5.9 per-
cent) and $387 (or 1.5 percent), respectively. The details of the individual elements that
make up these costs are presented in Tables 6-1 and 6-7 of Section 6.
*Appendix C.
7-1
-------
Table 7-I
Estimated Reduction in Truck Sales due to Noise Control
(First Year of Each Standard)*
Year of
Regulation
Regulatory
Level
Type of Truck
Total
Basejinet
Projection of
Sales (Number
of
Medium
Gasoline
Heavy
Gasoline
Medium
Diesel
Heavy
Diesel
1978
1982
1984
1984
1984
83dBA
80 dBA
80 dBA
78 dBA
75 dBA
875
4,759
4,894
8,972
18,079
296
526
523
883
r1 66l
127
269
277
345
1,729
3,748
3,834
5,598
8,872
3,027
9,032
9,528
15,798
29,142
Trucks)
428,594
478,536
506,758
506,758
*Assumes a demand elasticity of -0.7 for all truck types.
tSource, [ 1].
Table 7-2
Forecast Sales Adjusted for Decrease in Demand
Type of Truck
Year of Regulatory Medium Heavy Medium Heavy Total Number
Regulation Level Gasoline Gasoline Diesel Diesel of Trucks
1978 83 dBA 209,393 38,949 3,009 175,966 427,317
1982 8OdBA 215,683 38,250 3,060 212,511 469504
1984 8OdBA 221,764 38,021 3,152 234,293 497,230
1984 78dBA 217,686 37,661 3,084 232,530 490,961
1984 75dBA 208,579 36,883 2,899 229,255 477,616
7-2
-------
Assuming that the demand elasticity for all trucks is—0.7, these price increments will
result in a reduction in demand of 0.4 percent for medium gasoline trucks, 0.8 percent for
heavy gasoline trucks, 4.0 percent for medium diesel trucks, and 1.0 percent for heavy diesel
trucks. Table 7-1 shows that adoption of the 83-dBA level would reduce projected truck sales
by 2,937 trucks. This reduction is small compared to the baseline sales of 417,325 trucks.
Table 7-2 gives the adjusted sales forecast for each category of truck.
It should be noted that the dollar value of sales actually increases, although the number
of units sold declines. The increase in dollar sales is the result of the inelastic demand for
trucks (i.e., elasticity less than one). Discussion on the impact on trucks and engine manu-
facturers will present a more detailed discussion of this point.
80-dBA Regulatory Level
With a regulatory level of 80 dBA, prices will increase above 1973 levels by 3. 1 percent
for medium gasoline, 2.2 percent for heavy gasoline, 11.5 percent for medium diesel, and -
2.3 percent for heavy diesel trucks. The price increments (i.e., the differences in cost be-
tween an 83-dBA truck and an 80-dBA) wilIbe $145 for medium trucks, $130 for heavy
gasoline trucks, $424 for medium diesel trucks, and $233 for heavy diesel trucks. These
price increases will result in the demand reductions shown in Table 7-3.
Table 7-3
Percent Demand Reduction due to 80-dBA Regulatory Level*
Type of Truck
Incremental Reduction
Due to
83-dBA Standard
Percent
Incremental Reduction
Due to
80-dRA Standard
Percent
Medium gasoline.. .
Heavy gasoline....
Medium diesel . . . .
Heavy diesel
0.4
0.8
4.0
1.0
1.7
0.6
43
0.8
* Assumes a demand elasticity of —0.7
for all truck types.
7-3
-------
The reductions in demand for heavy gasoline trucks will be about 0.6 percent (third of
the reduction for the medium gasoline trucks). Medium diesel trucks will experience a re-
duced demand of more than 6 times that of the heavy diesel truck market. However, for
considerations of impact upon the manufacturing employment or upon the national
economy, the medium diesel truck market is the least important because of its small sales.
Assuming implementation in 1981, the cumulative reduction in unit sales due to the 80-
and 83-dBA regulatory levels would be 4,694 trucks in the medium gasoline market, 527
in the heavy gasoline market, 265 in the medium diesel market, and 3,312 in the heavy
market — a total for both markets of 8,798 trucks below present sales levels. Of this
total, 2,932 can be attributed to 83-dBA regulatory level and 5,866 to the 80-dBA level.
Table 7-2 shows the adjusted sales forecasts.
78-dBA Standard
With a 78-dBA regulatory level, price increases above 1973 levels will be 5.6 percent
and 3.3 percent for medium and heavy gasoline trucks and 14.4 percent and 3.4 percent
for medium and heavy diesel trucks. The dollar increase in going from 80 to 78 dBA will
be $150 for medium gasoline trucks, $125 for heavy gasoline trucks, $209 for medium
diesel trucks, and $271 for heavy diesel trucks. The corresponding demand reductions are
given in Table 7-4.
Table 7-4
Percent Demand Reduction due to 78-dBA Regulatory Level*
Type of Truck
Incremental Reduction
Dueto
78-dBA Standard
Percent
Medium gasoline...
Heavy gasoline -. ..
Medium diesel ....
Heavy diesel
1.8
0.9
.2.0
0.8
* Assumes a demand elasticity of —0.7
for all truck types.
75-dBA Regulatory Level
The incremental cost increase per truck of the 75-dBA regulatory level over the 78-dBA
level will be $335 for both medium and heavy gasoline trucks, $565 for medium diesel
7-4
-------
trucks, and $503 for heavy diesel trucks. Another relevant comparison is the incremental
cost between 80 and 75 dBA.
The incremental costs-per-truck of moving from 80 dBA to 75 dBA, then, are $485
for a medium gasoline truck, $460 for a heavy gasolme truck, $774 for a medium diesel
truck, and $774 for a heavy diesel truck.
The demand reductions expected to result from the 75-dBA regulatory level are given
in Table 7-5. The incremental demand reduction is for going from an 80-dBA level in 1981
to a 75-CIBA level in 1983.
Table 7-5
Percent Demand Reduction due to 75-dBA Regulatory Level*
Type of Truck
Incremental Reduction
Due to
75-dBA Standard
Percent
Medium gasoline...
Heavy gasoline. . . .
Medium diesel . . . .
Heavy diesel
5.9
2.9
7.6
2.5
* Assumes a demand elasticity of —0.7
for all truck types
As in the case of the other levels considered, the greatest impact will be on medium
d ese1 trucks. While the price increase for heavy diesel trucks is larger in absolute terms
than for heavy gasoline trucks, the percentage increase is smaller for heavy diesel than for
all types of gasoline trucks. Thus, the demand reduction is smallest for heavy diesel trucks.
Summary
Table 7-6 summarizes the incremental percentage price increases for each of the four
regulatory levels considered.
In ord r to obtain the total percentage price increase for any. combination of regula-
tions, simply add the percentage price increases for that combination. For example, the
price increases for an 80-, an 83-, and a 78-dBA combination of regulations for heavy diesel
trucks is 3.4 percent.
7-5
-------
Table 7-6
Incremental Price Increases for 83-, 80-, 78- and 75-dBA Regulatory Levels
Type of Truck
Price Increase (Percent)
Present to
83 dBA
83 c IBA to
80 cIBA
80 cIBA to
78 cIBA
80 cIBA to
75 CIBA
Medium gasoline..
Heavy gasoline . . .
Medium diesel ...
Heavydiesel
0.6
1.1
5.8
1.4
2.5
1.1
5.7
0.9
2.5
1.1
2.9
1.1
8.3
4.0
10.6
3.0
Operating Costs
The increase in the initial purchase price of a truck is only one component in the
total cost of truck noise control. Noise control will also have an impact on operating costs.
Reasons for changes in operating costs and the levels of these changes were dealt with in
Section 6 on a per truck basis. Here, briefly considered is the magnitude of cost changes as
apportioned over the entire truck population.
The average annual savings in operating costs for the final regulatory level for different
regulatory options are given in Table 7.7 for when credit is taken for savings in fuel costs for
more efficient fans and fan clutches and for savings in maintenance costs for exhaust gas seals
on diesel trucks. The savings in Table 7.7 are computed by taking the operating costs in Table
6-18 for each of the four truck categories and calculating the weighted average savings per
truck. The maximum savings occur for options G and E; however, there are still significant
savings associated with options C and N.
Total Costs
The total cost impact on truck users is estimated first by a component that represents
recovery of the incremental capital invested with interest; and second, one that represents
the incTeased yearly operating costs. Present value computations Were utilized in converting
estimated incremental investments and operating costs (savings) that occurred through 1991
to a common base year of 1978. These present value figures were then converted to uniform
annualized costs by the application of capital recovery costs.* All costs shown in Tables 7-8
* Uniform annualized cost computation represents a method of recovering an jgitlal capital investment over a specified
number of years at a specified rate of return by means of uniform-annual payments. (See Appendix K)
7-6
-------
Table 7-7
Savings in Average Operating Expenses with Use
of More Efficient Fans and Fan Clutches
Average Saving per Truck
Weighted for Distribution
Regulatory of Sales by Truck Category
Option* ($)
G 131
B 123
C 70
A 19
N 90
*The options are described in Table 4-I.
and 7-9 assume that there are no technological improvements in methods for noise control.
In practice, improvements are likely to occur.
From this point to the end of Section 7 we have adjusted all costs and revenues to
1975 dollars. Tables 1-3 of Appendix D show the new prices used. The factors used for
adjustment are based on the Bureau of Labor Statistics’ Wholesale Price Index for Truck
Prices and Consumer Price Index for Transportation.
Our discussion in this section concentrates on Options A, C, E and N. Calculations
were however performed for all options. The figures are given in Appendix E. Capital,
Operating and Total Costs for all options can be compared with the revenue figures given
in this section.
In Table 7.8, the totalannual costs are presented for Options A, C, E and N when
credit is taken for the increases in truck prices and savings in fuel and maintenance costs
associated with more efficient fans, fan clutches and exhaust gas seals. The highest annual
costs are shown for Option A and the lowest for Option B. The annual costs for Options
Cand N are similar, with the costs for Option N lower. When credit for the costs and
savings for fan treatments and exhaust gas seals is taken, the total annual costs given in
Table 7.9 are derived. Savings are shown for all options in every year, except for Option A
after 1989.
7-7
-------
Table 7-8
Total Annual Costs Without Credit for Costs and Savings for
more Efficient Fans, Fan Clutches and Exhaust Gas Seals
(Millions of Dollars)*
Year Option A Option C Option E Option N
1978... 20.5 20.5 20.5 20.5
1979.... 41.0 41.0 41.0 41.0
1980.... 61.5 61.5 61.5 61.5
1981 .... 81.9 81.9 81.9 81.9
1982.... 136.6 136.6 136.6 136.6
1983.... 190.5 190.5 190.5 190.5
1984.... 372.6 294.6 243.3 281.5
1985.... 552.6 397.4 294.8 370.3
1986.... 730.4 499.0 344.9 456.6
1987.... 904.4 598.2 393.0 539.7
1988.... 1,071.2 692.0 436.5 616.6
1989.... 1,231.8 782.4 478.3 689.6
1990.... 1,384.8 869.1 518.8 758.7
1991 .... 1,529.8 951.6 557.9 823.5
Uniform
Annualized
Costs 452 317 225 289
*Table 7-8 is extracted from Appendix E where more
detailed information is presented.
7-8
-------
Table 7-9
Total Annual Costs With Credit for Costs and Savings for
more Efficient Fans, Fan Clutches and Exhaust Gas Seals
(Millions of Dollars)*
Year
Option A
Option C
Option E
Option N
1978.... -118.2 -118.2 -118.2 -118.2
1979.... -227.1 -227.1 -227.1 -227.1
1980.... -325.8 -325.8 -325.8 -325.8
1981 .... -414.6 -414.6 -414.6 -414.6
1982.... 481.6 -481.6 -481.6 -481.6
1983 . .. . -539.3 -539.3 -539.3 -539.3
1984... . -466.3 -547.2 -586.7 -560.6
1985 . .. . -385.0 -545.5 -626.4 -573.5
1986. ... -297.3 -536.1 -660.8 -580.1
1987.... -206.4 -521.7 -691.6 -582.8
1988.... -119.0 -508.8 -724.3 -587.7
1989. .. . - 33.9 -495.1 -755.2 -592.5
1990.... - 46.8 481.8 -784.7 -597.8
1991 .... 121.0 471.2 -814.8 -605.8
Uniform
Annualized
Costs -307 -446 -523 -475
*Table 7-9 is extracted from Appendix E where more
detailed information is presented
7-9
-------
IMPA cT ON TRUCK AND ENGINE MANUFACTURERS
Two factors of concern in considering the impact on truck manufacturers are the over-
all level of economic activity in the truck manufacturing industry (e.g., employment and
output) and the possible increase in concentration within the industry. In general, the regu-
lation of noise levels of new trucks will not reduce the dollar value of sales (Table 7-12)
although the number of units produced will decrease (Table 7-1). Thus, no reduction in
employment is anticipated, but rather a probable increase. Labor/output ratios are given in
Table 7-10.
Table 7-10
Labor/Output Ratios
SIC Code for Industry
Column
1
— Column
2
Column
3
Value
Added
per
Production
Man $
$ Value
Added
per
Production
Man Hours
$ Value
Added
per
Production
Man Years
3711: Motor vehicle
cars and bodies
3712: Truck chassis
and trucks
3713: Truck and bus
bodies
3714: Motor vehicle
parts and
accessories
$3.46
$3.30
$2.69
$2.53
$20.04
$18.94
$10.06
$13.17
$41,487.32
$38,511.55
$19,795.80
$27,577.50
*Source: Census of Manufacturers 1972.
7-10
-------
Since revenue dollars are expected to rise in total (due to the increase in prices) addi-
tional man-hours are likely to be required. If work is subcontracted to parts and accessories
manufacturers who use more man-hours per production dollar, employment is in fact likely
to increase more than if additional manufacturing is performed by truck manufacturers.
Column 2 of Table 7-10 shows that to generate $18.94 in the parts and accessories industry
1.44 (18.94/13.17) man-hours would be required as opposed to 1 man-hour in the truck
chassis industry. Employment is not likely to fall as long as two conditions hold.
1. Elasticity of demand is less than an absolute value of one.
2. Labor/output ratios are at least as high for parts and accessories manufacturers as
for chassis and truck manufacturers.
The second concern, the possible increase in industry concentration, also seems unlikely
to occur. Small manufacturers appear to be as capable as large manufacturers of meeting the
proposed standards. This is particularly true for one small engine manufacturer who is
presently producing the quietest diesel engine. Thus, some small manufacturers do not appear to
have any cost disadvantage for regulations which will take effect in the more distant future
(i.e., 78- or 75-dBA).
Considering the diesel truck market, the changes in market structure brought about by
this regulation will most likely be at the level of the engine manufacturer rather than at the
level of the truck manufacturer. A key element in the cost of noise control (and thus the
price increase in trucks) is engine noise level. As shown in Section 6, noise levels from differ-
ent engines vary widely. Engines that emit high noise levels will require more extensive
treatments, and trucks that use these engines will cost more than trucks using quieter engines.
Thus, truck manufacturers will prefer using engines that arc inherently quieter.
It should be pointed out that some engine manufacturers also produce trucks, but a
number of firms produce either trucks or engines. In the diesel market, Mack, General
Motors, * and International Harvester produce both trucks and engines. These three produ-
cers account for 35 percent of the medium diesel trucks, and 55 percent of the heavy diesel
trucks. Thus, a large part of the output in both the medium and the heavy truck markets is
from firms which purchase engines from outside suppliers. It should be noted that General
MOtors sells engines to other truck manufacturers; all three firms offer trucks which have
engines other than the ones they produce. For example, you can buy an International Har-
vester truck with a Caterpillar engine. Table 7-1 1 shows the distribution of engine and
truck combinations, and Table 7-12 shows the current distribution of output among truck
manufacturers.
•General Motors produces Chevrolet and GMC trucks and Detroit Diesel and GMC truck engines.
7-1 1
-------
Table 7-11
Suppliers 91 Diesel Engines Used by Truck Manufacturers, 1972
Truck
Manufacturers
Allis-
Chalmers
Cater-
pillar
Cummins
Detroit
Diesel
GMC
IHC
Mack
Perkings
Scania
Vabis
Total
Chevrolet.., .
Diamond Reo
Dodge
FWD
Ford
GMC
IHC
Mack
White
Others
—
—
—
—
—
—
—
22
44
—
—
129
—
1
9,336
—
747
331
779
3,736
308
2,038
1,046
165
4,759
1,255
11,830
2,612
15,513
8,983
3,388
1,040
434
448
7,739
14,599
14,475
1,584
5,501
3,999
135
—
—
609
—
—
—
—
—
—
—
—
—
2,742
—
—
—
—
—
—
—
—
—
—
21,121
—
—
—
278
—
—
—
628
—
—
—
—
—
—
—
661
—
—
3,831
3,207
1,758
614
21,834
16,463
30,476
26,331
21,857
16,718
Total
66
15,079
48,509
53,207
744
2,742
21,121
960
661
143,089
Source: reference El].
-------
Table 7-12
Percent Market Share of New Trucks by Manufacturers, 1972
Truck
Manufacturer
Medium Trucks
Heavy Trucks
Gasoline
Diesel
Gasoline
Diesel
Chevrolet
23.6%
2.7%
3.8%
2.7%
Diamond Reo.
..
.02
0
2.5
2.3
Dodge
19.8
5.5
8.6
1.1
FWD
*
.2
.7
.4
Ford
28.0
59.7
33.2
13.6
GMC
11.3
8.8
19.4
11.6
IHC
17.2
23.1
29.1
21.2
Mack
0
0
*
19.1
White
0
.06
1.8
15.8
Others
.1
0
.8
12.1
than 0.05 percent.
Source: reference [ 1].
In the discussion of the impact of the regulation, concentration is on diesel-engine man-
ufacturers rather than truck producers. In the gasoline truck market, finns use primarily
their own production engines. In addition, there are few, if any, cost differentials between
gasoline truck manufacturers.
Section 6 presented the cost per truck for an 83-, 80-, 78- and 75dBA regulatory level.
These cost estimates were developed for each engine manufacturer. Diesel trucks can be
divided into three categories:
1. medium trucks using medium-duty engines,
2. heavy trucks using medium-duty engines, and
3. heavy trucks using heavy-duty engines.
These three categories represent three distinct submarkets. In terms of truck sales,
trucks in one category do not generally compete with trucks in another category. For
example, heavy trucks used in construction usually have medium duty engines, while line-
haul trucks use heavy-duty engines. The selection of engine type in a heavy truck is deter-
mined primarily by miles traveled per year.
7-13
-------
Presently, there are substantial cost differentials between diesel engine types [ 4].
The costs of quieting different types will also vary initially. As technology becomes better
developed, cost-effective methods will be adopted in preference to relatively ineffective
ones. The mix of engines produced in each category will become more cost-effective as com-
petition between manufacturers encourages implementation of better techniques. Over time,
differentials between manufacturers of noise control equipment should be reduced. A good
example of this behavior was provided by the costs of air pollution equipment, where cost
differences between manufacturers were reduced over a period of two or three years.
In addition, though there may be some price differentials (resulting from noise con-
trol) among trucks using engines from different manufacturers, the high degree of product
loyalty among truck purchasers will minimize any shifts. An additional factor militating
against large-scale shifts is that the producer of the quietest heavy-duty diesel engine presently
produces very few truck engines, accounting for less than 0.5 percent of current heavy-duty
diesel engines for trucks. Thus, a small reduction in demand for engines produced by other
manufacturers and a corresponding increase in demand for the quietest engine, would cause
a large relative increase in demand for the quiet engine. However, the magnitude of the
shift would be small in terms of the entire market.
In the medium-duty engine market, the major disadvantage would be suffered (at the
83-dBA regulatory level) by one manufacturer. This particular manufacturer produces a
number of engines which would be used as substitutes for the noisiest engine. Also, given
the lead times and this manufacturer’s strong position in the market, it seems likely that it
can and will reduce the noise level from this engine or develop a new engine to replace it.
In terms of the overall impact on truck manufacturers, Tables 7-1 and 7-2 showed the
number of trucks for the baseline and an adjusted sales forecast (with noise control). Al-
though these tables indicated that the number of trucks sold will decrease as a result of
higher purchase prices when noise control equipment is added to trucks, the dollar value of
sales will actually increase. Table 7-13 gives dollar values for first-year sales for the 83-, 80-,
78-, and 75-dBA regulatory levels and Table 7-14 gives baseline sales. Actual increases in
sales are $39 million in 1978 (with an 83-dBA level); $64 million in 1982 (with an 80-dBA
level); $68 million in 1984 (with a 80-dBA level); $100 million (with a 78-dBA level);
and $154 million (with a 75-dBA level) in 1984.
The most probable outcome will be an increase in employment as a result of noise con-
trol. If approximately the same amount of labor is required to produce a dollar of output
of noise-control equipment as is now required to produce a dollar of output in the truck
7-14
-------
Table 7-13
First-Year Sales of Trucks (Millions of 1975 $) under Adjusted Forecast of Demand
with Cost of Noise Controlsa
Year of
Regulation
Noise
Standard
Type of Truck
Total Sales
($ Billions)
Medium
Gasoline
Heavy
Gasoline
Medium
Diesel
Heavy
Diesel
1978 .. .
1982 .. .
1984...
1984...
1984...
83-dBA
80-dBA
80-dBA
78-dBA
75-dBA
1,489
1,572
1,616
1,626
1,642
554
550
547
547
551
28
30
31
31
32
5,534
6,744
7,435
7,456
7,490
r
7.605
8.896
9.629
9.660
9.715
aAdjusted demand computed from baseline figures. See Reference 1.
Table 7-14
Sales of Trucks (Millions of 1975 $) under Baseline Forecasea f
Demand at Original Cost Without Noise Control in the First Year of the Regulation
Year of
Regulation
Type of Truck
Total Sales
($ Billions)
Medium
Gasoline
Heavy
Gasoline
Medium
Gasoline
Heavy
Diesel
1978...
1982...
1984.,.
1,474
1,558
1,602
552
545
542
28
29
30
5,512
6,700
7,387
7.566
8.832
9.561
aSee Reference 1.
7-15
-------
industry, then the regulation will stimulate employment. As Table 7-10 shows the output/
labor ratio for noise-control equipment is at least the same as the present output/labor ratio
for the truck manufacturing industry. Items such as fan clutches, engine enclosures, and
exhaust mufflers have physical characteristics similar to other present truck components
and are produced in a similar manner.
Each of the proposed levels may have certain unique impacts or potential impacts, and
should be considered separately.
Since the proposed 83-dBA regulatory level becomes effective in 1978, the current slump
in truck manufacturing may have some relevance to the economic impact, It might be expected
that small manufacturers would be particularly affected, as they have less access to capital
markets and are less able to bear the cost of new equipment. However, for some of these smaller
companies, such as FWD, Auto Car, and Western Star, sales performance was as good or better
in 1975 than in 1974 1 181. The larger manufacturers such as General Motors and Mack have
been hit particularly hard with sales declines.t
For those regulations scheduled to take effect in 1982 and beyond, the current reduc-
tion in truck sales affecting the ability of truck manufacturers to finance noise-control in-
vestment would not be expected, nor would the slump be expect to persist to 1982. In
fact, the economy is now showing signs of recovery. Of course, a short-run cyclincal
downturn may occur during any period; this type of event can usually be predicted only
one or two quarters in advance.
Thermostatically controlled fans will be introduced to meet the 83-dBA regulation and
will also be used under the 80-dBA regulation. Therefore, possible supply problems
should be considered. Thermostatically controlled fans are expected to be used in about
50 percent of all truck production (i.e., for most heavy trucks). This corresponds to a demand
of about 207,000 thermostatic fans and represents a production rate of about 17,000 fans
per month. It is believed that fan manufacturers can increase fan production capacity to
meet these demand levels within a lead time of about 1 year.
For redesign and/or manufacturing of special components necessary for the 78- or 75-
cIBA level, the lead times proposed (i.e., 8 to 10 years) are adequate to ensure a smooth
transition to meet these standards.
*The less severe decline in sales of small farms reflects the specialized nature of their product. The markets for
specialized vehicles have been less severely impacted by the current economic stump.
7-16
-------
IMPACT UPON TRUCK-FREIGHT COMPANIES
Current Status of Trucking Industry
Tonnage hauled and earnings for 1975 are expected to fall below the depressed levels of
1974. Production cutbacks and inventory adjustments have led to a sharp decline in truck
tonnage since 1973 (Figure 7-1). The volume of freight transportation is closely tied to the
180 —
160 -
140 -
120
100
80
(1967 = 100)
1969 1970 1971 1972 1973 1974 1975
180
160
140
120
100
80
Source: American Trucking Associations
Figure 7-1. Intercity Truck Tonnage
economy (Figure 7-2). Relative to other sectors of the transportation industry, however,
trucking has experienced an increase. In 1973, motor carrier revenues accounted for
55.4 of every dollar spent for transportation, but this increasing share of transportation
business has only partly offset the effects of the economic downturn.
Traffic-related costs represent a substantial percentage of trucking expenditures. When
traffic falls, therefore, these costs also fall to some extent. Some increase in costs has been
experienced, nonetheless, and rates have been increased to compensate—often with a lag.
INTERCITY TRUCK
TONNAGE
FRB INDUSTRIAL
PRODUCTION iNDEX
QUARTERLY
I _ 1 _I
7-17
-------
200
180 —
160 —
140 —
120 —
100-
80 -
— 1960 61 62 63 64 65 66 67 68 69 70 71 72 73 74
(1960 = 100)
Source: Department of Commerce and American Trucking Associations.
Figure 7-2. Relationship Between Trucking and GNF
Recent ICC hearingS* indicate an unwillingness to allow rate increases to cover the costs of
slack capacity due to the recession.
Rate increases do not necessarily cover all expenses. Increases in labor costs, social
security, tolls and other non-labor costs have usually been allowed as the basis for rate
increases. Projected non-labor costs are not generally accepted. Such increases may be
granted in arrears. Expenses however, cannot always be recouped retroactively. Costs are
t Before the ICC: Justification of Middle Atlantic Conference for General Increases in Rates and Cbarges. Effective date—
July 1 and 8, 1975.
INTERCITY TRUCKING
(TONNAGE)
GNP IN DOLLARS
I I 1 __ _ l _ __ _ I I I I_ I I I I I
I I
7-18
-------
often passes through without markup. Some consideration is beginning to be given to the
problems of low rates of return in the industry. The Civil Aeronautics Board’s example in
allowing rate changes which actually improve profitability has been cited in the ICC hear-
ings*.
Rate increases in truck transportation do not appear to have eroded trucking’s market
share. Table 7-1 5 shows the percentage changes in price, ton miles, and market shares for rail
and truck since 1969. In 197 1-72 and 1972-73 truck prices per ton-mile rose by more than
rail prices. In 1971-72 rail prices actually fell. During these two periods, trucking either
maintained or increased its market share. Since 1972, this increase has not necessarily been
at the expense of rail whose market share was also growing.
Intermodal Competition
The probable extent of a shift away from trucking towards rail varies for different pro-
ducts. A study based on the 1963 Commodity Transportation Survey indicated that the
major determinants of modal choice were size and distance of shipment [ 5J Shipper group
or commodity type was also a key factor, however. Certain commodity groups are likely to
consider rail a viable alternative to trucking. Others are likely to find it unacceptable.
Table 7-16 shows the percentages of rail and highway freight by commodity for 1967
and 1972. Water, air, and other types of carriers are excluded to demonstrate the compe-
titive nature of the two modes, thus percentages add to 100.
In paper and allied products; metal cans and miscellaneous fabricated products; electri-
cal products and supplies; motor vehicles and equipment; instruments, photographic equip-
ment, watches and clocks, the share of tonnage going to rail increased between 1967 and
1972. This was probably due in part to the availability of “piggybacking” which has made
commodities less susceptible to spoilage and “shrinkage”. This is of particular importance
for high value goods.
*Before the ICC: Justification of Middle Atlantic Conference for General Increases in Rates and Changes. Effective date—
July 1 and 8, 1975.
7-19
-------
Table 7-15
I ’ . )
C
Modal Comparison of Rail and Truck Intercity, 1969-1974
Sources: Moody’s Transportation Manual
M. V. M. A. Truck Facts 1975
Survey of Current Business
Comparisons
1969
1970
1971
1972
1973
1974
Rail:
Ton-miles (Billions)
Revenues (Millions)
Truck:
Ton-miles (Billions)... ......
Revenues (Millions)
$ per K ton miles:
Rail
Truck
Percent of total intercity ton
miles (all modes):
Market Share: Rail
Truck
774
11,289
404
31,383.
14.59
77.68
41.03
21.25
768
11,869
412
33,553
15.45
81.44
39.83
21.28
744
12,730
430
37,570
17.11
87.37
38.48
22.18
784
13,105
470
41,690
16.72
88.70
37.77
22.63
858
14,801
505
46,515
17.25
92.11
38.43
22.63
861
16,936*
510
50,874*
19.67
99.75
38.60
22.90
1969-70
1970-71
1971-72
1972-73
1973-74
Percent change:
Rail price per ton mile
Truck price per ton mile
Rail ton-miles
Truck ton-miles
Rai lmarketshare
Truck market share
590
4.84
(.78)
1.98
(2.93)
.14
10.74
7.28
(3.13)
4.37
(3.39)
4.23
(2.28)
1.52
5.38
9.30
(1.85)
2.03
3.17
3 .84
9.44
7.45
1.75
.0
14.03
8.29
.35
.99
.44
1.19
-------
Table 7-16
Highway Rail Distribution by Shipper Group
Percent Distribution Based on Tons
Shipper Group
1967
1972
Highway Rail
Highway Rail
1.
Meat and diary products
72.8
27.2
2.
Canned and frozen foods and other
395
60.5
3.
Candy, cookies, beverages and tobacco
76.6
23.4
4.
Textiles and leather products
85.7
14.3
5.
Apparel and related products
88.9
11.1
6.
Paper and allied products
48.6
51.4
7.
Basic chemicals, plastics, synthetics and fibers
37.8
62.2
8.
Drugs, paints and other chemicals
565
43.5
9.
Petroleum and coal products
69.5
30.5
10.
Rubber and plastic products
74.0
26.0
11.
Lumber and wood products except furniture
45.1
54.9
1 2.
Furniture, fixture and miscellaneous
manufactured products
77.1
22.9
13.
Stone, clay and glass products
68.0
31.0
14.
Primary iron and steel products
56.7
15.
Primary nonferrous metal products
47.0
53.0
16.
Fabricated metal products except cans
76.8
23.2
17.
Metal cans and miscellaneous fabricated
metal products
72.2
27.8
18.
Industrial machinery except electrical
77.7
22.3
19.
Machinery except electrical and industrial . . .
62.0
•
38.0
20.
Communication products and parts
74.5
25.5
21.
Electrical products and supplies
64.9
35.1
22.
Motor vehicles and equipment
48.3
51.7
23.
Transportation equipment except motor
vehicles
63.1
36.9
24.
Instruments, photographic equipment,
watches and clocks
85.8
14.5
81.12
46.06
84.52
90.18
90.91
47.03
46.48
58.96
71.55
75.28
53.41
77.57
76.40
52.25
47.40
82.29
62.72
79.98
72.85
85.54
64.43
40.46
18.88
53.94
15.48
9.82
9.09
52.97
53.52
41.04
28.45
24.72
46.59
22.43
23.60
44.27
52.60
17.71
37.28
20.02
27.15
14.46
35.57
59.54
Source: U.S. Bureau of the Census, Census of Transportation,
Commodity Transportation Survey
80.14 19.86
78.14 21.86
1967 and 1972
7-21
-------
In all shipper groups, other than the five listed, rail reduced and trucking increased its
share between 1967 and 1972.
Concentration in the Trucking Industry
The number of LC.C.-regulated carriers in the United States has declined markedly in
recent years—from a total of 3,442 in 1971 to 2,711 in 1974. Most of the decline occurred
among special carriers, whose numbers went down by 24.2 percent between 1971 and 1974
(Table 7-1 7). Within the general-freight carrier market, some substantial shifts occurred.
Table 7-17
Change in Numbers of Carriers 1971 to 1974
Carriers 1971 1974 Change
(Percent)
General freight:
Intercity under $IM 407 161 -60.4
Intercityover$ IM 729 791 + 8.5
Local under $IM 131 64 -51.2
Loca lover$1M 101 103 +2.0
Total 1368 1119 —18.2
Percent of all carriers 39.7 41.3
Special carriers:
U.S. common
U.S. contract
U.S. local
Total
Percent of all carriers
Grand total, all carriers
1500
377
197
2074
60.3
3442
1161
330
92
1573
58.0
2711
-22.6
-12.5
..53 3
-24.2
-21.2
Source: Trinc’s Blue Book 1972 and 1975 (Reference 2).
The total 1 8 percent numerical decline of this latter group occurred among carriers whose
annual revenue is under $1 million. Increases in the numbers of carriers with over $1 mil-
lion in annual re’. enue suggest that a number of small carriers grew in size or were merged
into larger entities. The declines in the two under-$ 1-million generaifreight categories
were both greater than 50 percent.
7-22
-------
The total number of all carriers both I.C.C. regulated and not, was 15,144 in 1973 [ 61.
This number has probably declined in 1974 and 1975. There were 11,380 carriers with
revenues under $300,000 in 1973. Thus, although there are a few very large carriers, there
are many small ones. Figure 7-3 shows the distribution of I.C.C.-regulated carriers of
general freight. The majority of these have revenues over $1 million but under $10 million.
NUMBER OF
CARRIERS
800
700
600
500
400
300
200
100
0
$ REVENUE
RANGES
Figure 7.3. Size of I.C.C.-Regulated General Freight
Carriers: X 10,597.28.
The I.C.C. regulates all motor carriers holding interstate operating authority. Table 7-1 8
shows how trucking activity, both private and for-hire, is distributed between all local and inter-
city carriers.
Changes in the business and the economic downturn have made it hard for small carriers to
operate as many smaller carriers are only marginally profitable. Additional funds have been
required for new freight terminals and for computerized routing and billing. Funds for these im-
provements are not always as accessible to small businesses as to large. New business starts have
also been reduced.
to 1M to 1OM to
20M
to lOOM > 1000M
7-23
-------
Table 7-IS
Percentage of Trucking Total
Type of Truck
1965
1970
1980
(Projected)
For-Hire:
Local
15.2
15.0
15.7
Intercity
32.7
36.2
34.9
Private Trucking:
Local
34.0
31.5
31.7
Intercity
18.1
17.2
17.7
100.00
100.00
100.0
Source: Transportation Projections, 1970—1980,
U.S. Department of Transportation
As of January 1, 1974, the classification of carriers was changed so that Class I now
includes those whose annual revenues are in excess of $3 million (rather than $1 million).
This change reflects both inflation and the trend towards larger entities.
1974.
Table 7-19 shows the concentration in each of the six Regional Revenue Bureaus for
Table 7-19
Percentage of Market Revenues of the Top
Four (4) Carriers Measured by Revenue, 1974
Regional Revenue Bureaus
Revenue of Top
4 Carriers (Percent)
Southern Motor Carriers Conference*
Rocky Mountain Motor Tariff Bureau
Middlewest Motor Freight Bureau
Eastern Central Motor Carriers Association
Middle Atlantic Conference
Central & Southern Motor Freight Association
23.04
41.25
15.82
29.81
14.31
41.01
*1973 data.
Source: Statistics of the 6 Interregional Rate Bureaus,
as established by the Interstate Commerce Commission.
7-24
-------
In no region does more than 50 percent of the revenue go to the top four carriers.
Concehtration is highest in the Rocky Mountain, Central, and Southern regions. It is lowest
in the Middlewest. Nowhere does the concentration ratio come close to the Department of
Justice definition of high concentration, i.e., four carriers having 75 percent or more of the
revenues. Table 7-20 shows how the market share of the top four carriers is distributed.
Table 7-20
Market Share of the Top Four Carriers
Regional Revenue Bureaus
1
2
3
4
Southern Motor Carriers Conference
7.55
6.60
4.49
4.40
Rocky Mountain Motor Tariff Bureau
16.55
9.01
8.09
7.60
Middlewest Motor Freight Bureau
6.08
3.95
2.91
2.88
Eastern Central Motor Carriers Assoc.
12.84
6.07
5.45
5.45
Middle Atlantic Conference
4.22
3.76
3.61
2.72
Central & Southern Motor Freight Assoc.
18.44
8.50
7.77
6.30
Outlook for 1976
As of September 1975 the recession in the trucking industry has apparently bottomed out.
The 1974-1975 period saw the most serious reversal in traffic in recent history. This was due to
both inventory divestment and the slowdown in production. The trucking industry saw a
magnified version of the economy’s difficulties. From its peak in November 1974 to the trough
in March 1975, truck traffic receded 30 percent. This compares with a decline in total
national production of 14 percent from peak to trough. The 1975 truck traffic is expected
to be down about 16 to 17 percent from 1974 levels. The 1976 prospects are substantially
better. From 1975 levels, truck tonnage is expected to grow 12 to 15 percent in 1976 and
revenues to increase by 1 8 to 22 percent, allowing for an estimated freight rate increase of
8.2 percent. Forthcoming labor negotiations are expected to be followed without delay by an
appropriate rate increase. The industry should experience an above-average increase in demand
as the economy recovers and inventories are built up. The improved revenue picture should
enable many companies to be self-financing for their capital investment in the next few years.
Financial Status of I.C.C.-regulated Carriers
The preceding section indicated a substantial variability in the characteristics of carriers.
The following discusses the current status of the I.C.C-regulated carriers.
7-25
-------
Interpretation of Current Status
Table 7-21 shows key financial indicators for the I.C.C. regulated U.S. trucking
companies. Financial data for non-I.C.C. regulated companies are not readily available.
• Operating Revenues give an idea of the relative size and importance of various
sectors. It can be seen that intercity common carriers over-$1-million account
for 63 percent of operating revenue for all I.C.C.-regulated companies. If special
common carriers are added, we have 91 percent of the total I.C.C.-regulated
companies revenue. Local and special contract carriers are thus relatively unim-
portant.
• Net Operating Income. * Even when income from operations looks good, a business
may be in difficulty, if there are substantial nonoperating or extraordinary expenses,
e.g., interest expense or equipment losses. In general, this is a quick indicator of
profitability.
Table 7-21
Current Position of I.C.C.-Regulated U.S. Trucking*
Operating
Revenues
(S thousands)
Net
Operatingt
Income
(S thousands)
Number of
Power
Units
Number of
Camera
Operating
Ratio
(Percent)
Net Income
After Taxes
(Percent
of Total
Operating
Revenue)
Current
Ratio
Total Assets
(S thousands)
ROt
Percent
Before
Taxes
General freight
carriers:
Intercity Under SIM
Intercity Over $1 M
L oca lUn rjer$IM
Local Over SIM
121,354
12,412,015
44,898
329,219
1,875
659,725
(263)
6,743
3324
185,755
821
3,224
161
791
64
103
98,8
94.7
101.2
99.0
1.3
2.9
(.6)
1.5
1.15
1.11
1.14
1.41
52,598
5,539,902
21,478
185,816
3.57
11.92
(1.23)
3.63
Special carriers:
U.S. Common ‘
U.S. Contract . ‘ ‘
U.S. Local
Total special carrier:. .
5,560,939
966,254
95,079
6,722,272
231,667
28,945
3,683
264,295
106,180
18,776
3,244
128,200
1161
330
92
1573
95.9
97.1
98.2
96.1
2.0
1.3
2.5
1.9
1.16
1.04
1.31
1.14
2,358,885
424,963
83,787
2,867,635
9.82
6.81
4.4()
9.22
Grand total —
all carriers
19,669,078
934,085
321.924
2711 ‘
95.3
2.5
1.13
8,674,870
10.77
*Source: Trinc’s Blue Book (1975)
f See Appendix B for breakdown.
*The definition used is that from Trinc’s Blue Book (21. Sec Appendix F for detailed breakdown.
7-26
-------
• Power Units indicates the number of trucks of all types in the carrier industry. This
includes light trucks, which represent 10 percent of the trucks used for hire.
• Carriers is the number of separate business entities in each category.
• Operating Ratio (percent) is a simpler indicator than net operating income of the
profitability of incremental revenue. It is calculated by taking operating expenses as
a percent of operating revenue. A deficit in net operating income shows up as an
operating ratio of greater than 100 percent.
• Net income After Taxes (Percent of Total Operating Revenue) is a general measure
of profitability; this includes gains or adjustment to income which do not result
directly from operations.
• Current Assets/Current Liabilities Ratio is a good indication of the liquidity of a
company. If a company has more current assets than current liabilities, it may be
“cash rich.” The cash situation of those with a ratio less than 1 is generally tight.
A ratio less than 1 may reflect good management and an ability to keep debtors
from pressing for payment, or it may represent a company in trouble which failed
to adjust its expenditures to a decline in revenue.
• Tota l Assets is the sum of all assets. Fixed assets are included at net book value.
Book value is a variable measure in the carrier industry. The average life for a
truck is 10 years [ 7] ; however, IRS regulations allow trucks to be depreciated
faster than this. Therefore, there are a number of fully depreciated trucks
generating revenue, and the age of a particular carrier’s capital stock will cause
this figure to vary. This figure is also affected by the depreciation method used.
• Return on investment (ROt): percent (before taxes) is designed to show the
relationship of income to vested capita!. The only readily available measure of
invested capital is listed in Total Assets. The best available measure of income is
Net Operating Income before interest and taxes (see Appendix F for definition). In
using RO1 as a measure, it is important to remember:
I The age of the capital stock and the depreciation method will cause ROl
to fluctuate.
2 ROI is a measure of the average return on a group of nonhomogeneous assets,
e.g., land, trucks, cash, etc. The returns on each category of assets may be very
different.
3 ROt also measures the return on capital assets acquired over a number of years.
This should not be compared directly with the incremental return which is
demanded on new capital investment today. Fifteen years ago, 6 percent (after
tax) may well have been a reasonable return to expect. Today, 10 percent is
more usual.
7-27
-------
Analyzing Table 7-21 for each of these variables, one can observe the following:
• Local under-Si-million companies are on the average losing money on operations.
Their deficit is 0.6 percent of net income after taxes. Their current ratio, however,
is similar to that for U.S. trucking as a whole.
• Special contract carriers typically have a narrow margin between current assets
and liabilities, although they are making money on operations.
• Profit margins of trucking companies are characteristically narrow. Total labor
costs (including fringe benefits) represent about 60 percent of each dollar of
revenue, and scope for increased output per man hour is small. The National Team-
ster contract expires in March 1976, and, if wage increases are given, higher rates
will be needed. Being a regulated industry, rate adjustments may lag cost increases.
Despite a number of recent rate increases, a number of which exceeded those of
railroads, the overall market share for trucking has continued to rise (Table 7-1 5).
Rate increases have not led to a noticeable fail in traffic.
There is a well-known rule of thumb that a company’s current ratio (current assets!
current liabilities), should be at least 2: 1 and its quick ratio (current assets-inventories/current
liabilities), should be at least 1: 1. Since inventories are almost negligible for the trucking
industry, the current ratio of 1.13:1 is not unreasonable. However, this is not an industry
with great liquidity. Delays in approving rate increases therefore have a substantial impact on
a carrier’s cash position.
Total assets and ROl figures should be used with great care. Fluctuation in these
numbers may be only partly due to industry conditions. Taken in aggregate, however, the
I.C.C.-regulated industry has a relatively low ROl of 10.77 percent before taxes. Assuming
a tax rate of 48 percent, this yields an after tax ROl of 5.6 percent. This is substantially
lower than the 10 percent after tax return required for current investment. Municipal bonds,
which had been regarded as risk free, yield 8 percent clear of tax, 2 percent is a conservative
estimate of the risk premium required for trucking industry funds.
Financial Impact on the Trucking Industry
Assumptions used in assessing impact
1. Initially, it is assumed that all increased costs will be borne by the carrier, rather
than passed on as rate increases. This assumption is then relaxed in the discussion
of possible rate increases.
7-28
-------
2. Trucking industry revenues are assumed to grow at the same rate as GNP.*
[ Freight activity relates directly to production. As a long run estimate of
GNP, 3.5 percentf (real rate adjusted for inflation) seems reasonable despite
the decline of recent quarters.]
Table 7-22 projects the revenues, based on these assumptions, for U.S. trucking through
2000. A rate increase that produces a decline in demand could result in a decline in overall
revenues. However, it is likely that the demand is highly inelastic** and thus a rate increase
would not substantially decrease total revenue. The projections of operating income assume
that margins are maintained — i.e., that the operating ratio does not change. §
Revenues and costs are shown in Tables 7-23 and 7-24 for specific years discounted
at 10 percent. These tables are computed using Table 7-22 and Appendix E. The use of the
discount factor represents the opportunity costs of the funds. However, the percentage which
costs represent in a given year is independent of any discounting procedure. Tables 7-25
and 7-26 show the noise control costs as a percentage of revenue and operating income for
the years 1981, 1991, and 2000. The costs of any given regulation do not reach a steady
percentage of revenue until the entire truck population has come under the given regulation.
Where the truck life is 10 years, this will occur 10 years after the regulation is in effect, i.e.,
in 1992 for Options E and 1994 for Options A, C and N.
It is important to recognize that these percentages are computed for all truck purchasers.
The impact on any particular sector is not to be found simply by estimating the percentage
of trucks purchased by that sectOr. The truck mix for the sector is critical. Appendix G
discusses the procedure for finding the percentage for a given sector. The for-hire sector is
shown as an example. The savings and expenses of the regulation are not distributed evenly
across all types of truck. Medium-gasoline trucks will experience substantial savings, while
medium-diesel trucks will experience greater costs. Thus, savings will be larger than average
for agriculture and about average for I.C.C. carriers. The particular mix purchased is thus very
critical in assessing the impact on a given sector. Appendix G shows how this can be computed.
7.4.2 Rate Increases for ICC Regulated Carriers
Three questions must be asked concerning rate increases for I.C.C. regulated carriers to
cover noise control costs.
1. When will increases be permitted by the ICC?
2. What is the economic impact of a lag in rate increases?
3. How much rate relief will the ICC permit to offset noise control costs?
“There Is some evidence that they may grow faster as they become an increasing percentage of the transportation sector.
t3. percent is the most conservative percentage used for projections by Department of Transportation in “Transportation
1970-1980 Projections,” Office of Systems Analysis and Information (revised March 1973)
““See earlier discussion of intermodal freight competition and Tables 7-15 and 7-16.
§The operating ratio for I.C.C. carriers is assumed to be typical of the industry as a whole.
7-29
-------
Table 7-22
C
Revenue Projections for Trucking (Millions of Dollars)
* 1990 and 2000 figures are computed as projection from the D.O.T. projected 1980 figures, assuming 3.5 percent
real growth in G.N.P. This is the most conservative figure used in the D.O.T. study.
**1975 $ were arrived at using the Department of Labor statistics commodity price index for transportation.
Type of Trucking
1965
(Actual)
1970
(Actual)
1980*
(Projected)
1990*
(Estimated)
2000*
(Estimated)
1971 ($)
For Hire:
Local
5641.979
6875.718
10370.944
14629.253
20635.667
Intercity
12131.258
16571.536
23140.074
32641.388
46043.941
Private Trucking:
Local
12603.318
14412.456
21019.614
29650.267
41824.666
Intercity
6716.214
7875.583
11756.650
16583.93
23393.291
Total
37092.769
45735.293
66287.282
93504.838
131897.56
1975 ($)**
For Hire:
Local
7017.984
8552.616
12900.282
18197.137
25668.881
Intercity
15089.914
20613.178
28783.637
40602.198
57273.46
Private Trucking:
Local
15677.103
17927.466
26146.024
36881.581
52025.158
Intercity
8354.211
9793.335
14623.944
20628.535
29098.611
Total
46139.212
56886.535
82453.887
116309.45
164066.11
Source: Transportation Projections 1970-1980, U. S. Department of Transportation.
-------
Table 7-23
Revenue Discounted at 10 Percent* to 1977 (Millions of 1975 Dollars)
Type of Trucking
1981
1991
2000*
For Hire:
Local
10031.4
5455.5
2866.65
Intercity
22382.5
12172.6
6396.19
Private Trucks:
Local
20331.4
11057.2
5819.07
Intercity
11371.7
6184.5
3249.68
Total
64117.0
34869.9
18322.59
* fls ,j rate is used as the cost of capital and opportunity cost for all calculations. It may
be high for an industry such as I.C.C. carriers, whose margins are 4.75 percent and whose ROl
is 5.6 percent.
Table 7-24
Costs for Particular Years Discounted at 10 Percent* to 1977 (Millions of 1975 Dollars)
Options
1981
.4
1991
2000*
Option A with savings**
(311.5)
35.0
61.8
Option C with savings
(311.5)
(136.5)
( 64.3)
Option E with savings
(311.5)
(236.0)
(142.1)
Option N with savings
(311.5)
(175.5)
(103.8)
Option A without savings
61.6
443.1
317.8
Option C without savings
61.6
275.6
193.1
Option E without savings
61 .6
161.6
108.8
Option N without savings
61.6
238.5
156.6
*The impact of all regulations has reached a steady state by 2000. Changes are due pri-
marily to growth in the truck population and the variations in the demand for each type of
truck.
**Includes costs and savings for more efficient fans, fan clutches and exhaust gas seals.
Analysis of past ICC procedures indicates a variation from “a simultaneous rate increase”
to “an 8-week lag.” There is only limited information on the economic effects of a lag in
freight rate increases. It is likely in 1976 that a 7 percent rate increase will be allowed in May
for labor costs, and a .5 percent increase for fuel costs in June. It is estimated that a delay
of 5 weeks in these rate increases will reduce second quarter operating ratios by 2.8 percent.
This pressure on margins is of a short-term nature and for the year as a whole, the impact is
7-31
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Table 7-25
Projected Noise Control Costs in Selected Years as a Percentage of Revenue
Options
1981
1991
2000
Option A with savings . . . .
Option C with savings . . . .
Option E with savings . . . .
Option N with savings . . . .
Option A without savings . .
Option C without savings . .
Option E without savings . .
Option N without savings . .
(.486)
(.486)
(.486)
(.486)
.096
.096
.096
.096
.100
(.391)
(.677)
(.503)
1.271
.790
.463
.684
.337
(.351)
(.776)
(.566)
1.734
1.054
.594
.855
Table 7-26
Projected Noise Control Costs in Selected Years as a Percentage of Operating Income*
Options
1981
1991
2000
Option A with savings . . . .
Option C with savings . . . .
Option Ewithsavings . . . .
Option Nwith savings . . . .
Option A without savings . .
Option C without savings . .
Option E without savings . .
Option N without savings . .
(10.23)
(10.23)
(10.23)
(10.23)
2.02
2.02
2.02
2.02
2.10
( 8.23)
(14.25)
(10.59)
26.76
16.63
9.75
14.40
7.09
( 7.39)
(16.34)
(11.92)
36.50
22.19
12.50
18.00
is assumed that operating income is 4.75 percent of revenue and that the costs are
passed on.
much smaller. Nonetheless, it is important that the rate increases coincide, as nearly as possi-
ble, with cost increases. This is particularly true at a time when cash is tight.
The answer to the third question is equally difficult. The percentage by which rates
would have to be raised just to cover such costs (assuming there is no loss of market share)
is easily computed as:
Costs as
Annuahzed Cost of Noise Controls X 100
= percentage
Annualized Revenue
of revenue
These are shown in Table 7-25 for 1981, 1991 and 2000. These percentages do not allow
for any markup on the incremental costs of trucking services. For this reason, trucker’s
margins will still be eroded.
7-32
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Example for ICC Regulated Carriers
If on costs of 19.2 billion suppose an increase of 2 percent is experienced by truckers.
If this is passed on completely and no substitution occurs, revenues will become $20.54 billion
and operating income will still be $957.44 million. Although this is 4.75 percent of $20.16
billion, it is only 4.66 percent of $20.54 billion. Margins are thus eroded because the cost base
is increased. If no markup is allowed, the carriers will, in effect, be asked to put money
into noise-control equipment with no return; if a markup is allowed by the ICC to preserve
margins, then the inflationary effect of the noise-control equipment will be greater. To
preserve existing margins, it would be necessary to multiply the above equation by 1.0499,
thereby maintaining a 4.75 percent margin.
Possible Rate Increases for ICC Regulated Carriers
In this section, the assumption that there will be no rate increases to cover increased
costs is relaxed. Until 1973, labor costs provided the basis for freight rate increases. Non-
labor costs were generally offset by productivity increases. If productivity increases were not
completely offset by other costs, rates were raised to offset only part of a wage increase. Since
late 1973 however, because of rapid increases in non-labor costs, (e.g., fuel) there have been
three non-labor based rate increases. As the discussion earlier indicates, the I.C.C. has tradi-
tionally allowed historical non-labor cost increases but not projected ones. Such cost in-
creases eventually are often allowed to be passed through as rate increases without markup.
I.C.C. regulated carriers may have operating margins which are greater or less than the
aggregate. If a 4.75 percent markup is allowed by the I.C.C., those whose existing margins
are less than 4.75 percent will become more profitable, and vice versa, since the rates are
set without regard to individual carriers’ characteristics.
Impact on Particular Segments of the Carrier Industry
The impact on the for-hire sector in aggregate is shown in Appendix G. Table 7-21
showed the status of various segments of the I.C.C. regulated industry. It is important, however,
to appreciate that there is substantial variation between different carriers in the industry.
This may be due to scale, geographical location, route structure, types of freight, etc. Table
7-27 shows mean and standard deviation of operating ratios for I.C.C. regulated companies.
As can be seen, the operating ratio gets less favorable as companies get smaller. An operating
ratio greater than 100 indicates a company which is losing money on everyday business. If the
distribution were normal one would expect substantially more companies to have an operating
ratio greater than 100 than turns out to be the case. One explanation is that companies in this
7-33
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Table 7.27
Operating Ratios: Means and Standard Deviations
for ICC Regulated Companies*
Mean
Operating
Ratio
Standard
Deviation
Expected
Probability
of an Operating
Ratio> 100+
Actual
Percent With
Operating
Ratio> 100
Class I
(over lOOM)...
Class II
(20 to lOOM)..
Class III
(1 to 20M) ....
Class IV
(Under 1M)....
94.8
95.5
96.2
99.0
5.84
.
4.95
5.57
.
6.76
0.19
0.18
0.25
0.44
0.045
0.093
0.185
0.370
*1974 Statistics, Source: Trinc’s Blue Book (1975) [ 2].
+Based on a normal distribution of operating ratios
position may already have stopped operations and are no longer reporting to the I.C.C. It should
be remembered also that there are other factors (e.g., ability to decline unprofitable business)
that make it likely that the distribution is skewed to the favorable side of the mean. Companies
with a deficit from operations are likely to remain in business only for a limited time. There
are strong indications that in 1975 carriers’ margins were lower than indicated here.
Table 7-28 shows the current position for some selected companies* indicating that
there is substantial variation from the averages shown in Table 7-21. It is most important,
therefore, that concern not just with the aggregate impact on all trucking, but with the specific
impact on individual groups is given. Appendix G shows how this can be done for an industry
group. The substantial variation between I.C.C. regulated carriers will cause. any regulation to
be nonhomogeneous in its impact. Although the aggregate impact on an industry is important,
it is also critical to observe which segments of that industry will be affected to a greater or
lesser degree than the average.
*These companies were selected as representative of types within each group rather than by a segmented random sainpung
procedure. A statistical check was run to ascertain the representativeness of the companies selected. This check used a
revenue-based weighting scheme. Because of the weight given to Class I and the nonstatistical nature of the sample, Table
7-28 is compatible with a total population having an operating ratio of 91 percent and a current ratio of appro,dmately
1.18. These figures indicate that Table 7-28 represents a somewhat more favorable situation than is actually present. The
true population has an operating ratio of 95.4 percent and a current ratio of 1.13 (Table 7-21) and comparison with
Table 7-27 also indicates this. Table 7-28 should therefore be used with caution.
7-34
-------
Table 7-28 contains information similar to that in Table 7-21, but for four classes
within the the industry. Comparison of the two tables shows substantial deviations from the
average. Two of the companies shown are already running a deficit; net operating income
is negative, and the operating ratio is over 100. Any additional financial burden could cause
financial distress to companies in this position. Even if these companies could raise the
financing for noise controls, they may not be able to support the payments. It is important
to observe that these companies are medium or small and privately owned. It is this type of
carrier which may experience hardship. Table 7-21 shows that, taken together, local general
freight carriers under $1-million are in deficit. l’his group is probably the most vulnerable to
increased costs of noise control, even if able to pass these increased costs on via increased
rates.
Computed returns on investment described for Table 7-21 is also shown in Table 7-28
and should be used with great care. The age and mix of capital equipment varies greatly from
one company to another. As can be seen, ROl fluctuates a great deal. The ability to expend
the necessary funds for noise control equipment will depend both on the economic outlook
for the industry, and the existing financial position of any particular carrier. The short-term
outlook for the industry is rapidly improving (outlook for 1976). Even companies whose
condition appeared poor in 1974 may be able to provide substantial internal funds for invest-
ment by 1978. A good indicator is a substantial improvement in operating ratios.
If outside financing is required, the ability to borrow money will depend on a number of
factors:
• Existing leverage,
• Timing of present debt retirement,
• Access to money markets, e.g., stock market for public companies,
• Other sectors’ demands on the money markets,
• Prevailing interest rates, and
• Certainty of future profitability ensuring repayment.
These factors differ substantially for individual companies. The small and medium private
companies may have the most difficulty in raising funds. Smaller, newer companies are usually
found in Classes III and IV and as shown earlier concentration is increasing. If new entrants are
discouraged or their growth is inhibited, this is likely to continue.
7-35
-------
0
Table 7-28
Current* Sample Position of U.S. General Freight Trucking Companies
9974 Statiatlcs, Source Trinc’a Btue Book (1975) I2J.
tSee Appendlz B fce breakdown.
A edsJ tax aedit u&es this numbet to be positive dc p te the deficit on operating income.
Revenue Class
Operating
Revenues
$ thousand)
Net
Operatingf
Income
(S thousand)
No. of
Power
Units
Operating
Ratio
(percent)
Net Income
After Taxes
(Percent
of Total
Operating
Revenue)
Current
Ratio
Total Assets.
($ thousand)
ROI
percent
Before
Taxes
1. (Over lOOM)
A. Consolidated Freightways..
B. Roadway Express
C. Yellow Freight
D. Lee Way
E. Smith’s Transfer
426,175
504,375
351,385
113,315
126,295
33,833
60,500
43,789
8,548
10,584
5,019
2,324
4,736
593
2,255
92.1
88.0
87.5
92.5
91.6
4.6
7.0
6.9
3.8
3.8
0.85
1.63
1.09
1.17
.87
221,814
243,901
209,879
63,895
81,781
15.25
24.81
20.86
13.38
12.94
II. (2Oto lOOM)
A. Hall’s Mtr. Transit Company
B. Gordon’s
C. Mid-American
D. Milne Truck Lines
73,204
63,734
36,088
28,287
7,334
3,534
281
1,922
1,115
889
607
489
90.0
94.5
99.2
93:2
2.2
2.8
.1
5.4
.72
1.41
1.67
1.01
44,691
34,869
18,225
8,286
16.41
10.14
1.54
23.20
III. (lto2OM)
A. Link Trucking
B. Plc-Walsh Freight
C. Suwak Trucking
1,019
10,653
9,011
107
(574)
113
29
16
163
89.5
105.4
98.5
7.0
10.7
.9
1.22
3.05
1.79
544
3.969
1,617
19.67
(14.46)
8.23
IV. (Under I M)
A. M&G Transportation
B. Heding Truck Service
C. Heartland Express
562
688
563
(21)
78
17
7
25
10
103.7
88.6
96.9
(3.2)
6.4
10.1
.55
.84
2.57
182
285
1,122
(11.54)
27.37
1.52
-------
Impact on Users of Transportation Services
The impact of the noise control program on end users can be measured by the price
increases that would result if truck freight rates are increased. Table 7-29 shows both
direct and indirect truck transportation inputs for the commodities listed. The first column
shows the cents of truck transportation per dollar of output for each commodity for both
for-hire and private trucking. For example, commodity 8, food and drugs, requires 5.74 of
truck transportation per dollar of sales. The 5.74 reflects all truck transportation inputs for
raw materials, intermediate inputs, and the final product. The second column shows the
relative importance of trucking in each sector. The four right-hand columns show the change
in selling price, which results from Options A, C, E and N in 1991 and 2000. The rate
used was computed from the increase (decrease) in total costs as a percentage of revenut.
Savings result from Options C, E and N through the year 2000. The complete effect
of an option will not be felt until 10 years after its initiation, when the entire truck
population will have turned over. The figures for 1991 price increases should be viewed
accordingly. By 2000, the entire population will be subject to the option under consider-
ation. These figures therefore indicate the level at which costs will reach a steady
percentage.
It is important to note that the percentage used is an aggregate figure. A more
precise figure for each commodity can be arrived at by using the procedure to compute the
exact percentage cost increase for each sector as described in Appendix G.
Table 7-29 assumes no shifts to other forms of transportation due to the price increase.
Impact on truck purchases
Truck price increases and operating cost increases will affect the private trucking sector
as well as the for-hire sector. Table 7-29 presents the price increases that anticipated in 35
sectors of the economy and included both for-hire and private trucking.
To assess the relative impacts within the private trucking sector, the distribution of
future truck purchases by end users must be considered. It is assumed that distribution of
future purchases of truck type by end-user category will be in proportion to the present
distribution of truck ownership. Table 7-30, presenting the 1972 distribution of ownership
by truck type, can be interpreted as the best estimate of distribution of future truck purchases.
For medium diesel trucks, the operating and capital cost increases are the largest.
Excluding the for-hire sector already considered, the largest purchasers of medium diesel
trucks are the construction and service sectors. These two account for about 39 percent of
current ownership, and estimates will account for 39 percent of future purchases. While these
sectors will experience cost increases in trucking services, the dollar value of trucking services
7-37
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Table 7-29
Truck Transportation Costs per Dollar of Final Demand in Various Industries
(Fan Savings Are Included As Rates Would Be Adjusted to Allow for These)
Industries
Currentt
(1972) Cents
perSi
Demand
Truckingt
as a Percentage of
TransportationS
for All Modes
1991
Option A
1991
Option C
Increase
De
1991
Option E
(Decrease)
mand Due to
1991
Option N
per
Noise Control
2000 2000 2000 2000
Option A Option C Option E Option N
I. Agriculture 7.1 74.7 .0071 (.0278) (.0481) (.0. 5 ) 1) .0239 (.0249) (.0 I) (.U4U.)
2. Iron ore mining 4.7 17.2 .0047 (.0184) (.0318) (.0236) .0158 (.0165) (.0365) (.0266)
3. Nonferrousmining 9.7 59.5 .0097 (.0379) (.0657) (.0488) .0327 (.0341) (.0753) (.0549)
4. Coal mining 8.3 27.5 .0083 (.0324) (.0562) (.0417) .0280 (.0291) (.0644) (0470)
5. Miscellaneous mining 59.7 77.8 .0597 (.2334) (.4042) (.3003) .2011 (.2095) (.4633) (.3379)
6. Construction 4.4 62.0 .0044 (.0172) (.0298) (.0221) .0148 (.0154) (.0341) (.0249)
7. Ordnance 3.0 63.8 .0030 (.0117) (.0203) (.0151) .0101 (.0105) (.0233) (.0170)
8. Food and’drugs 5.7 67.1 .0057 (.0223) (.0386) (.0287). .0192 (.0200) (.0442) (.0323)
9. Textiles and apparel 4.2 77.8 .0042 (.0164) (.0284) (.0211) .0142 (.0147) (.0326) (.0238)
10. Lumberand products 5.2 38.5 .0052 (.0203) (.0352) (.0262) .0175 (.0182) (.0404) (.0294)
11. Furniture 4.0 59.7 .0040 (.0156) (.0271) (.0201) .0135 (.0140) (.0310) (.0226)
12. Paperandpaperproducts 4.9 46.7 .0049 (.0192) (.0332) (.0246) .0165 (.0172) (.0380) (.0277)
13. Printing 2.8 63.6 .0028 (.0109) (.0190) (.0141) .0094 (.0098) (.0217) (.0158)
14. Chemicals 6.! 56.5 .0061 (.0238) (.0413) (.0307) .0206 (.0214) (.0473) (.0345)
15. Plastic. paintsand rubber 4.3 64.2 .0043 (.0168) (.0291) (.0216) .0145 (.0151) (.0334) (.0243)
00 16. Petroand products 4.5 47.9 .0045 (.0176) (.0305) (.0226) .0152 (.0158) (.0349) (.0255)
17. Stone,elay,glassprodtrets 8.4 65.6 .0084 (.0328) (.0569) (.0422) .0283 (.0295) (.0652) (.0475)
18. Ironandsteel 3.6 43.4 .0036 (.0141) (.0244) (.0181) .0121 (.0126) (.0280) (.0204)
19. Nonferrousmetal 3.3 52.4 .0033 (.0129) (.0223) (.0166) .0111 (.0116) (.0256) (.0187)
20. Fabricated metal 3.0 57.7 .0030 (.0117) (.0203) (.0151) .0101 (.0105) (.0233) (.0170)
21. Farm,Constructionmachinery 3.7 53.6 .0037 (.0145) (.0250) (.0186) .0125 (.0130) (.0287) (.0209)
22. Industrial machinery 3.3 60.0 .0033 (.0 129) (.0223) (.0166) .0111 (.0116) (.0256) (.0 187)
23. Electricalmachinery 2.4 61.5 .0024 (.0094) (.0162) (.0121) .0081 (.0084) (.0186) (.0136)
24. Motorvehicles 3.5 51.5 .0035 (.0137) (.0237) (.0176) .0118 (.0123) (.0272) (.0198)
25. Aircraft 1.7 60.7 .0017 (.0066) (.0115) (.0086) .0057 (.0060) (.0132) (.0096)
26. Othertransportationequipmeflt 3.5 57.4 .0035 (.0137) (.0237) (.0176) .0118 (.0123) (.0272) (.0198)
27. Scientificopticalinstitute 4.7 87.0 .0047 (.0184) (.0318) (.0236) .0158 (.0165) (.0365) (.0266)
28. CommunicatiOns .8 72.7 .0008 (.003 1) (.0054) (.0040) .0027 (.0028) (.0062) (.0045)
29. Utilities 2.4 39.3 .0024 (.0094) (.0162) (.0121) .0081 (.0084) (.0186) (.0336)
30. Services 3.6 83.7 .0036 (.0141) (.0244) (.0181) .0121 (.0126) (.0279) (.0204)
31. Auto repairs 2.1 61.8 .0021 (.0082) (.0142) (.0106) .0071 (.0074) (.0163) (.0119)
32. Government enterprises 3.5 38.5 .0035 (.0137) (.0237) (.0176) .0118 (.0123) (.0272) (.0198)
33. Bus,travel,gifts 5.9 68.6 .0059 (.0231) (.0399) (.0297) .0199 (.0207) (.0458) (.0334)
34. Micellaneousmanufacturiflg 9.4 74.0 .0094 (.0368) (.0636) (.0473) .0317 (.0330) (.0729) (.0532)
35. Scrap sales 1.8 10.8 .0018 (.0070) (.0122) (.0090) .0061 (.0063) (.0140) (.0102)
Percent increase used _______________ . 100 ( .391) ( .677) ( .503) . 337 ( .351) ( .776) ( .566 )
tSowce for these columns is 1972 National Transportation Report 131.
Note: The four right’hsnd columns indicate the increase (decrease) in cents per $1 demand due to noise control regulations.
-------
Table 7-30
Percent of Size Class in Each Industry Category
Industries
Medium
Gasoline
Medium
Diesel
Heavy
Gasoline
Heavy
Diesel
Agriculture
36.57
9.33
16.89
4.45
Forestry and lumbering.
.
1.89
1.19
3.65
3.54
Mining
.82
1.09
1.67
1.87
Construction
1.22
24.95
21.07
15.91
Manufacturing
3.68
7.93
6.73
10.17
Wholesale and retail . .
.
22.41
2.48
21.43
14.67
ForHire
7.19
27.99
17.77
45.12
Personal transportation .
.
9.43
.21
1.63
.05
Utilities
3.19
.43
2.89
.53
Services
10.33
14.23
3.77
1.48
All other
3.27
10.18
2.52
2.22
Total
100
100
100
100
Source: Computer tapes for
survey.
1972 census of transportation, truck inventory, and user
consumed by these sectors is small. Table 7-29 shows that the direct and indirect purchasers
account for only 4.4 cents per dollar of final demand in construction and 3.6 cents per dollar
of final demand in the service sector.* Negligible impact is anticipated because of the small
proportion of trucking costs to total costs.
Including the for-hire sector along with the two mentioned above, these three sectors
account for 67 percent of mediur’ diesel truck ownership (and thus future purchases).
The price increases per truck, ranging from $42 at 83 dBA to $800 at 75 dBA for medium
gasoline trucks and $151 at 83 dBA to $866 at 75dBA for heavy gasoline trucks, are offset
(fully or in part) by operating cost savings. These operating cost savings include fuel savings
from treatment of fan noise. The major users of heavy gasoline trucks are wholesale and retail
*Note the cents per dollar of final demand include both direct and indirect trucking services. The large volume of medium
diesel trucks referred to in these industries is used in direct trucking services; thus, the impact would be even smaller than
these figures would indicate.
7-39
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trade (21 percent), agriculture (17 percent), and construction (21 percent). Of these three sectors,
agriculture is the largest user of truck transportation, as measured by the truck transportation
costs per dollar of final demand. Again, no significant cost increases in these sectors are antici-
pated particularly given the small price increases relative to the large operating cost savings.
Agriculture, wholesale and the retail trade account for almost 60 percent of the medium
gasoline truck ownership.
The for-hire sector has been considered separately, and this sector accounts for 45 percent
of heavy diesel trucks. The other major users are construction (16 percent), wholesale and
retail (15 percent), and manufacturing (10 percent) (Table 7-30).
The mining sectors .have substantial truck transportation costs. However, although a
relatively small number of trucks is owned by that sector, costs per dollar of final demand are
4.7 for iron ore mining, 9.7 for nonferrous mining, 8.3j for coal mining and 59.7 for
miscelleneous mining.
7-40
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REFERENCES
[ 1] KEARNEY, INC., A. T. A study to determine the economic impact of noise
emission standard in the medium and heavy duty truck industry, (EPA
Contract No. 68—01—154). A. T. Kearney, Inc. (1974).
[ 21 TRINC TRANSPORTATION CONSULTANTS. TRINC’S Blue Book of the
Trucking Industry, published annually by TRINC Transportation Consultants,
Division of Dun & Bradstreet, Inc.
[ 3] U.S. DEPARTMENT OF TRANSPORTATION. 1972 National Transportation
Report, Present status-future alternatives. U.S. Department of Transportation,
Washington, D.C. (July 1972).
[ 4] W. N. PATTERSON, P. RENTZ and E. K. BENDER, “Specialty Construction
Trucks: Noise and Cost of Abatement”, BBN Report 2566e, 28 September 1973.
[ 5] SURTI, V. H. and A. EBRAHIMI, Modal split of freight traffic, Traffic Quarterly
(October 1972).
[ 6] AMERICAN TRUCKING ASSOCIATIONS INC., American Trucking Trends 1974.
[ 7] ENVIRONMENTAL PROTECTION AGENCY, Background document for proposed
medium and heavy truck noise regulations, EPA-55019-74-0l8. Office of Noise
Abatement and Control, Washington, D. C. (October 1974).
[ 8] AUTOMOTIVE NEWS, September 2, 1975.
7-41
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Section 8
ENFORCEMENT
GENERAL
Enforcement of new product noise emission standards applicable to new medium and
heavy trucks will be accomplished through production verification testing of vehicle con-
figurations, assembly process testing using selective enforcement auditing of production
vehicles and in-use compliance programs. The predominant portion of any production veri-
fication testing and assembly process vehicle testing will be carried out by the manufacturer
and audited or confirmed by EPA personnel as necessary.
Any test used for production verification testing and any test used for assembly process
testing of production vehicles should be the same test or else correlative so that compliance
may be accurately determined. A measurement methodology used both for production veri-
fication testing and assembly process testing of medium and heavy trucks is a modified
version of the SAE standard test procedure J366b.
PRODUCT VERIFICATION
Production verification is the testing of early production models by a manufacturer or
by EPA to verify that a manufacturer has developed the necessary noise attenuation technol-
ogy and is capable to applying the technology in a manufacturing process.
Production verification does not involve any formal EPA approval or issuance of certi-
ficates subsequent to manufacturer testing, nor is any extensive testing required by EPA. A
vehicle configuration must undergo production verification prior to or soon after its distribu-
tion into commerce.
Like configurations may be grouped into a category as defined in the regulations. A
vehicle model would be considered to have been production verified after the manufacturer
has shown (based on the application of the noise measurement testing methodology) that a
configuration or configurations of that model conform to the standard. Production verifi-
cation testing of all configurations produced by a manufacturer may not be required if a
manufacturer can show that the noise levels of some configurations in a category are con-
sistently higher than others in a category. In such a case, the noisiest configuration would
8-1
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be the only configuration requiring verification. Manufacturers must reverify whenever they
implement engineering changes to their products that are likely to adversely affect noise emis-
sions. Additionally, some further testing on a continuing or other periodic basis of production
products will be necessary to assure that all products manufactured conform to the standards.
Product verification provides EPA with confidence that production models will conform
to the standards and also limits the possibility that non-comforming vehicles will be distri-
buted in commerce. If the possibility exists that subsequent models may not conform to the
standard, assembly process vehicle testing may be made a part of the enforcement strategy
in order to determine whether production vehicles continue to actually conform to the
standard.
ASSEMBLY PROCESS TESTING
Assembly process testing of production vehicles is a method where vehicles are tested
upon completion of assembly to determine whether they conform to applicable standards.
For this determination, only representative samples of newly-produced vehicles need be
tested and inferences can be drawn regarding the conformity (with the standard) of other
newly assembled vehicles.
Sample testing will involve the auditing of production vehicles on some random basis.
Any sampling strategy adopted by EPA does not attempt to impose a quality control or
quality assurance scheme upon a manufacturer but would merely audit the conformity of
his products and provide a deterrent to the distribution in commerce of non-conforming
products.
Without some justification to the contrary, 100 percent testing is unnecessary, since
sample testing can yield the desired result. At this time, 100 percent testing is not proposed
as a primary enforcement tool; however, 100 percent testing may be required should an audit
show that a manufacturer is in violation of the regulation by introducing in commerce ve-
hicles exceeding the standards.
ENFORCEMENT ACTION
The prohibitions in the Act would be violated in the following instances:
• The manufacturer fails. to properly verify the conformance of production
vehicles,
8-2
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• On the basis of assembly process testing or other information, it is determined
that non-conforming production vehicles are knowingly being distributed into
commerce, or
• The manufacturer fails to comply with an Administrator’s order specifying appro-
priate relief where non-conformity is determined.
REMEDIES
In addition to the criminal penalties, fines, and imprisonment, associated with viola-
tions of the prohibitions of the Act, the Administrator has the option of issuing an order
specifying such relief as he determines necessary to protect the public health and welfare.
Such orders could require that a manufacturer recall products distributed into commerce
not in conformity with the regulations whether or not the manufacturer had knowledge of
the non-conformity. Recall orders will be issued in situations where assembly process test-
mg demonstrates that vehicles of a particular configuration have been distributed in com-
merce not conforming with the applicable emission standards.
The Administrator may also issue an order requiring the manufacturer to cease distri-
bution in commerce of vehicles where the requirements of production verification have not
been met.
Any orders would be issued only after manufacturers had been afforded notice and an
opportunity for a hearing.
LABELING
The label will provide notice to buyers and users that the product is sold in conformity
with the regulations and that the vehicle is equipped with noise attenuation devices, which
should not be removed or rendered inoperative, as prohibited under Federal law. The label
also states that the use of a product which has been “tampered with” is prohibited.
IN-USE COMPLIANCE
If the goal of protecting the public health and welfare is to be fully achieved, the noise
levels of vehicles (which cannot be exceeded at the time of sale) must not increase during
the useful life of the vehicle except possibly minimal allowance for degradation which cannot
be prevented by reasonable maintenance and repair. The standard, therefore, should
8-3
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incorporate an in-use standard that must not be exceeded during the useful life. However, little
data is available to determine the useful life of vehicles or what amount of degradation can
be expected_during their useful life. Thus, EPA has chosen not to promulgate a useful life
standard at this time, but has reserved this option until sufficient data is available to impose
such a standard. The delay in promulgating this requirement should not be construed as a
deemphasis of this important requirement, but merely as a means to assure that an accurate
and fair useful life requirement may be imposed.
The manufacturer is required (by Section 6(d) (1) of the Act) to warrant to the first
purchaser and each subsequent purchaser that the vehicle was designed, built, and equipped
to conform at the time of sale to the Federal noise emission standards. Thus, the manufac-
turer is required to remedy all defects in design, assembly, or in any part or system, which
at the time of retail sale caused the Federal noise emission standard to be exceeded. Although
the warranty covers only date-of-sale nonconformity, the consumer may make a claim under
the warranty at any time during the life of the product, as long as he can establish noncom-
pliance on the date of sale.
Recall is the appropriate remedy (under Section 11(d) (1)) to require the manufacturer
to repair or replace a class of vehicles which fails to conform to Federal standards at the time
of sale. Such recall may be used, for example, when products in use are discovered with de-
fects relating back to the date of sale which would cause noncompliance.
Tampering with (i.e., removing or rendering inoperative) the noise control devices and
elements of design is prohibited under Section 20(2) (A) of the Act. The use of a product
after it has been tampered with is also prohibited.
Finally, manufacturers can be required (under Section 6 (c) (1)) to provide instructions
to purchasers specifying the maintenance, use, and repair necessary to minimize or eliminate
any possible degradation from the initial noise emission levels.
8-4
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Section 9
ENVIRONMENTAL EFFECTS
Whenever action is taken to control one form of environmental pollution, there are
possible spinoffs affecting other environmental factors or natural resource. This section
evaluates the effects of truck noise control on air and water pollution, solid waste disposal,
energy and natural resource consumption, and land-use.
The principal sources of truck power train noise are the fan, engine, and exhaust. Fan
noise control involves the use of large, slower-turning fans, and fan clutches that disengage
the fan entirely when cooling requirements for the engine are satisfied. Engine noise con-
trol is achieved by vibration-isolating the engine and employing engine barriers or enclo-
sures. Exhaust noise is controlled through the use of more effective mufflers.
AIR
The major potential effect on air pollution from the noise control measures described
above would be an increase in engine exhaust emissions as a result of an increase in exhaust
system backpressure Fl 1. Truck exhaust mufflers have been designed and tested that ade-
quately reduce exhaust noise without exceeding engine manufacturers backpressure specifi-
cations. Accordingly, no increase in air pollution is to be expected from noise control related
to exhaust mufflers. Air intake systems modifications, should they be necessary, are not
expected to result in any change in vehicle performance or increased exhaust emissions.
WATER AND SOLID WASTE
There are no significant impacts that would apparently result from truck noise control
on either water quality or solid waste disposal.
ENERGY AND NATURAL RESOURCE CONSUMPTION
There are three factors where noise controls affect energy consumption. The first and
major factor is the use of fans that can be disengaged when not required. Bender et al Eli
9-1
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developed the following estimates of fuel savings in gallons per mile per unit of accessory
horsepower (Table 9-1).
Table 9-1
Fuel Savings, Gallons Per Mile Per Unit of Accessory Horsepower
.
Engine Type
Truck Category
Medium
Heavy
Gasoline
Diesel
0.0035
.0019
0.0019
.0010
Also, the following annual mileages by truck category apply* (Table 9-2).
Table 9-2
Annual Mileage, Gallons Per Mile Per Unit of Accessory Horsepower
Engine Type
Truck Category
Medium
Heavy
Gasoline
Diesel
10,000
21,000
18,000
54,000
Finally, the number of trucks that are predicted to be in use in 1990 [ 2] are shown in
Table 9-3.
Data reduced from U.S. Bureau of Census, 1973.
9-2
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Table 9-3
Trucks in Use in 1991
Truck Type
Model Years
Estimated
Population in 1990
Medium Gasoline
Medium Gasoline
Medium Gasoline
Heavy Gasoline
Medium Diesel
Medium Diesel
Medium Diesel
Heavy Diesel
1978 - 1981
1982- 1983
1984- 1991
1978 - 1991
1978- 1981
1982 - 1983
1984- 1991
1978- 1991
376.2x10 3
277.3x i0 3
l,497.4x10 3
354.0x10 3
5 .3x 103
3.7x 103
24.3x 10
2,469.2x 10
Table 9-4
Decrease in Accessory Power Requirements
Truck Type
Regulatory Levels
Power Savings
(hp)
Medium Gasoline
Medium Gasoline
Medium Gasoline
Heavy Gasoline
Medium Diesel
Medium Diesel
Medium Diesel
Heavy Diesel
83dBA
8OdBA
78 and 75dBA
83, 80, 78 and 75 dBA
83dBA
8OdBA
78 and 7SdBA
83, 80, 78 and 75dBA
2.5
4.5
6.0
15.0
5.0
9.0
12.0
15.0
9-3
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Combining the data in Tables 9-1, 9-2 and 9-3 as well as the estimated power savings given
in Table 9-4 (also see Table 6-8) shows that under regulatory options A, C and N approximately
2.59 billion gallons of fuel would have been saved by 1991, and under regulatory option E,
2.50 billion gallons.
The second energy effect factor might involve decreases in engine efficiency as a result
of increased exhaust system backpressure. Since exhaust systems can generally be made to
meet engine manufacturers backpressure specifications, any effect on fuel consumption in
this area is expected to be minor (see Section 6).
A third energy effect factor on fuel consumption is the increased truck-rolling resis-
tance attributable to the weight of noise control materials varies from a few pounds for
larger mufflers to potentially several hundred pounds for an engine enclosure. Estimates
of increases in fuel consumption attributed to increases in weight for noise treatment given
in Section 6 show that the added weight has a small effect on fuel consumption.
Effects on the consumption of other natural resources are expected to be small. As
indicated, no more than the addition of several hundred pounds per truck are likely to be
required for noise treatment. This is a small fraction of the roughly 25,000 to 30,000 lbs
per tractor/trailer vehicle.
LAND-USE
The expected impact of this Federal new truck regulation on land-use would reduce
marginal capital damages on property bordering highways and streets. In a recent report,
Nelson indicated that “traffic noise has a negative and statistically significant effect on prop-
erty value” [ 3 1.
Nelson found that for suburban areas, marginal capital damages were $58 per property
per dBA above the residual level (L 1 o - L 90 ). These results were based only on individual
property sales in close proximity to major highways.
9-4
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REFERENCES
[ 1] BENDER, E. K., W. N. PATTERSON and G. E. FAX. The technology and costs of
quieting medium and heavy trucks, BBN Report 2710. Bolt Beranak and Newman,
Cambridge, Mass. (October 30, 1974).
[ 2] MILLER, D. C. Equations used for truck population models, BBN memo to Charles
1. Molloy, EPA/ONAC (May 23, 1974).
[ 3] NELSON, J. P. Effect of mobile-source air and noise pollution on residential property
value, Report No. DOT-OS-40094. Department of Transportation, Office of University
Research, Washington, D.C. 20590 (January 1975) p. 7 - 21 .
9-5
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Appendix A-i
INTRODUCTION TO DOCKET ANALYSIS
This analysis is intended to serve as a review of the public comments which were made
regarding the New Medium and Heavy Truck Proposed Regulation, published in the Federal
Register on October 30, 1974.
The analysis is structured as follows:
In the Summary of Comments (Section A-2), each issue is identified by a number or
series of numbers. The individual comments are grouped together by contributor. The
contributors are also grouped into the major categories of (1) truck manufacturer, (2) manu-
facturers related to the truck industry, (3) truck users, (4) private citizens, (5) State and
local governments, and (6) trade organizations.
Issues are identified and discussed in Sections A-3 through A-i i, as outlined below.
A discussion on the actions taken in response to public comments is presented for each issue.
Section
Number Docket Analysis Comment Categories
A-i Introduction
A-2 Summary of Comments
A-3 Benefits to Public Health and Welfare. Discusses the comments
related to the impact made by the proposed regulation on the
community noise environment.
A-4 Technology. Discusses the comments on the noise control technology
necessary to produce trucks that comply with the proposed regulations.
A-S Costs of Compliance. Examines the criticisms made of the costs
associated with producing trucks that comply with the proposed
regulations.
A-6 Costs Versus Benefits. Discusses comments on the justification of
the costs of the proposed regulations relative to the benefits to be
derived, and the methods of comparing costs and benefits.
A-i-I
-------
Section
Number Docket Analysis Comment Categories
A-7 Economic Impact. Issues on the economic impact of the proposed
regulations are discussed.
A-8 Testing. This section discusses criticisms of the proposed test
procedure.
A-9 Classification. Briefly discusses comments regarding the vehicles
to which the regulation should or should not be applicable.
A-i 0 Enforcement. Examines comments on the enforcement of the proposed
regulations.
A-i I Miscellaneous Comments.
A-l-2
-------
Appendix A-2
SUMMARY OF COMMENTS
Comments were made on the Proposed Noise Emission Standards on New Medium and
Heavy Trucks (Federal Register, 30 October 1974, p. 38338) in the form of written responses
in Docket ONAC 74-1 and in Public Hearings held on 19-20 February 1975 in Arlington,
Va. and 27 February 1975 in San Francisco, Calif. Summaries of the comments which fall
into the general categories of public health and welfare, available technology, costs of com-
pliance, costs vs benefits, economic impact, compliance testing or vehicle classification are
given here. The comment summaries are catalogued according to contributor, and the contri-
butors grouped into truck manufacturers, manufacturers related to the truck industry, truck
users, private citizens, governments (local, State or federal agencies), and trade organizations.
Within each group, the contributors are listed in alphabetical order by the name of the
organization, State or local jurisdiction, or citizen. The general category into which the
comment is placed is given in parentheses after each comment summary along with refer-
ences to the original comment. Numbers which begin with the letter “T” (e.g., T076) refer
to written Docket submissions. References to the Official Transcript of the Public Hearings
in Arlington, Va. and in SanFrancisco are given by PHW and PHSF, respectively. Written
submissions in response to questions or requests for additional information at the Hearings
are referenced by numbers beginning with “Th” (e.g., Th039).
A-2.1 TRUCK MANUFACTURERS
A2. 1.1 Chrysler Corporation
A-2. 1.1.1 Meeting the regulated 75-dBA regulatory level is not technically feasible.
The Freightliner DOT Quiet Truck is a 75-dBA truck (not 72-dBA as claimed by EPA) and
thus will not comply with the not-to-exceed 75-dBA regulation (Technology, p. 4—5 of
T087).
A-2. 1.1.2 Medium diesel trucks are the most difficult to quiet since they have very
high engine noise levels due to their high-speed, light-weight engine design. No prototype
A-2-l
-------
medium diesel truck has been built to demonstrate the availability of technology for meeting
the 75-dBA regulatory level (Technology, p.4 of T087).
A-2. 1.1.3 It is not possible to determine the acceptable design ranges on the para-
meters for devices and elements which are known to control noise over the useful life of
trucks (Technology, p. 2—210 of PHW).
A-2. 1.1.4 EPA underestimated the increase in the costs per truck required to meet
regulatory levels. To comply with the 83-dBA level would cost about $500 more per truck
and for the 80-dBA, $1200 more per truck. No estimate could be made for the 75-dBA
regulatory level (Costs of Compliance, p.6 of T087).
A-2. 1.1.5 Noise abatement equipment would cause an increase in annual service labor
costs of $800 per truck for the 80-dBA regulatory level (Costs of Compliance, p.7 of T087).
A-2. 1.1.6 The deceleration test should be required only on trucks equipped with
engine brakes. (Testing, p. 9 of T087 and p. 2-208 of PHW).
A-2. 1.1.7 The round-off procedure and the number of tests to be used are not ade-
quately described in the proposed test procedures. (Testing, p. 9 of T087).
A-2. 1.1.8 Motor homes should be excluded from the regulation. (Classification,
p. 8 of T087).
A-2.1.2 Crane Carrier Company
The regulations would have a greater economic impact on the smaller company, parti-
cularly those who build specialized vehicles, The costs for a test facility would be $250,000
and the operating costs would be $80,000 per year. These costs must be spread out over
fewer trucks, resulting in higher increases in costs for trucks from the smaller manufacturer.
The smaller company cannot compete with the larger ones for the technical talent required
to design and produce compliant vehicles. Customers can find ways to do without special-
ized vehicles. Therefore, an increase in prices could have a greater impact on the manufacturer
of specialized vehicles (Economic Impact, Ti 16).
A-2.l.3 Ford Motor Company
A-2.1.3.l The I-dBA increase in community noise level every 5 years caused by the
predicted increase in truck population given by EPA is too high. Predictions of future truck
populations are too high (Health & Welfare, p. 1 of T119 and p.3-199 of PHW).
A-2-2
-------
A-2. 1.3.2 The contributions to community noise from tires and regulated trucks should
be assessed separately (Health & Welfare, p. 2 of Ti 19).
A-2. 1.3.3 Costs-benefits analyses for more regulation options, such as 83-dBA from
1977 to 2000, need to be made (Health & Welfare, p. 1 of Ti 19).
A-2.l .3.4 Regulations in which 10 percent of the tested vehicles are allowed to be
2 dBA above the regulatory level will produce substantially all of the intended noise reduc-
tion (Health & Welfare, p. 3—197 of PHW).
A-2. 1 .3.5 “Off-the-sheir’ hardware does not exist which will produce the noise
reductions necessary to comply with 80- or 7 5-dBA regulatory levels, meet reliability require-
ments, and not reduce truck performance and fuel economy (Technology, p. 7 ofT! 19 and
p.3—198 of PHW).
A-2. 1.3.6 The DOT Quiet Trucks were prototypes of limited quantity involved in
linehaul service which is probably not the most severe type of operation and therefore do
not adequately demonstrate that technology is available to build reliable trucks which
comply with the 75-dBA regulation (Technology, p. 7 of T119).
A-2. 1.3.7 Vehicle testing indicates that truck noise levels approaching 77-dBA which
is needed to comply with the 80-dBA regulation cannot be reached (Technology, p. 3-213 of
PHW).
A-2.l.3.8 Design targets need to be at least 3 cIBA below not-to-exceed regulatory
levels to assure compliance of most trucks (Technology, p. 3-209 of PHW).
A-2.1.3.9 High backpressure in exhaust systems is associated with high noise reduc-
tion and reduced engine performance (Technology, p. 8 of Tl 19).
A-2.l .3.10 Some of the noisier engines are no longer usable where an 83-dBA regu-
lation is in effect (Technology, p. 4 of Tl 19).
A-2. 1.3.11 Many of the heavy diesel Ford trucks require a fan clutch, larger mufflers,
and engine noise shields to meet 83-dBA regulatory level (Technology, p.4 of Tl 19 and
p. 3—211 of PHW).
A-2.1.3.12 Design changes which will probably be required to meet the 80-dBA
regulation are full encapsulation for diesel engines, noise shields for gasoline engines, treat-
ment of air intake systems for diesel trucks, fan clutches, larger radiators and fans, double
wall exhaust pipes, wrapped mufflers, internal engine modifications and tire redesign
(Technology, pp. 3—212—4 of PHW).
A-2-3
-------
A-2. 1.3.13 Many gasoline trucks will require modifications to the cooling system,
including the addition of fan clutches, in order to comply with the 83-dBA regulation
(Technology, p. 4 of TI 19 and p. 3-211 of PHW).
A-2. 1.3.14 EPA underestimated the increase in the costs per truck required to meet
regulatory levels. To meet the 83-dBA regulation, the cost increases will be $163 for medium-
heavy gas trucks, $194 for extra-heavy gas trucks, $514 for mid-range diesel trucks, and
$973 for premium diesel trucks. For the 80-dBA regulation, the cost increases will be $700
for medium-heavy gas trucks, $900 for extra-heavy gas trucks, $1800 for mid-range diesel
trucks and $2500 for premium diesel trucks. These cost estimates include design and
development costs and costs associated with EPA’s requirement to document noise control
hardware, which were not included in the EPA estimates (Costs of Compliance, p. 9 of Ti 19
and p. 3-2 14 of PHW).
A-2.l.3.15 If 10 percent of the tested vehicles are allowed to exceed the regulated
levels by 2 dBA, the increased costs per truck will be reduced from a range of $ 163—973
to a range of $62—385 for the 83-dBA regulation (Costs of Compliance, p. 3—202 of PHW).
A-2. 1.3. 16 The noise regulations on trucks will result in only 3-dBA reduction in
community noise levels by 1990 at a cumulative cost of over 3 billion dollars. This noise
reduction will not be cost effective (Costs vs. Benefits, p. 1 of Ti 19).
A-2. 1.3.17 A trade-off analysis needs to be performed on quieting trucks versus using
noise abatement along highways, such as barriers, building insulation, and control of vehicle
traffic (Costs vs. Benefits, p. 2 of Ti 19).
A-2. 1.3.18 The effect of the Interstate Motor Carriers regulation should be assessed
before regulations on new trucks are promulgated (Costs vs. Benefits, p. 4 of Ti 19 and
p. 3-201 of PHW).
A-2.1.3.19 The 75-dBA regulation will reduce the overall noise from an individual
truck at highway speeds by only about 3.5 dBA. A non-sensitive observer requires 8-dB
to just detect an intensity difference of a pure tone. This implies that the truck noise re-
duction will not be noticeable or cost effective (Costs vs. Benefits, p. 7 of Ti 19).
A-2.1.3.20 The regulations will cause an added inflationary burden on the automobile
and trucking industry at a time when it is economically depressed (Economic Impact, p.
3—196 of PHW).
A-2. 1.3.21 The present supply of quiet engines is not enough to meet current demands
resulting from state and local noise regulations and therefore the future supply of quiet
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diesel engines may be inadequate to meet the EPA proposed regulations (Economic Impact,
p. 8 of T119 and p.3—198 of PHW).
A-2.l.3.22 The 80-dBA regulatory level will force manufacturers to reduce the
number of truck models (Economic Impact, p. 1 of Exhibit II of Th039).
A-2.2.3.23 The round-off procedure and the number of tests to be used are not
adequately described in the proposed test procedures. (Testing, p. 11 of Ti 19).
A-2.1.3.24 In order for the regulation to have a consistent impact on manufacturers,
they should be effective on calendar years instead of model years. (Miscellaneous, p. 10
of Ti 19).
A-2. 1.4 Freightilner Corporation
A .2. 1.4.1 The 77-dBA tire noise level used by EPA in assessing benefits to the public
welfare is for new ribbed tires on a smooth surface and is 5- to 9-dBA lower than half-worn
ribbed tires on typical road surfaces. The tire noise from a loaded tractor and trailer at
55 mph with half-worn ribbed tires is about 84 dBA. Using this level for tire noise, the
75-dBA regulation will result in only a 3- to 6-dBA reduction in total truck noise at 55 mph.
Since a linehaul truck spends around 70 percent of its operating time at speeds over 50 mph,
the benefits to the public welfare of the regulations will be small (Health & Welfare, p. 5 of
T103 and pp. 617—622 of PHSF).
A-2.l.4.2 Engine quieting kits reduce diesel engine noise by only about 2 dBA, not
up to 4 dBA as claimed by EPA (Technology, p. 6 of T103).
A-2. 1.4.3 Design targets need to be 2- to 3 dBA below not-to-exceed regulatory
levels in order to comply with the proposed regulations (Technology, p. 627 of PHSF).
A-2. 1.4.4 The tires on the final configuration of the Freightliner DOT Quiet Truck
were not suitable for highway use (Technology, p. 635 of PHSF).
A-2. 1.4.5 The Freightliner DOT Quiet Truck has a larger than normal engine com-
partment and radiator frontal area. Typical heavy diesel trucks have less room, which will
make it impossible to bring all trucks into compliance with the proposed 75-dBA regulation
(Technology, p. 636 of PHSF).
A-2.1.4.6 The noise treatment to meet the 75-dBA regulatory level will increase the
weight of the truck by about 700 lbs. This will result in a loss of about $1000 per year per
truck in revenue for the bulk hauler (Costs of Compliance, p. 2 of Tl03).
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A-2. 1.4.7 EPA underestimated the increase in the costs per truck required to meet the
proposed regulations. To comply with the 83-dBA regulatory Ievel)the truck price increase
will be $456 per truck, for the 80-dBA level, $500 to $700 per truck, and for the 75-dBA
level, $1000 to $1200 per truck (Costs of Compliance, p. 2-3 of T103).
A-2. 1.4.8 Fuel savings from fan clutches should not be included in estimating changes
in operating costs caused by noise regulations, since the energy shortage will force their use
in the absence of any noise regulations. The number of Freightliner trucks ordered with fan
clutches has increased from 1 percent to 11 percent. In addition, the proposed test for com-
pliance does not allow fan clutches to be off during testing, which removes the advantage of
using fan clutches in complying with the proposed regulations (Costs of Compliance, p. 4 of
T103 and pp. 623—4 of PHSF).
A-2 .1.4.9 The proposed 75-dBA regulatory level would severely limit the truck con-
figurations that could be manufactured (Economic Impact, p. 637 of PHSF).
A-2.1.4.10 The proposed regulations add to inflation (Economic Impact, p. 620 of
PHSF).
A-2. 1.4.11 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative. (Testing, p. 10 of T103).
A.2.1.5 General Motors
A.2. 1.5.1 Projections of changes in equivalent noise levels for urban freeways (55 mph)
and streets (35 mph) which should result from promulgation of the EPA proposed truck
noise regulations and promulgation of the GM proposed regulation of 83 dBA in 1977 show
that the inclusion of the 80 dBA and 75 dBA regulatory levels produce little additional reduc-
tion in the traffic noise levels. The maximum differences in the equivalent noise levels are
about 0.7 dBA at 55 mph and 2.3 dBA at 35 mph. These reductions result from a decrease
in regulatory levels of 8-dBA. The differences between the equivalent levels for 86 dBA and
83-dBA regulatory levels are 0.8 dBA for 55 mph and 1.9 dBA for 35 mph, which result
from a decrease in regulatory levels of 3 dBA. The most significant reductions result by
reducing regulatory levels to 83 dBA with decreased reductions in equivalent levels for
regulatory levels below 83 dBA. Therefore, only the 83-dBA regulation should be promul-
gated (Health & Welfare, pp. VI—l to VI—23 of T076 and pp. 40—46 of Th038).
A-2.1.5.2 Comparisons of EPA specified noise levels, which just intrude on given
activities, with predictions of noise levels versus distance from individual trucks regulated
at 83, 80 and 75 dBA indicate that regulating trucks at 80 or 75 dBA will have little effect in
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changing the number of activities intruded upon at distances greater than 70 feet. Therefore,
only the 83-dBA regulation should be promulgated since the 80 and 75-dBA regulatory
levels will produce little benefit to the public health and welfare (Health & Welfare, pp.
VI—24 to VI—48 of T076).
A-2. 1.5.3 Predictions of the distances at which the noise levels from an individual un-
regulated and an individual 83-dBA regulated truck exceed the noise levels from a continu-
ous flow of light vehicles by 10 dB at 55 mph indicate that the 83-dBA regulated truck does
not intrude over the background traffic noise 98 percent of the time. Therefore the 83-dBA
regulation is sufficient to reduce the intrusion of an individual truck most of the time, and
the 80 and 75-dBA regulations are not necessary (Health & Welfare, pp. VI—48 to VI—5 1 of
T076).
A-2. 1.5.4 The differences in the noise levels measured by SAE J366b for the existing
trucks and 83-dBA regulated trucks will be large enough to indicate that regulatory levels
below 83 dBA should not be established. The 50 percentile level was reduced by 7. l-dBA
and the 0.1 percentile level by 15.3-dBA (Health & Welfare, pp. VI—51 to VI—53 of T076).
A-2. 1.5.5 The differences in roadside noise levels between one truck which complies
with the 83 dBA regulation (80.5 dBA) and one which complies with the 80 dBA regulation
(78.2 dBA) are 0.5 dBA at 125 feet for urban acceleration, 1.6 dBA at 125 feet for 35 mph
cruise, and 0.3 dBA at 150 feet for 55 mph cruise. Both trucks were equipped with quiet
ribbed tires. These differences are small enough to indicate that the 80 dBA regulation will
bring little additional benefit over the 83 dBA regulation (Health & Welfare, p. 12 of Th004
and p. 2-46 of PHW).
A-2. 1.5.6 EPA should develop estimates of benfits for a regulatory program which
inciuaes all of the following necessary elements: new truck regulations, interstate carrier
regulations including state and local enforcement of identical regulations, regulations on
tire noise, and elimination of modified and poorly maintained light vehicles (Health &
Welfare, p. 54 of Th038).
A-2. 1.5.7 Design targets need to be 2 to 3 dBA below the not-to-exceed regulatory
levels in order to comply with proposed regulations (Technology, p. V-5 of T076).
A-2.l.5.8 In order to comply with the 83-dBA regulatory level, many heavy diesel
trucks will require double wall muffler and exhaust pipes, and engine noise barriers. In
addition, to bring most heavy diesel trucks into compliance with the 80-dBA level, modified
engines with barrel-shaped, tight clearance pistons, fan clutches, full underpans, and engine
compartment absorptive material will be needed. A larger radiator or a remote cooling
system, totally encapsulated turbocharged engines and transmissions, air cleaner silencers
and larger mufflers with premufflers will have to be added to many 80-dBA regulated trucks
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in order to comply with the 75-dBA regulatory level. Engine side shield will be required on
gasoline trucks to meet the 75-dBA regulation (Technology, pp. V-26-28 of T076).
A-2.l.5.9 The Freightliner DOT Quiet Truck is not a good demonstration of the
available technology to meet the 75-dBA regulation, because it had a special COE sleeper
cab with a larger engine compartment than available on most production heavy diesel trucks
(Technology, P. V-3 of T076).
A-2.l.5.l0 Piston slap is the major single source of noise in diesel engines and signifi-
cant engine noise reductions are not likely to result unless piston slap is reduced (Technology,
p V-b of T076).
A-2.l.5.l 1 The technology to manufacture engine noise barriers which are easy to
install and remove, satisfy durability requirements and provide sufficient attenuation is not
available (Technology, p. V-i 1-12 of T076).
A-2.l.5.l2 It will be necessary to turbocharge all diesel engines to reduce exhaust
noise enough to meet the 75-dBA regulation (Technology, p. V-13 of 1076).
A-2.l.5.13 A fully encapsulated engine is required to meet the 75-dBA regulation.
This will require the use of a remote cooling system in some cabs, since sufficient space
for large enough radiators is not available (Technology, p. V-13-14 of T076).
A-2.l.S.14 The durability of packed mufflers, tight clearance pistons, and absorptive
materials in engine compartments are not known (Technology, p. V-23 of T076).
A-2. 1.5.15 The technology is not available .to mass-produce trucks to comply with
the 75-dBA regulation since technology applications upon which production manufacturing
may be based for trucks to cbmply with the 75-dBA regulation have not been demonstrated
to be feasible (TechnolOgy, pp. 2-18-19 of PHW and p. 57 and 62 of Th038).
A-2.l.5.l6 Tire noise needs to be reduced so that it does not mask the reduction of
noise from other truck sources, such as engine, exhaust, and fan. However, it is not possible
with available technology to reduce tire noise levels much below the levels of the quietest
available tires (Technology, pp. 2-44and 2-69 of PHW).
A-2.1.5.17 Tire and aerodynamic noise (65-73 dBA), axle noise (up to 78 dBA), truck
frame radiation (up to 70 dBA), truck cab radiation (up to 65 dBA), and transmission noise
(up to 77 dBA) must be treated in addition to engine, cooling, exhaust and intake systems, in
order to comply with the 75 dBA regulation (Technology, pp. 59-61 of Th038).
A-2. 1.5.18 The durability and noise reduction effectiveness of new engine mounting
systenis necessary to comply with the 75-dBA regulation have not been determined (Techno-
logy, p. 62 of Th038).
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A-2. 1.5.19 The encapsulation of engines will cause increases in engine compartment
temperatures from about 100°F to 200°F which may affect the durability of some engine
mounted components and create a fire hazard (Technology, p. V—10 and V—23).
A-2. 1.5.20 Costs for compliance testing were not included in the estimated costs to
the customer of the truck. The test facility required by EPA will cost $286,000. In addition,
a $500,000 acoustically treated chassis dynaniometer facility will be required for develop-
ment testing (Costs of Compliance, p. VII—3 of T076).
A-2. 1.5.21 The estimations of customer price increases per truck were based on the
regulatory levels and not the design or median levels, and are therefore too low (Costs of
Compliance, p. VII—4 of T076).
A-2. 1.5.22 The decrease in costs of noise abatement due to future improvements in
noise control technology should not be included in cost estimates (Costs of Compliance,
p. VII—4 of T076).
A-2. 1.5.23 EPA’s costs estimates are outdated (Costs of Compliance, p. Vu—S of
TO 76).
A-2. 1.5.24 The fan clutch was included in the GM estimates of increases in purchase
prices of the truck, but the fuel savings were not included because there are not enough real
data on fuel savings over a large enough range of different operating conditions (Costs of
Compliance, p. VII-8 of T076).
A-2.l.5.25 The estimated average increases in prices for diesel trucks are $365 to
comply with 83-dBA regulatory level, $1090 for the 80-dBA level, and $4450 for the
75 dBA. For gasoline trucks, the average increases in truck price will be $25 to meet
the 83-dBA regulation, $130 for 8OdBA and $350 for 75 dBA. These price increase
estimates include increased costs due to development and testing, manufacturing, tooling,
compliance testing, and dealer and customer services associated with noise abatement
equipment. Costs for six models were weighted by sales volume before averaging. The figure
for the 83-dBA level is based on manufacturer’s suggested retail prices for “Quiet Truck
Packages” used to comply with local 83-dBA regulations (Costs of Compliance, pp. Vu—i 2—
13 of T076, p. 2—20 of PHW and pp. 12—15 of Th038).
A-2.1.5.26 The estimated average increases in annual maintenance costs per year
per diesel truck are $179 to comply with 83-dBA regulatory level, $304 for the 80-dBA
level and $305 for the 75-cIBA level. These estimates include increased labor costs for
ordinary maintenance caused by the addition of noise abatement equipment, and increased
costs for replacement parts to assure continued compliance. Costs for six models are
A-2-9
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weighted by sales volume in computing the average maintenance cost increases (Costs of
Compliance, pp. VI-1 2-13 of T076 and pp. 13-20 of Th038).
A-2.l.5.27 For one of GM’s truck models, a 6 percent reduction in cargo volume
would result in complying with the 75-dBA regulation (Costs of Compliance, p. VIl-7 of
1076).
A-2. 1.5.28 At 35 mph, the adoption of the 83-dBA regulation will yield 80 percent
of the benefit (8-dJ3A reduction for the 83-dBA regulation relative to 10.1 -dBA for the
75-dBA regulation) for 32 percent of the total costs ($5.2 billion of the $16.2 billion for
adoption of the EPA proposed regulations). At 55 mph, 95 percent of the benefits (5.9-dBA
of the total 6.2-dBA) result from 32 percent of the costs. Therefore, it is not cost-effective
to spend an additional $11 billion for such a small increase in benefits (Costs vs. Benefits,
pp. VlII-3-4 of T076).
A-2. 1 .5.29 The results of the analyses of benefits versus costs given by the Department
of Transportation (2.5.4.4) and the Council on Wage and Price Stability (2.5.6.1 ) are incor-
rect, mostly because the estimates of savings are too high. Their estimates are too high
because their assumptions, given below, are incorrect.
1. All trucks are operated 70,000 miles per year.
2. The average power savings with fans off is 19.5 hp for all medium and heavy
trucks.
3. Fan clutches will be used on all new regulated trucks and the resulting saving can
be credited to the noise emission regulations.
4. The price increase for trucks which comply with the 75-dBA regulation is $1075
(Cost vs. Benefits, Th052).
A-2.1 .5.30 Possible shifts in buying habits caused by noise regulations need to be
considered (Economic Impact, p. VII 7 of T076).
A-2.1 .5.31 The cumulative costs caused by .the EPA proposed noise regulations will
be $16.2 billion by 1990. If only the 83-dBA regulatory level is adopted, the cumulative
costs will be $5.2 billion. Thus, the national economy will be seriously affected by the EPA
proposed 80 and 75-dBA regulations. The cumulative cost estimates include projections of
vehicle sales, average customer costs per truck and average maintenance costs per truck
(Economic Impact, pp. VII-14-15 of T076).
A-2.1 .5.3 2 Environmental regulations contribute to inflation (Economic Impact,
WI-i of T076).
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A-2. 1 .5.33 An Inflation Impact Statement is required (Economic Impact, pp. 2-20
of PHW).
A-2.l .5.34 The proposed test procedure allows excessive variability and should include
test site correction factors. (Testing, p. IV-5 of 1076).
A-2. 1 .5.35 The proposed regulation provides no provisions for correcting measured
noise levels to standard conditions of temperature, barometric pressure, etc. (Testing,
p. tV-S of T076).
A-2. 1 .5.36 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative. (Testing, p. IV-4-5 of T076).
A-2. 1.6 International Harvester Company
A-2. 1.6.1 At speeds above 40 mph, tire noise overshadows the engine-related noise
for trucks regulated at 83 dBA, making regulations below 83 dBA completely ineffective
except in a few areas (Health & Welfare, p. 7 of 1113).
A-2. 1.6.2 Community noise modeling has not progressed to the extent that truck
noise can be adequately correlated to community noise levels. MVMA is presently spon-
soring an effort to provide an adequate model (Health & Welfare, p. 7 of Ti! 3).
A-2.l.6.3 EPA has not established that truck noise makes a significant contribution
to environmental noise levels, or derived a relation between environmental noise levels and
annoyance. In addition, EPA has not developed a relation between truck noise levels mea-
sured according to the test procedure in the proposed regulations and the levels necessary to
protect public health and welfare (Health & Welfare, p.26 of TI 13 and p.3—124 of PHW).
A-2.l.6.4 The noise generated by trucks do not cause hearing damage, but may pro-
duce annoyance which is difficult to measure objectively (Health & Welfare, p. 3—126 of
PHW).
A-2. 1.6.5 The manufacturer is forced to design 2 to 3 dBA below the regulatory
levels in order to comply with the proposed regulations (Technology, pp. 4—5 and 28 of
T1l3 and p. 3—122 of PHW).
A-2. 1.6.6 The technology to meet the 75-dBA regulatory level is not currently avail-
able for any truck. The fundamental design criteria was compromised in the Freightliner
A-2-l I
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DOT Quiet Truck and therefore it does not represent available technology. The cooling was
not adequate and the truck was unique in that it had a small engine in a chassis designed for
larger engines (Technology, pp. 6 and 35 of Ti 13).
A-2.l.6.7 The technology to meet the 80-dBA regulatory level does not exist for a
full truck line, because a 2-3/4 year lead time is required to redesign each truck model and
a full set of reliability tests is needed on each truck model (Technology, pp. 31 and 33 of
T113).
A-2.1.68 Extensive redesigns of the cooling, exhaust and air-intake systems and
the addition of engine panels were required for International Harvester DOT Quiet Truck
to comply with the 83-dBA regulation (Technology, pp. 28-30 of Ti 13).
A-2.1.6.9 The noise levels given in Table 2, Volume 5, page 11, of the HRBDG for
truck engine, exhaust and fan noise for a 55—65 mph cruising condition are higher than SAE
J366b levels which should be maximum levels. Such discrepancies cast doubt on the valid-
ity of these levels in HRBDG and, in turn, on the EPA background document (Technology,
p. l3ofThO4l).
A-2.1.6.lO The estimated increases in purchase price due to the addition of noise
abatement equipment are $583 for a heavy diesel truck to comply with the 83-dBA regula-
tory level and $2150 for the 80dBA level. These estimates are 3 to 4 times greater than
EPA’s estimates partly because EPA did not take into account the need to design trucks
2 to 3 dBA below the regulatorY levels (Costs of Compliance, pp. 30-32 of TI 13).
A-2. 1.6.11 The added costs increase at a faster rate as the levels of truck noise are
reduced to lower levels. Down to the regulatory level of 83 dBA the costs increase at a rate
of approximately $70/dBA and below the regulatory level of 83 dBA at about $750/ dBA
(Costs of Compliance, p. 3—125 of PHW).
A-2.1.6.12 The projected initial price increase ($2150 per truck) far outweighs any
benefit to public health and welfare (Costs vs. Benefits, p. 35 of TI 13).
A-2.1.6.13 The 80-dBA regulation should be adopted no sooner than 1983 and the
regulations re-evaluated in 1979 (Costs vs. Benefits, p. 6 of 1113).
A-2.1.6.14 An Inflation Impact Statement is required (Economic Impact, p. 3—118
of PHW).
A-2.l.6.15 Since truck manufacturers are currently being forced to eliminate some
truck configurations to meet local 83-dBA regulations, the EPA proposed regulations should
A-2-12
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reduce the number of truck configurations which can be offered. A list of truck-engine com-
binations dropped because of the California 83-dBA regulation was given (Economic Impact,
p. 3—143 of PHW and p. 17—18 of Th041).
A-2. 1.6.16 Increased demand for quiet engines may result in shortages (Economic
Impact, p. 18 of Th04 1).
A-2.l.6.17 The test procedure should be improved. (Testing, pp. 40-1 of Tl13).
A-2. 1.6.18 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative. (Testing, p. 46 of Ti 13).
A-2. 1 .6.19 The deceleration test should only be required on vehicles equipped with
engine brakes. (Testing, p. 45 of Tl 13).
A-2. 1.6.20 The instrumentation required for compliance testing should be more
precisely specified. (Testing, p. 51 of TI 13).
A-2.1.7 Mack Trucks, Inc.
A-2. 1.7.1 The 75-dBA regulated truck would not produce enough noise to serve as
a warning to pedestrians, and thus would constitute a safety hazard (Health & Welfare, p. 3
of Ti 13).
A-2. 1.7.2 Compliance with 86 and 83-dBA local regulations has already produced
drastic reductions in overall noise levels. An adoption of the 80-dBA regulation should be
considered after obtaining more experience with 83-dBA regulated trucks. The 75-dBA
regulation should be postponed indefinitely (Health & Welfare, p. 3 of TI 13).
A-2. 1.7.3 Truck noise c an produce annoyance but does not affect hearing loss (Health
& Welfare, p. 3—5 of PHW).
A-2. 1.7.4 Tire noise at higher speeds will reduce the benefits from regulations on truck
noise levels which are lower than 83-dBA (Health & Welfare, p. 3—6 of PHW).
A-2.l.7.5 Design targets need to be 2 to 3-dBA below the regulatory levels in order
to comply with proposed regulations (Technology, p. 1 of Ti 02 and p. 3—7 of PHW).
A-2.l.7.6 It is impossible to determine the design noise level for the 80 or 75-dBA
regulatory level which compensate for deterioration over the life of the truck (Technology,
p. 2 ofTlO2).
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A-2. 1.7.7 The 80-dBA regulation may require encapsulation of some power plants
and removal of the noisier engines. The 75-dBA regulation will require the elimination of a
majority of vehicle configurations, and the encapsulation of engines in trucks of the remain-
ing configurations (Technology, pp. 1—2 of T102).
A-2.1.7.8 Results from the DOT Quiet Truck Program can not be considered adequate
grounds for determining that the technology for meeting the 75-dBA regulation is available
since COE trucks are usually quieter than similarly equipped conventional trucks
(Technology, p. 2 of Tl02).
A-2.1.7.9 Because of the elimination of some engines and truck configurations which
will be caused by the 80 and 75-dBA regulations, the user may be forced to use a truck that
does not fulfill his requirements which may increase his operating Costs. Some present
engine-truck models can not be marketed in California, where an 83dBA regulation is in
effect (Economic Impact, p. 2 of T102, pp. 3—9 of PHW, and pp. 17—18 of ThO4l).
A-2.1.7.lO Federal regulatory agencies should consider the cumulative increase in
costs of all regulations on trucks, such as the Federal Motor Carrier Safety Regulations on
truck brakes and interior noise levels, and the EPA’s regulations Ofl smoke and gaseous
emissions, the regulations passby noise levels for interstate motor Carriers and the proposed,
new truck noise regulations (Economic Impact, pp. 8—9 of T102 and pp. 3—14 of PHW).
A-2. 1.7.11 A stationary compliance test would be desirable. (Testing p. 3-10 of PHW).
A-2. 1.7.12 The proposed test procedure allows excessive variability and should include
test site correction factors. (Testing, p. 7 of Tl02).
A-2. 1.7.13 The roun.d-off procedures and the number of tests to be used are not
adequately described in the proposed test procedures. (Testing, p. 6 of T102).
A-2. 1.8 Oshkosh Truck Corporation
A-2.1.8.1 New technology will be required to economically produce trucks to meet
the 75-dBA regulation (Technology, Ti 25).
A-2.1.8.2 In order to comply with the proposed noise regulations, heavy truck manu-
facturers will be largely dependent on the ability of engine manufacturers to produce quiet
engines (Economic Impact, T125).
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A-2.1.9 Paccar Inc.
A-2.1.9.1 Design targets need to be at least 2 dBA below the regulatory levels in
order to comply with the proposed regulations (Technology, p. 4 of 1126, pp. 443 and 465
of PHSF, and p. 2 of Th036).
A-2. 1.9.2 The degradation of the performance of noise reduction hardware and change
in noise levels from engines with age is not known (Technology, p. 444 of PHSF).
A-2.l.9.3 Technology is not available to comply with the proposed regulations
(Technology, p. 442 of PHSF).
A-2. 1.9.4 The estimated increases in the prices per truck to meet the 83-dBA regula-
tion will be $2 10-400, to meet the 80-dBA regulation, $700, and to meet the 75-dBA
regulation, $1400 (Costs of Compliance, pp. 442 and 465 of PHSF).
A-2. 1.9.5 The cost of compliance testing was not considered in assessing the costs of
compliance for the proposed regulations. The cost of an adequate test facility could be
$147,000 to $346,000. Independent testing services may cost nearly $1800 per truck for
manufacturers who custom-build trucks if testing is required on almost all trucks (Costs
of Compliance, p. 3 of T126 and p.443 of PHSF).
A-2. 1.9.6 The proposed regulations should not claim credit for the savings due to fan
clutches, since they will be widely used without the regulations (Costs of Compliance, p. 444
of PHSF).
A-2. 1.9.7 Medium trucks impact an estimated 34.6 million people whereas heavy
trucks impact an estimated 2.7 million people. Therefore, regulating medium and heavy
trucks separately could be used to increase the ratio of the public welfare benefits to costs
of compliance (Costs vs. Benefits, p. 1 of Th036).
A-2. 1.9.8 The proposed regulations are inflationary (Economic Impact, p. 446 of
PHSF).
A-2. 1.9.9 Cumulative effect of federal regulations to date have added approximately
$2550 to customer costs per truck. These added costs have been a major contributor to
the recent economic downturn. Therefore, in assessing the economic impact of the EPA
proposed regulations on new truck noise emissions, the cumulative effect of all federal
regulations on trucks should be considered (Economic Impact, p. 441 of PHSF).
A-2- 15
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A-2. 1.10 White Motor Corporation
A-2. 1.10.1 The responsibility for determining the benefits to the public health and
welfare of the proposed truck noise regulations rests with EPA. EPA has not substantiated
the benefits from the regulatory levels below 83 dBA. Therefore, the regulatory levels below
83 dBA should be removed from the regulations (Health & Welfare, p. 11—12 of T085 and
pp. 2—138 of PHW).
A-2.l.l0.,2 Heavy trucks typically operate above 35 mph where tire noise will reduce
the benefits derived from the proposed regulations (Health & Welfare, pp. 2—142 of PHSF).
A-2. 1.10.3 There are no data available to determine the deterioration of the perfor-
mance of noise abatement equipment (Technology, p. VI—3 of T085 and pp. 3—16 1 and
3—166 of PHSF).
A-2.l.10.4 Other noise sources in trucks which have yet to be measured or treated
will need treatment in order to comply with the lower regulatory levels (Technology, p.
2—161 of PHSF).
A-2.l.10,5 The truck owner, whose truck is weight limited, may lose $600 annually
because of weight increases caused by the 8 3-dBA regulation and $1600 annually for the
80-dBA regulation (Costs of Compliance, p. 2—141 of PHSF).
A-2.1.lO.6 EPA’s estimated increases in truck prices are too low. Estimated increases
in the prices of heavy diesel trucks will be $261 to meet the 83dBA regulation and $1307
to meet the 80-dBA regulation. Quieting kits to bring a Freightliner conventional truck into
compliance with local 83-dBA regulations cost $636. The above estimation of price increases
include manufacturing costs only and do not include any costs for testing required by EPA,
allowances for R&D, engineering, inflation, or excise taxes (Costs of Compliance, pp.
2—139—40 of PHW).
A-2l.10.7 The truck price increases at a faster rate as the levels of the truck noise
are reduced. Reducing the truck noise level to 81 cIBA costs $37/dBA, whereas reducing
the truck noise level from 81 to 78 dBA costs $349/dBA (Costs of Compliance, p. 3-140
of PHW).
A-2.l 10.8 An Inflation Impact Statement is required (Economic Impact, p. 111—i of
T085).
A-2.l. 10.9 The proposed regulations will contribute to inflation (Economic Impact,
p. 2—142 of PHSF).
A-2-1 6
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A-2.l,1O.10 The proposed test procedures should be improved. (Testing, p. v-I of T085).
A-2.1.10.l 1 A stationary test would be desirable, (Testing, p. V-S of T085).
A-2. 1.10.1 2 The proposed test procedure allows excessive variability and should
include test site correction factors. (Testing, p. V-3 of T085).
A-2. 1.10.13 The proposed regulation contains no provisions for correcting measured
noise levels to standard conditions of temperature, barometric pressure, etc. (Testing, pp. V-2-3 of T085).
A-2. 1.10.14 Testing should take place with the engine coolant at operating temper-
ature. (Testing, p. V-2 of T085)
A-2. 1. 10.15 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative. (Testing, p. V-7 of T085).
A-2. 1.10.16 The instrumentation required for compliance testing should be more
precisely specified. (Testing, p. VII-9 of T085).
A-2.2 MANUFACTURERS RELATED TO THE TRUCK INDUSTRY
A-2.2. 1 Cummins Engine Company, Inc.
A-2.2. 1.1 There are little data on the change in engine noise levels with the age of the
engine (Technology, p. 2 of Ti 24).
A-2.2. 1.2 Engine noise depends on engine power as well as engine type and design
(Technology, p. 3 of Ti 24).
A-2.2,l.,3 The average level of truck fan noise in 83.3 dBA which is higher than
indicated by EPA (Technology, p. 4 of TI 24).
A-2.2. 1.4 Transmission noise averages 75.5 dBA and chassis noise (coast-by at 30
mph) averages 70 dBA. Therefore, noise from the transmission and chassis may become
significant as the total vehicle noise level is reduced to comply with the 75-dRA regulatory
level (Technology, p. 4 of TI 24).
A-2- 17
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A-2.2.l..5 The costs for testing will be higher than estimated by EPA. For example, the
test site will cost approximately $150,000 (Costs of Compliance, p. 5 of T124).
A-2.2.2 Donaldson Company, Inc.
A-2.2.2. 1 Truck noise can produce annoyance, but does not affect hearing loss. There
is no accurate technique for objectively evaluating annoyance (Health & Welfare, p. 272—3
of PHSF).
A-2.2.2.2 The greatest annoyance comes from a small minority of the noisiest trucks.
Reduction in the noise levels from these trucks by the Interstate Motor Carriers will result
in a significant reduction in traffic noise. (Health & Welfare, p. 274 of PHSF).
A-2.2.2.3 Tire noise levels at highway speeds frequently exceed 80 dBA at 50 feet.
Therefore, regulatory levels below 8 4BA would not produce significant benefits, since
technology to reduce tire noise does not exist (Health & Welfare, p. 275 of PHSF).
A-2.2.2.4 Design targets need to be 2—5 dBA below the regulatory levels in order to
comply with the proposed regulations (Technology, p. 277 of PHSF).
A-2.2.2.5 Even with partial engine enclosures which were open in front and back, two
of the three DOT Quiet Trucks could not be quieted to below 75 cIBA. Therefore, it is not
clear that the technology is available to comply with the 75 cIBA regulation (Technology,
p.275 of PHSF).
A-2.2.2.6 Many engines will require partial enclosures to meet the 80-dBA regulation
and all will require enclosures to meet the 75-dBA regulation (Technology, p. 275 of PHSF).
A-2.2.2..7 Engine enclosureswill result in reduced payload capacities, loss in fuel
economy, and increased maintenance costs (Costs of Compliance, p. 275 of PHSF).
A-2.2.2.8 EPA’s estimates of increased truck prices are understated by at least 25
percent (Costs of Compliance, p. 276 of PHSF).
A-2.2.2.9 The 80 and 75-cIBA regulations should be postponed until experience with
-the 83-cIBA regulation can be used to better assess the benefits and costs of the lower
regulatory levels (Costs vs. Benefits, p. 273 of PHSF).
A-2.2.2.10 The small manufacturer of trucks with special equipment would be sub-
jected to an unreasonable economic burden (Economic Impact, p. 276 of PHSF).
A-2- 18
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A-2.2.3 B.F. Goodrich
A-2.2.3. 1 Tire noise will be a factor in complying with the 75-dBA regulation.
Therefore, the regulatory levels below 83-dBA should not be adopted until more information
is available on the control of tire noise (Technology, p. 4 of Th030).
A-2.2.3.2 Measuring in the “fast” response could result in levels l—2-dBA lower than
that measured under “slow” response. “Slow” response should be utilized. (Testing, p. 2 of Th030).
A-2.2.4 Koehring Company
A-2.2.4. 1 The proposed regulations will add absolutely nothing to the health and
welfare of the public (Health & Welfare, p. 374 and 384 of PHSF).
A-2.2.4.2 Facilities required for testing for compliance will cost between $500,000
and $1,000,000 (Costs of Compliance, p. 373 of PHSF).
A-2.24.,3 The estimated costs for transporting one special purpose constfuction eh
by rail, which required disassembling and reassembling, and testing according to the proposed
test procedures ranged from $2935 to $11,380 (Costs of Compliance, pp. 377—82 of PHSF).
A-2.2.4,4 The need for testing facilities for the federal brake safety regulation en-
couraged one large truck manufacturer to close one plant and move production to another
plant where test facilities were available. This had a significant economic impact on the area
where the plant was closed. Economic impact factors such as this should be considered
before the proposed regulations are promulgated (Economic Impact, p. 371 of PHSF).
A-2.24,5 The proposed regulations could put some manufacturers out of business
business (Economic Impact, p. 374 of PHSF).
A-2.2.5 Rexnord
A-2.25. I Mounting a mixer on a truck chassis does not materially affect the truck’s
noise emissions (Technology, p. 5 of T02 1).
A-2. 2.6 Schwitzer Engineering Components
A-2.2.6. 1 The technology does not appear to be available to comply with the 75-dBA
regulation (Technology, p. 2-174 of PHW).
A-2-19
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A-2.2.6.2 Tire noise at high speeds can not be reduced below about 80-dBA. There-
fore, reducing truck power plant noise to levels below 80dBA will not produce enough
benefits to justify the additional costs (Costs vs. Benefits, p. 2-174 of PHW).
A-2.2.6.3 The costs will be enormous if the 75-dBA regulation is established and then
must be postponed (Economic Impact, p. 2—175 of PHW).
A-2.2.6.4 The present high unemployment in the trucking industry and increasing
vehicle costs will increase the economic impact of the proposed regulations (Economic
Impact, p. 2—i 74 of PHW).
A-2.2.6.5 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan drive in its normal automatic mode (Testing, p. 2 of 1081).
A-2.2.6.6 The round-off procedure and the number of tests to be used is not ade-
quately described in the proposed test procedures (Testing, p. 1 of T08 1).
A-2.2.7 Walker Manufacturing
A-2.2.7. I The technology for exhaust systems would permit shorter lead times in the
proposed regulations (Technology, T05 3).
A-2..2.8 Horton Manufacturing Company, Inc.
A-2.2.,8.1 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative (Testing, T054).
A-2.2.9 Bendix Heavy Vehicle Systems Group
A-2.2.9.1 Vehicles equipped with thermostatically controlled fan drives should be
tested with the fan inoperative (Testing, 1088).
A-2-20
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A-2.2. 11 Buckeye Equipment Company
A-2.2. 11.1 The availability of enough acoustical consultants may be inadequate for
all manufacturers to be able to comply with these regulations. (Miscellaneous, T023).
42.3 TRUCK USERS
A-2.3. I American Trucking Associations, Inc.
A-2.3.l.l At speeds below 35 mph, tire noise will make a significant contribution to
the overall noise levels from trucks regulated at 80-dBA and below. Therefore, tire noise will
reduce the benefits derived from the proposed regulations. (Health & Welfare, p. 7 of Ti 08
and p. 3—47 of PHW).
A-2.3. 1.2 A comprehensive study of the technology of quieting tires, and the effect
of quieting tires on safety and costs of operation must be completed before the regulations
should be adopted. For example, the use of tire labeling as a tool for the truck manufac-
turer and user for selecting quiet tires should be considered. Within the available technology
for tires, there is a practical floor to tire noise below which it is impractical to produce a
tire of any tread configuration that would be acceptable and safe in normal truck service
(Technology, p.7 of T108 and p.3-47 of PHW).
42.3.1.3 The truck manufacturers will be forced to design for noise levels 2 to 3-dBA
below the regulatory levels in order to comply with the proposed regulations (Technology,
p. 4 ofTIOS).
A-2.3. 1.4 Major engine redesigns will probably be required in order to obtain any
worthwhile reduction in engine noise (Technology, p. 4 of T108).
A-2.3. 1.5 The regulations may force the use of turbocharged engines in place of
naturally aspirated engines in some trucks. The projection of increases in costs needs to
include the increased costs of using turbocharged engines in place of naturally aspirated
engines (Costs of Compliance, p. 4 of T108).
A-2-2l
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A-2.3. 1.6 The cost of modifications to truck cabs, resulting from redesign of cooling
systems required to reduce noise, should be included in the projections of increased truck
costs (Cost of Compliance, p. 5 of T108).
A-2.3.1.7 The price increases associated with quieting trucks rises exponentially as
the noise levels are reduced (Costs of Compliance, p. 9 of 1108).
A-2.3. 1.8 EPA’s estimates of increases in truck prices are low (Costs of Compliance,
p. 3—48 of PHW).
A-2.3. 1.9 The estimates of fuel savings presented by the Department of Trans-
portation are too high (Costs of Compliance, mO b).
A-2.3 110 The regulations may force engines to be redesigned with closer tolerances
and combustion modifications. The cost of the increases in failure rates of these redesigned
engines needs to be included in the economic analysis (Costs of Compliance, p.4 of T I 08).
A-2.3.1.l I The increase in weight due to noise treatment will affect bulk haulers the
most. This point was dismissed by EPA (Costs of Compliance, p. 349 of PHW).
4-2.3.1.12 The cost of quieting new trucks rises exponentially as the noise levels are
reduced, yet the benefits to the public are reduced to a point of little or no return. A more
careful study of cost/benefit ratios needs to be made before the regulations are adopted
(Costs vs. Benefits, p. 9 of TI 08 and p. 3—44 of PHW).
A-2.3.l.13 The adoption of the lower regulatory levels should be postponed until after
experience with the 83-dBA regulation can be obtained and used to assess better the costs
and benefits of the lower regulated levels (Costs vs. Benefits, p. 3—52 of PHW).
A-2.3.1.14 Federal regulations have increased the price of linehaul tractors by 14
percent over the increase due to inflation. Federal regulations have contributed to the present
recession. The cumulative effect of federal regulations will put the small trucker out of bus-
iness (Economic Impact, p. 3—50-1 of P11W).
A-2.3.1.15 The trucking industry was not adequately represented during the
development of the proposed regulations (Miscellaneous, p. 3 of TI 08).
A-2.3.2 Construction Machinery Company
A-2.3.2 ,l If the mixer mounter must comply with the proposed regulations, the
entire sales distribution pattern would be disrupted completely, resulting in two or three
large deakrs servicing the entire country (Economic Impact, TOl 5).
A-2-22
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A-2.3.3 Gifford-Hi]J Company
A-2.3.3.1 An Inflation Impact Statement is required (Economic Impact, 1067).
A-2.3.4 W.S. Hatch Company
A-23.4. 1 The regulations should not be promulgated until equipment that can be
used in complying with the regulations can be developed (Technology, Th042).
A-2.3.4.2 The EPA estimates of increases in prices and weights of trucks indicate
that bulk haulers will be seriously impacted economically (Costs of Compliance, Th042).
A-2.3.5 Overdrive Magazine
A-2.3.5. 1 The increases in weight for noise treatment will result in lost revenues to
the general freight operator of $8 to 69 per year for the 83 dBA regulatory level and $170
per year for the 75-dBA regulatory level. For the bulk hauler, the losses will be $51 to
445 per year for the 83-dEA level and $1000 per year for the 75-dBA level (Costs of
Compliance, p. 574 of PHSF).
A-2.3.5.2 The costs of the research and development needed to comply with the
proposed regulations should be borne by the entire public (Economic Impact p. 569 of
PHSF).
A-2.3.5.3 An analysis of the results of current federal regulations affecting the trucking
industry should be conducted before adopting any new regulations (Economic Impact, p. 570
of PHSF).
A-2.3.5.4 Because of increases in truck costs, projected profits for truckers will be
lower, making it more difficult to obtain necessary loans to buy trucks. This will force
many truckers out of the truck business (Economic Impact, p. 570—1 of PHSF).
A-2.3.5.5 An economic impact statement, which goes into more depth than provided
into the Background Document, must be prepared (Economic Impact, p. 572—3 of PHSF),
A-2.3.5.6 There is no analysis of the economic impact that the proposed regulations
will have on the independent trucker (Economic Impact, p. 576 of PHSF).
A-2-23
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A-2. 3.6 PROD (Professional Drivers)
A-2.3.6.1 Noise from trucks sometimes masks warning signals, such as those from
sirens from emergency vehicles. Quieter trucks would permit people to hear such signals,
thereby contributing to public safety (Health & Welfare, p. 2-246 of PHSF).
A-2.3.6.2 The estimated costs given by EPA apply to prototype vehicles. Under full
production, the added costs per truck will be lower (Costs of Compliance, p. 2—238 of PHW).
A-2.3.6.3 After promulgation of the proposed regulations on new trucks, the in-use
regulations on interstate carriers should be modified to bring the noise levels from old trucks
closer to those of new trucks (Costs vs. Benefits, p. 2—256—7 of PHW).
A-2.3.7 Regular Common Carrier Conference
A-2.3.7. I The manufacturer’s estimates of increases in annual operating costs may be
higher than the EPA estimates because the manufacturer considered the increase in
needed maintenance as the truck ages (Costs of Compliance, p. 1 of Th03 1).
A-23.7.,2 The costs of repairs which could be caused by failures of fan clutches
should be considered in estimating operating costs. For example, if the fan clutch bearing
fails, the fan may come off and damage the radiator (Costs of Compliance, p. 2 of Th03 1).
A-2.3.7.3 Operators cannot afford the current increases in truck prices. The proposed
regulations will increase truck prices even more, which will make the situation more difficult
for truck users (Economic Impact, p. 3 of Th03 1).
A-2.3.7.4 The cumulative increase in prices of new trucks caused by federal regulations
on trucks, such as those on brakes, interior noise levels and exterior noise levels, will prevent
truckers from buying the new trucks they need, which will have a serious economic impact
on them (Economic Impact, p. 4 of Th03 1).
A-2.4 PRIVATE CITIZENS
A-2.4.1 B.L.AtkmS
A-2.4. 1.1 By moving too quickly with truck regulations, EPA is contributing to
inflation (Economic Impact, T004).
A-2-24
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A-2.4.2 Lawrence Auerbach
A-2.4.2. 1 The current regulations, as well as future regulations, should be firmly
and effectively enforced (Costs vs. Benefits, T080).
A-2.4.3 Citizens Against Noise
A-2.4.3.1 Noise from trucks disturbs sleep and can affect health (Health & Welfare,
p. 3—82 of PHSF and Th037).
A-2.4.3.2 The technology is available to produce quieter tires (Technology, Th037).
A-2.4.3.3 The proposed regulations are too lenient. Truck noise levels should be
reduced to automobile noise levels (Costs vs. Benefits, p. 3—79 and 3—83 of PHW).
A-2.4.3.4. Regulations should be adopted to force operators to retrofit all trucks so
that the noise from all trucks is reduced (Costs vs. Benefits, p. 3—80 of PHW).
A-2.4.3.5 Regulations should be adopted which prevent trucks from operating at
night (8:00 p.m. to 8:00 a.m.) (Costs vs. Benefits, p. 3—80—1 of PHW).
A-2.4.4 Friends of the Earth and Sierra Club
A-2.4.4. 1 Technology is available to allow the 80-dBA regulatory level to be advanced
one year (Technology, Th029).
A-2.4.4.2 Research in this country as well as in England and Germany has clearly
shown that the 75-dBA regulation can be attained with available technology (Technology,
Th029).
A-2.4.5 Alan Parker
A-2.4.5.l The 83 and 80-dBA regulations should be made effective in 1976 and 1980,
respectively (Health & Welfare, T050).
A-2.4.6 George Wilson
A-2.4.6. 1 Manufacturing trucks to comply with the 75-dBA regulatory level is tech-
nically feasible (Technology, p. 499 of PHSF).
A-2-25
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A-2.4.6.2 In comments before promulgation of the California regulations, General
Motors indicated that they would have no problem in meeting the 86, 83 and 80-dBA
California regulations (Technology, p. 500 of PHSF).
The following citizens expressed their support of the proposed regulations: Harold
Blau (T002), Robert C. Puff, Jr. (TO 10), D. L. Bristol (1043), Stephen Richter (1049),
P. J. Coorey (1051), Lawrence Auerbach (T080), and Thomas F. Scanlan (T098).
A-2.5 GOVERNMENTAL AGENCIES (STATE, LOCAL AND FEDERAL AGENCIES)
A-2.5.1 California Highway Patrol
A-2.5 .l. I Regulations on operational noise levels should be adopted to insure that
truck noise levels do not increase with age (Costs vs. Benefits, p. 511-2 of PHSF).
A-2.5.2 City of Chicago, Department of Environmental Control
A-2.5.2. I The results from the DOT Quiet Truck Program indicate that the 75-dBA
regulation can be met (Technology, p. 2—2 62 of P11W and p. 485—6 of PHSF).
A-2.5.2.2 The lead times should be reduced so that the 75-dBA regulation becomes
effective in 1980 (Costs vs. Benefits, p. 2—262 of PHW and p.486 of PHSF).
A-2. 5.3 Delaware
A-2.5.3.,1 The technology of reducing tire noise was not addressed (Technology, T095).
A-2.5.3.2 The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, 1095).
A-2.5.3.3 There should be some provisions for the noise reduction of old trucks (Costs
vs. Benefits, T095).
A-2.5.3.4 The savings in costs for highway noise barriers and extra noise insulation of
buildings, and the increase in property values caused by the noise reduction for the new
truck regulations should be included in the economic analysis (Economic Impact, 1095).
A-25.3.5 Trucks in different GVWR categories should be regulated to different noise
levels. (Classification, 1095).
A-2-26
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A-2.5.4 Department of Transportation
A-2.5.4.,1 Regulations on tire noise of 83 dBA in 1977 and 80 dBA in 1981 for a
50 mph coast-by should be adopted concurrently with the proposed new truck regulations
(Health & Welfare, p. 6 of 1104 and p. 3—287 of PHW).
A-2.5.4.2 Since buses are usually operated in densely populated areas and are fre-
quently accelerating such that they generate higher levels than assumed by EPA (73-dBA at
50 feet), they should be included in the truck regulations (Health & Welfare, pp. 7—8 of
T104 and p. 3-289 of P11W).
A-2.5.4.3 The benefits of the proposed regulations on new truck noise emissions
should be identified separately from the benefits from regulations on other highway noise
sources, such as truck tires. At 55 mph, the reduction in traffic noise levels will be 0.2, 0.5
and 0.7-dBA for the 83, 80 and 75-dBA proposed regulations on trucks when there are no
regulations on tire noise, and 3.5, 4.1 and 4.6 dBA for the 83, 80 and 75-dBA regulations
with regulations on tire noise which reduces all tire noise levels to those of the quietest tires
known today. At 27 mph, the reductions in traffic noise levels will be 1.7, 3.1 and 4.5 dBA
for the 83, 80 and 75-dBA proposed regulations on trucks when there are no regulations on
tire noise, and 2.2, 3.7 and 5.2 dBA with regulations on tire noise. (Health &
Welfare, p. 3-29 of PHW).
A-2.5.4.4 Cooling system radiator shutters should not be referred to as noise
reduction equipment, since closing the shutters increases the noise by about 2 dBA
(Technology, p. 1 of Tl 04 and p. 3-282 of PHW).
A-2.5.4.5 In all of the trucks in the DOT Quiet Truck Program, the cooling
system noise was greater than 80 dBA. This suggests that many truck cooling systems
generate noise levels in excess of 80 dBA (Technology, p. 2 of T104 and p. 3-283 of PHW).
A—2.5.4.6 Given equal flow rates, the design of the cooling fan has little effect on
its noise generation (Technology, p. 2 of 1104 and p.3-283 of P11W).
A-2.5.4.7 Exhaust shell noise is high enough on many trucks that it will require
treatment to meet the 83-dBA regulation. On the International Harvester DOT Quiet
Truck the pipe shell noise was 82 dBA and the muffler shell noise was 74 dBA, whereas
the exhaust discharge noise was 76 dBA and noise due to exhaust leaks was 72-dBA
(Technology, pp. 3-4 of 1104 and p. 3-285 of PHW).
A-2-2 7
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A-2.5.4.8 Mufflers are available to reduce exhaust outlet noise of all popular truck
diesel engines to 75 dBA. In many cases, the 75-dBA level can be reached without series
mufflers (Technology, p. 4 of Tl04 and p. 3—285 of PHW).
A-2.5.4.9 There is no fundamental difference in the noise control technology for
trucks and buses (Technology p. 7 of T104 and p. 3—289 of P11W).
A-2.5.4.1O The manufacturing design levels would be about 4 dBA below the
regulatory levels which includes 2 dBA to account for variation of the levels for identical
trucks and 2 dBA to account for design tolerances (Technology, p. 10 of Ti 04, p. 3-296
of PHW and p. B-3, Information Brief, 10 April 1975).
A-2.5.4. 11 Sufficient information does not exist to assure that all trucks can
be quieted to a 75-dBA noise level (Technology, p. 7 of Ti 04 and p. 3-297 of PHW).
A-2.5.4.12 Reduction of cooling system noise to a level of 65 cIBA which is needed
to reduce most truck noise levels to 75 dBA will require radiators to be larger than those
available today. It may be possible to include large enough radiators on COE trucks, but
it will not be practical on conventional trucks because of the need for visibility (Technology,
p. 2—283 of P11W).
A-2.5.4.13 The data on engine, exhaust and fan noise levels, taken from the Highway
Research Board Design Guide for nominal highway operations, are higher than SAE J366b
test levels. These data appear to be about 5 dBA too high since engine-related highway noise
levels should be at least 2 dBA below levels measured according to SAE J366b test proced-
ures (Technology, p. 3—291 of PHW).
A-2.5.4.14 The tire noise level of 77 dBA at 55 mph, assumed by EPA in making
predictions of the benefits of the proposed regulations, is too low. Such a level is not
attainable by any tire known today (Technology, p. 3-292 of PHW).
A-2.5.4. 15 The fact that the noise levels of the International Harvester DOT Quiet
Truck decreased slightly with age can be partly attributed to thorough maintenance pro-
cedures (Technology, p. 3-298 of PHW).
A-2-2 8
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A-2.5.4.,1 6 EPA’s estimates of costs for noise abatement treatment are lower than the
costs quoted in the DOT Quiet Truck Program. Freightliner achieved 72—74 dBA at a cost of
$1400, International Harvester, 78 dBA for $1390 and 80 dBA for $516 and White Motors
Corp., 79—81 dBA for $260 and 77—79 cIBA for $1307 (Costs of Compliance, p. 10 of T104
and p. 3—296 of PHW).
A-2.5.4. 17 The monetary estimate associated with reductions in urban traffic noise is
about $20/person/dB. Using this figure along with estimates of the number of people ex-
posed to urban street or freeway traffic noise and the reductions in traffic noise for different
regulatory options, monetary estimates for the benefits were computed. Estimates of costs!
savings associated with each regulatory option were made assuming credit for fuel savings
from disengaged fan clutches. Comparing estimates of costs/savings and monetary estimates
of benefits show that the costs for the proposed regulations are greater than the benefits.
Savings are predicted to result with the regulatory options which do not have the 75-dBA
regulatory level. (Costs vs. Benefits, DOT Information Brief, April 10, 1975, pp. 5—7).
A-2.5.4. 18 EPA should consider the different benefits of using vertical and horizontal
exhaust systems. For example, lower exhaust noise levels are achievable more easily with
vertical systems than with horizontal due to apparent image source enhancement of the
horizontal systems. Technology is more advanced for vertical systems. The gases from under-
frame systems are more aggravating and create splash and spray visibility problems. The
lower exhaust outlet noise levels of underframe systems make roadside barriers more effec-
tive. Iinderframe systems present more difficult packaging problems. The noise radiated
vertically is 2-dBA higher for vertical systems (Costs vs. Benefits, pp. 4—5 of T 104 and p.
3—286—7 of P11W).
A-2.5.4.19 The total cost impact of the proposed regulations can not be
determined from the estimates given by EPA since production tolerances were not
included in the design levels used to estimate the costs (Economic Impact, p. 10
of Tl04 and p.3-296 of PHW).
A-2.5.4.20 Special purpose equipment should be covered under the regulations
(Classification, p. 9 of T1Q4).
A-2.5.4.21 Buses should be included in the regulations (Classification, p. 7 of TI 04).
A.2.5.5 City of Des Plaines, Illinois
A-2.5.5. 1 The proposed regulations should be more stringent so that they conform
with the local regulations in Chicago and California (Costs vs. Benefits, p. 658 of PHSF).
A-2-29
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A-2.5.6 Council on Wage and Price Stability
A-2.5.6. I The analysis of the increasing marginal costs and decreasing marginal bene-
fits strongly indicate a lack of justification 75-dBA regulatory level. The GM estimates of
truck price increases and operating costs for medium trucks and the DOT estimates for
heavy trucks were used. Benefits included estimates of changes in property values and fuel
consumption with fan clutches. The costs and benefits were cumulated to the year 2000
and discounted at a rate of 10 percent to a 1975 present value (Cost vs. Benefits, Th051).
A-2.5.7 District of Columbia
A-2.5.7. I The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, T063).
A-2.5.8 Federal Highway Administration, Ohio
A-2.58.l An Environmental Impact Statement is required (Health & Welfare, T066).
A-2.5.8.2 The assessment of increases in annual opbrating costs should take into
account replacement parts and labor costs to maintain a truck in compliance (Costs of
Compliance, T066).
A-2.5.8.3 The costs of testing facilities and manpower, and production delays due to
testing should be determined (Costs of Compliance, T066).
A-2.5.8.4 The effect of truck noise treatments on fuel consumption should be deter-
mined (Costs of Compliance, T066).
A-2.5.8.5 An assessment of a “do-nothing” alternative to the regulations shauld be
addressed (Costs vs. Benefits, TOM).
A-2.5.8. 6 The effect that increases in transportation costs have on the costs of cus-
tomer retail goods should be determined (Economic Impact, T066).
A-2.5.8.7 The effect that differences in cost increases for gasoline and diesel trucks
will have on buyer patterns should be determined (Economic Impact, T066).
A-2-30
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A-2.5.9 State of Illinois, Environmental Protection Agency
A-2.5.9. 1 The 75-dBA regulation is needed to reduce intrusions from noise emissions
from trucks (Health & Welfare, p. 310 of PHSF).
A-2.5.9.2 The 75-dBA regulation will not reduce roadside truck noise levels to levels
similar to the roadside levels of automobiles, as indicated in the Preamble to the Proposed
Regulations. The 75-dBA regulated truck will typically be around 10 dBA noisier than the
average automobile (Health & Welfare, p. 311 of PHSF).
A-2.5.9.3 A label on the vehicle should state the noise level produced at the time of
manufacture, GVWR and model year. (Miscellaneous, p.309 of PHSF)
A-2.5.1O Indiana
A-2.5.l0.1 The exhaust system should be required to be located beneath the truck
body (Costs vs. Benefits, T093).
A-2.5.I I Louisiana
A-2.5.1l.l The impact of training testing personnel and of production delays for
testing should be assessed (Costs of Compliance, Ti 27).
A-2.5. 11.2 Prior to promulgation, the economic impact of the regulation should be
re’ ised and re-evaluated to terms of the existing economic stiuation (Economic Impact,
T127).
A-2.5.12 Los Angeles County
A-2.5.12.1 An effort to regulate noise from buses should be initiated (Health &
Welfare, T105).
A-2.5.12.2 The California regulation of 70-dBA in 1987 should be included in
EPA’s regulations (Costs vs. Benefits, Ti 05).
A-2.5. 13 Mississippi
A-2.5.13.1. The effect of the regulations on public health should be assessed
(Health & Welfare, T073).
A-2-31
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A-2.5.l3.2 The effect of the regulations on highway safety should be considered
(Health & Welfare, T073).
A-2.5. 13.3 The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, T073).
A-2.5. 13.4 The economic analysis should consider the effect of the noise regulations
on the costs of highway projects (e.g., savings in required highway noise barriers) and on
property values (Economic Impact, T073).
A-2.5. 14 Minnesota
A-2.5.14.l Complementary regulations on tires on all vehicles at normal highway
speeds should be considered (Health & Welfare, T086).
A-2.5.l4.2 The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, T086).
A-2.5.14.3 States must rely on highway noise treatments until the regulations on trucks
become effective. (Miscellaneous, 1086)
A-2.5.15 New Mexico
A-2.5.1 5.1 The proposed new truck regulations are in excess of the 70-dBA L 10 FHWA
standards for residential, hospital and school areas. Therefore, truck regulations which are more
in keeping with 70-dBA at 50 feet should be adopted (Health & Welfare, T045).
A-2.5.15.2 The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, T045).
A-2.5.1 5.3 Noise abatement walls along highways cost about $1 00/foot. Therefore, the
effect of the new truck regulations on the need for highway noise barriers should be con-
sidered (Economic Impact, T045).
A-2.5.16 New York State
A-2.5.16.1 Since tire noise dominates at high speeds, regulations on tire noise should
be considered (Health & Welfare, T082 and Th027).
A-2-32
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A-2.5. 16.2 The regulations should include buses (Health & Welfare, T082 and Th027).
A-2.5.16.3 Special purpose equipment should be covered under the regulation.
(Miscellaneous, T046)
A-2.5.16.4 The regulation should include a high speed noise level standard.
(Miscellaneous, T082)
A-2.5.17 National Organization to Insure Sound Controlled Environment (NOISE)
A-2.5. 17.1 The predicted rate of increase in truck population of 4.3 percent per year
used in predicting benefits to the public welfare is too high (Health & Welfare, p. 3-31 2-3 of
PHW).
A-2.5.17.2 The regulations should be enforced at speeds below 50 mph instead of be-
low 35 mph, since tire noise does not become a factor for speeds below 50 mph (Health &
Welfare, p. 3-31 1 of PHW).
A-2.5.18 San Diego County
A-2.5. 18.1 Buses and vehicles over 6000 lbs. GVWR should be included in the regula-
tions (Health & Welfare, T097).
A-2.5.18.2 The regulatory levels should be at least as low as the California regulated
levels of 83 dBA in 1974, 80-dBA in 1977, and 70 dBA in 1987 (Costs vs. Benefits, T097).
A-2.5.19 San Francisco, Noise Control Task Force
A-2.5.19.1 Commercial trucks are capable of obtaining 80-dBA noise levels at reason-
able costs, now. The noise level from a bus was reduced from 90 to 81 dBA by retrofitting
noise treatment at a cost of $600 (Costs of Compliance, p. 416-7 of PHSF).
A-2.5.19.2 The proposed regulations are too lenient (Costs vs. Benefits, p. 414 of
PHSF).
A-2.5.20 Texas
A-2.5.20.1 Lower regulatory levels with shorter lead times should be considered (Costs
vs. Benefits, T042).
A-2-33
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A-2.5.20.2 The economic impact on the state and local governments of providing high-
way noise abatement treatment during the period before the EPA regulations become effec-
tive should be addressed (Economic Impact, T042).
A-2.5.21 Virginia
A-2.5.2 1.1 The height of exhaust stacks has an impact on the effectiveness of roadside
noise barriers and therefore should be addressed in the regulations (Costs vs. Benefits, T022).
A-2.5.21 .2 States must rely on highway noise treatment until the regulations on trucks
become effective (Miscellaneous, T022).
A-2.6 TRADE AND MANUFACTURING ORGANIZATIONS
A-2.6.1 American Road Builders Association
A-2.6.l .1 Studies which prove that there are harmful effects directly attributed to
noise from new trucks need to be conducted before the regulations are adopted (Health &
Welfare, Ti 14).
A-2.6.i.2 By the time the regulations become effective, inflation will have increased
the costs of compliance (Costs of Compliance, Th035).
A-2.6.2 Associated General Contractors of Colorado
A-2.6.2.1 The EPA projections of truck price increases are totally unrealistic (Costs of
Compliance, T060).
A-2.6.2.2 A tremendous reduction of noise can be accomplished by enforcement of
existing regulations (Costs vs. Benefits, T060).
A-2.6.2.3 The costs to all elements of the total economy, such as agency costs to en-
force the regulations, manufacturer’s costs, increased costs to the small businessman and
costs to the consumer, should be included in the costs projections (Economic Impact, T060).
A-2.6.2.4 The present state of the inflated economy should be considered in the analy-
sis of the economic impact of the regulations (Economic Impact, T060).
A-2.6.2.5 Trucks in different GVWR categories should be regulated to
different levels (Classification, T060).
A-2-34
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A-2.6.3 Automotive Exhaust Systems Manufacturers Committee
A-2.6.3.1 It is not technically feasible to determine the useful life of an exhaust system,
since there are no data on the driving habits of the vehicle owner. These data are critical in
determining the extent and speed of deterioration of exhaust systems (Technology, p. 9 of
T1l2).
A-2.6.4 Chamber of Commerce
A-2.6.4.1 EPA ’s estimate of 70 million people who are affected by traffic noise is too
high. It should be around 3-6 million (Health & Welfare, p. 2-104 of PHW).
A-2.6.4.2 The technology is not available to comply with the proposed regulations.
(Technology, p. 2-104 of PHW).
A-2.6.4.3 EPA’s estimates of the increases in truck prices are too low (Costs of
Compliance, pp. 2-105 and 2-111 of PHW).
A-2.6.4.4 The effects of the 83-dBA regulation should be assessed before lower levels
are set (Costs vs. Benefits, p. 2-1 14 of PHW).
A-2.6 ,4.5 The proposed regulations will cause trucks to be priced beyond reach
(Economic Impact, p. 2-103 of P11W).
A-2.6.4.6 The proposed regulations will have an inflationary impact on consumer goods
(Economic Impact, p. 2-104 of PHW).
A-2.6.4.7 The proposed regulations will help to drive the small trucker out of business
(Economic Impact, p. 2-106 of PHWX
A-2.6.4.8 The economic impact study is outdated (Economic Impact, p. 2-110-1 of
P11W).
A-2.6.4.9 The cumulative economic impact of all federal regulations on trucks should
be considered (Economic Impact, p. 2-118 of PHW).
A-2.6.S Construction Industry Manufacturers’ Association
A-26.5.1 Small manufacturers of custom-built specialty construction trucks do not
have the financial resources for the testing required in the proposed regulations (Costs of
Compliance, p. 357 of PHSF).
A-2-3 5
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A-2.6.6 Motor Vehicle Manufacturers’ Association
A-2.6.6.l EPA has not defined what is the “impact” that the regulations are intended
to relieve, or what is meant by “relief.” Does relief refer to avoiding hearing loss or reduction
in annoyance? (Health & Welfare, p. 3 of T099).
A-2.6.6.2 EPA has not met the statutory requirement which requires that the regulatory
levels be attainable with available technology (Technology, pp. 5-6 of T099).
A-2.6.6.3 The total increase in costs to users of attaining the 1990 level of benefits is
$2 to 3 billion higher than estimated by EPA since EPA failed to take into account all of the
costs incurred in the intervening years (Economic Impact, p. 4 of T099).
A-2.6.6.4 An Inflation Impact Statement is required (Economic Impact, p. 2 of T099)
A-2.6.7 National Solid Wastes Management Association
A-2.6.7.l Mounting a truck body could affect the noise emission characteristics of a
truck (Technology, p. 2-87-8 of PHW).
A-2.6.7.2 The economic impact on small companies engaged in solid wastes collection
and disposal services caused by increased prices and maintenance expenditures for equipment
should be carefully considered (Economic Impact, Ti 1 1).
A-2.6.7.3 Second-stage manufacturers of solid waste disposal trucks cannot afford the
costs of testing for compliance to the proposed regulations (Economic Impact, p. 2-92 of
PHW).
A-2.6.8 Recreation Vehicle Industry Association
A-2.6.8.l Motor homes have not been identified as a major source of noise. In fact,
motor homes are substantially quieter than medium and heavy duty trucks (Health & Welfare,
T120).
A-2.6.8.2 The regulations would have a devastating economic impact on the motor
home manufacturers and substantially restrict competition within the industry (Economic
Impact, T120).
A-2.6.8.3 Motor homes should be excluded from the Regulation (ClassifIcation, 1120).
A-2-36
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Appendix A-3
BENEFITS TO PUBLIC HEALTh AND WELFARE
A-3.1 BENEFITS TO PUBLIC HEALTH
A-3.l .1 Hearing Damage
Identification: The State of Mississippi (A 2.5.l3.l)* commented that the effects on public
health of the regulations on new truck noise emissions should be assessed. International
Harvester Company (A-2. 1.6.4), Mack Trucks, Inc. (A-2.l .7.3), and the Donaldson Company
(A-2.2.2. 1), asserted that outdoor noise from trucks does not cause damage to hearing, but
produces only annoyance. Citizens Against Noise (2.4.3.1) claimed that noise from trucks
disturbs sleep which can affect public health.
Djscussjon. In the assessment made by EPA of the impact of truck noise on hearing damage,
it was concluded that truck noise has little impact on hearing loss. EPA has identified an
8-hour equivalent noise level of 75 dBA as requisite to protect the public from hearing
damage with an adequate margin of safety [ II. Most people presently impacted by traffic
noise are exposed to equivalent levels less than 75 dBA. Note, however, that this is highly
dependent upon individuals’ exposure to non-traffic noise situations, i.e., workplace, recrea-
tional, etc. It is conceivable that exposure to traffic noise (even less than 75 dBA) combined
with hazardous or near-hazardous workplace/recreational noise may, in fact, be hazardous.
In the aggregate, however, most of the benefits from the regulations on new medium and
heavy truck noise emissions will be derived from the reduction of annoyance caused by
truck noise. In estimating the benefits to public health and welfare, EPA has focused atten-
tion on the reduction in the number of people disturbed or impacted by noise from trucks.
Even here it must be recognized that basic annoyance may adversely affect health by causing
general stress, fatigue, etc.
The annoyance associated with sleep disturbance by single truck passbys and the reduc-
tion in the present levels of annoyance by the regulations on new truck noise emissions has
been treated by EPA. However, little information exists on the impact on public health
caused by the disturbance of sleep by truck noise.
* Number refers to paragraph number in SectionA-2, SUMMARY OF COMMENTS.
A-3-1
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Action in Response to Public Comment: The benefits of the new truck noise emissions
regulations have been treated in terms of the reduction in annoyance caused by truck noise.
A-3.1.2 Safety
Identification: The State of Mississippi (A-2.5.13.2) suggested that the effect of the regula-
tions on highway safety should be considered. Mack Trucks, Inc. (A-2. 1 .7.1) commented
that the 75 dBA regulated truck would not produce enough noise to serve as a warning to
pedestrians. On the other hand, PROD (A-2.3.6.1) points out that the noise from unregu-
lated trucks masks the warning signals from emergency vehicles. Thus, the reduction of truck
noise is expected to increase the detection of warning signals, thereby contributing to public
safety.
Discussion: EPA agrees with PROD that an increase in the detectability of warning signals
should result from the reduction in overall traffic noise attributable to the reduction in truck
noise. It is not likely that the new truck regulations will produce a significant safety hazard,
as implied by Mack Trucks. Horns will probably provide most of the audible warnings to
pedestrians of impending danger. However, in the absence of the use of a horn, the 75 dBA
regulated truck will still be about 5 dBA noisier than unregulated automobiles. This should
be more than sufficient to provide warning to pedestrians close enough to be in danger.
Actions in Response to Public Comment: No further action has been taken.
A-3.2 BENEFITS TO PUBLIC WELFARE
A-3 .2.1 Need for Additional Study
Identification: The American. Road Builders Association (A-2.6.1 .1) suggested that there is
a need for studies which prove that there are harmful effects directly attributed to noise from
trucks. White Motor Corporation (A-2. 1.10.1) commented that the benefits to public wel-
fare for the new truck regulations have not been assessed. The American Trucking Associa-
tions, Inc. (A-2.3.I .10) pointed out that a more careful study of the benefits needs to be
conducted before the proposed regulations are adopted. According to the Motor Vehicle
Manufacturers Association, (A-2.6.6.l) definitions of “impact” on and “relief” to public
welfare have not been presented.
A-3-2
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International Harvester, Inc. (A-2. 1.6.2) and the Donaldson Company (A-2.2.2. 1)
indicated that modeling techniques have not been developed which are sufficient for accurate
predictions of benefits from motor vehicle noise regulations. International Harvester
(A-2. 1.6.3) added that EPA has not shown a relation between regulated truck noise levels
and noise levels necessary to protect public health and welfare. General Motors Corp. (GM)
(A-2.l .5.6) suggested that the effects of the Interstate Motor Carrier regulations, regula-
tions on tire noise and elimination of modified or poorly maintained light vehicles should be
considered in assessing benefits. The benefits of the regulations on new truck noise emis-
sions should be identified separately from the benefits for regulations on other sources of
traffic noise, according to the Department of Transportation (DOT) (A-2.5.4.3).
Ford Motor Company (A-2. 1 .3.3) commented that estimates of benefits should be
given for other regulatory programs. The Federal Highway Administration (A-2.5.8.5)
suggested that an assessment of the impact on the public welfare with no regulations on new
trucks be given.
Discussion: The equivalent number of people impacted by urban traffic noise is estimated
by EPA to be 37.3 million. Regulating only medium and heavy trucks to 75 dEA can reduce
this number by 13.1 million [ 2]. This indicates that medium and heavy trucks do have a
significant noise impact on people and that their regulation will bring appreciable relief.
Predictions of the benefits from several regulatory programs on noise emissions, from
new medium and heavy trucks have been made [ 2]. Estimates of the reductions in the
average noise levels for urban street traffic (average speed-27 mph) and freeway traffic
(average speed-S 5 mph) are given. The effect of these reductions on people is assessed. The
concept of equivalent number of people impacted is defined and used in making these as-
sessments. The word “relief” is used to indicate a reduction in the number of people im-
pacted by noise.
In revising the benefit predictions in response to public comment, predictions are given
for a wide range of possible regulations so that benefits from the final regulations can be
evaluated relative to more lenient and more stringent regulations. The regulatory programs
added in revising the predictions include the regulatory alternatives suggested by the Ford
Motor Company and the Federal Highway Administration. To provide additional insight
into the benefits will probably result from the new truck regulations alone and when sup-
ported by other regulations, predictions are given with and without a 4 dBA reduction in
noise levels from road vehicles other than medium and heavy trucks. Since average noise
levels are sometimes a poor indicator of annoyance from individual truck passby noise,
estimates of the amount of activity interference produced in different situations are given
for trucks regulated at different levels.
A-3-3
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In all of the revised predictions, relations between regulatory levels and typical truck
passby levels were developed using published truck noise measurement data, where avail-
able. The typical truck passby noise levels, individually or in averages with passby levels
from other vehicles, were compared to levels specified by EPA as necessary to protect pub-
lie health and welfare. Therefore, relations between regulated truck noise levels and levels
necessary to protect public health and welfare have been developed.
The effects of the Interstate Motor Carrier regulations and the elimination of the more
noisy vehicles were included in revising the estimates of the benefits to public health and
welfare. Truck tire noise levels were also considered.
Sophisticated modeling techniques are not available to accurately represent all possible
situations where people are impacted by noise. Even if such techniques were available,
employment in all possible situations would result in an overwhelming amount of data for
analyses. Therefore, simple modeling techniques representing typical scenarios were em-
ployed by EPA. These techniques are believed to be adequate for use, by EPA, in justi-
fying the selection of the final regulatory levels on a nationwide basis.
Action in Response to Public Comment: Some of the public comments were employed for
improving estimates of the benefits to the public health and welfare of new medium and
heavy truck noise emission regulations. The revised estimates are sufficient for use in sup-
porting the selection of the final regulatory levels. Additional studies have not been
conducted.
A-3.2.2 Accuracy of EPA Predictions
Identificatiofl. The Ford Motor Company (A-2.l.3) and N.O.LS.E. (A-2.5.l7.l) commented
that the truck population growth rates used in the EPA predictions of benefits to the pub-
lic welfare are too high. According to the Chamber of Commerce (A-2.6.4.l), the EPA
estimate of 70 million people affected by traffic noise is too high. The number should be
around 3 to 6 million. Koehring Company (A-2.2.4.l) implied that, since there will be no
benefits from the new truck regulationS the EPA predictions are incorrect. The State of
Illinois (A-2.5. 9 . 2 ) commented that the 75 dBA regulated truck will not be as quiet as a
typical automobile as indicated by EPA, but will be about 10 dBA noisier.
General Motors (A-2.l.5.l) and the Department of Transportation (A-2.5.4.3) both
presented predictions of the reductions in average noise levels in urban street and freeway
traffic for the different regulatory programs. Estimates of the annoyances produced by the
noise from indlvklual passbys of truck regulated at different levels were also given by
General Motors (42.5.1.2).
A-3-4
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Discussion: Changes in the traffic noise levels, due to different future growth rates of
trucks, will effect all of the estimates of average traffic noise reductions for the different
regulatory programs on new truck nearly equally, as long as the traffic mix of trucks and
other vehicles remains constant, as assumed by EPA in estimating benefits, In other words,
comparison of the traffic noise reductions estimated by EPA for different regulatory pro-
grams are not sensitive to the assumed truck population growth rate. In addition, the future
population growth rates of traffic vehicles cannot be accurately predicted. For these reasons,
EPA used a zero population growth rate in reviewing the estimates of traffic noise reduc-
tions. By assuming a zero growth rate, the EPA estimates of reductions in the equivalent
number of people impacted ( 1 eq) will be lower (i.e., more conversative) than estimates made
by assuming a positive growth rate.
The number of people exposed to an outdoor noise level with an Ldn greater than 55
dBA where the dominant source of noise is urban street traffic is given by EPA as 93.4
million people [ 3]. The Ldn = 55 dB has been identified by EPA as the outdoor noise
level requisite to protect the public from interference with outdoor activities and general
annoyance [ 1]. Therefore, the estimate of 3 to 6 million people affected by traffic noise,
particularly urban street traffic, referenced by the Chamber of Commerce appears to be
quite low.
In all of the estimates of benefits given by EPA, General Motors and the Department
of Transportation, definite reductions in the average traffic noise levels and the number of
people impacted by traffic noise are indicated. Therefore, the comment by the Koehring
Company that no benefits will accrue by regulating truck noise emissions is incorrect.
Typical roadside noise level for a 75 dBA regulated truck will be approximately 71 dBA
cruising at 27mph and 81 dBA, as measured at 50 ft. [ 2]. Noise emissions for existing
automobiles are 65 dBA and 75 dBA, respectively as measured at the same distance [ 2].
Therefore, the 75 dBA regulated truck will be noisier than existing automobiles, as indicated
by the State of Illinois. However, it will be noisier by about only 6 dBA.
For two regulatory programs, the predictions of reductions in the average traffic noise
given by General Motors and the Department of Transportation are compared to the EPA
predictions in Figure A-3. 1 for urban street traffic and in Figure A-3 .2 for freeway traffic.
In all predictions, the effect of reductions in non-truck vehicle noise levels of about 4 dBA
and the Interstate Motor Carrier Regulations are included. DOT and EPA assumed that all
trucks will be equipped with only ribbed tires in making the predictions given in Figures
A-3.l and A-3.2. GM assumed a reduction in tire noise of about 3.5 dBA from 1975 to
1993. In order to make comparisons, the curves in Figures A-3.l and A-3.2 for the GM
predictions are plots of the differences in the curves given by GM with and without noise
emission regulations.
A-3-5
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Figure A-3. 1. Comparison of EPA, GM, and DOT Estimates of Average Urban
Street Traffic Noise Reductions Due to New Truck Regulations
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Table A-3.2. Comparison of EPA, GM, and DOT Estimates of Avenge
Freeway Traffic Noise Reductions Due to New Truck Regulations
The DOT and GM estimates of reductions in the average urban street traffic noise are
higher than the EPA estimates, with the estimates from GM the most optimistic. EPA in-
cluded the effects of noise from buses and motorcycles in their estimates of the noise reduc-
tions. GM and DOT did not consider these vehicles in their model. This partially ex-
plains the higher estimated benefits predicted by GM and DOT. Because buses and motor-
cycles are noisier than automobiles, they tend to limit the potential reductions in urban
street traffic noise levels afforded by regulations on new medium and heavy trucks. Com-
parison of estimates from EPA with those from DOT and GM clearly indicate the necessity
of future noise emission regulations on buses and motorcycles.
CALENDAR YEAR
A-3-7
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The DOT and EPA estimates of the reductions in average freeway traffic noise levels are
nearly identical. The estimates of benefits from GM are higher than the DOT and EPA pi-e-
dictions. A partial explanation for this may be the assumed lower truck tire noise emission
levels used by GM. GM assumed a tire noise emission level of 78.5 dBA for 1981 and subse-
quent years, while EPA used a level of 81 dBA for 1977 and subsequent years.
In assessing the benefits to public health and welfare, EPA used the predictions of reduc-
tions in average traffic noise levels to estimate the changes in the extensiveness and severity
of impact for several regulatory programs. The is a better indicator of the benefits to
public welfare since it takes into account the number of people who benefit from traffic
noise reductions and the extent to which they are benefited (See Section 4). Therefore, the
selection of the final regulatory levels should be based more on the estimates of eq than on
decibel reductions in the average traffic noise levels.
EPA and GM have estimated the maximum distances from individual truck passbys at
which disruption of various activity occurs in different situations. Comparisons of these
estimates are shown in Figures A-3.3 through A-3.6. The estimates from GM are lower than
those from EPA for the following reasons:
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Figure A-3.3. Comparison of EPA and GM Predictions of Maximum
Activity-Interference Distances for Thought Process Indoors
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150 -
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PERCENTILE TRUCK NOiSE LEVELS
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A— A 83d9A AND 75dBA TRUCKS
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A-3-8
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PERCENTILE TRUCK NOISE LEVELS
Figure A-3.4. Comparison of EPA and GM Predictions of Maximum
Activity-Interference Distances for Sleeping Indoors
• EPA used noise levels for accelerating trucks while GM conservatively used levels
for trucks at constant speed, and
• The noise reduction factors assumed by GM for indoor situations are much higher
than those used in revised EPA estimates.
The noise levels from accelerating trucks are higher than the levels from cruising trucks.
Therefore, accelerating trucks are capable of producing greater activity interference than
trucks cruising at constant speed.
EPA — “SLEEPING—INDOORS-WINDOWS
CLOSED”
o— o EXISTING TRUCKS
83dBATRUCKS
—_ 75dBATRUCKS
0
/
GENERAL MOTORS — “FRAME HOUSE
INTERIOR ASLEEp”
-o EXISTINGTRUCKS
A-—— ———a 83dBA TRUCKS
____ . 75dBATRUCKS
,0
___ I
A-3-9
-------
LU
C )
z
I-
C l )
a
LU
c i
z _________
‘U
LU _________
U.
LU
I-
2
>
0
)<
Figure A-3.5. Comparison of EPA and GM Predictions of Maximum
Activity-Interference Distances for Normal Conversation Outdoors
GM used noise reduction factors of 35 to 29 dBA taken from data given in the first back-
ground document on the new truck regulations. A.noise reduction factor of 25 dBA was also
given in the first background document as an approximate national average for houses with
windows closed. This factor appears more reasonable and was therefore incorporated in the
revised estimates of activity interference.
Action in Response to Public Comments: EPA estimates of the benefits to the public we!-
fare have been revised. The selection of the final regulatory levels is based more on the esti-
mates of the reduction in the extensiveness and magnitude of annoyance and activity inter-
ference as measured by eq and maximum annoyance distances, than on estimates of the
EPA — “NORMAL CONVERSATION—OUTDOORS”
o - -o EXISTING TRUCKS
— ‘a 83dBATRUCKS
C 75dBATRUCKS
GM — “OUTDOOR RESIDENTIAL
NORMAL CONVERSATION”
o———-—--o EXISTING TRUCKS
t . .-———— S3dBATRUCKS
———-—--a 75dBATRUCKS
PERCENTILE TRUCK NOISE LEVELS
A-3- 10
-------
2800
2800
w
0
z
I-
UJ
0
w
L i i
Li.
LU
I-
)
I-
>
I-
0
x
1200
1200
800
400
L 10 L 01
PERCENTILE TRUCK NOISE LEVELS
Figure A-3.6. Comparison of EPA and GM Predictions of Maximum
Activity-Interference Distances for Thought Process Outdoors
changes in the traffic noise levels. EPA estimates of the benefits to public health and welfare
are believed to be more than sufficient to support the selection of the final regulatory levels.
A-3.2.3 Needed Benefits
Identification.’ The State of Illinois (A-2.5.9.l) commented that a 75-dBA regulation is
needed to reduce intrusions from noise emissions from trucks. According to the State of
New Mexico (A-2.5. 15.1), the new truck regulations should be similar to the 70 dBA L 10
Federal Highway Administration standard for residential, hospital and school areas.
2400
1600
2400
2000
EPA — “THOUGHT PROCESS—OUTDOORS”
o- - —o EXISTING TRUCKS
83dBATRUCKS•
0— —C 75dBATRUCKS
800
1600
GENERAL MOTORS — FRAME HOUSE
INTERIOR ASLEEp”
EXISTING TRUCKS
——— --_ 83dBA TRUCKS
D—-——--—-c 75dBA TRUCKS
L 1
A-3-1 1
-------
Discussion: Estimates of annoyance or intrusion from truck noise emissions demonstrate
that regulating trucks to a level of 75 dBA will not assure that people won’t still be an-
noyed with truck noise or that all activity disruption will be removed. In order to remove
all annoyance and activity disruptions caused by trucks, regulatory levels below 75 dBA
would be required. However, other considerations preclude lowering the regulatory levels
below 75 dBA at this time. For example, technology has not been demonstrated that will
reduce truck noise levels low enough to comply with not-to-exceed regulatory levels below
75 c IBA.
Action in Response to Futile Comments: No further action has been taken.
A-3.2.4 Benefits from More Lenient Regulations
Identification: Ford Motor Co. (A-2. 1.3.4) claimed that substantially all of the intended noise
reductions will result if 10 percent of the tested vehicles are allowed to exceed the regulation
level by 2 cIBA. According to Mack Trucks (A-2.l.7.2) drastic reductions in traffic noise
levels will result from the 83-dBA regulation. Donaldson Company (A-2.2.2.2) commented
that the greatest annoyance comes from a small minority of the noisiest trucks which will be
controlled by the interstate Motor Carriers Regulations.
General Motors Corporation asserted that the overwhelming amount of the benefits to
be derived from noise emission regulations on trucks will come from the combination of the
enforcement of the Interstate Motor Carriers Regulations and the 83-dBA regulation on new
trucks. In support of this assertion, General Motors presented the following data.
1. Predictions of the average, noise reductions from urban street and freeway traffic
for five regulatory programs (A-2. 1.5.1);
2. Predictions of the maximum intrusion distances for different activity/location sit-
uations for single passbys of existing trucks and trucks regulated at 83, 80, and
75 dBA (A-2.1.5.2);
3. Predictions of the distances at which the noise from an unregulated truck and a
truck regulated at 83 cIBA will be equal to and 10 dBA greater than the noise
from a continuous line of freely-flowing traffic at 55 mph (A-2. 1.5.3);
4. !ttthctions of the differences in typical low speed roadside levels for unregu-
lated trucks and trucks regulated at 83 dBA (A-2.1.5.4); and
A-3-12
-------
5. Comparison of SAE J366b measured levels and levels measured under different
typical operating conditions for the same trucks (A-2.l.5.5).
Discussion: Predictions of reductions in the average noise levels for urban street traffic are
given in Figure A-3.7 for the regulations proposed by EPA with nearly all trucks measured
at levels below the regulated levels (nearly 100 percent compliance) and with 10 percent of
the trucks allowed to exceed the regulatory level (90 percent compliance) as suggested by
Ford Motor Company. Shown in Figure A-3.8 are predictions of the equivalent number of
people impacted 0 eq computed using the reductions in traffic noise levels given in Figure
A-3.7. These predictions were computed following procedures given in Reference 2 and
Section 4. Using a standard deviation of 0.5 c IBA for the tested truck levels and a 1.0 dBA
factor to account for measurement instrumentation and site variations, the median tested
level was assumed to be 1 .5 c IBA below the regulatory levels for 90 percent compliance and
2.5 cIBA for nearly 100 percent compliance.
4.0
5.0
6.0
7.0
CALENDAR YEAR
Figure A-3.7. Predictions of Average Traffic Noise Reductions for 100 Percent
and 90 Percent Compliance to the EPA Proposed Regulations
EPA PROPOSED REGULATIONS WITH NEARLY 100% COMPLIANCE
— — — EPA PROPOSED REGULATIONS WITH 90% COMPLIANCE
PREDICTIONS INCLUDP EFFECTS OF INTERSTATE
MOTOR CARRIERS REGULATIONS AND 4 dBA REDUCTION IN
NOISE LEVELS OP NON-TRUCK VEHICLES
0.0
LU
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—j 1.0
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0
z
2.0
U.
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r 3.0
I - .
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a
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0
t
0
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A-3-13
-------
0
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0.
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0.
0
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D
2
I -
2
10.0
Figure A-3.8. Predictions of eq for 100 Percent and 90 Percent Compliance to the
EPA Proposed Regulations
Observation of the predictions in Figures A-3.7 and A-3.8 confirm the comments made
by Ford Motor Company that only small losses in the benefits would result if 10 percent of
the trucks are allowed to exceed the regulated level of 2 dBA. However, there is a provision
in the selective enforcement auditing in the proposed regulations that allows 6.8 percent of
the sampled vehicles to exceed the regulated level (Section 205.57-3(b) of Federal Register
Volume 39, No 210, Part 11, p. 38358). Changing this to 10 percent of the sampled vehicles
is under consideration by EPA.
Comparison of the revised EPA predictions of the noise reductions for urban street
traffic [ 2] are given in Figure A-3.9 with (1) no regulations on new trucks, (2) an 83-dBA
regulation in 1977, and (3) the regulations proposed by EPA. All predictions include the
benefits of the Interstate Motor Carrier Regulations as well as a 4-dBA reduction in non-
truck vehicle noise levels. These predictions do not substantiate the comment from the
Donaldson Company that the Interstate Motor Carrier Regulations will eliminate most an-
noyance from truck noise by removing the noisiest of the existing trucks. (Results in Fig-
ures A-3.3 through A-3.6 also fail to confirm the comment made by Donaldson.) The claim
that most of the reduction in traffic noise will result from the 83-dBA regulation made by
EPA PROPOSED REGtJLATIpNS WITH NEARLY 100% COMPLIANCE
— — — — EPA PROPOSED REGULATIONS WITH 90% COMPLIANCE
PREDICTIONS INCLUDE EFFECTS OF INTERSTATE
MOTOR CARRIERS REGULATIONS AND 4dM REDUCTION
IN NOISE LEVELS OF NON.TRUCI( VEHICLES
CALENDAR YEAR
A-3-14
-------
INTERSTATE MOTOR CARRIER REGULATIONS ONLY
— — — INTERSTATE MOTOR CARRIER AND 83 dBA REGULATIONS
— . — INTERSTATE MOTOR CARRIER AND EPA PROPOSED REGULATIONS
ALL PREDICTIONS INCLUDE 4 dBA REDUCTION IN
NON-TRUCK VEhICLE NOISE
ao - ao
7_0 — 7.0
I I I I Ii
1977 1981 1983 1985 1990 2000
CALENDAR YEAR
Figure A-3 .9. Predictions of Average Traffic Noise Reductions with Regulations
on New Medium and Heavy Trucks
General Motors Corporation and Mack Truck Inc. is also contrary to results given in Figure
A-3.9. Figure A-3. 10 shows that appreciable benefits in terms of reductions in population
impacted will be derived by regulating new medium and heavy trucks to levels below 83 dRA.
The estimates of the avenge noise reductions for urban street and freeway traffic fur-
nished by General Motors are higher than the estimates given by EPA. (See Figures A-3. 1
and A-3.2.) Emphasis will be placed in this discussion on the estimates for urban street
traffic, since tire noise will dominate in freeway traffic and tire noise is not addressed in the
proposed regulations. For urban street traffic noise, the differences between the EPA esti-
mates in noise levels for the proposed regulations and the 83-dBA regulation are nearly equi-
valent to the corresponding differences in the GM estimates. However, because the overall
reductions estimated by GM are larger than the EPA estimates, it visually appears that more
benefits will be derived from the 83-dBA regulation. Although EPA and GM use similar
methods and traffic population figures, differences in the EPA and GM estimates may be
attributed primarily to differences in the equivalent noise levels assumed by EPA and GM
A-3-1 5
-------
w
‘U
-J
0.
0
‘U
0
U.
0
‘U
z
I-
z
‘U
for each type of vehicle. The noise emission levels by vehicle type which were assumed by
EPA and GM are tabulated in Table A-3. 1. The following may be observed.
1. In the revised predictions of benefits, EPA considered the effect of motorcycles
and buses. Since motorcycles and buses are in general noisier than automobiles,
adding these sources will raise the overall traffic noise levels which, in turn, will
increase the masking of benefits derived from regulating new medium and heavy
trucks. Considering the noise from motorcycles and buses in the environmental
will both provide a better representation of existing conditions and improve the
accuracy of the anticipated traffic noise reductions.
2. The reductions in vehicle noise levels furnished by GM for regulated vehicles
(12.7 dBA for trucks and 6.5 dBA for automobiles) are higher than these re-
ductions in noise emissions given by EPA (9.7 dBA for trucks and 5.1 dBA for
automobiles). The principal reason for these differences is that the noise emission
levels from existing trucks and automobiles furnished by GM are about 5 dBA
higher than the levels used by EPA. Based upon an EPA survey of truck noise
emission levels [ 141. Different levels were used by EPA for medium and heavy
trucks. The equivalent noise levels used by GM for medium and heavy trucks is
INTERSTATE MOTOR CARRIER REGULATIONS ONLY
— — —INTERSTATE MOTOR CARRIER REGULATIONS AND 83 dBA REGULATIONS
— - —INTERSTATE MOTOR CARRIER REGULATIONS AND EPA PROPOSED REGULATIONS
ALL PREDICTIONS INCLUDE 4 dBA REDUCTION IN
NON-TRUCK VEHICLE NOISE
CALENDAR YEAR
Figure A-3. 10. Predictions of P with Regulations on
New Medium and Heavy Trucks
A-3-1 6
-------
Table A-3.l
Average Noise Levels Used in EPA and GM Estimates of
Noise Reductions in Urban Street Traffic
Urban Street Traffic
Average Noise Level
Total Population Mix
EPA
GM
EPA
GM
Trucks:
(dBA)
(dBA)
7.0%
7.0%
Existing
Interstate Motor Carrier
83 dBA New Truck Regulation
80 dBA New Truck Regulation
75 dBA New Truck Regulation
81.0*
79.6*
77.6
75.1
71.3
86.0
84.7
78.5
75,8
73.3
Automobiles and Light Trucks:
9 1.5%
93.0%
Untreated
Treated
66.6
61.5
70.5
63.5
Buses:
0.5%
0.0%
Untreated
Treated
80.6
75.5
—
—
Motorcycles:
1.0%
0.0%
Untreated
Treated
83.6
78.5
—
—
Represent weighted averages of the levels for medium and heavy trucks
nearly equal to the level used by EPA for heavy trucks (86.6 dBA). Considering
medium and heavy trucks separately, as done by EPA, yields a more accurate re-
presentation of real traffic situations since most medium trucks are powered by
gasoline engines, and therefore are quieter than most heavy trucks, many of
which are diesel-powered. The noise emission level for existing light vehicles used
by GM is based upon results from one survey taken in California [ 5]. On the
other hand, the median level used by EPA for light vehicles in urban street traffic
is based on results from the same survey plus results from five other surveys [ 2].
Hence, the levels used by EPA are believed to b more accurate.
In view of the above, it appears that the projections of anticipated reductions in average
traffic noise levels given by EPA are more accurate than those of GM. In addition, the higher
A-3-17
-------
estimates given by GM tend to diminish the relative magnitude of the additional benefits to
be derived from regulating trucks at levels below 83 dBA.
Reductions in the average traffic noise levels do not adequately measure the benefits to
the public welfare. A more useful measure of the benefits is the reduction in equivalent num-
ber of people impacted ( eq )• This is because the eq considers both the number of people
exposed to traffic noise and the magnitude or severity of individual impact. For this reason,
more emphasis should be placed °“ eq as a measure of benefits than on the average traffic
noise reduction.
According to predictions of the eq given by EPA (See Section 4), the difference
between the total for the regulation proposed by GM (83 dBA in 1977) and for the
regulations proposed by EPA is 6.8 million in 1990 for people exposed to urban street or
freeway traffic. Greater differences will occur if the reductions in non-truck vehicle noise
levels are higher than 4 dBA. Based upon these estimates, it appears that the overwhelming
amount of the benefits will not be derived from the combination of the 83-dBA regulation
and the Interstate Motor Carrier Regulations.
General Motors also predicted the maximum distances to which noise from single truck
passbys will intrude on people engaged in a given activity. Some of the GM predictions are
shown in Figures A-3.3 through A-3.6 along with EPA estimates of maximum intrusion dis-
tances for the same activity and location. Both sets of predictions indicate that the reduc-
tions in intrusion with decreases in regulatory levels diminish for levels below 83 dBA. Ob-
servation of the levels for unregulated and regulated trucks given in Table A-3.2 show that
the largest reduction in typical roadside noise levels will occur for the 83 dBA regulation,
which implies that the greatest reduction in intrusion will result from the 83 cIBA regulation.
Table A-3.2
SAE J366b Truck Noise Levels
Truck Comparisons
Percentile Levels
Median
(dBA)
Upper 10
(dBA)_
Upper 1
(dBA)
Upper 0.1
(dBA)
Existing truck fleet (GM)
Existing flew trucks (EPA)
Trucks regulated at 83 dBA (GM)
Trucks regulated at 75 dBA (GM)
87.6
84.7
80.5
72.5
92.3
87.6
81.8
73.8
96.2
89.7
82.2
74.8
98.9
91.6
83.6
75.6
A-3- 18
-------
• However, the statutory mandate given to EPA in the Noise Control Act is to promul-
gate regulations which are requisite to protect the public health and welfare. The statutory
mandate is not to set regulatory levels at a point beyond which the rate of return in bene-
fits begins to decrease. The result in Figures A-3.3 through A-3 ,6, particularly those given
by EPA, indicate that the public welfare would not be totally protected if the regulations
stopped at 83 cIBA. Ideally, the regulatory level would be below 75 dBA if all intrusion
factors attributed to truck noise are to be completely removed. However, taking into ac-
count the degree of noise reduction achievable through the application of the best avail-
able technology and the costs of compliance, as required in the Noise Control Act, may
preclude setting the regulatory levels below 75 c IBA.
As additional support to the claim that the 83-dBA regulation will result in most of the
needed benefits, GM predicted that, in 55 mph traffic, the noise from a single truck regu-
lated at 83 dBA is usually less than 10 dBA above the noise from a steady stream of light
vehicles at distances greater than 70 feet. In making these predictions, the median level used
by GM for trucks regulated at 83 dBA was 82.0 dBA, which is similar to the level of 82.3
dBA used by EPA in assessing the benefits to public welfare. Both EPA and GM assumed
that the passby noise levels for 83 dBA trucks had a Gaussian distribution with a standard
deviation of 2.0 dBA. Therefore, the predictions by GM appear reasonable. However, addi-
tional benefits will be realized in other situations, such as exposure to low speed traffic
noise where engine-related noise usually dominates over tire noise. Tire noise is not encom-
passed by the proposed regulations.
GM presented the estimates of SAE J366b truck noise levels for existing trucks and
truclth regulated at 83 dBA. These levels are given in Table A-3.2. GM concluded that the
83-dBA regulation will result in large reductions of ]ow speed traffic noise. However, since
the proposed regulations apply only to new trucks, comparison of tested levels of new
trucks should be made in assessing the impact of the 83-dBA regulation. The estimated
levels for existing new trucks given in Table A-3.2 are derived from data taken from reference
levels for existing new trucks given in Table A-3.2 are derived from data taken from reference 6.
level for new trucks by 4.2 c IBA, instead of 7.1 c IBA as implied by GM. The tested levels from
the noisiest new trucks will be reduced by 7.3 cIBA, instead of 15.3 dBA. In addition, GM
failed to consider the tested noise levels from new trucks regulated at 75 dBA shown in Table
A-3.2. These levels are derived using the same assumptions used by GM in deriving the levels
for 83-dBA regulated trucks. An additional reduction in the tested levels of 8 dBA should
occur for trucks regulated at 75 cIBA, from which added benefits should result as previously
discussed.
A-3- 19
-------
In final support of their position, a film was presented by GM in the public hearings in
Washington, D. C. In this film, the measured levels given in Table A-3.3 were presented. Ac-
cording to GM, the small differences between noise levels corresponding to the 83-dBA and
80—dBA regulated trucks is expected at 55 mph. Data taken from reference 17! , corrected
Table A-3.3
Noise Levels Recorded on GM Truck Noise Film
Regulated
Limit
SAE J366b
Standard
Passby
Microphone
at 50 feet
Urban
Acceleration
Microphone at
125 feet
35 mph
Cruise
Microphone at
125 feet
55 mph
Cruise
Microphone at
150 feet
86 dBA
83 dBA
80 dBA
85.2 c IBA
80.5 dBA
78.2 dIM
76.8 dBA
72.5 cIBA
72.0 cIBA
79.3 cIBA
75.3 cIBA
73.7 dIM
77.5 cIBA —
75.5 cIBA
75.2 cIBA
for differences in observation distances, show that noise from ribbed tires at 150 feet could
be as high as 75 dBA. The levels for the 83 cIBA and 80-dBA regulated trucks cruising at 35
mph show a difference comparable to the difference in the tested levels. However, the dif-
ference in levels for the 83 dBA and 80-dBA regulated trucks for urban acceleration at 125
feet is only 0.5 cIBA. This small difference is probably because of the high background
noise level that existed during the measurements. In other typical low-speed acceleration
situations where the background noise level would be lower, greater differences would proba-
bly occur.
In addition, it should be noted that the 86-dBA regulated truck measured 0.8 dBA be-
low the regulated limit whereas the 83- and 80-dBA regulated trucks measured 2.5 and 1.8
dBA below the limit. Therefore, the differences between the roadside levels for the 86- and
83-dBA regulated trucks are higher than the differences between the roadside levels for the
83- and 80-cIBA regulated trucks.
Action in Response to Public Comment: The estimates of the benefits presented by EPA in-
dicate that appreciable benefits will be derived from regulating new medium and heavy
trucks at levels lower than 83 dBA and considerations of the benefits to the public health
and welfare alone do not justify relaxing the proposed regulations.
A-3-20
-------
A-3.3 IMPACT OF OTHER TRAFFIC NOISE SOURCES
A-3.3.1 Mobile Homes
IdentiJIcation. The Recreation Vehicle Industry Association (A-2.6.8. 1) commented
that since motor homes are substantially quieter than medium and heavy trucks, they are not
a major source of noise and, therefore, should be exempted from the proposed regulations.
Discussion: The 1975 production of Type A motor homes, most of which fall into the classes
over 10,000 lbs gross vehicle weight reading, is approximately 30,000, according to the Re-
creation Vehicle Industry Association. The estimated production of medium gasoline trucks
given by EPA is 202,000 [ 8]. This indicates that about 15 percent of the new medium
gasoline trucks produced in 1975 are mobile homes. However, mobile homes are driven
fewer miles on the average than other medium and heavy trucks, so that less exposure to
noise from mobile homes may exist.
The Recreation Vehicle Industry Association also commented that mobile home manu-
facturers normally do not alter the engine, power train, or exhaust systems. Since these are
the major sources of noise, it is unlikely that motor homes are substantially quieter than
medium gasoline trucks.
Action in Response to Public Comment: It has not been shown that exempting motor
homes from the proposed regulations will not significantly reduce benefits. The Agency
has not exempted motor homes from the regulations.
A-3.3.2 Truck Tires
Identification. Freightliner (A-2.1.4.1), International Harvester (A-2.l.6.l), Mack Truck
(A-2.l.7.4), White Motor (A-2.l.lO.2), and Donaldson (A-2.2.2.3) commented that the bene-
fits for regulating trucks to levels below 83 dBA will be small, since at high speeds, uncon-
trolled tire noise will dominate engine-related noises that will be controlled by the regula-
tions. The benefits will be small, according to Freightliner and White Motor, because
heavy linehaul trucks typically are operated at speeds over 35 mph. Freightliner com-
mented that typical tire noise from a loaded tractor and trailer with half-worn tires is
about 84 dBA at 55 mph. Donaldson Company claimed that at highway speeds, truck tire
noise frequently exceeds 80 dBA at 50 feet. The American Trucking Associations (A-2.3. 1.1)
commented that tire noise will reduce the benefits to be derived from the proposed regula-
tions. The Ford Motor Company (A-2. 1.3.2) and the Department of Transportation
A-3-21
-------
(A-2.5.4.2) suggested that the contributions from truck tires should be identified separately
in assessing benefits. DOT presented estimates of reduction in freeway traffic noise with all
trucks equipped with crossbar tires on the drive wheels and with all trucks equipped with
only ribbed tires. The Donaldson Company (A-2.2.2.3) and Schwitzer (A-2.2.6. 1) claimed
that since tire noise cannot be reduced below 80 dBA, regulations below 80 dBA will be in-
effective. The Department of Transportation (A-2.5.4.l), Minnesota (A-2.5. 14.2) and New
York State (A-2.5.l 6.1) suggested that regulations on truck tires be considered. DOT re-
commended that regulations on tire noise of 83 dBA in 1977, and 80 dBA in 1981, for a
50 mph coast-by be adopted concurrently with the proposed new truck regulations. The
National Organization to Insure Sound Control Environment (A-2.5. 17.2) suggested that the
regulations be enforced at speeds up to 50 mph, since tire noise is not a dominant factor at
speeds below 50 mph.
Discussion: The impact of high speed (freeway) traffic noise should be less than the impact
of low speed (urban street) traffic noise for the following reasons [ 2].
1. The number of people exposed to outdoor noise from freeway traffic is less than
the number of people exposed to outdoor noise from urban street traffic. EPA
estimates that 59.0 million people are exposed to outdoor noise from urban
street traffic noise with a day-night equivalent noise level (Ldfl) greater than 60
dBA, whereas 3.1 million people are exposed to similar noise levels from freeway
traffic [ 31.
2. The reductions in freeway traffic noise levels will be less than the reductions in
urban street traffic noise because of the contributions made by truck tire noise
in freeway traffic.
In response to comments made by DOT, the truck tire noise level used by EPA for
predicting the overall noise levels for new regulated trucks has been revised from 77 dBA to
81 dBA [ 2]. This level corresponds to the peak level observed at 50 feet for a single unit
(2-axle) loaded truck passby at 55 mph with half-worn ribbed tires [ 7]. Some trucks, such
as those with more than two axles, will generate higher tire noise levels; whereas in other
trucks (those unloaded and equipped with new tires), the levels will be lower. The 81 -dBA tire
noise level is in agreement with comments made by the Donaldson Company that tire noise
levels above 80 dBA are frequently encountered. The tire noise level of 84 dBA, given by
Freightliner is for existing trucks which may often be equipped with crossbar tires. The
noise levels for individual existing trucks used in estimating benefits were based on survey
data where tire noise was not identified separately.
A-3-22
-------
The effects of noise from truck tires on the reductions in traffic noise can be separately
identified by comparing the estimates of the noise reductions for urban street and freeway
traffic. The differences can be attributed largely to contributions made by tire noise.
Because most of the benefits from the proposed regulations will result from reductions
in low speed traffic noise, the regulations should not be delayed until more information is
available on quieting tires. Quieting truck tires will have a significant effect only on the re-
ductions in high speed traffic noise. EPA is engaged in the development and acquisition of
information to support future regulatory action on truck tires [ 9].
The noise from a ribbed tire increases from levels of approximately 66 dBA when un-
loaded at 35 mph to about 72 dBA at 50 mph [ 7]. This increase is enough to become a
significant factor in complying with a 75-dBA or lower regulation, if the regulations were
enforced at speeds up to 50 mph. For crossbar tires, the noise levels would be higher;
therefore, the National Organization to Insure Sound Control Environment is incorrect
in commenting that tires would not become a factor if the maximum enforcement speed
is increased from 35 to 50 mph.
Action in Response to Public Comment: The estimates of benefits from reductions in free-
way traffic noise have been revised to include the higher noise level of 81 dBA for truck
tires. However, a fact that larger benefits will result from the reduction in urban street traffic
noise is emphasized.
A-3.3.3 Buses
IdentifIcation: The Department of Transportation (A-2.5.4.2), New York State (A-2.5.16.2),
and San Diego County (A-2.5.18.l) commented that buses should be included in the new
truck regulations. DOT added that buses are usually operated in densely populated areas and
are frequently accelerating so that they generate higher levels than assumed by EPA (73 dBA
at 50 feet). Los Angeles County (A-2.5. 12.1) suggested that an effort to regulate noise from
buses be initiated.
Discussion: Information is currently being gathered by EPA on buses for possible future
regulatory action. A typical roadside level of 79 dBA at 50 feet from existing buses was used
by EPA in estimating the be nefits for the regulations on new trucks [ 21. This level is 2 dBA
higher than the levels used by EPA for medium trucks and supports the comments made by
DOT.
#3-23
-------
Action in Response to Public Comment: No further action has been taken.
A-3.4 Environmental Impact Statement
Identification: The Federal Highway Administration (A-2.5.8.1) commented that an Envir-
onmental Impact Statement is required.
Discussion: Environmental Impact Statements are required on all regulatory actions pro-
posed after 15 October 1974. Since the proposed regulations were submitted to the Admin-
istrator for publication before October 15, 1974, an Environmental Impact Statement is not
required for the noise emission regulations on new medium and heavy trucks. It should be
noted that most of the information contained in Environmental Impact Statements has been
gathered and reported by EPA in this document.
Action in Response to Public Comment: A separate Environmental Impact Statement has
not been prepared.
A-3-24
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Appendix A-4
TECHNOLOGY
A-4.1 ACCURACY OF COMPONENT SOURCE LEVELS
A-4. 1.1 Fan Noise
Identifi cation: The Cummins Engine Company (A-2.2. 1.3) suggested that the noise of 63
fans tested in 1973 averaged 83.3 dBA and 25 fans tested in 1974 averaged 82.1 dBA. Simi-
larly, the Department of Transportation (A-2.5.4.7) questioned the validity of the statement
in the preamble by stating, ‘ In contrast (to the statement in the preamble) we suggest that
many cooling systems generate noise levels in excess of 80 dBA...” DOT supported this state-
ment with the DOT Quiet Truck Program baseline data on three fans which ranged from 83
to 86 dBA.
Discussion: The question of whether most fans generate more noise than 80 dBA cannot be
confidently resolved on the basis of the above data base. The Cummins and DOT data may
not be drawn from a base which is representative of the medium and heavy truck population.
Cummins manufactures only engines for diesel trucks constituting about one third of the
medium and heavy truck population. Similarly all of the three trucks identified by DOT are
class 8 cab-over-engine linehaul tractors.
- Data in Figures 5-3, 5-4 of reference 8, show that 13 out of 21 samples were below 80
dBA.
Action in Response to Public Comment: The sentence in question in the preamble has
been deleted.
A-4.1.2 HRBDG Levels
Identification: International Harvester (A-2.l .6.9) and the Department of Transportation
(A-2.5.4.13) Commented that the truck component source levels for 55-65 mph cruising
conditions taken from the Highway Research Board Design Guide (HRBDG), and used in
the EPA analysis of the benefits to public welfare [ 81 are higher than the SAE J366b
levels. Since the SAE J366b levels for the engine-related noises should be higher than the
engine-related noise levels under cruise conditions, the levels used by EPA may be incorrect.
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Discussion: The comments are correct, there appears to be a discrepancy in the Highway
Research Board Design Levels. In revising the estimates of the benefits to be derived from
the reduction in freeway traffic, the levels in the HRBDG were not used.
Action in Response to Public Comment: The levels given in Table 2 of Vol. 5 of the High-
way Research Board Design Guide are no longer used by EPA.
A-4.1.3 Engine Noise
Identification: The Cummins Engine Company (A-2.2.l .2) commented that engine noise
depends on engine power as well as engine type and design.
Discussion: Data on the engine noise levels of 35 diesel engines show little dependence of
noise level on engine power [ 61.
Action in Response to Public Comment: Since this issue has little impact on the technology
required to comply with the proposed regulations, no further action has been taken.
A-4.2 EFFECTIVENESS OF NOISE CONTROL TREATMENTS
A-4.2.1 Engine Quiet Kits
Identification: The Freightliner Corporation (A-2. 1.4.2) commented that engine quieting
kits reduce diesel engine noise by only about 2 dBA, not up to 4 dBA as claimed by EPA.
Discussion: Investigations of diesel engine noise reduction have shown that it is technically
feasible to achieve reductions up to 9 dBA without the use of noise bathers mounted to the
truck cable structure [ 10]. Most of the reduction appeared to be due to the use of covers
and isolating components. Hardware, such as parts for the isolation of diesel components
and shields mounted to the engine, has been developed and put into production for three
diesel engine models which achieve noise reductions of up to 6 dBA [ 11]. Therefore,
quieting kits are available which quiet diesel engines by more than the 2dBA cited by
Freightliner Corporation.
Action in Response to Public Comment: No further action has been taken.
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A-4.2.2 Radiator Shutters
Identification: The Department of Transportation (A-2.5.4.4) commented that cooling sys-
tem radiator shutters should not be considered noise reduction equipment as indicated by
EPA in the preamble to the proposed regulations [ 91.
Discussion: Data on the cooling system noise levels for the International Harvester DOT
Quiet Truck with shutters—open and closed—indicate that when shutters are closed, the cool-
ing system noise level is on the average more than 3 dBA higher [ 12]. When the shutters are
closed, the fan stalls which increases the noise output. Therefore, radiator shutters are not
noise abatement equipment, and DOT is correct in their comment.
Action in Response to Public Comment: Thermostatically controlled shutters are not
referred to as noise reduction equipment in the preamble to the regulations.
A-4.2.3 Fan Treatment
Identification: The Department of Transportation (A-2.5.4.6) commented that when radia-
tor fans of different designs were used and the air-flow rate held constant, the fan noise
remained essentially the same.
Discussion: DOT based their comment on tests of different fans conducted in the DOT
Quiet Truck Program [ 121. In the first set of test results, different fans were installed in the
original cooling system without making other modifications to the cooling sytem. Of the 11
fans tested, it was possible to develop an adequate amount of airflow with only six fans.
Using each of these six fans, the fan speed at maximum engine speed was varied until the
required air flow was developed. The shroud coverage was the same for all fans. The mea-
sured noise levels had a range of only 3 dBA. However, it is not clear whether some of
these fans were partially stalled, which would affect the noise output.
A second set of tests were conducted after modifications were made to improve the fan
environment and reduce the cooling system noise. Results from these tests indicate that the
range of fan noise for the seven fans tested was 4 dBA and that conventionally-designed fans
were among the quietest. Unfortunately, the fan coverage by the shroud was not the same
for each fan tested, varying from 1 25 percent to 85 percent. These differences in fan cover-
age affect the fan environment which is often as critical as the actual fan design in reducing
fan noise [ 12]. Thus, a different range of noise levels for the seven fan designs could result
when a constant fan coverage is used.
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In the fan tests on the International Harvester DOT Quiet Truck, all relevant fan design
parameters were not considered. In addition, because some of the fans could have been
stalled in the first set of tests and fan coverages were not the same in the second set of tests,
it should not be concluded from these tests that different fan designs cannot be used to
achieve appreciable reductions in fan noise.
Action in Response to Public Comment: No further action has been taken.
A-4.3 REQUIREMENTS FOR TRUCK NOISE CONTROL
A-4.3.l Cooling System
Identification: The Ford Motor Company (A-2.l.3.11, A-2.l.3.12, and A-2.l.3.13) com-
mented that many of their diesel and gasoline trucks will require a fan clutch and modifica-
tions to cooling systems in order to comply with the 83- and 80-dBA regulation. General
Motors (A-2. 1.5.8) claimed that fan clutches will be required for most heavy diesel trucks
to comply with the 80-dBA regulation. For the 75 c IBA regulation, GM (A-2.l.5.l 3) claimed
that larger radiators or remote cooling systems will need to be installed in most diesel trucks.
GM (A-2.1.5.8) called only for a viscous fan drive for gasoline trucks regulated at 83 or 80
dBA. A larger radiator was called for to meet the 75-dBA regulation. International Harves-
ter (A-2.1.6.8) implied that an extensive redesign of the cooling system will be required for
heavy diesel trucks to comply with the 83 dBA regulation. The Department of Transporta-
tion (A-2.5.4.12) commented that a cooling system noise level of 65 dBA will be required
for trucks to comply with the 75-dBA regulation. This will require radiators larger than
those presently available, which may be impractical in trucks with conventional cabs be-
cause of visibility requirements.
Discussion: In reply to these comments, we note that a fan noise level of 70 c IBA is low
enough to allow compliance with either the 83 or 80 dBA regulation [ 131. In the Inter-
national Harvester DOT Quiet Truck, cooling system noise with the radiator shutters open
was reduced from 81 cIBA to 70 cIBA by using a sealed, contoured shroud with a reduced
tip clearance, a redesigned radiator and different-fan-to-radiator distance [ 1 21. The
changes associated with this approach should not b considered extensive since no changes
in radiator or fan size, or location of the fan or cooling system was required.
A fan noise level of 64 cIBA would be low enough to allow compliance with the 75
dBA regulation [ 131. A larger radiator (2000 sq. in.), a larger slower-turning fan, a fan
shroud and partial engine enclosure were used in the Freightliner DOT Quiet Truck to re-
duce the cooling system noise from a level of 83 cIBA to 64 dBA [ 14] . With this cooling
system, the overall truck noise level was measured at 72 dBA with the fan on [ 1 5 J. Similar
techniques can be applied to trucks in order to comply with the 75-dBA regulations.
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In trucks with conventional cabs, techniques used on the International Harvester DOT
Quiet Truck, such as optimizing fan-to-radiator distances and using radiators with serpentine
fins, [ 121 can be employed to reduce the need for larger fans and radiators so that visibility
requirements could be met.
Action in Response to Public Comment: There is general agreement on the treatments re-
quired to reduce cooling system noise to levels tow enough for trucks to comply with the
proposed regulations. No further action has been taken.
A-4.3.2 Exhaust System
Identification: The Ford Motor Company (A-2.l.3.ll) claimed that many of their heavy
diesel trucks will require larger mufflers to meet an 83-dBA regulation. For the 80-dBA
regulation, Ford Motor (A-2. 1.3.12) predicted that double-wall exhaust pipes and wrapped
mufflers will also be needed. General Motors (A-2.l.5.8) commented that double-wall muf-
flers and exhaust pipes will be required on many heavy diesel trucks for the 83-dBA regula-
tion. The addition of larger packed mufflers will be needed to meet the 80-dBA regulation.
For the 7 5-dBA regulation, GM claimed that larger wrapped mufflers with premufflers and
larger double-wall exhaust piping will need to be added. All diesel engines will require turbo-
charging to reduce exhaust noise enough to meet the 75-dBA regulation, according to Gen-
eral Motors (A-2.l.5.12). In order to meet the 83-dBA regulation, International Harvester
(A-2. 1.6.8) claimed that an extensive redesign of the exhaust system will be needed.
The Department of Transportion (A-2.5.4.7) pointed out that on the International Har-
vester DOT Quiet Truck the exhaust pipe shell noise was initially 83 dBA and the muffler
shell noise 74 dBA, where the exhaust discharge noise was 76 dBA. Therefore, exhaust
shell noise will need treatment in order to meet the 83-dBA regulation. DOT (A-2.5.4.8)
also pointed out that mufflers are available to reduce exhaust outlet noise to 75 dilA for
all popular diesel trucks.
Discussion: In reply, consider the requirements for each regulatory level. For the 83-dBA
regulation, a design level for the exhaust system of 73 dBA should be adequate [ 131. Data
acquired in the DOT Quiet Truck Program show that this goal is achievable. Sealing exhaust
leaks reduced the exhaust shell noise on the Freightliner DOT Quiet Truck from 75 dBA to
71 c IBA. Using available mufflers, the exhaust outlet noise was further reduced to 66 dBA.
On the International Harvester DOT Quiet Truck, sealing exhaust leaks and using larger
wrapped mufflers reduced the total exhaust noise level to 72.5 dBA [ 161. The comments on
the required exhaust treatment for the 83-dBA regulation are in general agreement with the
experiences in the DOT Quiet Truck Program. However, the required treatments should not
be considered extensive, as claimed by International Harvester Company.
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An exhaust noise level of 69 dBA should be adequate to enable most trucks to comply
with the 80-dBA regulation. Adding wrapping to the exhaust piping on the International
Harvester DOT Quiet Truck with sealed exhaust leaks and larger wrapped mufflers reduced
the shell noise enough to reduce the total exhaust noise level to about 70 dBA [ 1 6]. The addi-
tion of a partial engine enclosure reduced the shell noise on the Freightliner DOT Quiet
Truck with sealed exhaust leaks [ 14]. With an exhaust outlet level of 66 dBA using available
mufflers, the total exhaust level would be approximately 70 dBA. In general, these results
are in agreement with comments made by truck manufacturers.
An exhaust manifold muffler, larger wrapped mufflers, stack silencers, partial engine
enclosure and exhaust joint seals were suffient to reduce the exhaust noise on the Freight-
liner DOT Quiet Truck enough to allow the overall truck noise level to be reduced to 72 dBA
[ 15]. This level is low enough to comply with the 75-dBA regulation and allow for a 3 dBA
tolerance. The exhaust system treatments used on the Freightliner DOT Quiet Truck are
similar to the treatments suggested by General Motors for trucks to comply with the 75-dBA
regulation. General Motors was the only contributor to offer comments on the required
exhaust treatment for the 75-dBA regulated truck. All of the diesel trucks considered by
GM were assumed to be equipped with two-stroke naturally-aspirated engines, which consti-
tute a minority of the diesel engine population and in general have higher unmuffled exhaust
noise levels than four-stroke and/or turbocharged diesel engines [ 61. As pointed out by
General Motors, double wall larger exhaust piping will be needed to reduce shell noise, par-
ticularly for two-stroke diesel engines.
Turbocharging diesel engines will help reduce the exhaust noise by around 5 to 10 dBA
[ 8], since the exhaust gases are passed through the turbocharger. If the engine in the Inter-
national Harvester DOT Quiet Truck had been turbocharged, the difficulty with reducing
exhaust noise level would have been eased. In their comments, General Motors added that
turbocharging increases engine efficiency and ease of meeting exhaust emission standards.
Therefore, turbocharging will probably become more widely used and may become a part of
the most cost effective method of reducing exhaust noise in order to comply with the 75-dBA
regulation. Although there is little data to support the claim by GM that turbocharging will
be required on all 75-dBA regulated trucks, it may be used on most of them.
In the preamble to the proposed regulations, it was stated that exhaust shell noise is low
enough that very few trucks will require exhaust shell noise treatment in order to reach levels
low enough to comply with the 83-dBA regulation. In both the International Harvester and
Freightliner DOT Quiet Trucks, some treatment of the exhaust shell noise was required to
reduce the truck noise level to a level low enough to comply with the 83-dBA regulation.
Therefore, the statement in the preamble appears to be incorrect, as pointed out by the
Department of Transportation. However, it should be noted that the shell noise levels given
by DOT in their comments are for the International Harvester DOT Quiet Truck which had a
A-4-6
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two-stroke diesel engine. In general, two-stroke diesel engines have higher exhaust noise levels
than four-stroke diesel engines. Therefore, the levels quoted by DOT should not be considered
as representative of all diesel engines.
Data on exhaust outlet noise levels for existing trucks with four-stroke diesel engines [ 61
shows that DOT is correct in commenting that mufflers are available which reduce outlet noise
to 75 dBA or below. The experience on the International Harvester DOT Quiet Truck with
available mufflers on a two-stroke diesel engine 116] also supports the comment made by DOT.
Action in Response to Public Comment: Corrections have been made in response to com-
ments by DOT on exhaust shell noise and available exhaust mufflers.
A-4.3.3 Engine
Identification: The Ford Motor Company (A-2. 1.3.20 and A-2. 1.3.11) predicted that for the
83-dBA regulation engine-noise shields will be needed and that some of the noisier engines
will no longer be usable. For the 80-CIBA regulation, full encapsulation for diesel engines and
noise shields for gasoline engines will be required, according to Ford (A-2.2.3. 12). Ford also
claimed that internal engine modifications will be needed for the 80-dBA regulation. Gen-
eral Motors (A-2.l.5.8) commented that engine noise barriers will be required for many
diesel trucks to meet the 83-dBA regulation. For the 80-dBA regulation, full underpans and
absorptive material will need to be added and engines will need internal modifications. The
engine modifications will include barrel-shaped, tight-clearance pistons to control piston slap
which is the major source of diesel engine noise, according to General Motors (A-2. 1.5.10).
To meet the 75-dBA regulation, General Motors (A-2.l .5.8) claimed that diesel engines will
need to be modified, turbocharged and fully encapsulated. General Motors added that en-
gine noise side-shields will be required for gasoline trucks to meet the 75-dBA regulation.
International Harvester (A-2. 1 .6.8) commented that engine noise shields will be re-
quired for the 83-dBA regulation. Mack Trucks, Inc. (A-2.l.7.7) claimed that the 80-dBA
regulation may require the encapsulation of some engines and removal of the noisier engines.
The 75-dBA regulation will require the elimination of a majority of existing diesel engines
and the encapsulation of the few which remain, according to Mack Trucks. The Donaldson
Company (A-2.2.2.6) asserted that many engines will require partial enclosures to meet the
80-dBA regulation and all will require full enclosures to meet the 75-dBA regulation. The
American Trucking Associations, Inc. (A-2.3.1.4)stated that major engine redesigns will
probably be required in order to obtain the engine noise reductions necessary to comply
with the proposed regulations.
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Discussion: EPA has shown that an engine noise level of 77 dBA should be low enough to
allow compliance with the 83-dBA regulation [ 131. Using the maximum noise levels for gaso-
line engines and 12 diesel engine models, treatments necessary to reduce engine noise to 77
dBA was derived [ 13]. The results of this study show that gasoline engines would not require
noise treatment [ 13] . Without internal modifications to the engine, side shields, which pro-
vide 2-4 dRA attenuation, may be used on 68 percent of existing diesel engines [ 131. Side
shields and an underpan may be used in 32 percent of the diesel engines [ 13]. Side shields
and underpans provide 4-10 dBA attenuation [ 17]. These comments are in general agree-
ment with those received from the public. When the Ford Motor Company claimed that
certain engines will no longer be usable in trucks complying with the 83-dBA regulatory
level, we believe they were not referring to a matter of technological unfeasibility, but rather
to a question of economic effectiveness. Certain noisy engines may be adequately quieted
by use of engine kits, side shields or enclosures. However, it is probably more responsive to
the market demand to avoid using these engines and offer quieter ones in their place.
For the 80-dBA regulation, the reduction of engine noise to 73 dBA should be sufficient
[ 13]. None of the existing truck engines have noise levels 73 dBA or below [ 8]. Gasoline
engines should require side shields to reach 73 dBA. Side shields should be adequate for 23
percent of the present population of new diesel engines [ 1 3]. Underpans and side shields may
be required for 62 percent of existing diesel engines and 17 percent of new diesel engines
may require partial enclosures [ 13]. Maximum noise levels for existing engines have been
used in predicting the required engine treatment. The engine noise levels used in the
background document to the proposed regulations [ 8] are in error. It was incorrectly as-
sumed that the engine noise levels were for engines outside the truck cab. The presence of
the cab provides at least 2 dBA attenuation which resulted in estimates of in-truck engine
noise levels that were low by approximately 2 dBA. This error has been corrected and the
additional engine noise ‘treatment provided.
Since it is likely that some reductions in diesel engine noise will be achieved, it appears
that the comment made by the Donaldson Company, that many engines will require partial
enclosures is an overstatement. The full engine encapsulations called for by the Ford Motor
Company and the Mack Truck Company to meet the 80-dBA regulation should not be re-
quired for any of the existing diesel engines. The use of underpans and side shields, along
with modifications to the engine, as suggested by the General Motors Corporation, will prob-
ably not be needed on most trucks for the 80-dBA regulation.
General Motors Corporation is correct in commenting that piston slap is a major source
of diesel engine noise. However, it should be noted that other sources, such as combustion,
fuel injection equipment, valve trains, gearing and accessories, also c ntribute to engine noise
[ 11]. In addition, investigations on engine noise reduction have resulted in reductions of 9
dBA and that most of the reduction in this investigation appeared to be due to the use of
covers and isolating components. When costs are considered, the use of covers, shields and
A-4-8
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isolating components is the most attractive solution to engine noise reduction [ 10]. There-
fore, the reduction of piston slap should not be considered as the only effective method of
reducing engine noise.
For the 75-dBA regulation, an engine noise level of 68 dBA should be low enough [ 131.
In order to reach this level, most diesel engines will require full or partial enclosures. Some
of the noisiest of the present diesel engines may require quiet kits in addition to enclosures
[ 131. Presently-available gasoline engines may require side shields and underpans to reach
engine noise levels of 68 dBA or below [ 13]. General Motors Corporation predicted that side
shields would be sufficient. The treatments presented here for the noisiest of existing diesel
engines are in general agreement with those suggested by General Motors Corporation for
all diesel engines. It should be noted that all of the diesel engines considered by General
Motors were two-stroke. Two-stroke diesel engines have engine noise levels at least 4 dBA
lower than the noisiest existing engines [ 131. The 75-dBA regulation should not force the
elimination of a majority of diesel engines, as indicated by Mack Trucks, since techniques for
reducing the noise from existing diesel engines to 68 dBA are available. Redesign of diesel
engines and the addition of covers and isolated components will probably eliminate the need
for full encapsulations on many trucks. The Donaldson comment that all diesel engines will
require full encapsulation is probably pessimistic.
In their comments, General Motors added that turbocharging increases engine efficien-
cy and helps to meet exhaust emission standards. With the increased concern recently over
fuel conservation and control of air emissions, the use of turbochargers on diesel engines will
become more attractive for reasons not related to noise reduction. Therefore, when fuel sav-
ings and the control of air and noise emissions are all considered, the use of turbochargers
could be incorporated by most engine manufacturers to meet the 75-dBA regulation.
On the Freightliner DOT Quiet Truck, the use of a partial engine enclosure, isolated-
mass engine mounts and an engine quiet kit was sufficient to reduce an initially noisy engine
(84 dBA) to a level low enough to allow an overall level of 72 dBA to be reached [ 15]. There-
fore, trucks with initially noisy engines can be quieted enough to comply with the 75-dBA
regulation. It is not likely that the 75-dBA regulation will force the elimination of a majority
of diesel engines as claimed by Mack Truck Company.
Although engine redesigns will probably not be required to meet the proposed regula-
tions, as suggested by the American Trucking Associations Inc., redesigning diesel engines
and adding covers and isolated components will probably be a cost effective method of re-
ducing engine noise. The demand on engine manufacturers for quiet engines by truck manu-
facturers will encourage the quieting of many of the present diesel engines and the introduc-
tion of some new quieter models.
Action in Response to Public Comment: No further action has been taken.
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A-4.3.4 Air Intake System
Identification: The Ford Motor Company (A-2.l .3.12) claimed that treatment of air intake
systems will probably be required for diesel trucks to meet the 80-dBA regulation. For the
75-dBA regulation, General Motors (A-2.1.5.8) predicted that air-cleaner silencers will be
needed on some di sel trucks. International Harvester Company (A-2. 1.6.8) asserted that
extensive redesigns of air intake systems will be required to meet the 83 dBA regulation.
Discussion: The noise levels for the air intake systems for the unquieted DOT Quiet Trucks
were as follows: Freightliner — 62 dBA [ 15], International Harvester — 72 dBA [ 16],
and White — below 65 dBA [ 181. Changing the rain cap on the International Harvester DOT
Quiet Truck reduced the air intake noise to 69 dBA [ 161. An air intake system noise level of
69 dBA should be adequate for trucks to meet the 83- or 80-dBA regulations [ 13]. Thus, it
appears that no significant changes from current practices for air intake treatment is needed
for the 83- and 80-dBA regulations.
For the 75-dBA regulation, the noise from air intake systems will need to be reduced
an additional 4 dBA to 65 dBA on most trucks. The air intake silencer used on the Inter-
national Harvester DOT Quiet Truck reduced the air intake noise by 4 dBA [ 16]. Therefore,
General Motors is correct in commenting that some trucks will require an air intake silencer
to meet the 75-dBA regulation.
Action in Response to Public Comment: No further action has been taken.
A-4.3.5 Other Sources
Identification: The White Motor Corporation (A-2.1 .10.4) commented that other noise
sources in trucks yet to be measured or treated will need treatment in order to comply with
lower regulatory levels. General Motors Corporation (A-2. 1 .5.17) claimed that tire and aero-
dynamic noise (65-73 dBA), axle noise (up to 78 dBA), truck frame radiation (up to 70 dBA),
truck cab radiation (up to 65 dBA) and transmission noise (up to 77 dBA) must be treated in
addition to engine, cooling, exhaust and air intake systems in order to comply with the 75-
dBA regulation. According to the Cummins Engin Company (A-2.2. 1.4), transmission noise,
with an average level of 75.5 dBA, and chassis noise, with an average level of 70 dBA at 30
mph, will need treatment for the 75-dBA regulation.
Discussion: Some data on source levels, and treatments of noise from sources other than en-
gine cooling, exhaust and air intake systems are available to deal with these points. The noise
level from the rear axle reported for the Freightliner DOT Quiet Truck was 58 dBA (14]. The
peak tire and aerodynamic noise was 62 dBA [ 14]. These levels are lower than those given
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by GM. No treatment of the rear axle or tires was required on the Freightliner DOT Quiet
Truck to quiet it to a level of 72 dBA.
The treatment of noise radiated from the transmission, truck frame and cab is included
on the Freightliner DOT Quiet Truck. The partial enclosure covered the transmission. In
their response to the proposed regulations, General Motors Corporation also included the
transmission inside enclosures. The isolated-mass engine mounts reduced the transmission of
structure-borne noise to the truck frame and cab, reducing the noise radiated by the frame
and cab. Special vibration mounts for the engine were considered by GM in the treatments
for the trucks. It appears that General Motors is correct in stating that in some trucks, treat-
ment of the transmission, truck frame, and cab will be required to comply with the 7 5-dBA
regulation. However, effective treatment of these sources has been demonstrated.
Action in Response to Public Comment: No further action has been taken.
A-4.4 DESIGN TOLERANCE
A-4.4. I Manufacturing and Test Variables
Identification: The Freightliner Corporation (A-2.1 .4.3), General Motors Corporation
(A-2.l .5.7), International Harvester Company (A-2.l .6.5), Mack Trucks Inc. (A-2.l .7.5) and
the American Trucking Associations Inc. (A-2.3.l .3) all commented that design targets for
truck manufacturers will need to be 2 to 3 dBA below the regulatory level. The Ford Motor
Company (A-2.l.3.8) claimed that the design target would be at least 3 dBA below the regu-
latory level. According to Paccar Inc. (A-2.l.9.l), the design target would be at least 2 dBA
below the regulatory level. Donaldson Company (A-2.2.2.4) predicted that a design target of
2 to 5 dBA below the regulatory level would be necessary. The Department of Transporta-
tion (A-2.5.4.lO) claimed that a design tolerance of 4 dBA would be needed; 2 dBA to ac-
count for the variation in the measured noise levels for trucks of the same configuration
and 2 dBA to account for design uncertainties.
Discussion: In the EPA analyses of the technology, costs of compliance [ 13], and benefits to
the public health and welfare [ 21 it is assumed that medium and heavy trucks will be de-
signed and built with median measured noise levels approximately 2.5 dBA below the regu-
latory level. The 2.5 dBA figure agrees with most of the comments received from truck
manufacturers and is believed to be accurate.
Action in Response to Public Comment: A design target of 2.5 dBA below the regulatory
level has been included in the assessments of the required noise reduction technology, and
the benefits and costs associated with various regulatory options for medium and heavy
trucks.
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A-4.4.2 Degradation of the Effectiveness of Treatment
Identification: Paccar Inc. (A-2.l .9.2) and The White Motor Corporation (A-2.1 .10.3) com-
mented that there is a lack of information on the degradation of the performance of noise
reduction hardware with time. Paccar Inc. (A-2.l.9.2) and The Cummins Engine Company
(A-2.2. 1.1) indicated that little information exists on the changes in engine noise levels with
age. Mack Trucks (A-2.l.7.6) claimed that it is impossible to determine the design noise
levels necessary to compensate for any increases in noise levels over the “useful life” of the
truck. According to the Chrysler Corporation (A-2.l.l .3), it is not possible to determine
the acceptable design ranges on the parameters for devices which control noise over the use-
ful life of trucks. The Automotive Exhaust Systems Manufacturers Committee (A-2.6.3.l)
pointed out that there is little data on the useful life of an exhaust system and that the acqui-
sition of enough data to determine the useful life of an exhaust system would not be techni-
cally feasible. The Department of Transportation (A-2.5.4.l 5) commented that the slight
decrease in the noise with age observed on the International Harvester DOT Quiet Truck
could be partly attributed to careful maintenance.
Discussion: This issue will have an impact on the design targets set by truck manufacturers
if the “useful life” provision in the proposed regulations is included in the final regulation.
With this provision, the manufacturers will have to allow for deterioration of noise abate-
ment equipment with age in designing and building trucks so that the trucks comply with
the regulatory level during its “useful life.”
There are two potential sources of data on the degradation of the performance of noise
control equipment with age. The first is the DOT Quiet Truck Program in which three quieted
truck models (Freightliner, International Harvester and White) have been placed into line-haul
service for approximately 1 year. An increase in the overall noise level of about 2 c IBA
was reported for the Freightliner truck [ 19]. However, part of the increase may be
attributed to the replacement of the original underpan with one of a differentdesign
and overfueling caused by the uncalibrated fuel delivery system. Reports dealing with
the other eight DOT Quiet Trucks (four International Harvester and four White trucks)
have yet to be published.
The second potential source of data on the degradation of noise abatement treatment is
the experience of the owners of trucks that comply with existing State or local new truck
regulations. In California, a not-to-exceed 83-cIBA regulation on the noise emissions from
new trucks with a CVWR of over 6000 pounds became effective on January 1, 1975. This
has not allowed sufficient time for useful degradation data to be obtained. The 86-dBA reg-
ulation (in effect for some time in California) has not required the application of extensive
noise treatment, so that little degradation data is available from 86-dBA regulated trucks.
Therefore the comments concerning the lack of information on degradation of noise abate-
ment and the changes in noise levels with age appear to be correct.’ It is difficult, therefore,
A-4-12
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for truck manufacturers to set design targets which taken into account the “useful life” pro-
vision in the proposed regulations.
Action in Response to Public Comment: The “useful life” requirement has been omitted in the
final regulations. However, EPA intends to include a “useful life” requirement in the future and
has reserved a section in the regulations for incorporation of a “useful life” in the future.
A-4.5 AVAILABILITY OF THE TECHNOLOGY REQUIRED FOR COMPLIANCE
Comments which deal in general with the availability of the required technology for
compliance to the proposed regulations are treated separately from the comments which treat
the adequacy of the Freightliner DOT Quiet Truck as a demonstration of the technology re-
quired to comply with the 75-dBA regulation.
A-4.5.1 General Availability of Technology
Identification: Several comments were received concerning the availability of the technology
required for compliance with the proposed regulations. The following commentors claimed
that the required technology is not available or has not been demonstrated for all trucks:
Chrysler Corporation (A-2.l .1.1), Ford Motor Company (A-2.l .3.5), General Motors Corpor-
ation (A-2.l.5.l 5), International Harvester Company (A-2.l .6.7), Oshkosh Truck Corpora-
tion (A-2.l.8.l), Paccar Inc., (A-2.l.9.3), Schwitzer (A-2.2.6.2), W. S. Hatch Company
(A-2.3.4.l), The Department of Transportation (A-2.5.4.l 1), Chamber of Commerce
(A-2.6.4.2) and Motor Vehicle Manufacturers Association (A-2.5.4.l 1). Comments by the
Friends of the Earth and Sierra Club (A-2.4.4.2) and George Wilson (A-2.4.6.l) claimed that
the required technology is available.
Oshkosh Truck Corporation, Paccar Inc., Schwitzer, and the U.S. Chamber of Commerce
did not provide supporting evidence for their claim that the technology is not available. The
Motor Vehicle Manufacturers Association added that EPA has not met the statutory require-
ment to take into account the best available technology in setting regulations on noise emis-
sions. According to W. S. Hatch Company, the regulations should not be promulgated until
equipment has been developed that can be used in meeting the regulations.
Chrysler Corporation claimed that medium diesel trucks are the most difficult to quiet,
since mediumduty diesel engines are noisier than heavy-duty engines, and that no medium
diesel trucks have been built that comply with the 75-dBA regulation. According to the Ford
Motor Company (A-2.l .3.7), vehicle testing indicates that truck noise levels approaching 77
dBA cannot be reached. A level approaching 77 dBA would be required to comply with the
80-dBA regulation. The Department of Transportation and the Donaldson Company (A-2.2.2.5)
claimed that the available information is not sufficient to assure that technology for compli-
A-4-l3
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ance with the 75-dBA regulation is available, since only one of the three attempts in the DOT
Quiet Truck Program to reach truck noise levels below 75 dBA was successful. General
Motors commented that the technology to mass-produce trucks which comply with the 75-
dBA regulation is not available. Ford Motor claimed that “off-the-shelf’ hardware does not
exist that will produce the noise reductions necessary to comply with the 80- or 75-dBA
regulation. The technology to meet the 80-dBA regulation does not exist for a full truck
line, according to International Harvester, because a 2 and 3/4-year lead time is required to
redesign each truck model and a full set of reliability tests is needed for each truck model.
The Friends of the Earth and Sierra Club (A-2.4.4.1) claimed that sufficient technology
is available to comply with the proposed regulations and that the lead time for the 80-dBA
regulation could be shortened by one year. They also commented that research in this
country, as well as in England and Germany, has clearly shown that the 75-dBA regulation
can be attained with available technology. Walker Manufacturing (A-2.2.7.l) added that the
technology for exhaust systems would permit shorter lead times. George Wilson, a consult-
ant in acoustics and noise control, commented that the technology is available for the 75-
dBA regulation and added (A-2.4.6.2) that General Motors claimed that they would have no
problem in meeting the 80-dBA regulation proposed by the State of California. The City of
Chicago (A-2.5.2.l) commented that the results from the DOT Quiet Truck Program indi-
cated that a 75-dBA regulation can be met.
Discussion: It is believed that the technology to bring medium and heavy trucks into corn-
plicance with regulatory levels as low as 75 dBA has been demonstrated as being available as
asserted by Friends of the Earth and Sierra Club, and George Wilson. EPA has shown that
the technology to comply with the 75-dBA regulatory level has been demonstrated, and
thereby has met the statutory requirement on available technology. Demonstrated tech-
nology to quiet each major truck noise source enough to allow trucks to comply with the
75-dBA regulatory level is discussed in Section 5 of this document.
Promulgating the regulations after noise treatment equipment necessary for compliance
to the proposed regulations has been made available for all truck models, as suggested by
W. S. Hatch Company and the Ford Motor Company, or as implied in comments by General
Motors Corporation, after the-mass-production of regulated trucks has been demonstrated,
is not recommended since without the regulations, the production of noise treatment equip-
ment and quiet trucks may be substantially delayed. The demonstration of the availability
of the technology for the development of such hardware is sufficient.
The following factors may be partly responsible for the fact that the noise levels of the
final configurations of the International Harvester and White Motors DOT Quiet Trucks were
not as low as the 72 dBA level of the final configuration of the Freightliner DOT Quiet Truck.
In many cases, these factors involved policy decisions and do not represent limitations on
achievable noise reductions.
A-4-14
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1. The goal for the lowest overall noise level (the “Reduced Noise Floor Goal”) for
the White Motors truck was 77 dBA 1118].
2. International Harvester and White Motors did not use a manifold muffler in the
exhaust system. The technology for the manifold muffler used by Freightliner
was developed concurrently to the quieting programs by International Harvester
and White Motors and was not available for application on the International
Harvester and White Motors trucks. The manifold muffler used on the final
configuration of the Freightliner truck had an insertion loss of approximately 7
dBA [ l4].
3. International Harvester did not increase the size of the cooling fan. Increasing the
fan size would have probably permitted the fan speed to be reduced without a’ loss
in cooling capacity. A larger radiator may have been needed to accommodate a
larger fan, which may have required modifications to the cab.
4. Although White Motors did explore the use of a larger fan, they did not optimize
the fan to radiator distance or increase the cooling efficiency of the radiator.
These techniques permitted fan noise reductions of approximately 4 and 2 dBA,
respectively, on the International Harvester truck [ 1 2].
5. International Harvester [ 20] and White Motors 1118] used close-fitting engine
covers and partial engine enclosures separately, whereas Freightliner used both
techniques simultaneously on a single truck to quiet engine noise [ 15].
6. Less absorbing material was used by International Harvester and White Motors
inside their partial engine enclosures than was used by Freightliner in their
enclosure. International Harvester used a I-inch thick layer of absorbing mate-
rial [ 201, where the layer thickness was 2 inches on the Freightliner truck [ 14].
White Motors used absorbing material on the underpan only [ 18]. Absorbing
material was used on other parts, as well as the underpan, on the other DOT Quiet
Trucks.
These factors indicated that it should be possible to further reduce the noise levels of the
International Harvester and White Motors DOT Quiet Trucks. Therefore, the fact that these
trucks did not achieve levels below 75 dBA should not constitute evidence that technology
is not available for compliance with the 75-dBA regulation.
The results from tests performed in the DOT Quiet Truck Program contradict the asser-
tion made by the Ford Motor Company that results from tests indicate that truck noise levels
approaching 77 dBA cannot be reached. As stated above, an SAE J366b test level of 72 dBA
was obtained by one of the participants in the DOT Quiet Truck Program.
A-4-I5
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The Chrysler Corporation is correct in commenting that no prototype medium diesel
truck has been built to meet a 7 5-DBA regulation. The population-weighted average of the
engine noise levels provided by truck manufacturers for medium-duty diesel engines [ 1 3] is
about 82.5 dBA under SAE J366b test conditions for the engines installed in the truck. For
heavy-duty diesel engines, the population-weighted average noise level is also about 79.5 dBA,
[ 13]. Therefore, the Chrysler Corporation is correct in commenting that medium-duty diesel
engines are on the average noisier than heavy-duty engines. However, the noisiest of avail-
able medium-duty diesel engines is only 1 dBA noisier than the heavy-duty diesel engine used
in the Freightline DOT Quiet Truck. The engine in the Freightliner truck initially had a
noise level of 84 dBA [ 1 5]. General Motors has indicated that it should be possible to reduce
engine noise levels by 1-3 dBA with engine modifications [ 21]. With these reductions, the
engine noise treatments demonstrated on the Freightliner DOT Quiet Truck should be
sufficient to quiet all medium diesel trucks enough to comply with a 75-dBA regulatory
level.
The reduction of medium-duty diesel engine noise can also be considered as follows. A
9 dBA reduction in diesel engine noise was achieved without using encapsulation techniques
[ 101. The partial enclosure used on the Freightliner DOT Quiet Truck demonstrated a noise
reduction of 11 dBA. Application of both of these demonstrated engine noise treatments
should be more than sufficient to reduce the noise from the noisiest medium-duty diesel
engine enough to allow medium trucks to comply with a 75-dBA regulatory level. There-
fore, building a prototype medium diesel truck which would comply with a 75-dBA regu-
latory level is not necessary to show that technology is available to bring medium diesel
trucks into compliance with a 75-dBA regulatory level.
All hardware used in the DOT Quiet Truck Program is adaptable to large scale produc-
tion. The noise treatment hardware for the exhaust and cooling systems used in the DOT
Quiet Truck Program are “off-the-shelf’ items. The partial engine-transmission enclosures,
isolated-mass engine mounts and exhaust manifold muffler were not “off-the-shelf” items.
However, there is no evidence to indicate that these noise treatments cannot be incorporated
into the mass-production of quiet trucks. Therefore, technology applications upon which
production manufacturing can be based for trucks to comply with a 75-dBA regulation have
been demonstrated and the comment of General Motors Corp. is not correct that
technology is not available to mass produce trucks’ complying with a 75-dBA regulation.
A major redesign may be required for the inclusion of all of the noise abatement treat-
ments necessary to comply with regulatory levels as low as 75 dBA. A major redesign, in-
cluding testing prototype vehicles, takes 2-3/4 years according to comments made by the
International Harvester Company. The lead time for the 80-dBA regulatory level in the
proposed regulation is 6 years, and 8 years for the 75-dBA regulatory level. This allows
time to perform major redesigns of two different models, one at a time for the 80-dBA regu-
lation and three models for a 75 dBA regulation. However, since many models will share
A-4-l6
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similar types of noise abatement hardware, such as partial engine enclosures and larger fans
and mufflers, the basic design changes will be similar so that several models could be rede-
signed simultaneously with only differences in detail. The lead times for the 80-dBA and 75-
dBA regulatory levels in the proposed regulations should be adequate, if the truck manufac-
turers utilize as much of the available time as possible.
Action in Response to Public Comment: The technology required for compliance to the pro-
posed regulations has been demonstrated as being available. Therefore, the availability of
technology did not require that the regulations be relaxed from those proposed.
A-4.5.2 Freightilner DOT Quiet Truck
Identification: Six truck manufacturers (Chrysler, Ford, Freightliner, General Motors, Inter-
national Harvester, and Mack) claimed that the results from the Freightliner DOT Quiet Truck
do not adequately demonstrate that the technology is available to build trucks which comply
with a 75-dBA regulation.
Chrysler Corp. (A-2. 1.1.1) claimed that, since the Freightliner DOT Quiet Truck was
measured at 75 dBA, it will not comply with a not-to-exceed 75-dBA regulation. Mack
Trucks Inc. (A-2.l .7.8) commented that the Freightliner truck was a cab over the engine
truck and that such trucks are quieter than similarly equipped trucks with conventional cabs.
Freigjitliner (A-2. 1.4.5), General Motors (A-2.1 .5.9), and International Harvester (A-2. 1.6.6)
indicated that the Freightliner truck was easier to quiet because the cab had an engine com-
partment designed for larger engines. More space was available for an engine enclosure and
larger radiators than is available on most production heavy diesel trucks. Therefore, it is
necessary to demonstrate that the 75-dBA regulation can be met on trucks with less space in
the engine compartment, according to Freightljner, General Motors, and International Har-
vester. In addition, International Harvester claimed that the fundamental design criteria
was compromised because the engine cooling in the final configuration was not adequate.
Freightilner (A-2. 1.4.4) added that the straight-ribbed tires used on the final configuration
of the Freightliner DOT Quiet Truck were not suitable for highway use. Ford Motor Com-
pany (A-2.l .3.6) claimed that the Freightliner truck was involved only in line-haul service
which is probably not the most severe type of operation. Therefore, evidence has not been
provided that trucks quieted enough to meet a 75-dBA regulation can also meet reliability
requirements under all typical service conditions.
Discussion: The final configuration of the Freightliner DOT Quiet Truck was measured at
72 dBA by Freightliner personnel with the cooling fan on and at 71 dBA by the California
Highway Patrol with the fan off F 1 5]. The test site in both measurements had a hard surface
between the truck and measurement point. The truck was prepared for fleet operation, and
A-4-17
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the measurements were conducted according to SAE J366a test procedures. Therefore, the
Freightliner truck would be in full compliance with a not-to-exceed 75-dBA regulation. A
3 dEA design tolerance needed for mass-production is included in the 72-dBA measured level
for the Freightliner truck. The measurement results referred to by the Chrysler Corporation
were taken from data presented in one of the early reports in the Freightliner DOT Quiet
Truck Program [ 221. These data were taken after thç application of the initial noise reduc-
tion treatment. The final configuration included changes in the exhaust manifold muffler,
engine mounts, engine enclosure (from a full to a partial enclosure), fan, and exhaust piping
and mufflers. These changes were made to increase the noise reduction at minimum increases
in costs.
Data taken from test trucks numbers 04, i i and 1 2 in Reference 23 do not support the
assertion made by Mack Trucks that trucics with the cab over the engine (COE trucks) are
significantly quieter than similarly-equipped trucks with a conventional cab. Truck 04 had a
conventional short-nose cab with a SAE J366b measured noise level of 88 dRA. Trucks 11
and 12 had a cab over the engine and noise levels of 86.5 and 88 dRA, respectively. These
trucks all had similar Cuinmins diesel engines and single vertical exhaust systems. This limited
amount of published data on similarly powered COE and conventional trucks is not sufficient
to verify that the COE style will make a truck quieter. However, there is little reason to be-
lieve that a larger data base would show significant differences (greater than 2-3 dBA) be-
tween similarly equipped COE trucks and conventional trucks, since noise characteristics of
the dominant sources of noise (engine, fan and exhaust system) would be essentially the same
for both cab styles.
Of more importance to the general issue of the availability of required technology for
compliance than differences in cab style is whether the Freightliner DOT Quiet Truck was
initially noisier than most trucks. The initial noise level for the Freightliner truck was 88
dBA (151. This level is higher than about 95 percent of the 384 sampled new diesel trucks
given [ 6J.
Freightliner, General Motors and International Harvester are correct in pointing out that
the cab in the Freightliner DOT Quiet Truck had an engine compartment designed for larger
engines so that more room was available for noise treatment than that available on many new
production trucks. In fact, the Freigbtliner model was selected because of the added space
available in the engine compartment, designed to accommodate up to a 650-horsepower
diesel engine, and a radiator with a frontal area of 2000 square inches. One of the objectives
of the DOT Quiet Truck Program was to apply available noise abatement technology to heavy
diesel trucks to reduce the noise levels to the lowest practical level. Selecting a model with a
smaller engine compartment may have required modifications to the cab and may have cost
the program more without changing the noise abatement technology required to meet the 75-
dBA goal.
A-4-18
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If the cabs of new trucks are redesigned, the same principles of noise abatement, such as
attenuating engine noise with shields or enclosures and absorptive material, muffling the ex-
haust, attenuating the radiated noise from exhaust piping and mufflers and providing slow
speed fans in the cooling system, could be used to obtain noise reductions similar to those ob-
tained for the Freightliner DOT Quiet Truck. In other words, the noise abatement technology
demonstrated on the Freightliner truck is representative of the available technology and is
applicable to all trucks, if some truck cabs are modified to accommodate larger engine com-
partments and radiators. Cab redesign is possible with available technology. Therefore, the
question becomes one of the necessary lead time to modify truck models in time to comply
with the proposed regulations. This question is addressed in Section A-4.5.l.
International Harvester is correct in commenting that the engine cooling capacity on the
final configuration of the Freightliner DOT Quiet Truck was below specifications. The air-
to-boil temperature of the final configuration was 1 21°F under full-power at 1 5 mph [ 151.
The factory recommended air-to-boil temperature is 1 25°F. Therefore, the air-to-boil tem-
perature of 1 21°F for the final configuration of the Freightliner truck was not a serious com-
promise in the fundamental design criteria. No attempt was made to improve the cooling
efficiency of the radiator in the final configuration of the Freightliner truck so that the re-
maining cooling capacity of 4° F in air-to-boil temperature could probably be obtained by
improving the efficiency of the radiator. However, the cooling was believed adequate. In
100,000 miles of line-haul service, the Freightliner truck encountered no engine cooling prob-
lems. [ 191
Freightliner Corporation is correct in commenting that the tires on the final configura-
tion of the Ereightliner DOT Quiet Truck were not suitable for highway use. The tires used
on the final configuration were 10.00 X 22 General HCR straight-ribbed tires [ 151. How-
ever, for the tests conducted by the California Highway Patrol, the Freightliner was equipped
with General Power Jet 11.0 X 24.5 tires on the front and General DCL 1.1.0 x 24,5 tires on
the rear [ 1 5] which are conventional-ribbed tires suitable for highway use. If conventional-
ribbed tires had been used during testing of the Freightliner truck, the overall noise levels
would not have been significantly affected since the noise levels from new ribbed tires are
usually less than 65 dBA at the vehicle test speed of approximately 25 mph used during the
tests on the Freightliner truck [ 7].
The comment made by Ford Motor Company that the Freightliner DOT Quiet Truck
was involved only in line-haul service is correct. Ford Motor is also correct in pointing out
that the Freightliner truck has not demonstrated the reliability of trucks regulated at 75 dBA
in all types df services. Adequate lead times are provided in the proposed regulations for
manufacturers to conduct the necessary reliability tests. There is no reason to believe that
the technology demonstrated to be reliable on the Freightliner DOT Quiet Truck could not
be adapted to trucks involved in other types of services without serious losses in reliability.
A-4-19
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Action in Response to Public Comment: The Freightliner DOT Quiet Truck is accepted by
EPA as a demonstration of available technology for quieting medium and heavy trucks to -
noise levels low enough to comply with a 75-dBA regulation.
A-4.5.3 Performance Compromises
identification: Ford Motor Company (A-2.1 .3.5) commented that “off-the-shell”’ hardware
does not exist which will produce the noise reductions necessary to comply with the 80- or
75-dBA regulation, meet reliability requirements and not reduce truck performance. Ford
Motor Company (A-2.1.3.9) added that high backpressure in exhaust systems is associated
with high noise reduction and reduced engine performance.
General Motors Corporation made the following comments on the performance compro-
mises associated with the noise treatments needed to comply with the proposed regulations.
1. The technology is not available to manufacture engine noise barriers which satisfy
durability requirements and are easy to install and remove (A-2.l .5.11).
2. The durability of packed mufflers, tight-clearance pistons, new engine mounting
systems and absorptive materials in engine compartments is not known (A-2. 1.5.14
and A-2.l.5.18).
3. The encapsulation of engines will cause increases in engine compartment temper-
atures from approximately 100° F to 200°F, which may affect the durability of
some engine mounted components and create a fire hazard (A-2.l.5.l9).
Discussion: The development and production of “off-the-shell”’ noise treatment hardware
will probably not occur until after the regulations are promulgated. The technology to de-
sign and manufacture the noise treatment hardware necessary to comply with the proposed
regulations and satisfy reliability requirements is believed to exist. There may be some re-
ductions in truck performance caused by increases in weight produced by the addition of
noise treatment hardware. However, increases in performance will be associated with some
noise treatments, such as fan clutches and turbocharging diesel engines.
Although some increase in backpressure was experienced in reducing exhaust noise on
the Freightliner and International Harvester DOT Quiet Trucks, the backpressure for the ex-
haust systems on the final configurations was within specified limits. The exhaust outlet
noise was reduced by 1 6 dBA on the Freightliner truck with an increase in backpressure
from 4.5 to 7.0 inches of water El 4J. The average backpressure for the baseline Freightliner
truck model is 12.0 inches of water [ IS 1.
#4-20
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On the International Harvester DOT Quiet Truck, the exhaust outlet noise was reduced
by 11 .5 with an increase in backpressure from 23 to 45 inches of water [ 16]. The higher back-
pressure was within the limits specified by the engine manufacturer [ 1 6]. Therefore, some in-
creases in back pressure may occur with reductions in exhaust noise, however it should be
possible to maintain the back pressures for treated exhausts within the limits specified by
engine manufacturers.
The Freightliner DOT Quiet Truck has been operated in line-haul service. In the first
100,000 miles of service, the serviceability has been good, the noise treatment hardware has,
in general, performed well and no unusual maintenance problems were encountered [ 24].
The Freightliner truck is equipped with special engine mounts, packed mufflers, and a par-
tial engine enclosure comprised of engine noise shields with absorptive material. Therefore,
the experience with the Frejghtliner truck indicates that special engine mounts, packed muf-
flers, engine noise barriers, and absorptive materials, which will satisfy maintenance and dura-
bility requirements, can be built.
No reliable data on the durability of engines with tight-clearance pistons used to reduce
engine noise is known. Therefore, the comment on the subject made by General Motors ap-
pears to be correct. However, the need to use tight-clearance pistons may not be required in
order to comply with the proposed regulations (see Section A-4.3.3).
Engine encapsulation should increase the engine compartment temperatures, even when
adequate liquid cooling is provided for the engine, since the cooling provided by the air flow
over the engine may be reduced by encapsulation. However, the increase in temperature
should be less than the 1000 F as indicated by General Motors since engine compartment tem-
peratures in current production trucks may often reach more than 100°F. It should be pos-
sible to provide adequate cooling inside engine encapsulations by means of lined ducts and
ventilating fans to minimize unusual heat damage to engine components and maintain ade-
quate reductions in engine noise levels. It may also be possible to mount heat sensitive en-
gine components outside the enclosure.
In the International Harvester DOT Quiet Truck program, some concern was expressed
about the fire hazards produced by oil saturated absorptive material located close to the
engine [ 201. These materials could be placed away from the engine on the engine compart-
ment walls or noise barriers and covered with a thin film to prevent the material from becom-
ing saturated with oil. The avoidance of the use of absorptive material in underpans should
also decrease fire hazards. These techniques were used in the partial engine enclosure on the
Freiglitliner DOT Quiet Truck. So far, no fires have been reported on this truck in current
field tests. [ 191
Action in Response to Public Comment: No further action has been taken.
A-4-21
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A-4.5.4 Tire Noise Reduction
Identification: General Motors (A-2.l .5.16) and Donaldson Co. (A-2.2.2.3) commented that
the technology to reduce tire noise much below the present levels is not available. The State
of Delaware (A-2.5.3. 1) claimed that the technology for reducing tire noise was not ade-
quately addressed. Schwitzer Engineering Components (A-2.2.6.l) claimed that tire noise
at freeway speeds cannot be reduced below about 80 dBA. The tire noise level of 77 dBA at
55 mph, used by EPA in estimating benefits, is not attainable by any tires known today, ac-
cording to the Department of Transportation (A-2.5.4.14).
B. F. Goodrich (A-2.2.3.1) suggested that the regulatory levels below 83 dBA be post-
poned until more information is available on quieting truck tires. The American Trucking
Associations Inc. (A-2.3.l .2) claimed that a comprehensive study of the technology of quiet-
ing tires and the effect of quieting tires on safety and costs of operation must be completed
before the regulations should be adopted.
Citizens Against Noise (A-2.4.3.2) claimed that technology is available to produce
quieter tires.
Discussion: The technology for quieting truck tires is not necessary for compliance to the
proposed regulations. Available ribbed tires, suitable for highway use, have noise levels of
approximately 66 dBA at 35 mph when mounted on an unloaded truck 17]. The speeds
during tests will be less than 35 mph so that the noise from ribbed truck tires will be less
than 66 dBA during testing. Tire noise levels less than 66 cIBA are generally low enough
to allow trucks tQ comply with a 75-dBA regulation
Most of the benefits from the proposed regulations will come from the reduction of low
speed traffic noise, where truck tires are not a dominant source of noise (Section A-3.3.2).
Therefore, the reduction of truck tire noise is not necessary to achieve significant benefits.
Truck tires may be the subject of future regulatory action by EPA [ 9], at which time the
issue of the availability of the technology for the reduction of truck tire noise will be
addressed.
Action in Response to Public Comment: No further action has been taken.
A-4-22
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A-4.6 OTHER ISSUES
A-4.6.1 Second Stage Manufacturers
Identification: Rexnord (A-2.2.5.1) and the National Solid Wastes Management Association
(A-2.6.7.1) commented that mounting a mixer on a truck chassis does not materially affect
the truck’s noise emissions.
Discussion: If, when mounting a mixer on a truck chassis, the exhaust system or engine
noise barriers are not modified, the noise emissions of the truck will probably not be signi-
ficantly changed. However, relocating exhaust piping or mufflers, or cutting holes in engine
noise barriers can affect the noise emissions of a truck. In order to prevent increases in the
noise emissions, it will be necessary to provide careful instructions to the second stage manu-
facturers on the modifications which affect noise emissions.
Action in Response to Public Comment: The responsibilities of the first and second stage
manufacturers for the prevention of modifications which may increase the noise emissions
have been specified in the regulations.
A-4.6.2 Buses
IdentifIcation: The Department of Transportation (A-2.5.4.9) commented that there is no
fundamental difference in the noise control technology for trucks and buses. This comment
was made in support of including buses in the proposed regulations.
Discussion: Although the fundamental technologies of quieting buses and trucks are similar,
a separate consideration of the environmental and economic impacts would be required be-
fore buses could be included in the new truck regulations. EPA is gathering information for
separate regulatory action on buses.
Action in Response to Public Comment: No further action has been taken.
A4-23
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Appendix A-S
COSTS OF COMPLIANCE
A-S. I INCREASES ON TRUCK PRICES
A-S. 1.1 Estimates of Truck Price Increases
Identification: Several truck manufacturers presented estimates of truck price increases for
compliance to the proposed regulations. Table A- S. I presents the estimates given by truck
manufacturers.
Ford Motor Company (A-2.1.3.l4) included design and development costs and costs
associated with EPA’s requirements to document noise-control hardware. According to
Ford, these costs were not included in the EPA estimates. Ford (A-2.l .3.15) also stated
that if 10 percent of the tested trucks were allowed to exceed the regulatory level by 2 dBA,
the price increases would be reduced by more than one-half. General Motors (A-2.l.5.21)
and International Harvester (A-2.l..6.lO) claimed that the EPA estimates are low because the
EPA estimates were based on regulatory levels and not the design levels which would be 2-3
dBA below the regulatory levels. The increased costs for development and testing, manu-
facturing, tooling, compliance testing, dealer and customer services associated with noise
abatement equipment were included in the General Motors’ estimates (A-2.l.5.25). General
Motors (A-2.l.5.23) added that the EPA estimates are outdated. The White Motors Corpor-
ation (A-2.i.i0.6) estimates do not include costs for testing, research and development,
engineering, inflation or excise taxes. According to International Harvester (A-2. 1 .6.1 1) and
White Motors (A-2.l.lO.7), the increases in truck prices should increase at a much faster
rate as the regulatory levels are reduced. The American Trucking Associations, Inc. (A-2.3.1 .7)
claimed that the increases in truck prices will rise exponentially as noise levels are reduced.
The Donaldson Company (A-2.2.2.8) claimed that EPA estimates are low by at least 25
percent. The U. S. Chamber of Commerce (A-2.6.4.3) and the American Trucking Associa-
lions Inc. (A-2.3.l .8) commented that EPA estimates were too low, but did not specify by
how much. The costs of turbocharging diesel engines (A-2.3. 1 .5) and modifying truck cabs
(A-2.3.1 .6) were not included in the EPA estimates, according to the American Trucking
Association. The Associated General Contractors of Colorado (A-2.6.2. 1) claimed that the
EPA estimates are totally unrealistic.
A-S-i
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Table A-S. 1. Estimates of Truck Price Increases Presented by Truck Manufacturers
Truck Manufacturer
Regulatory Levels
83 dBA
80 dBA
75 dBA
Gasoline
Diesel
Gasoline
Diesel
Gasoline
Diesel
Chrysler Corp. (2.1.1.4)
-
$500
-
$1200
-
-
Ford Motor Co. (2.1.3.14)
$1 63-194
$5 14-973
$700-900
$1800-2500
-
Freightliner Corp. (2.1.4.7)
-
$456
-
$ 500-700
-
$l000-1200
GeneralMotorsCorp.(2.1.5.25)
$25
$365
$130
$1090
$350
$4450
International Harvester Co. (2.1.6.10)
-
$583
-
$2150
-
-
Paccar Inc. (2.L9.4)
$210-400
-
$ 700
-
$1400
White Motors Corp. (2.1 .10.6)
-
$261
-
$1307
-------
The Chamber of Commerce (A-2.6.4.5) asserted that the regulations will cause trucks
to be priced beyond reach. By the time the regulations become effective, inflation will have
increased the truck price according to the American Road Builders Association (A-2.6. 1.2).
The Department of Transportation (A-2.5.4.16) pointed out that the EPA estimates
were higher than the price increases quoted in the DOT Quiet Truck Program. Freightliner
achieved 7 2-74 c IBA at costs of $1400, International Harvester 78 dBA for $1290 and 80
ElBA for $516, and White Motors 77-79 ElBA for $1307 and 79-8 1 ElBA for $260.
The City of San Francisco (A-2.5.19,l) commented that the trucks are now capable of
obtaining 80-dBA noise levels at reasonable costs. The noise level from a bus was re-
duced from 90 to 81 dBA by retrofitting noise treatment hardware at a cost of $600,
Discussions: The population-weighted average of the EPA estimates of truck price increases
are presented in Table A-S .2 [ I 31. In deriving these estimates, it was assumed that compli-
ance testing would be conducted with the fan on for trucks equipped with fan clutches. If the
fan is permitted to be turned off during testing, lower price increases are expected [ 13). The
estimates on Table A-5.2 represent revisions of the estimates given in the Background Docu-
ment to the proposed regulations [ 8]. The revised estimates are higher than the original
estimates.
Table A-5.2. EPA Estimates of Average Truck Price Increases for Proposed Regulations
TypeofTruck
Regulatory Levels
83 E lBA
80dBA
75 ElBA
Medium gasoline ...
Heavygasoline ....
Medium diesel ....
Heavydiesel
$ 35
$135
$426
$387
$180
$280
$865
$715
$ 665
$ 815
$1624
$1454
For comparison, EPA and truck manufacturers estimates are presented in Figure A-5.1
for diesel trucks. For the 83-dBA regulatory level, the estimates from Chrysler, Ford,
Freightliner, and International Harvester, arc higher than the EPA estimates. For the 80-
dBA regulatory level, the estimates from Chrysler, White Motors, Ford, and International
Harvester are higher than the EPA estimates. The estimates from Freightliner and Paccar
were lower than the EPA estimates. The spread of estimates for the 80-dBA regulatory
level is larger than the spread of estimates for the 83-dBA regulatory level.
Three truck manufacturers (General Motors, Paccar, and Freightliner) made estimates of
truck price increases for the 75-dBA regulatory level. Only the estimates made by General
Motors exceed EPA estimates for the 75-ElBA regulatory level,
A-5-3
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4500
- REGULATORY LEVEL — dBA
Figure A-5.I. Estimates or Truck Price Increases
4000
3500
U )
5
-J
a
( I ,
I L k
( I )
C
uJ
0
z
U i
a
C-
0
I —
3000
2500
2000
1500
1000
500
83 80
75
A-5-4
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Ford and General Motors presented estimates of price increases for gasoline trucks. The
Ford estimates are higher than EPA estimates for the 83- and 80-dBA regulatory levels. For
the 83-, 80- and 75-dBA regulatory levels, General Motors’ estimates for gasoline trucks are
lower than the EPA estimates. For the 75-dBA regulatory level, the General Motors’ esti-
mate is nearly one-half the EPA estimate.
The differences between the EPA and truck manufacturers’ estimates may be attributed
to differences in the following:
• The noise treatment hardware claimed as necessary to comply with the regulatory
levels,
• The estimates of the costs of each unit of noise treatment hardware.
The differences in noise treatments are discussed in Section A-4.3. There is general agree-
ment on the treatments needed to reduce cooling, exhaust, and air intake system noise.
However, the engine noise treatments claimed by truck manufacturers as necessary for die-
sel trucks to comply with the proposed regulations are greater than should be needed on most
diesel trucks (Section A-4.3.3). This contributes to the higher estimates given by truck man-
ufacturers.
It is not possible to determine the extent that estimates of costs for individual noise
treatment hardware contributes to the differences in estimated truck price increases, since
estimated costs for individual noise treatment hardware were not presented by truck manu-
facturers in their public comments. EPA presented costs estimates for noise control hard-
ware for cooling, exhaust, engine and air intake noise treatment for trucks equipped with
gasoline engines and for trucks equipped with one of twelve diesel engine models [ 13]. The
engine models were selected to cover most of the presently available truck engines. Because
the costs of quieting trucks are largely dependent on the initial engine and exhaust noise
levels, the estimates of price increases were organized according to engine type and model,
instead of truck model. The EPA estimates of price increases are based on cost estimates
presented in the DOT Quiet Truck Program, truck manufacturer’s estimates of price in-
creases for individual noise treatment hardware, and list prices for hardware currently in
production.
All of the design levels for each truck component noise level are low enough to allow
trucks to comply with not-to-exceed regulatory levels. The overall design level is 2-3 dBA
below the regulatory level [ 131. Thus, EPA estimates of truck price increases take into ac-
count the necessity to design below regulatory levels.
A-5-5
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A markup on manufacturing costs of 50 percent, given for the Freightliner DOT Quiet
Truck [ 25], was used by EPA in estimating the price increases. It is believed that this factor
is sufficient to cover the increased costs for development, testing, and dealer/customer services
associated with noise treatment. The costs associated with compliance testing is treated sep-
arately and not included in the price increases presented in Table A-5.
The EPA estimates are given in terms of 1973 dollars. Recently, a high rate of inflation
has increased the dollar cost. In order to update EPA estimates for use in assessing the
economic impact, the estimates were multiplied by rates of wholesale price indices for 1973
and 1975 for the truck manufacturing industry. (See Appendix D)
Replacing a naturally aspirated diesel engine with a turbocharged engine was not found
necessary in order to comply with the proposed regulations (Section A-4.3.2). Therefore,
including the costs of turbocharging diesel engines in estimates of truck price increases (as
suggested by the American Trucking Association) is not necessary. However, differences
in truck prices with a turbocharged or naturally aspirated diesel engine can be determined
from engine prices and estimates of increases in truck prices given by EPA. (See Section 6)
Redesigning some truck cabs may be necessary to accommodate an engine enclosure
and/or a larger radiator. When an engine enclosure and larger radiator are required in trucks,
the cost of redesigning the cab is included with the cost of the engine enclosure. On heavy
trucks where only a larger radiator is needed, the increased cost of enlarging the cab to ac-
commodate the larger radiator is included with the cost of the cooling system treatment.
On medium trucks, a larger radiator should not require redesigning the truck cab. Thus, the
American Trucking Associations, Inc. is incorrect in commenting that EPA estimates of
truck price increases do not include the costs of redesigning the truck cab.
If 10 percent of new trucks are allowed to exceed the regulatory level by 2 dBA, as
suggested by the Ford Motor Company, the design levels necessary to comply with the pro-
posed regulations could be increased by about I dBA (Section A-3.2.4). Linear interpretations
of EPA estimates for the 83- and 80-dBA regulatory levels indicate that a l-dBA increase in
design levels should result in decreases in truck price increases of approximately $50 for gas-
oline trucks, and $100 for diesel trucks at the 80-dBA regulatory level. These estimates are
approximately half the estimated reductions in truck price increases for 90 percent compli-
ance given by Ford (with the exception of the estimates given for “Premium Diesel Trucks”
where Ford estimated a decrease of $588).
General Motors, Paccar, Freightliner, and EPA have presented estimates of truck price
increases for more than two regulatory levels, such that some indication on the rate at which truck
prices may increase with lower regulatory levels can be derived. In each set of estimates, the rate of
increases in truck prices with lower regulatory levels rises. Only the estimates by General Motors,
A-5-6
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however, confirm the comments made by International Harvester, White Motors, and the
American Trucking Association that there is a much faster rate of increased prices at lower
regulatory levels. The comments by White Motors and International Harvester are based on
costs estimates derived from participation in the DOT Quiet Truck Program. These costs
estimates are discussed later.
A significant rise in truck prices at lower regulatory levels may not occur for the follow-
ing reasons:
• The costs of some noise treatments, such as cooling system and engine treatments,
do not rapidly rise at lower regulatory levels, and
• The costs of treating sources other than the engine, cooling system and exhaust
system, do not increase rapidly for regulatory levels approaching 75 dBA.
The estimated costs of treatment of cooling system noise for heavy trucks is $110 for
the 83-dBA regulatory level, $125 for the 80-dBA regulatory level and $200 for the 75-dBA
regulatory level [ 1 31. The largest increase in incremental costs occur for the 83-dBA regula-
tory level because of the need for a fan clutch so that the radiator shutters can be removed.
Without this treatment, little fan noise reduction can be achieved. Also, the estimated costs
for engine noise treatments do not rapidly rise with larger noise reductions [ 13].
The noise sources needing treatment at the 83-dBA regulatory level are the cooling system,
the exhaust system, and the engine. At the below 80-dBA regulatory level, treatment of the
air intake is added, at an estimated maximum price increase of $30. Treatment of transmis-
sion noise (included in the treatment of engine noise with no price increase) is added for the
below 80 dBA regulatory level. Therefore, reducing the regulatory level to below 80 dBA
should not result in a large cost increase in treating additional noise sources which would
add to the rate of increased truck prices at lower regulatory levels.
In the DOT Quiet Truck Program, both International Harvester [ 12] and White Motors
[ 18] selected the “worst case” trucks for quieting, whereas Freightliner selected one with
more available space for the installation of noise treatment. All three participants in the
DOT Quiet Truck Program applied noise treatments to the selected trucks, without making
significant modifications to the truck cab. This may have placed some constraints on the
International Harvester and White Motors trucks for the space available for engine enclosures
absorptive materials, manifold mufflers and larger slower-turning fans which may have de-
creased the cost-effectiveness of the noise treatment. The Freightliner truck was less limited
for space.
A-5-7
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In the proposed regulations, the lead times for compliance to the 80- and 75-dBA regu-
latory levels should be sufficient to allow cab redesigns when necessary to accommodate noise
treatment in a more cost-effective manner. Since the Freightliner truck was not space-
limited (as should be the case for well-designed new trucks), the estimates of price increases
given for the Freightilner truck are believed to be a better reflection of the price increases
that should occur on new trucks built in compliance with the proposed 80- and below
regulatory levels.
The comment by the City of San Francisco applies to retrofitting buses and is difficult
to relate directly to the costs of manufacturing new quiet trucks.
Action in Response to Public Comment: The EPA estimates of truck price increases have
been revised in response to public comments and to include new information made available
since the publication of the Background Document to the proposed regulations [ 81. The
revised estimates are based, in large part, on documented data and are derived from specified
costs for individual noise treatments. These estimates are believed by EPA to be as accurate
as the available data on costs will permit. Further revision has been taken.
A-S. 1,2 Future Price Increases
Identification: General Motors Corporation (A-2. 1.5.22) commented that the decrease in
costs of noise treatment due to future improvements in noise control technology should not
be included in estimates of truck price increases. The costs of noise treatment hardware will
be reduced under full production, according to Professional Drivers (A-2.3.6.3).
Discussion: In the final estimates of truck price increases used in assessing the costs versus
benefits of the regulations, no assumptions were made on reductions in costs for improve-
ments in noise control technology or increases in the production of noise treatment hard-
ware. However, brief consideration is given to the possible reductions in costs which may
result in the future. One of the possible improvements in noise control technology is the
reduction in engine noise by redesigning engines. Estimates of truck price increases are
given with the assumption that diesel engine noise can be reduced to 77-dBA and gasoline
engine noise to 75-dBA in order to demonstrate the potential savings which may be rea-
lized with the reduction of engine noise. (See Section 6)
Little data exists on the reduction in costs to be realized under full production of noise
treatment hardware. However, some reductions should occur. In attempting to project the
potential reductions in truck price increases, EPA assumed that the costs of noise control
hardware, currently in production but not in demand (such as fan clutches and the best
available exhaust mufflers) will decline by 10 percent as a result of increased production.
A-5-8
-------
The costs of hardware not currently in production (such as manifold mufflers and engine
enclosures) will decline by 50 percent under full production. If the assumptions on the
reduction of engine noise and costs under full production prove to be accurate in the
future, the price increases for medium gasoline and heavy diesel trucks may decrease by
more than one-half, for heavy gasoline trucks, by more than two-thirds, and for medium
diesel trucks by approximately one-fourth.
Action in Response to Public Comment: Sensitivity of estimates of truck price increases to
assumptions on improvements in noise control technology and costs reductions under full
production have been briefly considered. However, the assumptions are to be verified and
estimates of price increases derived without these assumptions are used in supporting the
selection of the final regulatory levels.
A-5,2 CHANGES IN OPERATING COSTS
A-5.2.1 Losses in Revenue
Identification: Freightliner Corporation (A-2. 1.4.6) commented that noise treatment for the
75-4BA regulatory level will add 700 pounds to trucks resulting in losses of approximately
$1000 per year per truck in revenues for the bulk hauler. Donaldson (A-2.2.2.7) pointed
out that engine enclosures will reduce payload capacities. The truck owner, whose truck is
weight-limited, may lose $600 annually because of weight increases caused by the 83-dBA
regulation, and $1600 annually for the 80-dBA regulation, according to White Motor Cor-
poration (A-2. 1.10,5). The American Trucking Associations, Inc. (A-2.3.1. 11) commented
that the weight of noise treatment will affect the bulk haulers the most and that EPA has
not considered this point.,. Overdrive Magazine (A-2.3.5.i) claimed that increases in weight
for noise treatment will cause the following losses in revenues: for the general freight hauler,
$8 to 69 per year for the 83-dBA regulatory level, and $170 per year for the 75-cIBA regu-
latory level; and for the bulk hauler, $5 I to 445 per year for the 83-dIBA level, and $1000
per year for the 75-dBA level. W. S. Hatch Co. (A-2.3.4.2) claimed that the weight increases
due to noise treatment have a serious impact on the bulk hauler. General Motors (A-2.l.5.27)
pointed out that a 6½ percent reduction in cargo volume would result in bringing one of
their truck models into compliance with the 75-cIBA regulatory level.
Discussion: The average increased weight estimate for heavy diesel trucks complying with
the 83-dBA regulatory of 141 pounds can be determined by using the weight increases given
in Table 6-8 and Table 6-I and computing the population-weighted average. For the 80-dBA
regulatory level, an average increase in weight for heavy diesel trucks of 339 pounds can be
computed; and for the 75-cIBA regulatory level, 705 pounds. The value of 705 pounds of
increased wieght agrees with the value given by the Freightliner Corporation.
A-5-9
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For the bulk hauler, the loss in revenue per mile due to an increase in tare weight of 1
pound is estimated at $12.5 x 10-6 [ 25]. Using this factor, and an average mileage of
54,000 miles for heavy diesel trucks [ 61, the average loss in revenue for the bulk hauler
should be approximately $95 per year for the 83-dBA regulatory level, $229 per year for
the 80-dBA regulatory level, and $476 per year for the 75-dBA regulatory level. The esti-
mates are lower than the estimates given by Freightliner, White Motors, and Overdrive
Magazine. However, for trucks which accumulate over 100,000 miles or more annually in
the bulk hauling service, the losses in revenues may approach $1,000 as estimated by Freight-
liner and Overdrive Magazine.
For the general cargo hauler, the loss in revenue per mile due to an increase in tare
weight of 1 pound is estimated at $1.94 x 106. Using this factor, the average loss in revenue
for the general cargo hauler should be approximately $15 for the 83-dBA regulatory level,
and $74 for the 75-dBA regulatory level. These estimates are lower than the estimates
given by Overdrive Magazine.
It should be noted that the discussed losses in revenues would be eliminated with an
increase in the legal limits on the Gross Combination Weight (GVW) of 700 pounds or more.
The 6½ percent loss in cargo volume predicted by General Motors is a result of the
assumption that a remote cooling system will be required in back of the truck cab. The re-
mote cooling system, according to General Motors, is required to provide the necessary
cooling for a fully enclosed diesel engine. However, projected reductions in engine noise
without enclosure techniques (Section A-4.3.3) indicate that full enclosures will probably
not be used in complying with the 75-dBA regulatory level in 1983. Therefore, the loss in
cargo volume caused by the remote cooling system will probably not occur on most trucks.
Action in Response to Public Comment. The presented estimates for average losses in
revenues caused by increases in tare weight are, in general, lower than the estimates pre-
sented in public comments. However, since the above estimates are based on data presented
in the DOT Quiet Truck Program and documented average annual mileage figures, these
estimates should be more representative of the actual losses in revenues which will occur as
a result of the regulations. No further action has been taken.
A-5.2.2 Changes in Rates of Fuel Consumption
Identification: Donaldson (A-2.2.2.7) commented that engine enclosures will result in
losses in fuel economy. The estimates of fuel savings presented by the Department of
A-S-b
-------
•Transportation are too high, according to the American Trucking Associations, Inc. (A-2.3 1.9).
The DOT estimates of fuel savings were derived in support of an assessment of costs and
benefits of different regulatory options. The Federal Highway Administration, Ohio
(A-2.5.8.4) suggested that the changes in rates of fuel consumption be determined.
Discussion: The combined effect on the rates of fuel consumption of increases in tare
weight, increases in exhaust backpressure, and changes in accessory horsepower require-
ments produced by noise treatments have been estimated by EPA. (See Section 6) The in-
creases in fuel consumption produced by increases in truck weight and exhaust backpressure
are small compared to the decreases in fuel consumption produced by the reduction in ac-
cessory power requirements for more efficient and quiet cooling system designs or for cooling
systems equipped with a fan clutch [ 13].
The estimates of fuel savings in Section 6 indicate that the American Trucking Associa-
tions, Inc. is correct in that the DOT estimates of fuel savings are too high.
Action in Response to Public Comment: Estimates of changes in rates of fuel consumption
and associated costs for trucks complying with the proposed regulations have been presented.
No further action has been taken.
A-5.2.3 Fuel Savings for Fan Clutches
Identification: Freightliner Corporation (A-2. 1.4.8) and Paccar, Inc. (A-2.l .9.6) commented
that fuel savings from the use of fan clutches should not be credited to the noise regulations,
since fan clutches will be widely used without the regulations. Freightiiner claimed that the
need to conserve fuel will also encourage the use of fan clutches. In addition, the proposed
test (which does not permit testing with the fan off) removes the advantage of using fan
clutches in complying with the proposed regulations, according to Freightliner. General
Motors (A-i 1.5.24) included the costs of fan clutches in estimates of increases in truck
prices, but did not include the savings in operating costs from fan clutches. According to
General Motors, there is not enough data on fuel savings.
Discussion: Fan clutches will be used on most heavy trucks, in order to remove radiator
shutters. When closed, radiator shutters prevent significant reductions in fan noise by means
of improvements in fan and fan-shroud design. Since most new medium trucks are not pre-
sently being equipped with radiator shutters, fan clutches are not needed. Fan treatments,
less costly than fan clutches, will probably be used on most medium trucks, even if fan-off
testing is permitted. Savings in accessory horsepower requirements will result from improved
cooling system designs on medium trucks [ 1 3].
A-5-l 1
-------
On heavy trucks, savings should occur because the fan clutch will disengage when the
fan is no longer required for cooling. Based on field tests, such as the tests on the Freight-
liner DOT Quiet Truck, the fan will be off more than 99 percent of the time during normal
operation [ 19]. Comments presented by Rockford Clutch in the public hearings in Arlington,
Va. also indicated that the fan will be off most of the time.
Changes in rates of fuel consumption have been estimated by EPA with and without
claiming credit for the savings from more efficient fans and fan clutches [ 13]. Using these
figures, changes in operating costs have been estimated with and without claiming credit for
the fuel savings from more efficient fans and fan clutches, The actual changes in operating
costs associated with regulations will be in between these two cost estimates, since, in the
absence of noise regulations on truck noise emissions, other concerns, such as the need to
conserve fuel, will encourage the use of more efficient fans and fan clutches. In order to be
consistent, the costs of more efficient fans and fan clutches were not included by EPA in
estimating the costs of compliance, when credit for savings was not taken. (See Section 6).
Action in Response to Public C’orninent: EPA has estimated the costs of compliance with
and without claiming credit for fuel savings from the use of more efficient fans and fan
clutches. No further action has been taken.
A-5.2.4 Changes in Maintenance Costs
Identification: The Federal Highway Administration, Ohio (A-2.5.8.2) suggested that the
estimates of changes in operating costs should take into account increased costs for main-
tenance. Donaldson (A-2.2.2.7) commented that engine enclosures will increase main-
tenance costs. Chrysler Corporation (A-2.l.l.5) claimed that noise treatment for the 80-c IBA
regulatory level will cause an increase in annual maintenance costs of $800 per truck. For
diesel trucks, the average increases in annual maintenance costs per year will be $179 for the
83-dBA regulatory level, $304 for the 80-dBA level and $305 for the 75-dBA level, accor-
ding to General Motors (A-2. 1.5.26). These estimates include increased labor costs for or-
dinary maintenance and replacement parts.
The Regular Common Carrier Conference (A-2.3.7.l) commented that truck rnanufac.
turers’ estimates of increases in annual operating costs may be higher than EPA estimates
because the manufacturers considered the increase in needed maintenance as the truck ages.
The Regular Common Carrier Conference added that the costs of repairs for fan clutch
failures should be included in estimates of changes in operating costs. The American Truck-
ing Associations, Inc. (A-2.3.I . 10) suggested that the costs per increased failure for engines
with close-fitting pistons need to be included in the estimates of costs of compliance.
A-5-12
-------
Discussion. Changes in maintenance costs, including increases associated with engine enclo-
sures, have been included in the estimates of changes in operating costs [ 131. For heavy diesel
trucks, EPA estimates of changes in annual maintenance costs are $-20 for the 83-dBA regu-
latory level, $32 for the 80-dBA level, and $180 for the 75-dBA level (See Section 6). These
estimates include changes in required maintenance labor and replacement parts. The savings in
maintenance costs associated with exhaust gas sealers [ 251 are included in the EPA estimates.
These savings may have been omitted in the estimates made by Chrysler and General Motors,
accounting for the differences between EPA, General Motors, and/or Chrysler estimates.
However, since increases in maintenance costs for each noise treatment were not given by
General Motors or Chrysler, it is not possible to identify the causes of differences between
the EPA, General Motors, or Chrysler estimates.
The EPA estimates for changes in annual maintenance costs are for the average change
in costs over the life of the truck. Thus, the EPA estimates do include increase in maintenance
costs as the truck ages.
The comment by the Regular Common Carrier Conference that fan clutch failures will
increase costs is probably based on earlier experiences with fan clutches with high failure
rates. In the public hearings in Arlington, Va., Rockford Clutch commented that cur-
rent fan clutches are reliable. Therefore, significant increases in maintenance costs are not
expected to result from fan clutch failures. The part which causes the fan clutch to fail on the
Freightliner DOT Quiet Truck has been redesigned for future manufacture [ 1 91.
In estimates of costs, EPA did not include the costs for internal modifications to
quiet diesel engines. Existing engines were assumed to be used in estimating truck price in-
creases. Therefore, the changes in maintenance costs due to potential increases in failure
rate of modified engines with close-fitting pistons are not included in the EPA estimates of
changes in maintenance costs.
Action in Response to Public Comment: Estimates of changes in maintenance costs for
the proposed regulations have been revised. The revised estimates are based on documented
data from the DOT Quiet Truck Program. No further action has been taken.
A-5.3 COSTS OF COMPLIANCE TESTING
Identification: General Motors, (A-2. 1.5.20), Paccar, Inc. (A-2. 1.95) and the Federal High-
way Administration, Ohio (A-2.5.8.3) commented on the costs of compliance. The fol-
lowing estimates of the cost for a site suitable for compliance testing were present in public
comments; General Motors — $286,000, Paccar — $147,000 to 346,000, Cummins Engine
Co. (A-2.2.l.5) — $150,000, and Koehring Company (A-2.2.4.2) — $500,000 to $1,000,000.
Independent testing would cost $1800 per truck according to Paccar. General Motors
claimed that a $500,000 facility would be required for development testing. For special
A-5-13
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purpose construction vehicles, the Koehring Company (A-2.2.4.3) estimated testing costs at
$2,935 to 11,380 per vehicle.
Discussion: The total annual costs of compliance testing has been estimated by EPA for
the truck manufacturing industry as $155,000 to $230,000 (Appendix H). With an annual
truck production of412,346 [ 8], the costs of testing would be $0.38 to 0.57 per truck.
Compared to other costs of compliance, such as truck price increases and changes in operating
costs, the cost for compliance testing should be negligible
The EPA estimates of the costs of compliance testing includes testing costs for produc-
tion verification and selective enforcement auditing, transportation to and from test sites,
and preparation of all reports required in the proposed regulations. Estimates were made for
individual truck manufacturers covering all but 4 percent of the industry.
The costs of facilities required for development testing are included in the markup of
the manufacturing costs of 50 percent to obtain price increases. (See Section 6).
The estimates of costs of testing presented by Koehring are for off-the-road construc-
tion vehicles and include costs of disassembling the vehicles for transportation to a suitable
test site. Such vehicles have been omitted from the regulations.
Action in Response to Public Comment: Estimates of the costs of compliance testing show
that these costs are negligible in comparison to other costs of compliance. No further action
has been taken.
A-5-14
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Appendix A-6
COSTS VERSUS BENEFITS
A-6.1 JUSTIFICATION OF COSTS AND BENEFITS
Identification: International Harvester (A-2. 1.6.1 3) commented that the initial price
increases far outweigh any benefits to the public welfare. According to the American
Trucking Associations, Inc. (A-2.3. 1 .12), costs rise exponentially as truck noise levels are
reduced, yet the benefits decrease to the point of little or no return. Ford Motor (A-2. 1.3.10)
claimed that the total cost of over 3 billion dollars for the proposed regulations is not worth
the 3 dBA reduction in community noise in 1990. Ford Motor Company (A-2. 1.3.19) added
that the nonsensitive observer requires 8 dBA to just detect an intensity difference of a pure
tone, and that the 75-dBA regulation will reduce individual truck noise by only 3.5 dBA at
highway speeds. Therefore, the noise reductions from the 75-dBA regulation will not be
noticeable. General Motors (A-2. 1.5.27) commented that the total cumulative costs for the
proposed regulations will be $16.2 billion in 1990, and the noise reduction will be 10.1 dBA;
whereas, the costs for an 83-dBA regulation will be $5.2 billion (or 32 percent of $16.2
billion) and the noise reduction will be 8 dBA (or 80 percent of 10.1 dBA). Therefore, the
additional costs of $1 1 billion for the small increase in benefits is not cost effective.
The Department of Transportation (A-2.5.4.17) presented estimates of the reduction in
the noise from urban street and freeway traffic for different regulatory alternatives. Using
the monetary value on urban property associated with changes in urban traffic noise of $20!
person/dB, monetary values for the estimated traffic noise reductions were computed by
DOT. For the proposed regulations, the costs estimated by DOT are greater than the mone-
tary value of the benefits, so that the proposed regulations are not cost-effective, according
to DOT. According to the analysis of the increasing marginal costs and decreasing marginal
benefits presented by the Council on Wage and Price Stability (A-2.5.6. 1), the 80-dBA and
75-dBA regulatory levels are not justified. The estimated benefits included changes in
property value and fuel consumption. The costs and benefits were cumulated by the Council
on Wage and Price Stability to the year 2000 and discounted at a rate of 10 percent to a
1975 present value.
In their response to the above comments, General Motors Corp. (A-2. 1.5.29) claimed
that the estimates of savings given by the Department of Transporation and the Council on
Wage and Price Stability are too high which led to overstatements of the benefits for differ-
ent regulatory alternatives.
A-6-l
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Discussion: The price increase given by International Harvester for a heavy truck
regulated at 80 dBA is $2150, one of the highest estimates given in the public comments for
a heavy diesel truck regulated at 80 dBA (see Figure A-i 1) and $1696 higher than the estimated
price increase given by EPA [ 41.
The population-weighted averages of EPA estimates of truck price increases and EPA
estimates of benefits in terms of traffic noise reduction given in Table A-6. 1 indicated that
the price increases become larger and the differences in benefits become smaller as the regu-
latory level is reduced. However, these estimates do not support the comment made by the
American Trucking Association, Inc. that the costs rise exponentially and the benefits de-
crease to the point of little or not return.
Table A-6.1
EPA Estimates of Costs and Benefits
Regulatory
Option
Average of EPA Estimates of
Truck Price Increases for
Lowest Regulatory Level*
Urban Street Traffic
Noise Reduction in l990
83dBAin 1977
83dBAin 1977
80 dBA in 1981
83dBAin 1977
8OdBAin 1981
75dBAin_1973
156
333
915
4.OdBA
5.2dBA
6.3dBA
*Wjth fan-off testing.
**Wjth a 4 dBA reduction in non-truck vehicle noise levels.
The 3-dBA figure quoted by Ford Motor Company as the reduction in the traffic noise
was taken from the EPA estimates of the traffic noise reduction associated with new truck
regulations and related to present traffic noise levels. However, a more realistic measure of
benefits is the difference in the projected change in noise levels with and without the pro-
posed regulations. In the revised estimates given by EPA the urban street traffic noise reduc-
tion is 6.3 dBA in 1990, more than twice the number quoted by the Ford Motor Company.
EPA has also revised the estimates of costs. The present value of the cumulative costs for the
proposed regulations is estimated to be approximately $3.2 billion in 1990 (See Appendix E).
Fuel savings from more efficient fans and fan clutches are not included in the EPA estimates of
$3.2 billion. Including fuel savings for more efficient fans and fan clutches, results in a savings
in the cumulative costs of approximately $2.2 billion instead of a cost of $3.2 billion. The
actual cumulation costs attributed to the regulations will fall in between these two estimates.
A-6-2
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Since the Ford estimate of costs fails close to the highest of the EPA costs estimates, the Ford
estimates of benefits appear to be low, they probably underestimated the cost-effectiveness
of the proposed regulations in their comments.
The comment made by Ford Motor Company on the detectability of an intensity
difference in a pure tone signal is not relevant to the exposure to truck noise. The human
response to the noise from a truck is not similar to the human response to a pure tone. In
many siutations, a single truck passby may raise the noise level above the background noise
by less than 8 d BA. However, since the noise is associated with a single identifiable source,
it usually produces greater distraction.
Even if an individual does not detect the XdB difference between two single-event
passbys, the statistical distribution of the entire population will be shifted XdB, and, hence,
benefits to the population will shift accordingly. It is inappropriate to compare single-event
judgements with statistically determined benefits to a large population.
General Motors based their comments on estimates of average traffic noise reductions and
total cumulative costs. Therefore, for the purpose of discussing the GM comments, estimates
of average traffic noise reductions and total cumulative costs have been computed from the EPA
analyses of benefits and costs for noise regulations on truck noise emission, using the same cumu-
lative procedure as GM even though this is not a significant number. As noted in Section A.3 .3.2,
a more representative measure of benefits than the reduction in average traffic noise levels is the
equivalent number of people impacted (Peq) . Also, the cumulative costs are properly represented
in terms of present value or uniform annualized costs (See Section A.7.7 .3). For example, the
present value for the proposed regulations cumulated to 1990 is $3.2 billion which is the number
corresponding to the $8.0 billion in the table (See Table A-7.l). The appropriate measures, based
on standard financial procedures, were used by EPA in selecting the final regulation.
A comparison of the EPA and GM estimates of reductions in urban street traffic noise levels
and cumulative costs are given in Table A-6.2. The GM estimates of benefits and costs are both
higher than the EPA estimates. For the EPA estimates, the ratio of the increase in costs to the
increase in noise reduction for the proposed regulations compared to the 83 dBA in 1977 regulation
is $2.6 billion/dBA. The corresponding figure computed from the GM estimates is $5.2 billion/cIBA,
which is twice the value computed from the EPA estimates. EPA does not consider that the ratio
dollars per dBA is a useful or significant number. It is presented here only for the purpose of com-
paring GM ’s computations and EPA’s. As discussed in Sections A .3 .2.2, A.5. 1 .1 and A.7 .7.3, the
estimates of benefits and costs given by EPA have been revised. The revised estimates are based
on documented data and modeling techniques which are more representative of the total populations
of the people impacted by truck noise and the trucks subjected to ‘the regulations than the model-
ing techniques used by GM. Therefore, the EPA estimates are probably more accurate than the
GM estimates.
A-6-3
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Table A-6.2
Comparison of EPA and General Motors Estimates of
Costs and Benefits
Regulatory
Option
Cumulative Costs
to 1990
(Billion of Dollars)
Urban Street Traffic
Noise Reduction in 1990
(dBA)
EPA*
GM
EPA
GM
83dBAin 1977
EPA Proposed
Regulations
1.9
8.0
5.2
16.2
4.0
6.3
8
10.1
*Without credit for costs and savings from more efficient fans, fan clutches and exhaust gas
seals. These estimates of cumulative costs represent less than 0.6% of the estimated total
trucking revenues cumulated over the same period of 1977-1990.
The Council on Wage and Price Stability assumed that the regulatory level will be
achieved on all trucks in the year in which the level becomes effective. This leads to an
overstatement of the benefits. Assigning a monetary value to the traffic noise reduction
in order to measure benefits can be misleading. Improvements in the quality of the environ-
ment, such as the reduction of noise, may not always be reflected in changes in property
values, as summed by DOT and the Council on Wage and Price Stability.
The total cost or saving estimates made by DOT for different regulatory alternatives
were based on the costs of quieting and operating the Freightliner DOT Quiet Truck. These
costs were applied to all medium and heavy trucks by DOT. The costs for medium gasoline
trucks, which make up over one half of the medium and heavy truck population, are signi-
ficantly different from the costs associated with heavy diesel trucks such as the Freightliner
DOT Quiet Truck [ 13]. The Council on Wage and Price Stability corrected this apparent
oversight by using the General Motors estimates of costs for medium trucks and DOT esti-
mates of costs for heavy trucks.
The DOT assumptions which have the most influence on the outcome of their analysis
are given below.
1. All trucks are operated 70,000 miles per year.
2. The power savings with the cooling fan off is 1 9.5 hp for all trucks.
A-6-4
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3. The price increase for trucks will be as given in Table A-6.3.
4. All new regulated trucks will be equipped with fan clutches and the resulting
savings can be credited to the regulations on new truck noise emissions.
In the cost-benefit analysis conducted by the Council on Wage and Price Stability, med-
ium trucks were assumed to average 35,000 miles per year and heavy trucks 70,000 miles per
year. The price increases of trucks assumed by the Council are given in Table A-6.4. Other-
wise, the DOT assumptions given above were used.
Table A-6.3
Estimates of Truck Price Increases Used in the DOT Analysis of Costs vs. Benefits
Type of Truck
Regulated Level
83 dBA
80 dBA
75 dBA
Medium Gasoline. . . .
Medium Diesel
Heavy Gasoline
Heavy Diesel
$329
$329
$329
$329
$1076
$1076
$1076
$1076
$1075
$1075
$1075
$1075
Table A-6.4
Estimates of Truck Price Increases Used in the Costs-Benefit
Analysis by the Council on Wage and Price Stability
Type of Truck
Regulatory Level
83 dBA
90 dBA
75 dBA
Medium Gasoline. . ..
Medium Diesel
Heavy Gasoline
Heavy Diesel
$ 25
$ 25
$329
$329
$ 130
$ 130
$1076
$1076
$ 350
$ 350
$1075
$1075
A-6-5
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In estimating the cumulative costs, EPA used the following assumptions. These assump-
tions are more detailed and appear to be more realistic than those used by DOT or the Coun-
cil on Wage and Price Stability.
1. The average annual mileage for medium gasoline trucks is 10,000 miles, medium
diesel trucks 21,000 miles, heavy gasoline trucks 18,000 miles and heavy diesel
trucks 54,000 miles. The annual mileage for each truck is a function of truck age,
decreasing with increasing age [ 8].
2. The power savings for a fan clutch is 15 hp for heavy trucks. It is assumed that
fan clutches will not be used on medium trucks for noise reduction. The power
savings for more efficient fans on medium gasoline used to comply with the
proposed regulations are as follows: for the 83-dBA regulatory level—2.5 hp, for
the 80-dBA level—4.5 hp, and for the 75-dBA level—6 hp. For medium diesel trucks,
twice the savings for medium gasoline trucks are used.
3. The price increases for trucks will be as given in Table A-6.5. These estimates are
based on the assumptions that trucks equipped with fan clutches will be permitted
to be tested with the fan off and that credit for the costs of fan clutches are
credited to the noise regulations.
4. The costs and fuel savings for fan clutches cannot be credited entirely to the noise
regulations. Other factors, such as fuel conservation, will encourage their use.
Table A-6.5
Estimates of Truck Price Increases Used in the Cost-Benefit
Analysis by EPA
Type of Truck
Regulatory Level
83 dBA
80 dBA
75 dBA
Medium Gasoline. . . .
Medium Diesel
Heavy Gasoline
He tvy Diesel
$ 35
$426
$125
$356
$180
$850
$255
$589
$ 665
$1624
$ 715
$1363
In their response to the comments by DOT and the Council on Wage and Price Stability,
General Motors suggested changes in the above assumptions that were in general agreement
with all of the EPA sssumptions; except, General Motors claimed that the price increases for
diesel trucks were understated by EPA, DOT, and the Council on Wage and Price Stability.
A-6-6
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The cumulative costs to 1 990 for the proposed regulations are estimated by EPA as
-$3.3 billion (a savings), when credit for the costs and savings from more efficient fans, fan
clutches and exhaust gas seals is included, and $8.0 billion without taking credit for more
efficient fans, fan clutches and exhaust gas seals. The actual costs that should be credited
to the proposed regulations will be in between these two estimates. The EPA estimates
differ significantly from the corresponding estimates given by the DOT ($9.1 billion) and
the Council on Wage and Price Stability ($13.8 billion) with credit for fuel savings. This
indicates that the result of the cost-benefit analysis is sensitive to the above assumptions,
Because the assumptions made by EPA are believed to be more realistic, EPA cost estimates
should be more accurate.
Action in Response to Public Comment: Based on the EPA analyses of costs and benefits,
regulations similar to those recommended by DOD have been adopted, with the intent of pro-
mulgating lower regulatory levels in the future. The recommendations made by the Council
on Wage and Price Stability based on their cost-benefit analyses have not been adopted, since
some of the key assumptions made in each analysis are subject to question. The recom-
mendation made by General Motors on the regulatory levels are based on estimates of
costs which appear to be high. Therefore, the GM recommendation has not been adopted.
A-6.2 OTHER REGULATORY APPROACHES
A-6.2.1 Stricter Enforcement of Existing Regulations
Identification: Donaldson Company (A-2.2.2.2) and Associated General Contractors of
Colorado (2.6.2. 1) commented that significant noise reductions will result from strict en-
forcement of the Interstate Motor Carrier Regulations. Lawrence Auerbach (A-2.4.2. 1) sug-
gested that strict eri forcement of existing regulations should accompany the regulations on
new trucks.
Discussion: EPA has made estimates of the benefits associated with the Interstate Motor
Carrier Regulations. The reduction in equivalent number of people impacted Peq is
estimated by EPA to be 3.3 million for the Interstate Motor Carrier Regulations out of a
total of 37.3 million for existing conditions. Adding the proposed regulations is estimated
to produce an additional reduction in eq of 8.5 million in 1990, with the assumption that
there will be no reduction in the noise levels from non-truck vehicles. In making these esti-
mates, strict enforcement of all regulations is assumed. These estimates indicate that the
reductions in req’ resulting from the Interstate Motor Carrier Regulations will not be ade-
quate in the long term, and that additional reductions provided by the proposed regulations
on new trucks will be needed.
Lawrence Auerback is correct. None of these regulations will be effective without
strict enforcement.
A-6-7
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Action in Response to Public Comment: No further action has been taken.
A-6.2.2 Regulations on The Noise Source
Identification: The States of Delaware (A-2.5.3.2), Mississippi (A-2.5.13.3), Minnesota
(A-2.5.14.2), New Mexico (A-2.5.15.2) and Virginia (A-2.5.21.1), and the District of Colum-
bia (A-2.5.7. 1) commented that the height of truck exhaust stacks has an impact on the
effectiveness of roadside noise barriers and therefore should be addressed in the regulations.
Indiana (A-2.5. 10.1) suggested that the exhaust system should be required to be located
beneath the truck body. The Department of Transportation (A-2.5 .4.18) recommended
that EPA consider the benefits of using vertical vs. horizontal exhaust systems. Several
suggested advantages for each were offered by DOT.
Discussion: The height of the exhaust stacks will determine the location of the source of
exhaust outlet noise. For trucks regulated at 75 dBA, exhaust outlet noise is expected to be
approximately 65 dBA or below [ 131. At freeway speeds, truck tires, which typically have
levels of 81 dBA or greater [ 71 , will dominate the exhaust outlet noise by about 1 5 dBA
for 75 dBA regulated trucks. Therefore, near freeways where most roadside barriers are
used, the effectiveness of roadside barriers in attenuating the noise from regulated trucks
will not be significantly improved by lowering exhaust stack heights.
The suggestions offered by DOT should be useful to the manufacturer in meeting the
new truck regulations and providing other desirable characteristics, such as the reduction of
splash and spray visibility problems. However, since the regulations are based on noise emis-
sion performance, the type or location of the exhaust system should be left to the manu-
facturer.
Action in Response to Public Comment: The height of exhaust stacks or locations of ex-
haust systems is not treated in the noise emissions regulations on new medium and heavy
trucks.
A-6.2.3 Treatment of Noise Path
Identification: The Ford Motor Company (A-2.1 .3.17) recommended that a trade-off analy-
sis be performed on quieting truck versus using noise abatement along highways and in build-
ings.
Discussion: The insulation of all buildings and homes would probably be prohibitively ex-
pensive, offer no protection outdoors, and be very difficult for local jurisdictions to regulate
and impossible under the Noise Control Act for EPA to regulate. Using noise abatement
treatments, such as barriers, along urban streets, where the greatest noise impact in terms of
eq occurs, is not feasible. However, the use of noise abatement treatment along freeways
A-6-8
-------
is available for use near noise-sensitive areas. For these reasons, little attention was devoted
to the trade-off analysis suggested by Ford Motor Company.
Action in Response to Public Comment: No further action has been taken.
A-6.2.4 Control of Truck Use
Identification: Ford Motor Company (A-2.l.3.17) suggested that a trade-off analysis be con-
ducted on the benefits and costs of quieting trucks versus controlling the use of trucks. The
State of Delaware (A-2.5.3.3) recommended that some provisions be adopted for noise reduc-
tion of old trucks. According to Citizens Against Noise (A-2.4.3.3), regulations should be
adopted to force operators to retrofit all trucks: PROD (A-2.3.6.3) commented that after
promulgation of the proposed regulations, in-use regulations on interstate motor carriers
should be modified to bring the noise levels from old trucks closer to those of new regulated
trucks. California Highway Patrol (A-2.5.l.l) suggested that regulations on operational noise
levels be adopted to prevent truck noise levels from increasing with the age of the truck. A
night curfew on all trucks was recommended by Citizens Against Noise (A-2.4.3.4).
Discussion: Restrictions on truck usage is left to local jurisdictions by the Noise Control Act.
Local regulations on the use of trucks should be used in conjunction with national new truck
and Interstate Motor Carrier Regulations to provide greater protection against noise in noise
sensitive areas. The areas which are sensitive to noise can be better defined by local govern-
ments more familiar with the communities involved. A trade-off analysis of new truck regu-
lations versus regulations on the use of trucks, other than the estimates of costs and benefits
given by EPA for the Interstate Motor Carrier Regulations, is not required, since both local
in-use and national regulatory actions are needed and may be used to complement each other.
EPA is considering modifying the Interstate Motor Carrier Regulations in the future to
bring the levels closer to the new truck regulatory levels. This could be used to prevent sig-
nificant degradation of the noise levels required under the new truck regulations. Retrofit-
ting old trucks will probably be considered, although it should be noted that retrofitting
trucks is less cost-effective in reducing noise levels than including noise treatment in design-
ing and building new trucks. Therefore, the regulatory levels which require retrofitting
noise treatment should not be expected to be as low as regulatory levels for new trucks.
EPA has no legal basis in the Noise Control Act for setting a curfew on the operation of
trucks at night.
A-6-9
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Action in Response to Public Comment: Modifying the Interstate Motor Carrier Regulations
to bring the regulatory levels closer to those in the new truck regulations are under considera-
tion by EPA. Other regulatory actions on truck use are left to local jurisdiction.
A-6.3 REGULATORY STRATEGY
Identification: Ford Motor Company (A-2. 1.3.1 8) recommended that the regulations on
new trucks be delayed until the effects of the Interstate Motor Carrier Regulations can be
assessed. Mack Trucks, (A-2.L7.2), Donaldson Company (A-2.2.2.9), the American Truck-
ing Associations (A-2.3. 1.11), and the U.S. Chamber of Commerce (A-2.6.4.4) suggested that
the effect of the 83 dBA new truck regulation be assessed before adopting the 80dBA new
truck regulation. Intemational Harvester (A-2.1.6.13) recommended that the 80-dBA regu-
lation be delayed until 1983 and the effect of the new truck regulations be re-evaluated in
1979.
According to Paccar, Inc. (A-2. 1.9.7) regulating medium and heavy trucks separately
should be used to increase the ratio of the benefits and costs, since medium trucks impact
an estimated 34.6 million, whereas heavy trucks impact an estimated 2.7 million.
Discussion: Setting and assessing the effects of each regulatory level on trucks, one at a
time, would delay the achievement of the ultimate goal of removing the noise impact pro-
duced by medium and heavy trucks. Time would be needed to perform an assessment of
the effects of each regulatory level, solicit and evaluate public comment, and provide suffi-
cient lead time for truck manufacturers to respond to the next regulatory level, The strate-
gy taken by EPA in the proposed regulations is to obtain the greatest protection of the
public health and welfare in the shortest time without imposing any unreasonable burdens
on truck manufacturers and users, or the national economy.
EPA estimated that the equivalent number of people impacted (Peq) by urban street
traffic is 34.6 million and by freeway traffic 2.7 million. In making these estimates, it
was assumed that medium and heavy trucks are part of both urban street and freeway
traffic. In their comments, Paccar, Inc. appears to have incorrectly interpreted the estimated
T ’eq for urban street traffic as the number of people impacted by medium trucks only and the
estimated eq for freeway traffic as the number of people impacted by heavy trucks only.
Therefore, the information presented by Paccar, Inc. cannot be used to justify regulating
medium and heavy trucks separately.
Action in Response to Public Comment: No change in the regulatory strategy taken by EPA
for new medium and .heavy trucks has been taken in response to public comment,
A-6-1 0
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46.4 NEED FOR STRICTER REGULATIONS
The issue of more lenient regulations is addressed in Section A-6. 1, “Justification of Costs
and Benefits”, where several of the public comments claimed that the benefits for the pro-
posed regulations do not justify the costs so that the regulations should be relaxed.
Identification: Alan Parker (A-2.4.5. I), the City of Chicago (A-2.5.2.2), the City of Des
Flames (A-2.5.5.1), Los Angeles County (A.2.5.12.2) and San Diego County (A-2.5.lS.2) all
recommended that regulatory levels similar to those of Chicago and California be adopted
by EPA. San Francisco (A 2.5.J9.I)commented that the proposed regulations are too
lenient. Texas (A-2.5.20. 1) suggested that lower regulatory levels and shorter lead times be
considered. According to New Mexico (A-2.5. 15.1), the regulations should be more in
keeping with the 70 dBA L 1 FHWA standards for residential, hospital and school areas.
Citizens Against Noise (A-2.4.3.2) claimed that the regulatory levels should be lowered to
bring truck noise levels down to the levels of automobiles.
Discussion: The Noise Control Act requires that EPA set standards which are requisite to
protect the public health and welfare and that EPA take into account the noise reduction
achievable through the application of the best available technology. EPA has identified out-
door noise levels with an Ldn equal to or less than 55 dBA as requisite to protect public
health and welfare with an adequate margin of safety [ I]. Using this level as a criterion,
estimates of the equivalent number of people impacted by urban traffic noise will be at least
11.5 million with the proposed regulations on new medium and heavy trucks in effect and
with noise levels from vehicles other than medium and heavy trucks reduced by 4 cIBA [ 13].
Using the same procedure, the existing eq of 37.3 million would be reduced by an esti-
mated 40 percent, if all noise from medium and heavy trucks was removed and other traffic
noise remained unchanged. If, in addition to removing all medium and heavy truck noise, a
reduction in noise levels from other traffic noise sources of 10 dBA is assumed, the eq
would be reduced by an estimated 95 percent. These estimates indicate that the regulatory
levels lower than those given in the proposed regulations are necessary to protect health and
welfare, as suggested in the above public comments. However, in the above argument, the
noise reduction achievable through the application of the best available technology was not
taken into account, as required by the Noise Control Act.
The proposed regulations can be met with the application of the best available tech-
nology (See Section ).
At this time, technology availability cannot be validated for regulatory levels lower
than 75 dBA or for a shorter lead time on the proposed regulations. Therefore, taking into
account the noise reductions achievable through the application of the best available tech-
nology will make it difficult for EPA to defend regulations which are more stringent than
those proposed. Further, the cost and economic impact resulting from various technology
applications must be considered by the Administrator.
A-6-l l
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It is difficult to relate the FHWA standards and the EPA regulations on new medium
and heavy trucks since the FHWA standards are given in terms of L 10 for all traffic and the
EPA regulations are given in terms of not-to-exceed levels for trucks under test conditions
designed to measure the maximum noise level. Since the median roadside level for 75-dBA
regulated trucks is expected to be around 71 dBA [ 13] and medium and heavy trucks will
make up about 7 percent of the traffic population on most streets in residential, hospital or
school areas, the EPA regulations should not violate the 70 dBA L 10 FHWA standards
For existing automobiles, roadside levels are about 65 dilA [ 13]. Therefore, in order to
reduce truck noise levels to the levels for automobiles would require lower regulatory levels
which may not be achievable using the best available technology.
Action in Response to Public Cotnnieni. The stringency of the regulations from those
proposed by EPA has not been increased because the technology may not be available for
compliance with more stringent regulations.
A-6-l 2
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Appendix A-7
ECONOMIC IMPACT
A-7.1 CURRENT ECONOMIC SLUMP
Identification: Ford Motor Company (A-2. 1.3.20) and Schwitzer Company (A-2.2.6.4) in-
dicated that the noise control costs will be an added inflationary burden upon the trucking
industry, which would make recovery from the recession more difficult.
The State of Louisiana (A-2.5.l 1.2) and the Associated General Contractors of Colo-
rado (A-2.6.2.4) expressed concern over the current state of the economy and asked that the
economic impact analysis be reassessed to take into account the current stat’e of the industry.
The U.S. Chamber of Commerce (A-2.6.4.8) claimed that the EPA economic impact analysis
on the proposed regulations is outdated.
Discussion: industry sales of medium and heavy trucks reached a peak of 446,793 in 1973.
In 1974 sales were only 420,534; down about 6%. Estimated truck production for 1975 was
down approximately 19% from 1974 levels. Truck registration figures* for the 10 months
through October 1975 show a substantial variation between manufacturers. Substantial
decreases occurred for all manufacturers. Con pared to the same period in 1974, the smallest
decrease occurred for Dodge (5%). Chevrolet, FWD, International and Western Star exper-
ienced decreases in the 20—27% range. Autocar and GMC experienced a 32% decline.
Brockway, Freightlin r, Kenworth, Mack, Peterbilt and White all experienced decreases
of over 40%.
The elasticity calculations for the change in demand for trucks given in Appendix C
indicate that although fewer trucks will be sold the net revenue to truck manufacturers
and employment in the industry are not likely to fall and will even increase under all regu-
lations (Tables 7-13 and 7-14). The extent of the adverse impact of the regulations should
therefore be limited to the increased inventory requirements for the more expensive
equipment.
* Registrations lag production so that increases in registrations will occur later than production.
A-7-1
-------
The state of the economy as a whole does have a direct effect on trucking and thus on
truck sales [ 8]. Price increases due to noise control equipment, however, are not likely to
exacerbate the cyclical downturn from the manufacturers point of view. In other words, it is
the demand for transportation services rather than the price of trucks which primarily deter-
mines truck sales.
Action in Response to Public Comments: The EPA economic impact analysis has been up-
dated to reflect recent economic conditions.
The inflationary effect on the economy as a whole, if manufacturers pass on 100 per-
cent of cost is discussed in Section 7. Due to the inelastic nature of the demand for trucks,
the manufacturing industry will not experience decreased revenue due to the regulation, as-
suming that all costs are passed on.
A-7.2 SUPPLY OF QUIET ENGINES
identification: Ford Motor Company (A-2.l.3.21) and International Harvester (A-2.1 .6.16)
indicated that manufacturers experienced a shortage of quiet diesel engines when the 83-dBA
regulatory level took effect in California and some other States. It was further asserted that
this condition would be amplified when the proposed EPA regulations increase the demand
for quiet engines. Oshkosh Truck Corporation (A-2. 1.8.2) commented that heavy truck
manufacturers will be dependent on the ability of engine manufacturers to produce quiet
engines.
Discussion: Brand loyalty amongst purchasers of trucks to particular engine manufacturers
is strong according to one truck manufacturer. In addition there is no company which pro-
duces only noisy engines. Therefore, it is not likely that individual engine manufacturers
will experience significant losses in sales due to the 83-dBA regulation.
However, for the 80- and 75-dBA regulatory levels, the demand for quiet engines should
increase. The 80-dBA regulatory level is proposed to take effect in 1982, thus allowing a
6-year lead time for development of quieter diesel engines. It has been estimated that engine
noise can be reduced by as much as 9 dBA without using enclosure techniques riol.
The Department of Transportation is sponsoring research to quiet diesel engines. The
results of this research are scheduled for availability to the public within the next 3 years.
Assuming that a 2-year lead time is required for implementation, the DOT-sponsored engine
quieting technology could be applied to increase the supply of quiet engines by 1982.
A-7-2
-------
Action in Response to Public Comment: Lead times appear to be adequate for diesel engine
manufacturers to meet the expected increase in demand for quiet engines for the 80- and
75-dRA regulatory levels.
A-7.3 SHIFTS IN BUYING HABITS
Identification: Ford Motor Company (A-2.1.3.22), Freightliner Corp. (A-2.1.4.9), Inter-
national Harvester (A-2. 1.6.15), and Mack Trucks Inc. (A-2. 1.7.9) stated that the adoption
of the proposed regulatory level will seriously limit their product line offering because
truck—engine configurations could no longer be marketed. According to these comments,
this impact is expected to be particularly severe when the 75-dl3A regulatory level takes
effect. General Motors (A-2. 1.5.30) asserted that the noise standards will cause major shifts
in buying habits. Federal Highway Administration, Ohio (A-2.5.8.7) pointed out that the
impact of relative cost increments for gasoline and diesel trucks upon buyer patterns should
be determined.
Discussion: Some trucks which comply with the 83-dEA regulatory level will probably cost
more than others [ 13]. However, the 83-dBA regulatory level applied nationally should not
force the elimination of any truck models, as suggested by International Harvester and
Mack Trucks. The lead times for the proposed 80- and 75-dBA regulatory levels provide suffi-
cient time for major truck redesigns where necessary, to accommodate noise treatments
(Section A-4.5.l) and avoid eliminating truck configurations.
At all regulatory levels medium diesel trucks experience the greatest price increase [ 131.
Heavy diesel trucks experience the second largest percent price increase at 83 dl3A but the
lowest at 75 dRA. Medium gasoline trucks experience large increases only for a 75-dBA
regulatory level. When no credit for the savings from more efficient fans, fan clutches, and
exhaust gas seals is taken, the changes in annual operating costs are less than $38 for all types
of trucks for the 83- and 80-dBA regulatory level [ 131. These small changes in operating costs
should not have a significant impact on buying habits. However, for a 75-dBA regulatory
level, the changes in annual operating costs are estimated to be $277 for medium diesel and
$180 for heavy diesel 113]. When credit for savings from more efficient fans, fan clutches
and exhaust gas seals are taken, a savings in operating costs occurs for all types of trucks,
except the medium diesel. These changes in price and operating costs are likely to have some
effect on the type of engine and truck chosen.
Medium diesel trucks have a relatively unimportant role in most sectors of the economy.
About half of the increased costs of medium diesel trucks will be borne by two sectors:
construction and for-hire (See Table 7.30). It may not be possible for the construction
sector to substitute gasoline for diesel trucks in many applications. Some substitution is
likely, however, in the for-hire sector.
A-7-3
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The largest potentialimpact of increased costs for medium gasoline trucks is in
agriculture. The price differentials between medium gasoline and medium diesel trucks
make any shifts away from gasoline trucks unlikely.
The construction and retail sectors each own 21 percent of all the heavy gasoline trucks
in use (See Table 7-30). Heavy gasoline trucks, however, represent almost half of the trucks
used by construction industry. No other sector depends on heavy gasoline trucks for more
than a quarter of its truck usage. The projected changes in both capital and operating costs
will tend to favor the use of heavy gasoline over heavy diesel trucks. However, the sector
purchasing the majority of heavy diesel trucks is the for-hire sector. This section is also
the most dependent on heavy diesel trucks. Costs for this industry are shown in Appendix G.
Due to the high mileage travelled by users of heavy diesel trucks, it is unlikely that a major
shift will occur.
A shift has been predicted from light-heavy to heavy-heavy trucks in order to reduce per
ton-mile operating costs [ 26]. The same argument would indicate a willingness to buy heavy
diesel trucks as long as their fuel costs per ton-mile is lower than for heavy gasoline trucks.
The EPA analysis of the economic impact of the proposed regulations does not include
the different demand elasticities for each type truck or the substitution of one type of truck
with another. Therefore, information on shifts in truck buying is not available. In order to
include the necessary level of detail, an analysis of the market by truck model would be re-
quired.
Action in Response to Public Comment: Estimates of the reduction in demand have been
made for medium and heavy trucks, assuming equal demand elasticities. Estimates of shifts
in truck buying have not been made.
A-7.4 IMPACT UPON TRUCKING COMPANIES
Economic impact of the noise regulation upon the trucking companies is examined in
this document. Issues relating to profits and competition were of particular importance to
trucking companies and trucking associations.
A-7.4.1 Profits
Identification: The Overdrive Magazine (A-2.3.5.4) made the assertion that increases in truck
costs will reduce profits for truckers and make it difficult to obtain necessary loans. The non-
availability of loans will foke many truckers out of the trucking business, according to Over-
drive Magazine.
Discussion: The impact on total trucking revenues and operating margins has been considered
by EPA (Tables 7-25 and 7-26). The for-hire sector was considered separately (Appendix G).
The financial problems and the economic outlook for the industry are discussed.
A-7-4
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The ability to obtain loans is directly related to the financial strength of a particular
company as well as access to money markets. Certain segments of the industry are in financial
distress. The price increases which will occur in 1977 (only 1-1/2 years after the economic
trough for trucking) are relatively small. However, economic conditions at the time when
the other regulations come into effect are likely to be far more important determinants of the
ability of truckers to obtain loans, than the price increases due to noise control. A tight money
market could make financing hard to obtain.
Action in Response to Public Comment: Ensuring that rate increases coincide with cost in-
creases will avoid a heavy drain on truckers’ cash resources. Means to assist truckers to ob-
tain loans in a competitive money market should be considered. Because of the relatively low
rates of return in trucking, the industry is particularly sensitive to high interest rates. Rate
increases should be allowed which provide for these interest payments as well as the capital
costs.
A-7.4.2 Small & Independent Truckers Position
Identification: The Overdrive Magazine (A-2.3.5.6) asserted that the EPA had not determined
• the economic impact upon independent truckers, who in the magazine’s opinion will suffer
the most. The proposed regulations could reduce profitability, which could force some small
truckers out of business, according to Overdrive Magazine (A-2.3.5.4) and the U.S. Chamber
of Commerce (A-2.6.4.7). According to the, Regular Common Carrier Conference (A-2.3.7.3),
operators cannot afford current increases in truck prices and the noise regulation will make
conditions worse for truck operators.
Discussion. This document covers all types of trucking. The problems of the smaller
companies are discussed (See Section 7).
It is generally accepted that a small company may not be able to absorb costs as readily
as a large one. Small trucking companies (including owner-operators) tend to have poorer
credit ratings, less sophisticated accounting practices, and pay higher prices for fuels and parts.
Their operating margins are smaller (Table 7-27) than those of the large companies. Given
these disadvantages, an increase in the price of trucking services may have a greater impact
on small companies than on large ones. Many trucking companies were operating very close
to break-even in 1974 and 1975. Obviously, even a small delay in passing on costs, can have
an impact on companies in this position.
If rate increases are granted rapidly and loans can be obtained, the small trucking com-
panies should not feel too great a burden. They may, however, have to pay a premium for
funds which larger, more-profitable companies do not. Smaller bank loans, in general, carry
higher interest rates [ 27]. The rate increase should take this into account.
A-7-5
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Action in Response to Public Comment: If timely rate increases are granted to cover costs
due to noise treatment, little impact on small trucking companies should result. Therefore,
the Interstate Commerce Commission should be aware of the increased costs which are likely
to occur.
A-7.5 IMPACT ON TRUCK MANUFACTURERS
Identification: The Koehring Company (A-2.2.4.5) claimed that the proposed regulations
could put some truck manufacturers out of business. Crane Carrier Company (A-2.l .2.1)
commented that the small truck manufacturer would experience a greater economic impact,
since the small manufacturer cannot compete with larger manufacturers for the required
technical talent. The small manufacturer depends more on the specialty truck market that
is more sensitive to price increases, according to the Crane Carrier Company.
Discussion: The elasticity of the truck market is such that truck price increases, when passed
on to the truck purchasers, result in increases of revenue to the truck manufacturers. (See
Table 7-13). Some increase in the amount of financing required for inventories is likely,
however. This will affect cash flow to some extent. The proposed regulations are not
likely to put any truck manufacturers out of business, as long as all costs are passed on.
The demand for specialty trucks is estimated to be less sensitive to price increases than
the demand for general-purpose trucks. The sales of specialty trucks are more sensitive than
the sales of general-purpose trucks to the conditions of the sector of the economy in which
they are used. For example, sales of trucks for use in the construction industry are con-
trolled to a large extent by the economic conditions of that industry.
Some of the technology required for compliance has been or will be made available to
the public through research sponsored by the Federal government. Examples of such research
include the DOT Quiet Truck Program and an ongoing program to reduce diesel engine noise.
Research sponsored by the Federal government should reduce the costs to small truck manu-
facturers for obtaining technical assistance.
Action in Response to Public Comment: A serious economic impact on truck manufacturers
is not expected.
A-7.6 IMPACT ON STATE HIGHWAY NOISE TREATMENT PROGRAMS
Identification: The savings to States for highway noise treatments, such as noise barriers,
and in the values of private property, should be included in the analysis of the economic im-
pact of the proposed regulations, according to the States of Delaware (A-2.5.3.4), Mississippi,
(A-2.5.13.4) and New Mexico (A-2.5.l5.3). New Mexico added that highway noise barriers
A-7-6
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cost about $1 00/foot. The State of Texas (A-2.5.20.2) suggested that the impact on State
governments providing highway noise treatments during the period before EPA regulations
become effective, should be addressed.
Discussion. The States of Delaware, Mississippi, and New Mexico are correct in suggesting
that some savings in highway noise treatments should result from the EPA proposed regula-
tions. However, because such treatments are used primarily in local areas where the noise
impact is high, the total costs nationwide for such treatment are impossible to predict accur-
ately. Some treatment will still be required in addition to the EPA regulations in order to
provide sufficient protection in certain situations, particularly along freeways where tire noise
dominates.
The Department of Transportation considered the effect of the regulations on property
values. However, as discussed in Section A-6.l, assigning monetary values (in terms of changes
in property values) to the benefits to the public welfare can be misleading.
The lead times in the proposed regulations have been selected to provide adequate time
for truck manufacturers to comply with the regulations. Decreasing the lead times to decrease
the burden on States for providing highway treatment, could have a serious impact on truck
manufacturers in attempting to comply with the regulations.
Action in I esponse to Public Comment: Estimates of costs to States for providing highway
treatments in situations of high noise impact are not included in the economic impact analy-
sis.
A-7.7 IMPACT ON NATIONAL ECONOMY
This part of the analysis of public comments is concerned with the national economy.
The comnientors expressed concern ranging from the inflationary aspects of the regulation
to cumulative costs of all Federal regulations that impact the trucking industry. The major
issues are discussed below.
A-7.7.l Inflation
identification: Freightljner (A-2.1.4.lO), General Motors (A-2.l.5.32), B. L. Atkins
(A-2.4.l.1), Paccar (A-2.1.9.8), White Motor (A-2.l.l0.4) and the U.S. Chamber of Com-
merce (A-2.6.4.6) expressed concern about the inflationary effect of the proposed regula-
tions. The Federal Highway Administration, Ohio (A-2.5.8.6) commented that the impact
of the proposed regulations on consumer prices should be determined.
A-7-7
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Discussion: The greatest inflationary impact is felt if all costs are passed on by each sector.
The inflationary effect thus shows up as an increase in truck transportation cost per dollar
of final demand The average percentage increase should be about 0.3 percent in the year
2000 (Table 7-29). The largest increase will be experienced by the miscellaneous mining
sector. This will be 0.19 cents per dollar of final demand. Other increases are around
0.01 to 0.03 cents per dollar (Table 7-29).
Action in Response to Public Comment: The inflationary impact has been estimated by EPA.
No further action has been taken.
A-7.7.2 Inflation Impact Statement
Identification: General Motors (A-2.l.5.33), International Harvester (A-2.l.6.14), White
Motor Corp. (A-2.l.lO.8), Gifford Mill Company (A-2.3.3.l), Overdrive Magazine (A-2.3.5.5)
and the Motor Vehicle Manufacturers Association (A-2.6.6.4) requested an inflationary im-
pact statement. Overdrive Magazine added that the inflation impact statement should go into
greater depth than in the background document for the proposed regulations.
Discussion: An inflation impact statement has been prepared by EPA, which goes into greater
depth than provided in the background document for the proposed regulations.
Action in Response to Public Comment: No further action has been taken.
A-7.7.3 Total Costs of EPA Proposed Regulations
ldentification. Table A-7. 1 presents the yearly and cumulative cost estimates of the proposed
regulation by General Motors (A-2.1 .5.31) and EPA. GM contended that the costs are un-
precedented in their magnitude and will contribute to inflation. The Department of Trans-
portation (A-2.5.4.19) claimed that the total cost estimated by EPA cannot be used to assess
the economic impact, since the EPA estimates do not include production tolerances. The
estimates of total costs should include agency costs for enforcement, manufacturers’ costs
and costs to small businesses and consumers, according to the Associated General Contractors
of Colorado (A-2.6.2.3). The Motor Vehicle Manufacturers’ Association (A-2.6.6.3) claimed
that the EPA estimates of cumulative costs are low since all of the costs incurred in the inter-
vening years were not taken into account.
Discussion: One of the sources of the differences between the GM and EPA estimates of
total costs is the differences in the computational procedures used in making the estimates.
EPA depreciated the costs of the truck over a 10-year period. GM accounted for the cost of
the truck at the time of purchase. For the purpose of this discussion, the EPA estimates of
A-7-8
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Table A-7.1
GM Forecasts Compared With EPA Forecasts of Total Costs
(Millions of Dollars)
Year
of
Purchase
GM Forecasts Figure VII-4, to
76
.
Recommend EPA Estimate
Option G*
Option E
Option A
Option G
Option E
Option A
1977
100.6
100.6
100.6
19.7
19.7
19,7
1978
141.2
141.2
141.2
39.4
39.4
39.4
1979
183.6
183.6
183.6
59.1
59.1
59.1.
1980
227.3
227.3
227.3
78.7
78.7
78.7
1981
272.5
459.1
459.1
98.0
131.2
131.2
1982
319.5
536.7
536.7
116.8
183.1
183.1
1983
368.4
617.4
1377.6
134.7
233.9
358.7
1984
418.9
701.2
1509.5
151.8
283.3
532.2
1985
463.0
779.9
1637.9
168.1
331.5
703.5
1986
508.7
861.8
1771.0
183.6
377.7
871.1
1987
527.6
919.0
1881.1
196.1
419.4
1,031.7
1988
548.6
978.5
1995.2
208.6
459.5
1,186.2
1989
569.8
1040.8
2113.9
221.2
498.3
1,333.5
1990
591.9
1105.5
2236.7
233.9
535.8
1,472.9
TOTAL
5,241.6
8,652.6
16,171.4
1,909,5
3,650.6
8,000.8
*Refcr to EPA Option in TabLe 4-1.
tWithout credit for costs and savings from more efficient fans, fan clutches and exhaust gas seals.
-------
total costs were recomputed using the GM accounting procedure for the cost of the truck.
With the GM accounting procedure, the EPA estimates of cumulative costs for the proposed
regulations increased by more than $ I billion.
Small differences result from slightly different projections of the truck sales for each
type through 1990. Although the same growth rates were used, different initial mixes were
used by EPA and GM. In the EPA estimates, the projected sales for each type of truck were
multiplied by the capital cost and projected interest cost to obtain the amount to be expended
in each year of the life of the truck. Changes in maintenance and fuel costs were computed
for each truck type based on mileage. Changes in fuel costs were not included in the GM
estimates of total costs. Total capital and operating costs were then summed to give the
total annual costs (See Appendix E).
For the proposed regulations, the cumulative costs for 1977-1990 given by GM is 16.2
billion dollars. The EPA estimates of cumulative cost is 8.0 billion dollars. The difference
in these estimates is due primarily to differences in truck price increases and changes in main-
tenance costs used by EPA and GM (See Sections A-5.l.l and A-5.2.4). When credit for the
costs and savings for more efficient fans, fan clutches and exhaust gas seals is taken, the EPA
estimates of the cumulative costs is —$3.3 billion (a savings). The cumulative costs which
should be credited to the proposed regulations is between the two estimates of $8.0 and
—$3.3 billion.
These cumulative costs should be compared with the cumulative revenues for trucking
as a whole for the same period (1977-1990). These are estimated to be $1,315 billion am
proximately (extrapolated using Table 7-22). The GM estimate of costs for Option A
represents 1 .23 percent fo the cumulative truck revenues. This, however, ignores the time
value of money. If we take the GM cost estimates for the proposed regulations (Option A)
discounted at 10 percent versus the revenues similarly discounted, costs are .97 percent of
revenues. The change is due to the fact that many of the substantial costs for noise treatment
are incurred in later years, particularly in terms of increased operating costs.
The GM estimates for the proposed regulations in 1990 are 1.92 percent of 1990
revenues. This ignores fuel savings which is likely to reduce this number to under 1 percent.
The EPA estimate of total costs for 1990 is 1.27 percent without allowing for fuel savings.
With fuel savings it is 0.10 percent.
The revised EPA estimates of total costs take into account production tolerances
needed to build trucks which comply with not-to-exceed regulatory levels. A tolerance of
2-3 dBA below the regulatory level was used by EPA. This tolerance is in agreement with the
tolerance suggested by everal truck manufacturers (Section A-4.4. 1).
A-7-lO
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The EPA estimates are for the total costs experienced by truck users. The costs may be
passed on, in which case, the costs will be incurred by small businesses and other users of
transportation services. The costs for EPA to enforce the regulations are estimated to be
small (Appendix H) compared to the costs to the truck users and therefore have not been
included in the estimates of total costs.
The original EPA estimate of the total annual costs in 1990 were $1 .1 billion for the
proposed regulations [ 8]. The revised estimate is $1.5 billion if no credit for any savings
in operating costs are taken. Therefore, the revised estimates of total costs with no credit
for savings are higher than the original estimates. In addition, estimates of the cumulative
total costs are given (See Appendix E), as suggested by the Motor Vehicle Manufacturers’
Association.
Action in Response to Public Comment: The estimated costs used by EPA differ from those
used by General Motors. The principal source of the differences between the estimates were
discussed. However, using the General Motors estimates indicates a limited inflationary impact.
Since fuel savings are not included in the GM estimates, the actual impact should be lower.
A-7.7.4 Cumulative Costs of alt Federal Regulations
identification: Mack Trucks (A-2.l.7.l0), Overdrive Magazine (A-2.3.5.3), Regular Common
Carrier Conference (A-2.3.7.4) and the U.S. Chamber of Commerce (A-2.6.4.9) state that
the cumulative costs of the recent Federal regulations on trucks have contributed signifiôantly
to increases in truck costs, and therefore, have contributed to the present recession. The
American Trucking Association (A-2.3. 1 .14) and Paccar, Inc., (A-2. 1 .9.9) stated that truck-
ing costs have already increased by 14 percent and $2,550 respectively, due to Federal
regulations.
Discussion. The cumulative costs of all government regulations on trucks has not been con-
sidered by EPA. Many different agencies are involved in promulgating these regulations.
There is a need to evaluate the proposed regulations on truck noise emissions in the light of
the impact on the economy of all government regulations on trucks. In addition to the cumu-
lative effect of Federal regulations on truck prices, the coordination of the effective dates in
Federal regulations could reduce the impact on manufacturers by decreasing the number of
needed model changes.
Action in Response to Public Comment: An interagency effort is needed to evaluate the
cumulative impact of government regulations on the trucking industry. These concerns will
be addressed as a part of the interagency/OMB review which will occur prior to promulgation.
A-7-1 1
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477.5 Research and Development Costs
Identification: The costs of the research and development should be borne by the entire
public, according to OverdrIve Magazine (A-2.3.5.2).
Discussion: Research and development costs that might be incurred by truck manufacturers
will be reflected in higher truck prices. It is expected that most of the increased capital and
operating costs of trucks can be passed along to the consumer and thus result in higher trans-
portation costs of commodities transported by trucks. Therefore, the entire public will bear
the noise costs. In addition, the Department of Transportation is sponsoring research and
development in quieting heavy diesel trucks and diesel engines. The DOT Quiet Truck Pro-
gram has produced 12 reports on noise treatments applied to three different heavy diesel
truck models.
Action in Response to Public Comments: The noise control costs will be borne to a sub-
stantial degree by the entire public in the form of higher prices for transported goods and
federal taxation to support research and development.
47.8 SECOND-STAGE MANUFACTURERS
A-7.8.l Motor Homes
Identification: According to Recreation Vehicle Industry Association (A-2.6.8.2) an esti-
mated 28 — 34,000 1975 model-year motor homes would fall into the 10,000 lb GVWR
category. This amounts to 12 to 15 percent of the trucks in the medium gasoline category
and about 35 to 40 percent of the total motor home market.
The industry association points out that there are a large number of motor home man-
ufacturers who are small in size and not likely to have sufficient funds for noise control re-
search, development, compliance testing, and certification. It was claimed that unequal
hardships would affect competition in the motor home industry.
Discussion: The major sources of truck noise are the engine, exhaust, and fan. These
sources will be treated by the chassis manufacturer. The Recreational Vehicle Industry
Association commented that mobile home manufacturers normally do not alter the engine,
cooling system, or exhaust system. In addition, chassis manufacturers should provide the
second-stage manufacturers with instructions on modifications that can be made without
affecting the noise emission characteristics of the vehicle. Therefore, the mobile home Sn-
ufacturers will not be required to make large investments for noise research and development.
47-12
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Before the chassis is delivered to the mobile home manufacturer, it is usually not
drivable. Therefore, it is difficult for the chassis manufacturer to test before delivery to the
mobile home manufacturer. Therefore, the mobile home manufacturer may have to perform
the required testing.
Action in Response to Public Comment: The requirements on the chasssis and mobile home
manufacturers in complying with the EPA regulations on noise emissions have been carefully
specified.
A-7.8.2 Specialty Trucks
Identification: According to the Donaldson Company (A-2.2.2.lO), the small manufac-
turer of special truck equipment will be subjected to unreasonable economic burden. The
Construction Machinery Company (A-2.3.2. 1) claimed that, if mixer mounters are included
in the regulations, the entire sales distribution pattern would be disrupted. The National
Solid Waste Management Association (A-2.6.7.2) suggested that the economic impact of the
regulations on small companies engaged in solid waste collection be carefully considered.
Second-stage manufacturers of solid waste disposal trucks cannot afford the costs of testing,
according to the National Solid Waste Management Association (A-2.6.7.3).
Discussion: Compliance with the proposed regulations are largely the responsibility of the
chassis manufacturer. The second-stage manufacturers will be required to comply with anti-
tampering instructions provided by the chassis manufacturer.
Truck-mounted waste compactors have been identified separately by EPA as major
sources of noise. EPA is investigating waste compactors for possible regulatory action. The
economic impact on these companies will be included in the EPA investigations.
Action in Response to Public Comment: Since most of the responsibility for compliance rests
with the chassis manufacturers, the impact on the second-stage manufacturers is expected to
be small.
A-7.9 OTHER ISSUES
A-7.9.l Impact on Local Areas
Identification: The Koehring Company (A-2.2.4.4) commented that the impact on local
areas of closings of truck manufacturing plants, that could be caused by the proposed regu-
lations, should be considered.
A-7-13
-------
Discussion: Total truck sales and employment by truck manufacturers should increase as a
result of the regulations (Section 7-2). Therefore, plant closings due to decreases in plant
utilization should not occur.
The Koehring Company mentioned that one truck manufacturing plant was closed be-
cause of the need to consolidate testing facilities required for the Federal brake regulation.
If the required testing for the EPA proposed regulations is performed at an EPA facility, the
total annual cost is estimated to range from $7450 for small manufacturers to $59,100 for
large manufacturers (Appendix H). These estimates include the production verification and
selective enforcement auditing testing costs and transportation costs to the EPA facility. The
cost of closing a plant is probably much higher. Therefore, the required testing should not
force plant closings.
Action in Response to Public Comment: No further action has been taken.
A-7.9.2 Impact on Postponing Regulatory Levels
Identification: Schwitzer Engineering Components (A-2.2.6.3) claimed that the costs will be
enormous if the 75-dBA regulatory level is established and then postponed.
Discussion: Schwitzer Engineering Components is correct in suggesting that there will be
added costs involved if a regulatory level below 80 cIBA is established and then postponed.
Postponing or removing the below 80 dBA regulatory level could impact the ability of truck
manufacturers to effectively recover investments in research and development. Disruption
of model changes, which must be planned at least 2 years in advance, could be effected by
postponing or removing the below 80 dBA regulatory level.
The recent experience of the air-brake standard indicates the problems which can occur
due to uncertainty about the timing of a proposed regulation. One company had over 28
production days of finished buses that met the new brake standard in inventory, before the
postponement came. There are difficulties in recovering the incremental costs incurred on
such inventory until the regulation comes into effect. If companies begin ordering parts and
modifying production schedules to meet a regulation, a postponement may be costly. Inven-
tories of parts and finished goods may become large. The lead time for a postponement should
be similar to that for any other model changed
Action in Response to Public Comment: The economic impact of any modification to the
regulations will be carefully considered by EPA prior to preparing a lower than 80 dBA
standard.
A-7- 14
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Appendix A-8
TEST PROCEDURE
INTRODUCTION
The National Bureau of Standards (NBS), in cooperation with EPA, has examined the
submission to the EPA docket and has contributed much to the response material in this sec-
tion (Appendix A-8).
In this chapter of the docket analysis, only those points having a significant impact on
the procedure are shown. Some of the changes offered by NBS are not included in the final
regulation due to inadequate supporting data or information. The overall testing procedure
does, however, Concur with the views of NBS.
A-8.1 Critique of Basic Test Procedure
Identification. International Harvester (A-2. 1.6.17) and White Motors (A-2. 1 .10.10) com-
mented that the test procedure should be improved.
Discussion: The Environmental Protection Agency (EPA) consulted with the National
Bureau of Standards regarding the test procedure which was suggested in the proposed
regulation. The Bureau of Standards made a series of suggestions for changes which were
adopted in the final version of the regulation. These changes are listed below:
Section 205.54-l(b)(1) in the proposed regulation has been replaced by: The test site
shall be such that the truck radiates sound into a free field over a reflecting plane. This con-
dition may be considered fulfilled if the test site consists of an open space free of large
reflecting surfaces, such as parked vehicles, signboards, buildings or hillsides, located within
30 meters of either the vehicle path or the microphone (Figure 10).
Section 205.54-l(b)(2) in the proposed regulation has been replaced by: The micro-
phone shall be located 15.2 ± 0.3 meters from the centerline of truck travel and 1.2 ± 0.1
meters above the ground plane. The microphone shall be oriented with respect to the
source so that the sound strikes the diaphragm at the angle for which the microphone was
calibrated to have the flattest frequency response characteristic over the frequency range
100 Hz to 10kHz.
A-8-1
-------
Section 205.5 4-l(b)(7) in the proposed regulation has been replaced by: The reference
point on the vehicle, to indicate when the vehicle is at any of the points on the vehicle path,
shall be the front of the vehicle except as follows. If the engine is located rearward of the
center of the chassis, the rear of the vehicle shall be used as the reference point. If the hori-
zontal distance from the reference point of the vehicle to the exhaust outlet is more than
5. 1 meters, tests shall be run using both the front and rear of the vehicle as reference points.
Section 205.54-l(b)(8)in the proposed regulation has been replaced by: The plane
containing the vehicle path and the microphone location shall be flat within ±0,05
meters.
Section 205.54-l(b)(8) in the proposed regulation has been replaced by: Measurements
shall not be made when the road surface is wet, covered with snow, or during precipitation.
Section 205.54-1(b)(9) in the proposed regulation has been replaced by: Bystanders
have an appreciable influence on sound level meter readings when they are in the vicinity
of the vehicle or microphone; therefore, not more than one person, other than the observer
reading the meter, shall be within 1 5.2 meters of the vehicle path or instrument and the
person shall be directly behind the observer reading the meter, on a line through the micro-
phone and observer. To minimize the effect of the observer and the container of the sound
level meter electronics on the measurements, a cable sound may be used between the micro-
phone and the sound level meter.
Section 205 .54 -I (b)(l0) in the proposed regulation has been replaced by: The maximum
A-weighted fast response sound level observed at the test site immediately before and after
the test shall be at least 10 dB below the regulatory level.
Section 205.54-l(b)(ll) in the proposed regulation has been replaced by: The road
surface within the test site upon which the vehicle travels) and, at a minimum, the measure-
ment area (BCD in Figure 10) shall be smooth concrete or smooth sealed asphalt, free of
extraneous material such as gravel.
A-8.2 Need for Stationary or Other Simpler Test
Identification: Mack Trucks (A-2. I .7 11) and White Motors (A-2. 1 .10.11) suggested that a
stationary test be included as a part of the enforcement of the regulations.
Discussion: There is limited correlation between stationary tests and drive-by tests. How-
ever, there is insufficient data to enable EPA to promulgate a regulation in which the
enforcement method utilizes a stationary test. The noise levels of new trucks tested under
A-8-2
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these conditions are not nearly as well known as under the low speed, high acceleration
test.
A-8.3 Test Site Specifications and Certification
Identification: General Motors (A-2.l.5.35), Mack Trucks (A-2.1.7.12) and White Motors
(A-2. 1.10.1 1) commented that the test procedure in the proposed regulations may produce
excessive variability in the test data and should therefore include test site correction factors.
Discussion: Test site variability is known to exist to some degree. However, research is
needed before correction factors and calibration procedures can be reliably established.
Until that time, the test procedure presently in use provides the most reasonable and accur-
ate measurement possible for all sites.
Action in Response to Public Comment: No change to the test methodology was made.
EPA clearly understands the problem and intends to work toward development of site
correction factors and calibration procedures where possible.
A-8.4 Corrections to Standard Conditions
Identification: General Motors (A-2. 1 .5.36) and White Motors (A-2. 1.10.13) pointed out
that the proposed regulations contains no provisions for correcting measured noise levels
to standard conditions of temperature, barometric pressure and humidity.
Discussion: This question is discussed briefly by NBS and they concluded that, “at the
present time, the data base is such that correction factors for temperature and barometric
pressure cannot be defined. Such corrections are needed and research to provide definition
of such factors should be given a high priority.”
In principle at least, the temperature, barometric pressure, and humidity can influence
the measured sound pressure levels in several ways:
• By modifying engine operation (e.g., combustion),
• By affecting sound propagation between the source and the measuring location,
• By affecting the measurement instrumentation.
A-8-3
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Action in Response to Public Comments: Standard conditions should be established
(e.g., 200 C and 760mm Hg). EPA intends to investigate the problem and work toward
development of ways to correct data to these standard conditions.
NBS supplied the following comment on this subject: If calibration devices are utilized
which are not independent of ambient pressure (e.g., a pistonphone) corrections must be
made for barometric or altimetric changes according to the recommendation of the instrw
ment manufacturer.
A-8.5 Engine Operating Temperature
Identification: White Motors (A-2.1 .10.14) suggested that testing take place with the engine
coolant at operating temperature.
Discussion: Trucks spend a very small percentage of operating time with engines below or
above their “normal” temperature. Thus, the cost and inconvenience of testing at a variety
of engine temperatures, in order to find the one at which maximum noise is produced, does
not seem worthwhile at this time. However, since measurable differences could occur, the
variance in the test procedure may be better controlled if engines are at normal operating
temperature during testing.
It may be assumed that truck manufacturers do not conduct tests in such a manner as
to result in engine overheating and possible damage. However, tests may be conducted by
personnel not under the manufacturer’s supervision. In most cases, a 1-minute cooling-off
period would not be needed, and if stipulated, would only increase testing time and cost.
Action in Response to Public Comment: NBS suggested that the text below be incorporated
into the test procedure and this has been done.
“The truck shall be brought to its normal operating temperature prior to
commencement of testing. During testing, appropriate caution shall be taken
to maintain the engine at temperatures within normal operating range.”
A-8.6 Operation of Thermostatic Fans and Radiator Shutters
Identificat ion: Freightliner (A-2. 1.4.11), General Motors (A-2.1 .5.37), International
Harvester (A-2.l .6.18), White Motors (A-2.l.10. 15), Schwitzer (A-2.2.6.5), Horton (A-2.2.8.1)
and Bendix (A-2.2.9. I) suggested that vehicles equipped with thermostatically controlled fan
clutches should be tested with fan off.
A-84
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Discussion. Considerable data exists demonstrating the small amount of time that a
thermostatically controlled radiator fan operates at or near maximum rpm (see Appendix
I). Their use also causes significant fuel savings to occur.
Statements have been made for allowing noise tests to be made with fans declutched
thus enabling manufacturers to use demand-actuated fans in conjunction with marginal
cooling systems that would require the fan to operate most of the time. However, at high-
way speeds additional cooling capacity of the fan is very small compared to the cooling
provided by “ram air.” Thus, the truck manufacturer must size his cooling system so that
the fan is really needed only under conditions of very low road speeds and high engine heat
output (e.g., long, slow hill climbs).
Action in Response to Public Comment: The regulation now allows vehicles with fan
clutches to be tested with the fan not operating. Thereby, an incentive is provided to use fan
clutches, resulting in lower noise output for the majority of the time and a fuel savings.
A-8.7 Deceleration Test
Identification: Chrysler (A-2. 1 .1 .6) and International Harvester (A-2. 1.6. 19) commented
that a deceleration test should be required only on trucks equipped with an engine brake.
Discussion: The comments that deceleration noise levels are below acceleration noise levels
for trucks not equipped with engine brakes are supported by discussions held between NBS
and others. NBS points out that the deceleration test procedure now specified in
J366b was added to fhe original procedure to address the problem of engine
brakes.
Action in Response to Public Comment: The deceleration test is now required only on
trucks equipped with engine brakes.
A-8.8 Instrumentation
Identification: International Harvester (A-2.l.6.20) and White Motors (A-2.1.lO.16) com-
mented that the instrumentation required for compliance testing should be more precisely
specified.
Discussion: The commentors are correct in that the instrumentation required for compliance
testing needs to be more precisely specified.
A-8-5
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Action in Response to Public Comment: The instrumentation required for compliance testing
has been more precisely defined. Sound level meters are required to meet ANSI Si .4.1971
specifications.
A-8.9 Repeat Measurements, Tolerances, and Round-Off
Identification: Chrysler (A-2. 1 .1 .7), Freightllner (A-2.1 .3.23), Mack Trucks (A-2. 1.7.13)
and Schwitzer (A-2.2.6.6) claimed that the round-off procedure and number of tests to be
used are not adequately described in the proposed regulations.
Discussion: The regulation now allows an unexplained, and unusually high noise measure-
ment to be deleted, and two other points to be those used for computing the average noise
level of one side of the vehicle. The points used must still be within 2 dB of each other, as
before. The new provision also limits the maximum number of measurements to 4 on each
side of the vehicle, to avoid unnecessary repetition.
With respect to variations in measured levels, much of the data upon which EPA bases
the analysis of economic and technical feasibility were subject to product variance and
measurement variance of roughly the same magnitude as that which will be in existence
after the regulation is in effect. The costs of complying with the regulation are closely tied
to these variances and hence to the position taken with regard to tolerances.
Action in Response to Public Comment: The entire question of measurement uncertainty
requires further investigation such that adequately precise measurements are made. These
are areas where the present information is too limited to make a major change to the pro-
posed regulation at this time.
A-8.lO Meter Response
Identification: B.F. Goodrich (A-2.2.3.2) commented that the “slow” meter response on the
sound level meter should be used.
Discussion: The comment refers to the measurement of tire noise and does not apply to
low speed, engine-related noise measured in the compliance tests in the proposed regulations.
Action in Response to Public Comment: The “fast” meter response is required on testing.
No further action has been taken.
A-8-6
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Appendix A-9
CLASSIFICATION
A-9.l Different Regulatory Levels for Different GVWR Categories
Identification: The State of Delaware (A-2.5.3.S) and the Associated General Contractors
of Colorado (A-2.6.2.5) suggested that trucks in different GVWR categories be regulated to
different noise levels.
Discussion: Data used in determining the classification system to be used in this regula-
tion shows that there are no reliable differences in noise levels between trucks of different
GVWR ‘s.
Action in Response to Public: No change in the classification of trUcks was made in
the regulations.
A-9.2 Vehicle under 10,000 lbs GVWR
Identification: San Diego County (A-25. 18.1) commented all trucks over 6,000 lbs GVWR
should be regulated.
Discussion: The lower limit for vehicles covejed by this regulation was set at 10,000 lbs be-
cause of the natural break occurring between light trucks/automobiles and medium/heavy
trucks. Also, this break occurs in industry, in many Department of Transportation safety
regulations, and in the Interstate Motor Carrier noise standards, recently promulgated by
EPA. The single, over 10,000 lbs classification allows a consistent and more simplified en-
forcement system, after the new trucks become “in use” trucks.
The proposed regulation allows other governments to set new product standards on
trucks under 10,000 lbs as well as allows the Federal Government to regulate the noise
emissions of new light trucks (less than 6,000 lbs.).
A-9-1
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Action in Response to Public Comment: The Preamble to the proposed regulation and the
Preamble to the final regulation adequately addresses this issue. No changes to the proposed
regulation were made.
A-9.3 Motor Homes
Identification: Chrysler Corporation (A-2.l.l.8) and the Recreation Vehicle Industry Associa-
tion (A-2.6.8.3) commented that motor homes should be excluded from the regulation.
Discussion: Motor homes are considered to be designed primarily for the purpose of trans-
porting one’s property (his living area), not necessarily just persons. They are, therefore,
defined under the definition of trucks and are covered by this regulation.
Action in Response to Public Comment: No change was made to the proposed regulation
regarding exclusion of motor homes from the regulation.
A-9.4 Special Purpose Equipment
Identification: The Department of Transportation (A-25.4-20) and the State of New York
(A-2.5.16.3) commented that special purpose equipment should be covered under the
regulation.
Discussion: The document which identified “New Medium and Heavy Duty Trucks” as a
major source of noise did not identify the various ancillary equipment carried on the differ-
ent trucks. Due to the facts that the various ancillary equipment is often not continuously
operated along roadways (as are the engine and drive train) and produces substantially differ-
ent acoustic emissions that may require development of new test techniques, the problems of
special equipment noise will be addressed in future regulations.
Action in Response to Public Comment: No change to the proposed regulation was made.
A-9.5 Buses
Identification: The Department of Transportation (A-2.5 .4.21) and San Diego County
(A-2.5.18.l) commented that buses should be included in the regulations.
A-9-2
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Discussion: The Preamble to the proposed regulation adequately answered this comment.
It is also discussed in the Preamble to the final regulation. EPA plans to regulate buses
separately.
Action in Response to Public Comment: No change to the proposed regulation is necessary.
A-9 -3
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Appendix A-1O
ENFORCEMENT
A-b .!
Several of the commenters questioned EPA authority to make broad inspections
and right to inspect and photograph records and information pertaining to a manufacturer’s
activities under the regulations. The commenters felt that such provisions allowed entry
into all areas regardless of whether the facility had anything to do with a manufacturer’s
noise control program.
The Agency authority for the inspection and monitoring section of the regulation
stems from the provisions in section 6 of the Act, which provides that any regulations may
contain testing procedures necessary to assure compliance with the noise emission standard;
and from the authority of section 13, which provides the Administrator the authority to
have access to information maintained by a manufacturer to enable the Administrator to
make a determination as to whether a manufacturer is acting or has acted in compliance
with the Act. EPA interprets the words “testing procedures” to include actions taken to
determine either directly, e.g., by emission tests or by inference, by examining the
conformity of the product to the information provided the Agency in the Production
Verification reports, whether the product is in conformity with the prescribed emission
standards. The regulations have been modified so as to limit the inspections and acquisition
of data to that information necessary for the Administrator to make a determination that
the manufacturer has been or is distributing conforming products into commerce. The
authority of EPA personnel is limited to examining records of tests conducted on production
verification products or products tested pursuant to SEA; inspecting areas where testing is
conducted, where vehicles are stored prior to testing, and inspecting those portions of the
assembly line where the products are being assembled. EPA has no interest in entry into
developmental laboratory areas or areas not concerned with a manufacturer’s activities
under the Noise Control Act of 1972.
A-i 0.2
Several.commenters were concerned with the Administrator’s discretion to refuse to
grant a hearing in situations in which orders were issued under section 11(d) of the Noise
Control Act.
A- 10-I
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The regulations have been modified so that in situations in which 11(d) orders are issued,
notification and opportunity for a hearing are afforded.
A-i 0.3
Several commenters criticized the attempt by the regulations to limit the right of counsel
and recommended that such limitation be stricken from the regulations.
As a result of those comments, portions of the regulations that, in fact, limit the right of
counsel have been deleted.
A-1O.4
Two commenters objected to the provisions in the proposed regulations requiring an
employee of a manufacturer to appear personally before an EPA Enforcement Officer on
the grounds that the provisions violated the basic principles of fairness and due process.
This portion of the regulation has been eliminated, since section 16(d) of the Act,
which provides that the Administrator may issue subpoenas for the attendance and testimony
of witnesses for the purpose of obtaining information to carry out the Noise Control Act,
provides the necessary authority to accomplish the Administrator’s purpose intended by the
proposed regulation.
A- 10.5
Several commenters felt that cease-to-distribute orders and recall orders went beyond
the statute and should be eliminated.
The Agency has interpreted section 11(d) of the Act, which provides for the issuance of
Administrative orders, as inclusive of the power U ’ issue cease-to-distribute orders and recall
orders. Any such orders would be preceded by notice and opportunity for a hearing.
A-iO.6
Two commenters suggested that the provision requiring a manufacturer to furnish free
reasonable assistance to EPA Enforcement Officers is invalid.
A-l0-2
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The scope and definition of reasonable assistance have been modified from that
contained in the proposed regulation. It is not anticipated that a manufacturer will incur
any cost in complying with the reasonable assistance requirements of these regulations.
A-I 0.7
two coffimenters suggested that because of the penalties provided for by the Act and
the cost associated with establishing and maintaining a test site it was their belief that EPA
must make a control site available to all persons affected by the regulations.
EPA is currently planning a noise enforcement test facility to be located in Sandusky,
Ohio. The facility will be used to conduct EPA required enforcement tests in addition to
conducting manufacturer requested tests. Such tests performed at the request of the
manufacturer will be accomplished at a reasonable cost to the manufacturer.
A-10.8
One commenter suggested that the regulations purport to pennit the Administrator
to superintend the manufacture of vehicles rather than control the distribution of such
vehicles into commerce.
EPA does not intend to interfere in the manufacturing process. EPA is interested only
in obtaining information as to the conformity of production products with the regulations.
The criteria that the vehicles selected for testing be built using normal production processing
does not “control” the production process and is included for the purpose of providing
assurance to the Administrator that tests are being performed on typical vehicles.
A-10.9
Many commenters requested that the definition of manufacturer be clarified in view of
the fact that there are many companies that install ancillary equipment, and it was unclear
as to whether these nonchassis/cab manufacturers were also responsible for complying with
the individual requirements of the regulation.
The regulations require that the first person who creates the entity that conforms to
the definition of vehicle is responsible for production verification and for complying with
the labelling requirements. Any person who performs subsequent manufacturing operations
on the new products after it has become a vehicle as described within these regulations need
A-I0-3
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not duplicate production verification or labelling operations. However, it is incumbent upon
this subsequent manufacturer to assure that his manufacturing operations do not cause the
product to exceed the prescribed standards or obscure or remove the required labels. In
order that the Administrator may determine the effect on the noise performance of the
vehicle, the subsequent manufacturer is subject to the selective enforcement audit of these
regulations.
A-i 0.10
Several commenters described the information recording and reporting requirements as
burdensome and costly.
The regulations have been revised so that most of the information required to be
submitted is sales literature that describes the product, and the amount of information to
be submitted with test reports has been substantially reduced. The regulations have also
been revised so that all data may be mailed to EPA as opposed to the proposed telephone
reporting requirements. The regulations have also been revised so as to permit execution
of reports required to be filed by a manufacturer’s authorized company representative in
lieu of a corporate vice-president as specified in the proposal. The final regulations also
provide that when information has been previously submitted and has remained the same,
subsequent reports need only refer to previous submissions.
A-10. li
Several commenters felt the cost of the administrative enforcement provisions would
be significant because of the large number of products that would be required to be tested
as a result of the production verification and audit test provisions and the need to construct
added test facilities to accomplish all the required testing.
EPA has reexamined the cost impact of the administrative enforcement provisions of
production verification and selective enforcement aiiditing and have again found them to be
reasonable. As a result of information gathered during the rulemaking process, which
included a public hearing and many written submissions to the docket, several modifications
were made to the regulations in the area of administrative enforcement provisions. These
modifications have made the PV and SEA process more flexible and tailored to an industry
with varied production loads and a varied product line. These changes have resulted in
reductions in cost to the manufacturer over those that would have been incurred based on
A-10.4
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the proposed regulations. Significant capital expenditures may be eliminated by those
manufacturers who avail themselves of the EPA enforcement test facility at Sandusky, Ohio,
in lieu of constructing additional facilities.
A- 10. 12
Several of the commenters recommended self-certification, as is now used under the
Motor Vehicle Safety Act, as a method of assuring compliance with the standards. Several
also suggested that if EPA believes that production verification testing is cost-effective, the
alternative proposal of testing a preproduction prototype could be adopted.
One manufacturer suggested that self-certification followed by selective enforcement
audit would provide the Administrator with an objective and cost-effective means of assur-
ing compliance.
The production verification concept embodied in these regulations is essentially a self-
certification approach. However, the compliance testing is required to be performed on
production units. The argued advantage of pre-production prototype testing is that it would
preclude a delay on the part of the manufacturer at the beginning of sales of a particular con-
figuration due to his inability to test because of inclement weather. These regulations
provide for a 45-day period in which conditional verification is granted by the Administrator
for a configuration pending completion of the required test.
This change is intended to resolve the concern about delays caused by weather and to
preserve the EPA desire that production units be tested to determine compliance.
A-i 0.13
One commenter suggested that the regulations compelled him to schedule the noisiest
configuration in a category for the first production.
Another commenter found that the configuration identified as having the highest sound
pressure level within a category most probably would not be the first configuration built
and, in fact, might not be built until some time late in the model year or perhaps not built
at all in that model year. The commenter suggested that the viable alternative was to allow
the manufacturer to production-verify the first configuration built in a category, in addition
to the requirement that he production-verify all configurations in a category that were known
or estimated to have higher sound pressure levels at the time of their actual production.
A-l0-5
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This would enable manufacturers to release some vehicles built-in categories that did not
have their loudest configuration production-verified, but however did have some configura-
tions verified.
The final regulations permit manufacturers to verify portions of categories based on
tests of configurations that are not the highest noise emitters of a particular category.
The regulations provide that a manufacturer may production-verify selected configura-
tions in any order he desires. That is, the manufacturer may, if he desires, select and schedule
for production the noisiest configuration, in which case all other configurations within a
category would be represented by that configuration, or he could wait until that particular
configuration was in fact produced and then test it. Intermediate configurations would be
production-verified as they are produced.
A-i 0.14
One commenter wanted to make clear that mass production does not necessarily mean
assembly line production in the heavy trucking industry. Off-line or end of assembly line
modification are common.
EPA does not intend to interfere with the industry’s normal mode of assembling or manu-
facturing trucks. It is the intent of EPA simply to test products when they have completed
the manufacturer’s assembly process regardless of what end of assembly line modifications
are required, as long as such procedures are part of the manufacturer’s normal mode of opera-
tion. It is the intent of EPA to require testing of vehicles that are complete.
A-i 0.15
Some manufacturers commented that production verification would delay and unnec-
essarily burden the manufacturer’s distribution process since distribution in commerce could
not take place until production verification has been completed.
The regulations have been modified so as to permit manufacturers to distribute vehicles
into commerce as soon as production begins. However, the requirement still remains that
the manufacturer must test certain of his early production models, for the most part the
loudest configuration of a category. However, this testing must now take place as soon as
weather conditions permit Within a 45-day grace period during which conditional production
verification is automatically granted.
A-lO-6
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This 45-day period is designed to accommodate a manufacturer’s transportation needs
and to provide for poor weather conditions. In addition the requirement that the manufacturer
provide 1 0-day advance notice of his intention to test has been removed.
A-I 0.16
Some manufacturers commented that the number of configurations available for sale
by them were extremely large and that an effort should be made to minimize the number
requiring testing.
One manufacturer suggested that the parameters designating a noise configuration be
limited to those that are significant factors in affecting noise levels. The EPA proposed
definition of configuration included a great number of unnecessary parameters.
Both the definition of category and configuration have been changed, with the defining
parameters significantly reduced. The agency has calculated, based on available information,
the total number of categories that would require testing if production verification is carried
out in accordance with these regulations and has found that it does in fact require only that
a nominal number of products be tested.
A-1O.17
Several manufacturers suggested the adoption of Military Standard 414 or some variable
tyve sampling plan in lieu of the proposed attributes plan.
An attributes-type sampling plan was proposed because it is independent of the under-
lying distribution of the data. Variables plans however are dependent on the underlying
distribution, and unless the distribution of noise data is normal, the use of a variables plan
in any strategy that determines the conformity ornonconformity of a manufacturer’s
product may not be correct. Several manufacturers provided data to the Agency tending to
demonstrate that the distribution of noise data was in fact normal. The Agency has further
analyzed such data and has determined that the evidence is not sufficient to warrant the
conclusion that noise data is distributed normally. In addition to this analysis, the Agency is
proceeding with the development of a variables-type sampling plan that may be proposed
for comment in the near future. The sampl ing plan promulgated in the regulations is
independentof the type of distribution that characterizes the data.
One of the chief advantages of a variables plan is that less testing is required to achieve the
same information about a sample population. The sampling plan promulgated in the regulations is a
A-l0-7
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modification of the attributes plan proposed several months ago. This plan provides for
situations in which production volume is small in addition to significantly reducing the
number of products requiring testing. Because of the small number of tests required under
the plan promulgated in the regulations, a shift to a variables plan could not be justified
on the basis of reducing test burden.
A-I 0.18
Several commenters interpreted the warranty required by §205.58-I to be a defects
warranty over the life of the vehicle.
The warranty required of the manufacturer is a performance warranty that the vehicle
meets the noise emission standards on the date of sale to the ultimate purchaser. Because
performance is warranted for the date of sale only, warranty claims must relate back to a
nonconformity on that day. To make the best case in relating back to the date of sale, the
claimant should be able to point to a defect in design, materials, or workmanship that existed
on the sale date and that caused noise emissions to exceed the standard. Thus, although the
claim may be made against the manufacturer at any time during the life of the vehicle, such
claim must relate back to noncompliance on the date of sale.
One commenter stated that to warrant compliance with noise emission standards, all
replacement parts must be supplied by the original manufacturer.
This comment reflects a misunderstanding of the warranty required. Because the
warranty covers the noise emission level on the date of sale only, replacement parts needed
after a period of use of tire vehicle would not normally be at issue under the warranty.
A-i 0.19
Some commenters asked for a definition of what constitutes tampering and whether the
use of aftermarket parts (parts not manufactured or authorized by the original equipment
manufacturer) would constitute tampering.
A list of acts that could adversely affect the noise control system of a vehicle and that
would constitute tampering, as determined by EPA, will be published in the owner’s manual.
This will give specific indications of those acts that will be considered tampering by the
Agency, unless it can be shown that noise emissions are not adversely affected by the act.
A-I 0-8
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In general, in terms of noise-related aftermarket parts, any nonoriginal equipment after-
market part (including a rebuilt part) may be installed in or on a vehicle subject to these regu-
lations if the installer has a reasonable basis for knowing that it will not adversely affect noise
emissions. For noise-related replacement aftermarket parts, a reasonable basis exists if (a) the
installer reasonably believes that the replacement part or rebuilt part is designed to perform
the same function with respect to noise control as the replaced part, or (b) the replacement
part or rebuilt part is represented in writing by the part manufacturer or rebuilder to perform
the same function with respect to noise control as the replaced part.
For noise-related, add-on, auxiliary, augmenting, or secondary parts or systems, a reason-
able basis exists if (a) the installer knows of noise emissions tests that show that the part does
not cause noise emissions to exceed the time-of-sale standards or to increase, if the noise
emissions already exceed the time-of-sale standards; or (b) the part or system manufacturer
represents in writing that tests have been performed with similar results (to (a) above); or (c) a
Federal, State or local environmental control agency with appropriate jurisdiction expressly
represents that a reasonable basis exists.
A-1O.20
Some commenters indicated that, in the tampering requirement, submission of informa-
tion 90 days before introduction of the vehicle into commerce represents an excessively long
time period for the manufacturer.
The 90-day requirement in the proposed regulations was established to allow EPA suffi-
cient time to evaluate the tampering data, to prepare a list of the acts that tampering enforce-
ment would focus on, and then to forward this list to the manufacturer for incorporation into
the owner’s manual. However, to account for the varying production schedules of manufac-
turers, the final regulation has been changed to allow for a time period based on the need of
the manufacturer. The regulation now requires that the manufacturer submit the requested
information within an adequate amount of time to provide EPA with 30 days to review the
data and to return a tampering list to the manufacturer for printing in the owner’s manual. If
the Administrator fails to provide the list to the manufacturer within 30 days of the date the
information was submitted, the manufacturer is not precluded from distributing the vehicles
into commerce. In this case, the list of tampering acts required in the owner’s manual shall be
omitted until the list is provided and the owner’s manual is otherwise reprinted.
A-lO-9
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A-I 0.21
Several commenters considered unreasonable and burdensome the requirements for the
submission of listings of noise control devices and elements of design (including performance
specifications) and acts that might constitute tampering.
The purpose of these requirements in the proposal was to enable the Administrator to
determine what acts will constitute tampering. Information submitted by the manufacturer
is not to be considered as a final judgment of what constitutes tampering, but will only pro-
vide the basic information for determination by the Administrator. The final regulations have
been modified so that no separate submission of the list of noise control devices and elements
of design is required: this is part of the information required to be provided in the product
verification report. The requirement for submission of noise-related performance specifications
has been deleted. The generation of the required information by the manufacturer can be
performed concurrently with the development of appropriate noise control systems. The
testing that will normally be performed in the development of the noise control systems and
the manufacturer’s engineering experience should provide a substantial basis from which the
required information can be generated.
A- 10.22
Some commenters stated that the requirement of issuing maintenance instructions
imposes a tremendous administrative burden upon the manufacturers.
The purpose of these instructions is to provide the purchaser with clear and simple pro-
cedures for the proper maintenance necessary to assure that degradation of noise emission
levels is eliminated or minimized during the life of the trucks, In the opinion of the Agency,
this requirements is not burdensome, because manufacturers presently provide purchasers
with instructions and recommended maintenance schedules necessary to keep the vehicles
in good operating condition. These required instructions would merely inform the purchasers
of the additional procedures and maintenance necessary to ensure that the noise control sys-
tern will operate as intended. Generally, the inforniation contained in these instructions will
be that information developed in the manufacturer’s program to design quieter vehicles and
that has been obtained from experience with in-use vehicles. Thus, there is generally no need
to obtain significant information not otherwise available.
A-lO-lO
-------
Appendix A-i i
MISCELLANEOUS
A-i 1 .1 Effective Dates
Identification: Ford Motor Company (A-2. 1 .3.24) commented that for the regulations
to have consistent impact on manufacturers, they should be effective on calendar years
instead of model years.
Discussion: Ford Motor Company justified their statement by the fact that exhaust emission
standards go into effect on a calendar year basis and accurate noise tests can only be run after
exhaust emission calibrations have been finalized. Having the two effective dates similar
would reduce testing requirements considerably. Also, diesel engine manufacturers work on
a calendar-year basis for changes they find necessary regarding exhaust emissions. Finally,
since the date of manufacture appears on a vehicle’s patent plate, enforcement on a calendar
year basis should not be difficult.
The manufacturer still holds the option of when to begin and end his model years. He
may begin his model years on January 1 and, by his own choice, be consistent with all other
manufacturers.
Action in Response to Public Comment: The regulation still requires model years as the
designator of the effective time of the regulation. However, due to delays in this final promul-
gation, the first standard (83 dBA) becomes effective on July 1, 1 977, instead of model year
1977, thereby allowing more time for compliance.
A-i 1.2 Highway Noise Treatment by States
Identification: The States of Minnesota (A-2.5.14.3) and Virginia (A-2.5.l.2) pointed out
that states must rely on highway noise treatments until the regulations on trucks become
effective.
Discussion: The proposed regulations were drafted considering the requirements to protect
health and welfare by reduction of the source limited by the ability of technology to comply
and the costs of compliance within a specific time period. The proposed lead times and sound
levels were derived using the above logic. The Noise Act further limits the Agency’ regulations
A-I 1-1
-------
to that covering specific products. No authority is granted for other areas such as noise bar-
riers and buffer zones. Granted, the levels will not satisfy all highway noise requirements,
but they are the best that can be achieved under the authority of the Noise Act, within the
constraints of technology and cost.
Action in Response to Public Comment: No further change to the regulation was made, as
the logic used in developing the regulation is stated in detail in the Preamble. Extensive back-
up data is presented in the Background Document sections on Technology, Economic Im-
pacts, and Health and Welfare.
A-i 1.3 Representation of Trucking Industry
Identification: The American Trucking Associations (A-2.3.l.15) asserted that the trucking
industry was not adequately represented during the development of the proposed regulations.
Discussion: The public has been invited to comment during the development of this regula-
tion by means of an Advanced Notice of Proposed Rulemaking, Notice of Proposed Rule-
making, and public hearings held in Washington, D.C. and San Francisco. EPA has examined
all comments received as a result of these formal actions and those received as other industry
and citizen inputs were obtained through less formal meetings. It is believed that adequate
opportunity for comment has been given to all parties.
Action in Response to Public Comment: No change was made to the proposed regulation as
a result of this issue.
A-i 1.4 Availability of Equipment and Acoustical Engineers
Identification: Buckeye Equipment Company (A-2.2. 11 .1) questioned the availability of
sufficient amounts of equipment and acoustical engineers, for use in quieting work.
Discussion: There are numerous large acoustical consulting firms presently in existence.
Should the market demand require expansion in order to assist truck manufacturers, there
will be no severe problem, given the presently proposed lead time.
Action in Response to Pub/ic Comment: No change was made to the regulation as a result
of this issue.
A-l1-2
-------
A-u.S Labeling
Identification: The State of Illinois (A-2.5.9.3) suggested that a label be attached to
regulated trucks which states the noise produced at the time of manufacture, GVWR, and
model year.
Discussion: The noise level produced at the time of manufacture is defined only when the
measurement methodology is also fully described. For this reason, it is deemed unadvisable
to place it on a label which could be misunderstood by local enforcement officers who are
unfamiliary with the correct testing procedure.
The GVWR and date of manufacture are obtainable from the vehicle registration
documents.
Action in Response to Public Comment: No change was made to the proposed regulation
as a result of this issue.
A-li .6 High Speed Standard
Identification: The State of New York (A-2.5. 16.4) suggested that the regulations include
a high speed noise level standard.
Discussion: The Preamble to the Proposed Regulation, section IlIe, suitably discusses the
reasons for not proposing a high speed standard at this time. Those reasons are: (1) tires
may be regulated at a later date, thereby aiding high speed noise abatement, and (2) the
Agency has already limited, to a degree, high speed noise by use of the Interstate Motor
Carrier Regulation; more quieting can be required only after additional cost and economic
impact analysis work is performed.
Action in Response to Public Comment: No change to the proposed regulation was made
as a result of this issue.
A-li -3
-------
REFERENCES FOR APPENDIX A
1] ENVIRONMENTAL PROTEC 1ON AGENCY. Information on levels of environ-
mental noise requisite to protect public health and welfare with an adequate margin
of safety, EPA Report 550/74-004. Office of Noise Abatement and Control,
Washington, D.C. 20460 (March 1974).
12] BURROUGHS, C. B. Public health and welfare benefits from regulations on new
medium and heavy truck noise emissions, BBN Tech memo W275 (Revised), Bolt
Beranek and Newman, Cambridge, Mass. (15 January 1976).
[ 31 GALLOWAY, W. J., K. McK. ELDRED, and M. A. SIMPSON, Population Distribu-
tion of the United States as a Function of Outdoor Noise Level, EPA Report
5 50/9-74-004. Office of Noise Abatement and Control, Washington, D. C. 20460
(June 1974).
[ 4] SHARP, B. H. A survey of truck noise levels and the effect of regulations, Wyle
Research Report WR74-8 (December 1974).
[ 5 ] STATE OF CALIFORNIA, Motor Vehicle Noise, Annex A-2 (February, 1973)
[ 6] BENDER, E. K., W. N. PATTERSON and G. E. FAX, The technology and cost of
quieting medium and heavy trucks, BBN Report 2710, Bolt Beranek and Newman Inc.,
Cambridge, Mass. (October 30, 1 974).
[ 7] DEPARTMENT OF TRANSPORTAT 1ON. Peak A-weighted sound levels due to
truck tires, D&T Report Truck Tire Noise I (September 1 970).
[ 81 ENVIRONMENTAL PROTECTION AGENCY, Background document for
proposed medium and heavy truck noise regulations EPA Report 550/9-74-018,
Office of Noise Abatement and Control, Washington, D. C. 20460 (October, 1974)
[ 9 ] Transportation Equipment Noise Emission Controls, Proposed Standards for
Medium and Heavy Duty Trucks, Federal Register, 39 210 Part II 38338-3 8362.
[ 101 JENKINS, S. H., N. LALOR and E. C. GROVER, Design aspects of low-noise
diesel engines. Soc of Auto Eng Paper 730246 (January 1973).
[ 11] JENKINS, S. H., and I-I. K. KUEHNER, Diesel engine noise reduction hardware
for vehicle noise control. Soc of Auto Eng Paper 73068 1 (June 1973).
A- 12-1
-------
[ 121 SHR.ADER, J. T. and W. H. PAGE. The reduction of cooling system noise on heavy
duty diesel trucks. Truck Noise IV-C, Report No. DOT-TST-74-22 (May 1974).
[ 13] BURROUGHS, C. B., Costs of compliance for regulations on new medium and heavy
truck noise emissions, BBN Tech. memo. No. 272. Bolt Beranek and Newman Inc.,
Cambridge, Mass. (January 15, 1976).
[ 14] BENDER, E. K., W. N. PATTERSON and M. C. KAYE, Source analysis and expen .
ments with noise control treatment applied to Freightliner Quieted Truck, Truck
Noise Ill-C, Report No. DOT-TST-74-20 (January 1974).
[ 15] KAYE, M. C. and E. K. BENDER, Final configuration of Freightliner Quieted
Truck, Truck Noise Ill-F, Report No. DOT-TST-75-23 (October 1974).
[ 16] SHRADER, J. T. and M.PR1ADKA, The reduction of intake and exhaust system
noise on heavy duty diesel trucks, Truck Noise IV-D, Report No. DOT-TST-75-14
(October 1974).
[ 171 GENERAL MOTORS. Proceedings of Conference on Motor Vehicle Noise, GM
Desert Proving Ground, April 3-4, 1973.
1181 WILLIAMS, G., R. L. GIVENS and F. SAARI. Noise reduction tests and develop-
ment performed on the White Motor Corp. Quieted Trucks, Truck Noise V A,
Report No. DOT-TST-75-61 (January 1975).
[ 191 BENDER, E. K. and M. C. KAYE. Field Test of Freightliner Quieted Truck,
Truck Noise l1I-G, Report No. DOT-TST-76-29 (September 1975).
[ 20] SHRADER, J. T. The reduction of engine noise of heavy duty diesel trucks,
Truck Noise IV-E, Report No, DOT-TST-75-88 (April 1975).
[ 211 LAW, R. M., Diesel engine and highway truck noise reduction, Soc of Auto Eng
Paper 730240, Detroit, Michigan (January 1973).
[ 221 KAYE, M. C. and E. E. UNGAR. Acoustic and performance test comparison of
initial quieted truck with contemporary production trucks, Truck Noise Ill-B
Report No. DOT-TST-74-2 (September 1973).
[ 231 CLOSE, W. H. and R. M. CLARKE, Interior and exterior A-weighted sound levels
of typical highway trucks. Truck Noise II, Report No. OST/TST-72-2 (July 1972).
A- 12-2
-------
1241 CLOSE, WILLIAM H., DOT Quiet Truck Program, Inter-Noise 74 Proceedings.
[ 25] FAX, G. E. and M. C. KAYE. The economics of quieting the Freightilner cab-
over-engine diesel truck, Truck Noise III-D Report No. DOT-TST-75-22 (October
1974).
[ 26] Automotice News, December 29, 1975.
127] FEDERAL RESERVE BOARD, Rates on business loans of banks, Federal Reserve
Bulletin (October 1975).
A- 12-3
-------
Appendix B
PREDICTIONS OF TRAFFIC POPULATION MIXES
B-I Traffic Population Predictions for Trucks
The percentages for different model year trucks in the traffic mix are weighted accord-
ing to total mileage driven by the trucks of the model year or years of interest. Predictions
of the total mileage driven are made using the following equation [ 4].
Tk= k
c c—j 3 j•iY*j
jn 1
where
T total mileage driven by trucks of type k and model years (c—n 1 ) to (c—n 2 ) in
calendar year c,
number of trucks of type k produced during model year m;
sj < fraction of trucks of type k surviving j years after production,
M}’ annual mileage drivenby truck of type k,j years after production;
difference in calendar year c and latest model year of interest; and
n 2 = difference in calendar year c and earliest model year of interest.
Annual production rates by types of trucks (P ) necessary in computing T are given
in Table B-I. The produètion figures for model years prior to 1973 are reported by the
Motor Vehicle Manufacturers Association [ 1 ]. The figures for model years 1973 and later
were computed by assuming a 1 .4 percent production growth rate for medium gasoline trucks
-0.3 percent for heavy gasoline trucks, 1.5 percent for medium diesel trucks and 5.0 percent
for heavy trucks [ 21. Percentages of trucks surviving as a function of age (SJ<) for all truck
types are presented in Table B-2. The data contained in Table B-2 are based on heavy diesel
truck data both from MVMA (11 and 1972 Bureau of the Census data [ 3J. Because there were
inconsistencies in the data reported by MVMA and the Bureau of Census for heavy gasoline
B-I
-------
Table B-i
Annual Production by Type of Truck (Thousands)
Model
P
P
P
Year
(Medium
(Medium
(Heavy
(Heavy
(m)
Gas)
Diesel)
Gas)
Diesel)
1960 1473 1 427 124
1961 177 1 34 24
1962 211 3 30 35
1963 222 4 39 43
1964 205 9 36 47
1965 228 9 41 63
1966 228 6 45 77
1967 189 5 39 64
1968 199 5 42 78
1969 219 3 41 96
1970 178 3 40 88
1971 193 3 38 98
1972 245 3 39 126
1973 198 3 40 133
1974 200 3 40 144
1975 202 3 40 155
1976 204 3 40 165
1977 207 3 39 174
1978 210 3 38 185
1979 213 3 38 195
1980 216 3 39 205
1981 219 3 39 214
1982 222 3 39 225
1983 225 3 39 236
1984 229 3 39 248
1985 232 4 39 260
1986 234 4 38 274
1987 237 4 38 288
1988 241 4 38 302
1989 244 4 37 317
1990 248 4 37 333
1991 251 4 36 350
1992 255 4 35 367
1993 258 4 34 385
1994 262 4 33 404
1995 266 4 32 425
1996 270 4 33 443
1997 274 4 34 462
1998 277 4 36 481
1999 281 4 37 502
B-2
-------
and medium trucks, the figures in Table B-2 for heavy diesel trucks have been assumed to
apply to all trucks. Data regarding annual mileage driven by trucks (Mj ), required for com-
putation of T are given in Table B-3. These data were obtained from 1972 Bureau of the
Census data tapes [ 3J.
Table B-2
Percentage of Trucks Surviving as a Function of Age
Age of sJ
Truck Precent Surviving
(j) (k1,2,3,and4)
1 99
2 98
3 96
4 93
5 88
6 81
7 73
8 66
9 58
10 52
11 46
12 41
13 36
14 32
15 29
16 25
17 22
18 19
19 16
20 13
21 10
22 8
23 6
24 4
25 2
B-3
-------
Table B-3
Using the values of in Table B-I, S in Table B-2, and M} in Table B-3, values
of T were computed for calendar years c = l97 , 1981, 1983, 1985, 1990, and 2000, for
medium gasoline trucks (k = 1), medium diesel trucks (k = 2), heavy gasoline trucks (k = 3),
and heavy diesel trucks (k = 4) and for values of n 1 and n 2 which apply to the regulatory
options given in Table 4-1.
in order to compute the fraction of the total truck population for truck type k in
calendar year c which were regulated at level i, the total mileage of the model years of truck
Annual Mileage per Truck (Thousands)
Age of
Mk
M
Mf
M
Truck
(Medium
(Medium
(Heavy
(Heavy
C i)
Gas)
Diesel)
Gas)
Diesel)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
23
30
33
20
27
29
16
24
25
13
22
21
11
19
17
10
17
16
9
15
15
8
13
13
7
12
12
7
11
10
6
10
9
6
9
8
5
8
7
5
7
6
5
7
6
4
6
5
4
5
5
4
5
4
4
5
4
3
5
3
3
5
3
3
5
3
3
5
3
3
5
3
3
5
3
73
67
61
55
50
45
40
37
34
31
28
25
22
20
is
16
15
14
13
12
12
11
10
10
10
B4
-------
type k which were subjected to regulatory level i and surviving to calendar year c is divided
by the total mileage for all model years of truck type k which are still operating in calendar
year c. This ratio is then multiplied by the percentage of the total traffic mix for truck type
k to determine the percentage of truck type k regulated at level i which is present in traffic
in calendar year c. The results from these computations are contained in Section B-5, where
different traffic mixes for trucks and automobiles are assumed for urban street and freeway
traffic.
B-2 Traffic Population Predictions for Automobiles
Automobiles are treated as a single class and assumed to include all light vehicles except
motorcycles. The percentage of new automobiles introduced each year is assumed to be 9
percent. New automobile sales are assumed to increase at a rate of 4 percent per year. Thus,
the cumulative percentage of new automobiles is assumed to increase by a factor of 0.09
(1 + 0.04)1 1 each year, where n represents the number of years over which the percentage of
new automobiles is accumulated. Using the above assumptions, the percentage of new and
old automobiles shown in Table B- 4 is generated. For purposes of predicting traffic noise
levels, new automobiles are defined as automobiles subject to local noise emission regulations,
which are assumed to be effective in 1973 and to remain unchanged. To compute the popu-
lation of new (regulated) automobiles in a given calendar year, the fraction of new automo-
biles is multiplied by the percentage of the total traffic mix for automobiles. The results are
contained in Section B-5, where different traffic mixes for automobiles are assumed for
urban street and freeway traffic.
Table B-4
Percentage of New and Old Automobiles and Motorcycles
Year
(n)
Percentage of
New Vehicles
Percentage of
Old Vehicles
1
9.4
90.6
2
19.1
80.9
3
29.2
70.8
4
39.7
60.3
5
50.6
49.4
6
62.0
38.0
7
73.8
26.2
8
86.1
13.9
9
97.8
2.2
10
100.0
0.0
B-5
-------
B-3 Traffic Population Predictions for Motorcycles
Motorcycles are not included in the freeway traffic scenarios. For urban street traffic,
new (regulated) motorcycles are assumed to accumulate at the same rate as automobiles.
Therefore the percentage of new (regulated) motorcycles in urban street traffic is computed
for a given calendar year by multiplying the total traffic mix for motorcycles by the fraction
of new motorcycles (Table B-4) for the number of years after the assumed regulations on
motorcycles become effective (1975).
B-4 Traffic Population Predictions for Buses
Buses are not included in the freeway traffic scenarios, but are contained in the pro-
jections of urban street traffic noise levels. The percentage of the total number of buses of
the model years which are subject to local regulations beginning in 1975 is based on the
cumulative mileage figures generated for medium trucks (Section B-I). That is, the retire-
ment and production rates, and annual mileages for buses are assumed equal to those for
medium trucks. Table B-S shows the cumulative percentages of noise-treated and untreated
buses as a function of the number of years after 1975, the year in which regulations on buses
are assumed to have become effective. Data in Table B-5 is multiplied by the traffic mix per-
centage for buses to obtain population figures for regulated and unregulated buses.
B-S Predictions of Traffic Mixes
Urban street traffic is assumed to be comprised of 1 .0 percent heavy trucks, 6.0 per-
cent medium trucks, 91.5 percent automobiles, 1.0 percent motorcycles, and 0.5 percent
buses [ 5]. For regulatory options in which regulatory levels are set according to engine
type, a traffic mix of 6.25 percent gasoline trucks and 0.75 percent diesel trucks is derived
by assuming that 100 percent of the medium trucks and 25 percent of the heavy trucks are
powered by gasoline engines. Using the mileage ratios for trucks as a function of model
year presented in Section B-l and the percentages of regulated and unregulated automo-
biles, motorcycles and buses presented in Sections B-2, B-3, and B-4, respectively, mixes for
urban street traffic as a function of calendar year are computed both with and without
assumed noise emission regulations on automobiles, motorcycles and buses and for the
different time periods involved in regulatory options for new trucks given in Table 4-1.
The traffic mixes, which are used in predicting urban street traffic noise levels, are
given in Table B-6 for medium trucks, Table B-7 for heavy trucks, Table B-8 for gasoline
trucks, Table B-9 for diesel trucks, Table B- 10 for automobiles, Table B-Il for motorcycles,
and Table B-12 for buses.
Freeway traffic is assumed to contain 1 0 percent trucks and 90 percent automobiles.
Applying the same procedure used for urban street traffic, the traffic mixes, which are used
in predicting freeway traffic noise levels, are computed. These mixes are given in Table B-i 3
for trucks and Table B-l4 for automobiles.
-------
Table B-5
Percentage of Noise-Treated and Unteated Buses
Years From
Noise-Treated
First
Model
Percentage of
Treated Buses
Percentag
Untreated
e of
Buses
1
19.7
80.3
2
36.4
63.6
3
49.4
50.6
4
59.5
40.5
5
67.5
32.5
6
74.1
25.9
7
79.3
20.7
8
83.5
16.5
9
86.7
13.3
10
89.5
10.5
11
91.6
8.4
12
93.4
6.6
13
94.7
5.3
14
95.8
4.2
15
96.8
3.2
16
97.5
2.5
17
98.1
1.9
18
98.6
1.4
19
99.0
1.0
20
99.3
0.7
25
100.0
0.0
The numbers shown in Tables B-6 through B-12 are the predictions of the percentages
of the total traffic population comprised of vehicles of the indicated type and model years
which exist in the indicated calendar year. For example, in Table B-6, it is predicted that in
1983, 2.2 percent of the total urban street traffic will be medium trucks of 1977—1981
model years.
8-7
-------
Table B-6
Urban Street Traffic Mix for Medium Trucks
Percentages of Total Traffic in Given Calendar Year
Comprised of Trucks of Given Model Years
Model
Years
Calendar Year
1978
1982 1984
1986
1991
2001
Prior to
1978
1978—1982
1978—1984
1978—1986
1978—2001
1982—1984
1982—1986
1982—2001
1984—1988
1984—2001
1986—2001
1988—2001
6.0
—
—
—
—
—
—
—
—
—
—
—
2.6
3.4
3.4
3.4
3.4
—
—
—
—
—
—
—
1.7
2.2
4.3
4.3
4.3
2.1
2.1
2.1
—
—
—
—
1.0
1.4
2.8
5.0
5.0
1.4
3.6
3.6
2.2
2.2
—
—
0.3
0.5
0.9
1.6
5.7
0.4
1.1
5.2
2.0
4.8
4.1
2.4
0.0
0.0
0.0
0.2
6.0
0.0
0.1
6.0
0.2
6.0
5.9
5.8
Table B-7
Urban Street Traffic Mix for Heavy Trucks
Percentages of Total Traffic in Given Calendar Year
Comprised of Trucks of Given Model Years
Model
Years
Calendar Year
—
1978
1982
1984
1986
1991
2001
Prior to
1978
1978—1982
1978—1984
1978—1986
1978—2001
1982—1984
1982—1986
1982—2001
1984—1988
1984—2001
1986—2001
1988—2001
1.0
—
—
—
—
—
—
—
—
—
0.4
0.6
0.6
0.6
0.6
—
—
—
—
—
—
0.2
0.4
0.8
0.8
0.8
0.4
0.4
0.4
—
—
—
—
0.13
0.27
0.52
0.87
0.87
0.25
0.60
0.60
0.35
0.35
—
—
0.03
0.07
0.15
0.30
0.97
0.08
0.21
0.90
0.33
0.82
0.69
0.67
0.0
0.0
0.0
0.02
1.0
0.0
0.01
1.0
0.03
1.0
0.99
0.97 -
B-8
-------
Table B-8
Urban Street Traffic Mix for Gasoline Trucks
Percentages of Total Traffic in Given Calender Year Comprised
of Trucks of Given Model Years
Model Years
Calender Year
1978
1982
1984
1986
1991
2001
Prior to 1978
1978- 1982
1982-1984
1984-2001
6.25
—
—
—
2.71
3.54
—
—
1.77
2.29
2.19
—
1.09
1.51
1.43
2.22
0.34
0.55
0.52
4.84
0.0
0.0
0.0
6.25
Table B-9
Urban Street Traffic Mix for Diesel Trucks
Percentages of Total Traffic in Given Calendar Year Comprised
of Trucks of Given Model Years
Model Years
Calender Year
1978
1982
1984
1986
1991
2001
Prior to 1978
1978- 1982
1982-1984
1984-2001
0.75
—
—
—
0.30
0.45
—
—
0.15
0.30
0.30
—
0.10
0.20
0.19
0.26
0.02
0.06
0.06
0.61
0.0
0.0
0.0
0.75
B-9
-------
Table B-tO
Urban Street Traffic Mix for Automobiles
Percentage of Total Traffic in Given Calendar Year
Comprised of Given Category of Automobiles
Automobile
Category
Calendar Year
1978
1982
1984
1986
1991
2001
Untreated
Treated
75
18
35
58
13
80
0
93
0
93
0
93
Table B-I 1
Urban Traffic Mix for Motorcycles
Percentage of Total Traffic in Given Calendar Year
Comprised of Given Category of Motorcycles
Motorcycle
Category
Calendar Year
1978
1982
1984
1986
1991
2001
Untreated
Treated
0.81
0.19
0.38
0.62
0.14
0.86
0.0
1.0
0.0
1.0
0.0
1.0
Table B-12
Urban Street Traffic Mix for Buses
Percentage of Total Traffic in Given Calendar Year
Comprised of Given Category of Buses
Bus
Category
Calendar Year
1978
1982
1984
1986
1991
2001
Untreated
Treated
0.32
0.18
0.13
0.37
0.08
0.42
0.05
0.45
0.02
0.48
0.0
0.50
B- 10
-------
Table B-13
Freeway Traffic Mix for Trucks
Percentages of Total Traffic in Given Calendar Year
Comprised of Trucks of Given Model Years
Model
Years
Calendar Year
1978
1982
1984
1986
1991
2001
Prior to
1978
1978—1982
1978—1984
1978—1986
1978—2001
1982—1984
1982—1986
1982—2001
1984—1988
1984—2001
1986—2001
1988—2001
10
—
—
—
—
—
4.3
5.7
5.7
5.7
5•7
—
—
—
—
—
—
2.7
3.7
7.3
7.3
7.3
3.6
3.6
3.6
—
—
—
—
1.6
2.4
4.8
4.8
8.4
2.4
6.0
6.0
3.6
3.6
—
—
0.5
0.8
1.5
2.8
9.5
0.7
1.9
8.7
3.3
8.0
6.8
4.9
0.0
0.0
0.0
0.2
10.0
0,0
0.2
10.0
0.3
10.0
9.8
9.7
Table B-14
Freeway Traffic Mix for Automobiles
Percentage of Total Traffic in Given Calendar Year
Comprised of Given Category of Automobiles
Model
Years
Calendar Year
1978
1982
1984
1986
1991
2001
Untreated
Treated
73
17
56
34
12
78
0
90
0
90
0
90
-
—
B-Il
-------
REFERENCES FOR APPENDIX B
[ I] MOTOR VEHICLE MANUFACTURERS ASSOICATION. 1973 Motor Truck Facts.
Motor Vehicle Manufacturers Assoication (1973).
[ 2] KEARNEY, A. T. A study to determine the economic impact of noise emission stand-
ards in the medium and heavy duty truck industry (Draft). A. T. Kearney Report
(April 1974).
[ 3] BUREAU OF THE CENSUS. 1972 truck inventory and use summary (Magnetic Tape).
U.S. Department of Commerce, Bureau of the Census (1972).
[ 4] MILLER, D. C. Equations used for truck population models, BBN Memo to Charles
T. Molloy, EPAJONAC (May 23, 1974).
[ 51 OFFiCE OF NOISE ABATEMENT AND CONTROL. Comparison of Alternative
Strategies for Identification and Regulation of Major Sources of Noise. Environmental
Protection Agency, Washington, D.C. 20460 (February 1975).
B- 12
-------
Appendix C
THE ELASTICITY OF DEMAND FOR MEDIUM AND HEAVY TRUCKS
In this study, we have assumed the demand elasticity for trucks to be —0.7. This is the
same elasticity which A. T. Kearney El] used in the original economic impact analysis of noise
regulations for medium and heavy trucks.
Other studies which have explicitly considered the demand elasticity for heavy trucks
have concluded that the demand is inelastic (i.e., elasticity is greater than a minus one). For
example, Ueno and Tsurumi [ 2] estimated the demand elasticity for trucks and buses to be
—0.32. This estimate contains (in addition to medium and heavy trucks) buses and light
trucks.
The results which were reported by Ueno et a!. indicate a greater degree of price inelas-
ticity than that used. This implies that the estimate of economic impact is somewhat con-
servative. Yet another way of approaching the demand elasticity of trucks is via the produc-
tion function* of the trucking sector and the elasticity of demand for trucking services.
The elasticity of demand e for a factor input is given by the following equation
€=(a—l)S +aN
where
a is the share of total factor payments going to the input whose elasticity is being
determined (i.e., the share of capital costs in total cost),
S is the elasticity of substitution in the production function, and
N is the absolute value of the elasticity of demand for the product (i.e., trucking
services).
t Production function is a statement of the relationship between different levels and combinations of productive inputs
(called factor inputs, e.g., capital, labor, fuel, raw material, etc.) and the corresponding outputs per time period.
C-i
-------
In a recent study by Laridenson and Staga [ 31, a production function with a constant elasti-
city of substitution equal to one (i.e., 6=1) was estimated for the (IS. trucking industry.
Using two different definitions of capital, a was estimated to be between 0.1 and 0.5.
As pointed out earlier, the elasticity of demand for trucking services N is low. Assum-
ing a value for N of —0.2, then the demand elasticity for trucks will range from a —0.12 to
-0.6 depending on the value of a.
The evidence strongly indicates that the elasticity of demand is less than one (i.e., the
absolute value), and that, in fact, the estimate of —0.7 is conservative.
SUPPLY ELASTICITY
Assumptions have been made that the industry operates under conditions of constant
cost; that is, that the industry supply curve is horizontal. There are, of course, a variety of
cost conditions for individual firms that will lead to a constant industry supply price. A con-
stant cost industry does not require that each firm operate under conditions of constant cost.
In the Ueno and Tsurumi study [ 21 the production functions for the auto industry were esti-
mated using production functions which were homogeneous of degree one. This implies a
constant cost industry. In another study by Tsurumi [ 41, the production functions for each auto
producer were estimated using a production function which was homogeneous of degree one
(i.e., linear). Again, this implies a constant cost industry.
It should be noted that a production function which is homogeneous to degree one gives
a constant long run cost only if the firm purchases factor inputs at constant cost. However, in
our analysis, we are dealing with a reduction in overall numbers of trucks and a slight increase
in dollar sales. Thus, over this rather small ‘range one can comfortably assume that factor costs
are constant.
C-2
-------
REFERENCES FOR APPENDIX C
11] KEARNEY, INC., A. T. A study to determine the economic import of noise emission
standard in the medium and heavy duty truck industry (EPA Contract No. 68-01-154)
AT Kearney, Inc. (1974).
[ 21 UENO, H. and H. TSURUMI. A dynamic supply and demand of the United States
Automotive Industry, together with a simulation experiment. Essays on Industrial Economics,
Vol. 1, Lawrence R. Klein (ed), Economic Research Unit, Department of Economics,
University of Pennsylvania (1969).
[ 3] LANDENSON and STAGA. Returns to scale in the U.S. Trucking Industry. The
Southern Economic Journal, Volume 40 (January 1974).
[ 4] TSURUMI. Primary Behavior in the U.S. Automotive Industry, Essays on Industrial
Economics, Volume 1. Lawrence R. Klein (ed), Economic Research Unit, Department of
Economics, University of Pennsylvania (1969).
C—3
-------
Appendix D
COSTS OF COMPLIANCE IN 1975 DOLLARS
From the wholesale price indices for trucks [ 1] given in Table D-1, the truck prices
(computed from price increases and average truck prices given in Tables 6-7 and 6-4,
respectively, in terms of 1973 dollars) can be inflated to 1975 dollars. The truck prices
in 1975 dollars are given in Table D-2 for different regulatory levels when fan-off compliance
testing is permitted.
Similarly, the changes in the average annual maintenance costs given in 1973 dollars
in Table 6-17 with credit for exhaust gas seals can be inflated to 1975 dollars using the
commodity price indices in Table 0-f. The resulting estimates are given in Table 0-3. When
credit for savings from exhaust gas seals is not taken, the average annual maintenance costs
in Table D-3 are increased by $65 for diesel trucks.
The average fuel costs per gallon are $0.60 for gasoline and $0.45 for diesel fuel in
1975 [ 21. The changes in fuel costs given in Tables 6-14 and 6-15 were computed using 1973
fuel costs of $0.50 for gasoline and $0.30 for diesel fuel. With the 1975 fuel costs, the
average changes in fuel costs given in Table 0-4 are computed for when credit for savings from
more efficient fans and fan clutches is taken. Without credit for these fan treatments, the
results in Table 0-5 are computed.
Table 0-f
Price Indexes Used for Adjusting Truck Prices and
Other Costs
Commodity Price Index for Transportation, 1967 = 100
1972 1973 1974 1975 (estimated
119.9 123.9 137.7 147.5
Wholesale Price Index for Trucks. 1967 = 100
1972 1973 1974 1975 (estimated)
121.1 123 ,0 136.9 149.0
0-1
-------
Table D-2
Average Price of Trucks (1975 Dollars)
Type of Truck
Baseline
83 dBA
80 dBA
78 dBA
75 dBA
Medium gas
Heavy gas
Medium diesel
Heavy diesel
$ 7,Q70
14,068
8,,916
31,021
S 7,112
14,219
9,432
31,452
$ 7,288
14,377
9,945
31,734
$ 7,469
14,528
10,199
32,063
$ 7,875
14,934
10,883
32,672
Table D 3
Average Changes in Maintenance Costs with Credit
for Savings for Exhaust Gas Seals (1975 Dollars)
Type of Truck
83 dBA
80 dBA
78 dBA
75 dBA
Medium gas
Heavy gas
Medium diesel
Heavy diesel
$11
23
(7)
(24)
$23
45
30
38
$108
131
232
101
$fl7
162
330
214
Table D4
Average Changes in Fuel Costs with Credit for Savings
for More Efficient Fans and Fan Clutches (1975 Dollars)
Type of Truck
83 dBA
80 dBA
78 cIBA
75 dBA
Medium gas
Heavy gas
Medium diesel
Heavy diesel
$(53)
(307)
(88)
(357)
$(94)
(306)
(182)
(350)
$(125)
(306)
(207)
(345)
$(122)
(301)
(202)
(301)
D-2
-------
Table D-5
Average Changes in Fuel Costs Without Credit for Savings
for More Efficient Fans and Fan Clutches (1975 Dollars)
Type of Truck
83 dBA
80 dBA
78 dBA
75 dBA
Medium gas
Heavygas
Medium diesel
Heavy diesel
$0
1
3
6
$1
2
9
15
$ I
2
9
18
$ 4
7
15
62
REFERENCES FOR APPENDIX D
El] DEPARTMENT OF LABOR. Commodity and Wholesale Price Indexes, Department of
Labor Statistics.
[ 21 Oil and Gas Journal, March 11, 1974.
D-3
-------
Appendix E
A COMPUTER MODEL TO DETERMINE
ECONOMIC COST OF NOISE REGULATION
Purpose of the Computer Model: A computer model has been developed for calculating the
future stream of annual economic costs generated by:
1. The proposed regulation, and
2. The alternative regulatory options which were under consideration at EPA.
Statement of the Problem: Economic costs of a regulatory option are incurred in the year a
noise standard takes affect and in subsequent years due to (1) purchases of new equipment
and (2) the changes in operating costs of all trucks.
In the computer model the following calculations are made:
(a) Capital Costs: Capital costs consist of two parts — the cost of financing increased
truck prices and the depreciation cost of the noise control equipment. The finance
charges and the depreciation costs occur over the life of a truck. In order to
calculate capital costs of a regulation in any given year, these costs must be com-
puted and summed for all trucks operating in that year.
(b) Operating Costs: Calculations of the operating costs include the following:
(i) The change in operating costs is composed of the incremental costs for newly
purchased trucks in any year and for all trucks purchased earlier (under
various noise regulations), that are still in service. The attrition rate increases
with age.
(ii) Like the attrition rate, the number of miles, travelled by a truck in any given
year changes with age. In addition, annual mileage varies for each type of
truck under consideration. For example, heavy diesel trucks travel greater
distances than medium gasoline trucks. Calculation of the operating costs
E- 1
-------
takes into account the changing annual mileage for the four categories of
trucks.
(c) Regulatory Levels and their Timing: Calculations are performed for each option
shown in Table E-1. Note that a regulatory option is a set of noise levels and
the effective date. A change in either of the two factors generates a new option.
Table E-l
Sequence of Options
Regulatory
Option Code
Effective Date of the Standard
1978
1982
1984
1986
1988
A
83
80
75
—
—
B
83
80
75
—
C
83
80
78
—
—
D
83
—
78
—
—
E
83
80
—
—
—
F
83
—
80
—
G
83
—
—
—
-
H
—
-
-
-
—
I
83
—
80
75
J
83
—
—
75
—
K
83
80
75 gas
78 diesel
L
83
80
75 gas only
M
83
80
75 medium
78heavy
—
—
N
83
80
75 medium only
—
—
Description of model: RDP Inc. has developed a computer program to compute the cost
of truck regulations in accordance with the model formulated by A. T. Kearney, Inc.*
The salient features of this model are reviewed below.
*Certain modifications to the original equations were madeby Bolt Beranek and Newman, Inc.
E-2
-------
The basis of the model is the following concept: the economic cost of the noise regula-
tions is equal to the number of trucks in each of several categories multiplied by the unit
incremental cost (due to the regulations) for each of those categories. Mathematically,
4 i i
AFE Pm,jCm ,j .(l)
jl m1
where
Aj Annual economic cost of noise regulations in year i,
i = Year under consideration,
j = year truck was built,
m truck type:
m = 1 -÷ medium gas
2 - heavy gas
3 -+ medium diesel
4.4 heavy diesel
1
m,j = Number of type m trucks produced in the yearj which are in service in the
year i, and
Unit incremental cost due to noise regulation in the year i for truck type m
produced in the year j.
There are then two questions to answer:
I. How many trucks are there in each category?
2. What are the costs associated with each category?
Considering question 1 first, we begin with a baseline population for each type of truck
in some base year J 5 and an expected growth rate for each truck type. We can then calculate
a baseline forecast for truck population:
E-3
-------
Fm,j Pm(l+Gm)JJB
where
Fmj Baseline production forecast for type m truck in the yearj,
= Production of type m truck in the base yearjB,
Gm = Expected growth rate in production for type m truck, and
i - JB = Number of years between baseline year and model year j.
Equation (2) gives us the projected truck population in the absence of any noise regu-
lations. It is expected that the regulations will increase truck prices and therefore lessen
demand. A demand reduction factor can be calculated as follows:
E •=N ITm,rTm 1 (3)
m,j m V T
L m,j
where
Em = Demand reduction factor reflecting the price elasticity for type m truck
produced in yearj
Tm, j = Price of type m truck produced in yearj
Tm = Price of type m truck in the absence of regulations
Nm = Price elasticity factor for truck type m (See Appendix C).
In addition, truck population will be reduced by normal attrition. We therefore intro-
duce an attrition factor
Si - = Percentage of original production of year j still in service in year i.
We are now in a position to answer the first question; how many trucks are there in
each category?
Pj j = Fmj ( Em,j)
E-4
-------
where
P j = Population of type m trucks produced in yearj in service in year i; and all
other quantities have previously been defined.
We can now move on to the second question; what are the costs associated with each
category? There are four types of costs included in the model: depreciation, capital costs
(interest), and operating costs. We now consider the three cost categories in order.
A straight line depreciation model is used. That is, depreciation is taken as
S
m,J1 (Tm,j in) ... )
where
= Annual increased unit depreciation chargeable in year i to type m trucks
produced in year j.
L = Economic life of truck.
The cost of capital is given by
— R T 1 1 •J
m,j m,j m I
where
I = Annual increased unit cost of capital (interest) chargeable in year i to the
type m truck produced in yearj
r = Cost of capital rate.
Note that equations (5) and (6) only apply to trucks which are less than L years old.
For trucks older than L years, depreciation and cost of capital are zero.
Operating costs are computed as follows:
Om,j Fm,jMi..j,m+ m,j . . .(7)
IE-5
-------
where
O , j = Change in annual operating costs per truck in year I for truck type m produced
in yearj
Fm, j = Change in fuel costs per truck-mile for truck type m produced m year j,
m Annual mileage for truck type m, i-j years after production
‘sm, j = Change in annual maintenance costs for truck type m produced in year j
The use of more efficient fans and thermostatically controlled fans as a means of
reducing noise actually adds to vehicle horsepower since the power required to drive
the fan is reduced. There is some question as to whether the fuel savings associated
with more efficient fans and fan clutches should be included in the model. There, calcu-
lations were made with and without the costs and fuel savings from more efficient
fan and fan clutches. Similarly, a question of whether the savings in maintenance costs
associated with exhaust gas seals should be credited to the regulations. Therefore,
calculations were made with and without costs and savings from exhaust gas seals.
We can now answer the second question, what are the costs associated with each
category of truck?
C ,,j = .. .(8)
where all quantities have previously been define& Equations (4) (8) can then be fed
into equation (I) to calculate the annual economic cost of the regulations.
Two additional quantities are calculated as well; present value of annual costs, and
uniform annualized cost. Present value of annual costs is computed from
N A
atE
i ti (l+r)’
E-6
-------
where
U = Present value of costs.
N Number of years for which calculation is done.
Uniform annualized cost may be defined by use of the following computational procedure.
Let there be a sequence of annual costs (A 1 ) I = 1,2. . ., N, which are not necessarily all equal.
The present value of an annual cost is defined as that sum of money which, if it were
available at the start of the monetary transaction and if it was invested at an interest rate (r)
would just be sufficient to pay the costs (A 1 ) when it was due. The sum of the present values
for all of the costs Ai (i = 1,2 . . . N) is the present value for the transaction. The uniform
annualized cost is the annuity of level payment, taken over the same period of time as the
original transaction, which has the same present value as the original transaction.
The uniform annualized cost is precisely defined by the following formula
i=N A 1
a 1 - (1 1- r) 1=1 (1 + r)’ (.10)
where
a = Uniform annualized cost,
A = Actual cost incurred in the th year,
r = Cost of capital or annual interest rate. Note: r is a fraction e.g., if the annual in
interest rate on a percentage basis is 5 percent then r = 0.05 (1), and
N = Number of years which have elapsed from the start to the end of the entire
transaction.
Since uniform annualized cost may not be entirely clear to all readers, an attempt has
been made to provide, in addition to the mathematical definition above, some qualitative equiva-
lent definition which are not mathematical. These are given below:
1. Uniform annualized cost is the constant annuity whose present value is the present
value of the actual annual costs incurred over the period of time under consideration.
2. Uniform annualized costs are the equal annual annuity payments made on a
hypothetical loan borrowed by the user of a product to pay for the additional
annual operating, maintenance, and c ital expenditures incurred over the life
E-7
-------
of: the product due to the application of noise abatement technology. The principal
of this hypothetical loan is equal to the total present value of these initial and future
expenditures.
3. The physical changes required to quiet a product generally cause the user of that
product to incur three types of expenses; an initial “capital” expenditure on the
quieting technology embodied in the product, and continuing additional operating
and maintenance expenditures incurred over the entire life of the product. These
induced expenditures are likely to change during the life of the product. In parti-
cular, the capital expenditures will probably all occur at the beginning of the product’s
life while annual operating expenditures could increase as the product gets older;
so that the annual sum of all three types of expenditures will differ from year to
year.
The concept of uniform annualized costs assumes that these expenditures are not made
when they actually come due but rather are met by equal annual installments paid over the
life of the product. The user of the product is viewed as initially borrowing a sum of money
equal to the total present value of all these actual payments. That is, a sum of money which,
if invested at some rate of interest, would yield enough money during the life of the product
to just meet all of the induced expenses when they actually come due, with nothing left over
at the end. The user conceptually pays back this hypothetical loan over the life of the pro-
duct in equal annual installments. These payments include not only the original principal
borrowed but also interest charges on the unpaid balance of the loan. That is, they are
annuity payments. These equal annual expenditures are referred to as uniform annualized
costs.
The net present value and uniform annualized costs are calculated for 1978, the first
year in which a regulation takes effect, for the stream of costs through 1991.
The program outputs are given below.
E-8
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUMING FAN-OFF COMPL TAHOE TEST I MG
WITHOUT CREDIT FOP COST AND SAVINGS FOR
FAN CLUTCHES AND EXHAUST .JOIF4TS
MORE EFFICIENT FiRNS
OPTION A REGULATION SCHEDULE:
RE,GULAT ION LEVEL
80 TiBA 78 DBA
1982 —
1982 —
1982 —
1982 —
ALL FIGURES IN BILLIONS OF DOLLARS
75 DEiR
1994
1984
1984
1984
OP & MNT CAPITAL
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
198.5
1986
t9 7
198$
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0.0
0.0204810
0.0409844
0.0615281
0. 0819441
0. 1365852
0. 1904693
0.3726530
0.5526049
0.7303897
0.9043999
1.3711746
1.2317514
1.3848009
1.5298586
1 • 6645098
1.7936306
1.9042778
2. 0147638
2. 1259384
2.2381792
2.3520927
2.4685440
2.5872936
0. 0
0. 0
0. 0
0.0204810
0.0614656
0. 1229937
0.2049378
0.3415229
0.5319920
0.904645
1.4572496
2. 1876392
3.0920391
4.1632147
5.3949642
6 • 7797642
8.3096199
9. 974 1278
1 1. 7677584
13. 6720343
15.6867952
17.8127289
20. 0509033
22.4029999
24. 8715363
27.4588318
.0. 0
0. 0
0.0
0.0104830
0.0211400
0. 031983 1
0. 0429245
0.0712225
0. 0996146
0. 1987334
0.2981685
0 • 3979543
0.4971740
0. 5953825
0. 6913303
0.7840837
0.8732482
0.9598635
1.0434914
1.1254129
1 • 2058344
1. 2855387
1.3648329
1.4442530
1. 524585?
1.6055174
0. 0
0. 0
0. 0
0.0099980
0.0198446
0. 0295450
0. 0390197
0. 065362€
0. 0908546
0. 173919€
0.2544364
0.3324357
0.4072255
0. 4757945
0.5404242
0.6007196
0.6566146
0.7046499
0.7501425
0. 7788659
0.8089300
0.8404006
0.8733443
0. 9078392
0.9439560
0.9817746
GROWTH RATE FOR
MEDIUM GAS: 0.014
HEAVY GAS: —0.003
MEDIUM DIESEL: 0.015
HEAVY DIESEL: 0.050
COST OF CAPITAL PATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS (1978 — 1991) = 3.329 BILLION DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991) . 0.452 BILLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
97$
197.9
197$
197$
YEAR
TOTAL
CUM TOT
13 -9, ,
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
AflUMING FAN—OFF COMPLIANCE TESTING
1 ,11TH CREDIT FOR COST RND SAVINGS FOR MOPE EFFICIENT FAHS
FAN CLUTCHES AND EXHAUST JOINTS
o Pt io n A REGULATION SCHEDULE:
REGULATION LEVEL
80 OBA 78 DEA
1982
1982 —
1982 —
1982 —
ALL FIGURES iN BILLIONS OF DOLLARS
75 DBA
1984
1984
1984
1934
CAPITAL
1975
1976,
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
I 98?
1988
1989
1 9 0
1 9 1
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0. 0
—0. 1181672
—0.2271118
—0. 3258045
—0.4145692
—0.4815935
—0.5392798
-0.4662725
—0.3849541
-0. 297319?
A c e - qe c.
—
—0.1190234
—0. 0339372
0.0468557
0. 121 0173
0. 1854286
0.2440563
0 2836572
0. 3216739
0.3587916
0.3954821
0.4314281
0.4675788
0.50:30799
0. 0
0.0
0. 0
—0.1181672
—0.3452789
—0.6710835
14 0856524
— 1. 5672455
—2. 1065254
—2. 5727997
—2.9577532
—3.2550726
-3. 46 1 272
—3. 5805511
—3. 6144886
—3.5676:3 2?
—3.4466152
—3.2611866
—3. 0171299
—2. 7334728
—2.4117985
—2. 0530071
-1.6375251
—1. 226 0971
—0.7585182
—0. 2554383
0. 0
0. 0
0. 0
—0. 1334054
—0.2573302
—0.370753:8
—0. 4738787
—0.5721408
—0. 6599:398
—0. 6749579
—0. 6787404
—0. 6733806
-0. E6I2 S3:’
—0.6447574
-0.6266618
— 0.6085317
—0. 592642
—0.5786240
—0. 5678950
—0.5593 167
—0.5537705
—0.5506429
—0. 549536:?
—0. 5508475
—0. 55:37 080
—0.5590577
0. 0
0. 0
0.0
0.0152381
0.0302184
0. 0449492
3. 059:3 (197
0. 0905470
0. 12066 1: 14
0.2086841
0. 29:378 6
0.3760614
e.
C’. 5257346
0.5927247
0.6553876
0.7136609
0.7640 535
0.8119518
0.8429736
0.3754445
0.91)94351
0.9450199
0. 9822763
1.0212870
1. 0621386
‘3RO dTH RATE FOR
MEDIUM GAS: 0.014
HEAVY GAS: —0.00:3
MEDIUM DIESEL: 0. 015
HEAVY DIESEL: 0.050
COST OF CAPITAL RATE: 0.1’)
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION USED
PPEZThT VALVE OF ANNUAL !CDsT (1978 — 199D = -2.264 BILLION DOLLARS
UNIFORM ANNUALIZED C0T (1978 — 1991) = —0.30? BILLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DiESEL
83 DDA
1978
1978
1978
1978
YEAR TOTAL CUM TOT OP MMT
£40
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUM 1MG FAN—OFF COMPLIANCE TEST 1MG
WITHOUT CREDIT FOP COST AND SAYLNiSS FOR
FAN CLUTCHES , AND EXHAUST JOINTS.
MOPE EFFICIENT FANS
OPTION B REGULATION SHEP IJLE:
REGULATION LEVEL
80 PEA 78 PEA
1982 —
1982 —
1982 —
1982 —
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DiESEL
HEAVY DIESEL
75 PEA
1986
1986
1986
1986
ALL FIGURES IN PILL IONS OF DOLLARS
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION uSED
PRESENT VALUE OF ANNUAL COSTS (1978 — 1991) = 2.648 BILLION DOLLARS
UNIFORM ANNUALIZED COfl (1978 — 1991) = 0.359 PILLION DOLLARS
33 DEA
I 978
1978
1978
1978
YEAR
TOTAL
CUM TOT
OP & MNT
1975
0.0
0.0
0.0
0.0
1976
0.0
0.0
0.0
0.0
19??
0.0
0.0
0.0
0.0
1978
0.0204810
0.0204810
0.0104830
0.0099980
0.0198446
1979
0.0409846
0.0614656
0.0211400
1980
0.0615281
0.1229937
0.03198:31
0.0295450
1981
0.0819441
0.2049378
0.0429245
0.0390197
1982
0.1365852
0.3415229
0.0712225
0.0653626
1983
0.1904693
0.5319920
0.0996146
1984
0.2433089
0.7753009
0.1279116
0.1153972
1985
0 .2947701
1.07007 3
0.1559333
0.1388370
1986
0.4838379
1.5599083
0.2599750
198?
0.6701189
2.2240276
0.3640601
1908
0.8509427
3.0749702
0.4681042
0.3828385
1989
1.0281668
4.10:31380
0.5714253
1990
1.2014828
5.3046188
0.6739166
1991
1.3687143
6.673:3294
0.7742095
0.6527401
1992
1.5241508
8.1974802
0.8714145
199.3
1.6728592
9.8703356
0.9653698
( 1 .7595476
1994
1.8163872
11.6867228
1.0568438
.
1995
1.9542980
13.6410189
1.1453705
.
0.8404006
1996
1997
2. 0728235
2. 1915894
15.7138405
17.90 54260
1.2324247
1.3182430
0.873346 2
0.9078392
1998
2.3112335
20.2166595
1.4033947
0.9439560
1999
2.4321632
22.6488190
1.4882069
0.9817746
2000
2.5552588
25.2040710
1.5734816
GROWTH RATE FOP
MEDIUM GAS: 0.014
HEAVY GAS: —0.003
MEDIUM DIESEL: 0.015
HEAVY DIESEL: 0.050
E-11
-------
PROGRAM TO COMPUTE COST OF MDI E REGULAT IONS
ASSUMING FAN—OFF COMPLIANCE TESTING
WITH CREDIT FOR COST AND :5.AVIN I3:S: FOR MOPE EFFICIENT FANS,
FAN CLUTCHES ANt’ EXHAUST JOINTS:
OPTION B REGULATION SCHEDULE:
RE’3ULAT I ON LEVEL
:30 t’BA 7$ DEA
198.2 —
1982 —
19 82 —
19 92
ALL FIGIJRES IN BILLIONS OF DOLLARS
YEAR
15
1976
19??
197 8
.:j 9 9
1980
49:31
1 $
1se4
1986
1987
1998
1999
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
TOTAL
0. 0
C’. .0
0.0
—0. 1181672
— 1:1.22711 18
—0. :3259045
—0.1145692
— 0 .481 5935
—0. 5392798
—0.5867161
—0. 6263728
—0.530 9416
— 0. 4:3 108 1.4
-0.3319429
—0.2315749
—0. 1314:394
-0. 0360892
0.0481712
0. 1258942
0. 1981559
0.2633600
0.3074719
0.3503360
0 • :3919014
0.4322831
0.47188 04
CIJM TOT
0 • 0
0. 0
0. 0
—0. 1181672
—0.3452789
—0. 671.08:35
—1. 0854524
—1 ..567a455
—2. 1065254
—2. 6932421
—:3.3194144
—3.8504562
—4.281538( 1
—4.6134796
—4.8450518
—4. 9764881
—5. 0125742
—4. %44Q1J3
—4.8385057
640:3494
—4. 3769894
—4. 0695171
—:3 7191 811
—3.3272800
—2. 8949966
—2. 4231167
OP & MNT
0.0
0. 0
0. 0
—0. 1334054
—0. 2573302
—0. 3707538
—0. 4738787
— 1 1.5721408
—0. 6599:398
—0. 7362130
—0. 8032663
—0. 7971151
—0. 7835906
—0. 7636800
— s ’. 7394324
—0. 7129575
—0. 6869488
—0. 6633907
—0. 6429299
—0.6252861
— Ii. 6120839
—0. 6019627
—0. 5946826
—0. 5903741
—0. 5890035
—0.5902574
CAPITAL
0. 0
0. 0
0. 0
0.0152381
0. 0302184
0. 0445492
0. 0593097
0.0905470
0. 1206604
0. 1.494968
0. 1768935
0.2462740
0.3525089
0. 4 317375
0.5091080
0.5814187
0. 6508605
0.7115630
0. 7688253
0.8234424
0.8754445
0.9054351
0.9450299
0.9822763
1.0212870
1. 0621386
PRE trlT V RLUE OF ANNUAL COSTS <1978 — 199D —2.914 BiLLION DOLLARS
UNiFORM ANN uALIZED COST <1978 — 1991) = —0. 396 BILLION DOLLARS
TRIJCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
19 7 ?
1978
1972
1979
75 T iER
1996
1986
19*6
1986
GROWTH RATE FOR
MEDIUM GAS.! 0. 014
HEAVY GAS.: —‘3. 1 10:3 -
MEDIUM DIESEL: 0. 015
IIEAVY-DIESEL: 0.05 (1
.Cps’toF..CAPITAL RATE: 0. 1 0
DEPRECThBLE TRUCK LIFE: 10.0 YEAR s
STRAIGHT LINE DEPRECIATION USED
B . 12
-------
PROGRAM TO COMPUTE COST OF NOISE REGULAT iONS
ASSIJMING FAN—OFF COMPLIANCE TESTING
WITHOUT CREDIT FOR CbST AND SAVINGS FOR MOPE EFFICIENT FANS
FAN CLUTCHES ANt’ EXHAUST JOINTS
OPTION C REGULATION .SCHEDIJLE:
REGULATION LEVEL
80 DFA 78 DBA
1982 1984
1982 1984
1982 1984
1982 1984
ALL FIGURES IN BILLIONS OF DOLLARS
YEAR
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
i98s
1989
1990
19.91
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0.0
0. 0204810
0. 0409846
0.0615281
0.0819441
0. 1365852
0. 1904693
0. 2946 081
0.3974228
0.4989691
0. $982080
U. tC tUU1 U )
0. 7824258
0.8691187
0.9516316
1.0267048
1 • 0994406
1.1659002
1. 2321043
1.2985668
1.3654919
1.4331379
1. 5020399
1.5720682
CUM TOT
0.0
0. 0
0.0
0. 0204810
0. 0614656
0. 1229937
0 .2049378
0.34.15229
0.5319920
0.8266001
1.2240229
1.7229919
2.3211994
a. ‘D132U08
3.7956266
4.6647415
5.6163692
6. 643072 1
7.742512 7
8. 9084101
10. 1405115
1 1. 4390793
12. 80457 02
14. 2377 81
15.7397480
17.3118134
0. 0
0. 0
0. 0
0.0104830
0.0211400
0.0319831
0. 0429245
0. ‘3712225
0. 0996146
0.1601758
0.2209466
0.281970?
0.3425863
U. 40d.4Cu’7
0.4606994
0.5171008
O. 5711702
0.6235904
0.6741450
0.7235123
0.7718136
0.8195230
0. 866806 0
0. 9138767
0.9612224
1.0086641
CAPI FRI
0. 0
0. 0
0. 0
0. 0099980
0. 0198446
0. 0295450
0.0:390197
0. 0653625
0. 0908546
0. 1344321
0. 1764765
0.216998?
0.2556216
U. C o
0.3217269
0.3520202
0.3804638
0.4031186
0.4252989
0.4423923
0.4602949
0.4790459
0.4986870
0.5192630
0.5408184
0. 5634032
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS (1978 — 1991) =
2.332 BILLION DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991) = 0.317 BILLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
1978
1978
1978
1978
TOTAL
75 DEA
OP & MNT
GROWTH RATE FOR
MEDIUM GAS: 0.014
HEAVY GAS: —0. 003
MEDIIJM DIESEL: 0. 015
HEAVY DIESELI 0.050
E-I 3
-------
PR)5PAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUMING FAN—OFF COMPL I ANCE TEST I HG
WITH CREDIT FOP COST AND SAVINGS: FOR M E EFFICIENT FANS
FAN CLUTCHES AND EXHAUST JOINTS
OPTION C REGULATION SCHEDULE:
REGULATI ON LEVB
80 DEA 78 DBA
198a 1984
1982 1984
1982 1984
19a? 1984
ALL FIGURES IN FILLIONS DOLLARS
YEF
1975
1976
1977
19 78
1979
1 .980
1981
1982
1983
1984
1985
1986
4 —.
C
1983
1989
1990
1991
1 9
1993
1994
1995
19%
1997
1998
1999
2000
TOTAL
0. 0
0. 0
0. 0
—0. 1181672
—0.2271118
—0. 3258045
—0.4145692
—0.4815935
—0. 5392798
—0.5471523
—0. 5454625
—0.5361295
C. -
—0. _,c 1 r .•t ?C
—0.5087669
—0. 4951342
—0.4818347
—0. 4711964
—0. 4672140
46575 15
—0. 4711022
—0. 4780794
—0.4863093
—0. 4955389
—0.5064481
—0. 5183936
—0.5321505
CUM TOT
0.0
0. 0
0.0
—0. 1181672
—0. 3452789
—0.671.0835
—1 • 0856524
—1.5672455
—2.1065254
—2.6536779
—3.1991405
—3. 7352705
—4.257C 190
—4.7657852
-5. 26 09186
—5. 7427511
—6. 2139473
—6. 681157 1
—7. 1469049
—7. 6180067
—8. 0960836
—8. 5823289
—9. 0779276
—9. 5843735
—10. 1027632
—10.6349115
OP & lINT
0. 0
0.0
0.0
—0. 1334054
—0.2573302
—0.3707538
—0. 47387$?
—0. 5721408
0.6599:398
—0. 7166448
—0. 7618716
—0. 7976128
—0. S26 0766
—0. 8496796
—0.8707681
—0. 8903408
—0.9107143
—0.9319 173
—0. 9551969
—0.9800066
—1 . 0073605
—1. 0369329
—1. 0685186
—1.102846.1
—1.1393242
—1•. 1787825
CAPITAL
0. 0
0. 0
0. 0
0.0152381
0.0302184
0. 0449492
0. 0593097
0. 0905470
0.1206604
0 1694926
0. 2164091
0.2614832
-t..
U • -J v—p.ji_ •i.
0.2409126
0.375633?
0. 4 085061
0.4395185
0. 4647040
0.4894459
0.5089042
0.5292820
0.5506250
0.5729802
0.5963983
0.6209306
0.6466321
• ,3RD TH PATE FOR
MEDIUM GAS: 0.014
fEAVY GAS: —0. 00:3
tEDIUM DIESEL: 0. 015
€ /Y DIESEL: 0.050
COST OF CAPITAL RATE:
0.10
DEPRECIABLE TRUCK.. LIFE: 10.0 ytAFS
STRAIGHT LI NE DEPRECIAT ION USE P
PRESENT VALUE OF ANNUAL COSTS cV?78 — 199.1) = —:3.289 BiLLION DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991 = —0.446 PILLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
1978
1978
1978
1978
75 PEA
E-1 4.
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUM I N ’ S FAN—OFF COMPL lANCE TESTING
IflTHOUT CREDIT FOR COST ANt ’ SAVINGS FOR
FAN CLUTCHES AND EXHAUST JOINTS
MOPE EFFICIENT FAN5
OPTION D REGULATION SCHEDULE:
REGULATION LEVEL
80 DEA 78 t’BA
— 1984
— 1984
— 1984
— 1984
ALL FIGURES IN BILLIONS OF DOLLARS
YEAR
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
TOTAL
0. 0
0. 0
0. 0
0. 0204810
0. 0409846
0.0615281
0. 0819441
0. 1020972
0.1216724
0.2288572
0.3349799
0.4402972
0.5439925
0.6431913
0.7395537
0.8318354
0.9195950
1 • 0038586
1. 0842533
1. 152527$
1 .2203522
1 • 2882404
1 . 3562832
1 • 4250202
1. 4949942
1.5659361
CUM TOT
0. 0
0. 0
0.0
0. 020481 0
0.0614656
0. 1229937
0. 2049378
0.3070349
0.4287073
0.6575644
0.9925442
1 • 4328413
1 • 9768333
2. 62 0 0247
3.3595791
4. 1914139
5.1110086
6.1148643
7.1991167
8.3516407
9.5719910
10. 8602285
12.2165079
13.6415272
15. 1365175
16.7024384
0. 0
0. 0
0.0
0.0104830
0.0211400
0.0319831
0. 0429245
0. 0538969
0. 0647163
0. 1262628
0. 188169?
0.2505576
0.3129095
0.3750420
0.4360389
0.4950384
0. 55164 06
0.6064 084
0.6589588
0.71 01404
0.7600614
0.8091962
0.8575974
0.9057589
0.9541765
1. 0025320
CAPITAL
0. 0
0. 0
0. 0
0. 0099980
0.0198446
0. 0295450
0.039019?
0. 0482004
0. 0569551
0. 1 025942
0.1468101
0. 1897399
0.2310930
0. 2681491
0.3035151
0. :336799
0.3679572
0.3974540
0.4252989
0. 4423923
0.4602949
0.4790459
0. 49:36:?? 0
0.5192630
0.5408184
0.5634032
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION IJSED
PRESENT VALUE OF ANNUAL COSTS ‘1978 — 1991) = 2.(’91 BILLION DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991) = 0.284 BILLION DOLLARS
TRIJCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
1978
1972
1978
1978
75 DEA
OP MNT
GROMTH RATE FOR
MEDIUM GAS: 0.014
HEAVY GAS: —0.003
MEDIUM DIESEL: 0.015
HEAVY DIESEL: 0.050
E-15
-------
PROGRAM TO cOMPIJTE COST OF NOISE REGULAT ION:Z:
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUr 1 DIESEL
HEAVY DIESEL
:33 DBA
197:3
1978
1978
1978
78 DBA
1984
1984
1984
1984
1975
1976
1977
1978
1979
1980
1981
1982
193:3
1984
1985
1986
1997
198:3
1989
199(1
1991
1992
1993
1994
1,995
1996
1997
1998
1999
2000
0.0
0. 0
0. 0
—0. 1181672
—0.2271118
—0. 3258 045
—0. 4145692
—0.4956881
—0.5698557
—0.5812590
—0. 5828347
—0. 5745250
—0.5590950
—U. 4 .3d(
—0.5263994
—0.5098908
—0. 4955776
—0. 4836746
—0. 4756669
—0. 4801612
—0.4863849
—0.4935910
—0.5022735
—0. 5126356
—0. 5237609
—0. 5%8 164
0. 0
0. 0
0.0
—0. 1181672
—0.3452789
—0. 671 0835
—1. 0856524
—1 .5813408
—2.1511965
—2. 7324553
—3.3152895
—3.8899145
—4.4490089
—4. 9 .s 53
—5.5187330
—6. 0286226
—6.5241985
—7. 0078707
-7. 4835343
—7. 9636927
—8. 4500761
—8. 9436646
• —9.4459362
—9.9585714
—10. 4822.313
—11. 0191450
0. 0
0. 0
0.0
—0. 1334054
—0.2573302
—0. 3707538
—0.4738787
—0.5688847
—0.6562667
—0. 7185845
—0.7692702
—C i. 8085675
—‘:‘. 8386306
0. b 5b(9
—0. 8836:336.
—0.9030182
—0.9224601
—0.9426578
—0.9651126
—0.9890655
—1. 0156660
—1. 0442152
—1. 0752535
—1. 1090336
—1. 1446915
—1. 1834488
0. 0
0.0
0. 0
0.0152381
0.0302184
0. 0449492
0. 0593 097
0. 0731967
0.0864112
0. 1373253
0. 1864359
0. 2339427
0.2795354
0.3192404
0.3572341
C’. 3931269
0.4268830
0.45 :39
0.4894459
0.5089042
0.5292820
0.5506250
0.5729802
0.5963983
0.6209306
0. 6466321
GROWTH RATE FOR
MED I UN GAS: ‘0. 014
HEAVY i3AS: —0. 003
MEDIUM DIESEL:
HEAVY DiESEL
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.1 . T’EARS:
STRAIGHT LIT’€ DEPRECIATION USED
PRESENT VALI.E OF ANNUAL COSTS (1978 — 1991 ) = —3.430 PILLION DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991> = —0.464 BILLION DOLLARS
ASSUMING FAN—OFF COMF’LIANCE TESTING
WITH CREDIT FOR COST AND SAVINGS FOR MORE EFFICIENT FANS,
FAN CLUTCHES AND EXHAUST JOINTS
OPTION D REGULATION SCHEDULE:
REGULAT ION LEVEL
:30 DBA 75 DBA
ALL FIGURES IN BILLIONS OF DOLLARS
YEAR
TOTAL CUM TOT
OP MNT
CAPITAL
C ’. 015
0. 050
E- 16
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUMING FAN—OFF COMPLIANCE TESTING
WITHOUT CREDIT FOP CO.!T AND SAVINGS FOR MORE EFFICIENT FANS,
FAN CLUTCHES, AND EXHAUST JOINTS
OPTION E REGULATION SCHEDULE:
REGULATION LEVEL
80 DEA 78 DBA 75 DBA
1982 — —
1982 — —
1982 — —
1982 — —
ALL FIGURES IN BILLIONS OF DOLLARS
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1999
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0. 0
0. 0204810
0. 0409846
0. O6152 1
0.0819441
0. 1365852
0. 1904693
0.2433089
0.2947701
0. 3448734
0.393 0255
0 4?5S” 5
0.4782615
0. 5 1877 04
0.5579194
0. 5919301
0.6262379
0. 6609346
0. 5961797
0. 7321656
0. 7690842
0.8068659
0.8457096
0. 8857689
0.0
0.0
0. 0
0.0204810
0.0614656
0. 1229937
0.2049378
0. 3415229
0.5319920
0. 7753009
1. t?00703
1. 414 ?437
1.8079700
. 2 4 4 47 4
2.7227354
3.2415056
3.7994251
4.39135:36
5.0175915
5. 6785259
6. 3747025
7. 1068668
7.8759480
8. 68281 08
9.5285206
10.4 142 1385
0. 0
0. 0
0.0
0. 01048:30
0. 0211400
0.0:319931
0. 0429245
0. 0712225
0.0996146
0. 1279116
0. 1559333
0. 183698!
0.2108389
C L ‘72 c ;fl
A I C
U.
0.2878694
0.3122117
0.3352588
0.3601295
0. 38 :38935
0.4076851
0.4316718
• 0. 456 0179
0.4806262
0.5056655
0.5312583
0. 0
0. 0
0. 0
0. 0099980
0. 0198446
0. 0295450
0.0390197
0. 0653626
0. 0908546
0.1153972
0. 1388370
0.1611752
0.1821865
A I ?c4A
0.21542( 12
0. 2309011
0.24570Th
0.2556716
0.2661085
0.2770411
.0. 2884946
0.3004938
0.3130662
0.3262395
0.34004:37
0.3545103
GROWTH RATE FOP
MEDIUM GAS: 0.014
HEAW GAS: —0.003
MEDIUM DIESEL: 0. 015
HEAVY DIEE L: 0.050
COST CAPITAL PATE: 0.10
DEPRECIABLE TRUCK LIFE: 10.’) YEARS
STRAIGHT LINE DEPRECIATION USEU
PRESENT VALUE OF ANNUAL COStS (1978 - 1991).= 1.661 BILLION DOLLARS
UNIFORM ANNUALIZED CUST (1978 — 1991. ) = 0.225 BILLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DBA
1 78
1978
1978
1978
YEAR TOTAL CUM TOT OP & PINT CAPITAL
E-1 7
-------
PROGRAM TO COMPUTE CB!T OF NOISE REGULATIONS
7:3 FDA 75 DBA
YEAR
TOTAL CUM TOT
OP & MNT
CAPITAL
1975
1976
1977
1978
1979
1980
1981
1982
198:3
1984
1985
1986
1987
4 r _b_
4 iC•’
1989
19S0
1991
1992
199:3
1994
1995
1996
1997
1998
1999
2000
0. 0
0.0
.0. 0
—0. 1181672
—0. 2271118
—0. 3258045
-0.4145692
—0.4815935
—0. 5392798
—0. 5867161
—0. 6263728
—0. 6608202
—0.6916441
C. 4 r’)
—0. 7552330
—0.7847265
—0. 8147573
—0.849740:3
—0. 8847815
—0.9201974
—0.9566005
—0. 9941885
— 1.0324497
—1.0723705
—1. 11 124
—1. 157 0997
0. 0
0.0
0. 0
—0.1181672
—0. 3452789
—0.67 10835
-1 • 0856524
—1.5672455
—2.1065254
—2.6932421
—3.3 196144
—3.9804449
—4.6720858
e
... . — ... .
—6.1515856
—6. 9363089
—7. 7510653
—8.6008053
—9.4855862
—1 0.4057808
—11.362:3810
—12.3565664
—13.3890123
—14.4613819
—15.575195:3
—16.7:322845
0. 0
0. 0
0. 0
—0. 1334054
—0. 2573302
—0. 3707539
—0.4738787
—0. 5721408
—0.6599398
—0. 7362130
—0. 80:32663
—0. 8637427
—0. 9189737
—0.97051 Er
—1. 0195551
—1. 0665045
—1.1133900
—1.1604166
—1.2090755
—1.2567091
—1. 3069639
—1. 3590641
—1 . 412531 9
—1.4683895
—1. 5265341
—1. 5073260
0. 0
0 • 0
0. 0
0. 0152:381
0.0302184
0. 0449492
0. 0593097
0. 0905470
0.1206604
0. 1494968
0. 1768935
0. 2029141
0.2273304
0. 26432 3 8
o • 281 7804
0. 29 86352
0.3106790
0.3232957
0.3365145
0.351)3644
0.3648770
0.3800842
0. 3960205
0.4127224
0.4302274
GROWTH RATE FOR
MEDIUM 1A5: 0.014
HEAVY GAS: —0. 003
rIEDIUM DIESEL: 0.015
HEAW DIESEL: 0.050
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUCk LIFE: 10.0 yEARS
STRAIGHT LIME DEPRECIATION USED
PRESENT \ UE OF ANNUAL COSTS (1978 — 1991) = —3.853 BILLION DOLLARS
UMIFOF II AR 1URLIZED COST <1978 — 1991) = —0.523 BILLION DOLLARS
ASSUMING FAN—OFF COMPLIANCE TESTING
WITH CREDIT FOP COST AND SAVINGS FOP MOPE EFFICIENT FANS
FAN CLUTCHES, AND E
-------
PROGRAM TO COMPUTE COST OF NOISE PEGIJLWrIOMS
78 DEA 75 OBA
YEAR
TOTAL CUM TOT
OP & MNT
CAP ITAL
GROWTH F iTE FOP
MEDIUM iA5: 0. 014
HEAVY 13Ff5: -0.003
MEDILPI DIE: EL: 0. 015
HEAVY DIESEL: 0.050
COST OF CAPITAL RATE: 0.10
DEPRECIABLE TRUC:K LIFE: 10.0 AR:S
STRAIGHT LINE DEPRECIATiON UED
PRESENT YFtUE OF AI’IIUAL CO :TS (3979 — 1993 .:’ = 1.420 BILLION DOLLARS
UNIFORM AfINJALIZED COST <1978 — 1991) = 0.193 BILLION DOLLAR: !:
ASSUMING FAN—OFF COMPL I ANCE TEST 1MG
WITHOUT C?EE’IT FOR COST ANO 5 /ING5. FOR MORE EFFICIENT FANS
FAN CLUTCHES AND EXHAUfl MINTS
OPTION F REGULATION SCHEDULE:
REGULATION LEVEL
TRUCK TYPE 8:3 OBA 90 PEA
MEDIUM Gt S 1978 1984
HEAVY GAS 1978 1984
MEDIUM .DIESEL 1978 1984
HEAVY DIESEL 1978 1984
ALL FIGURES IN BILLIONS OF DOLLARS
1975
0.0
0.0
0.0
0.0
1976
0.0 .
0.0
0.0
0.0
1977
0.0
0.0
0.0
0.0
1978
0.0204810
0.0204810
0.0104830
0.0099980
1979
0.0409846
0.06146.56
0.021140’)
0.019:3446
1980
0.0615281
0.1229937
0.0319831
0.0295450
1981
0.0819441
0.2049378
0.0429245
0.0:390197
1982
0. 1 020972
0.3070349
0. 0538969
0. 0482004
1983
0.1216724
0.4287073
0.064716:3
0.0569561
1984
0.1775580
0.6062653
0.09:39986
0.08.35593
1985
.
0.2323272
0.83859 35
0.1231565
0.1091706
1986
0.2 862016
1.1247940
0.1522850
0.1:3:99164
198?
A.33A810 1
1.46 f l 04fl
0.1811619
0.1576480
1989
0.3976951
1.8512993
0.2098913
0.1778u37
1989
0.4353892
2.2866879
0.23 81811
0.1972083
1990
0.4814858
2.7681742
0.2659071
0.2156789
1 91
0.5258828
3.2940569
0.2926819
0.2332009
1992
0.56908:33
3. 8631401
0.3190766
0.2500070
1993
0.6110517
4.4741917
0.3449430
0.2661085
1994
0.6475627
5.1217527
0.3705215
0.2770411
1995
0.6844273
5.8061781
0.3959326
0.2884946
1996
0.7218391
6.5280161
0.4213452
0.3004938
1997
0.7598755
7.2872895
0.44690 1
0.3130662
1998
0.7987484
8.0866:337
0.4725( 187
0.3262395
1999
0.8386639
8.9252939
0.49861%
0.3400437
2000
0.8796:36?
9.8049307
0.5251264
0.3545103
E-19
-------
F 0G WIN TO COHPUTE COST OF NOISE REGULATI eNS
ASSL*IItlG FAN-OFF CC itt lANCE lEST INS
WITH CREDIT FOR COST AND SAVINES FOR MORE EFFICIENT FANS.
FAN CLUTCHES. AND EXHAUST JOINT S
OPTION F REGULATION SCHEDULE ’
REGLL AT! ON LEVEL
80 DBA 78 DBR
1984 —
1984
1984 -
1984 — .
ALL FIGURES IN BILLIONS OF DOLLARS
1’975
1976
1977
19Th
1979
19*0
1981
1982
1983
1984
1985
1986
1 97
1988
1989
1990
1991
1c9 2
1993
1994
1995
1996
• 1997
1998
1999
2000
0.0
0.0
0.0
—0.1181672
—0.2271118
—0.3258045
—0.4145692
—0.4956881
—0.5698557
—0.620822?
—0.6437452
-0.6993254
—0. VERQSQP
—0.7588295
—0.7964982
—0.8127826
—0.8391385
—0.8662013
—0.8946970
—0.9292561
—0.9649060
—1.00.14696
—1.0391836
—1.0785570
—1.1191797
—1.1617651
GROWTH RATE FOR
tEDIUM SASs 0.014
HEAW SASs —0.003
NEDILfl DIESELs 0.015
i’EAW DIESEL I 0.050
0.0
0.0
0.0
—0.1181672
—0.3452789
—0.6710835
—1 • 0856524
—1.5813408
—2.1511965
a2. 7720194
—3.4357643
-4.1350899
—4. 864 1 1776
—5.6229067
-6.4094038
—7.2221851
—8.0613203
—8.9275179
• —9.8222113
—10.7514668
—11.7163696
—12.7178383
—13.7570219
— 14.8355761
—15.9547548
—17.1165161
0.0
0.0
0.0
—0.1334054
—0.2573302
—0.3707538
-0.4738787
—0.568884?
—0.6562667
—0.7381527.
—0.8106652
—0.8746990
—0.9315279
—0.9834048
—1. 0324211
—1.0791 st ?
—1.1251364
—1.1711569
-1.2179909
—1 • 2657681
—1.3152695
—1 • 3663464
—1.419266?
-1.4745770
—1.5319014
tI .5919914
0.0
0.0
0.0
0.015238 1
0.0302184
0.0449492
0.0593097
0.0711987
0.0864112
0.1173295
0.1469204
0.1753735
0.20253*4
0.2245765
0.2459241
0.2664016
0. 285 996
0.3049589
0.3232957
0. 336 l45
0.3503644
0.3648770
0.3800842
0.3980205
0.4127224
0.4302874
COST OF CAPITAL RATEs 0.10
DE R& tABLE TRUCK LIFE’ 10.0 rEARS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS (1978 - 19915 a —3•995 BILLIOI DOLLARS
UNIFORM ANNUALIZED COST (1978 — 1991) a —0.542 BILLION DOLLARS
TRUCK 1YPE
IEDIUPI GAS
HEAVY GAS
PEDIUN DIESEL
HEAVY DIESEL
83 DBA
1978
1978
1978
1978
75 DBA
YEAR TOTAL CUN TOT OP & MNT CAPITAL
E.2O
-------
PROGRAM TO COMP uTE COST OF NOISE REGULATIONS
A53UMIr I; FAN—OFF COMPL lANCE TEST 1MG
WITHOUT CREDIT FOR COST AND SAVINGS FOR MOPE EFFICIENT FANS’
FAN CLUTCHES AND EXHAUST JOIHIS
ALL FIGURES IN BILLIONS OF DOLLARS
TOTAL CIJM TOT
GPO )TH PATE FOP
MEDIUM GAS: 0. 014
FEAVY GAS: —0. 003
F€DI IJM DIESEL: 0.015
HEAVY DIESEL; (1.050
COST OF CAPITAL RATE: 0. 10
DEPRECIABLE TRUCK LIFE: 10. 0 YEARS
STRAIGHT I WE 1 iEPREC TAT ION USED
& P iNT CAPITAL
PRESENT VALUE OF At Ir IU FiL COSTS ‘1978 — 19’ l’ = 0.938 BILLION DOLLARS
UNIFORM ANNUALIED COST ‘1978 — 1991) = 0.127 BILLION DOLLARS
OPTION G REGULATiON SCHEDULE:
RESULAT ION LEVEL
TRUCK TYPE
MEDIUM RS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 DEA 80
1978
1978.
1978
1978
‘DBA 79 DEA 75 DBA
YE AR
1975
0.0
0.0
0.0
0.0
1976
0.0
0.0
0.0
0.0
1977
0.0
0.0
0.0
0.0
1978
0.0204810
0.0204810
0.0104830
0.0099980
1979
0.0409846
0.0614656
0.0211400
0.0198446
1980
0.0615281
0.1229937
0.03 193:31
0.0295450
1981
0.0819441
0.2049378
0.0429245
0.0390197
1982
0.1020972
0.3070349
0.0538969
0.0482004
1983
0.1216724
0.4287073
0.0647163
0.0569561
1984
0.1403770
0.5690841
0. 0751972
0.0651798
1985
0.1581289
0.7272128
0.0852742
0.0728546
1996
0. 1751424
0.9 ( 123552
0.0950445
0. 0800979
1987
0.1913186
1.093673?
0.1044112
0.0869072
1
0. IJ441Itb
1 S 0 IJ 4
1 1 113 b: .d
11
19:39
0.2174353
1.51556 8?
0.1225093
0.0949758
1990
0.230 5491
1.7462187
013310
0.0993081
1991
0.2439251
1.9901428
0. 1400728
0.1 033523
1992
0.2574225
2.2475653
0.1428035
0.1086189
1993
0.2712509
2.5188169
0.1576321
0.1136190
1994
0.2853463
2.8041630
0.1664822
0.1188641
1995
0.2998190
3.1039*20
0.175q524
0.1243665
1996
0.3145929
3.4186745
0.184553 ?
0.1301389
1997
0.2299912
3.7486658
0.1937964
0.1361948
1998
0.345742 ?
4. 0944090
0.20:3194 ?
0. 1425482
1999
0.3619714
4.4563780
0.2127576
0.1492140
2000
0.3787963
4.8351717
0.2225891
-0.1562076
E-21
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATI OHS
OPTION S REGULATION SCHEDULE:
PEG SATION LEVEL
$0 DPA 78 DBA
YEAR TOTAL CUM TOT
1975
1976
1977
1978
1979
1980
1991
1982
1983
1984
1983
1986
1987
199:?
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0.0
0. 0
0.0
—0. 1181672
—0.2271118
—0. 3258045
—0.4145692
—0. 495€381
-0.5698557
—o • 637 0222
—0.6986188
—0.756236 ci
—0. 8102174
_fl
—0.9188460
—0.9702341
—1 • 021 0915
—1. 0722437
—1. 1236792
-1. 1761866
—1.2300291
—1.2855234
-1. 3425426
—1. 4017372
—1.4631004
— 1. 5269938
0. 0
0. 0
0. 0
—0.1181672
—0.34 32799
-0.6710835
—1. 0 56S24
—1. 5813409
—2. 151 1965
-2. 7882185
—3. 4888374
—4. 2430725
-5. 0532873
_c: ‘ 1OQI tC
—6. 8:377552
—7. 9079872
—8. 8290 749
-9. 9013176
—11. 0249939
—12. 2011805
—13 • 4312096
—14. 7167$ 11
—16. 0592651
—1?. 4609985
—18. 9241 028
-20. 451C$56
0. 0
0. 0
0. 0
—0. 1334054
—0. 2573302
—0. 3707538
—0.4738787
—0.5688847
—0.656266?
—0.7358141
—0. 8089315
—0. 8773929
TV. 9415373
—1 ;
-1. OE.19869
—1. 1197252
—1.1772432
—1. 235.3849
—1.29415:32
—1 . 354354?
—1.4162693
—1.4802313
—1 • 5461383
—t.€146524
—1 • 695806:?
—1. 7599 49
0. 0
0. 0
0. 0
0.0152381
0. 0302194
0.0449492
0.0593097
0. 0731967
0.0864112
0. 0987915
0. 11 03132
0.121 1569
Cfl. 1313200
0.1431416
0. 1494912
0. 1561526
0.1631415
0. 1704741
0.1781676
0. 1862:397
0.1947095
0. 2035965
0. 2129217
0.2227069
0. 2329748
COST OF CAPITAL RATE: 0. 10
DEPRECIABLE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS <1978 — 1991: ’ = —4.273 PILLION DOLLARS
UNIFORM ANNUALIZED C:OST (1978 — 1991) = —o.5s0 BILLION DOLLARS
ASSUMING FAN—OFF CDMPL lANCE TESTING
WITH CREDIT FOP COST AND SAVINGS FOR MOPE EFFICIENT FANS
FAN CLIJTCHES. AND EXHAUST JOINTS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
$3 DBA
1978
1978
197$
1978
ALL FIGURES IN BILLIONS OF DOLLARS
75 DBA
OP & P i NT CAPITAL
GPOIJTH RATE FOR
MEDIUM GAS: 0.014
HEAVY GAS: —0.003
PEEi IUM DIESEL: 0.015
HEAVY DIESEL: 0.050
E-22
-------
PROGRAM TO COMPUTE COST OF NOiSE REGULATIONS
A SUMIN’3 FAN—OFF C0MPLIAN’:E TESTING
WITHOUT CREDIT FOR COST AND SAVINGS FOR
FAN CLUTCHES AND EXHAUST JOINTS
MORE EFFICIENT FANS
OPTION I REGULATION SCHEL*JLE:
REGULATION LEVEL
80 DBA 76 DBA
1984 —
1984 —
1984 —
1984 —
ALL FIGURES IN BILLIOFtS OF IOLLFFS
75 PEP
1988
1988
198*
1988
OP L MNT CAP iTAL
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
19:35
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0. 0
0.0204810
0. 0409846
0.0615281
0.0819441
0.1020972
0.1216724
0.1775580
0.232:3272
0.2862016
0.338810 1
0.5371914
0. 73:35667
0. 9275391
1.1179790
1.3044052
1.4846077
1.6522827
1.8128576
1 • 9680882
2.1174049
2.2460527
2.3750744
2.5052462
0. 0
0. 0
0. 0
0. 020481 0
0.06146%
0.1229937
0.2049378
0.3070 .349
0.4287073
0.6062653
0. 8:385 925
1.1247940.
1.46:36040
2. 0007954
2.7843616
3.6619511
4. 7799292
6. 0843334
7.5689402
9.2212219
Ii. 0340786
13. 0021658
15.1195688
17.3656158
19. 74 921
22. 2459259
0. 0
0. 0
0.0
0.0104830
0. 0211400
0. 0319831
0.0429245
0. 0538969
0.0647163
0. 0939985
0. 1231555
0. 1522850
0.1811619
0.2921459
0.4034419
0.5148518
0.6256505
0.7357212
0.8436715
0.948:3659
1 .0496349
1. 1483984
1.2440596
1 • 3382149
1. 4311 180
1.5234709
0’. 0
0. 0
0. 0
0. 0099980
0.0198446
0. 0295450
0. u39 0197
0. 0482004
0. 0569561
0. 083559.3
0.1091706
0.1339164
0. 1576480
0.2450453
0.3301245
0.4127:373
0.49 23323
0.5686*8:3
0.6409410
0. 7039219
0. 7632269
0.8196933
0. 8733463
0. 9078:392
0. 9439560
0.9817746
GRD TH RATE FOR
tEDIUM GAS: 0.014
EAVY GAS: —0.003
MEDIUM DIESEL; 0. 015
HEAVY DiESEL : 0. 050
COST OF CAPITAL RATE: 0.10
DEPRECIAFIE TRUCK LIFE: 10.0 YEARS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS (1978 — 1991:: ’ = 1.396 PILLION DOLLARS
UNIFORM ANNUALIZED COST U978 — 1991 = 0.257 B 1LLION DOLLARS
TRUCK TYPE
MEDIUM GAS
HEAVY GAS
MEDIUM DIESEL
P EAVY DI ESEL
8:3 DEA
1978
1978
1978
1978
YEAR
TOTAL
CUM TOT
E-23
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATThNS
ASSUMING FAN-OFF COMPLIANCE TESTING
WITH CREDIT FOP COST AND SAVIN5S FOP MOPE EFFICIENT FANS
FAN CLUTO-IEZ , AND EXH€IUST JOINTS
OPTION I REGULATION SCHEtØJLE:
REGULATION LEVEL
80 DBA 78 DE:A
1984 —
1984 —
1984 —
1984 —
ALL FISLPES IN BILLIONS OF DOLLARS
75 OBA
1988
1988
1988
1988
CAPITAL
1975
1976
197?
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1 9 8
1999
:2000
0. 0
• 0. 0
0. 0
—0. 1181672
—0.2271118
—0. 3258045
—0.4145692
—0. 4956881
-0.5698557
—0. 6208227
—0.6637452
—0.6993254
-0. 7289897
-0.6183662
-0.5049308
-0.388841?
—0. 2732772
—0. 1602126
—0. 0530904
0.0414217
0. 127940?
0.2081446
0.2807603
0.3304240
0. 3783063
0. 4246635
0. C i
0.0
0. 0
—0.1181672
-0. 3452789
-0.671 ic335
-1. 0856524
—1.581:3408
—2.151 1%5
-2.7720194
—3. 4 .357643
4.1350899
—4.8640776
—5.4824419
—5. 9873724
—6. 3762140
—6. 6494913
—6.8097019
—6. 8627901
8213673
—6. 6934242
—6. 4852781
—6. 2045 18:3
—5. 8740816
—5. 4957752
—5. 0711 098
0. 0
C ’. 0
0. 0
—0. 1334054
—0.2573302
—0.3707538
—0. 4738787
—0.5688847
—0. 6562667
—0. 7381527
—0.8106652
—0.8746990
—0.9 215279
—0.91 08602
—0.8850870
—0. 8542190
—0. 8208849
—0. 7868403
—0. 7546613
—0. 7258078
— 0.7013181
—0. 6803666
—0.5642578
—0.65184 c i i
—0. 6429803
— 0. 6374743
0. 0
0. 0
0. 0
0. 0152381
0. 0302184
0. 0449492
0. 05 3097
0. 0731967
0. 086.4112
0. 1173295
0. 1459204
0. 1753725
0. 2025394
0. 2924955
0. flU 1574
1 1.4653793
0.5476096
0.6266294
0.7015723
0.7672302
0.8292598
0 ,8885123
0. 9450199
0. 9822763
1 • 0212970
-1.0621386
GROWTH F TE FOP
PtDIUM 15A5: 0. 014
HEAVY SAt: —0. 002
P 1EflUM DIESEL: . 0. 015
HEAVY DIESELi 0.050
COST OF CAPITAL PATE: 0.10
l’EF’PECIA LE TRUCK LIFE: 10.0 TEARS
STRAIGHT LINE DEPRECIATION U EE’
PRESENT VALUE OF ANNUAL COSTS (1978 - 1991) —3.543 BILLION DOLLAP5
UNIFORM API IUALIZED COST (197$ — 1991) = —0.4 .91 BILLION DOLLARS:
TRUCK TYPE
MEDIUM S
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 BRA
1978
1978
1978
1978
YEAR
TOTAL
OJM TOT
OP & MNT
E-24
-------
PROGRAM TO COMPLITE COST OF NOISE PEGIJLRTIONS
TRUC9< TYPE
MEDIUM GAS
HEAVY E S
MEDIUM DIESEL
HEAVY DIESEL
83 t’BA
:9 :3
1978
1978
1978
75 PEA
1986
1986
1986
1986
1975
1976
1977
1978
1979
1980
1981
1982
1983
.1984
1985
1986
198?
I
1939
199’)
1991.
1992
1993
1994
1995
1996
1997
19%
1999
2000
0. 0
0. 0
0. 0
0.0204810
0.0409846
0. 0615281
0.0819441
0.1020972
C’. 1216724
0. 1403770
0. 1581289
0. .3542402
0.5485 :317
A, fl 1
0.926781?
1.1115112
1.2902900
1.4610405
1.6230679
1.7782888
1. 926057$
2. 0479794
2.1696215
2.2919054
2.4 15 122 Ij
2.540314?
0. 0
0. 0
0. 0
0.020481 0
0. 0614656
0. 122993?
0. 2049378
0. 3O?0349
0. 4287073
0. 5690841
0. 7272123
1.0814524
I • 6299839
2. 80 0
3. 295584?
4. 4070950
5. 6974821
7. 158521?
8.7815905
10.5598764
12. 4859343
14. 5339146
16. ?02 21 7
18. 9954224
21.4105530
2-3. 9508667
0. 0
0. 0
0.0
0.0104830
0.0211400
0. 0:319231
0. 0429245
0. 0538969
0. 0647163
0. 0751972
0. 0852742
0.19 17441
0. 2987937
A. 40A 342
0.5145 .387
0.6221473
0. 7279032
0. 8302 771
0. 9289787
1.0248165
1. 1 1?13’: ’3
1. 2075806
1 • 2962751
I •
I • 471165?
1 • 5585384
0. 0
0. 0
0.0
0. 0099980
0. 0198445
0. 0295450
0.0:39019?
0. 0482004
0. 0569551
0. 0651798
0. 0728546
0. 1624960
0.2497379
I I.
0.4122429
0. 4:393€55
0. 562490?
0.5307676
0. 6940938
0.7534771
0.8089300
0.8404006
0. 8733463
0. 9fl78392
0.9439560
0.9817746
GREmlIN PATE FOR
PEDItJM GAS: 0.0 14
b€RtY GAS.: —0. 003
MEDIUM DIESEL: 0. 015
HEAVY rIESEL: 0.050
cosi OF CAPITAL PArE: 0.10
DEPRECIABLE TRUCK LIFE: 10.0 EiRRS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF ANNUAL COSTS (1978 — 199D = 3.211 flLLION ItULLPR
UNIFORM ANNUALIZED COST ‘1978 — 1991) = 0.300 BILL ION DOLLARS
ASSUMING FAN—OFF COMPL I ANCE TESTING
WITHOUT CREDIT FOR COST AND SAVINGS FOP -MOPE EFFICIENT FANS
FAN CUJTCHES AND EXHAUST JOINTS
OPTION J PEGIJLAIION SCHEL UJLE:
REGILATI ON LEVEL
31) DEk 78 LEA
ALL F laRES IN BILLIONS OF tOLLARS
YEA R
TOTAL
CUM TOT
OP : . MNT
CAPITAL
E -25
-------
PR RAN TO COMPUTE COST OF MDI SE P EGLL.ATIOMS
ASSUMING FAN—OFF CUIPLIANCE TESTING
WTh CREDIT FOR COST AND SAVIPES FOR MORE EFFICIENT FANS,
FRI CWTCHES AVID EXHN)ST JOINTS
OPTION J REBJLATION SCHEDULEs
REGLLATIOM LEVEL
TRUCK TYPE 83 DIP 80 DIR 78 DIR 75 DIP
tEDIUM GAS 1978 — — 1986
HEAVY GAS 1978 — — 1986
MEDIUM DIESEL 1978 — — 1986
HEAVY DIESEL 1978 — — 1986
ALL FIGURES IN BILLIONS OF DQ..LARS
YEAR TOTAL CLII TOT OP S MNT CAPITAL
1975 0.0 0.0 0.0 0.0
1976 0.0 0.0 0.0 0.0
19?? 0.0 . 0.0 0.0 .0.0
1978 0.11916 7 2 —0.1191672 —0.1334054 0.0152381
1979 —0.2271118 —0.3452789 —0.2573302 0. 0302194
1980 —0.3258045 —0.6710835 —0.3707538 0.0449492
1981 —0. 4145692 —1.0856524 —0.473870 ? 0.059309?
1982 —0.4966881 —1.5813408 —0.568884? 0. 0731967
1983 —0.569855? —2.1511965 —0.656266? 0.0864112
1984 —0.6370222 —2.7882185 —0.7358141 0.0987915
1985 —0.6996188 —3.4868374 —0.8089315 0.1103132
1986 —0.6077017 —4.0945387 —0.812052? 0.2043514
199? -0.5099968 -4.6045341 —0.8056768 0.2956802
1988 —0.4090490 —5.0139913 —0.7896776 0.3806285
1989 —0.3039882 —5.3175659 —0.7671971 0.4632092
1990 —0.1975132 —5.5150795 —0.7403801 0.5428749
1991 —0. 0948073 —S.60988 —0.713364? 0.6185582
1992 0.0009485 —5.6089354 —0.6884554 0.6894049
1993 0.0892565 —5. 5196753 —0.6660621 0.7553195
1994 0.1709363 —$.348t368 —0.6463997 0.8173263
1995 0.2439764 —5.1047583 —0.63146P9 0.8754445
1996 0.2900994 —4.8146553 —0.6193346 . 0.9094351
1997 0.3343803 —4.4802742 —0.61063*3 0. 9450199
1998 0.3776294 —4.1 0 86449 —0.6046458 0.9822763
1999 0.4194588 —3.663 18% —0.6018280 1.0212870
2000 0.460383? —3 .2228 0 82 —0.6017541 1.0621386
GROWTH TE FOP
NEDILVI GAS! 0.014
HEAVY GASU —0.0GB
PEDIUI DIESEL’ 0.015
HEAVY DIESEL’ 0.050
COST OF CAPITAL PATE’ 0.10
DEFRECIAPLE TRUCK LIFE’ 10.0 YEAPS
STRAIGHT LINE DEPRECIATION USED
PRESENT VALUE OF AIt4UAL COSTS (1978 — 1991) s —3.1711 BILLION DOLLARS
UNIFONI RflNUALI D COST (1978 — 1991) • —0.430 BILLION DOLLARS
F -
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATt DM5
ASSUMING FAN-OFF COM LI A l ICE TESTING
WITHOUT CREDIT FOR COST AND SAYINGS FOR MOPE EFFICIENT FANS,
FAN CLUTCHES, AND EXHRflT JOINTS
OPTION K REGULATION SCHEDULE I
REGULATION LEVEL
TRUCK TYPE 83 VIA 80 I% 78 DBA 75 IlI s
MEDiUM GAS 1978 1982 — 1984
HEAVY GAS .1978 1982 — 1984
MEDIUM DIESEL 1978 1982 1984 —
HEAVY. DIESEL 1978 1982 1984 —
ALL FIGURES IN BILLIONS OF flLMS
YEAR TOTAL CUll TOT OP S lINT CAPITAL
1975 0.0 0.0 0.0 0.0
1976 0.0 0.0 0.0 0.0
1977 0.0 0.0 0.0 0.0
1978 0.0204810 0.0204810 0.0104830 0.0099980
1979 0.0409946 0.0614656 0.0211400 0.0198446
1980 0.0615281 0.1229937 0.0319831 0.0295450
1981 0.0819441 0.2049378 0.0429245 0.03 019?
1982 0.1365952 0.3415229 0.0712225 0.0653626
1983 0.1904693 0.5319920 0.0996146 0.0908546
1984 0.3140994 0.8460915 0.1633594 0.1507399
1985 0.4354258 1.2815170 0.2271179 0.2093080
1986 0.5544642 1.8359814 0.2908866 0.2635780
1987 0.6700710 2.5060520 0.3540295 0.3160417
fl’S S 0.tP9us 4 3.28Su8?6 U. øLb lfle U.db d4 ?O
1989 0.8832455 4. 1 3331 0.4?66E9L 0.4065799
1990 0.98 21458 5. 1504774 0.5350515 0.44709?8
1991 1.0752535 6.2257309 0.5908805 0.4943773
1992 1.1595631 7.3852921 0.6448755 0.514 5926
1993 1.2401962 8.6254873 0.6968309 0.5433692
1994 1.3092794 9.9347658 0.7474465 0. 5 61834?
1995 1.3780060 11.3127708 0.7968773 0.5811?00
1996. 1.4468909 12.7596617 0.8455985 0.6012936
1997 1.5161619 14.2758207 0.8937943 0.6223680
1998 1.5861015 15.8619194 0.9417031 0.6443980
1999 1.6572475 17.5191650 0.9898171 0.6674291
.2000 i.7a94693 19.248626? 1.0379572 .0.691510?
GROWTH PATE . FOR
PEDIUP’ GAS’ 0.014
HEAVY GAS’ —0.003
MEDIUM DIESEL’ 0.015
HEAVY DIESEL’ 0.050
COST OF CAPITAL PATE’ 0.10
DEPRECIABLE TRUCK LIFE’ 10.0 YEARS
STRAIGHT LIME DEPRECIATION USED
PRESENT YA$..UE OF AMPiupqL COSTS U978 — 1999 a 2.560 BILLION DOLLARS
UNIFOPM Mt4UALIZED COST (1978 — 1999 • 0.347 BILLION DOLLARS
E-27
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS.
A8SIIMING FAN—OFF COMPLIANCE TESTING
1 ,1 1TH C? Et’ IT FOR COST AND :5:AV 114155 FOP MOPE EFFI CIENT FANS ’
FAN C:IJJ Tc:It 5, AND EXHAUST JO 1 1 115
OPT ION K PEGULAT tori SCHEDULE:
REGULATION LEVEL
TRUCK TYPE :33 PEA :30 DE 7:3 PEA
MEDIUM GAS 1978 1332 —
HEAVY GAS 1978 19E:2 —
MEDIUM DIE:SEL 197 8 198:2 1 984
HEAVY DIESEL 197 :3 1 982 1994
ALL FII9JPE:S. IN BILLIONS; OF DDLLA S’
1975
1976
19??
1978
1979
1980
1981
1982
1983
1984
1985
1986
19:37
198 :3
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
I 999
2001’
0.0
0. 0
0. 0
—0. 1181672
—0.2271119
—0. 3258045
—0. 4145692
—0.48159:35
—0.539279:3
—0. 5251973
—0. 5028592
—0. 4743145
—0.4421808
—0.4128745
—0.3:344516
—0.358( 1843
—0.33 61322
—0.3223214
—0.3124264
—0. 314660:3
—0.31866:37
—0. 3240921
—0.3306250
—( 1.3:389074
—0. .34:3:3195
—0. 359606?
0. 0
0. 0
0. 0
— 0. 1181672
—0.:3452789
—0.6710835
—1.0856524
—1. 5672455
—2. 1 065254
—2. 531723
—.3.1345:325
—3. 5i: :33972
—4. 051 0778
—4. 4639511
—4. 8484 020
—5.2084829
—5. 5426162.
—5. 8549349
—6. 177:3615
—6. 492fl20E.
—6. :31 06:31:3
—7. 1347723
—7. 4653978
—7. 804:3051
—8. 152620.3
—8. 5122252
0. 0
0 • 0
0. 0
—0. 1:3:34 054
—0.257:3:302
—0.370752 .8
—0. 47:3:3797
—0. 573140:3
—0. 6599 :393
—0.71 08213
—0. 7507563
—0.7.31:373 5
—0. 805276:3
—0.
—0. 2440217
—0. 3E )641 0
—0. 8784468
—U.
—0.9185557
—0. 94 1 7167
—0. 967474?
— 0. 99554 :34
—1. 0259495
—1 . 059 O879
—1 . 09449? 0
—1. 1:32951 ?
0. 0
0. C I
O 0
0. 0152:3:31
0. cr302184
0. 0445492
0. 0593097
o. t:9 547C;
0. 1206604
1 ’. 1856243
0.247296?
0.3640952
I:. 4595706
0.5025556
i:. 5423099
0. 5750?30
.6062407
0.6270564
I: ,. 64 E:115
u.6715519
0. 695:325 1
0.7201 :s15
0. 746 1 7 2
0. 7733555
GPO JTH RATE FOR
MEDIUM GAS: 0. 014
HEA’ii iSAS: — 1:1. 1: 11: 1: ::
r1EDIIJFI nIESEL: o.
k€AVY DIESEL: 0. 050
COST OF CAPITAL PATE: 0. 10
DEPPECIA ILE TPUI::K LIFE: 10. 0 YEAR S
5IRAIGHF LINE DEPRECiATION USE r.
PRESENT VIiLUE OF ANNUAL COSTS gj9 ?O — 199 i ’ = —3. ‘133 pILLION D OLLARS
UNIFORM ANNUALIZED COST ‘t 97:3 — 1991 : . = —0. 412 BILLiON tOLLAVS
YEAR
TOTAL
75 PEA
19:34
19:34
OP & MNT CAPITAL
CU N TO T
E-28
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASS(JMII$5 FAN—OFF COMPLIANCE TESTING
WiTHOUT CREDIT FOP COST AND 5AV INGS FOP
FAN CLUTC}tS AND EXHAUST JoINT:
MORE EFFICIENT FANS
OPTION L REGULATION SCHEDULE:
REGULATI ON LEVEL
TRUCK WPE 8:3 PEA 80 t IFA 78 PEA
MEDIUM GAS 1.978 1982 —
HEAVY GAS 1978 1982 -
MEDIUM DIESEL 1978 1982 —
HEAVY DIESEL 1978 1982 —
ALL FIGURES IN BILLIONS OF DOLLARS
TOTAL CUM TOT
cP9WTH PATE FOP
r EDIUM 5f 1::: 0.014
HEAVY GAS: —0. 003
MEDIUM DIESEL: 0.015
I AVY DIESEL: 0. 050
CO:ST OF CAPITAL RATE: 0.10
t IEPPECIAPLE TRUCK LIFE: 1 0.0 YEA RS
STRAIGHT LINE DEPRECIATI ON USED
75 PEA
1984
1984
PPE:SENT VALUE OF ANNUAL COSTS: <1978 — 199 1:’ 2.205 FILLION DOLLARS
UNIFORM ANNUALIZED COST ‘:1978 — 1991:’ = 0.299 FILLION DOLLA PS
YEAR
OP PINT
CAPITAL
1975
0.0
0.0
0.0
0.0
1976
0.0
0.0
0.0
0.0
1977
0.0
0.0
0.0
0.0
1978
0.0204810
0.0204810
0.01048:30
‘3.0099980
1979
0.0409846
0.%14656
0.0211400
0.0198446
1980
0. 0615281
0.12299:37
0. 0319831
0.0295450
1981
0.0819441
0.2049379
0.0429245
0.0:390197
1982
0. 1365852
0.3415229
0. 0712225
0. 065.3626
1 33
0 1 04 3
0 531 2’i
0 0 14
u fl 0354t
1984
0.2876974
0.8196895
0.1496273
0.1380700
1985
0.392290?
1. 20 1979 5
0. 1991978
0. 18309:31
1986
0.4742:341
1.6762142
0. 2482986
0.2259359
1987
0.5625948
2. 2388086
0.2?64032
0.2651918
;::
r - T -c- t :—
: E 1c
I i 4c:t..
U .11 11 ) 1 34
133
u 7&13u1
- E”4 E5
‘1 3954i i79
u 3 3 72
1990
0.794793 4
4.3997507
0.4317017
0.36:30947
1991
0.8629819
5.2627287
0.4727972
u.:390 1; 5
1992
0.9230935
6. 1858195
0.5122929
0.4108047
1 3
0 3 ’i 22
7 1e 2 f I 2
0 55111c112
L I 43ijj7 3
1994
1.0298424
8.1960506
0.5867254
0.44:31193
1 5
1 fl727754
274?2t 0
i i 22.Era4
0 45 11
1996
1.1275606
10. 402:3357
0. 65708.44
0.4704770
1997
1.1764021
11.5787349
0.691: 3574
0 .4850447
1998
1.2254295
12.8042145
0.7251868
0.50024 .24
19
1 27511222
14 II7 .E4LE
II 5E 2
Is 51 1 f l I-
2000
1.3251581
15.4043961
0.7925 061
0.5326507
E-29
-------
PROGRAM TO COMPUTE C0:S:T OF NOISE PEGULATI oils
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1997
1988
1999
1990
1991
1 92
1993
1994
1995
1996
1997
199 3
1999
2000
0. 0
0. 0
0. 0
—0.1181672
—0.2271118
—0. 3258045
—0. 4145692
—0.4815935
—0. 5:392799
—0.553 8099
—0.5 503318
—0.56092:31
— IL S 7Q71 4
—0.5577247
—0.557794 Ci
—0.5589414
— (‘ .5634414
—0. 5752901
—0. 5901353
—0. 6133911
—0.6335510
—0.6654326
—0. 6937594
—0. 7243387
— ii . 7567188
—0. 7915612
0. 0
0. 0
0. 0
—0. 1181672
—0. 3452789
—0. 671 0835
—1. 08565Q4
—1. 5672455
—2. 1( 165254
—2.6603355
—:3 2206678
—3. 7815905
—4. fl39 A
—4, :3972836
—5.4550772
—6. 0140171
—6. 5774546
—7.1527424
—7. 7428770
—3, :355 55j
—8.9943158
—9.6602478
—10.35400:39
—11. 079:3405
—11.8:350554
—12. 6266155
0. 0
0. 0
o. 0
—0. 1334054
—0.257:3:302
—0. 4738787
—0. 5214U:
—0. 6599398
...C,
-.
—0. 7831401
—0.3 .310287
—i i. 47 ?4A 4
—0. 9095494
—0. 9445475
—0.9779151
—1. 012 ( 13 15
—1.. 0469933
— t . 08:3846 ,1
—1.1223221
—1. 1633625
— 1.2068186
—1 • 252442?
—1.:3010798
—1.3523140
—1. 4068451
0. 0
0. 0
0. 0
0152 3:31
0. 0302184
0. 0449492
0. 0593097
0. 0908470
0. 1206604
ii i7-3’: ’1C;:
0.2701 061
I ,. :3 144’i47
0.3519385
0. :3:367 :5
0.41297 39
u: . 44359 tt:
0.47170 13
0.49 .371 16
0.508 93 41
0.5248135
0.54 13 87 3
o. 5586345
0.5767421
U. S ’’A I I
0. 6152842
COST OF CAPITAL PATE: 0.10
DEPRECIABLE TRUCK. LIFE: to. 0 YEAR::
5TF IGNT LINE r ’EPPEC IAT.ION USED
PRESENT VALUE OF ANNUAL OSTS (1973 — 1991:’ = —3.419 BILLION FOLLA;::
uNIFORM ANNUALIZED COST (1978 — 1991:’ = —0.454 BILLION DOLLARS
ASSIJNItI5 FAN—OFF COMPLIArCE TEST In’;
I ITH CR IT FOP COST AND SAVINGS FOP MOPE EFFICIENT FANS
FAN CLUTCHES. AND EXHAUST JOINTS
OPTION L REGULATION SCHEft ILE:
PEG ULAT ION LEVEL
7:E: DEA
TPui::K Ti? E
MEDIUM GAS
HEAVY GAS:
MEDIUM DIESEL
HEAVY DIESEL
33 BBA
1978
197.8
1978
1978
8 (i BE A
1982
I 9.32
1982
1982
ALL FIGURES IN BILLIONS OF DOLLARS:
YE AR
75 tEA
1984
1984
OP & MNT
TOTAL
CUM TOT
CAP I TAL
GRO IITH PATE FOP
PE DI UN 5A5: 0. 014
HEAVY i3A.3 : —0. 003
POX UN DIESEL: 0. 015
HEAVY DIESEL: u:. 050
E-30
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASS uMING FAN—OFF COMPLIANCE TEST 1MG
WITHOL Ir CREDIT FOP COST ANt’ S / INGS FOP
FAL4 CLUTCHES. AND EXHRIJST •JO IN Ti
OPTI ON N PEGIJLAT ION ;CHEDULE:
REGULATION LEVEL
80 DBA 78 LEA
1982 —
1962 1984
1982 —
1982 1984
ALL FIGURES IN BILLIONS. OF DOLLARS
MOPE EFFICIENT FAN
TOTAL
OP &. MNT CAPITAL
1975
1976
1977
1978 ’
1979
1920
1981
1982
1983
1984
1 9 • 5
1 Z:6
1 C 9 7
L •94 ; .
1989
1990
1991
1992
1993
1994
1995
1996
1997
1 9 3
1999
2000
0. 0
0. 0
0.0
0. 0204810
0. 0409846
0.0615281
0.0819441
0. 1365852
0. 1904693
0.3109542
0.4293294
0.5456066
0.6586665
‘3. 5 ‘ 3(1
0.8674483
0. 9445538
1.0561686
1. 1392221
I . 2188501
1 .2876749
1. :3561974
1 . 4249239
1 . 4940796
1.5639400
1.6:350307
1.7072325
0 • 0
0.0
0.0
0.0204810
0. 0614656
0.1229937
0.2049378
0.3415229
0.5:319920
0.8429463
1 2722750
1.8172216
2.4755482
3.2418556
4.1093035
5. 0738621
6.1300278
7.2692490
8.4880991
9.7757711
11. 1319695
12.5568895
14. 05 1: 19672
15.6149063
17.2499237
18. 95716:36
0. 0
0. 0
0. 0
0.0104830
0.0211400
0.1)319:3:31
0. 0429245
0. 0712225
0. 0996146
0. 162:3694
0.2251914
O.2 .3 $0 7 :3
0.3503952
0.4117925
0.4715709 .
0. 5293240
0. 5846087
0.6381266
0. 6896845
0. 7:399595
0.7891005
0. 8855746
0.9:33317; :
0. 98 1289 7
1. 029323.5
0. 0
0. 0
U • 1$ I_I 4 I_I
0. 0158445
0. 1 ) 29545 ( 1
• lJi_., : .dS
0. 0908546
0. 1485848
0.204 1382
0. 25753(9
0. 3082705
1’. .3535155
0. 3958804
0.4:352381
0.4715540
0.5011 i)0
0.5291694
0.5 477191
0. 5470989
0. 5873471
O ‘ OA ‘
it ,,
u.t S.37395
0. 6779077
COST OF C IIPITAL PATE: 0. 10
DEPRECIABLE TRUCK LIFE: 1 0. 0 YEAR 3
STRAIGHT LI NE DEPRECIATION lJ ED
PPF :ENT VALUE OF ANNUAL i::OSTS: ‘: 19 3 — 1991.: ’ = C 4 E lI LION DOLLARE:
UNIFORM ANNUALIZED COST 1578 — 1991:’ = 0. 343 BILLION DPLL iF
TPUc. K TYPE
lED I UN GAS
HEAVY GAS
MEDIUM DIESEL
HEAVY DIESEL
83 LEA
1978
1978
1978
1978
75 MA
1964
1984
YE AR
CUM TOT
‘3RO’.,ITH PATE FQP
N E DI UN GAS: 0. 014
HtriVY : —i_i . ill_i: ::
PC DI UN r’ I ESEL: 0 • 015
1-EAVY DIESEL: 0. 050
E-3 1
-------
PRO ’3F M TO COMPUTE COST OF NOISE FEGULATIONS
1975
1976
1977
1978
1979
1980
1981
1982
1 9 3
1984
1985
1986
1988
19*9
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0.0
—0. 1181672
—0.2271118
—0.3258045
—0.4145692
—0. 4815935
—0. 5392798
—0.5287439
—0.5097009
—0.4842040
—0. 454S45t
—0.4280466
—0.4( 118429
—0.3773937
—0.3570406
—0.3445578
—0.3.357186
—0. 3382533
—0.3424909
—0.3480973
—0. 3547553
—0.3631270
—0. 3725947
—0.3839037
0. 0
0. 0
0. 0
—0.1181672
—0. 3452789
—0. 6710835
—1. 0856524
—1.5672455
—2.1065254
—2.6352701
—3. 1449709
—:3 6291742
—4. 0840197
—4.51206.30
—4.9129051
—5.2912979
—5. 4483383
—5. 9928942
—6. 3286104
r 6 • 66 B8625
—7. 0093489
—7. 3574438
—7. 712198:3
—8. 0753250
—8. 4479179
—8.8318195
0. 0
0.0
0. 0
—0. 1334 054
—0. 2573302
—0. 3707538
—0. 4728787
—0. 5721408
—0. 6599398
— i i. 7122322
— 0. 7534653
—0. 7857702
—0.8112383
—0. 8321579
—0. 85090*8
—0. 8681959
—0. 8866498
—0. 3061576
—0. 9278840
—0. 9513175
—0. 9773925
—1. 0058231
—1. 0362398
—1. 0696507
—1.1051950
—1.1437712
0. 0
0. 0
U. 0
0.0152281
0.0302184
0. 0449492
0. 0593057
0.0905470
0. 1206604
0. 1834885
0.242 7547
0.30 156 4
0.2563932
0.4041213
0. 4499661
0.4908019
0.5296 1 )94
0.5616007
0.5921659
0.6130644
0.63490 25
0.5577267
0.681 5836
0.7065247
0.7326006
0. 7598681
COST OF CAPITAL PATE: 3•jIu
DE PECIAPLE TRUCK LIFE: 10.0 YEARS
::TFAIP5HT L INE r ’EPPEC IAT ION ft EI
PRESENT VALUE OF ANNUAL COSTS 197* — 1951) = —:3. 07* BILLION DOLLARS
UNIFOct 1 ANNUALI:EI’ COST (1978 — 1991) = —0.41 * BILLION DOLLARS
ASSUMING FAN—OFF COMPLIANCE TESTING
1 ’ITH CRED IT FOP COST AtI ’ SAVINGS FOP I UPE EFFICIENT FANS,
FAN CLUTCHES AND E; •:HAUST .JOINT:
OPT 101 M PE’5ULAT I ON SCHEDULE:
PEGULAT I ON LEVEL
TRUCK TYPE 83 t’BA 80 DBA 7* t uBA
75 t uBA
MEDIUM GAS 1978 1 982 —
1984
HEAVY GAS 1978 1 982 1984
—
MEDIUM DIESEL 1978 1982 —
1984
HEAVY DIESEL 1978 1982 1984
—
ALL FIGURES IN BILLIONS DOLLARS
EAR TOTAL CUM TOT OP & MNT CAPITAL
G;D JTH PATE FOP
MEt ’ IIJpl GAS: 0.014
HER ’Y GAS: —0. 00:3
ME L ’ I UN DIESEL: 0 • 015
HEAVY DIESEL: 0. 050
E-32
-------
PROGF M TO C.OMPIJTE COST OF N f l SE REGULAT’IONS
ASSUMING FAN—OFF COMPLIANCE TESTING
I JITHOI JT CREDIT FOP COST AND SAYINGS FOP
FAN CLUTCHES, AND EXHAUST JO I NTS
MOPE EFFICIENT FANS,
OPTION N REGULATION SCHEDULE:
REGULAT ION LEVEL
wucv TYPE :3 PEA 80 PEA 78 PEA
MEDIUM GAS 1978 1982 —
HEAVY GA 1978 1982 —
MEDIUM DIESEL 1978 1982 —
HEAVY DIE:SEL 1978 1982 —
ALL FI’9JPES IN BILLIONS OF DOLLARS.
75 PEA
1984
1984
1975
1976
1977
1978
1979
198(1
1981
1982
1983
1994
1985
1986
1987
1988
J9:39
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
0. 0
0. 0
0. 0
0.0204810
0. 0409846
0. 0615281
0.0819441
0. 1365852
0. 1904693
0.2815419
0.970264:3
0.4566180
0.5397210
0.6165844
0. 6895989
0.7586805
0.8235167
0.8807513
0.9356748
0.9839022
1.0318069
1. 0797272
1. 1279658
1.1763191
1 .2254419
1.2752218
0.0
0. 0
0. 0
0. 02044310
0. 0614656
0. 12299:37
0.2049378
0.3415229
0.5319920
0. 81:35339
1. 1837978
1.6404161
2. 180137 4
2.7967215
3.4863205
4.2450008
5.0685167
5.9492674
‘.8849411
7.8688412
8.9006481
9. 9803743
11. 108237:3
12. 2 45545
13.5099964
14.7852163
0. 0
0. 0
0. 0
0. 0104830
0.0211400
0. 0:3198:3 1
0. 0429245
0. 0712225
0. 0996146
0.1464452 -
0. 1929252
0.2390260
0. A49 14
0. 3283653
0. 37096?Q
0.4119503
0.451 0093
0.4987015
0.5249917
0. 56 02593
0. 5946552
0.6284912
0.6619410
0.6950771
_t —,--fl—. — ’ -
I ) • ucd u U
0.7613311
0.0
0.0
0. ’)
0. 0099980
0. 0 19:3446
0. 0295450
0.0 .39019?
0. 0653626
0. 0909546
0. 135C ’96
0.177?397
0. 217S9 5
r a .ca
0.2882214
0.3186358
0. 3467:3.30
0.3725112
0. P920537
0.4106874
0.4236472
0.4371561
0.4512402
0. 4659251
0.4:31242;’
0.4972206
0. 5 13:39 0
cOST OF CAPITAL PATE: 0. 10
DEPRECIABLE TRUCK LIFE: 1 0 0 YEAP’
TPAIGNT LINE DEFPECIATIOrI ‘JSED
PESENT VALUE OF ANNUAL C oSTS (1976 — 1991 = 2. 1:32 BILLION DO LAP.S
UNIFORM ANNUALIZED COST (1978 — 1991) = 0.289 BILLION DOLLARS
YEAR TOTAL CIJM TOT OP & MNT CIRPITAL
POWTH PATE FOP
MEDI LIM t A: :: 0. 014
HEAVy i Ar :: —0.
P€ DIu DIESEL: 0. 015
HEF(QY DIESEL: 0. 050
E-33
-------
PROGRAM TO COMPUTE COST OF NOISE REGULATIONS
ASSUMING FAN—OFF COMPLIANCE TESTING
WITH CPE BIT FOP COST AND SAVINGS FOR NOPE EFFICIENT FANS,
FAN CWTCHES’ AND EXI’PUST JOINTS
OPTION 11 REGULATI ON SCHEDULE’
REGULATION LEVEL
TRUCK ‘r,PE 83 ’ DBA 80 DBA 78 DBA 75 DBP
MEDIUM GAS 1978 1982 — 1984
HEAVY GAS 137$ 1982 — —
TEDIUM DZ,ESEL 197$ 1982. — 1984
HEAVY DIESEL 1978 1982 — —
ALL FIGURES IN BILLIONS OF DOLLARS
YEAR TOTAL GUM TOT OP &PINT CAPITAL
1975 . 0.0 0.0 0.0 0.0
1976 0.0 0.0 0.0 0.0
1977 0.0 0.0 0.0 0.0
1978 —0.1181672 e O.11916fl —0.1334054 0.0152381
1979 —0.2211118 —0.34 ?89 —0.257330 ! 0.0302184
1980 —0.3258045 -0.6710835 - ‘0.3707538 0.0449492
1981 —0.4145692 —1.08 5 6524 —0.473878? 0.0591097
1982 —0.4915935 —1.5678455 —0.5721408 ‘ 0.0905470
1983 —0.5392798 —2.1065254 —0.6599398 0.1206604
1984 —0.5605813 —2.6671076 —0.7306524 0.1700709
1985 —0.57 05O —3.2406120 —0.7906111 0.217106 2
198$ —0.5801346 —3.8207464 —0.8419714 0.2618369
itS? —4.SeéóOeé — #.*ô35521 —&.i3óó?42 u.iô3h ’Tó
1988 —0.5877478 —4.991198? —0.9269133 0.3391662
1989 —0.5925020 —5.5*37975 —O.964624o 0.3721223
1990 —0.5977705 —6. 1815681 —1.0005264 0.4027563
1991 —0.6057827 —6.787349? ‘1.0368509 0.4310691
1992 —0.6206402 —7.4079985 —1.0737562 0.4531174
1993 —0.6379538 —8.0459404 —1. 1122475 0.4742942
1994 —0.6625136 —8.7084522 —1.1521425 0.4896302
1995 —0 . 6 887631 —9.3972149 -“1.1943884 0.5056269
19% —0.7165550 —10.1137686 —1.2388706 0.5223165
1997 —0.7456172 —10.8593845 . —1.2853470 0.5397309
1998 —0.7768Q02 —11.6361828 “i.334 ?044 0.5579054
1999 —0.8096752 —12.4458551 —1.3865519 0.5768770
2000 —0.8448834 —13.2907372 — 1.441565 5 0.5966835
GPDhITH RATE FOR
TEDIUM GAS I 0.014
HEAVY GAS’ —0. 003
TEDIUM DIESEL’ 0.015
HEAVY DIESELI 0.050
COST OF CAPITAL RAVEl 0.10
DEPRECIABLE TRUCK LIFE; 10.0 YEARS
STPAIG4T LINE DEPRECIATION USED
PRESENT YtUE OF ANNUAL COSTS (1978 — 1991) a -3 49$ BiLLION DOLLAfl’
IMIFORN ANNUPLIZED COST (197$ — 1991) a —0.475 BiLLION DOLLARS
E-34
-------
Appendix F
NET OPERATING INCOME DEFINED
Net Operating Income is computed as in Trinc’s Blue Book [ 1 ). Numbers in parenthe-
ses indicate the numbers in 1975 edition.
Net Operating Income = Operating Revenues (14) Minus Total Operating Expenses (21).
Total Operating Expenses (21) consist of the following:
• Salaries of Officers and Supervisory Staff (26)
• Salaries and Wages (27)
• Miscellaneous Paid Time Off (30)
• Other Fringe Benefits (31)
• Operating Supplies and Expenses
Fuel, Oil, Tires, etc. (33)
• General Supplies and Expenses (37)
• Operating Tax and Licenses (38)
• Insurance (41)
• Communications and Utilities (45)
• Depreciation and Amortization (46)
• Revenue Equipment Rents and Purchased Transportation (48)
• Building and Office Equipment Rents (51)
• Gain or Loss on Disposal of Operating Assets (52)
F-l
-------
• Miscellaneous Expenses (53)
All items listed above are attributable to the following activities. Trinc’s gives this break-
down also.
• Unehaul (54)
• Pickup and Delivery (55)
• Billing and Collecting (56)
• Platform (57)
• Terminal (58)
• Maintenance (59)
• Traffic and Sales (60)
• Insurance and Safety (61)
• General Administrative (62)
REFERENCES FOR APPENDIX F
[ 1] TRINC TRANSPORTATION CONSULTANTS. TRINC ’s Blue Book of the Trucking
Industry, published annually by TRINC Transportation Consultants, Division of
Dun & Bradstreet, Inc.
F-2
-------
Appendix G
METHOD FOR COMPUTING IMPACT ON A SPEC IFIC SECTOR
OF THE TRUCKING INDUSTRY
Table 6. 1 gives the total annual costs by truck type for all purchasers of trucks. To
adjust for the different mixes purchased by various sectors, we compute the following
equation for a given year for each type of truck.
M C . . .(G-l)
where
is the total annual costs for truck type j,
is the sector percentage for the particular year in question,
is the baseline percentage for that year,
M is the market share and
is the costs for truck type j.
Example: The For-Hire Sector
The projected truck mix* for the for-hire sector is
Medium Heavy Medium Heavy
Gaso linç Gasoline Diesel D i scl
32 .68% 19 .21% 2.36% 45.75%
This is substantially different from the total population given in Table 6.2 111. Adjust-
ments factors for the for-hire sector are given in Table 6.3. The projected market
share of trucks purchased by the for-hire sector is 50.6 percent.t The noise-control
regulation itself may cause a change in purchase-mix due to the use of thermostatically
controlled fans and the resulting savings. Accurate figures of the market share and purchase-
mix in the for-hire industry are difficult to obtain.
‘These figures assume that new trucks are purchased in the same proportion as those presently owned by a particular
sector. The trend toward heavier diesel trucks may change these numbers. The source for present ownership is the 1972
Census of Transportation, Truck inventory, and Use Survey.
tSee Table 7. 18 for 1980 Projected Market Share. It is assumed that trucks are purchased in proportion to revenue share.
6-1
-------
Table G.1
Total Annual Costs by Truck Type (Millions of 1975 $)
Truck Type
Without Fan Savings
With Fan Savings
1981
1991
2000
1981
1991
2000
Option A:
Mediumgas 11.4 350.5 493.0 (66.9) 41.2 106.8
Heavy gas 3.9 70.6 88.7 (639) (42.1) (25.6)
Medium diesel 1.6 15.0 21.2 (.4) 7.8 12.1
Heavy diesel 65.1 1093.8 1984.5 (283.4) 114.2 409.7
Option C:
Mediumgas 11.4 249.7 363.2 (66.9) (68.9) (35.5)
Heavygas 3.9 47.7 61.0 (63.9) (67.1) (55.7)
Medium diesel 1.6 11.2 15.7 (.4) 3.7 6.2
Heavy diesel 65.1 643.0 1132.1 (283.4) (338.9) (447.1)
Option E:
Mediumgas 11.4 93.6 116.9 (66.9) (159.4) (192.4)
Heavygas 3.9 22.4 25.4 (63.9) (92.9) (91.9)
Medium diesel 1.6 6.3 7.8 (.4) (.6) (.9)
Fleavydiesel 65.1 435.6 735.7 (283.4) (561.9) (871.9)
Option N:
Medium gas 11.4 350.5 493.0 (66.9) 41.2 106.8
Heavy gas 3.9 22.4 25.4 (63.9) (92.9) (91.9)
Medium diesel 1.6 15.0 21.2 (.4) 7.8 12.1
Heavydiesel 65.1 435.6 735.7 (283.4) (561.9) (871.9)
-------
Table G.2
Baseline Sales Projection Resulting Truck Mix
Truck Purchase
Mix Used
Percent
1983
1985
1990
Medium gasoline
Heavy gasoline
Medium diesel
Heavy diesel
45.40
7.85
.69
46. OQ
100
44.05
7.37
.67
4 7 92
100
40.58
6.24
.62
52.56
100
Table G.3
Adjustment Factors for the For-Hire Sector,
Using 1991 Baseline Mix*
Medium gasoline
Heavy gasoline
Medium diesel
Heavy diesel
32.68/40.58:
19.2 1/6.24 :
2.36/ .62 :
45 .75/52.56:
.8053
3.0785
3.8065
.8704
*This is slightly inaccurate as this mix is not adjusted for the elasticity of demand.
Table G.4 shows the total annual costs for the for-hire sector. Any one company
will differ from the aggregate. Tables G.5 and G.6 show these costs as a percentage of
for-hire revenues and operating income, respectively.
Summary
To assess the impact of the regulation on any group with a different purchase mix, it
is necess4ry only to recompute the costs using equation (G-1). This is also true if we
G-3
-------
Table GA
Total Annual Costs for the For-Hire Sector Adjusted for Truck-Mix
and Market Share in 1990 and 2000 (Millions of 1975 $)
Without Credit for Savings
With Credit for Savings
1991
2000
1991
- 2000
Option A
Option C
Option E
Option N
763.4
480.8
277.0
398.4
1253.9
771.9
426.2
605.3
32.7
(274.7)
(458.3)
(360.4)
207.4
(136.6)
(607.3)
(460.3)
wish to adjust the mix of the total population shown in Table A.21 . In this case the
equation would be
F.
Ct= (B tj
i-I ... (G-2)
where
is the total costs for all four types of trucks for a given year, and
FJ is the forecast percent of sales for each truck type j.
it is critical to remember that certain sectors will experience a more than average share of
savings while others will experience more than average costs. Table G.7 shows the mix by
sector of present truck ownership. These percentages can be used to compute a sector’s
specific costs assuming that trucks are purchased in the same proportion that they are
owned.
*There are some indications that the mix thosenby A. 1’. Kearney 1J is not representative.
G-4
-------
Table G-5
Total Annual Costs as a Percentage of Revenues*
For the For-Hire Sector
Without Credit for Savings
With Credit for Savings
—
1991
2000
1991
2000
—
Option A
1.298
1.663
.056
.275
Option C
.818
1.024
(.467)
(.181)
Option E
.471
.565
(.779)
(.805)
Option N
.678
.803
(.613)
(.6 10)
*Ba$ed on Table 7.23
Table G-6
Total Annual Costs as a Percentage of Operating Income*
Without Credit for Savings -
1991 2000
Option A 27.33 - 35.01
Option C 17.22 22.56
Option E 9.92 11.89
Option N 14.27 16.90
*Assumes Opctatin Income is 4.75%
Table G-7
Medium and Heavy Truck
Mix by Sector
Medium Medium Heavy Heavy Total
Sector Gas Diesel Gas Diesel Percent
Agriculture 87.59 .41 9.61 2.39 100
Forestry and Lumbering 52.99 .62 24.29 22.09 100
Mining 49.47 1.23 24.07 25.24 100
Construction 11.87 4.52 48.94 34.68 100
Manufacturing 47.82 1.90 20.79 29.49 100
Wholesale and Retail 72.70 .15 16.53 10.62 100
For Hire 32.68 2.36 19.21 45.75 100
Personal Transportation 96.12 0 3.88 0 100
Utilities 79.66 1.91 17.18 2.98 100
Services 87.38 2.24 7.57 2.8 100
AllOther 71.85 4.15 13.14 10.87 100
*Source: Based on 1972 Census of Transportation Truck Use and Inventory Vol. II
G-5
-------
REFERENCES FOR APPENDIX G
[ I] KEARNEY, INC, A. T. A study to determine the economic impact of noise emission
standard in the medium and heavy duty truck industry (EPA Contract No. 68-01-154),
A. T. Kearney, Inc. (1974).
G-6
-------
Appendix H
COST ANALYSIS OF PRODUCFION VERIFICATION AND
SELECTIVE ENFORCEMENT AUDITING FOR THE
MEDIUM AND HEAVY DUTY TRUCK INDUSTRY
An analysis has been performed to estimate the costs associated with typical manufac-
turer production verification testing and selective enforcement audit testing.
For the analysis, it was assumed that most of the testing would be done at the manu-
facturer’s facility. However, because some manufacturers may prefer not to construct a test
facility, an EPA facility will be available for their use at a fee which will cover actual costs
incurred by the government. Data gathered from manufacturers and the assumptions listed in
Table H-i served as the basis for the analysis.
From this analysis, it has been projected that the total cost to the industry for produc-
tion verification testing during the first year of compliance will range from $64,600, if all
testing is done at manufacturer’s test facilities, to $99,600 if all testing is done at the EPA
test facility. The true figure should lie somewhere between these two values. In subsequent
years, this figure can be expected to decrease due to the fact that manufacturers may be able
to utilize the initial production verification report for at least several models, when no change
has been made in the vehicle for the next model year.
The individual yearly cost figures for production verification testing at the manufac-
turer’s facility range from a high of $12,000 to a low of $4,000 with an average value of
$8075. For production verification testing at the EPA test facility, the breakdown by indi-
vidual companies ranges from $22,600 to $4,700 with an average value of $12,450.
Selective enforcement audit testing will be conducted by the manufacturer both on his
own initiative and upon request by EPA. Costs associated with testing requested by EPA
conducted at the manufacturer’s facility are estimated to total $90,000 for the industry as
a whole. This breaks down to a range of $24,000 to $2,000, with an industry average of
$11,250.
Manufacturers may be expected to utilize the EPA test facility to conduct selective
audit testing on their own request, primarily to determine the level of performance of their
products at the EPA facility. Costs associated with this testing, including transportation of
the test vehicles to the facility, are estimated to total $130,550 for the industry during the
H-i
-------
Table H-i
Explanatory Notes
Report Preparation Costs
All report costs are based on $100/test (1 day at $25k per man year)
Transportation Costs
(For two products)
Fixed
$30.00 (Basic cost of short haul)
Variable
16 cents/mile-driver ($8.00/hr or $16.00! 100 miles)
20 cents/mile-truck (12 cents/mi. for fuel, 8 cents/miles maintenance ÷
depreciation)
36 cents/mile total variable cost
Summary
$30.00 + $.36/miles (transport 2 products)
$l5.00+ $.18/miles (transport 1 product)
Cost of Testing
The cost of conducting the measurement methodology is estimated to be
approximately $100.
Test Requests
The number of test requests issued to the medium and heavy truck industry
each year is estimated at 45.
H-2
-------
first year of compliance. The breakdown within the industry ranges from a high of $36,319.
to a low of $2,750, with an value of $16,319. These costs can be expected to decrease some-
what following the first year the regulations are effective, as manufacturers become more
familiar with the compliance scheme, the production variance of their products, and the cor-
relation of results at their facility with those at the EPA facility.
Finally, based on EPA requesting that SEA of products be conducted at the EPA test
facility, the industry total is estimated at $40,550 per year for such testing (cost of trans-
portation only, since EPA would conduct the test at its own expense). Individual manu-
facturer costs range from a high of $14,500 to a low of $750 with an average of $5,069.
Table H-2 summarizes the estimates.
Table 11-2
Production Verification
Manufacturer Facility
EPA Facility*
Total
Average
High
Low
$64,600
8,075
12,000
4,000
$99,600
12,450
22,600
4,700
Selective Enforcement Auditing
Manufacturer Facility
EPA Facility*
EPA Facility**
Total
Average
High
Low
$90,000
11,250
24,000
2,000
$130,550
16,319
36,500
2,750
$40,550
5,069
14,500
750
Manufacturers request.
*SEPA’S request.
H-3
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Appendix I
SUMMARY OF FAN CLUTCH FIELD TESTS
(Excerpt for Docket Submission T104, Attachment B, Docket No.
ONAC 74-2, U.S. Department of Transportation)
The enclosed results summarize the fan clutch data accumulated through September
1 974. Separate results are given for the on-off type clutches and the modulating type since
the data obtained from these units are in a different format.
For the on-off units, the annual average total fan-on time is less than 3 percent. For
both types of clutches, the annual average significant fan-on time (from a noise point of
view) is low 1 percent. These results are based on more than 30,000 hours of engine operation
representing nearly 1 ,l00,000 vehicle miles on 24 trucks.
This summary supersedes the earlier projections since many of the units have flow been
in service for at least twelve months.
Data Acquisition
Clutches and data acquisition equipment were installed in 24 vehicles. Sixteen of these
units were of the on-off type, while the other eight were modulated drives. The fleets and
their operation are described in Table I-i.
For the on-off clutches, hour meters recorded the engine operating time as well as the
operating time of the fan. This data was used directly to obtain the “total” fan-on percent.
However, the fan is not a significant noise contributor all that time since many of the clutch
engagements occur at a low engine rpm. To determine the “significant” fan-on time (from
a noise point of view) a multi-channel tachograph recording is used. One channel displays
the engine rpm while an event marker indicates the clutch engagements. All clutch engagements
above 1600 engine rpm were considered significant while those below 1600 rpm were not.
This engine rpm was selected as the cut-off since the fan noise would be approximately 10
dB below its maximum level at this speed.
p
For the modulating type fan clutch, a strip chart recording was made which contained
engine rpm, fan rpm, coolant temperature and ambient temperature as a function of time.
This recording was used to obtain the “significant fan-on time” (defined as the time the fan
speed exceeded two-thirds of its maximum possible speed) as well as the total engine time.
I—i
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Farmland
Industries
Ryder Truck
Lines
Capitol-Rent-A
Truck/Hinky Dinky
ONC
Bairstow Inc.
Leaseway Inc./
Cotter & Co.
Arrow Motor
Transit
Clinton Electronics
Tanker, Grain
Van, High Cube
Van, High Cube
Groceries
Doubles,
Common Carrier
Dump Trailer
Urban Area
Van, High Cube
Hardware
Van, High Cube
Vehicle Parts
Van, High Cube
Table 1-1
Fan Clutch Installations
DOT Fan Clutch Program
Unit
Type
No.
Installed
Truck/Engine
Fleet
Location
Operation
Horton
Horton
Schwitzer
Schwitzer
Rockford
Rockford
Rockford
Rock ford
On-Off
On-Off
On-Off
On-Off
Modulated
Modulated
Modulated
Modulated
3
2
4
4
4
2
F-4370/NTC29O/335
COF4O7OA/8V7 1N55
F4370/NTC35O
C04070A/8V7 l&T
F5070/Super25O/270
COF4O7OA/8V7 1N65
COF4O7OA/Super 250
COF4O7OA/8V7 1 N65
Omaha,
Nebraska
Jacksonville,
Florida
Omaha,
Nebraska
Los Angeles,
California
Hammond,
Indiana
Chicago,
Illinois
Chicago,
illinois
Rockford,
Illinois
-------
Data was reported at one week periods, which were grouped into 2 or 3 month intervals
for ease of analysis. Instrumentation problems prohibited all of the data from being included
in the analysis. Generally, data from 8 to 10 of the on-off units and 5 to 8 of the modulated
drives were used to establish the average time in each interval.
Results
The resulting fan clutch operating time is shown in Figure 1-1 and 1-2. The annual average
total fan-on time for the on-off clutch is slightly under 3 percent. There is a trend toward
increased total fan-on time during the warmer months. Significant fan time is below 1 percent
and does not appear to change with the season of the year.
The modulated fan drive shows no significant fan time during the greater part of the
year. Even during the warmer months, the significant fan time is below 1 percent. The range
of fan-on time for each of the individual fleets is listed below.
Farmland Industries with Horton On-Off Clutches
Based on a 11-to 12-month operating period, the annual average total fan-on time ranged
from 4 to 9 percent for three trucks. For the majority of the one week reporting periods, the
total fan-on time occurred between 0 and 20 percent. The maximum it reached for any one
truck was 41 percent during mid-July. Most of the fan engagements occurred at low engine
speeds so that significant fan-on ranged between 0 and 5 percent for even the most severe
periods.
Ryder Truck Lines with Horton On-Off Clutches
Based on a 12-month operating period with two trucks, the annual average total fan-on time
was 2 percent and 7 percent for each truck, respectively. The range for the individual weekly
reporting periods was from 0 to 1 7 percent with the peak period distributed randomly through-
out the year. Significant fan-on time ranged from 0 to 10 percent.
Capitol Rent-a-Truck with Schwitzer On-Off Clutches
Data for 1 2 months indicates that the annual average total fan-on time was I or 2 percent
for the four trucks. The total fan-on time for the weekly reporting periods range from 0 to 6
percent with the maximum generally occurring in mid-July. Significant fan-on time ranged
between 0 and 1-1/2 percent.
1-3
-------
5-
5—
— 4-
C
8
C
E .
j — 3-
,
0
II
u 2
0—
C
8
0 ,
E
EE
o !
u_
— — total time
annual average significant time
seasonal variation
significant time
Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec
1973 Timeof Year 1974
Figure 1-2. Operating Time for Modulated Fan Clutch
1-4
annual average
seasonal variation
2
Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec
1973 1974
Time of Year
Figure I-i. Operating Time for On-Off Fan Clutch
seasonal variation
0
annual average
-------
ONC with Schwitzer On-Off Clutches
The data received from the four trucks in this fleet was somewhat inconsistant due to
instrumentation problems. The total fan-on time for weekly reporting periods ranged between
o and 8 percent with the peak periods distributed throughout the year. Significant fan-on time
ranged from 0 to 6 percent.
Bairstow Inc. with Rockford Modulating Clutch
After 12 months of operation on the truck, the highest fan speed achieved was 900 rpm.
Since this was well below the cut off speed of 1300 rpm, this unit had 0 percent significant
fan-on time.
Leaseway, Inc. with Rockford Modulating Clutches
In the 7 month period from March through September, 1974, the fan speed exceeded
1600 rpm for about 1-1/3 hours out of a total of 4025 engine hours for the four trucks (0.03
percent significant fan time). For the individual, one week reporting periods, the significant
fan-on time was near zero except on one truck during the week of August 31 to September 7
where it reached 5 percent.
Arrow Motor Transit with Rockford Modulating Clutches
Two trucks in this fleet were equipped with Rockford clutches. In the 8-month
period from February through September, 1974, the fan speed on one truck exceed 1300 rpm
for 9-1/2 hours out of a total of 1608 engine hours (0.6 percent significant fan-on time). For the
individual, one-week reporting periods, the significant fan-on time was near zero except for the
two week period from July 6 through July 20 where it reached 8 percent.
The second truck, which was identical to the first one, showed significant fan-on times
as high as 41 percent during the periods from mid-June until mid-September. This unusually
high operating time has not been explained; however, it undoubtedly indicates a defective cool-
ing system. This truck has not been included in the summary.
I-5
-------
Clinton Electronics with Rockford Modulating Clutch
In the 4-month period from June through September 1974, this one truck has
accumulated 9 hours of significant fan-on time (above 1600 rpm) out of 448 engine hours
(2 percent significant fan-on time). During the individual, one week reporting periods, the
significant fan-on was normally near 0 percent except for the period from June 29 through
July 1 O 1 where it reached 8 percent.
1-6
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