The Dillerville Rail Yard was constructed more than 100 years ago, built by railroads that no longer even exist. Entering from northwest Lancaster and passing over Harrisburg Avenue the rail line cut a swath through the City and suburban neighborhoods that grew up around it-a divider that continues to define the area today. In 1999 Norfolk Southern began operating these rail facilities as a result of the Conrail acquisition.
Several years ago, Norfolk Southern (NS) sold a portion of the yard for the construction of Clipper Stadium. Over a year later, the railroad's senior management announced plans to expand the Dillerville Rail Yard because of increased customer demand in the Lancaster market. As a result of this announcement, Franklin & Marshall College engaged senior NS management in discussions about relocating a portion of the railroad's operations in exchange for the remaining section of the eastern Yard-a concept that would effectively allow NS to consolidate the Yard's operations at the current site while simultaneously providing a chance to unify the campus and re-connect a portion of the city. NS agreed to investigate the College's concept because it provided the railroad with greater capacity to serve its local customers.
In 2005, Lancaster General joined with the College in studying the concept as a possible joint venture. Gannett Fleming, a nationally recognized engineering firm with a specialty in railroad planning and engineering operations, was retained to conduct the study. As part of its work Gannett Fleming also conducted a review of property along the rail line between Lancaster and Columbia to find any additional available sites that would accommodate the railroad's needs. In November 2006 the College and Lancaster General announced an effort to finalize feasibility and design studies for relocating a portion of the Rail Yard to a site behind the United States Post Office on Harrisburg Avenue, on the site of a former municipal dump. This relocation effectively allows NS to consolidate its Dillerville operations because it is adjacent to the main switching area east of the Harrisburg Avenue overpass.
The size of the proposed yard consolidation is approximately 12 acres. When combined with the existing NS tracks and right of way adjacent to the site, the new facility will be about half the size of the current rail yard section located between the Harrisburg Avenue overpass and Dillerville Road, where most of the switching of rail cars occurs today. In early 2007, Gannett Fleming began a final study of technical issues related to the site, started to identify solutions to these issues and began working on design concepts for the construction of the project.
At the same time, the three principals--NS, Franklin & Marshall College and Lancaster General--began the effort to inform local leaders and residents about the plan. In 2007, they held meetings in the neighborhoods near the proposed rail yard consolidation to disseminate preliminary information about the project. Two of the meetings were small gatherings in homes located in the Old School Lane Hills neighborhood and a third, larger gathering was held in the Barrcrest neighborhood. Local residents expressed their desire for more details about the project, and they were informed that the information they sought would be available after the engineering firm, Gannett Fleming, completed more of its analysis and design work. While the parties continued to respond directly to all questions or issues raised by local elected officials and neighbors, additional public meetings were delayed until the Gannett Fleming work was substantially completed.
Now, as the analysis and design work nears completion, the College, Lancaster General, and Norfolk Southern are prepared to present a more detailed review of the project to our neighbors in the surrounding communities of Lancaster City and Manheim, Lancaster and East Hempfield Townships. In February, the project team met with officials from these four municipalities, together with two residents from each community. From the input and advice we received at this meeting, we decided to expand the sound, vibration and air quality analysis for the project. The expanded scope required us to postpone the date of the large neighborhood meeting we had planned at the outset of the project. This meeting had been tentatively scheduled for April and will now take place in mid June. In the absence of the results of these tests, a comprehensive project presentation would not be responsive to the issues raised by these community leaders, and that is the sole reason for re-scheduling the presentation for June.
That said, we are sensitive to the public concerns and questions that have been raised about the project, and we recognize that our neighbors have the right to learn as much as possible about it. We are committed to meeting that obligation, and to that end we have prepared a list of Frequently Asked Questions, categorized in the links to the right, together with answers that reflect the most current factual information we possess.
We also want to do more to keep our neighbors informed. For this reason, we are also in the process of scheduling a series of small meetings in nearby neighborhoods, so that we can further engage residents in productive dialogue about the project.
Scope of Work & Norfolk Southern Operations
What is the scope of the project?
The Dillerville Yard project consists of three phases. First NS will acquire the site of the former municipal dump, which is adjacent to the eastern end of the current Yard at Harrisburg Avenue rail overpass. It does not relocate the entire yard but rather extends the existing facility a short distance to the west. (Please see the enclosed project map for reference.) The waste will be removed from the site, clean fill imported and new rails and ties installed along with some small structures to support maintenance activities.
Next, the portion of the Dillerville Yard located in the City of Lancaster (between the Harrisburg Avenue overpass and Dillerville Road) and situated behind the businesses along Harrisburg Avenue (Lancaster County Solid Waste Authority and Burnham) will be reconstructed. This is the section of the yard where most of the rail car switching occurs and will continue to occur in the future. The tracks will be temporarily removed and the yard regraded. Tracks will then be replaced in a straighter configuration and several new structures, such as a railroad office and trestle, will be constructed.
The final phase involves the installation of a private vehicular bridge adjacent to the railroad bridges across Harrisburg Avenue, which will be used by Norfolk Southern company vehicles accessing the yard.
The new design is referred to as a "bookend rail facility" with two yards connected by several tracks. It is important to note, however, that the project effectively shifts only the western boundary of the existing Dillerville Yard. This consolidation of the Yard permits more efficient and safer switching operations, while also offering the chance to re-connect the fabric of the City for the first time in more than a century.
How is the re-connection achieved?
When these improvements are complete, the section of the Dillerville Yard property east of Dillerville Road extending to Harrisburg Avenue will be transferred to Franklin & Marshall College and Lancaster General. The College proposes to consolidate its athletic fields at this location, known as the North Campus; and the Lancaster General has plans to construct buildings housing medical programs in need of expansion. As part of this development, we anticipate the re-connection of Liberty Street and College Avenue. In our view, the plans present an exciting opportunity to consolidate the campus, expand the region's leading health care facility, re-connect portions of the City currently divided by the railroad yard, and effectively remake a landscape that now features a rail yard office, a trestle for off-loading bulk materials, engine repairs and several tail tracks used to switch cars.
Where will the new Yard be located?
The new Yard will be located on the land formerly used as a municipal dump. It is situated north of the existing NS tracks behind the United States Post Office and east of the Little Conestoga Creek. Two parcels will be combined: one is approximately 11 acres and owned by the Lancaster County Solid Waste Management Authority and the other is about an acre in size and owned by the U.S. Postal Service. Norfolk Southern will own both parcels.
How will this project change rail operations in the area?
The project will enable NS to serve its Lancaster County customers' growing needs for rail shipments by creating space for approximately 230 additional rail cars at the Dillerville Yard facility. It is critically important to note, however, that the design permits more efficient and flexible rail car switching and storage operations. For this reason, while rail car capacity will increase the improved operational efficiencies from the new track layout will not increase the number of locomotives, trains or crews at the site as a result of the yard consolidation project. In other words, the new site allows more rail cars to be added to existing trains.
Why is this important?
If the number of locomotive engines does not increase, there is far less likelihood of increased diesel emissions or other environmental concerns at the site.
The expanded portion of the rail facility behind the Post Office will be used to store rail cars that have been retrieved from rail customers' facilities. The cars will sit in the yard for approximately 24-48 hours before they are connected to form a train that returns to the Harrisburg Enola Rail Yard, a process that already occurs today on a daily basis. The new Yard simply provides a way to conduct these operations more efficiently.
What is the Dillerville Rail Yard used for?
The existing train tracks and yard have been in use for more than 100 years as Lancaster City and the suburbs expanded around it. The Yard exists to serve customers in Lancaster and western Chester counties. One daily train from the Enola Yard is received and broken into eight local trains to be delivered to customers' facilities. A train of empty cars is returned to Enola each evening.
The Yard is well situated because of its geographical location near the center of the Lancaster market. It also sits close to the Amtrak line, which NS is permitted to cross at only specific intervals each day.
The Yard contains a raised trestle for unloading bulk materials into customers' trucks. Less than three percent of Norfolk Southern's business is conducted from the trestle and is not predicted to grow substantially as a result of this project.
Is there another site for this yard?
To pursue another location, a parcel of land about 60 acres in size would have to be purchased and developed to relocate the entire Dillerville operation. Gannett Fleming reviewed various parcels between the Dillerville Yard and Columbia and found only one site large enough to potentially accommodate NS operations. This property is slated for residential housing and is therefore unavailable. From an operations and customer service perspective, the Dillerville Yard is far more convenient given its central Lancaster County location.
Additionally, NS has never been interested in, nor pursued an expansion of its Columbia facility because there is insufficient room and the location is not ideal.
What are the environmental benefits of this project?
First, the site, a former municipal dump last used in 1962, will be completely cleaned up. The first phase of the project involves actually removing the waste from the site and properly disposing of it at Lancaster County's Frey Farm Landfill. Afterward, clean earth fill will be deposited and compacted to raise the grade to match the existing rail line. Though the removal of the old waste material adds several million dollars to the cost of the project, it is unquestionably the most responsible approach to cleaning up the site.
Second, based upon NS's current and projected customer activity, the additional rail capacity created by this project will divert approximately 55,000 trucks annually from Central Pennsylvania highways and roads. Put simply, fewer trucks means cleaner air for area residents and reduced highway maintenance costs for taxpayers. These benefits support the goal of reducing traffic on the region's overcrowded highway system and improving air quality conditions.
Third, moving freight by rail is a "greener" method than shipping by truck. A recent Wall Street Journal story noted: "Railroads say a load can be moved by rail using about a third as much fuel as it takes to haul it by truck. Railroads have friends among environmentalists, who see moving freight by train rather than truck as a way to reduce fuel burning and emissions. States have also started to climb aboard. In a 2002 report, the American Association of State Highway and Transportation Officials said transportation capacity could be increased more cheaply in some intercity corridors by adding railways rather than expanding highways."
Finally, NS predicts that because of the additional storage capacity that the new yard will create, the Farmingdale Road and Good Drive rail crossings will be closed for shorter periods of time. Currently, trains are sometimes switched on the main tracks, which, requires the closing of the crossings. By providing more yard capacity to store train cars, switching on these main tracks will be eliminated and the crossings will be closed for shorter periods of time. This means fewer traffic backups at these crossings and shorter delays when crossings are closed.
What environmental studies have been and will be conducted?
The environmental characterization of the former dump has been completed and its footprint determined. The Pennsylvania Department of Environmental Protection (DEP) must approve the waste removal plan before any work can begin, and afterward the DEP must certify that the clean up was completed properly.
The project will follow the federal National Environmental Policy Act (NEPA) because of the potential use of federal funds to complete the project. In November 2007, a scoping field-view was completed by representatives from the Pennsylvania Department of Transportation (PennDot) and the federal Department of Transportation. These officials reviewed the study area, discussed the proposed project and confirmed the level of NEPA documentation required. Studies will be conducted to characterize wetlands, streams, floodplains, threatened and endangered species, farmlands, historic structures, archaeological resources, hazardous or residual wastes, impacts to local businesses, and other concerns. The process has been started and the results will be submitted to PennDot for review.
At the beginning of the project, the College and Lancaster General committed to evaluating/assessing air quality, sound and vibration impacts. The scope has been expanded in response to questions raised by local officials and residents at our meeting in February. The College and Lancaster General will confirm that this project does not create an unacceptable health concern for the area before any work begins.
Initial air quality, sound and vibration studies also are underway and will be completed in May. The air quality model uses a standard methodology incorporating national standards for activities creating emissions, then comparing them with existing conditions and modeling their impact. In other words, the precise activity being introduced into an area is modeled to see whether it affects the existing environmental conditions. The results are then compared with federal and state air quality standards for risk assessment.
The sound and vibration studies will use standard methodologies that will be conducted in a comprehensive format with expanded areas of assessment not typically performed in such projects. Instruments will be used to capture existing conditions. Future sound and vibration levels will then be predicted using Federal Highway Administration (FHWA) and Federal Transit Administration (FTA) models. This data is combined to determine projected impact and compare it with national standards.
How will this project affect air quality?
First, NS will not be adding any additional locomotives as a result of this project. Thus there will be no new source of diesel emissions. Second, the current yard is so small that NS must move its rail cars three or four times to get them into the correct position for shipping. With the new yard this inefficiency will be eliminated because cars will have to be moved only once or twice during the process. Improving the efficiency of the operation should reduce air emissions from their current levels. Also, NS locomotives are equipped with technologies that reduce idling when not in use. Finally, the federal Environmental Protection Agency (EPA) recently finalized a three-part program that will dramatically reduce emissions from diesel locomotives of all types-including line-haul, switch and passenger rail locomotives. The rule will cut particulate matter emissions from these engines by as much as 90 percent and nitrogen oxide emissions by as much as 80 percent when fully implemented.
Because the number of locomotives will not increase and the locomotives already operate in the area, we anticipate no significant negative effect on air quality. Air quality modeling for existing and future rail yard locations is being performed to confirm this finding.
What are the College and Lancaster General doing to mitigate project impacts?
Both institutions are committed to mitigating noise created by the project through the installation of sound walls and/or landscaping buffers along the tracks. Even if not required by PennDot, these buffers will help protect nearby neighborhoods. Our engineers will use the results of the sound studies to recommend the most effective mitigation efforts.
What about the environmental claims made by opponents of the project?
- Health Risks
Some project opponents cite an EPA air quality study conducted in California and publicized in a 2007 National Public Radio story. A main subject of this study and story was a large facility near the Port of Los Angeles where trains, tractor trailers and container ships are located to form one of the largest (if not the largest) intermodal facilities of its kind in the world to distribute raw materials and finished products across the nation. The Los Angeles rail facility is approximately 900 acres in size and handles an estimated 100 trains a day. By comparison, the Dillerville Yard is not an intermodal facility. It is approximately 50 acres in total size and handles 10 trains per day. By any reasonable standard, it simply is misleading to compare the impact of the Los Angeles facility with the new Dillerville Yard consolidation.
NS has said that despite the additional rail cars that can be handled by consolidating the Dillerville facility, no additional locomotives, trains or crews will be added as a result of this project. Therefore, we do not anticipate a significant overall increase in emissions, or risk of cancer.
Like all internal combustion engines, diesel engines produce emissions with particulates that decrease the quality of air in any given area. Gannett Fleming's environmental study will incorporate a conservative human health risk assessment (HHRA). Since Pennsylvania does not have existing regulatory guidance/risk assessment standards for rail yard air quality parameters, the California Environmental Protection Agency (CAEPA) risk assessment guidelines will be utilized as a reference guide for this risk assessment. However, the California baseline approach cannot be used because Pennsylvania does not have baseline data equivalent to the California Air Resources Board (CARB).
- Light from the New Yard
NS's rail yard activity in Lancaster involves the daily arrival and departure of one train from Enola, limited local train traffic, and the coupling and decoupling of rail cars for market sorting. These activities occur at very regular intervals, and the yard is actually without rail activity for long periods of time each day. Given the hours of yard activity NS anticipates that, high intensity lighting will not be required during evening hours. Streetlight poles with standard "cobra head" lamps will be installed at switch locations and along the service drive from Harrisburg Avenue and adjacent to buildings in the new Yard for the safety of the NS employees. The impact from these streetlights will be minimal.
- Pollution from the New Rail Yard
This project is remediating a former municipal dump by removing waste material that has been present for more than half a century. As a result, construction of the new Yard will effectively eliminate this potential pollution source. The new Yard will be designed to collect storm water and prevent it from permeating the groundwater, thereby preventing remaining ground water contaminants from being quickly flushed from the site.
In addition, NS operations at the Dillerville Yard do not and will not create the pollution that some opponents claim. For example, diesel fuel is delivered by trucks and transferred directly into its locomotives; diesel full is not stored in tanks and piping systems on site. In addition, NS does not operate electrified locomotives that are associated with the common contaminant, PCBs. Finally, rail yard operations today are much cleaner than earlier generations because of stricter environmental regulations and operational best practices.
- Rail Safety and Hazardous Waste Shipments
NS is proud of its network-wide safety record and in particular the Dillerville Yard's safety performance. Personnel are vigilant about monitoring activity on their property and removing trespassers. For the past 18 years (1989-2006) Norfolk Southern has been awarded the E.H. Harriman Gold Award for Outstanding Safety Achievement in the U.S. rail industry. Norfolk Southern's Harrisburg Division, which includes operations in Lancaster, typically has been among the safest of the 11 divisions in the 22-state NS system.
By federal law NS must handle customer orders for all types of materials, including hazardous substances. To be clear, these types of materials are handled now on existing tracks in and out of the Dillerville Yard. In accordance with NS policy, rail cars with hazardous materials are not permitted to sit in a yard for longer than 48 hours before being delivered to customers. Moreover, the quantity of this type of material handled by NS over the past 25 years has declined significantly to the point where it is less than one percent of total shipments handled in the Yard. Indeed, hazardous materials account for less than three percent of shipments system-wide.
The hazardous materials of greatest concern are called "toxic inhalation hazards" (TIH). NS transports approximately 15 to 20 TIH car-loads per year (chlorine for treatment of a local water supply) and the amount is not predicted to increase as a result of this project.
In the unlikely event of a hazardous material release, NS personnel are trained to contact and assist local HAZMAT professionals in emergency response protocols.
- Decreased Property Values & Diminished Quality of Life
The College and Lancaster General believe that property values will not be affected because rail operations exist today adjacent to the neighborhoods and will not be greatly increased. The College also holds a vested interest in minimizing any negative effects of this project. Many of its faculty members and staff live in this neighborhood. Also the College's Baker Campus/Brickyard property is located between the neighborhood and the new rail yard.
Project Goals, Partners, Budget & Timeframe
What are the benefits of this project?
The project will enable Norfolk Southern to increase rail shipments to its customers in Lancaster and western Chester counties. Rail shipments are generally considered the most cost effective and efficient means of transporting materials providing for a stronger local economy.
By increasing rail shipments of materials, truck traffic is eliminated from the regional highway system, thus improving air quality and reducing road maintenance costs to taxpayers.
The project will improve traffic flow in northwest Lancaster City by connecting Liberty Street and College Avenue, and possibly two other streets with Harrisburg Avenue. The resulting traffic mitigation on the Harrisburg Avenue and Prince Street corridors will improve quality of life for residents of the area while fostering more responsible economic development in the northwest section of Lancaster.
The former rail yard will provide a footprint for responsible growth for the College and Lancaster General, one that includes the siting of the College's athletic fields. More jobs and tax revenues will result from the expansion of the Hospital on Harrisburg Avenue.
Finally, the project will remove an abandoned dump closed in 1962 by excavating the trash and properly disposing of the material at the Waste Authority's Frey Landfill.
Who is undertaking this project?
Norfolk Southern has named Franklin & Marshall College as its master developer for the project. The College partnered with Lancaster General to execute this initiative and will divide the land between the two institutions when the improvements are completed.
How much will this project cost and where is the funding coming from?
The entire project is expected to cost more than $40 million. Its exact cost will be known after the final engineering design documents are bid during the summer of 2008.
The College and Lancaster General are each investing $6 million and Norfolk Southern has pledged $2 million toward the project. The remaining funds will be secured from a variety of state and federal grant programs.
What is the project's time frame?
The engineering design will be completed in late spring and bid during the summer of 2008. The environmental filings will be completed and submitted by late spring with final sign off expected in the summer.
When funding is in place, the removal of trash and importation of fill will be the first work started and this work is expected to take about six months to complete.
The Dillerville Yard consolidation and the new bridge would follow and should take about two years to complete. The College and the Hospital would then remediate the existing rail yard property being vacated by NS and install infrastructure during the following year.
Approvals & Public Comment
What is the approval process for the project?
The current zoning for the site is industrial, permitting a utility such as a rail yard. Gannett Fleming is designing this project to meet local municipal land development ordinances. Our nation's railroads have been granted authority to operate independently of most local and state governmental regulations including zoning and land development. However, the project's plans will be submitted to Manheim Township and City of Lancaster planning staff for comment.
When is the opportunity for public comment?
Six neighborhood meetings and one focus group have been held since early 2007 to present project concepts. Several more meetings are planned during the spring of 2008. A larger neighborhood meeting will be held in mid June at the Alumni Sports & Fitness Center. A comprehensive briefing including the results of the air quality, sound and vibration testing will be presented.
Public input will not be limited to these meetings. Feedback will continue to be considered after construction has started. The June neighborhood presentation will not preclude future opportunities for comments from neighbors. Constructive suggestions that improve the project and can be reasonably incorporated after the work has begun will be considered.
Below is an explanation of the project's benefit to divert 55,000 truck trips to rail delivery.
One of the many benefits to the Norfolk Southern Dillerville Yard Consolidation Project is the number of tractor trailer trips it will remove from Central and South Central Pennsylvania roadways, which in turn decreases air pollution and reduces highway maintenance costs to repair the wear and tear created from these trucks. By using a federal government formula and customer information supplied by Norfolk Southern, the projected “truck diversions” are 55,000 annual trips. Truck diversions are an acceptable and recognizable means used by government and industry to evaluate the impact of a transportation project.
This truck diversion number was calculated by Gannett Fleming using information supplied by Norfolk Southern for their customers that have asked for expanded rail deliveries, which Norfolk Southern has been unable to provide because of the lack of space in the Dillerville Yard, coupled with Norfolk Southern’s expected growth of the overall Lancaster market. This information was inserted into a federal government air quality formula that resulted in the 55,000 truck diversion number. This number is a ”real estimate” based upon existing customer requests and projected demand based upon historical growth rates.
Truck diversions represent the shipment of goods that will shift from tractor trailers to rail with the completion of this project. Rail delivery is generally considered to be a more efficient and environmentally friendly method of moving goods.
Several points to keep in mind when considering this truck diversion number are:
- the diversion number accounts only for existing Norfolk Southern customers that have rail sidings to their facilities in the Lancaster market.
- the diversion number does not involve any intermodal activities. (Intermodal activities combine transportation methods to complete the delivery of goods such as moving materials from a ship to rail to truck before reaching the customer.)
- The Dillerville Yard is not an intermodal facility. The closest intermodal facility is the Rutherford Yard in Harrisburg, Pennsylvania where rail and truck modes are combined to complete the delivery of goods.
Truck diversions are a transportation industry concept and might be difficult to comprehend for some. However, it could be compared to a business concept used to decide on whether or not to introduce a new product or service. The company surveys its customers and proposes a new offering and inquires if the customers would be interested in purchasing it. From this information a business plan is constructed that is based upon expressed demand from customers as well as predicted demand using historical data about similar products or services.
Several years ago in an effort to address the overburdened Dillerville Yard, Norfolk Southern did a short-term test of offloading goods onto trucks in the Enola Rail Yard near Harrisburg and delivering them to their Lancaster customers. This experiment failed for a number of reasons and Norfolk Southern realized it needed to expand the Dillerville Yard for greater rail service or risk not being able to serve their expanding customer base in Lancaster.
The assumptions and method of calculating the truck diversion are listed below.
Determination of Truck Trip Elimination due to Dillerville Yard Capacity Improvements
Input/ Assumptions on Rail Operations:
- Dillerville Yard operates 6 days per week
- Largest Train, “Enola Cut”, comes in from Enola Yard – West of Harrisburg
- ‘Enola Cut’ has capacity to pull approx. 115 rail cars given tractive power.
- ‘Enola Cut’ presently carries approx. 60+ rail cars on average.
- Maximum increase of 55 rail cars/day possible but average of 40 rail cars/day assumed to be conservative.
- The present Yard Capacity is 303 Railcars.
- The proposed Yard Capacity is 475 Railcars, an increase of 172 Railcars.
- Federal CMAQ formula states a single railcar is assumed to have capacity of 3.5 Trucks. For our calculations, we assumed a single railcar equaled 3.0 Trucks to be conservative.
If calculations were based on additional capacity of yard, the truck trips would be as follows;
Total Truck trips reduced annually
= 172 Rail cars/day x 312 Days/year
= 53,664 Rail cars/yr. x 3.0 trucks/Rail car
= 160,992 Trucks x 2 Trips
= 321,984 Truck Trips per year
However, calculations were based on additional capacity of the “Enola Cut” Train, therefore the truck trips would be as follows;
Maximum Truck trips reduced annually
= 55 Rail cars/day x 312 Days/year
= 17,160 Rail cars/yr. x 3.0 trucks/Rail car
= 51,480 Trucks x 2 Trips
= 102,960 Truck Trips per year
Average Truck trips reduced annually
= 40 Rail cars/day x 312 Days/year
= 12,480 Rail cars/yr. x 3.0 trucks/Rail car
= 37,440 Trucks x 2 Trips
= 74,880 Truck Trips per year
Round to 75,000 Truck Trips per year*
* Of the diverted 75,000 Truck trips per year, 7,000 were credited to Phase I of the Dillerville Project in the CMAQ document justifying the funding of the initial additional capacity effort completed in 2007. Of the remaining 68,000 Truck trips per year, Franklin & Marshall College conservatively reduced the figure to 55,000 Truck trips per year for purposes of not overestimating the truck diversions possible.
The 55,000 truck diversion number is also conservatively estimated because: 1) the lower conversion factor of the number of trucks equaling the number of rail cars to haul the same amount was used, and 2) the average number of rail car increase versus the maximum for the Enola cut.