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Table 4-20 compares the estimated loss in property taxes to the additional local revenue created 

by each alternative. The property taxes lost are not inflated. Therefore, they are expressed in Net 

Present Value without having to discount them. The revenue gained was affected by inflation and 

is presented in Net Present Value to reflect its cumulative value in today’s dollars like the 

property taxes lost. While the forecast of revenues by terminal area cannot reflect how or where 

overall government revenues are spent, the table demonstrates that in each alternative, the 

“Government Revenue Gain,” produced more new local revenues than the property tax revenue 

lost. 

Table 4-20 

Terminal Area Property Tax Reduction 

and Local Revenue Gained a 

(millions of 2004 dollars) 

ALT 1 ALT 2 ALT 3 ALT 4 

Preferred 

Alternative (2008) 

 

Property 

Tax 

Revenue 

Reduction 

Net 

Gov’t. 

Revenue 

Gain 

Property 

Tax 

Revenue 

Reduction

Net 

Gov’t. 

Revenue 

Gain 

Property 

Tax 

Revenue 

Reduction

Net 

Gov’t. 

Revenue 

Gain 

Property 

Tax 

Revenue 

Reduction 

Net 

Gov’t. 

Revenue 

Gain 

Property 

Tax 

Revenue 

Reduction

Net 

Gov’t. 

Revenue 

Gain 

Detroit Plus Local Revenuesb 0.00 27.1 -17.3 49.9 -14.4 172.2 -13.8 177.4 -11.3 141 

All Revenues, State and Localc N/A 155 N/A 668 N/A 1,066 N/A 1,108 N/A 1,041 

a

Property tax figures are cumulative 2006 (the first year of expected implementation) to 2025 (or in the case of the Preferred, 

cumulative 2010 to 2030), expressed in 2004 (2008 for the Preferred) U.S. dollars (USD), in millions. Government Revenue 

Gain presented in Net Present Value, discounted at 2%, expressed as 2004 USD in millions (2008 for the Preferred). b

Local Revenues represent cumulative loss and gain for all local, public, and revenue-generating entities within the Detroit Plus 

zone, including property taxes collected by the City of Detroit, Wayne County, and all other taxing authorities. Because they 

were never inflated they weren’t discounted so they are already expressed in Net Present Value. c

All additional cumulative 2004-2005 (2008-2009 for the Preferred) revenues collected in the State of Michigan by any state or 

local entity. 

Source: The Corradino Group of Michigan, Inc. and Analytic Planning Services 

Preferred Alternative 

Results for the Preferred Alternative reflect updated data and reapplication of the REMI 

model. (Tables 4-19, 4-20 and Figure 4-30). The forecast net job gain of the Preferred 

Alternative, while less than Alternatives 3 and 4, is still substantial. Some 231 jobs would be 

relocated, while the economic stimulus would generate approximately 4,514 jobs including the 

2,359 jobs in the Detroit area. The schedule of the Preferred Alternative construction occurs 

later than was foreseen for the Practical Alternatives (Figure 4-30), as the project is delayed in 

its review/approval. Nonetheless, about 3,085 person years33 of employment would be 

generated, with construction peaking in 2014 at 620 jobs. 

4.6 Land Use and Zoning 

Land use statements below are drawn from the Detroit Master Plan of Policies dated 1992. 

Several commenters on the DEIS called for use of the 2004 Master Plan of Policies; 

however, the 2004 Plan was in draft form at the writing of the DEIS and FEIS. To see land 

use maps of the areas around the Detroit terminals, go to http://www.detroitmi.gov/ 

Departments/PlanningDevelopmentDepartment/Planning/LongRangeandCommunityPlanning

/2004MasterPlanDraft/tabid/2055/Default.aspx.

 

33 A person year is one person working one year. 
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4.6.1 Livernois-Junction Yard 

Land use in the Livernois-Junction Yard area is predominately industrial and commercial. The 

area has large amounts of land dedicated to railroads, scrap yards, equipment storage, container 

storage, and truck terminals and offices. Ford’s large River Rouge plant is to the west of the 

terminal. Residential land is to the east of the terminal and north of the industrial land that 

borders the terminal. A substantial amount of vacant land exists in the terminal area. The nonresidential zoning in Detroit around the Livernois terminal is predominantly intensive industrial 

and special industrial. The zoning in the area also includes single-family residential, two-family 

residential, medium density multi-family residential, low density multi-family residential, general 

business, local business, restricted industrial, and general industrial. The zoning in Dearborn 

around the Livernois-Junction Yard is intensive industrial. The Detroit Master Plan of Policies 

for the Southwest Sector of the City states: 

“Southwest Detroit has two outstanding economic characteristics: an 

exceptional concentration of very heavy industry, and a unique convergence 

of freight transportation modes. Weaknesses of the Sector relate to economic 

obsolescence in both the industrial and commercial plant. Strengths of the 

area include the Detroit River as a unique attraction, the fixed nature of the 

transport infrastructure, the availability of many sound industrial buildings, 

and the shopping habits of many local residents favoring neighborhood 

stores. 

Detroit’s major concentration of ports, rail facilities, truck terminals, 

pipelines, international crossings and associated or support facilities and 

organizations occurs in the Southwest Sector. This remains unchanged 

despite the serious and continuing erosion of the Sector’s manufacturing 

base. Only to a limited extent can changing technology, changing corporate 

ownership patterns, or other evolutionary factors disperse southwest Detroit’s 

highly significant concentration of freight facilities. In fact, prevailing 

economic forces actually favor continued concentration. 

The Southwest Sector, therefore, will remain an area of primary economic 

importance, and industrial activities, within the limits of sound planning and 

environmental protection.” 

The Dearborn Master Plan states the following: 

“A multi-modal freight terminal is planned to serve the Con Rail Railroad 

lines directly east of the City of Dearborn. This facility would be so close to 

Dearborn that it could eventually serve industrial development and shipping 

needs in both Detroit and Dearborn. A multi-modal facility would provide 

automatic transfers between port, rail, truck and air transit modes. Without 

such a multi-mode facility, a company would have to make separate 

arrangements when shipping goods over water, air, or land. With a multimodal terminal, a shipment can be automatically transferred from one mode 

of transportation to another without the need to make additional separate 

arrangements. Such a facility is a strong economic development incentive 

and although the facility will be located in Detroit, it will be close to 

Dearborn and should also have a strong economic development advantage 

for Dearborn.” 
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4.6.2 CP/Expressway Terminal

Land use immediately around the Expressway terminal includes railroad facilities, the old MCRR 

passenger station, a hospital, industrial land, commercial land, and vacant land. Zoning 

immediately around the Expressway terminal includes intensive industrial, general industrial, 

restricted industrial, two-family residential, and general business. 

4.6.3 CP/Oak Terminal

Land use around the CP/Oak terminal is predominately industrial. I-96 is located directly to the 

south of the terminal. Zoning immediately around the CP/Oak terminal includes intensive 

industrial, general industrial, restricted industrial, single-family residential, and two-family 

residential. 

4.6.4 CN/Moterm Terminal

Land use immediately around the CN/Moterm terminal is predominately industrial to the east and 

north and single-family residential to the west. Eight Mile Road and the Michigan State 

Fairgrounds are to the south of the terminal. Zoning, in Detroit, immediately around the Moterm 

terminal includes general business, two-family residential, and intensive industrial. Zoning, in 

Ferndale, immediately around the Moterm terminal is predominantly general manufacturing and 

light manufacturing with some low density residential, single-family residential, vehicular 

parking, and business zoning. The Detroit Master Plan of Polices for the North Sector of the city 

states: 

“The elements most greatly affecting the future of the North Sector are its 

industrial facilities, its neighborhood systems, and – directly tied to 

neighborhoods – its housing stock. The Sector’s greatest potential lies in the 

maximization of these three resources. 

Industrial areas of the North Sector appear to have excellent potential for 

continued employment opportunities, for expansion of select areas, and for 

continued support of the economic base of the City, given the Sector’s 

attributes of location. 

Central to the future of the North Sector is its neighborhood systems. The 

North Sector has many healthy neighborhoods on which to expand; it has just 

as many neighborhoods with the potential to become just as healthy as any of 

the best neighborhoods of the Detroit metropolitan area. 

The North Sector is a major trucking center, second in importance only to the 

Southwest Sector (among Detroit’s 11 planning sectors). Rail transportation, 

however, is of less importance to the North Sector, for rail lines mainly serve 

through traffic. The Sector is not heavily industrialized; there are very few 

active rail sidings here, and no rail classification yards (areas used for 

switching and freight trains linking up) or terminals remaining active. 

The construction of the planned Light Rail Transit (LRT) system along 

Woodward will have an important impact on the North Sector. The regional 

transportation plan calls for the development of a LRT system in the 

Woodward Corridor from downtown Detroit to the northern suburbs.” 
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The terminal proper lies in Ferndale. Its Master Plan states: 

“Ferndale’s economic health depends on maintaining and expanding the 

existing industrial and business base. The recent East Michigan Environmental 

Action Council (EMEAC) project reported that 20 percent of the industrial 

firms were considering relocating outside the City. Reasons given for 

considering relocating were: to be closer to customers; to find land to expand; 

to access cheaper labor pools; to escape local business decline; and to move to 

a more receptive city. An ongoing mechanism needs to be established to 

obtain input from the business and industrial community to assist the City of 

Ferndale and the Chamber of Commerce officials to identify priority needs.” 

Alternative 1: No Action 

The continued existence of the four rail terminals is contemplated by the Detroit Master Plan of 

Policies (Livernois-Junction Yard, CP/Expressway, CP/Oak and CN/Moterm terminals), the 

Dearborn Master Plan (Livernois-Junction Yard), and the Ferndale Master Plan (CN/Moterm). 

Alternative 2: Improve/Expand Existing Terminals 

Further development of the Livernois-Junction Yard is consistent with the Master Plan of Policies 

of the City of Detroit. It is also consistent with the Dearborn Master Plan. 

Expansion of the CP/Expressway terminal is consistent with the Master Plan of Policies of the 

City of Detroit, as described for the Southwest Sector of the City. 

Further development of the CP/Oak terminal is not specifically mentioned in the Master Plan of 

Policies of the City of Detroit. 

Expansion of the CN/Moterm terminal into the Fairgrounds is consistent with previous use of the 

Fairgrounds property by Canadian National Railroad and the current and more extensive use by 

DaimlerChrysler (refer to Figure 6-6). It is noteworthy the Michigan courts ruled in 1994 that use 

of the Fairgrounds is not subject to local government zoning control which allows the 

Fairgrounds to use its land as it sees fit. Expansion of CN/Moterm is consistent with the Detroit 

Master Plan of Policies for the North Sector of the City and with the Ferndale Master Plan. 

Alternative 3: Consolidate All Four Class I Railroads’ Intermodal Activity at LivernoisJunction Yard Area 

This consolidation at the Livernois-Junction Yard is consistent with the Detroit Master Plan of 

Policies and the Dearborn Master Plan, as much of that development will take place on industrial 

property while rezoning would be required of about 12 acres, out of the 384-acre expansion area, 

which is now residential. 

Alternative 4: The Composite Option 

Expanding the Livernois-Junction Yard is consistent with the Detroit Master Plan of Policies, as 

much of the development will take place on industrial property. About 10 acres of the 265-acre 

expansion area is now residential and rezoning will be required. Expansion of the CN/Moterm 

terminal is consistent with the Detroit Master Plan of Policies, the Ferndale Master Plan, and past 

practices at the Fairgrounds. 
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Preferred Alternative 

Expanding the Livernois-Junction Yard is consistent with the Detroit Master Plan of Policies, 

as much of the development will take place on industrial property. About 10 acres of the 

169-acre expansion area is now residential and rezoning will be required. This will be 

consistent with land uses in the area. 

4.7 Farmland and Open Space/Part 361 of Michigan Act 451 

Lands/Forest Land 

There is no agriculture or forestry zoning associated with any terminal. So, an additional review 

under the Federal Farmland Protection Policy Act is not required, therefore, an A.D. 1006 form 

was not prepared and coordinated with the U.S. Department of Agriculture, Natural Resources 

Conservation Service. The Michigan Department of Agriculture stated, “Since the construction 

of the proposed Detroit Intermodal Freight Terminal Project is to be accomplished within a highly 

developed part of the state, no adverse impacts to agriculture are anticipated.” (See letter dated 

September 18, 2002, Appendix A, Section 2 of the DEIS). No Michigan Public Act 451, Part 361 

(The Farmland and Open Space Preservation Act) parcels are within the project area. 

Preferred Alternative 

Conclusions have not changed from the DEIS; the Preferred Alternative would have no effect 

on Part 361 lands or farmland (see letter in Appendix A from the U.S. Department of 

Agriculture dated June 1, 2005). 

4.8 Air Quality Analysis 

The first 30 pages of this section is the DEIS analysis. The FEIS analysis is found at Section 

4.8.7. 

The DIFT air quality analysis was guided by an Air Quality Protocol (Appendix E) and included: 

• A discussion of air quality conformity and the attainment status of the project area with 

respect to the National Ambient Air Quality Standards (NAAQS), notably carbon 

monoxide (CO), ozone, and PM2.5 (particulate matter of 2.5 micros or smaller). 

• A discussion of pollution trends, and of U.S. EPA measures to improve air quality. 

• A discussion of air toxics, including a qualitative discussion of health risks and current 

science. 

• An estimate of the pollutant burden that will be generated by the No Action and Action 

Alternatives for each terminal for the NAAQS pollutants and several key air toxics. 

“Burden” means the mass of a pollutant produced in a given period. Burden does not 

mean the amount of a pollutant concentrated in a specific location. In this case, pollutant 

burden is expressed in tons per year. 

• An estimate of the pollutant burden produced by mobile source activities on the local 

public roadway network near each terminal that would experience traffic volume 

changes. This burden analysis included the NAAQS pollutants and several key air toxics. 

• A CO hotspot analysis at key intersections in the terminal areas that compared CO 

concentrations to the one- and eight-hour NAAQS. This was not a burden analysis but a 

concentration analysis, which defines the pollutant level at a specific location to which 

people are exposed. 
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4.8.1 Air Quality Conformity 

The Clean Air Act requires Michigan (and all other states) to have a State Implementation Plan 

(SIP) to demonstrate how it will attain and/or maintain National Ambient Air Quality Standards 

(NAAQS) (Table 4-21). SEMCOG, the Southeast Michigan Council of Governments, 

collaborates with the Air Quality Division of the Michigan Department of Environmental Quality 

(DEQ) on the work needed to prepare and/or update a SIP. SEMCOG is responsible for reviewing 

mobile source (vehicular) emissions in Southeast Michigan when projects are proposed for 

inclusion in their long-range transportation plan. SEMCOG’s 2030 Regional Transportation 

Plan (RTP) must undergo a quantitative analysis demonstrating that emissions levels associated 

with implementing planned projects are below designated emissions level limits (budgets) set 

forth in the SIP. In so doing, SEMCOG is managing and facilitating the transportation air quality 

conformity process in Southeast Michigan. The DIFT project is subject to air quality 

transportation conformity review through SEMCOG’s inclusion of any DIFT roadway 

improvements in its RTP. This will occur after the public hearing when a preferred alternative is 

determined. 

Table 4-21 

National Ambient Air Quality Standards 

Pollutants Average 

Time Primary Standard a

 Secondary Standard b

Carbon Monoxide 1-hr 35 ppm (40mg/m3) No Secondary Standard 

8-hr 9 ppm (10mg/m3) No Secondary Standard 

Lead Quarter 1.5 μg/m3 Same as Primary 

Nitrogen Dioxide Annual 0.053 ppm (100μg /m3) Same as Primary 

Ozone 1-hr 0.12 ppm (235μg/m3) Same as Primary 

8-hr 0.08 ppm (157μg/m3) Same as Primary 

Respirable Particulate 

Matter (10 microns or less) 

(PM10) 

24-hr 150 μg/m3 Same as Primary 

 Annual 50 μg/m3 Same as Primary 

Respirable Particulate 

Matter (2.5 microns or less) 

(PM2.5) 

24-hr 65 μg/m3 Same as Primary 

 Annual 15 μg/m3 Same as Primary 

Sulfur Dioxide 3-hr – 0.5 ppm (1300μg/m3) 

24-hr 0.14 ppm (365μg/ m3) – 

Annual 0.03 ppm (235μg/ m3) – 

Note: ppm is parts per million; mg is milligrams; μg is micrograms. 

a

 Primary NAAQS: the levels of air quality that the EPA judges necessary, with an adequate margin of safety, to protect the 

public health. 

b

 Secondary NAAQS: the levels of air quality that the EPA judges necessary to protect the public welfare from any known or 

anticipated adverse effects. 

Source: Code of Federal Regulations, Title 40, Part 50. 

Air quality conformity analyses for mobile sources required in Southeast Michigan currently 

involve two major pollutants: carbon monoxide (CO) and ozone (and its precursors volatile 

organic compounds and nitrogen oxides). A new standard will require such analysis for PM2.5 by 

April 2006. This attainment status of the region is as follows: 

Carbon monoxide - In 1999, Wayne, Oakland, and Macomb counties were redesignated 

from nonattainment to maintenance for CO. Similar to ozone, a positive conformity 

determination for CO requires that emissions in any future year remain at or below the 
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approved mobile source emissions budget of 3,843 tons/day. On January 28, 2005, 

(effective March 28, 2005) EPA approved a revised CO budget of 1946 tons /day. 

 

One-hour ozone - In 1995, the seven-county SEMCOG region was redesignated from 

nonattainment to maintenance for the one-hour ozone standard. At that time, a 

maintenance plan was developed establishing emissions budgets for the two precursors 

of ozone: volatile organic compounds (VOCs) and nitrogen oxides (NOx). In order for a 

conformity determination to be made with regard to the one-hour ozone standard, VOCs 

emissions cannot exceed the mobile source emissions budgets of 218 tons/day for years 

2004-2014, and 173 tons/day for years 2015 and beyond. For NOx, emissions cannot 

exceed the budget of 413 tons/day in any analysis year. The 8-hour standard (see below) 

now supplants the 1-hour standard, but until an 8-hour emissions budget is established, 

conformity will be the same as for 1-hour. 

Eight-hour ozone - On April 15, 2004, the EPA officially designated the seven-county 

SEMCOG region, plus Lenawee County, a moderate nonattainment area for the 8-hour 

ozone standard. In September 2004, EPA approved the reclassification of the area from 

moderate to marginal ozone nonattainment. A SIP, which must be approved by 2007, is 

currently being developed to address this issue. As noted, for the time being, the test of 

8-hour conformity remains the same as that used to demonstrate conformity for one 

hour. 

PM10 - As mobile sources in Southeast Michigan currently meets the NAAQS for this 

pollutant, a regional transportation conformity analysis is not required. 

PM2.5 - EPA designated seven counties in Southeast Michigan as nonattainment for this 

new standard December 15, 2004. Conformity determinations for PM2.5 will be required 

by April 5, 2006. 

The project must be included in SEMCOG’s cost-feasible Regional Transportation Plan and 

Transportation Improvement Program (TIP) to advance to design. To be included on the plan 

and TIP, it must be consistent with the State Implementation Plan (SIP). When analyzed together 

with other plan elements, the air pollution generated must not exceed “budgets” established in the 

SIP. After the public hearing, when a preferred alternative is determined; the DIFT project 

elements that cause changes to the transportation network will be evaluated by SEMCOG for air 

quality conformity. 

4.8.2 Pollution Trends – NAAQS Pollutants and Air Toxics 

This section presents: 1) information about air quality trends and measures EPA is taking to 

improve air quality; 2) data from air pollution monitoring stations nearest the terminals; and, 3) 

how these measures relate to PM2.5 and air toxics. 

4.8.2.1 Air Quality Trends and EPA Measures to Improve Air Quality 

EPA has recently implemented regulations related to on-road diesel engines, fuels, and non-road 

equipment, including that used on railroad yards. These regulations will substantially improve air 

quality. Before discussing these measures, it is of interest to review several relevant aspects of 

key pollutants. 

Diesel exhaust is a complex mixture of inorganic and organic (carbon-based) compounds that 

occur as a blend of gases and particles. The gaseous components include nitrogen oxides, sulfur 

compounds, and low-molecular-weight hydrocarbons, such as the aldehydes, benzene, 1,3-
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butadiene, and polynuclear aromatic hydrocarbons. The particle phase of diesel exhaust consists 

of elemental carbon, adsorbed organic compounds and small amounts of sulfate, nitrate, metals 

and other trace elements. Diesel particulate matter (DPM) has been estimated to comprise about 

six percent of the total PM2.5 inventory nationwide but more in urban areas, excluding natural and 

miscellaneous sources (U.S. EPA, 2002). 

Compounds of most specific interest for the DIFT project are those found in particulate matter 

and, to a lesser degree, volatile organic compounds (VOCs), which are also emitted by diesel 

vehicles. Data from the 1996 National Toxics Inventory indicate that mobile sources account for 

approximately 50 percent of air toxics emissions (U.S. EPA, 2000). Several of the air toxics that 

EPA has identified as priority mobile source air toxics (MSATs) constitute a subset of all VOCs. 

The MSATs considered in the DIFT environmental impact analysis (see Air Quality Protocol – 

Appendix E) are benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and acrolein. Also 

included on EPA’s list is diesel particulate matter (DPM). These particular air toxics were 

selected to be included in the burden analysis because: 1) mobile sources, both on-road and nonroad, contribute the majority of annual emissions for five of these air toxics (acetaldehyde, 

acrolein, benzene, 1,3-butadiene and formaldehyde) on a national basis; 2) they are representative 

of the complete list of gaseous mobile source air toxics; and, 3) these air toxics are some of the 

more important ones from a health standpoint. It is important to note that almost all of the 

remaining hazardous air pollutants (HAPs) emitted by mobile sources are trace metals, and 

compounds associated primarily with the particulate phase. Stationary and area sources account 

for most the nationwide emissions of these HAPS. 

EPA has issued a suite of motor vehicle and fuels regulations, including: 1) tailpipe emission 

standards for cars, SUVs, mini-vans, pickup trucks and heavy trucks and buses; 2) standards for 

cleaner-burning gasoline; 3) a national low-emission vehicle program; and, 4) standards for lowsulfur gasoline and diesel fuel. By the year 2020, these requirements are expected to reduce 

emissions of a number of air toxics (benzene, 1,3-butadiene, formaldehyde, and acetaldehyde) 

from highway motor vehicles by about 75 percent and diesel particulate matter by over 90 percent 

from 1990 levels (U.S. EPA, 2000). 

In addition, EPA issued a regulation in May 2004 to control emissions from diesel-powered nonroad engines, such as construction equipment and railroad locomotives. EPA also provides 

assistance in identifying and implementing voluntary programs, such as diesel retrofits, to achieve 

additional reductions. 

The EPA-approved MOBILE6.2 model allows projections of future emission factors for the 

NAAQS pollutants and certain air toxics associated with mobile sources. The model accounts for 

the recent EPA regulatory changes. Emission factors vary by speed and type of vehicle. By 

focusing on representative vehicle types and speeds, future emission factors can be related to 

trends over time (i.e. 2004, 2015, and 2025). Graphics illustrate substantial downward trends for 

the following representative conditions: 

• Passenger vehicles and NAAQS pollutants at: a) 10 mph (Figure 4-31a), and b) 30 mph 

(Figure 4-31b) 

• Passenger vehicles and air toxic pollutants at: a) 10 mph (Figure 4-31c), and b) 30 mph 

(Figure 4-31d) 

• Trucks and NAAQS pollutants at: a) 10 mph (Figure 4-31e), and b) 30 mph (Figure 4-

31f) 

• Trucks and air toxic pollutants at: a) 10 mph (Figure 4-31g), and b) 30 mph (Figure 4-

31h) 
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4.8.2.2 Monitoring Data 

Air pollution monitoring station data collected for the terminal areas are displayed in Figures 4-32 

through 4-39. The information for the Livernois-Junction Yard is from the Detroit Linwood 

monitor (Station 26-163-0016) and the Dearborn Wyoming monitor (Station 26-163-0033). 

Information for the Oak and Moterm terminals is from the Detroit Oak Park monitor (Station 26-

125-0001) for CO, ozone, and PM2.5. Data are not collected at this monitor for NOx and PM10, so 

the data from the Linwood and Wyoming monitors are the best available monitoring data. 

The most critical of these data are particulate matter and ozone, because of the area’s 

nonattainment status. 

There is a downward trend in ozone at the Livernois-Junction Yard in terms of the 1-hour 

standard (Figure 4-33 top), but 8-hour average values have risen over the last several years and 

are above the standard (Figure 4-33 bottom). The pattern is similar at the CP/Oak and 

CN/Moterm terminal areas (as measured at the Oak Park Drive monitoring station, Figure 4-38). 

The ozone issue will be addressed by SEMCOG in a transportation conformity assessment of the 

DIFT. But, in that regard, the ability of the DIFT to divert some freight shipments from trucks to 

rail will have a positive regional effect on ozone. 

For particulate matter at the CP/Oak and CN/Moterm terminal areas the 24-hour standard is not 

exceeded but the annual average has been (Figure 4-39 bottom). The Livernois-Junction Yard 

area shows a similar pattern, but the particulate values are higher. Particulate matter (PM10 and 

PM2.5) measurements have been trending upward, except for the annual mean value of PM2.5. 

And, the measured annual mean values for the last several years have been above the NAAQS 

(Figure 4-35 bottom). The PM10 values at the Wyoming Avenue monitoring station spiked in 

2003 for an undetermined reason. 

4.8.3 Air Toxics and PM2.5 – Health Effects and Limitations of Current Science 

Research is underway by EPA and others at a national level to evaluate ambient air toxics in 

order to understand their spatial variability in urban settings; evaluate data from mobile-source 

oriented monitors; and, provide data for the National Air Toxics Network maintained by EPA. 

One of the programs sponsored by EPA is the Detroit Air Toxics Pilot Project, which began 

collecting data from monitoring stations in 2001. Data from these programs may ultimately be 

used to develop standards to address health or environmental risks from air toxics. 

Some health agencies and research institutions have reported on the health effects of air toxics 

and PM2.5. Exposure to these pollutants at sufficient concentrations and durations may result in 

an increased chance of experiencing serious health effects. These health effects appear to include 

damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), 

developmental, respiratory and other health problems. The health effects from some air toxics 

may appear following a short period of exposure, while others may only appear after long-term 

exposure. “For these (and other) reasons, it is frequently very difficult to conclusively associate 

environmental levels and potentially linked public health impacts” (MDEQ, 2003). Additionally, 

supporting documents for the health assessment of diesel engine exhaust used in the development 

of EPA’s non-road rules acknowledge that “the assessment's health hazard conclusions are based 

on exposure to exhaust from diesel engines built prior to the mid-1990s”....and “as new diesel 

engines with cleaner exhaust emissions replace existing engines, the applicability of the 

conclusions in this Health Assessment Document will need to be re-evaluated” (U.S. EPA, 2002). 

This is particularly pertinent as the implementation of the DIFT project will occur only after 

EPA’s requirement that sulfur be taken out of fuel (2007) and all on- and off-road diesel engines 

will be substantially cleaner. 
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In addition to the uncertainty associated with quantifying the health risks of air toxics and PM2.5, 

issues related to quantifying impacts and the lack of standards have been raised. There are no 

NAAQS for air toxics, and methods for quantifying impacts are subject to scientific debate. 

Unlike smokestack testing for point sources, it is not feasible to directly measure mobile source 

emissions, given the number of tailpipes that would constitute any inventory. Modeling 

approaches, however, can provide a tool to assess project impacts and to compare the relative 

merits of various control strategies or project alternatives. But, although transportation and air 

quality models are constantly being tested and improved, models to calculate the dispersion of 

PM2.5 and air toxics, and the resulting concentrations at any given point, have not been adopted 

for regulatory use. 

These limitations preclude, at this time, the DIFT Study from conducting a quantitative pass/fail 

comparison to standards for air toxics and PM2.5. Nevertheless, in order to gain some insight into 

the relative differences among the alternatives with regard to air toxics and PM2.5, the pollutant 

burdens of the proposed alternatives are determined for all terminal sites and on the surrounding 

roadway network. This approach is consistent with the requirements of 40 CFR 1502.22 and 

1502.24. 

4.8.4 Terminal Pollutant Burden Estimates 

For each terminal, an area has been defined that covers the existing yard and any area of potential 

terminal expansion (Figures 4-40, 4-41, 4-42, and 4-43). Within these areas, the total pollution 

emitted has been calculated in tons per year for 2004, 2015, and 2025 for each alternative. The 

pollution burden analysis addresses: 

• Visitor and employee traffic on the rail yard. 

• Truck activity on the rail yard related to container delivery and pickup. 

• Container handling on the yard - moving containers between delivery points and trains. 

• Locomotive idling and movement on the yard. 

• Fugitive dust from paved and unpaved yard areas. 

• Vehicular travel on sites of businesses to be acquired. 

• Vehicular travel on streets that would be inside the terminal with project development: 

John Kronk and a section of Lonyo. 

• Fugitive dust from business sites and the public streets that would be closed. 

The terminal pollutant burden has been calculated for the following NAAQS pollutants: carbon 

monoxide (CO), hydrocarbons (HC), oxides of nitrogen (NOx), particulates of 10 microns or 

smaller (PM10), particulates of 2.5 microns or smaller (PM 2.5), and volatile organic compounds 

(VOC). It has likewise been calculated for the following air toxics: benzene, 1,3-butadiene, 

formaldehyde, acetaldehyde, acrolein, and diesel particulate matter (DPM). 

This information has been estimated for both on-road vehicles (cars and trucks) and non-road 

equipment (lifters, locomotives and other rail yard equipment) operating at a terminal. The 

emission factors (in grams/mile) for on-road sources (cars and trucks) are developed from 

MOBILE6.2. These factors are available for both NAAQS pollutants and air toxics. Emission 

factors for mobile source activity at 2.5 miles per hour were used to estimate idling conditions on 

the terminal yards because MOBILE6.2 does not generate emission factors for idling vehicles. 

The burden for on-road activity was based on vehicle miles of travel on the site. 
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Emissions from terminal tractors, hostlers and cranes were estimated using Exhaust and 

Crankcase Emission Factors for Nonroad Engine Modeling – Compression-Ignition, EPA420-P04-009, April 2004 and other technical guidance that support EPA’s NONROAD model. 

Emission factors for non-road air toxics were taken from technical documents supporting EPA’s 

1999 National Toxics Inventory, in consultation with EPA and SEMCOG. Information regarding 

equipment and usage activity at each terminal was obtained through interviews with terminal 

managers. 

Emission factors for locomotives were obtained from EPA’s 1997 “Emission Factors for 

Locomotives” (EPA420-F-97-051). A load factor, representing the portion of the engine’s 

horsepower needed for an activity, was applied to the emission factor in order to obtain a realistic 

emission estimate. PM2.5 emissions estimates were derived using a PM2.5 fraction of 0.97 as 

recommended by EPA April 2004. The burden for locomotives was based on the number of 

hours of operation on the site. Emission factors for locomotive air toxics were derived from the 

1999 National Toxics Inventory technical document. 

The burden analysis includes estimates of emission sources located outside the currently active 

terminals, extending to the limits of the expansion areas, i.e., Figures 4-40 through 4-43. 

Therefore, traffic of businesses to be relocated due to terminal expansion were added to the baseyear total, but subtracted from the build alternatives when such facilities are removed by an 

alternative. And, the emissions from roads that will be closed and included within the footprint of 

a terminal were similarly included in the base year, but subtracted from the alternatives that close 

these roads to public use. Examples are John Kronk Street and Lonyo Avenue. 

The PM2.5 burden analysis includes fugitive dust emissions. Project-related dust emissions are 

important in this analysis because the build alternatives would reduce PM emissions by covering 

unpaved surfaces including exposed soil in terminal areas. This paving is built into the Action 

Alternatives and is not considered mitigation. Road/soil dust tends to have a lower percentage of 

PM2.5 than diesel particulate matter; however, the sheer size of the unpaved terminal areas (e.g., at 

the Livernois-Junction Yard) represents a significant part of the total PM emissions (including 

PM2.5) that could be reduced by paving these areas. In the case of the Livernois-Junction 

Yard, analyses show that road/soil dust is a nuisance to DIFT neighbors because road/soil 

emissions are cool and not as buoyant as diesel emissions so they fall in a localized area in high 

concentrations. Diesel emissions are hot and buoyant so they tend to rise in the atmosphere and 

disperse over a wider area in relatively lower concentrations. EPA’s “Compilation of Air 

Pollutant Emission Factors, AP-42, Fifth Edition, Volume 1: Stationary Point and Area Sources,” 

revised December 2003, is the source of emission factors for fugitive dust emissions. The 

approximate acreage of unpaved area on each terminal was calculated using GIS mapping tools 

and verified by site visit. The estimates include individual calculations for roads as well as 

unpaved yards. 
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Data presented here are totals for each terminal for each alternative (Table 4-22a). Greater detail 

is provided in the Air Quality Impact Analysis Technical Report. In reviewing these results it is 

noted that nitrogen oxides (NOx) are good indicators of the overall pollution effects of the 

alternatives because they are diesel-engine based (cars produce little) and the data do not involve 

other considerations (like the dust with PM data). NOx is expected to drop from existing 

conditions to 2025 No Action conditions, increase under Alternative 2, then decrease somewhat 

under Alternatives 3 and 4. This pattern reflects: 1) the future drop in emissions from cleaner 

engines and fuels; then, 2) the increases related to more lifts affected by the efficiencies of 

operation brought about by Alternatives 3 and 4. 

Alternative 1: No Action would experience reductions across the range of most pollutants, 

including mobile source air toxics (MSATs), compared to current conditions, except particulate 

matter (PM). This overall positive trend is forecast to result from lower on-road, non-road, and 

locomotive emissions factors associated with cleaner fuels and cleaner engines, as prescribed by 

EPA. The PM increase is the exception and that is mainly due to increased activity on the 

unpaved terminal surfaces under Alternative 1. 

For Alternative 2: Improve/Expand Existing Terminals, most pollutants are forecast to be lower 

than existing conditions and to increase marginally over 2025 No Action conditions as the 

intermodal activity (lifts) are forecast to increase by almost 80 percent with improving/expanding 

the terminals. PM10 would be reduced relative to the 2025 No Action conditions, as dust would 

be controlled by paving. PM2.5 would be virtually unchanged overall. Paving would tend to 

reduce PM2.5, while increased intermodal activity would tend to increase it. 

Alternative 3 would consolidate all intermodal operations at the Livernois-Junction Yard area. In 

that area, terminal pollutant burdens would increase over both No Action and Alternative 2 

conditions because of the significant increase in intermodal activity (80 to 130 percent, 

respectively). 

Alternative 4 is forecast to be associated with terminal pollutant burdens in this area at virtually 

the same amounts as No Action and Alternative 2, even though the intermodal activity of the 

Livernois-Junction Yard area is forecast to more than double. A similar comparison exists for the 

CN/Moterm terminal under Alternative 4. 

Increased intermodal activity will shift freight from trucks to rail. This would reduce mileage and 

pollution. The expected reduction for Wayne County and the seven-county SEMCOG region is 

presented in Table 4-22b. 

Further information regarding the sources of the various pollutants at the terminals is presented in 

Table 4-23. The regulated on-road sources include automobiles and trucks. The recently 

regulated off-road vehicles include the container handling equipment and locomotives. Road and 

yard dust is shown separately because it is the volume of such material. 
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Table 4-22a 

Terminal Burdens – Annual Tons 

CO HC NOx PM10 PM2.5 VOCs DPM BENZ BUTA 

2004 SW Detroit/E Dearborna 41.3 7.0 93.9 177.3 43.5 7.1 6.3 0.13 0.02 CP/Oak 9.5 1.8 25.7 29.2 8.6 1.8 1.9 0.03 0.01 CN/Moterm 6.4 1.1 14.1 4.4 1.8 1.1 1.0 0.02 0.004 Totals 57.2 9.9 133.7 210.9 53.9 10.0 9.2 0.18 0.03 Alt. 1 – 2025 No Action SW Detroit/E Dearborna 18.2 3.9 28.3 227.1 47.3 3.9 1.2 0.07 0.02 CP/Oak 4.1 1.1 7.8 36.9 10.9 1.1 0.3 0.02 0.005 CN/Moterm 1.5 0.5 5.2 5.1 1.4 0.5 0.2 0.01 0.003 Totals 23.8 5.5 41.3 269.1 59.6 5.5 1.7 0.09 0.03 Alt. 2 – 2025 Improve/Expand SW Detroit/E Dearborna 21.4 5.8 37.9 185.8 47.2 5.9 1.6 0.10 0.02 CP/Oak 3.3 1.6 9.6 21.7 5.8 1.6 0.4 0.03 0.01 CN/Moterm 1.9 0.7 6.4 8.8 2.4 0.7 0.2 0.01 0.004 Totals 26.6 8.1 53.9 216.3 55.4 8.2 2.2 0.13 0.03 Alt. 3 - 2025 Consolidate Livernois-Junction 15.2 8.1 46.5 204.8 52.8 8.1 2.1 0.13 0.03 Alt. 4 - 2025 Composite SW Detroit/E Dearborna 13.0 7.2 39.1 160.9 41.6 7.2 1.8 0.12 0.03 CN/Moterm 1.9 0.7 6.4 8.8 2.4 0.7 0.2 0.01 0.004 Totals 14.9 7.9 45.4 169.8 44.0 7.9 2.0 0.13 0.03 

aIncludes the Livernois-Junction Yard, Expressway, Delray, and Triple Crown terminals. 

Note: VOCs are volatile organic compounds, DPM is diesel particulate mater, BENZ is benzene, BUTA is 1,3, butadiene, FORM is formaldehyde, ACET is acetaldehyd

Source: The Corradino Group of Michigan, Inc. 

Table 4-22b 

Reduction of Pollutants Due to Truck-to-Rail Diversion for Each Action Alternative 

CO HC NOx PM10 PM2.5 VOCs DPM BENZ BUTA 

In Wayne Co. 

Totals 17.8 16.1 33.8 3.0 1.7 15.9 1.7 0.17 0.10 

In Southeast Michigan 

Totals 48.7 37.7 128.9 11.8 6.7 37.2 6.7 0.41 0.24 

Note: VOCs are volatile organic compounds, DPM is diesel particulate mater, BENZ is benzene, BUTA is 1,3, butadiene, FORM is formaldehyde, ACET is acetaldehyd

Source: The Corradino Group of Michigan, Inc. 
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Table 4-23 

Terminal Burden by Activity Type – Annual Tons 

CO HC NOx PM10 PM2.5 VOCs DPM BENZ BUTA 

2004 Automobiles/Trucks 29.7 2.8 17.7 0.5 0.4 2.8 0.5 0.07 0.01 Container Handling 21.7 5.0 77.1 7.5 7.3 5.0 7.3 0.10 0.01 Locomotives 5.8 2.1 38.9 1.5 1.4 2.2 1.4 0.01 0.01  Road/Yard Dust 0.0 0.0 0.0 201.4 44.8 0.0 0.0 0.00 0.00 Totals 57.2 9.9 133.7 210.9 53.9 10.0 9.2 0.18 0.03 Alt. 1 - 2025 No Action Automobiles/Trucks 12.4 1.0 1.5 0.2 0.2 1.0 0.1 0.02 0.01 Container Handling 2.6 2.7 5.5 0.4 0.4 2.7 0.5 0.05 0.01 Locomotives 8.8 1.8 34.3 1.2 1.1 1.8 1.1 0.02 0.01  Road/Yard Dust - - - 267.3 57.9 - - - - Totals 23.8 5.5 41.3 269.1 59.6 5.5 1.7 0.09 0.03 Alt. 2 - 2025 Improve/Expand Automobiles/Trucks 11.5 1.4 2.3 0.4 0.2 1.4 0.1 0.02 0.01 Container Handling 4.2 4.5 9.2 0.7 0.7 4.5 0.7 0.09 0.01 Locomotives 10.9 2.2 42.4 1.4 1.4 2.3 1.4 0.02 0.01  Road/Yard Dust - - - 213.8 53.1 - - - - Totals 26.6 8.1 53.9 216.3 55.4 8.2 2.2 0.13 0.03 Alt. 3 - 2025 Consolidate Automobiles/Trucks 1.8 1.3 2.4 0.4 0.3 1.2 0.2 0.01 0.01 Container Handling 4.8 5.1 10.5 0.9 0.8 5.1 0.8 0.11 0.01 Locomotives 8.6 1.7 33.6 1.1 1.1 1.8 1.1 0.01 0.01  Road/Yard Dust - - - 202.4 50.6 - - - - Totals 15.2 8.1 46.5 204.8 52.8 8.1 2.1 0.13 0.03 Alt. 4 - 2025 Composite Automobiles/Trucks 1.68 1.1 2.1 0.30 0.23 1.08 0.15 0.01 0.01 Container Handling 4.71 5.1 10.3 0.90 0.78 5.08 0.78 0.10 0.01 Locomotives 8.5 1.7 33.0 1.12 1.1 1.7 1.1 0.0 0.0  Road/Yard Dust - - - 167.5 41.9 - - - - Totals 14.9 7.9 45.4 169.8 44.0 7.9 2.0 0.13 0.03 

Note: VOCs are volatile organic compounds, DPM is diesel particulate mater, BENZ is benzene, BUTA is 1,3, butadiene, FORM is formaldehyde, ACET is acetaldehyd

Source: The Corradino Group of Michigan, Inc. 
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4.8.5 Public Roadway Pollutant Burden Estimates 

A network of local roads near each terminal that could be influenced by the project has been 

identified (Figures 4-44 to 47). These include roads that would: 1) be used by new DIFT traffic; 

2) have traffic changes due to the closure of Lonyo; or, 3) experience changes in auto and truck 

traffic as businesses are relocated to accommodate terminal development. 

The traffic changes resulting from each alternative are summarized as follows: 

• Alternative 1: No Action 

9 Background auto and truck traffic will grow 25 percent between 2000 and 2025. 

• Alternative 2: Improve/Expand Existing Terminals 

9 Livernois-Junction Yard – DIFT trucks will use either Wyoming or Livernois. 

(Under Option A that maintains the Dix/Waterman/Vernor gate, traffic could use 

Livernois/Dragoon south of Dix, but in Options B and C, all Livernois traffic would 

be to/from the north on Livernois and connect with I-94, and Dragoon will not be a 

route to the intermodal terminal.) 

9 CP/Expressway terminal – Traffic would link directly to Michigan Avenue, rather 

than using 14th Street. 

9 CP/Oak terminal – A new entrance direct to Evergreen and the ramps linking to I-96 

would be created, ending intermodal truck use of the Southfield Freeway frontage 

roads and such local streets as Artesian. 

9 CN/Moterm terminal – Intermodal truck traffic would be eliminated from Fair and 

Chesterfield Streets, as the terminal would be accessed directly south of 8 Mile Road 

into the State Fairgrounds. 

• Alternative 3: Consolidate – DIFT truck traffic would use Wyoming and Livernois 

(north of the terminal gate). Local traffic on Lonyo would either shift to Central or to 

Wyoming, when Lonyo is closed at the rail yard boundaries. Intermodal activity would 

be eliminated at other terminals. 

• Alternative 4: Composite – The approach is similar to Alternative 3 at the LivernoisJunction yard and the same as Alternative 2 at CN/Moterm, as CN operations would not 

be consolidated, but expand into the State Fairgrounds. 

Using available information on background traffic levels, traffic shifts were calculated, with new 

intermodal truck traffic added, and traffic from displaced businesses removed. The vehicle miles 

of travel were calculated by link, and, using estimated speeds, the pollutant burden for each link 

was calculated. 

Table 4-24 shows the results for autos and trucks. The auto component of local road traffic 

produces the majority of the pollution, due to the much greater number of cars than trucks on the 

roadway system. This is particularly so for CO and hydrocarbons (HC). Trucks produce far 

more NOx per vehicle. Particulates are also produced more heavily by trucks, despite the fact 

that they are fewer in number. Nevertheless, even for NOx and particulates, in the future, no 

more than 30 percent is produced on the local road network by trucks. 
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Table 4-24 

Public Roadway Pollutant Burden 

Auto Truck 

Tons Per Year Tons Per Year 

CO HC NOx PM10 PM2.5 VOC DPM BENZ BUTA FORM ACET ACRO CO HC NOx PM10 PM2.5 VOC DPM BENZ BUTA FORM ACET 

2004 

Livernois-Junction 523.9 34.5 29.3 0.76 0.37 34.7 0.0 1.25 0.13 0.27 0.12 0.014 8.0 1.7 31.3 1.13 0.97 1.73 0.97 0.02 0.05 0.14 0.01 Expressway 73.3 4.7 4.0 0.11 0.05 4.7 0.0 0.17 0.02 0.04 0.02 0.002 0.9 0.2 3.9 0.14 0.12 0.20 0.12 0.00 0.01 0.02 0.00 CP/Oak 181.1 10.9 9.6 0.25 0.12 10.9 0.0 0.40 0.04 0.09 0.04 0.005 1.4 0.3 6.9 0.25 0.21 0.31 0.21 0.00 0.01 0.03 0.00 CN/Moterm 486.2 28.8 25.7 0.67 0.32 28.9 0.0 1.07 0.11 0.24 0.10 0.012 3.7 0.8 18.2 0.65 0.56 0.79 0.56 0.01 0.02 0.06 0.01 Totals 1264.5 78.9 68.6 1.79 0.86 79.2 0.0 2.89 0.30 0.64 0.28 0.033 14.0 3.0 60.6 2.17 1.86 3.03 1.86 0.03 0.09 0.25 0.02 2025 Alt. 1: No Action Livernois-Junction 315.4 10.4 7.7 0.87 0.39 10.4 0.0 0.41 0.04 0.08 0.04 0.004 1.0 0.9 2.5 0.25 0.14 0.94 0.14 0.01 0.03 0.08 0.01 Expressway 43.9 1.4 1.0 0.12 0.05 1.4 0.0 0.06 0.01 0.01 0.00 0.001 0.1 0.1 0.3 0.03 0.02 0.11 0.02 0.00 0.00 0.01 0.00 CP/Oak 107.9 3.2 2.5 0.29 0.13 3.3 0.0 0.13 0.01 0.03 0.01 0.001 0.2 0.2 0.5 0.05 0.03 0.17 0.03 0.00 0.00 0.01 0.00 CN/Moterm 289.2 8.5 6.7 0.77 0.35 8.6 0.0 0.35 0.03 0.07 0.03 0.004 0.4 0.4 1.4 0.14 0.08 0.42 0.08 0.00 0.01 0.03 0.00 Totals 756.4 23.5 17.9 2.05 0.92 23.7 0.0 0.95 0.09 0.19 0.08 0.010 1.7 1.6 4.7 0.47 0.27 1.64 0.27 0.01 0.04 0.13 0.01 2025 Alt. 2: Improve/Expand Livernois-Junction 323.0 10.6 7.9 0.89 0.40 10.7 0.0 0.42 0.04 0.08 0.04 0.004 1.2 1.1 2.9 0.30 0.17 1.12 0.17 0.01 0.03 0.09 0.01 Expressway 43.9 1.4 1.0 0.12 0.05 1.4 0.0 0.06 0.01 0.01 0.00 0.001 0.1 0.1 0.3 0.03 0.02 0.10 0.02 0.00 0.00 0.01 0.00 CP/Oak 107.6 3.2 2.5 0.29 0.13 3.2 0.0 0.13 0.01 0.03 0.01 0.001 0.2 0.2 0.5 0.05 0.03 0.15 0.03 0.00 0.00 0.01 0.00 CN/Moterm 289.2 8.5 6.7 0.77 0.35 8.6 0.0 0.35 0.03 0.07 0.03 0.004 0.4 0.4 1.4 0.14 0.08 0.41 0.08 0.00 0.01 0.03 0.00 Totals 763.7 23.7 18.1 2.07 0.94 23.9 0.0 0.96 0.09 0.19 0.07 0.010 1.9 1.8 5.1 0.52 0.30 0.78 0.30 0.01 0.04 0.14 0.01 2025 Alt. 3: Consolidate Livernois-Junction 300.0 9.9 7.3 0.82 0.37 10.0 0.0 0.39 0.04 0.07 0.03 0.004 0.8 0.7 1.9 0.19 0.11 0.74 0.11 0.01 0.02 0.06 0.00 Expressway 43.9 1.4 1.0 0.12 0.05 1.4 0.0 0.06 0.01 0.01 0.00 0.001 0.1 0.1 0.3 0.03 0.02 0.10 0.02 0.00 0.00 0.01 0.00 CP/Oak 107.9 3.2 2.5 0.29 0.13 3.3 0.0 0.13 0.01 0.03 0.01 0.001 0.2 0.2 0.5 0.05 0.03 0.15 0.03 0.00 0.00 0.01 0.00 CN/Moterm 289.2 8.5 6.7 0.77 0.35 8.6 0.0 0.35 0.03 0.07 0.03 0.004 0.4 0.4 1.3 0.13 0.08 0.39 0.08 0.00 0.01 0.03 0.00 Totals 741.0 23.0 17.5 2.00 0.90 23.3 0.0 0.93 0.09 0.18 0.07 0.010 1.5 1.4 4.0 0.40 0.24 1.38 0.24 0.01 0.03 0.11 0.01 2025 Alt. 4: Composite Livernois-Junction 301.4 10.0 7.4 0.83 0.38 10.0 0.0 0.39 0.04 0.08 0.03 0.004 0.8 0.7 1.9 0.19 0.10 0.72 0.10 0.01 0.02 0.06 0.00 Expressway 43.9 1.4 1.0 0.12 0.05 1.4 0.0 0.06 0.01 0.01 0.00 0.001 0.1 0.1 0.3 0.03 0.02 0.10 0.02 0.00 0.00 0.01 0.00 CP/Oak 107.9 3.2 2.5 0.29 0.13 3.3 0.0 0.13 0.01 0.03 0.01 0.001 0.2 0.2 0.5 0.05 0.03 0.15 0.03 0.00 0.00 0.01 0.00 CN/Moterm 289.2 8.5 6.7 0.77 0.35 8.6 0.0 0.35 0.03 0.07 0.03 0.004 0.4 0.4 1.3 0.13 0.08 0.39 0.08 0.00 0.01 0.03 0.00 Totals 742.4 23.1 17.6 2.01 0.91 23.3 0.0 0.93 0.09 0.19 0.07 0.010 1.5 1.4 4.0 0.40 0.23 1.36 0.23 0.01 0.03 0.11 0.01 

Note: VOCs are volatile organic compounds, DPM is diesel particulate mater, BENZ is benzene, BUTA is 1,3, butadiene, FORM is formaldehyde, ACET is acetaldehyde, and ACRO is acrolein. 

Source: The Corradino Group of Michigan, Inc. 
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Car traffic is also forecast to produce more air toxics than trucks for every pollutant for the 

roadway network around each terminal, with the exception of the Livernois-Junction Yard area, 

under Alternative 2. Under the latter scenario, the total truck contribution of the formaldehyde 

burden is about 55 percent of the total. For all other alternatives, and for all terminals, MSATs 

for trucks represent no more than 40 percent of all toxic burdens for the entire roadway network. 

The roadway network pollution burden of Alternative 1, i.e., No Action in 2025, shows 

substantial decreases in the emission burden on the local roadways compared to current 

conditions, even with an increase in intermodal activity. This results from cleaner engines and 

fuel as mandated by EPA. 

In 2025, the forecast of pollutant burdens on the Alternative 2 roadway system display virtually 

no difference, compared to taking no action, even as the intermodal activity would increase. That 

condition exists because both roadway systems carry the same background traffic while DIFT 

truck traffic is a relatively small contributor to total traffic and total pollution burden. The only 

exception to this is when Lonyo is closed, auto and non-DIFT truck traffic is diverted, in part, to 

Central Avenue. Under Alternative 2, there are few business relocations in the area served by 

these streets. As a result, the pollution burdens generated by auto/truck traffic are expected to 

increase on Central between John Kronk and St. Stephen Streets in 2025 by about 150 pounds per 

year for NOx compared to the 2025 No Action Alternative; by about 20 pounds per year for 

PM10; and, by about ten pounds per year for PM2.5. The change in the air toxics burden generated 

by auto/truck traffic on Central Avenue between Alternative 2 and the No Action condition in 

2025 is expected to be about ten pounds annually. The section of Central Avenue under the 

terminal would have equipment to vent the air directly above the terminal. These increases in 

pollutants just noted for Central Avenue are forecast to be matched by decreases along Lonyo. 

To gauge the level of these air toxic burdens, it is noted that the natural gas burned in 15 homes to 

run the furnace and hot water heater generates ten pounds of air toxics annually.34 

Alternatives 3 and 4 would have the greatest number of lifts and the greatest number of trucks 

serving those lifts. Nevertheless, the pollutant burden on the local roadway systems around the 

terminals would be slightly less than the No Action Alternative. The expansion of the LivernoisJunction Yard would require the relocation of a number of businesses, including several along 

John Kronk. The removal of the auto and truck trips of these businesses, and the more efficient 

movement of intermodal trucks to the terminal via expressway-to-arterial roadway connections 

would mean less traffic on several neighborhood streets. So, for Alternatives 3 and 4, the 

roadway pollutant burdens would be less than today, and slightly less than the No Action. For the 

CN/Moterm terminal, the roadway pollutant burdens would be virtually the same as No Action. 

Increased intermodal activity will shift freight from truck to rail. This would reduce truck 

mileage and pollution. The expected reductions in Wayne County, alone, and in the seven-county 

SEMCOG region are presented at the bottom of Table 4-22b. 

 

34 Derived from data in U.S. EPA’s AP-42, Compilation of Air Pollution Emission factors for natural gas combustion. 

Emissions are based on an average home natural gas use rate of 75,000 Btu/hr. for six months of the year. 
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4.8.6 CO Hot-spot Analysis 

Carbon monoxide is a colorless, odorless, poisonous gas produced by incomplete combustion. 

Due to the air quality maintenance status of Southeast Michigan with respect to the NAAQS for 

CO, a carbon monoxide hotspot analysis was performed. The analysis compared estimated 

worst-case CO concentrations at sensitive receptors near a dozen intersections around the 

terminals to the one- and eight-hour NAAQS (Table 4-25). Sensitive receptors are locations 

where humans might be expected to be present. 

Table 4-25 

Worst Case CO Concentrations 

One-hour 

Worst-case Values (Standard is 35 ppm) 

Term. Intersection 2004 2015 2025 Receptor Ambient 

(ppm) Result Alternative Result Alternative Result 

Liv-Jct Wyoming @ Mercier SE corner 3.8 4.5 Alt. 3 4.5 Alt. 3 4.5 

Liv-Jct Wyoming @ I-94 off ramp NW corner 3.8 5.1 Alt. 3 5.1 Alt. 3 4.8 

Liv-Jct Lonyo @ Arnold SW corner 3.8 5.3 Alt. 1 4.5 Alt. 2 4.5 

Liv-Jct Central @ St. Stephen NE corner 3.8 6.0 Alt. 1 5.1 Alt. 2 5.0 

Liv-Jct Central @ Dix NE corner 3.8 5.3 Alt. 1 4.5 Alt. 1 4.6 

Liv-Jct Livernois @ Kronk NW corner 3.8 5.7 Alt. 3 5.2 Alt. 3 5.2 

Liv-Jct Livernois @ Lafayette NE corner 3.8 4.6 Alt. 1 4.1 Alt. 1 4.1 

Liv-Jct Dragoon @ Lafayette NE corner 3.8 4.6 Alt. 1 4.1 Alt. 1 4.1 

Express. Michigan @ 14th SW corner 3.8 5.7 Alt. 4 4.9 Alt. 2 5.0 

Express. 14th @ Maranette SW corner 3.8 4.1 Alt. 4 3.7 Alt. 2 3.8 

Oak Evergreen @ I-96 Ramps NW corner 4.0 8.7 Alt. 2 6.6 Alt. 2 6.4 

Moterm Eight Mile @ Fair Street NW corner 4.0 5.9 Alt. 4 5.5 Alt. 2 5.4 

Eight-hour 

Worst-case Values (Standard is 9 ppm) 

Term. Intersection Receptor 2004 2015 2025 

Ambient 

(ppm) Result Alternative Result Alternative Result 

Liv-Jct Wyoming @ Mercier SE corner 2.3 2.8 Alt. 3 2.8 Alt. 3 2.8 

Liv-Jct Wyoming @ I-94 off ramp NW corner 2.3 3.2 Alt. 3 3.2 Alt. 3 3.0 

Liv-Jct Lonyo @ Arnold SW corner 2.3 3.3 Alt. 1 2.8 Alt. 2 2.8 

Liv-Jct Central @ St. Stephen NE corner 2.3 3.7 Alt. 1 3.2 Alt. 2 3.1 

Liv-Jct Central @ Dix NE corner 2.3 3.3 Alt. 1 2.8 Alt. 1 2.9 

Liv-Jct Livernois @ Kronk NW corner 2.3 3.5 Alt. 3 3.2 Alt. 3 3.2 

Liv-Jct Livernois @ Lafayette NE corner 2.3 2.9 Alt. 1 2.5 Alt. 1 2.5 

Liv-Jct Dragoon @ Lafayette NE corner 2.3 2.9 Alt. 1 2.5 Alt. 1 2.5 

Express. Michigan @ 14th SW corner 2.3 3.5 Alt. 4 3.0 Alt. 2 3.1 

Express. 14th @ Maranette SW corner 2.3 2.5 Alt. 4 2.3 Alt. 2 2.4 

Oak Evergreen @ I-96 Ramps NW corner 2.6 5.4 Alt. 2 4.1 Alt. 2 4.0 

Moterm Eight Mile @ Fair Street NW corner 2.6 3.7 Alt. 4 3.4 Alt. 2 3.3 

Notes: 1-hr background concentrations (3.8 & 4.0 ppm) are the 2nd highest 1-hour values recorded at the Detroit Linwood (26-

1630016) & Oak Park (26-125-0001) stations, respectively in 2002. The 8-hr background concentrations (2.3 & 2.6 ppm) are the 2nd 

highest 8-hour values recorded at these stations. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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This analysis is done with a computer program called CAL3QHC. It requires emission factors for 

various types of vehicles operating under various speeds and conditions (such as ambient 

temperature and fuel type), expressed in grams per mile. These emission factors are generated 

using the U.S. EPA-approved model, MOBILE6.2. Input parameters that go into the 

MOBILE6.2 model, such as the vehicle fleet mix and age, are drawn from SEMCOG in 

consultation with EPA and the Michigan Department of Environmental Quality (MDEQ). Traffic 

information for each alternative, along with information about roadway geometry and traffic flow 

conditions, are also used to determine the concentrations of CO at these sensitive receptors. 

The highest one-hour and eight-hour CO concentrations are found on Evergreen Road at the 

CP/Oak terminal. This is true for 2004, 2015 and 2025. Estimates of one-hour CO 

concentrations for these years are 8.7, 6.6, and 6.4 ppm, respectively. The EPA standard is 35 

ppm. Eight-hour values are 5.4, 4.1, and 4.0 ppm, respectively, compared to the standard of 9 

ppm. All these values are well below standards. Conditions at all other intersections on Table 

4-25 in all years under all scenarios are better. 

4.8.7 FEIS Preferred Alternative Air Quality Analysis 

This air quality section covers the analysis for the FEIS. Since the Air Quality Protocol 

(Appendix E) was developed, analysis methodologies have changed. This analysis for the FEIS 

reflects updates in intermodal activity for the No Action and Preferred Alternatives, as well as 

updates to monitor data and emission factors. Since the project began, the Southeast Michigan 

Council of Governments (SEMCOG) has updated the horizon year of its Regional Transportation 

Plan (RTP) to 2030. 

The updated air quality analysis was not done for the DEIS Build alternatives, because the 

Preferred Alternative represents what the railroads have agreed to. So, the earlier Practical 

Alternatives are no longer considered practical and updating data to 2030 is not fruitful as the air 

quality analysis was not a determining factor in the decision-making process that arrived at the 

Preferred Alternative. 

The air quality scope and methodology used in this FEIS are consistent with current guidance 

from the Federal Highway Administration (FHWA) and MDOT. Additional interagency 

consultation was held with the Southeast Michigan Council of Governments (SEMCOG), the 

U.S. Environmental Protection Agency (EPA) Region 5, and the Michigan Department of 

Environmental Quality (MDEQ). This air quality analysis covers the following topics: 

 1. An explanation of recent steps to improve air quality and past and future trend data; 

 2. A comparative analysis of the air quality effects of the Preferred and No Action 

Alternatives consistent with the National Environmental Policy Act (it covers 

terminal area and roadway pollutant burdens); 

 3. A quantitative analysis of Mobile Source Air Toxics (MSATs) consistent with the 

Interim Guidance on Air Toxics in NEPA Documents (FHWA, February 3, 2006) 

(terminal area and roadway); 

 4. The SEMCOG region’s attainment status with respect to air quality standards and 

analyses that show project conformity to the Clean Air Act. Conformity analysis 

covers: 

− General conformity (as applicable; see 40 CFR 93.153(b)); and, 

− Transportation conformity. Project-level conformity determinations must meet 

several criteria (see 40 CFR 93.109(b)), including: 
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− Regional analysis: ozone, carbon monoxide (CO), and particulate matter 

(PM2.5 and PM10) as demonstrated by the project coming from a currently 

conforming transportation plan and Transportation Improvement Program 

(TIP); and, 

− Hot-spot conformity (40 CFR 93.123 (b)(iii)): 

• CO (quantitative) 

• PM2.5 (qualitative) 

• PM10 (qualitative) 

 5. Construction impacts. 

With respect to global warming, to date no national standards have been established regarding 

greenhouse gases, nor has EPA established criteria or thresholds for greenhouse gas emissions. 

But, on April 2, 2007, the Supreme Court issued a decision in Massachusetts et al. v. 

Environmental Protection Agency et al. that the USEPA does have authority under the Clean Air 

Act to establish motor vehicle emissions standards for carbon dioxide CO2 emissions. Carbon 

dioxide (CO2) is a primary greenhouse gas. The USEPA is currently determining the 

implications of the Supreme Court decision on national policies and programs. However, the 

Court’s decision did not have any direct implications on requirements for evaluating 

transportation projects. Further, because of the interactions among elements of the transportation 

system as a whole, project-level emissions analyses for greenhouse gases are less informative 

than those conducted at the regional, state, or national level. Because of these concerns, FHWA 

concludes that CO2 emissions cannot be usefully evaluated in this EIS in the same way as other 

vehicle emissions. 

With respect to health impacts, the “Interim Guidance on Air Toxics in NEPA Documents” 

(FHWA, February 3, 2006) indicates that presently there is not adequate science to reliably 

include exposure modeling or risk assessment in the air quality analysis. The Interim Guidance 

explains that: 

• Modeling tools to generate air pollution emissions cannot be properly used at the project 

level because they are based on certain assumptions with regard to trip length and 

amounts of congestion and were based on a limited number of tests of mostly older 

vehicles. 

• Dispersion models that would indicate how much particulate matter and air toxics are in 

the air were developed to deal with carbon monoxide, which is relatively non-reactive, 

and their intent was to determine maximum, not more typical levels. Further, little is 

known about background pollution levels in many areas. 

• Even if emission levels and concentrations could be estimated, exposure assessment and 

risk analysis have their own shortcomings, due to extrapolation to annual levels, for 

example, let alone multiple years. 

The conclusion of these analyses is that the project has been found to conform to the Clean Air 

Act. The turnover in the vehicle fleet to newer vehicles using cleaner fuels means air quality will 

improve. MDOT will work to minimize air pollution during construction and the railroads are 

committed to reducing emissions in yard operations. See the Green Sheet at the end of Section 5. 

4.8.7.1 Recent EPA Actions and NAAQS Pollutant Trends 

This information has not changed from the DEIS, except for updated monitor data related to 

particulates, which is presented subsequently in the particulate hot-spot analyses. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4.8.7.2 No Action and Preferred Alternative Pollutant Burdens 

To maintain consistency with the analysis performed for the DEIS, comparisons are made here 

among the amount of pollution produced on the roadway system around the Livernois-Junction 

Yard in 2004, in 2015 (midway through the DIFT construction period of 2010 to 2020), and in 

the project design year of 2030. Likewise, estimates are made for those years of the amount of air 

pollution produced within the Livernois-Junction Yard by intermodal operations. To allow for a 

reasonable comparison, data for the existing Delray and Triple Crown operations, though not yet 

part of the Livernois-Junction Yard, are treated as if they were. This approach is consistent with 

the requirements of 40 CFR 1502.22 and 1502.24. 

4.8.7.2.1 Terminal Area Pollutant Burden Forecasts 

For the DEIS, an area was defined that covered the existing yard and any area of potential 

terminal expansion (Figure 4-40). Within these areas, the total pollution emitted was calculated 

in tons per year for 2004, 2015, and 2025 for each alternative. For this FEIS, data are provided 

only for build and no-build conditions for 2004, 2015 and 2030 at the Livernois-Junction Yard. 

The pollution burden analysis addresses: 

• Visitor and employee traffic on the rail yard. 

• Truck activity on the rail yard related to container delivery and pickup. 

• Container handling on the yard - moving containers between delivery points and 

trains. 

• Locomotive idling and movement on the yard. 

• Fugitive dust from paved and unpaved yard areas. 

• Vehicular travel on sites of businesses to be acquired. 

• Vehicular travel on streets that would be inside the terminal with project 

development – John Kronk and a section of Lonyo. 

• Fugitive dust from business sites and the public streets that would be closed by virtue 

of the proposed expansion. 

The terminal burden forecasts of the Preferred Alternative are presented in Table 4-26a for 2015 

and 2030. Existing (2004) and 2015 and 2030 No Action data are shown for comparison. 

Forecasts for the Preferred Alternative show higher values for NOx and VOCs than No Action 

due to increased intermodal activity. Particulate matter is substantially reduced as the Preferred 

Alternative paves the Livernois-Junction Yard. 

Increased intermodal activity will shift freight from trucks to rail. This would reduce mileage and 

pollution. The expected reduction for Wayne County and the seven-county SEMCOG region is 

presented in Table 4-26b. These reductions exceed the NOx and VOC higher values noted in the 

above paragraph. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-26a 

Detroit Intermodal Freight Terminal Study 

FEIS Terminal Burdens – Annual Tons 

 CO NOx PM10 PM2.5a VOCs 

2004 

SW Detroit/E Dearborn 41.3 93.9 177.3 43.5 7.1 

2015 No Action 

SW Detroit/E Dearbornb 29.6 46.0 155.0 26.0 3.9 

2015 Preferred Alternative 

SW Detroit/E Dearbornb 10.8 33.6 50.9 8.8 4.8 

2030 No Action 

SW Detroit/E Dearbornb 17.1 16.7 245.0 30.9 3.6 

2030 Preferred Alternative 

SW Detroit/E Dearbornb 13.7 29.1 92.0 14.9 6.6 

a EPA detected an error in its MOBILE6.2 emission factor computer program. That factor has been 

corrected for this table in this FEIS. Note: VOCs are volatile organic compounds. b

 Includes the lift activity now dispersed among the Livernois-Junction Yard, Delray and Triple Crown 

terminals. 

Source: The Corradino Group of Michigan, Inc.

Table 4-26b 

Detroit Intermodal Freight Terminal Study 

Reduction of Pollutants Due to Truck-to-Rail Diversion for Each Action Alternative 

 CO NOx PM10 PM2.5 VOCs 

In Wayne Co. 

Totals 17.8 33.8 3.0 1.7 15.9 

In Southeast Michigan 

Totals 48.7 128.9 11.8 6.7 37.2 

Source: The Corradino Group of Michigan, Inc. 

4.8.7.2.2 Public Roadway Pollutant Burden Forecasts 

A network of local roads near each terminal that could be influenced by the project was identified 

for the DEIS and now the FEIS (Figure 4-48). These are roads that would: 1) be used by new 

DIFT traffic; 2) have traffic changes due to the closure of Lonyo; 3) experience changes in auto 

and truck traffic as businesses are relocated to accommodate terminal development; or, 

4) experience changes in truck traffic due to gate changes. 

The traffic changes resulting from the Preferred Alternative are summarized as follows: 

• On Livernois: 1) the existing gate to the Livernois-Junction Yard will be retained, 

but will be constructed so trucks cannot enter from or leave to Livernois south of the 

terminal; 2) the existing gate of Dix/Waterman will be closed; and 3) a new gate will 

be fed via Kronk from Livernois (see Figure 3-19). 

• The balance of Kronk will be removed and a perimeter road will be put in its place 

designed to discourage truck traffic. 

• Two new gates will be built to serve the terminal from Wyoming. 

• Lonyo will be closed through the terminal and Central Avenue will be gradeseparated, passing under the terminal and carrying the Lonyo traffic, as well. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Traffic shifts were calculated, with new intermodal truck traffic added, and traffic from displaced 

businesses removed. The vehicle miles of travel were calculated by link, using traffic volumes 

and link lengths, and, using estimated speeds, the pollutant burden for each link was calculated. 

Table 4-27 shows the results for autos and trucks. The auto component of local road traffic 

produced the majority of the pollution, due to the much greater number of cars than trucks on the 

roadway system, particularly CO and VOCs. Trucks produce far more NOx per vehicle. 

Nonetheless, even for NOx and particulates, in 2030, no more than 20 percent of the auto plus 

truck total is produced on the public road network by trucks. 

It is noted that the methodologies in the MOBILE model limit the value of these results in terms 

of absolute numbers, but the data do provide a means of comparing links under build and nobuild scenarios. Auto plus truck burden totals are lower with the Preferred Alternative than the 

no action condition in both 2015 and 2030. 

The Preferred Alternative would direct DIFT truck traffic to two gates accessed from Wyoming 

Avenue and two from Livernois Avenue. (See Table 4-28 for truck traffic on links near the 

Livernois-Junction Yard with and without the project.) Access to the Wyoming gates is expected 

to be predominantly from I-94 and access to the Livernois gate is expected to be almost 

exclusively from I-94. This pattern moves the roadway air quality pollutant burden away from 

residential areas (Table 4-29). Combined with the lower emission factors in the future, the 

pollutant burdens on roadway links near the Livernois-Junction Yard will go down in the future 

(2015 and 2030) from base year (2004) levels and will generally be slightly less than No Action 

Alternative values (Table 4-29). 

The number of trucks on Wyoming south towards Dix will increase with the Preferred Alternative 

in 2015 relative to the No Action Alternative by 146 vehicles (see Table 4-28). This is a concern 

due to the presence near Wyoming Avenue of an air quality monitoring site. However, with the 

background cars and trucks, the annual PM2.5 value for 2015 for build and no build alternatives is 

the same, 0.06 tons per year (see Table 4-29) and half the 2004 value of 0.13 tons per year. 

Table 4-27 

Detroit Intermodal Freight Terminal Study 

FEIS Public Roadway Pollutant Burden

Livernois-Junction Yarda

Auto Truck Auto Plus Truck 

Tons Per Year Tons Per Year Tons Per Year 

CO NOx PM10 PM2.5 VOC CO NOx PM10 PM2.5 VOC CO NOx PM10 PM2.5 VOC 

 

2004 607.1 33.9 0.88 0.43 40.2 9.1 35.5 1.28 1.10 1.96 616.2 69.5 2.16 1.53 42.1 

2015 No 

Action 367.7 12.7 0.75 0.42 15.3 2.7 9.6 0.40 0.25 1.16 370.4 22.3 1.15 0.68 16.4 

2015 

Preferred 358.7 12.4 0.73 0.41 14.9 2.2 8.3 0.35 0.22 0.98 360.9 20.7 1.08 0.63 15.9 

2030 No 

Action 333.1 8.6 1.00 0.46 10.9 0.9 2.0 0.22 0.11 1.03 334.1 10.6 1.23 0.57 12.0 

2030 

Preferred 326.7 8.4 0.98 0.45 10.6 0.9 2.0 0.23 0.11 1.00 327.6 10.4 1.21 0.56 11.6 a

 The values in this table do not include CP/Expressway as that operation closed in June 2004. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-28 

Detroit Intermodal Freight Terminal Study 

Truck Volumes – Preferred Alternative and No Actiona 

 2004 2015 2030 

Build 

minus No 

Action 

Road Segment 

No 

Action Pref 

No 

Action Pref 2015 2030 

Liv-Junc Yard From To 

Wyoming Dix New Gate 1350 1499 1644 1634 2016 146 382 

 New Gate Kronk 1534 1703 2586 1856 3684 883 1828 

 Kronk I-94 Ramp 1360 1510 2128 1646 3209 619 1564 

 I-94 Ramp Michigan 1304 1447 2066 1578 3141 619 1564 

Lonyo Michigan Kronk 780 866 862 944 940 -4 -4 

 Kronk Dix 696 773 0 842 0 -773 -842 

Central Michigan Kronk 1024 1137 895 1239 998 -241 -241 

 Kronk Dix 955 1060 970 1156 1066 -90 -90 

Perimeter Rd Lonyo Central 0 0 431 0 470 431 470 

Livernois Michigan Exist. Gate 2275 2548 2552 2801 3433 4 633 

 Exist. Gate Dix 2420 2740 1749 3041 1927 -992 

-

1114 

 Dix I-75 1081 1226 618 1364 694 -609 -670 

Dragoon Dix I-75 968 1101 492 1227 557 -609 -670 

Kronk Wyoming Lonyo 300 333 0 363 0 -333 -363 

 Lonyo Central 239 265 0 289 0 -265 -289 

 Central Livernois 238 264 301 288 580 37 292 a

 To project Preferred Alternative traffic to 2030, background traffic was grown at 1% a year until 2025 then 0% a year 

to 2030. Intermodal traffic was based on lifts growth. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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2004 2004 2004 

 No Act. Pref No Act. Pref No Act. Pref No Act. Pref No Act. Pref No A

Livernois Junction From ToWyoming Dix New Gate 57.0 34.2 33.9 29.6 29.4 5.83 1.89 1.95 0.91 0.95 0.18 0.10 0.10 

New Gate Kronk 38.9 23.3 23.2 20.2 19.9 3.97 1.29 1.54 0.62 0.72 0.12 0.07 0.08 Kronk I-94 Ramp 34.5 20.6 20.3 17.9 17.6 3.52 1.14 1.31 0.55 0.63 0.11 0.06 0.07 

I-94 Ramp Michigan 33.1 19.8 19.5 17.2 16.9 3.38 1.09 1.26 0.53 0.61 0.11 0.06 0.07 

Lonyo Michigan Kronk 53.1 32.1 25.7 30.8 24.6 5.72 1.84 1.62 0.94 0.78 0.17 0.09 0.08 

Kronk Dix 23.7 14.3 0.0 13.7 0.0 2.55 0.82 0.00 0.42 0.00 0.08 0.04 0.00 

Central Michigan Kronk 61.0 36.8 41.8 35.4 40.3 6.57 2.12 2.12 1.08 1.17 0.20 0.11 0.11 

Kronk Dix 32.5 19.6 33.7 18.9 32.5 3.50 1.13 1.59 0.57 0.91 0.10 0.06 0.08 

Perimeter Rd Lonyo Central 0.0 0.0 16.0 0.0 15.4 0.00 0.00 0.78 0.00 0.44 0.00 0.00 0.04 

Livernois Michigan Exist. Gate 88.4 52.9 52.2 45.8 45.3 10.33 3.28 3.26 1.49 1.55 0.33 0.17 0.17 

Exist. Gate Dix 89.9 54.0 53.4 46.8 46.4 10.97 3.51 2.90 1.58 1.44 0.35 0.18 0.15 

Dix I-75 30.7 18.5 17.9 17.7 17.3 4.53 1.41 1.01 0.61 0.52 0.14 0.07 0.05 

Dragoon Dix I-75 33.3 20.0 19.5 19.2 18.8 4.39 1.39 0.99 0.64 0.55 0.14 0.07 0.05 

Kronk Wyoming Lonyo 20.2 12.1 0.0 10.5 0.0 2.11 0.69 0.00 0.33 0.00 0.07 0.04 0.00 

Lonyo Central 6.0 3.6 0.0 3.1 0.0 0.63 0.20 0.00 0.10 0.00 0.02 0.01 0.00 Central Livernois 14.0 8.5 3.8 7.3 3.3 1.47 0.48 0.34 0.23 0.16 0.05 0.03 0.02 

Totals 616.2 370.4 360.9 334.1 327.6 69.47 22.26 20.67 10.61 10.43 2.16 1.15 1.08 

2015 2030 2015 2030

2015 

Carbon Monoxide NOx PM10 

 Source: The Corradino Group of Michigan, Inc.
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluatio

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DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Preferred Alternative – Summary of Terminal and Roadway Burden

At the Livernois-Junction Yard, the Preferred Alternative would reduce the levels of NAAQS 

pollutants relative to No Action conditions in 2015 for all but VOC, which would be almost 

unchanged (Table 4-30). This is true in spite of including the CN/Oak intermodal operation at the 

Livernois-Junction Yard. In 2030, pollutants would remain lower than the No Action Alternative 

with the Preferred Alternative except for NOx and VOC. In those cases, the increases for the No 

Action Alternative would be more than offset at the Wayne County and regional levels. 

Particulate matter would be substantially reduced. 

Table 4-30 

Detroit Intermodal Freight Terminal Study 

Summary of Pollutant Burden Analysis – NAAQS 

Livernois-Junction Terminal 

 

Terminal Burden 

Carbon 

Monoxide NOx PM10 PM2.5 VOC 

2004 41.3 93.9 177.3 43.5 7.1 

2015 NA 29.6 46.0 155.0 26.0 3.9 

2015 Pref 10.8 33.6 50.9 8.8 4.8 

2030 NA 17.1 16.7 245.0 30.9 3.6 

2030 Pref 13.7 29.1 92.0 14.9 6.6 

Roads 

2004 616.2 69.5 2.2 1.5 42.1 

2015 NA 370.4 22.3 1.2 0.7 16.4 

2015 Pref 360.9 20.7 1.1 0.6 15.9 

2030 NA 334.1 10.6 1.2 0.6 12.0 

2030 Pref 327.6 10.4 1.2 0.6 11.6 

Totals 

2004 657.5 163.4 179.5 45.0 49.2 

2015 NA 400.0 68.3 156.2 26.7 20.3 

2015 Pref 371.7 54.3 52.0 9.4 20.7 

2030 NA 351.2 27.3 246.2 31.5 15.6 

2030 Pref 341.3 39.5 93.2 15.5 18.2 

Regional Reductions 

2025 Wayne Co. 17.8 33.8 3.0 1.7 15.9 

2025 SE Michigan 48.7 128.9 11.8 6.7 37.2 

Source: The Corradino Group of Michigan, Inc. 

4.8.7.3 Mobile Source Air Toxics (MSATS) – Quantitative Analysis 

This mobile source air toxic (MSAT) analysis is based on the Interim Guidance on Air Toxics in 

NEPA Documents (FHWA, February 3, 2006). MSAT was neither required, nor done for the 

DEIS. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4.8.7.3.1 Guidance and Trends 

In addition to the criteria air pollutants for which there are National Ambient Air Quality 

Standards (NAAQS), EPA regulates air toxics. Most originate from human-produced sources, 

including use of on-road mobile sources, non-road mobile sources (e.g., airplanes), area sources 

(e.g., dry cleaners) and stationary sources (e.g., factories and refineries). 

Mobile Source Air Toxics (MSATs) are a subset of the 188 air toxics defined by the Clean Air 

Act. The MSATs are compounds emitted from highway vehicles and non-road equipment. Some 

toxic compounds are present in fuel and are emitted to the air when the fuel evaporates or passes 

through the engine unburned. Other toxics are emitted from the incomplete combustion of fuels, 

as secondary combustion products, and from brake and tire wear. Metal air toxics also result from 

engine wear or from impurities in oil or gasoline. 

EPA is the lead federal agency for administering the Clean Air Act and has certain 

responsibilities regarding the health effects of MSATs. The Agency issued a Final Rule on 

Controlling Emissions of Hazardous Air Pollutants from Mobile Sources (66 FR 17229, March 

29, 2001) under the authority in Section 202 of the Clean Air Act. In its rule, EPA examined the 

impacts of existing and newly-promulgated mobile source control programs, including its: 

1) reformulated gasoline (RFG) program; 2) national low-emission vehicle (NLEV) standards; 

3) Tier 2 motor vehicle emissions standards and gasoline sulfur control requirements; and, 

4) proposed heavy-duty engine and vehicle standards and on-highway diesel fuel sulfur control 

requirements. Between 2000 and 2020, FHWA projects that even with a 64 percent increase in 

VMT (national average), these programs will result in reductions of on-highway emissions of 

benzene, formaldehyde, 1,3-butadiene, and acetaldehyde ranging from 57 percent to 65 percent, 

and will reduce on-highway diesel PM emissions by 87 percent, as shown in Figure 4-49. (It is 

noted that in this time frame VMT growth in the SEMCOG region will be substantially less, so 

MSATs reductions in the region will be even greater than this national example.) 

In February 2007, EPA finalized a rule to reduce hazardous air pollutants from mobile sources 

(Control of Hazardous Air Pollutants from Mobile Sources, February 9, 2007). The rule will limit 

the benzene content of gasoline and reduce toxic emissions from passenger vehicles and portable 

gas cans. EPA estimates that in 2030 this rule would reduce total emissions of mobile source air 

toxics by 330,000 tons and VOC emissions (precursors to ozone and PM2.5) by over 1 million 

tons. 

As a result of the analysis performed, EPA concluded that no further motor vehicle emissions 

standards or fuel standards were necessary to control MSATs. The agency is preparing another 

rule under authority of the Clean Air Act, Section 202(l) that will address these issues and could 

make adjustments to the full 21 and the primary six MSATs. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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This DIFT analysis follows the Interim Guidance on Air Toxic Analysis in NEPA Documents

(FHWA, February 3, 2006). It includes a basic analysis of the likely MSAT emission impacts. 

The DIFT project is being treated as a Tier 3 “Project with Higher Potential MSAT Effects” 

under that guidance because it will “create or significantly alter a major intermodal freight facility 

that has the potential to concentrate high levels of diesel particulate matter in a single location 

... .” 

Available technical tools do not enable a prediction of the project-specific health impacts of the 

emission changes associated with the Preferred Alternative. Due to these limitations, the 

following discussion is included in accordance with Council of Environmental Quality (CEQ) 

regulations (40 CFR 1502.22(b)) regarding incomplete or unavailable information: 

Information that is Unavailable or Incomplete – Evaluating the environmental and health 

impacts from MSATs on a proposed project would involve several key elements including: 

1) emissions modeling; 2) dispersion modeling, in order to estimate ambient concentrations 

resulting from the estimated emissions; 3) exposure modeling, in order to estimate human 

exposure to the estimated concentrations; and, then, 4) final determination of health impacts 

based on the estimated exposure. Each of these steps is encumbered by technical shortcomings or 

uncertain science that prevent a more complete determination of the MSAT health impacts of this 

project. 

− Emissions. The EPA tools to estimate MSAT emissions from motor vehicles are not 

sensitive to key variables determining these emissions in the context of highway 

projects. While MOBILE6.2 is used to predict emissions at a regional level, it has 

Figure 4-49 

Detroit Intermodal Freight Terminal Study 

U.S. Annual Vehicle Miles Traveled (VMT) vs. MSAT Emissions 

2000-2020 

Notes: For on-road mobile sources emissions factors were generated using MOBILE6.2. The MTBE proportion of the market 

for oxygenates is held constant at 50%. Gasoline RVP and oxygenate content are held constant. VMT is drawn from 

“Highway Statistics 2000,” Table VM-2 for 2000. Analysis assumes an annual national growth rate of 2.5%. "DPM + 

DEOG" is based on MOBILE6.2-generated factors for elemental carbon, organic carbon and SO4 from diesel-powered 

vehicles, with the particle size cutoff set at 10.0 microns. 

Source: FHWA 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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limited applicability at the project level. MOBILE6.2 is a trip-based model with 

emission factor projections based on a typical trip of 7.5 miles, and on average 

speeds for this typical trip. This means that MOBILE6.2 does not have the ability to 

predict emission factors for a specific vehicle operating condition at a specific 

location at a specific time. Because of this limitation, MOBILE6.2 can only 

approximate the operating speeds and levels of congestion likely to be present on the 

largest-scale projects, and cannot adequately capture emissions effects of smaller 

projects. For particulate matter, the model results are not sensitive to average trip 

speed, although the other MSAT emission rates do change with changes in trip speed. 

Also, the emissions rates used in MOBILE6.2, for both particulate matter and 

MSATs, are based on a limited number of tests of mostly older-technology vehicles. 

Lastly, in its discussions of PM under the conformity rule, EPA has identified 

problems with MOBILE6.2 as an obstacle to quantitative analysis. 

These deficiencies compromise the capability of MOBILE6.2 to estimate MSAT 

emissions. So, while MOBILE6.2 is an adequate tool for projecting emissions trends, 

and performing relative analyses among alternatives for very large projects, it is not 

sensitive enough to capture the effects of travel changes tied to smaller projects or to 

predict emissions near specific roadside locations. 

− Dispersion. The tools to predict how MSATs disperse are also limited. EPA's current 

regulatory models, CALINE3 and CAL3QHC, were developed and validated more 

than a decade ago for the purpose of predicting episodic concentrations of carbon 

monoxide to determine compliance with the NAAQS. The performance of dispersion 

models is more accurate for predicting maximum concentrations that can occur at 

some time at some location within a geographic area. This limitation makes it 

difficult to predict accurate exposure patterns at specific times at specific highway 

project locations across an urban area in order to assess potential health risk. Along 

with these general limitations of dispersion models, FHWA is also faced with a lack 

of monitoring data in most areas for use in establishing project-specific MSAT 

background concentrations. The National Cooperative Highway Research Program 

(NCHRP) is conducting research on best practices in applying models and other 

technical methods in the analysis of MSATs. This work also focuses on identifying 

appropriate methods of documenting and communicating MSAT impacts in the 

NEPA process and to the general public. But, the products are not available for use 

here. 

− Exposure Levels and Health Effects. Finally, even if emission levels and 

concentrations of MSATs could be accurately predicted, shortcomings in current 

techniques for exposure assessment and risk analysis preclude reaching meaningful 

conclusions about project-specific health impacts. Exposure assessments are difficult 

because it is difficult to accurately calculate annual concentrations of MSATs near 

roadways, and to determine the portion of a year that people are actually exposed to 

those concentrations at a specific location. These difficulties are magnified for 70-

year cancer assessments, particularly because unsupportable assumptions would have 

to be made regarding changes in travel patterns and vehicle technology (which 

affects emissions rates) over a 70-year period. There are also considerable 

uncertainties associated with the existing estimates of toxicity of the various MSATs, 

because of factors such as low-dose extrapolation and translation of occupational 

exposure data to the general population. Because of these shortcomings, any 

calculated difference in health impacts between alternatives is likely to be much 

smaller than the uncertainties associated with calculating the impacts. Consequently, 

the results of such assessments would not be useful to decision makers, who would 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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need to weigh this information against other project impacts that are better suited for 

quantitative analysis. 

Summary of Existing Credible Scientific Evidence Relevant to Evaluating the Impacts of 

MSATs – Research into the health impacts of MSATs is ongoing. For different emission types, 

there are a variety of studies that show that some either are statistically associated with adverse 

health outcomes through epidemiological studies (frequently based on emissions levels found in 

occupational settings) or that animals demonstrate adverse health outcomes when exposed to 

large doses. 

Exposure to toxics has been a focus of a number of EPA efforts. Most notably, the agency 

conducted the National Air Toxics Assessment (NATA) in 1996 to evaluate modeled estimates of 

human exposure applicable to the county level. While not intended for use as a measure of or 

benchmark for local exposure, the modeled estimates in the NATA database best illustrate the 

levels of various toxics when aggregated to a national or state level. 

EPA is in the process of assessing the risks of various kinds of exposures to these pollutants. 

EPA’s Integrated Risk Information System (IRIS) is a database of human health effects that may 

result from exposure to various substances found in the environment. IRIS is located at 

http://www.epa.gov/iris. The following toxicity information for the six prioritized MSATs was 

taken verbatim from the IRIS “Weight-of-Evidence Characterization” summaries and represents 

FHWA's most-current evaluations of the potential hazards and toxicology of these chemicals or 

mixtures. 

− Benzene is characterized as a known human carcinogen. 

− The potential carcinogenicity of acrolein cannot be determined because the existing 

data are inadequate for an assessment of human carcinogenic potential for either the 

oral or inhalation route of exposure. 

− Formaldehyde is a probable human carcinogen, based on limited evidence in 

humans, and sufficient evidence in animals. 

− 1,3-butadiene is characterized as carcinogenic to humans by inhalation. 

− Acetaldehyde is a probable human carcinogen based on increased incidence of nasal 

tumors in male and female rats and laryngeal tumors in male and female hamsters 

after inhalation exposure. 

− Diesel exhaust (DE) is likely to be carcinogenic to humans by inhalation from 

environmental exposures. Diesel exhaust as reviewed in this document is the 

combination of diesel particulate matter and diesel exhaust organic gases. 

− Diesel exhaust also represents chronic respiratory effects, possibly the primary 

noncancer hazard from MSATs. Prolonged exposures may impair pulmonary 

function and could produce symptoms, such as cough, phlegm, and chronic 

bronchitis. Exposure relationships have not been developed from these studies. 
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Relevance of Unavailable or Incomplete Information to Evaluating Reasonably Foreseeable 

Significant Adverse Impacts on the Environment, and Evaluation of Impacts Based upon 

Theoretical Approaches or Research Methods Generally Accepted in the Scientific 

Community – Because of the uncertainties outlined above, a quantitative assessment of the 

effects of air toxic emissions impacts on human health cannot be made at the project level. While 

available tools do allow the reasonable prediction of relative emissions changes among 

alternatives for larger projects, the amount of MSAT emissions from each of the project 

alternatives, and MSAT concentrations or exposures created by each of the project alternatives, 

cannot be predicted with enough accuracy to be useful in estimating health impacts. (As noted 

above, the current emissions model is not capable of serving as a meaningful emissions analysis 

tool for smaller projects.) Therefore, the relevance of the unavailable or incomplete information is 

that it is not possible to make a determination of whether any of the alternatives would have 

"significant adverse impacts on the human environment." 

A quantitative analysis of MSAT emissions relative to the various alternatives is presented in 

Section 4.8.3.3 of this report. It acknowledges that the build alternatives may shift exposure to 

MSAT emissions in certain locations, but the concentrations and duration of exposures are 

uncertain, and because of this uncertainty, the health effects from these emissions cannot be 

estimated. 

4.8.7.3.2 Other Studies 

Some recent studies have addressed MSAT health impacts in proximity to roadways. For 

example, the Health Effects Institute, a non-profit organization funded by EPA, FHWA, and 

industry, has undertaken a major series of studies to research near-roadway MSAT hot-spots, the 

health implications of the entire mix of mobile source pollutants, and other topics. But, the final 

summary of the series is not expected for several years. 

Other studies have reported that proximity to roadways is related to adverse health outcomes – 

particularly respiratory problems.35 Much of this research is not specific to MSATs, instead 

surveying the full spectrum of both NAAQS and other pollutants. FHWA cannot evaluate the 

validity of these studies, but more importantly, they do not provide information that would be 

useful to alleviate the uncertainties listed above and enable FHWA to perform a more 

comprehensive evaluation of the health impacts specific to this project. 

The Michigan Department of Environmental Quality, Air Quality Division (AQD), undertook to 

develop an air toxics monitoring strategy in 199236 and EPA established national monitoring 

programs. Detroit is one of several cities where air toxics are being monitored on an ongoing 

basis. The following are summaries of two recent and ongoing studies that have been conducted 

to evaluate particulates and air toxics in the Detroit area. They are drawn from MDEQ’s 2006 Air 

Quality Report. 

DATI: The Detroit Air Toxics Initiative (DATI) was initiated by MDEQ’s Air Quality 

Division (AQD), and funded by a grant from EPA’s Fiscal Year 2003 Community 

Assistance and Risk Reduction Initiative. The DATI project was a risk assessment and 

risk reduction project based on the Detroit Air Toxics Pilot Project’s air toxics monitoring 

data from April 2001 through April 2002. A total of 224 air toxics were monitored at 

 

35 South Coast Air Quality Management District, Multiple Air Toxic Exposure Study-II. 2000; The Sierra Club, 

Highway Health Hazards, 2004 summarizing 24 Studies on the relationship between health and air quality); 

Environmental Law Institute, NEPA's Uncertainty in the Federal Legal Scheme Controlling Air Pollution from Motor 

Vehicles, 35 ELR 10273. 2005, with health studies cited therein. 36 MDEQ, Air Quality Division, The Development of an Air Toxics Monitoring Strategy for Michigan, June 1992. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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seven sites in the Detroit area: Allen Park, Dearborn, W. Jefferson Avenue, W. Fort 

Street, Southfield, River Rouge, and northeast Detroit (E. Seven Mile). 

 The AQD finalized in 2005 the DATI Risk Assessment Report, along with a Technical 

Summary and Public Summary of that report.37 The AQD is continuing to monitor air 

toxics in the Detroit area in response to the DATI findings. This monitoring will 

determine whether the levels of air toxics have changed since the DATI monitoring in 

2001 and 2002 or remain at levels of concern. Updated information may be available in 

2008 as data currently being collected are synthesized. Meanwhile, the Risk Reduction 

Phase efforts continue, including the retrofit of a locomotive in Southwest Detroit (see 

SEMCOG Weight of Evidence in Section 4.8.4). 

DEARS: In 2004, the AQD and EPA’s National Exposure Research Laboratory and 

National Health and Environmental Effects Research Laboratory began conducting the 

Detroit Exposure Aerosol Research Study (DEARS). DEARS is a three-year field 

monitoring effort that is designed to measure exposure and describe exposure 

relationships for air toxics, PM components, PM from specific sources, and criteria 

pollutants in Detroit. The study includes monitors at the Allen Park site, indoor/outdoor 

monitors at participant’s houses, and personal exposure monitors.38 Among the DEARS 

objectives are to: 

• Determine the associations between concentrations measured at central site monitors 

and outdoor residential and indoor residential and personal exposures. 

• Identify the human activity factors that influence personal exposures to selected 

pollutants. 

• Investigate and apply source apportionment models to evaluate the contribution of 

specific ambient sources to residential concentrations and personal exposure to PM 

constituents and air toxics. 

• Determine the associations between ambient concentrations of criteria gases (O3, 

NO2, and SO2) and personal exposures for these gases. 

4.8.7.3.3 Quantitative MSAT Analysis – Preferred Alternative 

The quantitative analysis presented here provides a means of comparing the Preferred Alternative 

to taking no action, consistent with the guidance cited above. Terminal activity considered: 

visitor and employee traffic; container truck activity; container handling on the yard; locomotive 

activity; fugitive dust; loss of traffic and dust generation by businesses displaced by the projects 

and, closure of public streets that will fall within the future terminal. For the roadway analysis, 

the number of vehicles was used in conjunction with road link lengths and speeds. 

MSAT terminal data are shown in Table 4-31. The emission factor sources are as listed earlier. 

The overall conclusion is that for the terminal area, diesel particulate matter (DPM) will drop 

substantially from current levels with the Preferred Alternative. But, increased terminal activity 

will increase the levels of butadiene, formaldehyde, acetaldehyde, and acrolein compared to 

today’s levels and compared to taking no action. These increases would be more than offset by 

reductions in Wayne County (Table 4-31 bottom) with the mode shift from truck to rail. 

 

37 The DATI reports are available on the MDEQ Air Quality Division’s website at http://www.michigan.gov/deqair. 38 DEARS information is available at http://www.epa.gov/dears/. 
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Table 4-31 

Detroit Intermodal Freight Terminal Study 

Summary of Pollutant Burden Analysis – MSATs 

Livernois-Junction Terminal 

 

Terminal Burden BENZ BUTA FORM ACET ACRO DPM 

2004 0.13 0.02 0.63 0.29 0.04 6.30 

2015 No Action 0.70 0.02 0.42 0.19 0.03 2.50 

2015 Preferred 0.08 0.02 0.58 0.27 0.04 0.80 

2030 No Action 0.06 0.01 0.39 0.18 0.03 0.40 

2030 Preferred 0.11 0.02 0.84 0.40 0.06 0.70 

Roads 

2004 1.47 0.15 0.47 0.21 0.02 1.53 

2015 No Action 0.60 0.06 0.21 0.09 0.01 0.68 

2015 Preferred 0.58 0.06 0.19 0.08 0.01 0.63 

2030 No Action 0.45 0.04 0.17 0.07 0.01 0.57 

2030 Preferred 0.44 0.04 0.16 0.07 0.01 0.56 

Totals 

2004 1.60 0.17 1.10 0.50 0.06 7.83 

2015 No Action 1.30 0.08 0.63 0.28 0.04 3.18 

2015 Preferred 0.66 0.08 0.77 0.35 0.05 1.43 

2030 No Action 0.51 0.05 0.56 0.25 0.04 0.97 

2030 Preferred 0.55 0.07 1.00 0.47 0.07 1.26 

Regional Reductions 

2025 Wayne Co. 0.17 0.1 1.3 0.48 0.06 1.7 

2025 SE Michigan 0.41 0.24 3.05 1.12 0.14 6.7 

Source: The Corradino Group of Michigan, Inc. 

The roadway network under consideration is shown in Figure 4-48. The changes in truck 

traffic expected with the Preferred Alternative are shown in Table 4-28. MSAT summary 

roadway burdens are shown in Table 4-31. The Preferred Alternative will reduce the 

pollutant burden on the local road network analyzed, in 2015 and in 2030 compared to the No 

Action Alternative and 2004. The most important reductions would occur on Livernois and 

Dragoon south of Dix to I-75 where homes are 30 feet from the roads (Table 4-32). MSAT 

burdens in 2030 with the Preferred Alternative would be in the range of one-third of base 

year (2004) amounts. 

The sum of the terminal and roadway burdens indicates the Preferred Alternative will 

increase MSATs relative to taking no action in 2030, although, except for acrolein, the 

amounts would be less than 2004 levels. Regionally, the project will reduce MSATs. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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2004 2004 2004 2004 

 No Act. Pref No Act. Pref No Act. Pref No Act. Pref No Act. Pref No Act. Pref No Act. 

Livernois Junction From ToWyoming Dix New Gate 0.13 0.06 0.06 0.05 0.05 0.131 0.053 0.053 0.039 0.038 0.0132 0.0051 0.0051 0.0037 0.0038 0.0351 0.0165 0

New Gate Kronk 0.09 0.04 0.05 0.03 0.04 0.090 0.036 0.036 0.026 0.026 0.0090 0.0035 0.0036 0.0025 0.0028 0.0270 0.0112 0Kronk I-94 Ramp 0.08 0.04 0.04 0.03 0.04 0.079 0.032 0.032 0.023 0.023 0.0080 0.0031 0.0031 0.0022 0.0025 0.0239 0.0099 0I-94 Ramp Michigan 0.07 0.03 0.04 0.03 0.03 0.076 0.031 0.030 0.022 0.022 0.0076 0.0029 0.0030 0.0021 0.0024 0.0229 0.0095 0

Lonyo Michigan Kronk 0.12 0.05 0.05 0.05 0.04 0.131 0.053 0.043 0.041 0.033 0.0132 0.0052 0.0043 0.0038 0.0031 0.0416 0.0178 0

Kronk Dix 0.05 0.02 0.00 0.02 0.00 0.059 0.024 0.000 0.018 0.000 0.0059 0.0023 0.0000 0.0017 0.0000 0.0186 0.0080 0

Central Michigan Kronk 0.14 0.06 0.06 0.05 0.06 0.151 0.061 0.069 0.048 0.054 0.0152 0.0059 0.0065 0.0043 0.0047 0.0478 0.0205 0

Kronk Dix 0.07 0.03 0.05 0.03 0.05 0.080 0.033 0.056 0.025 0.043 0.0081 0.0032 0.0051 0.0023 0.0037 0.0255 0.0109 0

Perimeter Rd Lonyo Central 0.00 0.00 0.02 0.00 0.02 0.000 0.000 0.026 0.000 0.021 0.0000 0.0000 0.0025 0.0000 0.0018 0.0000 0.0000 0Livernois Michigan Exist. Gate 0.24 0.10 0.10 0.08 0.09 0.204 0.083 0.082 0.060 0.060 0.0207 0.0081 0.0080 0.0059 0.0061 0.0664 0.0287 0

Exist. Gate Dix 0.25 0.11 0.09 0.09 0.08 0.216 0.088 0.086 0.064 0.062 0.0222 0.0088 0.0083 0.0064 0.0059 0.0734 0.0325 0Dix I-75 0.11 0.04 0.03 0.03 0.03 0.076 0.031 0.030 0.024 0.023 0.0081 0.0033 0.0029 0.0024 0.0021 0.0301 0.0141 0

Dragoon Dix I-75 0.10 0.04 0.03 0.03 0.03 0.082 0.034 0.032 0.026 0.025 0.0085 0.0034 0.0030 0.0025 0.0022 0.0301 0.0138 0Kronk Wyoming Lonyo 0.05 0.02 0.00 0.02 0.00 0.048 0.020 0.000 0.014 0.000 0.0049 0.0019 0.0000 0.0014 0.0000 0.0149 0.0063 0

Lonyo Central 0.01 0.01 0.00 0.01 0.00 0.014 0.006 0.000 0.004 0.000 0.0015 0.0006 0.0000 0.0004 0.0000 0.0045 0.0019 0Central Livernois 0.03 0.01 0.01 0.01 0.01 0.034 0.014 0.006 0.010 0.005 0.0034 0.0013 0.0007 0.0010 0.0006 0.0104 0.0044 0

Totals 1.53 0.68 0.63 0.57 0.56 1.472 0.598 0.582 0.445 0.437 0.1493 0.0585 0.0561 0.0427 0.0417 0.4722 0.2059 0

2030 2015 2030 2015 2030 2015 

Diesel Part. Matter

2015

Benzene Butadiene Forma

 Source: The Corradino Group of Michigan, Inc. 
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4.8.7.4 SEMCOG Attainment Status/Air Quality Conformity 

This section updates the “attainment status” of the area with respect to National Ambient Air 

Quality Standard (NAAQS) pollutants since the DEIS was published. Then information is 

presented to demonstrate the Preferred Alternative “conforms” to the Clean Air Act, because it 

does not worsen air quality, cause new air quality violations, or delay the timely attainment of the 

NAAQS. 

EPA has promulgated two sets of regulations to implement the conformity requirements of the 

Clean Air Act: 1) Transportation Conformity Regulations, which apply to highways and mass 

transit and establish the criteria and procedures for determining whether transportation plans, 

programs, and projects funded under title 23 U.S.C. or the Federal Transit Act conform with the 

State Implementation Plan (58 FR 62188); and, 2) General Conformity Regulations, which apply 

to other Federal projects. These two regulatory approaches are discussed below. 

4.8.7.4.1 NAAQS and Regional Attainment Status 

The Clean Air Act requires Michigan (and all other states) to have a State Implementation Plan

(SIP) to demonstrate how it will attain and/or maintain NAAQS (Table 4-21). SEMCOG 

collaborates with the Air Quality Division of the Michigan Department of Environmental Quality 

(MDEQ) to prepare and/or update a SIP. SEMCOG is responsible for evaluating mobile source 

(vehicular) emissions in Southeast Michigan when projects are proposed for inclusion in its longrange transportation plan. SEMCOG’s 2030 Regional Transportation Plan (RTP) must undergo 

a quantitative analysis demonstrating that emissions levels associated with implementing planned 

transportation projects are equal to, or lower than designated emissions limits (budgets) set forth 

in the SIP. In doing so, SEMCOG is managing the transportation air quality conformity process 

in Southeast Michigan. The DIFT project is subject to air quality transportation conformity 

review through SEMCOG. This review has occurred and the DIFT Preferred Alternative has 

been found to conform. 

“Hot-spot” analyses of carbon monoxide (CO) and particulate matter are also a part of projectlevel transportation conformity and are discussed below. 

The following paragraphs report on the attainment status of the region, as updated since the 

DEIS. 

Carbon monoxide – In 1999, parts of Wayne (including all of the city of Detroit), 

Oakland, and Macomb counties were redesignated from nonattainment to 

maintenance for CO. A positive conformity determination for CO requires that 

emissions in any future year remain at or below the approved mobile source 

emissions budget of 1946 tons/day. Progress in addressing CO has advanced to the 

point that, starting in 2007, under amended 2006 air quality monitoring regulations, 

CO monitoring is no longer required. 

Eight-hour ozone – On April 15, 2004, the EPA officially designated the seven-county 

SEMCOG region, plus Lenawee County, a moderate nonattainment area for the 8-hour 

ozone standard. In September 2004, EPA approved the reclassification of the area from 

moderate to marginal ozone nonattainment. Since then, MDEQ and SEMCOG have 

implemented the control measures laid out in the region’s 2005 Ozone Attainment 

Strategy. These include a decrease in the allowable vapor pressure of summertime 

gasoline from 7.8 PSI (pounds per square inch) to 7.0 PSI, and a reduction in allowable 

VOC emissions from consumer and commercial products. Both of these measures went 

into effect in 2007. A formal SIP demonstrating how the region will attain the 8-hour 
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ozone standard was due in June 2007; however, it was delayed because it was anticipated 

the region would attain the standard by that date and be classified as a maintenance area. 

While the region was measuring attainment in June of 2007, a few high ozone readings in 

late August prevented the redesignation. By the end of the 2008 ozone season, Southeast 

Michigan was once again in compliance with the standard. Consequently, on March 2, 

2009, MDEQ submitted to U.S. EPA a “Request to Redesignate to Attainment Status” for 

ozone, citing attainment level design values for ozone for 2006-2008. On June 18, 2009, 

the region was redesinated as in attainment with the ozone standard. 

PM2.5 – EPA designated seven counties in Southeast Michigan nonattainment for the 

annual PM2.5 standard on December 15, 2004. A SIP for PM2.5 for the 15 ppm μg/m3

annual standard, which includes emission budgets for this pollutant, has been submitted 

to the U.S. EPA by MDEQ. That draft SIP is now under review. Until new budgets are 

approved, regional conformity for PM2.5 is determined by ensuring that future annual 

emissions do not exceed 2002 levels (2,766 tons/year for PM2.5 and 151,540 tons/year for 

NOx). The control strategy contained in the SIP is expected to bring Southeast Michigan 

into attainment of the annual PM2.5 standard by 2010. The latest monitoring data show all 

but one of the region’s 14 monitors are now meeting the standard. 

4.8.7.4.2 General Conformity 

General conformity normally applies to non-transportation projects. Threshold (de minimus)

emission levels have been set for particulate pollution (PM2.5 and PM10) to determine when 

general conformity determinations are necessary (40 CFR 93.153(b)). Because the DIFT is a 

transportation project, it would be logical to assume that only transportation conformity applies. 

But, DIFT is unique in that it has a terminal. There, trucks will idle briefly as they pick up and 

drop off containers. Therefore, plaza activity has been examined to determine whether de 

minimus levels of 100 tons per year for PM2.5 or PM10 are exceeded during system operations. 

The year of highest emissions, 2015, has been analyzed and compared to the de minimus

thresholds. 

Because of the scale of the DIFT project, the de minimus threshold was also applied to 

construction activities to determine whether PM10 dust levels exceed 100 tons in any construction 

year. 

4.8.7.4.2.1 PM2.5 and PM10 Operations de minimus Analysis

The de minimus level of 100 tons annually was published in the Federal Register of July 17, 

2006, for both PM2.5 and PM10. The DIFT project implementation will actually reduce the annual 

PM2.5 and PM10 burden at the Livernois-Junction Yard (the only terminal that receives 

government funding under the Preferred Alternative) in 2015 and 2030 compared to the No 

Action Alternative. So, the DIFT project operations will not trigger the need to conduct general 

conformity (see Table 4-26a and compare 2015 or 2030 Preferred Alternative values for PM2.5 or 

PM10 to the matching values for the No Action Alternative). 

4.8.7.4.2.2 PM10 Construction de minimus Analysis

An examination of the proposed DIFT construction program found that, in any given year, the 

dust created during project implementation will also be well within the PM10 de minimus level. 

The 300 existing acres, and 169 new acres, are predominantly clear of major buildings and 

structures. With a project implementation program of ten years, it is reasonable to assume about 

125 acres would be the most to be worked on in a given year. Assumptions were a site 

development area 1100 feet wide and 5000 feet long and use of earthmovers and/or graders with a 
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PM10 dust emission factor of 3.6 lbs/vehicle mile of travel of the construction equipment. Using 

the methodologies available in EPA’s “Compilation of Air Pollutant Emission Factors, AP-42, 

Fifth Edition, Volume 1: Stationary Point and Area Sources,” revised December 2003, and 

reasonable construction assumptions, maximum yearly estimates of dust from construction are 

under 30 tons, well under the 100 ton threshold. 

4.8.7.4.3 Transportation Conformity 

4.8.7.4.3.1 Regional Conformity

With identification of the Preferred Alternative, DIFT project elements that cause changes to the 

transportation network were evaluated by SEMCOG for air quality conformity. When analyzed 

together with other plan elements, the air pollution generated must not exceed “budgets” 

established in the SIP. This was the case for carbon monoxide, ozone, and PM2.5. This analysis 

has been performed and the DIFT has been included in SEMCOG’s cost-feasible RTP and 

Transportation Improvement Program (TIP). It can now advance to design. 

4.8.7.4.3.2 Hot-spot Analysis

Hot-spot analysis is designed to evaluate whether there are air quality impacts on a smaller scale 

than an entire nonattainment or maintenance area. Conforming to the purpose of the SIP means 

that transportation activities will not cause new air quality violations, worsen existing violations, 

or delay timely attainment of the NAAQS. 

The hot-spot analysis applies to carbon monoxide (CO), PM2.5, and PM10 consistent with 40 CFR 

93.116. 

The CO analysis is done on a quantitative basis per 40 CFR 93.123(a) to determine whether 

estimated “with-project” concentrations of CO exceed the established one-hour and/or eight-hour 

standards. If they do not, the project conforms. Hot-spot conformity for PM2.5 and PM10 is 

determined on a qualitative basis per 40 CFR 93.123(b)(4) until appropriate methods and 

modeling guidance are available for quantitative analysis. 

Regarding PM10, a portion of Detroit that includes the proposed new DIFT project is a 

maintenance area. In the Maintenance Plan, SEMCOG, MDEQ and EPA concluded that mobile 

source (vehicular) PM10 emissions are not a significant contributor to regional PM10 emissions, 

and SEMCOG is not required to consider PM10 in its regional conformity analyses. However, 

because no similar determination was made with respect to whether mobile source PM10

emissions contribute to localized hot-spot problems, a PM10 hot-spot qualitative analysis is 

required. 

CO Hot-spot Quantitative Analysis

Guidance for CO hot-spot analysis (40 CFR §93.123(a)) states that, if there are no violations of 

the CO standards in the area affected by the project, then the project's future effect is compared to 

the standard because the test is whether the project causes an exceedance of the standard at a 

sensitive receptor. There are no violations in the area. Modeling performed for the DEIS 

indicated no project alternative would have resulted in CO values at hot-spots around the 

terminals anywhere near the one-hour and eight-hour standards (Table 4-25). The same is true 

for the Preferred Alternative, which will have a lower activity level than Alternative 3 would have 

had. 
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PM2.5 Hot-spot Qualitative Analysis

Since the publication of the DEIS the air quality regulatory background for particulates has 

changed as a result of the publication of the “Final Rule for PM2.5 and PM10 Hot-spot Analyses in 

Project-Level Transportation Conformity Determinations,” which appeared in the March 10, 

2006, Federal Register. Subsequent to the publication of the Final Rule, EPA and FHWA jointly 

issued “Transportation Conformity Guidance for Qualitative Hot-spot Analysis in PM2.5 and PM10

Nonattainment and Maintenance Areas,” March 29, 2006. The DIFT project is of “air quality 

concern” (Transportation Conformity Guidance, Chapter 1.3) for PM2.5 because it would 

represent a transfer point that has “a significant number of diesel vehicles congregating at a single 

location.” (40 CFR 93.123(b)(1)(iii)). 

Upon the publication of the guidance, interagency consultation occurred on May 11, 2006, among 

EPA, FHWA, SEMCOG, MDOT and MDEQ. EPA, FHWA, and MDOT met again July 19, 

2006. Consultation led to an Addendum to the original Air Quality Protocol. Both the Protocol 

and the Addendum (Appendix E) guided the analysis in this section. Subsequent to these noted 

activities, interagency consultation continued on the Detroit River International Crossing (DRIC), 

a proposed new link to Canada also to be located in Southwest Detroit. The DIFT Project has 

independent utility from the DRIC. That further consultation led to refinements to the DIFT Air 

Quality Protocol and Addendum. The analysis that follows reflects the continued interagency 

consultation. 

The qualitative PM2.5 analysis covers: 

• A description of the proposed project; 

• The method chosen to conduct the analysis (Method B); 

• The type of emissions to be considered (PM2.5); 

• Background No Action conditions – base 2004 and future (2015 and 2030); 

• Project conditions – 2015 and 2030; 

• Documentation of public involvement; and, 

• Conclusions. 

This qualitative hot-spot analysis addresses both the 24-hour and annual standards for PM2.5. The 

SEMCOG area was designated non-attainment with the annual PM2.5 standard of 15 μ/m3

 in 

2004. The analysis herein addresses that standard and the concurrent 65 μg/m3

 24-hour standard. 

It is anticipated that during 2009 the region will be designated in non-attainment with the stricter 

35 μ/m3

 24-hour standard established in 2006. However, based on the rules that govern 

conformity, the region will have another year before conformity to the 35 μ/m3

 standard applies. 

Therefore, while 35 μ/m3

 is the 24-hour standard shown herein in tables and graphics, it is the 65 

μ/m3

 standard that is still the test for conformity. The DIFT project will be implemented over a 

number of years. If there are future federal actions or major project changes, the U.S. Department 

of Transportation will comply with whatever conformity requirements apply at that time. 

Project Description 

The DIFT project is fully described in Section 3.5. It is in Southwest Detroit, which became an 

industrial area beginning in the 1850s as ores came to the riverfront via Great Lakes ships. 

Railroads eventually made this a year-round activity. Brick manufacture and production of soda 

glass added to ore processing in Southwest Detroit. Then came steel mills and the auto industry. 

Worker housing developed adjacent to the factories. Later the Marathon refinery, coal-generated 

electric power and sludge burning at the Detroit sewage treatment plant contributed to air quality 

burdens in the area. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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An extensive public involvement program that covered air quality was conducted in this and other 

areas around intermodal terminals. It is described in Section 7 of this FEIS. 

Method Chosen 

This qualitative hot-spot analysis follows a hybrid of Methods A and B, as outlined in Chapter 4 

of the March 2006 EPA/FHWA Joint Guidance. It relies on air quality studies and data from 

available sources as identified through the interagency consultation process; some elements are 

area-wide and general in nature, and others are local or site specific. 

Background PM2.5 No Action Conditions - Base (2004) and Future (2015 and RTP Horizon 

Year - 2030) 

The sections below cover PM2.5 trends, air quality monitoring of PM2.5 in the area, SEMCOG’s 

PM2.5 attainment strategy projects conditions, construction, public involvement, and conclusion 

related to PM2.5. 

PM2.5 Trends and Outlook

EPA notes in its Particulate Pollution Report: Current Understanding of Air Quality and 

Emissions through 2003, that regional pollution in the eastern U.S. contributes more than half of 

total PM2.5 concentrations. Regional pollutions comes from power plants, natural sources, and 

urban pollution, and can be transported hundreds of miles. As a result, EPA has pursued a variety 

of programs aimed at point sources, as well as efforts to control mobile sources (Table 4-33). 

Table 4-33 

Detroit Intermodal Freight Terminal Study 

Selection of Emission Control Rules and Programs Contributing to PM Emission 

Reductions 1995-2015

Program Sector Direct PMa

Reductions 

SO2

Reductions 

PM 

Precursors 

NOx 

Reductions 

VOC 

Reductions 

Implementation 

Date 

Clean Air Nonroad 

Diesel Rule 

Mobile sources X X X 2004-2015 

Clean Air Interstate 

Rule (proposed 

December 2003) 

Electric Utilities X X X 2010-2015 

Acid Rain Program Electric Utilities X X 1995-2010 

Regional Haze 

Rule/Best Available 

Retrofit Technology 

Electric Utilitiesb X X X 2013-2015 

PM2.5 Implementationc Stationary/Area/ 

Mobile sources 

X X X X 2008-2015 

Maximum Achievable 

Control Technology 

(MACT) Standardsd

Stationary/Area X X 1996-2003 

Various Mobile Source 

Programse

Mobile sources X X X X Ongoing 

a

 Includes elemental and organic carbon, metals, and other direct emissions of PM. b

 Also applies to industrial boiler and the other source categories also covered under Prevention of Significant Deterioration (PSD). c

 Includes Reasonably Available Control Technology (RACT) and Reasonably Available Control Measures (RACM). d

 Includes a variety of source categories such as boilers and process heaters, pulp and paper, petroleum refineries, various minerals and ores, and 

others. While these standards are for hazardous air pollutants (HAPs) such as metals, measures to reduce HAPs in many cases also reduce PM 

emissions. 

e

 Includes such programs as onroad diesel and gasoline engines, nonroad gasoline engines, Low Sulfur Diesel and Gasoline Fuel Limits for onroad 

and offroad engines, motorcycles, land-based recreational vehicles and marine diesel engines. EPA finalized rules related to locomotive and marine 

compression-ignition engines and locomotive idling in March 2008. 

Source: Derived from EPA as presented in MDEQ’s 2006 Annual Air Quality Report for Michigan.
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 160

The EPA-approved MOBILE6.2 model emission factors show that mobile source emissions of 

particulate matter are expected to decline substantially (Figure 4-50), especially for trucks. The 

examples shown are for 10 and 30 miles per hour in 2004, 2015 and 2030. 

In the Midwest, EPA is assisted in addressing air quality concerns by the Lake Michigan Air 

Directors Consortium (LADCO), which works with its member states in the upper Midwest to 

develop the necessary technical support for new State Implementation Plans (SIPs) for regional 

haze, PM2.5, and 8-hour ozone. In Michigan, the Michigan Department of Environmental Quality 

(MDEQ) works to improve air quality, including the reduction of PM2.5. 

MDEQ’s 2006 Air Quality Report indicates that EPA 2002 data show area sources, such as farm 

fields and residential wood-burning, represent the largest share of PM2.5 emissions (37%), while 

non-road vehicles, such as construction equipment, add another 32 percent. On-road (vehicular) 

sources contribute 18 percent and point sources represent 13 percent. EPA estimates the Clean 

Air Non-road Diesel Rule, signed July 7, 2005, will reduce the engine emissions of non-road 

vehicles by more than 90 percent. 

MDEQ coordinates with EPA in its Speciation Trends Network (STN), which is designed to 

provide: 1) annual and seasonal spatial characterization of aerosols; 2) trends and tracking of 

control program progress; 3) integration of chemical speciation data with data related to the visual 

Figure 4-50 

Detroit Intermodal Freight Terminal Study 

MOBILE6.2 Emission Factor Trends – PM2.5 and PM10

 Source: The Corradino Group of Michigan, Inc. using MOBILE 6.2 with SEMCOG inputs. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 161

environment; and, 4) development of emission control strategies. Several programs measure 

particulates in Michigan. 

In a report entitled “Midwest Urban Organics Study: Lessons Learned,”39 LADCO addressed 

some relationships between PM2.5 and organic carbon mass (OM).40 LADCO found the major 

sources of OM are: 1) mobile sources, including on-road and non-road, gasoline and diesel, and 

smoking (high-emitting) and non-smoking vehicles; 2) burning (both residential wood 

combustion and wildfires); 3) industrial sources; and, 4) secondary organic aerosols. 

Near the DIFT study area, PM2.5 speciation data are being collected at Monitor 26-163-0001 in 

Allen Park and 26-163-0033 in Dearborn. MDEQ finds that PM2.5 from mobile sources can, to a 

degree, be differentiated from non-mobile sources, but that differentiating among mobile sources, 

such as trucks, is difficult. 

Monitoring of PM2.5

PM2.5 is measured at: 

• Wyoming Avenue (Station 26-163-0032 at 2842 Wyoming Avenue); 

• Fort Street (Station 26-163-0015 at 6921 West Fort Street); and, 

• West Lafayette (Station 26-163-0039 at 2000 West Lafayette). 

Certified 2008 PM2.5 data have been submitted to U.S. EPA by MDEQ that show these three 

monitors in Southwest Detroit under the 15 μ/m3

 annual standard, at 13.33, 12.85, and 12.23 

μ/m3

, respectively (Figure 4-51). Note the one μ = one millionth of a gram and m3 = cubic 

meter.) Values at these locations were under even the new, stricter 24-hour 98th Percentile 

standard of 35 μ/m3

 (31.7, 34.3, and 31.7 μ/m3, respectively). This means these three monitors 

were well under the applicable 24-hour 98th Percentile standard of 65 μ/m3 which is the 

applicable 24-hour conformity test standard that will remain in effect until spring or summer 

2010. 

The wind rose in Figure 4-52 shows the prevailing winds are from the southwest indicating, for 

most of the year, the area of heavy industry south and west of the project area (Figure 4-53) is 

contributing directly to the measurements of particulates at Dearborn and, to a lesser extent, West 

Fort Street. 

A comparison with other monitor data in Southeast Michigan points out how important industrial 

and point sources have been to the problem of PM2.5, in Southwest Detroit. Figure 4-54 shows 

monitors near freeways (in red). The table accompanying the graphic shows 24-hour and annual 

mean values of PM2.5, averaged over three years (the standards for PM2.5 are in terms of a threeyear rolling average). 

 

39 Sonoma Technology, Inc. and University of Wisconsin-Madison for Lake Michigan Air Directors Consortium, 

Midwest Urban Organics Study: Lessons Learned, March 31, 2006. 40 OM is defined as 1.8 times the measured organic carbon (OC). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 162

Figure 4-51 

Detroit Intermodal Freight Terminal Project 

PM2.5 Values and Trends at Nearby Monitors 

Monitored Pollutant: Particulate Matter (PM-2.5)

 98th Percentile 24-hr Average

 Station: 26-163-0015 at 6921 W. Fort, Detroit

Station: 26.163.0039 at 2000 W. Lafayette

Station 26-163-0033 at 2842 Wyoming Ave. Dearborn

30

40

50

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

PM2.5 Level (ug/m3)

EPA Standard (35 ug/m3) 24-Hr 98th Percentile - Fort

24-Hr 98th Percentile - Lay 24-Hr 98th Percentile Wyoming

Linear - 24-Hr 98th Percentile

Monitored Pollutant: Particulate Matter (PM-2.5)

Annual Mean

 Station: 26-163-0015 at 6921 W. Fort, Detroit

Station: 26.163.0039 at 2000 W. Lafayette

Station: 26-163-0033 at 2842 Wyoming Ave, Dearborn

10

15

20

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

PM2.5 Level (ug/m3)

EPA Standard (15 ug/m3) Annual Mean - Fort

Annual Mean - Lafayette Annual Mean - Wyoming

Linear (Annual Mean - Fort)
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 163

Figure 4-52 

Detroit Intermodal Freight Terminal Study 

Wind Rose for Detroit Metropolitan Airport 

 Source: http://www.deq.state.mi.us/documents/deq-rrd-DS-DetroitLead.pdf 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 164 

Figure 4-53 

Detroit Intermodal Freight Terminal Study 

Major Industries and Key Points 

 Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 165

Figure 4-54 

Detroit Intermodal Freight Terminal Study 

PM2.5 Values Relative to Daily Truck Volumes 

Comparison of Monitors (24-hr Standard = 35 μg/m3; Annual Mean = 15.0 μg/m3) 

2004-06 PM2.5

Name Address Monitor ID # 24-hr. Annual Nearest Major Roads 

Distance to 

Monitor (miles) 

2007 Daily 

2-way Trucks 

Dearborn 2842 Wyoming 261630033 44.2 17.2 I-94 1.2 10,000 

 I-75 1.3 12,000 

 Fort St. 1.2 1,200 

West Fort 6721 West Fort 261630015 40.6 15.8 I-75 0.2 12,000 

 Fort Street 0.1 1,200 

2000 W. Lafayette 261630039 32.4a 13.1a West I-75 0.3 12,000 

Lafayette Fort Street 0.1 1,200 

Livonia 38707 W 7 Mile 261630025 34.3 13.1 I-275 0.1 15,600 

 I-96 3.0 12,800 

 I-696 4.0 11,200 

 Grand River 2.5 1,260 

Oak Park 13701 Oak Park Dr. 261250001 39.2 13.4 I-696 0.6 6,600 

 8 Mile Road 1.5 2,000 

 Lodge Freeway (M10) 1.7 3,200 

 Woodward (M1) 2.0 1,100 

E 7 Mile 11600 E 7 Mile Rd. 261630019 41.2 14.1 I-94 2.5 7,400 

 I-75 4.0 12,700 

 I-696 4.0 8,800 

 8 Mile Road 1.0 3,600 a

 Only one year of data. 

Source: MDEQ and The Corradino Group of Michigan, Inc. Traffic volumes from MDOT Average Daily Commercial Traffic map on their website. 

Oak Park 

Monitoring 

Station 

E 7 Mile 

Monitoring

Station 

Dearborn 

Monitoring 

Station

Livonia 

Monitoring 

Station 

DAILY 

West Fort 

Monitoring 

Station West Lafayette

Monitoring 

Station 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 166

The Livonia monitor, with the highest adjacent daily truck volume (15,600 on I-275), had 

the lowest 24-hour and annual average mean values of PM2.5. The Livonia monitor, like 

other monitors in Wayne County, is situated in a flat open area without substantial 

concentrations of high-rise buildings. Compared to Dearborn, measurements are 

10 μg/m3

 (22%) lower on a 24-hour basis, and 4 μg/m3 (24%) lower on an annual mean 

basis. The fact that the prevailing winds are from the southwest does not have a large 

effect at Livonia because, from an air quality standpoint, the worst case is winds parallel 

to a road, so vehicular emissions accumulate. Trucks pass very close to the Livonia 

monitor (0.1 mile), compared to the Dearborn monitor, where I-94 and I-75 are 1.2 and 

1.3 miles away, respectively. All this is a clear indication that industry is the key player 

in the higher readings at the Dearborn monitor. 

The 2008 data plotted in Figure 4-51 show a substantial drop in PM2.5 values, compared 

to the data in Figure 4-54. U.S. Steel was temporarily closed down and the Severstal 

Steel plant has installed near air pollution control equipment. This again underscores that 

the newer data in Figure 4-51 reflects the reduction in point source PM2.5. 

SEMCOG Draft Weight of Evidence (WOE) and PM2.5 Attainment Strategy

The most comprehensive information available on PM2.5 for Southeast Michigan is found 

in information supporting SEMCOG’s PM2.5 SIP submittal to MDEQ, which is now 

under review. The information below is drawn from that documentation. It is noted that 

SEMCOG’s base year is 2002 for developing their contribution to the SIP. So, 2002 is a 

reference point in some of the following information. And, the date the region is to reach 

attainment for PM2.5 is 2010. The dates of analysis for the DIFT are 2004, as the base 

year; 2015, which represents a midway point in project development (construction 

activity peaks in 2014); and, 2030, which is the horizon year of SEMCOG’s Regional 

Transportation Plan. 

WOE observations for the Southeast Michigan region that relate to PM2.5 follow: 

• The Lake Michigan Air Directors Consortium (LADCO) finds the vast majority 

of PM2.5 comes from outside the region (75% +). Within the region, the vast 

majority comes from Wayne County. 

• The area surrounding the Dearborn and Southwestern High School (West Fort) 

monitors includes many PM2.5 sources that are exempt from MDEQ emissions 

reporting. 

• Numerous storage piles, unpaved lots, and barren lands exist near the Dearborn 

and Southwestern High School (West Fort) monitors. Only some facilities have 

fugitive dust plans. 

• Industrial facilities near the Dearborn and Southwestern High School monitors 

have closed or scaled back their operations (as measured since 2002); examples 

are Carmeuse/Detroit Lime, Daimler Chrysler McGraw Glass, Frito Lay, IPMC, 

Gutter Suppliers, Inc., Darling International, and Honeywell. 

• Significant local PM2.5 reductions are being achieved from controls underway at 

the Sverstal and U.S. Steel facilities, as well as the Marathon oil refinery. 

These reductions are based on: 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 167

− A Consent Order issued by MDEQ to Sverstal North America, Inc. that 

operates steel production facilities just west of the Dearborn monitor. 

− A Consent Decree entered into by EPA with Marathon Oil Company, 

which will substantially reduce nitrogen oxides and sulfur dioxide 

emissions at their Detroit refinery southwest of the project area. 

− Improvements planned at U.S. Steel on Zug Island and south. 

• As reported January 9, 2008,41 Marathon Oil announced it will commit $260 

million for pollution control in its proposed $1.9 billion onsite expansion. 

Targeted pollutants are sulfur dioxide, nitrogen oxide and PM. Also proposed 

are $2 million to install air quality monitors around the refinery and $1 million to 

reduce PM waste in neighborhoods around the plant, including street sweeping. 

• Emission reductions are expected from retrofitting (basically rebuilding with 

horsepower reduction) four diesel switch engine locomotives (using federal 

Congestion Mitigation/Air Quality funding through SEMCOG together with 

MDEQ funding) at the Rougemere Rail yard just west of the Dearborn monitor 

(in some cases only hundreds of feet). 

• The Dearborn monitor is close to several rail yards, one of which is immediately 

upwind of the monitor. LADCO recommended that locomotive emission 

reduction strategies, such as anti-idling and engine retrofits, be evaluated. As 

part of a federal Supplemental Environmental Project (SEP), DaimlerChrysler is 

to provide $1.5 million to install anti-idling equipment on approximately 40 

switch engine locomotives operating in rail yards and industrial sites near the 

Dearborn and Southwestern High School monitors. This project is expected to 

reduce NOx emission by 96 tons/year and PM by 2.8 tons/year. 

Monitoring data has led SEMCOG to a number of conclusions: 

− PM2.5 in Southeast Michigan is comprised largely of sulfates, nitrates, and 

organic carbon. At the Dearborn monitoring site, there is also a significant 

“crustal” component, which is largely iron. 

− Between 2000 and 2006, PM2.5 concentrations at all sites in the region steadily 

declined. The 3-year average concentration dropped 1.6 μg/m3

 between 2002 and 

2006. The largest decreases have occurred at the sites with the highest 

concentrations: Wyoming, West Fort, and Wyandotte in the industrial core of 

Southeast Michigan’s nonattainment area and concentrations have been 

decreasing faster than other sites. This is likely due to changes in emissions in the 

industrial area. 

− Analysis of monitoring data shows that counties north of Wayne did not 

contribute to PM2.5 nonattainment at the violating monitors. The analysis shows 

that the vast majority of the urban excess at these monitors on days when winds 

are from the northeast, north or northwest, comes from within Wayne County. 

Little increase is attributable to Oakland and Macomb counties. And in all cases, 

average concentrations at the violating monitors are well below the standard 

when winds are from these directions. 

 

41 Detroit News, January 9, 2008. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 168

− A wind rose for the iron component of PM2.5 at Dearborn points directly to the 

southwest. Conversely, the iron wind rose for Allen Park, while measuring much 

lower levels, points to the northeast. The Allen Park monitor is approximately 

five miles southwest of Dearborn. Additional wind direction analysis shows that, 

when winds are from the southwest average crustal concentrations at Dearborn 

are over 2.5 μg/m3 higher than those at Allen Park and are sometimes as much as 

6 μg/m3 higher. This clearly indicates a significant local iron source directly 

between these two sites (which are approximately five miles apart) and closer to 

the Dearborn monitor. The Sverstal Steel facility lies in exactly this position. As 

part of a consent order and permit with the State, this facility has installed new 

bag houses on its blast and basic oxygen furnaces, as well as other control 

equipment. These changes appear to have been effective in lowering emissions. 

− PM2.5 2008 values below the standards with U.S. Steel closed down and the 

Sverstal improvements in place support the indication that point sources are 

heavy contributors to PM2.5. 

PM2.5 Project Conditions - Future (2015 and RTP Horizon Year - 2030)

The qualitative “hot-spot” analysis in this section is in addition to the process SEMCOG 

has used in past years to determine regional transportation conformity (see Section 

4.8.7.4.1). The qualitative hot-spot analysis is designed to determine the effect of PM2.5

on a localized basis, i.e., project-level conformity. This hot-spot analysis is designed to 

consider direct emissions only, not secondary particles, as these take several hours to 

form in the atmosphere, giving emissions time to disperse beyond the immediate area of 

concern. 

The qualitative hot-spot analysis in this section addresses both the 24-hour and annual 

standards for PM2.5. It includes the Livernois-Junction terminal and the roadway network 

which trucks would use to carry containers to and from that terminal. It does not need to 

include activity at key intersections where the LOS drops to D or worse as traffic analysis 

found there are none. It considers construction activity as dust could be a consideration 

in the SIP. The SIP for PM2.5 is now under review by MDEQ and then EPA. 

Consequently, there are no “budgets” for PM2.5. 

The DIFT is a project of air quality concern because large numbers of diesel trucks are 

involved. The DIFT project and its increase in truck traffic will develop over a ten-year 

period, 2010 through 2019. There is no “year of opening” as there would be with many 

other transportation projects. Rather, the railroads, in conjunction with MDOT, will 

prioritize and capitalize a set of improvements over time. The year of peak construction 

is projected to be 2014, so for analysis purposes, the year of highest emissions is taken to 

be 2015. By this point, major features of the project are expected to be in place, such as 

the purchase of property and gate development. So, for example, the two new gates on 

Wyoming will be developed. The Detroit River International Crossing project will be in 

place (projected year of opening of 2015), limiting access to the DIFT by the 

reconstruction of the Livernois/Dragoon interchange with I-75. The further in time the 

analysis is performed, the cleaner the overall vehicle fleet will be. So, 2015 is a 

reasonable choice as the highest year of emissions. 

While DIFT will develop over a ten-year period, it consists of a set of project elements at 

different times and locations, none of which last five years. The project design year is 

2030, consistent with SEMCOG’s Regional Transportation Plan. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 169

PM2.5 annual terminal pollutant burden are projected to be 14.9 tons in 2030 for the 

Preferred Alternative, compared to 30.9 tons for the No Action Alternative (Table 4-30). 

In 2015, the relationship is 8.8 tons for the Preferred Alternative to 26.0 for the No 

Action Alternative. Existing (2004) PM2.5 totals 43.5 tons a year. Therefore, the 

Preferred Alternative PM2.5 terminal burden will be less than one fourth the 2004 

condition. The principal change will come with paving the yard. Though PM2.5 is a 

small fraction of the particulate matter on the unpaved yard, the yard is so big that even 

the small portion that is unpaved produces a large quantity of pollution. 

The DIFT project will result in more trucks overall, but redistribute them away from 

residential areas. This would happen by shifting trucks to two new gates off Wyoming 

Avenue, reorienting intermodal truck traffic on Livernois Avenue to the north, and 

closing the Dix/Waterman gate to the Livernois-Junction Yard (Table 4-34). 

Table 4-34 

Detroit Intermodal Freight Terminal Study 

Truck Volumes – Preferred Alternative and No Action 

2004

Base

No 

Action Pref.

No 

Action Pref. 2015 2030

Liv-Junc Yard From To

Wyoming Dix New Gate 1350 1499 1644 1634 2016 146 382

New Gate Kronk 1534 1703 2586 1856 3684 883 1828

Kronk I-94 Ramp 1360 1510 2128 1646 3209 619 1564

I-94 Ramp Michigan 1304 1447 2066 1578 3141 619 1564

Lonyo Michigan Kronk 780 866 862 944 940 -4 -4

Kronk Dix 696 773 0 842 0 -773 -842

Central Michigan Kronk 1024 1137 895 1239 998 -241 -241

Kronk Dix 955 1060 970 1156 1066 -90 -90

Perimeter Rd Lonyo Central 0 0 431 0 470 431 470

Livernois Michigan Exist. Gate 2275 2548 2552 2801 3433 4 633

Exist. Gate Dix 2420 2740 1749 3041 1927 -992 -1114

Dix I-75 1081 1226 618 1364 694 -609 -670

Dragoon Dix I-75 968 1101 492 1227 557 -609 -670

Kronk Wyoming Lonyo 300 333 0 363 0 -333 -363

Lonyo Central 239 265 0 289 0 -265 -289

Central Livernois 238 264 301 288 580 37 292

Pref. minus No Action

Road Segment

2015 2030

a

 To project Preferred Alternative traffic to 2030, background traffic was grown at 1% a year until 2025 then 0% a 

year to 2030. Intermodal traffic was based on lifts growth. 

 Source: The Corradino Group of Michigan, Inc. 

Truck volumes would decrease on Livernois Avenue and Dragoon Street south of the existing 

gate to I-75 ( red box on Table 4-34). Lonyo traffic would shift to Central Avenue ( orange 

box) and Kronk Street would be closed by the project ( green box). Traffic on Central Avenue 

will decrease because several large trucking concerns will be relocated by the project removing 

some truck traffic from Central ( blue box). Truck volumes will increase on Wyoming, 

between the new proposed gates and Michigan Avenue and, to a lesser extent, south of the gates 

to Dix. The Dearborn monitor is located on Wyoming between the new gates and Dix. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 170

In the intermediate year of 2015, the project is estimated to result in about 600 fewer trucks per 

day to the Livernois-Junction Yard area ({ red oval on Table 4-35) because, even though the 

project brings new trucks to the terminal, it eliminates existing land uses that generate many truck 

trips. In the near term, as these land uses are converted, the result would be fewer trucks. In 

2030, with further intermodal growth, there will be approximately 700 new truck trips ({ blue 

oval) in the Livernois-Junction Yard area because intermodal traffic will continue to increase 

beyond 2015, while there are no new relocations of non-intermodal trucking activities between 

2015 and 2030. Roads that, today, generate a substantial amount of dust will also be closed at the 

beginning of project construction, while project lifts and truck traffic will increase gradually 

thereafter. As a result, there are still increases on certain links, even in 2015, as shown on Figure 

4-55. 

Table 4-35

Detroit Intermodal Freight Terminal Study 

Net Truck Trips in Livernois-Junction Terminal Area 

 Truck Trips 

Condition 2015 2030 

Preferred Alternative Intermodal Trucks 1974 3800 

No Action Alternative Intermodal Trucks 956 1510

Increase with Preferred Alternative 1018 2290 

Trucks eliminated at Relocated Business -1600 -1600

Net Change in Trucks -582 690 

 Source: The Corradino Group of Michigan, Inc. 

For this qualitative analysis, three types of hot-spots have been identified (Figure 4-55): 

key intersections near the Livernois-Junction Yard; gates serving the yard; and, roadway 

links around the Livernois-Junction Yard with heavy truck traffic under the Preferred 

Alternative. 

Intersections – PM2.5

The traffic analysis (Section 4.1) examined over 100 intersections around the intermodal 

terminals to determine whether project-related traffic would cause impacts. The analysis 

found the truck (and auto) traffic changes of the Preferred Alternative will not result in 

any intersections operating at Level of Service D, or worse, in the peak hour in 2015 or in 

2030 in the Livernois-Junction Yard area. This analysis is based on additional traffic 

counts performed since the DEIS. Future background volumes were assumed to increase 

one percent a year from the present. Based on actual historic patterns, this overstates 

actual traffic growth. In addition, SEMCOG released a study in 2007 outlining reduced 

growth and travel in the region.42 So, the stated conditions for traffic represent worstcase conditions for air quality purposes. 

 

42 SEMCOG, A Region in Turbulence and Transition, April 2007. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 171

Figure 4-55 

Hotspot Analysis and Daily Truck Traffic on Key Links 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 172

Gates – PM2.5

Average check-in and check-out times of four minutes have been assumed at each 

terminal gate, compared to five minutes for the less efficient layouts of No Action. 

Actual Preferred Alternative times may be less. Four gates are distributed around the 

perimeter of the Livernois-Junction Yard under the Preferred Alternative. With No 

Action, all trucks enter the yard off of Livernois or Waterman at Dix. 

With the Preferred Alternative, the maximum two-way daily gate truck volume in 2030 at 

any one gate (Gate 5) is forecast to be 1270. Next in volume would be Gate 3 with 1,140 

two-way daily trucks (Figure 4-55). Total two-way trucks for all gates would be 3800. The 

annual PM2.5 pollutant burdens in tons for the idle time related to delay at the gates is 0.07 

tons in 2015 and 0.13 tons in 2030. 

The amount of delay and associated idling is small in comparison to the burden reduction the 

project bring – 17 tons in 2015 and 16 tons in 2030. 

Roadway Links – PM2.5

Figure 4-55 shows anticipated truck volumes on key roadway links near the LivernoisJunction Yard. It also shows that intermodal trucks will use Wyoming Avenue (80% 

north and 20% south) and Livernois Avenue (100% north to I-94) to get to the yard. This 

pattern would focus truck traffic on access routes that carry trucks today and reorient 

truck traffic away from residential areas, notably homes along the Livernois/Dragoon 

one-way pair that connects the Livernois-Junction Yard to I-75. Today, that one-way 

pair is a route of choice by truckers. The noted shifts are consistent with the wishes of 

local residents. The Livernois gate will be reengineered to prevent turns to and from the 

south. Also, the existing Waterman gate on the south side of the Livernois-Junction Yard 

will be closed. Waterman is another route that passes through a residential area. 

The only links with traffic increases due to the DIFT, other than the new Perimeter Road 

(i.e., a new Kronk Street), is Livernois Avenue north of the terminal and Wyoming 

Avenue. The Dearborn monitor is on the section of Wyoming between Dix and the new 

Gates 3 and 5. The monitor is also directly across from the Sverstal Steel facility which, 

together with improvements at U.S. Steel and the Marathon Refinery, are expected to 

experience an annual PM pollutant burden reduction of 330 tons. Federal Congestion 

Mitigation Air Quality funds are rebuilding four switch locomotives nearby with GenSet 

equipment to reduce PM emissions. These switch locomotives now idle while sitting on 

tracks as close as 250 feet from the Dearborn monitor. GenSet locomotives have 

multiple off-road, low-emitting diesel engines. Engines not in use are shut down. 

The overall roadway network pollution burden associated with the Livernois-Junction 

Yard would be reduced with the Preferred Alternative. In the base year of 2004, about 

1.5 tons of PM2.5 were generated on the identified road network of key links (Table 4-29, 

bottom row). In 2015 these levels would be reduced by over half a ton (build and nobuild conditions). By 2030, both the Preferred Alternative and No Action Alternative 

would generate only one-third of the 2004 amounts. While the MOBILE6.2 emission 

factors are not reflective of individual links, they allow a comparison of links. The road 

link of Wyoming between Dix and the new gates would see its burden fall from 0.13 tons 

annually in 2004 to 0.06 in 2015 and 0.05 in 2030, with either the Preferred Alterative or 

No Build Alternative. At the Wayne County level, PM reductions will be realized from 

the shift of traffic from truck to rail. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 173

The vehicles-per-day analysis found the project would increase truck traffic in the 

vicinity of the Dearborn monitor by 146 in 2015. It is not believed the increase in truck 

traffic by the Dearborn monitor will lead to new air quality violations or the delay in 

attaining standards because: 

• It is anticipated that the Dearborn monitor will attain the PM2.5 annual standard of 

15 μg/m3

 by 2010. (The applicable 24-hour conformity standard of 65 μg/m3 has 

never been an issue.) Though the 2007 value of 16.9 μg/m3

 was over the 

standard, values at the end of the year were lower. This reflects the 

implementation during the year of a Sverstal Steel baghouse (air quality control 

mechanism) just upwind of the monitor. All values in Michigan, except one, met 

the annual standard in 2008. 

• Implementation of engine-idle packages on the switch engines in the CONRAIL 

Rougemere Yard, across Wyoming from the Dearborn monitor, is expected to 

have direct results at that monitor. 

• Coincident with the above-cited activities is the institution of low sulfur fuel in 

2007 and the continuation of truck fleet turnover to much cleaner diesel engines, 

dampening the effect of the small increase in truck traffic. 

The emissions factors shown in Figure 4-50 illustrate that, for the typical roadway link 

speed of 30 mph, the emission factor for PM2.5 drops from 0.31 grams per mile in 2004, 

to 0.07 in 2015 (a 75 % reduction) and to 0.03 in 2030 (a 90 % reduction). 

Construction Considerations – PM2.5 

The PM2.5 analysis has considered roadway and terminal construction. However, in 

accordance with 93.123(c)(5), emissions from construction-related activities can be 

considered temporary, if they occur only during the construction phase and last five or 

fewer years at any individual site. Implementation of the DIFT project will extend for ten 

years but consists of a series of elements none of which is expected to last five years. 

Temporary emissions are not required to be included in hot-spot analyses. 

Documentation of Public Involvement – PM2.5 

There has been and will continue to be extensive public involvement for the DIFT 

project. It is documented in Section 7 of this FEIS. Air quality has been a recurrent topic 

at public meetings. Early coordination with agencies has been reinforced and augmented 

by the interagency consultation involved in preparing the Air Quality Protocol that has 

guided the development of the air quality analysis. 

Conclusions Related to PM2.5 Qualitative Hot-spot Analysis 

The conclusion of this qualitative PM2.5 hot-spot analysis is that the proposed project will 

not cause new air quality violations, worsen existing violations, or delay timely 

attainment of the NAAQS. Therefore, no mitigation is required. This applies to both the 

24-hour and annual standards. This conclusion, subject to interagency consultation, is 

based on the following: 

• SEMCOG and MDEQ have been moving aggressively to address air quality 

concerns, in general, and PM2.5, specifically. This includes programs such as 

diesel locomotive retrofits and controls on consumer products. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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• EPA is addressing the non-local component of PM2.5 pollution through programs 

such as the Clean Air Interstate Rule, stricter controls on vehicle emissions – 

including locomotives, and the low-sulfur fuel introduced in 2007. In March 

2008, EPA issued a final rule requiring that idle shutdown packages be added 

when locomotives are remanufactured. This normally occurs every five to 15 

years. 

• A number of major polluters believed to be significant contributors to the PM2.5

emission problem have closed. Mandated enforcement controls are being applied 

at other local industries such as Sverstal Steel, Marathon Oil and U.S. Steel. 

Marathon Oil has announced additional air quality control measures as part of a 

proposed expansion. 

• The SIP analysis addresses the SEMCOG region’s attainment of the PM2.5 65 

μg/m3

 24-hour and 15 μg/m3 annual standards by 2010. DIFT implementation 

will be just beginning at that point. Truck traffic will initially decrease as 

existing businesses are acquired for right-of-way. 

• Information in Figure 4-54 demonstrates that vehicular activity in Southeast 

Michigan can occur without violation of standards. The Livonia monitor is in 

close proximity to some of the heaviest truck movements in the region and is not 

violating the PM2.5 standards. And, this was occurring before the 2007 

elimination of sulfur from fuels and more stringent diesel engine requirements. 

• There are a number of trucking terminals in the area. To reduce fuel costs, most 

trucking companies are implementing anti-idling policies. 

• While recognizing that MOBILE6.2 emission factors are not designed for 

localized analysis, an examination of Wyoming between Dix and the new 

Livernois Junction west side entrances shows the 2004 PM2.5 annual pollutant 

burden of 0.13 tons would be cut in half by 2015 and reduce further to 0.05 tons 

in 2030 with a negligible difference between no action and the Preferred 

Alternative. 

Summary – Preferred Alternative – PM2.5

SEMCOG believes it will reach attainment of the annual PM2.5 standard by 2010, before the 

DIFT project commences. Monitoring data for 2008 that showed all but one monitor in Michigan 

under the standards supports this belief. Emission factors are trending down faster than truck 

traffic will increase. Every indication is that concentrations at nearby monitors will continue to 

trend downward as they are today. An example is that monitors next to some roadways with the 

highest data from truck volumes in the region (Livonia) are not violating standards. Therefore, it 

is concluded that the proposed project will not cause new air quality violations, worsen existing 

violations, or delay timely attainment of the annual or 24-hour NAAQS for PM2.5. 

Based on the above analyses, the project conforms to the Clean Air Act and no mitigation is 

required. 

PM10 Hot-spot Qualitative Analysis

The PM10 hot-spot analysis is substantially the same as the PM2.5 hot-spot analysis. The project 

description is presented in Section 2. A hybrid of Methods A and B is used. The documentation 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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of public involvement is that presented for the PM2.5 analysis. The DIFT project is of “air quality 

concern” (Transportation Conformity Guidance, Chapter 1.3) for PM10 because it would 

represent a transfer point that has “a significant number of diesel vehicles congregating at a single 

location.” (40 CFR 93.123(b)(1)(iii)). 

Background Conditions – PM10

MDEQ’s 2006 Air Quality Report presents 2002 EPA data showing that for PM10 Michigan’s 

sources are: point sources 34 percent, area sources 32 percent, non-road vehicles 20 percent, and 

on-road vehicles 14 percent. 

From 1996 to 2005, there were five 

exceedances of the 24-hour PM10 standard in 

Michigan. Each occurred at the Dearborn 

monitoring station (the closest PM10 monitor 

to the proposed project). Two exceedances in 

2003 and one in 2004 happened when 

construction occurred near the Dearborn 

monitor. However, only the 2004 exceedance 

was considered an “exceptional event” under 

federal criteria. That concentration was not 

used for attainment/nonattainment purposes, 

but the high value for 2003 was used, as the 

trend depicted in Figure 4-56 illustrates. In 

spite of that, the decline in PM10 is clearly 

evident. Many of the actions related to PM2.5

and point sources that are being pursued by 

MDEQ will have beneficial effects on PM10, 

as well. 

PM10 Project Conditions - Future (2015 and RTP Horizon Year - 2030) 

As with PM2.5, a perspective on likely project effects on PM10 concentrations can be gained by 

examining changes in future emission factors. Examples for the 10 mph speed that represents 

truck operation within the Livernois-Junction Yard, and 30 mph that represents roadway links, 

PM10 emission factors decline over time as shown below. 

10 mph 30 mph

• 2004 – 0.38 grams/mile = 100% 

• 2015 – 0.11 grams/mile = 29% of 2004 

• 2030 – 0.05 grams/mile = 13% of 2004 

• 2004 – 0.36 grams/mile = 100% 

• 2015 – 0.11 grams/mile = 28% of 2004 

• 2030 – 0.05 grams/mile = 14% of 2004 

As noted in the PM2.5 qualitative hot-spot analysis, no intersections will operate at Level of 

Service D or worse and so, under the guidelines for hot-spot analysis, no intersections are 

hot-spots. 

Idling trucks in gate areas are expected to generate through 0.08 annual tons of PM10 in 2015 and 

0.15 in 2030. 

The roadway network associated with the Livernois-Junction Yard would experience a decline in 

PM10 pollution in the future with or without the project. In the base year 2004, about 2.2 tons of 

PM10 were generated on the network of key links. By 2010, that would be reduced by almost 

one-half to about 1.1 tons, and by 2030, it would be 1.2 tons. 

Figure 4-56 

Detroit Intermodal Freight Terminal Study 

PM10 at Dearborn Monitor 

Monitored Pollutant: Particulate Matter (PM-10)

 24-hr Average

 Station: 26-163-0033 at 2842 Wyoming Avenue, Dearborn

60

80

100

120

140

160

180

200

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

 PM10 Level (ug/m3) 

EPA Standard (150 ug/m3) 24-Hr Max Average

Linear - 24-Hr Average

Source: The Corradino Group of Michigan, Inc. using MDEQ data. 
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Construction Considerations – PM10 

The DIFT project involves roadway and terminal construction. However, in accordance with 

93.123(c)(5), emissions from construction-related activities can be considered temporary, if they 

occur only during the construction phase and last five or fewer years at any individual site. This 

is expected to be the case on the DIFT. Temporary emissions are not required to be included in 

hot-spot analyses. Implementation of the DIFT project will extend for ten years but consists of a 

series of elements none of which is expected to last five years. 

Conclusions Related to PM10 Qualitative Hot-spot Analysis

The conclusion of this qualitative PM10 hot-spot analysis is that the proposed project will not 

cause new air quality violations. There are no existing violations. This applies to both the 

24-hour standard and the revoked annual standard. This conclusion, subject to interagency 

consultation, is based on the following: 

• SEMCOG and MDEQ have been moving aggressively to address air quality concerns, in 

general, and PM specifically. This includes programs such as diesel locomotive retrofits, 

and controls on consumer products. 

• EPA is addressing the non-local component of PM pollution through programs such as 

the Clean Air Interstate Rule, stricter controls on vehicle emissions – including 

locomotives, and the low-sulfur fuel introduced in 2007. In March 2008, EPA issued a 

final rule requiring that idle shutdown packages be added when locomotives are 

remanufactured. This normally occurs every five to 15 years. 

• A number of major polluters believed to be significant contributors to the PM2.5 emission 

problem have closed. Mandated enforcement controls are being applied at other local 

industries such as Sverstal Steel, Marathon Oil and U.S. Steel. Marathon Oil has 

announced additional air quality control measures as part of a proposed expansion. 

Reduction of PM2.5 at these locations will reduce PM10 as well. 

• The SIP analysis addresses the SEMCOG region’s attainment of the PM2.5 65 μg/m3

 24-

hour and 15 μg/m3

 annual standards by 2010. DIFT implementation will be just 

beginning at that point. Truck traffic will initially decrease as existing businesses are 

acquired for right-of-way. Again, measures to reduce PM2.5 will reduce PM10. 

• There are a number of trucking terminals in the area. To reduce fuel costs, most trucking 

companies are implementing anti-idling policies. 

• While recognizing that MOBILE6.2 emission factors are not designed for localized 

analysis, an examination of Wyoming between Dix and the new Livernois Junction west 

side entrances shows the 2004 PM10 annual pollutant burden of 0.18 tons would be cut in 

half by 2015 and stay at that level through 2030 with a negligible difference between no 

action and the Preferred Alternative. 

Summary- Preferred Alternative – PM10

Substantial reductions in PM10 are expected from industrial sources and monitors near these 

sources have been trending down. Emission factors are trending down faster than truck traffic is 

increasing. Every indication is that concentrations at the Dearborn monitor will continue to trend 

downward as they are today. Therefore, it is concluded that the proposed project will not cause 

new air quality violations of the 24-hour NAAQS for PM10. 
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4.8.7.5 Diesel Emissions Control Measures and Expected Effects 

Based on the above analyses, the project conforms to the Clean Air Act and no mitigation is 

required. Nonetheless, emission control measures will be part of the DIFT project. The Preferred 

Alternative includes a number of on-terminal air quality measures, some of which are required by 

law. These include: 

EPA regulations will continue to improve air quality on terminals as well as roadways. By mid2010 non-road diesel equipment, such as that used to move containers, will be required to use the 

same low-sulfur fuel that on-road vehicles began using in 2007. (This fuel prevents the fouling of 

pollution control equipment on newly manufactured vehicles.) Locomotives have until 2012 to 

start using the fuel. But, as a practical matter, refineries are fully converting to production of the 

ultra low sulfur fuel. All new and remanufactured locomotives must met Tier 3 air quality 

standards by 2009 (which includes idle reduction requirements) and Tier 4 by 2015 (essentially 

adding afterburners and benefiting from clean diesel). So, new equipment will continue to be 

cleaner. 

The railroads could adopt voluntary measures. While new diesel equipment will have cleaner 

burning engines and use low-sulfur fuels, hybrid or electric vehicles are an option. An additional 

optional measure that may be available would be a continued partnering on conversion of local 

switch locomotives to units that emit less and reduce idling. It is notable that CSX has received 

from SEMCOG in collaboration with MDOT Congestion Mitigation Air Quality (CMAQ) grants 

to retrofit four switch locomotives. These must remain in the Dearborn and Detroit yards for a 

minimum of five years. 

4.8.7.6 Construction Impacts – Preferred Alternative 

Construction for the DIFT would represent a series of projects spread over time: 1) land 

acquisition and clearing one section at a time; 2) site development; and, 3) roadway 

improvements at I-94 and Central Avenue. Therefore, the provisions of 40 CFR 93.153 regarding 

general conformity do not apply. 

It is anticipated that most construction related to ground disturbance would occur in one year. 

MDOT’s Standard Construction Specification Sections 107.15(A) and 107.19 would apply to 

control fugitive dust during construction and cleaning of haul roads. 

Construction mitigation is not required, but several voluntary measures are planned that include 

strategies that reduce engine activity or reduce emissions per unit of operating time. Operational 

agreements that reduce or redirect work or shift times to avoid community exposures can have 

positive benefits. For example, agreements that stress work activity outside normal hours of an 

adjacent school campus would be operations-oriented mitigation. Also, technological 

adjustments to construction equipment, such as off-road dump trucks and bulldozers, could be an 

appropriate strategy. These technological fixes could include particulate matter traps, oxidation 

catalysts, and other devices that provide an after-treatment of exhaust emissions. The use of 

ultra-low sulfur diesel will be in effect for non-road vehicles in 2010. 
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4.9 Noise and Vibrations 

Receptors with sensitivity to noise exist adjacent to the Livernois-Junction Yard area, near the 

CP/Expressway and CN/Moterm terminals, and along several residential streets that experience 

truck traffic at these and the CP/Oak terminal (see areas indicated by red arrows on Figures 4-57 

through 4-62). Analysis was performed to determine whether, with the Action Alternatives, any 

areas qualify for noise abatement in the loudest hour of the day. The reader is referred to the 

Noise Study Technical Report for more detail. Analysis found that the number of new intermodal 

trains at the Livernois-Junction Yard would be expected to go from two in 2004 to 8, 10, 18 and 

24 for alternatives 1 through 4. Those numbers assumed the continued operation of 

CP/Expressway, moved to the Livernois-Junction Yard. Since that time, as noted, that operation 

has ended. The Preferred Alternative will bring an estimated 28 intermodal trains to the yard. 

These trains will come in and go out in all directions, so these volumes do not represent trains 

on any one link.

At the Livernois-Junction Yard, homes border the north side of John Kronk Street. At the 

CP/Expressway terminal, the United Community Hospital is along the north side. (Note that since 

the DEIS was published, this hospital has closed.) There are no sensitive noise receptors within 

1,000 feet of the CP/Oak terminal. The residential area west of the Moterm terminal is affected 

by a “consent judgment” issued in 1993 that addressed disputes between the City of Ferndale and 

CN related to rail terminal issues. Pursuant to the judgment, a wall was constructed by CN on the 

west edge of the terminal. Expansion of CN/Moterm under the action alternatives would have 

occurred south of Eight Mile Road in the State Fairgrounds. There is a residential neighborhood 

east of the State Fairgrounds. 

Noise level changes occur where there are changes in train volumes and/or where on-street traffic 

volumes change. For MDOT projects, noise is evaluated on the basis of the loudest hour, as 

expressed in Leq(1hr), i.e., the equivalent noise level or “average” of sound over that loudest hour. 

Rail noise is often expressed in terms of “Ldn,” the day-night noise equivalent level. It is the 

“average” sound level over a 24-hour period, with a 10-dBA penalty added to noise occurring 

between 10:00 p.m. and 7:00 a.m. The penalty is added because of the greater sensitivity to noise 

during the night. Future train volumes were estimated on rail lines around each of the terminals 

to determine whether noise levels would increase in the loudest hour and over a 24-hour period. 

Likewise, changes in truck volumes serving the terminals were projected. 

There are many noise sources around the terminals today associated with truck traffic and the 

activities conducted on the prevailing industrial land uses. A portion of the truck traffic is related 

to intermodal terminal activity today and would be in the future, although in the future the trucks 

would be directed to streets away from residential areas, unlike the condition today at all 

terminals. Notable non-intermodal noise sources near the Livernois-Junction Yard today are: 

• Conveyer belt operations of the material handling business on the south side of the 

Livernois-Junction Yard west of Lonyo. These activities can be heard all the way across 

the yard in the neighborhood to the north. 

• Equipment noise from a variety of industrial/manufacturing activities along the north 

side of Kronk. In several areas, chain link fences and, sometimes, the width of a street 

are all that separate these activities from residences. 

• Truck traffic on Lonyo, Central, Kronk, and Livernois/Dragoon where residential 

properties are very close to the roadway. 

 
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At the CP/Expressway terminal, the principal noise sources are I-75, I-96, Michigan Avenue and 

existing rail operations on the tracks leading to the tunnel to Canada. 

At the CP/Oak Yard, the principal noise sources are Evergreen Road, I-96, M-39 (the Southfield 

Freeway), and industrial machinery and operations north of the intermodal yard. 

At the CN/Moterm terminal, the principal noise source is the yard itself, the railroad tracks north 

and south, and Eight Mile Road. CN Railroad operates under an agreement with the City of 

Ferndale that restricts the activity type by hours of operation on the yard to reduce noise effects 

on the neighborhood. 

4.9.1 Train Noise 

Train noise on rail lines around each of the terminals was estimated based on train type, speed, 

and throttle position.43 Focusing on just those project-related, intermodal trains near sensitive 

areas, the number of trains is forecast to grow from four per day in 2025 under the No Action 

Scenario to 28 under Alternative 3. The 24-trains-a-day increase amounts to about one train 

every hour at the Livernois-Junction Yard area under Alternative 3, when all intermodal traffic is 

consolidated in one location. It is noted that the number of trains increases with lifts. But, in that 

growth process, trains first get longer as demand grows. Then, when the maximum number of 

cars per train is reached, demand is met by scheduling a new train. 

The largest anticipated train volumes are related not to the proposed action covered in the EIS, 

but to the potential expansion of Amtrak service and initiation of commuter train operations eastwest through the Livernois-Junction Yard. It has been indicated Amtrak will have an increase in 

operations from three to nine trains daily (equal to an increase from six to 18 passbys, as the 

trains operate two-way). And, seven commuter rail trains (14 passbys) are projected.44 These 

non-project activities (i.e., Amtrak and commuter rail) will increase daily train volumes along 

Kronk by 32 passbys at relatively high speeds. Because the Amtrak commuter trains serve 

passengers, they would tend to concentrate during peak travel hours so the hourly train volumes 

are expected to increase by four. 

Under FHWA/MDOT guidance, abatement (mitigation) must be considered when noise levels 

approach or exceed 67 dBA (decibels acoustic, a weighting of the noise spectrum to match human 

sensitivity). “Approach” is defined in Michigan as a 1-dBA reduction from the maximum of 67 

dBA. So, the effective criterion for consideration of mitigation is 66 dBA during the loudest hour 

of the day (Table 4-36). Mitigation must also be considered if a project results in a substantial 

increase (10 dBA or more) in noise levels. All sites have been considered. However, it is 

generally known that commercial and industrial sites prefer that there be no interference with the 

view to their establishments. Using the criteria in Table 4-36, abatement has been considered at 

each sensitive location listed in Table 4-37 for each alternative. 

 

43 Transit Noise and Vibration Impact Assessment, Federal Transit Administration, April 1995. 44 Projections in Amtrak and commuter rail operations from Downtown Detroit to Metro Airport, SEMCOG, 2001. 
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Table 4-36 

FHWA Noise Abatement Criteria (NAC) 

(Hourly A-Weighted Sound Level-decibels [dBA]) 

Activity 

Category Description of Activity Category Leq(h) L10(h)

A Lands on which serenity and quiet are of extraordinary 

significance and where the preservation of those qualities is 

essential, if the area is to continue to service its intended 

purpose. 

57 (Exterior) 60 (Exterior) 

B Picnic areas, recreation areas, playgrounds, active sports 

areas, parks, residences, motels, hotels, schools, churches, 

libraries, and hospitals. 

67 (Exterior) 70 (Exterior) 

C Developed lands, properties, or activities not included in 

Categories A and B above. 

72 (Exterior) 75 (Exterior) 

D Undeveloped lands. -- -- 

E Residences, motels, hotels, public meeting rooms, schools, 

churches, libraries, hospitals and auditoriums. 

52 (Interior) 55 (Interior) 

Note: Leq(h) is used in this analysis. 

Source: Based on Table 1 of 23 CFR 772 as found in MDOT’s Noise Policy.
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Table 4-37 

Trains and Noise Levels in Sensitive Areas 

(Note: These are not all intermodal train movements.) 

Terminal Livernois-Junction Yard CP/Expressway Yard b CP/Oak Yard 

Sensitive 

Area Kronk Street East of Martina United Community Hospital Area None 

Daily Train Passbysd Daily Train Passbysd 

 Amtrak Commuter Rail Conventional Freight Inter- modal Total Amtrak Commuter Rail Conventional Freight Inter- modal Total Amtrak Co

2004 6 0 18 4 28 0 0 26 4 30 No receptors 6 Alt. 1 2025 18 14 22 4 58 0 0 31 4 35 No receptors 18 Alt. 2 2025 18 14 22 4 58 0 0 31 4 35 No receptors 18 Alt. 3 2025 18 14 22 20 74 0 0 31 0 31 No receptors 18 Alt. 4 2025 18 14 22 12 66 0 0 31 0 31 No receptors 18 

Pref. 2030 18 14 22 10 64 0 0 31 0 27 No receptors 18 

Leq in Loudest Hour @ 100 Feet from Tracke in dBA – Noise mitigation must be consistent where levels exceed 66 dBA. 2004 71 dBA 69 dBA No receptors Alt. 1 2025 72 dBA 70 dBA No receptors Alt. 2 2025 72 dBA -Abatement incorporated into terminal design 70 dBA – Mitigation not feasible No receptors 69 dBA - AbAlt. 3 2025 74 dBA - Abatement incorporated into terminal design 69 dBA – Mitigation not feasible No receptors Alt. 4 2025 73 dBA - Abatement incorporated into terminal design 69 dBA – Mitigation not feasible No receptors 

Pref. 2030 73 dBA-Abatement incorporated into terminal designf NA No receptors 

Ldn for 24-hour period – Same mitigation as noted above 2004 73 dBA 72 dBA No receptors Alt. 1 2025 74 dBA 73 dBA No receptors Alt. 2 2025 74 dBA 73 dBA No receptors Alt. 3 2025 77 dBA 71 dBA No receptors Alt. 4 2025 76 dBA 71 dBA No receptors 

Pref. 2030 75 dBA NA No receptors 

a This noise sensitive area is at the east end of the Livernois-Junction Yard. Most intermodal trains would not operate in that area. b CP/Expressway intermodal trains come in from Canada and return to Canada via the rail tunnel under the Detroit River and do not progress any further into the U.S. Thc CN intermodal trains come and go from the north and so do not penetrate as far as the Fairgrounds and the residential area to the east today. They would have in the fu

d Some trains operate one way through the yard. Others pull in, then back out. For noise purposes the latter is counted as two passbys. Daily trains are listed for pur

calculation is done for the loudest hour. e Leq shown is as estimated for a reference distance of 100 feet. These values are adjusted to determine whether more distant sensitive receptors are exposed to noise lev

f Along Kronk, a 1,700 foot wall 12 feet in height is planned. A reduction of the peak hour noise level of five decibels or more will be experienced by 39 dwelling units.Source: The Corradino Group of Michigan, Inc. 
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The noise analysis was performed in terms of MDOT’s Noise Policy, recognizing that the DIFT 

project will include special features to buffer the community from intermodal activity. 

Alternative 1 – No Action 

Alternative 1 would not have included any mitigation, as this was the No Action condition. 

• Livernois-Junction Yard - Five homes have front line exposure along the north side of 

Kronk between Cabot Street and Trenton Avenue and would experience noise levels in 

excess of the established FHWA residential criterion. Another 30 homes would experience 

noises levels in excess of the criterion further east on Kronk between Martin Street and 

Livernois Avenue (Figure 4-63). 

• CP/Expressway Terminal - The sensitive receptors are the United Community Hospital 

inside the curve of I-75 and residences over a block away from intermodal operations. The 

Hospital (now closed) receives noise from the intermodal area today above the criterion 

level and that condition would continue under Alternative 1. Noise levels from the 

intermodal activity are not above the criterion for the noted residential area. 

• CP/Oak Terminal - Residences are over 1000 feet away to the north and do not experience 

noise levels from the rail terminal in excess of criteria. This would not change under the 

No Action Alternative. 

• CN/Moterm Terminal - A residential neighborhood east of the State Fairgrounds would be 

exposed to additional train noise under No Action conditions but not at the 66-dBA level 

(Figure 4-64). 

Alternative 2 – Improve/Expand Existing Terminals 

Alternative 2 would expand existing terminals. Current exceedances of the noise abatement 

criterion at the two locations along Kronk at the Livernois-Junction Yard would continue. In the 

neighborhood east of the State Fairgrounds at the expanded CN/Moterm terminal the noise criterion 

would be exceeded for the first time. All these locations would be shielded by walls for security 

that would be designed to mitigate noise a minimum of five decibels, to a point below the 

residential criterion. These walls are considered part of the alternative’s design, notwithstanding the 

“reasonability” criteria specified in Michigan’s Noise Policy. Each terminal is discussed below. 

• Livernois-Junction Yard – In the Cabot Street and Trenton Avenue area the fact that there 

are only five homes with front line noise exposure means that it is not possible to build a 

noise wall that is “reasonable” per Michigan’s Noise Policy. A noise wall has to extend 

beyond the limits of the residences for some distance in each direction to afford noise 

abatement. But, as noted, the DIFT has included a wall in its design around the yard for 

security purposes, so a wall would be constructed at this location as part of the project and 

is not subject to the normal “reasonable” test as it serves security and buffering functions. 

Along the north side of Kronk, between Martin Street and Livernois Avenue, more than 

20 homes have front-line exposure to noise from the Livernois-Junction Yard and almost 

40 would have line-of-sight exposure to the rail activity. These single-family homes 

would experience at least a five-decibel decrease in noise levels with a wall 12 feet high 

that is part of the terminal’s design (Figure 4-63). The wall would be positioned between 

the edge of the rail yard and John Kronk. If this section of the wall that affords noise 

abatement to this residential area were evaluated with respect to Michigan’s Noise 
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Policy, it would be considered reasonable because the cost per dwelling unit is estimated 

to be $24,000, compared to the criterion $36,907 (2006 dollars). 

• CP/Expressway Terminal – Alternative 2 called for terminal expansion east of I-75 and 

south of Michigan Avenue. The United Community Hospital was located inside the curve 

of I-75. Noise mitigation is not feasible at this location because the hospital is multi-story 

and immediately adjacent to I-75 and Michigan Avenue both of which contribute noise to 

the hospital site greater than the expected intermodal rail noise. The residential area, more 

than a block south of the terminal, would not have been adversely affected by noise levels 

from intermodal activity. 

• CP/Oak Terminal – Alternative 2 called for intermodal terminal expansion to the north. 

There are no sensitive receptors within 1000 feet of the terminal. Nonetheless, a wall 

would have been created along the northern edge of the property for security purposes, if 

the terminal had been expanded. 

• CN/Moterm Terminal – Alternative 2 called for terminal expansion in the east section of 

the Michigan State Fairgrounds. Across the railroad tracks to the east of the Fairgrounds, 

seventeen homes along Fayette Street have direct exposure to the existing rail line and its 

associated activity. (Note that no intermodal trains operate today in the Fayette Street area 

as the trains pull into the Moterm terminal from the north and exit to the north.) The 

increase in train activity with intermodal expansion into the Fairgrounds would have been 

two trains a day over No Action conditions with one train in the loudest hour. Due to the 

low level of existing train activity along this track section, the intermodal trains would 

increase the overall noise level to the point that the residential noise criterion would be 

exceeded. The cost of a wall that is 1,600 feet long at this location is estimated to be 

$900,000 or $56,000 per dwelling unit. This does not meet the Noise Policy criterion. 

However, as with other locations, a wall was to be included in the project’s design for 

security purposes, if the terminal had been expanded (refer to Figure 4-64). The wall 

would be built as described above so that the noise criterion is no longer exceeded. 

Alternative 2 would have reduced rail noise except for one location where horn blowing would have 

increased. Horn blowing at rail crossings of roads is generally considered to be the most intrusive 

noise. Trains serving the CN/Moterm terminal presently use their horns in the area of Nine Mile 

Road and Hilton Road. There, intermodal trains would have increased from one to four movements 

daily (as total trains increase from 11 to 27), if the CN/Moterm terminal had been expanded 

(Alternatives 2 and 4). 

On the other hand, at the Livernois-Junction Yard horn use will cease. Trains use their horns at 

Lonyo Avenue and Central Avenue today. There will be no need for horn use there under any of 

the Action Alternatives (Alternatives 2, 3, and 4) as Lonyo would be closed and Central would be 

reconstructed to pass under the rail yard. 

Alternative 3 would have expanded the Livernois-Junction Yard area. There would be increased 

intermodal traffic, but property acquisition in the area would have removed a number of homes, 

and a wall was planned along the north side of the expanded rail yard for security purposes. It 

would have protected from noise the remaining homes in the Cabot/Trenton area and the 

Martin/Livernois area. If this section of the wall that affords noise abatement to the Martin to 

Livernois Avenue residential area was evaluated with respect to Michigan’s Noise Policy, it 

would have qualified for noise mitigation funding. Horn blowing at Lonyo and Central Avenues 

would have ceased. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Alternative 4 would likewise have had impacts that would have been mitigated along east Kronk, 

plus impacts to the area east of Fairgrounds, as noted in Alternative 2. Horn blowing at Lonyo 

and Central Avenues would have ceased. 

4.9.2 Roadway Noise 

As a rule, doubling the energy of sound (twice as much traffic, half as much distance) results in 

about a 3 dBA sound level increase, a level undetectable by most people unless they are in a 

controlled laboratory setting. Thus, noticeable noise impacts typically result only when the road 

is moved much closer to sensitive receptors. 

Under the No Action Alternative (Alternative 1) background traffic was assumed to grow at one 

percent a year and there would have been no mitigation. Under all Action Alternatives, roadway 

noise would not have increased perceptibly (no more than 3 dBA). The DIFT project will focus 

new truck traffic along designated travel paths, notably on Wyoming Avenue and Livernois 

Avenue and away from sensitive receptors. 

The DIFT traffic analysis determined the existing auto and truck volumes on the local street 

networks around each of the terminals. Then, new traffic related to the DIFT project under each 

alternative was added, based on proposed terminal gate locations and access routings. Traffic 

related to properties that would be acquired for the project was removed from the network. The 

net volume change on each roadway link was then estimated for each alternative. The change in 

auto and truck traffic allowed an estimate of the change in noise level. 

Perceptible noise level reductions are expected at several residential locations, resulting from 

reduced truck traffic (Figure 4-65), most notably: 

• Livernois-Junction Yard – Livernois Avenue and Dragoon Street south of Dix to I-75 

(Alternatives 3 and 4). 

• CP/Oak Terminal (Alternatives 2, 3 and 4) – Artesian Street. 

• CN/Moterm Terminal (Alternatives 2, 3, and 4) – Fair Street and Chesterfield Street 

north of Eight Mile Road. 

4.9.3 Vibrations 

Detectable vibrations are normal where trains and trucks are active. During the feasibility study 

for the DIFT project, vibration levels were measured at four locations in the vicinity of the 

Livernois-Junction Yard (Figure 4-66): 1) Beard Elementary School at 1551 Beard Street (along 

the rail line from the east yard area to the Springwells/I-75 area); 2) the Bill Ford Family Services 

and Learning Center, 3401 Schaefer Road; 3) a vacant lot on Porath Court near Wyoming Avenue 

(next to the I-94 off-ramp); and, 4) a vacant lot at 3321 Clippert Street at John Kronk, 

approximately three blocks west of Livernois and north of John Kronk (Figure 4-66). At the first 

location train passbys were measured, at the second trucks, at the third trucks, and at the fourth 

trucks and trains. Although the measurements detected vibration levels perceptible to humans, 

the annoyance level45 was reached only at the Beard School. However, vibrations at annoyance 

levels were noted at the school in the absence of trains as well as when a locomotive passes by. It 

is expected there will be 12 more intermodal train passbys per day, maximum, in 2025 between 

No Action and the busiest Action Alternative. Today there are about 15 passby trains during the

 

45 The “Annoyance Level” is based on a rating curve which is four times higher than the base human perception rating 

curve consistent with procedures of the American National Standard Institute (ANSI) S3.29-1983, reaffirmed in 1996. 
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DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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school day. This increase relating to intermodal growth would amount to less than one additional 

locomotive passby per hour during the school day in 2025 based on the data in Table 4-37. 

The above vibration measurement locations represent “worst case” conditions for all locations 

under any alternative. No vibration mitigation is proposed for any Action Alternative. 

At the CP/Expressway, CP/Oak and CN/Moterm terminals, train and truck passbys occur in a 

manner similar to the Livernois-Junction Yard, except that they are less frequent. At all sites 

there are multiple sources of vibration from non-intermodal truck or rail traffic, such as industrial 

processes, heating and air conditioning units, transformers, and a variety of other indoor and 

outdoor sources. The vibrations due to intermodal activity are detectable but not intrusive in 

these environments. 

Preferred Alternative – Noise and Vibrations 

The Preferred Alternative will include security walls along the north and south sides of the 

Livernois-Junction Yard, where residential uses are adjacent that will mitigate noise levels at a 

set of sensitive receptors by five dBA, consistent with walls considered for all Action 

Alternatives. Along the north side of the yard, along Kronk Street, where the active tracks are 

relatively close to homes, the intermodal train increase is estimated to be from four in 2004 to 

ten in 2030. At this location, the security wall will need to be 1,700 feet long and 12 feet high. 

Such a wall will reduce noise levels by at least five decibels at 39 dwelling units. 

Rail horn use would cease at Lonyo and Central as the former would be closed and the latter 

would pass under the rail yard. Perceptible noise level reductions will occur on Livernois 

Avenue and Dragoon Street south of Dix to I-75 due to reduced truck traffic there. 

The conclusions related to vibrations with the Preferred Alternative are the same as with the 

Action Alternatives. There could be perceptible vibrations at the Beard School less frequently 

than once per hour during the school day (ten new intermodal trains with the Preferred 

Alternative in 2030 versus 12 with Alternative 3 in 2025). No mitigation is proposed because 

vibrations occur in the absence of intermodal train activity. 

4.10 Threatened and Endangered Species 

Threatened and endangered species are officially protected in Michigan by both federal and state 

Endangered Species Acts: Public Act 451, Part 365 and Act 203 of the Public Acts of 1974, 

respectively. An endangered species (E) under the acts is defined as in danger of extinction 

throughout all or a significant portion of its range. A threatened species (T) under the acts is 

likely to become endangered within the foreseeable future throughout all or a significant portion 

of its range. Special concern species (SC) are not afforded legal protection under the acts, 

although MDOT treats them as listed species due to their declining populations. Extensive efforts 

are made to avoid and minimize impacts to these species, and their habitats, in an effort to help 

them from becoming listed in the future. They are species with declining or relict populations in 

Michigan or are species for which more information is needed. 

There will be no effect on threatened, endangered and special concern species at any of the 

terminals under any Action Alternative. According to the MDNR, Wildlife Division: a) at the 

Livernois-Junction Yard area, there are no known occurrences of federal- or state-listed 

endangered, threatened, or otherwise significant species, natural plant communities, or natural 

features (see letter dated September 13, 2002, Appendix A, Section 2); and, b) at the 

CP/Expressway, CP/Oak and CN/Moterm areas, the project should have no impact on rare or 

natural features (see letter dated September 19, 2003, Appendix A, Section 2). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Preferred Alternative 

Conclusions related to threatened, endangered and special concern species have not changed 

from the DEIS. The Preferred Alternative will have no effect on these species. 

A snail called the heath helicellid, Xerolenta (=Helicella) obvia, has been found in the Detroit 

area associated with railroad yards, including the Tri-modal facility on Dix and within the 

Livernois-Junction Yard. It has been considered an agricultural pest in Europe especially of 

grains. It could become a pest in Michigan. Attempts are underway to eradicate the 

populations found so far. Property owners will need to be aware of this potential pest during 

DIFT project development. 

4.11 Waterways/Water Quality/Floodplains/Coastal Resources 

4.11.1 Waterways 

No waterways or waterbodies including lakes, ponds, perennial streams, and intermittent streams 

would be affected by any alternative. 

Preferred Alternative 

No waterways or waterbodies including lakes, ponds, perennial streams, and intermittent 

streams would be affected by the Preferred Alternative. There would be no effects on coastal 

zone resources. 

4.11.2 Water Quality 

All of the Action Alternatives would have had minimal impacts on the quality of surface or 

groundwater, or the level of the groundwater table. There are no floodplains at any of the sites. 

No physical disturbance of stream and riparian vegetation would occur, as there is no open water 

or waterway at any of the sites. All of the sites are located in developed urban areas. In the 

future, surface runoff from all of the sites would have continued to flow to the combined sewer 

system. Because the unpaved portions of existing terminals would have remained unpaved under 

Alternative 1 – No Action, the amount of runoff for Alternatives 2, 3 and 4 would be greater than 

Alternative 1. That terminal runoff (including that for newly paved surfaces) would have been 

directed to an engineered on-site collection system first, using oversized pipes and swales to 

ensure future flow rates were not increased. Because of the combined sewer system, all water 

would have been treated before it flowed to the Detroit River. The Detroit Water and Sewer 

Department has developed a Combined Sewer Overflow (CSO) screening and disinfection 

facility, Baby Creek, just south of the DIFT project. Another CSO is planned for the area 

between Jefferson Avenue and the Detroit River northeast of Fort Wayne.

The railroads, like many other industries, are required by the federal government to have 

pollution prevention plans to prevent impacts to stormwater, surface water and groundwater. 

These plans include, among other things, provisions requiring spill prevention, response, training 

and reporting. 

Groundwater is present in the glacial drift and underlying sedimentary bedrock formations. The 

regional geology consists of surficial lacustrine clay and silt deposits underlain by limestone, 

shale and sandstone beds of Ordovician to Pennsylvania age. The glacial drift in Wayne County 

ranges from a few feet to as much as 330 feet. These deposits are thinnest near the mouth of the 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Detroit River and thicken toward the west and northwest. Most of Detroit sits on an ancient 

glacial, clay plain lake bed and salt mines. 

The quality of groundwater is highly mineralized. There are no known potable water wells, 

including public water supply wells in the vicinities of the terminals. The water supply for 

Detroit is Lake St. Clair. None of the terminals are located in wellhead protection areas. 

Because of the underlying clays and the proposed stormwater collection/storage system, 

infiltration to groundwater was expected to be insignificant for any Action Alternative. 

Preferred Alternative 

Conclusions related to water quality do not change but options have been developed to deal 

with the increased volume of surface runoff that will result from the increased proportion of 

the Livernois-Junction Yard that is paved. The Preferred Alternative’s increased surface 

runoff will be directed to an engineered on-site collection system to ensure that future flow 

rates leaving the site do not increase. The flow will be subject to NPDES permitting. The 

DIFT improvements on the yard will be designed and constructed by the railroads. The 

railroads will apply for the NPDES permits. Requirements of the permits are not known at this 

time. Whether any treatment will be required is not known. Stormwater will flow: 1) to the 

local combined sewer system and thence Detroit’s Wastewater Treatment Plant; or, 2) directly 

to the Rouge River via new stormwater pipes constructed within railroad right-of-way. Under 

the second option, the stormwater would not pass through the wastewater treatment plant and 

fees to the Detroit Water and Sewer Department required under the first option would be 

avoided. Planning to-date calls for detention on site in pipes. Under severe storms, minor 

ponding around catch basins would add to the stormwater detention storage. The yard is 

relatively impervious today (gravel and packed earth). The surface area subject to a decrease 

in permeability is approximately 362 acres. The additional runoff to be detained would be 8.14 

acre-feet from a ten-year storm event. 

Paving the yard will result in significantly less erosion and silt carried to local roads which 

now clog the local storm drainage system. Likewise, reduction in dirt carried to local roads by 

vehicle tires and/or blown there will benefit water (and air) quality. 

4.11.3 Floodways and Floodplains 

Floodplain analysis must be performed consistent with 23 CFR 650 and Executive Order 11998. 

The analysis must examine whether a project creates or increases a hazard to people and/or 

property, and whether there is an impact on natural and beneficial floodplain values. These 

values include: fish, wildlife, plants, open space, natural beauty, scientific study, outdoor 

recreation, agriculture, aquaculture, forestry, natural moderation of floods, water quality 

maintenance, and groundwater recharge. 

There are no waterways (streams/surface drains) in the areas of the Action Alternatives. The 

project areas are drained by combined sanitary/storm sewers. 

There will be no encroachment on any regulatory floodway (the main channel that carries water) 

or floodplain (the area into which water extends during periods of flooding) in any alternative. 

No significant hazard to people or property will result from the project. There will be no effects 

to the 100-year floodplain. The Action Alternatives will not result in a loss in natural and 

beneficial floodplain values. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4.11.4 Coastal Resources 

The Preferred Alternative is outside Michigan’s Coastal Zone and will have no effect on 

resources therein. Likewise, it is not subject to the Great Lakes Coastal Barrier Act. There 

will be no effect on any coastal barrier, critical dunes, or high risk erosion areas. 

Preferred Alternative 

Conclusions related to floodways and floodplains do not change; the Preferred Alternative will 

not affect floodways or floodplains. 

4.12 Wetlands 

Fieldwork to identify wetlands was performed consistent with state and federal guidance at the 

intermodal terminals in the spring of 2002, the spring and summer of 2003, and the summer of 

2004. State and federal laws and regulations (Federal Executive Order 11990 and Part 303 of 

Michigan Public Act 451 of 1994) protect wetlands and require that: 1) they be avoided to the 

extent feasible and prudent; 2) if unavoidable, impacts be minimized; and, 3) mitigation be 

provided in the form of wetland replacement, generally as close as possible to, and in the same 

watershed as, the impact area. 

The US Geologic Service (USGS) topographic maps of the sites revealed flat topography 

substantially altered by industrial and commercial development. Site visits confirmed that there 

is no undeveloped land on any of the parcels. Vegetated surfaces are mainly road medians, lawns, 

and parks. The National Wetland Inventory (NWI) maps of the sites indicated that no wetlands 

occurred on or adjacent to any site. The Soil Survey of Wayne County, Michigan is not a 

complete survey of all areas of Wayne County. The National Resource Conservation Service 

(NRCS) did not map areas that had been fully developed prior to the time the original survey was 

conducted. The areas were not surveyed and not included in the mapped soil units for this section 

of Detroit because the areas have been urbanized for several decades, with considerable 

disturbance to natural soils. 

4.12.1 Alternative 1: No Action 

Under the No Action Alternative there would have been no effect on wetlands. 

4.12.2 Alternative 2: Improve/Expand Existing Terminals

Livernois-Junction Yard 

One wetland (Palustrine Emergent) was identified within the area of investigation. This area is 

located in the southeast corner of a railroad overpass crossing Central Avenue. It is 

approximately 20 x 20 feet (400 square feet or less than 0.01 acre) and predominantly consists of 

willow (Salix spp.) and common reed (Phragmites australis). Wetland hydrology was evidenced 

by water seeping out of the coarse gravel railroad ballast and fill that forms the foundation of the 

overpass on the east side of Central Avenue. This water apparently seeps down from the railroad 

and collects in a flat area next to a used auto parts business. The drainage pattern appears to 

direct water from the flat wetland area to the sidewalk on the east side of Central Avenue and 

north to the lowest point of the street under the viaduct. 

This small area is located in a highly urbanized setting, next to a busy street and wedged between 

the railroad track and the salvage yard. Because it is flat, it appears to have minimal stormwater 

storage capacity. Because it is next to an auto salvage yard, its function as a filter is questionable 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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as wetland drainage water may well take up chemicals seeping from the salvage yard prior to 

overflowing onto the sidewalk and draining into the street. The patch is quite small so that its 

wildlife value is judged non-existent. The plant species (common reed [Phragmites australis] and 

willow [Salix spp.]) are not particularly useful to wildlife as food sources and they are not thick 

enough to provide much cover. In summary, this is a very small, marginal wetland of minor 

environmental significance. MDOT, through a cooperative agreement with MDEQ, will build or 

restore compensatory mitigation for unavoidable wetland impacts using a “Moment of 

Opportunity” site allowed under the General Permit Category of Part 303 of P.A. 451 (1994, as 

amended). 

CP/Expressway Terminal 

Field investigation revealed no wetlands in this highly urbanized area. Vegetated areas consisted 

of turfgrass (Poa spp.) with weedy species such as common plantain (Plantago major), and 

dandelion (Taraxacum officinale). A small patch of common reed (Phragmites australis) was 

found growing out of a crack where the vertical wall of a viaduct intersects with street pavement 

on the northeast side of the 20th Street viaduct. This area apparently receives water draining from 

the railroad ballast on top of the viaduct, down to the crack along the street where it temporarily 

pools around a pile of discarded tires stacked against a chain-link fence. This area, approximately 

ten square feet in total area, is not considered a wetland. 

CP/Oak Terminal 

Examination of the site aerial photograph indicated one area that might be capable of supporting 

wetlands, an abandoned field located in the northeast corner of the I-96/Evergreen Road 

interchange. Field investigation revealed no wetlands in this area, only old-field vegetation and 

some small elm (Ulmus americana) and box elder (Acer negundo) trees. Notable wildlife 

observed during the site visit included two American woodcocks (Scolofax minor), several 

eastern cottontail rabbits (Sylvilagus floridanus), and a Ring-necked pheasant (Phasianus

colchicus). Field investigation also revealed some vegetation in a low area of 200-300 sq. ft. 

extent alongside the ballast of an abandoned railroad spur in this area. But the soils and 

hydrology in this area do not support determination that it is a wetland. 

CN/Moterm Terminal 

At the south end of the Fairgrounds near the railroad tracks is a 3,200-square-foot (0.07-acre) low 

quality Palustrine Emergent wetland created by earth stockpiling. It supports 13 wetland plant 

species. The area contains piles of soil, concrete and asphalt. This site, like the site at the 

Livernois-Junction Yard, would also have been mitigated through the “Moment of Opportunity” 

process. 

4.12.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal Activity at 

Livernois-Junction Yard Area

The conditions of Alternative 2 for the Livernois-Junction Yard, presented above, applied here. 

4.12.4 Alternative 4: The Composite Option 

The conditions of Alternative 2 for the Livernois-Junction Yard and the CN/Moterm terminal, 

presented above, applied here. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Preferred Alternative 

The 400 square foot (less than 0.01 acre) Palustrine Emergent wetland identified at the 

southeast corner of Central Avenue and the railroad overpass, at the south limit of the current 

yard, will be lost under the Preferred Alternative. MDOT, through a cooperative agreement 

with MDEQ, will build or restore compensatory mitigation for unavoidable wetland impacts 

using a “Moment of Opportunity” site allowed under the General Permit Category of Part 303 

of P.A. 451 (1994, as amended). 

The project is in compliance with Executive Order 11990, “Protection of Wetlands.” It has 

been determined that there is no practicable alternative to the proposed action, and that the 

proposed action includes all practicable measures to minimize harm to wetlands that may 

result from such use. 

4.13 Historic and Archaeological Resources 

The National Register of Historic Places has established criteria for determining a property’s 

historic significance. These criteria require a property to have integrity of location, design, setting, 

materials, workmanship, feeling, and association. Additionally, the property typically has to be 50 

years old or older, and meet one or more of the following: Criterion A) be associated with a 

significant event; Criterion B) be associated with the lives of significant persons; Criterion C) 

embody the distinctive characteristics of a type, period or method of construction, or represent the 

work of a master; or, Criterion D) have yielded or may be likely to yield information important in 

history or prehistory (usually archaeological sites). 

To satisfy Section 106 of the National Historic Preservation Act and Section 4(f) of the Department 

of Transportation Act, MDOT contacted the Michigan State Historic Preservation Office (SHPO) for 

help in identifying project area historic and archaeological sites. The SHPO recommended that 

MDOT conduct historic and archaeological surveys to locate sites eligible for listing on the National 

Register of Historic Places. The FHWA and MDOT began cultural resource surveys by delineating 

an Area of Potential Effect (APE) for the project. The APE represents the maximum area potentially 

affected, both directly and indirectly, by the project and is approved at the outset of the analysis by 

the State Historic Preservation Office (SHPO). The SHPO agreed the APE would extend 300 feet 

beyond the existing rail yards and the proposed expansions for above-ground resources. 

Surveys of historic and archaeological resources took place within the APE in 2002, 2003 and 2004. 

The survey results, project impacts, and mitigation measures are described in separate reports.46

 

46 “Archaeological Literature Search and Field Review of the Detroit Intermodal Freight Terminal (DIFT) Project 

Detroit and Dearborn, Michigan”, Commonwealth Cultural Resources Group, November 2002; “Assessment of 

Archaeological Sensitivity for the Proposed CP/Oak - Detroit Intermodal Freight Terminal City of Detroit, Wayne 

County, Michigan”, Commonwealth Cultural Resources Group, April 2003; “Above-ground Resources Assessment for 

the Proposed CP/Oak - Detroit Intermodal Freight Terminal City of Detroit, Wayne County, Michigan”, 

Commonwealth Cultural Resources Group, May 2003; “Assessment of Archaeological Sensitivity for the Proposed 

CP/Expressway - Detroit Intermodal Freight Terminal City of Detroit, Wayne County, Michigan”, Commonwealth 

Cultural Resources Group, June 2003; “Above-ground Resources Assessment for the Proposed CP/Expressway - 

Detroit Intermodal Freight Terminal City of Detroit, Wayne County, Michigan”, Commonwealth Cultural Resources 

Group, June 2003; “Assessment of Archaeological Sensitivity for the Proposed CN/Moterm - Detroit Intermodal 

Freight Terminal City of Ferndale, Oakland County, Michigan”, Commonwealth Cultural Resources Group, August 

2003; “Assessment of Archaeological Sensitivity for the Proposed CSX Livernois - Detroit Intermodal Freight 

Terminal Cities of Detroit and Dearborn, Wayne County, Michigan”, Commonwealth Cultural Resources Group, 

September 2003; “Above-ground Resources Survey of the Michigan State Fair Property - Detroit Intermodal Freight 

Terminal Project City of Detroit, Wayne County, Michigan”, Commonwealth Cultural Resources Group, February 

2004; “Above-ground Resources Assessment for the Proposed CSX-Livernois-Detroit Intermodal Freight Terminal 

Cities of Detroit and Dearborn, Michigan,” Commonwealth Cultural Resources Group, May 2004.
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Each of the Action Alternatives would have had an “adverse effect” on above-ground cultural 

resources. In making this determination, the criteria of adverse effect, as listed in Section 106 of 

the National Historic Preservation Act were applied. A project results in an adverse effect on an 

historic property when it diminishes those characteristics that make it historically significant. 

Activities that may result in an adverse effect include demolition, landscape changes, isolation of 

a property from its setting, and the introduction of visual, audible or atmospheric elements out of 

keeping with the character of the property. 

Adverse effects on historic resources are avoided when prudent and feasible. When it is not prudent 

and feasible to avoid adverse effects, they are minimized. Because the Action Alternatives would 

have adversely affected an historic property, mitigation measures would have been developed if any 

of these alternatives had advanced after the public hearing. The Preferred Alternative has adverse 

effects. So, measures have been developed in consultation with the SHPO, the community, and 

the Advisory Council on Historic Preservation in Washington, D.C. That information is 

presented in Section 6 of this document, which covers impacts to Section 4(f) properties. 

Research and field review found no known National Register eligible archaeological resources at 

any intermodal terminal for any alternative. However, at the time of the DEIS, the SHPO agreed 

with the assessment that field investigations at two archaeological sites at the Livernois-Junction 

Yard should be conducted to determine whether archaeological deposits exist prior to any 

construction (see letter dated November 22, 2004 in Appendix A, Section 2). Subsequently, it 

was determined that the Preferred Alternative would avoid the Jacques Baby Mill site and that 

recent construction activities by the railroad in the vicinity of the Michigan Central Stockyard 

Hotel site has likely further buried the site under fill. Ground disturbing activities will not be 

conducted in this area.

4.13.1 Alternative 1: No Action 

Under the No Action Alternative, there would have been no government-sponsored effect on any 

above-ground historical resources or on any archaeological resources. 

4.13.2 Alternative 2: Improve/Expand Existing Terminals

Livernois-Junction Yard 

Implementation of Alternative 2 at the Livernois-Junction Yard would not have had an adverse 

effect upon National Register-eligible or listed above ground resources. 

An archaeological survey was performed. The impact of urban and industrial development over 

the past century has fundamentally reduced the potential for archaeological site survival. This is 

especially evident in the destruction of the natural drainageways that previously laced the project 

area. Cut-and-fill operations along the creek margins, combined with the opening of brickyard 

clay pits, have had a catastrophic impact on the integrity and continued survival of any 

archaeological sites associated with the DIFT project expansion/acquisition parcels. 

CP/Expressway Terminal 

A reconnaissance-level survey of the APE found one structure, one building, and one district that 

are recommended eligible for the National Register (Table 4-38 and Figure 4-67). One of these 

three that would have been adversely affected by Alternative 2 is discussed next. The State 

Historic Preservation Office (SHPO) has concurred with the eligibility and effect determinations 

for the CP/Expressway terminal (see letter in Appendix A, Section 2 dated October 18, 2004). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-38 

Summary of Project Effects on Potential 

National Register Eligible Cultural Resources 

Alt. Terminal 

ID No. on 

Figure 

1-16 

Site Name Location Description Effect 

2 CP/ 

Expressway 

1 Michigan Central Railroad 

Passenger Station and Bridge 

Deck 

West Vernor Highway Railroad station and bridge 

decks, circa 1905-1915 

Proposed/modified tracks on 

bridge deck. Adverse effect. 

2 CP/ 

Expressway 

2 Roosevelt Park Annex Maranette St. and 14th St. Post Office PWA Moderne, 

circa 1935 

No property to be taken. No 

adverse effect. 

2 CP/ 

Expressway 

3 St. Paul’s German Evangelical 

Lutheran Church district 

17th and Rose Street Gothic Revival and Italianate 

church, school, and residence, 

circa 1892 

No property to be taken. No 

adverse effect. 

2/4 CN/ 

Moterm 

4 Exhibition Building Historic 

District 

Michigan State Fairgrounds Dairy Cattle Building, 

Coliseum, Agriculture 

Building, Poultry Building, 

and Whitehall 

No property to be taken. No 

adverse effect. 

2/4 CN/ 

Moterm 

5 Band Shell Michigan State Fairgrounds Outdoor proscenium stage, 

circa 1938 

No property to be taken. No 

adverse effect. 

2/4 CN/ 

Moterm 

6 Grant House Michigan State Fairgrounds Balloon-framed house 

associated with Ulysses S. 

Grant, circa pre-1850 

No property to be taken. No 

adverse effect. 

2/4 CN/ 

Moterm 

7 Garland Stove Michigan State Fairgrounds Large wood carved stove for 

commercial advertising art, 

circa late 1800s 

No property to be taken. No 

adverse effect. 

3/4

Pref.

Liv-Jct 8 Michigan Box Company/ 

Spranger Wire Wheel 

Company 

7175 Clayton Street Factory originally built to 

make auto parts. Now pallets 

are made at the site. 

Right-of-way needed for 

Alternatives 3 and 4 and 

Preferred Alternative would 

require demolition of this building. 

Adverse effect. MOA required. 

3/4 Liv-Jct 9 Rickenbacker Motor 

Company/Springfield Body 

Corporation 

4815 Cabot Former factory that produced 

automobiles 

Alternative 3 would require a 

portion of the factory that is not 

eligible. Alternative 4 and 

Preferred Alternative would 

require land south of the 

buildings but no parts of the 

building. No adverse effect.

3/4 Liv-Jct 10 Frederick Wolf and Sons 

historic homes 

West side of Central near 

St. John St. 

Three 1890s Queen Ann 

homes (one is outside APE) 

No property to be taken. No 

adverse effect. 

3/4

Pref.

Liv-Jct 11 House 6332 John Kronk Historic home No property to be taken. SHPO 

will review Preferred Alternative

security wall design. 

3/4 Liv-Jct 12 Tomms House 3434 Martin Street Historic home No property to be taken. Adverse 

effect under Alternative 3. 

3/4 Liv-Jct 13 Markey House 3504 Martin Street Historic home No property to be taken. Adverse 

effect under Alternative 3. 

3 Liv-Jct 14 Federal Screw Works Factory 3301-3401 Martin Street Former factory that produced 

fasteners for the auto industry. 

Area needed for Alternative 3 

would require this property. 

Adverse effect. 

3/4 Liv-Jct 15 Livernois Avenue Art Deco 

Bridge 

Near Livernois and John 

Kronk 

Bridge No property to be taken. No 

adverse effect. 

3/4 Liv-Jct 16 Southern Avenue Twin 

Warren Truss Bridge 

Southern Avenue west of 

Wyoming Street 

Bridge No property to be taken. No 

adverse effect. 

3/4 Liv-Jct 17 Clippert Brick Company 

office 

10500 Southern Avenue Former office building for 

area brick companies 

Building will not be affected. No 

adverse effect. 

3/4 Liv-Jct 18 Central Avenue Fire 

Station/Engine Company No. 

37 

2820 Central Avenue Fire Station No property to be taken. No 

adverse effect. 

Source: Commonwealth Cultural Resources Group 
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The Michigan Central Railroad (MCRR) passenger station and bridge-deck structure spanning 

West Vernor Highway is recommended eligible as a contributing element of the NRHP-listed 

Michigan Central Railroad Station. Its potential for NRHP nomination, either individually or as 

an element of the NRHP-listed passenger station, relates directly to its unique character as a 

marker in the early evolution of monolithic reinforced concrete bridge/deck design specific to the 

ca. 1905-1915 period. Its eligibility would be based on the structure’s significance in engineering 

design (i.e., Criterion C). Under Alternative 2, proposed/modified tracks would have been 

constructed on the bridge deck structure causing an adverse effect. Hence, a Memorandum of 

Agreement (MOA) would have been necessary and would have been included in this FEIS, if 

Alternative 2 had become the preferred alternative. It would have stipulated conditions to 

mitigate impacts to the property adversely affected. 

The two other properties eligible for the National Register but not affected by Alternative 2 are 

discussed next. 

The former U.S. Post Office Roosevelt Park Annex is recommended eligible for listing on the 

NRHP as an individual resource. Built in 1935 as a PWA-financed project by the noted Detroitbased architectural firm of Albert Kahn, Inc., it stands among the few of the later non-industrial 

buildings of Kahn design. It is eligible as it is the product of a recognized master architect and 

embodies a distinctive type of public architecture (PWA Moderne) by incorporating elements of 

Craftsman/Art Deco composition in its brickwork facades, along with the streamline form of Art 

Moderne bracketing on the building’s main entry (i.e., Criterion C). No property will be taken 

from this site and project implementation will not represent an adverse effect. 

The three-building complex associated with St. Paul’s German Evangelical Lutheran Church is 

recommended eligible as an historic district. It includes three brick buildings originally (1872/1873) 

associated with the St. Paul’s German Evangelical Lutheran Church: the church, school, and 

residence located on the east side of 17th Street. While all are minimally altered, they continue to 

maintain a high degree of architectural integrity, and they are characteristic of styles (Gothic 

Revival and Italianate) popular during the third quarter of the 19th Century (Criterion C). St. Paul’s 

German Evangelical Lutheran church is the only surviving example of three German churches 

established between 1859 and 1873 in the immediate three-block area of 16th and 17th streets. The 

church, school, and parsonage are among the few surviving elements of the German ethnic 

neighborhood that emerged along the westerly fringe of the city’s Irish-dominated Corktown district 

during the third quarter of the nineteenth century. As such, these three elements of the proposed St. 

Paul’s Church Historic District also meet Criterion A, which requires that the district be associated 

with events or trends significant in history. No property would have been taken at these sites and 

project implementation would not have represented an adverse effect. 

One previously identified archaeological site is in the study area (20WN274). It is located well to 

the south of the existing CP/Expressway terminal and would not have been adversely affected by 

facility expansion. Early 20th Century redevelopment impacts associated with the 1913 MCRR 

station and yard facility were extensive. These entailed the creation of multiple grade separations 

that surround the entirety of the property proposed for terminal expansion, along with cut-and-fill 

operations that raised the level of portions of the yard as much as 5 feet (1.5 m) to 8 feet (2.4 m) 

above the original ground surface. Therefore, given both the intensity and character of alterations 

in and around the project site the probability of encountering intact prehistoric or early historic 

archaeological remains is minimal. The use of the existing tractor-trailer yard and the Detroit 

Department of Public Works property, as part of the larger CP/Expressway expansion area, would 

not have constituted an adverse affect upon area archaeological resources. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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CP/Oak Terminal 

Nineteen commercial/industrial buildings dating to a ca. 1945-1959 context were identified and 

surveyed within the APE. None were judged eligible for nomination to the National Register. As 

a result of this assessment, the proposed DIFT expansion would not have had an adverse effect 

upon National Register-eligible above-ground resources. The SHPO concurred that the APE for 

this terminal contained no National Register-eligible resources (see letter dated October 18, 2004 

in Appendix A). 

No previously recorded archaeological sites were found in the APE. Industrial development at 

and around the CP/Oak terminal has been a dominating aspect of land use since the 1940s. The 

trend was intensified from the 1950s through early 1970s with the same additional rebuilding 

activity in the easterly half of the APE during the 1990s. As a result, approximately 95 percent of 

the APE can be defined as built area, consisting of both buildings and extensive paved lot areas. 

Therefore, due to the intensity of this past development of the CP/Oak project site, coupled with 

the elimination of the bulk of the open grounds west of Westwood, project implementation would 

not have represented an adverse effect upon area archaeological resources. 

CN/Moterm Terminal 

A review of previously recorded above-ground resources revealed three sites listed on the 

National Register in the area to the west of the proposed terminal expansion at the Michigan State 

Fairgrounds (MSF): the Dairy Cattle Building, the Coliseum, and the Agriculture Building 

(Table 4-38) (Figure 4-68). A reconnaissance-level survey of the MSF found that these three 

sites, along with the Poultry Building and Whitehall, should be combined as one district that is 

recommended eligible for the National Register. In addition to this listing, the survey found three 

other individual sites at the MSF that are recommended eligible for the National Register: the 

Band Shell, the Grant House, and the Garland Store. No property would have been taken from 

any of these sites. 

The SHPO concurred with the eligibility determinations for these sites and that there would be no 

effect on any of the properties identified as National Register eligible within the State 

Fairgrounds property (see letters dated October 18, 2004 and January 21, 2005, in Appendix A). 

 

The area that would be needed for the expansion of the CN/Moterm yard is called the “Railroad 

Lot” on contemporary site plans of the Fairgrounds. Its existence as a leased property has been 

an ongoing feature of the Fairground’s land use since at least 1935 when the lot was occupied by 

the Detroit Racing Association. The Railroad Lot presently serves as a distinct component of the 

State Fairgrounds property used for automotive storage under a lease agreement with an auto 

distributor. Based on the foregoing, the Railroad Lot and its components are not eligible for 

listing on the NRHP either individually or as part of a district. 

No previously-recorded archaeological sites were found in the APE. Industrial development and 

redevelopment has been ongoing within the APE over the last 70 years. These activities include: 

1) filing water courses on the east portion of the State Fairgrounds for development as a horse race 

track; 2) conversion of the horse track to auto use, including construction of bleachers; 3) grade 

separation of the railroad and Eight Mile Road; 4) construction and later removal of concrete pads 

put in place for horse barns along the north and south edges of the Fairgrounds; 5) development of a 

private softball field complex; 6) paving related to earlier railroad use; and, 7) covering with gravel 

to provide a surface for new vehicle storage. Therefore, the probability of encountering intact 

historic or prehistoric archaeological remains within the proposed expansion area is extremely low. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4.13.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal Activity at 

Livernois-Junction Yard Area

A field survey of all pre-1959 standing structures was conducted, along with literature research 

and interviews with knowledgeable persons in the area to determine their historic significance 

and eligibility for listing on the National Register. Public meetings were held at which 

information about such resources was discussed. Consultation was undertaken with the SHPO 

(see letters dated October 18, 2004 and January 21, 2005, in Appendix A). As a result, 11 

sites/districts were considered potentially eligible for listing on the National Register at the 

Livernois-Junction Yard area under the Consolidation Alternative (Table 4-38 and Figure 4-69). 

Four of the eligible sites were expected to suffer an adverse effect from Alternative 3 – the 

Spranger Wire Wheel Company building, the Federal Screw Works Factory, the Markey House, 

and the Tomms House. Additional information was needed on one of the other sites (the house at 

6332 John Kronk) to determine if there will be an adverse effect. Nonetheless, due to the 

determination of an adverse effect on the four properties cited above, a Memorandum of 

Agreement (MOA) was necessary and was to be included in this FEIS, if Alternative 3 had been 

the preferred alternative. The MOA was to stipulate conditions that mitigate impacts to the 

property adversely affected. Section 6 of the DEIS provided a Draft Section 4(f) Evaluation of 

the property that would experience an adverse effect and that would be covered in the MOA. 

That section has been updated for the Preferred Alternative for this FEIS. Potentially eligible 

sites in the APE are discussed next. 

The following were in, or partially in, the footprint of Alternative 3. 

• The Michigan Box Company, also known as the General Box Company, and the 

Spranger Wire Wheel Company/Detroit Wire Wheel Corporation at 7175 Clayton Street 

between Parkinson Avenue and Central Avenue is eligible for the National Register. 

Alternative 3 would have required the demolition of this property, resulting in an adverse 

effect. 

• The Federal Screw Works factory at 3301-3401 Martin Street is eligible for the National 

Register. Alternative 3 would have required the demolition of this property, resulting in 

an adverse effect. 

• The Rickenbacker Motor Company building/Springfield Body Corporation that runs 

along Cabot is eligible for the National Register. Eligibility only applies to the northern 

part of the building not the southern part that was added in the late 1950s. A portion of 

the non-National Register eligible southern part of the building is inside the project 

footprint. Removing this non-eligible portion of the building would have had no adverse 

effect according to the SHPO (see letter dated January 21, 2005, in Appendix A). 

The following are within the APE but outside of the proposed expansion footprint of Alternative 

3. No property would have been taken from these sites. 

• A historic house at 6332 John Kronk on the east end of the project area. A determination 

on whether there is an adverse visual effect on this site was to be made in consultation 

with the SHPO. 

• The Tomms House at 3434 Martin Street. There would have been a visual adverse effect 

due to the removal of the Federal Screw Works Factory across the street. 

• The Markey House at 3504 Martin Street. There would have been a visual adverse effect 

due to the removal of the Federal Screw Works Factory across the street. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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The following are also within the APE but outside of the project footprint. No property would 

have been taken from these sites and implementing Alternative 3 would not have represented an 

adverse effect. 

• Three 1890s Queen Ann homes associated with Frederick Wolf and his sons in the 

Central Avenue and St. John Street area at 4229, 4237, and 4311 Central Avenue make 

up a historic district that is likely eligible for the National Register. 

• The Livernois Avenue Art Deco Bridge (rail) over Livernois Avenue near John Kronk. 

• The Southern Avenue Twin Warren Truss Bridge on Southern Avenue west of Wyoming 

Street (still to be determined if this site is eligible for the National Register). 

• The Clippert Brick Company Office at 10500 Southern Avenue. 

• The Central Avenue Fire Station/Engine Company No. 37 at 2820 Central Avenue. 

An archaeological survey was performed in the APE for Alternative 3. All recorded sites are well 

beyond the APE. Most of the area has been previously disturbed. The impact of urban and 

industrial development over the past century has reduced the potential for archaeological site 

survival. This is especially evident in the destruction of the natural drainageways that previously 

laced the project area. Cut-and-fill operations along the creek margins, combined with the 

opening of brickyard clay pits, has had a catastrophic impact on the integrity and continued 

survival of any archaeological sites associated with the terminal expansion/acquisition parcels 

and in the APE. However, the SHPO agreed with the assessment that field investigations at two 

archaeological sites should be conducted prior to construction, if Alternative 3 were chosen as the 

preferred alternative. 

4.13.4 Alternative 4: The Composite Option

The Composite Alternative proposed the intermodal activities of three railroads (CSX, NS and 

Canadian Pacific) be consolidated at Livernois-Junction Yard, while the CN/Moterm terminal 

would be expanded onto the “Railroad Lot” on the Michigan State Fairgrounds property. The 

effects on cultural resources under this alternative were the same as those at CN/Moterm under 

Alternative 2 and smaller at Livernois-Junction Yard than under Alternative 3. No property 

would have been taken from any of the eligible historic sites at the Fairgrounds. At the 

Livernois-Junction Yard the National Register eligible Spranger Wire Wheel Company would 

have been required for Alternative 4, resulting in an adverse effect. However, unlike Alternative 

3, there would not have been an adverse effect on the Federal Screw Works Factory, the Markey 

House, and the Tomms House. 

4.13.5 Preferred Alternative 

Above-ground Structures - The Preferred Alternative will have an adverse effect on the 

Michigan Box Company by causing its removal. A Memorandum of Agreement (MOA) related 

to this property is included in Appendix C. Impacts to the property are addressed in Section 6 

of this FEIS, which is the Final Section 4(f) Evaluation for the DIFT Project. The SHPO has 

also stated (letter dated June 20, 2005 in Appendix A) the “construction of a barrier wall 

alongside the railroad yard across the street from the house [6332 John Kronk] has the 

potential to result in an Adverse Effect on the house through its height, design, and placement. 

Therefore, any alternative that includes the construction of such a wall must include the 

condition that the plans for the barrier wall and any landscaping are subject to review and 

approval by the SHPO.” This condition has been added to the MOA. Final resolution will be 

contained in the Final MOA in the Record of Decision. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Traditional Cultural and Religious Properties – Project early coordination letters were sent to 

the twelve (12) federally recognized Tribes of Michigan seeking comments regarding any 

issues and/or special concerns relating to this undertaking. Also, there are no known 

traditional cultural and/or religious properties claimed or reported by any other cultural group 

within the area of potential effect. Subsequent to these tribal notifications, no requests for 

consultation or identification of any Traditional Cultural and/or Religious Properties were 

received from any of the twelve federally recognized Tribes. Therefore, because there are no 

reported impacts to traditional cultural and/or religious properties and no request for 

consultation caused by this undertaking regarding any such properties, no historic properties 

are affected and the Section 106 process pertaining to traditional cultural and/or religious 

properties has been completed. 

Archaeological Resources – The archaeological Area of Potential Effect (APE) for this project 

has been researched. Two known extant potential archaeological resources were identified 

within the APE. The State Historic Preservation Office has agreed that field investigations at 

these two archaeological sites (Jacque Baby Mill and the Michigan Central Stockyard Hotel) at 

the Livernois-Junction Yard area are not required. The footprint of the Preferred Alternative 

is some distance away from the probable mill site, and the site of Stockyards Hotel has been 

disturbed and/or likely buried beneath fill by construction activity on the part of a railroad by 

activity unrelated to the DIFT. Ground disturbing activities will not be conducted in this area. 

As a result of these consultations, it has been determined and agreed that no archaeological 

resources are affected by this undertaking. In the event any unknown archaeological 

resources are accidentally identified during the execution of the work, it is agreed that the site 

is only important for the information it may reveal and not for preservation in place. 

Construction plans will specify that excavation beneath existing ground disturbance is 

prohibited in this environmentally sensitive area, and a map depicting the sensitive area will 

also accompany the plans. 

4.14 Parkland and Public Recreation Land 

A number of parks are located near the study areas of the four terminals. These are shown on 

Figure 4-12a-d and listed in Table 4-10a-d along with other community facilities. The portion of 

the State Fairgrounds proposed for use under Alternatives 2 and 4 was considered to be public 

recreational land and so impacts to it were covered in Section 6 of the DEIS. 

4.14.1 Alternative 1: No Action 

Under the No Action Alternative no parkland would have been directly or indirectly affected. 

4.14.2 Alternative 2: Improve/Expand Existing Terminals

Under the Improve/Expand Alternative, the only recreation land affected would have been 

approximately 35 acres of the State Fairgrounds (see Section 6). 

Livernois-Junction Yard 

• Wilson Playground on Lonyo is to the north of the expansion area. It would not have 

been directly or indirectly affected by the proposed terminal expansion, including noise. 

• Loverix Park is south of the expansion area. It would not have been directly or indirectly 

affected by the proposed terminal expansion, including noise. 

• Patton Memorial Park is to the south of the expansion area. It would not have been 

directly or indirectly affected by the proposed terminal expansion, including noise. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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• Dearborn City Park is west of the expansion area. It would not have been directly or 

indirectly affected by the proposed terminal expansion, including noise. 

CP/Expressway Terminal 

• Roosevelt Park is to the northeast of the expansion area. It would not have been directly 

or indirectly affected by the proposed terminal expansion, including noise. 

• Macomb Park is directly north of the expansion area. It would not have been directly or 

indirectly affected by the proposed terminal expansion, including noise. 

CP/Oak Terminal 

No parkland would have been directly or indirectly affected near the CP/Oak terminal under the 

Improve/Expand Alternative.

CN/Moterm Terminal 

• The eastern portion of the State Fairgrounds (approximately 35 acres), now leased for 

new vehicle storage, would have been used (including parking used during the annual 

State Fair, which runs for about two weeks, usually in August). 

• Hunt Playground is east of the existing railroad tracks and the potential expansion area 

across from the State Fairgrounds. It would not have been directly or indirectly affected 

by the proposed terminal expansion, including noise. 

4.14.3 Alternative 3: Consolidate All Four Railroads’ Intermodal Activity at LivernoisJunction Yard Area 

The conditions of Alternative 2 for the Livernois-Junction Yard, presented above, applied here.

4.14.4 Alternative 4: The Composite Option 

The conditions of Alternative 2 for the Livernois-Junction Yard and the CN/Moterm terminal, 

presented above, applied here.

Preferred Alternative - Parkland 

The Preferred Alternative will not have any direct or indirect effect on any parkland. 

4.15 Visual Conditions 

One component of visual conditions, terminal lighting, is covered in Section 4.20. 

4.15.1 Alternative 1: No Action 

Under the No Action Alternative no changes to visual conditions would have occurred. 

Abandoned properties, salvage yards, and industrial facilities would have remained without 

improvements to the properties or landscaped buffer areas. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4.15.2 Alternative 2: Improve/Expand Existing Terminals

Livernois-Junction Yard 

Under Alternative 2, the north side of the Livernois-Junction Yard, and a portion of the south 

side, would have had a wall for security which would have screened the terminal (refer to Figures 

3-3, 3-4 and 3-5). Nonetheless, abandoned properties, salvage yards, and industrial facilities 

would have remained immediately adjacent to the terminal. 

CP/Expressway Terminal 

Under Alternative 2, a City of Detroit Public Works facility, industrial land, and existing rail 

facilities would have been used to expand the CP/Expressway terminal. Visual conditions would 

have remained similar to existing conditions.

CP/Oak Terminal 

Under Alternative 2, industrial land and existing rail facilities would have been used for the 

CP/Oak terminal. A wall for security would have been built between the yard and the area to the 

north, which is primarily industrial. This wall would have shielded the view of the yard (refer to 

Figure 3-10).

CN/Moterm Terminal 

Under Alternative 2, land now used for parking at the Michigan State Fairgrounds would have 

been converted to terminal use. A wall for security would have been built on the east side of the 

mainline tracks south of Eight Mile Road. This would have shielded the view of the yard (refer 

to Figure 3-11). 

4.15.3 Alternative 3: Consolidate All Four Railroads’ Intermodal Activity at LivernoisJunction Yard Area 

Under Alternative 3, a wall would have been built for security on the north side, and part of the 

south side, of the expanded Livernois-Junction Yard (refer to Figure 3-6). A new perimeter road 

was also part of the plans on the terminal’s north boundary. These features would have shielded 

the view of the terminal and provided a more visually pleasing setting than the existing 

conditions. Several abandoned properties, salvage yards, and industrial facilities would have been 

removed and new intermodal facilities would have been built in their place. Figure 4-70 

illustrates several areas that would have been visually improved under the Consolidation 

alternative. Figure 4-71 provides an example of the visual relationship between the Melvindale 

intermodal terminal in Detroit and the adjacent neighborhood, in a similar setting. 

4.15.4 Alternative 4: The Composite Option 

Under Alternative 4, the visual conditions at the Livernois-Junction Yard would have been 

essentially the same as those for the facilities as described above for Alternative 3 except that the 

north boundary would have been different. The conditions expected at the CN/Moterm terminal 

for Alternative 4 would have been those for the facilities as described above for Alternative 2. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 217

Area on Kronk, near Stecker, that potentially would be taken by the 

Consolidate and Composite Alternatives. 

Area on Central, south of existing yard, that potentially would be taken

by the Consolidate and Composite Alternatives. 

Area on Clayton, east of Central, that potentially would be taken by the

Consolidate and Composite Alternatives. 

Figure 4-70 

Areas Around LivernoisJunction Yard with 

Opportunities for Visual 

Enhancements

Source: The Corradino Group of Michigan, Inc. 

Terminal 

Terminal 

Terminal 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 218

Figure 4-71 

Triple Crown Terminal in 

Melvindale, Michigan 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 219

Preferred Alternative – Visual Conditions 

A wall will be built for security on the north side, and part of the south side, of the expanded 

Livernois-Junction Yard (refer to Figure 3-6). A new perimeter road is also part of the plan on 

the terminal’s north boundary. These features will shield the view of the terminal and provide 

a more visually pleasing setting than the existing conditions. Several abandoned properties, 

salvage yards, and industrial facilities will be removed and new intermodal facilities will be 

built in their place. Figure 4-70 illustrates several areas that will be visually improved. Figure 

4-71 provides an example of the visual relationship between the Melvindale intermodal 

terminal in Detroit and the adjacent neighborhood, in a similar setting. 

4.16 Contaminated Sites 

A Project Area Contamination Survey (PACS), or Level 1 Environmental Site Assessment, was 

conducted for the DIFT project.47 The purpose of the PACS was to investigate parcels of property 

potentially affected by the project for the presence of environmental contamination and to 

determine the need for further investigation and mitigation measures. Because there was no 

development outside the rail terminal under the No Action Alternative, it was not the subject of 

the PACS. 

The PACS included field reconnaissance interviews with business owners, review of federal and 

state environmental records, and review of historical land use records. The PACS assessed 

commercial and industrial properties that potentially would have been acquired under one or 

more of the Action Alternatives being studied. Residential properties were not investigated 

unless there were specific observations or reported indications of contamination. Nonetheless, 

most, if not all, are expected to have some asbestos materials which would be appropriately 

handled during their removal, if such action occurs. 

More than five dozen sites were investigated for contamination (see Table 4-39 and Figure 1-16). 

Table 4-39 contains environmental records, terminal location and affected alternative 

information, and a contamination potential rating for each site. The federal environmental 

records and databases searched were CERCLIS (Comprehensive Environmental Response, 

Compensation, and Liability, Information System); NPL (National Priorities List [Superfund]); 

RCRIS (Resource Conservation and Recovery Information System); CORRACTS (Corrective 

Action Report); and, ERNS (Emergency Response Notification System). State environmental 

records that were reviewed include SHWS (State Contaminated Sites); SWF/LF (Solid Waste 

Facilities Database); LUST (Leaking Underground Storage Tanks); UST (Underground Storage 

Tanks); BEA (Baseline Environmental Assessment); Indian UST (USTs on Indian land); and, 

HIST LF (Inactive Solid Waste Facilities). These databases and lists conform to requirements in 

ASTM E1527-00 (Standard Practice for Environmental Site Assessments: Phase I Environmental 

Site Assessment Process). 

 

47 “Project Area Contamination Survey,” The Corradino Group, August 2004. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-39 

Contamination Summary 

(see Figure 1-16) 

Reco

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

LUST 

3/4/P Liv-Jct 1 MNP Steel Service and Warehouse 3401 Martin Detroit X-C 3/4/P Liv-Jct 2 Vacant Industrial 3601 Parkinson Detroit Xc X-O 

3 Liv-Jct 3 Gal Cro Steel Processing 3631 Parkinson Detroit Xc X-O 

3/4/P Liv-Jct 4 Fontana Forest Products 7175 Clayton Detroit 3/4/P Liv-Jct 5 Red's Towing Service 7301 Clayton Detroit 

2/3/4/P Liv-Jct 6 Advance Auto Glass and Parts 3600 Central Detroit 2/3/4/P Liv-Jct 7 Herman Brothers Pet Products/Trager Research & Manufacturing 3650 Central Detroit 

3/4/P Liv-Jct 8 Heavy Ts Auto Parts/Rod Auto Parts 3760 Central Detroit Xd 

3 Liv-Jct 9 American Minority Sys/Luco Cartage/Priority Container Serv/PSA-AMSI 7414 Clayton Detroit 

3/4/P Liv-Jct 10 Michigan Wholesale & Repair 3700 Central Detroit 3/4/P Liv-Jct 11 Lacaria Concrete Construction 3720 Central Detroit 

2/3/4/P Liv-Jct 12 Crown Enterprises (ANR Freight System) 3685 Central Detroit Xb Xc 

3 Liv-Jct 13 Superior Diesel Repair 3735 Central Detroit 3 Liv-Jct 14 Panacea - Property 1 4175-95 Central Detroit X-O 3 Liv-Jct 15 Panacea - Property 2 3936-40 Lonyo Detroit 3 Liv-Jct 16 Panacea - Property 3 3950 Lonyo Detroit X-O 3 Liv-Jct 17 Stanley Cupp 4111 Central Detroit 

3/4/P Liv-Jct 18 Dix Scrap Iron & Metal Co 3890 Lonyo Detroit 3/4/P Liv-Jct 19 Big B's Auto 3800 Lonyo Detroit 3/4/P Liv-Jct 20 Spartan Industrial 3896,3930-34 Lonyo Detroit X-C 3/4/P Liv-Jct 21 Spartan Industrial Warehouse 8350 John Kronk Detroit X-C 3/4/P Liv-Jct 22 Spartan Express 3901 Lonyo Detroit X-O 

3 Liv-Jct 23 Jorgenson Collision Center 3949 Lonyo Detroit 3 Liv-Jct 24 American International 4011 Lonyo Detroit X-O 

a - Other potential contamination site identified by reconnaissance and/or other records. 

P - Preferred Alternative 

b - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. LUST - Leaking underground storage tank; X-C = Closec - Baseline Environmental Assessment has been conducted. UST - Underground storage tank. d - Michigan State Priority List site. RCRIS - Resource Conservation and Recovery Informate - Ratings are: L = Low, M = Medium, H = High CERCLIS - Comprehensive Environmental Response, C

Information System. NPL - National Priority Listing. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-39 (continued) 

Contamination Summary 

(see Figure 1-16) 

Re

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

3/4/P Liv-Jct 25 Motor City Corporation 3801 Trenton Detroit 3/4/P Liv-Jct 26 S L Cabot, LLC 4157 Cabot Detroit Xc 3/4/P Liv-Jct 27 Ferrous Processing Corp 9100 J Kronk Detroit 3/4/P Liv-Jct 28 Williams Detroit-Alison 4000 Stecker Dearborn 

3/4 Liv-Jct 29 Jebco Investments LC-Property 1 4200-4300 Stecker Dearborn 3/4 Liv-Jct 30 National Industrial Maintenance 4400 Stecker Dearborn 3/4 Liv-Jct 31 R.E. Leggette Company 9335 St. Stephens Dearborn Xd 3/4 Liv-Jct 32 Truck City, Inc. 4121 Stecker Dearborn 3/4 Liv-Jct 33 MCI Telecommunications Corp. 4401 Stecker Dearborn 3/4 Liv-Jct 34 Jebco Investments LC-Property 2 4401 Stecker Dearborn 3/4 Liv-Jct 35 K & R Express 4601 Stecker Dearborn 3/4 Liv-Jct 36 TIP Trailer Leasing 10000 Southern Dearborn 3/4 Liv-Jct 37 Advance Pool 10400 Southern Dearborn 3/4 Liv-Jct 38 Nour's Investment Company 4210-20 Wyoming Dearborn 3/4 Liv-Jct 39 GLS Leasco, Inc. 4410 Wyoming Dearborn 3/4 Liv-Jct 40 Central Transport, Inc. 4440 Wyoming Dearborn X X 3/4 Liv-Jct 41 Jouney, Inc. Steel Service/Seng Tire 4800 Wyoming Dearborn 

3/4/P Liv-Jct 42 Action Tire Service Co 3969 Wyoming Dearborn 

2f/3/4/P Liv-Jct 43 Ford Motor Vulcan Plant 3900 Wyoming Dearborn 2f/3/4/P Liv-Jct 44 Cummins Michigan 3760 Wyoming Dearborn 2f/3/4/P Liv-Jct 45 Wyoming Self-service 3740 Wyoming Dearborn 2f/3/4/P Liv-Jct 46 Vacant Freight Terminal 10100 Mercier Dearborn 2f/3/4/P Liv-Jct 47 Vacant Freight Terminal 9900 Mercier Dearborn 

3/4/P Liv-Jct 48 Boulevard & Trumbull Inv., Inc. 7700 Dixg Detroit X 

a - Other potential contamination site identified by reconnaissance and/or other records. 

P - Preferred Alternative 

b - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. LUST - Leaking underground storage tank; c - Baseline Environmental Assessment has been conducted. UST - Underground storage tank. d - Michigan State Priority List site. RCRIS - Resource Conservation and Recovee - Ratings are: L = Low, M = Medium, H = High CERCLIS - Comprehensive Environmental f - These properties would be needed under Alternative 2 Option B, but not needed under Alternative 2 Options A and C. Information System. g - This site also includes 7800, 7840, 7904 and 7950 Dix. NPL - National Priority Listing. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-39 (continued) 

Contamination Summary 

(see Figure 1-16) 

R

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

2/3/4/P Liv-Jct 49 Lafayette Recycling 7700,7730,7750 Dix Detroit 

3/4/P Liv-Jct 50 M. Dick & S.F. Corbell 2881 Centralh Detroit 3/4/P Liv-Jct 51 Central Avenue Properties LLC 2921, 2951 Central Detroit X 3/4/P Liv-Jct 52 Thomas Adams, Jr. 2971,81,91 Central Detroit 

2/3/4/P Liv-Jct 53 Chester Herman Warehouse 3005,11 21 Central Detroit 2/3/4/P Liv-Jct 54 Central Auto Parts 3022 Central/7276 Dix Detroit 

3/4/P Liv-Jct 55 Central Auto Clinic 2910,2930 Central Detroit 3/4/P Liv-Jct 56 S. Corbell Property 2880-96 Central Detroit 3/4/P Liv-Jct 57 Vacant Commercial Lots 2803-2889 Stair Detroit 3/4/P Liv-Jct 58 Trimodal 7100,7256,60,7272 Dix Detroit 

2 CP/Oak 59 Milford Fabricating Company 12810 Auburni Detroit 2 CP/Oak 60 Madias Brothers/Grove Recycling/First Evergreen 12850 Evergreen Detroit 2 CP/Oak 61 Gateway Detroit Assoc/Parsec/Roofing Ins/Piston Auto/Technicolor. LLC 12601 Southfield Detroit 2 CP/Oak 62 T&B Properties/Michigan Glove & Safety, Inc. 12801 Auburn Detroit 2 CP/Oak 63 Praxair Distribution 12820 Evergreen Detroit 2 CP/Oak 64 L&M Leasing Associates/Ferrini Contracting Corp. 12735 Auburn Detroit 2 CP/Oak 65 Metaldyne 19001 Glendale Detroit 2 CP/Expressway 66 Department of Public Works 2633 Michigan Detroit 

2/3/4/P Liv-Jct 67 Detroit Brake Parcel 5030 Military Detroit 

a - Other potential contamination site identified by reconnaissance and/or other records. 

P - Preferred Alternative 

b - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. LUST - Leaking underground storage c - Baseline Environmental Assessment has been conducted. UST - Underground storage tank. d - Michigan State Priority List site. RCRIS - Resource Conservation and Re - Ratings are: L = Low, M = Medium, H = High CERCLIS - Comprehensive Environmf - These properties would be needed under Alternative 2 Option B, but not needed under Alternative 2 Options A and C. Information System. g - This site also includes 7800, 7840, 7904 and 7950 Dix. NPL - National Priority Listing. h - This site also includes 2881, 2887, 2889 and 2897 Central. i - This site also includes 12820 Auburn, 12620, 12646, 12650, 12660, and 12661 Westwood. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 223

The PACS found: 

• no NPL sites; 

• two CERCLIS sites, both of which were NFRAP (No Further Remedial Action Planned) 

sites – ANR Freight System (Crown Enterprises), 3685 Central Avenue, and Central 

Transport, Inc., 4440 Wyoming; 

• no RCRIS TSD facilities (Treatment, Storage or Disposal); 

• 31 RCRIS hazardous waste generators; 

• no CORRACTS sites; 

• four ERNS sites; 

• nine Michigan Contaminated Sites List sites; and, 

• 28 LUST sites. 

Based on interviews with property owners and occupants, site visits, and record reviews, each of 

the sites was rated low (L), medium (M), or high (H) for potential environmental contamination. 

L (Low): These sites include known current or former hazardous or petroleum handlers that are 

not currently being investigated or remediating an environmental problem. Examples of this 

category are gas stations that have been designated “closed LUST” sites and businesses that 

handle hazardous materials or petroleum. 

M/H (Medium/High): These sites have a reasonable chance of contamination on a given site. 

Examples of this category include gas stations that are identified by MDEQ as open LUST sites, 

former gas stations closed prior to December 1988 (the date of current federal and state UST 

regulations), sites on the Michigan Central Contaminated Sites List, and sites that exhibit 

indications of improper handling of materials, such as the presence of stained soils, improperly 

stored materials, etc., or other evidence of a recognized environmental condition. These sites 

may need sampling and testing to characterize their environmental condition. 

Nine of the 15 M/H rated sites for Alternative 2, and all of the M/H rated sites for Alternative 3 

(45 sites) and Alternative 4 (37 sites) were located in the area adjacent to the Livernois-Junction 

Yard. This area has been in industrial/commercial usage for 100 years or more and is 

predominantly occupied by automobile salvage businesses, truck and automotive repair shops and 

motor freight terminals. The most common environmental issues associated with these land uses 

are soil impacts from oils, metals, and solvents and subsurface soil/groundwater impacts from 

leaking petroleum underground storage tanks. All sites rated M/H might have needed further 

investigation and/or soil borings to further assess contamination potential. 

The PACS also investigated a vacant parcel that is part of the Detroit Brake Machining property 

on the northeast corner of I-94 and Livernois Avenue. This site was reviewed because it would 

have been acquired for improvements to the I-94/Livernois interchange for Alternatives 2, 3 and 

4. This site was rated Low for contamination potential based on a review of environmental and 

historical land use records. Additional investigation would be needed if right-of-way from the 

adjoining Detroit Brake forge property were to be acquired. 

The review of historical land use records revealed that several brickyards and clay pits were 

located along John Kronk in the late 1800s and early 1900s. Some of the historical references 

suggest that industrial wastes were used to backfill the clay pits. Some of the landowners 

interviewed during the PACS noted the possibility of fill on their properties. The review of 

MDEQ records did not identify any records or investigative reports of filled clay pits in the 

project area. Sites located at former clay pits were rated M/H because of the possibility of 

contaminated fill. These sites and the Central Transport site at 4440 Wyoming, which was 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 224

reportedly used as a landfill, would have required more extensive investigations to characterize 

their environmental condition. 

It is expected that many of the impacts identified during the PACS can be managed through the 

use of measures such as limited soil removal. Most of the M/H rated LUST sites identified for 

this project are currently being remediated under the jurisdiction of MDEQ and will likely be 

restored before the property acquisition phase of the project begins. 

A limited Preliminary Site Investigation (PSI) was also conducted as part of the environmental 

assessment process. The purpose of the PSI was to further investigate parcels of property 

identified in the PACS as having known or suspected contamination. Typically, the PSI consists 

of on-site sampling of soils, groundwater, and/or surface water and laboratory analysis of 

samples. The PSI conducted for the DIFT Project consisted of soil borings in public rights-ofway near the Livernois-Junction Yard, the CP/Expressway and CP/Oak terminals in Detroit, 

because landowners would not grant permission to collect samples on their properties. The soil 

borings in the public rights-of-way provided a means of examining subsurface soil conditions to 

identify indications of pervasive contamination and backfilled clay pits, which have been well 

documented in the vicinity of the Livernois-Junction Yard. The findings of the PSI did not reveal 

any indications of pervasive soil contamination or fill. No soil borings were conducted in 

Dearborn for the Livernois-Junction Yard, or at the CN/Moterm terminal (Ferndale). 

With project implementation of any Action Alternative, additional soil borings will be required 

before a property is acquired/remediated. Impacts will be minimized by disposing contaminated 

materials properly and by protecting workers. A Risk Assessment Plan will be developed, if the 

DIFT project goes forward, to include a Worker Health and Safety Plan. If monitoring wells are 

present, they will be abandoned properly. All contaminated areas will be marked on the plans. A 

Utility Plan will also be prepared to ensure no deep utility cuts will impact and/or spread existing 

contamination. 

Preferred Alternative 

All of the conclusions of the preceding paragraph remain valid for the Preferred Alternative. 

Likewise, conclusions above related to the properties listed in Table 4-39 for the Preferred 

Alternative also remain valid. Twenty-seven properties rated M/H will require further 

mitigation and/or soil borings to further assess soil contamination. 

4.17 Indirect and Cumulative Impacts 

The indirect (secondary) and cumulative effects associated with the proposed improvements to 

intermodal terminal development are presented here. The basis upon which the analysis was 

conducted is defined in federal guidance, which indicates the following: 

Indirect (secondary) effects – Caused by an action (intermodal terminal expansion) and occurring 

later in time or farther removed in distance, but occurring in the reasonably foreseeable future (40 

CFR 1508.8(b)). 

Cumulative effects – Resulting from the incremental impact of the action when added to other 

past, present and reasonably foreseeable future actions, regardless of what agency or person 

undertakes such actions (40 CFR 1508.7). 

The indirect effects are summarized in Table 4-40 (Practical Alternatives) and Table 4-41

(Preferred Alternative). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 225 

Table 4-40 

Summary of Indirect Impacts 

Impact ALT 1 - 2025 NO ACTION ALT 2 - 2025 IMPROVE/EXPAND ALT 3 - 2025 CONSOLIDATE 

Terminal Area LIV-JCT-CP/EXPa CP/OAK CN/MOTERM LIV-JCT-CP/EXPb CP/OAK CN/MOTERM LIV-JCT-CP/EXPc 

Mobility 

Traffic • Acceptable levels 

of traffic congestion throughout network except at Dix/ Waterman/ Vernor intersection. 

• Acceptable 

levels of traffic congestion throughout network. 

• Acceptable 

levels of traffic congestion throughout network. 

• Acceptable levels 

of traffic congestion throughout network except at Dix/Waterman/ Vernor gate area under Option A. 

• Acceptable levels 

of traffic congestion throughout network. 

• Acceptable levels 

of traffic congestion throughout network. 

• Acceptable levels o

traffic congestion throughout network 

but five intersection

which can be made acceptable by modified signal phasing. 

Economic 

Impacts 

Jobse in terminalarea

• Net Jobs Gained: 

• Terminal Area 194 • Overall 1,029 

• Net Jobs Gained: 

• Terminal Area 130• Overall 1,029

• Net Jobs Gained: 

• Terminal Area 88• Overall 1,029

• Net Jobs Gained: 

• Terminal Area 786• Overall 4,950

• Net Jobs Gained: 

• Terminal Area 187• Overall 4,950

• Net Jobs Gained: 

• Terminal Area 390• Overall 4,950

• Net Jobs Gained: 

• Terminal Area 2,24• Overall 9,05

Land Use 

Land Use • Maintains existing 

land use pattern. 

• Up to 10 acres of 

available land converted to uses by industrial and commercial businesses supporting intermodal activity. 

• Maintains 

existing land use pattern. 

• Up to 5 acres of 

available land converted to uses by industrial and commercial businesses supporting intermodal activity. 

• Maintains 

existing land use pattern. 

• Up to 5 acres of 

available land converted to uses by industrial and commercial businesses supporting intermodal activity. 

• Consistent with 

Detroit and Dearborn land use plans. 

• Up to 40 net acres 

of available land converted to uses by industrial and commercial businesses supporting intermodal activity. 

• Detroit land use 

plan does not mention terminal. 

• Up to 15 net acres 

of available land converted to uses by industrial and commercial businesses supporting intermodal activity 

• Consistent with 

Detroit and Ferndale land use plans. 

• Up to 20 net acres 

of available land converted to uses by industrial and commercial businesses supporting intermodal activity 

• Consistent with 

Detroit and Dearborn land use plans. 

• Up to 120 net acres 

of available land converted to uses b

industrial and commercial 

businesses supporting intermodal activity

Carbon Monoxide Hot Spots 

• No violations of 

CO standards at intersections. 

• No violations of 

CO standards at intersections. 

• No violations of

CO standards at intersections. 

• No violations of 

CO standards at intersections. 

• No violations of 

CO standards at intersections. 

• No violations of 

CO standards at intersections. 

• No violations of CO 

standards at intersections. 

Air Quality 

Pollutant Burden 

• Terminal burdens 

less than existing conditions except for PM10 and PM2.5. 

• Roadway burdens 

less than existing conditions because of cleaner engines and fuels. 

• Regional burdens are 

reduced. 

• Terminal burdens 

less than existing conditions except for PM10 and 

PM2.5. 

• Roadway burdens 

less than existing conditions because of cleaner engines and fuels. 

• Regional burdens 

are reduced. 

• Terminal burdens 

less than existing conditions except for PM10 and 

PM2.5. 

• Roadway burdens 

less than existing conditions 

because of cleaner 

engines and fuels.

• Regional burdens 

are reduced. 

• Terminal burdens 

increase over No Action due to increased intermodal activity. 

• Roadway burdens 

virtually same as No Action. 

• Regional burdens are 

reduced. 

• Terminal burdens 

increase over No Action due to increased intermodal activity. 

• Roadway burdens 

virtually same as No Action. 

• Regional burdens are 

reduced. 

• Terminal burdens 

increase over No Action due to increased intermodal activity. 

• Roadway burdens 

virtually same as No Action. 

• Regional burdens are 

reduced 

• Terminal burdens 

increase over No Action due to increaseintermodal activity. 

• Roadway burdens 

slightly less than No Action. 

• Regional burdens are 

reduced. 

a Includes the Livernois-Junction Yard, CP/Expressway, and NS/Delray and Triple Crown terminals. b Includes the existing Livernois-Junction Yard and CP/Expressway terminals. The intermodal operations of NS at Delray and Triple Crown will be transferred to the Livernois-Junction Yar

intermodal railroad business.

c Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway, CP/Oak and CN/Moterm. These latter three terminals would serve non-intermodal 

d Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway and CP/Oak. These latter two terminals would serve non-intermodal railroad busine Net jobs are those gained in terminal area. Each terminal area is defined as an “impact zone” around each existing intermodal terminal. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 226 

Table 4-40 (continued) 

Summary of Indirect Impacts 

Impact ALT 1 - 2025 NO ACTION ALT 2 - 2025 IMPROVE/EXPAND ALT 3 - 2025 CONSOLIDAT

Terminal Area LIV-JCT-CP/EXPa CP/OAK CN/MOTERM LIV-JCT-CP/EXPb CP/OAK CN/MOTERM LIV-JCT- CP/EXPc Effects on Community Cohesion 

• Industrial/ 

commercial uses will continue to be mixed with residential uses. 

• Continued 

rail/vehicle conflicts at Central/Lonyo. 

• Industrial/ 

commercial uses will continue to be mixed with residential uses.

• Industrial/ 

commercial uses will continue to be mixed with residential uses.

• Lonyo closed. 

Central railroad crossing grade separated. 

• Truck traffic 

reduced on neighborhood streets. 

• Truck traffic 

reduced on neighborhood streets. 

• Truck traffic 

reduced on neighborhood streets. 

• Lonyo closed

Central railrocrossing gradseparated. 

• Truck traffic 

reduced on neighborhood streets. 

Potential Environmental Justice Issues 

• No adverse 

disproportionate impact expected 

• No adverse 

disproportionateimpact expected

• No adverse 

disproportionate impact expected

• No adverse 

disproportionate impact expected 

• No adverse 

disproportionate impact expected 

• No adverse 

disproportionate impact expected 

• No adverse 

disproportionimpact expec

Community Change in Aesthetics 

• Intermodal 

terminals/activity will continue to grow without aesthetic improvements and protection of surrounding neighborhoods. 

• Intermodal 

terminals/activity will continue to grow without aesthetic improvements and protection of surrounding neighborhoods.

• Intermodal 

terminals/activity will continue to grow without aesthetic improvements and protection of surrounding neighborhoods.

• Spillover effect 

from improved terminal aesthetics. 

• Spillover effect 

from improved terminal aesthetics. 

• Spillover effect 

from improved terminal aesthetics. 

• Spillover effe

from improveterminal aesthetics. Nnorth side perimeter roawill also enhance area and have spillover effe

a Includes the Livernois-Junction Yard, CP/Expressway, and NS/Delray and Triple Crown terminals. b Includes the existing Livernois-Junction Yard and CP/Expressway terminals. The intermodal operations of NS at Delray and Triple Crown will be transferred to the Livernois-Junction Yar

intermodal railroad business.

c Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway, CP/Oak and CN/Moterm. These latter three terminals would serve non-intermodal 

d Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway and CP/Oak. These latter two terminals would serve non-intermodal railroad busine Net jobs are those gained in terminal area. Each terminal area is defined as an “impact zone” around each existing intermodal terminal. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 227 

Table 4-40 (continued) 

Summary of Indirect Impacts

Impacts ALT 1 - 2025 NO ACTION ALT 2 - 2025 IMPROVE/EXPAND ALT 3 - 20

CONSOLID

Terminal Area LIV-JCT-CP/EXPa CP/OAK CN/MOTERM LIV-JCT-CP/EXPb CP/OAK CN/MOTERM LIV-JCT

CP/EXP

Noise 

Noise Considerations • No perceptible 

increase. 

• No perceptible 

increase. 

• No perceptible 

increase. 

• No perceptible 

increase with planned security

wall. 

• No perceptible 

increase with planned security wall. 

• No 

perceptible increase with planned securitywall. 

• No percept

increase wplanned se

wall. 

Effects on Historic/Archaeological Resources 

• No indirect effect • No indirect effect • No indirect 

effect 

• Potential positive 

spillover effect. 

• Potential 

positive spillover effect.

• Potential 

positive spillover effect. 

• Potential 

positive spillover ef

Cultural 4(f) 

Resources Effects on Parklands/ 

Recreational Land • No indirect effect • No indirect, effect 

• No indirect 

effect 

• No indirect effect • No indirect 

effect 

• No indirect 

effect 

• No indirec

effect 

Contaminated 

Sites 

• Potential to remediate 

up to 10 acres for non-terminal intermodal activity 

• Potential to 

remediate up to 5 acres for nonterminal intermodal activity

• Potential to 

remediate up to 5 acres for nonterminal intermodal activity 

• Potential to 

remediate up to 40 acres for nonterminal intermodal activity 

• Potential to 

remediate up to 15 acres for non-terminal intermodal activity 

• Potential to 

remediate up to 20 acres for nonterminal intermodal activity 

• Potential to 

remediate u120 acres fonon-terminaintermodal activity 

Water Quantity/Quality • Spill prevention 

plans will be in place. 

• Spill prevention 

plans will be in place. 

• Spill prevention 

plans will be in place. 

• Yard paving will 

improve drainage. 

• Spill prevention 

plans will be in place. 

• Yard paving 

will improve drainage. 

• Spill 

prevention plans will be in place. 

• Fairgrounds 

is now gravel. Yard paving will improve drainage. 

• Spill 

prevention plans will be in place. 

• Yard pavin

will improvdrainage. 

• Spill preve

plans will bplace. 

Water 

Quantity/Quality of Wetlands Affected • No indirect effect. • No indirect effect. 

• No indirect 

effect. 

• No indirect effect. • No indirect 

effect. 

• No indirect 

effect. 

• No indirec

effect. 

a Includes the Livernois-Junction Yard, CP/Expressway, and NS/Delray and Triple Crown terminals. b Includes the existing Livernois-Junction Yard and CP/Expressway terminals. The intermodal operations of NS at Delray and Triple Crown will be transferred to the Livernois-Junction Yard. These latter two 

business.

c Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway, CP/Oak and CN/Moterm. These latter three terminals would serve non-intermodal railroad busine

d Includes the expanded Livernois-Junction Yard to accommodate the intermodal operations of CP/Expressway and CP/Oak. These latter two terminals would serve non-intermodal railroad business. e Net jobs are those gained in terminal area. Each terminal area is defined as an “impact zone” around each existing intermodal terminal. 

Source: The Corradino Group of Michigan, Inc. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 228 

Table 4-41 

Summary of Indirect Impacts – Preferred Alternative 

Livernois-Junction Yard Areaa

Air Quality Mobility Economic Impacts Land Use Hot Spots Pollutant Burden Community Cohesion 

• Grade separation 

of Central will reduce vehicle-rail conflicts and crashes. 

• I-94/Livernois 

interchange improvement will improve safety. 

• Truck traffic will 

be reduced on local roads. 

• Net Jobs Gained:  Terminal Area 1,542 

Statewide 

 4,514 

• Consistent with 

Detroit and Dearborn land use plans. 

• Likely stimulation 

of local redevelopment. 

• No violations of 

CO standards at intersections. 

• Qualitative analysis 

of PM2.5 or PM10 hotspots indicates there will be no standards violated.

• Terminal burdens 

about same as No Action even with increased intermodal activity. 

• Roadway burdens 

similar to No Action. 

• Regional burdens 

will be reduced with freight shift to rail. 

• Lonyo will be 

closed. Central Avenue railroad crossing will be grade separated. 

• Truck traffic will be 

reduced on neighborhood streets. 

Cultural 

Environmental 

Justice Noise Considerations Historic/ Archaeological 4(f) 

Resources 

Parklands/ 

Recreational Land 

4(f) Resources 

Contaminated Sites Surface Water Impacts 

• There is a history 

of impacts to minority and lowincome populations associated with past industrialization and transportation projects. There will be adverse disproportionate impacts from this project. 

• No perceptible 

increase with the addition of planned security walls. 

• Potential positive 

spillover effect. 

• No indirect effects. • Up to 100 acres for 

non-terminal intermodal activity will be remediated. 

• Yard paving will 

improve drainage. 

• Spill prevention 

plans will be in place. 

• Particulate matter 

that clogs sewers will be reduced. 

Wetlands 

Farmland and Open 

Space /Part 361 

Lands 

Threatened and 

Endangered Species Visual Effects Soils Energy 

• No indirect impact. • No active farmland, 

or Part 361 land needed. 

• No indirect impact. • Potential spillover 

effect from buffer around yard. 

• No indirect 

impact 

• Improved 

efficiencies from conversion of some freight shipments from truck to rail are expected. 

a Only the Livernois-Junction Yard is involved in the Preferred Alternative. There are no project impacts at other terminals. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 229

Alternative 1: No Action 

Livernois-Junction Yard/CP-Expressway Terminal Area – Alternative 1 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the Livernois-Junction 

Yard/CP-Expressway terminal area would have occurred under Alternative 1: 

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the terminals except at the Dix/Waterman/Vernor 

intersection/gate area, as presented in Section 4.1. This conclusion extends to traffic 

brought by induced growth. 

• Economic Impacts – Over the next 20 years there would have been almost 200 jobs 

created in the terminal area due to continuing growth of intermodal activity, as 

defined in Section 4.5. 

• Land Use – The expected investment of the railroads in intermodal activity would 

have been likely to stimulate, over the next 20 years, private sector 

industrial/commercial use of up to 10 acres of available land in the terminal area, as 

defined in Section 4.5. This expected use of land was consistent with development 

patterns that currently exist. 

• Air Quality – Analyses presented in Section 4.8 indicate no violations of CO 

standards were expected in the areas around the terminals. Compared to today’s 

conditions, pollution would have been expected to be lower largely because of the 

use of cleaner engines and fuels, as mandated by U.S. EPA. Nonetheless, the 

railyards were not paved under Alternative 1. Regionally, pollutants were forecast to 

be lower due to the diversion of freight shipments from truck to rail and the use of 

cleaner fuels and engines. 

• Community Effects – Continued vehicle conflicts were expected at Lonyo and 

Central as the rail lines at these street crossings were not to be separated from the 

railroad tracks, as defined in Section 4.1. And, industrial and commercial uses were 

expected to continue to be mixed with residential uses in the terminal area, as they 

are today, and defined in Section 4.6. This pattern was not likely to be associated 

with aesthetic improvements to enhance/protect surrounding neighborhoods. 

• Noise – No perceptible noise increases at sensitive receptors due to terminal activity 

were forecast from current conditions, as defined in Section 4.9. 

• Cultural Resources – No effect was expected on historical or archaeological 

resources, nor parks/recreational lands, as presented in Sections 4.13 and 4.14, 

respectively. 

• Contaminated Sites – The increased intermodal activity could cause, over the next 

20 years, up to 10 acres of contaminated land (e.g., brownfields) to be reclaimed by 

private sector development. 

• Water Quality – The status quo in water quality was expected to continue, as future 

conditions would be a continuation of past trends, as discussed in Section 4.11. 

Prevention plans to address spills of hazardous materials would have continued to be 

maintained by the railroads as required by the federal government. The small amount 

(up to 10 acres) of potentially reclaimed properties (e.g., brownfields) was also 

considered a continuation of current trends. 

The results of the conditions presented above indicate the base condition with no change will 

perpetuate the trends of the last 30 to 50 years in the Livernois- Junction/CP-Expressway 

terminal area. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 230

CP/Oak Terminal Area – Alternative 1 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the CP/Oak terminal area 

would have occurred under Alternative 1: 

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the CP/Oak terminal. Even still, truck traffic will 

continue to use neighborhood streets, as today, as presented in Section 4.1. This 

conclusion extends to traffic brought by induced growth. 

• Economic Impacts – Over the next 20 years, there would have been about 130 jobs 

created in the terminal area due to continuing growth of intermodal activity, as 

defined in Section 4.5. 

• Land Use – The expected investment of the railroads in intermodal activity would 

have been likely to stimulate, over the next 20 years, private sector 

industrial/commercial use of up to five acres of available land in the terminal area to 

support intermodal activity, as defined in Section 4.5. This use of land would have 

been consistent with development patterns that currently exist. 

• Air Quality – Analyses presented in Section 4.8 indicate no violations of CO 

standards would have been expected in the terminal area. Compared to today’s 

conditions, pollution would be expected to be lower largely because of the use of 

cleaner engines and fuels, as mandated by EPA. Regionally, pollutants would have 

been forecast to be reduced due to the diversion of freight shipments from truck to 

rail and the use of cleaner fuels and engines. 

• Community Effects – No acquisition would have been associated with terminal 

expansion as there would have been none, as defined in Section 4.4. Industrial and 

commercial uses are expected to continue to be mixed with residential uses in the 

terminal area, as they are today, and as defined in Section 4.6. This pattern would 

not have been likely to be associated with aesthetics improvements. 

• Noise – No perceptible noise increase at sensitive receptors due to terminal activity 

would have been forecast from current conditions, as defined in Section 4.9. 

• Cultural Resources – No effect was expected on historical or archaeological 

resources, nor parks/recreational lands, as presented in Sections 4.13 and 4.14, 

respectively. 

• Contaminated Sites – The increased intermodal activity could have caused, over the 

next 20 years, up to five acres of contaminated land in brownfields to be reclaimed 

by private sector development. 

• Water Quality – The status quo in water quality was expected to continue, as future 

conditions will be a continuation of past trends, as discussed in Section 4.11. 

Prevention plans to address spills are and will continue to be maintained by the 

railroads as required by the federal government. The small amount (up to five acres) 

of potentially reclaimed properties (e.g., brownfields) would have been considered a 

continuation of current trends. 

The results of the conditions presented above indicate there would have been no change in the 

trends of the last 30 to 50 years in the CP/Oak terminal area. 

CN/Moterm Terminal Area – Alternative 1 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the CN/Moterm terminal 

area would have occurred under Alternative 1: 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

4 - 231

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the CN/Moterm terminal. This conclusion extends to 

traffic brought by induced growth. 

• Economic Impacts – Over the next 20 years, there would have been about 90 jobs 

created in the terminal area due to continuing growth in intermodal activity, as 

defined in Section 4.5. 

• Land Use – The expected investment of the railroads in intermodal activity would 

have been likely to stimulate, over the next 20 years, industrial/commercial use of up 

to five acres of available land in the terminal area, as defined in Section 4.5. This use 

of land would have been consistent with development patterns that currently exist. 

• Air Quality – Analyses presented in Section 4.8 indicate no violations of CO 

standards would have been expected in the area around the terminal. Compared to 

today’s conditions, pollution would have been expected to be lower, largely because 

of the use of cleaner engines and fuels, as mandated by EPA. Regionally, pollutants 

were forecast to be lower due to the diversion of freight shipments from truck to rail 

and the use of cleaner fuels and engines. 

• Community Effects – No acquisition would have been associated with terminal 

expansion as there would have been none, as defined in Section 4.4. Industrial and 

commercial uses are expected to continue to be mixed with residential uses in the 

terminal area, as they are today, and as defined in Section 4.6. This pattern would 

have been likely to be associated with aesthetic improvements. 

• Noise – No perceptible noise increase was forecast at sensitive receptors due to 

terminal activity from current conditions, as defined in Section 4.9. 

• Cultural Resources – No effect was expected on historical and archaeological 

resources, nor parks/recreational lands, as presented in Sections 4.13 and 4.15, 

respectively. 

• Contaminated Sites – The increased intermodal activity could have caused, over the 

next 20 years, up to five acres of contaminated land (e.g., brownfields) to be 

reclaimed by private sector development. 

• Water Quality – The status quo in water quality was expected to continue, as future 

conditions will be a continuation of past trends, as discussed in Section 4.11. 

Prevention plans to address spills are and will continue to be maintained by the 

railroads as required by the federal government. The small amount (up to five acres) 

of potentially reclaimed properties (brownfields) would have been considered a 

continuation of current trends. 

The results of the conditions presented above indicate there would have been no change in the 

trends of the last 30 to 50 years in the CN/Moterm terminal area. This condition, though, 

would have been less positive overall than the Action Alternatives, discussed next. 

Alternative 2: Improve/Expand Existing Terminals 

Livernois-Junction Yard/CP-Expressway Terminal Area – Alternative 2 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the Livernois-Junction/CPExpressway terminal area would have occurred under Alternative 2: 

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the terminals, except at the Dix/Waterman/Vernor 

intersection/gate area under Option A, as presented in Section 4.1. Truck traffic 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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would have been reduced on neighborhood streets. And, Lonyo would be closed 

while the Central Avenue crossing of the railroad tracks would have become grade 

separated, thereby improving the safe movement of traffic around the terminal area. 

Finally, improving the I-94/Livernois interchange would have improved safe truck 

movements and reduced truck traffic on neighborhood streets. The acceptable level 

of service would have remained true with induced growth except at 

Dix/Waterman/Vernor. 

• Economic Impacts – Over the next 20 years, there would have been about 800 jobs 

created in the terminal area due to intermodal activity, as defined in Section 4.5. 

Growth in the local tax base was forecast as was local business expansion. 

• Land Use – The expected investment by the railroads and government would have 

been likely to stimulate, over the next 20 years, industrial/commercial use of up to 40 

acres of available land in the terminal area to support intermodal activity, as defined 

in Section 4.5. This intermodal development activity would have been consistent 

with the land use plans of Detroit and Dearborn. Unwanted mixing of land uses must 

be resisted by applying already-existing provisions of the Detroit Master Plan and 

Policies and Dearborn Master Plan. 

• Air Quality – Analyses presented in Section 4.8 indicate no violations of CO 

standards would have been expected in the areas around the terminals. Compared to 

the No Action condition in 2025, terminal pollutant burdens were expected to 

increase due to the forecast increase in intermodal activity. The Livernois-Junction 

Yard would have been paved. The 2025 pollution burdens of the roadways around 

the terminals were forecast to be virtually the same as today. The regional mobile 

source pollutant burdens were expected to be reduced due to diversion of freight 

shipments from truck to rail and the use of cleaner fuels and engines. 

• Community Effects – Lonyo would have been closed and Central Avenue rebuilt to 

pass under the railroad lines, improving the safe flow of vehicles. Truck traffic on 

neighborhood streets would have been reduced. Walls for security on the north side 

of the terminal, and part of the south, would have buffered its activity, improving the 

aesthetics of the area. The terminal would have been paved, reducing the effects of 

dust on the nearby population. 

• Noise – No perceptible increase in noise in sensitive areas was expected with planned 

walls for security purposes, as defined in Section 4.9. Traffic volumes in the terminal 

area would have increased as economic conditions improve. 

• Cultural Resources – There would be no indirect effects on cultural resources. No 

effects were forecast on parks/recreational lands, as presented in Section 4.14. 

• Contaminated Sites – The increased intermodal activity could have caused, over the 

next 20 years, up to 40 acres of contaminated land (e.g., brownfields) to be reclaimed 

by private sector development. This could have led to reduced exposure to 

contamination and improved the quality of stormwater runoff. 

• Water Quality – As discussed in Section 4.11, it was expected that paving the 

Livernois-Junction Yard would have improved drainage as the runoff today clogs 

sewer inlets which causes standing water. Where the project increased stormwater 

amounts by paving terminals surfaces that now absorb water, storage would have 

been engineered into the system (oversized pipes or retention areas) so that the flow 

rate of stormwater did not increase. Because of the combined sewer system, all water 

would have been treated before it flowed to the Detroit River. Prevention plans to 

address accidental spills of hazardous materials would have continued to be 

maintained by the railroads as required by the federal government. Reclaiming up to 

40 acres of potentially contaminated property (brownfields) might have occurred. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Positive developments were forecast in the economic impacts, land use and community 

effects. 

CP/Oak Terminal Area – Alternative 2 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the CP/Oak terminal area 

would have occurred under Alternative 2: 

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the terminal, as presented in Section 4.1. This 

conclusion extends to traffic brought by induced growth. 

• Economic Impacts – Over the next 20 years, 600 jobs relocated from the terminal 

would have been regained and another 200 created in the terminal area. As a result, 

local business expansion was also expected as well as growth in the tax base. 

• Land Use – The expected investment by the railroads and government would have 

been likely to stimulate, over the next 20 years, industrial/commercial use of up to 15 

acres of available land in the terminal area to support intermodal activity, as defined 

in Section 4.5. This intermodal development activity would have been consistent 

with the land use plan of Detroit. Unwanted mixing of land uses should be resisted 

by applying already-existing provisions of the Detroit Master Plan of Policies. 

• Air Quality – Analyses presented in Section 4.8 indicated no violations of CO 

standards were expected in the areas around the CP/Oak terminal. Compared to the 

No Action condition in 2025, terminal pollutant burdens were expected to increase 

due to the forecast increase in intermodal activity. The 2025 pollutant burdens of the 

roadways around the terminal were forecast to be virtually the same as today. The 

regional mobile source pollutant burdens were expected to be reduced due to the 

diversion of freight shipments to rail and the use of cleaner fuels and engines. 

• Community Effects – Truck traffic on neighborhood streets would have been 

reduced. Security walls on the north side of the terminal would have buffered its 

activity, improving the aesthetics of the area. 

• Noise – No perceptible increase in noise in sensitive areas was expected with planned 

walls for security purposes, as defined in Section 4.9. Traffic volumes in the terminal 

area would have increased with improved economic conditions. 

• Cultural Resources – There would be no indirect effect expected on historic, 

archaeological or parks/recreational land resources, as presented in Sections 4.13 and 

4.14, respectively. 

• Contaminated Sites – The increased intermodal activity could have caused, over the 

next 20 years, up to 15 acres of contaminated land (e.g., brownfields) to be reclaimed 

by private sector development. This could have led to reduced exposure to 

contamination and improved the quality of stormwater runoff. 

• Water Quality – As described in Section 4.11, it was expected that paving of the 

CP/Oak Yard would have improved water quality. Where the project increases 

stormwater amounts by paving surfaces at terminals that now absorb water, storage 

would have been engineered into the system (oversized pipes or retention areas) so 

that the flow rate of stormwater did not increase. Because of the combined sewer 

system, all water would have been treated before it flowed to the Detroit River. 

Prevention plans to address accidental spills of hazardous materials would have 

continued to be maintained by the railroads as required by the federal government. 

Reclaiming up to 15 acres of potentially contaminated properties (e.g., brownfields) 

was possible. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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The results of the conditions presented above indicated an adverse effect due to an increase in 

terminal pollutant burdens in the areas around the terminal. This was associated with 

increased intermodal activity, compared to the No Action Alternative. Positive developments 

were forecast in almost all other evaluation areas. On balance, there would have been no 

disproportionate adverse effect on populations covered by the EJ Executive Order in the 

CP/Oak terminal area as a result of Alternative 2’s proposed terminal expansion. 

Nonetheless, it was recognized an adverse effect(s) may occur and, if so, it (they) would have 

been mitigated and/or minimized in the design, right-of-way and construction phases of 

project implementation, if Alternative 2 had been selected as the preferred alternative. 

CN/Moterm Terminal Area – Alternative 2 

The analyses presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the CN/Moterm terminal 

area would have occurred under Alternative 2: 

• Mobility – Acceptable levels of traffic congestion were expected throughout the 

roadway network around the terminal, as described in Section 4.1. This conclusion 

extends to traffic brought by induced growth. 

• Economic Effects – Over the next 20 years, there would have been almost 400 jobs 

created in the terminal area due to intermodal terminal activity, as defined in Section 

4.5. Growth in local businesses and the tax base were expected. 

• Land Use – The expected investment by the railroads and government was likely to 

stimulate, over the next 20 years, industrial/commercial use of up to 20 acres of 

available land in the terminal area to support intermodal activity, as defined in 

Section 4.5. This expected intermodal development was consistent with the land use 

plan of Detroit. Unwanted mixing of land uses should be resisted by applying 

already-existing provisions in the Detroit Master Plan of Policies and the Ferndale, 

Highland Park and Hazel Park land use plans. 

• Air Quality – Analyses presented in Section 4.8 indicated no violations of CO 

standards were expected in the areas around the terminals. Compared to the No 

Action condition in 2025, terminal pollutant burdens were expected to increase due to 

the forecast increase in intermodal activity. The 2025 pollution burden of the 

roadways around the terminal were projected to be virtually the same as today. The 

regional mobile source pollutant burdens were expected to be reduced due to 

diversion of freight shipments from truck to rail and the use of cleaner fuels and 

engines. 

• Community Effects – Up to 35 acres of Fairgrounds property would have been 

leased for terminal activity. Truck traffic on neighborhood streets would have been 

reduced. Walls for security on the east side of the terminal, south of Eight Mile 

Road, would have buffered its activity. The gravel area at the Fairgrounds would 

have been paved, reducing the effects of dust on nearby areas. 

• Noise – No perceptible increase in noise in sensitive areas was expected with planned 

walls for security purposes, as defined in Section 4.9. Traffic volumes in the area 

would have increased with improved economic conditions. 

• Cultural Resources – There would have been no effect on historic and 

archaeological resources expected, but up to 35 acres of State Fairgrounds property 

would have been leased for intermodal terminal activity. In the past, about 10 acres 

of Fairgrounds property was used for this purpose by Canadian National Railroad. 

Information on this issue was presented in Sections 4.13 and 4.14, respectively. 

• Contaminated Sites – The increased intermodal activity would have caused, over 

the next 20 years, up to 20 acres of contaminated land (e.g., brownfields) to be 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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reclaimed by private sector development. This could have led to reduced exposure to 

contamination and improved the quality of stormwater runoff. 

• Water Quality – As described in Section 4.11, it was expected that paving the gravel 

area of the Fairgrounds to be used for intermodal terminal development would have 

improved water quality. Where the project increased stormwater amounts by paving 

surfaces at terminals that now absorb water, storage would have been engineered into 

the system (oversized pipes or retention areas) so that the flow rate did not increase. 

Because of the combined sewer system, all water would have been treated before it 

flowed to the Detroit River. Prevention plans to address accidental spills of 

hazardous materials would have continued to be maintained as required by the 

federal government. Reclaiming up to 20 acres of potentially contaminated 

properties (e.g., brownfields) was possible. 

The results of the conditions presented above indicated an adverse effect due to an increase in 

terminal air pollutant burdens. This was associated with increased intermodal activity 

compared to the No Action Alternative. Also, there would have been an adverse effect as up 

to 35 acres of protected 4(f) recreational land would have been used for intermodal terminal 

expansion. Positive developments were forecast in almost all other evaluation areas. On 

balance, there would have been no disproportionate adverse effect on populations covered by 

the EJ Executive Order in the CN/Moterm terminal area as a result of Alternative 2’s 

proposed terminal expansion. Nonetheless, it was recognized an adverse effect(s) might 

occur and, if so, it (they) would have been mitigated and/or minimized in the design, right-ofway and construction phases of project implementation, if Alternative 2 had been selected as 

the Preferred Alternative. 

Alternative 3: Consolidate All Four Class I Railroads’ Intermodal Activity at 

Livernois-Junction Yard Area 

The analysis presented throughout this document, the results of which are summarized in 

Tables 4-40 and 4-41, indicate the following indirect impacts for the Livernois-Junction 

Yard/CP-Expressway terminal area would have occurred under Alternative 3: 

• Mobility – There would have been acceptable levels of traffic congestion throughout 

the roadway network around the terminal, except at five intersections. Modifying 

signal timings at these intersections would have addressed this problem, as presented 

in Section 4.1. Truck traffic will be reduced on neighborhood streets. Lonyo would 

have been closed while the Central Avenue crossing of the railroad tracks would have 

been grade separated, thereby improving the safe movement of traffic around the 

terminal area. Finally, improving the I-94/Livernois interchange would have 

improved safe truck movements and also helped reduce truck traffic on neighborhood 

streets. The acceptable level of service would have remained true with induced 

growth. 

• Economic Impacts – Jobs expected to be relocated out of the terminal area due to 

terminal expansion would have been replaced by more than 2,200 new jobs 

associated with the investment in intermodal development, over the next 20 years, as 

defined in Section 4.5. Local business expansion and growth in the local tax base 

were anticipated. 

• Land Use – The expected investment by the railroads and government was likely to 

stimulate, over the next 20 years, industrial/commercial development of up to 120 

acres of available land to support intermodal activity, as defined in Section 4.5. This 

intermodal development activity was consistent with the land use plans of Detroit and 

Dearborn. Unwanted mixing of land uses should be resisted by applying already-
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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existing provisions in the Detroit Master Plan of Policies and the Dearborn Master 

Plan. 

• Air Quality – Analyses presented in Section 4.8 indicated no violations of CO 

standards would have been expected in the areas around the terminal. Compared to 

the No Action condition in 2025, terminal pollutant burdens were expected to 

increase with the increase in intermodal activity. The roadway burdens were 

expected to be slightly less than the No Action Alternative because of the removal of 

traffic through acquisition/relocation from the area around the terminal (64 

businesses, 71 single-family residences and 12 apartment units). The regional mobile 

source pollutant burdens were expected to be reduced due to diversion of freight 

shipments from truck to rail and the use of cleaner fuels and engines. 

• Community Effects – Jobs relocated out of the terminal area would have been 

compensated by an increase of more than 2,200 new jobs stimulated by intermodal 

investment, consistent with data presented in Section 4.5. Lonyo would have been 

closed and Central Avenue grade separated from the railroad lines, improving safe 

flow of vehicles. Truck traffic on neighborhood streets would have been reduced. 

Walls for security on the north side of the terminal, and part of the south, would have 

buffered its activity, improving the aesthetics of the area. The terminal would have 

been paved, reducing the effects of dust on the nearby population. 

• Noise – No perceptible increase in noise on sensitive areas was expected with 

planned walls for security purposes, as defined in Section 4.9. Traffic volumes in the 

terminal area would have increased as economic conditions improved. 

• Cultural Resources – An adverse effect was expected by removal of the Michigan 

Box Company building and the Federal Screw Works Factory and potential adverse 

effects applied to the Markey and Tomms Houses, as defined in Section 4.13, but 

indirect effects could be positive through the spillover effect of local redevelopment. 

No effects were forecast on parks/recreational lands, as presented in Section 4.14. 

• Contaminated Sites – The increased intermodal activity could have caused, over the 

next 20 years, up to 120 acres of contaminated land (e.g., brownfields) to be 

reclaimed by the private sector. This could have led to reduced exposure to 

contamination and improved the quality of stormwater runoff. 

• Water Quality – As discussed in Section 4.11, it was expected that paving the 

Livernois-Junction Yard would have improved drainage as the runoff today clogs 

sewer inlets, which causes standing water. Where the project increases stormwater 

amounts by paving terminals surfaces that now absorb water, storage would have 

been engineered in the system (oversized pipes or retention areas) so that the flow 

rate of stormwater did not increase. Because the combined sewer system, all water 

would have been treated before it flowed to the Detroit River. Prevention plans to 

address accidental spills of hazardous materials would have continued to be 

maintained by the railroads. Reclaiming up to 120 acres of potential contaminated 

properties (e.g., brownfields) was possible. 

The results of the conditions presented above indicated minimal adverse effects and the 

potential for an overall positive indirect effect. 

Alternative 4: The Composite Option 

The impacts on the Livernois-Junction Yard and the CN/Moterm terminal, both of which 

would have been expanded under Alternative 4, are summarized on Tables 4-40 and 4-41. 

They are very much like those effects reported on for Alternative 3 for the Livernois-Junction 

Yard and for Alternative 2 for the CN/Moterm terminal. The conclusion again is that there 

would have been minimal indirect impacts and those would be positive. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Summary of Practical Alternatives 

Alternative 3 was viewed as having the most positive effect overall on EJ populations as it 

generated the most jobs. The pollutant burden for all terminals combined was less than 

today, as was the roadway burden. 

Preferred Alternative – Livernois-Junction Yard 

The following indirect impacts will result from the Preferred Alternative. 

• Mobility – There will be acceptable levels of traffic congestion throughout the 

roadway network around the terminal, as presented in Section 4.1 of this FEIS. 

There will be a net increase of approximately 700 trucks a day in 2030 in the 

terminal area compared to the No Action Alternative. The planned road and gate 

improvements will split truck traffic between Livernois and Wyoming Avenues, 

with Wyoming serving an industrial area. Truck traffic will be reduced on 

neighborhood streets (Central north of Kronk, Livernois south of the terminal 

entrance gate, and Dragoon south of Dix). Lonyo will be closed, while the 

Central Avenue crossing of the railroad tracks will be grade separated, thereby 

improving the safe movement of traffic around the terminal area. Finally, 

improving the I-94/Livernois interchange will improve safe truck movements and 

also help reduce truck traffic on neighborhood streets. There will be no impacts 

on public transit routes. 

• Economic Impacts – Jobs relocated out of the terminal area due to terminal 

expansion will be replaced in the terminal area by more than 1,540 new jobs 

associated with the investment in intermodal development, over the next 20 years, 

as defined in Section 4.5 of this FEIS. The new job total is expected to be 

approximately 4,500 statewide. In the Detroit area, the net new jobs total is 

forecast at about 2,300. Local business expansion and growth in the local tax base 

are anticipated. 

• Land Use – The expected investment by the government and railroads is likely to 

stimulate, over the next 20 years, industrial/commercial development of up to 60 

acres of available land to support intermodal activity, as defined in Section 4.5 of 

this FEIS. This intermodal development activity is consistent with the land use 

plans of Detroit and Dearborn. Unwanted mixing of land uses can and should 

be resisted by applying already-existing provisions in the Detroit Master Plan of 

Policies and the Dearborn Master Plan. 

• Air Quality – Analyses presented in Section 4.8 of this FEIS indicate no 

violations of CO standards are expected in the area around the Preferred 

Alternative. Likewise, no violations of PM2.5 or PM10 daily or annual standards 

are anticipated, based on qualitative hot-spot analyses of these two pollutants. 

Compared to the No Action condition in 2030, terminal pollutant burdens are 

expected to change. Carbon monoxide and particulate matter are expected to 

decrease, while the other pollutants are expected to increase with the increase in 

intermodal activity. The roadway burdens are expected to be about the same as 

the No Action Alternative because of the removal of traffic through 

acquisition/relocation from the area around the terminal (29 businesses). The 

regional mobile source pollutant burdens will be reduced due to diversion of 

freight shipments from truck to rail and the use of cleaner fuels and engines. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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• Community Effects – Residential and job losses would be offset by new jobs 

stimulated by intermodal investment, consistent with data presented in Section 

4.5 of this FEIS. Lonyo would be closed and Central Avenue grade separated 

from the railroad lines, improving safe flow of vehicles. Truck traffic on 

neighborhood streets would be reduced. Security walls on the north side of the 

terminal, and part of the south, will buffer its activity, improving the aesthetics of 

the area. The terminal will be paved, reducing the effects of dust on the nearby 

population. 

• Environmental Justice – There is a history of impacts to minority and lowincome populations associated with past industrialization and transportation 

projects. There will be adverse disproportionate impacts from this project. 

• Noise – No perceptible increase in noise on sensitive areas is expected with 

planned security walls, as defined in Section 4.9 of this FEIS. Traffic volumes in 

the terminal area will increase as economic conditions improve, but in terms of 

noise, the changes with DIFT traffic are inconsequential compared to background 

traffic. The exception is that redirecting truck traffic on Livernois away from the 

area south of the entry gate and closing the existing gate, at Dix/Waterman, will 

cut truck traffic on south Livernois and Dragoon to a noticeable extent, so that 

noise levels will be perceptibly lower. 

• Cultural Resources – An adverse effect is expected by removal of the Michigan 

Box Company building, as defined in Section 4.13, but indirect effects could be 

positive through the spillover effect of local redevelopment.48 No effects are 

forecast on parks/recreational lands, as presented in Section 4.14 of this FEIS. 

• Contaminated Sites – The increased intermodal activity could cause, over the 

next 20 years, up to 60 acres of contaminated land (e.g., brownfields) to be 

reclaimed by the private sector. This could lead to increased, but less polluted, 

water runoff. 

• Water Quality – As discussed in Section 4.11 of this FEIS, it is expected that 

paving the Livernois-Junction Yard will improve drainage as the runoff today 

clogs sewer inlets, which causes standing water in railroad viaducts on Lonyo, 

Central and Livernois. The standing water sometimes causes these roads to be 

impassable. Where the project increases stormwater amounts by paving terminal 

surfaces that now absorb water, surface runoff will be directed to an engineered 

onsite collection site to ensure that future flow rates do not increase. Because of 

the combined sewer system, all water will be treated before it outfalls to the 

Detroit River. Prevention plans to address accidental spills of hazardous 

materials will continue to be maintained by the railroads. Reclaiming up to 60 

acres of potential contaminated properties (e.g., brownfields) is possible, as noted 

above. 

• Farmland, Open Space, Threatened and Endangered Species, Soils – There will 

be no indirect effects on these resources. 

• Visual Effects – The improved visual effect of the buffering of the Detroit 

Livernois Yard could have a spillover effect in the neighborhood. 

• Energy – There will be long-term benefits from the increased conversion of 

freight hauling to rail. 

The results of the conditions presented above indicate long-term effects will be positive. 

 

48 The State Historic Preservation Officer (SHPO) will review the security wall across from the house at 6332 Kronk. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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It is recognized that, over time, undesirable environmental features have accumulated from 

industrialization and related transportation projects. Some have existed for many years. 

Public resources to address many of these conditions have been lacking. The DIFT project 

is envisioned as a way for public and private sector investments to bring some measure of 

improvement to existing rail activity and the affected population, knowing that activity will 

expand in the future with or without the project. On balance, the investment and 

improvements of Action Alternatives is seen to have beneficial indirect effects on to these 

areas compared to the No Action Alternative. 

4.17.1 Cumulative Effects 

The most significant past, present and reasonably foreseeable future sections that affect each of 

the terminal areas are summarized here (Tables 4-42 – Practical Alternatives and 4-43 – Preferred 

Alternative): 

Livernois-Junction Yard/CP Expressway Terminal Area 

The trend towards the urbanization of this terminal area is directly linked to the elaboration of an 

existing railroad routing coupled with the opening of Michigan’s northern mineral ranges 

beginning in the 1850s. In 1863, the Grand Trunk Union Depot passenger station was built. The 

Michigan Central passenger station, on West Vernor Highway south of Michigan Avenue, was 

finished in 1909, immediately following the railroad tunnel to Windsor. The Ambassador Bridge 

was opened in 1928. 

Construction of I-75 began in 1962 and was completed in 1972. It cuts through the LivernoisJunction Yard/CP Expressway terminal area. I-94 was completed between the mid-1950s and 

early 1960s through the Livernois terminal area. I-96 connects with both I-94 and I-75 in the 

terminal area. These freeways are considered intrusions on otherwise tightly-knit neighborhoods. 

The primary factor driving development in the southwest area of Detroit/east Dearborn was the 

creation of Ford Motor Company’s Rouge Plant in 1918/1919. Housing development in the 

terminal area bounded by Livernois (east), Michigan (north), Wyoming (west), and Dix/West 

Vernor (south) is dated primarily between 1900 and 1929. But, since its heyday, this part of 

Detroit, and all of the City, have been affected by outmigration of corporations, then people. The 

globalization of businesses, typified by such pacts as the North American Free Trade Agreement 

(NAFTA), has fueled that change. Notable exceptions are Ford Motor Company’s $2 billion 

investment in re-engineering its Rouge Plant and General Motors’ move to Downtown Detroit. 

Nonetheless, ongoing revitalization in the area includes: 

• Bagley Housing Condominium Development. 

• Continued redevelopment along Vernor Highway, including the Bowtie area at the 

Vernor/Livernois Avenue intersection. 

• Continued housing stabilization due to code enforcement and related activities. 

• Housing development in east Dearborn east of Wyoming served by Roberts Street. 

• A new Museum of Arab Culture opposite the Dearborn City Hall. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 4-42 

Summary of Cumulative Effects – All Action Alternatives 

Alternative 2: Improve-Expand 

Alternative 3: Consolidate 

Alternative 4: Composite of Alts. 2 and 3 

Terminal/ All Terminals Livernois-Junction CP/Oak CN/Moterm 

Alternative 

Effects No Action Alternatives 2, 3 and 4 Alternative 2 Alternatives 2 and 4 

Mobility • Normal, non-DIFT traffic 

increases. Truck traffic 

continues to use 

neighborhood streets. 

• A West Detroit, Junction 

project supports Amtrak. 

• Detroit River International 

Crossing offers alternative 

to Ambassador Bridge. and 

reduces truck traffic on 

Livernois/Dragoon. 

• No negative effect of 

congestion on major arteries or 

local streets unless Jobs Tunnel 

follows intermodal relocation. 

• No negative effect of congestion on 

major arteries or local streets. 

• No negative effect of congestion on 

major arteries or local streets. 

Economic Impacts • Virtually no change in 

job/economic trends. 

• Michigan Ave development 

support redevelopment. 

• Local business expansion in 

several sectors is expected. 

• Increase in local jobs is 

expected with greater income 

levels and buying power. 

• Growth in tax base is expected. 

• Local business expansion in several 

sectors is expected. 

• Increase in local jobs is expected 

with greater income levels and 

buying power. 

• Growth in tax base is expected. 

• Local business expansion in several 

sectors is expected. 

• Increase in local jobs is expected 

with greater income levels and 

buying power. 

• Growth in tax base is expected. 

Land Use • Maintains existing land use 

and development patterns. 

• Land use changes due to 

improved economic stimulus. 

• Unwanted mixing of land uses 

must be resisted by applying 

Detroit Master Plan of Policies. 

• Land use changes due to improved 

economic stimulus. 

• Unwanted mixing of land uses must 

be resisted by applying Detroit 

Master Plan of Policies. 

• Land use changes due to improved 

economic stimulus. 

• Unwanted mixing of land uses 

must be resisted by applying 

Detroit Master Plan of Policies. 

Air Quality • Pollution reduced by 

cleaner engines and fuel. 

• Increase in development will 

possibly increase local pollution 

but emissions will decrease 

faster than travel increases with 

no adverse effect expected. 

• Increase in development will 

possibly increase local pollution but 

emissions will decrease faster than 

travel increases with no adverse 

effect expected. 

• Increase in development will 

possibly increase local pollution 

but emissions will decrease faster 

than travel increases with no 

adverse effect expected. 

Community Effects • Industrial/commercial uses 

will continue to be mixed 

with residential uses. 

• Continued rail/vehicle 

conflicts at Central and 

Lonyo. 

• Ripple-wave development may 

create opportunities for use of 

underused residential parcels. 

• New local development may 

lead to unwanted mixing of 

uses unless already-existing 

provisions in Detroit Master 

Plan of Policies and Dearborn 

Land Use Plan are strictly 

applied. 

• Ripple-wave development may 

create opportunities for use of 

underused residential parcels. 

• New local development may lead to 

unwanted mixing of uses unless 

already-existing provisions in 

Detroit Master Plan of Policies are 

strictly applied. 

• Ripple-wave development may 

create opportunities for use of 

underused residential parcels. 

• New local development may lead 

to unwanted mixing of uses unless 

already-existing provisions in 

Detroit Master Plan of Policies and 

Ferndale, Highland Park and Hazel 

Park Land Use Plans are strictly 

applied. 

Noise • No perceptible increase due 

to intermodal terminal 

activity. 

• Traffic volumes will increase. 

Proper location of growth away 

from sensitive areas will avoid 

adverse noise impacts. 

• Traffic volumes will increase. 

Proper location of growth away 

from sensitive areas will avoid 

adverse noise impacts. 

• Traffic volumes will increase. 

Property location of growth away 

from sensitive areas will avoid 

adverse noise impacts. 

Cultural Resources • No effects expected. • Historic districts/properties may 

experience effects that may be 

adverse if local controls are not 

applied or benefit from positive 

spillover effect with 

redevelopment. 

• Historic districts/properties may 

experience effects that may be 

adverse if local controls are not 

applied or benefit from positive 

spillover effect with redevelopment. 

• Historic districts/properties may 

experience effects that may be 

adverse if local controls are not 

applied or benefit from positive 

spillover effect with 

redevelopment. 

Contaminated Sites • Reclaiming properties now 

affected by hazardous 

materials is expected to 

have a positive effect. 

• Reclaiming properties now 

affected by hazardous materials 

is expected to have a positive 

effect. 

• Reclaiming properties now affected 

by hazardous materials is expected 

to have a positive effect. 

• Reclaiming properties now affected 

by hazardous materials is expected 

to have a positive effect. 

Water Quality • Maintains status quo. • Increased development could 

lead to more impervious surface 

runoff and pollutant load. It is 

expected available 

infrastructure will handle 

cumulative development but no 

certainty exists. 

• Increased development could lead to 

more impervious surface runoff and 

pollutant load. It is expected 

available infrastructure will handle 

cumulative development but no 

certainty exists. 

• Increased development could lead 

to more impervious surface runoff 

and pollutant load. It is expected 

infrastructure will handle 

cumulative development but no 

certainty exists. 

Source: The Corradino Group of Michigan, Inc. 
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Table 4-43 

Summary of Cumulative Effects – Preferred Alternative 

Terminal/ Livernois-Junction CP/Oak CN/Moterm 

Alternative 

Effects Preferred Alternative Preferred Alternative 

Not Part of 

Preferred Alternative 

Mobility • No negative effect of congestion on 

major arteries or local streets. 

Ambassador Gateway project will 

reduce trucks on local streets in SW 

Detroit. 

• A West Detroit, Junction project 

supports Amtrak. 

• Detroit River International Crossing 

offers alternative to Ambassador Bridge. 

and reduces truck traffic on 

Livernois/Dragoon. 

• Oak Terminal reverts to nonintermodal rail use. No negative 

effect of congestion on major 

arteries or local streets. 

• Moterm not part of Preferred 

Alternative. Normal, non-DIFT 

traffic increases. Truck traffic 

continues to use neighborhood 

streets. 

Economic Impacts • Local business expansion in several 

sectors is expected. 

• Increase in local jobs is expected with 

greater income levels and buying power. 

• Growth in tax base is expected. 

• Michigan Ave development support 

redevelopment. 

• No local terminal area effects of 

significance are expected. 

• No local terminal area effects of 

significance are expected. 

Land Use • Land use changes due to improved 

economic stimulus are expected. 

• Unwanted mixing of land uses must be 

resisted by applying Detroit Master Plan 

of Policies. 

• Maintains existing land use and 

development patterns. 

• Maintains existing land use and 

development patterns. 

Air Quality • Changes at local industry will improve 

air quality. 

• Increase in development might possibly 

increase local pollution relative to No 

Action Alternative, but emissions will 

decrease faster than travel increases, 

with no adverse effect expected. 

• Oak Terminal reverts to nonintermodal rail use, reducing 

truck traffic and improving local 

air quality due to cleaner fuels 

and engines. 

• Pollution reduced by cleaner 

engines and fuel. 

Community Effects • Ripple-wave development may create 

opportunities for use of underused 

residential parcels. 

• New local development might lead to 

unwanted mixing of uses unless alreadyexisting provisions in Detroit Master 

Plan of Policies and Dearborn Land Use 

Plan are strictly applied. 

• Status quo maintained, no 

cumulative effects anticipated. 

• Virtually no change in community 

effects, unless sponsor is found for 

regional park at Fairgrounds. 

Noise • Project will divert/reduce trucks from 

Central, and Livernois/Dragoon, 

reducing noise levels there and shield 

sensitive areas from rail yard noise. 

• Traffic volumes will increase as 

economic conditions improve. Proper 

location of growth away from sensitive 

areas will avoid adverse noise impacts. 

• Status quo maintained, no 

cumulative effects anticipated. 

• No perceptible increase due to 

intermodal terminal activity. 

Cultural Resources • Project support for economic 

redevelopment will have positive effect 

on rehabilitation of historic 

districts/properties, if local preservation 

controls are applied. 

• Status quo maintained, no 

cumulative effects anticipated. 

• No effects expected. 

Contaminated Sites • Reclaiming properties now affected by 

hazardous materials is expected to have 

a positive effect. 

• Status quo maintained, no 

cumulative effects anticipated. 

• No cumulative effects anticipated. 

Water Quality • Increased development could lead to 

more impervious surface runoff and 

pollutant load. It is expected available 

infrastructure will handle cumulative 

development but no certainty exists. 

• Paving yard will reduce surface runoff, 

which clogs sewers. 

• Status quo maintained, no 

cumulative effects anticipated. 

• No cumulative effects anticipated. 

Visual Effects • Potential spillover effect from buffer 

around yard. 

• Status quo maintained, no 

cumulative effects anticipated. 

• Status quo maintained, no 

cumulative effects anticipated. 

Energy • Improved efficiencies from conversion 

of some freight shipments from truck to 

rail are expected. 

• Status quo maintained, no 

cumulative effects anticipated. 

• Status quo maintained, no 

cumulative effects anticipated. 

Source: The Corradino Group of Michigan, Inc. 
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• Expansion of Truck City in an area bounded by Michigan, Southern, Wyoming and 

Stecker. 

• Potential revitalization of Michigan Central Depot to Detroit police headquarters and 

other office space. 

• Proposed west Riverfront Development. 

• Potential revitalization of Tiger Stadium. 

• Proposed housing along Michigan Avenue, east of West Grant Boulevard. 

• Proposed greenway development at Romanowski Park. 

Infrastructure developments include: 

• A combined sewage overflow facility at Patton Park. 

• A proposed conversion by a private venture of the Detroit-Windsor Railroad tunnels to 

truck and construction of a new rail tunnel. 

• An improved connection between the Ambassador Bridge and the interstate highway 

system. 

• A possible new border crossing. 

• Rehabilitating I-94. 

• Potential passenger rail service between Detroit and Ann Arbor as well as Metro Airport 

passing through the Livernois-Junction Yard area. 

• Possible high-type transit (bus rapid transit or light rail are potential examples of 

improvements) in almost one dozen corridors, including along Michigan Avenue and Fort 

Street within the terminal area. 

The future trend of development in the Livernois-Junction Yard/CP Expressway terminal area is 

summarized in the City of Detroit Master Plan of Policies, which views the area as follows: 

“Southwest Detroit has two outstanding economic characteristics: an exceptional 

concentration of very heavy industry, and a unique convergence of freight transportation 

modes. Weaknesses of the Sector relate to economic obsolescence in both the industrial 

and commercial plant. Strengths of the area include the Detroit River as a unique 

attraction, the fixed nature of the transport infrastructure, the availability of many sound 

industrial buildings, and the shopping habits of many local residents favoring 

neighborhood stores. 

“Detroit’s major concentration of ports, rail facilities, truck terminals, pipelines, 

international crossings and associated or support facilities and organizations occurs in 

the Southwest Sector. This remains unchanged despite the serious and continuing 

erosion of the Sector’s manufacturing base. Only to a limited extent can changing 

technology, changing corporate ownership patterns, or other evolutionary factors 

disperse southwest Detroit’s highly significant concentration of freight facilities. In fact, 

prevailing economic forces actually favor continued concentration. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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“The Southwest Sector, therefore, will remain an area of primary economic importance, 

and industrial activities, within the limits of sound planning and environmental 

protection. 

“Keys to the renewal of the Southwest area will include an improved education system 

aimed at specific needs of the residents (including career training and the re-education of 

adults), a safe, secure, and healthy environment, good recreational facilities, and 

improved public transportation.” 

The Dearborn Master Plan states the following: 

”The Dearborn master plan proposes continuation of an extensive belt of general 

industrial land which follows the railroad lines along the entire eastern side of Dearborn. 

Within this large industrial corridor are located the Ford Motor Company, Chrysler 

Corporation, American Blower Company, the Detroit Water Board, and many other 

large industrial installations. The only exception to this large industrial corridor on the 

city’s east side are the older residential neighborhoods, which exist in the vicinity of Dix 

Road and Wyoming Avenue. The Detroit master plan proposes a similar band of general 

industrial use along Detroit’s boundary with Dearborn. Adjacent to the corresponding 

Detroit industrial corridor are older residential neighborhoods. The adjoining Dearborn 

and Detroit industrial areas form one of the major heavy manufacturing corridors in 

southeast Michigan. The continued vitality of this industrial corridor will depend on the 

need to rebuild and improve the obsolete I-94 Industrial Freeway and the need to 

introduce newer forms of multi-modal transportation. The railroad line which previously 

served that portion of the industrial corridor between Ford Road and Tireman Avenue 

has been recently abandoned. The Industrial Freeway portion of Interstate-94 is an 

antiquated expressway which was never designed to carry the high volumes of traffic 

which it now carries. The interface of this expressway with Dearborn’s major street 

pattern and the design of the ramping system need to be completely redesigned and 

rebuilt to serve modern needs. Along its southeast boundary, Dearborn and Detroit 

share Patton Park, a major urban park, which is adjacent to the Woodmere Cemetery in 

Detroit. The park and cemetery are very compatible adjoining land uses to the older 

residential neighborhoods which exist in Dearborn in the Dix Road/Wyoming area. 

“Both the Dearborn and Detroit master plans indicate a continuation of lower-density 

single-family neighborhoods on both sides of Tireman Avenue on Dearborn’s 

northernmost boundary. Both Dearborn and Detroit indicate a strip commercial 

development in their master plans along the common boundary which they share along 

Greenfield Road. In general, the City of Detroit’s master plan indicates low-density 

single family development throughout those neighborhoods which are north of Ford 

Road. There are no problems of land use compatibility between the two cities.” 

CP/Oak Terminal Area 

The Detroit, Lansing & Lake Michigan Railroad was completed across the terminal area from 

east to west in 1871. In 1891, the line was merged with the Flint & Pere Marquette Railroad, 

which opened a spur-line to the southwest Detroit manufacturing center at Delray. This area, like 

all others in Detroit, experienced in the last 30+ years a significant outmigration of businesses, 

jobs and, then, population. As noted earlier, the globalization of business has had a major effect 

on this place which was once known as “The Arsenal of Democracy.” The construction of 

expressways fostered outward-moving development in the second half of the 20th century. The 

Southfield Freeway (M-39) connecting I-94 to Eight Mile Road (M-102) was completed between 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Schoolcraft and Six Mile Road in 1963. The I-96 connector from I-75 to I-275 was completed in 

1975. 

Post-1910 land use patterns were directly influenced by Detroit’s industrial growth. During the 

succeeding decades, and through the start of World War II, the entirety of the CP/Oak terminal area 

was rapidly subdivided for housing and small industry. The process of industrial development was 

further heightened during World War II and the immediate post-war period. In the 1947 Detroit 

Planning Commission land use report, the CP/Oak terminal area was identified as being in the 

fastest growing new industrial corridors that ribboned the city along its extended network of 

railroads. But, development in the area slowed considerably. Now it is largely focused in the 

commercial revitalization of Grand River Avenue and continued stabilization of housing through 

code enforcement and related activities. 

New infrastructure development in the area is limited, beyond regular maintenance and repair of 

existing facilities. Long-term plans by SEMCOG include high-type transit facilities/services 

along Grand River Avenue and in the vicinity of the Southfield Freeway. 

Unlike the Southwest Sector of Detroit, the Detroit Master Plan of Policies is silent on the issue 

of the CP/Oak rail terminal. 

It portrays the future land use/development trends in areas around the terminal (known as the 

West Sector) as follows: 

“The physical condition of much of the housing, commercial, and industrial development 

in the West Sector is generally good, a reflection of the fact that much of the area 

developed after World War II and is one of the new parts of Detroit. 

“The West Sector has the potential to continue to be one of Detroit’s most popular areas 

for family living. It offers a wide variety of substantial single-family and apartment 

housing, a very generous amount of recreation facilities, and good accessibility to 

downtown and suburban shopping and employment.” 

CN/Moterm Terminal Area 

CN/Moterm has direct access to two interstates: I-696 running east/west and I-75 running 

north/south. Primary exits along I-696 that serve the area include Woodward Avenue (exit 16), 

Schaefer Highway (exit 14), and I-75 (exit 18). Primary exits along I-75 that serve the area 

include Nine Mile Road (exit 60), Eight Mile Road (exit 59), and Six Mile Road (exit 57). The 

area is also served by State Highway 1 (Woodward Avenue), linking downtown Detroit with 

Pontiac and by State Highway 102 (Eight Mile Road). 

The 1905 placement of the Michigan State Fairgrounds on the edge of Wayne County’s northern 

boundary with Oakland County established the facility in the rural countryside separating Detroit 

and Pontiac. Over the next quarter century, growth, emanating out of Detroit, completely 

changed the surrounding landscape. 

The proximity of Ford Motor Company’s Highland Park plant was the driving force in urban 

development throughout north Detroit and the Royal Oak Township area during the first quarter 

of the 20th century, with development primarily concentrated along Woodward Avenue. The 

creation of the cities of Highland Park (1918), Hamtramck (1922), and Royal Oak (1921) was 

shortly followed by the incorporation of the cities of Ferndale (1927), Pleasant Ridge (1928), 

Berkley (1932), and Huntington Woods (1932). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Throughout the decade following the close of World War I, Detroit’s north-end neighborhoods 

were promoted as areas of housing development for the upwardly mobile, middle class. As a 

direct result of automotive plant development in the nearby Highland Park and Hamtramck 

communities, between 1939 and 1945, the number of Oakland County residents employed in 

local suburban plants jumped from 2,000 to 21,000. In 1955, Ferndale advertised itself as being 

“on the world’s greatest highway,” further noting that upwards of 55 percent of the municipal tax 

value ($45.8 million) was based on business and industrial properties, “...thus insuring stability 

to the city’s financial future”. The Grand Trunk Railroad yard (now the CN/Moterm terminal) 

was described as being “central to the auto centers of Detroit, Pontiac and Flint.” The 

commentary went on to note that, 

 “The residential quality of Ferndale has been improved by this industrial growth, for the 

reason that the industrial district has been confined by the far-sighted authorities to the 

railroad neighborhood in the eastern part of the city. This control has also expressed 

itself in the high character of industries located here.”49

Much of that has changed with the changing competitive environment. For example, Highland Park 

has experienced the loss to competing communities of its largest employer. Nonetheless, it 

continues to pursue sustainability. 

Major revitalization efforts in the four cities that host the CN/Moterm terminal area (Detroit, 

Ferndale, Highland Park and Hazel Park) include: 

• Planned redevelopment of the southeast corner of Woodward Avenue and Eight Mile 

Road. 

• Proposed development at the State Fairgrounds (e.g., Joe Dumars Field House). 

• Planned revitalization of Ferndale’s business core and neighborhoods. 

• Proposed mixed-use redevelopment of the Hazel Park Race Course. 

• Residential and commercial revitalization throughout Highland Park typified by the 

following projects: 

9 Town Center. 

9 Highland Heights Historic District. 

9 Medbury-Grovelawn Historic District. 

9 Neighborhood commercial development along Hamilton Avenue. 

9 Infill townhome development south of the Davison Freeway. 

9 Industrial revitalization at the Farmer Model-T area. 

9 Industrial development along Oakland Boulevard. 

 

49 Ferndale City Directory. R.L. Polk and Company, Detroit. 1955. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Major transportation developments in the area include the proposed widening of I-75 throughout 

Oakland County; the revitalization of the Woodward Avenue/Eight Mile Road intersection; and, 

high-type transit along corridors like Eight Mile, Woodward Avenue, and Gratiot Avenue. 

Future development possibilities for the area around the CN/Moterm terminal are best portrayed 

in the master plans of each of the four host cities. For Detroit’s North Sector, the Master Plan of 

Policies indicates 

“The elements most greatly affecting the future of the North Sector are its industrial 

facilities, its neighborhood systems, and – directly tied to neighborhoods – its housing 

stock. The Sector’s greatest potential lies in the maximization of these three resources. 

“Industrial areas of the North Sector appear to have excellent potential for continued 

employment opportunities, for expansion of select areas, and for continued support of the 

economic base of the City, given the Sector’s attributes of location. 

“Central to the future of the North Sector is its neighborhood systems. The North Sector 

has many healthy neighborhoods on which to expand; it has just as many neighborhoods 

with the potential to become just as healthy as any of the best neighborhoods of the 

Detroit metropolitan area. 

“The North Sector is a major trucking center, second in importance only to the Southwest 

Sector (among Detroit’s 11 planning sectors). Rail transportation, however, is of less 

importance to the North Sector, for rail lines mainly serve through traffic. The Sector is 

not heavily industrialized; there are very few active rail sidings here, and no rail 

classification yards (areas used for switching and freight trains linking up) or terminals 

remaining active. 

“The construction of the planned Light Rail Transit (LRT) system along Woodward will 

have an important impact on the North Sector. The regional transportation plan calls for 

the development of a LRT system in the Woodward Corridor from downtown Detroit to 

the northern suburbs.” 

The Ferndale Master Plan cites the following for the area “Southeast of Nine Mile Road and 

Woodward Avenue:” 

“The Grand Trunk Railroad property and the surrounding industrial uses are the primary 

users of land in the Southeast Planning Area. 

• The industrial land use pattern is proposed for minor expansion in three areas. These 

include two areas along Bennett between Fair and Westend and Troy south of Nine Mile. 

• Along sections of Hilton south of Hazelhurst, a mixture of multiple-family use and office 

use is proposed. This office and residential redevelopment area would receive the same 

zoning as is proposed for the Livernois corridor (mixed use residential and office). 

• Multiple-family land uses are proposed for: area south of Nine Mile and east of 

Woodward Avenue; on the west side of Hilton, south of Hazelhurst, also west of Hilton, 

east of Woodward between Webster and Chesterfield. 

• Business redevelopment and expansion is proposed east of Woodward Avenue and north 

of Eight Mile Road. The consolidation of sites and enlargement of existing uses is 

discouraged. These increases in land use intensity must meet the same objectives listed 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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for the business redevelopment along Eight Mile west of Woodward and the PUD zoning 

should be considered. 

• Another business area in need of improvement is at Hilton and Nine Mile Road. In 

addition to business uses, the possibility of locating a station for rail commuters should 

be explored with other agencies in the Metro area. 

• For the area east of Wanda between Channing and Chesterfield, uses should be 

encouraged that function as buffers between the residential uses to the east and the 

industrial uses to the west. For the industrial sites along Wanda (south of Nine Mile 

Road) parking, storage and high intensity use areas should be buffered from the 

residential uses. The buffered areas can be developed by using landscaping, walls, earth 

berms or fences. Within the Wanda Street rights-of-way more street trees can be planted 

to help buffer the residential uses from the industrial uses.” 

The Hazel Park Master Plan indicates: 

“Eight Mile Road Corridor. A major component of the plan for the Eight Mile Road 

Corridor is to increase the area and depth of parcels to improve their industrial or 

commercial potential. This will allow for parking areas and a landscape buffer to 

protect and strengthen residential areas north of the frontage. Closing of Muir Street 

could be considered in conjunction with significant development proposals. Most of the 

frontage is planned for corridor business or industrial use which will increase the 

potential reuse of vacant properties beyond traditional retail or highway commercial. 

Viable light industrial uses can co-exist with commercial and a more cohesive corridor 

can emerge with sufficient parcel depth, attractive landscaping, quality site design 

standards, signage and lighting. The City should remain involved with the Eight Mile 

Boulevard Association and seek opportunities to coordinate redevelopment plans with 

regional planning and design proposals for the Eight Mile Road Corridor.” 

The Highland Park Master Plan indicates: 

“Highland Park seeks to re-establish the city as a livable community. Desiring to 

establish land use policies which will encourage and direct new investment in the city, 

this Master Plan provides a guide for land use to meet the city’s goals. To make 

Highland Park a desirable and livable community, the city will focus on the following: 

• Improving the city’s neighborhoods 

• Rebuilding the economic base 

• Creating a better image for the community, which announces that Highland Park is 

an attractive small town oasis in the urbanized metropolitan area 

• Revitalizing Woodward Avenue as the city’s main street.” 

“A strong economic base is critical to the future of Highland Park. While the city has 

seen new investment in the community, it is important to direct additional investment to 

the rebuilding of the city’s economic base. The city is an attractive business location, 

accessible to the region and, with the recommended infrastructure improvements, 

provides opportunities for new development. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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“The Master Plan provides for a diversity of business types including larger parcels of ten 

acres and more for properties in the Oakland corridor, a new business park at the former 

Ford Model T plant, upgrading of existing business districts (Victor Street and Midland 

Park areas), and the establishment of a communications corridor in cooperation with 

Detroit’s Focus Hope area. 

“Future office and community retail development are encouraged in mixed-use areas in 

the City Center located on Woodward between the Conrail viaduct and Davison Freeway. 

These mixed-use areas also could contain housing on upper floors and rear portions of the 

parcels. In addition, neighborhood amenity retail is encouraged in smaller centers 

proximate to the residential areas on Hamilton and Woodward. 

“It is estimated that implementation of these land use policies over the next decade could 

create approximately $18 million in annual taxes to the city and a total of nearly 10,000 

jobs. With a future residential population of approximately 24,000, the city’s tax base 

could be more supportive of schools and community services.” 

Cumulative Effect Summary 

Based on the past, present and reasonably foreseeable future trends, the following cumulative 

effects can be anticipated with development of all Action Alternatives in the terminal areas 

associated with the Livernois-Junction Yard/CP-Expressway terminal, CP/Oak terminal and 

CN/Moterm terminal (refer to Table 4-42). For the No Action condition, these impacts are a 

continuation of past trends. 

• Mobility: While there will be an increase in traffic due to both the growth in 

intermodal activity and the stimulated additional development under the Action 

Alternatives, there are no negative congestion effects expected either on major 

arteries or local neighborhood streets. 

It should be noted that under Alternatives 3 and 4, where intermodal operations of 

either three or four railroads are consolidated at the Livernois-Junction Yard, the 

terminals at CP/Oak and CN/Moterm will continue to be used by the railroads for 

shipping freight by other means than intermodal. That activity will be associated 

with a smaller volume of truck traffic than if the terminals were to continue to serve 

intermodal. 

• Economic Impacts: It is expected that local businesses will develop or expand in 

several sectors related to the growth in intermodal transportation. Likewise, such 

change will be associated with an increase in local jobs with greater income levels 

and buying power. This should then help grow the tax base. These expected 

conditions apply to each of the three terminal areas. But, they will be greater under 

Alternatives 3 and 4 (i.e., some form of intermodal consolidation) than Alternative 2 

(no consolidation) and Alternative 1 (No Action). 

• Land Use Changes: Land use changes are expected to accelerate with growth in 

intermodal transportation and the associated and improved economic stimulus. Such 

growth could be associated with the mixing of land use types that are unwanted, i.e., 

industrial/commercial with residential. This can be avoided by local units of 

government applying already-existing land use/zoning principles, like those in the 

City of Detroit’s Master Plan of Policies and the master plans of Dearborn, Ferndale, 

Hazel Park and Highland Park. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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• Air Quality: Increased development might increase local pollution relative to the No 

Action Alternative. But, results of the analysis indicate that such increases will not 

cause standards to be violated if the development is properly located and pollution in 

almost all cases will be less than today, including cumulative growth. This will 

happen if government actions are consistent with the planning processes cited earlier 

and in the appendices to this report. 

• Cultural Resources: Historic districts/properties might experience adverse effects 

from new private sector development associated with the growth in intermodal 

activity that could occur adjacent to their boundaries if already-existing local 

government controls are not applied. Conversely they may experience positive 

spillover effects from redevelopment. 

• Community Cohesion: Development stimulated by intermodal activity/investment 

may create opportunities for use of abandoned residential parcels (the City of Detroit 

owns thousands of such parcels as a result of tax delinquencies). This development 

could lead to unwanted mixing of land uses if controls in the master plans of various 

cities are not implemented. For example, tracts large enough to hold logistics 

businesses to support intermodal activity could locate along or near the LivernoisJunction Yard, such as the Ward Bakery at Toledo Avenue and West Grand 

Boulevard. This parcel is tucked in a residential area and should it be allowed to 

develop, the increased truck traffic will have a negative effect on the community. 

• Noise: Traffic volumes and ambient noise levels will increase as economic 

conditions improve. Negative effects are not expected and can be avoided with care 

by the developer and local government agencies in locating this increased 

development away from sensitive uses. 

• Water Quality: Increased development could lead to more impervious surface runoff 

and pollutant load. This could be offset by reclaiming properties now affected by 

contaminated materials for increased economic activity. Thousands of such 

properties exist, are abandoned, and have not been remediated. Use of some of the 

properties by DIFT-related activities will cause remediation which will improve the 

quality of the runoff into surface and subsurface drainage infrastructure, compared to 

the No Action condition. 

These cumulative effects are those expected in each of the three areas around the intermodal 

terminals. Broader regional effects are virtually impossible to quantify or locate geographically. 

But, the possibility exists that, with or without the DIFT, the four Class I railroads will make 

other improvements on their own (like at interlockers discussed in Section 3.4.1) in the Southeast 

Michigan region. To the extent any of these require environmental clearances, they will be 

pursued. 

It is also important to recognize what effects may occur in one key regional area: wealth 

distribution/redistribution, which occurs with shifts in population, employment and tax base. 

Shifts in tax base occur as land is developed for new housing and businesses. Shifts also occur 

within existing built-up areas as residents and businesses move. Both processes usually result in 

less taxable property in older communities that have little undeveloped land and room to grow. 

That is typically the case in southern Oakland County communities, such as Hazel Park and 

Ferndale and such Wayne County communities as Dearborn. 

Market-driven actions and supporting public policy decisions underlie the dynamics of the wealth 

distribution pattern in the Detroit-centered region. All of these decisions operate separately from 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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the Action Alternatives. These dynamics include, as cited by SEMCOG in its report entitled 

Land Use Changes in Southeast Michigan, Causes and Consequences, “...residential segregation 

by race and income, federal tax subsidies for home mortgage interest and property taxes, school 

funding and quality, crime and public safety, societal ideals of lifestyle and urban design, 

constitutional protections of private property rights, infrastructure financing policies, and extent 

of personal vehicle ownership and use.” 

The DIFT has the ability to respond to this pattern in a positive way. By building on the 

transportation and industrial strength of the areas in which intermodal terminals function; by 

making improvements to push terminal traffic out of residential areas; by creating walls that 

provide terminal security and reduce noise; by paving surfaces that are unpaved; by creating jobs 

in the local areas around the terminals; and by preparing/training community residents to be able 

to take those jobs, the DIFT can have greater positive than negative impacts – direct, indirect and 

cumulative. 

The DIFT can also be measured as a positive proposal by using a number of principles of 

Governor Granholm’s Land Use Leadership Council, which promote use of existing 

infrastructure in communities to create public-private investments to address economic and other 

quality-of-life issues. These principles are: 

• Supporting efforts to make Michigan cities more livable by expediting the reuse of 

abandoned properties, controlling blight, encouraging private investment, encouraging 

mixed-use development, improving transportation options, supporting a full range of 

housing options, and attracting and retaining residents who can contribute to the viability 

of our urban core areas. 

• Making better use of existing public infrastructure by encouraging public and private 

investment in already developed areas. 

• Creating incentives to encourage interagency and intergovernmental cooperation in 

addressing land use issues and public investments of more than local concern. 

• Encouraging private investment in already developed areas by removing governmental 

barriers and creating incentives. 

• Identifying “commerce centers” where infrastructure is already serving relatively dense 

populations to guide the future investment of state resources to support private 

investment and development. 

Preferred Alternative – Cumulative Impacts 

Cumulative impacts are summarized in Table 4-43. 

For the Preferred Alternative, the conclusions related to cumulative impacts for Alternative 4 

above would apply as they relate to the Livernois-Junction Yard area for mobility, economic 

impacts, land use changes, air quality, cultural resources, community cohesion, noise, and 

water quality. In response to comments on the DEIS, additional information is provided on 

several of these topics. 

• Mobility – A West Detroit Junction railroad project will improve Amtrak passenger 

train movement in Southwest Detroit. 

 Michigan Avenue was recently reconstructed, substantially improving its driving 

surface and improving travel speeds. MDOT has also been reconstructing Fort Street 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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from the Ambassador Bridge, south across the Rouge River. The reconstruction of the 

bridge over the Rouge River will require a two-year detour of vehicular, bicycle and 

pedestrian traffic to the Dix Road bridge to the north, beginning in 2009. 

 The Ambassador Bridge Gateway Project will complete in 2009 direct access between 

the Ambassador Bridge and the interstate system. In the past, many trucks lost their 

way and “wandered” around Southwest Detroit on roads trying to get to or from the 

Ambassador Bridge. And, one signed truck route goes along Clark Park in 

Mexicantown. The Gateway Project will substantially reduce the chance trucks will 

use local streets. 

 The Detroit International River Crossing (DRIC) project is to provide a new bridge to 

Canada. The crossing will connect to I-75 between the Rouge River and the 

Ambassador Bridge. It will “split” the traffic to/from Canada with the Ambassador 

Bridge. A new crossing to Canada will avoid mobility restrictions between Southeast 

Michigan and Ontario, Canada. 

 All of the DRIC Study alternatives under consideration would close the direct 

connection between I-75 and the Livernois/Dragoon one-way pair that now provides an 

unwanted conduit for trucks through the Southwest Detroit neighborhood to points 

north, including the Livernois-Junction Yard. 

 Whether or not the DRIC Study produces a new crossing, the Ambassador Bridge 

owners are pursuing construction of a replacement span. It would directly connect to 

the plazas in the U.S. and Canada that are being expanded. 

 The synergistic effects of the Gateway Project, and a new river crossing to Canada, be 

it a replacement Ambassador Bridge and/or a new government-sponsored project, or 

both, on the DIFT are few. Little intermodal truck activity comes across the DetroitWindsor border. This is known from observation and documented in information 

released by FHWA in 2006 (based on 2002 data), which found that the combination of 

“truck-rail intermodal” and “other intermodal” represents ony one fourth of one 

percent of weight (in tons) flowing across the border at Detroit.50 The biggest change 

that could be brought by the DRIC would be closing the Livernois-Dragoon 

interchange with I-75. This interchange closure would reinforce the DIFT’s intention 

to focus truck traffic on I-94 to Livernois and Wyoming Avenue, which will keep truck 

traffic out of neighborhoods. Planning is advancing on upgrading the plaza of the 

Blue Water Bridge at Port Huron. This change would have a negligible effect on the 

Detroit-Windsor area, including the DIFT project. 

• Economic Impacts - It is expected the reconstruction of Michigan Avenue by MDOT 

will foster economic redevelopment there. 

 The Ambassador Bridge Gateway Project will divert truck traffic from Fort Street, as 

direct ramp connections to the interstates are being provided. Today, all trucks coming 

into the U.S. get to I-75 southbound via Fort Street. Some of these trucks likely take 

advantage of the numerous truck-oriented businesses along Fort Street. These 

businesses will see fewer trucks passing by. 

 

50 Data from the Freight Analysis Framework (FAF) as presented by FHWA February 13, 2006, in Lansing. For 

information on the FAF see http://ops.fhwa.dot.gov/freight/freight_analysis/faf/ 
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 Local business expansion in several sectors is expected with increased jobs and tax 

base. 

• Land Use – Without the DIFT project there is no indication the pattern of 

industrial/trucking/scrap yard uses will change. Though residential rehabilitation is 

occurring in Southwest Detroit, this is not the case nearer the Livernois-Junction Yard. 

Several homes on the north side of John Kronk originally counted as relocations in the 

DEIS have burned and are no longer standing. 

• There is a community sense that appropriately placed vegetation can have a long-term 

positive land use effect. By providing a buffered “edge” to the railroad terminal, the 

project will be a better neighbor than the rail yard is today, and help stabilize land uses 

in the area. There are few such buffers in the area now. 

• Air Quality – A number of actions are being taken regionally to improve air quality. 

Actions related to U.S. Steel, Sverstal Steel and Marathon are noted in the Section 4.8. 

Dust control plans have been instituted in some instances. The Ambassador Bridge 

Gateway project will provide direct connections for trucks to the freeway system, 

eliminating Fort Street as the access to I-75 southbound. The DIFT project promotes 

the use of rail, rather than roads to move freight and reduce both on-terminal and 

local roadway emissions. Insofar as increased development accompanies these projects 

individually and/or collectively over time, SEMCOG has forecast that cleaner engines 

and fuel will outstrip increased travel. 

• Over the long term, increasingly stringent EPA controls announced in March 2008 on 

new and remanufactured locomotives (remanufacturing normally occurs every five to 

15 years) and on locomotive idling will substantially improve CO2, NOx and PM 

emissions. 

• Both MDOT and the railroads have made commitments to try to improve air quality. 

See the Green Sheet at the end of Section 5. 

• Community Effects – Ripple-wave development may create opportunities for use of 

underused residential parcels. 

• New local development might lead to unwanted mixing of uses unless already-existing 

provisions in Detroit Master Plan of Policies and Dearborn Land Use Plan are strictly 

applied. 

• Noise – Project will divert/reduce trucks from Central, and Livernois/Dragoon, 

reducing noise levels there and shield sensitive areas from rail yard noise. 

• Traffic volumes will increase as economic conditions improve. Proper location of 

growth away from sensitive areas will avoid adverse noise impacts. 

• Cultural Resources – Project support for economic redevelopment will have positive 

effect on rehabilitation of historic districts/properties, if local preservation controls are 

applied. 

• Contaminated Sites – Reclaiming properties now affected by hazardous materials is 

expected to have a positive effect. 
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• Water Quality – Increased development could lead to more impervious surface runoff 

and pollutant load. It is expected available infrastructure will handle cumulative 

development but no certainty exists. 

• Paving yard will reduce surface runoff, which clogs sewers. 

• Farmland, Open Space, Threatened and Endangered Species, Soils – There will be no 

indirect effects on these resources. 

• Visual Effects – The improved visual effect of the buffering of the Detroit Livernois 

Yard could have a spillover effect in the neighborhood. 

• Energy – There will be long-term benefits from the increased conversion of freight 

hauling to rail and support of measures to improve Amtrak’s operations. 

4.18 Emergency Response Controls 

Each of the Class I railroads operating intermodal freight terminals in Southeast Michigan has 

Emergency Response Plans in place to address transportation incidents involving U.S. DOTregulated materials (hazardous materials, hazardous substances and hazardous wastes) and oils. 

These plans prescribe procedures to respond to spill incidents from derailments, leaks, fuel spills, 

etc. 

Regulations governing Emergency Response Plans include OSHA’s (the U.S. Occupational 

Safety and Health Administration) Hazardous Waste Operations and Emergency Response 

(HAZWOPER) requirements, U.S. DOT’s 49 CFR 130, the Oil Pollution Prevention and 

Response regulations (40 CFR Part 112) and other programs of the Clean Water Act. 

Components of Emergency Response Plans include pre-emergency planning coordination with 

local agencies; assignment of personnel, their roles and responsibilities; hazard recognition; 

specialized personnel training; site security and control; emergency notification procedures; spill 

response equipment; and, emergency medical treatment provisions. 

Spill prevention and response at fixed facilities (including railroad terminals) that store quantities 

of oil and hazardous materials above threshold amounts are addressed with Spill Prevention 

Control and Countermeasures Plans (SPCC) and Stormwater Pollution Prevention Plans that have 

been prepared by the railroads. These plans focus on prevention of releases to streams and other 

water bodies. 

These procedures were part of the No Action Alternative and all Action Alternatives, as well. 

Preferred Alternative 

The procedures listed above apply to the Preferred Alternative. 

4.19 Terminal Security 

For all Action Alternatives, walls, fencing, other physical barriers, and electronic systems (e.g., 

sensors, alarms) are part of each Action Alternative to protect areas within an intermodal terminal 

from unauthorized access. Access control points for personnel and vehicles to move through the 

terminal boundary lines (such as gates, doors, guard stations, and electronically controlled or 

monitored portals) are also included in each Action Alternative’s design. Measures that will 
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enhance these boundaries/access points include clear zones on both sides of fences, security 

lighting, locks, CCTV systems and signage. 

While the number of access points will be kept to a minimum, adequate vehicle access points are 

planned for maintenance and emergency operations. To prevent obstructions within the gate path 

and protect gate equipment, the design concept includes proper drainage grading; planned gaps in 

curbs; installation of concrete channels or mow strips below the gate path; and, use of bollards. 

Security effectiveness of the perimeter will be enhanced by the provision of clear areas on both 

sides of the wall to facilitate surveillance and maintenance of the wall and deny cover to vandals 

and trespassers. Suggested clear distances range from 10 to 30 feet, within which there should be 

no climbable objects, trees, or utility poles abutting the wall nor areas for stackable crates, pallets, 

storage containers, or other materials. Likewise, the parking of vehicles along the wall will also 

be prevented. In addition, landscaping within the clear area will be designed to reduce potential 

hidden locations for persons, objects, fence damage, and vandalism. 

Lighting of the area on both sides of gates, and selected areas of walls, will be provided. 

Similarly, sufficient lighting will be provided for areas in which a CCTV (closed circuit 

television) camera is intended to monitor activity. Reduced lighting, or sensor-activated lighting, 

may be considered in areas which have minimal traffic throughput in the off-peak hours. CCTV 

monitoring will be considered, particularly for low-traffic gates and maintenance access points 

that are removed from principal activity areas. 

Signage will be posted on certain security boundaries and at selected access points. Signs will be 

located such that when standing at one sign, the observer will be able to see the next sign in both 

directions. The use of signage, even in some non-required locations, will provide a deterrent by 

warning of the boundary as well as for notification of the consequences for violation. Many 

locations with access control or CCTV equipment may warrant signage for either directional or 

legal purposes (e.g., “Alarm Will Sound If Opened,” “Authorized Personnel Only,” “Notice: All 

Activities In This Area Are Being Recorded via CCTV,” etc.). 

VACIS (Vehicle and Cargo Inspection Station) is an X-ray-type device that is able to see into 

containers/trailers to detect any unusual cargo. VACIS systems are now being installed by each 

of Canadian Pacific and Canadian National Railroads to screen trains on the Canadian side of the 

international border before they enter the U.S. Consideration by all DIFT participants (public and 

private) will be given to installing a VACIS system at the Livernois-Junction Yard under 

Alternatives 2, 3 or 4, if an Action Alternative is chosen for implementation. The allocation of 

cost would be determined at that time. 

Preferred Alternative 

The conclusions in the above paragraphs remain true for the Preferred Alternative. 

4.20 Terminal Lighting 

The CP/Expressway and the CP/Oak terminals are surrounded by railroad tracks, major 

roadways, industrial properties, and commercial properties. Because of this, no sensitive areas 

such as residential neighborhoods would have been affected by lighting at those terminals. 

Directional lighting would have been used at the CN/Moterm terminal, in areas near the 

residential neighborhood east of the proposed expansion area in Alternatives 2 and 4, and at the 

Livernois-Junction Yard near residential areas such as along Cabot, Lawndale, and Trenton 

Avenues, and the area south of Dix Avenue at the central/east ends of the terminal. Nonetheless, 

it is noted that lighting would have increased at each terminal under Alternatives 2, 3 and 4. 
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Preferred Alternative 

Lighting will increase with the Preferred Alternative for security purposes. To the extent 

practical, lighting in the area of Cabot, Lawndale, and Trenton Avenues, along east Kronk and 

the area south of Dix Avenue at the central/east end of the terminal will be directional to 

minimize glare in these residential areas. There is already street lighting in each of these 

areas. 

4.21 Soils 

The former clay pits near the Livernois-Junction Yard will need to be tested to determine what 

type of soil/materials were used to infill the area. The potential for the existence of contaminated 

materials causes this need, as defined in Section 4.16. 

Preferred Alternative 

The above conclusion remains true for the Preferred Alternative. 

4.22 Construction Permits 

Michigan Department of Environmental Quality permits would have been required for Action 

Alternatives during the design phase for use of wetlands and stormwater discharges. The 

construction phasing will dictate the number of permits required. See Section 5.4 for a list of 

required permits. 

Preferred Alternative 

The above conclusion remains true for the Preferred Alternative. 

4.23 Energy 

Energy would be used to construct an Action Alternative. Fuel savings should be realized in the 

long term due to improved efficiencies in the movement of freight on rail to, from, and within 

intermodal yards. There will also be improved efficiencies in the movement of freight on trucks to 

and from intermodal yards adding to fuel savings, consistent with the reduction of vehicle miles of 

travel in shifting freight from truck to rail (each intermodal rail car is the equivalent of three trucks). 

Preferred Alternative 

The above conclusion remains true for the Preferred Alternative. 

4.24 Implementation Cost 

Estimated construction costs (in 2004 dollars) are $170 million for Alternative 2, $458 million for 

Alternative 3, and $436 million for Alternative 4. Right-of-way/property-related costs are 

estimated to be $98 million for Alternative 2, $125 million for Alternative 3, and $115 million for 

Alternative 4. Total estimated project implementation costs are $267 million for Alternative 2, 

$583 million for Alternative 3, and $551 million for Alternative 4. These costs will be borne by 

both government and the railroads. 
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Preferred Alternative 

Estimated construction costs for the Preferred Alternative (in 2008 dollars) are $395 million. 

Community mitigation/enhancement costs add another $11 million. Another $123 million is 

required for right-of-way and relocation. These costs will be borne by both government and 

the railroads. The total project cost is $529 million. Accounting for the years in which the 

dollars will actually be spent means that inflation adds another $121 million for a year of 

expenditure project cost of $650 million (at an estimated confidence level of 70%). 

4.25 The Relationship Between Local Short-Term Uses of the 

Environment and the Maintenance and Enhancement of LongTerm Productivity 

This project is a result of local and regional, as well as statewide comprehensive planning. Present 

and future freight needs were considered and are reflected in the Preferred Alternative that address 

the proposed project’s purpose and need. It is concluded that the local short-term impacts and use 

of resources by the Preferred Alternative51 are consistent with the maintenance and enhancement of 

long-term productivity for both the local (Southeast Michigan) area and the State of Michigan. 

Project construction will result in increased use of a more efficient mode – rail – over the long term, 

compared to the No Action Alternative. 

Preferred Alternative 

The above conclusion remains true for the Preferred Alternative. 

4.26 Irreversible and Irretrievable Commitments of Resources Which 

Would be Involved in the Proposed Action

To date, the DIFT studies have cost $7.5 million. There would be no additional cost if no 

government action is taken. Implementation of the Preferred Alternative involves a commitment 

of a range of natural, physical, human, and fiscal resources. Land used for expansion/

construction of a proposed terminal is an irreversible commitment of land. 

Considerable amounts of fossil fuels, labor, and construction materials such as cement, aggregate, 

and bituminous material will be expended for this project. Additionally, large amounts of labor 

and natural resources will be used in the fabrication and preparation of construction materials. 

Their use will not have an adverse effect upon the supply. 

Construction of the Preferred Alternative will require a substantial expenditure of state, federal, 

local and private funds. The commitment of these resources will result in an improved freight 

transportation system, providing improved efficiency, safety, and savings in time. These are 

expected to outweigh the commitment of these resources. 

Preferred Alternative 

The above conclusions remain true for the Preferred Alternative. 

 

51 In the context of a major transportation improvement, short-term use of the environment means use of resources such 

as fossil fuels, building materials, petroleum, and the like, for a few years, not for an indefinite period.