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In conjunction with their ADA argument, petitioners argue
that one of the underlying purposes of section 6421 is to provide
relief for local mass transportation systems, and therefore we
must construe the statute to include paratransit providers as
beneficiaries in order to be consistent with and further this
purpose. See Greyhound Corp. v. United States, 495 F.2d 863, 868
(9th Cir. 1974) (“Special relief is also provided, in the case of
gasoline, diesel fuel, and special motor-fuel taxes, for fuel
used in the operation of local or mass transportation systems.”
(quoting H. Rept. 2022, 84th Cong., 2d Sess. (1956), 1956-2 C.B.
1285, 1289)). The legislative history of the statute as amended
in 1978, the statute which we are construing in this case, states
as the statute’s purpose “to encourage greater use of bus
transportation.” S. Rept. 95-529, supra at 54, 1978-3 C.B. (Vol.
2) at 246 (emphasis added). Petitioner cites authority on
statutory interpretation that notes that there is a presumption
against an implied repeal of legislative purpose. However, we do
not consider our holding to conflict with the purpose of the
statute as originally enacted. Nor do we find that the 1978
amendment intended to repeal the stated purpose of the 1956 act.
Rather, the 1978 amendment simply designated the scope of the
local mass transportation systems that Congress wanted to qualify
under section 6421. We cannot accommodate petitioners’ request
to ignore words in the statute and gloss over stated
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