Those actually do come in above the minimum requirement, but not overly so. If they didn't then places like Essex wouldn't be allowed to use them.
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Interesting Bill, when I was working on the Berkshire Scenic, I was under the impression that our FRA inspector wouldn’t allow them for that reason. If they are allowed, that would be such a nice choice for 52. In my opinion, you couldn’t ask for a better sound that isn’t so harsh as to destroy people’s ears on open cars etc.