Tuesday, December 21, 2010

Comments on relocation of Allston Freight Yards

A very major part of the environmental destruction on the Charles River is Harvard’s purchase of the Mass. Pike (I90), the Mass. Pike exit facility, and the Beacon Park Railroad Yards in Allston.

That is right, Harvard owns a key part of the Mass. Pike. They purchased it from the state a few months after the MBTA’s study proved that the Grand Junction railroad through the nesting area of the Charles River White Geese, and its bridge across the Charles River could be used as an exit from the Mass. Pike.

An incredible amount of the destruction pending or accomplished can be explained as part of this project.

Harvard’s other maneuvers lead to the conclusion that Harvard plans to move Harvard Medical School to this Allston freight yard / Mass. Pike exit ramps location. All they have to do is empty it.

Part of the emptying is moving the freight yards. The plan for the freight yards is to move them to Worcester, MA.

Marilyn Wellons has commented on the Environmental Notification Statement on this matter, and provided us her comments, which are printed below.

I have reviewed the most recent issue of The Environmental Monitor at http://www.env.state.ma.us/mepa/emonitor.aspx. I do not see this listed, so I assume the deadline is past.

Apologies to Marilyn. There was definite confusion in the receipt of this report.

December 13, 2010

Secretary Ian A. Bowles
Executive Office of Energy and Environmental Affairs
Attn: MEPA Office [Aisling Eglington], EEA No. 14673
100 Cambridge Street, Suite 900
Boston, MA 02114
Aisling Eglington aisling.eglington@state.ma.us

Re: ENF No. 14673, CSX Worcester Expansion Project

Dear Secretary Bowles:

The ENF before you is narrowly focused. Its premise is that the Beacon Park Terminal (BPT) be closed and that its multimodal transportation functions move to Worcester.

The closing of BPT however is not a fait accompli. It is, according to the Memo of Understanding (MOU) between CSX and the Commonwealth, contingent on, among other things, determination of the environmental consequences of that closing and the expansion of the Worcester Terminal. Because it is so narrowly focused it cannot make the case for the asserted advantage to the region compared to retaining and modernizing BPT.

Specifically, and to cite only one aspect, Proponent’s reasoning at, Regional Emission Reductions—that the replacement of old equipment at Worcester and reduction of emissions, combined with the elimination of emissions from old equipment at a closed BPT is a straightforward benefit—is inadequate. The asserted advantage here misses the advantage to the region of the alternative, i.e., replacing old equipment at Beacon Park Yards and retaining its advantage for rail freight in the urban core.

There is a more significant problem. Throughout the public process involved with this proposed major change in transportation for the Boston MPO, EOT has failed to answer questions repeatedly raised about its effect on air quality in the region. At the March 25, 2010 public meeting on the state’s Freight Study, EOT stated in response to this specific question that there were no actual figures available to the public for air quality assessment, only a “guess” that it would improve—as the ENF now argues. EOT also confirmed that the actual numbers would not be forthcoming (Steve Olanoff question, Ned Codd response).

The ENF widens its scope from Worcester itself to assert regional benefits from the closure of BPT. It does not however advance regional data to support the claim that this is a greater benefit than the alternative it fails to discuss. Indeed, the ENF claims only a “general evaluation” rather than the detailed analysis required for, at minimum, greater credibility if not validity. If the percentage of “goods currently delivered to the Beacon Park Terminal via rail are ultimately delivered to points West of Boston by truck” are “significant,” the ENF should provide that percentage and supporting data. The ENF omits them (p. 5-17).

Given that the Allston Landing Multimodal Transportation Study, a prior work, addresses this and other issues of the proposed move, the continuing gaps in data and analysis are remarkable. The RFR for the Allston Study, posted by the Executive Office of Transportation and Construction (EOTC) on 26 January, 2004, was awarded to HNTB. It was to consider “landside freight rail access to the Port of Boston, a commuter rail station, Urban Ring service, and the reconfiguration of the Massachusetts Turnpike. . . . [and] rail freight service as now conducted at Allston Landing South and connections to the local street system.” Consideration of these issues in a modernized BPT, as well as of the consequences of moving CSX’s multimodal operations to Worcester, are the proper scope for MEPA review now.

In commissioning the Allston study, EOTC affirmed the importance of “ensuring that a solid freight network [continue] to serve the port [of Boston], the City of Boston, and the New England region. To that end, EOT will be conducting a study to explore ways to assure a strong port-to-rail connection, at Allston Landing” (EOT long-term plan, quoted in Atlantic Northeast Rails & Ports, 05#03A, 18 March 2005, p.10).

The Commonwealth failed to allow completion of this comprehensive study and release of its draft. Its scope and preliminary findings would seem to bear directly on questions the ENF before you avoids asking. I urge you to require the full EIR the project actually demands for compliance with Federal law.

The ENF alludes to “future expansion” of the Worcester Terminal (5.0) and to an ultimate projection of not 150,000 container lifts per year but up to 200,000 (5.9.3), presumably the result of the undescribed future expansion. It is not clear whether the traffic analysis reflects both the full expansion with these additional lifts and the state’s assumed 70% increase in truck freight by 2030.

The discussion of wildlife habitat at 5.2.1 is admitted to be incomplete. The ENF does not, unfortunately, require the noting of urban wilds that give harborage to valuable species, e.g., skunks, raccoons, and possums, all natural predators of rats, or of their value to migrating songbirds. The projected destruction of trees and the urban wild around the scrap yard would be a major loss and should not be ignored.

A proper EIR may confirm the advantages of expanding Worcester and closing BPT as the ENF asserts. The ENF before you cannot and does not do so. I therefore also urge you to issue a Certificate requiring a full Environmental Impact Review that analyzes the true scope of the alternative to expansion of the Worcester Terminal.

Yours sincerely,

Marilyn Wellons