Appendix A

Section 1. Agency Comments on DEIS 

and 

Section 2. SHPO Letters 

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1 Comment acknowledged. 

2 The CN/Moterm Terminal is not part of the Preferred Alternative. 

1 

2

Letter 1, U.S. Department of Agriculture, June 1, 2005 
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Letter 2, U.S. EPA, August 16, 2005 
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Letter 2, continued 
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Letter 2, continued 
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1 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the 

Livernois-Junction Yard terminal by siting gates and access routes to minimize exposure to 

neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue 

(Figure 3-19) with concrete curbs so trucks are forced to/from the north via an improved I94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor 

Avenue; and, 2) providing new Wyoming Avenue entrances that connect directly to I-94. Wyoming, 

like Livernois Avenue, is a major arterial with no residential frontage and little nearby residential 

development. Second, voluntary emission reduction measures are drawn from experiences with 

addressing diesel and PM2.5 emissions through EPA’s National Clean Diesel Campaign and other 

initiatives. These would include the measures such as Engine Idling Reduction Programs for trucks 

and locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling 

locomotives; use of electrified truck parking areas; and, use of alternative fuels for handling 

equipment. 

2 PM 2.5 and diesel particulate matter (DPM) concentration forecasts are not included. The tools to 

calculate concentrations are not yet reliable and concentration prediction is not required. 

1 

2 

Letter 2, continued 
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3 MDEQ is taking a variety of actions to control point sources. Sulfur has been removed from diesel 

fuel. New restrictions on diesel vehicles will substantially reduce mobile source particulate emissions. 

The DIFT project has been found to be in conformity (see Section 4.8.4). 

4.1 Interim year (2015) data, based on the anticipated DIFT implementation schedule, are found in Section 

4.8. 

4.2 FHWA-sponsored environmental documents do not normally include air quality emissions for 

construction because it is impossible to define the type of construction equipment and their activities at 

this planning stage. For the PM2.5 and PM 10 hot-spot analysis construction estimates were made and 

compared to the other terminal development activities, such as closing Lonyo and reducing truck 

traffic on Kronk to ensure that the construction activities do not contribute to violations of the 

standards. 

4.3 Truck volumes are shown in Figure 4-11. 

2 

3 

4.1 

4.2

4.1 cont 

4.3 

Letter 2, continued 
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4.4 PM 2.5 and diesel particulate matter (DPM) concentration forecasts are not included. The tools to calculate concentrations are 

not yet reliable and concentration prediction is not required. 

4.5 The DIFT traffic analysis presented in Section 4.1 of the EIS demonstrates that traffic congestion is not caused by DIFT 

activities. No intersections are forecast to experience congestion under the Preferred Alternative. 

4.6 In 2030 the number of daily trucks with the Preferred Alternative compared to No Action goes up by fewer than 700 (Table 

1-4). The number of trucks does not go up four times from No Action to any scenario. Information on traffic patterns to be 

achieved under each alternative was included in the traffic/gate descriptions in DEIS Sections 4.1 and 4.8.2, which cover the 

local roadway burden. This information has been expanded upon in Section 4.8 of the FEIS. 

4.7 A drive through of the neighborhood, and comments received at public meetings, demonstrate that dust is prevalent in the 

neighborhoods; it is both a nuisance and an air quality concern. Work by the Lake Michigan Air Directors Consortium 

reported on in a draft "Weight of Evidence" document prepared by SEMCOG in support of PM2.5 analysis indicates that dust 

control related to PM is an issue that may need further attention. FEIS Table 4-31 (Preferred Alternative) reflects the 

assumption that the terminals will be paved as part of the project's design. The methodology used in calculating dust is from 

EPA’s AP-42. The assumptions and calculations are all shown in Appendix A of the Air Quality Impact Analysis Technical 

Report. 

4.4 

4.5 

4.6 

4.7 

Letter 2, continued 
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4.8 The FEIS expands on the discussion of the differences between No Action and the Preferred 

Alternative and summarizes these in a new Table 4-30. 

5 General conformity was found not to apply. 

4.8 

4.4 cont 

5 

Letter 2, continued 

4.7 
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6.1 The analysis for the Preferred Alternative in this FEIS finds there is a disproportionate effect on EJ populations. The 

DEIS did not. Section 4.3.2 covers Environmental Justice issues. The methodology of the analysis has been stated more 

explicitly for this FEIS. It opens with an explanation of the Executive Order, and provides information on the subject 

populations. The comparison base for each terminal area is the Detroit Urbanized Area. Next, all impact categories are 

reviewed for all alternatives to determine whether there are disproportionate impacts. Impacts at each terminal were 

identified and presented at the end of the impacts discussion for each terminal. The conclusions for the DEIS for the 

terminals were that there were no disproportionate EJ impacts. Since the DEIS it has been determined that the loss of 

residences, jobs, and cultural resources is disproportionate, so mitigation is identified in Section 5. The analysis 

recognizes positive and negative effects on EJ populations and concludes adverse effects will receive appropriate 

mitigation because of the disproportionate negative effects on population groups covered by the EJ Executive Order. 

6.2 The analysis for the Preferred Alternative in this FEIS finds there will also be adverse effects on Title VI population 

groups. The FEIS complied with Title VI of the Civil Rights Act of 1964, and did not exclude the participation of any 

group or deny benefits of any program or activity. To ensure compliance the following steps were taken: 1) an intensive 

community involvement effort was implemented in order to identify Title VI and Environmental Justice groups within 

the project area; 2) an analysis of direct, indirect, and cumulative effects was done to determine the impacts the proposed 

project might have on Environmental Justice and Title VI population groups; 3) project mitigation and community 

enhancements were developed to benefit Environmental and Title VI population groups. A separate evaluation of Title 

VI groups within the project area(s) can be found in Section 4.3.1 of the FEIS. 

6.3 Impacts to the local community have been identified and are the subject of Section 4 and mitigation is identified in 

Section 5 of the FEIS. That analysis recognizes positive and negative effects on EJ populations and concludes as follows: 

"there will be disproportionately adverse housing and cultural resource effects on minority or low-income populations” 

covered by the EJ Executive Order. 

6.1 

6.2 

6.3 

Letter 2, continued 
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7 The projects mentioned in the comment are all included in the analysis of indirect and cumulative 

effects documented in Section 4.17. A new "Delray" bridge to Canada plus the proposed second span 

of the Ambassador Bridge are discussed in the revised indirect and cumulative analysis for the FEIS. 

8 There are systemic reasons for the demand for intermodal freight movement: the price of fuel, the 

congestion of highways with limited ability to improve capacity and the cost competitiveness of 

shipping by rail. The limitation on existing terminal capacity is documented in Section 2.2. 

Alternatives to improve existing rail yards are covered in Section 3. One such alternative is 

Alternative 2. Increasing the size of the terminals in response to the forecast demand will create a 

modern, efficient terminal. Improvements to the tracks in the area will also increase efficiency, but 

these improvements do not increase terminal capacity. 

7 

8 

Letter 2, continued 
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Letter 2, continued 
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1 The Preferred Alternative allows the intermodal activity at the Willow Run Terminal to be transferred 

to the Livernois-Junction Yard. 

1 

Letter 3a, Federal Aviation Administration, August 12, 2005 
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1 Section 4.16 notes the likely presence of asbestos in the buildings to be demolished. Assessment of 

asbestos-containing materials and lead-based paints will be conducted during the property acquisition 

phase of the project. MDOT construction specifications address such activities. 

1 

Letter 3b, Department of Interior, August 8, 2005 
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1 Comment acknowledged. 

1 

Letter 4, Michigan Department of Environmental Quality, August 12, 2005 
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2 Section 4.12.2 states that the wetland impacted (0.1 acres) has minimal storm water storage capacity, 

minimal filter capacity, and no wildlife value. A general permit to address this impact will be obtained 

under Part 303 of P.A. 451. 

3 This correction has been made. 

4 The Livernois-Junction Yard, and the expansion area to the north under the Preferred Alternative, will 

be paved for efficient operation. Stormwater is covered in Section 5.8 and permitting is covered in 

Section 5.4. All requirements related to water quality and discharge rates will be met. 

5 Coordination has occurred through file review at MDEQ during the Project Area Contamination 

Survey. Coordination will continue in order to address contamination issues. 

2 

3 

4 

5 

Letter 4, continued 
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Letter 5, MDEQ Air Quality Division, August 16, 2005 
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1 PM 2.5 and diesel particulate matter (DPM) concentration forecasts are not included. The tools to 

calculate concentrations are not yet reliable and concentration prediction is not required. 

2 Air quality impacts were an important consideration in developing the project alternatives and in 

decisions related to routing truck traffic in the Preferred Alternative. Possible health effects of PM2.5 

and air toxics are noted in Section 4.8.3 of the FEIS. The reasons why no additional analysis of health 

effects will be done are stated in that section. 

3 Health effects of PM2.5 and air toxics are noted in Section 4.8.3 of the FEIS. The reasons why no 

additional analysis of health effects will be done are stated in that section. The FEIS finds a 

disproportionate effect on environmental justice populations. All alternatives would affect 

environmental justice populations. 

1 

2 

3 

Letter 5, continued 
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4 The cited increases in lifts and trucks are wrong. The maximum percent increases under the most 

expansive Action Alternative was 132 % in lifts (Figure 4-1) and 142 % in trucks (Alternative 3, 

compare totals in Tables 4-1c and 4-3). The Preferred Alternative will have an increase in lifts and 

trucks of 57 percent more than the No Action Alternative (Figure 4-10). The "net new" number of 

trucks with the Preferred Alternative, compared to the No Action Alternative, is about 700 at the 

Livernois-Junction Yard (Table 4-22b), as the project will relocate a number of heavy truck 

generators. 

5 As there are no air toxic standards, the burden analysis in the DEIS compared the alternatives to one 

another, rather than to a standard. The data in Table 4-31 shows the relationship between the No 

Action Alternative and the Preferred Alternative. 

6 FHWA guidance issued February 13, 2006 and EPA Rules of March 10th find the science still lacking 

to accurately predict particulate concentrations. 

4 

4 

1 cont. 

5 

6 

Letter 5, continued 
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7 Possible health effects of PM2.5 and air toxics are noted in Section 4.8.3 of the FEIS. The reasons why no additional analysis of health effects will be done are 

stated in that section. 

8 The FEIS expands on the discussion of the differences between No Action and the Preferred Alternative and summarizes these in a new Table 4-31. 

9 The example is illustrative, allowing a lay person to have some understanding of the magnitude of other air toxics in the environment. Its accuracy depends on 

EPA's AP-42 document, which is the recognized source for such information. 

10 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the Livernois-Junction Yard terminal by siting gates and access 

routes to minimize exposure to neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue (Figure 3-19) with concrete 

curbs so trucks are forced to/from the north via an improved I-94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor 

Avenue; and, 2) providing new Wyoming Avenue entrances that connect directly to I-94. Wyoming, like Livernois Avenue, is a major arterial with no residential 

frontage and little nearby residential development. Second, voluntary emission reduction measures are drawn from experiences with addressing diesel and PM2.5 

emissions through EPA’s National Clean Diesel Campaign and other initiatives. These would include the measures such as Engine Idling Reduction Programs for 

trucks and locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling locomotives; use of electrified truck parking areas; and, use of 

alternative fuels for handling equipment. 

11 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the Livernois-Junction Yard terminal by siting gates and access 

routes to minimize exposure to neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue (Figure 3-19) with concrete 

curbs so trucks are forced to/from the north via an improved I-94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor 

Avenue; and, 2) providing new Wyoming Avenue entrances that connect directly to I-94. Wyoming, like Livernois Avenue, is a major arterial with no residential 

frontage and little nearby residential development. Second, voluntary emission reduction measures are drawn from experiences with addressing diesel and PM2.5 

emissions through EPA’s National Clean Diesel Campaign and other initiatives. These would include the measures such as Engine Idling Reduction Programs for 

trucks and locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling locomotives; use of electrified truck parking areas; and, use of 

alternative fuels for handling equipment. 

7 

7 cont 

8 

9 

10 

11

Letter 5, continued 
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12 FHWA-sponsored environmental documents do not normally include air quality emissions for 

construction because it is impossible to define the type of construction equipment and their activities at 

this planning stage. For the PM2.5 and PM10 hot-spot analysis construction estimates were made and 

compared to the other terminal development activities, such as closing Lonyo and reducing truck 

traffic on Kronk to ensure that the construction activities do not contribute to violations of the 

standards. 

13 Interim year (2015) data, based on the anticipated DIFT implementation schedule, are found in Section 

4.8. 

11 cont

12 

13 

Letter 5, continued 
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Letter 6, SEMCOG, July 8, 2005 
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Letter 6, continued 
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1 No other separations of the rail line and roadways are needed to allow the Preferred Alternative to function safely and efficiently. 

2 See Table 4-32 and the introductory text to Section 4.9 

3 The Livernois-Junction Yard, and the expansion area to the north under the Preferred Alternative, will be paved for efficient operation. 

Stormwater is covered in Section 5.8 and permitting is covered in Section 5.4. All requirements related to water quality and discharge rates 

will be met. 

4 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the Livernois-Junction Yard terminal by siting 

gates and access routes to minimize exposure to neighborhoods and residential development by: 1) constructing the entry point off Livernois 

Avenue (Figure 3-19) with concrete curbs so trucks are forced to/from the north via an improved I-94/Livernois interchange, and not to/from 

the south and the dense neighborhood south of Vernor Avenue; and, 2) providing new Wyoming Avenue entrances that connect directly to I94. Wyoming, like Livernois Avenue, is a major arterial with no residential frontage and little nearby residential development. Second, 

voluntary emission reduction measures are drawn from experiences with addressing diesel and PM2.5 emissions through EPA’s National 

Clean Diesel Campaign and other initiatives. These would include the measures such as Engine Idling Reduction Programs for trucks and 

locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling locomotives; use of electrified truck parking areas; 

and, use of alternative fuels for handling equipment. 

1 

2 

3 

4 

Letter 6, continued 
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5 If the comment refers to air toxics at the Livernois-Junction Yard, the answer is "yes", there would be 

less on-terminal activity than with the Preferred Alternative. 

6 The language has been clarified. 

7 No. The language has been clarified. 

8 The difference is a function of the terminal layouts and traffic patterns assumed under each alternative. 

Alternative 4 is a more efficient layout. Note that some emission factors changed for the FEIS as 

corrections were made to MOBILE6.2 and to AP-42. 

9 This change has been made. 

10 This change has been made. 

11 This change has been made. 

12 Spikes were noted by MDEQ in their 2005 Air Quality Report as resulting from construction near the 

monitor. Adjustments were made, as noted in Section 4.8.4.3. 

4 

5 

6 

7 

8 

9 

10 

11 

12 

Letter 6, continued 
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13 Comment acknowledged. 

13 

Letter 6, continued 
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1 MDOT is supportive of such efforts at the local level. Land use is under the control of the cities of 

Detroit and Dearborn, where the terminal of the Preferred Alternative is located. SEMCOG develops 

the regional transportation plan, based on input from local jurisdictions and in cooperation with 

MDOT. 

1 

Letter 7, Detroit City Council, May 17, 2005 
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Letter 8, City of Detroit Department of Environmental Affairs, August 15, 2005 
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2 This document has been reviewed for legal sufficiency by the Federal Highway Administration and 

was approved as meeting the requirements of the NEPA process. 

3 A modified Alternative 4 is the Preferred Alternative. It is smaller, as the CP/Expressway operation 

has ended, and expansion of the CN/Moterm Terminal into the Fairgrounds is no longer part of the 

alternative. The Preferred Alternative will be associated with a governance structure. See the Predevelopment Plan Agreement in Appendix F. 

2 

3 

Letter 8, continued 
DIFT Final Environmental Impact Statement and Final Section 4(f) Evaluation 

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4 The 2004 plan was not official at the time the DEIS and FEIS were prepared, so it could not be used as 

the basis of analysis, but its contents were reviewed, and there are no known changes in 

impacts/conclusions. 

3 cont 

4 

Letter 8, continued 
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Letter 8, continued 
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4.1 The EIS addresses all impacts, consistent with state and federal regulations and laws. The benefits of 

the project are also addressed. 

4.1 

4.1 cont 

Letter 8, continued 
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4.2 The discussion of the potential direct, indirect and cumulative effects with the CN/Moterm facility 

covered an area in Northwest Detroit and Southern Oakland County that is 22 square miles with more 

than 140,000 people according to the 2000 U.S. Census. That area includes Highland Park and the 

area between it and the Fairgrounds. The analysis also covered the Highland Park Comprehensive 

Plan and its relation to the existing intermodal terminal and its proposed expansion. 

4.2 

4.2 cont 

Letter 8, continued 
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4.2 cont 

4.2 cont 

Letter 8, continued 
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5 The positive and negative indirect and cumulative effects are cited at the end of Section 4.17. 

4.2 

cont 

4.2 

5 

Letter 8, continued 
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5.1 The discussion of existing land uses is included in Section 4.6 and future land uses is in Section 4.17. 

The positive and negative indirect and cumulative effects are cited at the end of Section 4.17. U.S.-

Canada intermodal truck traffic carried on the Ambassador Bridge is very minor. The DIFT will have 

almost no effect on the Ambassador Bridge. 

5.1 

5.1 cont 

Letter 8, continued 
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5.2 MDOT has and will coordinate with local officials regarding proposed improvements. 

5.3 Section 4.17 mentions all of the projects listed in the comment and discusses their positive and 

negative indirect and cumulative effects. A NEPA document does not evaluate the adopted Plan of a 

Metropolitan Planning Organization such as SEMCOG. 

5.2 

5.3 

Letter 8, continued 
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6 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the 

Livernois-Junction Yard terminal by siting gates and access routes to minimize exposure to 

neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue 

(Figure 3-19) with concrete curbs so trucks are forced to/from the north via an improved I94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor 

Avenue; and, 2) providing a new Wyoming Avenue entrance that connects directly to I-94. Wyoming, 

like Livernois Avenue, is a major arterial with no residential frontage and little nearby residential 

development. Second, voluntary emission reduction measures are drawn from experiences with 

addressing diesel and PM2.5 emissions through EPA’s National Clean Diesel Campaign and other 

initiatives. These would include the measures such as Engine Idling Reduction Programs for trucks 

and locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling 

locomotives; use of electrified truck parking areas; and, use of alternative fuels for handling 

equipment. 

5.3 cont 

6 

Letter 8, continued 
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6.1 The burden analysis is not based on trends. The roadway burden emission factors assume SEMCOG's 

fleet vehicle mix, which is approved by EPA, together with traffic volumes and speeds estimated for 

this project. The terminal burden analysis likewise used EPA guidelines and emission factors, 

together with site layouts specific to each terminal and alternative. 

6.2 Section 4.8.7 covers the terminal burden analysis and lists all vehicular movements on the yard that 

were considered. It covers the roadway burden analysis, and refers to Figures 4-48, which show the 

roadway networks where traffic to and from the terminals is considered. 

6.1 

6.2 

6.2 

Letter 8, continued 
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6.3 The Air Quality Impact Technical Report provides them an extensive amount of data used to generate 

the link-by-link roadway pollutant burden forecasts (using EPA emission factors), and all elements of 

the terminal activity: visitor/employee traffic; truck activity on the rail yard related to container 

delivery and pickup; container handling (moving containers between delivery points and trains); 

locomotive idling and movement on the yard; fugitive dust from paved and unpaved yard areas; 

vehicular travel on sites of businesses to be acquired; vehicular travel on streets that would close with 

development (John Kronk and a section of Lonyo); and, fugitive dust from business sites and streets 

that would be closed. Canadian trucks are produced in the same factories and generally meet the same 

emission standards as US trucks. No data are provided to indicate intermodal trucks are different than 

other trucks. The analysis does account for trucks traveling to and from the terminals as well as the 

truck trip reduction through diversion to rail. 

6.4 The project has found to be in conformity with all NAAQS by SEMCOG in conjunction with FHWA. 

See Section 4.8.7. 

6.3 

6.4 

Letter 8, continued 
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7 The traffic analysis, documented in Section 4.1 , addresses DIFT-related traffic by comparing the 

highest forecast for each Action scenario to the lowest forecast of No Action. The traffic of other 

projects included in SEMCOG's plan is incorporated in the analysis by using SEMCOG's traffic data 

and roadway network for future conditions. The activities of AMTRAK and commuter rail expected 

to move through the Livernois-Junction Yard are included in Section 4.9.1. 

7.1 The I-94 change will not encourage use of Livernois as a route from the airport and points west to 8 

Mile. No one would drive over 7 miles of surface streets with upwards of a dozen signals, rather than 

using the parallel-freeway system. 

7 

7.1 

Letter 8, continued 
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8.1 The noise analyses of the DIFT DEIS/FEIS require mitigation for noise in the loudest hour. The nature of this noise metric is such that it is 

designed to control continuous noise, not "impulse noise." The entire Livernois-Junction Yard will be buffered from non-industrial uses so that 

the noise in the loudest hour does not exceed the established criterion of 67 dBA at sensitive receptors, such as homes. Impulse noise, such as 

container handling, is controlled by local noise ordinances, in this case the cities of Detroit and Dearborn. 

8.2 The train noise analysis is in the Noise and Vibration Technical Report and is summarized in Section 4.9 of the FEIS. All sensitive areas around 

the project will be properly buffered to reduce projected noise levels below established residential criteria. 

8.3 That security wall will also block/attenuate noise. 

9 Section 4.3.2 covers Environmental Justice issues. It opens with an explanation of the Executive Order, and provides information on the subject 

populations. To prevent repetition, figures earlier in the EIS are referred to. The comparison base for each terminal area is the Detroit 

Urbanized Area. All impact categories are reviewed for all alternatives. Table 4-16 summarizes impacts: mobility, economic impacts, air 

quality, community effects, noise, and cultural resources. The same table summarizes mitigation measures. Impacts to the local community 

have been identified and are presented in Section 4. Mitigation is identified in Section 5. The analysis recognizes positive and negative effects 

on EJ populations and concludes adverse effects will receive appropriate mitigation because of the disproportionate negative effects on 

population groups covered by the EJ Executive Order. 

9.1 As explained in Sections 4.3.1 and 4.3.2 of the FEIS, the Detroit Urbanized Area is the basis of comparison to each of three defined "terminal 

areas" which range in size from 22 to 35 square miles and 140,000 to 164,000 people. The terminal areas are aggregations of census tracts 

around each terminal. The Detroit Urbanized Area is defined in the footnotes to Table 4-12 and shown in Figure 4-13c. 

8.1 

8.2 

8.3 

9 

9.1 

Letter 8, continued 
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10 See Section 5. 

9.1 

9.1 cont 

10 

Letter 8, continued 
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10.1 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the 

Livernois-Junction Yard terminal by siting gates and access routes to minimize exposure to 

neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue 

(Figure 3-19) with concrete curbs so trucks are forced to/from the north via an improved I94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor 

Avenue; and, 2) providing new Wyoming Avenue entrances that connect directly to I-94. Wyoming, 

like Livernois Avenue, is a major arterial with no residential frontage and little nearby residential 

development. Second, voluntary emission reduction measures are drawn from experiences with 

addressing diesel and PM2.5 emissions through EPA’s National Clean Diesel Campaign and other 

initiatives. These would include the measures such as Engine Idling Reduction Programs for trucks 

and locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling 

locomotives; use of electrified truck parking areas; and, use of alternative fuels for handling 

equipment. 

Letter 8, continued 

10.1
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10.2.1 "Tipping fees" are not required as the railroads will directly pay for about 28% of the capital costs of the Preferred Alternative. 

10.2.2 See Section 5. 

10.2.3 See Section 5, Mitigation. First, the Preferred Alternative minimizes air pollutant emissions at the Livernois-Junction Yard terminal by siting gates and access routes 

to minimize exposure to neighborhoods and residential development by: 1) constructing the entry point off Livernois Avenue (Figure 3-19) with concrete curbs so 

trucks are forced to/from the north via an improved I-94/Livernois interchange, and not to/from the south and the dense neighborhood south of Vernor Avenue; and, 

2) providing new Wyoming Avenue entrances that connect directly to I-94. Wyoming, like Livernois Avenue, is a major arterial with no residential frontage and 

little nearby residential development. Second, voluntary emission reduction measures are drawn from experiences with addressing diesel and PM2.5 emissions 

through EPA’s National Clean Diesel Campaign and other initiatives. These would include the measures such as Engine Idling Reduction Programs for trucks and 

locomotives, auxiliary power units for trucks, and automatic shut-off devices for idling locomotives; use of electrified truck parking areas; and, use of alternative 

fuels for handling equipment. 

10.2.4 The noise study in the FEIS meets all federal and state requirements. Mitigation of noise is associated with barrier walls that are part of the design of the Preferred 

Alternative. There is no need for the project to mitigate pre-existing conditions although the new barrier walls will do so where they are placed. 

10.2.5 Dix at Central and Livernois at I-94 will be improved as part of the project. The grade separation of Central from the rail line will also be part of the project and 

MDOT will take over that portion of Central Avenue from the local jurisdiction. All other roads in the area except Michigan Avenue, I-94, and I-75 are under local 

government control. 

10.2.6 Enhancements are planned at Dix/Vernor, Livernois @ I-94, and Wyoming at Michigan. Design there and at all gates will follow American Association of State 

Highway Officials (AASHTO) guidelines, thereby addressing safety needs. 

10.2.7 The Livernois-Junction Yard, and the expansion area to the north under the Preferred Alternative, will be paved for efficient operation. Stormwater is covered in 

Section 5.8 and permitting is covered in Section 5.4. All requirements related to water quality and discharge rates will be met. 

10.2.8 The design of the Preferred Alternative includes a buffer as described in Sections 4.9, 4.15 and 4.19. 

10.2.9 The Preferred Alternative does not include a truck route by the Beard School. 

10.2.10 The current situation at the Livernois-Junction Yard in terms of emergency response of police and fire services will be improved by the Preferred Alternative as there 

will be no blocking of their movement by trains. Jobs will increase and local tax revenues will increase. 

10.2.11 Viaduct actions in the Livernois-Junction Yard area are the responsibility of either the railroads or the local jurisdictions. Viaduct improvements have been included 

in the Enhancement Program. See the last section of the Green Sheet. 

10.2.12 The design of the Preferred Alternative includes a buffer as described in Sections 4.9, 4.15 and 4.19. 

10.2.13 See Section 5. 

10.2.14 Every attempt will be made to relocate in the Terminal Area persons and businesses affected by the Preferred Alternative, if they so choose. 

10.2.15 Enforcement of air quality rules and regulations is the responsibility of the Michigan Department of Environmental Quality and the U.S. EPA. SEMCOG plays a 

role by working with these agencies to set "budgets" to guide the region to attainment of National Ambient Air Quality Standards. The DIFT project has been found 

to conform to the Clean Air Act (Section 4.8.4). 

10.2.16 The EPA regulations on diesel fuel content and new diesel engines will affect terminals (off-road) and on-road equipment (intermodal trucks). There will be no 

control over the trucks that use the terminal. All vehicles will be subject to idle controls while at the terminal. 

10.2.17 Improved transit does not improve intermodal freight movement or address the project purpose and need. Nonetheless, the Preferred Alternative accommodates 

AMTRAK and commuter rail operations through the Livernois-Junction Yard. 

10.2.1 

10.2.2 

10.2.3 

10.2.4 

10.2.5 

10.2.6 

10.2.7 

10.2.8 

10.2.9 

10.2.10 

10.2.11 

10.2.12 

10.2.13 

10.2.14 

10.2.15 

10.2.16 

10.2.17 

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10.2.18 Stormwater monitoring is not warranted with the anticipated project stormwater controls. 

10.2.18 

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11.1 Comment acknowledged. 

11.1 

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11.2 Intermodal truck traffic will follow the routings created by the project on Wyoming Avenue and on 

Livernois Avenue north of the Livernois-Junction yard. Intermodal truck traffic will be reduced on 

Livernois and Dragoon south of the terminal. Major truck traffic will be reduced on Central and 

Lonyo. The increase in intermodal truck traffic on Wyoming and Livernois will be negligible relative 

to background traffic. Maintenance will no longer be required by Dearborn on Southern Street or 

Kronk, as they will be incorporated into the terminal. The new perimeter road of the terminal will be 

maintained by local governments, as it is today. The Preferred Alternative includes improvements at 

Central/Dix. 

11.2 

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11.3 Intermodal truck traffic will follow the routings created by the project on Wyoming Avenue and on 

Livernois Avenue north of the Livernois-Junction yard. Intermodal truck traffic will be reduced on 

Livernois and Dragoon south of the terminal. Major truck traffic will be reduced on Central and 

Lonyo. The increase in intermodal truck traffic on Wyoming and Livernois will be negligible relative 

to background traffic. Maintenance will no longer be required by Dearborn on Southern Street or 

Kronk, as they will be incorporated into the terminal. The new perimeter road of the terminal will be 

maintained by local governments, as it is today. The Preferred Alternative includes improvements at 

Central/Dix. 

11.3 

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11.4 Intermodal truck traffic will follow the routings created by the project on Wyoming Avenue and on 

Livernois Avenue north of the Livernois-Junction yard. Intermodal truck traffic will be reduced on 

Livernois and Dragoon south of the terminal. Major truck traffic will be reduced on Central and 

Lonyo. The increase in intermodal truck traffic on Wyoming and Livernois will be negligible relative 

to background traffic. Maintenance will no longer be required by Dearborn on Southern Street or 

Kronk, as they will be incorporated into the terminal. The new perimeter road of the terminal will be 

maintained by local governments, as it is today. The Preferred Alternative includes improvements at 

Central/Dix. 

11.4 

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