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

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SECTION 5 

MITIGATION OF IMPACTS 

The goal of mitigative measures is to preserve, to the greatest extent possible, existing 

neighborhoods, land use, and natural resources, while making improvements. Although some 

adverse impacts are unavoidable, MDOT, through environmental review, design, and 

construction processes, takes precautions to protect social and environmental systems. 

Construction activities that include the mitigation measures listed below are those currently 

contained in the MDOT 2003 “Standard Specifications for Construction.” 

Further agency coordination will continue through the design stage. Design plans will be 

reviewed by many MDOT personnel prior to contract letting in order to incorporate any 

additional social, economic, or environmental protection items. Construction sites will be 

reviewed to ensure that the mitigation measures proposed are carried out and to determine if 

additional protection is required. More mitigation measures may be developed if additional 

impacts are identified. Specific mitigation measures will be included in the design plans and 

permit applications. A Project Mitigation Summary “Green Sheet,” which identifies proposed 

project specific mitigation, is included at the end of Section 5. 

MDOT has agreed to participate along with FHWA in a set of enhancements in the 

community. These are also discussed at the end of Section 5 and at the end of the Green Sheet. 

5.1 Right-of-Way Acquisition and Relocation Impacts 

A Conceptual Stage Relocation Plan has been prepared and can be found in Appendix B. The 

following standard procedures will be followed. 

Compliance with State and Federal Laws – Acquisition and relocation assistance and services 

will be provided by MDOT in accordance and compliance with Act 31, Michigan P.A. 1970; 

Act 227, Michigan P.A. 1972; and the Federal Uniform Relocation Assistance and Real Property 

Acquisition Policies Act of 1970 as amended; Act 149, Michigan P.A. 1911, as amended; and, 

Act 87, Michigan P.A. 1980, as amended. MDOT will inform individuals, businesses and nonprofit organizations of the impact, if any, of the project on their property. Every effort will be 

made, through relocation assistance, to lessen the impact when it occurs. 

Residential – MDOT is required by statute to determine the availability of comparable, decent, 

safe and sanitary housing for eligible displaced individuals. MDOT has specific programs to 

implement the statutory and constitutional requirements of property acquisition and relocation of 

eligible displacees. Appropriate measures will be taken to ensure that all eligible displaced 

individuals are advised of the rights and benefits available and courses of action open to them. 

Business and Non-profit Organizations – MDOT is required by statute to offer relocation to 

displaced businesses and non-profit organizations (none in the case of the DIFT Preferred 

Alternative). MDOT has specific programs that will implement the statutory and constitutional 

requirements of property acquisition and relocation of eligible displacees. Appropriate measures 

will be taken to ensure that all eligible displaced businesses are advised of the rights, benefits, and 

courses of action open to them. Displaced businesses will be encouraged to relocate within the 

same community. 

Purchasing Property – MDOT will pay just compensation for fee purchase or easement use of 

property required for transportation purposes. “Just compensation” as defined by the courts is the 

payment of “fair market value” for the property rights acquired, plus allowable damages to any 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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remaining property. “Fair market value” is defined as the highest price estimated, in terms of 

money, the property would bring if offered for sale on the open market by a willing seller, with a 

reasonable time allowed to find a purchaser, buying with the knowledge of all the uses to which it 

is adapted, and for which it is capable of being used. 

Relocation Information – A booklet entitled “Your Rights and Benefits” detailing the relocation 

assistance program can be obtained from the Michigan Department of Transportation, Real Estate 

Division, P.O. Box 30050, Lansing, Michigan, 48909 or phone (517) 373-2200. It is online at: 

http://www.michigan.gov/mdot. Click on “Doing Business” (left side), then click on “Real 

Estate” (middle), then scroll to the bottom and click on “Your Rights and Benefits.” 

Property Acquisition Information – A booklet entitled “Public Roads & Private Property” 

detailing the purchase of private property can be obtained from the Michigan Department of 

Transportation, Real Estate Division, P.O. Box 30050, Lansing, Michigan, 48909 or phone (517) 

373-2200. It is online at: http://www.michigan.gov/mdot. Click on “Doing Business” (left side), 

then click on “Real Estate” (middle), then scroll to the bottom and click on “Public Roads, Private 

Property.” 

5.2 Walls for Terminal Security 

Walls for terminal security will be provided under the Preferred Alternative as an integral part 

of the proposed project. At the Livernois-Junction Yard, they will be along the north side of 

the terminal where there are residential sections. The walls will be defined in height to abate 

noise (per MDOT’s Noise Policy), as well as provide security. In the Kronk Street area, this 

involves a 1,700 foot wall 12 feet high. 

5.3 Soil Erosion and Sedimentation Control 

Accelerated sedimentation caused by project-related construction will be controlled before it 

enters a water body or leaves the highway right-of-way by the placement of temporary or 

permanent erosion and sedimentation control measures. MDOT has developed a series of 

standards for erosion control items to be included on design plans. The design plans will describe 

the erosion controls and their locations. Payment is made to the contractor for construction and 

maintenance of items used from this list of items specifically developed for the project. 

MDOT has on file with the Michigan Department of Environmental Quality (MDEQ) an 

approved operating erosion and sedimentation control program which ensures compliance with 

Part 91, Soil Erosion and Sedimentation Control of Act 451, as amended. MDOT has been 

designated an “Authorized Public Agency” and is self-regulated in its efforts to comply with Part 

91. However, MDEQ may inspect and enforce soil erosion and sedimentation control practices 

during construction to ensure that MDOT and the contractor are in compliance with Part 91 and 

the acceptable erosion and sedimentation control program. 

Work done by the railroads on their own property will require compliance with Act 451, Part 91, 

Soil Erosion & Sediment Control. 

The following is a list of the mitigation measures for this project to be carried out in accordance 

with permit requirements. Note that other measures may be determined necessary and added 

during the design phase. 

1. All construction operations will be confined to the project right-of-way limits or acquired 

easements. 
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2. Areas disturbed by construction activities will be stabilized and vegetated as soon as 

possible during the construction period in order to control erosion. 

3. Special attention will be given to protecting natural vegetative growth outside the 

project’s construction limits from unnecessary removal or siltation. Natural vegetation, 

in conjunction with other sedimentation controls, provides filtration of highway runoff. 

4. Protection of storm sewer inlets will be done to prevent sediment from entering the storm 

sewer system. 

5. The contractor is responsible for preventing the tracking of material onto local roads and 

streets. If material is tracked onto roads or streets, it shall be removed. 

5.4 Environmental Permits 

Environmental permits for the Preferred Alternative will be obtained prior to construction 

activities to ensure appropriate steps are taken to protect existing/remaining resources. 

Impacts on wetlands will require permits under federal and state law: 

Federal

• Executive Order 11990 (Wetland Protection) 

• Clean Water Act of 1977, as amended: Section 401, State Water Quality Certification; 

Section 402(p), National Pollutant Discharge Elimination System, storm water permit; 

and, Section 404, related to dredge and fill. 

Federal Executive Order 11990 on Wetland Protection states that when federal funds are used on 

a project, allowing impacts to any wetland (regardless of size) will require that there be no 

practicable alternative to impacts on that wetland. 

Section 401 of the Clean Water Act of 1977, as amended, requires certification from the state’s 

water quality agency (MDEQ) to ensure that the discharge of dredged or fill material complies 

with the provisions of the Federal Water Pollution Control Act. 

Section 402(p) of the Clean Water Act and subsequent regulation under 40 CFR 122.26 requires a 

National Pollutant Discharge Elimination System Storm Water discharge permit for construction 

projects that involve land clearing or disturbance of one acre or greater. Permit application 

requirements include: 1) a location map and description of the nature of the construction activity; 

2) location of the proposed discharge; 3) total area of the site and area to be disturbed; 4) an 

estimate of the runoff coefficient of the site and the increase in impervious area after construction 

is complete; and, 5) the nature of the fill. The intent of these requirements is to reduce impacts on 

water quality during and after construction. 

State – Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as 

amended: 

• Part 55, Air Pollution Control 

• Part 303, Wetlands Protection 

A Part 55 Air Pollution Control permit-to-install, or general permit, is required for any portable 

bituminous or concrete plant or crusher. Also see Section 5.12. 

A Part 303 Wetland permit is required for any wetland disturbance, temporary as well as 

permanent. 
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5.5 Existing Vegetation 

The existing natural and ornamental vegetative cover will be retained wherever and whenever 

possible within the public right-of-way limits. Where the existing ground cover must be 

removed, replacement vegetation will be established in a timely manner, using seed and mulch or 

sod. 

Trees within public right-of-way will be saved as long as safety requirements are met. All 

property owners will be notified before any trees in front of their residences are removed and will 

be offered replacement trees to help offset the aesthetic and/or functional loss of the trees. 

Replacement tree species, numbers, and planting recommendations will be made jointly by 

MDOT’s Roadside Development Section and the Region Resource Specialist as part of the 

project design process following contact and coordination with adjacent property owners. For 

those owners who request replacement trees, the trees are to be replaced (with the property 

owners’ approval) on their property as close to the right-of-way line as possible. The property 

owners will then assume the responsibility for maintaining these trees. 

5.6 Disposal of Surplus or Unsuitable Material 

Surplus or unsuitable material generated by the removal of structures, trees, etc., will be disposed 

of in accordance with the following provisions designed to control the possible detrimental 

impacts of such actions. When surplus or unsuitable material is to be disposed of outside of the 

right-of-way, the contractor will obtain and file with MDOT written permission from the owner 

of the property on which the material is to be placed. In addition, no surplus or unsuitable 

material will be disposed in any public or private wetland area. Inert material may be used as a 

basement fill to a depth not less than three feet below the ground level, if the basement is not 

within the roadway cross section. Such material must be covered with at least three feet of clean 

soil to fill voids. Basement walls are to be removed to ground level. All regulations of the 

MDEQ governing disposal of solid wastes will be complied with. 

5.7 Groundwater Quality 

The sealing of water wells, septic systems, and sewer lines for the protection of groundwater 

quality will be ensured by the enforcement of MDOT specifications imposed on the contractor 

during construction. For houses or other structures with sewer service that are relocated or must 

be razed, sewer lines will be filled with concrete grout at the basement level, and water will be 

turned off at the street. In rural areas, the sewer line to the septic tank must be filled at the 

basement level. Abandoned water wells will be filled with grout applied from the bottom 

upwards through a conduit extended to the bottom of the well in one continuous operation until 

the well is filled. The contractor must also meet all local and Michigan Department of 

Community Health (MDCH) requirements. 

Contractors will generally be allowed 60 to 90 days following issuance of the demolition contract 

for the site to be completely cleared. However, no more than 48 hours will be permitted 

following removal of any structure to fill the foundation to ground level. If the foundation is not 

filled within this time, MDOT will take independent action to fill the foundation, charging costs 

incurred to the contractor. The MDEQ notification procedures for demolitions will be followed. 

The above specifications have been approved by the Michigan Department of Community Health. 

The contractor will also be referred to the local health department for assistance when special 

conditions such as flowing wells or wells with a high artesian head are encountered. If high water 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

5 - 5

tables are encountered in cut sections, special methods will be used to reduce any negative effects 

on the area groundwater. 

Drainage structures will be built as necessary along the pavement to drain the roadway sub-base. 

Edge drains will be used to intercept horizontal seepage. Stone baskets will be used to maintain 

and reroute the flow of springs when found below the roadway. Intercepted water will be 

discharged into an available storm sewer. 

5.8 Surface Water Quality 

Adequate soil erosion and sedimentation control measures will be implemented. A combination 

of detention basins, sediment basins and vegetated ditches will be used to promote infiltration, 

thereby reducing the potential impacts on water quality from added runoff and associated 

pollutants, including deicing salts and heavy metals. The runoff from the terminals is currently 

discharged and, in the future, will continue to be discharged to combined sewer systems, which 

treat the wastewater at the municipal treatment plants before being discharged. Runoff flow rates 

will not be increased. This will be ensured by constructing onsite detention areas or holding 

stormwater onsite in underground pipes. 

The railroads may choose to carry stormwater directly to the Rouge River through pipes in 

their own right-of-way. The railroads would be subject to National Pollutant Discharge 

Elimination System (HPDES) permitting. 

5.9 Maintaining Traffic During Construction 

The disruption of traffic in the construction area will be minimized to the extent possible. All 

construction areas and altered traffic patterns will be clearly marked during the construction 

phase. A preliminary construction staging program for the Preferred Alternative has been 

developed and is the subject of ongoing review to ensure the constructability of the project and 

minimize impacts to the local neighborhoods and the motoring public. The preliminary 

staging plan expects project implementation to begin in 2010 and conclude in 2019. 

Modification of the I-94/Livernois Avenue ramps in the northeast and northwest quadrants of 

the interchange is expected to be accomplished in one construction season (March through 

November). Lonyo will not be closed before construction of the Central Avenue underpass is 

complete. The underpass is expected to take up to three years to construct. 

5.10 Continuance of Public Utility Service 

Utilities will require relocation or adjustment. In doing so, coordination between MDOT and the 

affected utility company will take place during design, prior to actual construction. Proposed 

staging plans will also be presented to utilities to make them aware of the project. Service to the 

project area will be maintained with temporary connections during construction so service 

interruptions will be minimized. 

5.11 Construction Noise and Vibration Impacts 

Construction noise also will be minimized by measures such as requiring that construction 

equipment have mufflers; that portable compressors meet federal noise-level standards for that 

equipment; and, that all portable equipment be placed away from or shielded from sensitive noise 

receptors, if at all possible. All local noise ordinances will be adhered to. 
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Where pavement must be fractured, structures must be removed, and/or piling or steel sheeting 

must be driven, care will be taken to prevent vibration damage to adjacent structures. In areas 

where construction-related vibration is possible, basement surveys will be offered. These areas 

will be identified during the design phase and surveys would be offered before construction 

begins to document any damage caused by MDOT construction. Geotechnical analysis 

conducted for the project will aid in the understanding of potential vibration impacts and 

mitigation. Vibration impacts will be reviewed further during the design phase. Vibration 

impacts are not anticipated at this time. 

5.12 Control of Air Pollution During Construction 

The contractor will be required to comply with all federal, state and local laws and regulations 

governing the control of air pollution. 

Dust Control: During construction of any project, adequate dust-control measures will be 

maintained to avoid detriment to the safety, health, welfare, or comfort of any person, or cause 

damage to any property or business. 

Bituminous and Concrete Plants: All bituminous and Portland cement concrete proportioning 

plants and crushers must meet the requirements of the rules of Part 55 of Act 451, Natural 

Resources and Environmental Protection. Any portable concrete plant must meet the minimum 

250-foot setback requirement from any residential, commercial, or public assembly property or 

the contractor is required to apply for a permit to install from MDEQ. Portable crushers must 

have a setback of 500 feet or more for a general permit; otherwise, a permit to install is required. 

Asphalt plants must have a setback of 800 feet or more or a site specific permit is required. The 

permit process, including any public comment period, if required, may take up to six months. 

Dust collectors must be provided on all bituminous and concrete proportioning plants. Dry, fine 

aggregate material removed from the dryer exhaust by the dust collector will be returned to the 

dryer discharge unless otherwise directed by the engineer. 

Construction emissions may represent a large new source of PM2.5 emissions. The 

implementation of a construction emissions reduction plan may be considered to target 

emissions from construction sources. This plan might include actions such as: retrofitting offroad construction equipment; using ultra-low sulfur fuels for all equipment; limiting the age of 

on-road vehicles used in construction projects; minimizing engine operations; restricting 

construction activities around certain more sensitive receptors; instituting fugitive dust control 

plans; using diesel particulate traps and oxidation catalysts; and, using existing power sources 

or clean fuel generators, rather than temporary power generators. 

5.13 Wetland Mitigation 

Preliminary consultation regarding mitigation for wetlands was undertaken during delineation of 

wetlands. Mitigation of proposed wetland impacts has involved: 1) avoidance of wetlands where 

feasible, 2) minimization of unavoidable impact by adjustments to the project alignment and 

typical section, and 3) compensatory wetland construction or restoration. The first two steps have 

been integral to project development. Specific mitigation measures will be done in accordance to 

all applicable statutes administered by appropriate agencies. 

Wetland areas were evaluated and maximum efforts were made to avoid and minimize wetland 

impacts. Minimization of wetland impacts during construction will be further accomplished by 

soil erosion and sediment control practices consistent with MDOT’s Soil Erosion Program. 
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Compensatory wetland restoration or creation is planned, in accordance with state and local 

wetland protection ordinances, to mitigate unavoidable impacts to approximately 0.01 acres of 

wetlands at the Livernois-Junction Yard. This area is made up of marginal wetlands of minor 

ecological significance. These wetlands are proposed for mitigation at a 1:1 ratio, so there is a 

requirement to replace 0.01 acres. 

MDOT, through a cooperative agreement with MDEQ, would 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). 

5.14 Contamination 

A Project Area Contamination Survey (PACS), or Level I Environmental Site Assessment was 

conducted for the DIFT Project to determine if any known or potential sites of environmental 

contamination exist that could affect the project design, cost, or schedule. The PACS covered 

existing right-of-way (ROW), proposed fee ROW, proposed grading permits and proposed 

easements. The PACS process included field reconnaissance with business owners, review of 

federal and state records, and review of historical land use records. 

Investigations were done for 67 individual sites and up to 19 sites have been identified for a 

Phase II survey, under the Preferred Alternative. Additional soil borings will be required to 

further identify potential contamination on sites to be acquired. Contamination areas will be 

marked on all construction plans. A Utility Plan will also be prepared to ensure no deep utility 

cuts will impact and/or spread existing contamination. A Risk Assessment Plan will be 

developed to include a Worker Health and Safety Plan. All contaminated materials will be 

properly disposed of. All monitoring wells will be properly sealed and abandoned. 

5.15 National Geodetic Survey Monuments 

The project area will be reviewed prior to construction to determine whether any U.S. Department 

of Commerce, National Geodetic survey monuments (http://www.ngs.noaa.gov) will be 

disturbed. If so, 90-day notification will be given to the Department of Commerce. 

5.16 Cultural Resources 

The Michigan Box Company and the house at 6332 Kronk are eligible for listing on the 

National Register of Historic Places and will be affected by the Preferred Alternative. 

Coordination with the SHPO will continue, consistent with the updated Memorandum of 

Agreement in Appendix C in order to document impacts and mitigation measures. 

5.17 Additional Mitigation or Modifications 

The final mitigation package will be reviewed by division representatives on the MDOT project 

study team, in cooperation with concerned state, federal, and local agencies. 

Some changes to the early mitigation concepts discussed in this document may be required when 

design proceeds. These mitigation concepts will be implemented to the extent possible. Where 

changes are necessary, they will be designed and field reviewed before permits are applied for or 

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

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These preceding mitigation concepts are based on the best information available through 

September 2009. 

It is noted elements that are part of each terminal’s design (paving, lighting, walls for security, 

Central Avenue underpass) are covered in a Pre-Development Plan Agreement included as 

Appendix F. The PDPA is the basis of more detailed agreements, to be developed/executed with 

individual railroads once the Record of Decision is issued. In those areas around the terminals 

where Federal Highway Administration Noise Abatement Criteria are exceeded due to terminal 

activity, the walls will be designed to reduce terminal noise a minimum of 5 dBA. 

Community Enhancements 

In response to a proposal advanced by local community members who organized themselves 

into a group called “Working Group for a Community Benefits Agreement on the Detroit 

Intermodal Freight Terminal Project,” MDOT has agreed to participate along with FHWA in 

a set of enhancements in the community related to the DIFT Project. A Central Avenue 

viaduct will allow vehicles to safely pass under the terminal, eliminating the possibility of 

train/car crashes on Central Avenue. Once the Central underpass is completed, traffic on 

Lonyo Avenue will be rerouted to Central Avenue, eliminating any future car/train crashes at 

that location also. 

Road upgrades will be made including a maximum of $11 million for improvements to federalaid local roads that carry DIFT truck traffic and were identified as a priority by community 

leaders. The DIFT will address the important issue of reducing truck traffic on neighborhood 

streets by channeling truck movements to I-94 from Livernois Avenue, through the use of 

directional curbing at the gate entrance. A new gate will be constructed at the west end of the 

yard, providing direct access to I-94 via Wyoming Avenue. 

Construction of security walls along the north perimeter of the terminal will minimize visual 

and noise impacts. Natural buffering in the form of shrubbery and landscaping are also 

included. MDOT will work together with the City of Detroit in an effort to secure 

Transportation Enhancement Funds to beautify roadways and greenways near the DIFT. 

MDOT will participate with other stakeholders, such as the Michigan Economic Development 

Corporation, the Detroit Economic Growth Corporation, and the Dearborn Department of 

Economic Development in funding a study of economic development opportunities. 
Green Sheet: Project Mitigation Summary 

Detroit Intermodal Freight Terminal (DIFT) FEIS

For the Preferred Alternative *

This Project Mitigation Summary Green Sheet contains the project specific mitigation measures 

being considered at this time. A list of Community Enhancements that are above and beyond 

what is required mitigation for this project is included at the end of this Green Sheet. A Final 

Green Sheet will be prepared and included in the Record of Decision (ROD) for this project. 

These mitigation items may be modified during the ROD, final design, right-of-way acquisition, 

or construction phases of the project. 

General Green Sheet Items 

Impact Category Mitigation Measures 

I. Social and Economic Environment 

a. Central Avenue Viaduct 

The construction of a railroad bridge at Central Avenue will allow vehicles to safely pass 

under the terminal, eliminating the possibility of train/car crashes on Central Avenue. 

Rerouting Lonyo Avenue traffic to Central Avenue will eliminate any future car/train 

crashes at Lonyo also. 

b. Visual Effects Security walls are planned at the Livernois-Junction Yard along the north side and part of 

the south side. A new perimeter road along the north side will include a landscaped buffer. 

Security wall construction and construction materials will be discussed with the affected 

residents in the vicinity of potential construction and local officials during Context 

Sensitive Solutions (CSS) workshops during the design phase. Directional lighting shall be 

used adjacent to residential areas. 

c. Relocations Adequate replacement housing and industrial/commercial space is available in southwest 

Detroit for those residents and businesses who wish to remain in the area. This project 

would relocate 32 residential dwelling units and 29 businesses. The DIFT Conceptual 

Stage Relocation Plan can be found in Appendix B of this FEIS. 

d. Environmental 

Justice/Title VI 

Population Groups 

Mitigation and enhancement measures such as landscaping, security walls, and local road 

improvements will benefit minority and low income population groups and Title VI 

population groups who will be impacted by this project. 

e. Noise Project noise levels exceed FHWA Noise Abatement Criteria at several locations adjacent 

to terminals. Walls at the perimeter of the Livernois-Junction Yard are planned as part of 

the project for security and aesthetic purposes. In noise sensitive areas, these security walls 

will be designed to also provide noise abatement.**

II. Natural Environment 

a. Wetlands A maximum of 0.01 acres of impacted wetlands will be replaced under the “General Permit 

Category” where the mitigation will be rolled into another mitigation project elsewhere in 

the state. A permit will be obtained from the Michigan Department of Environmental 

Quality for using this wetland. 

b. Tree Removal/ 

Clearing/Landscaping 

Mature trees will be preserved where possible. Remaining property owners will be notified 

before any trees in front of their residences are removed and will be offered replacement 

trees. Landscaping will be provided along the north perimeter road that will become the 

connection to John Kronk Street. Landscaping will emphasize native species and not 

include invasive species. 

c. Water Quality For runoff, stormwater management facilities will include detention in oversized pipes. 

Stormwater at all terminals flows to combined sanitary/storm sewers presently. Stormwater 

management will be incorporated into the project’s final design and is subject to National 

Pollutant Discharge Elimination System (NPDES) permitting. Options for pretreated 

stormwater runoff could include piping stormwater direct to the Rouge River through pipes 

so that there is no reliance on the Detroit Water and Sewer Department’s combined sewer 

system. 

d. Invasive Species Xerolenta obvia (an invasive land snail) eradication efforts continue in the LivernoisJunction Yard area by the Animal and Plant Health Inspection Service – Plant Protection 

and Quarantine of the U.S. Department of Agriculture (APHIS-PPQ) in coordination with 

the railroads. When construction efforts are undertaken by either MDOT or the railroads

the local APHIS-PPQ office in Romulus, Michigan will be contacted (734.942.9005) to 

coordinate with these ongoing eradication efforts. * Elements that are part of the Livernois-Junction terminal design (paving, lighting, walls for security, Central Avenue underpass) are 

covered in a Pre-Development Plan Agreement (PDPA) among MDOT and the participating railroads. The PDPA accompanies this 

FEIS as Appendix F. 

** In those areas around the terminals where Federal Highway Administration Noise Abatement Criteria are exceeded due to terminal

activity, the security walls will be designed to reduce terminal noise a minimum of 5 dBA. The principal wall anticipated would be 

1,700 feet long and 12 feet high along John Kronk Street, between Martin Street and Livernois Avenue. 

October 2009 
III. Hazardous / Contaminated Materials 

a. Contaminated Sites A Project Area Contamination Survey has been completed. Up to 27 sites will need 

Preliminary Site Investigations prior to right-of-way acquisition. Contamination areas will 

be marked on all construction plans. Proper disposal of any hazardous/contaminated 

material will occur. All monitoring wells will be properly abandoned. A Utility Plan will 

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

contamination. A Risk Assessment Plan will be developed which will include a Worker 

Health and Safety Plan. 

IV. Cultural Environment 

a. Historic The Michigan Box Company building is eligible for listing on the National Register of 

Historic Places and will be demolished by this project. Coordination with the SHPO will 

continue in order to develop appropriate mitigation measures. The SHPO will also review 

plans for the security wall in the vicinity of 6332 Kronk for compatibility. See signed 

Memorandum of Agreement (MOA) in Appendix C. 

b. Archaeology Ground-disturbing activities will not take place in the vicinity of the Michigan Central 

Stockyards Hotel site as a part of the DIFT Project. Construction plans will specify that 

excavation beneath existing disturbance is prohibited in this environmentally sensitive area, 

and a map depicting the environmentally sensitive area will also accompany the plans. See 

signed MOA in Appendix C. 

V. Construction 

a. Vibration Basement surveys will be offered in areas where vibration effects could occur by MDOT 

construction. These areas will be identified during the design phase, where pavement and 

bridge removal will occur, or where piling and/or steel sheeting is planned. Impacts are not 

anticipated at this time. 

b. Maintenance of Traffic Modification of the I-94 ramps in the northwest and northeast quadrants of the interchange at 

Livernois will require temporary detours. The construction of the Central Avenue underpass 

will require a detour to Lonyo Avenue. Lonyo will not be closed until the Central Avenue 

underpass is complete. 
 Community Enhancements 

Impact Category Enhancement Measures 

a. Local Roads In the vicinity of the DIFT Project area, adjacent local roads will be evaluated to determine 

what improvements are needed to the roadway - including paving, sidewalks, streetscaping, 

and lighting. MDOT will coordinate with the City of Detroit to determine the scope of work, 

cost (not to exceed $11 million), and schedule for the local road improvements. 

Environmental clearance for the local road improvements will be addressed in future separate 

clearances. 

b. Transportation 

Enhancement Funds 

MDOT will work together with the City of Detroit in an effort to secure Transportation 

Enhancement Funds to further beautify roadways and greenways in the vicinity of the DIFT. 

c. Truck Traffic The DIFT will also address the important issue of reducing truck traffic on neighborhood 

streets by channeling truck movements to/from I-94 along Livernois Avenue, through the use 

of directional curbing at the Livernois gate and by eliminating the Waterman/Dix entrance to 

the terminal. 

d. Livernois-Junction 

Yard Access 

New gates will be constructed at the west end of the yard, providing direct access to I-94 via 

Wyoming Avenue. 

e. Security Walls Construction of security walls at various locations along the perimeter of the terminal will 

minimize visual and noise impacts. 

f. Economic MDOT will participate with other stakeholders in funding a study of economic development 

opportunities that will support small business development in the DIFT study area. MDOT 

will continue to coordinate with the Michigan Economic Development Corporation, the 

Detroit Economic Growth Corporation, the Dearborn Department of Economic 

Development, various public-private partnerships and the local community. 

g. Air Quality MDOT will work with contractors on an operational agreement to control air pollution 

during construction. A construction emissions plan may include actions such as: retrofitting 

off-road construction equipment; limiting the age of off-road vehicles used in construction 

projects; minimizing engine operations; restricting construction activities around certain 

more-sensitive receptors, like Southwestern High School (when it is in session); using diesel 

particulate traps and oxidation catalysts; and, using existing power sources or clean fuel 

generators, rather than temporary power generators. The Contractor will institute fugitive 

dust control plans per MDOT 2003 Standard Construction Specifications under Section 

107.15A and 107.19. 

MDOT will work with SEMCOG, MDEQ, and the private sector to create an action plan that 

includes short-term and long-term objectives aimed at reducing fugitive dust, diesel truck 

idling, fuel consumption, or diesel emissions to limit PM2.5 emissions in the study area 

defined by the map shown in Figure 3-16 of this FEIS. The action plan will identify 

priorities for future federal aid eligible transportation projects through programs such as 

Congestion Mitigation and Air Quality (CMAQ) and the Midwest Clean Diesel Initiative. 

The action plan will be implemented during design and construction phases, and sustained 

through the maintenance and operations of the facilities. Activities could also include 

outreach activities to inform commercial operations and residents on air pollution control 

strategies. The actual projects will be generated from the community and its partners who 

will develop project proposals. 

h. Job Training MDOT will coordinate with the City of Detroit Workforce Development, the Michigan 

Department of Energy, Labor and Economic Growth to explore job training opportunities, 

English as a Second Language (ESL), and other training options in the project area. 

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

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SECTION 6 

FINAL SECTION 4(f) EVALUATION 

6.1 Introduction 

This section describes and evaluates impacts to properties protected by Section 4(f) of the 

Department of Transportation Act of 1966. The purpose of the Final Section 4(f) Evaluation is to 

ensure that, where there are adverse effects to protected resources, such as historic sites and 

publicly-owned public parks, recreation areas, wildlife and waterfowl refuges, all prudent and 

feasible alternatives to use of such resources have been considered, planning has included all 

possible measures to minimize harm, and coordination with appropriate agencies has 

satisfactorily occurred. It is noted the proposed project will not involve any “6(f)” properties, i.e., 

those benefiting from the use of the Land and Water Conservation Fund Act. 

Section 4(f) applies to all historic sites of national, state or local significance, whether or not these 

sites are publicly owned or open to the public, but except in unusual circumstances, only historic 

properties on or eligible for inclusion on the National Register of Historic Places are protected. 

A publicly owned park, recreation area or wildlife and waterfowl refuge must be a "significant" 

resource for Section 4(f) to apply. Pursuant to 23 C.F.R. 771.135 (c), 4(f) resources are presumed 

to be significant unless the official having jurisdiction over the site concludes that the entire site is 

not significant. Even if this is done, FHWA must make an independent evaluation to assure that 

the official's finding of significance or non-significance is reasonable. The State Fairgrounds was 

assumed to be significant. 

The Federal Highway Administration (FHWA) has determined the project would have a use of 

the potentially historic properties and recreational resources noted below with Alternatives 2, 3 or 

4 (Table 6-1). “Use” of a Section 4(f) property means: 1) permanent incorporation into a 

transportation facility; or, 2) proximity impacts so severe that the activities, features or attributes 

hat qualify the property are substantially impaired. The Preferred Alternative affects only the 

first entry on the list below:

• Michigan/General Box Company (Spranger/Detroit Wire Wheel Corporation) 

• 6332 John Kronk Street 

• Federal Screw Works Factory 

• Markey House 

• Tomms House 

• Michigan Central Railroad Bridge Deck 

• Michigan State Fairgrounds (a 4(f) but not a 6(f) property) 

The alternatives considered for intermodal terminal development are summarized on Table 1-1 

and elaborated upon in Section 1.2, to which the reader is referred. 

Expanded intermodal terminals would result in a use of the noted properties. FHWA has 

consulted with the SHPO to develop measures to minimize harm. This final Section 4(f) 

document was prepared for processing under the procedures set forth in FHWA regulation 23 

CFR 771.135. A Final Memorandum of Agreement (MOA) is included in Appendix C. 
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Table 6-1 

Potential National Register Eligible Cultural Resources and Recreational Resources Adverse Effects 

Alt. Terminal Site Name Location Description of Area Impacted

National Register 

Eligibility 

Criteriaa

Effect 

3/4/ 

Pref. 

Liv-Jct Michigan Box 

Company/Spranger 

Wire Wheel 

Corporation 

7175 Clayton 

Street 

Factory originally built to 

make auto parts. Now pallets 

are made at the site. 

C Area needed for Alternatives 3 

and 4 would require demolition, 

which is an adverse effect. Also 

true for Preferred Alternative. 

2/3/4 Liv-Jct House 6332 Kronk Historic Home C Potential adverse visual effect 

from placement of wall at terminal 

edge. SHPO to review. 

3 Liv-Jct Federal Screw 

Works Factory 

3301-3401 

Martin Street 

Factory originally built to 

make auto parts. Now a 

warehouse 

A + B Area needed for Alternative 3 

would require demolition of this 

property. 

3 Liv-Jct Markey House 3504 Martin 

Street 

Historic Home A + C The Federal Screw Works Factory 

across the street would be 

demolished under Alternative 3 

causing an adverse visual effect. 

3 Liv-Jct Tomms House 3434 Martin 

Street 

Historic Home C The Federal Screw Works Factory 

across the street would be 

demolished under Alternative 3 

causing an adverse visual effect. 

2 CP/ Expressway Michigan Central 

Railroad Bridge 

Deck 

2405 West 

Vernor Highway 

Bridge deck structure 

associated with Michigan 

Central passenger station 

complex. 

C Tracks would be added and 

modified on the bridge for 

Alternative 2. 

2/4 CN/Moterm Michigan State 

Fairgrounds (MSF) 

Woodward 

Avenue and 8 

Mile Road 

Area used to store new 

vehicles prior to shipment 

Not Applicable A portion of the area used to store 

new vehicles prior to shipment 

that is leased from the MSF, 

would be required under 

Alternatives 2 and 4. a See Section 6.3.1. 

Source: Commonwealth Cultural Resources Group and The Corradino Group of Michigan, Inc. 

6.2 Proposed Action and Need for Project 

The purpose of the Detroit Intermodal Freight Terminal project is to support the economic 

competitiveness of southeastern Michigan and the state by improving freight transportation 

opportunities and efficiencies for business, industry and the military. The goal is to ensure that 

Southeast Michigan has a facility, or facilities, with sufficient capacity and interconnectivity to 

provide for existing and future intermodal demand and reduce time, monetary costs and 

congestion to support the economic competitiveness of Southeast Michigan. 

Detroit is now one of the top intermodal markets in the nation. More intermodal traffic could 

flow through Detroit if the capacity were provided and a plan were developed for a betterconnected railroad and highway system. The Detroit market has characteristics that could cause 

intermodal traffic to grow faster than the national average, including Detroit’s role in the 

automotive industry and strategic position on the Canadian border. 

The Michigan Department of Transportation is engaged in the DIFT study to ensure that the 

businesses and industries involved in the intermodal freight transportation segment of the 

economy continue to have access to the market (customers, workers, shippers, and the like). 

This, in turn, will support mobility and maintenance of the Michigan and national economies and 

national defense as well as a high quality of life for the region’s citizens including: 
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• Providing the necessary infrastructure to support current and future distribution needs of 

industry, particularly auto manufacturing, the state’s largest industry, and other Southeast 

Michigan businesses. 

• Achieving a competitive advantage both regionally and nationally by focusing federal, 

state, local and private (i.e., railroad and other private entities) investments and resources 

on an “intermodal” strategy. 

• Stimulating economic development and redevelopment throughout Southeast Michigan 

resulting in job creation, an increased tax base, and lower cost of consumer goods. 

• Reducing truck “vehicle miles traveled,” which saves lives, reduces pollution and 

conserves highway capacity. 

• Removing intermodal terminal-related truck traffic from the local streets of the nearby 

neighborhoods so that quality of life issues, such as air pollution and safety, are 

improved. 

• Buffering existing intermodal facility from nearby neighborhoods through improvements 

that reduce noise and use trees, vegetation and other enhancements to improve the 

terminal’s exterior appearance and security. 

The proposed intermodal improvements are needed to handle the increasing intermodal volumes, 

which have grown from 283,000 lifts (a movement of a container from a truck to a train or vice 

versa) in 1992 to 348,000 lifts in 2002. The capacity of the existing intermodal terminals in the 

region is about 345,000 annual lifts. The forecast demand for 2025, if no extraordinarily positive 

trends occur, would range from about 500,000 to 700,000 annual lifts. 

See Section 2, Purpose and Need for Action, for more information.

6.3 Description of Resources 

6.3.1 Historic Resources 

The National Register of Historic Places (NRHP) was created by the National Historic 

Preservation Act of 1966 and is administered by the National Park Service. The NRHP 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 must 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 be likely to yield information important in 

history or prehistory (usually archaeological sites). A property typically has to be 50 years old or 

older to be considered National Register eligible. No known National Register eligible 

archaeological sites were found at any of the terminals. The SHPO has agreed with the 

assessment that two archaeological sites at the Livernois-Junction Yard will be unaffected by 

the Preferred Alternative, as the Baby Mills site is outside the footprint of this alternative and 

the Stockyards Hotel has likely been buried by railroad activity. Ground disturbing activities 

will not be conducted in this area. Construction plans will specify that excavation beneath 

existing ground disturbance is prohibited in this environmentally sensitive area. A map 

depicting the environmentally sensitive area will accompany the plans. 
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A discussion of properties considered eligible and expected to experience adverse effects with the 

project follows. 

Michigan/General Box Company (Spranger/Detroit Wire Wheel Corporation) 7175 Clayton 

Street, Detroit – Adverse Effect by Preferred Alternative 

In 1917 the property at 7175 Clayton was first listed as the site of the Spranger Wire Wheel 

Company. The business continued under this name through the following year; by 1919, it was 

redesignated as the Detroit Wire Wheel Company. This latter organization went defunct by the 

next year, when the building was listed as vacant. This situation remained unchanged through 

1924. 

Information about the wheel company and its participating officers is scanty. The founderpresident of the firm, Nichols M. Spranger, was a successful Detroit physician before, during, and 

after his venture as a would-be automotive parts manufacturer. His associates in the wheel 

manufacturing business were Jacob M. Schaefer, vice president; John Reinke, secretary; and 

William Finzel, treasurer. All three continued with the business as it later transitioned into the 

Detroit Wire Wheel Corporation. Spranger was, however, replaced as president by Frederick R. 

Schmalziedt, while J. Robert Wilken was added to the list of officers as General Manager. In 

1917, the Spranger Wire Wheel factory was exclusively devoted to automotive supply. The 

choice of factory location placed the facility adjacent to the railroad and the Prest-O-Light 

Company’s automotive headlamp factory, which was built in 1916. 

The footprint of the 7175 Clayton factory building measures approximately 120 ft. by 260 ft. See 

Figure 4-54 for its location relative to the Action Alternatives. Constructed of brick, the building 

exhibits a basilica form, common to factory and exhibition hall designs of the period, with a 

central two-story core paralleled by two side-flanking one-story wings (Figure 6-1). The forward 

two-story portion of the building is devoted to office space. The stone coping of the front second 

story parapet exhibits a slight downward slope from center to outer wall, with window groups 

being arranged in three sash and two sash bays. The second story windows are replacements, 

with observed first story units consisting of one-over-one double-hung wood sashes. First and 

second story clerestory windows of the factory segment consist of large triple-frame metal sash 

bays mounted on brick quarter walls (first story) between the building’s multiple wall buttresses. 

A cantilevered steel H-beam canopy, with metal sash glass windows, defines the first-story 

storage and loading dock running along the entire west side of the factory component. Decorative 

embellishments are limited to four pressed concrete, or carved limestone, symbolic wire wheels 

with Gothic letter “S” hubs affixed at the two-story pier mid-sections. 

Exterior structural alterations, in addition to second story window replacements, are limited to a 

loading dock with a poured concrete base, and constructed of steel beams and concrete block. 

Located at the northwest corner of the north façade, the loading bays are flat roofed and cut below 

grade, inclining towards the building from Clayton. 

A one-story concrete block wing connects the rear (south) of the factory to a two-story warehouse 

that is clad with corrugated sheet metal panels. The westerly wall of the latter building curves 

along an abandoned railroad spur and is pierced by three wide cargo bays. Window bays are 

numerous, consisting of metal frame sashes. They are restricted to the second story and most are 

covered with flakeboard panels. 

A circular three-story concrete block wood chip storage silo abuts a concrete block “heater” 

building. Their associated metal tube and hopper feeder assemblies occupy the space between the 

factory and warehouse. A tall, narrow chimneystack, supported by metal wires, defines the waste 

incinerator facility housed in the heater building. 
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The wire wheel factory building at 7175 Clayton is a rare example of a relatively unaltered World 

War I period automotive parts supply facility. Although the business was financially 

unsuccessful, the building is a historically significant example of an early supply shop that 

flourished during the initial stages of Detroit area automobile industry growth. This building is 

considered eligible for listing on the NRHP under Criterion C. However, the adjacent wood stock 

warehouse and disposal facilities to the rear of the factory are additions unrelated to the auto 

industry and are non-contributing elements of the property. The SHPO concurred that this site is 

eligible for the National Register (see letter dated October 18, 2004 in Appendix A of the DEIS). 

This property is privately owned. It is currently occupied by Fontana Forest Products which 

produces wooden pallets and containers. 

House at 6332 John Kronk – Not affected by Preferred Alternative

This one-and-one-half story brick Gabled-Ell dwelling exhibits gothic or pointed, arch gabled 

vent windows and elliptical arched first floor window bays. The front entry is off-set, though its 

form is obscured by an enclosed porch addition. The rear of the building is formed by a 

compound one-story hipped roof addition and a telescoping one-story lean-to roof addition. The 

building is stylistically eclectic and exhibits both Gothic and Italianate influences. 

While the historical associations of the dwelling at 6332 John Kronk Avenue have proven 

elusive, it is stylistically assignable to the 1873 period of platting for the associated Cicotte, 

Gilbert and Barkume Subdivision. An example of a 19th Century Detroit worker cottage, brick 

examples are particularly rare. 

Brick dwellings within the project vicinity are exceedingly rare for all periods. During the pre1920 period, the use of common brick was largely restricted to commercial buildings along 

Michigan and Livernois avenues and to foundation wall or pier supports for area housing. 

Nineteenth century brick houses are the single tangible reminder of the once significant part that 

the brick industry played in Springwells Township economics and manufacturing. The dwelling 

is eligible for listing on the NRHP listing under Criterion C. The dwelling is distinctive in its 

embodiment of a type, period, or method of construction (Criterion C); specifically the dwelling’s 

distinct style expressing ca. 1865-1875 Italianate influence. 

6332 John Kronk Streetscape, View to south-southwest toward rail yard from house (house is on the right) 
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Federal Screw Works Factory 3301/3401 Martin Street, Detroit – Not Affected by Preferred 

Alternative 

Historically the facility at 3301/3401 

Martin Street is associated with Federal 

Screw Works, a manufacturer of 

fasteners to the auto industry. Federal 

Screw Works, now headquartered in St. 

Clair Shores, Michigan, was founded 

in Detroit in 1917 to produce fasteners. 

Their primary focus was serving the 

automobile industry, in particular 

General Motors and Ford. 

The original building in the existing 

complex was built in circa 1920 at 

3401 Martin Street (near the Otis Street 

intersection). The building housed 

office, warehouse and machine shop 

functions in a steel frame and brick 

building, two stories at the front and one story with monitor at the back (Figure 6-2). The factory 

was expanded towards Bruckner Street and Southern Street/John Kronk and behind the Martin 

Street structures, in later years, with one addition on Southern/John Kronk added in 1950. 

The Modern/Eclectic five bay 1920 building follows common themes that were translated into 

office, school, and commercial buildings of the period, doing away with Victorian excess in favor 

of cleaner, more modern lines. As is common in this modern and somewhat conservative style, 

the building gains most of its subtle expression from the use of patterned dark brick and limestone 

and cast stone detailing. Brick pilasters support an implied cornice of brick with cast stone 

blocks done in a bas-relief of various nuts and bolts and is finished with limestone coping along 

the parapet. The entrance bay is marked by a slightly projecting entry arcade with simple 

classical detailing. While the first floor has been modified with the replacement of the original 

large windows with smaller aluminum units, the original factory building retains good integrity 

overall. 

To the northwest, running to Bruckner Street, is a multiple bay one-story addition with a monitor 

roof. The date of construction is not clear but may date to wartime expansion in the early 1940s. 

Each bay carries a single large window opening, currently filled with brick. To the southwest is 

another addition, date of construction unknown, steel framed with large panel windows, currently 

carrying opaque panels. 

The Federal Screw Works was involved in a divisive and violent strike in the spring of 1938 with 

national implications and which involved key figures in the labor movement and local 

government. The factory is considered eligible for inclusion in the NRHP under Criterion A 

(association with events that have made a significant contribution to broad patterns of our history) 

and possibly under Criterion B for its association with the lives of persons significant in our past 

– in this instance for the association with Walter Reuther, during his formative years as President 

of United Automobile Workers (UAW) West Side Local 174; Stanley Nowak, who was one of 

the first five organizers hired by the UAW and served ten years in the Michigan State Senate as 

Michigan’s first labor legislator (and twice faced expulsion from the United States in reaction to 

his pro-labor politics); and the locally significant – for its corruption, uncovered by U.S. Senator 

Homer Ferguson – administration of Mayor Richard W. Reading. 

Figure 6-2 

Federal Screw Works Factory 

3301-3401 Martin Street 

Source: Michigan Department of Transportation 
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3301/3401 Martin Street is currently owned and used as a warehouse facility by MNP 

Corporation. MNP manufactures, among other products, fasteners used in the automobile 

industry. 

Markey House, 3504 Martin Avenue, Detroit - Not Affected by Preferred Alternative 

This two-story brick Italianate style Side Gable house (ca. 1865) is four bays wide. The front 

façade exhibits a full width one-story hipped roof porch with black painted iron column supports. 

The elliptical brick window bay hoods on the front façade protrude from the wall. This feature 

does not occur on the side bays, or those associated with the two-story flat roof rear addition to 

the building. much of the building is vine covered or obscured by vegetation (Figure 6-3). 

The dwelling at 3504 Martin Avenue was built in ca. 1865 by Michael Markey a successful Irishborn farmer who had settled in Springwells Township in 1848/1849. As of 1870 Markey’s 

dwelling figured as a conspicuous component of his $12,500.00 estate as valued in federal 

census. He, thus, was among the wealthier residents of Springwells Township. Following his 

death in June 1875, the residence continued to be occupied by his son, Matthew. In 1885, 

Figure 6-3 

Markey and Tomms Houses 

Martin Street

3504 Martin Streetscape, View to South-Southwest 

3434 Martin Streetscape, View to South-Southwest 

Source: CCRG 
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Matthew was listed as a wood and coal dealer with a stand on Livernois Avenue. He continued to 

reside at 3504 Martin through at least 1911. 

While Michael Markey’s direct involvement in the local brick industry cannot be demonstrated, 

as of 1876, his brother John, and a probable nephew, Peter, were both identified as brick makers 

operating on Private Claim 60, along Martin Avenue. John’s dwelling, now gone, was located on 

Lot 9 directly to the north of Michael’s property. Peter’s dwelling was on the west side of the 

avenue and is still extant at 4323 Martin Avenue. 

Brick dwellings within the project vicinity area exceedingly rare for all periods. During the pre1920 period, the use of common brick was largely restricted to commercial buildings along 

Michigan and Livernois avenues and to foundation wall or pier supports for area housing. 

Nineteenth century brick houses are the single tangible reminder of the once significant part that 

the brick industry played in Springwells Township economics and manufacturing. The dwelling 

is eligible for listing on the NRHP listing under Criteria A and C. Criterion A requires that the 

resources be associated with events or a pattern of event significant in history. In this case, the 

dwelling’s evidence of the earliest phases of area rural industrialization, which furnished the clay 

products that figured importantly in the early city growth of Detroit. The dwelling is further 

distinctive in its embodiment of a type, period, or method of construction (Criterion C); 

specifically the dwelling’s distinct style expressing ca. 1865-1875 Italianate influence. 

Tomms House 3434 Martin Avenue, Detroit - Not Affected by Preferred Alternative

This Italianate brick dwelling (ca. 1875) exhibits a modern wood frame two-story rear addition 

and an offset, enclosed front porch entry made of brick. Side bays are simple elliptical arch 

forms. The window bays on the front façade exhibit corbelled surrounds with stone 

ornamentation. Twin corbelled belt courses on the first and second floors run across the front of 

the building from the corners to window surrounds. All windows and doors appear to be 

replacements (Figure 6-3). 

The dwelling at 3434 Martin Avenue dates to ca. 1875. As of 1876, these grounds to the east of 

Martin Avenue were in the possession of Henry and August Tomm. Listed in the 1880 census as 

natives of Saxony, the Tomm family resided at the 3434 Martin Avenue location for no more than 

a decade. They appear, however, to have been responsible for the construction of the dwelling. 

Listed as Henry Tomin in the 1885 city directory, he was identified as a gardener. Two years 

later, the property was occupied by another German-born gardener, Henry Damm. 

Brick dwellings within the project vicinity are exceedingly rare for all periods. During the pre1920 period, the use of common brick was largely restricted to commercial buildings along 

Michigan and Livernois avenues and to foundation wall or pier supports for area housing. 

Nineteenth century brick houses are the single tangible reminder of the once significant part that 

the brick industry played in Springwells Township economics and manufacturing. The dwelling 

is eligible for listing on the NRHP listing under Criterion C. The dwelling is distinctive in its 

embodiment of a type, period, or method of construction (Criterion C); specifically the dwelling’s 

distinct style expressing ca. 1865-1875 Italianate influence. 
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Michigan Central Railroad Bridge Deck at the Passenger Station Complex 2405 West 

Vernor Highway, Detroit - Not Affected by Preferred Alternative

This sixteen-story Beaux-Arts building complex was erected by the Michigan Central Railroad 

(MCRR) in 1912/1913. Two firms designed the complex, Warren and Wetmore, and Reed and 

Stem. Warren and Wetmore were responsible for the station work and Reed and Stem for the 

construction engineering and the track work. Whitney Warren, the principal architect of the 

MCRR passenger station, and of the New York Central Railroad’s (NYCRR) Grand Central 

Station, had been French-trained. After winning a silver medal for architectural design at the 

Paris Exposition in 1900, he was made a member, in 1905, of the Academie des Beaux-Arts. His 

association in passenger station design for the NYCRR and MCRR is due, in part, to his familial 

relationship with the Vanderbilts, who held a controlling interest in both railroads. 

Originally identified as the MCRR passenger station, it was later known as the New York Central 

Railroad-Michigan Central District Detroit Passenger Terminal, the Penn Central Passenger 

Station (Detroit 1969), and the Amtrak Train Station. The building, which includes an entry 

pavilion and attached sixteen-story office element, was listed on the NRHP as of March 16, 1975. 

The complex was closed in 1987 and presently exists as a heavily damaged, vacant shell. 

The NRHP nomination form omits mention of other structural elements of the complex extending 

below the existing CP/Expressway terminal. These include the MCRR passenger baggage and 

U.S. Post Office sorting rooms, an express shipping room facing Newark Street, and an extensive 

train shed, the last of which was demolished in 2000. The total area of this structure also includes 

the bridged grade separation spanning West Vernor Highway. The overriding feature linking 

these multiple units as a single resource is the steel girder-and-beam framing system supporting 

the concrete arch slab that caps the entire structure and forms the deck of the existing 

CP/Expressway terminal (Figure 6-4). The structure is massive, covering an area of some 

234,000 square feet. See Figures 4-52 and 6-5 for its location relative to Alternative 2. 

The cargo and U.S. Post Office sorting facilities are largely obscured by their below-deck setting. 

The overall dimensions of this element of the structure measure approximately 340 ft (northsouth) by 570 ft (east-west). Its core composition consists of steel frame reinforced concrete, with 

floor-to-ceiling heights ranging from 12 ft. to 14 ft. The exterior along Newark Street (south) 

exhibits a poured concrete footing (cargo dock) surmounted by riveted steel plate columns 

bracketing 30 metal door (overhead) cargo bays. The upper facade consists of exposed hollow 

terra cotta block. 

The north facade of the deck attaches to the rear (south) wing of the passenger terminal. This 

element of the cargo facility exhibits a Flemish bond brick veneer with the parapet exhibiting 

limestone block coping and a bed mold pattern cornice. A hanging metal shed roof awning 

extends along its entire length covering nine open window and door bays. A similar presentation 

also marks the wall space extending below the West Vernor Highway bridge. 

The bridge element of this structure spans the 100-ft wide West Vernor Highway right-of-way 

and covers an area extending approximately 340 ft along the length of this street. The west end 

of the bridge rests atop a reinforced concrete wall abutment, with the east end forming the roof of 

the adjoining cargo sorting facility. The south parapet of the bridge consists of an undecorated 

poured concrete wall set atop a moulded cavetto device encasing the outer supporting steel girder. 

The north-side bridge parapet duplicates the brickwork and limestone coping and cornice patterns 

occurring on the adjoining baggage sorting facility. The four steel plate columns defining the 

north and south bridge facades are square and concrete encased, with recessed panels. 
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Reinforced concrete building design was a product of construction technology that emerged 

during the late 1890s. Although plagued with numerous failures, as architects and builders pushed 

its capabilities over the next two decades, certain standards and design approaches became well 

established. Among these was the adoption of the arched reinforced concrete slab deck in both 

bridge and building construction, a form specifically designed to “support heavy loads.” 

Although “commonly used”51 as of 1910, the arched slab deck was referred to as only 

“sometimes”51 employed as of 1917. The approach is totally omitted in standard design texts of 

the succeeding period. And, while the arched concrete slab deck figured as a prominent feature of 

bridge and building design from ca. 1905 to 1915, its use as a standard in railroad engineering 

remains undocumented. 

The design of the MCRR railroad yard deck, encompassing an area of some 234,000 square feet, 

employed a complex upper- and lower-flange girder-and-beam framing system capable of 

supporting the thousands of tons of rail traffic that has passed over it each day for the past 

90 years. It ranks as a unique example of early twentieth-century railroad engineering design. 

On the basis of the foregoing, the bridge-deck structure is an integral component of the MCRR 

passenger station complex. 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 Criterion C for the structure’s significance 

in engineering design. The SHPO concurred that this site is eligible for the National Register

(see letter dated October 18, 2004 in Appendix A of the DEIS). 

This property is privately owned and is under lease for railroad purposes. 

6.3.2 Recreational Resources 

Michigan State Fairgrounds Woodward Avenue and Eight Mile Road, Detroit - Not 

Affected by Preferred Alternative 

The Michigan State Fairgrounds (MSF) property encompasses approximately 167 acres at the 

southeast corner of Woodward Avenue (M-1) and Eight Mile Road (M-102), both of which were 

developed as divided Super Highway corridors during the 1925 through 1932 period. The site, 

originally 135 acres, has been occupied by the MSF since 1905. Its status as a state-owned 

property dates to 1921, when title was transferred from the Michigan State Agricultural Society to 

the newly-created State of Michigan, Department of Agriculture. One of the three major goals in 

the Fairgrounds Mission Statement is to provide recreation opportunities along with those that are 

educational and entertaining (see letter dated September 9, 2003 and the Purposes and Aims 

Statement in Appendix A). In addition to the State Fair, the Fairgrounds is used for other events 

such as dog shows, horse shows, trade shows, concerts, and swap meets. 

The easterly third of the Fairgrounds, adjacent to the railroad, is a fenced gravel parking and 

storage area designated on the current Michigan State Fairgrounds and Exhibition Center site plan 

as the “Railroad Lot” (Figure 6-6). This parcel adjoins the existing CN/Moterm railroad yard to 

the north of Eight Mile/Base Line Road (M-102). It is within the east half of this lot, adjacent to 

the existing railroad right-of-way, that the CN/Moterm yard has been proposed to expand 

 

51 Radford, W.A. Cement and How to Use It, The Radford Architectural Company, Chicago, 1910. 
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approximately 35 acres as an alternative to the facility’s expansion in the City of Ferndale. See 

Figures 4-10d and 4-53 for its location relative to Alternatives 2 and 4. This area is used for 

parking during the Michigan State Fair which is a period of up to 14 days in August of each year. 

The Michigan State Fair is said to be the oldest in the country and is an essential component of 

the state and regional recreational fabric. However, the land proposed for intermodal rail use is 

not a part of the State Fair activity except for parking. The property along the railroad in recent 

years has been used for container storage by the Canadian National (CN) Railroad. In 

conjunction with a consent agreement between the City of Ferndale and CN in the early 1990s, 

trucks at the CN intermodal terminal on the north side of Eight Mile Road began using a bridge 

within railroad right-of-way over Eight Mile Road. The purpose of the bridge is to provide an 

alternative means of entry and exit to the intermodal yard without having to use Fair and 

Chesterfield Streets (which are in Ferndale). They are the local streets north of Eight Mile Road 

that provide access to the intermodal terminal today. CN leased the additional land to expand 

their operations south of Eight Mile Road. When CN lost a major customer, it discontinued use 

of the bridge and resumed use of Fair and Chesterfield Streets. 

There is a history of railroad use of the Fairgrounds under lease agreement, and the bridge 

remains in place on railroad property to resume such use. Today, land on the east side of the 

Fairgrounds is used through a lease agreement to store new automotive vehicles before they are 

shipped to their final destination. The area is not accessible to the public. Entry to the entire 

Fairgrounds site is accomplished by passing through a single entry accompanied by a guard on 

duty 24 hours a day. Prior to this area being used for automobile storage, it was used as a private 

racetrack, part of CN/Moterm’s intermodal facility, and as a private softball complex. Since its 

use as a private softball complex, the area has been covered with gravel. There have been a 

variety of suggestions for use of the land over time, including a racetrack and a regional metro 

park. 

6.4 Impacts on the Section 4(f) Properties 

The properties used by the project alternatives are summarized in Table 6-1. The Preferred 

Alternative use of Section 4(f) property is limited to the Michigan Box Company/Spranger 

Wire Wheel Corporation. 

Alternative 2, Improve/Expand the CP/Expressway terminal would have added and modified 

tracks on the Bridge Deck at the Michigan Central Railroad passenger station complex at the 

CP/Expressway intermodal terminal. The addition and modification of tracks at this site was 

considered an adverse effect to a historic resource as defined by Section 106 and would result in a 

use of a protected resource. The SHPO concurred this would be an adverse effect (see letter 

dated October 18, 2004 in Appendix A of the DEIS). 

Alternative 3: Consolidating all intermodal activity at the Livernois-Junction Yard and 

Alternative 4: the Composite Alternative of consolidating intermodal activity of three railroads at 

the Livernois-Junction Yard and expanding the CN/Moterm terminal would have required the 

total removal of the Michigan Box Company/Spranger Wire Wheel Corporation site for the 

expansion of the Livernois-Junction Yard. The total removal of buildings at this site is 

considered an adverse effect to a historic resource as defined by Section 106 and would result in 

the use of a protected resource. The SHPO concurred this would be an adverse effect (see letter 

dated October 18, 2004 in Appendix A of the DEIS). 

Alternative 3: Consolidating all intermodal activity at the Livernois-Junction Yard would have 

required the total removal of the Federal Screw Works Factory for the expansion of the 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Livernois-Junction Yard. The total removal of this factory is considered an adverse effect on the 

following three historic properties as defined by Section 106, and would result in the use of 

protected resources: the Federal Screw Works Factory, the Markey House (adverse visual effect), 

and the Tomms House (adverse visual effect). The SHPO states this would be an adverse effect 

(see letter dated January 21, 2005 in Appendix A). 

Alternatives 2, 3 and 4: The house at 6332 John Kronk currently faces the existing rail yard. 

There will be no expansion of the rail yard in its vicinity under any of the alternatives. A wall 

would be built that would block the current view of rail activity. The active mainline tracks 

through the yard are in the immediate foreground. Train volumes on these tracks will 

substantially increase from about 30 to 60 under No Action conditions. Intermodal expansion 

could add up to another 12 train passbys. The SHPO has further concluded that the wall 

alongside the railroad yard across the street from 6332 John Kronk Street “has the potential to 

result in an Adverse Effect on the house through its height, design, and placement. Therefore, 

any alternative that includes the construction of such a wall must include the condition that the 

plans for the barrier wall and any landscaping are subject to review and approval by the SHPO.” 

(Letter dated June 20, 2005 in Appendix A.) The potential adverse effect to a historic resource as 

defined by Section 106 would result in the use of a protected resource. 

Alternative 2 and Alternative 4 would have required approximately 35 acres of Michigan State 

Fairgrounds (MSF) property. The taking of this area at this site is considered a use of a protected 

resource (recreational property). 

Preferred Alternative – Impacts to Section 4(f) Properties 

The Preferred Alternative will require the total clearing of the Michigan Box 

Company/Spranger Wire Wheel Corporation site for the expansion of the Livernois-Junction 

Yard. The Preferred Alternative needs long straight sections of rail yard for efficient 

intermodal operations. This can only occur by closing Lonyo, lowering Central Avenue under 

the rail yard, and acquiring sufficient land parallel to the existing yard to add terminal width. 

The Michigan/General Box Company (Spranger/Detroit Wire Wheel Corporation) lies within 

the land needed. The terminal cannot prudently be reconfigured to avoid this use to operate 

efficiently. The total removal of buildings at this site is considered an adverse effect as defined 

by Section 106 and would result in the use of a protected resource. The SHPO concurred this 

would be an adverse effect (see letter dated October 18, 2004 in Appendix A of the DEIS). 

CN elected not to participate in government-funded improvements at its Moterm Terminal, so 

the Preferred Alternative has no effects on the Michigan State Fairgrounds property 

(recreational property). 

6.5 Avoidance Alternatives 

Build alternatives were considered, as well as the No Action Alternative. These included 

improving/expanding four existing intermodal terminals, consolidating the intermodal activity of 

four Class I railroads at the Livernois-Junction Yard, and a composite alternative of consolidating 

the intermodal activity of three of the major railroads at the Livernois-Junction Yard while 

improving/expanding the CN/Moterm terminal. Build alternatives that were found not to be 

feasible and prudent/practical included expanding smaller terminals and developing terminals at 

greenfield sites. These were found not to be prudent alternatives as they would not meet the 

project’s purpose and need and they were eliminated from further study. The No Action 

Alternative does not meet the project’s purpose and need. The development of alternatives and 

their evaluation are discussed in Section 3. The Preferred Alternative is a modification of 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Alternative 4 that recognizes the termination of CP’s Expressway operation and the fact that 

CN will not participate in terminal improvements, so there will no changes through 

government action at the Moterm Terminal. 

6.5.1 Historic Properties 

The build alternatives were designed to avoid effects on Section 4(f) properties. Potential historic 

resources were identified early in the analysis process; those that were deemed to have potential 

for the National Register were avoided, where prudent and feasible. These properties acted as 

design layout “controls.” Avoidance and then minimization guided the development of the 

alternatives. 

All feasible and practical alternatives underwent detailed study in the DEIS. Alternatives which 

clearly did not address the project purpose and need, described below, were eliminated from 

future consideration. 

Other Sites for Intermodal Terminals 

Since the 1980s, railroads have consolidated their intermodal service networks into fewer, larger hub 

terminals as they saw an opportunity to consolidate enough volume in one location to justify lift 

machines and other expensive equipment/facilities. Small facilities have been eliminated. For 

example, the activity at the smaller Norfolk Southern intermodal terminal at Oakwood has been 

shifted/consolidated at the Livernois-Junction Yard. This location, and others in the region like at 

Highland Park, do not lend themselves to productive intermodal operations. Nevertheless, an 

existing terminal like Melvindale, and even Willow Run, may be used for some time into the future, 

if adequate capacity is not available on a timely basis at the Livernois-Junction Yard. But, even if 

these Class I railroad terminals stay in use indefinitely, their capacity, when added to that of the four 

intermodal terminals most likely to continue, does not address the demand expected in the future. 

The August, 1994 Mercer Report52 identified the CN/Highland Park terminal as one of two 

alternatives that warranted further investigation for a consolidated terminal (the LivernoisJunction Yard was the other alternative identified at that time). The Mercer Report and 

subsequent research has found the Highland Park site is not a viable intermodal terminal option 

for CN because: 

 1. The Highland Park property is cut up by major transportation facilities, so that standards 

for a modern intermodal terminal cannot be met. 

 2. Storage and support tracks would have to be located offsite causing additional switching 

inefficiencies for the rail operators and the possible need for additional property 

acquisition. 

It is not a viable option for CSX, NS and CP because: 

 1. Extensive trackage rights would be required for any of these railroads to use the site. 

 2. The cost and time for these carriers to access the site make it an unacceptable option. 

It has also been suggested the Port of Detroit is an alternative to the consolidation at LivernoisJunction Yard. The Port of Detroit, consisting of approximately 36 privately owned marine 

terminals, continues to be a successful and active commercial port that typically handles 15-20 

million tons of cargo annually. The vast majority of this cargo consists of bulk materials, including 

 

52 Greater Detroit Area Intermodal Study, Phase II – Intermodal Transportation Center Concept, Mercer Management 

Consulting, August 1994. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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iron ore, stone, coal, cement, and petroleum. A portion of these bulk cargoes is transferred between 

ships and trucks for local or regional distribution. Another portion of these cargoes are processed or 

transformed at the port (e.g., steel mills, electric generating plants, asphalt plants, etc.). A fairly 

small portion of Detroit’s waterborne commerce consists of general (non-bulk) cargo, including 

steel products and, occasionally, machinery. These cargoes are also transferred between ships and 

trucks (occasionally rail) for local or regional distribution/collection. 

There are no regular movements of containers via marine transportation at the Port of Detroit or 

other Great Lakes ports. For overseas container movements, the economic efficiencies of the 

overland transportation system (rail and truck) serving coastal ports, combined with the physical 

constraints of the Great Lakes/St. Lawrence Seaway System (lock size, channel depth, 

seasonality), make direct movement of containers through Great Lakes ports uncompetitive and 

highly unlikely. Southeast Michigan’s overseas container traffic utilizes the efficient rail 

connections to coastal ports, including Montreal, Halifax, New York/New Jersey, Baltimore, 

Hampton Roads, Los Angeles/Long Beach, Oakland, Seattle/Tacoma, and Vancouver. This is 

largely affected by the lack of reliability for time-sensitive cargo to move inland via the St. 

Lawrence Seaway as weather makes its use practically impossible for months each year. 

Finally, it is not a viable option for consolidation because extensive trackage rights would be 

required for CP and CN to use the port. 

Greenfield Site 

The proposed concept of intermodal freight consolidation focuses on the Livernois-Junction Yard 

area. It lies at a railroad point called West Detroit, which is reached by each of the four Class I 

railroads serving the Greater Detroit Area. Canadian National (CN) and Norfolk Southern (NS) 

reach West Detroit over their own lines while Canadian Pacific (CP) and CSX reach the LivernoisJunction Yard either with trackage rights (CP) or ownership of Conrail (CSX). There is no other 

location in the Greater Detroit Area or the state of Michigan where this occurs. 

Each of the railroads reaches Detroit over a network of individually-owned rail lines. There are 

locations along those lines where tracts of land that are largely undeveloped and otherwise known 

as “greenfields,” might appear to be available for the development. But only one railroad would 

be able to reach any such new intermodal terminal location. 

Another issue with those undeveloped properties is they tend to be removed from the shippers 

that they will be serving. This results in increased distance/time to haul goods (drayage) and 

contributes to highway congestion creating a less efficient intermodal transportation system, 

which is counter to the purpose of this project. “Greenfield” developments may also contribute to 

urban sprawl and require new highway, utility and other infrastructure. Conversely, for the most 

part, the existing intermodal facilities, and the proposed consolidated terminal at the LivernoisJunction Yard, are able to use the established infrastructure that is already in place. 

The earlier studies in 1993/1994 conducted for MDOT by Mercer Consulting examined possible 

“greenfield” sites. One, Willow Run, while having several attributes, was served by only a single 

railroad at the time, Conrail. Since the sale of the Conrail assets, Norfolk Southern now controls 

access to the location. Additionally, Willow Run has been proposed for high-speed passenger 

service. The earlier MDOT studies found that the Willow Run site was far from its market with 

high pickup and delivery costs. Nevertheless, because of the Triple Crown business growth, NS 

has had to re-open the Willow Run terminal or lose the business. It has, at the same time, asked 

MDOT for financial assistance so that it can consolidate all its intermodal operations on an 

accelerated pace at the Livernois-Junction Yard. None can be provided unless and until the DIFT 

environmental review is complete. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Overall, a “greenfield” site does not meet the purpose of the project because it results in increased 

distance/time to haul goods (drayage) and contributes to highway congestion creating a less 

efficient intermodal transportation system. 

CBRA Alternative 

An alternative proposed by a group known as Communities for a Better Rail Alternative (CBRA) 

focuses only on the Livernois-Junction Yard. It involves several elements including building a 

new interchange at I-94/Rotunda Drive to connect with the rail line plus a second interchange 

connecting the rail line with I-75 north of the Ambassador Bridge. These interchange concepts 

are not possible according to American Association of State Highway and Transportation 

Officials (AASHTO) design standards because of constraints on spacing of interchanges, and 

elevations/grades. In addition, the CBRA alternative would not meet the forecasted future 

demand for lift capacity. There would be no increase in the terminals’ size for increased lift 

capacity resulting in a lift deficiency ranging from 155,000 to 431,000 lifts per year. 

6.5.2 Recreational Properties 

Several alternatives, described below, were studied to expand the CN/Moterm terminal without 

using any of the Michigan State Fairgrounds. None of these were found to be feasible and 

prudent. But, under the Preferred Alternative, CN elected not to participate in governmentfunded improvements at its Moterm Terminal, so the Preferred Alternative has no effects on 

any recreational property.

Moterm Expansion to the East into Ferndale 

Expansion to the east of the existing CN/Moterm terminal into the industrial area of Ferndale 

would have involved the acquisition of 10 businesses. These businesses provide a major portion 

of the tax base for the City of Ferndale (population fewer than 25,000 people). Because of the 

limited amount of industrial redevelopment property in the city, these businesses would have 

been lost to other areas. Additionally, Gage Products Company would have been displaced. This 

company is a permitted storer of up to one million gallons of hazardous materials. It is Ferndale’s 

largest taxpayer. It would not have been possible to relocate this business in Ferndale because of 

its handling of hazardous materials. 

Due to the large number of business relocations that would have been required and the major 

reduction in tax revenues for Ferndale, expansion to the east was not a feasible and prudent 

alternative. 

Moterm Expansion to the West into Ferndale 

Expansion to the west of the existing CN/Moterm terminal would have required relocation of 

approximately seven businesses, 60 single-family residences, and a large above-ground storage 

tank. This included construction of a perimeter road along the outside of the railroad fence that 

would have provided north-south connectivity within the remaining neighborhood. It accounted 

for placement of a wall for terminal security and noise reduction purposes. Any additional 

buffering would have required acquisition of more residences and possibly businesses. It is 

presumed the gate would have remained in its present location. Presently Fair Park provides 

some buffering to the community. This park would have been acquired by an expansion to the 

west; a 4(f) impact. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Due to the large number of relocations that would be required and the taking of Fair Park, 

expansion to the west was not a feasible and prudent alternative. 

Moterm Expansion to the South and East into Detroit 

Expansion into the Detroit neighborhood south of Eight Mile Road and east of the railroad tracks 

would have involved acquisition of seven businesses and 90 single-family homes. Locating the 

gate east of the railroad tracks must be at a sufficient distance from the railroad overpass on Eight 

Mile Road to allow for safe movements. This adds to the footprint of the site. Additionally, such 

an expansion would have required the total acquisition of Hunt Playground (about 6 acres in 

size); a 4(f) impact. 

Due to the large number of relocations that would be required and the acquisition of Hunt 

Playground, expansion into the Detroit neighborhood east of the railroad tracks and south of 

Eight Mile Road was not a feasible and prudent alternative. 

Preferred Alternative – Historic and Recreational Resources 

Avoidance of Section 4(f) resources was managed in the Preferred Alternative with the 

exception of the Michigan Box Company/Spranger Wire Wheel Corporation site. 

6.5.3 Statement of No Prudent and Feasible Alternatives 

Based on the avoidance alternatives analyzed above for the Michigan Box Company/Spranger 

Wire Wheel Corporation, there are no prudent and feasible alternatives to the use of Section 

4(f) land. There are unique problems and unusual factors involved in the use of alternatives 

that avoid these properties. The cost, social, economic, and environmental impacts, and 

community disruption resulting from such alternatives reaches extraordinary magnitudes. 

6.6 Measures to Minimize Harm 

A number of measures to minimize harm apply to all sites. Prior to construction, MDOT will 

establish a permanent record of the history and current conditions of sites determined to be 

eligible for the National Register of Historic Places in conjunction with the SHPO. This 

consultation will also guide the appropriate level of detail of the documentation. MDOT will 

provide original copies of the documentation with photos to the SHPO and appropriate local 

archives designated by the SHPO. MDOT will also work with the SHPO to develop context 

sensitive design measures near historic sites (see signed Memorandum of Agreement [MOA] in 

Appendix C). 

6.6.1 Michigan/General Box Company (Spranger/Detroit Wire Wheel Corporation) 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. Alternative 4, the Composite Alternative, where three railroads are 

consolidated at the Livernois-Junction Yard and the CN/Moterm terminal is improved/expanded 

was created to further reduce impacts in the Livernois-Junction area compared to Alternative 3. 

Alternative 4 required approximately 120 fewer acres at the Livernois-Junction Yard than 

Alternative 3. But, even with this minimized alternative, the Michigan/General Box Company 

(Spranger/Detroit Wire Wheel Corporation) was required to meet the future intermodal capacity 

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

6 - 21

This National Register eligible resource (see Section 6.3) is affected by the Preferred 

Alternative. Harm will be mitigated by establishing a permanent record of the history and 

current conditions of this site in accordance with the MOA in Appendix C. As a modification 

of Alternative 4, the Preferred Alternative has the same land needs on the north side of the 

Livernois-Junction Yard that include removing this resource. 

6.6.2 6332 John Kronk 

The house at 6332 John Kronk currently faces the existing rail yard. A wall along the edge of the 

Livernois-Junction Yard will be built that would block the current view of rail activity under all 

build alternatives. The active mainline tracks through the yard are those nearest to Kronk. Train 

volumes on these tracks will substantially increase from about 30 to 60 under No Action 

conditions. Intermodal expansion could add up to another 12 train passbys. The wall is required 

for security purposes and to buffer the adjacent community, including 6332 Kronk, from the 

increasing rail activity. 

This resource is not used by the Preferred Alternative. Coordination with the SHPO in the 

design of the wall and accompanying landscaping will minimize harm to this resource. 

6.6.3 Federal Screw Works Factory 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. But, even with this minimized acquisition area, the Federal Screw 

Works Factory would have been required to meet the future intermodal needs of Alternative 3. 

This resource is not used by the Preferred Alternative. 

6.6.4 Markey House 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. With this minimized acquisition area, the Markey House is not 

required. However, the demolition of the Federal Screw Works Factory across the street under 

Alternative 3 would have resulted in an adverse visual effect to a historic resource as defined by 

Section 106 and would result in a use of a protected resource. 

This resource is not used by the Preferred Alternative because the Federal Screw Works 

Factory will not be removed by the Preferred Alternative. 

6.6.5 Tomms House 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. With this minimized acquisition area, the Tomms House is not 

required. However, the demolition of the Federal Screw Works Factory across the street under 

Alternative 3 would have resulted in an adverse visual effect to a historic resource as defined by 

Section 106 and would result in a use of a protected resource. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

6 - 22

This resource is not used by the Preferred Alternative because the Federal Screw Works 

Factory will not be removed by the Preferred Alternative. 

6.6.6 Michigan Central Railroad Bridge Deck 

Alternative 2 Improve/Expand the existing terminal at CP/Expressway would have 

used/adversely affected the Michigan Central Railroad Bridge Deck because railroad tracks 

would have been added on it. Minimizing the acquisition area required for an 

improved/expanded terminal would still require alteration of the bridge deck under Alternative 2 

only. 

This resource is not used by the Preferred Alternative. 

6.6.7 Michigan State Fairgrounds 

Alternative 2 Improve/Expand the existing terminals and Alternative 4, the Composite 

Alternative, where three railroads were to be consolidated at the Livernois-Junction Yard and the 

CN/Moterm terminal was to be improved/expanded at the Michigan State Fairgrounds would 

both have required land from the State Fairgrounds. Because no alternatives to expanding the 

CN/Moterm terminal without using the Fairgrounds were feasible and practical, efforts were 

made to minimize the impact on the Fairgrounds property. This area is labeled as “Railroad Lot” 

on Fairgrounds’ maps. No active public or private recreation areas would have been taken. The 

land that would be used at the Fairgrounds property is currently leased for the parking of new 

automotive vehicles prior to shipment. Prior to this use, the area in question was used as a private 

racetrack, part of CN/Moterm’s intermodal facility, and as a private softball complex. 

In an effort to minimize impacts, the area for expansion of the CN/Moterm terminal was reduced 

to approximately 35 acres from 50 acres. Coordination occurred with the Fairgrounds 

management on where to place the terminal expansion, how to design the terminal, and how to 

mitigate impacts sensitive to the Fairground’s needs, including replacement parking needed 

during the annual State Fair. 

This resource is not used by the Preferred Alternative. The need for land at the Fairgrounds 

ended when CN elected not to participate in terminal expansion under the DIFT Project. 

6.7 Coordination 

Effects of the proposed action, the alternatives considered, and the proposed measures to 

minimize harm have been reviewed by and developed in consultation with the SHPO, and 

discussed with property owners (all of whom have been contacted in the course of the analysis) 

and the official having jurisdiction over the State Fairgrounds. FHWA will provide information 

to the Advisory Council on Historic Preservation for their review and comment. MDOT has 

conducted extensive owner interviews to complete the historic property inventory and held the 

following meetings, to which the public was invited: 

• July 11, 2002 – LASED Youth Center. (Total attendance 50.) Purpose: To introduce the 

Environmental Impact Statement process. 

• August 15, 2002 – DIFT Information Office, 2722 Livernois Avenue. (Total attendance 

20). Purpose: To discuss how to improve the appearance of the west side of Livernois 

Avenue at the yard entrance. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

6 - 23

• February 24, 25, 26, and 27, 2003 – The Community House, Edison Oakland Public 

School Academy, MDOT Detroit Transportation Service Center, and LASED Youth 

Center. (Total attendance 110.) Purpose: To discuss Illustrative Alternatives. 

• September 15, 16, 17, and 18, 2003 – The Holiday Inn in Grandmont, Edison Oakland 

Public School Academy, Michigan Conference of Teamsters Welfare Fund, and 

Dearborn P.D. Training Room. (Total attendance 310.) Purpose: To discuss Practical 

Alternatives. 

• March 29, 30, 31, and April 1, 2004 - The Michigan State Fairgrounds, The Holiday Inn 

in Grandmont, IBEW Local 22, and LASED Youth Center. (Total attendance 400.) 

Purpose: To discuss Practical Alternatives. 

Two scoping meetings were conducted – September 19, 2002 and June 4, 2003. The first scoping 

meeting included a bus tour of the area around the Livernois-Junction Yard/CP Expressway 

terminal. The second scoping meeting was held after the number of action alternatives increased 

from two to three to include the Improve/Expand Alternative. Each scoping meeting included a 

public comment period. 

In addition to the public meetings, the DIFT Local Advisory Council was formed of community 

representatives. It met 30 times between June 2002 and October 2004, inclusive. Each meeting 

was open to the public and provided for public comment. A tour was conducted for the public of 

the areas around intermodal terminals in Southwest Detroit and Melvindale as part of the July 11, 

2002 public meeting. Another tour was conducted of Chicago intermodal terminals on July 16, 

2002. Local Advisory Council members were invited to participate in March 2003 of a tour of 

Detroit area intermodal terminals. 

The public engagement process also involved many small group/one-on-one meetings requested 

by the public or set up by MDOT. 

Historic resources were not raised as a concern by the public at these meetings. Several people 

who attended the March 29, 2004 meeting at the Michigan State Fairgrounds commented that 

they would like to see the current leased parking/unused areas at the Fairgrounds converted into a 

metro park. 

Coordination was ongoing with the General Manager of the Michigan State Fairgrounds. 

Meetings with the General Manager occurred on at least a half-dozen occasions from the fall of 

2003 until August 2004 (refer to Page A-11 of the DEIS). 

Public hearings were held after publication and distribution of the Draft EIS/Draft Section 4(f) 

Evaluation. 

• June 13, 14, 15 and 16, 2005 - LASED Youth Center, IBEW Local 22, the Holiday Inn in 

Grandmont, and the Michigan State Fairgrounds. (Total attendance 290.) 

The public hearings provided an overview of the study and allowed participants the opportunity 

to comment either on a comment form or to a court reporter. The DEIS was distributed to the 

appropriate federal, state, and local agencies, and was made available for public review and 

comment for 60 days after the public hearing. Historic resources were not raised as a concern by 

the public at these hearings.
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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6.8 Section 4(f) Conclusion 

Based on the above considerations, there is no feasible and prudent alternative to the use of the 

Michigan/General Box Company (Spranger/Detroit Wire Wheel Corporation) at 7175 Clayton 

Street, Detroit. The proposed action includes all possible planning to minimize harm resulting 

from such use. An updated Memorandum of Agreement outlining mitigation for these properties 

is included in Appendix C. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 1

SECTION 7

AGENCY COORDINATION AND PUBLIC MEETINGS

This section provides an overview of the public and agency input that was vital to the 

development of the alternatives, the analysis of impacts, the selection of the Preferred Alternative 

and the measures to minimize harm that have been developed to mitigate project impacts. This 

section includes: early coordination; the public meetings conducted during the course of the 

project that led to the public hearing, including the results of interviews with individuals and 

groups with project interests in each terminal area; environmental justice and Title VI; 

coordination with Native American groups; comments received from the public at the public 

hearing and during the comment period and the responses to them; and, the comments of 

agencies and other entities and responses to them. 

7.1 Agency Coordination

Scoping meetings were held September 19, 2002 and June 4, 2003 in Detroit for agencies and 

local entities. Prior to the meeting a scoping packet was mailed to those invited. A listing of 

those invited, those who attended and those who responded to scoping materials was in Appendix 

A of the DEIS. 

7.2 Public Meetings 

Engagement of the public in preparing the Draft Environmental Impact Statement involved a 

series of meetings. Each included mailings to between 5,000 and 25,000 residences and 

businesses – the mailings increased as the alternatives expanded in number to include terminal 

sites at CP/Expressway, CP/Oak and CN/Moterm as well as the Livernois-Junction Yard. From 

the outset, the mailings, as well as all printed literature available at public meetings, were 

provided in English, Spanish and Arabic. Spanish and Arabic translators were available at each 

public meeting. The meeting format used was both Public Forum and a combination of Public 

Forum and Town Hall meeting. The public meetings are as follows: 

• July 11, 2002 – LASED Youth Center. (Total attendance 50.) Purpose: To introduce the 

Environmental Impact Statement process. 

• August 15, 2002 – DIFT Information Office, 2722 Livernois Avenue. (Total attendance 

20). Purpose: To discuss how to improve the appearance of the west side of Livernois 

Avenue at the yard entrance. Open May 2002 to May 2003. 

• February 24, 25, 26, and 27, 2003 – The Community House, Edison Oakland Public 

School Academy, MDOT Detroit Transportation Service Center, and LASED Youth 

Center. (Total attendance 110.) Purpose: To discuss Illustrative Alternatives. 

• September 15, 16, 17, and 18, 2003 – The Holiday Inn in Grandmont, Edison Oakland 

Public School Academy, Michigan Conference of Teamsters Welfare Fund, and 

Dearborn P.D. Training Room. (Total attendance 310.) Purpose: To discuss Practical 

Alternatives. 

• March 29, 30, 31, and April 1, 2004 - the Michigan State Fairgrounds, the Holiday Inn in 

Grandmont, IBEW Local 22, and LASED Youth Center. (Total attendance 400.) 

Purpose: To discuss Practical Alternatives. 

Two scoping meetings were conducted – September 19, 2002 and June 4, 2003. The first scoping 

meeting included a bus tour of the area around the Livernois-Junction Yard/CP Expressway 

terminal. The second scoping meeting was held after the number of alternatives increased to 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 2

include the improving/expanding existing intermodal terminals in addition to the No Action and 

Consolidate options. Each scoping meeting included a public comment period. 

In addition to this series of public meetings, the DIFT Local Advisory Council was formed of 

community representatives. It met 30 times from June 2002 to and including October 2004. 

Each meeting was opened to the public and included a public comment period. Local Advisory 

Council members, and others, participated in the August 2002 tour of intermodal facilities in 

Chicago (59th Street, Corwith and Willow Springs terminals); as well as the March, 2003 tour of 

Detroit area intermodal terminals. The public at large was provided the means to tour the areas 

around intermodal terminals in Southwest Detroit and Melvindale as part of the July 11, 2002 

public meeting. Another tour was conducted of Chicago’s intermodal terminals on July 16, 2002. 

The public engagement process involved many small group/one-on-one meetings requested by 

the public or set up by MDOT. It also provided a Web site and 800 number to access information 

at any time. 

7.2.1 Interview Process 

One component of the community inventory effort was an outreach/interview process that 

contacted the various populations involved in this analysis to define issues/services/facilities 

serving these groups. More than half of the 110+ individuals/groups contacted participated in the 

interviews. The following summarizes the results of those discussions. 

Overall, the strongest characteristics of the terminal area communities are their resiliency, ethnic 

diversity, local shopping districts, and residential neighborhoods. However, each community is 

not without its share of challenges. The infrastructure is also in need of repair, and new strategies 

are needed to retrofit land uses, while preventing deterioration of neighborhoods. The housing 

stock dates back to the early 1900s. The areas’ lack of suitable housing has sparked a 

revitalization of older housing. 

The residents of each terminal area are neighbors with industry and heavy freight traffic. The 

history of each community has always involved industry. This industrial history has left a legacy 

of the mixture of incompatible land uses. Many buildings that once provided economic security 

to area residents are now vacant. As a result, many of the owner-occupants of residential units 

are not resistive of a move, as determined by interviews. 

Two of the three terminal areas have experienced continued decline as has the City of Detroit 

itself. Recent data indicate the City of Detroit has lost an additional 40,000 people between 2000 

and 2003 putting its current population at 911,000, the number of people in Detroit around the 

time of World War I. Nevertheless, southwest Detroit and the Livernois-Junction Yard terminal 

area have experienced a resurgence. This has resulted in many new locally-owned businesses. 

They range from family-owned bakeries to large-scale manufacturing operations. Evidenced by 

the amount of renovated storefront businesses, homes, and “new” commercial development along 

the main thoroughfare of W. Vernor Highway, it is clear that the community is revitalized. 

Community cohesion is a concern here and in the two other terminal areas. 

Livernois-Junction/CP Expressway Terminal Area 

Over two dozen groups/individuals in the Livernois-Junction/CP Expressway terminal area were 

interviewed (Table 7-1). The most-frequently cited community facilities are schools and places 

of worship. Important organizations mentioned include the Arab Community Center for 

Economic and Social Services (ACCESS), Community Health and Social Services (CHASS), 

Detroit Hispanic Development Corporation (DHDC), LA SED, Latino Family Services, and 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 3

Mexicantown Community Development Corporation. Social groups mentioned are the Puerto 

Rican Club, the Yemen Social Club and Kemeny Recreation Center. 

Issues of interest include the need for education (including English as a second language), jobs 

and job training, and personal security. A number of groups cited health care, housing and 

sustaining the area’s revitalization (both housing and commercial development, including small 

business development) as key concerns. The continued importance of W. Vernor Avenue as a 

neighborhood commercial corridor was mentioned as a matter of importance. And, replicating 

that success on Michigan Avenue was cited. 

Projects in the area that are emerging include the Riverfront Revitalization and Reuse of Tiger 

Stadium, the Mercado/Welcome Center at the Ambassador Bridge Gateway, the housing 

revitalization near Roberts Avenue in East Dearborn, and many smaller housing and commercial 

projects. 

Traffic, especially heavy-duty truck traffic in the area, was often mentioned as a concern. So are 

the related environmental issues, particularly pollution and its relationship to asthma. The latter 

is of concern because many people in the terminal area have little or no means to pay for health 

care/medications. 

CP/Oak Terminal Area 

 

Four groups/individuals were interviewed to discuss community facilities and services in the 

CP/Oak terminal area (Table 7-2). Here, too, places of worship were cited as key 

institutions/facilities. Others noted include the North Rosedale Community House and O’Shea 

Recreation Center. Key service programs are Head Start as well as the Police Athletic League. 

Issues of significance include stabilizing housing in the area, addressing crime and trash. Traffic 

was also cited as an issue. The rail yard and related activities were not singled-out as a particular 

concern. It was noted the railroads have the potential of being a good neighbor in the community. 

CN/Moterm Terminal Area 

Eight groups/individuals were interviewed in the CN/Moterm terminal area (Table 7-3). Again, the 

places of worship and schools (including the seven schools in Ferndale) were frequently cited as 

important community facilities. Additional facilities of community importance are the Kulick and 

Tindal Centers in Ferndale, the State Fairgrounds, and housing centers (like the Hilton Apartments) 

that serve the elderly and those of lower income. Frequently mentioned in the interviews was the 

Chaldean community in terms of its facilities and services as well as the energy offered in 

revitalizing the housing and business activity in the area around Seven and Eight Mile Roads, 

Woodward and John R. 

Issues of importance in this terminal area are sustaining the development, along Woodward 

Avenue in both Ferndale and Detroit and revitalizing Eight Mile Road. Concerns about railroad 

terminal operations, including possible expansion of the CN/Moterm rail yard, include: the 

blocking by trains of traffic movements including school buses and emergency equipment; noise; 

air pollution; increased truck traffic; depreciation of housing values; and, the threat to desired 

developments at the State Fairgrounds (i.e., a Huron Metro Park) and at the southeast corner of 

the intersection of Woodward Avenue and Eight Mile Road. The potential of the expanded 

intermodal terminal thwarting those desired projects was stressed as a concern. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 4

Other Organizations 

A dozen groups/individuals not specifically focused on a terminal area were also interviewed to 

provide an overview of social/cultural issues of key populations in general (Table 7-4). When 

addressing the German, Irish and Polish communities, the clear indication is the decline of 

concentration of these ethnic groups and the services/facilities/organizations, including places of 

worship, to support them. A review of Table 4-12 echoes that trend as all non-minority ethnic 

groups, except the Arab community, declined in the Detroit Urbanized Area in the 1990s. Most 

significant among these are the Irish, German and Polish. This trend is repeated, but with less 

significant declines, in each terminal area. 

Views by non-terminal area-based groups that are focused on African American issues, indicate 

concern about jobs, job training, crime, and health care/substance abuse. Those non-terminal 

groups that are focused on Hispanic issues also view employment, education, crime and health 

care as key concerns. 

7.3 Coordination with Native American Groups 

Scoping meetings were held September 19, 2002 and June 4, 2003 in Detroit for agencies and 

local entities. The Saginaw Chippewa Indian Tribe was invited to both meetings by U.S. mail. 

Prior to the meetings a scoping packet was mailed to those invited. A listing of those invited, 

those who attended and those who responded to scoping materials was in Appendix A of the 

DEIS. The Ziibiwing Cultural Society, The Saginaw Chippewa Indian Tribe responded to the 

invitation and scoping materials September 9, 2002 by letter, stating “at this time we do not have 

any information concerning the presence of any Indian Traditional Cultural Properties, Sacred 

Sites, or other Significant Properties to the projected project area(s). This is not to say that such a 

site may not exist, just that this office does not have any available information of the area(s) at 

this time.” 

The Saginaw Chippewa Indian Tribe was sent a copy of the DEIS.
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 5

Table 7-1 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

African American Arab Arab Arab H

Key Population 

Group 

Issue Original United Citizens of SW Detroit Dr. Nabeel Abraham, Professor @ Henry Ford Community College Congress of Arab Organizations of Michigan ACCESS CHASS - Co

and So

FACILITIES WHICH SERVE THE KEY POPULATION: 

Kemeny Recreation Center, parks, schools, Neighborhood City Hall, roller rink, 30+ churches in the area. There is a Critical Care Unit in the city of Lincoln Park that serves area residents. 

Two Yemen social clubs in the area, the mosque, retail district and schools (Star and Salina). 

None Recorded The mosque at 9945 W. Vernor, 

Star Academy on Lonyo, new housing near Roberts, new/expanded school for all grades on Wyoming. 

Schools, churrecreation cendistricts. 

SERVICES FOR THE KEY POPULATION: 

Kemeny programs for seniors. ACCESS, various mosques 

around Detroit. Dearborn is enclave of Arab community. In Salina's school area, there is Yemeni population. 

The National Conference for Community and Justice provides cooperation between law enforcement and the community and helps build bridges within the community 

ACCESS with its many services, e.g., academic enrichment, family literacy, youth recreation, career development, community health and research, social services, employment training, cultural arts. 

Increase in paupper respiratSoccer leagueHedwig Park and Otis. RomParks may be of the trucks. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Unemployment for young people in their 20s and 30s. 

Physical improvements to the area. Jobs for the Yememi community, Homeland security and prejudicial treatment. 

None Recorded Area is very special in that it is 

the magnet for working-class Arabs worldwide to begin a new/better life. Revitalization is ongoing with new/refurbished homes, expanding schools to serve the growing population. It is not to be negatively impacted by traffic, and negative environmental factors, like air pollution. 

Air quality, aspollution. IncLoss of housimobility due ttraffic. Threadevelopment. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Commercial development to support residents in the area. Park development. 

The area is vibrant. Economic opportunities for those who are energetic. 

More commercial and residential development 

Community will continue to grow. It must not be set back by poorly designed projects. 

Building of neHealth and So(CHASS) facipatient flow. 

OTHER ISSUES: Environmental issues that affect 

the area. The possibility of truck traffic causing more problems with prostitution along Fort Street between Schaeffer and Outer Drive. Jobs that could result because many young men and women or young families need employment. 

None Recorded None Recorded The community only has three 

access routes: Lonyo, Wyoming and Vernor/Dix. Closing Lonyo, more trucks on Wyoming and drainage problems on Vernor/Dix do not serve the Arab community well. 

Fort St. Businbeing developcommercial njobs need to b
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 6

Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Hispanic Hispanic Hispanic Hispanic Native Ame

Group 

Issue Dominican Consulate LA SED MCDC ROCA Eternal Church American Indian 

Social Serv

FACILITIES WHICH SERVE THE KEY POPULATION: 

Evangelical churches in SW Detroit and St. Stephens on Central. 

Churches, LA SED, other nonprofits in the area. Cesar Chavez schools, Latino Family Services, W. Vernor 

Commercial district, Michigan Avenue commercial district, MCDC District, Bagley Housing, BUOY 3, Roberto Clemente Recreation Center, Bowen Branch library, all Catholic churches especially the churches with schools. 

Religious institutions that assist community residents with a variety of services. 

The Native Americaon Lawndale serves American communithroughout the Metrarea. 

SERVICES FOR THE KEY POPULATION: 

Immigration processing has become much more difficult since 9/11. 

Senior transportation to services, information referral, food and friendship programs. 

Housing Development, jobs and economic development in the business district that employ people from neighborhoods. Economic development in the commercial districts. 

Religious counseling, job referral, housing opportunities. 

Health screenings, sabuse counseling, ymentoring programspiritual gatherings. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Lack of education and training. English is an impediment amongst Dominicans. 

Senior transportation and translation 

Crime and the need for education. 

Lack of education; learning English can be problematic for some. Employment opportunities are bad. Lack of available housing in this neighborhood forces people to locate outside the city of Detroit. 

Uses of the land relDetroit Intermodal FTerminal Project. Cthe American Indian spiritual connection land and does not wfurther damaged by uses. Pollution of ththat will be entering 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The lack of jobs with decent pay. 

Access to services and jobs. Locally-owned businesses, a 

strong workforce and the new image of Southwest Detroit as a stable and growing community. 

Concern about jobs. Improvements to th

community such as access to health carecleanliness and resprights of people. 

OTHER ISSUES: None Recorded Does not see the benefits of the 

DIFT because the railroad terminal will eventually deteriorate. If nothing happens to fix the terminal it will only get worse. The truck traffic throughout the community affects the structural integrity of the businesses and homes. 

None Recorded Need for jobs. None Recorded 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 7

Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Polish Other Other Other 

Group 

Issue St. Stephens Bagley Housing Bridging Communities Casa Maria 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches including St. Stephens which has a school K-8 of mostly Hispanic children. Twenty years ago the school was primarily Polish. 

Churches and schools and the different social services agencies in the community. 

Bridging Communities directly serves the elderly. 

None Reported 

SERVICES FOR THE KEY POPULATION: 

Religious counseling and education. 

Housing rehabilitation and new home construction for low-income families and seniors. 

Outreach programs to the elderly by pairing young and elderly people as well as making neighborhood improvements. 

Casa Maria provides after-school programs for children as well as prescription/medication referral. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The Polish community has gone down in number because they are an aging population. Transportation for the seniors is an issue. 

Environmental issues and traffic congestion. The DRTP proposal that would take trucks off the roads and put them directly on the freeway. 

Violence (in all forms). Need to improve transportation, health care and support services, like the Family Independence Agency. 

Housing and health care needs. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The Polish community is no longer large in parish. 

Rehabilitation of the MC Depot because it affects the business environment of the area. 

Strong commercial and residential revitalization by newly-arrived people which improves the city’s tax base and the overall quality of life in the neighborhoods. 

Grant funding is not available 

OTHER ISSUES: The church is located on Central 

Avenue which has a lot of heavy truck traffic. 

SW Detroit is continuing to grow and any plans should take into account the changing nature of the community's ethnic diversity and the needs that result from that. 

None Recorded None Recorded 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 8

Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Other Other Other Other Other 

Group 

Issue 

Family Support 

Team of 

SW Detroit 

Holy Redeemer Catholic 

Church Hope Evangelical Ministries Hubbard Richard CDC Michigan Avenu

Associati

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches, schools and shopping along Vernor. Revitalization of Michigan Avenue shopping. 

None Recorded Churches, schools. Grocery stores, restaurants 

along Bagley and Vernor, Saint Anne’s Church, Webster school, Roberto Clemente Center, Matrix Theatre, Bagley Housing, MCDC, BUOY 3 Center. 

Schools, churches, BGirls Club, 

SERVICES FOR THE KEY POPULATION: 

Various non-profits in the community that provide social services for families. 

Churches and schools. Church-provided services None Recorded Habitat for Humani

planning to build 60 West Grand Blvd. aMichigan Avenue. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

DIFT's affect on mobility and travel for area residents as a result of more trucks in the community. Physical separation caused by the DIFT. 

Increased rates of asthma attacks. The dust from the Livernois Yard can be mitigated by paving, but still concerned about the emissions from increased number of trucks. Underpasses need to be clean and well lit. The idea of the railroads being good corporate citizens is key. 

Lack of employment opportunities, inability to attract major food chains or large-scale development. 

The Detroit River Tunnel and Ambassador Bridge plans, air quality, deterioration of infrastructure, health care, immigration and English as a second language, housing and employment. 

Trucks, prostitutionair pollution. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

New housing developments. Safer and sustainable communities. A family-orientated community. 

The presence of the railroads and the infusion investment should help the community improve itself. Southwest Detroit can be a national model for neighborhood redevelopment that demonstrates a post-industrial community that rebounds to become a place where residents both live and work. Southwest Detroit is a place of cultural strength, a place of diversity. 

Dismal outlook unless some major project comes to the area. 

Small business and commercial growth, more population growth, sustainable neighborhood not dependent upon big box, franchise-owned companies. 

More Hispanic busithe future. A FamilStore, (mini K-martlighting for 2 1⁄2 milLivernois and WyomMichigan. Buffers industry and commu

OTHER ISSUES: DIFT may pose some 

threat to potential developers and investments. 

None Recorded The area is suffering from lack 

of economic investment. The DIFT facility would positively affect the area with support businesses. 

Increase in trade and commerce will offer benefits to the region, but to the smaller community there will be little rewards. The community views the DIFT as some sort of exploitation. 

There should be a pinfrastructure improstandards need to be to accommodate the trucking in the area
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 9

Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Other Other Other Other 

Group 

Issue Our Lady Queen Of Angels Patton Park Southwest Detroit Business Association Southwest Detro

Improvement Associ

FACILITIES WHICH SERVE THE KEY POPULATION: 

CVS, auto repair stores, grocery stores and the Michigan Avenue Corridor. 

Patton Park, Romanowski Park, Holy Cross Cemetery. 

Churches both Catholic and Pentecostal, parks, MCDC, commercial areas, the W. Vernor Commercial District, schools (Public, Private, and Charter). 

Churches and schools, as wmany non-profits, that provservices. The restaurants iare important because they local economic and culturabenefits. 

SERVICES FOR THE KEY POPULATION: 

Churches, the Boys and Girls Club. 

None Recorded Restaurants and stores that provide 

unique cultural goods for the Hispanic community as well as the churches that provide Mass and services in Spanish. 

Agencies such as LA SEDLatino Family Services anDocument preparation, job services, crisis interventionreferral. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The biggest issues in the community deal primarily with trash, break-ins to private property and prostitution on Michigan Avenue. For the Hispanics, immigration and naturalization is a continuing problem, as well as employment opportunities. 

Environmental impacts associated with the DIFT. Loss of community base. SW Detroit has been a dumping ground for industry. The continued dumping will destroy the revitalization that is taking place in the neighborhoods. Social/economic disservice to the minorities in the community. Closing Lonyo by the DIFT Project will impact the people who attend the soccer league games at the parks. Increased truck traffic will hamper residents ability to travel through the community. Loss of housing on Lawndale, Trenton and Cabot. 

Air Quality. A healthy environment promotes stability for community residents. The dust at the Livernois Yard is a problem. Central and Livernois connectivity. Clark Park renovation (Ice Rink). 

Unemployment, there is no be found in the immediate People have to travel outsito seek employment. Afforrent. Health care is a big prbecause many Hispanics aruninsured in the area. Asthother types of ailments. Ena second language. As it rethe DIFT, community’s coare the projected numbers and the routes of traffic. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Renovation of housing and reestablishment of business along Michigan Avenue. This growth is primarily due to the Hispanic population. Every so often, a new business emerges along Michigan Avenue. 

SW Detroit has an integrated community where people get along, raise families in ethnically diverse neighborhoods, supported by schools, community activities. 

The "bow-tie" development at Vernor/Livernois. The Mexicantown Welcome Center and major rehabilitation of four buildings along W. Vernor. The Greenway network and links connecting different parts of the community. New businesses opening in the community. Soccer leagues continue to grow in popularity. 

Community growth. The aattractive because it’s knowHispanic neighborhood ana sense of comfort for Hispthe area. 

OTHER ISSUES: The Polish community has 

migrated out of the area. 

Area is a dumping ground because of industry. Why don't they put the DIFT in Auburn Hills? 

The cultural diversity of the area must be protected as well as the retention of young people. Must protect jobs that can be potentially lost due to the creation of a DIFT. 

None Reported 

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

7 - 10

Table 7-2 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews CP/Oak Terminal Area 

Key Population Other Other Other 

Group 

Issue

Far Northwest Neighborhood 

City Hall 

Grandmont Rosedale 

Development Corporation Southfield/Jeffries Business Association We

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches along the Southfield Freeway. 

The North Rosedale Community House, The North Rosedale Park and a variety of churches. 

River Rouge Park and the Churches on Southfield. The O'She

American Warren an

SERVICES FOR THE KEY POPULATION: 

None Recorded Headstart Programs and a PAL 

(Police Athletic League) football team that practices and plays in Stobel Park. 

The churches are very active with the community and provide social activities. Sunday at church is an all-day event; parishioners arrive for services in the morning and stay until the late afternoon. 

The large organizatiobreakfast fcommunittrash pick-

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

None Recorded The lack of city services and 

the quality of the schools. Air quality. The Southfield Freeway, which is one of the busiest freeways in the nation. High incidents of asthma. 

Traffic. Trucks using the intermodal facility travel through residential areas to get to the yard. A truck-only road for the CP/Oak facility would benefit the community and should be designed so that local business can use it as well. A good sound wall is needed as is better lighting in the yard. 

Crime, ligtrash. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Stabilization of housing and the increase of housing and commercial development. 

A stable neighborhood with room to grow. If the city services are improved, the community will grow. 

This area has never deteriorated and the city is constantly updating and fixing the area with grants. Main concern is traffic. 

Neighborhis to get thto maintain moving in

OTHER ISSUES: There are no parks, schools or public 

places around the CP/Oak terminal area. 

Traffic is bad on both the residential and city streets. 

The railroad can be a good neighbor to the community. The rail yard should complement the neighborhood and be aesthetically pleasing. 

A stable annationalitiare moving 

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

7 - 11

Table 7-3 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

CN/Moterm Terminal Area 

Key Population Arab Arab Other 

Group 

Issue Chaldean Sacred Heart Arab American & Chaldean Council Bagley Association Eight Mile B

FACILITIES WHICH SERVE THE KEY POPULATION: 

Facilities that serve the Chaldean community between Woodward Avenue and John R. on Seven Mile -- ethnic grocery stores, education centers and restaurants that are Chaldean owned and operated. 

Arab American & Chaldean Council. 

Shopping along Eight Mile, Seven Mile and Livernois. The schools, churches and homes of the area are all important considerations. 

The many storefront busChaldean community aloopportunities to the areaCommunity Center. 

SERVICES FOR THE KEY POPULATION: 

A variety of services ranging from transition and immigration to education and business entrepreneurial efforts. 

Employment training, teen programs, behavioral health, dental care, youth center and computer lab. 

The church-based programs including those for abused women. 

Those provided by schooCenter. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Many Chaldean families are moving back to Detroit and specifically that area between Seven and Eight Mile Roads, Woodward and John R. 

Revitalization of Chaldean Town. 

Empty buildings along Wyoming, Livernois, and Seven Mile. The reduction of city services because of budgetary issues. 

Deterioration of the roadvolumes and an ongoing conditions may result in base. The projected DIFanything that appears to 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Chaldeans develop businesses that can support industry. 

Cooperation from city, state, and federal governments to improve infrastructure. Want the area to be shopper friendly and a destination, like Greek Town. 

Small business development along Livernois. Small-scale industrial or manufacturing businesses. 

The proposed Outlet Cencorner of Woodward and Woodward bridge downresidential development

OTHER ISSUES: None Recorded Funding of Chaldean programs. None Recorded The diversity of the area
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 12

Table 7-3 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

CN/Moterm Terminal Area 

Key Population Other Other Other 

Group 

Issue Ferndale Public Schools Ferndale Chamber of Commerce Hazel Park 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Seven public schools and one charter school in the City of Ferndale. The closest school to the railroad terminal in Ferndale is Wilson Elementary. 

The commercial and residential developments along Eight Mile Road. Woodward and Nine Mile are the life blood of the city. 

None Recorded Strong resi

along EighSeven MileFairgroundrecreationaindustrial aof the CN/MHilton ApaThe Chalderesidential community awarded to 

SERVICES FOR THE KEY POPULATION: 

Education. None Recorded The Chaldean community is growing in both 

residential and business areas. The Chaldeans have a social club called the Eastern Palace, which is located on the west side of John R. There are some new businesses off Nine Mile on John R on the west side that are Chaldean owned and operated. 

Various cosummer, WNational H

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The school system has bus routes that cross railroad tracks at the following locations: Hilton Rd., Nine Mile, Camborne and Woodward Heights. Trains that block traffic are a problem because they cause delays for commuters and school buses. 

The main issue of concern related to the DIFT is the possible affects of loss of housing or businesses if the expansion were to happen inside the city of Ferndale. 

Webster School is very close to the DIFT expansion area in the Fairgrounds. 

The main ipollution (atraffic, depdevelopmetax base. Iaffected beRoad. AffeFairgroundthe GovernHomeland lack of funappearance and Detroitthe DIFT p

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Loading and unloading of trains should be restricted during school hours. School buses are assigned to use Eight and Ten Mile Roads to avoid the tracks as much as possible. 

The City of Ferndale is land locked to the point that the only way to build new is to knock down old. 

The city is 100% developed. Any efforts to construct in Hazel Park would involve redevelopment. The race track is the only "open" area that can be redeveloped. However, it is privately owned and the owners can do what they feel is necessary for their business. 

Huron Met

OTHER ISSUES: None Recorded There are no ethnic enclaves in 

the City of Ferndale. 

Against the DIFT because it is incompatible with the residential character of the area and it will have an adverse environmental impact on the western residential areas of Hazel Park. 

Ferndale is backgroundthat celebraattend annu

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

7 - 13

Table 7-4 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population African American African American African American 

Group 

Issue Alkebulan Village Black Family Development Operation Get Down D

FACILITIES WHICH SERVE THE KEY POPULATION: 

4 H Club, Sub-Center None Recorded Every Organization The 

throGerChr“CalocMil

SERVICES FOR THE KEY POPULATION: 

Sub-Center provides youth programs, and after-school programs. Operation Get Down provides emergency services and shelter for people that have drug abuse problems. 

None Recorded Wide range of Issues Thi

Aid witme

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

There needs to be more jobs and job training. Utility companies have to have more sensitivity in the winter months, helping people pay their bills and not shutting off their water and heat. 

The low number of Spanish-speaking officers in the police departments and the lack of Latino representation on City Council. 

Substance abuse, education and mental health 

The from for the 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

If jobs and job training do not improve, the community will die. 

Include Spanish in curriculum. Teaching Spanish will open up Central and South America to create a radical economic impact on Detroit. 

Jobs, health issues, social services. The 

OTHER ISSUES: None Recorded Crime. Change from enforcement as 

solution to looking at societal solutions, such as unemployment and poverty. Change the city charter to balance between Mayor and City Council. Redistrict so that Latinos get fair representation on City Council. 

None Recorded The 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

7 - 14

Table 7-4 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population German Hispanic Hispanic 

Group 

Issue

German-American 

Cultural Center 

Local Historian Osvaldo Rivera on Detroit 

Puerto Rican Community 

Wayne State University Chicano/ 

Boricua Studies Program 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Carpathia Club The Catholic and Evangelical churches/schools. 

The Puerto Rican Club. 

Mexicantown Center, LA SED, Puerto Rican Club and churches in the area. 

GOTo

SERVICES FOR THE KEY POPULATION: 

None Reported Non-profits like LA SED and Latino Family 

Services. 

Access to education and family counseling T

coal

Jub

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

None Reported Education/crime/lack of political candidates 

running for office. 

Lack of employment. Recruitment by gangs to sell drugs due to a lack of employment. Lack of affordable health care 

Irco

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The German population is getting smaller because there are fewer Germans migrating into southeastern Michigan. 

Puerto Rican leaders don't see themselves in positions of authority mainly because in the Hispanic community they are the minority. 

Leadership of Latino leaders. Better Latino organizations 

N

OTHER ISSUES: None Recorded Non-profits like LA SED and Latino Family 

Services. 

None Recorded T

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

7 - 15

Table 7-4 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population Polish Polish Other 

Group 

Issue Hamtramck Historical Commission The Polish Weekly Covenant House 

FACILITIES WHICH SERVE THE KEY POPULATION: 

St. Florian Church. Polish American Veteran's Hall. 

Catholic churches throughout the area like St. Florian, St. Peter and Paul, St. Hedwig. The city of Hamtramck is a Polish enclave. 

Human Service agencies, parks, recreation centers, schools and churches.

Deimed

SERVICES FOR THE KEY POPULATION: 

The Polish National Alliance. This Polish newspaper provides 

information on events and services. Restaurants, churches and PAV clubs in Hamtramck all provide socialization for the Polish people. 

Covenant House provides students with tutoring and shelter. 

ThspAsHmlea

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Concern about the future of Hamtramck. Older community of Polish people who 

need health care. 

Young people are dropping out of school at a high rate and trying to find work. This population is not being served at no fault of its own. The resources are just not being provided. Obtaining identification is sometimes a challenge for young people. 

OnremMmco

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The Polish community and organizations coming together to promote their culture.

Continued efforts to promote and preserve Polish culture 

Rehabilitation of homes and businesses is happening everyday on Vernor now on Michigan Ave. and to a lesser extent on Fort St. 

Mbu

OTHER ISSUES: None Recorded None Recorded Does not know much about the DIFT 

only heard the negatives of pollution and increased truck traffic. Wants to see what the potential benefits for the community in terms of jobs and organization of truck traffic. 

No

 Source: The Corradino Group of Michigan, Inc. 
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7.4 Public Hearing, Public Comments, and Responses 

Public Hearings were held June 13, 14, 15 and 16, 2005, at LASED Youth Center, IBEW 

Local 22, The Holiday Inn in Grandmont, and The Michigan State Fairgrounds, respectively. 

Total attendance at the meetings was approximately 290 persons. The numbers of comments 

received are as follows: 

• 34, 23, 15, and 43 people, respectively over the four nights, speaking at the public 

hearing or giving oral comments to court recorders (total 115 persons – note that some 

were repeat speakers over the four hearings) 

• 28 comment forms turned in at the hearings or received before the close of comments 

on March 12, 2004. 

• Numerous signatures on petitions 

• 10 e-mails 

• 13 comments recorded onto the web site 

• 26 letters from individuals, groups, or public entities 

• 12 letters from resource agencies and elected officials 

Full copies of all comments (including the public hearing transcript) can be reviewed at the 

locations listed in the preface to this FEIS. 

The following pages represent comments received from the general public and a number of 

organizations. They are organized by category in Table 7-5. 

It should be noted that a commenter often had multiple comments or issues. 

Comments received from agencies and government entities are treated separately in Appendix 

F. 
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Table 7-5 

Comment Categories Used to Sort Comments 

Process Impacts - security 

Purpose and Need Impacts - stormwater 

Alternatives Impacts - stress 

Impacts Impacts - trucks 

Impacts - 4(f) Impacts - tax base loss 

Impacts - AQ Impacts - tax increase 

Impacts - benefits Impacts - wetlands 

Impacts - business Mitigation - air 

Impacts - community cohesion Mitigation - buffer 

Impacts - construction Mitigation - Community Benefits Agreement 

Impacts - cultural resources Mitigation - construction 

Impacts - cumulative Mitigation - context sensitive design 

Impacts - disproportionate Mitigation - general 

Impacts - economic analysis Mitigation - jobs 

Impacts - EJ Mitigation - lighting 

Impacts - farmland Mitigation - limits to intermodal 

Impacts - general Mitigation - noise 

Impacts - hazmat Mitigation - noise monitoring 

Impacts - insurance costs Mitigation - sustainable 

Impacts - interviews Mitigation - SW Detroit Plan 

Impacts - land use Mitigation - truck routes 

Impacts - noise Mitigation - vibration 

Impacts - parks Public Involvement - ads 

Impacts - property values Public Involvement - cultural outreach 

Impacts - quality of life Public Involvement - governance 

Impacts - relocation Public Involvement - meetings 
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Response Category Generalized Comment Response 

Process 

I'm concerned about a method of presenting alternatives that occurred in the DIFT. First MDOT presents alternatives that outrage the community, then it comes back with revisions that capture a small amount of the community input. 

MDOT has worked throughout the project understand community input (see Section community input has shaped alternatives and the selection of the Preferred Alternatincludes a number of features suggested members. 

Process - areas of controversy 

Section 1.4 "Areas of Controversy" on page 1-66 provides only one sentence on potential negative impacts. More information and detail is necessary for evaluation purposes. 

More information and detail are provided iof this FEIS. 

Process - legal sufficiency 

The DEIS does not meet the requirements of NEPA. 

This document has been reviewed for legthe Federal Highway Administration and wmeeting the requirements of the NEPA pr

Purpose and Need The DIFT Project is not needed. 

The Purpose and Need for the project are documented in Section 2. 

Purpose and Need - beneficiaries 

The railroads will be the only beneficiaries of the DIFT. 

While the railroads will benefit, so will the stronger economy. And, jobs will be genedefined in Section 4.5. 

Purpose and Need - beneficiaries The DIFT Project is only needed by the railroads. 

The Purpose and Need for the project are documented in Section 2. The railroads wfinancially to the Preferred Alternative in pbenefits that will accrue to them. MDOT aalso invest because there is a public need public benefit from this project. 

Purpose and Need - capacity & demand 

The data presented demonstrate that the DIFT is actually designed to create additional intermodal capacity demand, rather than to satisfy it. 

Capacity and demand are separate. The Alternative will not "create" demand, but r

Purpose and Need - capacity/efficiency 

The data in the DEIS indicate there is a need to provide additional terminal capacity, but it is unclear how capacity efficiency was calculated for the Detroit region. The Purpose and Needs Section could be improved by including a more complete explanation of how capacity targets were determined. 

There are systemic reasons for the demanintermodal freight movement: the price of congestion of highways with limited ability capacity and the cost competitiveness of sThe limitation on existing terminal capacity Detroit Area is documented in Section 2.2to improve existing rail yards are covered Increasing the size of the terminals and mimprovements to the tracks in the area ouincrease efficiency as well as terminal cap
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Response Category Generalized Comment Response 

Purpose and Need - capacity/efficiency - 1998 

The DEIS states that the maximum possible capacity at the four existing terminals is only 345,000 lifts. Yet on the preceding page it notes that 400,000 lifts were accommodated in Detroit in 1998. 

The historical trends in intermodal activity them are recognized in the EIS. Modern slogistics, just-in-time manufacturing and dleaner organizations have revolutionized tand the military transport freight. There is additional capacity by the 2030 planning hlimitation on existing terminal capacity is dSection 2.2. There are systemic reasons for intermodal freight movement: the price congestion of highways with limited ability capacity and the cost competitiveness of sTerminals can operate over capacity but, not do so efficiently. 

Purpose and Need - capacity efficiency - Alternative 2 

It is unclear how only expansion alternatives can meet the purpose and need and why improvements at the existing yards in the area would not improve efficiency and also capacity. 

The alternatives noted in the comment on existing rail yards are covered in Section 3option is Alternative 2. But, increasing the terminals, in response to the forecast dema more efficient intermodal system. Improtracks in the area will also increase efficieimprovements do not increase terminal ca

Purpose and Need - capacity efficiency - intermodal growth 

The DEIS notes that the capacity of intermodal terminals in the region is about 345,000 annual lifts, but fails to explain how the region handled 400,000 lifts in 1998. How can we be sure that the economic and security concerns that caused the decline will not affect intermodal trains in the future?

The limitation on existing terminal capacity in Section 3. Regional and national econohave softened causing a reduction, for a tdemand for all kinds of transportation, incintermodal. Reputable economic forecastIH Global Insight, see the freight demand significantly as the economy rebounds in 2beyond. Terminals can operate over caparoads, do not do so efficiently. 

Purpose and Need - capacity efficiency - paving 

It has not been shown how capacity can be increased by means other than expansion. 

A terminal needs more space to gain morSome limited increase in efficiency on the terminal space, by paving or stacking, concan be gained. 

Purpose and Need - containers/trade 

What is the net import/export effect resulting from each of the Action Alternatives vs. No Action? 

The economic impact analysis presented is based on historical trends which have inglobalization of the economy for years. Tindicates the Preferred Alternative will creincrease of 4,500 jobs in the state of Mich
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Response Category Generalized Comment Response 

Purpose and Need - containers/trade - railroads 

How do you justify the taking of public land needed for recreation to help a foreign corporation, which pays no local taxes, to distribute foreign manufactured products that have cost us our jobs? 

The railroads will contribute financially to tAlternative in proportion to the benefits thathem. MDOT and FHWA will also invest ba public need for and a public benefit from No public land for recreation will be acquiPreferred Alternative. 

Purpose and Need - forecasts 

It appears that the number of lifts for 2025 may be overstated, suggesting the Commodity Flow Model is inaccurate, and that the analysis unfairly rates no expansion alternatives poorly and favors expansion alternatives. 

This FEIS states the position of the railroareviewed the forecasts of the Action Alternindicated that the high end of each 2025 frange are optimistic, but reasonably so, in horizon year being more than 20 years in expansion in response to the forecasts dothe project's purpose and need. 

Purpose and Need - forecasts - external improvements 

Lift projections for the Action Alternatives rely on unsubstantiated assumptions that improvements 

will also be made to intermodal terminals and rail connections in Chicago, Indiana and Ohio. No evidence is provided suggesting that improvements at facilities in Indiana and Ohio are even being considered, much less planned. 

These assumptions about intermodal expplaces, like Chicago or Indianapolis, consincrease, intermodal demand in the DetroAdditionally, intermodal improvements in Congoing as part of a program known as Cdemonstrating the assumptions are realist

Purpose and Need - forecasts - factors 

The Commodity Flow Model apparently does not account for all relevant factors. Twenty factors in the National Cooperative Highway Research Report were identified as impacting intermodal freight demand, yet the CFM report notes only several were considered. Also, there is no evidence that specific recent changes in the economy were considered, most notably the decline of the manufacturing sector, especially the auto industry in the Detroit area. 

The intermodal model accounts for the facdirectly affecting conditions in the Detroit adegree of explanation of these factors on activity in the Detroit area is included in thFlow Model Technical Report. 

Purpose and Need - forecasts - manufacturing economic analysis 

The expansion of intermodal facilities is unnecessary given the changes in the State's economy since this project was first proposed. 

The economic impact analysis, presented is based on historical trends which include globalization of the economy for years. Tindicates the Preferred Alternative will creincrease of 4,500 jobs in the state of Mich

Purpose and Need - forecasts - intermodal growth 

Manufacturing methods have changed, bringing suppliers closer. That lessens the need to ship parts great distances. 

There are systemic reasons for the demanintermodal freight movement: the price of congestion of highways with limited ability capacity and the cost competitiveness of s
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Response Category Generalized Comment Response 

Purpose and Need - forecasts - model 

The stated need for an expanded intermodal facility is based on old studies. 

An intermodal freight forecasting model wspecifically for this study. The limitation oterminal capacity is documented in Sectioare systemic reasons for the demand for ifreight movement: the price of fuel, the cohighways with limited ability to improve cacost competitiveness of shipping by rail. 

Purpose and Need - forecasts - need 

Why does the DEIS use optimistic lift numbers to show need? 

The EIS uses high forecasts for the Action and a low forecast for No Action to determsignificant level of impacts. The forecasts appropriate. 

Purpose and Need - forecasts - previous 

Why is it assumed that earlier demand and capacity numbers developed by Mercer Management and Consulting are incorrect? 

The explanation of the earlier forecasts is Section 2.2. As noted in Section 2.2.1, thin 1994 for 2002 was exceeded by the actactivity in 2002 in the Detroit area. 

Purpose and Need - forecasts - recent growth 

Why does the DEIS use preliminary results from January 2004 to illustrate demand versus capacity? Is more recent data available? 

The DEIS was written in the spring of 200systemic reasons for the demand for intermovement: the price of fuel, the congestiwith limited ability to improve capacity and competitiveness of shipping by rail. 

Purpose and Need - forecasts - terminal size 

It is stated that railroads have consolidated intermodal services and that smaller facilities have been eliminated from consideration for the DIFT. The Local Advisory Council tour in Chicago visited the 59th Street CSX intermodal facility of 150 acres and the BNSF Corwith facility of 300 acres and was informed that the latter, which is the size of the existing Livernois-Junction Yard, is the largest intermodal facility in Chicago. 

The statement in the EIS is correct. In the nine intermodal terminals in existence in 1consolidated to six, while intermodal activ

Purpose and Need - forecasts - trends 

The claim that substantial new capacity is needed relies on the study from 1994 that projects significant increases in intermodal needs in the region. In fact intermodal activity has fallen from a high of 400,000 lifts in 1998 to a level in 2002 that is almost as low as it was in 1994. 

The historical trends in intermodal activity them are recognized in the EIS. Modern slogistics, just-in-time manufacturing and dleaner organizations have revolutionized tand the military transport freight. There is additional capacity by the 2030 planning hlimitation on existing terminal capacity is dSection 2.2. There are systemic reasons for intermodal freight movement: the price congestion of highways with limited ability capacity and the cost competitiveness of s
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Response Category Generalized Comment Response 

Purpose and Need - industry support 

What assurances or letters of support have been submitted by industry, particularly the automotive manufacturing sector? 

DaimlerChrysler has stated it values intermtransportation as an efficient, cost effectivtruck and rail modes and believes it will plSoutheastern Michigan transportation netwsupports the completion of the EIS and wiresults. Ford has indicated, while it uses service, its “Overall business plan for interis projected to remain flat into the foreseeNS, CN and CP all signed the MemoranduUnderstanding supporting the DIFT study address the future intermodal needs of the CSX has joined these railroads in signing Development Plan Agreement, the succesMemorandum of Understanding. 

Purpose and Need - industry support - purpose and need 

Section 1, page 166, of the DEIS identifies areas of 

controversy. One controversy is omitted, the project's Purpose and Need. General Motors and Daimler Chrysler have been silent, while Ford has publicly stated they have no needs for incremental 

intermodal services. It appears the purpose of the project is to create intermodal demand or capture demand, rather than response to demand. The demand versus capacity forecast on page 26 makes the assumption that NS intermodal will consolidate at Livernois-Junction, and does not include Oakwood, Delray or Willow Run in its calculations of capacity, although that capacity is in use. 

Relatively few substantive comments havon purpose and need, and it has not been area of controversy. Intermodal demand "created." The Delray and Willow Run facSouthern may be consolidated to the LiveYard area under the Preferred Alternative

Purpose and Need - mass transit 

The money to be spent on the DIFT should go toward funding mass transit. 

Comment acknowledged. MDOT and FHmass transportation as well as highway animprovements, usually through different fu

Purpose and Need - national defense 

The DEIS does not fully explain the statement that the DIFT is needed for national defense. 

The military handles a component of its lointermodal operations. Specific data are cnot available for public dissemination. 

Alternative 

An action alternative is favored at LivernoisJunction Yard that provides paving, buffering, access gates at Wyoming and Livernois, and that 

addresses intermodal needs of the State. 

Comment acknowledged. The Preferred Aeach of these and meets the project purpo

Alternative - for MDOT is urged to proceed with the DIFT. Comment acknowledged. Alternative - noninduced Alternatives considered should address both induced and non-induced growth. 

The project purpose and need anticipates project meets that anticipated growth. Thiinduced and non-induced growth for Secti
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Response Category Generalized Comment Response 

Alternative 2 Alternative 2 is not sufficient. 

The Preferred Alternative provides greatecapacity than Alternative 2. 

Alternative 2 - against Alternative 2, Option A is not favored. Comment acknowledged. Alternative 2 - for Alternative 2 is favored. Comment acknowledged. Alternative 3 

The DIFT is strongly supported, but not at the Fairgrounds. 

Comment acknowledged. The Preferred Anot affect the Moterm Terminal and CN hanot planning to expand the Moterm facility future. 

Alternative 3 - against 

Alternative 3, or any other consolidation of regional intermodal activity at a single location in Southwest Detroit that provides little or no direct benefit to the City of Detroit or neighborhoods surrounding the Yard, while imposing numerous traffic, environmental health, safety, social and economic costs, is opposed. 

This comment reflects an early City resoluresolution passed July 27, 2005, the Detrourged MDOT to invest in the Livernois-Junconsistent with the needs of the surroundiand found the No Action Alternative to be 

Alternative 3 - for Put the DIFT at the Livernois-Junction Yard. Comment acknowledged. Alternative 3 - for - no danger 

Alternative 3 is favored as it does not pose danger to the surrounding area. Comment acknowledged. 

Alternative 4 Alternative 4 is the best alternative. 

A modified Alternative 4 is the Preferred Asmaller, as the CP/Expressway operation expansion of the CN/Moterm Terminal into Fairgrounds is no longer part of the alternPreferred Alternative will be associated wgovernance structure. See the Pre-DevelAgreement in Appendix F. 

Alternative 4 - modified 

Alternative 4 is the favored alternative, but with some modifications. 

Comment acknowledged. A modification has been identified as the Preferred Alternplan has been included in Section 5 to adcommunity issues. 

Alternative 4 - modified - trucks 

Alternative 4 is favored if truck traffic issues are addressed. 

A modification of Alternative 4 has been idPreferred Alternative and a plan has been Section 5 to address specific community ialternative removes many trucks each weneighborhood streets to access the truck northwest corner of the intersection of CeKronk. 

Alternatives 3 & 4 

Alternatives 3 and 4 are the best. The area is already in disrepair. Comment acknowledged. 

Alternative CN Moterm There should be no expansion at CN Moterm. 

Comment acknowledged. The Preferred Anot affect the Moterm Terminal and CN hanot planning to expand the Moterm facility future. . 
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Response Category Generalized Comment Response 

Alternative - Community Improvement Plan A community improvement plan is favored. 

Section 3.2.3 notes that the Communities Alternative Community Improvement Plan interchanges that cannot be built and fails project purpose and need, which requires Nonetheless, a number of elements of the balance of access between Wyoming and Avenues; closing the Waterman entranceaccommodation of transit (commuter rail); circulation; Central rebuilt below grade; refrom neighborhood streets; a buffer arounfacility; job creation for residents) have, in components of the Preferred Alternative bthrough a series of actions included in Seactions will be done in partnership with the 

Alternative - concurrence The selected alternatives should be carried forward. Comment acknowledged. Alternative - CP Expressway - against 

The CP Expressway Terminal should not be included as part of the DIFT. 

The CP Expressway operations were sus2004 and are not to resume as part of the Alternative. There is no provision for CP/anywhere in the Preferred Alternative. 

Alternative - CP Oak issues 

There is concern with issues associated with CP Oak such as access, safety and residential relocation. 

The Preferred Alternative does not involve the CP/Oak Terminal. The CP intermodawill be transferred to an expanded LivernoYard as part of the Preferred Alternative. mean the Oak Terminal will close or shrinwill not be the location of CP's intermodal operations. 

Alternative - Dix gate A Dix/Waterman gate is unacceptable. 

The Preferred Alternative does not include Dix/Waterman gate in the long-range futuat the Livernois-Junction Yard. 

Alternative - Fairgrounds - against 

The Fairgrounds should not be used as part of the DIFT. 

The Preferred Alternative does not affect tTerminal or Fairgrounds and CN has indicplanning to expand at the Moterm facility ifuture. 

Alternative - Fairgrounds - footprint 

Did the acreage of the Fairgrounds proposed for use in the DIFT change? 

The CN Moterm terminal and/or Fairgrounpart of the Preferred Alternative. 

Alternative - Fairgrounds - for 

Locating the DIFT at the Fairgrounds is better than locating it at its expanded Ferndale site. 

Expansion in Ferndale was not considerenoted in Section 3.4.1. But this terminal (be expanded as part of the DIFT Preferre
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Response Category Generalized Comment Response 

Alternative - Intermodal - water A water component should be added to the DIFT. 

There is virtually no opportunity to depend intermodal shipments due to conditions of transportation and weather conditions affeand St. Lawrence Seaway. According to tLakes/St. Lawrence Seaway Study (Army Engineers, February 2003) only five percecontainer vessel capacity can be accommlocks of the St. Lawrence Seaway. 

Alternative - Livernois-Junction - against expansion 

Our community vehemently opposes the expansion of the Livernois-Junction Yard. 

Comment acknowledged. The Preferred Aexpands the Livernois-Junction Yard by 1reduction of over200 acres from Alternativin the DEIS. 

Alternative - No Action - against The No Action Alternative is unacceptable. 

The No Action Alternative must be carried DEIS stage and is not the Preferred AlternPreferred Alternative does not involve the Terminal and eliminates the closed CP/Exoperation. It is also associated with a serimprovements. 

Alternative - No Action - against - government needed 

The No Action Alternative is unacceptable and government involvement is needed. 

No Action is not the Preferred Alternative. MDOT and FHWA have chosen a Preferrewhich includes governance and funding sthese partners to implement the DIFT Pro

Alternative - No Action - against DIFT 

The No Action Alternative is favored and the DIFT is opposed in any form. 

Comment acknowledged. But, No Action with the official plans of the City of Detroit Dearborn and does not meet the project pneed. 

Alternative - No Action - against private action Private expansion activities are opposed. 

The proposed project has been developed government can act in partnership with thimprove the efficiency of goods movemen

Alternative - No Action - citizen opposition There is strong citizen opposition to the DIFT. 

Comment acknowledged. But, support is the Detroit City Council, and in the Southwarea where the Preferred Alternative will limplemented. 

Alternative - No Action - for 

Intermodal expansion in Detroit and/or Dearborn is opposed. 

Comment acknowledged. However, No Ameet the project purpose and need. And, Alternative improves conditions at and aroreduces truck volumes in neighborhoods, community improvements. 
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Response Category Generalized Comment Response 

Alternative - No Action - for - against pollution 

A No Action Alternative is favored to limit pollution and noise. 

Comment acknowledged. However, No Aimprove conditions at or around rail yardsvolumes or routes, or stimulate community physically or economically. The Preferred offers more protections for air, water and than the No Action Alternative. 

Alternative - No Action - for - Ferndale The DIFT is firmly opposed in Ferndale. 

The Preferred Alternative does not affect tTerminal in Ferndale or the Fairgrounds in 

Alternative - No Action - modified - no expansion 

The No Action Alternative with improvements is preferred, not expansion at existing terminals. 

The Preferred Alternative provides a serieimprovements. Without some expansion oJunction Yard, per the Preferred Alternativwill make their own decisions regarding imexisting terminals and the cities of Detroit will make their own decisions in providing managing truck traffic, reducing pollution, the community cohesion. This is particulawhen considering that none of the roads aLivernois-Junction Yard are state roads. 

Alternative - No Action - modified Alt 4 

The Preferred Alternative is opposed due to its community impacts. 

The Preferred Alternative brings a governand community improvements (see Sectioby the Southwest Detroit community, the DCouncil, the railroads, MDOT and the FedAdministration. 

Alternative - No Action - modified Alt 4 

There is a need for community benefits and rail yard improvements. 

The Preferred Alternative brings a governand community improvements as well as improvements (see Section 5) endorsed bSouthwest Detroit community, the Detroit the railroads, MDOT and the Federal HighAdministration. 

Alternative - No Action - modified Alt 2 

There should be no rail yard expansion. Existing terminals should be improved and existing impacts should be mitigated. 

Rail yard expansion is needed to meet the purpose and need. The Preferred Alternatgovernance structure and community impwell as rail yard improvements (see Sectioby the Southwest Detroit community, the DCouncil, the railroads, MDOT and the FedAdministration. 
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Response Category Generalized Comment Response 

Alternative - No Action - modify on site 

Livernois-Junction Yard should not be expanded. Improvements should be made to reduce the existing impacts on the neighborhood. 

Rail yard expansion is needed to meet the purpose and need. The Preferred Alternatgovernance structure and community impwell as rail yard improvements (see Sectioby the Southwest Detroit community, the DCouncil, the railroads, MDOT and the FedAdministration. 

Alternative - No Action - modify on site 

Livernois-Junction Yard should not be expanded. Improvements should be made within the current boundaries. 

Rail yard expansion is needed to meet the purpose and need. The Preferred Alternatgovernance structure and community impwell as rail yard improvements (see Sectioby the Southwest Detroit community, the DCouncil, the railroads, MDOT and the FedAdministration. 

Alternative - Other locations 

It appears that other locations outside the City of Detroit were not considered. 

Sections 3.2.1 and 3.2.2 consider these afind they do not meet the project's purpos

Alternative - Other locations - Detroit 

It appears that other areas within Detroit were not considered. 

Both Greenfield and existing sites with raiincluding brownfields were extensively ex(Sections 3.2.1 and 3.2.2). 

Alternative - Other locations - Moterm Why wasn't CN's facility in Port Huron considered? 

The analysis was limited to Wayne County areas. 

Alternative - Other locations - outside SE Michigan 

Why not consider locations in other areas of Michigan? 

The purpose and need of the project addrneeds of Southeast Michigan around Way

Alternative - Other locations - Willow Run 

Additional government review is needed if Willow Run is used. 

The Preferred Alternative allows the intermthe Willow Run Terminal to be transferred Livernois-Junction Yard. 

Alternative - Preferred 

Why is MDOT unable to state a preferred alternative? 

National Environmental Policy Act (NEPAregulations allow a Preferred Alternative tat the Public Hearing, or after all commenhave been received and considered. MDOmany comments on the DEIS and considedecision-making process before identifyinAlternative. 

Alternative - Preferred - CN 

CN's position makes Alternative 4 the Preferred Alternative by default. 

The Preferred Alternative is a modification 4, which does not include expansion of thTerminal. 

Alternative - Preferred - CSX 

You're continuing with this process when you clearly admit that CSX has refused to sign the Memorandum of Understanding (MOU) and CN does not intend to relocate to Livernois-Junction Yard. 

Each Class I railroad was afforded the opparticipate. CSX deemed more informatiobefore it signed an MOU which was includNonetheless, this FEIS includes the next vwhich is called the Pre-Development Plan (Appendix F). It has been signed by all fo
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Response Category Generalized Comment Response 

Alternative - Preferred - site plans 

Will there be a need to alter the site plans to meet the requirements of the railroads? 

Yes. The alterations are included as part Alternative. 

Alternative - public ownership 

I support public ownership of transportation infrastructure. 

Comment acknowledged. The anticipated structure is outlined in the Pre-DevelopmeAgreement found in Appendix F. 

Alternative - RR regulation 

Public money should not be spent to make the railroads provide community improvement. 

Without some expansion of the Livernois-per the Preferred Alternative, the railroads own decisions regarding improvements to terminals and the cities of Detroit and Deatheir own decisions regarding safe roads, traffic, reducing pollution, and improving thThe Preferred Alternative provides a serieimprovements. 

Alternative - RR regulation actions 

The condition at the Junction Yard is simply untenable. The roads have deteriorated, the viaducts are unkempt, trucks are out of control on every neighborhood street and the sewers back-up. 

The Preferred Alternative provides a mechthe yards, manage truck traffic, and reducsediment that clogs sewers. 

Alternative - RR regulation off site 

The users of the intermodal facilities should pay to maintain them. 

Independent of partnership with the goveractions of the railroads are based on busiand a series of federal laws that often supregulation. The state has virtually no reguand the railroads are under no obligation toutside their business interests, while opeconsistently with the guiding federal regul

Alternative - transit A light rail transit alternative should be included. 

Improved transit does not improve intermomovement or address the project purpose Nonetheless, the Preferred Alternative acAMTRAK and commuter rail operations thLivernois-Junction Yard. 

Alternative - transit - Lonyo 

The DEIS fails to consider options such as improving public transit and non-motorized transportation. 

The Preferred Alternative considers local motorized facilities and proposals (Section 4.2.3). It includes a buffer around the LiveYard plus improvements to Central Avenuimprove pedestrian movements and their of auto drivers/occupants. Field counts on different years during and after school houpedestrian activity and no bicycle use. 

Alternative - two entry points 

There must be only two points for truck ingress and egress at the Livernois-Junction Yard, one on the east one on the west with equal distribution between the two. 

The Preferred Alternative will have two enLivernois and two on Wyoming. The traffishown in Table 4-9, with 2,410 trips (two-wWyoming and 1,390 on Livernois. 
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Response Category Generalized Comment Response 

Alternative - two entry points - modified Alternatives 3 and 4 

With Alternatives 3 and 4, which gates serve the south part of the yard and which serve the north part of the yard? 

Alternatives 3 and 4 had options with diffeWyoming and Livernois. The Preferred Alttwo yard entry points on Livernois and two Gate 2 off Livernois serves the portion of tthe east-west mainline tracks. 

Alternative - use of tax dollars 

Tax money should not go toward subsidizing the railroads and trucking companies. 

MDOT evaluates needs statewide and maregarding the best use of its public investmmaintain and improve the transportation nDIFT Project is an opportunity to support tcompetitiveness of Southeast Michigan anThe financing package to implement the Dcontinuing negotiation, but its basic elemecontained in the Pre-Development Plan AAppendix F and includes investment by thgovernment, the railroads, and MDOT. Thalone would not take such a broad approaintermodal services and creating the assoeffects without such a partnership. 

Alternative - use of tax dollars - CN 

If someone is going to offer you money, you'd probably accept the money. I think that's CN's position. 

The Preferred Alternative does not affect tTerminal. CN has indicated it does not wasubsidized in terms of terminal developmesupport track improvements that benefit a

Alternative - use of tax dollars - livability 

Tax dollars spent on transportation should be spent on things that make our community more livable. 

The Preferred Alternative includes a serieimprovements through partnership among Federal Highway Administration and the r

Alternative - use of tax dollars - other uses There are better uses of public money. 

MDOT's use of its financial resources is fotransportation-related improvements. 

Alternative - use of tax dollars - other uses/benefits 

This money and funds for this study should have been directed towards addressing the concerns of the people. 

The Preferred Alternative includes a serieimprovements through partnership among Federal Highway Administration and the r

Alternative - use of tax dollars - source What entity will fund the improvements? 

MDOT evaluates needs statewide and maregarding the best use of its public investmmaintain and improve the transportation nDIFT Project is an opportunity to support tcompetitiveness of Southeast Michigan anThe financing package to implement the Dcontinuing negotiation, but its basic elemecontained in the Pre-Development Plan AAppendix F and includes funding by the fegovernment, the railroads, and MDOT. 
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Response Category Generalized Comment Response 

Alternative - use of tax dollars - state? 

Is state funding required in order to get the federal funding? Would it necessarily require state funding? 

The financing package to implement the Dcontinuing negotiation, but its basic elemecontained in the Pre-Development Plan Aincluded in Appendix F and includes fundifederal government, the state of Michigan railroads. 

Alternative - use of tax dollars 

Why should the state fund projects for the railroads that come at the expense of the residents in the area? 

MDOT evaluates needs statewide and maregarding the best use of its public investmmaintain and improve the transportation nDIFT Project is an opportunity to support tcompetitiveness of Southeast Michigan anThe railroads alone would not improve intservices and create the associated positiveffects without a partnership with governm

Alternative Evaluation 

An environmental issues and risk assessment should cover existing conditions to identify causes of poor conditions so that development can occur without adding to the existing (air quality) burden. 

The environmental analysis indicates few consequences are expected and, where ebe minimized through mitigation. Additionhas been added on existing and future air conditions including particulate matter (Se

Alternative Evaluation - AQ & health 

The draft EIS fails to provide an overview of the current air quality and health status in the area. 

The DEIS reported official MDEQ data avtime the DEIS was published in May 2005includes updated information in Section 4information is available on MDEQ's websihttp://www.michigan.gov/deq including the Air Quality Report. 

Alternative Evaluation - AQ data More air quality data are needed. 

The DEIS reported official MDEQ data avtime the DEIS was published in May 2005carries updated information in Section 4.8information is available on MDEQ's websihttp://www.michigan.gov/deq and particulaAnnual Air Quality Report. 

Alternative Evaluation - AQ data Moterm 

The air quality data from the Oak Park monitoring location does not include enough data and is not an accurate representation for the area being considered. 

Oak Park is the nearest monitoring locatioCN/Moterm Terminal. As noted in Section not collected at this monitor for NOx and P

data from the Linwood and Wyoming monbest available." 

Alternative Evaluation - existing AQ 

The adjacent neighborhoods have already been identified by air quality officials as the most heavily polluted in Southeastern Michigan. Comment acknowledged. 

Alternative Evaluation - existing AQ - particulates 

The DEIS didn't take into consideration that our community has one of the highest particulate matter levels in the country. 

Section 4.8.4 states the area is non-attain

and specifically addresses PM2.5. 
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Response Category Generalized Comment Response 

Alternative Evaluation - graphics 

A more complete graphic of community facilities is 

needed for the CP/Oak Terminal. 

Figure 4-12c shows no community facilitiethere are none, as noted at the bottom of 

Alternative Evaluation - graphics corrections 

There are errors in the Community Facilities Map, Figure 4-10A. 

Comment acknowledged. Corrections havThe new figure number is 4-12a. 

Alternative Evaluation - infrastructure 

MDOT, the City and Wayne County consistently ignored improvements in the infrastructure around the yard including streets, sewers, viaducts and the perimeter of the yard. 

The proposed project is sponsored by MDThe nearest facilities for which MDOT has are I-75, Michigan Avenue, and I-94. Othunder local jurisdiction as are sewers and the project MDOT will take over Central Aconstruct its viaduct under the Livernois-J

Alternative Evaluation - old data 

The DEIS used old data in regards to the community. 

This FEIS has been changed where spechave been noted by commenters and whefield review have indicated a need. It has updated where new data are available. 

Alternative Evaluation - culturally unique SW Detroit is a unique cultural destination. Comment acknowledged. Alternative Evaluation - growing area 

From a policy perspective, taking homes and businesses from the only growing area of the City of Detroit does not make sense. 

Expansion of intermodal facilities was conlocations (Alternative 2). The Preferred Asmaller version of the Alternative 4 as shoPotential residential property acquisitions reduced from a maximum of 83 under Altewith the Preferred Alternative. And, businacquisitions have been reduced from 64 t

Alternative Evaluation - growing area - investment 

The state has already invested substantially in Southwest Detroit and the DIFT can build on that investment. 

MDOT believes the Preferred Alternative appropriate investment in SW Detroit to suredevelopment and growth. 

Alternative Evaluation - transportation burden 

Southwest Detroit is already disproportionately burdened by transportation and freight. 

There has been no substantial change in transportation infrastructure of Southwest years, following completion of the interstathis context, the "disproportionate impact" present at least that long. Prior to the inteindustry grew around the railroads and hodeveloped for the industrial workers. Any consequences of this development have naddressed largely because of lack of goveresources. 

Impacts 

The DEIS analyzes environmental impacts at the state or regional level only and does not properly consider impacts at the local level. 

Impacts at the local level are analyzed anthroughout Section 4. 

Impacts - 4(f) 

There's a reasonable and prudent alternative to use of the State Fairgrounds. 

The Preferred Alternative includes taking Fairgrounds/ CN Moterm Terminal. 
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Response Category Generalized Comment Response 

Impacts - AQ 

It is not only important to not make sure air quality does not worsen, but take measures to ensure that it improves. 

The air quality analysis uses EPA-approvesoftware and finds that, primarily through regulatory actions, air quality will substanthowever, the increase in intermodal activiby the project will increase activity at the LJunction Yard with the Preferred Alternativcovers air quality. 

Impacts - AQ 2015 

Emissions information for air toxics and PM2.5 is 

only presented for 2004 and 2025. What about the intervening years? 

Interim year (2015) data, based on the animplementation schedule, are found in Se

Impacts - AQ alternatives 

Either Alternative 3 or 4 is essential in order to reduce the overall pollution. 

The Preferred Alternative has positive effepollution as described in Section 4.8. 

Impacts - AQ burden 

MDOT tries to downplay the significance of the increased air pollution by including a lengthy section on "EPA Measures to Improve Air Quality." MDOT provides modeled data showing reductions in national air pollution levels resulting from these measures. 

As a "disclosure" document, it is importanpresent information regarding the relationpollution to regulation versus the proposeanalysis also compares each Action Alternrelative to 2004, 2015 and 2030 No Action 

Impacts - AQ burden - Alt. 4 

The assumption under Alternative 4 that the increase in rail cars and trucks and the corresponding decrease in automobiles will in fact reduce pollution in the coming years is overstated and misleading. 

The air quality analysis uses EPA-approvesoftware. The decrease in air pollution defrom EPA's stricter emission standards. Amobile-source polluting land uses would bwhich means that pollution would be remoarea taken over by the terminal. The termreplaces the existing land use, and in somintense from the standpoint of air emissionexisting use. 

Impacts - AQ burden - Alt. 4 reduction 

PM10 and PM2.5 terminal burdens are much lower for Alternative 4 than 1 through 3. This appears to be reduced road and yard dust. Why is the reduction so much greater for Alternative 4 than Alternatives 2 and 3, which also would be paved at Livernois-Junction? 

The difference is a function of the terminatraffic patterns assumed under each alternAlternative 4 is a more efficient layout. Noemission factors changed for this FEIS, as were made to MOBILE6.2 and AP-42. 

Impacts - AQ burden - comparison 

The possibility that air pollution reductions will occur as a result of the EPA regulations is not a proper focus for the environmental assessment of the DIFT Project. Rather, the air quality analysis should be concerned with how each alternative measures up to the others, with or without the implementation of future EPA regulations. 

The air quality analysis uses EPA-approvemethods/software. As a "disclosure" docupresents information regarding the relationpollution to regulation versus the proposeanalysis then compares each Action Alterpollution relative to 2004, 2015 and 2030 conditions. 
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Response Category Generalized Comment Response 

Impacts - AQ burden - comparison to No Action 

MDOT omits from its Environmental Justice analysis the key finding of its air quality assessment that each Action Alternative poses significant increases in pollution emissions over the No Action Alternative. Instead MDOT, again deceptively, compares levels of pollution under DIFT to today's conditions rather than rating each alternative against the No Action. 

Action Alternative terminal burdens are coAction Conditions are in Tables 4-22a and Practical Alternatives and 4-26a for the PrAlternative (Section 4.8.4). Preferred Altepollutant burdens are compared to No Act27 and by road segment in Table 4-29. TAlternatives do not produce "significant inpollution emissions over the No Action AltSee Table 4-30 for an overall comparison Alternative. 

Impacts - AQ burden - conclusion 

The conclusion at the local terminal area, pollution is expected to decrease is misleading. It derives solely from the change in National Diesel Emission Standards and not from the decision at hand. 

Air emissions are compared to 2004 condand 2030 No Action conditions. Where emlower with the project, it is because the adactivity generates less pollution than the nuses that it replaces. 

Impacts - AQ burden - EPA regulations 

Consultants have claimed that trucks will emit less pollution as EPA regulations kick in. 

The analysis uses the EPA-approved vehfactors from MOBILE6.2, as is stated in SEPA says trucks will emit less pollution. 

Impacts - AQ burden - EPA regulations - results 

Increased air pollution that the DIFT would produce is hidden by factoring in air quality benefits associated with government regulations. Each Action Alternative increases total terminal pollution over the No Action Alternative. 

Action Alternative terminal burdens are coAction Conditions are in Tables 4-22a and Practical Alternatives and 4-26a for the PrAlternative (Section 4.8.4). Preferred Altepollutant burdens are compared to No Act27 and by road segment in Table 4-29. TAlternatives do not produce "significant inpollution emissions over the No Action AltSee Table 4-30 for an overall comparison Alternative. 

Impacts - AQ burden - explanation 

A thoughtful explanation of comparative impacts from the various different alternatives on the surrounding neighborhoods would have added value to the EIS. Comment acknowledged. 

Impacts - AQ burden - fleet replacement 

The statement that the sulfur rule in 2007, applying to on-road and off-road engines, will make them substantially cleaner is misleading because a significant number of older engines will be in use for many years. MDOT must identify the assumptions made for fleet replacement rates for various kinds of diesel powered vehicles and equipment. 

The fleet replacement assumptions were SEMCOG, and are based on vehicle registhe region. These are approved by EPA athe required EPA-approved analysis proce

Impacts - AQ burden - growth 

The DEIS states that pollutant burdens in the terminal area will go up with the consolidation and composite alternatives at 80 to 130 percent. while the No Action Alternative shows less growth. Comment acknowledged. 
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Response Category Generalized Comment Response 

Impacts - AQ burden - inputs 

The DEIS states that the pollutant burden on the 

local roadway system around the terminal will be 

slightly less than the No Action Alternative. Unstated are the basic modeling assumptions about the types, amounts and emission profiles of vehicles traveling nearby for each alternative. 

The types of vehicles are supplied by SEMvehicle registration data. Emission "profilecontained in the MOBILE6.2 emission facwith use of those vehicle fleet assumptionstated in Sections 4.8.1 and 4.8.2. 

Impacts - AQ burden - local 

The draft EIS acknowledges there will be an increased pollutant burden at Junction Yard, then fails to determine the resulting burden on the local immediate community. 

The overall comparison of air pollution in tcommunity with and without the project is 4-30. 

Impacts - AQ burden - local measurement 

While MDOT claims to have engaged in a "burden analysis," the draft EIS does not measure the burden of air pollution on anyone and instead simply estimates the total amount of various pollutants that the DIFT would produce. 

The pollutant burden analysis is consistenAir Quality Protocol shown in Appendix E. 

Impacts - AQ burden - Moterm 

The CN Moterm PM10 is going to double when this comes through. That's not true of other areas; none of them are going double like Moterm would. 

The Preferred Alternative does not affect tTerminal. CN has indicated it will not expFairgrounds. 

Impacts - AQ burden - new traffic 

If satellite businesses are coming in, you have to include the burden that those satellite businesses will bring to the community. 

The terminal area includes the previously-plus a "zone of influence" as defined in SeThe three terminal areas range in size frosquare miles and contain from 140,000 to people, according to the 2000 Census. Tair pollution generator is relocated from thimpact analysis area, pollution goes downbusinesses are expected to be relocated tlarger terminal area. Pollution associated businesses at new locations could go up oestimate would be speculative. Backgrouincreased for the analysis at one percent increase allows for the relocations and infbusinesses. 
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Response Category Generalized Comment Response 

Impacts - AQ burden - new traffic - two areas 

The fact that relocated businesses would stay in the 

area contradicts the assumption of the air quality analysis, which says that the trucks would be moved out of the area. 

The terminal area includes the previously-plus a "zone of influence" as defined in SeThe three terminal areas range in size frosquare miles and contain from 140,000 to people, according to the 2000 Census. Tair pollution generator is relocated from thimpact analysis area, pollution goes downbusinesses are expected to be relocated tlarger terminal area. Pollution associated businesses at new locations could go up oestimate would be speculative. Backgrouincreased for the analysis at one percent increase allows for the relocations and infbusinesses. 

Impacts - AQ burden - paving 

The DEIS attributes air quality improvements to the Action Alternatives. Paving the terminal areas could improve air quality without expanding the footprint of the terminal. 

The statement is true, but there is every inyards would not be paved without governminvolvement, i.e., the DIFT Project. 

Impacts - AQ burden - relative emissions 

It is not enough to roughly estimate relative emissions of the various alternatives. 

The Air Quality Protocol in Appendix E guanalysis. It was developed by MDOT in cFHWA, US EPA, MDEQ and SEMCOG. 

Impacts - AQ burden - support 

The DEIS concludes, without support, that all the air quality issues will be resolved by the implementation of the Clean Air Interstate rules and USEPA's rules requiring the upgrading of diesel engines. This analysis is flawed for multiple reasons. 

The Air Quality Impact Technical Report pextensive amount of data used to generatlink roadway pollutant burden forecasts (uemission factors), and all elements of the activity: visitor/employee traffic; truck activyard related to container delivery and pickhandling (moving containers between delitrains); locomotive idling and movement ofugitive dust from paved and unpaved yarvehicular travel on sites of businesses to bvehicular travel on streets that would closdevelopment (John Kronk and a section ofugitive dust from business sites and streebe closed. Canadian trucks are produced factories and generally meet the same emstandards as US trucks. No data are provintermodal trucks are different than other tanalysis does account for trucks traveling terminals as well as the truck trip reductiodiversion to rail. 
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Response Category Generalized Comment Response 

Impacts - AQ burden - truck increase 

It is unclear why the DEIS predicts the public roadway burden for diesel PM should go down for Alternatives 3 & 4 compared with No Action in 2025, when the number of trucks appears to increase by at least four times. 

In 2030, the number of daily trucks associPreferred Alternative, compared to the No Condition, goes up by about 700 (Table 1number of trucks does not go up four timeAction to any Action Alternative. Informatpatterns to be experienced under each altincluded in the traffic/gate descriptions in in Section 4.8, which covers the local roadThis information has been expanded upon 

Impacts - AQ burden analysis 

The burden analysis is flawed. It is based on trends derived from national standards that are not reflective of and are different from local trends. 

The burden analysis is not based on trendroadway burden emission factors assume fleet vehicle mix, which is approved by EPtraffic volumes and speeds estimated for tThe terminal pollutant burden analysis likeguidelines and emission factors, together specific to each terminal and alternative. 

Impacts - AQ burden HAPS 

A quantitative air analysis should include all hazardous air pollutants (HAPS) found in diesel exhaust. 

Mobile source air toxics (MSATs) are anawith joint U.S. EPA and FHWA guidance i

Impacts - AQ clarification NOx 

On Page 1-42 and 4-116, the wording is confusing with respect to Alternative 2's NOx emissions. The language has been clarified. 

Impacts - AQ clarification PM2.5 

The Alternative 2 narrative says PM10 would be reduced in 2025 relative to No Action, but PM2.5 would be virtually unchanged. The table shows PM2.5 would be reduced 7% over No Action. Does the narrative only pertain to the SW Detroit/E. Dearborn site? 

The narrative does not pertain only to the Detroit/East Dearborn site. The language clarified. 

Impacts - AQ comparative impacts 

The burden of proof rests with MDOT to describe the comparative impacts of the proposals versus the status quo. Well-tested research methodologies and air dispersion models are available that can be tailored to show the effect that increased terminal pollution would have on the surrounding neighborhood. 

The comparative air quality impacts were the DEIS and its technical reports in the foterminal burden and roadway link-by-link cpollutant burdens for 2004, and for Action conditions for 2015 and 2025. Tables 4-2show terminal burdens with Table 4-26a cPreferred Alternative. Tables 4-27 and 4-burdens for the roadway links in the vicinitLivernois-Junction Yard. The future year extended to 2030. (Figure 4-44 shows the 

Impacts - AQ - comparison do nothing 

The real question is how much the DIFT would increase air pollution over doing nothing. 

Terminal and roadway burden analyses (Scompare the Preferred Alternative to existconditions and No Action in 2015 and 203each of the many activities that occur. All summarized in Table 4-30. 
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Response Category Generalized Comment Response 

Impacts - AQ - comparisons 

The DEIS failed to take a hard look at a number of impacts, including air quality. The Action Alternatives would make air quality significantly worse. 

Terminal and roadway burden analyses (Scompare the Preferred Alternative to existconditions and No Action in 2015 and 203each of the many activities that occur. All summarized in Table 4-30. 

Impacts - AQ - conformity 

The Livernois-Junction Yard area in Wayne County is near the Dearborn PM2.5 monitoring site and registers some of the highest readings in the eastern US. The additional activity from this project will affect the State's ability to attain the PM2.5 standard. 

The DIFT Project has been found to be in Section 4.8.7) for PM2.5. 

Impacts - AQ - conformity - Dearborn monitor 

 With the number of lifts increasing up to four times from current levels and trucks increasing up to six times the current levels, there is concern associated with the impacts at the Dearborn monitor which is already heavily burdened with respect to PM2.5. 

The cited increases in lifts and trucks are maximum percent increases under the moAction Alternative was 132 % in lifts (Figu% in trucks (Alternative 3, compare totals and 4-3). The Preferred Alternative will hain lifts and trucks of 57 percent more than Alternative (Figure 4-10). The "net new" nwith the Preferred Alternative, compared tAlternative, is about 700 at the Livernois J(Table 1-4), as the project will relocate a ntruck generators. 

Impacts - AQ - conformity - general 

This project will need to address the general conformity requirements, if applicable. General conformity was found not to apply

Impacts - AQ - conformity - timing 

The DIFT air quality impacts should be incorporated into the SEMCOG modeling process now as a part of the decision-making process rather than after the final alternative is identified. 

The conformity procedures used for the Dconsistent with guiding laws and regulatio

Impacts - AQ - conformity - traffic congestion 

Maps in the DEIS show predicted traffic volumes exceeding a 1.00 volume to capacity ratio in several locations near the Dearborn PM2.5 monitor. That would suggest substantial congestion will occur at a number of intersections. 

The DIFT traffic analysis presented in Secdemonstrates that traffic congestion is not DIFT activities. No intersections are forecexperience congestion with the Preferred defined as a Level of Service of D or wors

Impacts - AQ - conformity determination 

Detroit's current air quality non-attainment status should be considered in the DEIS and the selection of a preferred alternative. 

The project has found to be in conformity by SEMCOG in conjunction with FHWA. 4.8.7. 

Impacts - AQ - conformity - standards 

The region faces even stricter PM2.5 standards within several years. 

The DIFT analysis is based on current lawregulations. If those change prior to projeanalysis will change. Project conformity is the 15 μg/m3 annual and 65 μg/m3 24-hou

Impacts - AQ - correction There is a typographical error on page 4-101. This change has been made. 
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Response Category Generalized Comment Response 

Impacts - AQ - Dearborn monitor values 

Regarding the spike in 2003 PM10 values at the Dearborn monitor, there evidently were false readings because the monitor was only 300 feet from the construction site of the new Salina School. 

Spikes were noted by MDEQ in their 2006 Report as resulting from construction neaAdjustments were made, as noted in Sect

Impacts - AQ - dust - existing The Livernois-Junction Yard should be paved. 

The railroads have stated they do not inteyards in the absence of government particthe DIFT Project. 

Impacts - AQ - dust - importance 

The DEIS states that road dust represents a significant part of the total PM emissions. Focusing on road dust overlooks more significant and costeffective mitigation options. 

A drive through of the neighborhood, and received at public meetings, demonstrate prevalent in the neighborhoods; it is both an air quality concern. Work by the Lake Directors Consortium reported on in a draEvidence" document prepared by SEMCOPM2.5 analysis indicates that dust control is an issue that may need further attention(Preferred Alternative) reflects the assumpterminals will be paved as part of the projeThe methodology used in calculating dust AP-42. The assumptions and calculations in Appendix A of the Air Quality Impact AnTechnical Report. 

Impacts - AQ - dust - paving Livernois Yard 

MDOT states that paving the Livernois Yard could 

reduce soil and dust, it does not show by how much. 

Pollution related to dust (PM10) will be red60 % under the Preferred Alternative, comAction at the Livernois-Junction Yard. Thand calculations are shown in Appendix A Quality Impact Analysis Technical Report

Impacts - AQ - general 

The DIFT will increase pollution and adversely impact air quality. 

Air quality has improved dramatically in thstringent regulations on automotive vehiclindustries have been implemented. Lead plummeted. Ozone values are down consEPA controls on diesel engines and diesean additional significant positive effect. SSection 4.8.2.1. 

Impacts - AQ - health 

The DEIS should include additional analysis of public health impacts. 

Possible health effects of PM2.5 and air toin Section 4.8.3. The reasons why no addof health effects will be done are stated in 

Impacts - AQ - health - asthma 

The impact of the DIFT on asthma should be considered. 

Substantially lower future PM2.5 and diesmatter (DPM) are forecast as EPA increasdiesel engines and fuel. Also, the Preferrdirects trucks away from neighborhoods abetter suited to truck traffic. 
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Response Category Generalized Comment Response 

Impacts - AQ - health - asthma - 5000 trucks 

Will the DIFT contribute to an increased incidence of asthma? 

With EPA-mandated PM2.5 and fuel contrlevels by 2030 will be approximately 37% were in 2004 at the Livernois-Junction Yathe terminal and local roadway network co

Impacts - AQ - health - asthma today 

We have the second highest asthma rate in the country. 

According to Epidemiology in Michigan 20Report (Michigan Department of Human H"Michigan needs to improve its ability to cinformation on the number of people with Michigan populations. Information on the people with asthma is not available for all (particularly young children) or subpopulaexample, Arab/Chaldean or Hispanic popuare also not available at the level of geogrwould aid in planning and conducting asthinterventions (e.g., county, city or school d

Impacts - AQ - health - background 

A large body of scientific literature links exposure to traffic and diesel exhaust to health problems. 

Possible health effects of PM2.5 and air toin Section 4.8.3. 

Impacts - AQ - health - compensation 

Residents should be compensated for health care needed by those affected by pollutants and carcinogens due to the freight yards. 

There will be no air quality impacts requiricompensation. 

Impacts - AQ - health - compensation - additional analysis 

DHWP requests a cost benefit analysis to address the impact of cost for additional medical care for the insured and uninsured (and time lost from work). 

Possible health effects of PM2.5 and air toin Section 4.8.3. The reasons why no addof health effects will be done are stated in 

Impacts - AQ - health - conclusions 

Additional analysis is needed to support the impacts on human health that are stated in the DEIS. 

Air quality impacts were an important consdeveloping the project alternatives and in related to routing truck traffic in the PreferPossible health effects of PM2.5 and air toin Section 4.8.3 of this FEIS. The reasons additional analysis of health effects will be stated in that section. 

Impacts - AQ - health - correction 

There is inconsistency between a statement in the DEIS and the EPA's website in terms of health effects of air toxics. 

The paraphrasing of the EPA's language corrected in this FEIS. 
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Response Category Generalized Comment Response 

Impacts - AQ - health - DATI 

The Detroit Air Toxics Initiative (DATI) was ignored in the DEIS. 

The Detroit Air Toxics Initiative Report (DAafter the DEIS was printed for public availreport dated November 2005 and availablhttp://www.michigan.gov/documents/DAT_COMPLETE_FINAL_REPORT_11-9-05_The DATI project's goals are to "characterair toxics in the Detroit area, to assess the associated with those levels, and to work representative stakeholder group to develthe findings and to recommend risk reducThe report is summarized in Section 4.8.7

Impacts - AQ - health - dispersion 

There needs to be a health impact study and analysis of dispersion of the emissions. 

Dispersion of air pollutants other than CO Possible health effects of PM2.5 and air toin Section 4.8.7.3. The reasons why no aanalysis of health effects will be done are section. 

Impacts - AQ - health - effects 

The burden analysis does not provide exposure data important to understanding health impacts. 

Possible health effects of PM2.5 and air toin Section 4.8.7.3. The reasons why no aanalysis of health effects will be done are section. 

Impacts - AQ - health - EPA study 

There should be a review and inclusion of USEPA's study Health Effects of Environmental Exposure Among Children Living in Detroit. 

The cited study is described on EPA's Wewww.epa.gov/dears/studies.htm. Quoting "Background" section of the Web site, "Prhas shown that concentrations of PM2.5 m

concentrations measured at community sireasonable surrogate for personal PM maconcentration exposures. Presently, it is n

specific components of PM and related aifrom specific ambient sources observe the relationship." The studies include: the D

and Aerosol Research study (DEARS); thChildren's Health Study (DCHS); the DetrCardiovascular Health Study; and, the DeToxicology Study. 
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Response Category Generalized Comment Response 

Impacts - AQ - health - established limits 

There should be regular studies of the impacts of the DIFT on upper respiratory disease with established pollution limits. 

Establishing pollution limits to protect the and welfare is the purview of EPA under tAct. In December 2006, EPA reduced the standard for PM2.5; non-attainment desigbeen in place since 2004. A series of studin Detroit to determine whether establishestations give results for PM2.5 that providinformation about pollution levels in the sucommunity. The network of existing polluSouthwest Detroit is the densest of any ar

Impacts - AQ - health - existing 

The current levels of air pollution in Detroit are already having a negative impact on the health of local residents. 

Concern with levels of air pollution in Southas spurred studies with researchers and parties from EPA, the Michigan DepartmeEnvironmental Quality, the University of MDetroit Department of Environmental AffaDetroit Public Schools. EPA will be investambient source impact information obtaincommunity, residential and potentially the can be used in linked toxicological, epidemhealth effect studies. See www.epa.gov/dears/studies.htm. 

Impacts - AQ - health - exposure 

We really have no knowledge on how pollutants might affect people who live around the rail yard facilities. 

Possible health effects of PM2.5 and air toin Section 4.8.7.3. The reasons why no aanalysis of health effects will be done are section. 

Impacts - AQ - health - law 

Even though there is no National Air Quality Standard for air toxics, further study and quantification of health impacts related to air toxics is needed. 

Possible health effects of PM2.5 and air toin Section 4.8.7.3. The reasons why no aanalysis of health effects will be done are section. 

Impacts - AQ - health - legal 

Appropriate and useful methods are available to assess potential health impacts associated with the DIFT. 

FHWA guidance issued February 13, 200science still lacking to accurately predict pconcentrations. 

Impacts - AQ - health - Moterm 

There will be an increase in leukemia, and various other cancers and asthma in the area of the Moterm terminal. 

The Preferred Alternative does not affect tTerminal. CN has indicated it will not expFairgrounds. 

Impacts - AQ - health - risks There is no mention of health risks in the DEIS. 

A health risk analysis is not required and hdone for the reasons cited in Section 4.8.7

Impacts - AQ - health - risks difficulty 

There must be a way to estimate health risks posed by the DIFT. 

A health risk analysis is not required and hdone for the reasons cited in Section 4.8.7
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Response Category Generalized Comment Response 

Impacts - AQ - health - SW vs. region 

The potential environmental/health impacts as a result of the DIFT will negatively impact Southwest Detroit, while improving conditions for the region. 

Table 4-31 shows air pollution burdens on and local roadway systems will substantiatoday's conditions in all locations as more regulation of diesel vehicles and fuel takethe Preferred Alternative, more roadway liimprove than not, and the terminal burden reduced. 

Impacts - AQ - mercury 

Does the air get cleaner with double the number of trucks because of the recent relaxation of the mercury laws associated with coal? 

The analysis shows pollution from trucks wreduced in the future. Regulation of poweburn coal with respect to mercury is a sepunrelated to trucks. 

Impacts - AQ - mobile source measurements 

It should be noted that in the DEIS, not a single air quality or emissions measurement has been collected. Rather, all analysis is based on modeling. 

Southern Wayne County has the most comof monitoring stations in Michigan. The mfrom these stations is reported in Sections Modeling is used by SEMCOG in its attaindeterminations for future conditions, and Mmodeled CO hotspots and used the MOBfactor model to determine pollutant burden

Impacts - AQ - mobile source measurements clarified 

Language in the DEIS regarding mobile source emissions indicate that the authors are unfamiliar with mobile source inventory methodologies. The reference to tailpipe emissions has be

Impacts - AQ - noise 

The DEIS analysis of air quality, noise and vibrations and their related potential health impact should be strengthened. 

The analysis meets all applicable state anregulations and guidelines. 

Impacts - AQ - old trucks 

Older trucks that contribute more to air pollution than trucks made in 2007 or later, could remain on the road and in the fleet mix for many years. Were the correct assumptions on fleet mix used in the air quality analysis? 

The air quality analysis uses the vehicle afrom Michigan vehicle registration data. TSEMCOG's, as approved by EPA. There using another data set, nor any known altset. 

Impacts - AQ - old trucks mitigation 

Will MDOT require trucks used in the DIFT be equipped with engines fitting the 2007 standards? 

While conditions are stipulated in the Pre-Plan Agreement that require actions on thrailroads (because the government is provto the railroads), such requirements will notrucks hauling containers to and from the restrictions while in the terminals will be pthe DIFT, to the extent feasible. 

Impacts - AQ - old trucks smell 

How will EPA regulations and standards be 

enforced, as they relate to trucking firms? 

Fuel with a high sulfur content will not be future. Over time, newer, cleaner trucks wtrucks. "Enforcement" comes in the form new vehicles when they are manufactured
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Response Category Generalized Comment Response 

Impacts - AQ - PM The air is getting dirtier every day. 

Dirty windshields normally result from depparticulate matter (PM). Figure 4-31 showparticulate emission factors and Figures 4show the trends for particulate matter at thmonitoring station, which is nearest to the Junction Yard, the area of the Preferred Alocalized basis, dust from trucks coming oareas is a local source of PM. The Preferwill pave the Livernois-Junction Yard. 

Impacts - AQ - PM 2.5 analysis 

The increase in traffic will exacerbate the existing high levels of particulate matter in the air. 

Information on particulate matter from roain Tables 4-27 and 4-29 and is detailed by Traffic volumes by roadway link near the tshown in Table 4-28; those volumes are fodown in the future on many of these links. particulate matter on the intermodal terminare included in Tables 4-26a. Under the PAlternative particulates are substantially recompared to the present and No Action A(Table 4-31). 

Impacts - AQ - PM 2.5 analysis ozone 

The air quality burden analysis does not consider key pollutants of concern from DIFT trucks and trains (PM2.5 and ozone). 

PM2.5 is addressed in the response to othRegarding ozone, information has been pprecursors - volatile organic compounds (nitrogen oxides (NOx), as is customary in analysis of a transportation project. SEMCevaluated the Preferred Alternative and foconformity with the State Implementation 

Impacts - AQ - PM 2.5 existing 

The existing PM 2.5 levels in Southwest Detroit and Dearborn are too high. 

PM 2.5 readings in Dearborn (monitoring on Wyoming nearest to the Livernois-Juncarea of the Preferred Alternative) are the hstate, and so particulate matter is of obviohere, as elsewhere in Dearborn and SouthMDEQ and EPA have taken actions to redlevels. 

Impacts - AQ - PM2.5 concentrations 

Local assessment of PM2.5 ambient concentrations from the (Livernois-Junction) yard and traffic should be performed, including a breakout of diesel PM. 

PM 2.5 and diesel particulate matter (DPMforecasts are not included. The tools to cconcentrations are not yet reliable and coprediction is not required. 

Impacts - AQ - PM2.5 concentrations - meetings 

Local assessment of PM2.5 ambient concentrations from the (Livernois-Junction) yard and traffic should be performed, including a breakout of diesel PM. These were requested during meetings and conference calls with the AQD. 

PM 2.5 concentration forecasts are not inctools to calculate concentrations are not yconcentration prediction is not required. 
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Response Category Generalized Comment Response 

Impacts - AQ - PM2.5 modeling 

The EIS is misleading in stating that a dispersion modeling analysis is precluded by limitations such as lack of EPA standards or models. 

PM 2.5 concentration forecasts are not inctools to calculate concentrations are not yconcentration prediction is not required. 

Impacts - AQ - PM2.5 paving 

Paving the terminal will not decrease the amount of PM2.5 emissions from diesel trucks and trains and should not be presented as a solution to PM2.5 emissions 

Paving will reduce the nuisance of dust, wpredominantly PM10 (or larger-sized partia fraction of the dust. PM/dust is very reaarea around the Livernois-Junction Yard, Preferred Alternative. It is not a substitute measures and has not been presented as 

Impacts - AQ - point source 

The DEIS fails to consider the air quality impacts of trucks traveling to and from the DIFT as they traverse roads from the freeway to the terminal. 

Section 4.8.4, covering the terminal burdeall vehicular movements on the yard that wconsidered. Section 4.8.5 and 4.8.7 (PrefAlternative) covers the roadway burden anrefers to Figures 4-44 to 4-47, which show networks where traffic to and from the termconsidered. 

Impacts - AQ - standards 

Have the trucking firms that do not switch to cleaner diesel engines been considered in the air quality analysis? 

The fleet replacement assumptions were SEMCOG, and are based on vehicle registhe region. These are approved by EPA athe required EPA-approved analysis proce

Impacts - AQ - standards delay 

The air quality analysis is based on an optimal situation that government standards and fuel changes will occur. Scenarios should be considered in which the optimal situation doesn't happen. 

EPA's standards were delayed in the courhave now gone into effect. According to Estandards change, they will become more emission factors in the future assume a comix. This is not "optimal" as it is likely the hybrids and vehicles that use less fuel. 

Impacts - AQ - standards EJ 

MDOT in no way holds responsibility for federal fuel and engine standards and so should not include air quality benefits attributable to those measures in its Environmental Justice analysis of DIFT. 

Michigan/MDOT is subject to compliance regulations. The EIS must take into accouthat are in place at the time the document 

Impacts - AQ - standards results 

Because of increased diesel truck traffic from the DIFT, residents in Southwest Detroit and south Dearborn would realize almost no air quality benefit as a result of the regulations requiring cleaner truck engines. 

Information on particulate matter from roain Tables 4-27 and 4-29 and is detailed by Traffic volumes by roadway link near the tshown in Table 4-28; those volumes are fodown in the future on many of these links. particulate matter on the intermodal terminare included in Tables 4-26a. Under the PAlternative, particulates are forecast to be reduced, compared to present (2004) conAction Alternative (Table 4-26a). 
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Response Category Generalized Comment Response 

Impacts - AQ - toxics analogy 

The statement comparing estimates of aggregated air toxics from residential home heating to air toxics roadway burdens is not particularly fitting or accurate. 

The example is illustrative, allowing a lay some understanding of the magnitude of oin the environment. 

Impacts - AQ - toxics as carcinogens 

MDOT does not acknowledge that the particular air toxics in diesel exhaust are listed by the EPA as known or probable human carcinogens. 

In this FEIS the discussion of air toxics haexpanded, and carcinogenicity is noted. 

Impacts - AQ - toxics conclusions 

The DEIS lacks conclusions related to the air toxics burden estimates. 

This FEIS expands on the discussion of thbetween No Action and the Preferred Altesummarizes these in a new Table 4-26a. 

Impacts - AQ - toxics evaluation 

Without dispersion modeling and risk assessment, it is not possible to effectively use the air toxics information presented in the DEIS. 

As there are no air toxic standards, the buthe DEIS compared the alternatives to onrather than to a standard. The data in Tabthe relationship between the No Action Altthe Preferred Alternative. 

Impacts - AQ - toxics results 

Why are toxic emissions so much lower in the No Action Alternative? Is it assumed there will be a lot less container handling under No Action? 

If the comment refers to air toxics at the LJunction Yard, the answer is "yes," there won-terminal activity with the Preferred AlteAction as the Preferred Alternative's termilead to more efficient vehicle activity. 

Impacts - benefits 

The railroad yards bounded by Livernois, Kronk and Wyoming should be used as part of the DIFT, it will only improve these areas. Comment acknowledged. 

Impacts - benefits - ACCESS 

I can't understand how the DIFT Project would negatively affect the south end of Dearborn and wonder if the members of ACCESS are really being told the real benefits to the project. 

ACCESS has been involved in the project the benefits and impacts cited by MDOT. 

Impacts - benefits - AQ 

Intermodal improves air quality by creating shorter truck trips through the increased use of rail. Comment acknowledged. 

Impacts - benefits - businesses The DIFT will not benefit businesses. 

There is potential for improved business ain many sectors of the economy as a resuimplementing an Action Alternative. Thesforecast to pay average annual compensaper year per Section 4.5.2. 

Impacts - benefits - Dearborn 

The direct economic benefit to the City of Dearborn would be minimal. 

This comment is contrary to the statemenDearborn Master Plan per Section 4.6.1. potential for improved business and relatesectors of the economy as a result of implAction Alternative. 

Impacts - benefits - jobs 

It is important to note that the DIFT will bring 3,000+ jobs to the area. Comment acknowledged. 
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Response Category Generalized Comment Response 

Impacts - benefits - local 

There are no benefits to my community from the project. 

The community improvement plan providebenefits to the local Southwest Detroit/Eacommunity, beyond those accruing from tregional economic stimulus and reduced ractivity. 

Impacts - benefits - local improvements 

Who wants the project and how does it benefit those parties? How does the public benefit? 

MDOT, the Federal Highway Administratiorailroads, the City Council of Detroit and mSouthwest Detroit community in a group kGateway Community Development Collabothers, support the project. Additionally, tSection 5 include improvements to benefit immediately around the Livernois-Junction the area of the Preferred Alternative. 

Impacts - benefits - local mitigation 

What are the proposed benefits to the area around the DIFT? 

The measures in Section 5 of this FEIS inimprovements to benefit the area immediaLivernois-Junction Yard, which is the area Preferred Alternative. 

Impacts - benefits - opinion 

The cost of all alternatives outweighs the benefits to 

the community. Comment acknowledged. 

Impacts - benefits - Southwest Detroit 

The DEIS creates the impression that the presence of the DIFT in Southwest Detroit is desirable, beneficial and has no adverse impact. The DEIS cannot omit facts to support the action and reject those that do not. 

The EIS addresses all impacts, consistent federal regulations and laws. The benefits are also addressed. 

Impacts - benefits - stimulus 

The DIFT will stimulate economic development in Southwest Detroit. 

The project will have positive primary and economic effects as presented in Section 

Impacts - business - benefits 

Is there any improvement in the situation for the businesses that back up to the railroad lines (at the Livernois-Junction Yard)? 

Rear borders would change in most caseswill be maintained to businesses that have 

Impacts - business impacts 

Traffic congestion on Wyoming may have implications for local businesses. 

Traffic congestion is not forecast to occur Preferred Alternative. 

Impacts - business impacts - Central I am concerned about my property at 3774 Central. 

This property will not be relocated by the Alternative. 

Impacts - business impacts - Lonyo 

Closing Lonyo and making travel more circuitous around the yard could hurt businesses in Southwest Detroit and South Dearborn. 

The travel time of a motorist with traveling would increase about two minutes when LHowever, the Central underpass means thbe encountered by roadway traffic. Todaythe mainline tracks adjacent to Kronk is copass frequently and there will be more tra
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Response Category Generalized Comment Response 

Impacts - business impacts - Oak 

I'm in the CP Oak area and I'm concerned about my property. You've got me locked in on three sides. I don't like it, and I want somebody to take me out of there. 

The DIFT Project will have no effect on thterminal's boundaries. The Preferred Alteintermodal operations now at the CP/Oak Livernois-Junction yard. The Oak yard, owrailroad, would be used for other rail purpo

Impacts - business impacts - tool and die 

We run a tool and die business with very fine machine tolerances. The increase of intermodal traffic and those trains cause a problem for my business. Is there any relief for businesses that are on these lines coming in? 

The Livernois-Junction Yard has had rail uyears in varying intensities. The proposed consistent with other changes over time akeeping with the yard's use by railroads. 

Impacts - business - Michigan 

In terms of a gate at Wyoming, will there be any impact on the southwest corner of Michigan Avenue and Wyoming? No. 

Impacts - business site 

Within that acreage of Alternative 4 are you going to try to accommodate appropriate businesses? Is there going to be room for any kind of industry related to the development? 

The terminal at the Livernois-Junction YarPreferred Alternative will not include non-businesses. The economic analysis indicwill stimulate business/economic developmforecast to occur in the broad area (35 sqaround the Livernois-Junction Yard. 

Impacts - community cohesion 

The proposed DIFT would destroy the cohesion of one of the few richly diverse communities in the state of Michigan. 

The Preferred Alternative will close Lonyotruck traffic on neighborhood streets. It wsecurity wall around most of the terminal, landscaped buffer in the north where residnearest to the terminal today and in the fubusinesses and residents in 32 residencerelocated by the Preferred Alternative. 

Impacts - community cohesion - Oak 

Section 4.2 "Social Impacts/Community Cohesion" needs to provide more detail for the CP/Oak community. 

More detail is not needed as the Preferred does not involve expansion of the CP/Oak 

Impacts - compare other locations 

Has this type of expansion occurred in any other parts of the country or the state, and if so, what was 

the impact on that community? 

Tours of other intermodal sites in Chicago to community leaders, and information is pDIFT Technical Report No. 3, (October 20to 4-6. Chicago intermodal terminals posiwith the surrounding community. The CanTriple Crown intermodal terminal in Melvinexists with its neighboring community. Re71 of this FEIS. 

Impacts - construction 

The DIFT terminal should not be under construction at the same time as the Fort Avenue bridge. 

The Fort Street Bridge construction is schcompleted before the DIFT Project's consscheduled to begin. 
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Response Category Generalized Comment Response 

Impacts - cultural resources 

Historic structures within the footprints of any DIFT alternative should be relocated and saved as opposed to documented and demolished. 

See Section 6. The only historic site that experience an adverse effect is the formeCompany/Spranger Wire Wheel CorporatClayton Street, which would be demolisheMemorandum of Agreement (Appendix C) determined that the site will be properly reis demolished. Moving the building is not 

Impacts - cultural resources - Fairgrounds 

Was the historical value of the State Fairgrounds considered? 

Yes. See Section 6. The Fairgrounds will by the Preferred Alternative. 

Impacts - cumulative 

The study failed to consider key potential adverse impacts on the affected communities such as indirect and cumulative effects. 

The positive and negative indirect and cumare cited at the end of Section 4.17. 

Impacts - cumulative - health 

In regard to health data, there's little if any discussion about secondary or cumulative effects. 

No health risk analysis was undertaken fostated in Section 4.8.3 of the DEIS. So, thFEIS contain no statements on secondary health effects. 

Impacts - cumulative - health impacts 

The air quality and related health impacts of the DIFT alternatives have not been adequately described. 

Possible health effects of PM2.5 and air toin Section 4.8.3 of the DEIS. The reasons additional analysis of health effects will be stated in that section. 

Impacts - cumulative - intermodal 

There is a lack of discussion associated with existing conditions and how the DIFT will change the existing conditions. Specifically, how will the 

DIFT impact the Ambassador Bridge? 

The discussion of existing land uses is incSection 4.6 and future land uses is in Secpositive and negative indirect and cumulacited at the end of Section 4.17. U.S.-Cantruck traffic carried on the Ambassador Brminor. The DIFT will have almost no effecAmbassador Bridge. 

Impacts - cumulative - other projects 

There should be a comprehensive assessment of all transportation-related projects, including I-94 and bridge expansion. 

The projects mentioned in the comment ain the analysis of indirect and cumulative edocumented in Section 4.17. A new "DelrCanada plus the proposed second span oAmbassador Bridge are discussed in the and cumulative analysis for this FEIS. 

Impacts - cumulative - residential 

If businesses do relocate in the DIFT area, this raises concerns about additional indirect impacts on the remaining residential areas surrounding the yard. 

The positive and negative indirect and cumof the Preferred Alternative are cited at th4.17. The effects of relocating businesses expansion of the Livernois-Junction Yard, Preferred Alternative, are included in Sect
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Response Category Generalized Comment Response 

Impacts - cumulative - SEMCOG 

The DEIS fails to discuss the future impacts of the DIFT as they relate to the projects in SEMCOG's 2030 Plan, other local projects in the planning process, and other private developments. 

Section 4.17 mentions all of the projects licomment and discusses their positive and indirect and cumulative effects. A NEPA dnot evaluate the adopted Plan of a MetropOrganization such as SEMCOG. 

Impacts - cumulative - traffic 

The traffic pattern analysis is incomplete and does not account for foreseeable impacts of other transportation projects. 

The traffic analysis, documented in Sectioaddresses DIFT-related traffic by compariforecast for each Action scenario to the loNo Action. The traffic of other projects incSEMCOG's plan is incorporated in the anaSEMCOG's traffic data and roadway netwconditions. The activities of AMTRAK and expected to move through the Livernois-Jare included in Section 4.9.1. 

Impacts - cumulative - trucks 

A comprehensive analysis of the major truck generators in the community and transportation projects is needed. 

The traffic analysis for this EIS takes into truck traffic, relocation of some generators and the traffic generated by the project. A truck generators in the area is beyond the EIS. 

Impacts - disproportionate burden AQ 

South Dearborn and Southwest Detroit already bear a disproportionate burden of air quality problems. 

The pollution burdens in those areas are pSection 4.8.7.2, as represented by data copollution monitoring stations (Section 4.8.2

Impacts - disproportionate burden AQ - adding to 

Southwest Detroit is the second or third most polluted area in the country with Zug Isle and all the industry. Bringing trucks with the diesel fuel is going to add to the pollution we already have. 

The roadway air quality burden with the PAlternative decreases in some locations in Dearborn and Southwest Detroit and increas is presented in Table 4-29. 

Impacts - disproportionate burden - take away problems 

Existing deficiencies in Southwest Detroit's air quality and roadways need to be addressed. 

The air quality burden produced by mobile the Preferred Alternative will be better matoday by locating terminal gates/entry pointhe neighborhoods; by relocating to other from these neighborhoods truck-dependeand, by improving Central Avenue. 

Impacts - economic analysis 

Is this a priority that the state needs to be spending money on? 

MDOT and the Federal Highway Administso. The project Purpose and Need Statemwhy the project has been undertaken. Ecare described in Section 4.5. 
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Response Category Generalized Comment Response 

Impacts - economic analysis - brownfields 

The clean-up and redevelopment of any contaminated parcel considered for acquisition must be done in compliance with Part 201 of PA451 of 1994. Grants and loans are available for environmental assessments, clean-ups and redevelopment of Brownfield sites. Funds are targeted to promote economic development and reuse of brown fields. Comment acknowledged. 

Impacts - economic analysis - job retention 

Retention of housing, business and jobs should be reviewed. 

MDOT will relocate locally those who wish the area. 

Impacts - economic analysis - local 

An independent review of economic impacts is needed. 

Section 4.5 summarizes the findings of thImpact Analysis Technical Report. Additionot required by FHWA. 

Impacts - economic analysis - mitigation 

A plan is needed to encourage business development and create local jobs. 

Section 5 contains mitigation measures to grow local jobs around the Livernois-Juncsite of the Preferred Alternative, and to traresidents to qualify for those jobs. 

Impacts - economic analysis plan Where is the business plan for the DIFT? 

The framework of the business plan, incluconcept of governance, is included in the the Pre-Development Plan Agreement. 

Impacts - economic analysis proposal 

The proposal that Michael Belzer and his colleagues wrote about three years ago to provide a 

solid framework for tying transportation dollars to the host community will be resubmitted. Comment acknowledged. 

Impacts - economic analysis REMI 

The REMI model used in the DIFT analysis is designed for use at a regional level and less accurate at a local level. 

The economic analysis cites all the issues application. The forecast gain with the PrAlternative of 1,542 permanent jobs in the and 4,514 statewide through intermodal ovalid forecasts using a recognized tool froof Massachusetts. 

Impacts - economic investment 

We need an investment, not just an industrial infrastructure, be it border crossings or intermodal freight terminals and our economic capital. Comment acknowledged. 

Impacts - EJ 

Existing environmental problems were not addressed in the Environmental Justice analysis. 

Table 7-4 summarizes the results of over held with community representatives and issues and concerns, affecting key populaissues, including environmental issues, anSection 4.3.2, "Environmental Justice" of tspecifically covers land use, air quality, nocontaminated sites, and water quantity an
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Response Category Generalized Comment Response 

Impacts - EJ 

Environmental Justice impacts were not thoroughly analyzed and considered. 

Impacts to the local community have been are the subject of Section 4 and mitigation Section 5. That documentation recognizes negative effects on EJ populations and cofollows: "there will be disproportionately aand cultural resource effects on minority opopulations” covered by the EJ Executive 

Impacts - EJ AQ 

Populations near the terminal area are disproportionately impacted in terms of air quality. 

Pollution from all trucks is expected to decpollution discussed in the comment may bdisproportionately distributed, it is not the intermodal traffic now or in the future. The industrial pollution and possibly other mobgenerators. Nonetheless, impacts to the lhave been identified and are the subject omitigation as identified in Section 5. That drecognizes positive and negative effects opopulations and concludes there will be disproportionately adverse housing and cueffects on minority or low-income populatithe EJ Executive Order. 

Impacts - EJ boundaries 

The Environmental Justice analysis should make comparisons to populations in a larger area such as the region. 

As explained in Sections 4.3.1 and 4.3.2 oDetroit Urbanized Area is the basis of comof three defined "terminal areas" which ra22 to 35 square miles and 140,000 to 164The terminal areas are aggregations of cearound each terminal. The Detroit Urbanidefined in the footnotes to Table 4-12 and Figure 4-13c. 

Impacts - EJ boundaries & Purpose and Need 

The relevant geographic area for the DIFT EJ analysis is Southeast Michigan. 

As explained in Sections 4.3.1 and 4.3.2 oDetroit Urbanized Area is the basis of comof three defined "terminal areas" which ra22 to 35 square miles and 140,000 to 164The terminal areas are aggregations of cearound each terminal. The Detroit Urbanidefined in the footnotes to Table 4-12 and Figure 4-13c. 

Impacts - EJ boundaries graphic 

What is the boundary of the Detroit Urbanized Area? 

A graphic, Figure 4-13c, has been added boundary. 

Impacts - EJ boundaries - zip codes 

The selection of comparative populations for the EJ analysis makes little sense. 

The terminal areas represent cohesive groneighborhoods/areas of influence. They wby the Local Advisory Council and were mresult. 
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Response Category Generalized Comment Response 

Impacts - EJ - community involvement 

The application of Environmental Justice principles requires community involvement. 

Many meetings were held with the generainterested groups, and stakeholders (see ensure everyone understood the project, iits opportunities. The Executive Order on Justice is quoted in Section 4.3.2. Commimprovement measures were generated bmembers and MDOT. 

Impacts - EJ - conclusion 

The draft EIS erroneously concludes that minority and low income communities will not be disproportionately and adversely impacted by the DIFT. 

Section 4.3.2 covers Environmental Justicopens with an explanation of the Executivprovides information on the subject populaprevent repetition, figures earlier in the EIto. The comparison base for each terminDetroit Urbanized Area. All impact categoreviewed for all alternatives. Table 4-15 sdirect and indirect impacts: mobility, econland use, air quality, community effects, n4(f) resources, contaminated sites, and waTable 4-16 summarizes these same topiccumulative impacts. Impacts to the local cbeen identified and are presented in Sectiis identified in Section 5. The analysis recand negative effects on EJ populations anthere will be disproportionately adverse hocultural resource effects on minority or lowpopulations covered by the EJ Executive 

Impacts - EJ - correction 

The accuracy of the minority data used in the EJ analysis is in question. 

The method of the commenter is slightly dmethod used by MDOT. Conclusions are The same areas continue to be considerejustice areas. 

Impacts - EJ correction - approach 

The Environmental Justice analysis failed to include the "some other race alone" and "two or more races" categories. 

The stated approach was not used in the analysis used a threshold of at least 2% oArea's population to define the affected gr
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Response Category Generalized Comment Response 

Impacts - EJ - deficient 

The DEIS states that the populations of the affected terminal areas are dominated by groups covered under Environmental Justice, acknowledges adverse impacts, yet concludes there will be no disproportionate adverse impacts. 

This FEIS recognizes that over time, undeenvironmental features have accumulated and related transportation developments. existed for many years. Public resources many of these conditions have been lackiProject is envisioned as a way for public asector investments to bring some measurimprovement to existing rail activity with thpopulations knowing the activity will expanwith or without the project. On balance, thand improvements of Action Alternatives abeneficial to those populations compared Condition. 

Impacts - EJ - definitions 

The DEIS should provide accurate definitions of 

race, ethnicity and/or national origin of residents of the affected area for the purpose of addressing Environmental Justice. Such definition is in Sections 4.3.1 and 4.

Impacts - EJ - health 

How are environmental health issues addressed under Environmental Justice? 

Health effects of PM2.5 and air toxics are Section 4.8.3. The reasons why no additianalysis of health effects will be done are section. The EIS finds disproportionate efproposed project on environmental justice All alternatives would affect environmentapopulations. 

Impacts - EJ - health risk analysis 

A health impact study must be conducted as part of the EIS given that there is a disproportionately high adverse pollution burden on minority and low income communities. 

A health risk analysis is not required and hdone for the reasons cited in Section 4.8.3

Impacts - EJ - issues 

A better definition of environmental justice issues is needed. 

"Environmental justice" is defined in SectiEIS finds disproportionate effects of the pon environmental justice populations. All would affect environmental justice populat
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Response Category Generalized Comment Response 

Impacts - EJ - jobs 

The environmental analysis conclusion suggests that job creation associated with the project should be viewed as balancing out negative impacts on air and water quality and health. This violates the Executive Order on Environmental Justice. 

This FEIS recognizes that over time, undeenvironmental features have accumulated and related transportation developments. existed for many years. Public resources many of these conditions have been lackiProject is envisioned as a way for public asector investments to bring some measurimprovement to existing rail activity with thpopulations knowing the activity will expanwith or without the project. On balance, thand improvements of Action Alternatives abeneficial to those populations compared Condition. 

Impacts - EJ - Title VI 

There is no separate evaluation of impacts under Title VI of the Civil Rights Act of 1964. 

The separate evaluation was done and is Section 4.3.1. 

Impacts - EJ - Title VI - comparison 

The Arab-American, Hispanic and American Indian populations have not been analyzed as special groups that dominate each terminal area. 

The populations identified in the commentSection 4.3 and Table 4-12 in that sectioncovers Environmental Justice. 

Impacts - EJ - Title VI - fragmentation 

Any expansion of the Junction Yard would serve to further fragment the community, particularly the Arab and Hispanic communities. 

The expansion of the Livernois-Junction YPreferred Alternative would be to the north and south into a largely industrial area. Tpopulation of 32 residences is a mix of whHispanic. Every effort will be made to relopopulation away from the railroad yard itschoose. The same is true of businesses, indicated in earlier interviews the intention the larger terminal area. Closing Lonyo wcircuitous travel for those using that conneincluding Arab-American families south of Junction Yard traveling to and from Star Awith the alternative routes, there will be no trains as the Central Avenue connection wseparated. This will improve the safety of pedestrians and motorists, as there would crossing of the rail yard, which has proven be hazardous. Counts of pedestrians and Lonyo found no activity. 
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Response Category Generalized Comment Response 

Impacts - EJ - tradeoff 

You cite economic factors that are not relevant to environmental justice. You cannot mitigate people's health by offering them the possibility of a job. 

Some mitigation of impacts are considereenhancements. Also, the improvements ioperations by, for example, keeping intermof neighborhoods, will benefit air quality. the U.S. Department of Transportation in tAddress Environmental Justice in Minority and Low-Income Populations," states in Smaking determinations regarding dispropoand adverse effects on minority and low-inpopulations, mitigation and enhancements will be taken and all offsetting benefits to tminority and low-income populations may account" (Federal Register pages 18377-1997). Short-term construction and long-tcome with the project and may be consideenhancements. 

Impacts - farmland 

There is no potential for a negative effect on prime or unique farm land. Comment acknowledged. 

Impacts - general 

The DIFT has the potential to impact residents and the environment. Comment acknowledged. 

Impacts - hazmat 

With respect to the contamination report and soil test, what kind of contamination was found? The types of enhancements are cited in S

Impacts - hazmat - asbestos 

The final FEIS should indicate whether or not lead and asbestos exist in buildings to be demolished and describe plans for their safe handling, removal and disposal. 

Section 4.16 notes the likely presence of abuildings to be demolished. Assessment containing materials and lead-based paintconducted during the property acquisition project. MDOT construction specifications activities. 

Impacts - hazmat - coordination 

On contamination sites, coordination should occur within DEQ's Waste Management Division and Remediation and Redevelopment Divisions. 

Coordination has occurred through file revduring the Project Area Contamination SuCoordination will continue in order to addrcontamination issues. 

Impacts - hazmat - Moterm 

There is concern associated with the handling of additional hazardous materials at the Moterm facility. Comment acknowledged. 

Impacts - hazmat - operations 

Increased intermodal activity has the potential to create additional soil and water contamination. 

Participating railroads have Emergency Rto comply with applicable federal and statconcerning hazardous and petroleum storspill prevention, spill response, incident rerelated concerns. As a practical matter, thJunction Yard will be paved with the Prefeand oil/water separators will be included in water drainage system. 
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Response Category Generalized Comment Response 

Impacts - hazmat - rail operations 

Locomotive maintenance, rail car refurbishing and maintenance, and track maintenance can result in environmental problems. 

The Preferred Alternative will not change operations with respect to rail car refurbismaintenance, or track maintenance. 

Impacts - hazmat - remediation 

What type of remediation will be given to residents within 1000 feet of an intermodal site? 

Remediation of contaminated properties oproperty acquisition, but only of the propeacquired. If the commenter is referring to improvements, these are presented in Se

Impacts - hazmat - remediation type 

Remediation of railroads depends on the contaminants present, their concentration and the media they're affecting (soil or water). In addition, selecting remediation strategies also involves an indepth analysis of the cost associated with development. 

No project-related testing is required on eproperties. 

Impacts - hazmat - soil borings 

Where does the soil study along the St. Stephen's area of the city of Dearborn stand at this time? 

As is stated in Section 4.16, no soil boringperformed in Dearborn. They will be perfoproperties are acquired for the Preferred Athe next project phase after a signed Reco

Impacts - hazmat - transport 

There are safety concerns associated with the transport of hazardous materials in such close proximity to residences. 

Typically, intermodal containers are not ushazardous materials except such items as items in controlled conditions. These lattesubject to the same regulation and contromaterials in railroad tank cars and trucks. incidental hazardous materials would be care now carried by truck. 

Impacts - insurance costs 

The state is trying to propose trucks coming into our communities. The trucks will increase our insurance costs, which are already going up. 

Trucks volumes will be reduced in neighb

on the gate configurations of the Preferred 

Impacts - interviews 

Community opinion should prevail over data presented in the DEIS. Comment acknowledged. 

Impacts - interviews - blight 

Blight should be included as a significant community concern in the community interview descriptions. 

The term "blight" was not noted in the intePollution, truck traffic and industrial dump

Impacts - land use 

The DIFT is a massive industrial use contrary to ongoing efforts of the community to plan for a better, more healthful, land use. Comment acknowledged. 
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Response Category Generalized Comment Response 

Impacts - land use - 2004 plan 

The City of Detroit 2004 Master Plan of Policies directs the City to "demolish vacant and/or dangerous structures and encourage rehabilitation and infill housing"; "buffer the negative impacts of industrial land uses upon residential areas"; "redevelop the underutilized sites in the corridor by attracting new and encouraging small-scale industries to use the land for expansion or relocation"; and, "support diverse, year-round recreational activities at the State Fairgrounds". 

Comment acknowledged. The 2004 plan at the time the DEIS and FEIS were prepanot be used as the basis of analysis, but itreviewed, and there are no known changeimpacts/conclusions. 

Impacts - land use - business investment 

Without a mix of businesses, the chance of getting private industries is drastically reduced. The removal of 64 businesses does not encourage private investment or diversity in local business. 

The Preferred Alternative would relocate 2MDOT is committed to help relocate these within the local area, if they so choose. Rof the Livernois-Junction Yard as part of thAlternative is forecast to support other posdevelopment efforts. 

Impacts - land use - control 

Over 31 percent of the occupied land in Southwest Detroit is used for industrial transportation purposes. The DIFT must not increase this percentage. It must contribute to the quality of life and a strong local economy. 

Redevelopment of the Livernois-Junction the Preferred Alternative is forecast to suppositive economic development efforts. 

Impacts - land use - control cities 

Land use changes could be associated with the mixing of land use types that are unwanted with the DIFT. However, no mitigation is recommended. 

The unwanted mixing is not of incompatibterminal but the land uses in the terminal Section 4.17.1. Nonetheless, control of lawith the cities of Dearborn and Detroit. Mjurisdiction over land use. 

Impacts - land use - existing container yard 

Acquiring the existing intermodal container yard on the north side of Dix west of Waterman should be explored. This use is a large piece of land adjacent to the Livernois-Junction yard which is very poorly maintained, and this land could help meet the capacity requirements of the DIFT. 

It is believed that the property noted in the would be part of the DIFT Program. 

Impacts - land use - Expressway Terminal 

If you're taking all the property around the train station, it's going to sit there for another 20 years, because there won't be enough parking for another use of that land. 

The Preferred Alternative makes no use oCP/Expressway Terminal at the Michigan 

Impacts - land use - issues 

The project should assist understanding of issues 

affecting the community and develop, implement, and evaluate plans of action that will address those issues. 

A reading of this FEIS does assist undersissues, especially Section 7.2.1, which suviews of community leaders. The DIFT Pactions to enhance the community. See S
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Response Category Generalized Comment Response 

Impacts - land use - MLULC 

The DEIS invokes the recommendations of the Michigan Land Use Leadership Council (MLULC) report as evidence that action alternatives represent a good land use decision. The fourth tenant of that report states "foster distinctive attractive communities with a strong sense of place." Expanding the railroad into just such a community eliminating residences and businesses and increasing the amount of truck traffic by approximately 5000 trips per day is not justified under this directive. 

Intermodal trucks will be routed along streneighborhoods. Jobs will be created that employment to local residents. Communiimprovements will provide other local enhTherefore, the Preferred Alternative is conMichigan Land Use Leadership Council R

Impacts - land use - Moterm 

It should be demonstrated that the proposed expansion of the CN Terminal into the State Fairgrounds would not hinder the redevelopment of neighborhoods immediately surrounding the proposed site. 

The Preferred Alternative does not affect tTerminal. CN has indicated it will not expFairgrounds. 

Impacts - land use - options 

A vibrant urban center needs to have an extensive set of options to attract new residents. By concentrating the development around one entity or industry, you are limiting those options and the possible attractiveness of moving to that area of the city. 

The Preferred Alternative is consistent witthe railroad property, which has had for alresidential uses immediately to the north aWith the Preferred Alternative, residential buffered from the Livernois-Junction Yard walls and landscaping. 

Impacts - land use plan 

The analysis of the land use and social environment is based on obsolete and incomplete data. The Master Planning documents of 2004 more accurately depict Detroit and the neighborhoods, but the City's 1992 Master Plan document was used. 

The 2004 plan was not official at the time FEIS were prepared, so it could not be usof analysis, but its contents were reviewedno known changes in impacts/conclusions

Impacts - land use - property values 

By eliminating 93 houses and having a 300-400 acre intermodal rail yard in the center of a community, the availability of housing options is reduced and will possibly reduce property values. 

Residents of 32 housing units will be relocreduction of previous estimates as severarelocation area no longer exist. Decent, ssanitary housing is available, as concludeRelocation Plan - Conceptual Stage, AppeProperty values are not expected to drop experiences at terminals like that in Melvinas well as terminals at similar settings in CTechnical Report No. 3 of the DIFT Feasib

Impacts - land use - proximity to residential 

The Livernois-Junction Yard is in close proximity to large residential areas in Dearborn and Detroit. 

The Preferred Alternative would not be dirto any residential area that does not have exposure today. With the project, any resadjacent to the terminal would be bufferedthe case today. 
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Response Category Generalized Comment Response 

Impacts - land use - residence inventory 

An inventory of residences located less than or equal to 1000 feet of an intermodal site should be provided. 

Comment noted. Off-site impacts are limifrom trucks and trains. Noise levels exceewill be mitigated. 

Impacts - land use - revitalization 

The DEIS paints a picture of Southwest Detroit's communities as on an upswing due to the variety of local owned business and residential neighborhoods. In both the consolidation and composite alternatives, there's a proposed elimination of parts of these same residential neighborhoods and local shopping districts. The DEIS fails to justify that disruption of the upward revitalization trend. 

The Preferred Alternative would require thpeople in 32 residences, but no local shopThe residential section slated for relocationext to industrial uses. The remaining newould be buffered from the Livernois-Juncnot today. Truck traffic is forecast to increroads that are predominantly industrial/codecrease on streets serving residential arproject will complement the upward revitathrough design of the Preferred Alternativplan and its economic stimulus. 

Impacts - land use - shopping center 

The neighborhood has long sought a major shopping center and such a place may develop at the northwest corner of Vernor and Livernois. This project can make that happen. Comment acknowledged. 

Impacts - land use - trends 

The DEIS fails to provide adequate study of the future land use trends expected. 

The Preferred Alternative is virtually no difuse activity than today. But, it will improve compatibility with the surrounding areas broutings, buffers, paving and community im(Section 5). 

Impacts - Metropark 

A Metro Park is desired at the Fairgrounds to provide additional local recreational opportunities. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairg

Impacts - noise - containers 

Additional container movement will generate additional noise. This has not been accounted for in the DEIS. 

The noise analyses of the DIFT DEIS/FEImitigation for noise in the loudest hour. Tnoise metric is such that it is designed to ccontinuous noise, not "impulse noise." Imsuch as container handling, is controlled bordinances, in this case the cities of DetroDearborn. The entire Livernois-Junction Ybuffered from non-industrial uses so that tloudest hour does not exceed the establis67 dBA at sensitive receptors, such as ho

Impacts - noise - containers - Moterm 

Noise associated with existing container movement at the Moterm facility is excessive. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairgwould have any effect on current intermodthe Moterm Terminal. 
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Response Category Generalized Comment Response 

Impacts - noise - trains 

There is no noise analysis associated with the movement of trains on terminal property. 

The train noise analysis is documented in Vibration Technical Report and summariz4.9. All sensitive areas around the projecbuffered to reduce projected noise to leveestablished residential criteria. 

Impacts - noise - trains - Moterm 

Existing train noise at the Moterm facility is excessive. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairgwould have any effect on current intermodthe Moterm Terminal. 

Impacts - noise - truck 

With additional truck traffic, noise levels will increase. 

The Preferred Alternative will reduce noisterminal where there are adjacent sensitivIntermodal trucks will be focused on WyomLivernois Avenues north of the terminal. Sterminal, on Livernois and Dragoon, intermtraffic will be reduced as the terminal entraconfigured to prevent entry/exit from the sFurthermore, the Detroit River InternationStudy includes closing the I-75 interchangLivernois/Dragoon, thereby eliminating inton these streets. 

Impacts - noise - truck - Vernor 

The existing truck related noise on Vernor Highway is excessive. 

The Preferred Alternative will not increase on Vernor. The existing entrance at WateLivernois-Junction Yard will be closed by tAlternative, eliminating intermodal trucks f

Impacts - noise - vibration 

The vibration of the trucks and how it will impact homes is a concern. 

The Preferred Alternative routes trucks awresidential areas. Vibrations travel only a distance. 

Impacts - noise - distraction 

An increase in traffic will result in an increase in noise in South Dearborn, distracting students from their lessons. 

The change in intermodal trucks on Wyomwith the Preferred Alternative will have no impact on noise conditions compared to thcondition. 

Impacts - noise - Expressway Terminal 

Under Alternative 2, how would a sensitive community facility such as a hospital (United Community Hospital) just 90 feet away from this expanded intermodal terminal not be affected? The United Community Hospital has close
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Response Category Generalized Comment Response 

Impacts - NW Detroit 

The discussion of the CN/Moterm facility fails to acknowledge the existence of the entire Northwest side of Detroit and the area between the Fairgrounds and Highland Park, which was critical to the selection of alternatives. 

The discussion of the potential direct, indicumulative effects with the CN/Moterm facarea in Northwest Detroit and Southern Othat is 22 square miles with more than 140according to the 2000 U.S. Census. That Highland Park and the area between it anFairgrounds. The analysis also covered tPark Comprehensive Plan and its relation intermodal terminal and its proposed expa

Impacts - old data 

Much of the data used in the study is outdated or incomplete. 

The DEIS and FEIS have used the most uavailable at the time of analysis, consistenEnvironmental Protection Act (NEPA) req

Impacts - parks 

DIFT impacts to Patton Park, Lapeer Park, and Romanowski Park have not been fully considered. There will be no negative effect on these p

Impacts - parks - Loverix Park 

Loverix Park at Tractor and Robert Streets no longer exists. 

Loverix Park, though inactive, does exist aeast of Wyoming and north of Tractor Stre

Impacts - property values 

What are the potential impacts to property values near an expanded intermodal facility? 

An analysis performed during the DIFT Fefound that property values near two compintermodal sites in Chicago were stable or Figures 4-3 to 4-6 of that report for photogdata). A review of Multiple Listing Service sales in the vicinity of the intermodal termSoutheast Michigan found the same. 

Impacts - property values and road maintenance - Dearborn 

Additional truck traffic would likely cause decreases in surrounding property values and increase the burden to the City of Dearborn for the cost of additional road maintenance and repair. 

The economic analysis included in Sectioconversion of private land to government the loss of property tax revenue will be moby the tax gains due to increased economassociated with improving intermodal tranSoutheast Michigan. The increase in trucWyoming will be negligible relative to back

Impacts - property values - Moterm 

An expanded Moterm terminal would have a negative impact on property values. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairg

Impacts - property values - tax revenues 

Decreased property values as a result of increased rail and truck activity, traffic congestion, noise and air pollution is a concern. 

The economic analysis included in Sectioconversion of private land to government the loss of property tax revenue will be moby the tax gains due to increased economassociated with the improving intermodal Southeast Michigan. 
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Response Category Generalized Comment Response 

Impacts - quality of life 

The project will affect the air we breathe, increase traffic, cause distraction at neighborhood schools, and limit the connection between our communities and family members. 

Intermodal truck traffic will follow the routiWyoming Avenue and on Livernois AvenuLivernois-Junction Yard. Intermodal truckreduced on Livernois and Dragoon south Lonyo will be closed, causing a more circutwo minutes via Central, when there is no trains are present, which occurs many timnew Central route will have no conflict, as separated under the railroad, more than otwo-minute additional travel time with Lon

Impacts - quality of life - Dearborn 

Trucks are very close to residential areas in Detroit near Livernois and in Dearborn near the Eugene Porath neighborhood and north of Lapeer Park. 

A number of homes have been bought anCity of Dearborn in the Porath neighborhoPark is a block away from Wyoming and mblock away from the new terminal gate of Alternative. It will not be affected by the PAlternative. 

Impacts - quality of life - greening 

Additional truck traffic could hinder the community revitalization that has been occurring, including planned greenway developments in the Southwest 

Detroit/Dearborn and lower River Rouge corridor. 

The project will bring its own greening throplanned buffers that complement other plainitiatives. Intermodal truck traffic will be fcommercial/industrial areas and away from areas. 

Impacts - quality of life - increased activity 

All the alternatives increase traffic in an area of Detroit and South Dearborn that already has levels of truck traffic that are untenable. It affects the quality of life with noise and vibrations. 

Intermodal truck traffic will be focused on commercial/industrial areas and away from areas. The Preferred Alternative further sterminal gate on Wyoming south of Souththe nearest residential area, as compared presented in the DEIS. Noise and vibratiointermodal activity will not be perceptible cNo Action Alternative. 

Impacts - quality of life - Moterm 

Quality of life issues, such as noise and air quality, must be considered at the Moterm Terminal. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairg

Impacts - quality of life - Moterm community benefits 

Quality of life issues, such as noise and air quality, must be considered at Moterm and community benefits must be part of the selected alternative. 

The Preferred Alternative does not include at the Moterm Terminal or the State Fairg

Impacts - relocation 

There should be a relocation program, including compensation, for displaced residents and businesses. 

Every attempt will be made to relocate in tArea persons and businesses affected by Alternative, if they so choose. 

Impacts - relocation - approach 

Let’s square up the boundaries when we buy properties; go after the whole ball game. 

The Preferred Alternative defines the propneeds and most appropriate way to configmeet project needs. 
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Response Category Generalized Comment Response 

Impacts - relocation - business 

Alternatives 3 and 4 appear to require the taking of Truck City immediately north of John Kronk between Stecker and Wyoming. To move this facility away from Junction Yard would seriously damage its competitive advantage and there is no justification for the taking of one active privately owned intermodal business for the purpose of providing the site to another privately owned intermodal business. This property is not now required for the D

Impacts - relocation - business CenTra 

The CenTra Company operates an intermodal freight facility at Central and Kronk. The Action Alternatives take all or part of this property. If this facility were forced to relocate, there is no assurance that another adequate facility could be located in the city of Detroit. 

The property in question is part of the acqPreferred Alternative. Adequate opportunrelocation of the operations on this properthe related interests own a number of areaKronk between Stecker and Wyoming whlonger part of the proposed terminal expaRelocation here of CenTra is, therefore, a 

Impacts - relocation - business CenTra acquisition 

Any change in the land uses in or around the existing or planned Junction Yard must include the provision of property interior to or immediately adjacent to Junction Yard that would permit the continued operation and future growth of the CenTra Company. Otherwise the action that would take the property of one privately owned active intermodal rail facility would provide that site to another privately owned intermodal rail facility for its expansion. 

There is no provision in the Preferred Alteancillary businesses, other that the first-clbe present on the Livernois-Junction Yard

Impacts - relocation - business effect 

Proposals 3 & 4 affect our business. Alternative 3 would be absolutely disastrous for our Central location, where access would be cut. 

The properties in question are to be requiproject under the Preferred Alternative. Rbusinesses there will be done consistent wapplicable federal and state regulations. Athe property in question would be done cofederal and state laws/regulations. No profor the project would be sold to a private in

Impacts - relocation effort 

Sixty-four (64) businesses and eighty-three (83) residences will be relocated under Alternative 3. This has the potential for a tremendous disruption to this community. 

Comment acknowledged. The proposed for the Preferred Alternative are 32 residebusinesses. 
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Response Category Generalized Comment Response 

Impacts - relocation - Expressway 

Page 3-17, second to last paragraph states "Expanding the terminal would require the acquisition of...one institutional property and no residences." Presumably the property in question is the City of Detroit, DPW yard. The office building on this site is fairly new. Given this, and the importance and proximity of the yard and its office operations, what plans and contingencies will be developed to help in the transition to a new location? 

The Preferred Alternative does not include to the area in question. 

Impacts - relocation - list 

What data or database was used to calculate the number of residents and businesses that will be relocated? When was this data/database produced? Please provide updated copies. 

The relocation areas were determined by An interview was conducted by MDOT witowner that agreed to participate in order trelocation needs. The Preferred Alternativrelocation of 32 residences and 29 busine

Impacts - relocation - No Action 

We are demanding that the homes and businesses be left whole and that the improvements be done without the destruction of the community. 

The Preferred Alternative requires relocatproject's purpose and need. 

Impacts - relocation - willing 

I believe my house on Cabot Street and the others will be gone and I would like compensation. 

The updated Conceptual Stage Relocatioincluded in Appendix B. Answers to most related to right-of-way-acquisition and reloprovided on MDOT's web site at: http://www.michigan.gov/mdot/ Click on Business" (left side), then on "Real Estatenumber of explanatory documents are list

Impacts - security - land use 

We believe the Department of Homeland Security could have considerable influence on land use around the Ambassador Bridge as well as other major transportation infrastructures. We would be pleased if Congresswoman Cheeks Kilpatrick could set up a meeting to introduce DHS to these ideas. 

An x-ray screening system known as VACin border crossing planning to screen trainthe U.S. The Department of Homeland SeCongresswoman Kilpatrick are kept informabout the DIFT and other major projects. 

Impacts - security - military 

Increased security and a military presence is of concern. 

The railroads will maintain security at the will be no military "presence" in the termin

Impacts - security - military - containers 

The Department of Homeland Security should ensure that all necessary protections are in place for the safe and efficient use of the LivernoisJunction Yard, that includes analysis of materials to be hauled through the community and limitations on certain hazardous materials and a plan to deal with hazardous materials incidents at the yard. 

The containers of CP and CN are x-rayed enter Southeast Michigan. Additionally, thAlternative allows for an x-ray inspection dplaced at the terminal of the Preferred Alteoperated by CSX and NS. 
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Response Category Generalized Comment Response 

Impacts - stormwater 

Paving at Livernois-Junction Yard could have an impact on water quality due to increased run-off. A stormwater drainage treatment system in needed. 

The Livernois-Junction Yard, and the expathe north under the Preferred Alternative, Stormwater will be properly handled as doSection 5.8. Permitting is covered in Sectrequirements related to water quality and will be met. 

Impacts - stormwater - acres 

Paving 845 acres of land within the LivernoisJunction Yard will greatly increase the amount of rain runoff. The DEIS does not examine the 

expected increase in the frequency of combined sewer overflows. 

There will be no increase in combined sewthe project's design will ensure that flow rayard do not exceed today's levels (Section 

Impacts - stormwater - infrastructure 

The draft EIS does not adequately analyze the ability of the Detroit sewer system to handle the increased runoff from the DIFT. The DEIS asserts that the runoff will be directed to onsite collection, however, no detail is presented. The DEIS notes 

that "no certainty exists" as to whether existing infrastructure will be able to handle the increased runoff. 

The Livernois-Junction Yard and the expathe north for the Preferred Alternative will Stormwater will be properly handled as doSection 5.8. Permitting is covered in Sectdetails of the stormwater system will be dedesign phase. 

Impacts - stormwater - monitoring 

Water quality monitoring and improvements are needed to mitigate depositions to the Rouge and the Detroit rivers. 

Stormwater monitoring is not warranted wanticipated project stormwater controls. 

Impacts - stormwater - petroleum 

Runoff from the freight terminal is likely to contain significant amounts of petroleum products and the impact of this runoff on water quality is not addressed. 

The Livernois-Junction Yard, and the expathe north under the Preferred Alternative, Stormwater will be properly handled as doSection 5.8. Permitting is covered in SectOil/water separators will be constructed odrains. Flow rates from the site will not in

Impacts - stormwater - recharge 

Compacted and impervious surfaces also will reduce or prevent groundwater recharge. 

The Livernois-Junction Yard and the expathe north under the Preferred Alternative wefficient operation. Stormwater will be proas documented in Section 5.8. Permitting Section 5.4. Sediment basins and vegetatincorporated into the design of the Preferrto promote infiltration. 

Impacts - stress 

The trucks create a stressful environment and our youthful residents aren't going to be able to use their neighborhood. 

Intermodal truck traffic will follow the routithe project on Wyoming Avenue and on LAvenue, north of the Livernois-Junction Ytruck traffic will be reduced on Livernois asouth of the terminal. The number of heareduced on Central and Lonyo. 
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Response Category Generalized Comment Response 

Impacts - trucks - Alternative 2 effects 

Alternative 2 will result in 1,270 trucks per day compared to Alternative 1: a) more streets would be affected but with reduced severity; b) Detroit acceptance should be contingent on 100 percent state and/or federal funding for roadway improvements; c) the Central underpass would mitigate rail/vehicular conflicts and enhance safety; d) closing Lonyo would generate increased traffic at Central/Dix, requiring modifications. 

Intermodal truck traffic will follow the routithe project on Wyoming Avenue and on LAvenue, north of the Livernois-Junction Ytruck traffic will be reduced on Livernois asouth of the terminal. The number of heareduced on Central and Lonyo. The increintermodal truck traffic on Wyoming and Lnegligible relative to background traffic. Mno longer be required by Dearborn on Kroincorporated into the terminal. The new pthe terminal will be maintained by local goThe Preferred Alternative includes improvCentral/Dix. 

Impacts - trucks - alternative effects - traffic signal 

The potential for conflicts between intermodal traffic and other traffic at the Livernois Avenue Gate is too high. A traffic signal study with appropriate mitigation therefore should be planned for at this location. 

The traffic signal already there will lower tconflicts. No study is needed. 

Impacts - trucks - alternative effects - truck traffic 

Alternative 1 (No Action) has an increase in truck traffic that will accelerate damage to city streets, particularly at Livernois and Wyoming, and increase noise and dust, without any mitigation in place. Comment acknowledged. 

Impacts - trucks - annual 

We're talking about an increase of 365,000 to up over 700,000 trucks and they're going mostly to the Junction Yard, is that true? 

The numbers cited are lifts per year, not trfor an expanded Livernois-Junction Yard. Alternative will have an estimated 1,050,0and 3,880 two-way truck trips a day in 203Livernois-Junction Yard. But that truck tot700 more than would be present under thAlternative as businesses with lots of trucby the project. 

Impacts - trucks - Central flooding 

We live in a neighborhood where there are very poor drains and terrible sewer lines and you're talking about a tunnel for Central that's only going to flood. 

The underpass (grade separation) at Cennew equipment and new piping to ensure occur. 

Impacts - trucks - Central traffic 

There is concern regarding increased noise and air pollution associated with additional trucks on Central Avenue. 

Truck traffic on Central is serving existing is anticipated, based on the planned footpPreferred Alternative, a major truck generrelocated. It attracted 2,500 trucks per weaccording to the terminal operators. Relohave the effect of reducing truck traffic on Avenue. The planned interchange improvLivernois and I-94 will also encourage somthat now uses Central to use Livernois. 
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Response Category Generalized Comment Response 

Impacts - trucks - congestion 

Additional truck traffic on already congested roads is unacceptable. 

Section 4.1 documents that the existing rohas adequate capacity for all project-relatchanges, if minor improvements to traffic timings/phasings are made. 

Impacts - trucks - consultation 

It is recommendation that a discussion with City Planning and Traffic officials is needed to gain a true picture of the present impacts. 

MDOT has and will coordinate with local oregarding proposed improvements. 

Impacts - trucks - crashes/safety 

There are potential safety risks posed by a significant increase in the number of trucks on neighborhood streets. 

With the Preferred Alternative, intermodal follow the routings created by the project oAvenue and on Livernois Avenue, north oJunction Yard. Intermodal trucks will be rLivernois and Dragoon south of the terminDix/Waterman entrance will be closed. 

Impacts - trucks - crashes/safety - design 

Intersection enhancements are needed to address safety issues with truck/vehicle movement at intersections and terminal entrances and exit points. 

Design at all gates will follow American AsState Highway Officials (AASHTO) guideladdressing safety needs. 

Impacts - trucks - Fairgrounds 

There will be increased traffic around the Fairgrounds. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 

Impacts - trucks - gates 

All gates except on Wyoming and Livernois should be prohibited now and in the future. 

The Preferred Alternative has gates only oand Wyoming Avenue. 

Impacts - trucks - I75 route 

What routes will trucks use to reach the proposed western entrances of the Livernois-Junction Yard along Wyoming from I-75? What percentage of trucks is expected to come from I-75 versus I-94 

under each alternative? 

Intermodal truck traffic is expected to appWyoming gates to the terminal via I-94. Tcan either use Southfield or Schaefer to gthe Preferred Alternative, 80% of trucks acome from I-94 and 20% from I-75. 

Impacts - trucks - I94 ramp 

Reconstruction of Central below grade and reconstruction of the I-94 Livernois ramp are important improvements that should occur whether or not MDOT ultimately builds the DIFT. 

Central Avenue is a local road. Its improvat the I-94/Livernois Avenue interchange atied to the Preferred Alternative. 

Impacts - trucks - I94/Livernois interchange 

The improvements at Livernois and I-94 will encourage use of Livernois as a route from Metropolitan Airport and points west to Eight Mile Road and the CN/Moterm facility. 

The proposed I-94 change at Livernois Avintended to encourage use of Livernois as east-side terminal gate rather than streets neighborhoods and will not serve as a corMile Road and the CN/Moterm facility. 

Impacts - trucks - information 

Basic information on the number of trucks and trains for each alternative and the number of acres occupied by each alternative is difficult to locate. 

Traffic truck data are prominently displaye4.1. The numbers of trains of all types usby the Livernois-Junction Yard terminal at next to the neighborhood on Kronk are preTable 4-37. 
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Response Category Generalized Comment Response 

Impacts - trucks - Lonyo Lonyo should not be closed. 

Eliminating roads crossing the Livernois-Jcritical to the function of the terminal and tmotorists and pedestrians. Automotive traLonyo Avenue that will be rerouted to Centake an additional two minutes, but no traiencountered, eliminating the potential for accidents, which have occurred. Counts fpedestrians or bicyclists do not use Lonyo railroad tracks. 

Impacts - trucks - Lonyo gate 

A new gate at Lonyo north of Dix should not be permitted. 

The access to the gate referred to is from the gate is internal to the future Livernois-

Impacts - trucks - Lonyo school 

Closing Lonyo will have negative impacts on community cohesion and the local charter school. 

Field observation found students at the cheither dropped off by car or take a school vehicles can reroute to Central Avenue wiencountering trains, eliminating the potentaccidents. The number of trains will increwith or without the project. 

Impacts - trucks - Lonyo - school rail crossing eliminated 

Closing Lonyo Avenue will have a negative effect on Dearborn as it is the main route to the neighborhoods and local charter school. 

Eliminating roads crossing the Livernois-Jcritical to the function of the terminal and tmotorists. Automotive traffic now using Lothat will be rerouted to Central Avenue wiladditional two minutes, but no trains will eencountered, eliminating the potential for accidents, which have occurred. Counts fpedestrians and bicyclists using Lonyo anrailroad tracks. 

Impacts - trucks - Lonyo 

Lonyo should remain open. Rerouting all the trucks that are going to Mars through Central is kind of defeating the purpose. 

Eliminating roads crossing the Livernois-Jcritical to the function of the terminal and tmotorists and pedestrians. Automotive traLonyo Avenue that will be rerouted to Cenadditional two minutes, but no trains will eencountered, eliminating the potential for accidents, which have occurred. Counts fpedestrians and bicyclists do not use Lonyrailroad tracks. 

Impacts - trucks - Moterm 

Increased truck traffic is a concern associated with expansion at the Moterm terminal. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 
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Response Category Generalized Comment Response 

Impacts - trucks - noise 

I am concerned about the increase in truck traffic, noise and vibrations of my home. 

A doubling of traffic volumes is required to perceptible increase in noise levels. This anywhere because of intermodal traffic asthe Preferred Alternative. The project will than an additional 700 trucks to the local r2030, compared to the No Action Alternatvibration impacts. And, those trucks will fWyoming and Livernois, away from neigh

Impacts - trucks - quality of life 

Increased truck traffic will be detrimental to quality of life in the area. 

With the Preferred Alternative intermodal follow routings on Wyoming Avenue and oAvenue, north of the Livernois-Junction Ytruck volumes will be reduced on Livernoisouth of the terminal and the Dix/Watermabe closed. 

Impacts - trucks - rail and truck traffic 

The DIFT Project would significantly increase the rail and truck traffic in and around the proposed Livernois-Junction Yard. 

Truck traffic changes with the project are 4-34 and train volume changes are shown All streets around the terminal are project2030 traffic without congestion. 

Impacts - trucks - rail line improvements 

The DEIS identifies a problem that could limit intermodal growth; that being rail line congestion and conflicts. No solution to this problem is recommended nor were there any discussions of cost, land acquisition problems, or other confounding difficulties. 

Rail line improvements included in the PreAlternative are listed in Section 3.5 and sh3-15. 

Impacts - trucks - rail lines - grade separations 

Alternatives 2 through 4 discuss grade separating Central Avenue. Are other railroad grade separations planned or other modifications to enhance the safe movement of traffic around the terminal area? 

No other separations of the rail line and roneeded to allow the Preferred Alternative safely and efficiently. 

Impacts - trucks - rail lines - Moterm 

Railroad crossings in the area around the Moterm terminal need improvement and will only become more degraded with increased rail activity. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 

Impacts - trucks - rail lines - Oak 

Are they going to upgrade all the rail lines within the CP Oak terminal area that are feeding into that yard, and not only the train lines but the traffic lines like Evergreen and Wyoming? 

The Preferred Alternative does not include at the Oak Terminal only the removal of itfunction. 

Impacts - trucks - rail lines - other traffic 

The DEIS projects an overall increase in train traffic (freight and passenger/AMTRAK). Improvements to tracks and related infrastructure are planned under all action alternatives. How will this increase in train activity affect the surrounding communities? 

The 2030 intermodal component at the LivYard growth is ten additional trains per daestimated increase of 40. No significant nare anticipated due to the increased intermtraffic. And, the other train movements arby other governments than MDOT. Their defined in those studies. They are not kn
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Response Category Generalized Comment Response 

Impacts - trucks - rail lines - Wyoming and Schaefer 

Will there be any change in the way the north/south traffic is affected by the train crossings such as at Schaefer and Wyoming? No. 

Impacts - trucks - rail volumes 

Has there been any identification of current rail volumes and the potential increase or decrease for each alternative? 

Yes. These are presented on Table 4-37 introductory text to Section 4.9. 

Impacts - trucks - roads 

Improvements are needed to all roads and viaducts around the Livernois-Junction Yard, including but not limited to, John Kronk, Central, Lonyo, Dragoon, Wyoming, Fort and Livernois. 

Dix at Central and Livernois at I-94 will be part of the project. The grade separation the rail line will also be part of the project take over that portion of Central Avenue frjurisdiction. All other roads in the area exAvenue, I-94, and I-75 are under local govcontrol. 

Impacts - trucks - roads improved 

Will area roads around the terminal, such as, Livernois, Central, John Kronk, and Wyoming be improved? 

Dix at Central and Livernois at I-94 will be part of the project. The grade separation the rail line will also be part of the project take over that portion of Central Avenue frjurisdiction. All other roads in the area exAvenue, I-94, and I-75 are under local govcontrol. 

Impacts - trucks - roads maintenance Who is going to fix the roads? 

The owner of the road is responsible for itthe case of the roads around the PreferreMDOT is responsible for Michigan AvenueIt will take over Central Avenue to build ththe Livernois-Junction Yard. All other roacontrolled by Wayne County, the City of DCity of Dearborn. 

Impacts - trucks - roads Moterm 

Who will maintain the road improvements to Eight Mile Road that are proposed on page S-31? 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. Nupkeep of Eight Mile Road is the responsi

Impacts - trucks - timing 

The FEIS should phase any changes to Junction yard that result in increased truck traffic to coincide with the completion of the I-75 Gateway Project. 

The Gateway Project at the Ambassador complete at about the time the DIFT improunderway. 

Impacts - trucks - viaducts 

All railroad viaducts need to be repaired, maintained and well lit with proper drainage. 

Viaduct actions in the Livernois-Junction Ythe responsibility of either the railroads or jurisdictions. 

Impacts - trucks - viaducts improved 

All railroad viaducts need to be repaired or replaced if necessary. 

Viaduct actions in the Livernois-Junction Ythe responsibility of either the railroads or jurisdictions. The owner of the road is resupkeep. In the case of the roads around tAlternative, MDOT is responsible for Michand I-94. All other roads are controlled by County, the City of Detroit or the City of D
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Response Category Generalized Comment Response 

Impacts - trucks - vibration 

My concern is about truck traffic. I live one street 

over from Fort and less than a block from I-75. I already have cracks in my foundation. I'm wondering, if we're going to have all this truck traffic, are they going to help people get their houses stabilized. 

MDOT offers basement surveys that docuprior to construction if construction is claimdamage. However, this project cannot recproblems. 

Impacts - trucks - volumes 

The public roadway network is depicted in the DEIS, but there is no description of truck volumes or truck routes. Truck volumes are shown in Figure 4-11. 

Impacts - trucks - weight 

I'm concerned about what's going to happen with the intermodal trucks with their weight and their size. 

Intermodal trucks are regulated by the stasize and weight. 

Impacts - trucks - Woodward and Eight Mile Road 

Eighteen wheelers traveling on Woodward and Eight Mile are not the kind of vehicles they were designed to carry. 

Woodward and Eight Mile Road are state designed to carry all traffic. 

Impacts - trucks - Wyoming 

Alternatives 3 & 4 in particular increase the levels of truck traffic in Dearborn, especially development of new gates on the western side of the LivernoisJunction Yard. 

The Preferred Alternative includes two gaand two off Livernois. These gates will rein truck traffic volumes on Wyoming that aFigure 4-11. 

Impacts - trucks - Wyoming - capacity 

Wyoming is not large enough to accommodate the proposed increase in truck traffic. 

The Preferred Alternative includes two gaand two off Livernois. These gates will rein truck traffic volumes on Wyoming that aFigure 4-11. 

Impacts - trucks - Wyoming - capacity intersection 

Wyoming is going to be at or above capacity in 2025, based on the numbers that MDOT provided. 

Updated numbers for the Preferred AlternWyoming to be within capacity. 

Impacts - trucks - Wyoming - Dearborn 

Of concern is the potential impact of increased truck traffic in surrounding neighborhoods as well as the shift in trucks to the Dearborn community. The majority of trucks would use newly created west entrances, passing the Eugene Porath neighborhood and the south Dearborn neighborhood located just north of Lapeer Park. 

There will be a decrease of intermodal truneighborhoods. The houses in the Eugenneighborhood are being purchased and dthe city of Dearborn. The gate nearest Lablock away. It will not be impacted by the Alternative. 

Impacts - trucks - Wyoming - delays 

Delays in Wyoming have important implications for residents in south Dearborn. Also, there's a Dearborn fire station on Wyoming. 

The Preferred Alternative includes two gaand two off Livernois. These gates will rein truck traffic volumes on Wyoming that aFigure 4-11. 

Impacts - trucks - Wyoming - gates 

There is concern associated with more truck traffic being generated by a proposed terminal gates on Wyoming. 

Comment acknowledged. The Preferred Aincludes two gates off Wyoming and two oThese gates will result in changes in truck on Wyoming that are shown in Figure 4-1

Impacts - trucks - Wyoming - PM 

Traffic on Wyoming will exacerbate the existing high levels of particulate matter. 

Reductions brought by cleaner engines angreatly reduce particulate matter generate
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Response Category Generalized Comment Response 

Impacts - trucks - Wyoming - school 

The proposed use of Wyoming Avenue will have an adverse affect on school buses which use Wyoming. 

School buses commonly travel on arterial truck traffic. 

Impacts - trucks - Wyoming - school buses 

A new elementary school and community center have been built on Wyoming Avenue and Wyoming is the main school bus route. 

School buses commonly travel on arterial truck traffic. 

Impacts - trucks - Wyoming - school truck traffic 

Most of the alternatives use Wyoming, which is used to bus our kids to local schools. Use of Wyoming is totally detrimental to our neighborhood and will hamper economic growth. 

School buses commonly travel on arterial truck traffic. Wyoming is an arterial highwcommercial/industrial area. Economic groto be improved by implementing the Prefe

Impacts - trucks - Wyoming - shifts from Livernois 

The shift of the majority of the trucks from the current eastern entrances to the west directly affects the Arab-American and Muslim populations there. 

The presence of a nearby concentration opopulations of all ethnic origins at and arothe Preferred Alternative is covered in Secintermodal traffic of the Preferred Alternattargeted to affect any population. 

Impacts - tax base loss 

The proposed project would displace existing residents and businesses and remove property from the city and county tax rolls. 

The economic effects of the Preferred Altedocumented in Section 4.5. The loss of pforecast to be more than offset by the poseffects of the Preferred Alternative. 

Impacts - tax base loss - business 

The DIFT would result in the loss of existing businesses in Detroit and Dearborn and would be replaced with rail-owned operations that would not produce tax revenue. MDOT repeatedly mentions that jobs and businesses won't locate out of the area, but this is not supported by any evidence. 

The economic effects of the Preferred Altedocumented in Section 4.5. Businesses trelocated by the Preferred Alternative are relocate in the area defined in Section 3.4

Impacts - tax base loss - economic effects 

Given that the railroads don't pay state taxes and taxpaying businesses and residents will be displaced by the DIFT, how does the DIFT benefit taxpayers? 

The economic effects of the Preferred Altedocumented in Section 4.5. Overall, the PAlternative is forecast to create by 2030 1in the area around the terminal. And, Detother local governments and the state of Mexpected to realize significant gains in tax

Impacts - tax base loss - funding 

How will the DIFT be paid for given that the 

railroads don’t pay state taxes? 

The costs of most transportation programfinanced 100% by public/government fundof the Detroit Intermodal Freight Terminal government/public funds will cover about costs and the railroads 35%. 

Impacts - tax base loss - incorrect 

This project doesn't generate money or the tax dollars. 

The Preferred Alternative does generate tSection 4.5. 

Impacts - tax base loss - Moterm 

I live in Ferndale and am concerned about the negative impact of the DIFT Project at the Fairgrounds. It will substantially lower the base. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 
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Response Category Generalized Comment Response 

Impacts - tax base loss - SW Detroit 

With the net loss of jobs and tax base in Southwest Detroit, the net gain of jobs and tax base must be in Southwest Detroit. 

There will be a net gain of jobs and tax ba4.5. 

Impacts - tax increase 

We don't need increased taxes to keep up with fire and police protection. Comment acknowledged. 

Impacts - tax services - cost 

Local tax dollars will be required for police, fire, HAZMAT and DPW personnel. 

With the Preferred Alternative, jobs will inctax revenues will increase; see Section 4.

Impacts - tax services cost - Moterm 

Expanding the CN Yard would place financial strain on the local community by requiring additional public safety and public works resources. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 

Impacts - tax - tipping fees 

Intermodal lift tipping fees could be earmarked for specific community improvement/enhancement projects. 

"Tipping fees" are not required. The railropay for about 35% of the capital costs of tAlternative. 

Impacts - wetlands 

The DEIS estimates that between 0 and 0.08 acres of wetland impact will occur. The functions and values of impacted wetlands should be defined in the EIS and a permit will be required under Part 303 Wetlands Protection. 

Section 4.12.2 states that the wetland impacres) has minimal storm water storage cfilter capacity, and no wildlife value. A geaddress this impact will be obtained undeP.A. 451. 

Impacts - wetlands - correction 

Page 1-66 under State Permits should read Part 303 "Wetlands Protection". This correction has been made. 

Mitigation 

How can the impacts of the alternatives presented in the DEIS be evaluated without inclusion of planned mitigation for each alternative? Mitigation is covered in Section 5. 

Mitigation - air mitigation 

As part of the Community Benefits package, air quality mitigation that incorporates environmental best practices must be implemented. 

Mitigation is covered in Section 5. No negimpacts are predicted with the Preferred A

Mitigation - air mitigation - retrofit 

Will stationary equipment in the terminals like lift machines be retrofitted with newer, cleaner technology? How will MDOT mandate that the railroads comply with the newest EPA recommendations? 

The EPA regulations on diesel fuel contendiesel engines will affect terminals (off-roaequipment (intermodal trucks). There will over the trucks that use the terminal. All vsubject to idle controls while at the termina

Mitigation - air monitoring 

There needs to be a method and plan for constant monitoring and enforcement of air quality standards. 

Enforcement of air quality rules and regularesponsibility of the Michigan Department Environmental Quality and the U.S. EPA. plays a role by working with these agencie"budgets" to guide the region to attainmenAmbient Air Quality Standards. The DIFT been found to conform to the Clean Air Ac4.8.7). 

Mitigation - buffer 

The perimeter land around the entire terminal should be buffered and landscaped. 

The design of the Preferred Alternative incas described in Sections 4.9, 4.15 and 4.1
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Response Category Generalized Comment Response 

Mitigation - buffer - impacts 

The possible disruption of pedestrian and bicycle traffic along newly planned recreational pathways such as Detroit Dearborn Greenway should be assessed. 

Such impacts are assessed and documen4.2.2. 

Mitigation - buffer - eliminating roads 

All action alternatives propose relocating John Kronk and closing Lonyo and, presumably, other nearby local streets. This has the potential for causing a disruption to non-motorized activity (pedestrians and bicyclists). Additional planned remediation should be provided. 

Eliminating roads crossing the Livernois-Jcritical to the function of the yard and the smotorists. Traffic now using Lonyo that wCentral Avenue will take an additional two no trains will be encountered, eliminating severe crashes, which have occurred. Cofind pedestrians and bicyclists using Lonythe railroad tracks. 

Mitigation - buffer - landscaping 

A buffer should be built to separate people and animals from equipment at the terminal. 

Security walls proposed to be built around will accomplish this objective. 

Mitigation - buffer - Livernois & Wyoming 

Add beautification to the Livernois and Wyoming exits off of I-94 to mitigate heavy truck usage. This proposal is not part of the Preferred A

Mitigation - buffer - maintenance 

There should be a commitment to maintain the perimeter land buffer with a dedicated revenue source. 

The design of the Preferred Alternative incas described in Section 4.2. The maintenbuffer will be local government's responsib

Mitigation - buffer - south side 

The perimeter around the entire rail yard should be buffered, landscaped and greened sufficiently to mitigate air and noise impacts. 

The design of the Preferred Alternative incas described in Sections 4.15 and 4.19. Tmaintenance of the buffer will be local govresponsibility. A buffer is not needed on tthe Preferred Alternative from one block ewest to Wyoming Avenue because of the industrial uses and the Woodmere Cemet

Mitigation - Community Benefits Agreement A Community Benefits Agreement is needed. See Section 5 for mitigation. Mitigation - Community Benefits Agreement - access 

A formal written agreement is needed to ensure that there will be no truck access along the existing track that runs along the Springwells Village community. 

The design of the Preferred Alternative dothis type of access. 

Mitigation - Community Benefits Agreement - awaits development 

What policies or procedures have been developed to maintain properties after they are improved? 

The railroads will be responsible for terminmaintenance. An agreement will be put in Record of Decision. Central Avenue and interchange will be maintained by MDOT. improved or not, are the responsibility of ugovernment. 
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Response Category Generalized Comment Response 

Mitigation - Community Benefits Agreement - buffer 

Any proposal must contain an adequate maintenance plan for the perimeter along the yards with dedicated revenue sources. A written agreement with a timeline should be developed and signed outlining maintenance responsibilities. 

The design of the Preferred Alternative incas described in Sections 4.9, 4.15 and 4.1maintenance of the buffer will be local govresponsibility. 

Mitigation - Community Benefits Agreement - issues 

We need to have public resources or private resources devoted to paving the facility, providing a buffer, and better lighting. 

These issues are documented in Sections Sections 3.4, 4.9 and 4.15 (buffers); Secti(landscaping); and, Section 4.20 (lights). 

Mitigation - Community Benefits Agreement - mitigation plan 

With the No Action Alternative, the opportunity to promote local economic development and address long-overdue infrastructure improvements will be lost for years, if not forever. 

The No Action Alternative is not the PrefeThe mitigation plan addresses, to the extesuch issues that are "long-overdue." 

Mitigation - Community Benefits Agreement - railroads 

"The Enhancement Project" done a few years ago resulted in a chain link fence and some internal configuration in the yard, neither of which benefited the community a great deal. 

The "enhancement project" was not MDOwas a railroads' project. 

Mitigation - Community Benefits Agreement - shift intermodal 

It is mentioned that the other existing terminals will 

continue to operate, serving different railroad business. What assurances are there that they will 

not revert to intermodal in the future? 

The plan is to shift intermodal from all termCN/Moterm to the area of the Livernois-JuThe Pre-Development Plan Agreement beand the railroads prevents the duplication facilities. 

Mitigation - Community Benefits Package 

This is still very much about the freight companies. There is nothing in this that says, yes, we understand the concerns of the community. 

The project has been refined to address cconcerns, including mitigation, to the exte

Mitigation - construction 

Special attention should be given to movement of soil particles to surface waters during construction Section 5.3 details soil erosion and sedim

Mitigation - construction AQ 

There should be a plan to address construction emissions, including such actions as: retrofitting offroad equipment, using ultra-low sulfur diesel fuels for all equipment, limiting the age of on-road vehicles using construction to 1998 and newer vehicles, dust control plans, diesel particulate traps and oxidation catalysts, and use of existing power sources or clean fuel generators rather than temporary generators. 

Such suggested measures are covered in For the PM2.5 and PM 10 hot-spot analysestimates were made and compared to thdevelopment activities, such as closing Loreducing truck traffic on Kronk to ensure tconstruction activities do not contribute to standards. 

Mitigation - context sensitive design 

The DIFT provides an opportunity to implement a project that could act as a model of "context sensitive design" for the state and country. More work is needed. 

Context Sensitive Solutions guide all MDOdesigns. The DIFT Preferred Alternative icovered by three principles if the project gdesign. 

Mitigation - general 

Nothing was said about mitigation. Is there a mitigation plan for Southwest Detroit? Mitigation is covered in Section 5. 
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Response Category Generalized Comment Response 

Mitigation - jobs - average pay I do not believe there will be better jobs. 

Comment acknowledged. The average pajobs associated with the Preferred Alternaper year (2008 dollars). These data are inSection 4.5. 

Mitigation - jobs - by community 

When calculating net jobs loss/gained, the DEIS does not specify the number of jobs lost or gained by the community and should. It should also indicate what percentage of the new jobs are likely to be held by residents of the affected areas. 

The jobs by community are shown in Tablissue of "local" jobs is addressed in Sectio

Mitigation - jobs - Detroit area 

As a result of the changes that the DIFT introduces, how many blue-collar jobs will be created for City of Detroit residents? How many white-collar jobs? 

The specific number of permanent jobs foarea in the Preferred Alternative is 2,359, in Section 4.5.2. 

Mitigation - jobs - economic effects 

For the DIFT to go forward in a meaningful direction, there has to be a clear cut way to ensure that the majority of jobs translate into jobs for people in the metropolitan Detroit area. 

The economic effects of the Preferred Alteincluded in Section 4.5. 

Mitigation - jobs - local 

A percentage of the jobs created should accrue to 

local residents and a job training program should be developed for local residents. 

The economic effects of the Preferred Alteincluded in Section 4.5. The need for "loctraining of local residents is addressed in 

Mitigation - jobs - minority 

A local minority, women and small business utilization program should be developed to increase 

participation of these businesses in all phases of the DIFT Project. 

The need for minority participation in jobs addressed in Section 5. 

Mitigation - jobs - mitigation plan 

A percentage of the new jobs should be available to people who live in the area. 

The economic effects of the Preferred Alteincluded in Section 4.5. This issue is addextent possible, in Section 5. 

Mitigation - jobs - permanent 

What is the expectation of the average salary of new jobs? 

The average pay of permanent jobs assocPreferred Alternative is $40,000 per year These data are included in Section 4.5. 

Mitigation - jobs - programs 

What plans or proposals will be generated to ensure that the stated number of permanent and construction jobs will be available for city of Detroit residents? Such a plan would serve to mitigate the burden placed upon the City and its residents. 

This issue is addressed, to the extent pos5. 

Mitigation - lighting 

Improved lighting that is screened from adjacent residential neighbors is needed around the terminal. Planned directional lighting is discussed in 

Mitigation - limits to intermodal 

There should be no further incremental expansion of the intermodal yard outside of the negotiated boundary such as at Ward Bakery. 

Expansion beyond the limits of the Preferat the Livernois-Junction Yard is not part oAlternative. While private companies devbusinesses at locations which they choosdevelopments are eventually controlled by government. 
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Response Category Generalized Comment Response 

Mitigation - limits to intermodal - Central Depot 

No intermodal development should occur outside of Livernois-Junction yard at the Michigan Central Depot or former Ward Bakery. 

Intermodal development at the Michigan Cnot part of the Preferred Alternative. Noncannot limit private companies from develbusinesses at locations they prefer. Such are controlled by local units of governmen

Mitigation - noise mitigation 

Who is going to pay for sound barriers? The businesses that now exist should pay. MDOT will pay for noise buffering. 

Mitigation - noise mitigation 

Barrier walls that mitigate noise impacts must be developed appropriately. 

Noise mitigation is required on FHWA-spoprojects, where criteria are exceeded, and implemented for this project as is noted in Noise mitigation will be integrated into the and buffering of the terminal. 

Mitigation - noise mitigation - attenuate noise 

The only wall at Livernois will be a security wall to protect the DIFT. That security wall will also block/attenuate 

Mitigation - noise mitigation - barrier 

The green sheet included at the end of Section 5 of 

the DEIS notes that barrier walls and other elements of each terminal's design are covered in the Memorandum of Understanding between the railroads and MDOT. Yet, the term "barrier walls" never appears in the signed MOU. 

The Pre-Development Plan Agreement, in indicates that walls are the responsibility oSection 5 addresses walls that attenuate nMDOT participation. 

Mitigation - noise mitigation - buffer 

Why is there no barrier wall on the south side of the terminal? 

The design of the Preferred Alternative incas described in Sections 4.9, 4.15 and 4.1maintenance of the buffer will be local govresponsibility. A buffer is not needed on tthe Preferred Alternative from one block ewest to Wyoming Avenue because the teradjacent to industrial uses, some of which continued rail service, and the Woodmere which do not represent a security or noiseissue. 

Mitigation - noise mitigation - commerce violation 

Rail activity, particularly train assembly, should be limited at night. 

Such limitations cannot be imposed as theviolation of interstate commerce. 

Mitigation - noise mitigation - entrance 

This entrance on Livernois should be a barrier wall because of sound effects. 

There must be an opening at the entrance so trucks can get in and out. 

Mitigation - noise mitigation - "impact noise" 

An expanded noise study should address "impact noise" generated by rail yard activities and installation of noise barrier walls at all locations where noise levels impact residential areas. 

The noise analysis meets all federal and srequirements. Mitigation of noise is assocthat are part of the design of the Preferred There is no need for the project to mitigate conditions although the new walls will do sare placed. 
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Response Category Generalized Comment Response 

Mitigation - noise mitigation - Moterm 

How will noise impacts be mitigated at the Moterm terminal? 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 

Mitigation - noise mitigation - Moterm walls 

Noise walls don't work. Within a half-block of the Ferndale Yard I can hear the train. The loaders are noisier than trucks. 

Walls work for attenuating certain noise at receptors but are less effective at greater the wall. The Preferred Alternative does nchanges at the Moterm Terminal or Fairgr

Mitigation - noise mitigation - Oak 

Once the barrier wall is up at Oak on the north side, who will be responsible for maintaining it? 

The Preferred Alternative does not include at the Oak Terminal except removal of inte

Mitigation - noise monitoring 

Noise monitoring analysis needs to happen in an ongoing basis and there should be remediation measures if thresholds are exceeded. 

Noise levels are estimated in advance of a appropriate measures are taken when the consistent with commitments made in this 

Mitigation - sustainable 

The latest sustainable environmental practices must be incorporated into the development of the project. 

The design of the Preferred Alternative incthe yard for operational and water quality detention of storm drainage and landscapdescribed in Section 4.19. The railroads wresponsible for improvements on the term

Mitigation - sustainable - details 

There is a provision in the Los Angeles Community Benefits Agreements on green building principles. Comment acknowledged. 

Mitigation - sustainable - fuel cells 

Will the State consider fuel cell operated railroad systems for this study? 

Railroads will take advantage of innovatioproven and cost efficient. Fuel cell technoapply primarily to electrified, not diesel, rahave value in passenger applications wheare stop-and-go to take advantage of regebraking. 

Mitigation - SW Detroit Plan 

The city of Detroit, MDOT and SEMCOG should work with community and transportation stakeholders to develop a land use and transportation plan for Southwest Detroit. 

MDOT is supportive of such efforts at the Land use is under the control of the cities Dearborn, where the terminal of the Prefeis located. SEMCOG develops the regionaplan, based on input from local jurisdictioncooperation with MDOT. 

Mitigation - truck routes - analysis 

There should be an analysis of truck generators and routes to remove truck traffic from residential and neighborhood commercial areas. 

MDOT has attempted, throughout the DIFdevelopment of the Preferred Alternative tto community needs by: 1) positioning termboth east and west ends of the terminal to intermodal traffic out of the surrounding nedesigning the gate at Livernois so that truenter and exit to the north; 3) improving thinterchange to support use of Livernois, raCentral and other neighborhood streets; aimproving the intersection of Dix and Cent

Mitigation - truck routes - analysis plan 

The 2004 revised Master Plan of Policies directs the City to "establish and enforce designated truck routes" (Policy 8.1, 1-18). Comment acknowledged. 
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Response Category Generalized Comment Response 

Mitigation - truck routes - enforcement 

There needs to be enforcement of truck routes. How will this be accomplished? 

Enforcement of truck routes is a local poliPublic roads are for public (including truckthere is a defensible reason otherwise to r

Mitigation – truck routes - freeway connection 

The number of freeway exits should be limited to keep trucks off of local neighborhood streets. 

The Preferred Alternative will design the eLivernois-Junction yard from Livernois so only enter and exit to the north, reducing itraffic on Livernois and Dragoon to the soend of the yard, trucks will travel to/from I-Wyoming and to I-75 via Wyoming and Dione of several similar routes. It is also cothe Detroit River International Crossing StLivernois/Dragoon interchange at I-75 will thereby inhibiting trucks to and from the saccessing I-75 via Livernois Avenue. 

Mitigation – truck routes - gates 

Traffic and safety infrastructure improvements must be better addressed. Two gates can be included, one on the east and one on the west. Truck routes must not lead through residential neighborhoods. 

The Preferred Alternative includes gates oon the east and west of the Livernois-Juncensure that intermodal truck routes do not residential areas. 

Mitigation - truck routes - I-75 

Have you considered a truck way from I-75 on the east near I-96 all the way along the railroad tracks west to either Wyoming or Miller Street? 

No, because there is no opportunity to contruck roadway to I-75 due to the many ramgeometric conditions in that area. A truckthe I-75/Springwells area along the railroaconsidered early in the DIFT study, but it wthe community as being too intrusive. 

Mitigation - truck routes - Moterm 

The potential expansion of the Canadian National Terminal into the State Fairgrounds should not interfere or conflict with the City's directive to regulate truck traffic. 

The Preferred Alternative does not include at the Moterm Terminal or Fairgrounds. 

Mitigation - truck routes - Vernor All the trucks are going down Vernor Highway. 

Vernor will not be a logical route for intermusing the Livernois-Junction Yard under thAlternative. It should be noted there are mintermodal trucks in the area that use Verthis project has no control. 

Mitigation - vibration impacts/mitigation 

The DIFT would significantly increase vibration impacts on local schools and neighborhoods, but proposes no mitigation. 

Through analysis it was found there will bvibration impacts that would need to be m
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Response Category Generalized Comment Response 

Mitigation - vibration mitigation 

There is no proposed vibration mitigation under any Action Alternative. Vibrations can do major structural damage to buildings. 

Vibrations analysis in Section 4.9.3 found in the area only get to the level of annoyameasured location. Annoyance levels are structural damage levels. MDOT offers basurveys to document the existing conditioprior to construction. The purpose of such document conditions prior to construction whether construction vibration causes damof such is made. MDOT does fix damagewhere it is properly documented. 

Mitigation - vibration mitigation - Beard School 

The DEIS notes a negative impact on noise levels which reach an annoyance level only at the Beard School but proposes no mitigation to address this negative impact. 

The vibration levels noted were from rail ovariety of other equipment or activity in the electric transformers and air conditioning has no responsibility to mitigate such vibra

Mitigation - vibration mitigation - survey 

It is stated that MDOT will offer basement surveys in areas where vibration from construction could damage structures, but does not offer to fix the damage. 

The purpose of such a survey is to documprior to construction to determine whether vibration causes damage, if a claim of sucMDOT does fix damage, when and where documented. 

Public Involvement - ads 

The DIFT EIS meetings need to be better publicized. 

Section 7.2 explains the efforts made to inThe mail list grew to 25,000 by the Public Local Advisory Council, whose job it was, the word out" to its constituencies met 30 notifications of each meeting. An "800" nuavailable 24/7. Ads were placed in severaannouncing all public meetings. MDOT hproject documentation on its web site http://www.michigan.gov/mdot, which is frupdated. 

Public Involvement - ads - Highland Park 

Legacy News in Highland Park was not contacted to announce meetings. 

While this comment is acknowledged, Secexplains the efforts made to inform residelist grew to 25,000 by the Public Hearing. came to a meeting and signed in was conof future meetings. Ads were placed in senewspapers announcing all public meetinprovides project documentation on its web http://www.michigan.gov/mdot, which is frupdated. 

Public Involvement - cultural outreach 

The public outreach materials need to be presented in a more simple form. 

MDOT provided information in English, ArSpanish, had interpreters at all public meeoffered to meet with any person to read/indocuments, if such service were needed. 
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Response Category Generalized Comment Response 

Public Involvement - cultural outreach - residents 

Language and cultural barriers may prevent effective participation in the decision making process including public notice and comment procedures. 

MDOT provided information in English, ArSpanish, had interpreters at all public meeoffered to meet with any person to read/indocuments, if such service were needed. 

Public Involvement - governance 

There should be local community representation on 

a public project governing board as an outcome of the Community Benefits Agreement. 

Details of governance are in the Pre-DeveAgreement in Appendix F. 

Public Involvement - governance - languages 

There needs to be a local staff person to assist the community as the project goes forward. 

Comment acknowledged. MDOT and conpersons have been available throughout tstudy (see meetings list in Section 7.2). Minformation in English, Arab and Spanish, interpreters at all public meetings, and offwith any person to read/interpret project dsuch service were needed. 

Public Involvement - meetings after Public Hearing 

MDOT should be encouraged to continue a transparent process that invites community input. 

Comment acknowledged. MDOT and conpersons have been available throughout tstudy (see meetings list in Section 7.2). Minformation in English, Arab and Spanish, interpreters at all public meetings, and offwith any person to read/interpret project dsuch service were needed. 

Public Involvement - meetings after Public Hearing - final meeting 

MDOT should hold an additional round of public hearings when a preferred alternative is identified. 

A final meeting in the planning/environmebe held after approval of this FEIS. 

Public Involvement - meetings - comments 

Will all of the written and spoken comments be considered and will everyone present at the public meeting get a copy of them? 

All comments have been considered and to herein. The comments received at the subsequently from agencies, and from the the close of the commenting period on Auare available at the locations listed in the FEIS and at MDOT web site www.Michiga

Public Involvement - meetings - format 

The structure of the recent public meetings should be used for all meetings wherein there’s a public presentation, with an opportunity for public comments together with information stations. Community organizations with a strong interest in the EIS should be allowed to present information. 

Comment acknowledged. The public has information and permitted to distribute docDIFT meetings. 

Public Involvement - meetings - Highland Park 

When did the presentation to the Highland Park Planning Commission take place? 

MDOT presented to the Highland Park PlaCommission on May 5, 2005 in the evenin

Public Involvement - meetings - LAC membership 

MDOT should designate a seat on their Local Advisory Council for a representative of the City Planning Commission. 

The opportunity was afforded and a PlannCommission representative participated in Advisory Council. 
DIFT Comments on DEIS and Responses 

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

7 - 82

Response Category Generalized Comment Response 

Public Involvement - meetings - request 

Detroit City Council resolved June 25, 2003 and approved by waiver of the Mayor's Office on July 1, 

2003, to respectfully request MDOT to host as many public meetings in the affected community as is required and provide written materials widely distributed to ensure community members understand this project. 

Comment acknowledged and adhered to. list of meetings in Section 7.2. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

8 - 1

SECTION 8 

LIST OF PREPARERS 

8.1 Federal Highway Administration 

James R. Cramer, Planning Program Manager/Air Quality Specialist, Federal Highway 

Administration. Bachelor of Civil Engineering, The Ohio State University. Thirty-eight years’ 

experience in transportation planning, engineering and air quality analysis. 

Mary Finch, Civil Rights Program Manager, Federal Highway Administration (FHWA). B.S. 

in Management, Northwood University; A.A.S. degrees in Accounting and Human Services, 

University of Alaska Anchorage; Master Compliance Administrator (MCA) Certification, 

Morgan State University. Twenty-four years in federal government including seven in 

Department of Defense Civil Engineering, 17 in Department of Transportation with ten in Federal 

Aviation Administration and seven in FHWA. 

Ryan Rizzo, Major Project Manager, Federal Highway Administration. B.S. in Civil 

Engineering, Michigan State University; M.S. Engineering, University of Michigan. Associate 

Certificate in Project Management – ESI and The George Washington University School of 

Business. Twenty-four years’ experience in transportation planning and engineering. 

David T. Williams, Environmental Program Manager. B.A. in Environmental Policy and 

Technology, University of Michigan; M.P.A. Environmental Policy & Natural Resources 

Management, University of Washington; 19 years of environmental experience (nine of those 

years include NEPA). 

8.2 Michigan Department of Transportation 

Larry Karnes, Freight Policy Specialist. B.S. in Geography, Michigan State University; M.A. 

in Transportation Geography, Western Michigan University. Two years’ experience teaching 

Geography at The Ohio State University. Three years’ experience with the federal government. 

Four years experience as Chief Transportation Planner for the East Central Michigan Planning & 

Development Regional Commission. Twenty-six years’ experience in freight transportation 

planning with MDOT. Managed original conceptual planning effort. 

Lori Noblet, Environmental Coordinator. B.S. in Political Science, University of Wyoming; 

Masters in Urban Planning (MUP), Michigan State University; 21 years of experience with 

MDOT in preparing environmental impact statements and assessments. 

Robert Parsons, Public Hearings Officer. B.S. in Interpersonal and Public Communications, 

Central Michigan University. Eighteen years of experience in communications at MDOT. 

Coordination of the public involvement effort. 

Terry Stepanski, Project Manager, B.S. in Civil Engineering, Michigan Technological 

University. Registered Professional Engineer in the State of Michigan. Twenty-three years of 

experience in all phases of Highway Development, Design, Construction and Maintenance at 

MDOT. Review of the entire EIS. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

8 - 2

William J. Swagler, Right-of-Way Estimate. B.A. in Business Management, Northwood 

University. Cost Estimator and Licensed Real Estate Appraiser, 29 years’ experience with the 

MDOT, Real Estate Division. Developer of the Conceptual Stage Relocation Plan. 

Other MDOT Personnel Assigned to this Project:

Mohammed Alghurabi, initial project manager 

Michael Anglebrandt, Project Area Contamination Survey review 

Geralyn Ayers, environmental review 

Lloyd Baldwin, cultural resources review 

Margaret Barondess, environmental review 

Richard Bayus, indirect and cumulative effects 

Sue Datta, Metro Region representative, EIS review 

Jeff Edwards, Metro Region representative, planning review 

Tom Hanf, air quality and noise analysis review 

Heather Hicks, contaminated site analysis review 

Catherine Jensen, traffic review 

Greg Johnson, Metro Region Engineer 

Amy Lipset, traffic review 

Bethany Matousek, stormwater 

Kim Moody-Holmes, contaminated site analysis 

Lori Noblet, EIS review and community impact analysis review and environmental justice 

Sherry Piacenti, real estate 

Douglas Proper, mitigation review 

Kelly Ramirez, Conceptual Stage Relocation Plan 

James Robertson, archaeological effects 

Dave Ruggles, archaeological review 

Dave Schuen, threatened and endangered species review 

Frank Spica, noise analysis review 

Richard Wolinski, ecology 

David Wresinski, Division Administrator 

Ulrika Zay, coastal resources 

Andrew Zeigler, project review 

Tom Zurburg, noise analysis review 

8.3 Consultants Disclosure Statement 

The consultants performing the analysis for this environmental document have no financial or 

other interest in the outcome of this project, in accordance with Council on Environmental 

Quality Regulation, 40, C.F.R. 1506.5(c) (1999). 

8.4 Consultant Team 

Joseph C. Corradino, Project Manager, The Corradino Group. B.C.E. Villanova University; 

M.S.C.E., Purdue University. Forty-one years of project management and environmental 

experience. Principal author of EIS and quality control on supporting Technical Reports. 

Jim Hartman, Traffic Projections and Analysis, The Corradino Group, B.S.C.E, Michigan 

State University. Fifteen years of experience in civil engineering planning with emphasis on 

traffic analysis. Traffic Report. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

8 - 3

Richard Ray, Transportation Planner, The Corradino Group, B.A., University of Iowa; M.S. 

Urban and Regional Planning, University of Iowa. Ten years of experience in transportation 

planning and NEPA documentation. 

Ted Stone, Environmental Manager, The Corradino Group. B.A., Northwestern University. 

More than 32 years experience in preparation of environmental documentation. Noise Technical 

Report, Air Quality Technical Report. 

Michael Tackett, Senior Environmentalist, The Corradino Group, B.S. and M.S. Forestry, 

University of Kentucky. Twenty-eight years of experience in geology, soils, and contamination. 

Project Area Contamination Survey. 

Mark Butler, Planner, The Corradino Group, B.A., Boston College; M.S. Planning, Florida 

State University; M.P.A., Florida State University. More than seven years experience in land use 

and development planning and transportation planning. Economic Impact Technical Report. 

C. Stephan Demeter, Senior Historical Archaeologist/Principal Investigator, Commonwealth 

Cultural Resources Group. B.A. Anthropology and History Wayne State University; M.A 

Anthropology, Wayne State University. Thirty-two years performing historic resource surveys. 

John Freeland, Wetland Analysis, Tilton & Associates, Inc., Ph.D., PWS. B.S. Grand Valley 

State University; M.S. University of New Hampshire; Ph.D. North Dakota State University. 

Seventeen years of wetland and integrated resource assessment. Wetlands Report. 

Deborah Schutt, Socioeconomic Analysis, Schutt and Company; B.A. Valparaiso University; 

M.S. Urban Planning Wayne State University. Twenty-nine years of management and planning 

experience. 

Randy Henke, Alfred Benesch & Company, B.S. University of Wisconsin-Madison. Twentynine years experience in railroad engineering, planning and operations both internationally and 

domestically. Engineering Concepts Report. 

Michael Kunz, Alfred Benesch & Company, B.S. Marquette University. Five years railroad track 

layout and design. Engineering Concepts Report. 

Doug Strauss, Engineer, Alfred Benesch & Company, B.S.C.E., Michigan Technical University. 

Eighteen years of civil and roadway design experience. Engineering Concepts Report. 

Phil Walsh, Alfred Benesch & Company, B.E. University of Cantabury, New Zealand. Twentythree years experience in railroad engineering and management. Engineering Concepts Report. 

Terry Campbell, Analytical Planning Services, B.A., M.A., and M.U.A., Wichita State 

University, Ph.D., University of Southern California. Thirty-one years regional economic and 

development planning. Economic Impact Technical Report. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

8 - 4
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

9 - 1

SECTION 9 

DISTRIBUTION LIST 

The following is a list of agencies, organizations, persons and organizations to whom the FEIS 

was sent: 

Federal Agencies

Advisory Council on Historic Preservation 

Environmental Protection Agency, Administrator, Washington, D.C. 

Environmental Protection Agency, Region V 

Federal Aviation Administration 

Federal Emergency Management Agency 

Federal Railroad Administration 

Federal Transit Administration 

U.S. Army, Corps of Engineers 

U.S. Department of Agriculture 

U.S. Department of Agriculture, Natural Resource Conservation Service 

U.S. Department of Health and Human Services, Center for Disease Control and Prevention, 

National Center for Environmental Health 

U.S. Department of Homeland Security 

U.S. Department of Housing and Urban Development, Area Director 

U.S. Department of the Interior, Fish and Wildlife Service 

State Agencies

Michigan Department of Agriculture 

Michigan Department of Community Health 

Michigan Department of Environmental Quality 

Michigan Department of History, Arts and Library, State Historic Preservation Office 

Michigan Department of Labor and Economic Growth 

Michigan Department of Natural Resources 

Michigan Economic Development Corporation 

Michigan Environmental Science Board 

Michigan State Fairgrounds 

Local Jurisdictions and Agencies

Michigan United Conservation Clubs, Inc. 

Sierra Club 

Clean Water Action, Michigan 

Michigan Environmental Council 

City of Detroit 

Detroit Department of Transportation 

City of Dearborn 

City of Ferndale 

Oakland County 

Southeast Michigan Council of Governments (SEMCOG) 

Oakland County Commission 

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

9 - 2

Wayne County Commission 

Wayne County Road Commission 

State Senator Hansen Clarke, District 1 

State Senator Irma Clark-Coleman, District 3 

State Senator Samuel Thomas, III, District 4 

State Senator Tupac Hunter, District 5 

State Senator Gilda Jacobs, District 14 

State Representative Fred Durhal, District 6 

State Representative Gabe Leland, District 10 

State Representative Rashid Tlaib, District 12 

State Representative Gino Polidori, District 15 

State Representative Ellen Lipton, District 27 

U.S. Senator Carl Levin 

U.S. Senator Debbie Stabenow 

U.S. Representative Carolyn Cheeks Kilpatrick 

U.S. Representative John Conyers, Jr. 

U.S. Representative Sander Levin 

U.S. Representative John Dingell 

Other 

CSX 

Canadian National Railroad 

Canadian Pacific Railway 

Norfolk Southern Railroad 

Ford Motor Company 

DaimlerChrysler 

General Motors 

Community Action Against Asthma 

Detroit Intermodal Freight Terminal Local Advisory Council and Committee Members 

Ziibiwing Cultural Society, The Saginaw Chippewa Indian Tribe 

Commenters 

All those making substantive comments on the DEIS will receive a copy of the FEIS. 
INDEX 

Page

Act 451, Part 361...............................................................................1-36, 1-47, 4-105, 4-199, 4-202, 4-204 

Agency Coordination ..............................................................................4-173, 4-214, 4-254, 5-1, 6-22, 7-1 

Air Quality............................................................. 1-18, 1-20, 1-32, 1-49, 4-91, 4-105, 4-237, 4-249, 4-253 

Alternatives ........................................................................................................................................ 1-3, 3-1 

Alternatives Eliminated from Further Study ............................................................................................. 3-2 

Archaeological Resources ............................................................................................................ 1-37, 4-204 

Bicycle Considerations............................................................................................................................ 4-54 

Clean Water Act .......................................................................................................... 1-45, 1-47, 4-254, 5-3 

Community Cohesion..........................................................................................................1-12, 4-40, 4-250 

Community Facilities .............................................................................................................................. 4-49 

Construction Noise .................................................................................................................................... 5-5 

Contaminated Sites..............................................................................1-13, 1-19, 1-39, 4-219, 4-239, 4-253 

Cost.......................................................................................................................... 1-48, 4-99, 4-256, 4-257 

Crashes .......................................................................................................................... 1-12, 4-36, 4-40, 5-8 

Cultural Resources .................................................... 1-19, 4-89, 4-92, 4-204, 4-239, 4-249, 4-253, 5-7, 6-2 

Description of the Preferred Alternative ................................................................................................... 1-3 

Early Coordination .......................................................................................... 1-36, 1-49, 4-173, 4-214, 7-1 

Economics ...........................................................................................1-20, 4-91, 4-95, 4-237, 4-249, 4-252 

Emergency Response ................................................................................................................... 1-45, 4-254 

Energy ....................................................................................................................1-48, 4-239, 4-253, 4-256 

Environmental Consequences ................................................................................................................... 4-1 

Environmental Justice ...................................................................................... 1-16, 1-49, 4-75, 4-89, 4-238 

Executive Order 11990..................................................................................... 1-36, 1-47, 4-202, 4-204, 5-3 

Executive Order 11998.......................................................................................................................... 4-201 

Executive Order 12898..........................................................................................................1-17, 4-75, 4-89 

Farmland.................................................................................................................1-16, 4-105, 4-239, 4-253 

Federal Agency Coordination........................................................................................................... 6-22, 7-1 

Floodplains ................................................................................................................................... 1-36, 4-200 

Floodways .................................................................................................................................... 1-36, 4-201 

Groundwater.............................................................................................................. 1-40, 4-200, 4-223, 5-4 

Historic Resources.............................................................................................. 1-37, 4-205, 5-3, 6-17, 6-23 

Land Use......................................................................... 1-16, 1-18, 1-41, 1-43, 4-101, 4-237, 4-249, 4-252 

Lighting .................................................................................................1-46, 1-50, 4-215, 4-254, 4-255, 5-8 

List of Preparers ........................................................................................................................................ 8-1 
INDEX (continued)

Page

Maintaining Traffic .......................................................................................................................... 4-56, 5-5 

Mass Transit ............................................................................................................................................ 4-55 

Mitigation ............................................................................................................. 1-10, 1-50, 1-51, 3-41, 5-1 

Need ................................................................................................................................................... 2-3, 6-2 

No Action Alternative ....................................................................1-11, 2-5, 3-2, 3-36, 4-137, 4-159, 4-249 

Noise .................................................... 1-18, 1-35, 1-42, 1-51, 2-10, 4-91, 4-178, 4-238, 4-250, 4-253, 5-2 

Ozone.........................................................................................1-23, 4-105 to 4-110, 4-136, 4-155 to 4-157 

Parkland........................................................................................................................................ 1-38, 4-214 

Particulates ......................................................................................4-93, 4-116, 4-125, 4-136, 4-158, 4-161 

Pedestrian Considerations ....................................................................................................................... 4-54 

Permits.....................................................................................................1-36, 1-47, 4-93, 4-201, 4-256, 5-3 

Property Taxes....................................................................................................................................... 4-101 

Public Involvement........................................................................................................................... 1-49, 7-1 

Purpose ...................................................................................................................................................... 2-1 

Relocations .................................................................................................................. 1-16, 4-75, 4-91, 4-93 

Scoping......................................................................................................................................6-23, 7-1, 7-4 

Section 4(f).................................................................................................................... 6-1, 6-16, 6-20, 6-24 

Section 401 Permit ........................................................................................................................... 1-47, 5-3 

Section 404 Permit ........................................................................................................................... 1-47, 5-3 

Sedimentation............................................................................................................................................ 5-2 

Social Impacts ......................................................................................................................................... 4-40 

Soils........................................................................................................1-40, 1-46, 4-239, 4-253, 4-255 5-2 

State Agency Coordination........................................................................................................5-7, 6-22, 7-1 

Surface Water........................................................................................................................1-40, 4-200, 5-5 

Terminal Security ..................................................................................................................1-45, 4-254, 5-2 

Threatened and Endangered Species ......................................................................1-35, 4-199, 4-239, 4-253 

Title VI ................................................................................................................. 1-17, 4-57, 4-75, 4-89, 7-1 

Traffic............................................................................................................1-11, 1-17, 1-26, 4-1, 4-56, 5-5 

Vibrations ...............................................................................................................1-35, 4-178, 4-196, 4-199 

Visual Conditions..............................................................................................................1-38, 4-215, 4-219 

Water Quality ....................................................................... 1-19, 1-30, 1-42, 4-200, 4-239, 4-250, 5-4, 5-5 

Wetland Mitigation.................................................................................................................................... 5-6 

Wetlands................................................................................................................................1-36, 4-202, 5-3 

Zoning ................................................................................................................................................... 4-101