Mr. NADER. Very inflated. In fact, in 1950 the Association of American Railroads gave figures of servicing equipment and labor of a very, very much lower order of magnitude. Even if you include increases of cost, it is nowhere near that figure.

Mr. VANDER JAGT. I was also interested in your relating to this committee the total assets of the railroad industries. I am not much of a mathematician, but if we take the total assets and even the inflated figure, which you allege to be an inflated figure of $100 million, the cost of doing the job, the total job, would be something like one three-hundredths of 1 percent of the investment. Is that roughly correct, would you say?

Mr. NADER. Yes. That is not taking into account certain nonrailroad assets controlled by the same company as well.

Mr. VANDER JAGT. So it could be even smaller.

Mr. NADER. In reference to that other citation, Congressman, this is Association of American Railroads Technical Report No. 7, "Retention of Waste from Railroad Passenger Cars," page 24, 1950.

Mr. REUSS. Mr. Wright?

Mr. WRIGHT. I do not have any questions at this point, Mr. Chairman. I think Mr. Nader's statement is very clear.

Mr. GUDE. No questions at this time.

Mr. REUSS. We will now hear from Mr. R. R. Manion, vice president for operations and maintenance, of the Association of American Railroads. You, too, have a prepared statement, Mr. Manion, which I think was originally prepared for Mr. Goodfellow, the president, to present, but I gather you will present his statement this morning.

Mr. MANION. Yes, sir.

Mr. REUSS. Without objection, will you now proceed?

STATEMENT OF THOMAS M. GOODFELLOW, PRESIDENT, ASSOCIATION OF AMERICAN RAILROADS, PRESENTED BY R. R. MANION, VICE PRESIDENT, OPERATIONS AND MAINTENANCE DEPARTMENT; ACCOMPANIED BY WILLIAM MOLONEY, VICE PRESIDENT AND GENERAL COUNSEL

Mr. MANION. Mr. Chairman, Mr. Goodfellow came down with a virus over the weekend, so I am presenting, if you do not mind, his testimony, and I would also like to introduce to you, and have him sit with me, Mr. William Moloney, vice president and general counsel of the AAR. Mr. Goodfellow, as you know, is the president of the Association of American Railroads.

I appreciate this opportunity to appear before you gentlemen and to assure you that we, in the railroad industry, share your interest in the improvement of our environment.

Both our association and our individual railroads have been engaged in antipollution efforts for many years. And we are presently engaged in an industrywide research program designed to eliminate any practices which might contribute to harmful pollution.

You have expressed a concern about health hazards resulting from the release of human waste directly to railroad rights-of-way. This concern is understandable.

We became seriously concerned about it 20 to 25 years ago. At that time, the railroads financed a 5-year study to find out what-if any— pollutant effect resulted from the discharge of waste from our passenger train equipment.

Participating in this sanitation research project were medical, engineering, and mechanical officers of the industry, together with representatives of the U.S. Public Health Service-including its Assistant Surgeon General and Chief of Sanitation.

Consulting director on this project was Dr. Abel Wolman of Johns Hopkins University of Baltimore, an internationally known expert in the sanitation field.

Every aspect of the suspected problem was thoroughly examined by this team. It reported that no evidence was found that sewage wastes from railroad passengers had caused the spread of communicable diseases, and that the bacteria count in railroad ballast, in runoffs from roadbeds, and in the atmosphere of trains, was no greater than in other environments generally not considered to be a health hazard. I do not know of any development in the past 20 years that would change the conclusions reached as a result of that study. There has been no report of disease from this source, and no indication that water supplies or other natural resources have been endangered by contamination from human waste discharged from a railroad car. In fact, the exposure has been greatly reduced since that time.

In view of these facts, I think we should consider the nature of the problem we are talking about. Is it really a matter of public healthor essentially one of esthetics? Certainly, the practice cannot be defended from the standpoint of esthetics. Body wastes-whether human or animal-are offensive to our sight and smell.

We would readily agree with the necessity for prompt action to eliminate a health hazard. But I believe we should consider many factors before reaching a conclusion about measures which achieve purely esthetic results.

Basically, there are three types of railroad equipment from which human wastes are discharged to the private property of the railroads. These are locomotives, cabooses, and passenger train cars. If the railroads were required to change their disposal methods immediately, we would have to convert toilets on each unit to some form of retention equipment. Does a purely esthetic problem warrant this effort and the cost involved?

To what extent are these facilities used?

Between 1950 and 1968, the number of locomotives and caboose units in service was reduced by about 50 percent. The average trip of crews in freight service in 1968 was 109 miles requiring about 22 hours. Local freight train crews make frequent stops at stations or industrial properties where stationary plumbing facilities are available. Engine crews average 311⁄2 hours on trains in passenger service. It seems apparent from these figures that use of on-train toilet facilities by crew members would be negligible.

Intercity railroad passenger service has dwindled considerably— especially on long-distance trains as indicated by the fact that the average trip is now only 86 miles. Unless this service is taken over by some agency-such as that proposed in legislation now before Congress-it will soon be driven from the scene by economic factors.

Commuter service is expanding, but in 1968 the average commuter trip by rail was only 21 miles. The average time on train was 43 minutes. Certainly, the commuter is not likely to use the train facilities under normal circumstances. In recognition of this fact, toilets are not even provided on some commuter trains or on equipment operated in metropolitan transit systems.

If the railroads are forced to install retention type toilets, what would be involved? Technically, of course, it is possible to convert present facilities on locomotives and cabooses. There are several types of equipment that could be used-incinerating, chemical recirculating and holding tank types. Passenger cars would present great mechanical and structural obstacles to modification. These include the location of trucks, generators and other equipment which would make it difficult to accommodate the necesary tanks. This is especially true with respect to sleeping cars, which may have as many as 17 toilets, it says here, although there are certain types of equipment that may have as many as 30.

What are the economic factors involved?

At the present, about 5 percent of our locomotive fleet, exclusive of switch engines or auxiliary units, is equipped with retention toilets. We would have to convert the toilets on the remaining 18,500 locomotives, at an average of $1,000 per unit. The total cost would be $18,500,000. Conversion of facilities on 15,000 cabooses would cost about $11,000,000. Estimating the conversion costs for passenger equipment is practically impossible because of difficulties I have already described.

If the cost averaged no more than $1,000 per toilet unit, the total would exceed $29,398,000. In the data attached to printed copies of this statement, I have explained how we arrived at these figures.

As you can see, the conversion cost would we staggering especially for an industry whose financial posture leaves much to be desired. But that is only part of the story. The disposal of the waste might prove even more burdensome.

Incinerating units which a number of carriers have installed on locomotives do not cause major servicing problems. But maintenance difficulties have been substantial, and crew members have found some units so objectionable they refuse to use them. Also, we could not use incinerating units in cabooses, because there is not enough power available. That means we would have to use chemical or recirculating type equipment-similar to that used in commercial aircraft-in cabooses and passenger equipment.

These require periodic collection of waste material and replenishment of water, disinfectant and antifreeze. This is no problem with airlines because they operate a limited number of units, compared to the total we would have in locomotives and cabooses. In addition, they can schedule planes to permit daily servicing of toilets at a few major terminals. We could not do that. We would have to have service installations at hundreds of terminals scattered all over the country. There are two kinds of equipment that might be used.

First, a mobile unit equipped to collect waste, then discharge it into a sanitary system. This method could be used if adequate sanitary facilities were available. But the equipment would have to be bought

and yards might have to be redesigned to permit access of the mobile unit to locomotives and cabooses. Otherwise, we would have to do a lot of switching at considerable expense and with a substantial loss of time.

The second method would require fixed installations, draining directly into a sanitary system. This probably would cost even more, considering initial installation and operating costs.

No study has been made on any railroad system to find out how many service installations would be needed or the cost involved. We may need as many as 1,500. The average cost might range from $15,000 upward. That would mean an initial capital outlay of $22,500,000. The continuing expenses are unknown. But they would be considerable.

In amplifying this statement, Mr. Chairman, I respectfully request that your letters to me [Thomas M. Goodfellow] of January 20 and July 7, 1970-and my replies of March 2 and July 21, 1970-be made a part of the record of this hearing.

Mr. REUSS. And they will so be made part of the record, without objection.

[The correspondence referred to, and subsequent correspondence between Congressman Reuss and Mr. Goodfellow, follow:]

HOUSE OF REPRESENTATIVES,

CONSERVATION AND NATURAL RESOURCES SUBCOMMITTEE
OF THE COMMITTEE ON GOVERNMENT OPERATIONS,
Washington, D.C., January 20, 1970.

Mr. THOMAS M. GOODFELLOW,
President, Association of American Railroads,
Washington, D.C.

DEAR MR. GOODFELLOW: In November 1969, this subcommittee began examination of the problem of human waste disposal from interstate trains. According to a report entitled, "A Report on Railroad Waste Pollution, November 1, 1969” by Monogram Industries, Inc. of Venice, Calif.-a copy of which, I understand, is already in your Association's possession-our Nation's railroads are operating with only the most primitive of human waste disposal systems. That report indicates that over 50 million pounds of untreated human waste are discharged annually from locomotives and cabooses. Although that report does not include any estimate of human wastes discharged from commuter and intercity passenger trains, even greater amounts presumably emanate therefrom. These wastes constitute a significant and avoidable source of pollution of our Nation's watersheds. We would appreciate your providing to us the following information:

1. A copy of the most recent isue of your association's publication, "Yearbook of Railroad Facts."

2. A copy of the following publications:

(a) Your association's technical report No. 6, "Bacteriological Studies of Effects of Human Wastes from Passenger Carrying Cars on Railroad Rights of Way" (1950).

(b) Any other reports concerning human waste disposal from railroad cars which you can make available is us, or cite to us.

(c) Your association's technical report No. 7, "Retention of Wastes from Railroad Passenger Cars" (1950)

3. (a) Does the Monogram Industries report on Railroad Waste Pollution accurately estimate the quantity of untreated human wastes discharged from locomotives and cabooses?

(b) If your estimate is different, please state your estimate and the basis thereof.

4. State the estimated quantity of untreated human wastes discharged in 1969 from intercity and commuter passenger cars, and the basis for your estimate.

5. State the estimated total number of miles of railroad right-of-way which:

(a) are in the United States;

(b) cross over a reservoir, waterway or other body of water;

(c) pass within 1 mile of any reservoir, waterway or other body of water. 6. Please provide the information requested in tables A and B attached.

7. What do the railroads do to control the effects of the disposal of untreated human wastes from railroad cars onto the roadbed or bridges?

S. Why are the railroads not universally utilizing waste holding systems like those used on buses and airplanes?

9. (a) Please provide estimates of the cost to install a holding tank type disposal system in all railroad cars which lack such a system. Please provide separate estimates for:

(i) locomotives

(ii) cabooses

(iii) intercity passenger cars

(iv) commuter passenger cars

(b) please explain the basis for these estimates.

10. (a) Are the railroads presently installing a holding tank type disposal system in the four types of cars listed in question 9 which lack such a system? (b) At what current rate (cars/year) are they doing so?

(c) How long will it be before all railroad cars will have such a system? 11. We would appreciate your views and recommendations for reducing or eliminating the discharge of untreated human wastes from railroad cars.

Sincerely,

HENRY S. REUSS,

Chairman, Conservation and Natural Resources Subcommittee.

TABLE A.-ESTIMATED NUMBER OF PERSON-DAYS TRAVELED BY ALL PASSENGERS AND CREW DURING 1969 ON RAILROAD CARS

Note: Travel on a railroad car during any part of a 24-hour period by a person constitutes a person-day for purposes of this table.

ASSOCIATION OF AMERICAN RAILROADS,
Washington, D.C., March 2, 1970.

DEAR MR. CHAIRMAN: The following information is provided in response to request contained in your letter of January 20, 1970 concerning waste disposal from interstate trains.