Tuesday, December 14, 2010

Why CSX Railyard Expansion in Worcester, MA Needs an Environmental Review

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.massfreightandrailplan.com/). One member of the audience at the Boston presentation questioned the logic of extricating all operations from Allston to make way for a Harvard expansion that now looks, at best, many years away. Project Manager Ned Codd justified the move by noting that much of the freight that comes into the yard must be trucked back out to the 128/495 belt. Currently, the Com­monwealth and the railroad are working together to raise 14 highway bridges between the New York state line and Westborough to accommodate the now standard double-stack shipments; raising the clearances all the way into Boston would be prohibitively expensive, he said.

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/city-manager/csx-expansion-plan, “CSX Expansion Plan – Update, 5/18/10”). The narrative of its November ENF ignored the issue, save for a brief discussion of solid and hazard­ous waste where it asserted that the project does not meet the MEPA review threshold, or require any special state permits for their use and storage (same website, ENF Part I, p. 5-22).

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.org/Bookstore/ProductDetail.cfm?ItemNumber=2893). Given the in­creased chance of derailment during switching operations and the ever-present possibility of a terrorist attack on such a tank car, the repeated as­surances of CSX are not enough to guarantee our safety. The concerns of the public and its elected officials must be fully addressed; the railroad must not be allowed to simply deny that there is any potential problem.

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.

Respectfully submitted,

John Kyper, Transportation Chair

Sierra Club, Massachusetts Chapter

1 comment:

  1. Why is it that nobody is questioning the REAL reason why this deal is being rushed through all of the public planning phases? The withdrawal of CSX from its Allston yard has nothing to do with increasing commuter rail efficiency! It is instead, all about the Harvard University land grab! What is not widely known is that Harvard has been after that swath of CSX real estate for decades now. They already have drawings of buildings which they plan to build on the site, once they acquire it. The sticking point has always been that that CSX would not sell it to them unless the deal was made both profitable and operationally feasible. It took the Massachusetts state government to accomplish both objectives - all in the name of a commuter rail initiative. The Mass. government purchased the rights to this land to supposedly improve the on-time performance of the Worcester commuter rail line. Further, they've virtually assured CSX that the railroad would win approval of its Worcester yard expansion, despite the environmental concerns, as a replacement of the facility that it would be relinquishing - a feat that would be all but impossible without State House influence. What the state hasn't yet revealed is that it plans to sell the Allston land to Harvard University for but a fraction of its true value. The back room deal has already been made and the taxpayers will pay in two ways: by both subsidizing the expansion of Harvard University and by giving up valuable state transportation assets. Why is it that the Allston Yard is not being considered for MBTA usage - a passenger car yard or engine terminal, for instance? Unfortunately, as Mr. Kyper has already pointed out, the Massachusetts transportation system - particularly the eastbound portion of the Mass turnpike from Worcester to Boston - will suffer from a substantial increase in truck traffic, especially at a time when the road is already at full capacity four to six hours per day. This land giveaway must be stopped and the public must be fully informed before any movement of this railroad facility is begun.