Railroad Noise Associated with the Canadian National Railway Use of the EJ&E Railroad 6/8/12 Prepared for the: Village of Hoffman Estates Prepared by: Thomas Thunder, AuD, FAAA, INCE Audiologist and Acoustical Consultant Acoustic Associates, Ltd Palatine, Illinois 1 Executive Summary The Canadian National Railway acquired control of the EJ&E and has projected that the number of trains will increase from 10 to about 25 per day. As part of the regulatory process, an environmental impact statement was prepared that identified noise impacts to property near the tracks. The portion of track relevant to Hoffman Estates residents is the section running from Golf Road to Shoe Factory Road. The primary source of railroad noise in this case is locomotive and rolling noise. Locomotive engines produce high levels of low frequency noise. But this noise is short-lived compared to the longer exposure of the rolling noise generated by the interaction of numerous wheels on the long rails. Rolling noise has an extra impact because the frequencies it generates fall within the range of frequencies necessary for speech communication. The noise from one train was measured on the deck of a home 140 feet from the tracks. It peaked at 78 dB when the locomotives passed. The average level of the rolling noise from this 120 car train moving at about 15 mph was 69 dB. This level is twice the loudness of conversation. The impact of train noise is evaluated by determining the average daily sound level (called the day-night level or Ldn). In this case, the primary factor for increasing the noise impact is the number of trains. From a strict acoustical perspective, increasing the number of trains by 2½ times would increase the Ldn by 4 dB. This increase falls between a just noticeable difference (3 dB) and a significant difference (5 dB). Wheel and rail roughness is directly correlated with the noise from trains. Limiting roughness has a direct benefit for the entire community. Since measuring rail roughness is not the jurisdiction of any town, Hoffman Estates will need to trust that CN also recognizes this relationship and that it will exceed the Federal Railroad Administration (FRA) and American Railway Engineering and Maintenance-of-Way Association (AREMA) standards with respect to roughness. To mitigate the noise, CN has proposed tall masonry walls. It anticipates a noise reduction of about 5-9 dB. This reduction would be significant and would cut the loudness by nearly 50% for the closest locations. But those in the 2nd and 3rd row of homes away from the tracks would experience much less mitigation (although these homes are less impacted anyway simply because they are farther from the tracks). Making the walls shorter would reduce their effectiveness. Landscaping would not reduce the noise, but there would be a psycho-acoustical benefit by adding more green space. Constructing the proposed walls has been called into question for several reasons: 1) Because of their intermittent and transient nature, communities as a whole are more tolerant of railroad noise than other sources that have equal daily average sound levels (e.g., aircraft, factories, and road traffic). 2) The proposed wall would offer little benefit to 2nd floor elevations, 2 3) Trains are not a novel source to this community and, as such, a number of residents may have acclimated to this type of noise, 4) While doubling the number of trains would seem like it ought to double the impact, in the field of psycho-acoustics, it represents only a noticeable, not significant, increase in impact, and 5) The walls would block the view of the forest preserve; this would remove the green landscape view that residents currently enjoy, value, and hope to have for many years. In addition to, or in lieu of, the tall CN walls, residents could employ their own controls. One control would be to build short and partially transparent walls around their decks or patios. They could also replace windows on the east side, especially the 2nd floor bedroom windows, with acoustically rated windows to lower the noise inside the home. Background The Canadian National Railway Company (CN) acquired control of the EJ&E Railway in 2009. Currently, about 10 trains per day operate along the tracks that lie along the eastern border of the residential areas in Hoffman Estates between Golf Road and Shoe Factory Road. Figure 1 shows an aerial view of the residential community on the west side of this section of the railroad tracks CN has projected that the number of trains would increase to about 25 per day. The Section of Environmental Analysis (SEA) of the Surface Transportation Board (STB) conducted an Environmental Impact Study (EIS) that included a noise impact evaluation. Based on computer modeling, the SEA determined that the Day-Night Level (Ldn) of noise on the adjacent residential property would increase by more Day-Night Level (Ldn) is than 3 dB and to a level greater than an Ldn of 65 dB. To mitigate this the time-averaged impact, noise barrier walls have been proposed. These walls would be sound level over a 24constructed of precast masonry blocks and would reduce railroad noise hour period with 10 dB on the closest properties by an estimated 5-10 dB. added to the noise This paper discusses railroad noise relative to the residential areas in Hoffman Estates in a greater depth than presented in the EIS. It also characterizes the current and future impact of this noise on the adjacent residents, reviews barrier walls as a basic noise mitigation approach, and offers conceptual approaches not covered in the EIS. 3 between 10 PM and 7 AM to account for the greater sensitivity to noise during this period. Ldn is the descriptor CNRR IL 59 Forest Preserve Figure 1 - Aerial view of railroad running from Golf Road to Shoe Factory Road that borders the eastern edge of Hoffman Estates residential areas. Field Measurements of Existing Railroad Noise The EIS did not base its analysis and findings on actual measurements of the noise from the current operations along the subject segment of the railroad. While it was not the intent of the EIS to conduct such a survey, we felt it was important to measure at least one train pass-by event to characterize the noise from the perspective of residents. This assessment also served as a basis for evaluating the validity of the EIS modeling. On February 15, 2012, we set up a sound level meter and digital recorder about 140 feet from the tracks at a home on Nicholson Drive in the Estates of Deer Crossing subdivision. Figure 2 shows this equipment set up on the deck with a view of the railroad tracks just beyond the white fence. Popular Creek Forset Preserve is in the background. At 9:43 AM, a northbound train passed this area. The train was about 120 cars long and was reportedly traveling at a speed of about 15-25 mph. A time-history analysis was conducted that resulted in the trace shown in Figure 3. This trace shows the sound level generated by the train over time. Before the train arrived, the level was about 47 dB. This is called the ambient noise of the neighborhood. As the locomotives approached, the sound level increased reaching a maximum level of 78 dB as the locomotives passed directly in front of the measuring station. 4 Figure 2 - Sound measuring equipment set up on the deck of a home adjacent to the railroad tracks. Figure 3 – Sound level time-history of a train passing near the background of a home. 5 Once the locomotives passed, the sound level dropped about 10 dB and remained at that level until the last railcar passed. This last part of the noise event is called rolling noise, which, as seen by the trace, fluctuates because of the interaction of the wheels and rails. The time-averaged level of the rolling noise (often called the equivalent level or Leq) was 69 dB. A spectral analysis was also conducted to examine which frequencies contribute the most to the overall noise level. The left-hand portion of Figure 4 shows the total (unweighted) and A-weighted sound levels. The lowest ambient noise recorded was 43 dB. This is the noise with no trains and due to the all-encompassing sounds of distant A-weighted sound level is the overall sound level after the low sources - such as the traffic along Shoe Factory Road. frequencies are diminished to The right-hand portion of Figure 4 shows the train noise broken account for the reduced sensitivity down into the full audible spectrum between 20 and 20,000 Hz. that humans have for low-pitched The locomotive noise spectrum reveals a prominent frequency at sound. The A-weighted level is 63 Hz. This is the low-pitched rumble heard as the engines pass. used so commonly that this filter is assumed unless otherwise For the rolling noise spectrum, a prominent frequency at 80 Hz is stipulated. seen, which may be from the low speed wheel-rail interaction. Rolling noise in general is related to the degree of roughness of the wheel and/or track and the speed of the train. Rolling noise also produces a wideband noise in the 160-5,000 Hz range. This range is important because noise in the critical speech range (i.e., the frequencies between 500 and 4,000 Hz) will greatly impair speech communication. Figure 4 - Spectral plot showing the overall level and the frequency components of locomotive 6 and rolling noise. In summary, locomotive noise is characterized by an intense, low-frequency sound that is transient. On the other hand, rolling noise is characterized by a lower sound level, but much longer in duration and predominately in the mid-frequencies. A sound exposure analysis was conducted to determine whether locomotive or rolling noise has the greatest impact on people. The Sound Exposure Level (SEL) is a metric based on the product of the intensity of the noise and its duration. Although the results were comparable for the specific train we measured, rolling noise has the greater impact for three reasons: 1) With freight trains, the duration of rolling stock noise is substantially greater than passenger trains. 2) Humans are more sensitive to mid-frequency noise, which is where rolling railcars generate a substantial amount of noise. 3) Rolling stock produces a substantial amount of noise in the speech frequencies, which has a great impact on listening to the TV, hearing over the phone, and understanding people in conversation. Sources of Railroad Noise Noise is a byproduct of the power generated by the engines and the interaction of the railcars and the tracks. With the massive and large loads of most freight trains, it is not surprising how much noise a train generates. There are a number of sources of railroad noise. Aerodynamic noise is one source; but this only applies to high-speed trains. Rail squeal is another source, but this only applies to curved sections of tracks. Train horns are another source, but in this case, horn soundings are distant because Shoe Factory Road is designated as a Quiet Zone. The only relevant sources in this case are the locomotives and the wheel-rail interaction of the railcars. Locomotives generate noise from the air intake, engine casing, traction, and exhaust. Because of their low rotational movement, the locomotive engines normally generate low-pitched noise. Locomotive noise in this case is transient because the locomotives usually pass relatively quickly. In other words, they are not expected to idle or perform back-and-forth movements on a regular basis. Railcars generate “rolling noise,” which is the sound associated with: a) the vibration of the wheels, b) the undercarriage (bogie), c) the body of the railcars, and d) the interaction of the wheels with the rails and ties (sleepers) on the roadbed. Research has shown that rolling noise is a significant source of railroad noise and originates mostly from the wheels - not the undercarriages or the railcar bodies. The sound level of freight trains generally increases about 10 dB per doubling of speed. Conversely, a train traveling at half the speed will generate 10 dB less noise – which sounds half as loud. This means that a train moving at 22 mph is half as loud as one moving at 44 mph. 7 The character of railroad noise is a low frequency bass sound as the locomotives pass. The rolling noise, however, is largely a mid-frequency spectrum where the ear is more sensitive. Because the duration of rolling noise is typically much longer than locomotive noise, the rolling noise is the dominant impact As indicated above, wheel and rail noise are the dominate sources of rolling noise. Wheel noise is primarily a higher frequency noise. Rail noise is primarily a wideband noise, but can be lower in frequency if the rail supports are “soft.” The most significant effect on the noise emissions from wheels and wheels are their roughness. Since noise is a product of vibration, the rounder and smoother the wheel and the rail are, the lower the vibration and the lower the noise. In some cases, a regular pattern of roughness can occur which creates a “corrugation” in the rail. This causes a howling sound known as “rail roar” whose frequency is related to the speed of the train; the greater the speed, the louder and more high-pitched the sound. The propagation of wheel and rail noise to residents in Hoffman Estates is significant because of several factors. 1) The back patios and decks are in close proximity to the train tracks. With a distance of only 100200 feet, there is little land to buffer the residents from the noise. 2) Because trains are made up of a multitude of wheels (sources), the reduction in noise with distance is only 3-4 dB per doubling of distance - not the usual 6 dB per doubling of distance observed for single, stationary sources like a neighbor’s air conditioning unit. This means that comparatively more residents are affected by train noise. 3) The existing natural vegetation is insufficient in density and depth to noticeably reduce the noise. In addition, the amount of total existing vegetation varies along the length of the subdivision. The annoyance of any type of noise depends primarily on the average daily level of the noise – as reflected by the Day-Night Level (Ldn) metric. Other factors also play a role such as ambient noise, time of day and year, tonal content, range of noise intrusion, novelty of the exposure, and the nature of the noise itself (e.g., aircraft vs. railroad vs. road traffic). New methods of relating the proportion of people in a community annoyed by a noise have resulted in a metric called the Community Tolerance Level (CTL). This metric is defined as the Ldn where half the community is highly annoyed by the noise. It is worthy to note that the CTL for freight trains, as in this case, was 87.8 dB in contrast to the CTL for aircraft which was 73.3 dB. Other sources such as high-speed trains, high vibration trains, passenger trains, and road traffic fell in between. What this means is that communities are generally more tolerant of freight railroad noise than other sources. Stated differently, given the same Ldn, there would be far fewer people annoyed by train noise than other sources. 8 Frequently Asked Questions The following section answers many of the questions that homeowners and Village officials have asked about railroad noise, the EIS, and the walls that CN has proposed to mitigate the noise. 1. How loud is train noise and what does it compare to? Based on our measurements at 140 feet from the track for a train travelling at around 15-25 mph, we found that the locomotive engine reaches a maximum, A-weighted, sound level of 78 dB. But the longest and most significant noise is the rolling noise from the railcars. The time-averaged level of this noise was 69 dB. Based on normal conversational speech at 60 dB, this train was about twice as loud as conversation. 2. Would lower train speeds equate to less noise? Yes. Each time you cut the speed in half, you lower the level by 9 dB. For example, if a train measured 80 dB while moving at 48 mph, it would be 71 dB moving at 24 mph and 62 dB moving at 12 mph. In acoustics, a drop of 10 dB represents a loudness reduction of one-half. Hence, each time the train speed is cut in half, its loudness is cut in half as well. The sound exposure level (SEL) of an event is a metric that correlates with the impact of that even. The SEL is based on the intensity and duration of the event. Although a train moving at half speed will take twice as long to pass, calculations reveal that the net SEL of a slower moving train is significantly less than the same train moving at a higher speed. 3. Considering that the number of trains will increase from 10 to 25 per day, what is the general increase in impact? The metric used most often to assess long term impact of noise is the Day-Night Level (Ldn). This is a time-averaged level computed over a full 24-hour day and includes a 10-dB penalty applied between 10 PM and 7 AM to account for the increased sensitivity that people have during nighttime hours. If the increase in train traffic is during the night, the Ldn would increase substantially because of this penalty. But If the increase were limited to daytime hours, the Ldn would increase only a small amount. The Ldn is not an arithmetic average. Instead, it uses logarithmic averaging which weights the louder sounds more than the soft sounds. The time-averaged level of the entire 6-minute train event we observed was 71 dB at 140 feet. Based on an ambient sound level of 47 dB, the timeaveraged level for 10 trains during the day would be 59 dB. For 25 trains during the day, it would increase to 63 dB, an increase of 4 dB. An increase of this amount would represent only a slight increase in impact compared to the impact the residents now experience with 10 trains per day. 4. Where is an appropriate measurement reference, e.g., middle of yard vs. in the home; 1st floor vs. second floor; patio vs. kitchen, etc. Outdoors is the conventional place to take noise readings. This gives less variance to the measurement. Also, the levels inside a home can be predicted based on the construction of a home. The reference distance that CN used appears to be about 75 feet from the tracks. Although a more common reference distance is 50 feet, this distance represents the middle of most backyards and is closer to the tracks than the back decks or patios of the homes. The ground location is acceptable since the noise level (at least without a barrier wall) would not differ much between a 1st or 2nd floor location. 9 5. Does the Parsons’ analysis meet and conform to best practice and current standards? Yes. Based on a review of portions of the EIS, the analysis was performed using the methods of the Federal Transportation Administration. 6. Are their findings valid and substantiated? Yes. Based on extrapolating the train event we assessed, we estimate a daytime time-average level of 63 dB at 140 feet for 25 trains in a day. If this is corrected for trains at 30 mph, for CN’s reference distance of 75 feet, and assuming a nominal number of trains occurring at night, then CN’s projected Ldn of 69 dB as given in the EIS is reasonable. 7. What if any changes to the study should be made? There was no evaluation of existing train noise to show that the computational model used was indeed representative and valid. In addition, even though wheel and rail roughness are major factors in the generation of railroad noise, there was no discussion of this or of existing wheel and rail conditions. 8. Is there anything different that should have been recommended? Although the STB decision references AREMA standards (which contain rail condition criteria), knowing how critical wheel and rail conditions are in generating rolling noise, the EIS should have explicitly addressed these factors and stated what rail condition was assumed to generate the noise contours. Since the EIS did not address wheel and rail roughness, it is not surprising that it did not also outline how roughness would be monitored and corrected in the future. However, a condition of the STB approval does require that CN maintain the track and its equipment in a manner that meets the AREMA standard. 9. How is wall effectiveness evaluated? The effectiveness of a wall is measured by how many decibels the noise drops at a specific location when the wall in introduced. This is called “insertion loss.” How well a wall works is related to how much farther the noise must travel over the top of the wall compared a direct path without the barrier. 10. How does wall proximity change the wall’s effectiveness? Barriers work by ensuring that the path over the top of the wall is longer than a direct (but blocked) path through the wall. When either the source or the receiver is close to the wall, the path length difference is large and the barrier is very effective. Although not practical in this case, a short wall just a bit higher than the top of the wheels would be effective, but only if it was very close to the wheels. A short wall on a receiver’s patio could also be effective, as long as it is close to the listener. When the wall is far from the source, its height must be increased to maintain the same path length difference and, therefore, its effectiveness. Also, residents in the 2nd and 3rd row of homes would be far enough from the wall that they would hear little difference with or without the wall (although they would experience less impact anyways simply because they are farther from the tracks). 11. We question the effectiveness of the stated noise reduction of 5 to 10 dB as being significant. A 3-dB decrease would not be noticeable. However, a 5-dB decrease is considered significant. A 10 dB decrease represents a substantial noise reduction since it sounds ½ as loud. Accordingly, the stated noise reduction would, in fact, be significant. 10 12. Will the proposed wall design achieve the noise reductions represented in the analysis? Yes. As a rule, if a barrier is tall enough to block the line-of-sight of a source, you can expect a 5-dB decrease. Every foot above this yields ½ to 1 dB more reduction depending on the noise spectrum and the type of noise source (e.g., trains vs. a transformer). Using this rule-of-thumb, CNs stated performance of 5-9 dB appears valid. 13. What are the effects of different material types, e.g., reflecting vs. absorptive? For a barrier to work well, the only noise heard on the receiving side should be the sound that “spills” over the top. To ensure this, heavy and solid materials like steel, brick, masonry blocks, and timber are used to block the sound from transmitting through the wall. In cases where the source is large, like a railcar, sound bounces off the source itself and back over the top of the wall. This diminishes the wall’s effectiveness. In these cases, it is helpful to use sound absorption material. This is often in the form of slotted concrete blocks that contain sound absorptive fill in their hollow cores or as perforated steel panels that cover sound absorptive blankets. Sound absorption can make a 2-3 dB difference. 14. Why does the wall have to be so high? To be effective, the height of a wall must exceed the height of the sound source. Locomotives and railcars are tall, so the wall must also be tall. Also, as discussed above, the farther a wall is located from the source (or receiver), the less effective it is. To compensate for this, the wall must be made taller. Another factor is the frequency of the noise source. Walls are less effective at blocking low frequency sound. So if low frequency sound is the major contributor to the overall noise, then the wall is made taller to reduce “spill-over.” 15. How does the effectiveness of a wall change where the wall ends and the tracks are high relative to homes? At the ends of the barrier, some of the train noise will travel around the side. This is called flanking noise and reduces the effectiveness of the wall for those homes near the ends of the wall. Also, if there are points where the tracks are high, the wall height might need to change a corresponding amount to maintain wall effectiveness. 16. Would landscaping work in lieu of the walls? No. Unless the trees were tall, dense, and deep, there would be little effect. Landscaping does, however, have a psychological effect in reducing the annoyance of the noise when trees and bushes block the view of the noise source. This perceptual effect is roughly equivalent to a 5-dB reduction. 17. What is the general effectiveness of windows, doors, and home insulation? While most modern homes are designed with enhanced thermal insulation, this does not necessarily improve its sound insulation performance. Homes can be built for reduced noise transmission, but this is best done when the home is constructed. Retrofitting a home for noise reduction can be expensive. However, because windows are usually the weakest element in a building facade, indoor noise levels can be lowered by replacing these windows with acoustically rated windows. Acoustically rated windows are designed and tested for a high sound transmission class (STC) rating. Depending on a number of factors, this may amount to a 4-8 dB noise reduction. 11 Options for Railroad Noise Reduction 1. Control at the Source Control of noise at the source is generally more cost-effective than controls in the path (like a wall or earth berm) or at the receiver (such as sound proofing a home). In addition, controls at the source benefit everyone in the community, not just a select few that are immediately adjacent to the source. Unfortunately, since the demise of the Office of Noise Abatement and Control, there has been no Federal directive encouraging the reduction of train noise emissions. Instead, the focus has been on path controls such as barrier walls, despite their high cost and visual intrusion. Reductions in wheel and rail roughness will lead to reduced noise in direct proportion to the reduction in roughness. Maintaining wheels and tracks in good condition by periodic rail grinding and wheel truing is the most effective and important means for controlling the noise from wheel/rail interaction. Although the roughness of the worst component (wheel or rail) must be lowered first, the range of roughness is much greater on rails than on wheels. According to CN officials, “geometry cars” will be used to measure rail roughness. If necessary, a grinder is sent out to restore the original shape. Along the Hoffman Estates section of track, surfacing and grinding were completed in the later part of 2011 and a geometry car checked roughness in February of 2012. These operations have been reported by CN to meet or exceed both AREMA and FRA standards. As for wheels, certain types of brakes reduce the development of roughness, which, on a good track, can reduce the noise by 10 dB. No matter what type of brake is on a wheel, according to CN, “Wheel Impact Load Detectors” have been installed at several locations on the EJ&E to pick up wheel irregularities. If wheel roughness is detected, this device notifies the crew so that they can set off the car for repair. 2. Controls in the Path Noise barriers are the most commonly used strategy to mitigate railroad noise despite the fact that retrofitting for source controls has better cost-effectiveness. But without national incentives, it is easier to install barriers. There are several arguments against walls in this location: 1) There is a general aversion to the walls because of their proposed height. Even at the proposed height, their effectiveness is greatly diminished for 2nd floor locations because at this elevation, the line-of-site is not effectively blocked. 2) Trains are not a new source to this community. While introducing trains for the first time would substantially impact residents, residents have acclimated to a certain degree to the existing train noise. In addition, increasing the existing train traffic two- or three-fold has a far less 12 incremental impact than introducing a new source to the community. 3) The noise source is transient and intermittent with long intervals. Compared with sources that generate noise all the time (like a manufacturing plant or trucking depot), the noise in this case is only “on” for short periods with relatively long intervals in between. 4) The noise from the railroad is predictable. The noise level and character experienced by residents is the same. And while residents don’t have control over the time and length of the trains, they do know that the noise will end in a few minutes. 5) The walls would block the view of the forest preserve. If these walls blocked the view of a manufacturing plant, a trucking facility, or an expressway, there would be a psychological benefit of a wall. But in this case, the wall would remove “green landscape” from their view. According to residents, this green landscape is a critical component of their desire to live where they live. Furthermore, as a forest preserve, they know that this land will not be developed, which is a notion that adds value to their properties. 3. Controls at the Receiver There are receiver controls that residents could consider to help mitigate train noise. One option would be to build a short wall around parts of their patio or deck. The lower portion could be masonry or wood and the upper part could be Plexiglas or glass to allow a view of the forest preserve. As discussed above, if close enough, a wall near the listeners could be effective. A test project would help quantify the actual benefit of such a barrier and guide residents in their construction if they wished to pursue this approach. Figure 5 – An example of a transparent wall that would mitigate the train noise but allow residents to view the Forest Preserve and observe their children playing in the backyard. The height would be about 8 feet tall. 13 Another control would be to replace the windows on the east side of the homes with windows that have a higher acoustical rating. To evaluate this approach, a representative window should be examined and tested at Riverbank Acoustical Labs in Geneva to determine its sound transmission class (STC) rating. An acoustical study should then be conducted to evaluate the potential benefit of retrofitting windows with acoustical windows. A test project would help quantify the benefit of such windows and help residents make an informed decision about retrofitting. This test project would be especially useful for 2nd floor bedroom because: 1) 2nd floor elevations will receive little benefit from the wall proposed by CN, and 2) bedrooms are a critical receiving location because of issues relating to sleep quality. A final option relates to enhanced landscaping. As indicated above, conventional landscaping will have negligible effect on train noise. However, to the degree that landscaping can visually shield the train, there will be a beneficial psycho-acoustical effect. Conclusions The Canadian National Railway has estimated that the number of trains will increase from about 10 to 25 per day. Since the calculated Ldn exceeds the Federal criteria for impact, CN has proposed tall, masonry walls to shield the noise. Concerns have been expressed by residents about the construction of these walls. While the estimated reduction of 5-9 dB is reasonable and significant, they understand it is not substantial. The residents also feel the walls will block their view of the forest preserve to the east, a view they currently enjoy and value and hope to for many years. There are also concerns about the need for the proposed wall from an acoustical perspective. Communities as a whole are more tolerant of railroad noise than other sources such as aircraft, factories, and road traffic. In addition, train noise is not a new source to this community. Hence the real measure of impact is the increase in noise, not so much the absolute level of noise. Based on increasing the number of trains from 10 to 25 per day, the incremental impact is 4 dB. This represents a noticeable, but not a significant change. Furthermore, the walls would offer little to no benefit for 2nd floor elevations. With the direct correlation between wheel/rail roughness and noise, it is surprising that the EIS did not acknowledge the critical role that this factor plays in railroad noise. Without this acknowledgment, it is not surprising that the EIS did not outline a program to ensure that wheels and rails would be checked and treated to limit roughness. In lieu of (or In addition to) the tall walls that CN has proposed, residents could employ their own controls. This could include partially transparent walls around decks and patios that would shield the noise and make it easier to communicate. Residents could also replace windows on the east side with acoustically rated windows to lower the noise inside their homes. This would be especially beneficial for 2nd floor bedrooms where sleep quality is important. --- END --14
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