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In accordance with the National Environmental Policy Act of 1969, 42 U.S.C. 4321, et seq., this draft environmental impact statement represents an analysis of the environmental effects of the proposed action.

BACKGROUND

The specific action proposed herein, in addition to background information, is fully discussed in the interim report of the Commission, and that report is hereby incorporated by reference and made part of this draft environmental impact

statement.

Historically, commercial zones and terminal areas have been established by one of two methods. First, the Commission, on its own motion or on petition of an interested party, can specifically define an individual municipality's commercial zone based on economic and commercial facts peculiar to that municipality. The second method utilized for determining all other commercial zones is the population-mileage formula which was originally developed by the Commission in Ex Parte No. MC-37, Commercial Zones and Terminal Areas, 46 M.C.C. 665 (1946). In that proceeding, the Commission took notice of specific commercial zones previously defined and devised a formula of general applicability whereby the extent of all commercial zones and terminal areas can be easily determined. The commercial zone of a city which has not been individually defined is established by drawing an imaginary contour around the city limits. The mileage presented in the formula represents the distance between the city limits and the boundary of the commercial zone. Consequently, the contour of the zone will resemble the contour of the city limits. Under the formula, the size of the commercial zone will vary according to the population of the base municipality. Air mileage is used and the population is determined by the last decennial census. Included within the commercial zone as generally defined are the base municipality, points in the United States in all contiguous municipalities, all unincorporated areas within the United States within the mileage limits, and all municipalities wholly surrounded (or surrounded except for water) by the municipality, any United States municipality contiguous thereto, or any United States municipality included within the commercial zone of the base municipality.

DESCRIPTION OF THE EXISTING ENVIRONMENT

The population-mileage formula in its present form was developed 30 years ago and is predicated to some extent on demographic and industrial factors which were evident at that time. Since that time the United States has experienced the so-called postwar population boom. This respresents one of the fastest growing periods in the history of the country. In addition to the rapid growth of population, the basic patterns of development and expansion have also changed. The importance of the central city has declined as suburban areas and satellite cities have grown. In addition,

recent times have seen the mergence of the megalopolis as suburban areas expand outward and overlap. While this trend has been most noticeable in terms of population trends, the importance of the central city in terms of economic and commercial activity has likewise declined. Table I illustrates the growth rate of selected urban areas in the United States. It is interesting to note that, in almost all cases, the percent change in population of suburban areas (outside central city) is significantly greater than the percent change for the central cities, and the central cities' share of overall metropolitan population has been declining.

In addition to the significant increase in the population growth rate since World War II, the development of the Interstate Highway System and the construction of freeway systems circumventing and radiating from the central cities have caused an acceleration in population diffusion in metropolitan areas away from the central cities.

While population trends over the past 30 years show a dramatic diffusion away from central cities, it is recognized that this population trend does not present an entirely accurate picture of industrial and commercial trends occurring in the same areas. The best available data which the Commission has received, however, has been in terms of population trends, and appears to be a reasonable basis for drawing conclusions on the need to adjust the population-mileage formula, especially in view of the fact that the formula historically has been based on demographic facts.

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While the general trend in population diffusion is noticeable, it is interesting to examine, in detail, the extent of population diffusion around various representative

cities. The Freight Forwarders Institute, a party to this proceeding, has commissioned a study to examine various factors which bear on the applicability of the populationmileage formula.' Much of the data developed was obtained from a computer data service, Urban Decision System, and is based on information received from the U.S. Bureau of Census, Census of Population, for 1960 and 1970.

The basic method of the report was to examine the metropolitan areas of 12 cities. These cities were selected because of, among other things, their differing geographic and physical characteristics, and their varying population growth rates. As a means of comparing population diffusion, the metropolitan area for each of the cities was determined by drawing a circle around the central city (the radius of each measured 60 miles) and comparing growth trends within various contours and concentric bands radiating from the central cities.

Table C-I (Appendix C to the interim report of the Commission), which has been developed from the above-mentioned study, compares the total number of people living within a 60 mile radius of given cities with the percent of those people which would be captured in specified contours and rings. For each contour and ring the cumulative percent of the population captured is presented for both 1960 and 1970. The cumulative annual average growth rate is also presented. There are certain pertinent conclusions which can be drawn from Table C-I. First, the average annual growth rate generally increases the further from the central city. This fact lends support to the trend noticed above, i.e., that the suburban areas are growing at a more rapid pace then the central cities. Second, in metropolitan areas such as Baltimore and San Francisco (where city and suburban areas of near comparable size are located in close proximity to one another) the central city is a less significant factor in terms of share of population.

EFFECTS OF PROPOSED FORMULA

Based on the data developed above, it is possible to measure the increases in population which would be captured by commercial zones under the proposed formula. Table C-2 (Appendix C to the interim report of the Commission) compares the percent of the population within a 60 mile ring which would be presently captured within the commercial zone of selected cities based on the current formula to the percent which would be captured under the proposed formula. While all cities presented show an increase in the percent of population which would be captured, it is interesting to note that the most dramatic increase would occur in New York and Los Angeles, the two largest cities in the country.

II. Probable Environmental Impacts.

(1). Decrease in interlining.—The most direct environmental impact associated with an expansion of the commercial zone and terminal area formula will be a decrease in the number of interline operations for long-haul carriers which are currently required. As an example, until recently, Rockville, Md., was not included in the Washington, D.C., terminal area. If an interstate carrier with authority between Chicago, Ill., and Washington, D.C., had a shipment from Chicago bound for Rockville, it would be required to enter the Washington terminal area and transfer its shipment to another carrier (usually a local or short-haul carrier) with authority to serve Rockville from

***An Assessment of the Population-Mileage Formula For Terminal Areas," Arthur D. Little, Inc., 1975.

Washinton. Once Rockville is included in the Washington terminal zone, this shipment could be made directly to Rockville with the same authority, thus eliminating the need for an interline in Washington.

Similar results can be expected for any given city should the commercial zone and terminal area formula be expanded. Such a scenario would involve a beneficial environmental impact in terms of air pollution, fuel consumption, and traffic congestion. Expansion of terminal areas would have the effect of decreasing the mileage as well as the number of hauls needed to make deliveries in certain instances. This will, in turn, reduce the fuel consumption of regulated carriers as well as the amount of air polluting emittants. Similarly, this action would remove from the urban and suburban highways and streets a number of trucks, thus reducing traffic congestion in these areas.

This latter result is especially important in view of the goals and policies established by the Clean Air Act of 1970. This act requires all States to submit plans for meeting the national ambient air quality standards established by the Environmental Protection Agency (EPA) in 1971. The standards are directed towards protecting the public health and welfare from known effects of the major air pollutants, including the four primarily associated with motor vehicles: carbon monoxide, nitrogen oxide, photo-chemical oxidant, and hydrocarbons. Transportation control plans (TCP) are required for any air quality region where controls on stationary sources, combined with Federal new car emission standards, are inadequate to ensure attainment or maintenance of the ambient standards. TCP's have been generally required for major metropolitan areas which typically exhibit high concentrations of air pollutants. Plans implemented to date generally include, among other things, strategies to establish inspection programs for Federal motor vehicle controls, mass transit improvements, automobile restraints and disincentives, and restriction of truck delivery to non-peak commuting periods.

Expansion of the commercial zone formula is expected to result in a reduction in traffic congestion in the central cities, by reducing the mileage and amount of interlining presently required. Consequently, this action will be consistent with the general strategies which relate to the reduction of vehicle miles travelled (VMT) within the urban core. Furthermore, this result will allow greater flexibility by Federal, State, and local officials in establishing control strategies.

Due to the nature of motor carrier operations, some carriers presented with this opportunity to eliminate interlining as described above may, in fact, continue the present practice of interlining, inasmuch as it may be more convenient to break bulk at terminal facilities within existing terminal areas. To the extent that this occurs, the beneficial environmental effects previously described will not occur.

(2). More efficient pickup and delivery operations. Local and short-haul carriers regularly perform exempt pickup and delivery services within commercial zones and terminal areas. Since many individual shipments consist of less-than-truckload size, a local carrier can combine pickups and deliveries to various shippers at the same time. Because of the high concentration of shippers in metropolitan areas, it would not be unusual to find large numbers of shippers located around the perimeter of existing commercial zones. At the present time an exempt local carrier can serve only those shippers located within the zone and would, consequently, be unable to complete a truckload by serving shippers located just outside the zone. Expansion of the formula would expand the commercial zone market and enable exempt carriers to complete loads by serving shippers, which are located in close proximity to shippers previously served but heretofore outside of the exempt zone. This should have the effect of

fostering more efficient operations by local exempt carriers, thus helping to conserve fuel and scarce natural resources.

(3). Industrial and Commercial Location.-One of the arguments raised in this proceeding is that there is a direct correlation between the extent of a given city's commercial zone and terminal area and industrial and commercial location decisions; thus, one of the factors which a firm will consider before choosing a particular location for a plant is whether that site is located in the commercial zone of a nearby city or population center. It is asserted that a expansion of the population-mileage formula will have the effect of encouraging plantsite locations within the expanded commercial zone area. It is evident that an important location determinant is the availability of a fast, efficient, and inexpensive transportation system. Inclusion of a particular plantsite in a given commercial zone may arguably minimize transportation costs (by the elimination of excess mileage and interlining), and may promote a faster delivery schedule by providing a more direct service.

Assuming that there is a nexus between the extent of a given commercial zone and industrial location determinants, expansion of the zone formula would affect land use patterns and the character of metropolitan development. By expanding the formula, shippers may have an added incentive to locate in suburban areas farther from the central city, where there is adequate room for plantsite location and future expansion. This would be environmentally beneficial in that it would alleviate to some extent congestion problems and help to limit concentrated over-development. On the other hand, this might lead to an even greater tendency toward outward diffusion, thus fostering urban sprawl, and destroying natural surroundings.

The historic position of the Commission, however, has been that modifications of commercial zones are made in recognition of economic facts already in existence. A commercial zone is expanded only when the economic facts indicate that a particular area has become an economic part of the central city. This is usually determined by examining the extent of industrial and commercial activity already occurring.

The Economic Development Administration (EDA) of the United States Department of Commerce recently conducted two studies which bear on this question. The first is a Survey of Manufacturing Plant Characteristics for 1970. EDA surveyed over 3,000 plants representing 223 product classes in an attempt to gain a clear picture of the characteristics of existing plants. The survey found, among other things, that 76 percent of plantsites located in cities of less than 50,000 people were located less than 50 miles from a city with a population of at least 50,000. Of additional relevance is the fact that 84 percent of the products shipped from these plants was by motor carrier (72 percent for products received). Yet 56 percent indicated that, for products shipped by the plant, more than next day or 2 day delivery amounted to 22 percent for products shipped and 20 percent for products received. The second study performed by EDA is a Survey of Industrial Location Determinants, which is designed to survey the local features and characteristics considered important by firms intending to locate in a given area. In selecting locational objectives to be achieved, the factors mentioned most often were (1) improvement in shippers' transportation efficiency or economy, (2) closer proximity to distributors and customers, and (3) ability to serve new and expanded markets. The location of a plantsite within a given terminal area may aid in improving transportation economy and efficiency. However, the survey points out a number of other factors unrelated to the commercial zone question which, to varying degrees, play an important role in location preferences, among which are (1) the proximity to a major highway interchange, (2) the existence of a suitable industrial park or economic development program, (3) compatible zoning laws, (4) the availability of contract

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