Over the last three years, TRRAAC's proposed alternate plans were considered and rejected during the project's engineering design phase by our engineering firm, Gannett Fleming. Each of the sites were dismissed because of major flaws which prevented project goals for increased capacity and improved operational efficiencies from being met, as well as, having conflicts with safety and best practises for railroad yard operations.
In mid-May, TRRAAC was informed that their alternative site plans would be reviewed by Gannett Fleming. On Monday, June 16, I and Rich Cross, Gannett Fleming, met with Sarah Young Fisher, Dan Gillis and Bob Hannum, TRRAAC leadership, and Bob Desmarias, Jr, Lancaster Township Planning Commission Member and President of School Lane Hills Neighborhood Association, for approximately two hours to share Gannett Fleming's review of their alternative site plans.
I believe that the individuals left the meeting acknowledging their alternative sites had major obstacles for implementation.
June 12, 2008
Review by consultants Gannett Fleming of TRAAC's proposed alternative. (download PDF)
Listed below are responses to TRRAAC’s “12 Reasons” statement in support of its proposed Alternative #1 and #2 locations.
TRAACC Reason 1: “First and Foremost, the alternative location will accomplish all of the Principal’s Goals and Objectives, except for 1 lacrosse field, which can be easily relocated in the remaining green space.”
Answer: Alternative #1 and #2 do not meet the Project Partners’ goals and objectives. The Alternatives fail to meet two of the Project’s primary goals because TRRAAC’s scenario has Norfolk Southern continuing to operate a less efficient yard with less capacity than the design proposed by the Project Partners. Please see Rich Cross’ review letter on this website.
TRRAAC Reason 2: “Secondly, the alternative location will keep 12 additional acres of taxable property on the city tax roles.”
Answer: While it is unclear exactly what acreage TRRAAC is referring to in this statement, the College and Lancaster General pay property taxes and make payment in lieu of taxes. This practice will continue with regard to the acreage transferred to the College and Lancaster General from Norfolk Southern. Consequently, no property will be removed from the tax rolls (or excluded from payment in lieu of taxes) as a result of this transaction.
TRRAAC Reason 3: “Thirdly, tax monies will be saved by reducing by 1/3 the amount of acreage that will need to be remediated due to 100+ years of railroad usage.”
Answer: This statement equates remediation costs directly to acreage. This is an unfounded conclusion that is unable to be supported without a comprehensive environmental characterization of the current rail yard. Such analysis does not exist so there is no factual basis for this conclusion. Furthermore, the public funds that will be used (together with significant private equity from the Project Partners) are grants from existing programs that are designed specifically for this type of initiative involving railroads, environmental remediation and economic development.
TRRAAC Reason #4: “Fourth, the alternative location will allow for more time and thoughtful consideration to be given to the remediation of the old Municipal Dump. How will the dust created by removing many cubic yards of soil potentially contaminated with asbestos be controlled? How and who will be responsible for cleanup and monitoring outside of the work site for dust that settles throughout the neighborhoods. What potential health risks will be involved? This remediation can not just be rushed thru.”
Answer: No one intends to “rush thru” any remediation plan for this site. The remediation plan of the former municipal dump will be submitted to the Pennsylvania Department of Environmental Protection (DEP) for their Act 2 Program along with the comprehensive characterization of the site. DEP will review and amend the proposed plan if needed to ensure that the site is remediated according to DEP regulations using best practices, which assures for the safe removal of non-media substances.
Our environmental characterization produced only two samples of waste materials that contained a small proportion of asbestos in a non-friable, organically-bound (NOB) form. During the initial stages of waste removal activities, air monitoring will be performed to assess the presence of friable asbestos. If any friable asbestos would be found during the removal of the non-media solids from the site, all appropriate procedures (each of which will be contained in our site specific Health and Safety Plan) must be immediately implemented. There are approved methods of dealing with the removal of friable asbestos, and to the extent that such action is needed, the removal process would be governed by the appropriate methods and regulations.
TRRAAC Reason #5: “Fifth, Norfolk Southern saves the unnecessary expense of having to build a private access bridge over the Harrisburg Pike in order to access the disconnected piece of the rail yard. This also saves the public the inconvenience caused by this unnecessary construction on the busy Harrisburg Pike.”
Answer: Since TRRAAC’s Alternative Site #1 and #2 are not workable for reasons outlined in Rich Cross’ review letter, the matter of eliminating the bridge is a moot point. However, if Alternative Site #1 and #2 were feasible a bridge would still be required to address Norfolk Southern’s need to access the western portion of its right of way. Without a new vehicular bridge, Norfolk Southern must still have its personnel vehicles drive to the Farmingdale crossing to access their trains west of the Dillerville Yard.
TRRAAC Reason #6: “Sixth, the alternative location will give Norfolk Southern the ability to stage one long train of empty cars for the return to Enola on the “fly” rather than waste the extra fuel and create the extra diesel emissions to build the empty train at time of departure from multiple smaller segments.”
Answer: This statement is very unclear in what it is attempting to convey. It does not take into consideration the manner in which rail yards function nor does it account for Norfolk Southern’s daily operations in the Dillerville Yard.
TRRAAC Reason #7: “Seventh, the alternative location does not move yard engine activities to the stretch of track that runs immediately behind and within 50 feet of homes bordering the tracks in the Barrcrest and Gentry Heights neighborhoods. This activity will be necessary to efficiently service the proposed site and to build the “empty” train from the western end of the proposed site.”
Answer: This statement inaccurately describes the proposed yard as being within 50 feet of the Barrcrest and Gentry Heights neighborhoods, and it does not take into account how Norfolk Southern will use the new yard to build outbound trains.
TRRAAC Reason #8: “Eighth, the alternative location does not add to the current blockages of Farmingdale and Good roads while the “empty” trains are being built. Additionally, a long train of 1 mile plus will cause blockage on Rohrerstown Road if the train is built from multiple segments working from the western end of the proposed location.”
Answer: This statement does not take into consideration how rail yards function generally, nor does it accurately consider Norfolk Southern’s daily operations in the Dillerville Yard. Norfolk Southern has stated that the Farmingdale Road crossing will not be blocked as frequently as it is now given the additional space in the new and remodeled yards.
TRRAAC Reason #9: “Ninth, the alternative location remains in a more suitable, long-standing industrial area. The proposed location will move industrial noise within close proximity and line of sight Long’s Park’s Summer Concert Series, there by diminishing one of the finest and free cultural activities in the Lancaster County area. Additionally, the proposed site will be directly adjacent to the proposed Crossing at Conestoga shopping center, which is being billed as a unique, upscale, outdoor, city-like atmosphere to draw people to the area from outside regions. It is not hard to image that the proposed rail yard will have a detrimental effect on the success of this proposed up-scale center.”
Answer: The proposed Dillerville Yard consolidation keeps the largest portion of the existing yard in its current location. The proposed site is about the same distance to Long’s Park as the existing Dillerville Yard and will generally be unseen from the Park given the existing level of vegetation and assuming the Crossings Project will be built. Also, the new portion of the Yard will be built on land currently zoned as industrial. In fact, the 50-acre parcel across from the proposed site and adjacent to the Old School Lane Hills and Barrcrest neighborhoods is also zoned industrial.
In addition, High Real Estate has expressed its support of the Dillerville Rail Consolidation Project based upon the many benefits it brings to the region.
TRRAAC Reason #10: “Tenth, the alternative location will remain being serviced by a full-time, professional fire department, with prior experience dealing with HazMat events on the current rail yard. In the proposed location, these responsibilities will be shifted to capable, but burdened, volunteer fire companies.”
Answer: The Lancaster City Fire Department, a full time and paid department, has been designated as Incident Command for emergency events in the Dillerville Yard by the Lancaster County HazMat Team, and that status is most likely to continue in the future. The municipal fire departments and county emergency professionals practice responding to situations involving multiple emergency responders to ensure the most highly trained and capable team is in control of any situation. In addition, Norfolk Southern will update its existing emergency plans that are on file with municipal emergency responders prior to opening the proposed yard.
TRRAAC Reason #11: “Eleventh, the alternative location keeps Rt.30 farther, and thus less likely, to be shut down in the face of a larger HazMat issue or fire than has been previously experienced in the current yard to date. Small scale accidents have been happening. No one can say that a larger incident is not possible. The proposed location has the Rt. 30/Harrisburg Pike interchange within a 1/2 mile impact radius and a much larger stretch of Rt. 30 in a 1 mile impact radius. The traffic chaos that would be created on either side of a larger-scale incident in the proposed yard would unnecessarily create additional dangers in the event of an emergency.”
Answer: This statement inaccurately portrays basic emergency management procedures. In the unlikely case of a large emergency event in either portion of the Dillerville Yard, neighbors would mostly likely be instructed to remain indoors and not evacuate. Traffic impacts to local and area road networks are not going to be impacted by this project. In addition, prevailing winds are away from the neighborhoods and the Dillerville Yard. It is also worth noting that Norfolk Southern has stated that this project will not cause the amount of hazardous materials to be shipped through the Dillervile Yard to increase.
TRRAAC #12: “And Lastly, the alternative location, while achieving all of the Principal’s Goals and Objectives, does not place long-standing, pleasant, tax-generating, residential neighborhoods in danger of decay. To endanger these neighborhoods does not enhance the project in any way. It is an unnecessary loss of wealth for the area as property values fall due to the change in character of the neighborhoods.”
Answer: The environmental studies of noise, vibration, air quality and health risk show no impact to the Old School Lane Hills and Barrcrest neighborhoods. Real estate professionals who have reviewed the Project make it clear that there are two primary factors that impact property values; zoning and owner maintenance. In this instance, the proposed rail yard will be located on land already zoned for industrial use and across the tracks from a large parcel (Brickyard) that is also already zoned industrial. The consolidation of the Dillerville Yard will occur on land that is zoned for precisely these types of activities, and has been for decades. The neighborhoods have developed over the last 90 years near or adjacent to an operating rail yard and track.
Please see below and our Third-Party Review page for more correspondence involving The Rail Road Action & Advisory Committee.
October 23, 2008
Alan Rosenbloom to John Fry (download PDF)
October 30, 2008
Orris responds to Rosenbloom (download PDF)
October 20, 2008
William J. Cluck to Keith Orris (download PDF)
October 29, 2008
Orris responds to Cluck (download PDF)
July 9, 2008
Gary Brown, RT Environmental Services, to Keith Orris (download PDF)
July 28, 2008
Keith Orris responds to Gary Brown (download PDF)
June 18, 2008
Orris responds to East Hempfield Township Manager Robert Krimmel (download PDF)