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

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•
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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Figure 4-26b 

Integration of Commodity Flow and REMI Modeling Processes 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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• Property taxes lost due to public acquisition of property; 

• Equipment costs; 

• Operations and maintenance costs; and, 

• Additional railroad terminal revenues related to increased intermodal business. 

 

The sources of the input data are summarized as follows: 

• The total investments to implement, equip, operate and maintain each Action Alternative 

range from $326.4 million for Alternative 2 to $697.7 million for Alternative 3 (Table 

4-17). These costs were developed in consultation with railroad operators and project 

engineers. 

• Revenue generated by intermodal business was calculated based on the number of 

additional lifts forecast in each alternative. The revenue reflects the competitiveness of 

the alternatives, i.e., Alternatives 3 and 4 have a greater geographical reach than 

Alternative 2 and that improved position is reflected in the revenue. 

• Businesses subjected to relocation were interviewed, to the extent possible, and available 

land within the various study zones was inventoried to establish the likely destination of 

relocated businesses and their associated jobs. The interviews established that no businesses 

would cease operations or relocate outside the Southeast Michigan region, and that most 

businesses would relocate as close as possible to their current location. Therefore, while 

some jobs would be relocated, no jobs would be lost to the region in any alternative. 

• An inventory indicated that sufficient for-sale and available rental housing stock existed 

in the zone in which residential property would be acquired, ensuring that displaced 

households had ample opportunity to relocate within the area. 

• Property tax records were used to determine the amount of property tax revenue that 

would be lost due to public acquisition of property. 

Table 4-17 

Construction Costs by Alternativea

(millions of 2004 dollars) 

Category Alt. 1 

Total 

Alt. 2 

Total 

Alt. 3 

Total 

Alt. 4 

Total 

 

 Construction Costs $10.5 $169.7 $457.7 $436.0 

 Land Acquisition/ 

Relocation/Remediation Costs $0.0 $97.5 $125.0 $114.9 

 Equipment Investment $0.0 $50.0 $100.0 $100.0 

 Operations & Maintenance Costs $0.0 $9.2 $15.0 $17.1 

 All Costs $10.5 $326.4 $697.7 $668.0 a

Represents railroad or government contribution to total cost at application of REMI Model at June 1, 2004. 

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

Jobs 

Table 4-18 compares the number of jobs relocated from each local terminal area with the number 

of net jobs resulting from each alternative in the year 2025. “Net Jobs Gained” reflects the actual 

number of additional jobs gained, while accounting for the jobs removed as a result of business 

relocations. While some jobs are relocated from their original local terminal area to a different 

area, no jobs are lost to the region as a result of relocation. 

Table 4-18 

Jobs Relocateda

 and Net Jobs Gainedb 

ALT 1 – 2025 ALT 2 – 2025 ALT 3 – 2025 ALT 4 - 2025 

 Analysis Area Jobs 

Relocated 

from Areaa

 

Net Jobs 

Gainedb

Jobs 

Relocated 

from Areaa

Net Jobs 

Gainedb

Jobs 

Relocated 

from Areaa

Net Jobs 

Gainedb

Jobs 

Relocated 

from Areaa

Net Jobs 

Gainedb

Liv Jct/CP Exp 0 194 0 786 286 2,245 275 1,956

CP/Oak 0 130 596 187 0 513 0 496

CN/Moterm 0 88 0 390 0 495 0 695

Detroit Plus 0 459 411 1,764 196 3,780 190 3,658

Wayne Plus 0 564 224 2,521 104 4,844 100 4,705

Michigan 0 1,029 0 4,950 0 9,050 0 8,819 aIncludes jobs relocated to outside their original local terminal area. bNet jobs gained in study area, deducting for jobs relocated to outside their original local terminal area. 

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

The jobs presented on Table 4-18 include direct, indirect, and induced jobs. Direct jobs are those 

directly associated with the intermodal facility. Jobs such as suppliers, service providers, and 

support services to the intermodal business are considered “indirect” jobs. Induced jobs are those 

created as a result of the presence of direct and indirect wage earners requiring services in the 

local economy. Induced jobs include restaurant workers, teachers, and retail clerks needed to 

serve the direct and indirect jobs. 

Table 4-18 reveals job creation for each alternative. Alternative 1: No Action is, in 2025, 

associated with over 1,000 additional jobs in the local and regional economies compared to 

today’s conditions. Alternative 2: Improve/Expand Existing Terminals is associated with about 

5,000 new jobs, or about 4,000 more than forecast for the No Action Alternative. Alternatives 3 

and 4, which in 2025 are associated with the largest increases in intermodal activity and 

investment, stimulate the greatest amount of total job growth, creating approximately 9,000 new 

jobs, which is about 8,000 more jobs than under the No Action Alternative. For the City of 

Detroit, the net jobs gain ranges from about 1,760 to almost 4,000 depending on Action 

Alternative. New jobs occur in all sectors of the economy and represent a diverse range of skill 

and wage levels. The average wage for all new jobs created is forecast to be about $40,000 per 

year. 
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In addition to permanent jobs, employment opportunities will also be created during the 

construction period of each alternative (Figure 4-27). Overall, Alternatives 3 and 4 would create 

more construction jobs over a longer period than Alternative 2 because of the increased 

investment in the former alternatives. No major construction, beyond maintenance, is expected 

under Alternative 1. 

Government Revenues 

While state and local government revenues are predominantly comprised of taxes, they also 

include all fees, charges, and other sources of income that all government entities at the local and 

state levels collect. The Policy InsightTM model is calibrated to reflect the most recent 

government revenue data at the state and local levels and creates a control forecast that can be 

compared to the effects of each DIFT alternative. 

Alternatives 2 through 4 involve at least some acquisition that removes properties from the tax 

rolls as the acquired property would be owned by the state (MDOT), which does not pay taxes. 

Table 4-19 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,” produces more new local revenues than the property tax revenue 

that is lost. 

Figure 4-28: Construction Employment 

Associated with DIFT Project 

0

100

200

300

400

500

600

ALT 2 132 377 146 184 253 222 140 0 0 0

ALT 3 130 180 354 550 436 472 360 327 142 24

ALT 4 125 192 350 545 434 399 407 253 116 33

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

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

Figure 4-27: Construction Employment Associated 

with DIFT Project 
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Table 4-19 

Terminal Area Property Tax Reduction 

and Local Revenue Gained a 

 ALT 1 ALT 2 ALT 3 ALT 4 

 

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 27.09 -17.33 49.86 -14.37 172.24 -13.80 177.36 

All Revenues, State and Localc N/A 154.88 N/A 667.80 N/A 1,065.62 N/A 1,108.04 a

Property tax figures are cumulative 2006 (the first year of expected implementation) to 2025, expressed in 2004 U.S. dollars (USD), 

in millions. Government Revenue Gain presented in Net Present Value, discounted at 2%, expressed as 2004 USD in millions. 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 revenues collected in the State of Michigan by any state or local entity. 

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

4.6 Land Use and Zoning 

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. 
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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.” 

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 multi-modal 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.” 

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. 
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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 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. 
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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 while rezoning would be required 

of about 10 acres, out of the 265-acre expansion area, which is now residential. 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. 

4.7 Farmland/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). No Michigan Public Act 451, Part 361 (The 

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

4.8 Air Quality Analysis 

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. 
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• 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. 

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 4-20). 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 4-20 

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. 
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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 

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. 
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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-

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

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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 4-28a), and b) 30 mph 

(Figure 4-28b) 

• Passenger vehicles and air toxic pollutants at: a) 10 mph (Figure 4-28c), and b) 30 mph 

(Figure 4-28d) 

• Trucks and NAAQS pollutants at: a) 10 mph (Figure 4-28e), and b) 30 mph (Figure 4-

28f) 

• Trucks and air toxic pollutants at: a) 10 mph (Figure 4-28g), and b) 30 mph (Figure 4-

28h) 

Monitoring Data 

Air pollution monitoring station data collected for the terminal areas are displayed in Figures 4-29 

through 4-36. 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 4-30 top), but 8-hour average values have risen over the last several years and 

are above the standard (Figure 4-30 bottom). The pattern is similar at the CP/Oak and 

CN/Moterm terminal areas (as measured at the Oak Park Drive monitoring station, Figure 4-35). 

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 4-36 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 4-32 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. 
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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. 

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 4-37, 4-38, 4-39, and 4-40). 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. 
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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. 

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 4-37 through 4-40. 

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 
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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. 

Data presented here are totals for each terminal for each alternative (Table 4-21). 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 4-21a. 
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Table 4-21 

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 acetaldehydSource: The Corradino Group of Michigan, Inc. 

Table 4-21a 

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 acetaldehydSource: The Corradino Group of Michigan, Inc. 
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Further information regarding the sources of the various pollutants at the terminals is presented in 

Table 4-21b. 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. 

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 (Figure 4-41). 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. 
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Table 4-21b 

Terminal Burden by Activity Type – Annual Tons 

CO HC NOx PM10 PM2.5 VOCs DPM BENZ BUTA FOR

2004 Automobiles/Trucks 29.7 2.8 17.7 0.5 0.4 2.8 0.5 0.07 0.01 0.1Container Handling 21.7 5.0 77.1 7.5 7.3 5.0 7.3 0.10 0.01 0.76 Locomotives 5.8 2.1 38.9 1.5 1.4 2.2 1.4 0.01 0.01 0.09  Road/Yard Dust 0.0 0.0 0.0 201.4 44.8 0.0 0.0 0.00 0.00 0.00 Totals 57.2 9.9 133.7 210.9 53.9 10.0 9.2 0.18 0.03 0.96 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 0.05 Container Handling 2.6 2.7 5.5 0.4 0.4 2.7 0.5 0.05 0.01 0.40 Locomotives 8.8 1.8 34.3 1.2 1.1 1.8 1.1 0.02 0.01 0.14  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 0.59 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 0.09 Container Handling 4.2 4.5 9.2 0.7 0.7 4.5 0.7 0.09 0.01 0.67 Locomotives 10.9 2.2 42.4 1.4 1.4 2.3 1.4 0.02 0.01 0.17  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 0.93 Alt. 3 - 2025 Consolidate Automobiles/Trucks 1.8 1.3 2.4 0.4 0.3 1.2 0.2 0.01 0.01 0.10 Container Handling 4.8 5.1 10.5 0.9 0.8 5.1 0.8 0.11 0.01 0.77 Locomotives 8.6 1.7 33.6 1.1 1.1 1.8 1.1 0.01 0.01 0.13  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 1.00 Alt. 4 - 2025 Composite Automobiles/Trucks 1.68 1.1 2.1 0.30 0.23 1.08 0.15 0.01 0.01 0.09 Container Handling 4.71 5.1 10.3 0.90 0.78 5.08 0.78 0.10 0.01 0.76 Locomotives 8.5 1.7 33.0 1.12 1.1 1.7 1.1 0.0 0.0 0.1  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 0.98 

Note: VOCs are volatile organic compounds, DPM is diesel particulate mater, BENZ is benzene, BUTA is 1,3, butadiene, FORM is formaldehyde, ACET is acetaldehydSource: The Corradino Group of Michigan, Inc. 
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Table 4-22 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. 

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.13 

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. 

 

13 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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Table 4-22 

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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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 4-21a. 

4.8.6 CO Hotspot 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 4-23). Sensitive receptors are locations 

where humans might be expected to be present. 

Table 4-23 

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. 
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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 

4-23 in all years under all scenarios are better. 

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 4-42 

through 4-47). 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. 

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. 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 would 

occur 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: 
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• 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. 

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.14 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 24 under Alternative 3. The 20-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.15 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 4-24). Mitigation must also be considered if a project results in a substantial 

 

14 Transit Noise and Vibration Impact Assessment, Federal Transit Administration, April 1995. 15 Projections in Amtrak and commuter rail operations from Downtown Detroit to Metro Airport, SEMCOG, 2001. 
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increase (10 dBA or more) in noise levels. All sites will be 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 4-24, abatement has been considered at each 

sensitive location listed in Table 4-25 for each alternative. 

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. 

Table 4-24 

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.

Alternative 1 – No Action 

Alternative 1 would not include any mitigation, as this is 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 4-48). 

• 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 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. 
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Table 4-25 

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 Comm

Ra

2004 6 0 18 4 28 0 0 26 4 30 No receptors 6 0 Alt. 1 2025 18 14 22 4 58 0 0 31 4 35 No receptors 18 0 Alt. 2 2025 18 14 22 4 58 0 0 31 4 35 No receptors 18 0 Alt. 3 2025 18 14 22 20 74 0 0 31 0 31 No receptors 18 0 Alt. 4 2025 18 14 22 12 66 0 0 31 0 31 No receptors 18 0 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 - AbaAlt. 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 no feasible No receptors 69 dBA - AbaLdn 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 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. c 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 in the future u

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 purpose

Leq noise 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 levSource: The Corradino Group of Michigan, Inc. 
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• 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 4-49). 

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 barrier 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 barrier 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 4-48). The wall would be positioned between 

the edge of the rail yard and John Kronk. If this section of the barrier wall that affords 

noise abatement to this residential area were evaluated with respect to Michigan’s Noise 

Policy, it would be considered reasonable because the cost per dwelling unit is estimated 

to be $22,400, compared to the criterion $34,772 (2004 dollars). 

• CP/Expressway Terminal – Alternative 2 calls for terminal expansion east of I-75 and south 

of Michigan Avenue. The United Community Hospital is 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, will not be adversely affected by noise levels from intermodal 

activity. 

• CP/Oak Terminal – Alternative 2 calls for intermodal terminal expansion to the north. 

There are no sensitive receptors within 1000 feet of the terminal. Nevertheless, a barrier 

wall will be created along the northern edge of the property for security purposes, if the 

terminal were expanded. 
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• CN/Moterm Terminal – Alternative 2 calls 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 be 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 barrier wall is included in the project’s design for security purposes, 

if the terminal were expanded (refer to Figure 4-49). The wall would be built as described 

above so that the noise criterion is no longer exceeded. 

Alternative 2 will reduce rail noise except for one location where horn blowing will increase. 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 will increase from one to four movements daily (as total trains 

increase from 11 to 27), if the CN/Moterm terminal were 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 expand the Livernois-Junction Yard area. There would be increased 

intermodal traffic, but property acquisition in the area would remove a number of homes, and a 

barrier wall is planned along the north side of the expanded rail yard for security purposes. It will 

also serve to protect from noise the remaining homes in the Cabot/Trenton area and the 

Martin/Livernois area. If this section of the barrier wall that affords noise abatement to the 

Martin to Livernois Avenue residential area was evaluated with respect to Michigan’s Noise 

Policy, it would qualify for noise mitigation funding. Horn blowing at Lonyo and Central 

Avenues would cease. 

Alternative 4 would likewise have impacts that would be 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 cease. 

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 be no mitigation. Under all Action Alternatives, roadway noise 

would not increase 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. 
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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 4-50), 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 4-51): 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 4-51). 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 level16 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 

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 4-25. 

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. 

 

16 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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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. 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 and endangered 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). 

4.11 Waterways/Water Quality/Floodplains 

4.11.1 Waterways 

No waterways or waterbodies including lakes, ponds, perennial streams, and intermittent streams 

would be affected by any alternative. 

4.11.2 Water Quality 

All of the Action Alternatives will have minimal to no 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 will 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 will continue to flow to the combined sewer system. Because 

the unpaved portions of existing terminals would remain 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) will be directed to an engineered 

on-site collection system first, using oversized pipes and swales to ensure future flow rates are not 

increased. Because of the combined sewer system, all water will be treated before it outfalls to 

the Detroit River. 

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 
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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 Erie. 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 is expected to be insignificant for any Action Alternative. 

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/drains) in the areas of the Action Alternatives. The areas are on 

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 

floodway fringe (i.e., 100-year floodplain) affected. The Action Alternatives will not result in a 

loss in natural and beneficial floodplain values. 

4.12 Wetlands

Fieldwork to identify wetlands was performed consistent with state and federal guidance at the 

intermodal terminals in the spring of 2002, and the spring and summer of 2003 and 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. 
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4.12.1 Alternative 1: No Action 

Under the No Action Alternative there would be 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 

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. Minor vegetated surfaces 

consisted of turfgrass (Poa spp.) with assorted weed species such as common plantain (Plantago 

major), and dandelion (Taraxacum officinale). A small patch of giant 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, several eastern cottontail 

rabbits, and a Ring-neck pheasant. Field investigation also revealed some vegetation in a low 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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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 be 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, apply 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, apply here. 

4.13 Historic and Archaeological Resources 

The National Register of Historic Places has established criteria for determining 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 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 aboveground 

resources. 
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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.17 

Each of the Action Alternatives would have an “adverse effect” on 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 adversely affect an historic property, mitigation measures must be developed 

should any of these alternatives be advanced after the public hearing. These measures are to be 

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 archaeologic resources at 

any intermodal terminal for any alternative. However, the SHPO has 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). 

4.13.1 Alternative 1: No Action 

Under the No Action Alternative, there would be no government-sponsored effect on any aboveground historical resources or on any archaeological resources. 

 

17 “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.
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4.13.2 Alternative 2: Improve/Expand Existing Terminals

Livernois-Junction Yard 

Implementation of Alternative 2 at the Livernois-Junction Yard will not have 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. 

Nevertheless, two potential sites will undergo further investigation prior to any construction if 

Alternative 3 is determined to be the preferred alternative. 

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 4-26 and Figure 4-52). One of these 

three that would be 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). 

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 be constructed on 

the bridge deck structure causing an adverse effect. Hence, a Memorandum of Agreement 

(MOA) will be necessary and will be included in the FEIS, if Alternative 2 becomes the preferred 

alternative. It will stipulate conditions that mitigate impacts to the property adversely affected. 

Section 6 of this DEIS provides a Draft Section 4(f) Evaluation of the property that would 

experience an adverse effect and that would be covered in the MOA. 

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. 
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Table 4-26 

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 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. 

Area needed for Alternatives 3 and 

4 would require this property. 

Adverse effect. 

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 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 Liv-Jct 11 House 6332 John Kronk Historic home No property to be taken. 

Determination of adverse effect not 

yet made. 

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 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 nineteenth 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 Irishdominated 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 

will be taken at these sites and project implementation will not represent 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 will not be adversely affected by facility 

expansion. Early twentieth-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 ft (1.5 m) to 8 ft (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, will 

not constitute an adverse affect upon area archaeological resources. 

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 will not have an adverse effect upon 

National Register-eligible aboveground 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 will 

not represent an adverse effect upon area archaeological resources. 
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CN/Moterm Terminal 

A review of previously recorded aboveground 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 4-26) (Figure 4-53). 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 will be 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 archaeologic 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 archaeologic remains within the proposed expansion 

area is extremely low. 

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 are considered potentially eligible for listing on the National Register at the 

Livernois-Junction Yard area under the Consolidation Alternative (Table 4-26 and Figure 4-54). 
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Four of the eligible sites are expected to suffer an adverse effect from the project – the Spranger 

Wire Wheel Company building, the Federal Screw Works Factory, the Markey House, and the 

Tomms House. Additional information is needed on one of the other sites (the house at 6332 

John Kronk) to determine if there will be an adverse effect. Nevertheless, due to the 

determination of an adverse effect on the four properties cited above, a Memorandum of 

Agreement (MOA) will be necessary and will be included in the FEIS, if Alternative 3 is the 

preferred alternative. It will stipulate conditions that mitigate impacts to the property adversely 

affected. Section 6 of this DEIS provides a Draft Section 4(f) Evaluation of the property that 

would experience an adverse effect and that would be covered in the MOA. Potentially eligible 

sites in the APE are discussed next. 

The following are 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 likely eligible for the National 

Register. Alternative 3 will require the demolition of this property resulting in an adverse 

effect. 

• The Federal Screw Works factory at 3301-3401 Martin Street is likely eligible for the 

National Register. Alternative 3 will require the demolition of this property resulting in 

an adverse effect. 

• The Rickenbacker Motor Company building/Springfield Body Corporation that runs 

along Cabot is likely 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 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. No property 

will be 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 will be included in the FEIS, if 

Alternative 3 is chosen as the preferred alternative. 

• The Tomms House at 3434 Martin Street. There will be 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 will be a visual adverse effect due to the 

removal of the Federal Screw Works Factory across the street. 

The following are also within the APE but outside of the project footprint. No property will be 

taken from these sites and implementing Alternative 3 will not represent 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. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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An archaeological survey was performed in the APE for the 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 has agreed with the assessment that field investigations at 

two archaeological sites should be conducted prior to construction, if Alternative 3 is chosen as 

the preferred alternative. 

4.13.4 Alternative 4: The Composite Option

The Composite Alternative proposes 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 are the same as those at CN/Moterm under 

Alternative 2 and smaller at Livernois-Junction Yard than under Alternative 3. No property 

would be taken from any of the eligible historic sites at the Fairgrounds. At the LivernoisJunction Yard the National Register eligible Spranger Wire Wheel Company is required for 

Alternative 4 resulting in an adverse effect. However, unlike Alternative 3, there would not be an 

adverse effect on the Federal Screw Works Factory, the Markey House, and the Tomms House. 

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 4-10a-d and listed in Table 4-9a-d along with other community facilities. The portion of 

the State Fairgrounds proposed for use under Alternatives 2 and 4 is considered to be public 

recreational land and so impacts to it are covered in Section 6 of the DEIS. 

4.14.1 Alternative 1: No Action 

Under the No Action Alternative no parkland would be directly or indirectly affected. 

4.14.2 Alternative 2: Improve/Expand Existing Terminals

Under the Improve/Expand Alternative, the only recreation land affected would be approximately 

35 acres of the State Fairgrounds (see Section 6 [the Draft 4(4) Evaluation] of this DEIS). 

Livernois-Junction Yard 

• Wilson Playground on Lonyo is to the north of the expansion area. It will not be directly 

or indirectly affected by the proposed terminal expansion, including noise. 

• Loverix Park is south of the expansion area. It will not be directly or indirectly affected 

by the proposed terminal expansion, including noise. 

• Patton Memorial Park is to the south of the expansion area. It will not be directly or 

indirectly affected by the proposed terminal expansion, including noise. 

• Dearborn City Park is west of the expansion area. It will not be directly or indirectly 

affected by the proposed terminal expansion, including noise. 
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CP/Expressway Terminal 

• Roosevelt Park is to the northeast of the expansion area. It will not be directly or 

indirectly affected by the proposed terminal expansion, including noise. 

• Macomb Park is directly north of the expansion area. It will not be directly or indirectly 

affected by the proposed terminal expansion, including noise. 

CP/Oak Terminal 

No parkland will be 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 automotive vehicle storage, would be 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 will not be 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, apply 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, apply here.

4.15 Visual Conditions 

4.15.1 Alternative 1: No Action 

Under the No Action Alternative no changes to visual conditions would occur. Abandoned 

properties, salvage yards, and industrial facilities would remain without improvements to the 

properties or landscaped buffer areas. 

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 a barrier wall for security which would screen the terminal (refer to Figures 3-3, 

3-4 and 3-5). Nevertheless, abandoned properties, salvage yards, and industrial facilities would 

remain immediately adjacent to the terminal.
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CP/Expressway Terminal 

Under Alternative 2, a City of Detroit Public Works facility, industrial land, and existing rail 

facilities would be used to expand the CP/Expressway terminal. Visual conditions would remain 

similar to existing conditions.

CP/Oak Terminal 

Under Alternative 2, industrial land and existing rail facilities would be used for the CP/Oak 

terminal. A barrier wall for security would be built between the yard and the area to the north, 

which is primarily industrial. This wall would shield 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 be 

converted to terminal use. A barrier wall for security would be built on the east side of the 

mainline tracks south of Eight Mile Road. This would shield 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 barrier wall would 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 plans on the terminal’s north boundary. These features would 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 would be removed and new 

intermodal facilities would be built in their place. Figure 4-55 illustrates several areas that would 

be visually improved under the Consolidation alternative. Figure 4-56 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 will be essentially the 

same as those for the facilities as described above for Alternative 3 except that the north boundary 

would be different. The conditions expected at the CN/Moterm terminal for Alternative 4 will be 

those for the facilities as described above for Alternative 2. 

4.16 Contaminated Sites 

A Project Area Contamination Survey (PACS), or Level 1 environmental assessment, was 

conducted for the DIFT project.18 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 is no 

development expected outside the rail terminal under the No Action Alternative, it is not the 

subject of the PACS. 

 

18 “Project Area Contamination Survey,” The Corradino Group, August 2004. 
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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 4-55 

Areas Around LivernoisJunction Yard with 

Opportunities for Visual 

Enhancements

Source: The Corradino Group of Michigan, Inc. 

Terminal 

Terminal 

Terminal 
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Figure 4-56 

Triple Crown Terminal in 

Melvindale, Michigan 

Source: The Corradino Group of Michigan, Inc. 
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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 be 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. Nevertheless, 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 4-27 and Figure 1-16). 

Table 4-27 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 are those specified in 

ASTM E1527-00 (Standard Practice for Environmental Site Assessments: Phase I Environmental 

Site Assessment Process). 

The PACS found: no CERCLIS NPL sites; two CERCLIS non-NPL 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 the interviews and research conducted, 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 soil borings to conclusively characterize their environmental condition. 
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Table 4-27 

Contamination Summary 

Record

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

LUST 

3/4 Liv-Jct 1 MNP Steel Service and Warehouse 3401 Martin Detroit X-C 3/4 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 Liv-Jct 4 Fontana Forest Products 7175 Clayton Detroit 3/4 Liv-Jct 5 Red's Towing Service 7301 Clayton Detroit 

2/3/4 Liv-Jct 6 Advance Auto Glass and Parts 3600 Central Detroit 2/3/4 Liv-Jct 7 Herman Brothers Pet Products/Trager Research & Manufacturing 3650 Central Detroit 

3/4 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 Liv-Jct 10 Michigan Wholesale & Repair 3700 Central Detroit 3/4 Liv-Jct 11 Lacaria Concrete Construction 3720 Central Detroit 

2/3/4 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 Liv-Jct 18 Dix Scrap Iron & Metal Co 3890 Lonyo Detroit 3/4 Liv-Jct 19 Big B's Auto 3800 Lonyo Detroit 3/4 Liv-Jct 20 Spartan Industrial 3896,3930-34 Lonyo Detroit X-C 3/4 Liv-Jct 21 Spartan Industrial Warehouse 8350 John Kronk Detroit X-C 3/4 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. LUST - Leaking underground storage tank; X-C = Closed cb - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. UST - Underground storage tank. c - Baseline Environmental Assessment has been conducted. RCRIS - Resource Conservation and Recovery Information d - Michigan State Priority List site. CERCLIS - Comprehensive Environmental Response, Come - Ratings are: L = Low, M = Medium, H = High Information System. 

NPL - National Priority Listing. 
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Table 4-27 (continued) 

Contamination Summary 

Rec

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

3/4 Liv-Jct 25 Motor City Corporation 3801 Trenton Detroit 3/4 Liv-Jct 26 S L Cabot, LLC 4157 Cabot Detroit Xc X3/4 Liv-Jct 27 Ferrous Processing Corp 9100 J Kronk Detroit 3/4 Liv-Jct 28 Williams Detroit-Alison 4000 Stecker Dearborn X3/4 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 X3/4 Liv-Jct 32 Truck City, Inc. 4121 Stecker Dearborn 3/4 Liv-Jct 33 MCI Telecommunications Corp. 4401 Stecker Dearborn X3/4 Liv-Jct 34 Jebco Investments LC-Property 2 4401 Stecker Dearborn X3/4 Liv-Jct 35 K & R Express 4601 Stecker Dearborn X3/4 Liv-Jct 36 TIP Trailer Leasing 10000 Southern Dearborn 3/4 Liv-Jct 37 Advance Pool 10400 Southern Dearborn X3/4 Liv-Jct 38 Nour's Investment Company 4210-20 Wyoming Dearborn X3/4 Liv-Jct 39 GLS Leasco, Inc. 4410 Wyoming Dearborn 3/4 Liv-Jct 40 Central Transport, Inc. 4440 Wyoming Dearborn X X X3/4 Liv-Jct 41 Jouney, Inc. Steel Service/Seng Tire 4800 Wyoming Dearborn 3/4 Liv-Jct 42 Action Tire Service Co 3969 Wyoming Dearborn 

2f/3/4 Liv-Jct 43 Ford Motor Vulcan Plant 3900 Wyoming Dearborn 2f/3/4 Liv-Jct 44 Cummins Michigan 3760 Wyoming Dearborn X2f/3/4 Liv-Jct 45 Wyoming Self-service 3740 Wyoming Dearborn 2f/3/4 Liv-Jct 46 Vacant Freight Terminal 10100 Mercier Dearborn 2f/3/4 Liv-Jct 47 Vacant Freight Terminal 9900 Mercier Dearborn X

3/4 Liv-Jct 48 Boulevard & Trumbull Inv., Inc. 7700 Dixg Detroit X X

a - Other potential contamination site identified by reconnaissance and/or other records. LUST - Leaking underground storage tank; X-b - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. UST - Underground storage tank. c - Baseline Environmental Assessment has been conducted. RCRIS - Resource Conservation and Recovery d - Michigan State Priority List site. 

CERCLIS - Comprehensive Environmental ReLiability e - Ratings are: L = Low, M = Medium, H = High Information System. f - These properties would be required under Alternative 2 Option B, but not needed under Alternative 2 Options A and 

C. NPL - National Priority Listing. g - This site also includes 7800, 7840, 7904 and 7950 Dix. 
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Table 4-27 (continued) 

Contamination Summary 

R

Alt. Terminal SID No. Site Name Address or Location City 

CERCLIS (non NPL) 

MI Contam. Sites 

2/3/4 Liv-Jct 49 Lafayette Recycling 7700,7730,7750 Dix Detroit 

3/4 Liv-Jct 50 M. Dick & S.F. Corbell 2881 Centralh Detroit 3/4 Liv-Jct 51 Central Avenue Properties LLC 2921, 2951 Central Detroit X 3/4 Liv-Jct 52 Thomas Adams, Jr. 2971,81,91 Central Detroit 

2/3/4 Liv-Jct 53 Chester Herman Warehouse 3005,11 21 Central Detroit 2/3/4 Liv-Jct 54 Central Auto Parts 3022 Central/7276 Dix Detroit 

3/4 Liv-Jct 55 Central Auto Clinic 2910,2930 Central Detroit 3/4 Liv-Jct 56 S. Corbell Property 2880-96 Central Detroit 3/4 Liv-Jct 57 Vacant Commercial Lots 2803-2889 Stair Detroit 3/4 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 Liv-Jct 67 Detroit Brake Parcel 5030 Military Detroit 

a - Other potential contamination site identified by reconnaissance and/or other records. LUST - Leaking underground storage tankb - Delisted CERCLIS NFRAP (No Further Remedial Action Planned) site. UST - Underground storage tank. c - Baseline Environmental Assessment has been conducted. RCRIS - Resource Conservation and Recod - Michigan State Priority List site. CERCLIS - Comprehensive Environmente - Ratings are: L = Low, M = Medium, H = High Information System. f - These properties would be required under Alternative 2 Option B, but not needed under Alternative 2 Options A and C. NPL - National Priority Listing. g - This site also includes 7800, 7840, 7904 and 7950 Dix.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. 

Source: The Corradino Group of Michigan, Inc. 
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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) are 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 may need 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 be 

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 is 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 

reportedly used as a landfill, will require 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 that was conducted for the DIFT Project consisted of soil borings in public 

rights-of-way 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). They will 

be needed if the project moves forward. 

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 
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Utility Plan will also be prepared to ensure no deep utility cuts will impact and/or spread existing 

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 father 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 direct and indirect effects are presented in Section 4.3, particularly 4.3.2 and Table 4-14. 

The cumulative effects are summarized in Table 4-15, they are elaborated upon here. 

4.17.1 Cumulative Effects 

The most significant past, present and foreseeable future sections that affect each of the terminal 

areas are summarized here: 

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. 

Nevertheless, ongoing revitalization in the area includes: 
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• 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 

• 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: 
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“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. 

“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. 
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“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 

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.” 
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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). 

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.”19

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. Nevertheless, 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). 

 

19 Ferndale City Directory. R.L. Polk and Company, Detroit. 1955. 
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• 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. 

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. 
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“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 

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 
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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. 

“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.” 

Based on the past, present and 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 4-15). 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, there are no negative congestion 
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effects expected either on major arteries or local neighborhood streets unless the 

proposed Jobs Tunnel project were to be implemented where the CP/Expressway 

terminal is located. That project proposes to convert two existing rail tunnels to trucks 

and build a third, more modern terminal for rail. The proposal is in the discussion phase. 

Public information on details is limited. 

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 be accelerated 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. 

• Air Quality: Increased development will likely increase local pollution. But, results 

of the analysis of direct/indirect air quality impacts indicates that such increases will 

not cause standards to be violated if the development is properly located. 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 may 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. 

• 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 
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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 

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 barrier walls 

that provide terminal security and reduce noise; by paving surfaces that are unpaved; by creating 

jobs which can be directed to 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 
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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. 

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 are part of the No Action Alternative and all Action Alternatives, as well. 

4.19 Terminal Security 

For all Action Alternatives, barrier 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 enhance these boundaries/access points include clear zones on both sides of fences, 

security lighting, locks, CCTV systems and signage. 
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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 barrier 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 will be determined at that time. 

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 will be affected by lighting at those terminals. Directional 

lighting will be 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. Nevertheless, it is noted that lighting will 

increase at each terminal under Alternatives 2, 3 and 4. 
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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. 

4.22 Construction Permits 

Michigan Department of Environmental Quality permits will be 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. 

4.23 Energy 

Energy will 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). 

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. 

4.25 The Relationship Between Local Short-Term Uses of the 

Environment and the Maintenance and Enhancement of 

 Long-Term 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 Action Alternatives that 

address the proposed project’s purpose and need. It is concluded that the local short-term impacts 

and use of resources by the Action Alternatives are consistent with the maintenance and 

enhancement of long-term productivity for both the local (Southeast Michigan) area and the State 

of Michigan. 

4.26 Irreversible and Irretrievable Commitments of Resources Which 

Would be Involved in the Proposed Action

Implementation of each Action 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. 
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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. 

However, these materials are not in short supply, and their use will not have an adverse effect 

upon continued availability of these resources. 

Construction of each Action 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.