Secretary Ian A. Bowles
Executive Office of Energy and Environmental Affairs
Attn: MEPA Office EOEA #14973
Attn: Aisling Eglington, MEPA Analyst
100 Cambridge Street, Suite 900
Boston, MA 02114
Re: Comments on CSX Worcester rail yard expansion plan
Environmental Notification Form
Dear Secretary Bowles:
The Massachusetts Chapter of the Sierra Club finds unsatisfactory the recently submitted ENF filed by the CSX railroad, for the expansion of its Worcester rail yard and intermodal terminal from 28 acres to 79. This project is integral to the railroad’s agreement with the Commonwealth to relocate its principal Massachusetts freight handling facility from Beacon Park Yard in Allston—a deal that includes MassDOT’s purchase of its tracks between Framingham and Worcester, and increasing the frequency of MBTA commuter rail service to Boston along this approximately 20-mile segment. Smaller rail yards in Westborough and West Springfield will also be upgraded as part of its larger plan. We firmly believe that work of the full magnitude being proposed here, including its ancillary projects, necessitates the submission of an Environmental Impact Statement.
CSX wishes to expand Worcester as the preeminent regional rail hub for New England, intersecting as it does with rail lines to the north and south that would enable it to provide through freight service to the entire region. It desires expedited approval from your office with this ENF, so it can commence construction in Worcester for a planned completion in late 2012 when it is obligated to vacate Beacon Park. The Club contends, however, that the relocation raises serious issues in terms of transportation planning, justice to the surrounding neighborhoods, and public safety. Thus we strongly urge the Secretary to deny the railroad’s request for an environmental certificate at this time, but require it to submit a full EIS to address the concerns of the various communities affected by the work in question.
Earlier this year MassDOT conducted several public meetings around the Commonwealth to explain the Massachusetts Freight and Rail Plan (http://www.
While the aim of taking truck traffic off the roads certainly argues for the expansion of rail yards on the suburban periphery, planners seem oblivious to the likelihood that closing down Beacon Park would markedly increase the volume of trucks driving in to service the urban core, putting further strain on the Turnpike, Route 9 and other regional highways. They justify the closure as allowing for the upgrading of the Boston-Worcester line for increased passenger rail service, which would purportedly take more traffic off the roads than would be generated by added truck traffic coming into the city—hardly a convincing explanation. Retaining Allston for some freight use and perhaps also using one or two smaller yards (e.g., Framingham, in addition to Westborough) could allow for a more even distribution of freight yet not increase the strain on our highways, but such a proposal is not on the table.
CSX is eager to expedite this project in order to meet its September 2012 deadline to move out of Beacon Park Yard; however, the railroad did not unveil the planned expansion to the public until last winter. Its haste and alleged highhandedness have provoked controversy in Worcester, particularly from abutting residents and business owners (“Property owners unhappy with CSX eminent domain strategy,” Worcester Telegram, October 21, 2010). Since it was first announced, the total size of the yard has grown from 51 acres to 79. Several small streets would now be closed and homes and businesses taken, leading people to question whether all the proposed property takings are necessary for the project.
But the most urgent issue in the rail yard controversy is less discussed: the transport, storage and transferring of hazardous materials in highly populated areas, e.g., chlorine gas, ammonia and other highly dangerous shipments. Once again, CSX has been less than forthcoming. In response to a Worcester City Council order in April requesting information about the number and amount of hazardous materials it transports through the city, the railroad dodged the question (http://www.worcesterma.gov/
CSX has also minimized concerns expressed by officials of neighboring towns, and by the public. Chemicals are to be transferred at the Westborough facility, 30 per cent of which are considered to be hazardous—but not chlorine, according to the railroad (“Officials consider safety in rail deal,” Boston Globe, November 14, 2010), which will be shipped through the site to unspecified destinations. The railroad was openly contemptuous to selectmen from adjacent Southborough, who wanted to discuss their safety concerns with its representatives (“CSX draws criticism in Southborough,” Wicked Local Westborough, December 4, 2010). At a public meeting in Worcester early this month, its governmental affairs liaison for Massachusetts brushed aside such issues, declaring that the completed terminal will be “one of the greenest terminals in the CSX system,” with “emissions . . . less than what they are today” (“CSX environmental study at issue,” Telegram, December 3, 2010).
We have all read news reports about mass evacuations of communities necessitated by the derailing and rupturing of tank cars carrying chlorine and other hazardous substances. For a glimpse at what kinds of risks might be at stake, see p. 24 from the document available on free download from the Chlorine Institute website (Pamphlet 74): One standard 90-ton chlorine tank car can produce a toxic gas cloud at a very dangerous level over any city 15 miles long and 4 miles wide (http://www.chlorineinstitute.
Thus it is incumbent upon the Secretary to require that CSX prepare a full Environmental Impact Statement. The Worcester rail yard is not just one discrete project, but part of a larger proposal planned to be implemented at various sites in Massachusetts. Its effects should not be studied separately but all together, as this project will have many widespread effects and not just in one or two locations. This is a big study, but the effects are large. At the very least, it must frankly address both the potential risks of the project, and its plans to work with in-house and local hazmat teams in the event of any catastrophe. Our lives depend on it.