There are many reasons to have major concerns about the proposed project to rebuild the CSX Rail Virginia Avenue Tunnel: the social, economic, and health impacts of a huge construction project at the edge of a swatch of residential neighborhoods, businesses, and recreational areas. ANC6B voiced its concerns, sought remedies, and requested compensating benefits in its letter in response to the NEPA draft Environmental Impact Statement (DEIS) released last year. Many other government agencies, organizations, and individuals did the same. We await the release of a Final EIS in which the DC Department of Transportation (DDOT) and the Federal Highway Administration (FHWA) will put forward a “preferred alternative”. This could be the one of the 3 proposed build alternatives or the no-build alternative in the DEIS … or a hybrid approach.
Meanwhile, a group is working in opposition on the outside of this formal study process. In promoting a 1/16 community meeting with Mayor Gray, the group raised the following concerns: “presence of 8,000 square feet of asbestos, hazardous materials transport and risk of derailment similar to Willard Ohio and Casselton North Dakota, more than five-fold increase in permanent structural vibration to area buildings, potential for stalled development during the projected 4-6 year construction time frame, and disruptive traffic congestion and closure of area streets and highway ramps.” I respond to all but one of these claims below. But, I do not understand their mention of a five-fold increase in building vibration once the tunnel is rebuilt. The data source could be in the DEIS Appendix F: Vibration Technical Report.
The group doesn’t make it clear what their aim is in raising these and other concerns. Is it to: (1) stop the project from going forward, (2) force the adoption of one of the alternatives removed from consideration earlier in the study, or (3) what? And, if they don’t get whatever it is they want, will they file a suit against the study’s conclusions, dragging out this multi-year study process for a couple of more years? (Shades of Hine!) Meanwhile, development in a part of ANC6B–the Lower 8th–continues to languish, awaiting the final decision on the tunnel project. West of the Lower 8th, though, where most of the opposition resides, a continuing fast pace of development is predicted by the Capitol Riverfront BID Annual Report 2013.
This is not to say that those stridently opposed to the project don’t have a right to conduct a politicized campaign. It’s quite understandable as some live on the “front lines” of this project. But, I don’t have to agree with the way they are using and perpetuating misinformation about what we know about the project. The effect of this tactic was all too clear at the Mayor Gray meeting on 1/16. One woman there feared she would end up with lung disease because the tunnel may have asbestos that needs to be removed. Another was quite anxious that emergency services she needs to call on for her special needs child would be blocked from getting to her house (“everything will be blocked off!!”). Where do people get these ideas? Why has no one explained that removal of asbestos has a proscribed protocol these days to prevent impacts to both those doing the work and anyone nearby. And, what causes people to believe that the city would let CSX block emergency services during the project? I fault the opponents. Isn’t it possible to fight a good fight without whipping people up into a frenzy?
Does the DEIS say traffic will be disrupted? Yes. Does the study propose a plan to mitigate that disruption? Yes. Is it perfect? No. But, aside from 2nd Street, all north/south crossings of Virginia Avenue will remain open during construction. Will these streets be closed occasionally and for short periods of time? Yes. Will the I-695 exit ramp at 6th Street and on ramp at 8th Street be closed for the duration? No. Will each have to be closed for a short time while decking is installed at these intersections with Virginia Avenue? Yes. Does the DEIS show special lanes to be set up to provide continuing access for residences and businesses in close proximity to the construction area? Yes.
Clarity on the Proposed Alternatives
Another bit of misinformation heard repeated at the 1/16 meeting (and earlier at the Congresswoman Norton meeting in November) is that all proposed build alternatives involve train service running through an open trench during construction. Not (exactly) True. While all 3 involve open trench construction, in 1 of the 3 alternatives, trains would operate along (all but 230 feet of track) in an enclosed tunnel during construction. Estimated project duration for this alternative is 2.5 to 3.5 years. But, opponents argue against this alternative because of those 230 feet of open trench train operation. ANC6B in its letter on the DEIS did not choose among the alternatives, realizing that all 3 build alternatives involve tradeoffs. Instead, we noted the pros and cons of each alternative and asked for a hybrid. The opponents claim that an alternative during which train traffic is rerouted elsewhere in the mid-Atlantic region during construction would result in a quicker reconstruction. In a technical document, the DEIS estimates this alternative would take 2.5 years for construction but the start of the project would be delayed for months to set up all the routing agreements. The DEIS also details complexities of rerouting freight trains along specific routes and the impacts through other communities that rerouting might cause. There’s a bit of NIMBY-ism in this one, I think.
Wrapped up in the concerns about the problems of trains running through an open trench, is the issue of hazardous materials transported by CSX. This issue has long predated the discussions about rebuilding the tunnel. And, like many controversies of this nature, I doubt it will be settled by this study. Considerable hazardous materials transportation occurs in the open today in the project area. A portion of the CSX route through DC is above ground and will remain so whether or not the tunnel is reconstructed. And, trucks carry unknown quantities of hazardous materials along I-695 (parallel to Virginia Avenue) since it is the designated route for all hazardous materials road transport through DC. Nationally, by the way, trucks carried 53.9 percent of hazardous material shipments by ton in 2007 while rail carried 5.8 percent. The alarms being raised on hazardous materials are diverting attention away from other more probable problems an open trench might cause. And, I repeat: one proposed DIES alternative does not involve running trains through an open trench during construction.
It is highly unlikely that a “derailment similar to Casselton ND” could occur along Virginia Avenue since CSX does not haul single commodity tank car trains through this area like the one that caused that accident. For hazardous materials transport to be a serious problem, one should ask: Is CSX accident prone? Data from the Federal Railroad Administration (FRA) don’t appear to say so. In 2012, CSX reported 221 accidents or 10.6 percent of the total number of accidents by all freight and passenger railroads. (That’s a list of 36 railroads plus an “Other” category that had 284 accidents in 2012.) Among the 5 major U.S. freight railroads (as defined by the American Association of Railroads), CSX stacks up as third in number of accidents behind Burlington Northern Santa Fe (428) and Union Pacific (564). Norfolk Southern comes in at (191) and Kansas City Southern (37). But, counts alone are not good for comparisons. Accident numbers need to be normalized in some way to account for differences in operations. FRA converts the data into ‘accidents/1 million train miles’ for each railroad. Here’s how the 5 line up: Norfolk Southern (2.02), CSX (2.12), BNSF (2.18), Kansas City (2.99), Union Pacific (3.06). [It should be noted that railroad accident statistics can be quite complicated to work with as there are many variables and caveats. None of the data here, for instance, include accidents at highway crossings.]
Accidents Involving Hazardous Materials
Of CSX’s 216 accidents in 2012, two resulted in the release of hazardous materials from 2 cars and caused the evacuation of 106 persons. Two comparisons: Norfolk Southern had 2 hazardous materials releasing accidents in 2012; they involved 4 cars and 154 persons were evacuated. The same year, Union Pacific had 6 such accidents involving 9 cars in which 3 persons were evacuated. More data: Between 2005 and 2012, CSX has reported 8 train accidents in DC, none of which involved hazardous materials releases. CSX did have a train derailment in a rail yard near Baltimore in 2013 that involved the release of hazardous materials; 24 persons were evacuated.
One good point that arose at the Mayor’s 1/16 meeting is burdens vs. benefits. Specifically, what will the neighborhood and DC benefit from enduring the burden of the disruptions of this construction project for a number of years? It’s not like construction of the Metro that ended up providing transit service throughout the region. ANC6B and others have been advocating for a linear park with a pedestrian and bike path stretching from Garfield Park at 3rd Street along Virginia Avenue all the way to 11th Street and beyond. Included in this request is a major redesign of Virginia Avenue Park. But, is a linear park that will revitalize a lifeless space and serve all residents both north and south of the Freeway enough? Is it possible to equalize burdens and benefits? The community has already been tapping into CSX pockets for a fenced in dog area in Virginia Avenue Park, a new roof for the St. Paul AUMP Church, support for summer concerts at The Yards Park, and so on. What more could/should we ask for?
This project is so complex with any number of interrelated impacts: noise, vibration, air pollution, traffic, and even rats. It can be hard to grasp it all. And, it certainly cannot be explained in sound bites. Read through comments on the DEIS submitted by many agencies and organizations and you will find an amazing overlapping of concerns and questions. In addition, there are some unique issues being raised, given the varied expertise of commentators. All of these are excellent contributions toward making the FEIS a major improvement over the DEIS. In the end, the FEIS may improve our comfort level about this project but it will never satisfy everyone. It might help alleviate some concerns, though, if DDOT and FHWA more thoroughly explain the pros and cons of a temporary reroute option that was taken ‘off the table’ in the DEIS. And, greater protections for seniors living in the Arthur Capper apartments may need to evolve from the FEIS.
Data References (the old-fashioned way in case the links change). The “home” of Federal rail statistics is at the Federal Railroad Administration (FRA) Office of Safety Analysis. There you can make hundreds of different queries, slicing data this way and that. I found, however, that different queries for the same bit of data do not always generate the same number.
- (2012 accident data): U.S. Department of Transportation DOT), FRA, Railroad Safety Statistics, 2012 Preliminary Annual Report, October 24, 2013, Table 5-1. Available at http://safetydata.fra.dot.gov/OfficeofSafety/publicsite/Prelim.aspx
- (accidents/1 million train miles) USDOT, FRA, Office of Safety Analysis, 1.03 Overview Charts by Railroad.
- (hazardous materials accidents) USDOT, FRA, Office of Safety Analysis, 1.01 Accident/Incident Overview.
- (Accidents in DC) USDOT, FRA, Office of Safety Analysis, 1.05 Accident/Incident Overview Charts by State.
- (National Hazardous Materials Shipments) USDOT, RITA/Bureau of Transportation Statistics, Special Report: Hazardous Materials Highlights—2007 Commodity Flow Survey.
- American Association of Railroads, North American Freight Statistics, April 17, 2013, page 2. Available at https://www.aar.org/StatisticsAndPublications/Documents/AAR-Stats-2013-07-09.pdf