This document has been published by authorization of the Director of the State of Michigan’s Department of Transportation in 

keeping with the intent of the National Environmental Policy Act of 1969 and subsequent implementing regulations and policies, 

including Title VI of the Civil Rights Act of 1964, that direct agencies to provide the public and other agencies an opportunity to 

review and comment on proposed projects and alternatives so that potential impacts of the project can be considered and taken 

into account during the decision-making process. Requests for alternative formats of this document under Title II of the 

Americans with Disabilities Act may be made by calling 517.373.9534 or TDD 800.649.3777. 

This document has been produced by MDOT with the assistance of a team of consultants led by The Corradino Group of 

Michigan, Inc. The cost of publishing 300 copies of this document at approximately $63.42 per copy is $19,026. The document 

has been printed in accordance with Michigan Executive Directive 1991-6. 


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

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PREFACE

The National Environmental Policy Act (NEPA) of 1969 requires that the social, economic, and natural 

environmental impacts of any proposed action of the federal government be analyzed for decision-making and 

public information purposes. There are three classes of action. Class I Actions are those that may significantly 

affect the environment and require the preparation of an Environmental Impact Statement (EIS). Class II 

Actions (categorical exclusions) are those that do not individually or cumulatively have a significant effect on 

the environment and do not require preparing an EIS or an Environmental Assessment (EA). Class III Actions 

are those for which the significance of impacts is not clearly established. Class III Actions require preparing 

an EA to determine the significance of impacts and the appropriate environmental document to be prepared – 

either an EIS or a Finding of No Significant Impact (FONSI). 

This document is a Final Environmental Impact Statement (FEIS) and Final Section 4(f) Evaluation for the 

proposed improvement of an intermodal freight terminal in Wayne County in Michigan. It presents the 

Preferred Alternative, and the measures proposed to minimize harm to the project area. The Draft 

Environmental Impact Statement (DEIS) was approved April 15, 2005, and public hearings were held June 

13, 14, 15 and 16, 2005. Though more than three years has passed since the signing of the DEIS, it has been 

determined that a supplemental DEIS is not required (see the Foreword in this FEIS). This FEIS reflects the 

comments received during the public hearing process and updated data in all critical areas. This FEIS will be 

distributed to federal, state and local agencies, private organizations and all members of the public making 

substantive comments on the DEIS. Following the circulation of this FEIS, it will be forwarded to the Federal 

Highway Administration (FHWA) with a recommendation that a Record of Decision (ROD) be issued. The 

ROD will allow the project to move forward into the design phase. The project has been included in the 

Southeast Michigan Council of Government’s (SEMCOG’s) cost-feasible Regional Transportation Plan. This 

means that federal, state and local funding has been identified. A Pre-Development Plan Agreement (PDPA) 

found in Appendix F indicates the level of funding commitments of the involved railroads. 

Because of adverse effects on historic resources this document also serves as coordination documentation 

under Section 106 of the National Historic Preservation Act of 1966, as amended, and as the Final Section 

4(f) Evaluation, under Section 4(f) of the Department of Transportation Act of 1966, which protects these 

resources. 

This document was prepared by a consultant working with the Michigan Department of Transportation 

(MDOT), in cooperation with FHWA and other members of a Technical Team. The Technical Team includes 

representatives from the following divisions within MDOT: Design, Environmental, Planning, 

Communications, Intermodal/Multimodal, Real Estate, Traffic and Safety, and the Metro Region. Information 

was also furnished by other federal and state agencies, local units of government, public interest groups, a 

Steering Committee comprised of representatives of MDOT, the City of Detroit, railroads, and automakers, 

and a Local Advisory Council of stakeholders and interested local groups, and individual citizens. 

This Final EIS is available for review at the MDOT’s Lansing office at 425 West Ottawa Street (third floor), 

48909; the Metro Region office at 18101 W. Nine Mile Road, Southfield, MI 48075; the Detroit 

Transportation Service Center at 1400 Howard Street, Detroit, MI 48216; and, the Oakland Transportation 

Service Center at 2300 Dixie Highway, Waterford, MI 48238. It is also available at the Ferndale Public 

Library, 222 E. Nine Mile, Ferndale, MI 48220; the Henry Ford Centennial Library, 16301 Michigan Avenue, 

Dearborn, MI 48126; the Detroit Public Library, 5201 Woodward Avenue, Detroit, MI 48202; and the Bowen 

Branch of the Detroit Public Library, 3648 W. Vernor, Detroit, MI 48216. Technical documents referred to in 

this Environmental Impact Statement are available at the same locations. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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A Federal agency may publish a notice in the Federal Register, pursuant to 23 USC Section 139(I), 

indicating that one or more Federal agencies have taken final action on permits, licenses, or approvals for 

a transportation project. If such notice is published, claims seeking judicial review of those Federal 

agency actions will be barred, unless such claims are filed within 180 days after the date of publication of 

the notice, or within a shorter time period as specified in the Federal laws pursuant to which judicial 

review of the Federal agency action is allowed. If no notice is published, then the periods of time that 

otherwise are provided by the Federal laws governing such claims will apply. 

The reader will note bold text in green boxes such as surrounds this paragraph. This highlights 

changes for the FEIS related to the Preferred Alternative. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table of Contents

Page

Preface......................................................................................................................................................... iii 

SECTION 1 – SUMMARY

 1.1 Background ..................................................................................................................... 1-1 

 1.2 Practical Alternatives Considered in DEIS ..................................................................... 1-3 

 1.3 Description of the Preferred Alternative ......................................................................... 1-3 

 1.4 Impacts .......................................................................................................................... 1-11 

 1.4.1 Traffic and Safety............................................................................................. 1-11 

 1.4.2 Relocations, Community Cohesion, Environmental Justice, 

 Land Use, and Farmland ................................................................................. 1-16 

 1.4.3 Economics – Permanent and Construction Jobs............................................... 1-20 

 1.4.4 Air Quality........................................................................................................ 1-20

 1.4.4.1 Pollution Burden Analysis .................................................................. 1-20 

 1.4.4.1.1 Terminal Area Pollution Burden .......................................... 1-21 

 1.4.4.1.2 Public Roadway Pollution Burden ...................................... 1-21 

 1.4.4.2 Mobile Source Air Toxics (MSATs) – Quantitative Analysis ............ 1-22 

 1.4.4.2.1 Terminal Area MSAT Quantitative Analysis...................... 1-22 

 1.4.4.2.2 Roadway MSAT Quantitative Analysis.............................. 1-22 

 1.4.4.3 SEMCOG Attainment Status/Air Quality Conformity........................ 1-22 

 1.4.4.3.1 General Conformity............................................................. 1-23 

 1.4.4.3.2 Transportation Conformity.................................................. 1-23 

 1.4.4.4 Construction Impacts – Preferred Alternative..................................... 1-34 

 1.5 Noise and Vibrations..................................................................................................... 1-35 

 1.6 Threatened and Endangered Species............................................................................. 1-35 

 1.7 Waterways/Water Quality/Floodplains/Coastal Resources........................................... 1-36 

 1.7.1 Waterways........................................................................................................ 1-36 

 1.7.2 Water Quality ................................................................................................... 1-36 

 1.7.3 Floodways and Floodplains.............................................................................. 1-36 

 1.7.4 Coastal Resources ............................................................................................ 1-36 

 1.8 Wetlands........................................................................................................................ 1-36 

 1.9 Historic and Archaeological Resources......................................................................... 1-37 

 1.10 Parkland and Public Recreation Land ........................................................................... 1-38 

 1.11 Visual Conditions.......................................................................................................... 1-38 

 1.12 Contaminated Sites........................................................................................................ 1-39 

 1.13 Indirect and Cumulative Impacts .................................................................................. 1-41 

 1.14 Emergency Response Controls...................................................................................... 1-45 

 1.15 Terminal Security.......................................................................................................... 1-45 

 1.16 Terminal Lighting ......................................................................................................... 1-46 

 1.17 Soils .......................................................................................................................... 1-46 

 1.18 Permits .......................................................................................................................... 1-47 

 1.19 Energy .......................................................................................................................... 1-48 

 1.20 Implementation Cost ..................................................................................................... 1-48 

 1.21 The Relationship Between Local Short-Term Uses of the Environment and the 

Maintenance and Enhancement of Long-Term Productivity ........................................ 1-48 

 1.22 Irreversible and Irretrievable Commitments of Resources Which Would be 

Involved in the Proposed Action ................................................................................... 1-48 

 1.23 Areas of Controversy .................................................................................................... 1-49 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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 1.24 Public Involvement ....................................................................................................... 1-49 

 1.25 Unresolved Issues.......................................................................................................... 1-50 

 1.26 Project Status................................................................................................................. 1-50 

 1.27 Additional Mitigation or Modifications ........................................................................ 1-50 

SECTION 2 – PURPOSE OF AND NEED FOR ACTION

 2.1 Purpose of the Proposed Action ...................................................................................... 2-1 

 2.1.1 Project Background............................................................................................ 2-1 

 2.2 Need for the Proposed Action ......................................................................................... 2-3 

2.2.1 Intermodal Terminal Capacity Versus Demand................................................. 2-4 

 2.2.2 Intermodal Connectivity Needs.......................................................................... 2-6 

 2.3 Government Involvement................................................................................................ 2-9 

 2.4 Summary ......................................................................................................................... 2-9 

SECTION 3 – ALTERNATIVES 

 3.1 Alternatives Development............................................................................................... 3-1

 3.2 Alternatives Eliminated from Further Study ................................................................... 3-2 

 3.2.1 Other Sites for Intermodal Terminals................................................................. 3-2 

 3.2.2 Greenfield Site.................................................................................................... 3-4 

 3.2.3 Communities for a Better Rail Alternative......................................................... 3-4 

 3.3 Project Status................................................................................................................... 3-5 

 3.4 Practical Alternatives ...................................................................................................... 3-5 

 3.4.1 Characteristics of Proposed Intermodal Terminals ............................................ 3-5 

 3.4.2 Terminal Areas................................................................................................. 3-30 

 3.5 Preferred Alternative ................................................................................................... 3-36 

SECTION 4 – AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

 4.1 Traffic ............................................................................................................................ 4-1 

 4.2 Social Impacts/Community Cohesion ........................................................................... 4-40 

 4.2.1 Community Facilities ....................................................................................... 4-49 

 4.2.2 Considerations Relating to Pedestrian Access and Bicycle Use ...................... 4-54 

 4.2.3 Considerations Relating to Mass Transit Service............................................. 4-55 

 4.2.4 Maintaining Traffic .......................................................................................... 4-56 

 4.3 Population Characteristics of Key Groups .................................................................... 4-57 

 4.3.1 Title VI ............................................................................................................. 4-57 

 4.3.2 Environmental Justice ...................................................................................... 4-75 

 4.4 Relocations.................................................................................................................... 4-93 

 4.4.1 Alternative 1: No Action ................................................................................. 4-94 

 4.4.2 Alternative 2: Improve/Expand Existing Terminals........................................ 4-94 

 4.4.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal 

 Activity at Livernois-Junction Yard Area ........................................................ 4-94 

 4.4.4 Alternative 4: The Composite Option ............................................................. 4-94 

 4.5 Economic Impacts ......................................................................................................... 4-95 

 4.5.1 Introduction ...................................................................................................... 4-95 

 4.5.2 Results .............................................................................................................. 4-99 

 4.6 Land Use and Zoning .................................................................................................. 4-101

 4.6.1 Livernois-Junction Yard................................................................................. 4-102 

 4.6.2 CP/Expressway Terminal............................................................................... 4-103 

 4.6.3 CP/Oak Terminal............................................................................................ 4-103 

 4.6.4 CN/Moterm Terminal..................................................................................... 4-103 

 4.7 Farmland and Open Space/Part 361 of Michigan Act 451 Lands/Forest Land........... 4-105 
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 4.8 Air Quality Analysis.................................................................................................... 4-105 

 4.8.1 Air Quality Conformity.................................................................................. 4-106 

 4.8.2 Pollution Trends – NAAQS Pollutants and Air Toxics.................................. 4-107 

 4.8.2.1 Air Quality Trends and EPA Measures to Improve Air Quality ........ 4-107 

 4.8.2.2 Monitoring Data ................................................................................. 4-110 

 4.8.3 Air Toxics and PM 2.5 – Health Effects and Limitations 

 of Current Science.......................................................................................... 4-110 

 4.8.4 Terminal Pollutant Burden Estimates............................................................. 4-116 

 4.8.5 Public Roadway Pollutant Burden Estimates................................................. 4-125 

 4.8.6 CO Hot-spot Analysis .................................................................................... 4-134 

 4.8.7 FEIS Preferred Alternative Air Quality Analysis ........................................ 4-135 

 4.8.7.1 Recent EPA Actions and NAAQS Pollutant Trends ........................ 4-136 

 4.8.7.2 No Action and Preferred Alternative Pollutant Burdens................. 4-137 

 4.8.7.2.1 Terminal Area Pollutant Burden Forecasts..................... 4-137 

 4.8.7.2.2 Public Roadway Pollutant Burden Forecasts................... 4-138 

 4.8.7.3 Mobile Source Air Toxics (MSATs) – Quantitative Analysis ......... 4-145 

 4.8.7.3.1 Guidance and Trends ........................................................ 4-146 

 4.8.7.3.2 Other Studies ..................................................................... 4-150 

 4.8.7.3.3 Quantitative MSAT Analysis – Preferred Alternative...... 4-151 

 4.8.7.4 SEMCOG Attainment Status/Air Quality Conformity.................... 4-155 

 4.8.7.4.1 NAAQS and Regional Attainment Status......................... 4-155 

 4.8.7.4.2 General Conformity........................................................... 4-156 

 4.8.7.4.3 Transportation Conformity ............................................... 4-157 

 4.8.7.5 Diesel Emissions Control Measures and Expected Effects ............ 4-177 

 4.8.7.6 Construction Impacts – Preferred Alternative ................................ 4-177 

 4.9 Noise and Vibrations................................................................................................... 4-178 

 4.9.1 Train Noise..................................................................................................... 4-188 

 4.9.2 Roadway Noise .............................................................................................. 4-196 

 4.9.3 Vibrations....................................................................................................... 4-196 

 4.10 Threatened and Endangered Species........................................................................... 4-199 

 4.11 Waterways/Water Quality/Floodplains/Coastal Resources......................................... 4-200 

 4.11.1 Waterways...................................................................................................... 4-200 

 4.11.2 Water Quality ................................................................................................. 4-200 

 4.11.3 Floodways and Floodplains............................................................................ 4-201 

 4.11.4 Coastal Resources .......................................................................................... 4-202 

 4.12 Wetlands...................................................................................................................... 4-202 

 4.12.1 Alternative 1: No Action ............................................................................... 4-202 

 4.12.2 Alternative 2: Improve/Expand Existing Terminals...................................... 4-202 

 4.12.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal 

 Activity at Livernois-Junction Yard Area ...................................................... 4-203 

 4.12.4 Alternative 4: The Composite Option ........................................................... 4-203 

 4.13 Historic and Archaeological Resources....................................................................... 4-204 

 4.13.1 Alternative 1: No Action ............................................................................... 4-205 

 4.13.2 Alternative 2: Improve/Expand Existing Terminals...................................... 4-205 

 4.13.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal 

 Activity at Livernois-Junction Yard Area ...................................................... 4-211 

 4.13.4 Alternative 4: The Composite Option ........................................................... 4-213 

 4.13.5 Preferred Alternative..................................................................................... 4-213 

4.14 Parkland and Public Recreation Land ......................................................................... 4-214 

 4.14.1 Alternative 1: No Action ............................................................................... 4-214 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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 4.14.2 Alternative 2: Improve/Expand Existing Terminals...................................... 4-214 

 4.14.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal 

 Activity at Livernois-Junction Yard Area ...................................................... 4-215 

 4.14.4 Alternative 4: The Composite Option ........................................................... 4-215 

 4.15 Visual Conditions........................................................................................................ 4-215 

 4.15.1 Alternative 1: No Action ............................................................................... 4-215 

 4.15.2 Alternative 2: Improve/Expand Existing Terminals...................................... 4-216 

 4.15.3 Alternative 3: Consolidate All Four Class I Railroads’ Intermodal 

 Activity at Livernois-Junction Yard Area ...................................................... 4-216 

 4.15.4 Alternative 4: The Composite Option ........................................................... 4-216 

 4.16 Contaminated Sites...................................................................................................... 4-219 

 4.17 Indirect and Cumulative Impacts ................................................................................ 4-224 

 4.17.1 Cumulative Effects......................................................................................... 4-239 

 4.18 Emergency Response Controls.................................................................................... 4-253 

 4.19 Terminal Security........................................................................................................ 4-253 

 4.20 Terminal Lighting ....................................................................................................... 4-254 

 4.21 Soils ........................................................................................................................ 4-255 

 4.22 Construction Permits ................................................................................................... 4-255 

 4.23 Energy ....................................................................................................................... 4-255 

 4.24 Implementation Cost ................................................................................................. 4-255 

 4.25 The Relationship Between Local Short-Term Uses of the Environment 

 and the Maintenance and Enhancement of Long-Term Productivity.......................... 4-256 

 4.26 Irreversible and Irretrievable Commitments of Resources Which Would 

 be Involved in the Proposed Action ............................................................................ 4-256 

SECTION 5 – MITIGATION OF IMPACTS

 5.1 Right-of-Way Acquisition and Relocation Impacts ........................................................ 5-1 

 5.2 Walls for Terminal Security............................................................................................ 5-2

 5.3 Soil Erosion and Sedimentation Control ......................................................................... 5-2 

 5.4 Environmental Permits.................................................................................................... 5-3 

 5.5 Existing Vegetation ......................................................................................................... 5-4 

 5.6 Disposal of Surplus or Unsuitable Material .................................................................... 5-4 

 5.7 Groundwater Quality....................................................................................................... 5-4 

 5.8 Surface Water Quality..................................................................................................... 5-5 

 5.9 Maintaining Traffic During Construction ....................................................................... 5-5 

 5.10 Continuance of Public Utility Service............................................................................. 5-5 

 5.11 Construction Noise and Vibration Impacts ..................................................................... 5-5 

 5.12 Control of Air Pollution During Construction................................................................. 5-6 

 5.13 Wetland Mitigation ......................................................................................................... 5-6 

 5.14 Contamination ................................................................................................................. 5-7 

 5.15 National Geodetic Survey Monuments ........................................................................... 5-7 

 5.16 Cultural Resources .......................................................................................................... 5-7 

 5.17 Additional Mitigation or Modifications .......................................................................... 5-7 

 Green Sheet – Project Mitigation Summary ................................................................. 5-9 

SECTION 6 – FINAL SECTION 4(f) EVALUATION 

 6.1 Introduction ..................................................................................................................... 6-1 

 6.2 Proposed Action and Need for Project ............................................................................ 6-2 

6.3 Description of Resources................................................................................................. 6-3 

 6.3.1 Historic Resources.............................................................................................. 6-3 

 6.3.2 Recreational Resources .................................................................................... 6-13 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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6.4 Impacts on the Section 4(f) Properties ......................................................................... 6-15 

6.5 Avoidance Alternatives ................................................................................................. 6-16

 6.5.1 Historic Properties............................................................................................ 6-17 

 6.5.2 Recreational Properties .................................................................................... 6-19 

 6.5.3 Statement of No Prudent and Feasible Alternatives......................................... 6-20 

6.6 Measures to Minimize Harm......................................................................................... 6-20 

 6.6.1 Michigan/General Box Company (Spranger/ 

 Detroit Wire Wheel Corporation)..................................................................... 6-20 

 6.6.2 6332 John Kronk .............................................................................................. 6-21 

 6.6.3 Federal Screw Works Factory .......................................................................... 6-21 

 6.6.4 Markey House .................................................................................................. 6-21 

 6.6.5 Tomms House .................................................................................................. 6-21 

 6.6.6 Michigan Central Railroad Bridge Deck.......................................................... 6-22 

 6.6.7 Michigan State Fairgrounds ............................................................................. 6-22 

6.7 Coordination.................................................................................................................. 6-22 

6.8 Section 4(f) Conclusion................................................................................................. 6-24

SECTION 7 – AGENCY COORDINATION AND PUBLIC MEETINGS

 7.1 Agency Coordination ...................................................................................................... 7-1 

 7.2 Public Meetings............................................................................................................... 7-1 

 7.2.1 Interview Process ............................................................................................... 7-2 

 7.3 Coordination with Native American Groups................................................................... 7-4 

 7.4 Public Hearing, Public Comments and Responses .................................................... 7-16 

SECTION 8 – LIST OF PREPARERS 

 8.1 Federal Highway Administration .................................................................................... 8-1 

 8.2 Michigan Department of Transportation......................................................................... 8-1 

 8.3 Consultant Disclosure Statement..................................................................................... 8-2 

 8.4 Consultant Team ............................................................................................................. 8-2 

SECTION 9 – DISTRIBUTION LIST .................................................................................................. 9-1 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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APPENDICES

 Appendix A Agency Comments on DEIS and SHPO Letters ............................................... A-1 

 Appendix B Relocation Plan - Conceptual Stage ...................................................................B-1 

 Appendix C Memorandum of Agreement with SHPO...........................................................C-1 

 Appendix D Right-of-Way Areas Needed by Alternative ..................................................... D-1 

 Appendix E Air Quality Protocol...........................................................................................E-1 

 Appendix F Pre-Development Plan Agreement Between Railroads and MDOT................ F-1 

 Appendix G Federal Highway Administration Concurrence that DEIS is Valid............... G-1 

 Appendix H Environmental Justice Analysis Approach........................................................ H-1 

 Technical Reports (Under Separate Cover and Listed Alphabetically) 

• Air Quality Impact Analysis Technical Report 

• Commodity Flow Model Report 

• Community Inventory Technical Report 

• Economic Impact Analysis Technical Report 

• Engineering Concepts Report 

• Indirect and Cumulative Impacts Analysis Technical Report 

• Noise and Vibrations Study Report 

• Project Area Contamination Survey 

• Traffic Analysis Report 

I:\Projects\2846-A-From L\WP\reports\FEIS\Chapters - Oct 2009\Beginning-TOC.doc 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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LIST OF FIGURES

 Figure 1-1a Current Class I Railroad Intermodal Terminals in Southeast Michigan ............ 1-2 

 Figure 1-1b Preferred Alternative .......................................................................................... 1-5

 Figure 1-1c Alternative Footprints ........................................................................................ 1-7 

 Figure 1-1d Major Interlockers in the Detroit Area ............................................................... 1-9 

 Figure 1-2 Forecast of Intermodal Activity (Lifts) – Without CP/Expressway................. 1-11 

 Figure 1-3 Daily Two-way Truck Traffic on Key Links ................................................... 1-14 

 Figure 1-4 Preferred Alternative with Terminals............................................................... 1-15 

 Figure 2-1 Highway Flows of Both Domestic and International Freight 

 Moving into/through Michigan .......................................................................... 2-2 

 Figure 2-2 U.S. Rail Intermodal Traffic............................................................................... 2-3 

 Figure 2-3 Key Transportation Components of Freight System.......................................... 2-7 

 Figure 3-1 Future Location of Intermodal Terminals in Southeast Michigan 

 Under Practical Alternatives .............................................................................. 3-6 

 Figure 3-2 Existing Livernois-Junction Yard Access .......................................................... 3-7 

 Figure 3-3 Livernois-Junction Yard – Alternative 2 Option A............................................ 3-9 

 Figure 3-4 Livernois-Junction Yard – Alternative 2 Option B .......................................... 3-11 

 Figure 3-5 Livernois-Junction Yard – Alternative 2 Option C .......................................... 3-13 

 Figure 3-6 Livernois-Junction Yard – Alternative 3.......................................................... 3-15 

 Figure 3-7 Livernois-Junction Yard – Alternative 4.......................................................... 3-19 

 Figure 3-8 Former CP/Expressway Terminal Access........................................................ 3-21 

 Figure 3-9 CP/Expressway Terminal – Alternative 2 ........................................................ 3-22 

 Figure 3-10 Existing CP/Oak Terminal Access................................................................... 3-23 

 Figure 3-11 CP/Oak Terminal – Alternative 2 Option A..................................................... 3-25 

 Figure 3-12 CP/Oak Terminal – Alternative 2 Option B..................................................... 3-26 

 Figure 3-13 Existing CN/Moterm Terminal Access ............................................................ 3-27 

 Figure 3-14 CN/Moterm Terminal – Alternative 2.............................................................. 3-29 

 Figure 3-15 Major Interlockers in Detroit Area................................................................... 3-31 

 Figure 3-16 Terminal Area – Livernois-Junction & CP/Expressway Terminals................. 3-32 

 Figure 3-17 Terminal Area – CP/Oak Terminal .................................................................. 3-34 

 Figure 3-18 Terminal Area – CN/Moterm Terminal ........................................................... 3-35 

 Figure 3-19 Preferred Alternative ........................................................................................ 3-39 

 Figure 4-1 Forecast of Intermodal Activity (Lifts) - DEIS .................................................. 4-2 

 Figure 4-1a I-94/Livernois Interchange Proposed Modification ........................................... 4-8 

 Figure 4-2a Alternative 2A – Livernois-Junction Yard East 

 2025 Morning Peak Volume-to-Capacity Ratios ............................................... 4-9 

 Figure 4-2b Alternative 2A – Livernois-Junction Yard East 

 2025 Afternoon Volume-to-Capacity Ratios ................................................... 4-10 

 Figure 4-3a Alternative 2B – Livernois-Junction Yard East 

 Original Scenario 2025 Morning Peak Volume-to-Capacity Ratios................ 4-11 

 Figure 4-3b Alternative 2B – Livernois-Junction Yard West 

 Original Scenario 2025 Morning Peak Volume-to-Capacity Ratios................ 4-12 

 Figure 4-3c Alternative 2B – Livernois-Junction Yard East 

 Original Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-13 

 Figure 4-3d Alternative 2B – Livernois-Junction Yard West 

 Original Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-14 

 Figure 4-3e Alternative 2B – Livernois-Junction Yard East 

 Revised Scenario 2025 Morning Peak Volume-to-Capacity Ratios ................ 4-15 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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 Figure 4-3f Alternative 2B – Livernois-Junction Yard West 

 Revised Scenario 2025 Morning Peak Volume-to-Capacity Ratios ................ 4-16 

 Figure 4-3g Alternative 2B – Livernois-Junction Yard East 

 Revised Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-17 

 Figure 4-3h Alternative 2B – Livernois-Junction Yard West 

 Revised Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-18 

 Figure 4-4a Alternative 2C – Livernois-Junction Yard 

 2025 Morning Peak Volume-to-Capacity Ratios ............................................. 4-19 

 Figure 4-4b Alternative 2C – Livernois-Junction Yard 

 2025 Afternoon Peak Volume-to-Capacity Ratios........................................... 4-20 

 Figure 4-5a Alternative 2 – CP/Expressway Terminal 

 2025 Morning Peak Volume-to-Capacity Ratios ............................................. 4-21 

 Figure 4-5b Alternative 2 – CP/Expressway Terminal 

 2025 Afternoon Peak Volume-to-Capacity Ratios........................................... 4-22 

 Figure 4-6a Alternative 2 Options A & B – CP/Oak Terminal 

 2025 Morning Peak Volume-to-Capacity Ratios ............................................. 4-23 

 Figure 4-6b Alternative 2 Options A & B – CP/Oak Terminal 

 2025 Afternoon Peak Volume-to-Capacity Ratios........................................... 4-24 

 Figure 4-7a Alternatives 2 & 4 – CN/Moterm Terminal 

 2025 Morning Peak Volume-to-Capacity Ratios ............................................. 4-25 

 Figure 4-7b Alternatives 2 & 4 – CN/Moterm Terminal 

 2025 Afternoon Peak Volume-to-Capacity Ratios........................................... 4-26 

 Figure 4-8a Alternative 3 – Consolidated Terminal 

 Original Scenario 2025 Morning Peak Volume-to-Capacity Ratios................ 4-27 

 Figure 4-8b Alternative 3 – Consolidated Terminal 

 Original Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-28 

 Figure 4-8c Alternative 3 – Consolidated Terminal 

 Revised Scenario 2025 Morning Peak Volume-to-Capacity Ratios ................ 4-29 

 Figure 4-8d Alternative 3 – Consolidated Terminal 

 Revised Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-30 

 Figure 4-9a Alternative 4 – Consolidated Terminal 

 Original Scenario 2025 Morning Peak Volume-to-Capacity Ratios................ 4-31 

 Figure 4-9b Alternative 4 – Consolidated Terminal 

 Original Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-32 

 Figure 4-9c Alternative 4 – Consolidated Terminal 

 Revised Scenario 2025 Morning Peak Volume-to-Capacity Ratios ................ 4-33 

 Figure 4-9d Alternative 4 – Consolidated Terminal 

 Revised Scenario 2025 Afternoon Peak Volume-to-Capacity Ratios.............. 4-34 

 Figure 4-9e Preferred Alternative 

 2030 Afternoon Peak Volume-to-Capacity Ratios ......................................... 4-35 

 Figure 4-10 Forecast of Intermodal Activity (Lifts) – Without CP/Expressway................. 4-37 

 Figure 4-11 Daily Two-way Truck Traffic on Key Links – No Action and Preferred ........ 4-39 

 Figure 4-12a Livernois-Junction Yard Community Facilities ............................................... 4-41 

 Figure 4-12b CP/Expressway Terminal (Now Closed) Community Facilities...................... 4-43 

 Figure 4-12c CP/Oak Terminal Community Facilities.......................................................... 4-44 

 Figure 4-12d CN/Moterm Terminal Community Facilities ................................................... 4-45 

 Figure 4-13a Community Facilities by Intermodal Terminal Area ....................................... 4-46 

 Figure 4-13b Community Facilities by Intermodal Terminal Area ....................................... 4-47 

 Figure 4-13c Detroit Urbanized Area .................................................................................... 4-58 

 Figure 4-14 Arab Ancestry Population by Census Tract in Intermodal Terminal Area ...... 4-62 

 Figure 4-15 Asian Population by Census Tract in Intermodal Terminal Area .................... 4-62 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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 Figure 4-16 Black or African American Population by Census Tract in 

 Intermodal Terminal Area................................................................................ 4-63 

 Figure 4-17 English Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-63 

 Figure 4-18 French Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-64 

 Figure 4-19 German Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-64 

 Figure 4-20 Hispanic/Latino Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-65 

 Figure 4-21 Irish Ancestry Population by Census Tract in Intermodal Terminal Area....... 4-65 

 Figure 4-22 Italian Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-66 

 Figure 4-23 Polish Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-66 

 Figure 4-24 Scottish Ancestry Population by Census Tract in Intermodal 

 Terminal Area .................................................................................................. 4-67 

 Figure 4-25 American Indian/Alaskan Native Population by Census Tract in 

 Intermodal Terminal Area................................................................................ 4-67 

 Figure 4-26 Native Hawaiian/Pacific Islander Population by Census Tract in 

 Intermodal Terminal Area................................................................................ 4-68 

 Figure 4-27 Households with Income Below Poverty by Census Tract in 

 Intermodal Terminal Area................................................................................ 4-77 

 Figure 4-28a Composite Coverage of Populations Addressed by Federal 

 Environmental Justice Executive Order ........................................................... 4-77 

 Figure 4-28b Peak Growth by Community in Southeast Michigan 1990-2000..................... 4-78 

 Figure 4-29a Economic Analysis Areas ................................................................................ 4-96 

 Figure 4-29b Integration of Commodity Flow and REMI Modeling Processes – 

 FEIS 2030......................................................................................................... 4-98 

 Figure 4-30 Construction Employment – FEIS ................................................................. 4-100 

 Figure 4-31 Emission Factor Trends.................................................................................. 4-109 

 Figure 4-32 Livernois-Junction Yard Terminal Area 

 Monitored Pollutant: Carbon Monoxide (CO) – Maximum 1-hr Average ... 4-111 

 Figure 4-33 Livernois-Junction Yard Terminal Area 

 Monitored Pollutant: Ozone (O3) – 1-hr Average ......................................... 4-111 

 Figure 4-34 Livernois-Junction Yard Terminal Area 

 Monitored Pollutant: Nitrogen Dioxide (NO2) – Annual Mean .................... 4-112 

 Figure 4-35 Livernois-Junction Yard Terminal Area 

 Monitored Pollutant: Particulate Matter (PM2.5) – 24-hr Average ................ 4-112 

 Figure 4-36 Livernois-Junction Yard Terminal Area 

 Monitored Pollutant: Particulate Matter (PM10) – 24-hr Average................. 4-113 

 Figure 4-37 CP/Oak and CN/Moterm Terminal Areas 

 Monitored Pollutant: Carbon Monoxide (CO) – Maximum 1-hr Average ... 4-114 

 Figure 4-38 CP/Oak and CN/Moterm Terminal Areas 

 Monitored Pollutant: Ozone (O3) – 1-hr Average ......................................... 4-114 

 Figure 4-39 CP/Oak and CN/Moterm Terminal Areas 

 Monitored Pollutant: Particulate Matter (PM2.5) – 24-hr Average ................ 4-115 

 Figure 4-40 Livernois-Junction Terminal Air Quality Impact Analysis Study Area......... 4-117 

 Figure 4-41 CP/Expressway Terminal Air Quality Impact Analysis Study Area.............. 4-118 

 Figure 4-42 CP/Oak Terminal Air Quality Impact Analysis Study Area .......................... 4-119 

 Figure 4-43 CN/Moterm Terminal Air Quality Impact Analysis Study Area ................... 4-120 

 Figure 4-44 Public Road Burden Analysis Links for Livernois-Junction Yard................. 4-126 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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 Figure 4-45 Public Road Burden Analysis Links for CP/Expressway Terminal............... 4-127 

 Figure 4-46 Public Road Burden Analysis Links for CP/Oak Terminal............................ 4-128 

 Figure 4-47 Public Road Burden Analysis Links for CN/Moterm Terminal..................... 4-129 

 Figure 4-48 Public Road Burden Analysis Links for Livernois-Junction Yard................. 4-139 

 Figure 4-49 U.S. Annual Vehicle Miles Traveled (VMT) vs. MSAT Emissions – 

 2000-2020....................................................................................................... 4-147 

 Figure 4-50 MOBILE6.2 Emission Factor Trends – PM2.5 and PM10 ............................... 4-160 

 Figure 4-51 PM2.5 Values and Trends at Nearby Monitors................................................ 4-162 

 Figure 4-52 Wind Rose for Detroit Metropolitan Airport.................................................. 4-163 

 Figure 4-53 Major Industries and Key Points.................................................................... 4-164 

 Figure 4-54 PM2.5 Values Relative to Daily Truck Volumes............................................. 4-165 

 Figure 4-55 Hotspot Analysis & Daily Truck Traffic on Key Links................................. 4-171 

 Figure 4-56 PM10 at Dearborn Monitor.............................................................................. 4-175 

 Figure 4-57 Livernois-Junction Yard Alternative 2, Noise Sensitive Areas...................... 4-179 

 Figure 4-58 Livernois-Junction Yard Alternative 3, Noise Sensitive Areas...................... 4-181 

 Figure 4-59 Livernois-Junction Yard Alternative 4, Noise Sensitive Areas...................... 4-183 

 Figure 4-60 CP/Expressway Terminal, Noise Sensitive Areas.......................................... 4-185 

 Figure 4-61 CP/Oak Terminal, Noise Sensitive Areas ...................................................... 4-186 

 Figure 4-62 CN/Moterm Terminal, Noise Sensitive Areas ............................................... 4-187 

 Figure 4-63a Sensitive Noise Receptors North Side of Kronk, Livernois-Junction Yard ... 4-192 

 Figure 4-63b Sensitive Noise Receptors North Side of Kronk, Livernois-Junction Yard ... 4-193 

 Figure 4-64 Sensitive Noise Receptors, East Side of State Fairgrounds 

 CN/Moterm Terminal..................................................................................... 4-194 

 Figure 4-65 Perceptible Noise Level Reductions............................................................... 4-197 

 Figure 4-66 Vibration Analysis Locations......................................................................... 4-198 

 Figure 4-67 CP/Expressway Terminal Eligible Historic Resources .................................. 4-207 

 Figure 4-68 CN/Moterm Terminal Historic Resources ..................................................... 4-210 

 Figure 4-69 Livernois-Junction Terminal Historic Resources........................................... 4-212 

 Figure 4-70 Areas Around Livernois-Junction Yard with Opportunities for 

 Visual Enhancements ..................................................................................... 4-217 

 Figure 4-71 Triple Crown Terminal in Melvindale, Michigan .......................................... 4-218 

 Figure 6-1 Michigan/General Box Company, 7175 Clayton Street..................................... 6-5 

 Figure 6-2 Federal Screw Works Factory, 3301-3401 Martin Street................................... 6-7 

 Figure 6-3 Markey and Tomms Houses, Martin Street........................................................ 6-8 

 Figure 6-4 Michigan Central Railroad Bridge Deck.......................................................... 6-11 

 Figure 6-5 CP/Expressway Terminal Alternative 2 ........................................................... 6-12 

 Figure 6-6 Michigan State Fairgrounds ............................................................................. 6-14 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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LIST OF TABLES 

 Table 1-1 Summary of Direct and Indirect Impacts – 

 No Action and Preferred Alternative – Livernois-Junction Yard .................... 1-12 

 Table 1-2 2030 Annual Lifts and Truck Traffic ............................................................... 1-16 

 Table 1-3 Truck Volumes – Preferred Alternative and No Action................................... 1-26 

 Table 1-4 Net Truck Trips at Livernois-Junction Terminal.............................................. 1-27 

 Table 2-1 2002 Lift Summary ............................................................................................ 2-4 

 Table 2-2 Revised for FEIS Demand vs. Capacity, No Action Scenario ........................... 2-5 

 Table 2-3 Revised for FEIS Demand vs. Capacity, 

 Revised Low-end-of-Range Forecast................................................................. 2-6 

 Table 3-1 Railroad Interlockers and Track Locations Affected by Alternatives.............. 3-30 

 Table 4-1a 2025 Annual Lifts – No Action Alternative – DEIS 

 from Commodity Flow Model Results............................................................... 4-3 

 Table 4-1b 2025 Annual Lifts – No Action Alternative – DEIS 

 with Adjustment Downward from Commodity Flow Results............................ 4-3 

 Table 4-1c 2025 Truck Traffic (Two-way Trips) 

 Alternative 1: No Action Alternative – DEIS ................................................... 4-3 

 Table 4-1d Relationship of Lifts to Truck Movements – DEIS............................................ 4-5 

 Table 4-2 2025 Truck Traffic (Two-way Trips) 

 Alternative 2: Improve/Expand – DEIS ............................................................ 4-5 

 Table 4-3 2025 Truck Traffic (Two-way Trips) Alternative 3: Consolidate – DEIS ........ 4-5 

 Table 4-4 2025 Traffic Forecast – Annual Lifts and Daily Two-way Truck Trips 

 Alternative 4: The Composite Option – DEIS .................................................. 4-6 

 Table 4-5 2025 Traffic Forecast – Daily Two-way Truck Trips 

 Alternative 2: Expand/Improve Existing Terminals – DEIS 

 Livernois-Junction Yard..................................................................................... 4-6 

 Table 4-6 2025 Traffic Forecast – Daily Two-way Truck Trips 

 Alternative 3: Consolidate All Four RRs – DEIS 

 Livernois-Junction Area..................................................................................... 4-6 

 Table 4-7 2025 Traffic Forecast – Daily Two-way Truck Trips 

 Alternative 4: Consolidate Three RRs at Livernois-Junction Area and 

 Expand CN/Moterm at Fairgrounds – DEIS ...................................................... 4-7 

 Table 4-8 Proposed Traffic Operations Improvements at Key Intersections...................... 4-7 

 Table 4-9 2030 Annual Lifts and Truck Traffic – FEIS ................................................... 4-37 

 Table 4-10a Community Facilities – Livernois-Junction Yard ............................................ 4-50 

 Table 4-10b Community Facilities – CP/Expressway Terminal Alternative 2 .................... 4-52 

 Table 4-10c Community Facilities – CP/Oak Terminal Alternative 2................................. 4-52 

 Table 4-10d Community Facilities – CN/Moterm Terminal Alternatives 2 and 4............... 4-53 

 Table 4-11 Population by Intermodal Terminal Host City ................................................. 4-57 

 Table 4-12 Population and Total Households by Terminal Area in 2000 .......................... 4-59 

 Table 4-13 Population and Total Households by Terminal Area in 1990 .......................... 4-60 

 Table 4-14 2000 Labor Force Characteristics..................................................................... 4-69 

 Table 4-15 1990 Labor Force Characteristics..................................................................... 4-70 

Table 4-16 Preferred Alternative Impacts, Mitigation and Community 

 Enhancements to EJ Population.................................................................... 4-90 

 Table 4-17 Relocation Information .................................................................................... 4-93 
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 Table 4-18 Construction Costs by Alternative ................................................................... 4-99 

 Table 4-19 Jobs Relocated and Net Jobs Gained................................................................ 4-99 

 Table 4-20 Terminal Area Property Tax Reduction and Local Revenue Gained............. 4-101 

 Table 4-21 National Ambient Air Quality Standards ....................................................... 4-106 

 Table 4-22a Terminal Burdens – Annual Tons .................................................................. 4-123 

 Table 4-22b Reduction of Pollutants Due to Truck-to-Rail Diversion for 

 Each Action Alternative ................................................................................. 4-123 

 Table 4-23 Terminal Burden by Activity Type – Annual Tons........................................ 4-124 

 Table 4-24 Public Roadway Pollutant Burden ................................................................. 4-131 

 Table 4-25 Worst Case CO Concentrations...................................................................... 4-134 

 Table 4-26a FEIS Terminal Burdens – Annual Tons......................................................... 4-138 

 Table 4-26b Reduction of Pollutants Due to Truck-to-Rail Diversion for 

 Each Action Alternative ................................................................................. 4-138 

 Table 4-27 FEIS Public Roadway Pollutant Burden ........................................................ 4-140 

 Table 4-28 Truck Volumes – Preferred Alternative and No Action................................. 4-141 

 Table 4-29 FEIS Public Roadway Pollutant Burden by Link – NAAQS Pollutants ........ 4-143 

 Table 4-30 Summary of Pollutant Burden Analysis – NAAQS 

 Livernois-Junction Terminal .......................................................................... 4-145 

 Table 4-31 Summary of Pollutant Burden Analysis – MSATs 

 Livernois-Junction Terminal .......................................................................... 4-152 

 Table 4-32 FEIS Public Roadway Pollutant Burden by Link – 

 Mobile Source Air Toxics .............................................................................. 4-153 

 Table 4-33 Selection of Emission Control Rules and Programs Contributing 

 to PM Emission Reductions, 1995-2015....................................................... 4-159 

 Table 4-34 Truck Volumes – Preferred Alternative and No Action................................. 4-169 

 Table 4-35 Net Truck Trips in Livernois-Junction Terminal Area................................... 4-170 

 Table 4-36 FHWA Noise Abatement Criteria (NAC) ...................................................... 4-189 

 Table 4-37 Trains and Noise Levels in Sensitive Areas................................................... 4-190 

 Table 4-38 Summary of Project Effects on Potential National Register 

 Eligible Cultural Resources............................................................................ 4-206 

 Table 4-39 Contamination Summary................................................................................ 4-220 

 Table 4-40 Summary of Indirect Impacts......................................................................... 4-225 

 Table 4-41 Summary of Indirect Impacts – Preferred Alternative ................................... 4-228 

 Table 4-42 Summary of Cumulative Effects – All Action Alternatives........................... 4-240 

 Table 4-43 Summary of Cumulative Effects – Preferred Alternative .............................. 4-241 

 Table 6-1 Potential National Register Eligible Cultural Resources and 

 Recreational Resources Adverse Effects............................................................ 6-2 

 Table 7-1 Summary of Interviews 

 Livernois-Junction/CP Expressway Terminal Area ........................................... 7-5 

 Table 7-2 Summary of Interviews – CP/Oak Terminal Area ........................................... 7-10 

 Table 7-3 Summary of Interviews – CN/Moterm Terminal Area .................................... 7-11 

 Table 7-4 Summary of Interviews – Outside of Terminal Areas...................................... 7-13 

 Table 7-5 Comment Categories Used to Sort Comments................................................. 7-17 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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FOREWORD 

This Final Environmental Impact Statement (FEIS) highlights the Preferred Alternative at the end 

of each section by placing the bold/italic text in a green border. 

The Preferred Alternative is a modification of Alternative 4: CSX and NS intermodal rail 

operations will expand at the Livernois-Junction Yard. The Triple Crown operation of NS 

might move from Melvindale to the Livernois-Junction Yard. And, CP will move its intermodal 

operations from the Oak Terminal to the Livernois-Junction Yard. CN has elected not to shift 

its Moterm operation to the Livernois-Junction Yard and not to expand its terminal. But, it 

will participate in paying its share of the external-to-terminal rail improvements that are part 

of the DIFT project. Meanwhile, the CP/Expressway intermodal operation closed permanently 

in June 2004 and is no longer part of the project. 

Because it has been more than three years since the signing of the Draft EIS (May 2005), a reevaluation of the DEIS was required per 23 CFR 771.129. The purpose of this re-evaluation is 

to determine whether or not a supplement to the DEIS or a new DEIS is needed. The 

Michigan Department of Transportation (MDOT) re-evaluated the Detroit Intermodal Freight 

Terminal (DIFT) DEIS. MDOT has determined that a supplemental DEIS is not warranted as 

the analysis for the DEIS remains valid for a reduced footprint and the analysis has kept pace 

with the air quality regulatory changes. The Federal Highway Administration concurs in this 

conclusion (see Appendix G). 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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

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SECTION 1 

SUMMARY

1.1 Background

Intermodal freight is a shipping method used 

to send products from manufacturers to 

where people buy them. It is called 

“intermodal” because it employs two 

“modes,” trucks and trains, using special 

containers or trailers. Trucks take the 

product from the origin to a rail yard and 

trains move the product from city to city. 

Finally, trucks take the products from a rail 

yard to their final destination. This is an 

efficient method of transportation because 

shippers move their containers from the 

trucks to the trains and back again without 

having to repack the products. This method 

often proves cost competitive, which is why 

more companies are using it. 

Operations vary, but, generally, within a rail 

yard a truck will arrive at an entry gate and 

check in, completing paperwork. Often the 

paperwork arrives ahead of the truck 

electronically. Once the truck checks in, it is 

directed to a parking slot where its 

container(s) or trailer is deposited. The truck 

then exits empty or picks up an outgoing 

load. The container is moved to a waiting 

train by either a large front-loader-type 

machine or a crane that straddles the load. 

Trailers may be loaded similarly or endloaded. When the train is loaded, it departs 

on a predetermined schedule. 

In Southeast Michigan, the transfer of trailers is conducted by Norfolk Southern’s (NS) Triple 

Crown operation. Today, that is accomplished at the Melvindale and Willow Run terminals. 

Canadian Pacific (CP) also transferred trailers in its Expressway operation at the terminal behind 

the Michigan Central Depot, but that operation ended in June 2004. CP handles containers at the 

Oak terminal. Both NS and CSX transfer containers at the Livernois-Junction Yard. Canadian 

National Railroad (CN) handles containers at the Moterm terminal in Ferndale, Michigan. 

(Mazda has an intermodal terminal in Flat Rock in Wayne County serviced by Canadian National 

Railroad, but it is solely dedicated to Mazda use.) 

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

competitiveness of Southeast Michigan and the state by improving freight transportation 

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

Southeast Michigan has a regional 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. 

Intermodal Containers on the Move 

Intermodal Container Being Loaded to Railcar 
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There is a current lack of adequate intermodal capacity in Southeast Michigan (see Section 2.2.1), 

and the connectivity between intermodal terminals is poor (see Section 2.2.2). Therefore, the 

DIFT Project proposed enhancement of intermodal operations by the four Class I railroads14

(Figure 1-1a). As an example of the lack of capacity, the Norfolk Southern Railroad has 

increased its Triple Crown business to the extent it could be accommodated at the Melvindale 

terminal. Norfolk Southern has requested financial assistance of the Michigan Department of 

Transportation (MDOT) so that it can consolidate its intermodal operations at its portion of the 

Livernois-Junction Yard. But, until the DIFT is concluded, use of federal monies to provide such 

assistance is not available. So, NS has reopened its Willow Run terminal in Romulus, Michigan, 

to handle its Triple Crown business growth. Once the Record of Decision (ROD) is signed, and, 

if appropriate improvements are made on a timely basis, NS will shift its intermodal operations in 

Michigan to the Livernois-Junction Yard. 

This FEIS includes a signed Pre-Development Plan Agreement (Appendix F) that provides a 

basis for railroad development under the Preferred Alternative. 

 

14 A Class I Railroad does at least $319 million (2007 dollars) of business annually. In Michigan there are four Class I 

railroads: CSX, Norfolk Southern, Canadian National and Canadian Pacific. 

Figure 1-1a 

Current Class I Railroad Intermodal Terminals in Southeast Michigan 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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1.2 Practical Alternatives Considered in DEIS 

Practical Alternatives were analyzed for this project with extensive public involvement. The 

alternatives and their impacts were documented in the Draft Environmental Impact Statement 

(DEIS) and in technical reports listed at the end of the Table of Contents. The general 

characteristics of the Practical Alternatives are: 

Alternative 1 No Action: This alternative assumed the railroads would develop their existing 

intermodal rail yards in Southeast Michigan without federal and state government 

funding assistance and oversight. 

Alternative 2 Improve/Expand: This alternative proposed improvements would be made to 

four existing intermodal rail terminals (at Livernois-Junction Yard, 

CP/Expressway, CP/Oak and CN/Moterm) operated by the four Class I railroads 

in Southeast Michigan with railroad funding, as well as federal and state 

governments funding assistance and oversight. This alternative included 

improvements inside and outside the existing railroad terminal property. 

Alternative 3 Consolidate: This alternative proposed the intermodal operations of all four 

Class 1 railroads be consolidated at the Livernois-Junction Yard area. Railroad 

funding, plus federal and state governments funding assistance and oversight 

would be involved in making improvements inside and outside the existing yard. 

The existing terminals from which intermodal business was to be transferred 

were to continue to serve other railroad business. 

Alternative 4 The Composite Option: This alternative proposed the intermodal operations of 

three railroads (CSX, Norfolk Southern and Canadian Pacific) be consolidated at 

the site of the Livernois-Junction Yard in Southwest Detroit, while 

improving/expanding the existing CN/Moterm terminal, with federal and state 

funding assistance and oversight for improvements inside and outside the 

terminals. The railroads would also invest in these improvements. The existing 

terminals from which intermodal business was to be transferred were to continue 

to serve other railroad business. 

“External-to-terminal” improvements, such as the rail connections at Delray, Milwaukee Junction 

and Vinewood interlockers (locations where rail lines cross), were part of Alternatives 2, 3 and 4. 

These were to be accomplished on existing railroad property. Alternative 2, 3 and 4 also included 

improving the north side of the I-94/Livernois Avenue interchange to facilitate truck movements 

to the Livernois-Junction Yard and keep them out of the neighborhood to the south. 

1.3 Description of the Preferred Alternative 

This summary focuses on the characteristics and impacts of the Preferred Alternative. Details on 

how this alternative compares to the Practical Alternatives are included in the remainder of this 

FEIS. 

The Preferred Alternative (Figure 1-1b) was formulated after reviewing public and agencies’ 

comments that were received after the public hearing, and in consultation with the railroads. The 

Preferred Alternative involves consolidating intermodal operations of the CSX, NS, and CP 

railroads at the Livernois-Junction Yard in Southwest Detroit. The Preferred Alternative shown 

in Figure 1-1b includes elements from the Practical Alternatives. The difference between the 

Preferred Alternative and Alternative 4 is that CP’s Expressway operation (trailer loading) at the 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 4

Michigan Central Depot has ended and CN has opted not to expand its existing Moterm terminal. 

The footprint for the Preferred Alternative is smaller than the footprint for Alternative 4, or 

Alternative 3 (Figure 1-1c). 

External-to-terminal rail improvements are included with the Preferred Alternative. CN will still 

pay its share of external-to-terminal rail improvements that are part of the DIFT project. Such 

improvements will increase the efficiency of operations. Road improvements will also be made. 

Both the proposed external-to-terminal rail and road improvements are discussed below. 

The DIFT project has independent utility from the Detroit River International Crossing (DRIC). 

The DIFT is a reasonable expenditure even if no additional transportation improvements are 

made in the area. The biggest change that could be brought by the DRIC would be closing the 

Livernois-Dragoon interchange with I-75. This interchange closure would reinforce the DIFT’s 

intention to focus truck traffic on I-94 to Livernois and Wyoming Avenues, which will keep truck 

traffic out of neighborhoods. 

The Gateway Project, which improves access to the Ambassador Bridge, and any new river 

crossing from Detroit to Canada will have little effect on the DIFT because a very small amount 

of intermodal truck traffic crosses the Detroit-Windsor Border. This is known from observation 

and documented by the Federal Highway Administration (FHWA) in 2006 (based on 2002 data), 

which found that the combination of “truck-rail intermodal” and “other intermodal” represents 

only one fourth of one percent of the weight (in tons) flowing across the border at Detroit.15

Discussion of a new rail tunnel in Detroit adjacent to the existing rail tunnel is again underway. It 

would permit passage of domestic “double stack” containers (stacking containers two high on a 

rail car) carried by CP across the border. The smaller international sized containers that are 

handled at the Detroit-Livernois Yard are already double stacked through the existing tunnel, so a 

new rail tunnel would have a negligible effect on the DIFT. 

The proposed project to upgrade the Blue Water Bridge Plaza would have a negligible effect on 

the Detroit-Windsor area, including the DIFT project, because there will be neither cost, nor 

travel time savings sufficient to cause long distance diversions. 

The Preferred Alternative will: 

• Expand the NS and CSX intermodal operations at the Livernois-Junction Yard; 

• Shift the NS Triple Crown operations from Melvindale and Willow Run in Romulus to 

the Livernois-Junction Yard; and 

• Move the CP Oak intermodal operation to the Livernois-Junction Yard. 

Also, all four Class I railroads will participate in an external rail improvement program at the 

following locations (Preferred Alternative locations shown in yellow in Figure 1-1d): 

• Beaubien 

• Coolidge 

• Delray 

• Dix 

• Mill 

• Milwaukee Junction 

• Oakwood Junction 

• Schaefer 

• Trenton 

• Vinewood 

• Waterman 

• West Detroit 

• New Rotunda 

• Track from Delray to Dix 

• Track from Oakwood to 

Schaefer 

 

15 Data from the Freight Analysis Framework (FAF) as presented by FHWA, February 14, 2006, in Lansing. For 

information on the FAF see http://ops.fjwa.dot.gov/freight/freight_analysis/faf/ 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluatio

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

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

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Figure 1-1c 

Livernois-Junction Yard 

Alternative Footprints 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluatio

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

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Figure 1-1d 

Major Interlockers in the Detroit Area 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Proposed Modification of the I-94/Livernois Interchange 

Proposed Central Avenue Underpass 

Several road improvements will be made to facilitate access to the Livernois-Junction Yard: 

• Modifying the I-94/Livernois 

interchange on its north side so 

that trucks will use this 

interchange (one curve is now 

too tight for efficient use) and 

Livernois Avenue, rather than 

other roads that pass through 

areas that are predominantly 

residential; 

• Closing the Waterman/Dix 

entrance to the LivernoisJunction Yard and modifying 

the Livernois entrance so that 

trucks access the yard from I-94 

only; 

• Closing Lonyo Avenue and 

rebuilding Central Avenue 

under the Livernois-Junction 

Yard so that railroad operations 

do not conflict with the 

movements of cars and trucks 

that now pass across the yard; 

• Providing two new access 

points to the yard from the west 

off Wyoming Avenue. The 

most southerly is approximately 

1,000 feet south of the point 

where the mainline east-west 

tracks servicing the yard cross 

Wyoming Avenue. The other is 

approximately 500 feet south of 

the mainline track crossing. 

• Improving John Kronk for a new gate at Martin (entrance from Livernois Avenue) for a 

new terminal on the north of and contiguous to the existing Livernois-Junction Yard. 

• Constructing a north perimeter road to replace John Kronk between a point west of 

Stecker to Central, then along the terminal boundary to Martin. This road is laid out with 

curves east of Central Avenue to discourage use by large trucks and high-speed traffic. 

The Preferred Alternative will generate by 2030 approximately 4,500 permanent jobs statewide of 

which about 2,360 new jobs will be in the Detroit area, and approximately 1,540 in the LivernoisJunction Yard area. 

The Preferred Alternative will require acquisition of approximately 169 acres of land and relocate 

28 single-family dwellings, four apartment units, and 29 businesses. 

Consultation with public interest stakeholders has resulted in a carefully defined program of 

mitigation/enhancements that is summarized on the project mitigation summary “Green Sheet” 

contained in this FEIS at the end of Section 5. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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1.4 Impacts 

The following is a summary of 

the impacts associated with the 

No Action and Preferred 

Alternatives (Table 1-1). A more 

detailed description of impacts is 

found in Section 4 of this FEIS. 

Proposed mitigation measures 

are discussed in Section 5. 

1.4.1 Traffic and Safety 

The traffic analysis of the 

Preferred Alternative was 

updated in 2008 to extend the 

forecasts to 2030, the Horizon 

Year in the Long-Range 

Transportation Plan of 

SEMCOG, the regional planning agency. The forecast of traffic for the Preferred Alternative was 

also adjusted when it became clear that the CP’s Expressway operation, which was doing 

business in Southeast Michigan at the Michigan Central Depot, would not continue. It was 

assumed 25 percent of the CP/Expressway business would go to a competitor and the rest to 

shipment by truck. Figure 1-2 and Table 1-2 show the changes. 

Figure 1-2 

Forecast of Intermodal Activity (Lifts) – Without CP/Expressway 

Table 1-2 illustrates how annual lifts translate to daily two-way truck volumes at gates. The 

assignment of these trucks to key links in the roadway network around the Livernois-Junction 

Yard is shown on Figure 1-3. Railroad operating terminals are shown in Figure 1-4. Background 

traffic was assumed to grow at one percent a year. So, the No Action Alternative volumes 

increase over time. With the Preferred Alternative, new gates at the west end of the yard 

connecting to Wyoming Avenue would split intermodal truck traffic with Livernois Avenue 

(Table 1-2 and Figure 1-3). The gate at Dix/Waterman, near a residential area, would close. 

Truck volumes on Central Avenue, which serves a residential area for most of its length north of 

Kronk Street, would decline. 

Existing Livernois-Junction Yard to be Expanded for DIFT Program 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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Table 1-1 

Summary of Direct and Indirect Impacts – No Action and Preferred Alternatives – Livernois-Jun

Livernois-Junction Yard Areaa

Traffic and Safety Community Cohesion Environmental Justice Land Use No. of Residen

Affected (Acq

No Action Preferred No Action Preferred No Action Preferred No Action Preferred 

No 

Action 

• Normal, nonDIFT traffic of 

all kinds increases. Truck traffic continues to use neighborhood streets. 

• Acceptable 

volume/capacity conditions at all intersections, except at the Dix/Waterman/Vernor intersection. 

• Continued 

rail/vehicle conflicts at Central and at Lonyo. 

• Grade separation 

of Central will reduce vehiclerail conflicts and crashes. 

• I-94/Livernois 

interchange improvement will improve safety. 

• Truck traffic will 

be reduced on local roads. 

• Acceptable 

volume/capacity conditions will be experienced at all intersections. 

• Industrial/

commercial uses will continue to be mixed with residential uses. 

• Continued rail/

vehicle conflicts at Central/Lonyo. 

• Lonyo will be 

closed. Central Avenue railroad crossing will be grade separated. 

• Truck traffic will 

be reduced on neighborhood streets. 

• No adverse 

disproportionate impact expected. 

• There is a history 

of impacts to minority and lowincome populations associated with past industrialization and transportation projects. There will be adverse disproportionate impacts from this project. 

• Maintains 

existing land use pattern. 

• Consistent with 

Detroit and Dearborn land use plans. 

0 • 2

f

• F

a

Farmland and Open Space/ Air Quality 

Part 361 Lands Economic Impacts Hot Spots Pollutant Burden 

No Action Preferred No Action Preferred No Action Preferred No Action Prefer

• No active 

farmland, or Part 361 open space land needed. 

• No active 

farmland, or Part 361 land needed. 

• Jobs Relocated: 0 • Net Jobs Gained:  Terminal Area 194 

 Statewide 1,029 

• Jobs Relocated: 231 • Net Jobs Gained: 

 Terminal Area 1,542  Statewide 4,514 

• No violations 

of CO standards at intersections. 

• No violations 

of CO standards at intersections. 

• Qualitative 

analysis of PM2.5 or PM10

hotspots indicates there will be no standards violated. 

• Terminal burdens 

less than existing conditions except for PM10 and 

PM2.5. 

• Roadway burdens 

less than existing conditions because of cleaner engines and fuels. 

• Regional burdens 

are reduced. 

• Terminal 

about samAction evincreased intermodactivity. 

• Roadway 

similar to Action. 

• Regional 

will be rewith freigto rail. 

a Only the Livernois-Junction Yard is involved in the Preferred Alternative. There are no project impacts at other terminals. 

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

1 - 13

Table 1-1 (continued) 

Summary of Direct and Indirect Impacts – No Action and Preferred Alternatives – Livernois-Jun

Livernois-Junction Yard Areaa

Surface Water Impacts Wetlands Threatened and Endangered Species Historic/ Archaeological 4(f) Resources Parklands/ Recreational Land 4(f) Resources 

No Action Preferred No Action Preferred No Action Preferred No Action Preferred No Action Preferred 

• No 

change 

• Yard paving will 

improve drainage. 

• Storm drainage 

subject of NPDES permitting. 

• Spill prevention 

plans will be in place. 

• Particulate matter 

that clogs sewers will be reduced. 

• None • 0.01 acres of 

Palustrine Emergent wetland of low quality will be affected. 

• None • None • No effect • Adverse effect with 

removal of Michigan Box Company building. 

• SHPO review of 

security wall across from 6332 Kronk for compatibility. 

• No effect • No direct effects, 

indirect or cumulative negative effects. 

Contaminated Sites Soils Indirect and Cumulative Energy 

No Action Preferred No Action Preferred No Action Preferred No Action Preferred 

• No sites 

around terminal area expected to change 

• Potential to 

remediate up to 10 acres for nonterminal intermodal activity 

• 27 sites 

need additional testing 

• Up to 100 

acres for nonterminal intermodal activity will be remediated. 

• No 

change 

• Former clay 

pits will need geotechnical testing prior to construction of any structures. 

• Perpetuates 

current conditions/trends in traffic, economics, land use, community effects, noise, cultural resources, contaminated sites and water quality. Pollution reduced by cleaner engines/fuel. 

• No negative 

traffic congestion effects. 

• Some 

business expansion expected. 

• Unwanted 

mixing of land uses must be resisted through local land use controls. 

• No adverse 

air quality effects are expected. 

• Ambient 

noise levels may increase in commercial areas with no negative effect. 

• Existing land 

use controls must be enforced to avoid adverse cultural resource impacts. 

• Some 

contaminated property reclaimed. 

• Available 

infrastructure is expected to handle stormwater from the buildout of the expanded LivernoisJunction Yard. 

• DRICb project 

will reduce I-75 access to Livernois/Dragoon 

• Continues 

past trends. 

• Energy wi

be used during constructio

• Improved 

efficienciefrom conversion some freigshipments from truck rail are expected. 

a Only the Livernois-Junction Yard is involved in the Preferred Alternative. There are no project impacts at other terminals. b DRIC is the Detroit River International Crossing, proposing a new international bridge to Canada. The DIFT has independent utility from the DRIC. 

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

1 - 14

Figure 1-3 

Daily Two-way Truck Traffic on Key Links 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 15

Table 1-2 

Figure 1-4 

Detroit Intermodal Freight Terminal Project 

Preferred Alternative with Terminals
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 16

Table 1-2 

2030 Annual Lifts and Truck Traffic 

No Action Alternative 

 From Commodity Flow Model 

Terminala Low High 

Adjusted 

Downward 

Daily Two-Way 

Truck Trips 

Principal 

Access 

W 425,800 533,000 309,800 1,520 Livernois 

Y 160,500 200,900 117,900 460 Evergreen 

Z 81,900 87,800 75,000 430 8 Mile 

Total 668,000 821,700 503,000 2,410 

Preferred Alternative 

 From Commodity Flow Model 

Terminala Low High 

Daily Two-Way 

Truck Trips 

Terminal 

Gate 

Principal 

Access 

A 101,000 135,000 720 NA 8 Mile Rd. 

B 127,000 157,000 570 2 Livernois 

C 132,000 188,500 1,270 3 Wyoming 

D1 227,000 357,000 1,140 5 Wyoming 

D2 135,000 212,500 820 4 Livernois 

Total 722,000 1,050,000 4,520 

a

 Terminal’s owner/operator is not identified at the railroads’ request in light of proprietary interests. 

Source: The Corradino Group of Michigan, Inc. 

The daily 2030 two-way intermodal truck total will be 4,520 (3,800 at the Livernois-Junction 

Yard and 720 at the CN/Moterm terminal) in the Preferred Alternative, compared to 2,400 (1,500 

at the Livernois-Junction Yard) with the No Action Alternative. The net increase in intermodal 

truck trips at the Livernois-Junction Yard would be 2,300. But, acquisition of land for the 

Preferred Alternative will eliminate 1,600 two-way truck trips per day. The net result is an 

increase of 700 trucks per day. Traffic will shift from Livernois Avenue to Wyoming Avenue, 

with 80 percent of the Wyoming traffic expected to use I-94. 

The truck (and auto) traffic adjustments from the Preferred Alternative would not result in any 

intersections being at Level of Service D3

, or worse, in the peak hour in 2015 or 2030. 

The Preferred Alternative will close Lonyo Avenue at the rail terminal and divert its traffic via a 

new Perimeter Road to Central Avenue. Safety will be improved with eliminating the two 

rail/highway crossings. The regional shift from truck to rail will reduce regional vehicle miles of 

travel so that Wayne County’s annual 2030 injury crashes and fatalities will be reduced by 25 and 

one, respectively, and the reduction in these statistics for the seven-county Southeast Michigan 

region will be 97 and 4, compared to the No Action Alternative. 

1.4.2 Relocations, Community Cohesion, Environmental Justice, Land Use and Farmland 

Expanding the Livernois-Junction Yard, as called for in the Preferred Alternative, is consistent 

with the Detroit Master Plan of Policies because much of the development will take place on 

industrial property. About ten acres of the 169 acres of the expansion area is now residential and 

rezoning would be required. 

 

3

 Level of Service (LOS) is a way of expressing how much congestion there is. LOS “A” is best. LOS “E” is the 

maximum flow possible without breakdown. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 17

The Preferred Alternative is expected to result in the acquisition of thirty-two housing units. 

Adequate housing is available to accommodate the relocatees. Twenty-nine businesses will be 

relocated. They provide 275 jobs. Vacant industrial/commercial space is widespread so finding 

opportunities to relocate businesses is 

not complicated. The business owner at 

the northwest corner of Central Avenue 

and Kronk Street has noted a concern 

with relocation. No farmland will be 

affected, nor will the Part 361 lands 

which are protected by state law. 

The Preferred Alternative will provide a 

buffer/security wall on the north side 

and most of the south side of the 

terminal, creating a visual and noise 

break between the terminal and 

adjacent neighborhoods/noise-sensitive 

residential uses. 

There will be disproportionately 

adverse housing and cultural resource 

effects on minority or low-income 

populations as defined in Executive 

Order 12898, “Federal Actions To 

Address Environmental Justice In 

Minority Populations And Low-Income 

Populations,” or discrimination 

prohibited by Title VI of the Civil 

Rights Act of 1964. The details are 

provided below. 

• Mobility – There will be acceptable levels of traffic congestion throughout the roadway 

network around the terminal, as presented in Section 4.1 of this FEIS. There will be a net 

increase of approximately 700 trucks a day in 2030 in the terminal area compared to the 

No Action Alternative. The planned road and gate improvements will split truck traffic 

between Livernois and Wyoming Avenues, with Wyoming serving an industrial area and 

Livernois Avenue serving a mix of residential and commercial development. Truck 

traffic will be reduced on neighborhood streets (Central north of Kronk, Livernois south 

of the terminal entrance gate, and Dragoon south of Dix). Lonyo will be closed, while 

the Central Avenue crossing of the railroad tracks will be grade separated, thereby 

improving the safe movement of traffic around the terminal area. Finally, improving the 

I-94/Livernois interchange will improve safe truck movements and also help reduce truck 

traffic on neighborhood streets. There will be no impacts on public transit routes. 

• Economic Impacts – Approximately 275 jobs are expected to relocate within or outside of 

the terminal area due to terminal expansion. These will be replaced in the terminal area by 

more than 1,540 new jobs associated with the investment in intermodal development, over 

the next 20 years, as defined in Section 4.5 of this FEIS. The new job total is expected to 

be approximately 4,500 statewide. In the Detroit area, the net new jobs total is forecast at 

about 2,360. Local business expansion and growth in the local tax base are anticipated. 

Proposed Security Wall and Perimeter Road 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 18

• Land Use – The expected investment by the government and railroads is likely to 

stimulate, over the next 20 years, industrial/commercial development of up to 60 acres of 

available land to support intermodal activity, as defined in Section 4.5 of this FEIS. This 

intermodal development activity is consistent with the land use plans of Detroit and 

Dearborn. Unwanted mixing of land uses can and should be resisted by applying 

already-existing provisions in the Detroit Master Plan of Policies and the Dearborn 

Master Plan. 

• Air Quality – Analyses presented in Section 4.8 of this FEIS indicate no violations of CO 

standards are expected in the area around the Preferred Alternative. Likewise, no 

violations of PM2.5 or PM10 daily or annual standards are anticipated, based on qualitative 

hot-spot analyses of these two pollutants. Compared to the No Action condition in 2030, 

terminal pollutant burdens are expected to change. Carbon monoxide and particulate 

matter are expected to decrease, while the other pollutants are expected to increase with 

the increase in intermodal activity. The roadway burdens are expected to be about the 

same as the No Action Alternative because of the removal of traffic through 

acquisition/relocation from the area around the terminal (29 businesses). The regional 

mobile source pollutant burdens will be reduced due to diversion of freight shipments 

from truck to rail and the use of cleaner fuels and engines. 

• Community Effects – Twenty-nine business properties, 28 single-family residences, and 

four apartment units are expected to be acquired for the expansion of the terminal. 

Almost 275 jobs would be relocated within or outside of the terminal area, compensated 

by an increase of approximately 1,540 new jobs stimulated by intermodal investment, 

consistent with data presented in Section 4.5 of this FEIS. Lonyo would be closed and 

Central Avenue grade separated from the railroad lines, improving safe flow of vehicles, 

pedestrians and bicyclists. Truck traffic on a number of neighborhood streets would be 

reduced. Security walls on the north side of the terminal, and part of the south, will 

buffer its activity, improving the aesthetics of the area. The terminal will be paved, 

reducing the effects of dust on the nearby population. 

• Noise – No perceptible increase in noise on sensitive areas is expected with planned 

security walls, as defined in Section 4.9 of this FEIS. Traffic volumes in the terminal area 

will increase as economic conditions improve, but in terms of noise, the changes with DIFT 

traffic are inconsequential compared to background traffic. The exception is that 

redirecting truck traffic on Livernois away from the area south of the entry gate and closing 

the existing gate, at Dix/Waterman, will cut truck traffic on south Livernois and Dragoon to 

a noticeable extent, so that noise levels will be perceptibly lower. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 19

• Cultural Resources – Removal of the 

Michigan Box Company building will 

result in an adverse effect; the 

construction of a security wall across 

from 6332 Kronk may pose an 

adverse effect.4

 (Section 4.13.) No 

effects are forecast on parks/

recreational lands, as presented in 

Section 4.14 of this FEIS. 

• Contaminated Sites – Twenty-seven 

sites in the immediate area around the 

terminal, suspected of having 

contamination, need additional 

testing. This information is presented 

in Section 4.16 of this FEIS. The 

increased intermodal activity could 

cause, over the next 20 years, up to 60 

acres of contaminated land (e.g., 

brownfields) to be reclaimed by the 

private sector. This could lead to 

increased, but less polluted, water 

runoff. 

• Water Quality – As discussed in 

Section 4.11 of this FEIS, it is 

expected that paving the LivernoisJunction Yard will improve drainage 

as the runoff today clogs sewer inlets, 

which causes standing water in 

railroad viaducts on Lonyo, Central and Livernois. The standing water sometimes causes 

these roads to be impassable. The storm drainage system of the improved terminal will 

be subject to National Pollution Discharge Elimination System (NPDES) permitting. 

Where the project increases stormwater amounts by paving terminal surfaces that now 

absorb water, surface runoff will be directed to an engineered onsite collection site to 

ensure that future flow rates do not increase. Because of the combined sewer system, all 

water will be treated before it outfalls to the Detroit River. Prevention plans to address 

accidental spills of hazardous materials will continue to be maintained by the railroads. 

Reclaiming up to 60 acres of potential contaminated properties (e.g., brownfields) is 

possible, as noted above. 

The results of the conditions presented above indicate an adverse effect in terms of relocations 

and cultural resources on populations covered by the EJ regulations. Therefore, mitigation is 

included in Section 5 of this FEIS. Nonetheless, it must be recognized that, over time, 

undesirable environmental features have accumulated from industrialization and related 

transportation projects. Some have existed for many years. Public resources to address many of 

these conditions have been lacking. The DIFT project is envisioned as a way for public and 

private sector investments to bring some measure of improvement to existing rail activity and the 

affected population, knowing that activity will expand in the future with or without the project. 

 

4

 The State Historic Preservation Officer (SHPO) will review the security barrier wall across from the house at 

6332 Kronk in the design phase. 

Michigan Box Company — North Wall, View to East. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 20

On balance, the investment and improvements of the Preferred Alternative with mitigation and 

community enhancements is seen to be beneficial to these areas compared to the No Action 

Alternative. 

1.4.3 Economics – Permanent and Construction Jobs 

Results of the analysis of the Preferred Alternative 

reflect updated data and reapplication of the REMI 

model. While some 275 jobs would be relocated by 

the DIFT project, the economic stimulus of it would 

generate approximately 4,500 jobs statewide 

including 2,360 jobs in the Detroit area. The 

schedule of the Preferred Alternative construction 

occurs later than was foreseen for the Practical 

Alternatives, as the project has been delayed in its 

review/approval. Nonetheless, about 3,085 person 

years5

 of employment would be generated, with 

construction peaking in 2014 at 620 jobs. 

1.4.4 Air Quality 

A protocol (Appendix E) was developed to guide the DEIS air quality analysis with respect to 

National Ambient Air Quality Standards (NAAQS) and Mobile Source Air Toxics (MSATs).6

 

Since the DEIS was published, analysis methodologies have changed. Therefore, the air quality 

presentation is considerably different than that in the DEIS. Further, the analysis reflects updates 

for the intermodal activity of the Preferred Alternative, as well as air pollutant monitor data and 

emission factors. Also reflected in the analysis is the fact that, since the project began, the 

Southeast Michigan Council of Governments (SEMCOG) has advanced the horizon year of their 

Regional Transportation Plan (RTP) to 2030 from 2025. 

The scope of and methodology used in this air quality analysis are consistent with current 

guidance from the Federal Highway Administration (FHWA) and MDOT. Interagency 

consultation was held with SEMCOG, the U.S. Environmental Protection Agency (EPA) 

Region 5, and the Michigan Department of Environmental Quality (MDEQ). This air quality 

analysis covers the following topics: 

• Pollution Burden 

• Mobile Source Air Toxics 

• Air Quality Conformity 

• Air Quality Control Measures 

• Construction Impacts 

1.4.4.1 Pollution Burden Analysis 

Pollutant burden analysis was performed for conditions at the terminal and on the surrounding 

streets (Section 4.8.2). The analysis of the terminal activity includes visitor and employee traffic; 

container truck activity; container handling in the yard; locomotive activity; fugitive dust; loss of 

 

5

 A person year is one person working one year. 

6

 The Corradino Group, Detroit Intermodal Freight Terminal Study Air Quality Protocol, March 2005 and Addendum 

October 2006. 

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

1 - 21

traffic due to relocation of some businesses; and, closure of public streets that fall within the 

future terminal. For the roadway analysis, the number of vehicles was used in conjunction with 

road link lengths and speeds. 

1.4.4.1.1 Terminal Area Pollution Burden 

Because the CN/Moterm terminal is not to be expanded as part of the Preferred Alternative, its 

activity and pollutant burden will be only marginally higher than under No Action conditions. On 

the Livernois-Junction Yard, the greater truck activity, compared to the No Action Alternative, 

means the hydrocarbon (HC), nitrogen oxide (NOx), volatile organic compounds (VOCs), diesel 

particulate matter (DPM), benzene, formaldehyde, acetaldehyde and acrolein burdens will be 

higher. The paving of the yard will substantially reduce particulate matter compared to No 

Action. 

EPA regulations will continue to improve air quality on terminals as well as roadways. By mid2010 non-road diesel equipment, such as that used to move containers, will be required to use the 

same low-sulfur fuel that on-road vehicles began using in 2007. (This fuel prevents the fouling of 

pollution control equipment on newly manufactured vehicles.) Locomotives have until 2012 to 

start using the fuel. But, as a practical matter, refineries are fully converting to production of the 

ultra low sulfur fuel. All new and remanufactured locomotives must met Tier 3 air quality 

standards by 2009 (which includes idle reduction requirements) and Tier 4 by 2015 (essentially 

adding afterburners and benefiting from clean diesel). So, new equipment will continue to be 

cleaner. The railroads could adopt voluntary measures. 

While new diesel equipment will have cleaner burning engines and use low-sulfur fuels, hybrid or 

electric vehicles are an option. An additional optional measure that may be available would be a 

continued partnering on conversion of local switch locomotives to units that emit less and reduce 

idling. It is notable that CSX has received from SEMCOG in collaboration with MDOT 

Congestion Mitigation Air Quality (CMAQ) grants to retrofit four switch locomotives. These 

must remain in the Dearborn and Detroit yards for a minimum of five years. 

1.4.4.1.2 Public Roadway Pollution Burden 

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

Avenue and two from Livernois Avenue. Access to the Wyoming gates is expected to be 

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

This pattern moves the roadway air quality pollutant burden away from residential areas. 

Combined with the lower emission factors in the future, the pollutant burden on many roadway 

links near the Livernois-Junction Yard will go down in the future (2015 and 2030) from base year 

(2004) levels and will be slightly less than the No Action Alternative. 

In 2015, the number of trucks on Wyoming Avenue, south towards Dix, will increase by 145 with 

the Preferred Alternative relative to the No Action Alternative. This is in close proximity to the 

Wyoming Avenue air quality monitoring site. However, the annual PM2.5 value for 2015, which 

is of greatest concern, is the same (0.06 tons) as for the No Action conditions and less than half of 

the 2004 value of 0.13 tons per year. 

In summary, considering both roadway and terminal pollutant burdens, the Preferred Alternative 

at the Livernois-Junction Yard would reduce the levels of NAAQS pollutants relative to the No 

Action Alternative in 2015 for all but VOC, which would be almost unchanged. When pollution 

within the terminal is added in 2030, these pollutants would remain lower than the No Action 

Alternative, except for NOx and VOC. In those latter cases, the increases over the No Action 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 22

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

Particulate matter would be substantially reduced. 

1.4.4.2 Mobile Source Air Toxics (MSATs) – Quantitative Analysis 

The quantitative analysis of MSATs presented in Section 4.8.3 of this FEIS provides a means of 

comparing the Preferred Alternative to taking no action, consistent with the federal guidance and 

the agreed-upon analysis protocol. 

1.4.4.2.1 Terminal Area MSAT Quantitative Analysis 

The overall conclusion for MSAT conditions for the terminal area indicate diesel particulate 

matter (DPM) will drop substantially from current levels with the Preferred Alternative. But, 

increased terminal activity will increase the levels of butadiene, formaldehyde, acetaldehyde, and 

acrolein compared to today’s levels and compared to taking no action. These increases would be 

more than offset by reductions in Wayne County with the mode shift from truck to rail. 

1.4.4.2.2 Roadway MSAT Quantitative Analysis 

The Preferred Alternative will reduce 

the MSAT pollutant burden on the 

local road network in 2015 and in 

2030, compared to 2004. The most 

important reductions would occur on 

Livernois Avenue and Dragoon Street 

south of Dix to I-75. There, the 

homes are about 30 feet from the 

streets. MSAT burdens in 2030 with 

the Preferred Alternative would be 

about one-third of base year (2004) 

amounts. 

1.4.4.3 SEMCOG Attainment Status/Air Quality Conformity 

EPA has promulgated two sets of regulations to implement the conformity requirements of the 

Clean Air Act: 1) General Conformity Regulations, which apply to other Federal projects; and 

2) Transportation Conformity Regulations, which apply to highways and mass transit and 

establish the criteria and procedures for determining whether transportation plans, programs, and 

projects funded under title 23 U.S.C. or the Federal Transit Act conform with the State 

Implementation Plan (58 FR 62188). These two regulatory approaches are discussed below. 

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

(SIP) to demonstrate how it will attain and/or maintain NAAQS (Table 4-21). SEMCOG 

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

(MDEQ) to prepare and/or update a SIP. SEMCOG is responsible for evaluating mobile source 

(vehicular) emissions in Southeast Michigan when projects are proposed for inclusion in its longrange transportation plan. SEMCOG’s 2030 Regional Transportation Plan (RTP) must undergo a 

quantitative analysis demonstrating that emissions levels associated with implementing planned 

transportation projects are equal to, or lower than designated emissions limits (budgets) set forth 

in the SIP. In doing so, SEMCOG is managing the transportation air quality conformity process 

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

U.S. Annual Vehicle Miles vs. MSAT Emissions 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 23

review through SEMCOG. This review has occurred and the DIFT Preferred Alternative has 

been found to conform. 

1.4.4.3.1 General Conformity 

General conformity normally applies to non-transportation projects. Threshold (de minimus) 

emission levels have been set by EPA for particulate pollution (PM2.5 and PM10) to determine 

when general conformity determinations are necessary (40 CFR 93.153(b)). Because the DIFT is 

a transportation project, transportation conformity would normally apply. But, DIFT is unique in 

that it involves a terminal(s). There, trucks will idle briefly as they pick up and drop off 

containers. Therefore, plaza activity has been examined to determine whether de minimus levels 

of 100 tons per year for PM2.5 or PM10 are exceeded during system operations. The year of 

highest emissions, 2015, has been analyzed and compared to the de minimus thresholds. 

Because of the scale of the DIFT project, the de minimus threshold was also applied to 

construction activities to determine whether PM10 dust levels exceed 100 tons in any construction 

year. 

PM2.5 and PM10 Operations de minimus Analysis – The federally-determined de minimus level 

of 100 tons annually was published in the Federal Register of July 17, 2006, for both PM2.5 and 

PM10. The DIFT project implementation will actually reduce the annual PM2.5 and PM10 burden 

at the Livernois-Junction Yard (the only terminal that receives government funding under the 

Preferred Alternative) in 2015 and 2030 compared to the No Action Alternative. So, the DIFT 

project operations will not trigger the need to conduct general conformity. 

PM10 Construction de minimus Analysis – An examination of the proposed DIFT construction 

program found that, in any given year, the dust created during project implementation will also be 

well within the PM10 de minimus level. The 300 existing acres, plus 169 new acres, are 

predominantly clear of major buildings and structures. With a project implementation program of 

ten years, it is reasonable to assume about 125 acres would be the most to be worked on in a 

given year. Assumptions were a site development area 1100 feet wide and 5000 feet long and use 

of earthmovers and/or graders with a PM10 dust emission factor of 3.6 lbs/vehicle mile of travel of 

the construction equipment. Using the methodologies available in EPA’s “Compilation of Air 

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

revised December 2003, and the construction assumptions, maximum yearly estimates of dust 

from construction are under 30 tons, well under the 100 ton threshold. 

1.4.4.3.2 Transportation Conformity 

Regional Conformity – With identification of the Preferred Alternative, DIFT project elements 

that cause changes to the transportation network were evaluated by SEMCOG for air quality 

conformity. When analyzed together with other plan elements, the air pollution generated must 

not exceed “budgets” established in the SIP. This is the case for carbon monoxide, ozone, and 

PM2.5. This analysis has been performed and the DIFT has been included in SEMCOG’s costfeasible RTP and Transportation Improvement Program (TIP). 

Hot-spot Analysis – Hot-spot analysis is designed to evaluate whether there are air quality 

impacts on a smaller scale than an entire nonattainment or maintenance area. Conforming to the 

purpose of the SIP means that transportation activities will not cause new air quality violations, 

worsen existing violations, or delay timely attainment of the NAAQS. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 24

The hot-spot analysis applies to carbon monoxide (CO), PM2.5, and PM10, consistent with 40 CFR 

93.116. 

The CO analysis is done on a quantitative basis per 40 CFR 93.123(a) to determine whether 

estimated “with-project” concentrations of CO exceed the established one-hour and/or eight-hour 

standards. If they do not, the project conforms. Hot-spot conformity for PM2.5 and PM10 is 

determined on a qualitative basis per 40 CFR 93.123(b)(4) until appropriate methods and 

modeling guidance are available for quantitative analysis. 

Regarding PM10, a portion of Detroit that includes the proposed DIFT project is a maintenance 

area. In the Maintenance Plan, SEMCOG, MDEQ and EPA concluded that mobile source 

(vehicular) PM10 emissions are not a significant contributor to regional PM10 emissions. So, 

SEMCOG is not required to consider PM10 in its regional conformity analyses. However, 

because no similar determination was made with respect to whether mobile source PM10

emissions contribute to localized hot-spot problems, a PM10 hot-spot qualitative analysis is 

required. It is covered later in this section. First, discussions of CO and PM2.5 are presented.

CO Hot-spot Quantitative Analysis – 

Guidance for CO hot-spot analysis 

(40 CFR 93.123(a)) states that, if there are 

no violations of the CO standards in the 

area affected by the project, then the 

project's future effect is compared to the 

standard because the test is whether the 

project causes an exceedance of the 

standard at a sensitive receptor. Based on 

available local monitoring data, there are 

no current violations in the area. So, the 

test is whether the project could cause a 

new violation. Modeling performed for the 

DEIS indicates the Preferred Alternative 

would not cause CO values at hot-spots 

around the terminal anywhere near the 

level of the one-hour and eight-hour 

NAAQS standards. 

PM2.5 Hot-spot Qualitative Analysis – This subsection addresses the change since the 

publication of the DEIS in the air quality regulatory background resulting from the 

publication of the “Final Rule for PM2.5 and PM10 Hot-spot Analyses in Project-Level 

Transportation Conformity Determinations,” which appeared in the March 10, 2006, Federal 

Register. Subsequent to the publication of the Final Rule, EPA and FHWA jointly issued 

“Transportation Conformity Guidance for Qualitative Hot-spot Analysis in PM2.5 and PM10

Nonattainment and Maintenance Areas,” March 29, 2006. The DIFT project is of “air quality 

concern” (Transportation Conformity Guidance, Chapter 1.3) for PM2.5 because it would 

represent a transfer point that has “a significant number of diesel vehicles congregating at a 

single location.” (40 CFR 93.123(b)(1)(iii)). A hybrid of methods A and B from the 

Guidance is used. 

Upon publication of the guidance, interagency consultation occurred on May 11, 2006, 

among EPA, FHWA, SEMCOG, MDOT and MDEQ. EPA, FHWA, and MDOT met again 

July 19, 2006. Consultation led to an Addendum to the original Air Quality Protocol for the 

Project Area Air Quality Monitors 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 25

DIFT project (Appendix E). Both the Protocol and the Addendum 

guided the analysis in this section of this FEIS. Subsequent to 

these noted activities, interagency consultation continued on the 

Detroit River International Crossing (DRIC), which proposes 

building a new bridge to Canada, also to be located in Southwest 

Detroit. The DIFT project has independent utility from the DRIC. 

That further consultation led to refinements to the DIFT Air 

Quality Protocol and Addendum. The analysis that follows 

reflects the continued interagency consultation. 

The qualitative PM2.5 “hot-spot” analysis is in addition to the 

process SEMCOG has used in past years to determine regional 

transportation conformity. The qualitative hot-spot analysis is 

designed to determine the effect of PM2.5 on a localized basis, i.e., project-level conformity. 

This hot-spot analysis is designed to consider direct emissions only, not secondary particles, 

as these take several hours to form in the atmosphere, giving emissions time to disperse 

beyond the immediate area of concern. 

The qualitative hot-spot analysis in this section addresses both the 24-hour and annual 

standards for PM2.5. The SEMCOG area was designated non-attainment with the annual 

PM2.5 standard of 15 μ/m3

 in 2004. The analysis herein addresses that standard and the 

concurrent 65 μg/m3

 24-hour standard. It has been anticipated that during 2009 the region 

will be designated in non-attainment with the stricter 35 μ/m3

 24-hour standard established in 

2006. However, based on the rules that govern conformity, the region will have another year 

before conformity to the 35 μ/m3

 standard applies. Therefore, while 35 μ/m3 is the 24-hour 

standard shown herein in tables and graphics, it is the 65 μ/m3

 standard that is still the test for 

conformity. The DIFT project will be implemented over a number of years. If there are 

future federal actions or major project changes, the U.S. Department of Transportation will 

comply with whatever conformity requirements apply at that time. 

The hot-spot analysis includes the Livernois-Junction Yard and the roadway network which 

trucks would use to carry containers to and from that terminal. It does not need to include 

activity at key intersections where the LOS drops to D, or worse, because the DIFT traffic 

analysis found there are no such locations. It considers construction activity because dust 

could be a consideration in the SIP. The SIP for PM2.5 is now under review by U.S. EPA. 

Consequently, there are not yet “budgets”7

 for PM2.5. Until there are, regional conformity is 

determined by ensuring that future annual emissions do not exceed 2002 levels. 

The DIFT is a project of air quality concern because large numbers of diesel trucks are 

involved. The DIFT project, and its increase in truck traffic, will develop over a ten-year 

period, 2010 through 2019. There is no “year of opening,” as there would be with many 

other transportation projects. Rather, the railroads, in conjunction with MDOT, will prioritize 

and capitalize a set of improvements over time. The year of peak construction is projected to 

be 2014. So, for analysis purposes, the year of highest emissions is taken to be 2015. By this 

point in time, major features of the project are expected to be in place, such as the purchase of 

property and entry gate development on Wyoming Avenue. The Detroit River International 

Crossing project will be in place (projected year of opening of 2015), limiting access to the 

DIFT by the reconstruction of the Livernois/Dragoon interchange with I-75. The further in 

 

7

 Budgets for certain pollutants limit how much can be produced in an area so that air quality standards can be attained 

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

1 - 26

the future the analysis is performed, the cleaner the overall vehicle fleet will be. So, 2015 is a 

reasonable choice as the highest year of emissions. 

While the Preferred Alternative will develop over a ten-year period, it consists of a set of 

project elements at different times and locations, none of which last five years. The project 

design year is 2030, consistent with SEMCOG’s Regional Transportation Plan. 

The PM2.5 annual terminal pollutant burden is projected to be 14.9 tons in 2030 for the 

Preferred Alternative, compared to 30.9 tons for the No Action Alternative. In 2015, the 

relationship is 8.8 tons for the Preferred Alternative to 26.0 for the No Action Alternative. 

Existing (2004) PM2.5 is 43.5 tons a year. Therefore, the Preferred Alternative’s PM2.5

terminal burden will be less than one fourth the 2004 condition. The principal change will 

come with paving the Livernois-Junction Yard. Though PM2.5 is a small fraction of the 

particulate matter on the unpaved yard, the yard is so big that the portion which is unpaved 

produces a large quantity of pollution. 

The DIFT project would result in higher intermodal truck volumes overall, but a 

redistribution of that truck traffic away from residential areas. This would happen by shifting 

trucks to two new gates off Wyoming Avenue, reorienting intermodal truck traffic on 

Livernois Avenue to the north, and closing the Dix/Waterman gate to the Livernois-Junction 

Yard. These changes can be seen in the last two columns in Table 1-3. Truck volumes 

would decrease on Livernois Avenue and Dragoon Street south of the existing gate to I-75 

( red box on Table 1-3). Lonyo traffic ( orange box) would shift to Central Avenue and 

Kronk Street would be closed by the project ( green box). The net traffic change on 

Central Avenue ( blue box) would be a decrease because several large trucking concerns 

would be relocated by the project and trucks that are presently using Central would be 

removed in the future. Truck volumes will increase on Wyoming ( black box), especially 

between the new proposed gates and Michigan Avenue and, to a lesser extent, south of the 

gates towards Dix. The Dearborn air quality monitor is located on Wyoming between the 

new gates and Dix. 

Table 1-3

Detroit Intermodal Freight Terminal Study 

Truck Volumes – Preferred Alternative and No Action 

2004

Base

No 

Action Pref.

No 

Action Pref. 2015 2030

Liv-Junc Yard From To

Wyoming Dix New Gate 1350 1499 1644 1634 2016 146 382

New Gate Kronk 1534 1703 2586 1856 3684 883 1828

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

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

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

Kronk Dix 696 773 0 842 0 -773 -842

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

Kronk Dix 955 1060 970 1156 1066 -90 -90

Perimeter Rd Lonyo Central 0 0 431 0 470 431 470

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

Exist. Gate Dix 2420 2740 1749 3041 1927 -992 -1114

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

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

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

Lonyo Central 239 265 0 289 0 -265 -289

Central Livernois 238 264 301 288 580 37 292

Pref. minus No Action

Road Segment

2015 2030

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

traffic was based on lifts growth. 

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

1 - 27

In the intermediate year of 2015, the project is estimated to result in about 600 fewer trucks 

per day to the Livernois-Junction Yard area ({ red oval on Table 1-4) because, even though 

the project brings new trucks to the terminal, it would eliminate existing land uses that 

generate many truck trips. In the near term, as these land uses are converted, the result would 

be fewer trucks. In 2030, with further intermodal growth, there will be approximately 700 

additional truck trips ({ blue oval on Table 1-4) in the Livernois-Junction Yard area because 

intermodal traffic will continue to increase beyond 2015, while there would be no new 

relocations of non-intermodal trucking activities between 2015 and 2030. Roads that, today, 

generate a substantial amount of dust will also be closed at the beginning of project 

construction, while project lifts and truck traffic will increase gradually thereafter. As a 

result, there will still be increases on certain roadway links, even in 2015, as shown on 

Figure 1-3. 

Table 1-4

Detroit Intermodal Freight Terminal Study 

Net Truck Trips at Livernois-Junction Terminal 

 Truck Trips 

Condition 2015 2030 

Preferred Alternative Intermodal Trucks 1974 3800 

No Action Alternative Intermodal Trucks 956 1510

 Increase with Preferred Alternative 1018 2290 

Trucks eliminated at Relocated Business -1600 -1600

Net Change in Trucks -582 690 

Source: The Corradino Group of Michigan, Inc. 

 

For this qualitative analysis, three types of hot-spots have been identified (Figure 1-3): key 

intersections near the Livernois-Junction Yard; gates serving the yard; and, roadway links

around the Livernois-Junction Yard with heavy truck traffic under the Preferred Alternative. 

Intersections

The traffic analysis (Section 4.1 of this FEIS) examined over 100 intersections around the 

intermodal terminals to determine whether project-related traffic would cause impacts. 

The analysis found the truck (and auto) traffic changes of the Preferred Alternative will 

not result in any intersection operating at Level of Service D, or worse, in the peak hour 

in 2015 or in 2030 in the Livernois-Junction Yard area. This analysis has been updated 

with additional traffic counts performed since the DEIS. Future background volumes 

were assumed to increase one percent a year from the present. Based on actual historic 

patterns, this overstates actual traffic growth. In addition, SEMCOG released a study in 

2007 outlining reduced growth and travel in the region.8

 So, the stated conditions for 

traffic represent worst-case conditions for air quality purposes. 

Gates

Average check-in and check-out times of four minutes have been assumed at each 

terminal gate, compared to five minutes for the less efficient layouts of No Action. 

 

8

 SEMCOG, A Region in Turbulence and Transition, April 2007. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 28

Actual Preferred Alternative times may be less. Four gates are distributed around the 

perimeter of the Livernois-Junction Yard under the Preferred Alternative. With No 

Action, all trucks enter the yard off of Livernois or Waterman at Dix. 

With the Preferred Alternative, the maximum two-way daily gate truck volume in 2030 at 

any one gate (Gate 5) is forecast to be 1270. Next in volume would be Gate 3 with 1,140 

two-way daily trucks (Figure 1-3). Total two-way trucks for all gates would be 3800. The 

estimated annual PM2.5 pollutant burdens in tons for the idle time related to delay at the gates 

is 0.7 tons in 2015 and 0.13 tons in 2030. 

The amount of delay and associated idling is small in comparison to the burden reduction the 

project would bring: 17 tons in 2015 and 16 tons in 2030. 

Roadway Links

Figure 1-3 shows anticipated truck volumes on key roadway links near the LivernoisJunction Yard. It also shows that intermodal trucks will use Wyoming Avenue (80% 

north and 20% south) and Livernois Avenue (100% north to I-94) to get to and from the 

yard. This pattern would focus truck traffic on routes that carry trucks today and reorient 

truck traffic away from residential areas, notably homes along the Livernois/Dragoon 

one-way pair that connects the Livernois-Junction Yard to I-75. Today, that one-way 

pair is a route of choice by truckers. The noted shifts are consistent with the wishes of 

local residents. The Livernois gate will be reengineered to prevent turns to and from the 

south as will the intersection of Kronk (Gate 2) with Livernois Avenue. Also, the 

existing Waterman gate on the south side of the Livernois-Junction Yard will be closed. 

Waterman is another route that passes through a residential area. 

The only links with traffic increases due to the DIFT are Livernois Avenue north of the 

terminal and Wyoming Avenue. The Dearborn air quality monitor is on the section of 

Wyoming between Dix and the new Gates 3 and 5. The monitor is also directly across 

from the Sverstal Steel facility which, together with improvements at U.S. Steel and the 

Marathon Refinery, are expected to experience an annual PM pollutant burden reduction 

of 330 tons. Work is underway to use federal Congestion Mitigation Air Quality 

(CMAQ) funds to rebuild four switch locomotives with GenSet equipment to reduce PM 

emissions. These switch locomotives idle while sitting on tracks as close as 250 feet 

from the Dearborn monitor. GenSet locomotives have multiple off-road, low-emitting 

diesel engines, and engines shut down while not in use. 

The overall roadway network pollution burden associated with the Livernois-Junction 

Yard would be reduced with the Preferred Alternative. In the base year of 2004, about 

1.5 tons of PM2.5 were generated on the identified road network of key links. In 2015 

these levels would be reduced by over half a ton with the Preferred Alternative. By 2030, 

both the Preferred Alternative and No Action Alternative would generate only one-third 

of the 2004 amounts. The road link of Wyoming between Dix and the new gates would 

see its burden fall from 0.13 tons annually in 2004 to 0.06 in 2015 and 0.05 in 2030, with 

either the Preferred Alterative or No Build Alternative. At the Wayne County level, PM 

reductions will be realized from the shift of traffic from truck to rail. 

The vehicles-per-day analysis found the project would increase truck traffic in the 

vicinity of the Dearborn monitor by 146 in 2015. It is not believed the increase in truck 

traffic by the Dearborn monitor will lead to new air quality violations or the delay in 

attaining standards because: 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 29

1) It is anticipated that the Dearborn monitor will attain the PM2.5 annual standard of 

15 μg/m3

 by 2010 and continue to conform to the 65 μ/m3 daily standard. 

Though the 2007 value of 16.9 μg/m3

 was over the standard, values at the end of 

the year were lower. This reflects the implementation during the year of a 

Sverstal Steel baghouse (air quality control mechanism) just upwind of the 

monitor. Data for 2008 are below the standards (see conclusions below). 

2) Implementation of engine-idle packages on the switch engines in the CONRAIL 

Rougemere Yard, across Wyoming from the Dearborn monitor, is expected to 

have direct results at that monitor. 

3) Coincident with the above-cited activities is the institution of low sulfur fuel in 

2007 and the continuation of truck fleet turnover to much cleaner diesel engines, 

dampening the effect of the small increase in truck traffic. 

The analysis indicates, for the typical roadway link speed of 30 mph, the emission factor 

for PM2.5 drops from 0.31 grams per mile in 2004, to 0.07 in 2015 (a 75 percent 

reduction) and to 0.03 in 2030 (a 90 percent reduction). 

Construction Considerations

The DIFT project involves roadway and terminal construction. The PM2.5 analysis has 

considered this construction. However, in accordance with 93.123(c)(5), emissions from 

construction-related activities can be considered temporary, if they occur only during the 

construction phase and last five or fewer years at any individual site. Implementation of 

the DIFT project will extend for ten years but consists of a series of elements none of 

which is expected to last five years. Temporary emissions are not required to be included 

in hot-spot analyses. 

Conclusions Related to PM2.5 Qualitative Hot-spot Analysis

The conclusion of this qualitative PM2.5 hot-spot analysis is that the proposed project will 

not cause new air quality violations, worsen existing violations, or delay timely 

attainment of the NAAQS. Therefore, no mitigation is required. But, voluntary 

measures are proposed as discussed earlier. This applies to both the 24-hour and annual 

standards. This conclusion, subject to interagency consultation, is based on the 

following: 

• SEMCOG and MDEQ have been moving aggressively to address air quality 

concerns, in general, and PM2.5, specifically. This includes programs such as 

diesel locomotive retrofits, and controls on consumer products. 

• EPA is addressing the non-local component of PM2.5 pollution through programs 

such as the Clean Air Interstate Rule, stricter controls on vehicle emissions – 

including locomotives, and the low-sulfur fuel introduced in 2007. In March 

2008, EPA issued a final rule requiring that idle shutdown packages be added 

when locomotives are remanufactured. This normally occurs every five to 15 

years. 

• A number of major polluters believed to be significant contributors to the PM2.5

emission problem have closed. Mandated enforcement controls are being applied 

at other local industries such as Sverstal Steel, Marathon Oil and U.S. Steel. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 30

Marathon Oil has announced additional air quality control measures as part of a 

proposed expansion. 

• The SIP analysis addresses the SEMCOG region’s attainment of the PM2.5 15 

μg/m3

 annual standard by 2010. DIFT implementation will be just beginning at 

that point. Truck traffic will initially decrease as existing businesses are acquired 

for right-of-way. 

• Information on the relationship of vehicular traffic to pollution at monitoring 

sites demonstrates that vehicular activity in Southeast Michigan can occur 

without violation of standards. The Livonia monitor is in close proximity to 

some of the heaviest truck movements in the region and is not violating the PM2.5

standards. And, this occurred before the 2007 elimination of sulfur from fuels 

and more stringent diesel engine requirements. 

• There are a number of trucking terminals in the area. To reduce fuel costs, most 

trucking companies are implementing anti-idling policies. 

• While recognizing that MOBILE6.2 emission factors are not designed for 

localized analysis, an examination of Wyoming between Dix and the new 

Livernois-Junction Yard west-side gates shows the 2004 PM2.5 annual pollutant 

burden of 0.13 tons would be cut in half by 2015 and reduced further to 0.05 tons 

in 2030 with a negligible difference between no action and the Preferred 

Alternative. 

In summary, SEMCOG believes it will reach attainment of the annual PM2.5 standard by 2010, 

when the DIFT project is expected to commence. Substantial reductions are expected from 

industrial sources and data from monitors near these sources have been trending down. Emission 

factors are trending down faster than truck traffic will increase. Every indication is that 

concentrations at nearby monitors will continue to trend downward. 

Certified 2008 PM2.5 data have been submitted to U.S. EPA by MDEQ that show the three 

monitors of PM2.5 in Southwest Detroit at 2842 Wyoming, 6921 West Fort, and 2000 West 

Lafayette all under the 15 μ/m3

 annual standard, at 13.33, 12.85, and 12.23 μ/m3 respectively. 

Likewise values at these locations were under even the new, stricter 24-hour 98th Percentile 

standard of 35 μ/m3

 with values for 2842 Wyoming, 6921 West Fort, and 2000 West Lafayette 

of: 31.7, 34.3, and 31.7, respectively. This means they were well under the applicable 24-hour 

98th Percentile standard of 65 μ/m3 which is the applicable standard for the 24-hour conformity 

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

1 - 31

Monitored Pollutant: Particulate Matter (PM-2.5)

 98th Percentile 24-hr Average

 Station: 26-163-0015 at 6921 W. Fort, Detroit

Station: 26.163.0039 at 2000 W. Lafayette

Station 26-163-0033 at 2842 Wyoming Ave. Dearborn

30

40

50

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

PM2.5 Level (ug/m3)

EPA Standard (35 ug/m3) 24-Hr 98th Percentile - Fort

24-Hr 98th Percentile - Lay 24-Hr 98th Percentile Wyoming

Linear - 24-Hr 98th Percentile

Monitored Pollutant: Particulate Matter (PM-2.5)

Annual Mean

 Station: 26-163-0015 at 6921 W. Fort, Detroit

Station: 26.163.0039 at 2000 W. Lafayette

Station: 26-163-0033 at 2842 Wyoming Ave, Dearborn

10

15

20

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Year

PM2.5 Level (ug/m3)

EPA Standard (15 ug/m3) Annual Mean - Fort

Annual Mean - Lafayette Annual Mean - Wyoming

Linear (Annual Mean - Fort)
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 32

Therefore, the conclusion is that the proposed project will not cause new air quality violations, 

worsen existing violations, or delay timely attainment of the annual or 24-hour NAAQS for 

PM2.5. 

PM10 Hot-spot Qualitative Analysis – The PM10 hot-spot analysis is substantially the same 

as the PM2.5 hot-spot analysis. The DIFT project is of “air quality concern” (Transportation 

Conformity Guidance, Chapter 1.3) for PM10 because it would represent a transfer point that 

has “a significant number of diesel vehicles congregating at a single location.” (40 CFR 

93.123(b)(1)(iii). 

Background Conditions

MDEQ’s 2006 Air Quality Report presents 2002 EPA data showing that for PM10

Michigan’s sources are: point sources – 34 percent, area sources – 32 percent, non-road 

vehicles – 20 percent, and on-road vehicles – 14 percent. MOBILE6.2 emission factors 

for PM10 substantially decline over time. 

From 1996 to 2005, there 

were five exceedances of the 

24-hour PM10 standard in 

Michigan. Each occurred at 

the Dearborn monitoring 

station (the closest PM10

monitor to the proposed 

project). Two exceedances in 

2003 and one in 2004 

happened when construction 

occurred near the Dearborn 

monitor. However, only the 

2004 exceedance was 

considered an “exceptional 

event” under federal criteria. 

That concentration was not 

used for attainment/

nonattainment purposes, but 

the high value for 2003 was used. In spite of that, the decline in PM10 is clearly evident. 

Many of the actions related to PM2.5, and point sources that are being pursued by MDEQ, 

will have beneficial effects on PM10, as well. 

PM10 Project Conditions - Future (2015 and RTP Horizon Year - 2030)

As with PM2.5, a perspective on likely project effects on PM10 concentrations can be 

gained by examining changes in future emission factors. For the 10 mph speed, that 

represents truck operation within the Livernois-Junction Yard, and 30 mph, that 

represents travel on roadway links, PM10 emission factors decline over time as shown 

below. 

Detroit Intermodal Freight Terminal Study 

PM10 at Dearborn Monitor 

Monitored Pollutant: Particulate Matter (PM-10)

 24-hr Average

 Station: 26-163-0033 at 2842 Wyoming Avenue, Dearborn

60

80

100

120

140

160

180

200

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Year

 PM10 Level (ug/m3) 

EPA Standard (150 ug/m3) 24-Hr Max Average

Linear - 24-Hr Average

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

1 - 33

10 mph 30 mph

• 2004 – 0.38 grams/mile = 100% 

• 2015 – 0.11 grams/mile = 29% of 2004 

• 2030 – 0.05 grams/mile = 13% of 2004 

• 2004 – 0.36 grams/mile = 100% 

• 2015 – 0.11 grams/mile = 28% of 2004 

• 2030 – 0.05 grams/mile = 14% of 2004 

As noted in the PM2.5 qualitative hot-spot analysis, no intersections will operate at Level 

of Service D, or worse, and, so, under the guidelines for hot-spot analysis, no 

intersections are hot-spots. 

Gates are expected to generate through idling trucks 0.8 annual tons of PM10 in 2015 and 

0.15 annual tons in 2030. 

The roadway network associated with the Livernois-Junction Yard would experience a 

decline in PM10 pollution in the future with or without the project. In the base year 2004, 

about 2.2 tons of PM10 were generated on the network of key links. By 2015, that would 

be reduced by one-half to about 1.1 tons, and by 2030, it would be 1.2 tons. 

Construction Considerations

The DIFT project involves roadway and terminal construction. However, in accordance 

with 93.123(c)(5), emissions from construction-related activities can be considered 

temporary, if they occur only during the construction phase and last five or fewer years at 

any individual site. This is expected to be the case on the DIFT. Temporary emissions 

are not required to be included in hot-spot analyses. Implementation of the DIFT project 

will extend for ten years but consists of a series of elements none of which is expected to 

last five years. 

Conclusions Related to PM10 Qualitative Hot-spot Analysis

The conclusion of this qualitative PM10 hot-spot analysis is that the proposed project will 

not cause new air quality violations. There are no existing violations. This applies to 

both the 24-hour standard and the revoked annual standard. This conclusion, subject to 

interagency consultation, is based on many of the same factors for PM2.5 conditions, 

which are repeated here for completeness: 

• SEMCOG and MDEQ have been moving aggressively to address air quality 

concerns, in general, and PM specifically. This includes programs such as diesel 

locomotive retrofits, and controls on consumer products. 

• EPA is addressing the non-local component of PM pollution through programs 

such as the Clean Air Interstate Rule, stricter controls on vehicle emissions – 

including locomotives, and the low-sulfur fuel introduced in 2007. In March 

2008, EPA issued a final rule requiring that idle shutdown packages be added 

when locomotives are remanufactured. This normally occurs every five to 15 

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

1 - 34

• A number of major polluters believed to be significant contributors to the PM2.5

emission problem have closed. Mandated enforcement controls are being applied 

at other local industries such as Sverstal Steel, Marathon Oil and U.S. Steel. 

Marathon Oil has announced additional air quality control measures as part of a 

proposed expansion. Reduction of PM2.5 at these locations will reduce PM10 as 

well. 

• The SIP analysis addresses the SEMCOG region’s attainment of the PM2.5 15 

μg/m3

 annual standard by 2010. DIFT implementation will be just beginning at 

that point. Truck traffic will initially decrease as existing businesses are acquired 

for right-of-way. Again, measures to reduce PM2.5 will reduce PM10. 

• There are a number of trucking terminals in the area. To reduce fuel costs, most 

trucking companies are implementing anti-idling policies. 

• While recognizing that MOBILE6.2 emission factors are not designed for 

localized analysis, an examination of Wyoming between Dix and the new 

Livernois-Junction Yard west-side gates shows the 2004 PM10 annual pollutant 

burden of 0.18 tons would be cut in half by 2015 and stay at that level through 

2030 with a negligible difference between no action and the Preferred 

Alternative. 

In summary, substantial reductions in PM10 are expected from industrial sources and 

monitors near these sources have been trending down. Emission factors are trending 

down faster than truck traffic is increasing. Every indication is that concentrations at the 

Dearborn monitor will continue to trend downward as they are today. Therefore, the 

conclusion is that the proposed project will not cause new air quality violations of 24-

hour NAAQS for PM10. 

1.4.4.4 Construction Impacts – Preferred Alternative 

Construction for the DIFT would represent a series of projects spread over time: 1) land 

acquisition and clearing one section at a time; 2) site development; and, 3) roadway 

improvements at I-94 and at Central Avenue. Therefore, the provisions of 40 CFR 93.153 

regarding general conformity do not apply. 

It is anticipated that most construction related to ground disturbance would occur in one year. 

MDOT’s Standard Construction Specification Sections 107.15(A) and 107.19 would apply to 

control fugitive dust during construction and cleaning of haul roads. 

Construction mitigation is not required, but several voluntary measures are outlined in the 

Community enhancements section of the Green Sheet that follows Section 5. Included are 

strategies that reduce engine activity or reduce emissions per unit of operating time. Operational 

agreements that reduce or redirect work or shift times to avoid community exposures can have 

positive benefits. For example, agreements that stress work activity outside normal hours of an 

adjacent school campus would be operations-oriented mitigation. Also, technological 

adjustments to construction equipment, such as off-road dump trucks and bulldozers, could be an 

appropriate strategy. These technological fixes could include particulate matter traps, oxidation 

catalysts, and other devices that provide an after-treatment of exhaust emissions. The use of 

ultra-low sulfur diesel will be in effect for non-road vehicles in 2010. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 35

1.5 Noise and Vibrations 

Receptors with sensitivity to noise exist adjacent to the Livernois-Junction Yard area, near the 

CN/Moterm terminal, and along several residential streets that experience truck traffic at these 

and the CP/Oak terminal. Analysis was performed to determine whether any areas qualify for 

noise abatement in the loudest hour of the day. It found that the number of new intermodal trains 

at the Livernois-Junction Yard would be expected to go from two in 2004 to 28. These trains 

come in and go out in all directions, so these volumes do not represent trains on any one rail link. 

Preferred Alternative – Noise and Vibrations 

The Preferred Alternative will include security 

walls along the north and south sides of the 

Livernois-Junction Yard, where residential uses 

are adjacent. This will mitigate noise. Along the 

north side of the yard, along Kronk Street where 

the active tracks are relatively close to homes, the 

intermodal train increase is estimated to be from 

four in 2004 to ten in 2030. In this location, the 

security wall would extend 1,700 feet at 12 feet 

high to control noise. Rail horn use would cease 

at Lonyo and Central as the former would be closed and the latter would pass under the rail yard. 

Perceptible noise level reductions will occur on Livernois Avenue and Dragoon Street south of 

Dix to I-75 due to reduced truck traffic there. 

The conclusions related to vibrations with the Preferred Alternative is that there could be 

perceptible vibrations at the Beard School less frequently than once per hour during the school 

day (ten new intermodal trains with the Preferred Alternative in 2030 routed past the school). No 

mitigation is proposed because vibrations occur throughout the school day even in the absence of 

intermodal train activity. 

1.6 Threatened and Endangered Species 

The Preferred Alternative will have no effect 

on any state or federally listed Threatened, 

Endangered, or Special Concern plant or 

animal specie. 

A snail called the heath helicellid, Xerolenta 

(=Helicella) obvia, has been found in the 

Detroit area associated with railroad yards, 

including the Tri-modal facility on Dix and 

within the Livernois-Junction Yard. It has 

been considered an agricultural pest in Europe especially of grains. It could become a pest in 

Michigan. Attempts are underway to eradicate the populations found so far. Property owners will 

need to be made aware of this potential pest during DIFT project development. 

Example of Security Wall in Residential Area at Nearby 

Melvindale Terminal 

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

1 - 36

1.7 Waterways/Water Quality/Floodplains/Coastal Resources 

1.7.1 Waterways 

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

would be affected by the Preferred Alternative. 

1.7.2 Water Quality 

The Preferred Alternative will increase surface runoff on-site, but it will be directed to an 

engineered on-site collection system to ensure that future flow rates off the site do not increase. 

There are no special pollutants of concern associated with intermodal operations (see Section 1.14 

Emergency Response Controls). The flow will be subject to NPDES permitting. The railroads 

will be responsible for applying for these permits and meeting their conditions. Paving the yard 

will result in significantly less erosion and silt carried to local roads clogging the local storm 

drainage system. Likewise, reduction in dirt carried to local roads by vehicle tires and/or blown 

there will benefit water quality. 

1.7.3 Floodways and Floodplains 

The Preferred Alternative will not affect floodways or floodplains. 

1.7.4 Coastal Resources

The Preferred Alternative is outside Michigan’s Coastal Zone and will have no effect on 

resources therein. Likewise, it is not subject to the Great Lakes Coastal Barrier Act. There will 

be no effect on any coastal barrier, critical dunes, or high risk erosion areas. 

1.8 Wetlands 

The 400 square foot (less than 0.01 acre) Palustrine 

Emergent wetland identified at the southeast corner 

of Central Avenue and the railroad overpass, at the 

south limit of the current yard, will be lost under the 

Preferred Alternative. MDOT, through a cooperative 

agreement with MDEQ, will build or restore 

compensatory mitigation for unavoidable wetland 

impacts using a “Moment of Opportunity” site 

allowed under the General Permit Category of Part 

303 of the Michigan Natural Resources and 

Environmental Act 451 (1994, as amended). 

The project is in compliance with Executive Order 11990, “Protection of Wetlands.” It has been 

determined that there is no practicable alternative to the proposed action, and that the proposed 

action includes all practicable measures to minimize harm to wetlands that may result from such 

use. 

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

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1.9 Historic and Archaeological Resources 

Impacts on properties on or eligible for the National Register of 

Historic Places (Section 106 of the National Historic Preservation 

Act properties) were reviewed. These resources are also afforded 

protection under Section 4(f) of the Department of Transportation 

Act of 1966 if there is a “use” of the property (see Section 6 of 

this FEIS). Adverse effects9

 on historic resources are avoided 

when prudent and feasible. When it is not prudent and feasible to 

avoid adverse effects, they are minimized or mitigated. The 

Preferred Alternative has adverse effects. So, measures have been 

developed in consultation with the State Historic Preservation 

Officer (SHPO), the community, and the Advisory Council on 

Historic Preservation in Washington, D.C. That information is 

presented in Section 6 of this document, which covers impacts to 

Section 4(f) properties. 

Archaeological Resources – Research and field review found no 

known National Register eligible archaeological resources at any 

intermodal terminal for any alternative. However, at the time of 

the DEIS, the SHPO agreed with the assessment that field 

investigations at two archaeological sites at the Livernois-Junction 

Yard (Jacques Baby Mill and the Michigan Central Stockyard 

Hotel) should be conducted to determine whether archaeological 

deposits exist prior to any construction (see letter dated November 

22, 2004 in Appendix A, Section 2). Subsequently, it was 

determined that the Preferred Alternative would avoid the Jacques 

Baby Mill site and recent construction activity by the railroad in 

the vicinity of the Michigan Central Stockyard Hotel within the 

Livernois-Junction Yard has likely further buried the site under 

fill. DIFT activity is expected to add more fill, protecting the site. 

(See Section 4.13.5.) 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. 

Therefore, as a result of these consultations, it has been determined and agreed that no historic 

properties are affected for archeological resources by this undertaking. Finally, in the event any 

unknown archaeological resources are accidentally identified during the execution of the work, it 

is also agreed that the site is only important for the information it may reveal and not for 

preservation in place. 

Above-ground Resources – The Preferred Alternative will have an adverse effect on the 

Michigan Box Company by causing its removal. A Memorandum of Agreement (MOA) related 

to this property is included in Appendix C. Impacts to the property are addressed in Section 6 of 

this FEIS, which is the Final Section 4(f) Evaluation for the DIFT Project. Also, the SHPO stated 

 

9

 Adverse effects occur when a project alters the characteristics that qualify the property for the National Register of 

Historic Places. 

What is the National Historic 

Preservation Act (NHPA)? 

Legislation passed in 1966 

establishing the federal 

government’s policy on historic 

preservation and the national 

historic preservation program 

through which that policy is 

implemented. 

What is Section 4(f)? 

Section 4(f) of the Department of 

Transportation Act of 1966 states 

that no transportation project 

should be approved which requires 

the “use” of any publicly owned 

land from a public park, recreation 

area, wildlife and waterfowl refuge, 

or historic site unless there is no 

feasible or prudent alternative to 

use of such land. 

What is the National Register of 

Historic Places (NRHP)? 

The NRHP, established under the 

NHPA of 1966, is the official list of 

cultural resources worthy of 

preservation maintained by the 

National Park Service. Properties 

listed in the NRHP include 

districts, sites, buildings, structures, 

and objects that are significant in 

American history, architecture, 

archaeology, engineering, and 

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

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in a letter dated June 20, 2005 (Appendix A) that the “construction of a barrier wall alongside the 

railroad yard across the street from the house [6332 John Kronk] has the potential to result in an 

Adverse Effect on the house through its height, design, and placement. Therefore, any alternative 

that includes the construction of such a wall must include the condition that the plans for the 

barrier wall and any landscaping are subject to review and approval by the SHPO.” Since that 

time the SHPO has found that there would be no adverse effect (see MOA, Appendix C). 

6332 John Kronk Streetscape, View to south-southwest toward rail yard from house (house is on the right) 

Traditional Cultural and Religious Properties – There are no known traditional cultural and/or 

religious properties claimed or reported by any other cultural group within the area of potential 

effect. Project early coordination letters were sent to the twelve (12) federally recognized Tribes 

of Michigan seeking comments regarding any issues and/or special concerns relating to this 

undertaking. Subsequent to these tribal notifications, no requests for consultation or 

identification of any Traditional Cultural and/or Religious Properties were received from any of 

the twelve federally recognized Tribes. Therefore, because there are no reported impacts to 

traditional cultural and/or religious properties and no request for consultation caused by this 

undertaking regarding any such properties, no historic properties are affected and the Section 106 

process pertaining to traditional cultural and/or religious properties has been completed. 

1.10 Parkland and Public Recreation Land 

The Preferred Alternative will not have any direct or indirect effect on any parkland, including 

during construction. 

1.11 Visual Conditions 

A wall will be built for security on the north 

side, and part of the south side, of the 

expanded Livernois-Junction Yard. A new 

perimeter road is also part of the plan on the 

terminal’s north boundary. These features 

will shield the view of the terminal and 

provide a more visually pleasing setting than 

the existing conditions. Several abandoned 

properties, salvage yards, and industrial 

facilities will be removed and new intermodal 

facilities will be built in their place. Area on Kronk, near Stecker, that would be taken by the 

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

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1.12 Contaminated Sites 

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

conducted for the DIFT project.10 The purpose of the PACS was to investigate parcels of property 

potentially affected by the project for the presence of environmental contamination and to 

determine the need for further investigation and, where needed, mitigation measures. Because 

there was no development outside the rail terminal under the No Action Alternative, it was not 

the subject of the PACS. 

More than five dozen sites were investigated for contamination. The federal environmental 

records and databases searched were: 

• CERCLIS (Comprehensive Environmental Response, Compensation, and Liability, 

Information System); NPL (National Priorities List [Superfund]); 

• RCRIS (Resource Conservation and Recovery Information System); 

• CORRACTS (Corrective Action Report); and, 

• ERNS (Emergency Response Notification System). 

State environmental records that were reviewed include: 

• SHWS (State Contaminated Sites); 

• SWF/LF (Solid Waste Facilities Database); 

• LUST (Leaking Underground Storage Tanks); 

• UST (Underground Storage Tanks); 

• BEA (Baseline Environmental Assessment); 

• Indian UST (USTs on Indian land); and, 

• HIST LF (Inactive Solid Waste Facilities). 

These databases and lists conform to the requirements of ASTM E1527-00 (Standard Practice for 

Environmental Site Assessments: Phase I Environmental Site Assessment Process). 

The PACS found: 

• No NPL sites; 

• Two CERCLIS sites, both of which were NFRAP (No Further Remedial Action Planned) 

sites – ANR Freight System (Crown Enterprises), 3685 Central Avenue, and Central 

Transport, Inc., 4440 Wyoming; 

• No RCRIS TSD facilities (Treatment, Storage or Disposal); 

• Thirty-one RCRIS hazardous waste generators; 

• No CORRACTS sites; 

• Four ERNS sites; 

• Nine Michigan Contaminated Sites List sites; and, 

• Twenty-eight LUST sites. 

Based on interviews with property owners and occupants, site visits, and record reviews, each of 

the sites was rated low (L), medium (M), or high (H) for potential environmental contamination. 

 

10 “Project Area Contamination Survey,” The Corradino Group, August 2004. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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L (Low): These sites include known current or former hazardous or petroleum handlers that are 

not currently being investigated or remediating an environmental problem. Examples of this 

category are gas stations that have been designated “closed LUST” sites and businesses that 

handle hazardous materials or petroleum. 

M/H (Medium/High): These sites: have a reasonable chance of contamination on a given site. 

Examples of this category include gas stations that are identified by MDEQ as open LUST sites; 

former gas stations closed prior to December 1988 (the date of current federal and state UST 

regulations); sites on the Michigan Central Contaminated Sites List; and, sites that exhibit 

indications of improper handling of materials, such as the presence of stained soils, improperly 

stored materials, etc., or other evidence of a recognized environmental condition. These sites 

may need sampling and testing to characterize their environmental condition. 

A limited Preliminary Site Investigation (PSI) was also conducted as part of the environmental 

assessment process. The purpose of the PSI was to further investigate parcels of property 

identified in the PACS as having known or suspected contamination. Typically, the PSI consists 

of on-site sampling of soils, groundwater, and/or surface water and laboratory analysis of 

samples. The PSI conducted for the DIFT Project consisted of soil borings in public rights-ofway near the Livernois-Junction Yard, 

the CP/Expressway and CP/Oak 

terminals in Detroit, because 

landowners would not grant 

permission to collect samples on their 

properties. The soil borings in the 

public rights-of-way provided a means 

of examining subsurface soil 

conditions to identify signs of 

pervasive contamination and 

backfilled clay pits, which have been 

well documented in the vicinity of the 

Livernois-Junction Yard. The findings 

of the PSI did not reveal any 

indications of pervasive soil 

contamination or fill. No soil borings 

were conducted in Dearborn for the 

Livernois-Junction Yard. 

Twenty-seven properties rated M/H will require PSIs to assess potential contamination and to 

determine if cleanup or mitigation is required. Impacts will be minimized by disposing 

contaminated material properly and by protecting workers. As the DIFT project goes forward, a 

Risk Assessment Plan will be developed to include a Worker Health and Safety Plan. If 

monitoring wells are present, they will be abandoned properly. All contaminated areas will be 

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

impact and/or spread existing contamination. 

Geoprobe Vehicle Used for Soil Sampling 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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1.13 Indirect and Cumulative Impacts 

The indirect (secondary) and cumulative effects associated with the proposed improvements to 

intermodal terminal development are presented here. The basis upon which the analysis was 

conducted is defined in federal guidance, which indicates the following: 

Indirect (secondary) effects – Caused by an action (intermodal terminal expansion) and occurring 

later in time or father removed in distance, but occurring in the reasonably foreseeable future (40 

CFR 1508.8(b)). 

Cumulative effects – Resulting from the incremental impact of the action when added to other 

past, present and reasonably foreseeable future actions, regardless of what agency or person 

undertakes such actions (40 CFR 1508.7). 

Indirect and cumulative impacts for the Preferred Alternative are summarized below. Additional 

information, at the end of this section, has been developed in response to comments on the DEIS. 

• Mobility: While there will be an increase in traffic due to both the growth in intermodal 

activity and the stimulated additional development, there are no negative 

congestion/mobility effects expected either on major arteries or local neighborhood 

streets. 

It should be noted that under the Preferred Alternative, where intermodal operations of 

three railroads are to be consolidated at the Livernois-Junction Yard, the terminals at 

CP/Oak, Melvindale and Willow Run are to continue to be used for shipping freight by 

other means than intermodal. That activity would be associated with a smaller volume of 

truck traffic than if the terminal was to continue to serve intermodal. 

• Economic Impacts: It is expected that local businesses will develop or expand in several 

sectors related to the growth in intermodal transportation. Likewise, such change will be 

associated with an increase in local jobs with greater income levels and buying power. 

This should then help grow the tax base. 

• Land Use Changes: Land use changes are expected to accelerate with growth in 

intermodal transportation and the associated and improved economic stimulus. Such 

growth could be associated with the mixing of land use types that are unwanted, i.e., 

industrial/commercial with residential. This can be avoided by local units of government 

applying already-existing land use/zoning principles, like those in the City of Detroit’s 

Master Plan of Policies. 

• Air Quality: Increased development will likely increase vehicular activity. But, results 

of the analysis of direct/indirect air quality impacts indicate that such increases will not 

cause standards to be violated. This will happen through government actions that are 

consistent with the planning policies in effect in each jurisdiction. 

• Cultural Resources: Historic districts/properties may experience adverse effects from 

new private sector development associated with the growth in intermodal activity that 

could occur adjacent to their boundaries if already-existing local governmental controls 

are not applied. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 42

• Community Cohesion: Development stimulated by intermodal activity/investment may 

create opportunities for use of abandoned residential parcels (the City of Detroit owns 

thousands of such parcels as a result of tax delinquencies). This development could lead 

to unwanted mixing of land uses if controls in the master plans of various cities are not 

implemented. For example, logistics businesses to support intermodal activity could 

locate (if not regulated) along or near the Livernois-Junction Yard, on tracts of land that 

are tucked in residential areas. If that is allowed to occur, increased truck activity would 

have a negative effect on the surrounding community. 

• Noise: Traffic volumes and ambient noise levels will increase as economic conditions 

improve. Negative effects are not expected and can be avoided with care by the 

developer and local government agencies in locating this increased development away 

from sensitive uses. The DRIC project would reconfigure access along I-75 in the 

Livernois/Dragoon area. These changes could lead to a significant drop in truck access in 

the area north of I-75. 

• Water Quality: Increased development could lead to more impervious surface runoff and 

pollutant load. This could be offset by reclaiming properties now affected by 

contaminated materials for increased economic activity. Thousands of such properties 

exist, are abandoned, and have not been remediated. Use of some of these properties by 

DIFT-related activities will cause remediation, which will improve the quality of the 

runoff into surface and subsurface drainage infrastructure. 

For the Preferred Alternative, the conclusions related to indirect and cumulative impacts, cited 

above, are amplified here in response to comments on the DEIS. 

• Mobility – A West Detroit Junction railroad project will facilitate Amtrak train 

movement in Southwest Detroit. 

Michigan Avenue was recently reconstructed, substantially improving its driving surface 

and improving travel speeds. MDOT has also been reconstructing Fort Street from the 

Ambassador Bridge, south across the Rouge River. The reconstruction of the bridge over 

the Rouge River will require a two-year detour of vehicular, bicycle and pedestrian traffic 

to the Dix Road bridge to the north. 

The Ambassador Bridge Gateway Project, scheduled to be completed in 2009, was 

planned to provide direct access between the Ambassador Bridge and the interstate 

system. In the past, many trucks lost their way and “wandered” around Southwest 

Detroit on local streets trying to get to or from the Ambassador Bridge. The Gateway 

Project will substantially reduce the chance trucks will use local streets. 

The Detroit River International Crossing (DRIC) project is to provide a new bridge to 

Canada. The crossing will connect to I-75 between the Rouge River and the Ambassador 

Bridge. It will provide an alternative to the Ambassador Bridge for traffic to/from 

Canada. A new crossing to Canada will avoid mobility restrictions between Southeast 

Michigan and Ontario, Canada. The DIFT project has independent utility from the 

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

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 Future Detroit River Crossing 

The biggest change that could be brought by the DRIC to the DIFT would be closing the 

Livernois-Dragoon interchange with I-75. This would reinforce the DIFT intention to 

focus truck traffic on I-94 to Livernois and Wyoming Avenues. 

Whether or not the DRIC Study produces a new crossing, the Ambassador Bridge owners 

are pursuing construction of a replacement span. It would directly connect to the plazas 

in the U.S. and Canada that are being expanded. 

The proposed project to upgrade the Blue Water Bridge Plaza would have a negligible 

effect on the Detroit -Windsor area, including the DIFT project, because there will be 

neither cost, nor travel time savings sufficient to cause long distance diversions. 

• Economic Impacts - It is expected the reconstruction of Michigan Avenue by MDOT will 

foster economic redevelopment there. 

The Ambassador Bridge Gateway Project was planned to divert truck traffic from Fort 

Street to direct ramp connections to the interstates. Historically, all trucks coming into 

the U.S. got to I-75 southbound via Fort Street. Some of these trucks likely take 

advantage of the numerous truck-oriented businesses along Fort Street. These businesses 

will see fewer trucks passing by. 

• Land Use – Without the DIFT project there is no indication the pattern of industrial/

trucking/scrap yard uses will change. Though residential rehabilitation is occurring in 

Southwest Detroit, this is not the case nearer the Livernois-Junction Yard. Several homes 

on the north side of John Kronk, originally counted as relocations in the DEIS, no longer 

exist. 

There is a community sense that appropriately placed vegetation can have a long-term 

positive land use effect on air quality – via the Sverstal Consent Agreement. By 

providing a buffered “edge” to the railroad terminal, the project will be a better neighbor 

than the rail yard is today, and help stabilize land uses in the area. There are few such 

buffers in the area now. 

• Air Quality – A number of actions are being taken regionally to improve air quality. 

Actions related to U.S. Steel, Sverstal Steel and Marathon were noted earlier. Dust 

control plans have been instituted in some instances. The Ambassador Bridge Gateway 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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project will provide direct connections for trucks to the freeway system, eliminating Fort 

Street as the access to I-75 southbound. The DIFT project promotes the use of rail, rather 

than roads to move freight and reduce both on-terminal and local roadway emissions. 

Insofar as increased development accompanies these projects individually and/or 

collectively over time, SEMCOG has forecast that cleaner engines and fuel will outstrip 

increased travel. 

Over the long term, increasingly stringent EPA controls announced in March 2008 on 

new and remanufactured locomotives (remanufacturing normally occurs every five to 15 

years) and on locomotive idling will substantially improve CO2, NOx and PM emissions. 

It is also important to recognize what effects may occur in one key regional area: wealth 

distribution/redistribution, which occurs with shifts in population, employment and tax base. 

Shifts in tax base occur as land is developed for new housing and businesses. Shifts also occur 

within existing built-up areas as residents and businesses move. Both processes usually result in 

less taxable property in older communities that have little undeveloped land and room to grow. 

Market-driven actions and supporting public policy decisions underlie the dynamics of the wealth 

distribution pattern in the Detroit-centered region. All of these dynamics operate separately from 

the Preferred Alternative. These dynamics include, as cited by SEMCOG in its report entitled 

Land Use Changes in Southeast Michigan, Causes and Consequences, “...residential segregation 

by race and income, federal tax subsidies for home mortgage interest and property taxes, school 

funding and quality, crime and public safety, societal ideals of lifestyle and urban design, 

constitutional protections of private property rights, infrastructure financing policies, and extent 

of personal vehicle ownership and use.” 

The DIFT Preferred Alternative has the ability to respond to this pattern in a positive way. The 

DIFT can have greater positive than negative impacts – direct, indirect and cumulative, by 

building on the transportation and industrial strength of the areas in which intermodal terminals 

function; by making improvements to move terminal traffic out of residential areas; by 

constructing walls that provide terminal security and reduce noise; by paving surfaces that are 

unpaved; by creating jobs in the local area around the terminal; and, by helping residents be 

prepared to take those jobs. 

The DIFT can also be measured as a positive proposal by using a number of principles of 

Governor Granholm’s Land Use Leadership Council, which promote use of existing 

infrastructure in communities to create public-private investments to address economic and other 

quality-of-life issues. These principles are: 

• Supporting efforts to make Michigan cities more livable by expediting the reuse of 

abandoned properties, controlling blight, encouraging private investment, encouraging 

mixed-use development, improving transportation options, supporting a full range of 

housing options, and attracting and retaining residents who can contribute to the viability 

of our urban core areas. 

• Making better use of existing public infrastructure by encouraging public and private 

investment in already developed areas. 

• Creating incentives to encourage interagency and intergovernmental cooperation in 

addressing land use issues and public investments of more than local concern. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 45

• Encouraging private investment in already developed areas by removing governmental 

barriers and creating incentives. 

• Identifying “commerce centers” where infrastructure is already serving relatively dense 

populations to guide the future investment of state resources to support private 

investment and development. 

1.14 Emergency Response Controls 

Each of the Class I railroads operating intermodal freight terminals in Southeast Michigan has 

Emergency Response Plans in place to address transportation incidents involving U.S. DOTregulated materials (hazardous materials, hazardous substances and hazardous wastes) and oils. 

These plans prescribe procedures to respond to spill incidents from derailments, leaks, fuel spills, 

etc. 

Regulations governing Emergency Response Plans include OSHA’s (the U.S. Occupational 

Safety and Health Administration) Hazardous Waste Operations and Emergency Response 

(HAZWOPER) requirements, U.S. DOT’s 49 CFR 130, the Oil Pollution Prevention and 

Response regulations (40 CFR Part 112) and other programs of the Clean Water Act. 

Components of Emergency Response Plans include pre-emergency planning coordination with 

local agencies; assignment of personnel, their roles and responsibilities; hazard recognition; 

specialized personnel training; site security and control; emergency notification procedures; spill 

response equipment; and, emergency medical treatment provisions. 

Spill prevention and response at fixed facilities (including railroad terminals) that store quantities 

of oil and hazardous materials above threshold amounts are addressed with Spill Prevention 

Control and Countermeasures Plans (SPCC) and Stormwater Pollution Prevention Plans that have 

been prepared by the railroads. These plans focus on prevention of releases to streams and other 

water bodies. 

These procedures are part of the Preferred Alternative. 

1.15 Terminal Security 

Security walls, fencing, other physical barriers, and electronic systems (e.g., sensors, alarms) are 

part of the Preferred Alternative to protect areas within the terminal from unauthorized access. 

Along Kronk Street between Martin Street and Livernois Avenue, the security wall will also act 

to abate noise. This 1700-foot wall would be 12 feet tall above the existing retaining wall. 

Access control points for personnel and vehicles to move through the terminal boundary lines 

(such as gates, doors, guard stations, and electronically controlled or monitored portals) are also 

included in the conceptual design of the Preferred Alternative. Measures that will enhance these 

boundaries/access points include clear zones on both sides of fences, security lighting, locks, 

closed-circuit television (CCTV) systems and signage. 

While the number of access points will be kept to a minimum, adequate vehicle access points are 

planned for maintenance and emergency operations. To prevent obstructions within the gate path 

and protect gate equipment, the design concept includes proper drainage grading; planned gaps in 

curbs; installation of concrete channels or mow strips below the gate path; and, use of bollards. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

1 - 46

Security effectiveness of the perimeter area will be enhanced by the provision of clear areas on 

both sides of the wall to facilitate surveillance and maintenance of the wall and deny cover to 

vandals and trespassers. Suggested clear distances range from 10 to 30 feet, within which there 

should be no climbable objects, trees, or utility poles abutting the wall nor areas for stackable 

crates, pallets, storage containers, or other materials. Likewise, the parking of vehicles along the 

wall will also be prevented. In addition, landscaping within the clear area will be designed to 

reduce potential hidden locations for persons, objects, fence damage, and vandalism. 

Lighting of the area on both sides of gates, and selected areas of walls, will be provided. 

Similarly, sufficient lighting will be provided for areas in which a CCTV camera is intended to 

monitor activity. Reduced lighting, or sensor-activated lighting, may be considered in areas 

which have minimal traffic in the off-peak hours. CCTV monitoring will be considered, 

particularly for low-traffic gates and maintenance access points that are removed from principal 

activity areas. 

Signage will be posted on certain security boundaries and at selected access points. Signs will be 

located such that when standing at one sign, the observer will be able to see the next sign in both 

directions. The use of signage, even in some non-required locations, will provide a deterrent by 

warning of the boundary as well as for notification of the consequences for violation. Many 

locations with access control or CCTV equipment may warrant signage for either directional or 

legal purposes (e.g., “Alarm Will Sound If Opened,” “Authorized Personnel Only,” “Notice: All 

Activities In This Area Are Being Recorded via CCTV,” etc.). 

VACIS (Vehicle and Cargo Inspection Station) is an X-ray-type device that is able to see into 

containers/trailers to detect any unusual cargo. VACIS systems are in operation by each of 

Canadian Pacific and Canadian National Railroads to screen trains on the Canadian side of the 

international border before they enter the U.S. Consideration by all DIFT participants (public and 

private) will be given to installing a VACIS (or similar) system at the Livernois-Junction Yard 

with the Preferred Alternative. 

1.16 Terminal Lighting 

Lighting will increase with the Preferred 

Alternative for security purposes. To the extent 

practical, lighting in the area of Cabot, 

Lawndale, and Trenton Avenues, along east 

Kronk and the area south of Dix Avenue (at the 

central/east end of the terminal) will be 

directional to minimize glare in these residential 

areas. There is already street lighting in each of 

these areas. 

1.17 Soils 

The former clay pits near the Livernois-Junction Yard will need to be tested to determine what 

type of soil/materials were used to infill the area. The potential of the existence of contaminated 

materials causes this need. 

Directional Lighting at Terminal Edge 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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1.18 Permits 

Construction activities for the Preferred Alternative will involve obtaining permits in several 

areas 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, stormwater permit; 

and, Section 404, related to dredge and fill. 

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

project, impacting any wetland (regardless of size) requires 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 permit for construction projects 

that involve land clearing of one acre or greater. 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 

All bituminous and Portland Cement concrete proportioning plants and crushers must meet the 

requirements of the rules of Part 55 of Act 451. 

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

temporary. At the Livernois Yard, MDOT, through an agreement with the MDEQ, would 

provide wetland mitigation using a “Moment-of-Opportunity” site allowed under the General 

Permit Category for Part 303. 

Final mitigation measures proposed in areas requiring the above permits will be developed in 

consultation with the appropriate agencies, and will be included in the design plans and permit 

applications for implementing the project. Section 5 of this FEIS summarizes mitigation 

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

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1.19 Energy 

Energy would be used to construct the Preferred Alternative. Fuel savings should be realized in the 

long term due to improved efficiencies in the movement of freight on rail to, from, and within 

intermodal yards. There will also be improved efficiencies in the movement of freight on trucks to 

and from intermodal yards adding to fuel savings, consistent with the reduction of vehicle miles of 

travel in shifting freight from truck to rail (each intermodal rail car is the equivalent of three trucks). 

1.20 Implementation Cost 

Estimated construction costs for the Preferred Alternative (in 2008 dollars) are $395 million. 

Community enhancement costs add $11 million (Table 4-18). Another $123 million is required 

for right-of-way and relocation. These costs will be borne by both government and the railroads. 

The total project cost is $529 million. Accounting for the years in which the dollars will actually 

be spent means that inflation adds another $121 million for a year of expenditure project cost of 

$650 million (at an estimated level of confidence of 70 percent). 

1.21 The Relationship Between Local Short-Term Uses of the 

Environment and the Maintenance and Enhancement of LongTerm Productivity 

This project is a result of local and regional, as well as statewide comprehensive planning. Present 

and future freight needs were considered and are reflected in the Preferred Alternative that address 

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

of resources by the Preferred Alternative11 are consistent with the maintenance and enhancement of 

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

Project construction will result in increased use of a more efficient mode – rail – over the long term, 

compared to the No Action Alternative. 

1.22 Irreversible and Irretrievable Commitments of Resources Which 

Would be Involved in the Proposed Action

To date, the DIFT studies have cost $7.5 million. There would be no additional cost if no 

government action is taken. Implementation of the Preferred Alternative involves a commitment 

of a range of natural, physical, human, and fiscal resources. Land used for 

expansion/construction of a proposed terminal is an irreversible commitment of land. 

Considerable amounts of fossil fuels, labor, and construction materials such as cement, aggregate, 

and bituminous material will be expended for this project. Additionally, large amounts of labor 

and natural resources will be used in the fabrication and preparation of construction materials. 

Their use will not have an adverse effect upon the supply. 

Construction of the Preferred Alternative will require a substantial expenditure of state, federal, 

local and private funds. The commitment of these resources will result in an improved freight 

transportation system, providing improved efficiency, safety, and savings in time. These are 

expected to outweigh the commitment of these resources. 

 

11 In the context of a major transportation improvement, short-term use of the environment means use of resources such 

as fossil fuels, building materials, petroleum, and the like, for a few years, not for an indefinite period. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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1.23 Areas of Controversy 

Project controversy originated early in the project over the number of trucks forecast to use the 

project at the Livernois-Junction Yard where all four railroads would consolidate their intermodal 

operations. Revised forecasts and engagement with the community reduced the concern, but 

controversy lingered when the scope of the Practical Alternatives was expanded to include the 

potential expansion of the existing Oak and Moterm terminals. The latter is located in Ferndale and 

the expansion potentials were to the west into a neighborhood, to the east into a major employment 

center and tax-base resource for the community, and to the south into the Michigan State 

Fairgrounds (which had seen earlier rail use). Use of the State Fairgrounds was included as a site 

for a Practical Alternative. As the comments in Section 7 indicate, there was substantial concern 

about use of the Fairgrounds. 

Southwest Detroit near the Livernois-Junction is an area of high concentration of minorities and 

low-income peoples. So environmental justice is an issue. This took the form of concern about air 

quality and health effects. The analysis finds no air quality effects, but there remain concerns about 

truck traffic and health effects. 

The remaining principal areas of controversy, in addition to issues arising out of property 

acquisition, are impacts to the tax and employment base, impacts to the sustainability of the areas 

near the terminals, and air quality impacts. 

They have been addressed with the Preferred Alternative through mitigation and community 

enhancements, and in the Pre-Development Plan Agreement with the railroads (see Section 1.27 

and Appendix F). 

1.24 Public Involvement

Public and agency input 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. Section 7 of this FEIS covers: 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; 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. 

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 
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• 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. 

Section 7 addresses comments received from the general public and a number of organizations. 

Comments received from agencies and government entities are treated separately in Appendix A. 

1.25 Unresolved Issues 

There are no substantive unresolved issues. 

1.26 Project Status 

This project is listed in MDOT’s 2005-2030 State Long-Range Transportation Plan. It is on 

SEMCOG’s 2030 Regional Transportation Plan (RTP), with construction beginning in 2010. 

With its inclusion on the plan, it was shown to be in conformity with the Clean Air Act. After 

this Final EIS is completed, a Record of Decision (ROD) for the project will be requested. Its 

signing allows the project to advance to design. 

Due to modifications that are recommended at the I-94 interchange with Livernois Avenue, an 

Interstate Break-in-Access Justification Report (IAJR) is being prepared to document the effect of 

the proposed access changes on the interstate system and affected local roads. Analysis 

performed for the IAJR has been incorporated into this FEIS. 

The Canadian National Railway Company; Canadian Pacific Railway Company; Conrail; CSX 

Intermodal and CSX Transportation, Inc.; Norfolk Southern Railway Company and Triple Crown 

Services Company; and the Michigan Department of Transportation have signed a 

Pre-Development Plan Agreement (Appendix F). The signature of that document was a 

necessary condition for the signing of this FEIS. It refines the understandings and intentions of 

the parties with respect to certain terms of the DIFT. 

Subsequent to the Record of Decision, a detailed DIFT Development Plan (20-year period) 

agreed to by all the parties, will be signed. Thereafter, Program Agreements (rolling five-year 

periods) will lead to individual Project Agreements executed by MDOT with individual railroads. 

1.27 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. 

These mitigation concepts are based on the best information available through October 2009. 

It is noted elements that are part of terminal design (paving, lighting, security walls, Central 

Avenue underpass) are covered in a Pre-Development Plan Agreement included as Appendix F. 
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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 security walls will be designed to reduce terminal noise a minimum of 5 dBA. 

Community Mitigation and 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 

improvements in the community related to the DIFT project. 

• 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, and schedule for the local road improvements. Environmental 

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

• 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. 

• 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. 

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

via Wyoming Avenue. 

• Construction of security walls at various locations along the perimeter of the terminal 

will minimize visual and noise impacts. 

• 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. 

• 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. 

• MDOT will coordinate with the Michigan Department of Labor and Economic Growth to 

explore job training opportunities, English as a Second Language (ESL), and other 

training options in the project area.
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SECTION 2 

PURPOSE OF AND NEED FOR ACTION 

This section defines the purpose of the proposed action, including a brief history of intermodal 

activity in the Greater Detroit Area (GDA). It then explains the need for the project in terms of 

demand and capacity. 

2.1 Purpose of the Proposed Action 

The purpose of the Detroit Intermodal Freight Terminal (DIFT) 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 

Southeast Michigan has a regional 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. 

2.1.1 Project Background 

The growth of U.S. intermodal traffic (Figures 2-1 and 2-2), the enormous influx of double-stack 

trains, and the entry and rapid growth of rail-truckload initiatives have all raised questions about 

the adequacy of intermodal terminals to handle traffic increases, and to do so efficiently. 

In the 1980s, railroads began to consolidate their intermodal service networks into fewer, larger 

hub terminals. Railroads saw an opportunity to consolidate enough volume in one location to 

justify lift machines and other costly improvements/equipment, and to eliminate smaller facilities. 

But, the challenge is to not only provide capacity for future intermodal growth; it is to also plan 

for this growth so that rail and highway freight facilities operate as a coordinated system. 

The initial response to the challenge occurred when the Michigan Department of Transportation 

hired Mercer Management Consultants in 1993 to respond to the Michigan Legislature’s initiative 

to address intermodal transportation in the Greater Detroit Area. The results of that, and 

subsequent work, recognized that: 

• Detroit is one of the top markets in the nation for intermodal freight (trailer or container 

loads moving by rail). 

• Detroit has led the nation in its use of “RoadRailer” technology, i.e., a truck trailer 

becomes a rail car by placing rail wheels underneath. 

• One-third of Detroit’s intermodal traffic is trucked to and from other cities. This means it 

travels by rail to Chicago, Toledo, or Windsor for example, and then is trucked to Detroit. 

Better intermodal service could result in a diversion of some of this intermodal activity to 

Detroit because of reduced transportation costs. This would eliminate some trucks from 

Michigan’s roads, which could reduce congestion and help ease the need for added 

capacity on the roadway network. 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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• The proposed improvement of the Detroit-Windsor rail tunnel and the construction of a 

new Port Huron-Sarnia rail tunnel enhance intermodal access to/from the Detroit area. 

2.2 Need for the Proposed Action 

The Detroit area has a need for greater intermodal capacity and improved connectivity

among the intermodal terminals of the Class I railroads. The needs of the U.S. economy and 

national defense are undergoing a significant change. Modern supply chain logistics, just-in-time 

manufacturing and deployment, and leaner organizations have revolutionized the way industry and 

the military transport freight. Concurrently, intermodal freight transport also is undergoing change. 

It is growing, spreading into new markets and restructuring to meet the needs of its customers. 

Supporting the needs of business, industry and the military – particularly in the way they contribute 

to the quality of life, the economy and national defense – continues to be the primary justification 

for public investments in the transportation system. 

Intermodal traffic could grow faster and to greater levels in Detroit, if adequate capacity

existed (Section 2.2.1). Detroit has been one of the top intermodal markets in the nation. The 

Detroit market has characteristics that could cause intermodal traffic to grow faster than the national 

average, including its strategic trade relationship with Canada ($150 billion in cross-border trade 

annually). 

MDOT’s role in the DIFT is to improve the connectivity between modes through provision of a 

better interface between the public road system and the private rail system and to facilitate the 

development of significant capacity at the region’s intermodal facilities (Section 2.2.2). It is the 

role of government (in this case MDOT) to ensure that the businesses and industries involved in the 

freight transportation segment of the economy continue to have access to the market (i.e., customers, 

Figure 2-2 

U.S. Rail Intermodal Traffic
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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workers, shippers, etc.). This, in turn, supports jobs in Michigan and nationally and ensures 

maintenance of the national defense as well as a high quality of life for the region’s citizens. 

2.2.1 Intermodal Terminal Capacity Versus Demand 

The following discussion deals with intermodal terminal activity in the Greater Detroit Area 

(GDA). It is presented without identifying each terminal because of the proprietary nature of the 

information. 

Mercer Management Consulting, under contract with the Michigan Department of Transportation, 

assessed the 1993/1994 conditions of intermodal transportation in the GDA and defined a course 

for the future. The study found that the volume of intermodal traffic, called lifts,11 was 335,000 

in 1994, which was an 18 percent increase over the 1992 volume of 283,000 lifts. In 1998, the 

volume had grown to approximately 400,000 lifts or another 16 percent over 1994. The number 

of lifts then declined, mainly because of the railroads’ decision to truck more GDA products to 

Chicago, the economic conditions of the period, and the increasing attention to international 

security threats. By 2002 the number of lifts had rebounded and was higher (Table 2-1) than the 

low end of the forecast Mercer had made for 2000 (i.e., 335,000 lifts). Those Mercer forecasts 

had indicated the intermodal capacity of the GDA would be exceeded in 2000. 

Table 2-1 

2002 Lift Summary 

Terminala

 Lifts 

1 60,000 

2 55,000 

3 83,000 

4 77,000 

5 25,000 

6 48,000 

Total 348,000 a

 Terminals are those that served intermodal 

activity in 2002, exclusive of Mazda, which is not 

available for commercial use. Willow Run was 

not in intermodal service in 2002. CP/Expressway 

service was available at Michigan Central Depot 

in 2002 but was terminated in June 2004.

Source: The Corradino Group of Michigan, Inc. 

through cooperation of CSX, NS, CP and CN. 

Following the Mercer work, MDOT conducted a feasibility study in 2001. It concluded that 

doing nothing did not address the regional intermodal capacity demands on Southeast Michigan. 

It also determined that a build alternative could provide the future capacity needed, help address 

community issues in the vicinity of the Livernois-Junction Yard and form a partnership of 

railroads, community and government to create a sustainable environment. The feasibility study 

led to this Environmental Impact Study, which began early in 2002. 

As an early part of the environmental analysis, an inventory was conducted in 2002 of intermodal 

activity and capacity at each of the six terminals operating at that time. It ratified the earlier 

Mercer forecast and the feasibility study conclusion that the overall regional intermodal demand 

is at terminal capacity, while three of six terminals lacked adequate capacity. Subsequent 

information gathered for the DIFT project indicates the Norfolk Southern Railroad had realized a 

significant increase in its Triple Crown business to the extent it cannot be accommodated at its 

 

11 A lift is the transfer of a trailer or container to or from a rail car. 
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Melvindale terminal. NS requested MDOT’s financial assistance so that it can consolidate its 

Triple Crown intermodal trailer operations at the Livernois-Junction Yard, as it has done with its 

container operations. But, until the DIFT EIS is finalized and a Record of Decision executed, use 

of federal monies to provide such assistance is not available. So, NS reopened in 2004 its 

terminal at Willow Run in Romulus, Michigan to handle its Triple Crown business growth. If the 

DIFT were approved, and if appropriate improvements are made on a timely basis, NS might

shift all its Triple Crown operations in Michigan to the Livernois-Junction Yard. This would 

leave four intermodal Class I Railroad12 terminals serving Southeast Michigan. 

An assessment of the demand/capacity relationships at the three intermodal terminals that will 

serve the region in the future under the No Action Alternative is shown on Table 2-2. A range of

demand is provided based on varying growth rate forecasts. Table 2-2 also illustrates the 

maximum possible capacity as provided by the terminal operator. It is the most the terminal can 

handle with the densest use of the existing terminal space, i.e., stacking of containers/parking of 

trailers, and without additional property. These data indicate a lack of capacity at each yard and 

an overall deficit in the region from 80 percent to almost 120 percent by 2025 (Table 2-2). Note 

that Table 2-2 has been modified for this FEIS to reflect the fact that the CP/Expressway 

terminal has closed because Canadian Pacific has terminated its Expressway business entirely.

It is noteworthy that the growth associated with the No Action Alternative is forecast by use of a 

commodity flow model created specifically for the study of the Detroit Intermodal Freight 

Terminal (refer to Technical Report list at the end of Table of Contents). The model’s results 

were reviewed by the railroads affected by the DIFT. The intermodal terminal operators who 

responded indicated the high end of the lift range for the alternatives involving government 

investment (i.e., Alternatives 2, 3 and 4) are optimistic, but reasonably so, in light of the horizon 

being 2025. (The commodity flow model was rerun in April 2008 for 2030 with similar 

findings.) These consultations also indicated that, without government assistance, i.e., 

Alternative 1: No Action, the intermodal growth could be as low as about 470,000 lifts per year 

in 2025, compared to the model’s low side forecast of 571,000 lifts. This is because business 

could be shifted to terminals outside the region, for example CSX to Cleveland, NS to Toledo or 

Columbus and CP to Chicago. Nonetheless, even this lower forecast of future activity under No 

Action conditions cannot be handled without the railroads expanding existing terminals 

(Table 2-3). 

 

12 A Class I railroad does at least $250 million of business annually. 

Table 2-2 Revised for FEIS 

Demand vs. Capacity 

No Action Scenario

2025 Outlook of Lift Activity 

(Demand)c Terminala,b

Low High 

Lift 

Capacity 

Lift Deficiency 

W 363,900 455,500 150,000 213,900 to 305,500 

Y 137,200 171,700 95,000 42,200 to 76,700 

Z 70,000 75,000 75,000 -5,000 to 0 

Total 571,100 702,200 320,000 251,100 to 382,200 

 78% to 119% a

All Norfolk Southern intermodal activity is consolidated at Livernois-Junction Yard, so NS’ four terminals become one. b

Terminal’s owner/operator is not identified at the railroads’ request in light of proprietary interests. c

Detroit Intermodal Freight Terminal Project, “Commodity Flow Model Structure and Preliminary Results,” January 

2004 as adjusted to reflect elimination of the CP/Expressway operation and updated in April 2008 for 2030. 

Source: The Corradino Group of Michigan, Inc. 
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2.2.2 Intermodal Connectivity Needs 

Because freight transport is not just about terminal facilities but also about how the system 

operates, there is a need to provide a better interface between the public road system (primarily 

interstate freeways) and the terminals and between the rail lines themselves external to the 

intermodal terminals. There is a need to locate and coordinate services so they can best meet the 

needs of businesses, industries, and the U.S. military in Michigan and nationally. Individual 

private businesses, such as rail companies, are not expected to take sole responsibility for these 

system issues. Government has a role. The types of connections to be considered in addressing 

the need for better connectivity are (Figure 2-3): 

• Rail-to-Highway (I-75, I-96, I-94) 

• Rail-to-Rail (CN, CP, CSX, NS) 

• Rail-to-Cross-Border Connections 

− Bridges (Blue Water, Ambassador and possible new crossing) 

− Tunnels (Port Huron-Sarnia and Detroit-Windsor) 

The rail-to-highway issues, while specific to each alternative, affect connections to I-75, I-96, and 

I-94. For example, channeling trucks directly to I-96 at the CP/Oak terminal would ease traffic 

on local streets such as Artesian, Davison and Schoolcraft. Likewise, better connections between 

Livernois Avenue and I-94 would ease traffic on streets such as Central Avenue and 

Livernois/Dragoon Avenues south of the Livernois-Junction Yard. 

While it is important to ensure good cross-border connections, it is recognized that only one 

fourth of one percent of the freight tonnage crossing the border at Detroit is truck-related 

intermodal, so the effect of a new Ambassador Bridge span or the implementation of the DRIC 

project would have a negligible effect on the DIFT. 

As an example of the difficult rail-to-rail connectivity issues in the Detroit area, the June 2003 

Trains magazine reported: “...For railroads, Detroit is the proverbial bowl of spaghetti. Main lines 

entangle and intertwine in seemingly impossible combinations.” Nothing has changed since that 

article was published. 

It is noted that improvements to intermodal connectivity near the Livernois-Junction Yard will also 

benefit Amtrak passenger rail service. 

Table 2-3 Revised for FEIS 

Demand vs. Capacity 

Revised Low-end-of-Range Forecast

Terminala,b 2025 Revised Low-end 

Lift Forecast Lift Capacity Low-end-of-Range Lift Deficiency 

W 289,000 150,000 139,000 

Y 110,000 95,000 15,000 

Z 70,000 75,000 -5,000 

Total 469,000 320,000 149,000 

 47% a

All Norfolk Southern intermodal activity is consolidated at Livernois-Junction Yard, so NS’ four 

terminals become one. 

b

Terminal’s owner/operator is not identified at the railroads’ request in light of proprietary interests.

Source: The Corradino Group of Michigan, Inc.
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Railroad capacity is determined through a combination of allowable train speed, length of trains, 

route conflicts (delays), signaling and track switching operations. In Detroit, a number of these 

issues are causing problems for the approximately 80 trains per day that operate through the 

Southwest Detroit area. 

• Train Speeds. Due to the layout and the historical development of the routes in the 

Detroit area, train speeds are restricted at many of the junctions because of the curves in 

the tracks, track conditions, inadequate signaling or railroad operating rules. Trains 

operating at 10 mph occupy track junctions 2.5 times longer than trains operating at 25 

mph. 

 Examples: 

− The Milwaukee Junction and Bay City Junction interlockers (refer to Figure 3-15 for 

interlocker locations) have severe curves restricting speeds to just 10 mph. 

− Delray’s interlocker does not have adequate signaling equipment, so trains must 

operate at less than 20 mph. 

Because of speed restrictions, Norfolk Southern trains traveling from Livernois-Junction Yard to 

the River Rouge Bridge are scheduled to take 30 minutes, even though it is approximately three 

miles away. Trains occupying these segments of track for this long – whether they are departing, 

waiting or arriving – reduce the available track time for other trains, which must park and wait. 

• Length of Trains. For many years, the standard rail car was 40 feet long and a typical 

train with 100 cars was about 4,000 feet long. Today, many rail cars are 90 feet long 

with some reaching 250 feet. Train length can easily reach 9,000 feet. 

 Examples: 

− If a train longer than 4,000 feet is stopped between West Detroit interlocker and 

Delray interlocker it will block tracks at Dix and Waterman, stopping other trains 

trying to get into the Livernois-Junction Yard as well as through the corridor. 

− A train moving to the NS/Oakwood Yard could have tracks blocked affecting 

movement to and from Delray, River Rouge and Ecorse. 

• Route Conflicts. Because of the way some track connections are laid out, trains 

sometimes block other trains. 

 Examples: 

− Amtrak passenger trains currently travel west from the Milwaukee Junction 

interlocker to Livernois-Junction Yard. While making this trip, they stop all 

movements on three of the four tracks causing conflicts at Milwaukee Junction 

interlocker. The Amtrak trains cause conflicts again at Beaubien Junction, stopping 

the movement on three of the four tracks there. They then have to cross over the 

Vinewood interlocker, stopping movement on all but one track. Finally, they cross at 

the West Detroit interlocker, stopping all movement on the CN and NS mainline 

track.13

− Every time a CP train travels through the Delray interlocker, all NS and CN trains 

must stop moving until the CP train has cleared the yard. 

• Signaling. In the area around Livernois-Junction Yard, several different signaling 

situations cause major impacts on train operations. 

 

13 Note: An independent Amtrak project may address this issue. 
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Examples: 

− The Delray interlocker is operated by CSX, while the River Rouge Bridge, less than 

half a mile southwest, is operated by NS. The track in between has signals in only 

one direction. This requires continual coordination among railroads for every train 

movement. 

− Because there are signals in only one direction, trains must operate at restricted 

speeds. 

− Signal spacing governs the speed at which trains can operate. Trains leaving and 

entering areas with signals around the Livernois-Junction Yard generally must 

operate at only 10 mph. 

− In several locations, more than one train operator is needed to make a single 

movement. This happens when one railroad has control over one switch while 

another has control of a second switch, and both are needed for a train to move 

through an area. This occurs at Vinewood, where Conrail has control of one switch 

and CN has control over the other switch. This also occurs at the CP Lou, Coolidge 

and Milwaukee Junction interlockers. 

• Switching Operations. At several locations in the area, railroads must use the mainline 

tracks to switch rail cars around while “building” a train. 

 Examples: 

− At the southeast end of Livernois-Junction Yard, rail cars being switched take up 

three of the four available tracks that mainline trains could be using to pass through. 

− This also occurs at the east end of Livernois-Junction Yard, and at the Milwaukee 

Junction and Ecorse interlockers. At all of these locations, switching rail cars 

impacts movement within the yard or on the mainline. 

In all cases cited above, any increase in the number of trains or the amount of switching required 

will make the existing problems worse. Addressing these rail connection problems would 

improve the efficiency of the yards, increase the productivity of freight trains, improve travel 

times for Amtrak passenger trains, and reduce costs, pollution and noise. 

2.3 Government Involvement 

A commitment to study improving intermodal transportation in Southeast Michigan was initiated 

in 1993 by MDOT. In 1998, study of Detroit Intermodal Freight Terminal was listed as a High 

Priority Project within the federal transportation bill known as the Transportation Equity Act of 

the 21st Century, or TEA-21. TEA-21 provided $18 million in federal funding assistance for the 

project (TEA-21, Section 1602, High Priority Project 1221). 

2.4 Summary

The Michigan Department of Transportation is engaged in the DIFT 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) by supporting an 

increase in intermodal capacity and connectivity. This, in turn, will support mobility and 

maintenance of the Michigan and national economies and national defense and promote a high 

quality of life for the region’s citizens including the following, if improvements are made to the 

intermodal system under one of the Action Alternatives: 
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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 

through job creation, and an increasing the tax base. 

• 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 

addressed. 

• Buffering the intermodal facility from nearby neighborhoods through improvements that 

reduce noise and use trees, vegetation and other enhancements to improve the terminal’s 

exterior appearance. 

The project is needed to handle the increasing intermodal volumes, which grew from 283,000 lifts 

in 1992 to 348,000 lifts in 2002 (down from a high of about 400,000 in 1998 largely due to 

economic and security risk conditions). It is estimated the current lift volume is 383,000. The 

capacity of the existing intermodal terminals in the region is about 320,000 annual lifts. The 

forecast demand for 2025, if normal trends occur, would range from about 470,000 to 700,000 

annual lifts. 
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SECTION 3 

ALTERNATIVES 

A Preferred Alternative has now been identified. The decision on the Preferred Alternative 

was made after the public hearing and comment period that followed, consideration of all 

comments and engagement of the four affected railroads. Bold, italicized text in a green box 

such as this shows changes for this FEIS. 

This section describes how the alternatives were developed from the purpose and need as stated 

in the Notice of Intent14 (NOI), through the consideration of many regional sites (see Section 

3.2.2) including “greenfield” sites, and consideration of an alternative proposed by a local 

organization, to a set of Practical Alternatives that have been analyzed in this EIS. 

3.1 Alternatives Development

The purpose of an EIS is to present alternatives, disclose impacts related to the alternatives and 

serve as a decision-making document in order to select an alternative that addresses the project’s 

need and best meets the goal of the project, while considering the impacts. The goal of the DIFT 

is to develop a regional facility or facilities with enough capacity to handle current and future 

intermodal freight shipments needed by business, industry and the U.S. military and to provide 

efficient interconnectivity of intermodal operations to reduce time, monetary costs, and 

congestion to support the economic competitiveness of Southeastern Michigan and the nation. 

This report also identifies impacts and benefits of all Practical Alternatives. Where negative 

impacts are identified, ways to avoid, minimize or mitigate them are examined and applied, as 

appropriate. 

From the passage of TEA-21 in 1998 (Public Law 105-178, Section 1602, High Priority Project 

[HPP] 1221) until the fall of 2002, federal and state efforts on the DIFT project were directed at a 

single intermodal terminal in Southwest Detroit, Wayne County at the Livernois-Junction Yard. 

In March 2002, the federal Notice of Intent was published to advise the public that an 

Environmental Impact Statement (EIS) would be prepared. It listed one alternative to taking no 

action, i.e., “refinements to Rail Strategy 3,” as identified in the Detroit Intermodal Freight 

Terminal Project Feasibility Study, Technical Report No. 4, i.e., consolidation of regional 

intermodal operations at the Livernois-Junction Yard. In the latter part of 2002, the Federal 

Highway Administration, following a resource agency scoping meeting held on September 19, 

2002, issued the following position: 

“The overall goal of the DIFT is to enhance intermodal operations and 

economic competitiveness of SE Michigan. In fulfilling this goal, we 

(FHWA) believe treating the RRs with equity is sound public policy. This 

policy does not [emphasis added] define the starting point, rather it places 

a condition on the outcome, similar, for example, to assuring that air 

quality standards will be met. In our (FHWA) view this policy does not 

pre-limit [emphasis added] the EIS to investigating only a single solution. 

The EIS must consider a range of practical alternatives. Ultimately, the 

EIS process will result in a preferred alternative and the EIS must clearly 

articulate the basis for the preferred alternative.” 

 

14 A Notice of Intent is the formal announcement in the Federal Register that a study is underway and that an 

Environmental Impact Statement will be developed. The NOI was published in the Federal Register on March 13, 

2002. A revised NOI was published in the Federal Register March 21, 2003. 
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Subsequently, the approach to alternatives was updated. The revised Notice of Intent was issued 

in March 2003. Since then, the project has evolved, with public involvement, to include the 

following: 

Alternative 1 No Action: This alternative assumed the railroads would develop their existing 

intermodal rail yards in Southeast Michigan without federal and state government 

funding assistance and oversight. 

Alternative 2 Improve/Expand: This alternative proposed improvements to four existing 

intermodal rail terminals (at Livernois-Junction Yard, CP/Expressway, CP/Oak and 

CN/Moterm) operated by the four Class I railroads in Southeast Michigan with 

railroad funding, as well as federal and state governments funding assistance and 

oversight. This alternative includes improvements inside and outside the existing 

railroad terminal property. 

Alternative 3 Consolidate: This alternative proposed the intermodal operations of all four 

Class 1 railroads be consolidated at the Livernois-Junction Yard area. Railroad 

funding, plus federal and state governments funding assistance and oversight are 

to be involved in making improvements inside and outside the existing yard. The 

existing terminals from which intermodal business would be transferred would 

continue to serve other railroad business. 

Alternative 4 The Composite Option: This alternative proposed the intermodal operations of 

three railroads (CSX, Norfolk Southern and Canadian Pacific) be consolidated at the 

site of the Livernois-Junction Yard in southwest Detroit, while improving/expanding 

the existing CN/Moterm terminal, with federal and state funding assistance and 

oversight for improvements inside and outside the terminals. The railroads were also 

to invest in these improvements. The existing terminals from which intermodal 

business would be transferred would continue to serve other railroad business. 

It is important to recognize that “external-to-terminal” improvements, such as the rail 

connections/interfaces at Delray, West Detroit, Milwaukee Junction, Vinewood and other 

interlockers, are part of Alternatives 2, 3 and 4 (see Figure 3-15). These are to be accomplished 

on existing railroad property.15 All Action Alternatives also include improving the north side of 

the I-94/Livernois Avenue interchange to facilitate truck movements to the Livernois-Junction 

Yard and keep them out of the neighborhood north of the yard. 

3.2 Alternatives Eliminated from Further Study

All reasonable and Practical Alternatives were carried forward for detailed study. Alternatives, 

which clearly did not address the project purpose and need were eliminated from future 

consideration. The latter alternatives are described below. 

3.2.1 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 intermodal activity at the smaller Norfolk Southern terminal at Oakwood was 

shifted/consolidated at the Livernois-Junction Yard in 2003. This location, and others in the region 

like at Highland Park, do not lend themselves to productive intermodal operations. Nonetheless, an 

 

15 Minor right-of-way might be required at the West Detroit interlocker, though this may be achieved through a 

separate Amtrak project. 
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existing terminal like Norfolk Southern’s terminals at Melvindale and Willow Run may be used for 

some time into the future, if adequate capacity is not available for consolidation 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 Report16 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 also not a viable option for CSX, NS and CP or for consolidation of the intermodal activity of 

all four railroads for the above-stated reasons, plus: 

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. 

The Port of Detroit has also been suggested as 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 

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 practical option for consolidation because extensive trackage rights would be required 

for CP and CN to use the port. 

 

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

Consulting, August 1994. 
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3.2.2 Greenfield Site 

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 development. But the rail infrastructure is not 

available for access by multiple railroads. The same can be said of abandoned properties known 

as “brownfield” sites. 

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

that they would be serving. This fragmentation 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. Finally, “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 Livernois-Junction 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. The earlier MDOT studies found that the Willow Run site was far from its 

market with high pickup and delivery costs. Nonetheless, because of the Triple Crown business 

growth, NS has had to reopen 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 and a Build Alternative approved. 

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. 

3.2.3 Communities for a Better Rail 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 in 2025. 

Nonetheless, the basic CBRA concept of improving, without expanding the boundaries of the 

Livernois-Junction Yard and improving its physical relation with the surrounding community is 

closely, but not completely, aligned with the proposal for that terminal under Alternative 2. 
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3.3 Project Status 

A Preferred Alternative has been identified in consultation with the railroads, and after the DEIS 

publication, public hearing and consideration of comments received from the public and agencies. 

The comment period was from May 13, 2005, to August 16, 2005. MDOT provided an 

extended comment period to respect requests from Congressional and local interests for a 

90-day review period. Subsequently, consultation continued among government agencies and 

stakeholders to work out details of ownership, operation and mitigation. The project was added 

to SEMCOG’s Regional Transportation Plan in November 2008. 

3.4 Practical Alternatives 

The Practical Alternatives analyzed in the DEIS were those defined at the outset of this section 

and identified as follows: 

• Alternative 1 – No Action 

• Alternative 2 – Improve/Expand Existing Terminals 

• Alternative 3 – Consolidate All Four Class I Railroads’ Intermodal Activity at the 

Livernois-Junction Yard Area 

• Alternative 4 – The Composite Option, or a combination of Alternatives 2 and 3. 

3.4.1 Characteristics of Proposed Intermodal Terminals 

The following information is provided to understand how the terminals shown on Figure 3-1 

would operate. Their general characteristics were summarized in Table 1-1. 

Livernois-Junction Yard 

CSX and Norfolk Southern jointly control the 300-acre Livernois-Junction Yard. The yard was 

improved in 2004-2005 through a project of independent utility with a $10 million public 

(MDOT)/private (CSX/NS) investment. Meanwhile, NS’s Triple Crown business has outgrown 

its Melvindale terminal. So, NS reopened its Willow Run terminal in 2004. NS has indicated it 

prefers to consolidate all its intermodal business at the Livernois-Junction Yard, provided 

adequate facilities can be developed. NS has asked MDOT for financial assistance in 

accomplishing that objective. None can be provided unless and until the environmental review of 

the proposed DIFT is complete and a Build Alternative approved. 

Under Alternative 1 – No Action, the Livernois-Junction Yard is to continue to operate with two 

gates – one at Livernois Avenue, between John Kronk Street and Toledo Avenue, and a second 

near the intersection of Dix/Waterman/Vernor (Figure 3-2). Trucks now use a variety of paths to 

reach these gates, including streets like Dragoon, Livernois and Vernor. Other local streets, such 

as Waterman, Dix and Springwells are impacted by intermodal trucks. Additionally, a host of 

industrial activities, (e.g., the trucking center at the northwest corner of John Kronk Street and 

Central Avenue), will likely continue to operate/grow causing streets like Central Avenue to 

experience an increase in large-truck traffic. 
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Figure 3-2 

Existing Livernois-Junction Yard Access
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Under Alternative 2 – Improve/Expand Existing Terminals, the Livernois-Junction Yard 

is to still be served by the Livernois Avenue entrance. Three options were considered: 

• Under Option A, the Dix/Waterman/Vernor gate is to remain (Figure 3-3). There would 

be no displacements of residential properties but eight business relocations on 10 to 11 

acres. 

• Under Option B, the Dix/Waterman/Vernor gate would be eliminated by developing a 

western gate (Figure 3-4) served by Wyoming Avenue. Eleven businesses would be 

relocated but no residential properties. Acquisition would be 29.5 acres. 

• Under Option C, the Dix/Waterman/Vernor gate would be eliminated by focusing all 

traffic at the Livernois Avenue gate, with a tunnel (14’-9” clearance) in the yard to allow 

trucks to move under the rail lines to access both sides of the terminal without crossing 

the rail lines at grade (Figure 3-5). Eight businesses would be relocated but no residential 

units. Acquisition would be 10 to 11 acres. 

Under DIFT Alternative 2, for all options, Lonyo Avenue would be closed at the rail yard 

boundary. Traffic would be channeled by way of a relocated John Kronk Street to Central 

Avenue (see Figure 3-3). Central would pass under the railroad tracks (Figures 3-3 through 3-5). 

Businesses supporting the terminal’s intermodal growth would likely have been drawn to the area 

near the terminal. There are hundreds of acres of brownfield and other vacant/abandoned 

properties in the vicinity of the terminal (known as the “terminal area,” which is elaborated on in 

Section 3.4.2 of this FEIS) to accommodate such development. Under this alternative, the 

Livernois-Junction Yard would be paved and a wall for terminal security provided along the 

entire north side of the terminal and on the south side, east of Central Avenue. These latter two 

elements are integral parts of the proposed alternative. 

Under Alternative 3 – Consolidation, the Livernois-Junction Yard is to accommodate all Class I 

railroads’ intermodal operations in Southeast Michigan. The terminal would be served by five 

gates (Figure 3-6). Alternative 3, like Alternative 2, would see Lonyo Avenue closed and Central 

Avenue pass under the railroad tracks. Because this alternative would remove John Kronk as a 

city street, a perimeter road on the terminal’s north side would be constructed to include a 

landscaped buffer. It would allow travel between Livernois and Wyoming Avenues. Alternative 

3 would require acquisition of approximately 384 acres and relocation of 64 businesses and 83 

residential units. This acquisition would cause diversion to other locations in the terminal area of 

more than 4,000 trips per day. So, while the expanded intermodal activity under Alternative 3 

was to generate about 5,000 daily truck trips (two-way) in 2025 (which is approximately 3,500 

more daily truck trips (two-way) expected at the terminal than the No Action Alternative), there 

was to be an offsetting relocation of trips from the area immediately surrounding the terminal to 

the broader terminal area. Furthermore, access to the terminal’s gates would be a combination of 

interstate-to-major arterial connectors (i.e., I-75/I-94 to Wyoming/Livernois17 Avenues) thereby 

directing intermodal trucks away from the neighborhoods. Businesses supporting the terminal’s 

intermodal growth would likely be drawn to the area near the terminal. Under this alternative, the 

Livernois-Junction Yard would be paved and a wall for terminal security would be provided 

along the entire north side of the terminal and on the south side east of Central Avenue. These 

latter two elements are integral parts of the proposed alternative. 

 

17 The Livernois Avenue entrance would be configured so trucks must enter from or exit to the north. 
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Alternative 4 – Composite of Alternatives 2 and 3 is similar to Alternative 3, except Canadian 

National Railroad would remain at an expanded/improved Moterm facility and its intermodal 

business would not be consolidated at the area of the Livernois-Junction Yard. This would 

reduce the number of gates there to four, compared to five for Alternative 3 (Figure 3-7). The 

potential acquisition of 265 acres at the Livernois-Junction Yard area (119 fewer than Alternative 

3) would involve acquisition of 51 businesses and 33 residential units. This acquisition would 

have caused the relocation of more than 3,600 trips per day. The number of daily, two-way 

intermodal truck trips in 2025 would be close to 4,600. So, the net “new” trips would be 1,000. 

The access routes to these gates via the interstate highway system, in combination with Wyoming 

and Livernois Avenues, would be the same as Alternative 3. Lonyo Avenue would be closed at 

the terminal boundary. Its traffic would be channeled via a new perimeter road to connect with 

Central Avenue to pass under the railroad tracks. The perimeter road and buffer would be built 

on the north side of the terminal to connect Livernois and Wyoming Avenue. Businesses 

supporting the terminal’s intermodal growth would likely have been drawn to the area near the 

terminal. Under this alternative, the Livernois-Junction Yard would be paved and a wall for 

terminal security provided along the entire north side of the terminal and on the south side, east of 

Central Avenue. A security wall would also be placed on the east side of the CN/Moterm 

terminal. These elements are integral parts of the proposed alternative. 

CP/Expressway Terminal 

The CP/Expressway terminal was open when the Practical Alternatives were developed, but was 

closed in June 2004. The CP/Expressway terminal under the Alternative 1 - No Action in 2025 

was expected to handle about 140 daily two-way truck trips using city streets (Figure 3-8). Under 

Alternative 2 - Improve/Expand, the truck trips were expected to grow to 250 also using city 

streets (Figure 3-9). Expanding the terminal would require the acquisition of 12 acres, including 

one institutional property and no residences. Businesses supporting the terminal’s intermodal 

growth would likely have been drawn to the area near the terminal. It is noteworthy that 

expansion of this terminal would have been precluded if the Jobs Tunnel proposed at that time by 

the Detroit River Tunnel Partnership (DTRP) were to become a reality, because there was not 

enough space to handle both projects. The DRTP project proposed to convert two existing rail 

tunnels connecting Detroit and Windsor to truck use and build a third, more modern, tunnel for 

rail. Proponents have withdrawn their proposal for truck tunnels, but continue planning for a new 

rail tunnel. 

Under Alternatives 3 and 4, CP/Expressway’s business (trailers) would be consolidated at the 

Livernois-Junction Yard area (refer to Figures 3-6 and 3-7). 

CP/Oak Terminal 

Under Alternative 1 – No Action, Canadian Pacific Railway (CP) would continue to operate on 

approximately 24 acres leased from CSX to conduct its intermodal container business at the 

CP/Oak terminal (Figure 3-10). Truck traffic would grow from 280 trips (two-way) to almost 

400 trips (two-way) by 2025 under No Action, Alternative 1. 
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Figure 3-8 

Former CP/Expressway Terminal Access 
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Figure 3-10 

Existing CP/Oak Terminal Access 
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Under Alternative 2 – Improve/Expand Existing Terminals, expanding the CP/Oak terminal 

would grow the two-way, daily truck volume to about 700. Today, trucks access that yard 

through one gate and exit at two locations. These trucks use the Southfield Freeway service drive 

plus local streets like Glendale, Davison, and Artesian to travel to/from this facility. There were 

two options for this terminal under Alternative 2 (Figure 3-11 and 3-12), differing only in the 

connection between the improved interchange at I-96/Evergreen Road and the expanded terminal. 

By virtue of the improved access, intermodal truck traffic affecting the surrounding 

neighborhood, including numerous residential properties located along the Southfield Freeway 

service drive, would be virtually eliminated and the now-existing gates closed. Expanding the 

terminal would require acquisition of five businesses for Option A and six for Option B. The 

truck traffic associated with these businesses would be relocated elsewhere. No residential 

property was to be acquired. The expanded terminal was to be about 60 acres larger than today. 

Businesses supporting the terminal’s intermodal growth would be drawn to the area near the 

terminal. Under this alternative, a wall for terminal security would be provided on the north side 

of the terminal as an integral part of this proposed alternative. 

Under Alternatives 3 and 4, CP/Oak’s business (containers) would be consolidated at the 

Livernois-Junction Yard area (refer to Figures 3-6 and 3-7). 

CN/Moterm Terminal 

Grand Trunk Western Railroad, now Canadian National (CN), has for many years operated the 

29-acre terminal in Ferndale north of Eight Mile Road. Trucks access/egress the terminal by way 

of Fair and Chesterfield Streets north of Eight Mile Road. Late in the 1990s, the intermodal 

business there was roughly double what it is today. At that time, CN leased five to 10 acres of 

State Fairgrounds property for container storage (south of Eight Mile Road). When a major 

shipping contract ended, CN ceased its use of the Fairgrounds property. 

Under Alternative 1, the CN/Moterm terminal would continue on the existing 29-acre site (Figure 

3-13). The number of daily two-way truck trips in 2025 was expected to be 370. 

In developing the proposal for Alternatives 2 and 4 to re-enter the Fairgrounds for expansion of 

the CN/Moterm terminal, options to the east and west of the terminal, and north of Eight Mile 

Road, were examined, but were not considered reasonable. 

• Going west would require penetration of a dense residential area. Sixty single-family 

houses would be acquired, as well as seven businesses. Fair Park would also be taken by 

expansion of the terminal to the west. 

• Expanding the terminal to the east, north of Eight Mile Road, would cause displacement 

of 10 businesses that, combined, are responsible for a major portion of the tax base of the 

City of Ferndale. Because of the limited amount of industrial redevelopment property in 

the city, these businesses would likely be lost to other areas. Additionally, Gage Products 

Company would be displaced by expanding the CN/Moterm terminal to the east. This 

company is a permitted storer of up to one million gallons of hazardous material. It is 

Ferndale’s largest taxpayer. It is not possible to relocate it in Ferndale because of its 

handling of hazardous material. 

• Expanding the terminal to the east, south of Eight Mile Road, would cause the 

displacement of 90 single-family residences and seven businesses. Hunt Playground 

(about six acres) would also be removed. 
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Figure 3-13 

Existing CN/Moterm Terminal Access 
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So, the proposed expansion of the Moterm terminal avoided going east or west of the terminal, 

north of Eight Mile Road. It avoided going east of the existing tracks south of Eight Mile Road. 

Expansion was proposed due south into the State Fairgrounds on approximately 35 acres (Figure 

3-13 and Figure 4-10d). Access would be directly from Eight Mile Road south into the terminal. 

A survey of the terminal’s intermodal activity indicated that virtually all intermodal trucks use 

I-75 and M-102 (Eight Mile Road) to access the terminal. That is expected to be the pattern of 

the future. A wall for terminal security was to be provided on the east side of the terminal as an 

integral part of this proposed alternative. 

It is noted that use of the Fairgrounds as depicted on Figure 3-13 would cause no residential or 

business relocations. It would have created a 4(f) recreational resource impact and wetland 

impact, discussed in more detail in Sections 4.14 and 5.13, respectively. 

Under Alternatives 2 and 4, the number of intermodal trucks serving the Moterm terminal on an 

average day in 2025 was expected to be 650 compared to 370 under Alternative 1 – No Action. 

Businesses supporting the terminal’s intermodal growth would likely have been drawn to the area 

near the terminal (Figure 3-14). A wall for terminal security was to be provided on the east side 

of the terminal as an integral part of the proposed alternative. 

Under Alternative 3, Canadian National’s intermodal operation would be shifted to the LivernoisJunction Yard area (refer to Figure 3-6). 

Continued Use of CP/Oak, CN/Moterm and CP/Expressway 

Under Alternatives 3 and 4, where intermodal operations of either three or four railroads were 

proposed to consolidate at the Livernois-Junction Yard, the terminals at CP/Oak and CN/Moterm 

would continue to be used by the railroads for shipping freight by means other than intermodal. 

That activity was assumed to be associated with a much smaller volume of truck traffic than if the 

terminal were to continue to serve intermodal. Shifting intermodal activity from the 

CP/Expressway terminal to the Livernois-Junction Yard area under Alternatives 3 and 4 would 

allow the Expressway terminal area to be transitioned to other uses (but in any case, the 

Expressway operation is now closed). 
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Rail Network Improvements 

The rail network in the Greater Detroit Area has a number of correctable shortcomings that would 

increase the efficiency of train movements. These are switches, interlockers,18 and track 

modifications that will positively affect intermodal train speed and lessen route conflicts and, as a 

result, enhance the region’s rail system interconnectivity. This is consistent with the project 

purpose as stated in Section 2.1. None of these proposals would involve any right-of-way 

acquisition. All would occur on existing railroad-owned property except for a possible minor 

acquisition associated with the West Detroit interlocker.19 No environmental impacts are 

anticipated with these improvements. 

Figure 3-15 shows the major interlockers in the Detroit area. Those affected by the Practical 

Alternatives are listed in Table 3-1. Continuing discussions with the railroads have led to a 

revised list for the Preferred Alternative (see Section 3.5). Those are highlighted in yellow. 

Table 3-1 

Railroad Interlockers and Track Locations Affected by Alternatives 

Alternative Railroad Interlocker 2 3 4 

2. Beaubien 9 9 9

4. Delray 9 9 9

5. Dix 9 9 9

7. Lou 9 9 9

9. Milwaukee Junction NC 9 NC 

12. P Company 9 9 9

14. Townline 9 9 9

17. Vinewood 9 9 9

18. Waterman 9 9 9

19. West Detroit 9 9 9

NC – No Change 

Source: Alfred Benesch & Company

 

3.4.2 Terminal Areas 

Each intermodal terminal has a “zone of influence” known as a terminal area. The definition of 

each terminal area reflects the neighborhood/community relationships to the terminal and the 

transportation facilities serving them. In defining each terminal area associated with 

transportation/land use interaction, aerial photography since the mid-1930s was examined to assess 

the extent to which transportation and land developments have occurred over the last 70 years. The 

definition of each terminal area was also established by examining community facilities and services. 

Livernois-Junction Yard and CP/Expressway Terminal Area 

The terminal area that encompasses the Livernois-Junction Yard and the CP/Expressway terminal 

is shown on Figure 3-16. It lies in the cities of Detroit and Dearborn. Railroad facilities and 

activities have been dominant in this area since 1850. 

 

18 Interlockers are locations where trains must stop for one another. Interlockers are controlled by signals. 

19 A survey is required to determine property lines and a separate Amtrak project may partly address this issue. 
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About 80 train movements occur daily at some point within the area, with fewer than half being 

continuous, through movements. International border crossings at the Ambassador Bridge, the 

Detroit-Windsor Tunnel, and the Detroit-Canada Rail Tunnel serve the area. A portion of the 

geographical area known as the Port of Detroit is within the project area. And, Greater Detroit’s 

airports are directly connected to the project area by the freeway system. 

The Fisher Freeway (I-75) cuts through the terminal area. It is a major north-south interstate 

highway that connects Sault Ste. Marie to the north, in Michigan’s Upper Peninsula, to Miami, 

Florida. I-75 is a major economic corridor that is critical to Michigan’s and the nation’s 

economy. 

The Edsel Ford Freeway (I-94) also traverses the terminal area. It is a primary east-west 

connector linking Canada through Port Huron, Michigan, to Chicago and points west. I-94 also 

links four regional airports in Southeast Michigan. I-96 (Jeffries Freeway) originates at the 

Ambassador Bridge where it intersects with I-75 and I-94. It runs west through Lansing, 

Michigan, and Grand Rapids before terminating near Muskegon, Michigan. 

The Detroit Department of Transportation (DDOT) operates a number of bus routes on Michigan, 

Dix, Livernois and Wyoming Avenues. Suburban Mobility Authority for Regional Transit 

(SMART) operates a route on Michigan Avenue. 

CP/Oak Terminal Area 

CP/Oak is located entirely in the City of Detroit (Figure 3-17). A rail line has occupied the 

current location of CP/Oak since 1871 when the Detroit, Lansing and Lake Michigan Railroad 

completed its east-west routing through the site. Existing rail activity in the proposed terminal 

area includes intermodal and conventional rail freight operations of Canadian Pacific Railway on 

land leased from CSX. Land uses in the study area are a blend of industrial, commercial, and 

residential. 

This terminal area’s primary north/south highway route is the Southfield Freeway (M-39) 

connecting with I-75, I-94, Michigan Avenue (U.S. 12), I-96, and the Lodge Freeway (M-10). 

Primary exits along the Southfield Freeway that serve the area include I-96 (exit 11), Joy Road 

(exit 9), and Grand River Avenue (exit 13). The main east/west route is I-96, which originates at 

the Ambassador Bridge where it intersects with I-75 and I-94. It runs west through Lansing and 

Grand Rapids before terminating at U.S. 31 near Muskegon on the western side of Michigan. 

Primary exits along I-96 that serve the area include Evergreen Road (exit 182) and the Southfield 

Freeway (exit 183). SMART and DDOT both provide bus service in the area. SMART serves 

the area with park-and-ride-routes connecting Livonia and Farmington to downtown Detroit and 

routes along Plymouth and Schoolcraft. DDOT provides bus service to the area through its 

Plymouth, Schoolcraft, Evergreen and Southfield routes. 

CN/Moterm Terminal Area 

The terminal area around CN/Moterm is bounded by I-696 on the north, Seven Mile Road on the 

south, Dequindre Avenue on the east, and Schaefer Road on the west (Figure 3-18). 

Approximately two-thirds of the area is in Wayne County with the balance in Oakland County. 

Land uses in the study area are a blend of industrial, commercial, and residential. The Michigan 

State Fairgrounds is located to the south of the terminal. 
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The CN/Moterm area has direct access to two interstates – I-696 running east/west and I-75 

running north/south. Primary exits along I-696 that serve the area include Schaefer Highway 

(exit 14), Woodward Avenue (exit 16), and I-75 (exit 18). Primary exits along I-75 that serve the 

area include Nine Mile Road (exit 60), Eight Mile Road (exit 59), and Six Mile Road (exit 57). 

The area is also served by M-1 (Woodward Avenue), linking downtown Detroit with Pontiac and 

M-102 (Eight Mile Road). 

Several public transportation routes serve the area. SMART provides bus service to the area with 

its Woodward and John R routes as well as east/west routes along Eight Mile and Nine Mile 

Roads. DDOT maintains bus routes along Woodward, Eight Mile Road, and Seven Mile Road. 

3.5 Preferred Alternative 

Review of public and agencies’ comments after the public hearing, plus consultation with the 

railroads, led to the formulation of the Preferred Alternative. 

The purpose of the project is to support the economic competitiveness of southeastern 

Michigan and the state by improving freight transportation opportunities and efficiencies. The 

intent was for the public sector to afford the first class railroads operating in southeastern 

Michigan the opportunity to participate. It was recognized that much of the growth in freight 

transportation would come in the form of intermodal container use. So, the participation of 

the railroads is essential to the project. The development of the alternatives represented a way 

to test how the public sector could support the private railroads in an equitable way. The 

railroads meanwhile discussed internally their business plans and needs. Some railroads had 

the need for expanded capacity, others, in the end determined they did not. All saw advantages 

to the various external rail improvements. This process of consultation leading to the 

Preferred Alternative was evolutionary. For example, during the course of the study, the CP 

Expressway operation at the Michigan Central Depot went out of business. The Preferred 

Alternative represents the culmination of the process and is codified in the railroad’s 

agreement to the outcome in the signed Pre-Development Plan Agreement (Appendix F). 

From the public point of view, the process allowed planning for intermodal growth to be done 

consistent with community needs. Area roadway improvements and paving, buffers around the 

Livernois-Junction Yard, and addressing poorly working viaducts under railroad lines that 

leave the yard were addressed in the comprehensive process that led to the Preferred 

Alternative. Conclusions reached as a result of this consultation process are: 

• The No Action Alternative does not meet the project purpose and need. 

• CSX, NS and CP desire to be at the Livernois-Junction Yard. Therefore, Alternative 2, 

which would have had each railroad expand its current location, is not consistent with 

the desires of CP. Because the project is designed to afford an opportunity for all Class 

I railroads to participate, and moving to the Livernois-Junction Yard is the way that 

CP desires to participate, Alternative 2 cannot be the Preferred Alternative. 

• Because CN desires to remain at its Moterm Terminal, Alternative 3, which would 

consolidate all railroads at the Livernois-Junction Yard cannot be the Preferred 

Alternative. 

• Alternative 4 was designed to bring CSX, NS, and CP together at the LivernoisJunction Yard and have CN expand at Moterm. But that expansion of Moterm was not 

desired by CN and, if expansion had occurred, it would have been into the Michigan 

State Fairgrounds. 

The Preferred Alternative (Figure 3-19) is a variation of Alternative 4 that will consolidate 

intermodal operations of CSX, NS, and CP railroads in Southwest Detroit at the LivernoisJunction Yard. The CP/Oak terminal will continue to be used for non-intermodal purposes. 
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Canadian Pacific’s Expressway (trailer loading) operation at the Michigan Central Depot has 

terminated. The Canadian National Railroad will not shift its Moterm operations to the 

Livernois-Junction Yard and not expand its terminal. But, it, like the other railroads, will 

participate in paying its share of external-to-terminal rail improvements that are part of the 

DIFT project. Such improvements by the DIFT project will increase the efficiency of 

operations of all the railroads. The agreement on the Preferred Alternative is memorialized in 

the signed Pre-Development Plan Agreement in Appendix F. Road improvements will also be 

made, as discussed below. 

In summary, the Preferred Alternative will: 

• Expand the NS and CSX intermodal operations at the Livernois-Junction Yard; 

• Provide the opportunity to shift the NS Triple Crown operations from Melvindale and 

Willow Run in Romulus to the Livernois-Junction Yard; and 

• Move the CP Oak intermodal operation to the Livernois-Junction Yard. 

All four Class I railroads will participate in an external rail improvement program at the 

following locations (Figure 3-15): 

• Beaubien 

• Coolidge 

• Delray 

• Dix 

• Mill 

• Milwaukee Junction 

• Oakwood Junction 

• Schaefer 

• Trenton 

• Vinewood 

• Waterman 

• West Detroit 

• New Rotunda 

• Track from Delray to Dix 

• Track from Oakwood to Schaefer 

Several road improvements will be made to facilitate access to the Livernois-Junction Yard: 

• Modifying the I-94/Livernois interchange on its north side so that trucks will use this 

interchange (one curve is now too tight for efficient use) and Livernois Avenue, rather 

than other roads that pass through areas that are predominantly residential; 

• Closing the Waterman/Dix entrance to the Livernois-Junction Yard and modifying the 

Livernois entrance so that trucks access the yard from I-94 only; 

• Closing Lonyo Avenue and rebuilding Central Avenue under the Livernois-Junction 

Yard so that railroad operations do not conflict with the movements of cars and trucks 

that now pass across the yard; 

• Providing two new access points to the yard from the west off Wyoming Avenue. The 

most southerly is approximately 1,000 feet south of the point where the mainline eastwest tracks servicing the yard cross Wyoming Avenue. The other is approximately 500 

feet south of the mainline track crossing. 

• Improving John Kronk for a new gate at Martin (entrance from Livernois Avenue) for 

a new terminal on the north of and contiguous to the existing Livernois-Junction Yard. 

• Constructing a north perimeter road to replace John Kronk between a point west of 

Stecker to Central, then along the terminal boundary to Martin. This road is laid out 

with curves east of Central Avenue to discourage use by large trucks and high-speed 

traffic. 
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The Preferred Alternative will generate by 2030 4,500 permanent jobs statewide of which 3,150 

new jobs will be in the Detroit area, and 1,542 in the Livernois-Junction Yard area. 

The Preferred Alternative will require acquisition of approximately 169 acres of land and 

relocate 28 single-family dwellings, four apartment units, and 29 businesses. The daily 2030 

two-way intermodal truck traffic total will be 4,520 (3,800 at the Livernois-Junction Yard), 

compared to 2,400 (1,500 at the Livernois-Junction Yard) with the No Action Alternative. The 

net increase in intermodal truck trips at the Livernois-Junction Yard would be 2,300. But, 

acquisition of land for the Preferred Alternative will eliminate 1,600 two-way truck trips. 

Thus, the net result is an increase of 700 truck trips per day. Intermodal truck traffic in 2030 

would be split 37%/63% between Livernois Avenue and Wyoming Avenue, respectively. 

Intermodal truck traffic on Livernois/Dragoon south of the terminal would drop to a negligible 

volume. This will be, in part, due to changes at the Livernois/Dragoon interchange with I-75 

that are part of the Preferred Alternative for the Detroit River International Crossing Project 

(DRIC). The DRIC project will eliminate direct ramp connections to Livernois and Dragoon 

and make truck access via I-75 substantially more difficult, while improvements to the 

I-94/Livernois interchange will make access from the north much more attractive. The DIFT 

project has independent utility from the DRIC project. 

Consultation with public interest stakeholders has resulted in a carefully defined program of 

mitigation/enhancements that is summarized on the “Green Sheet” contained in this FEIS at 

the end of Section 5. 
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