2024 Cost per ton mile rail vs truck

A ton-mile is one ton shipped for one mile. While truck incidents involving hazardous ... 380 for truck, compared with 23 for rail, according to the Bureau of Transportation Statistics. The .... Fedex drop off express

Trains burn less fuel per ton-mile than road vehicles and a train, which can have as many as 100 wagons, only needs one driver. There are, however, some additional costs that are incurred in a rail journey: at each end of the rail transit, a road delivery will be needed, and there will be a lift cost to transfer the container between the train and the road vehicle.Rail external costs are 0.24 cent to 0.25 cent (US) per ton-mile, well less than the 1.11 cent for freight trucking, but external costs for rail generally constitute a larger amount relative to private costs, 9.3–22.6%, than is the case for trucking, 13.2%.Total of Median Costs 4.0 0.5 2014 Cents Per Ton-Mile Note: For damages from CO 2, three numbers are shown to describe the distribution of estimates of external costs; values toward the middle of the range are much more likely to be selected. For other sources of external costs, ... Shift in Ton-Miles From Truck to Rail (Percent) 3.6 3.9 3.8 0.8 …a Incudes Freight, Express, and Mail. b Estimates from 1980 to 1989 come from the Association of American Railroads using ton mile values from the Surface Transportation Board’s Waybill Sample. The Waybill Sample represents all major U.S. railroads, including all Class I railroads and several short-line railroads. Compare the Costs. The cost per ton-mile for a barge is only $0.97, compared to $2.53 for rail, and $5.35 for trucking. Barge v. Truck & Rail Capability - PDF; Other benefits include an improved natural environment for fish and wildlife, parks and recreational areas, generation of clean and renewable hydroelectric power, reduced soil erosion ...The authors note that air pollution and greenhouse gas costs equal $1,000 per 1 million barrel-miles via rail transportation compared to just under $400 in damages from spills and accidents ...The Bureau of Transportation Statistics (BTS) has revised the methodology for calculating freight ton‐miles across modes. 1 The objective is to make more comprehensive estimates by using the estimates of total freight ton‐miles and pipeline ton‐miles from the Federal Highway Administration's Freight Analysis Framework 2 (FAF). FAF uses the …While some costs in the U.S., like land and labor, tend to be relatively high compared to elsewhere in the world, the U.S. stays competitive by having an efficient, low cost transportation system. Grains and oilseeds rely on an integrated multimodal transportation system to move from farm to market, including truck, barge, rail, and ocean vessels.The data tables are based on primary data that EIA collects from plant owners and operators on Form EIA-923, Power Plant Operations Report, and on supplement data and analysis of coal transportation costs that we released in June 2011 and November 2012. The initial report on coal transportation rates covered 2001 through 2008, applied …by truck (per ton-mile) are around eight times higher than by rail; those costs net of existing taxes represent about 20 percent of the cost of truck transport and about 11 …Rail Cost Adjustment Factor (RCAF) The RCAF was established in response to the requirement in the Staggers Rail Act of 1980 that a quarterly cost-recovery index be created. Each quarter, the AAR submits the RCAF index to the Surface Transportation Board for approval. (Includes the RCAF-U and RCAF-A). RCAF Description. a. because of high capital cost, rail must have a large volume of traffic to justify the expense b. water transport requires low rates of energy per ton mile moved c. operating costs per ton mile tend to be low for trucks d. a and b abov e e. b and c above.Sep 29, 2023 · Published by Statista Research Department , Sep 29, 2023. In 2020, the U.S. average freight revenue per ton-mile in Class I rail traffic stood at 4.4 U.S. dollar cents. This was a slight drop ... The study shows that, based on the annualized cost methodology, the transport cost per ton-mile via freight pipeline is cost competitive with truck, rail, and TOFC for four of the five configurations within the Philadelphia-Chicago transportation corridor if the annual tonnage is high. For the fifth configuration, truck is clearly a less ...Jun 16, 2015 · Barges being towed down a river will get 953 net ton-miles, but being towed against the flow of the current will drop to 243 (Tolliver) with an overall average of 576 ton-miles, with rail 413, truck 155. Davis reports that rail (294 Btu/ton-mile in 2012) is 40% more energy intensive than barge (210 Btu/ton-mile in 2012), nearly the same ... See full list on freightcourse.com Cost: Safety: Rail: 455 ton-miles/ gallon: 216 million annual tons per track: 2.7 cents per ton-mile: 0.61 fatalities per billion tonmiles: Diesel Truck : 105 ton-miles/ gallon: 37.8 million annual tons per lane: 5.0 cents per ton-mile: 1.45 fatalities per billion tonmiles: Rail Freight is: 4 times more fuel efficient;The data tables are based on primary data that EIA collects from plant owners and operators on Form EIA-923, Power Plant Operations Report, and on supplement data and analysis of coal transportation costs that we released in June 2011 and November 2012. The initial report on coal transportation rates covered 2001 through 2008, applied …Freight transportation plays an important role in our global economy. Billions of tons of cargo are transported around the world each year by trucks, planes, ships, and trains. This transportation makes up 8% of global greenhouse gas emissions, and as much as 11% if warehouses and ports are included. Growing economies in Asia, Africa and …One ton-mile is the equivalent of shipping one ton of product, one mile. One ton-mile is the equivalent of shipping one gallon of milk about 225 miles. Importing a piece of furniture that weighs 100 lbs. from China to Seattle incurs over 300 ton-miles. 562 billion ton-miles were incurred in the shipment of coal in the US in 2002 alone.In terms of CO2 emissions per tonne of cargo transported one mile, shipping is recognised as the most efficient form of commercial transport. However, the enormous scale of the industry means that it is nevertheless a significant contributor to the world’s total greenhouse gas emissions (around 3% of total global CO2 emissions).Dec 25, 2017 · A per container railway transportation cost of $2.50 per mile can be applied to the Long Beach – Chicago (2,100 miles - $5,200) and Long Beach – Newark/New York City (3,000 miles - $7,500) links. Let’s say you were able to optimize routes to eliminate 20% of your fleet’s yearly miles. Using the American Transport Research Institute’s latest cost per truck mile data of $1.82, a 30-truck fleet running 1.5 million miles a year would save $546,000 yearly – dollars that move from an expense line straight to the profit line.A ton-mile is one ton shipped for one mile. While truck incidents involving hazardous ... 380 for truck, compared with 23 for rail, according to the Bureau of Transportation Statistics. The ...Carbon Calculator. Railroads are an environmentally responsible way to transport goods. Trains, on average, are 3-4x more fuel-efficient than trucks. See how shipping freight by rail helps eliminate carbon dioxide from the air and remove trucks off congested roads. 1 Select the number of rail cars.Due to its ability to move major quantities of freight at one time, rail shipping has a lower cost-per-ton-mile (the cost of moving one ton of freight one mile) than truck shipping. In fact, a train requires less energy to move …Oct 15, 2020 · Intermodal spot rates were $1.74 per mile at the beginning of October, compared to the monthly average of $1.31 in May, according to Croke. Overall, U.S. railroads originated about 1.4 million intermodal containers in September, an increase of more than 7% YoY, according to the latest numbers from the Association of American Railroads . The average freight revenue per ton-mile compared to the Producer Price Index increased for all freight modes. From 1990 to 2020, the oil pipeline mode experienced the largest increase, rising by 181.1 percent, followed by truck at 128.4 percent, and domestic water transportation by 107.0 percent. One ton-mile is the equivalent of shipping one ton of product, one mile. One ton-mile is the equivalent of shipping one gallon of milk about 225 miles. Importing a piece of furniture that weighs 100 lbs. from China to Seattle incurs over 300 ton-miles. 562 billion ton-miles were incurred in the shipment of coal in the US in 2002 alone.Some carriers have announced rates above $6k/FEU for Mediterranean shipments starting mid-month, and surcharges of $500 to as much as $2,700 per container could make all-in prices even higher. Asia – N. America rates climbed 55% to $3,900/FEU to the East Coast. Trucks generate 154.2 tons or 10 times (1,000 percent) more emissions than barges per ton-mile of cargo moved. • Highlights the significant infrastructure impacts of waterborne freight were diverted to highways. Approximately 2 inches of asphalt would have to be added to the pavement of 118,688 lane-miles of rural interstate given the higher ...Dec 25, 2017 · A per container railway transportation cost of $2.50 per mile can be applied to the Long Beach – Chicago (2,100 miles - $5,200) and Long Beach – Newark/New York City (3,000 miles - $7,500) links. Weight and Value of Freight Shipments by Domestic Mode: 2017 Domestic Moda. because of high capital cost, rail must have a large volume of traffic to justify the expense b. water transport requires low rates of energy per ton mile moved c. operating costs per ton mile tend to be low for trucks d. a and b abov e e. b and c above.Step 1: Determine the total amount of ton-miles. Multiply 1,000 miles times 20 tons, which gives us a total of 20,000 ton-miles. Step 2: Get the weight-based truck emissions factor for a freight truck. The average freight truck in the U.S. emits 161.8 grams of CO2 per ton-mile. Step 3: Multiply this emissions factor with the total ton-miles ...Carbon Calculator. Railroads are an environmentally responsible way to transport goods. Trains, on average, are 3-4x more fuel-efficient than trucks. See how shipping freight by rail helps eliminate carbon dioxide from the air and remove trucks off congested roads. 1 Select the number of rail cars.Classes 4–6 truck. Classes 7–8 truck. freight rail. domestic marine. 2020 2030 2040 2050. Passenger travel energy intensity by mode. AEO2022 Reference case. thousand British thermal units per passenger -mile. Freight travel energy intensity by mode . AEO2022 Reference case. thousand British thermal units per ton-mile Comparison of Freight Rail and Trucking. As of 2014, freight rail resulted in 21.2 metric tons of GHG emissions per million ton-miles while trucks emitted 154.1 metric tons of …ton-mile in the US: 1 ton-mile * ( 0.907185 t / short ton) * ( 1.609344 km / mile ) ... A semi truck traveling from Los Angeles to Chicago ... Energy efficiency in transport can be measured in L/100 km or miles per gallon (mpg). This can be normalized per vehicle, as in fuel economy in automobiles, ...8. ›. ». Freight Facts and Figures, developed by the Bureau of Transportation Statistics, is a collection of charts and statistical tables about freight transportation in the United States. These interactive visualizations and tables provide a snapshot of freight movement; the extent, condition, and performance of the freight transportation ...Sep 9, 2019 · A rail movement might cost in the 4.5 cents per ton-mile price range versus a truck price in the 9 cents or higher range. The trade-off to the shipper, however, can often be a higher inventory carrying cost because carloads arrives a day early or a day late as much as 40% of the time. Mar 29, 2017 · Trucks generate 154.2 tons or 10 times (1,000 percent) more emissions than barges per ton-mile of cargo moved. • Highlights the significant infrastructure impacts of waterborne freight were diverted to highways. Approximately 2 inches of asphalt would have to be added to the pavement of 118,688 lane-miles of rural interstate given the higher ... The same study referenced above showed that external costs per ton-mile amounted to about $2.62 – $5.86 for road transport compared to only $0.3 – $0.82 for …Exports at $1,826 per ton and imports at $1,456 per ton are higher than domestic shipments at $799 per ton in 2007. Exports and imports accounted for 10.7 percent of the tons and 19.1 percent of the value in 2007 and are forecast to make up an even greater share of freight moving throughout the United States, reaching 19.0 percent …Rail freight: Overview of the market. The rail freight transport market was valued at $247.39 billion in 2020, and is expected to register a CAGR (compound annual growth rate) of about 2% from 2021 to 2026. In the US alone, the rail freight transportation market was estimated at $58 billion in 2022.Although, transport by truck is a more direct shipping route, as discussed above, it is not the most cost effective. "The cost to combine rail and truck using a bulk transfer terminal is approximately $95.54 per net ton. By comparison, rail direct is $70.27 per net ton, and over-the-road truck is $214.96 per net ton."The average shipment by truck was 63 miles compared to an average of 640 miles by rail. Hazardous materials shipments by hazard class Flammable liquids are the predominant hazardous materials transported in the United States, accounting for 81.8 percent by value, 83.1 percent by weight, and 70.5 percent of the ton-miles of all hazardous ...ton-mile in the US: 1 ton-mile * ( 0.907185 t / short ton) * ( 1.609344 km / mile ) ... A semi truck traveling from Los Angeles to Chicago ... Energy efficiency in transport can be measured in L/100 km or miles per gallon (mpg). This can be normalized per vehicle, as in fuel economy in automobiles, ...Dec 25, 2017 · A per container railway transportation cost of $2.50 per mile can be applied to the Long Beach – Chicago (2,100 miles - $5,200) and Long Beach – Newark/New York City (3,000 miles - $7,500) links. May 1, 2020 · O n average, over all the scenarios we examined, total per-ton-mile operating costs for conveyor haul age were about 39% of those for truck transport. These costs include the diesel (US$2.65 per gallon) or electricity (US$0.087 per kWh) to propel the truck or the belt, maintenance and repair parts and labour, tires and an operator for the truck ... Sep 9, 2019 · A rail movement might cost in the 4.5 cents per ton-mile price range versus a truck price in the 9 cents or higher range. The trade-off to the shipper, however, can often be a higher inventory carrying cost because carloads arrives a day early or a day late as much as 40% of the time. Jun 16, 2015 · Barges being towed down a river will get 953 net ton-miles, but being towed against the flow of the current will drop to 243 (Tolliver) with an overall average of 576 ton-miles, with rail 413, truck 155. Davis reports that rail (294 Btu/ton-mile in 2012) is 40% more energy intensive than barge (210 Btu/ton-mile in 2012), nearly the same ... Mar 29, 2017 · Trucks generate 154.2 tons or 10 times more emissions than barges per ton-mile of cargo moved. The report is available here . MORE TOP STORIES Water Air (including truck and air) Rail (includes truck and rail) Pipeline Other and unknown b) 0 50 100 150 200 250 1980 1985 1990 1995 2000 Index: 1980=100 Intercity truck Class I rail Water Oil pipeline Figure 1. a) Modal share in 1997; and b) change since 1980 in domestic ton-miles carried by mode.Rail Energy Cost Analysis Package: The system Perspective. AAR Report R-467, Association of American Railroads, Washington, D.C., Aug. 1984. ... M.B. Hargrove. The Economics of Improved Truck Design. In The Economics and Performance of Freight Car Trucks, AAR Report R-490, Associ ation of American Railroads, Chicago, Ill., ... nance …Rail's advantage is a much lower cost-per-ton-mile basis (the cost of moving one ton a distance of one mile) than trucking. unit trains. dedicated trains that move from a single origin to a single destination. Large shippers in agriculture, mining, and auto industries use these ... LCVs require special clearance to operate on most roadways. truck vs rail …COST. If you're hauling goods crosstown or even intrastate, trucking may be the better bargain. It's also a good consideration if your volume doesn't even fill one rail car. …Freight Facts and Figures, developed by the Bureau of Transportation Statistics, is a collection of charts and statistical tables about freight transportation in the United States. These interactive visualizations and tables provide a snapshot of freight movement; the extent, condition, and performance of the freight transportation system; the economic …The Freight Analysis Framework (FAF) database has estimates of US freight flows. Data are available for states and metropolitan areas. Flows include all modes of transportation and 42 commodity types. The Bureau of Transportation Statistics (BTS) produces the FAF with support from the Federal Highway Administration (FHWA).Water Air (including truck and air) Rail (includes truck and rail) Pipeline Other and unknown b) 0 50 100 150 200 250 1980 1985 1990 1995 2000 Index: 1980=100 Intercity truck Class I rail Water Oil pipeline Figure 1. a) Modal share in 1997; and b) change since 1980 in domestic ton-miles carried by mode. Lower electricity and maintenance costs will magnify the impact of autonomous-related cost reductions. If autonomous electric trucks were to absorb the ton-miles shipped over rail in the US, the truck logistics market could double to roughly 3.4 trillion ton-miles, a $100 billion market-opportunity.COST. If you're hauling goods crosstown or even intrastate, trucking may be the better bargain. It's also a good consideration if your volume doesn't even fill one rail car. …Oil spill volume per billion-ton-miles compared among transportation modes. ... It’s simply cheaper and quicker to transport by pipeline than by rail or by truck. The difference in cost is about ...Cost: Safety: Rail: 455 ton-miles/ gallon: 216 million annual tons per track: 2.7 cents per ton-mile: 0.61 fatalities per billion tonmiles: Diesel Truck : 105 ton-miles/ gallon: 37.8 million annual tons per lane: 5.0 cents per ton-mile: 1.45 fatalities per billion tonmiles: Rail Freight is: 4 times more fuel efficient; About 6 times the capacity; About ½ the cost; Less …Apr 20, 2020 · The cost to combine rail and truck using a bulk transfer terminal is approximately $95.54 per net ton. By comparison, rail direct is $70.27 per net ton, and over-the-road truck is $214.96 per net ton. Using multi-modal rail and truck transit compared to truck alone, you can cut transportation costs by more than half. Railcar Equipment Costs Total of Median Costs 4.0 0.5 2014 Cents Per Ton-Mile Note: For damages from CO 2, three numbers are shown to describe the distribution of estimates of external costs; values toward the middle of the range are much more likely to be selected. For other sources of external costs, ... Shift in Ton-Miles From Truck to Rail (Percent) 3.6 3.9 3.8 0.8 …Barges being towed down a river will get 953 net ton-miles, but being towed against the flow of the current will drop to 243 (Tolliver) with an overall average of 576 ton-miles, with rail 413, truck 155. Davis reports that rail (294 Btu/ton-mile in 2012) is 40% more energy intensive than barge (210 Btu/ton-mile in 2012), nearly the same ...Oct 23, 2023 · When shipping in bulk, the cost per ton-mile for rail transport is often lower than other methods. A train will use less energy when carrying freight that’s equivalent to 300 trucks. This means less fuel is used, which saves costs for shippers. Shipping freight by rail is faster than truck, but only if traveling over long distances. Rail shipping is much more cost-effective than truck shipping for several reasons. Rail is a much more fuel-efficient mode of transportation. Railcars can also …Trucks have cost advantages for shorter distances (less than 250 to 500 miles) and function primarily as the short-haul mode between farm and local silos. ... often less than half of rail’s per ton-mile cost. The economics of unit rail trains. There have been three technical advances in the past half century that have helped U.S. railroads retain …Apr 20, 2020Trucks generate 154.2 tons or 10 times (1,000 percent) more emissions than barges per ton-mile of cargo moved. • Highlights the significant infrastructure impacts of waterborne freight were diverted to highways. Approximately 2 inches of asphalt would have to be added to the pavement of 118,688 lane-miles of rural interstate given the higher ..."The cost to combine rail and truck using a bulk transfer terminal is approximately $95.54 per net ton. By comparison, rail direct is $70.27 per net ton, and …Compare the Costs. The cost per ton-mile for a barge is only $0.97, compared to $2.53 for rail, and $5.35 for trucking. Barge v. Truck & Rail Capability - PDF; Other benefits include an improved natural environment for fish and wildlife, parks and recreational areas, generation of clean and renewable hydroelectric power, reduced soil erosion ...by truck (per ton-mile) are around eight times higher than by rail; those costs net of existing taxes represent about 20 percent of the cost of truck transport and about 11 …Ship: 576 miles per gallon per ton of cargo Train: 492 miles per gallon per ton of cargo Truck: 134 miles per gallon per ton of cargo Reply Roughneck16 • Civil / Structures • from cost per ton estimates by Haling and Cohen (1995), which are in turn based on estimates from ... portation cost (termed “netbacks”). Firms move oil to a rail or pipeline terminal using either truck ... is available capacity, because rail is significantly costlier than pipeline per barrel-mile shipped. For example, Frittelli et al (2014, p. 7) noted that: …The results are based on the projected average mix of trucks and trains in California for the given year. Results show that as California’s current truck regulations are implemented through 2023, …

Trains are more fuel-efficient than trucks, and rail transportation produces fewer greenhouse gas emissions per ton of freight transported. Overall, both rail and intermodal transportation have their advantages and disadvantages, and the choice between the two will depend on factors such as distance, cost, and the specific needs of the shipment.. 678732

The study shows that, based on the annualized cost methodology, the transport cost per ton-mile via freight pipeline is cost competitive with truck, rail, and TOFC for four of the …Published by Statista Research Department , Sep 29, 2023. In 2020, the U.S. average freight revenue per ton-mile in Class I rail traffic stood at 4.4 U.S. dollar cents. This was a slight drop ...Not only does moving freight by rail instead of truck lowers GHG emissions by up to 75%, on average, it reduces the economic toll of congestion and expensive highway repairs. ... As taxes and fees from commercial trucks inadequately cover the cost of highway damage, freight rail’s private investments don’t just drive down emissions, they alleviate taxpayer …Let’s say you were able to optimize routes to eliminate 20% of your fleet’s yearly miles. Using the American Transport Research Institute’s latest cost per truck mile data of $1.82, a 30-truck fleet running 1.5 million miles a year would save $546,000 yearly – dollars that move from an expense line straight to the profit line.Rail external costs are 0.24 cent to 0.25 cent (US) per ton-mile, well less than the 1.11 cent for freight trucking, but external costs for rail generally constitute a larger amount relative to private costs, 9.3–22.6%, than is the case for trucking, 13.2%.Rail Barge Truck Exports Ocean Brazil Mexico Grain Truck/Ocean Rate Advisory Datasets Specialists Subscription Information----- The next release is ... the rate for shipping a metric ton (mt) of grain from the U.S. Gulf to Japan was $82.25. This was unchanged from the ... high auction and secondary market rates could exceed the base …One Rail Car: 100 tons: 3,500 bushels: 30,240 gallons: 100-Car Train Unit: 10,000 tons: 350,000 bushels: 3,024,000 gallons: Large Semi: 26 tons: 910 bushels: 7,865 gallons: Safety of Shipping Methods. Comparison of the safety records of barge, train, and semi truck per billion ton-miles (Source: C. Jake Haulk Ph.D. – Inland Waterways as Vital …Freight Facts and Figures, developed by the Bureau of Transportation Statistics, is a collection of charts and statistical tables about freight transportation in the United States. These interactive visualizations and tables provide a snapshot of freight movement; the extent, condition, and performance of the freight transportation system; the economic …For example, a 2015 study conducted by the Congressional Budget Office, found that moving cargo via rail costs about 5.1 cents per ton-mile, whereas the cost via truck is 15.6 cents per ton-mile, and this because a truck can handle 1 – 2 containers per trip, whereas a train can handle a few hundred. There are also external costs indicating …Rail Barge Truck Exports Ocean Brazil Mexico Grain Truck/Ocean Rate Advisory Datasets Specialists Subscription Information----- The next release is ... the rate for shipping a metric ton (mt) of grain from the U.S. Gulf to Japan was $82.25. This was unchanged from the ... high auction and secondary market rates could exceed the base …Freight rail easily trumps trucking, aviation and other transportation sectors in moving goods while producing the least carbon emissions. Over the past quarter century, freight railroad’s fuel ..."The cost to combine rail and truck using a bulk transfer terminal is approximately $95.54 per net ton. By comparison, rail direct is $70.27 per net ton, and …– Tax rates on truck shipping: 2.3¢ per ton- mile, $1.62 per gallon – Tax rates on rail shipping: 0.3¢ per ton-mile, $1.34 per gallon Vehicle miles traveled (VMT ) tax (distance only, not weight) plus fuel tax – Truck tax rate: 30¢ per mile, $1.62 per gallon – Rail tax rate: 12¢ per mile, $1.34 per gallon VMT tax alone – Truck ... Oil spill volume per billion-ton-miles compared among transportation modes. ... It’s simply cheaper and quicker to transport by pipeline than by rail or by truck. The difference in cost is about ...Rail's advantage is a much lower cost-per-ton-mile basis (the cost of moving one ton a distance of one mile) than trucking. unit trains. dedicated trains that move from a single origin to a single destination. Large shippers in agriculture, mining, and auto industries use these ... LCVs require special clearance to operate on most roadways. truck vs rail …Trucking cost per ton: Conveyor cost per ton: Project life: IRS Depreciable life: Inflation rate for expenses: Cost of capital (interest rate): Corporate tax rate: Summary of Spreadsheet Variables 3,000,000 tons per year fixed 5 miles, flat one way $12,790,099 $1.21 year 1 $.203 year 1 20 years 10 years 3% per year 8% 30% RESULTS SHOWN ON GRAPH The data tables are based on primary data that EIA collects from plant owners and operators on Form EIA-923, Power Plant Operations Report, and on supplement data and analysis of coal transportation costs that we released in June 2011 and November 2012. The initial report on coal transportation rates covered 2001 through 2008, applied …Typical values for various transportation modes, using numbers based on an EPA publication, are 253 g CO2-eq/ton-mile for diesel trucks, 27 g CO2-eq/ton-mile for rail, and 41 g CO2-eq/ton-mile for domestic water transportation. (Other sources provide somewhat different numbers, but these values are reasonably representative of the general ... .

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