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SECTION 5 

MITIGATION OF IMPACTS 

This section applies to all Action Alternatives, unless otherwise stated. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5.1 Right-of-Way Acquisition and Relocation Impacts 

A Conceptual Stage Relocation Plan has been prepared (Appendix B). The following standard 

procedures will be followed. 

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

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

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

Acquisition Policies Act of 1970 as amended, and Act 87, and Michigan P.A. 1980 as amended. 

MDOT will inform individuals, businesses and non-profit organizations of the impact, if any, of 

the project on their property. Every effort will be made, through relocation assistance, to lessen 

the impact when it occurs. 

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

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

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

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

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

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

displaced businesses and non-profit organizations. MDOT has specific programs that will 

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

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

businesses or non-profit organizations are advised of the rights, benefits, and courses of action 

open to them. Displaced businesses and organizations will be encouraged to relocate within the 

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

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

payment of “fair market value” for the property rights acquired, plus allowable damages to any 

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

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

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

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

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

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

Support Area, PO Box 30050, Lansing, Michigan, 48909 or phone (517) 373-2200. 

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

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

Transportation, Real Estate Support Area, P. O. Box 30050, Lansing, Michigan, 48909 or phone 

(517) 373-2200. 

5.2 Barrier Walls for Terminal Security 

Barrier walls for terminal security would be provided under all Action Alternatives as an integral 

part of the proposed project. Under Alternative 2, at the Livernois-Junction Yard, they would be 

along the north side of the terminal. A barrier wall would be built on the south side of the 

Livernois-Junction Yard east of Central. This barrier wall has been defined in height to also 

abate noise (per MDOT’s Noise Policy) as well as provide security. A barrier wall for security 

purposes will be placed on the north side of the CP/Oak terminal. Similarly, a barrier wall for 

security would also be provided on the east side of the railroad tracks to protect the neighborhood 

there, if the CN/Moterm terminal were expanded into the State Fairgrounds (Alternatives 2 and 

4). It, too, has been defined in height to also abate noise. A barrier wall will also be placed on 

the west side of the terminal between the State Fairgrounds and railroad activity. 

Under Alternatives 3 and 4 the same walls would be provided as under Alternative 2 adjusted as 

necessary by the north boundary of the terminal at the Livernois-Junction Yard. 

5.3 Soil Erosion and Sedimentation Control 

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

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

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

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

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

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

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

approved operating erosion and sedimentation control program which ensures compliance with 

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

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

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

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

the acceptable erosion and sedimentation control program. 
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The following is a list of the mitigation measures for this project to be carried out in accordance 

with permit requirements. 

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

easements. 

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

possible during the construction period in order to control erosion. 

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

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

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

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

sewer system. 

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

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

5.4 Environmental Permits 

For each Action Alternative construction activities will involve obtaining permits in several areas 

to ensure appropriate steps are taken to protect existing/remaining resources. Impacts on bodies 

of water such as lakes, streams, drains and wetlands will require permits under federal and state 

law: 

Federal

• Executive Order 11990 (Wetland Protection) 

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

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

and, Section 404, related to dredge and fill. 

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

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

practicable alternative to impacts on that wetland. 

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

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

with the provisions of the Federal Water Pollution Control Act. 

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

National Pollutant Discharge Elimination System Storm Water discharge permit for construction 

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

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

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

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

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

water quality during and after construction. 
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State – Michigan Natural Resources and Environmental Protection Act, 1994 PA 451, as 

amended: 

• Part 55, Air Pollution Control 

• Part 303, Wetland Protection 

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

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

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

permanent. 

5.5 Existing Vegetation 

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

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

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

sod. 

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

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

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

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

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

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

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

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

then assume the responsibility for maintaining these trees. 

5.6 Disposal of Surplus or Unsuitable Material 

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

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

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

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

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

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

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

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

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

MDEQ governing disposal of solid wastes will be complied with. 

5.7 Groundwater Quality 

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

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

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

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

turned off at the street. In rural areas, the sewer line to the septic tank must be filled at the 
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basement level. Abandoned water wells will be filled with grout applied from the bottom 

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

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

Community Health (MDCH) requirements. 

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

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

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

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

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

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

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

conditions such as flowing wells or wells with a high artesian head are encountered. If high water 

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

on the area groundwater. 

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

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

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

discharged into an available storm sewer. 

5.8 Surface Water Quality 

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

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

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

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

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

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

will not be increased. 

5.9 Maintaining Traffic During Construction 

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

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

phase. A preliminary construction staging program for each Action Alternative has been 

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

minimize impacts to the local neighborhoods and the motoring public. If an Action Alternative is 

chosen, the preliminary staging plan expects project implementation to begin in 2006 and 

conclude by 2015, depending on the alternative chosen. Modification of the I-94/Livernois 

Avenue ramps in the northeast and northwest quadrants of the interchange is expected to be 

accomplished in one construction season (March through November). Lonyo will not be closed 

before construction of the Central Avenue underpass is complete. The under pass is expected to 

take at least two years to construct. 

5.10 Continuance of Public Utility Service 

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

affected utility company will take place during design, prior to actual construction. Proposed 
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staging plans will also be presented to utilities to make them aware of the project. Service to the 

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

interruptions will be minimized. 

5.11 Construction Noise and Vibration Impacts 

Barrier walls for security purposes, included in terminal design, will be installed first, to the 

extent practicable, in areas to minimize noise due to construction and, later, terminal operation on 

sensitive receptors (e.g., north of Kronk at the Livernois-Junction Yard and south of Eight Mile 

Road, east of the Fairgrounds). 

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

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

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

receptors, if at all possible. All local noise ordinances will be adhered to. 

Where pavement must be fractured, structures must be removed, and/or piling or steel sheeting 

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

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

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

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

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

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

impacts are not anticipated at this time. 

5.12 Control of Air Pollution During Construction 

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

governing the control of air pollution. 

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

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

damage to any property or business. 

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

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

Resources and Environmental Protection. For any portable bituminous or concrete plant or 

crusher, the contractor must apply for a permit-to-install or general permit. This permit should be 

applied for a minimum of 45 calendar days for plants with an active MDEQ permit (or 75 

calendar days for plants not previously permitted in Michigan) prior to the plant being installed. 

Dust collectors must be provided on all bituminous plants. Dry, fine aggregate material removed 

from the dryer exhaust by the dust collector must be returned to the dryer discharge unless 

otherwise directed by the project engineer. 

5.13 Wetland Mitigation 

Preliminary consultation regarding mitigation for wetlands was undertaken during delineation of 

wetlands. Mitigation of proposed wetland impacts has followed three sequential steps: 1) 

avoidance of wetlands where feasible, 2) minimization of unavoidable impact by adjustments to 
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the project alignment and typical section, and 3) compensatory wetland construction or 

restoration. The first two steps have been integral to project development. Specific mitigation 

measures would be done in accordance to all applicable statutes administered by appropriate 

agencies. 

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

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

soil erosion and sediment control practices consistent with MDOT’s Soil Erosion Program. 

Compensatory wetland restoration or creation is planned, in accordance with state and local 

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

wetlands at the Livernois-Junction Yard (Alternatives 2, 3 and 4) and 0.07 acres at the 

Fairgrounds (Alternatives 2 and 4). These areas are made up of marginal wetlands of minor 

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

a mitigation need of about 0.08 acres. 

Both wetlands impacted by Alternatives 2, 3 and 4 are Palustrine Emergent of low biological 

quality. The wetland at the Livernois-Junction Yard is dominated by common reed (Phragmites 

australis) and willow (Salix spp.). The wetland at the Fairgrounds supported 13 wetland plant 

species. 

MDOT, through a cooperative agreement with MDEQ, would build or restore compensatory 

mitigation for unavoidable wetland impacts using a “Moment of Opportunity” site allowed under 

the General Permit Category of Part 303 of P.A. 451 (1994, as amended). 

5.14 Contamination 

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

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

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

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

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

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

Investigations were done for 67 individual sites and up to 45 sites have been identified for a 

Phase II survey, depending on which alternative is selected. Additional soil borings will be 

required to further identify potential contamination along the selected alternative. Contamination 

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

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

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

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

5.15 National Geodetic Survey Monuments 

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

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

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

Several properties eligible for listing on the National Register of Historic Places may be affected 

by the project. Where prudent and feasible, they will be avoided. Where it is not prudent and 

feasible to avoid an historic resource, the impact will be minimized to the extent possible and 

there will be mitigation. Coordination with the SHPO will continue in order to document impacts 

and mitigation measures. 

5.17 Additional Mitigation or Modifications 

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

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

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

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

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

construction begins. 

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

2005. 

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

security, Central Avenue underpass) are covered in a Memorandum of Understanding (MOU). 

The MOU accompanies this DEIS as Appendix F. The MOU is the basis of a more detailed 

agreement, to be developed/executed once a preferred alternative is identified and before the 

FEIS is issued. In those areas around the terminals where Federal Highway Administration Noise 

Abatement Criteria are exceeded due to terminal activity, the barrier walls will be designed to 

reduce terminal noise a minimum of 5 dBA below the criteria levels. 
Detroit Intermodal Freight Terminal DEIS 

Green Sheet: Project Mitigation Summarya,b

Impact Category Mitigation Measures 

I. Social and Economic Environment 

a. Visual Effects Buffers/barrier walls are planned at the Livernois-Junction Yard under 

Alternatives 2, 3, and 4 and at CP/Oak along the north side (Alternative 

2), and along the east side of the railroad tracks at the Fairgrounds 

(Alternatives 2 and 4). Buffer/barrier wall construction and construction 

materials will be discussed with the affected public in the vicinity of 

potential construction. 

b. Relocations Adequate replacement housing and industrial/commercial space is 

available to replace up to 83 dwelling units and 64 businesses that could 

be relocated. 

c. Recreational Approximately 35 acres of the Michigan State Fairgrounds will be 

affected for Alternatives 2 and 4. Coordination with Michigan 

Department of Agriculture will occur in order to document impacts and 

mitigation measures including provision of parking during the State Fair. 

d. Noise Project noise levels exceed FHWA Noise Abatement Criteria at several 

locations adjacent to terminals. Barrier walls are planned as part of the 

project for security purposes. In noise sensitive areas, these barrier walls 

will be designed to also provide noise abatement.a

II. Natural Environment 

a. Wetlands A maximum of 0.08 acres of impacted wetlands will be replaced under 

the “moment of opportunity” arrangement where the mitigation will be 

rolled into another mitigation project elsewhere in the state. A permit 

will be obtained from the Michigan Department of Environmental 

Quality for using this wetland. 

b. Tree Removal/ 

Clearing/Landscaping 

Mature trees will be preserved where possible. Property owners will be 

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

be offered replacement trees. 

c. Water Quality For runoff, storm water management facilities will include detention 

basins and oversized pipes. Storm water at all terminals flows to 

combined sanitary/storm sewers. Storm water management will be 

incorporated into the project’s final design. 

III. Hazardous / Contaminated Materials 

a. Contaminated Sites A Project Area Contamination Survey has been completed. Up to 45 

sites have been identified for a Phase II survey, depending on which 

alternative is selected, prior to right-of-way acquisition. More soil 

borings will be needed. Contamination areas will be marked on all 

construction plans. Proper disposal of any hazardous/contaminated 

material will occur. All monitoring wells will be properly abandoned. 

A Utility Plan will also be prepared to ensure no deep utility cuts will 

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

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

IV. Cultural Environment 

a. Historic Several properties eligible for listing on the National Register of Historic 

Places may be affected by this project. Coordination with the SHPO 

will continue in order to document impacts and mitigation measures. 

May 2005 
V. Construction 

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

occur. These areas will be identified during the design phase, where 

pavement and bridge removal will occur, or where piling and/or steel 

sheeting is planned. Impacts are not anticipated at this time. 

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

of the interchange at Livernois will require temporary detours. The 

construction of the Central Avenue underpass will require a detour to 

Lonyo Avenue. Lonyo will not be closed until the Central Avenue 

underpass is complete. a

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

Avenue underpass) are covered in a Memorandum of Understanding (MOU). The MOU accompanies this DEIS as 

Appendix F. The MOU is the basis of a more detailed agreement, to be developed/executed once a preferred 

alternative is identified and before the FEIS is issued. In those areas around the terminals where Federal Highway 

Administration Noise Abatement Criteria are exceeded due to terminal activity, the barrier walls will be designed 

to reduce terminal noise a minimum of 5 dBA below the criteria levels. b

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

at this time. These mitigation items may be modified during the FEIS or Record of Decision (ROD), final design, 

right-of-way acquisition, or construction phases of the project. 
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SECTION 6 

DRAFT SECTION 4(f) EVALUATION 

6.1 Introduction 

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

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

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

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

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

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

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

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

The Federal Highway Administration (FHWA) has determined the project will result in adverse 

effects on the potentially historic properties and recreational resources noted below if Alternatives 

2, 3 and 4 (Table 6-1) were selected: 

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

• Federal Screw Works Factory 

• Markey House 

• Tomms House 

• Michigan Central Railroad Bridge Deck 

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

Table 6-1 

Potential National Register Eligible Cultural Resources and Recreational Resources Adverse Effects 

Alt. Terminal Site Name Location Description of Area Impacted

National Register 

Eligibility 

Criteriaa

Effect 

3/4 Liv-Jct Michigan Box 

Company/Spranger 

Wire Wheel 

Corporation 

7175 Clayton Street Factory originally built to 

make auto parts. Now pallets 

are made at the site. 

C Area needed for Alternatives 3 

and 4 would require demolition of 

this property. 

3 Liv-Jct Federal Screw Works 

Factory 

3301-3401 Martin 

Street 

Factory originally built to 

make auto parts. Now a 

warehouse 

A + B Area needed for Alternative 3 

would require demolition of this 

property. 

3 Liv-Jct Markey House 3504 Martin Street Historic Home A + C The Federal Screw Works Factory 

across the street would be 

demolished under Alternative 3 

causing an adverse visual effect. 

3 Liv-Jct Tomms House 3434 Martin Street Historic Home C The Federal Screw Works Factory 

across the street would be 

demolished under Alternative 3 

causing an adverse visual effect. 

2 CP/Expressway Michigan Central 

Railroad Bridge Deck 

2405 West Vernor 

Highway 

Bridge deck structure 

associated with Michigan 

Central passenger station 

complex. 

C Tracks would be added and 

modified on the bridge for 

Alternative 2. 

2/4 CN/Moterm Michigan State 

Fairgrounds (MSF) 

Woodward Avenue and 

8 Mile Road 

Area used to store new 

vehicles prior to shipment 

Not Applicable A portion of the area used to store 

new vehicles prior to shipment, 

that is leased from the MSF, 

would be required under 

Alternatives 2 and 4. a See Section 6.3.1. 

Source: Commonwealth Cultural Resources Group and The Corradino Group of Michigan, Inc. 
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The alternatives for intermodal terminal development are summarized on Table 1-1 and 

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

Expanded intermodal terminals would adversely affect these properties. FHWA has consulted 

with the State Historic Preservation Officer (SHPO) and the Michigan State Fairgrounds on 

determinations of eligibility and effect and to develop measures to minimize harm. This draft 

Section 4(f) document was prepared for processing under the procedures set forth in FHWA 

regulation 23 CFR 771.135. A draft Memorandum of Agreement (MOA) is included in 

Appendix C and a final MOA will be developed, as appropriate, for inclusion in the FEIS. 

6.2 Proposed Action and Need for Project 

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

competitiveness of southeastern Michigan and the state by improving freight transportation 

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

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

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

congestion to support the economic competitiveness of Southeast Michigan. 

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

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

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

automotive capital of the world and strategic position on the Canadian border. 

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

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

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

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

national defense as well as a high quality of life for the region’s citizens including: 

• Providing the necessary infrastructure to support current and future distribution needs of 

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

Michigan businesses. 

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

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

on an “intermodal” strategy. 

• Stimulating economic development and redevelopment throughout Southeast Michigan 

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

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

conserves highway capacity. 

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

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

improved. 
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• Buffering existing intermodal facility from nearby neighborhoods through improvements 

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

terminal’s exterior appearance and security. 

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

which have grown from 283,000 lifts in 1992 to 348,000 lifts in 2002. The capacity of the 

existing intermodal terminals in the region is about 345,000 annual lifts. The forecast demand for 

2025, if no extraordinarily positive trends occur, would range from about 500,000 to 800,000 

annual lifts. 

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

6.3 Description of Resources 

6.3.1 Historic Resources 

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

Preservation Act of 1966 and is administered by the National Park Service. The NRHP has 

established criteria for determining historic significance. These criteria require a property to have 

integrity of location, design, setting, materials, workmanship, feeling, and association. 

Additionally, the property must meet one of the following: Criterion A) be associated with a 

significant event; Criterion B) be associated with the lives of significant persons; Criterion C) 

embody the distinctive characteristics of a type, period or method of construction, or represent the 

work of a master; or, Criterion D) have yielded or be likely to yield information important in 

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

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

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

assessment that field investigations at two archaeological sites at the Livernois-Junction Yard 

should be conducted to determine whether archaeological deposits are present prior to any 

construction (see letter dated November 22, 2004 in Appendix A). A discussion of properties 

considered eligible and expected to experience adverse effects with the project follows.1

 

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

Street, Detroit

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

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

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

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

1924. 

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

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

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

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

 

1

 In addition to the properties considered eligible for the National Register and expected to experience adverse effects, 

there is one more property at the Livernois-Junction Yard where the final determination about effect has not been 

concurred in by the SHPO (the house at 6332 John Kronk). This determination will be made prior to the FEIS. If it is 

determined that there will be an adverse effect (or a use) at this site, it will be added to the 4(f) statement. 
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Detroit Wire Wheel Corporation. Spranger was, however, replaced as president by Frederick R. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

grade, inclining towards the building from Clayton. 

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

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

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

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

covered with flakeboard panels. 

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

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

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

incinerator facility housed in the heater building. 

The wire wheel factory building at 7175 Clayton is a rare example of a relatively unaltered World 

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

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

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

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

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

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

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

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

produces wooden pallets and containers. 
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Federal Screw Works Factory 3301/3401 Martin Street, Detroit 

Historically the facility at 3301/3401 Martin Street is associated with Federal Screw Works, a 

manufacturer of fasteners to the auto industry. Federal Screw Works, now headquartered in St. 

Clair Shores, Michigan, was founded in Detroit in 1917 to produce fasteners. Their primary 

focus was serving the automobile industry, in particular General Motors and Ford. 

The original building in the existing complex 

was built in circa 1920 at 3401 Martin Street 

(near the Otis Street intersection). The 

building housed office, warehouse and 

machine shop functions in a steel frame and 

brick building, two stories at the front and 

one story with monitor at the back (Figure 6-

2). The factory was expanded towards 

Bruckner Street and Southern Street / John 

Kronk and behind the Martin Street 

structures, in later years, with one addition 

on Southern/John Kronk added in 1950. 

The Modern/Eclectic five bay 1920 building 

follows common themes that were translated 

into office, school, and commercial buildings 

of the period, doing away with Victorian 

excess in favor of cleaner, more modern 

lines. As is common in this modern and 

somewhat conservative style, the building 

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

stone detailing. Brick pilasters support an implied cornice of brick with cast stone blocks done in 

a bas-relief of various nuts and bolts and is finished with limestone coping along the parapet. The 

entrance bay is marked by a slightly projecting entry arcade with simple classical detailing. While 

the first floor has been modified with the replacement of the original large windows with smaller 

aluminum units, the original factory building retains good integrity overall. 

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

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

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

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

carrying opaque panels. 

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

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

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

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

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

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

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

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

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

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

Homer Ferguson – administration of Mayor Richard W. Reading. 

Figure 6-2 

Federal Screw Works Factory 

3301-3401 Martin Street 

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

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

industry. 

Markey House, 3504 Martin Avenue, Detroit 

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

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

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

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

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

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

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

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

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

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

reside at 3504 Martin through at least 1911. 

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

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

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

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

avenue and is still extant at 4323 Martin Avenue. 

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

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

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

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

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

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

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

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

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

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

Tomms House 3434 Martin Avenue, Detroit 

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

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

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

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

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

replacements (Figure 6-3). 
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The dwelling at 3434 Martin Avenue dates to ca. 1875. As of 1876, these grounds to the east of 

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

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

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

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

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

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

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

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

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

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

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

distinct style expressing ca. 1865-1875 Italianate influence. 

Figure 6-3 

Markey and Tomms Houses 

Martin Street

3504 Martin Streetscape, View to South-Southwest 

3434 Martin Streetscape, View to South-Southwest 

Source: CCRG 
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Michigan Central Railroad Bridge Deck at the Passenger Station Complex 2405 West 

Vernor Highway, Detroit 

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

(MCRR) in 1912/1913, having been designed by the architectural and engineering firms of 

Warren and Westmore and Reed and Stem. Whitney Warren, the principal architect of the 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

terra cotta block. 

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

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

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

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

also marks the wall space extending below the West Vernor Highway bridge. 
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The bridge element of this structure spans the 100-ft wide West Vernor Highway right-of-way 

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

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

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

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

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

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

north and south bridge facades are square and concrete encased, with recessed panels. 

Reinforced concrete building design was a product of construction technology that emerged 

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

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

became well established. Among these was the adoption of the arched reinforced concrete slab 

deck in both bridge and building construction, a form specifically designed to “support heavy 

loads.” 

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

employed as of 1917. The approach is totally omitted in standard design texts of the succeeding 

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

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

undocumented. 

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

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

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

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

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

passenger station complex. Its potential for NRHP nomination, either individually or as an 

element of the NRHP-listed passenger station, relates directly to its unique character as a marker 

in the early evolution of monolithic reinforced concrete bridge/deck design specific to the 

ca.1905-1915 period. Its eligibility would be based on Criterion C for the structure’s significance 

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

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

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

6.3.2 Recreational Resources 

Michigan State Fairgrounds Woodward Avenue and Eight Mile Road, Detroit

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

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

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

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

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

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

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

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

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

such as dog shows, horse shows, trade shows, concerts, and swap meets. 
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The easterly third of the Fairgrounds, adjacent to the railroad, is a fenced gravel parking and 

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

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

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

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

approximately 35 acres as an alternative to the facility’s expansion in the City of Ferndale. See 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

park. 

6.4 Impacts on the Section 4(f) Properties 

The properties discussed above are expected to experience adverse effects with the project. The 

properties and potential adverse effects are summarized in Table 6-1. 

Alternative 2, Improve/Expand the CP/Expressway terminal would add and modify tracks on the 

Bridge Deck at the Michigan Central Railroad passenger station complex at the CP/Expressway 

intermodal terminal. The addition and modification of tracks at this site is considered an adverse 

effect. The SHPO concurred this would be an adverse effect (see letter dated October 18, 2004 in 

Appendix A). 
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Alternative 3: Consolidating all intermodal activity at the Livernois-Junction Yard and 

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

the Livernois-Junction Yard and expanding the CN/Moterm terminal would both require the total 

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

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

adverse effect. The SHPO concurred this would be an adverse effect (see letter dated October 18, 

2004 in Appendix A). 

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

the total removal of the Federal Screw Works Factory for the expansion of the Livernois-Junction 

Yard. The total removal of this factory is considered an adverse effect on these three properties: 

the Federal Screw Works Factory, the Markey House (adverse visual effect), and the Tomms 

House (adverse visual effect). The SHPO states this would be an adverse effect (see letter dated 

January 21, 2005 in Appendix A). 

Alternative 2 and Alternative 4 would require approximately 35 acres of Michigan State 

Fairgrounds (MSF) property. The taking of this area at this site is considered an adverse effect. 

6.5 Avoidance Alternatives 

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

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

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

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

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

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

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

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

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

their evaluation are discussed in Section 3. 

6.5.1 Historic Properties 

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

resources were identified early in the analysis process. Those that were deemed to have some 

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

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

the alternatives. 

All feasible and practical alternatives have been carried forward for detailed study in this DEIS. 

Alternatives which clearly do not address the project purpose and need, described below, were 

eliminated from future consideration. 

Other Sites for Intermodal Terminals 

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

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

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

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

shifted/consolidated at the Livernois-Junction Yard. This location, and others in the region like at 
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Highland Park, do not lend themselves to productive intermodal operations. Nevertheless, an 

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

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

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

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

The August, 1994 Mercer Report2

 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. 

Greenfield Site 

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

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

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

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

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

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

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

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

be able to reach any such new intermodal terminal location. 

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

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

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

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

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

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

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

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

 

2

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

Consulting, August 1994. 
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railroad at the time, Conrail. Since the sale of the Conrail assets, Norfolk Southern now controls 

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

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

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

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

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

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

environmental review is complete. 

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

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

efficient intermodal transportation system. 

CBRA Alternative 

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

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

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

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

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

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

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

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

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

6.5.2 Recreational Properties 

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

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

prudent. 

Expansion to the East into Ferndale 

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

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

tax base for the City of Ferndale (population fewer than 25,000 people). Because of the limited 

amount of industrial redevelopment property in the city, these businesses would be lost to other 

areas. Additionally, Gage Products Company would be displaced. This company is a permitted 

storer of up to one million gallons of hazardous materials. It is Ferndale’s largest taxpayer. It 

would not be possible to relocate this business in Ferndale because of its handling of hazardous 

materials. 

Due to the large number of business relocations that would be required and the major reduction in 

tax revenues for Ferndale, expansion to the east is not a feasible and prudent alternative. 

Expansion to the West into Ferndale 

Expansion to the west of the existing CN/Moterm terminal would require relocation of 

approximately seven businesses, 60 single-family residences, and a large above-ground storage 

tank. This includes for construction of a perimeter road along the outside of the railroad fence 

that would provide north-south connectivity within the remaining neighborhood. It accounts for 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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placement of a barrier wall for terminal security and noise reduction purposes. Any additional 

buffering would require acquisition of more residences and possibly businesses. It is presumed 

the gate would remain in its present location. Presently Fair Park provides some buffering to the 

community. This park would also be acquired by an expansion to the west. This would be a 4(f) 

impact. 

Due to the large number of relocations that would be required and the taking of Fair Park, 

expansion to the west is not a feasible and prudent alternative. 

Expansion to the South and East into Detroit 

Expansion into the Detroit neighborhood south of Eight Mile Road and east of the railroad tracks 

would involve acquisition of seven businesses and 90 single-family homes. Locating the gate 

east of the railroad tracks must be at a sufficient distance from the railroad overpass on Eight 

Mile Road to allow for safe movements. This adds to the footprint of the site. Additionally, such 

an expansion would require the total acquisition of Hunt Playground (about 6 acres in size). This 

would be a 4(f) impact. 

Due to the large number of relocations that would be required and the acquisition of Hunt 

Playground, expansion into the Detroit neighborhood east of the railroad tracks and south of 

Eight Mile Road is not a feasible and prudent alternative. 

6.6 Measures to Minimize Harm 

A number of measures to minimize harm apply to all sites. Prior to construction, MDOT will 

establish a permanent record of the history and current conditions of sites determined to be 

eligible for the National Register of Historic Places in conjunction with the SHPO. This 

consultation will also guide the appropriate level of detail of the documentation. MDOT will 

provide original copies of the documentation with photos to the SHPO and appropriate local 

archives designated by the SHPO. MDOT will also work with the SHPO to develop context 

sensitive design measures near historic sites (see draft Memorandum of Agreement [MOA] in 

Appendix C). 

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

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. Alternative 4, the Composite Alternative, where three railroads are 

consolidated at the Livernois-Junction Yard and the CN/Moterm terminal is improved/expanded 

was created to further reduce impacts in the Livernois-Junction area compared to Alternative 3. 

Alternative 4 will require approximately 120 fewer acres at the Livernois-Junction Yard than 

Alternative 3. But, even with this minimized alternative, the Michigan/General Box Company 

(Spranger/Detroit Wire Wheel Corporation) is required to meet the future intermodal capacity 

need. 

6.6.2 Federal Screw Works Factory 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. But, even with this minimized acquisition area, the Federal Screw 

Works Factory is required to meet the future intermodal capacity needs. 

6.6.3 Markey House 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. With this minimized acquisition area, the Markey House is not 

required. However, the demolition of the Federal Screw Works Factory across the street would 

still result in an adverse visual effect. 

6.6.4 Tomms House 

At the outset of the project the concept for intermodal consolidation in the area of the LivernoisJunction Yard called for acquisition of 700 to 800 acres north of John Kronk. Analysis reduced 

this to 384 acres for Alternative 3, which would consolidate all four major railroads at the 

Livernois-Junction Yard. With this minimized acquisition area, the Tomms House is not 

required. However, the demolition of the Federal Screw Works Factory across the street would 

still result in an adverse visual effect. 

6.6.5 Michigan Central Railroad Bridge Deck 

Alternative 2 Improve/Expand the existing terminal at CP/Expressway would adversely affect the 

Michigan Central Railroad Bridge Deck because railroad tracks would be added on it. The bridge 

deck is part of the existing intermodal terminal at CP/Expressway. Minimizing the acquisition 

areas required for an improved/expanded terminal would still require alteration of the bridge 

deck. 

6.6.6 Michigan State Fairgrounds

Alternative 2 Improve/Expand the existing terminals and Alternative 4, the Composite 

Alternative, where three railroads are consolidated at the Livernois-Junction Yard and the 

CN/Moterm terminal is improved/expanded at the Michigan State Fairgrounds would both 

require land from the State Fairgrounds. Because no alternatives to expanding the CN/Moterm 

terminal without using the Fairgrounds were feasible and practical, efforts were made to 

minimize the impact on the Fairgrounds property. This area is labeled as “Railroad Lot” on 

Fairgrounds’ maps. No active public or private recreation areas would be taken. The land that 

would be used at the Fairgrounds property is currently leased for the parking of new automotive 

vehicles prior to shipment. Prior to this use, the area in question was used as a private racetrack, 

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

In an effort to minimize impacts, the area for expansion of the CN/Moterm terminal has been 

reduced to approximately 35 acres from 50 acres. Coordination has occurred with the 

Fairgrounds management on where to place the terminal expansion, how to design the terminal, 

and on how to mitigate impacts in a way that is sensitive to the Fairground’s needs, including 

replacement parking needed during the annual State Fair. Consultations will continue with the 

official with jurisdiction over the Fairgrounds to determine necessary agreements to use the 

Fairgrounds. 
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6.7 Coordination 

Effects of the proposed action, the alternatives considered, and the proposed measures to 

minimize harm have been reviewed by and developed in consultation with the SHPO, and 

discussed with property owners (all of whom have been contacted in the course of the analysis) 

and the official having jurisdiction over the State Fairgrounds. FHWA will provide information 

to the Advisory Council on Historic Preservation for their review and comment. MDOT has 

conducted extensive owner interviews to complete the historic property inventory and held the 

following meetings, to which the public was invited: 

• July 11, 2002 – LASED Youth Center. (Total attendance 50.) Purpose: To introduce the 

Environmental Impact Statement process. 

• August 15, 2002 – DIFT Information Office, 2722 Livernois Avenue. (Total attendance 

20). Purpose: To discuss how to improve the appearance of the west side of Livernois 

Avenue at the yard entrance. 

• February 24, 25, 26, and 27, 2003 – The Community House, Edison Oakland Public 

School Academy, MDOT Detroit Transportation Service Center, and LASED Youth 

Center. (Total attendance 110.) Purpose: To discuss Illustrative Alternatives. 

• September 15, 16, 17, and 18, 2003 – The Holiday Inn in Grandmont, Edison Oakland 

Public School Academy, Michigan Conference of Teamsters Welfare Fund, and 

Dearborn P.D. Training Room. (Total attendance 310.) Purpose: To discuss Practical 

Alternatives. 

• March 29, 30, 31, and April 1, 2004 - The Michigan State Fairgrounds, The Holiday Inn 

in Grandmont, IBEW Local 22, and LASED Youth Center. (Total attendance 400.) 

Purpose: To discuss Practical Alternatives. 

Two scoping meetings were conducted – September 19, 2002 and June 4, 2003. The first scoping 

meeting included a bus tour of the area around the Livernois-Junction Yard/CP Expressway 

terminal. The second scoping meeting was held after the number of alternatives increased from 

two to three to include the Improve/Expand Alternative. Each scoping meeting included a public 

comment period. 

In addition to the public meetings, the DIFT Local Advisory Council was formed of community 

representatives. It met 30 times between June 2002 and October 2004, inclusive. Each meeting 

was open to the public and provided for public comment. A tour was conducted for the public of 

the areas around intermodal terminals in Southwest Detroit and Melvindale as part of the July 11, 

2002 public meeting. Another tour was conducted of Chicago intermodal terminals on July 16, 

2002. Local Advisory Council members were invited to participate in March 2003 of a tour of 

Detroit area intermodal terminals. 

The public engagement process also involved many small group/one-on-one meetings requested 

by the public or set up by MDOT. 

Historic resources have not been raised as a concern by the public at these meetings. Several 

people who attended the March 29, 2004 meeting at the Michigan State Fairgrounds commented 

that they would like to see the current leased parking/unused areas at the Fairgrounds converted 

into a metro park. 
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Coordination has been ongoing with the General Manager of the Michigan State Fairgrounds. 

Meetings with the General Manager have occurred on at least a half-dozen occasions from the fall 

of 2003 until August 2004 (refer to Page A-11). 

As part of the National Environmental Policy Act public involvement process, MDOT will 

continue to seek input concerning potential impacts and mitigation choices. 

A public hearing will be held after publication and distribution of the Draft EIS/Draft Section 4(f) 

Evaluation. The public hearing will provide an overview of the study and allow participants the 

opportunity to comment either on a comment form or to a court reporter. This document is being 

distributed to the appropriate federal, state, and local agencies, and will be made available for 

public review and comment for 60 days after the public hearing. 
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DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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SECTION 7

EARLY COORDINATION AND PUBLIC MEETINGS

7.1 Early Coordination

Scoping meetings were held September 19, 2002 and June 4, 2003 in Detroit for agencies and 

local entities. Prior to the meeting a scoping packet was mailed to those invited. A listing of 

those invited, those who attended and those who responded to scoping materials is found in 

Appendix A. Pertinent correspondence received by MDOT is also included in Appendix A, as 

are minutes of the scoping meetings. 

Comments received from federal and state agencies in response to early coordination are listed 

below. 

7.1.1 Federal Agencies 

• Department of Army, Corps of Engineers – stated, “As a result of the transfer of a portion 

of the Corps’ regulatory responsibilities to the Michigan Department of Environmental 

Quality (MDEQ), this site is no longer in the Corps’ jurisdiction. Therefore, we 

recommend that you contact Ms. Peg Bostwick, Lake and Stream Protection Unit, Land 

and Water Management Division, MDEQ for a determination of State permit 

requirements.” 

7.1.2 State Agencies 

• Michigan Department of Natural Resources, Wildlife Division – noted, “There are no 

known occurrences of federal- or state-listed endangered, threatened, or otherwise 

significant species, natural plant communities, or natural features at the locations 

specified.” 

• Michigan Department of Agriculture – noted, “Since the construction of the proposed 

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

developed part of the state, no adverse impacts to agriculture are anticipated.” 

7.2 Public Meetings 

Engagement of the public in preparing the Draft Environmental Impact Statement involved a 

series of meetings. Each included mailings to between 5,000 and 25,000 residences and 

businesses – the mailings increased as the alternatives expanded in number to include terminal 

sites at CP/Expressway, CP/Oak and CN/Moterm as well as the Livernois-Junction Yard. From 

the outset, the mailings, as well as all printed literature available at public meetings, were 

provided in English, Spanish and Arabic. Spanish and Arabic translators were available at each 

public meeting. The meeting format used was both Public Forum and a combination of Public 

Forum and Town Hall meeting. The public meetings are as follows: 

• July 11, 2002 – LASED Youth Center. (Total attendance 50.) Purpose: To introduce the 

Environmental Impact Statement process. 

• August 15, 2002 – DIFT Information Office, 2722 Livernois Avenue. (Total attendance 

20). Purpose: To discuss how to improve the appearance of the west side of Livernois 

Avenue at the yard entrance. Open May 2002 to May 2003. 
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• February 24, 25, 26, and 27, 2003 – The Community House, Edison Oakland Public 

School Academy, MDOT Detroit Transportation Service Center, and LASED Youth 

Center. (Total attendance 110.) Purpose: To discuss Illustrative Alternatives. 

• September 15, 16, 17, and 18, 2003 – The Holiday Inn in Grandmont, Edison Oakland 

Public School Academy, Michigan Conference of Teamsters Welfare Fund, and 

Dearborn P.D. Training Room. (Total attendance 310.) Purpose: To discuss Practical 

Alternatives. 

• March 29, 30, 31, and April 1, 2004 - The Michigan State Fairgrounds, The Holiday Inn 

in Grandmont, IBEW Local 22, and LASED Youth Center. (Total attendance 400.) 

Purpose: To discuss Practical Alternatives. 

Two scoping meetings were conducted – September 19, 2002 and June 4, 2003. The first scoping 

meeting included a bus tour of the area around the Livernois-Junction Yard/CP Expressway 

terminal. The second scoping meeting was held after the number of alternatives increased to 

include the improving/expanding existing intermodal terminals in addition to the No Action and 

Consolidate options. Each scoping meeting included a public comment period. 

In addition to this series of public meetings, the DIFT Local Advisory Council was formed of 

community representatives. It met 30 times from June 2002 to and including October 2004. 

Each meeting was opened to the public and included a public comment period. Local Advisory 

Council members, and others, participated in the August 2002 tour of intermodal facilities in 

Chicago (59th Street, Corwith and Willow Springs terminals); as well as the March, 2003 tour of 

Detroit area intermodal terminals. The public at large was provided the means to tour the areas 

around intermodal terminals in Southwest Detroit and Melvindale as part of the July 11, 2002 

public meeting. Another tour was conducted of Chicago’s intermodal terminals on July 16, 2002. 

The public engagement process involved many small group/one-on-one meetings requested by 

the public or set up by MDOT. It also provided a Web site and 800 number to access information 

at any time. 

7.2.1 Interview Process 

One component of the community inventory effort was an outreach/interview process that 

contacted the various populations involved in this analysis to define issues/services/facilities 

serving these groups. More than half of the 110+ individuals/groups contacted participated in the 

interviews. The following summarizes the results of those discussions. 

Overall, the strongest characteristics of the terminal area communities are their resiliency, ethnic 

diversity, local shopping districts, and residential neighborhoods. However, each community is 

not without its share of challenges. The infrastructure is also in need of repair, and new strategies 

are needed to retrofit land uses, while preventing deterioration of neighborhoods. The housing 

stock dates back to the early 1900s. The areas’ lack of suitable housing has sparked a 

revitalization of older housing. 

The residents of each terminal area are neighbors with industry and heavy freight traffic. The 

history of each community has always involved industry. This industrial history has left a legacy 

of the mixture of incompatible land uses. Many buildings that once provided economic security 

to area residents are now vacant. As a result, many of the owner-occupants of residential units 

are not resistive of a move, as determined by interviews. 
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Two of the three terminal areas have experienced continued decline as has the City of Detroit 

itself. Recent data indicate the City of Detroit has lost an additional 40,000 people between 2000 

and 2003 putting its current population at 911,000, the number of people in Detroit around the 

time of World War I. Nevertheless, southwest Detroit and the Livernois-Junction Yard terminal 

area have experienced a resurgence. This has resulted in many new locally-owned businesses. 

They range from family-owned bakeries to large-scale manufacturing operations. Evidenced by 

the amount of renovated storefront businesses, homes, and “new” commercial development along 

the main thoroughfare of W. Vernor Highway, it is clear that the community is revitalized. 

Community cohesion is a concern here and in the two other terminal areas. 

Livernois-Junction/CP Expressway Terminal Area 

Over two dozen groups/individuals in the Livernois-Junction/CP Expressway terminal area were 

interviewed (Table 7-1). The most-frequently cited community facilities are schools and places 

of worship. Important organizations mentioned include the Arab Community Center for 

Economic and Social Services (ACCESS), Community Health and Social Services (CHASS), 

Detroit Hispanic Development Corporation (DHDC), LA SED, Latino Family Services, and 

Mexicantown Community Development Corporation. Social groups mentioned are the Puerto 

Rican Club, the Yemen Social Club and Kemeny Recreation Center. 

Issues of interest include the need for education (including English as a second language), jobs 

and job training, and personal security. A number of groups cited health care, housing and 

sustaining the area’s revitalization (both housing and commercial development, including small 

business development) as key concerns. The continued importance of W. Vernor Avenue as a 

neighborhood commercial corridor was mentioned as a matter of importance. And, replicating 

that success on Michigan Avenue was cited. 

Projects in the area that are emerging include the Riverfront Revitalization and Reuse of Tiger 

Stadium, the Mercado/Welcome Center at the Ambassador Bridge Gateway, the housing 

revitalization near Roberts Avenue in East Dearborn, and many smaller housing and commercial 

projects. 

Traffic, especially heavy-duty truck traffic in the area, was often mentioned as a concern. So are 

the related environmental issues, particularly pollution and its relationship to asthma. The latter 

is of concern because many people in the terminal area have little or no means to pay for health 

care/medications. 

CP/Oak Terminal Area 

 

Four groups/individuals were interviewed to discuss community facilities and services in the 

CP/Oak terminal area (Table 7-2). Here, too, places of worship were cited as key 

institutions/facilities. Others noted include the North Rosedale Community House and O’Shea 

Recreation Center. Key service programs are Head Start as well as the Police Athletic League. 

Issues of significance include stabilizing housing in the area, addressing crime and trash. Traffic 

was also cited as an issue. The rail yard and related activities were not singled-out as a particular 

concern. It was noted the railroads have the potential of being a good neighbor in the community. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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Table 7-1 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

African American Arab Arab Arab H

Key Population 

Group 

Issue Original United Citizens of SW Detroit Dr. Nabeel Abraham, Professor @ Henry Ford Community College Congress of Arab Organizations of Michigan ACCESS CHASS - C

and S

FACILITIES WHICH SERVE THE KEY POPULATION: 

Kemeny Recreation Center, parks, schools, Neighborhood City Hall, roller rink, 30+ churches in the area. There is a Critical Care Unit in the city of Lincoln Park that serves area residents. 

Two Yemen social clubs in the area, the mosque, retail district and schools (Star and Salina). 

None Recorded The mosque at 9945 W. Vernor, 

Star Academy on Lonyo, new housing near Roberts, new/expanded school for all grades on Wyoming. 

Schools, churecreation cedistricts. 

SERVICES FOR THE KEY POPULATION: 

Kemeny programs for seniors. ACCESS, various mosques 

around Detroit. Dearborn is enclave of Arab community. In Salina's school area, there is Yemeni population. 

The National Conference for Community and Justice provides cooperation between law enforcement and the community and helps build bridges within the community 

ACCESS with its many services, e.g., academic enrichment, family literacy, youth recreation, career development, community health and research, social services, employment training, cultural arts. 

Increase in pupper respiraSoccer leaguHedwig Park and Otis. RoParks may bof the trucks

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Unemployment for young people in their 20s and 30s. 

Physical improvements to the area. Jobs for the Yememi community, Homeland security and prejudicial treatment. 

None Recorded Area is very special in that it is 

the magnet for working-class Arabs worldwide to begin a new/better life. Revitalization is ongoing with new/refurbished homes, expanding schools to serve the growing population. It is not to be negatively impacted by traffic, and negative environmental factors, like air pollution. 

Air quality, apollution. InLoss of housmobility due traffic. Thredevelopment

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Commercial development to support residents in the area. Park development. 

The area is vibrant. Economic opportunities for those who are energetic. 

More commercial and residential development 

Community will continue to grow. It must not be set back by poorly designed projects. 

Building of nHealth and S(CHASS) facpatient flow. 

OTHER ISSUES: Environmental issues that affect 

the area. The possibility of truck traffic causing more problems with prostitution along Fort Street between Schaeffer and Outer Drive. Jobs that could result because many young men and women or young families need employment. 

None Recorded None Recorded The community only has three 

access routes: Lonyo, Wyoming and Vernor/Dix. Closing Lonyo, more trucks on Wyoming and drainage problems on Vernor/Dix do not serve the Arab community well. 

Fort St. Busibeing develocommercial jobs need to 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Hispanic Hispanic Hispanic Hispanic Native Americ

Group 

Issue Dominican Consulate LA SED MCDC ROCA Eternal Church American Indian H

Social Servic

FACILITIES WHICH SERVE THE KEY POPULATION: 

Evangelical churches in SW Detroit and St. Stephens on Central. 

Churches, LA SED, other nonprofits in the area. Cesar Chavez schools, Latino Family Services, W. Vernor 

Commercial district, Michigan Avenue commercial district, MCDC District, Bagley Housing, BUOY 3, Roberto Clemente Recreation Center, Bowen Branch library, all Catholic churches especially the churches with schools. 

Religious institutions that assist community residents with a variety of services. 

The Native American on Lawndale serves thAmerican community throughout the Metro area. 

SERVICES FOR THE KEY POPULATION: 

Immigration processing has become much more difficult since 9/11. 

Senior transportation to services, information referral, food and friendship programs. 

Housing Development, jobs and economic development in the business district that employ people from neighborhoods. Economic development in the commercial districts. 

Religious counseling, job referral, housing opportunities. 

Health screenings, subabuse counseling, youmentoring programs, espiritual gatherings. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Lack of education and training. English is an impediment amongst Dominicans. 

Senior transportation and translation 

Crime and the need for education. 

Lack of education; learning English can be problematic for some. Employment opportunities are bad. Lack of available housing in this neighborhood forces people to locate outside the city of Detroit. 

Uses of the land relateDetroit Intermodal FreTerminal Project. Cuthe American Indian hspiritual connection wland and does not wanfurther damaged by inuses. Pollution of the that will be entering th

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The lack of jobs with decent pay. 

Access to services and jobs. Locally-owned businesses, a 

strong workforce and the new image of Southwest Detroit as a stable and growing community. 

Concern about jobs. Improvements to the 

community such as hoaccess to health care, cleanliness and respecrights of people. 

OTHER ISSUES: None Recorded Does not see the benefits of the 

DIFT because the railroad terminal will eventually deteriorate. If nothing happens to fix the terminal it will only get worse. The truck traffic throughout the community affects the structural integrity of the businesses and homes. 

None Recorded Need for jobs. None Recorded 
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Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Polish Other Other Other 

Group 

Issue St. Stephens Bagley Housing Bridging Communities Casa Maria 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches including St. Stephens which has a school K-8 of mostly Hispanic children. Twenty years ago the school was primarily Polish. 

Churches and schools and the different social services agencies in the community. 

Bridging Communities directly serves the elderly. 

None Reported 

SERVICES FOR THE KEY POPULATION: 

Religious counseling and education. 

Housing rehabilitation and new home construction for low-income families and seniors. 

Outreach programs to the elderly by pairing young and elderly people as well as making neighborhood improvements. 

Casa Maria provides after-school programs for children as well as prescription/medication referral. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The Polish community has gone down in number because they are an aging population. Transportation for the seniors is an issue. 

Environmental issues and traffic congestion. The DRTP proposal that would take trucks off the roads and put them directly on the freeway. 

Violence (in all forms). Need to improve transportation, health care and support services, like the Family Independence Agency. 

Housing and health care needs. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The Polish community is no longer large in parish. 

Rehabilitation of the MC Depot because it affects the business environment of the area. 

Strong commercial and residential revitalization by newly-arrived people which improves the city’s tax base and the overall quality of life in the neighborhoods. 

Grant funding is not available 

OTHER ISSUES: The church is located on 

Central Avenue which has a lot of heavy truck traffic. 

SW Detroit is continuing to grow and any plans should take into account the changing nature of the community's ethnic diversity and the needs that result from that. 

None Recorded None Recorded 
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Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Other Other Other Other Other 

Group 

Issue 

Family Support Team 

of 

SW Detroit 

Holy Redeemer Catholic 

Church Hope Evangelical Ministries Hubbard Richard CDC Michigan Avenue B

Association 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches, schools and shopping along Vernor. Revitalization of Michigan Avenue shopping. 

None Recorded Churches, schools. Grocery stores, restaurants 

along Bagley and Vernor, Saint Anne’s Church, Webster school, Roberto Clemente Center, Matrix Theatre, Bagley Housing, MCDC, BUOY 3 Center. 

Schools, churches, BoGirls Club, 

SERVICES FOR THE KEY POPULATION: 

Various non-profits in the community that provide social services for families. 

Churches and schools. Church-provided services None Recorded Habitat for Humanity, 

planning to build 60 hWest Grand Blvd. and Michigan Avenue. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

DIFT's affect on mobility and travel for area residents as a result of more trucks in the community. Physical separation caused by the DIFT. 

Increased rates of asthma attacks. The dust from the Livernois Yard can be mitigated by paving, but still concerned about the emissions from increased number of trucks. Underpasses need to be clean and well lit. The idea of the railroads being good corporate citizens is key. 

Lack of employment opportunities, inability to attract major food chains or large-scale development. 

The Detroit River Tunnel and Ambassador Bridge plans, air quality, deterioration of infrastructure, health care, immigration and English as a second language, housing and employment. 

Trucks, prostitution, aair pollution. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

New housing developments. Safer and sustainable communities. A family-orientated community. 

The presence of the railroads and the infusion investment should help the community improve itself. Southwest Detroit can be a national model for neighborhood redevelopment that demonstrates a post-industrial community that rebounds to become a place where residents both live and work. Southwest Detroit is a place of cultural strength, a place of diversity. 

Dismal outlook unless some major project comes to the area. 

Small business and commercial growth, more population growth, sustainable neighborhood not dependent upon big box, franchise-owned companies. 

More Hispanic businethe future. A Family DStore, (mini K-mart). lighting for 2 1⁄2 miles Livernois and WyomiMichigan. Buffers beindustry and commun

OTHER ISSUES: DIFT may pose some 

threat to potential developers and investments. 

None Recorded The area is suffering from lack 

of economic investment. The DIFT facility would positively affect the area with support businesses. 

Increase in trade and commerce will offer benefits to the region, but to the smaller community there will be little rewards. The community views the DIFT as some sort of exploitation. 

There should be a plan infrastructure improvestandards need to be into accommodate the gtrucking in the area. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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Table 7-1 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Livernois-Junction/CP Expressway Terminal Area 

Key Population Other Other Other Other 

Group 

Issue Our Lady Queen Of Angels Patton Park Southwest Detroit Business Association Southwest Detroit Improvement Associat

FACILITIES WHICH SERVE THE KEY POPULATION: 

CVS, auto repair stores, grocery stores and the Michigan Avenue Corridor. 

Patton Park, Romanowski Park, Holy Cross Cemetery. 

Churches both Catholic and Pentecostal, parks, MCDC, commercial areas, the W. Vernor Commercial District, schools (Public, Private, and Charter). 

Churches and schools, as wemany non-profits, that providservices. The restaurants in tare important because they plocal economic and cultural benefits. 

SERVICES FOR THE KEY POPULATION: 

Churches, the Boys and Girls Club. 

None Recorded Restaurants and stores that provide 

unique cultural goods for the Hispanic community as well as the churches that provide Mass and services in Spanish. 

Agencies such as LA SED, DLatino Family Services and oDocument preparation, job reservices, crisis intervention, hreferral. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The biggest issues in the community deal primarily with trash, break-ins to private property and prostitution on Michigan Avenue. For the Hispanics, immigration and naturalization is a continuing problem, as well as employment opportunities. 

Environmental impacts associated with the DIFT. Loss of community base. SW Detroit has been a dumping ground for industry. The continued dumping will destroy the revitalization that is taking place in the neighborhoods. Social/economic disservice to the minorities in the community. Closing Lonyo by the DIFT project will impact the people who attend the soccer league games at the parks. Increased truck traffic will hamper residents ability to travel through the community. Loss of housing on Lawndale, Trenton and Cabot. 

Air Quality. A healthy environment promotes stability for community residents. The dust at the Livernois Yard is a problem. Central and Livernois connectivity. Clark Park renovation (Ice Rink). 

Unemployment, there is no wbe found in the immediate arPeople have to travel outside to seek employment. Affordarent. Health care is a big probbecause many Hispanics are uninsured in the area. Asthmother types of ailments. Enga second language. As it relathe DIFT, community’s concare the projected numbers of and the routes of traffic. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Renovation of housing and reestablishment of business along Michigan Avenue. This growth is primarily due to the Hispanic population. Every so often, a new business emerges along Michigan Avenue. 

SW Detroit has an integrated community where people get along, raise families in ethnically diverse neighborhoods, supported by schools, community activities. 

The "bow-tie" development at Vernor/Livernois. The Mexicantown Welcome Center and major rehabilitation of four buildings along W. Vernor. The Greenway network and links connecting different parts of the community. New businesses opening in the community. Soccer leagues continue to grow in popularity. 

Community growth. The areattractive because it’s known Hispanic neighborhood and ta sense of comfort for Hispanthe area. 

OTHER ISSUES: The Polish community has 

migrated out of the area. 

Area is a dumping ground because of industry. Why don't they put the DIFT in Auburn Hills? 

The cultural diversity of the area must be protected as well as the retention of young people. Must protect jobs that can be potentially lost due to the creation of a DIFT. 

None Reported 

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

7 - 9

Table 7-2 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews CP/Oak Terminal Area 

Key Population Other Other Other 

Group 

Issue

Far Northwest Neighborhood 

City Hall 

Grandmont Rosedale 

Development Corporation Southfield/Jeffries Business Association West Wa

FACILITIES WHICH SERVE THE KEY POPULATION: 

Churches along the Southfield Freeway. 

The North Rosedale Community House, The North Rosedale Park and a variety of churches. 

River Rouge Park and the Churches on Southfield. The O'Shea Rec

American Indian Warren and the 

SERVICES FOR THE KEY POPULATION: 

None Recorded Headstart Programs and a PAL 

(Police Athletic League) football team that practices and plays in Stobel Park. 

The churches are very active with the community and provide social activities. Sunday at church is an all-day event; parishioners arrive for services in the morning and stay until the late afternoon. 

The large churchorganizations prbreakfast for sencommunity forutrash pick-up sy

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

None Recorded The lack of city services and 

the quality of the schools. Air quality. The Southfield Freeway, which is one of the busiest freeways in the nation. High incidents of asthma. 

Traffic. Trucks using the intermodal facility travel through residential areas to get to the yard. A truck-only road for the CP/Oak facility would benefit the community and should be designed so that local business can use it as well. A good sound wall is needed as is better lighting in the yard. 

Crime, lighting, trash. 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Stabilization of housing and the increase of housing and commercial development. 

A stable neighborhood with room to grow. If the city services are improved, the community will grow. 

This area has never deteriorated and the city is constantly updating and fixing the area with grants. Main concern is traffic. 

Neighborhood cis to get the trash to maintain their moving in, fillin

OTHER ISSUES: There are no parks, schools or public 

places around the CP/Oak terminal area. 

Traffic is bad on both the residential and city streets. 

The railroad can be a good neighbor to the community. The rail yard should complement the neighborhood and be aesthetically pleasing. 

A stable and divnationalities live are moving in. 

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

7 - 10

CN/Moterm Terminal Area 

Eight groups/individuals were interviewed in the CN/Moterm terminal area (Table 7-3). Again, the 

places of worship and schools (including the seven schools in Ferndale) were frequently cited as 

important community facilities. Additional facilities of community importance are the Kulick and 

Tindal Centers in Ferndale, the State Fairgrounds, and housing centers (like the Hilton Apartments) 

that serve the elderly and those of lower income. Frequently mentioned in the interviews was the 

Chaldean community in terms of its facilities and services as well as the energy offered in 

revitalizing the housing and business activity in the area around Seven and Eight Mile Roads, 

Woodward and John R. 

Issues of importance in this terminal area are sustaining the development, along Woodward 

Avenue in both Ferndale and Detroit and revitalizing Eight Mile Road. Concerns about railroad 

terminal operations, including possible expansion of the CN/Moterm rail yard, include: the 

blocking by trains of traffic movements including school buses and emergency equipment; noise; 

air pollution; increased truck traffic; depreciation of housing values; and, the threat to desired 

developments at the State Fairgrounds (i.e., a Huron Metro Park) and at the southeast corner of 

the intersection of Woodward Avenue and Eight Mile Road. The potential of the expanded 

intermodal terminal thwarting those desired projects was stressed as a concern. 

Other Organizations 

A dozen groups/individuals not specifically focused on a terminal area were also interviewed to 

provide an overview of social/cultural issues of key populations in general (Table 7-4). When 

addressing the German, Irish and Polish communities, the clear indication is the decline of 

concentration of these ethnic groups and the services/facilities/organizations, including places of 

worship, to support them. A review of Table 4-12 echoes that trend as all non-minority ethnic 

groups, except the Arab community, declined in the Detroit Urbanized Area in the 1990s. Most 

significant among these are the Irish, German and Polish. This trend is repeated, but with less 

significant declines, in each terminal area. 

Views by non-terminal area-based groups that are focused on African American issues, indicate 

concern about jobs, job training, crime, and health care/substance abuse. Those non-terminal 

groups that are focused on Hispanic issues also view employment, education, crime and health 

care as key concerns. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

7 - 11

Table 7-3 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

CN/Moterm Terminal Area 

Key Population Arab Arab Other Othe

Group 

Issue Chaldean Sacred Heart Arab American & Chaldean Council Bagley Association Eight Mile Boulev

FACILITIES WHICH SERVE THE KEY POPULATION: 

Facilities that serve the Chaldean community between Woodward Avenue and John R. on Seven Mile -- ethnic grocery stores, education centers and restaurants that are Chaldean owned and operated. 

Arab American & Chaldean Council. 

Shopping along Eight Mile, Seven Mile and Livernois. The schools, churches and homes of the area are all important considerations. 

The many storefront businesses Chaldean community along Sevopportunities to the area's residCommunity Center. 

SERVICES FOR THE KEY POPULATION: 

A variety of services ranging from transition and immigration to education and business entrepreneurial efforts. 

Employment training, teen programs, behavioral health, dental care, youth center and computer lab. 

The church-based programs including those for abused women. 

Those provided by schools and Center. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Many Chaldean families are moving back to Detroit and specifically that area between Seven and Eight Mile Roads, Woodward and John R. 

Revitalization of Chaldean Town. 

Empty buildings along Wyoming, Livernois, and Seven Mile. The reduction of city services because of budgetary issues. 

Deterioration of the roads as a volumes and an ongoing lack oconditions may result in a deterbase. The projected DIFT deveanything that appears to be aest

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Chaldeans develop businesses that can support industry. 

Cooperation from city, state, and federal governments to improve infrastructure. Want the area to be shopper friendly and a destination, like Greek Town. 

Small business development along Livernois. Small-scale industrial or manufacturing businesses. 

The proposed Outlet Center decorner of Woodward and Eight Woodward bridge down. Use oresidential development. 

OTHER ISSUES: None Recorded Funding of Chaldean programs. None Recorded The diversity of the area. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

7 - 12

Table 7-3 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

CN/Moterm Terminal Area 

Key Population Other Other Other 

Group 

Issue Ferndale Public Schools Ferndale Chamber of Commerce Hazel Park 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Seven public schools and one charter school in the City of Ferndale. The closest school to the railroad terminal in Ferndale is Wilson Elementary. 

The commercial and residential developments along Eight Mile Road. Woodward and Nine Mile are the life blood of the city. 

None Recorded Strong resid

along Eight Seven Mile. Fairgroundsrecreational industrial areof the CN/MHilton ApartThe Chaldearesidential acommunity cawarded to t

SERVICES FOR THE KEY POPULATION: 

Education. None Recorded The Chaldean community is growing in both 

residential and business areas. The Chaldeans have a social club called the Eastern Palace, which is located on the west side of John R. There are some new businesses off Nine Mile on John R on the west side that are Chaldean owned and operated. 

Various comsummer, WoNational He

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

The school system has bus routes that cross railroad tracks at the following locations: Hilton Rd., Nine Mile, Camborne and Woodward Heights. Trains that block traffic are a problem because they cause delays for commuters and school buses. 

The main issue of concern related to the DIFT is the possible affects of loss of housing or businesses if the expansion were to happen inside the city of Ferndale. 

Webster School is very close to the DIFT expansion area in the Fairgrounds. 

The main isspollution (aitraffic, depredevelopmentax base. In affected becRoad. AffecFairgroundsthe GovernoHomeland selack of fundappearance oand Detroit. the DIFT pro

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

Loading and unloading of trains should be restricted during school hours. School buses are assigned to use Eight and Ten Mile Roads to avoid the tracks as much as possible. 

The City of Ferndale is land locked to the point that the only way to build new is to knock down old. 

The city is 100% developed. Any efforts to construct in Hazel Park would involve redevelopment. The race track is the only "open" area that can be redeveloped. However, it is privately owned and the owners can do what they feel is necessary for their business. 

Huron Metro 

OTHER ISSUES: None Recorded There are no ethnic enclaves in 

the City of Ferndale. 

Against the DIFT because it is incompatible with the residential character of the area and it will have an adverse environmental impact on the western residential areas of Hazel Park. 

Ferndale is vbackgroundsthat celebratattend annua

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

7 - 13

Table 7-4 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population African American African American African American 

Group 

Issue Alkebulan Village Black Family Development Operation Get Down Detroit 

FACILITIES WHICH SERVE THE KEY POPULATION: 

4 H Club, Sub-Center None Recorded Every Organization The Germ

throughouGermans cChrysler t“Carpathilocated beMile Road

SERVICES FOR THE KEY POPULATION: 

Sub-Center provides youth programs, and after-school programs. Operation Get Down provides emergency services and shelter for people that have drug abuse problems. 

None Recorded Wide range of Issues This organ

Aid Sociewith medimembers 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

There needs to be more jobs and job training. Utility companies have to have more sensitivity in the winter months, helping people pay their bills and not shutting off their water and heat. 

The low number of Spanish-speaking officers in the police departments and the lack of Latino representation on City Council. 

Substance abuse, education and mental health 

The lack ofrom Eurofor many rthe lack of 

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

If jobs and job training do not improve, the community will die. 

Include Spanish in curriculum. Teaching Spanish will open up Central and South America to create a radical economic impact on Detroit. 

Jobs, health issues, social services. The aging 

OTHER ISSUES: None Recorded Crime. Change from enforcement as 

solution to looking at societal solutions, such as unemployment and poverty. Change the city charter to balance between Mayor and City Council. Redistrict so that Latinos get fair representation on City Council. 

None Recorded The Germ
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

7 - 14

Table 7-4 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population German Hispanic Hispanic 

Group 

Issue

German-American 

Cultural Center 

Local Historian Osvaldo Rivera on Detroit 

Puerto Rican Community 

Wayne State University Chicano/ 

Boricua Studies Program 

FACILITIES WHICH SERVE THE KEY POPULATION: 

Carpathia Club The Catholic and Evangelical churches/schools. 

The Puerto Rican Club. 

Mexicantown Center, LA SED, Puerto Rican Club and churches in the area. 

GaOrTeon 

SERVICES FOR THE KEY POPULATION: 

None Reported Non-profits like LA SED and Latino Family 

Services. 

Access to education and family counseling Th

conalsJunbig

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

None Reported Education/crime/lack of political candidates 

running for office. 

Lack of employment. Recruitment by gangs to sell drugs due to a lack of employment. Lack of affordable health care 

Iriscou

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The German population is getting smaller because there are fewer Germans migrating into southeastern Michigan. 

Puerto Rican leaders don't see themselves in positions of authority mainly because in the Hispanic community they are the minority. 

Leadership of Latino leaders. Better Latino organizations 

No

OTHER ISSUES: None Recorded Non-profits like LA SED and Latino Family 

Services. 

None Recorded Th

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

7 - 15

Table 7-4 (continued) 

Detroit Intermodal Freight Terminal Project 

Summary of Interviews 

Outside of Terminal Areas 

Key Population Polish Polish Other 

Group 

Issue Hamtramck Historical Commission The Polish Weekly Covenant House Northe

FACILITIES WHICH SERVE THE KEY POPULATION: 

St. Florian Church. Polish American Veteran's Hall. 

Catholic churches throughout the area like St. Florian, St. Peter and Paul, St. Hedwig. The city of Hamtramck is a Polish enclave. 

Human Service agencies, parks, recreation centers, schools and churches.

Detroit Pimportaneducation 

SERVICES FOR THE KEY POPULATION: 

The Polish National Alliance. This Polish newspaper provides 

information on events and services. Restaurants, churches and PAV clubs in Hamtramck all provide socialization for the Polish people. 

Covenant House provides students with tutoring and shelter. 

There are specificaAsian coHmong cleader. 

ISSUES/CONCERNS AFFECTING THE KEY POPULATION: 

Concern about the future of Hamtramck. Older community of Polish people who 

need health care. 

Young people are dropping out of school at a high rate and trying to find work. This population is not being served at no fault of its own. The resources are just not being provided. Obtaining identification is sometimes a challenge for young people. 

Once an resources migrate iMacomb most impcommun

OPPORTUNITIES AHEAD FOR THE KEY POPULATION: 

The Polish community and organizations coming together to promote their culture.

Continued efforts to promote and preserve Polish culture 

Rehabilitation of homes and businesses is happening everyday on Vernor now on Michigan Ave. and to a lesser extent on Fort St. 

Many Asbusiness 

OTHER ISSUES: None Recorded None Recorded Does not know much about the DIFT 

only heard the negatives of pollution and increased truck traffic. Wants to see what the potential benefits for the community in terms of jobs and organization of truck traffic. 

None Re

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

7 - 16
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

8 - 1

SECTION 8 

LIST OF PREPARERS 

Michigan Department of Transportation 

Mohammed Alghurabi, Project Manager. B.S. in Civil Engineering, Wayne State University. 

11 years of experience in MDOT Design Division, five years’ experience at the Florida 

Department of Transportation (FDOT). Review of the entire EIS. 

Larry Karnes, Freight Policy Specialist. B.S. in Geography, Michigan State University; M.A. 

in Transportation Geography, Western Michigan University. Two years’ experience teaching 

Geography at The Ohio State University. Three years’ experience with the federal government. 

Four years experience as Chief Transportation Planner for the East Central Michigan Planning & 

Development Regional Commission. Twenty-four years’ experience in freight transportation 

planning with MDOT. Managed original conceptual planning effort. 

Geralyn Ayers, Environmental Coordinator. B.A. in Agriculture/Environmental Studies from 

Western Michigan University; 26 years' experience with the Michigan Department of 

Transportation in preparing environmental impact statements and assessments. Environmental 

Analysis Unit Supervisor, Project Planning Division. 

Robert Parsons, Public Hearings Officer. B.S. in Interpersonal and Public Communications, 

Central Michigan University. Sixteen years of experience in communications at MDOT. 

Coordination of the public involvement effort. 

William J. Swagler, Right-of-Way Estimate. B.A. in Business Management, Northwood 

University. Cost Estimator and Licensed Real Estate Appraiser, 27 years’ experience with the 

MDOT, Real Estate Division. Developer of the Conceptual Stage Relocation Plan. 

Other MDOT Personnel Assigned to this Project:

Michael Anglebrandt, Project Area Contamination Survey Review 

Lloyd Baldwin, Cultural Resources Review 

Sue Datta, Metro Region Representative, EIS review 

Jeff Edwards, Metro Region representative 

Tom Hanf, Air Quality Analysis Review, Noise Analysis Review 

Heather Hicks, Contaminated Site Analysis review 

Catherine Jensen, Traffic review 

Greg Johnson, Metro Region Engineer 

Lori Noblet, EIS Review and Community Impact Analysis review 

Sherry Piacenti, Real Estate 

Douglas Proper, Mitigation Review 

Kelly Ramirez, Conceptual Stage Relocation Plan 

Dave Ruggles, Archaeological Review 

Dave Schuen, Threatened and Endangered Species Review 

Frank Spica, Noise Analysis Review 

David Wresinski, Division Administrator 

Andrew Zeigler, Project review 

Tom Zurburg, Noise Analysis Review 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

8 - 2

Consultant Team 

The consultants performing the analysis for this environmental document have no financial or 

other interest in the project or its outcome. 

Joseph C. Corradino, Project Manager, The Corradino Group. B.C.E. Villanova University; 

M.S.C.E., Purdue University. Thirty-nine years of project management and environmental 

experience. Principal author of EIS and quality control on supporting Technical Reports. 

Jim Hartman, Traffic Projections and Analysis, The Corradino Group, B.S.C.E, Michigan 

State University. Thirteen years of experience in civil engineering planning with emphasis on 

traffic analysis. Traffic Report. 

Richard Ray, Transportation Planner, The Corradino Group, B.A., University of Iowa; M.S. 

Urban and Regional Planning, University of Iowa. Eight years of experience in transportation 

planning and NEPA documentation. 

Ted Stone, Environmental Manager, The Corradino Group. B.A., Northwestern University. 

More than 30 years experience in preparation of environmental documentation. Noise Technical 

Report, Air Quality Technical Report. 

Michael Tackett, Senior Environmentalist, The Corradino Group, B.S. and M.S. Forestry, 

University of Kentucky. Twenty-six years of experience in geology, soils, and contamination. 

Project Area Contamination Survey. 

Mark Butler, Planner, The Corradino Group, B.A., Boston College; M.S. Planning, Florida 

State University; M.P.A., Florida State University. More than five years experience in land use 

and development planning and transportation planning. Economic Impact Technical Report. 

C. Stephan Demeter, Senior Historical Archaeologist/Principal Investigator, Commonwealth 

Cultural Resources Group. B.A. Anthropology and History Wayne State University; M.A 

Anthropology, Wayne State University. Thirty years performing historic resource surveys. 

John Freeland, Wetland Analysis, Tilton & Associates, Inc., Ph.D., PWS. B.S. Grand Valley 

State University; M.S. University of New Hampshire; Ph.D. North Dakota State University. 

Fifteen years of wetland and integrated resource assessment. Wetlands Report. 

Deborah Schutt, Socioeconomic Analysis, Schutt and Company; B.A. Valparaiso University; 

M.S. Urban Planning Wayne State University. Twenty-seven years of management and planning 

experience. 

Randy Henke, Alfred Benesch & Company, B.S. University of Wisconsin-Madison. Twentyseven years experience in railroad engineering, planning and operations both internationally and 

domestically. Engineering Concepts Report. 

Michael Kunz, Alfred Benesch & Company, B.S. Marquette University. Three years railroad 

track layout and design. Engineering Concepts Report. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

8 - 3

Doug Strauss, Engineer, Alfred Benesch & Company, B.S.C.E., Michigan Technical University. 

Sixteen years of civil and roadway design experience. Engineering Concepts Report. 

Phil Walsh, Alfred Benesch & Company, B.E. University of Cantabury, New Zealand. Twentyone years experience in railroad engineering and management. Engineering Concepts Report. 

Terry Campbell, Analytical Planning Services, B.A., M.A., and M.U.A., Wichita State 

University, Ph.D., University of Southern California. Twenty-nine years regional economic and 

development planning. Economic Impact Technical Report. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

8 - 4
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

9 - 1

SECTION 9 

DISTRIBUTION LIST 

The following is a list of agencies, organizations, persons and organizations to whom this 

document has been sent: 

Federal Agencies

Environmental Protection Agency, Administrator, Washington, D.C. Environmental Protection 

Agency, Region V 

U.S. Department of Agriculture, Natural Resource Conservation Service 

U.S. Department of Commerce, Environmental Affairs 

U.S. Department of Housing and Urban Development, Area Director 

U.S. Department of the Interior 

U.S. Department of Transportation, Assistant Secretary for Policy and International Affairs (P-1) 

U.S. Department of Energy, Washington Office 

U.S. Department of Health and Human Services, Center for Disease Control and Prevention, 

National Center for Environmental Health 

U.S. Army, Corps of Engineers 

Federal Emergency Management Agency 

Federal Aviation Administration 

Federal Transit Administration 

Federal Railroad Administration 

State Agencies

Michigan Department of Agriculture 

Michigan Department of Environmental Quality 

Michigan Department of Natural Resources 

Michigan Department of History, Arts and Library, State Historic Preservation Office 

Michigan Department of Community Health 

Michigan Environmental Science Board 

Michigan Department of Labor and Economic Growth 

Michigan State Fairgrounds 

Local Jurisdictions and Agencies

Michigan United Conservation Clubs, Inc. 

Sierra Club 

Clean Water Action, Michigan 

Michigan Environmental Council 

City of Detroit 

City of Dearborn 

City of Ferndale 

Detroit Department of Transportation 

Oakland County 

Southeast Michigan Council of Governments (SEMCOG) 

Suburban Mobility Authority for Regional Transportation 

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

9 - 2

Oakland County Road Commission 

Wayne County Executive 

Wayne County Commission 

Wayne County Road Commission 

State Senator Hansen Clarke, District 1 

State Senator Irma Clark-Coleman, District 3 

State Senator Samuel Thomas, III, District 4 

State Senator Burton Leland, District 5 

State Senator Gilda Jacobs, District 14 

State Representative Marsha Cheeks, District 6 

State Representative Gabe Leland, District 10 

State Representative Steve Tobocman, District 12 

State Representative Gino Polidori, District 15 

State Representative Andy Meisner, District 27 

U.S. Senator Carl Levin 

U.S. Senator Debbie Stabenow 

U.S. Representative Carolyn Cheeks Kilpatrick 

U.S. Representative John Conyers, Jr. 

U.S. Representative Sander Levin 

U.S. Representative John Dingell 

Other 

CSX 

Canadian National Railroad 

Canadian Pacific Railway 

Norfolk Southern Railroad 

Ford Motor Company 

DaimlerChrysler 

General Motors 

Community Action Against Asthma 

Detroit Intermodal Freight Terminal Local Advisory Committee Members 

Ziibiwing Cultural Society, The Saginaw Chippewa Indian Tribe 

Detroit Intermodal Freight Terminal Local Advisory Council 
Appendix A

Scoping Meetings and Correspondence 

Section 1 

List of Those Invited to Scoping Meetings 

Section 2 

Correspondence Received in Response to Scoping 

Section 3 

Notes of Scoping Meetings 

Appendix A- Section 1 

List of Those Invited to Scoping Meetings 

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

A- 1

FEDERAL AGENCIES

Ms. Araceli (Raz) Baust 

Office of the Special Assistant for 

Transportation Engineering 

MTMCTEA 

Mr. Lester Berman 

Environmental Officer 

U.S. Department of Housing and Urban 

Development 

Mr. William Cooper 

Director 

MTMCTEA 

Mr. Craig Czarnecki 

Field Supervisor 

U.S. Department of the Interior 

Fish and Wildlife Service 

Mr. Joel Ettinger 

Regional Administrator 

Federal Transit Administration 

Mr. Laurence Hasvold 

Regional Administrator 

Federal Railroad Administration 

Mr. Kenneth Holt 

National Center for Environmental Health 

Centers for Disease Control 

Ms. Sherry Kamke 

U.S. Environmental Protection Agency, 

Region 5 

Mr. Robert S. Korpanty 

MTMCTEA 

Attn: MTTE-SA 

Colonel Daryl Lundy 

Department of Military & Veterans Affairs 

Mr. Gary Mannesto 

Chief 

Regulatory Office 

Department of the Army 

Detroit District, Corps of Engineers 

Mr. Ernie Quintana 

Acting Regional Director 

National Park Service, Midwest Region 

Ms. Vicki Rutson 

Acting Chief 

Section of Environmental Analysis 

Surface Transportation Board 

Mr. Dale W. Shipley 

Regional Director 

Federal Emergency Management Agency 

Mr. Kenneth A. Westlake, Chief 

Environmental Planning and Evaluation 

Branch 

Office of Strategic Environmental Analysis 

U.S. Environmental Protection Agency, 

Region 5 

Mr. Ronald C. Williams 

State Conservationist 

U.S. Department of Agriculture 

Natural Resources Conservation Service 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

A- 2

STATE AGENCIES

Mr. George Burgoyne 

Resource Management Deputy 

Department of Natural Resources 

Ms. Jan Christensen 

Interim Policy & Legislative Liaison 

Health Legislation & Policy Development 

Michigan Department of Community Health 

Mr. Brian Conway 

State Historic Preservation Officer 

Michigan Department of History, Arts, and 

Libraries 

Mr. Gerald Fulcher 

Geological & Land Water Management 

Division 

Department of Environmental Quality 

Mr. G. Vinson Hellwig 

Division Chief 

Air Quality Division, Department of 

Environmental Quality 

Mr. David C. Hollister 

Department of Consumer & Industry 

Services 

Lt. Colonel Tom Howko 

Michigan Department of Military and 

Veterans Affairs 

Ms. Teresa Seidel 

District Supervisor for Air Quality 

Southeast Michigan District Office 

Department of Environmental Quality 

Mr. Peter Trezise 

Senior Deputy Director 

Michigan Department of Community Health 

Lewis Cass Building, 6th Floor 

Mr. Dan Wyant 

Director 

Michigan Department of Agriculture 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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LOCAL AGENCIES

Dr. John Artis 

Superintendent 

Dearborn Public Schools 

Mr. Charles Barbieri 

Commander 

Detroit Police Department 

4th Precinct 

Mr. Harold Berry 

Fire Marshal 

Detroit Fire Department 

Mr. Michael Birrell 

Chief 

Fire Chief’s Office 

City of Dearborn 

Mr. Robert Brown 

Executive Director/Special Projects 

Detroit Public Schools 

Ms. Marsha S. Bruhn 

Director 

City Planning Commission 

Mr. Ulysses Burdell 

Interim Dept. Director 

Detroit Department of Public Works 

Mr. Michael Darga 

Wayne County Engineering, Design Office 

Mr. Warren Evans 

Sheriff 

Wayne County Sheriff Department 

Mr. Gary Fujita 

Deputy Director and Assistant Director 

Detroit Water and Sewerage Department 

Ms. Claryce Gibbons-Allen 

Director 

Detroit Department of Transportation 

Mr. Kurt Giberson 

Director 

Department of Public Works 

City of Dearborn 

Ms. Dorothy Gonzales 

Wayne County Office of Health and 

Community Services 

Ms. Joan Gumkowski 

Director 

Dearborn Health Department 

Mr. Patrick Hogan 

Wayne County Division of Roads 

Mr. Bob Hunt 

Wayne County Planning Division 

Mr. George Jackson 

Detroit Economic Growth Corporation 

Mr. Jeff Jones 

Law Department 

City of Detroit 

Mr. Frank Katarzis 

Dearborn Economic and Community 

Development 

Mr. Ken Kucel 

Wayne County Department of Services 

Division of Engineering 

Ms. Sarah Lile 

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

A- 4

LOCAL AGENCIES (continued) 

Ms. Patricia Linklater 

Chairperson 

Historic District Commission 

Dr. Noble Maseru 

Director 

Detroit Health Department 

Mr. John Nagy 

City Planner 

Mr. Carmine Palombo 

Director 

Transportation Programs 

SEMCOG 

Mr. Mohan Paruvakat 

Senior Assistant Traffic Engineer 

City of Detroit 

Ms. Josephine Powell 

Deputy Director, Compliance & Public 

Affairs 

Wayne County Department of Environment 

Mr. Albert Richardson 

Chief of Fire Operations 

Mr. Darrell Rodgers 

Executive Director, Environmental Health 

and Safety 

Detroit Public Schools 

Mr. David Sanders 

Metropolitan Affairs Coalition 

Mr. Tony Shannon 

Homeland Security Deputy Director, Wayne 

County 

Mr. Shelby Slater 

Detroit Homeland Security Director 

Detroit Fire Department 

Mr. Tim Strutz 

Chief of Police 

City of Dearborn Police Department 

Mr. Dave Tyler 

Wayne County JED 

Mr. J. David Vanderveen 

Director 

Oakland County Central Services 

Mr. Walter Watkins 

Director 

Detroit Planning and Development 

Department 

Ms. Judith West 

Deputy Director 

Detroit Health Department 

Mr. William Worden 

Director 

Historic Designation Advisory Board 

Mr. Dennis Zembala 

Director 

City of Detroit Historical Department 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

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LOCAL, STATE AND U.S. ELECTED OFFICIALS

Hon. Robert (Art) Blackwell 

Wayne County Commissioner 

Ms. Jeanean Bryant 

Commissioner Alisha Bell's Office 

Hon. Irma Clark-Coleman 

State Senator District 3 

Hon. Hansen Clarke 

State Senator District 1 

Hon. John Conyers 

U.S. Representative 

Hon. David Coulter 

Oakland County Commissioner 

Hon. John Dingell 

U. S. Representative 

Hon. Robert Ficano 

County Executive 

Executive of Wayne County 

Hon. Michael A. Guido 

Mayor 

Mayor’s Office, City of Dearborn 

Hon. Morris Hood, III 

State Representative District 11 

Hon. Gilda Jacobs 

State Senator District 14 

Hon. Carolyn Kilpatrick 

U.S. Representative 

Hon. Kwame M. Kilpatrick 

Mayor 

Mayor’s Office, City of Detroit 

Hon. Carl Levin 

U.S. Senator 

Hon. Andy Meisner 

State Representative District 27 

Hon. Brooks Patterson 

County Executive 

Oakland County 

Hon. Bruce Patterson 

State Senator District 7 

Hon. Robert Porter 

Mayor 

City of Ferndale 

Hon. Triette Reeves 

State Representative District 10 

Hon. Debbie Stabenow 

U.S. Senator 

Hon. Samuel Thomas, III 

State Senator District 4 

Hon. Steve Tobocman 

State Representative District 12 

Hon. Gary Woronchak 

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

A- 6

OTHER AGENCIES

Mr. Keith G. Harrison 

Executive Director 

Michigan Environmental Science Board 

Ms. Cyndi Roper 

Clean Water Action 

Mr. Conan Smith 

Land Programs Director 

Michigan Environmental Council 

Mr. Sam Washington 

Executive Director 

Michigan United Conservation Clubs, Inc. 

Ms. Anne Woiwode 

Director 

Sierra Club 

Mackinac Chapter 
Appendix A- Section 2 

Correspondence Received in Response to Scoping 

1. September 9, 2002 - Ziibiwing Cultural Society, The Saginaw Chippewa Indian Tribe 

2. September 13, 2002 – Michigan Department of Natural Resources, Wildlife Division 

3. September 18, 2002 – Michigan Department of Agriculture 

4. October 2, 2002 – US Department of the Army, Corps of Engineers 

5. September 9, 2003 – Michigan State Fair 

6. September 19, 2003 – Michigan Department of Natural Resources, Wildlife Division 

7. October 18, 2004 – State Historic Preservation Office 

8. November 22, 2004 – State Historic Preservation Office 

9. January 4, 2005 – Michigan State Fair 

10. January 21, 2005 – State Historic Preservation Office 

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Appendix A- Section 3 

Notes of Scoping Meetings 

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Detroit Intermodal Freight Terminal Project 

Draft Notes 

Scoping Meeting 

September 19, 2002; 9:00 a.m. 

Latino Family Services Center 

Background: This is a formal scoping meeting for the DIFT Project. 

Attendance: See attachment. 

Discussion: 

The purpose of the meeting was to describe the project and its potential impacts and to solicit from those 

agencies contacted, and others who attended, responses to the purpose and need for the project, the 

project alternatives, and potential impacts. Resource agencies were invited, as were other organizations 

that might potentially have involvement with the project. Notification also was extended to those who 

have indicated an interest in the project, and/or are considered community leaders. 

Ari Adler of MDOT began the meeting by asking those present to introduce themselves. Mr. Adler then 

turned the meeting over to Don Cameron of the Federal Highway Administration (FHWA) who used a 

PowerPoint presentation to discuss the National Environmental Policy Act (NEPA) and the 

Environmental Impact Statement (EIS) process. A hard copy of Don Cameron's PowerPoint presentation 

was distributed. In his remarks, he covered NEPA’s objectives and the role of NEPA as an “umbrella” 

for a variety of federal laws, and regulations. He then discussed the EIS process: the study approach, 

notice of intent, purpose and need, scoping, draft EIS, public hearing, final EIS, and the Record of 

Decision (ROD). He noted that the purpose of today’s meeting was scoping, which is designed to define 

a study area, develop a list of stakeholders, inventory and map known resources, identify socioeconomic 

and environmental constraints, identify preliminary alternatives, and initiate the public involvement and 

agency coordination process. Don then explained how an EIS is prepared and its components; how that 

leads to a public hearing; and, how the public hearing comments are addressed in the process of preparing 

the final EIS. The process is concluded with a Record of Decision, which is a written record explaining 

why the lead agency, in this case the Federal Highway Administration, has taken a particular course of 

action. 

Ari Adler then asked Joe Corradino to explain the project purpose and need, a document which was 

distributed by mail to all resource agencies in advance of the September 19 meeting. Joe Corradino 

explained that the presence of the Livernois-Junction Yard area in Southwest Detroit could allow the 

consolidation there of a number of intermodal terminals in the region, several of which are experiencing 

capacity problems at their current locations. Consolidation at a single location is expected to improve the 

economic position of Southeast Michigan. Joe Corradino then played a videotape that explained the 

project. After the presentation, Ari Adler asked that those present offer their comments. These are 

presented below along with MDOT's response, where appropriate. 

 
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Comment: Frank Katarzis of The City of Dearborn indicated the City has no comments at the present 

time. 

Comment: Alex Sanchez of the Michigan Department of Natural Resources: There are few streams and 

only one small wetland in the area and that avoidance should be considered with respect to 

that wetland. 

Comment: Albert Richardson of the Detroit Fire Department: Concerned about traffic patterns. 

Question: Unidentified speaker: What code would be used for the design of roads and what would be 

done to ensure proper use of the truck-only road? 

Response: Within railroad property, the railroad would build to their own design needs and would 

control the use of the truck-only road. Outside the railroad property, it is likely the perimeter 

road would be a city street and built to meet city standards. Other improvements outside the 

terminal would be the state’s responsibility and designed to meet state standards. Terminal 

access would be focused on the Livernois and Wyoming areas in such a way to encourage 

truck-only road use directly from those streets into the terminal. There may be a control 

device to limit areas to only DIFT vehicles. 

Question: Harold Watkins of Detroit Environmental Management: Which railroads operate in the area? 

Will there be flow study of the numbers of trains and what they transport? Also, will there be 

access to the area for EMS? 

Response: There will be a forecast of the number of trains. Emergency access will be addressed in the 

DEIS; roads built for the project must be accessible to emergency vehicles. The EIS will 

contain a plan to address spills of hazardous materials. And, the terminal’s drainage system 

will be designed to contain runoff until it’s appropriate to be released. 

Comment: Mr. Gildon of the Detroit Fire Department: Keep in mind that all roads everywhere should be 

accessible by all of our emergency apparatus. That’s what the Fire Department is going to 

require. 

Question: Mark Merkey of Wayne County Department of Public Services: How roads under the 

jurisdictions of Wayne County would be handled. Were Dix or Wyoming going to be rebuilt 

as part of the project if increased truck traffic deteriorates them? 

 Response: Some improvements to these roads may be part of the project where the roads directly 

serve the DIFT. 

Comment: Mr. Chbib of the Detroit Public School Systems: The truck-only road close to Beard School 

should be switched to the far side of the railroad tracks and that the existing fence be 

replaced. Also, he asked how to further comment on this project? 
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Response: A wall of some sort was being considered along the rail property near the Beard School. 

People can communicate issues on the project via the project’s Web site, by letter, or at 

public meetings. 

Question: Unidentified speaker: Asked about the time frame was for submitting comments. 

Response: Comments were being accepted throughout the EIS process. 

Comment: Mr. Palombo of SEMCOG indicated his agency had reviewed the project purpose and need 

and stated that, from SEMCOG’s regional perspective, particular concerns were air quality, 

noise and truck traffic. 

Comment: Ms. Lile of Detroit Department of Environmental Affairs: The Detroit Department of 

Environmental Affairs will touch base with each City agency and compile a City response. It 

will be submitted at a later point in time. 

Response: It would be helpful if you submit your comments as soon as you can. 

Comment: Officer Chris Braymon, Dearborn Police Department: Concerned for public safety. 

At this point, having received comments from the agencies invited to the scoping meeting, comments 

from the general public were invited. 

Comment: Father Reilly of St. Anne’s Church: Dumping this project on the City mashes its people.

Comment: Ms. Milberg, area resident and member of Southwest Detroit Business Association: The 

project is not going to be helpful to the economics of the neighborhood. 

Question: Ms. Gruelle of Southwest Detroit Environmental Vision: Creating a consolidated hazardous 

spill plan is productive. Asks if long periods of truck vibration cause destruction of 

buildings? Cites the Beard School concerns and stresses air pollution's effects on asthma, 

cancer, and heart disease, particularly in this sensitive area of Southwest Detroit. 

Response: A study will be undertaken to determine the effect of truck vibrations. Air quality studies 

will also be conducted. Both direct and indirect effects of the project will be measured in a 

number of categories. 

Comment: Unidentified speaker: The DIFT Project has to be considered in light of the Ambassador 

Bridge Project, the proposed Rail Truck Tunnel, an improved track connection that would 

facilitate AMTRAK use through the DIFT, and additional changes resulting from the breakup 

of Conrail. 

Comment: Unidentified speaker: The Arab community is not being considered a minority group and 

should be. 
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Comment: Ms. Kavanaugh of Communities for a Better Rail Alternative: Our organization has offered 

an alternative that we should like fully evaluated in the EIS process. Our alternative has been 

mis-characterized in the past as the “No Action” alternative. Our alternative would provide 

for almost half of the forecasted demand. 

Comment: Ms. Savoie of the Arab Community Center for Economic and Social Services indicated her 

group would submit written comments today. She indicated Ms. Gruelle’s comments cover 

concerns that are very strong in the community. Ms. Savoie cited a “glaring omission” of the 

Arab American Community’s presence in examining environmental justice issues in data that 

the DIFT project has presented to date. She noted the Arab-American community is not a 

federally recognized minority but is almost impossible to ignore in Michigan. She also 

indicated her organization believes MDOT is in violation of the NEPA Code, which requires 

full evaluation of all reasonable alternatives, including those that only partially meet the 

stated goal of the project, even those that are outside the scope of the agency's authority and 

that are not within the context of the finding currently available. She also noted it is 

repugnant to consider only No Action and one alternative. Ms. Savoie stressed her 

organization will submit case law to support these issues. 

Response: The efforts of the DIFT Project Team to provide full information to the Arab Community 

were noted. 

Comment: Ms. Wendler of the Southwest Detroit Business Association: Her organization is concerned 

about the loss of 99 businesses in MDOT's preferred alternative. She would like to know the 

number of jobs lost at these businesses along with the income tax loss. Urges the state not to 

respond to her concerns until it has the answers. 

Comment: Mr. Slovic: Notes he’s seen no information concerning projects already in the pipeline that 

will affect DIFT at the Livernois-Junction Yard. Cites as examples the Detroit River 

Terminal Project and the West Detroit Connector in MDOT’s current budget for a $500,000 

improvement. 

Response: The DIFT will account for other projects that are underway or planned. 

Comment: Unidentified speaker: It is hard to analyze the No Action Alternative without the Federal 

Railroad Administration’s position on the disposition of Conrail assets. 

Comment: Ms. Milberg: Allen Park is far from Southwest Detroit and indicates, “those population 

figures of white folks in that community were added (the DIFT reports) to kind of bump up 

the totals so that it would reduce by percentages the number of minorities that would be 

affected.” 

Comment: Greg Warren: Indicates those who spoke from the area have very good concerns. 
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Comment: Ms. Rodriguez of Mexicantown Community Development Corporation: This is the only 

neighborhood in the entire City of Detroit that has had any significant growth in businesses 

and residents. Notes the upcoming construction of an international Welcome Center. Cites 

the reeling-effect of the construction of freeways in the late 1960s. Urges the need to work 

something out that is going to benefit everyone but, primarily, that doesn’t destroy the 

neighborhood that many have worked so hard to reconstruct. 

Comment: Mr. Christiansen of the Southwest Detroit Improvement Association, an area resident, and a 

City Planning Commissioner: Notes his very big disappointment at the number of 

community people in attendance and also business people or business representatives. 

Indicates honest answers on the proposed DIFT will require getting the word to some people 

that can give you some answers. 

Response: This meeting is a process to gather together resource agencies. It’s open to the public to 

allow further involvement to, at least observe and offer comments. There have been many 

more opportunities for the public to provide comments. 

The meeting moved at 11:00 a.m. to a bus tour of the Livernois-Junction Yard area where the DIFT is 

proposed to be located. 
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Detroit Intermodal Freight Terminal Project 

Scoping Meeting 

September 19, 2002; 9:00 a.m. 

Latino Family Services 

Attendance 

Name Representing Address City Zip Telephone 

Fatima Aidibi Corp. Translation Svcs. 26966 Rochelle Dbn. Hts. 48127 313.792.1327 CoHeidi Alcock CPC 202 CAYMC Detroit 48226 224-3281 alKen Anderson SDBA Detroit keJamie Antonini USDA-NRCS 446 N. Elizabeth Marin City Gerri Ayers MDOT/ENV 425 W. Ottawa Lansing 48909 517.335.2635 Gabrielle Bagnasco DCX 800 Chrysler Dr. Auburn Hills 48326 248.576.8729 Bryon Botts 4065 Lawndale Detroit 48210 313.846.7292 William Bowman NRCS 3001 Coolidge Rd. East Lansing 48911 517.324.5241 Chris Braymon City of Dearborn 16099 Michigan Dearborn 48126 313.943.2294 Mahmoud Chbib Det. Pub. Sch. 5057 Woodward, Suite 564 Detroit 48202 313.494.1842 Tom Christiansen LPC 2754 Casper Detroit 48209 313.842.7304 ToMarty Connour MARS Ind. 3100 Lonyo Detroit 48209 313.841.1800 Jeff Edwards MDOT Metro Reg. 18101 W. 9 Mile Southfield 48075 248-483-5114 edDoug Fishell MDOT Real Estate Lansing 517.373.2210 Claryce Gibbons-Allen DDOT 1301 E. Warren Detroit 48207 833.7670 Weylin Gildon Fire Dept. 250 W. Larned Detroit 48226 596-2907 Greg Gorno GTSJ/DIA 18673 Dix B’town 48192 734.281.1666 grChris Gulock City Planning 202 Coleman A Young Ctr. Detroit 48226 313.224.7888 Alan Hayner City of Detroit 65 Cad Tower Detroit 48226 224.9033 ahRobert Hedges City of Dearborn 13015 Michigan Dearborn 48126 313.943.2035 Marc Higginbotham Norfolk Southern 2000 Town Center, Ste. 1900 Southfield 48075 248.351.2670 Frank Jackson House Dem. Leader 3011 W. Grand Blvd, Ste. 1070 Detroit 48202 313.871.6985 reJohn James JGI 4001 Fort St. Detroit 48209 841.0070 Reg Johnson Det. Law 1650 First Nat’l Detroit 48226 313.237.5065 Jeff Jones Det. Law 1650 First Nat’l Detroit 48226 313.237.5065 Frank Katarzis City of Dearborn E&LD 13615 Michigan Dearborn 48126 313.943.2180 fkK. Kavanaugh SDBA 7752 W. Vernor Detroit 48210 842.0986 Bruce M. King City of Detroit 660 Woodward Detroit 313.471.5103 kiGay Lynn Kinter NRCS 1525 N. Elms Flint 45032 810.230.5766 Sarah Lile City of Detroit 1800 First Nat. Bldg. Detroit 48226 313.471.5115 Mark Merkey Wayne County DPS 415 Clifford Detroit 313.224.7272 mKathy Milberg Resident/SDBA 9152 Chamberlain Detroit 48209 313.554.1850 
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Name Representing Address City Zip Telephone 

Carmine Palombo SEMCOG Bob Parsons MDOT Lansing 517.335.2488 paSherry Piacenti MDOT 7050 W. Saginaw Lansing 48917 517.321.5071 piJoe Redican LAC 5668 Baber Detroit 48206 313.844.4443 joRev. A. Leo Reilly St. Anne Parish 1000 St. Anne Detroit 48216 964.5766 Albert Richardson D.F.D. 250 W. Larned Detroit 48226 313.596.2922 Jim Roach AVT 991 Rosewood E. Lansing 48823 517.351.8927 Alex Romero WC Sheriff 1231 St. Antoine Detroit 48226 224.7103 arAlex Sanchez DEQ 525 W. Allegan Lansing 48909 517.335.3473 Kathryn Savoie ACCESS 6450 Maple St. Dearborn 48126 313.554.0376 ksChuck Scott Scott Cont. Service POBox 10008 Detroit 48210 313.849.4553 chChris Singer Det. News 224.2127 Paul Slaun Scott Container POBox 10008 Detroit 48210 313.523.9124 Donald-Ray Smith Detroit Planning 65 Cadillac, Suite 1300 Detroit 48226 313.224.1319 drLinda Vertin City of Detroit 7140 W. Fort Detroit 48210 596.5420 LLGreg Warren Harold Watkins Det. Env. Mgt. 250 W. Larned Detroit 48226 313.596.5195 wK. Wendler SDBA 7752 W. Vernor Detroit 48209 842.0986 wMarja Winters Det. Plng. Comm. 202 CAYMC Detroit 48226 313.224.6376 wiAndy Zeigler MDOT 18101 W. Nine Mile Southfield 48075 248.483.5108 zeMona __________ MCDC 2620 _________ Detroit 48216 967.9898 
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Detroit Intermodal Freight Terminal Project (DIFT) 

Scoping Meeting 

June 4, 2003, 10:00 a.m. 

Northwest Activities Center, Detroit 

Purpose: This is the second part of the formal scoping meeting on the Detroit Intermodal Freight Terminal 

Project, the first part having been conducted on September 19, 2002. Its purpose is to familiarize 

agencies and those with permitting and regulatory authority about the purpose and need and 

alternatives for the DIFT Project and to familiarize those in attendance with the National 

Environmental Policy Act (NEPA)/Environmental Impact Statement (EIS) process. 

Attendance: See attached list. 

Discussion:

Welcome/Introductions

Mohammed Alghurabi opened the meeting and noted that a tour would be conducted directly following the scoping 

discussion. He also indicated Arabic and Spanish translators were available. He provided a brief introduction of the 

project and indicated Greg Johnson of the Michigan Department of Transportation (MDOT) would serve as moderator 

of the meeting. Mr. Johnson began by asking for introductions and by describing how the meeting would be 

conducted. He introduced Don Cameron of the Federal Highway Administration (FHWA) to provide an overview of 

the NEPA/EIS process. 

NEPA/EIS Presentation

Mr. Cameron explained the NEPA/EIS process. He noted the role of public involvement; the alternatives and impacts 

covered by an EIS; the conduct of a public hearing on the Draft EIS; and, the preparation of the FEIS, including a 

recommended alternative and the Record of Decision. He then opened the floor to questions regarding his 

presentation. 

NEPA/EIS Questions

Question: What is the timeline for the project? 

Response: The Draft EIS is scheduled for completion in summer 2004. Within a year from then, the Record of 

Decision (ROD) should be complete. 

Q: How does federal funding relate to the ROD? 
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R: The ROD is the last step in developing the Final EIS. Design of the project cannot begin until the Record of 

Decision is complete. The Record of Decision could result in doing nothing at all. 

Q: Does NEPA require that all state and local regulations and rules be met? 

R: Yes. 

Q: Does the County have to sign off on the Record of Decision? 

R: The first decision is made by MDOT. If MDOT does something without concurrence of what agencies think, 

that can sometimes create problems. I think in the Detroit area, the case we’re looking for is concurrence of 

the major portion of the metropolitan area and once the individual city by itself is saying “we object”, it may 

not be enough to cross it out. 

Project Overview

Joe Corradino provided background on the project, its purpose and need, and potential issues. He defined what 

intermodal is and the nature of its recent growth. He noted where the terminals are in Southeast Michigan today and 

are expected to be in the future and the capacity of each. He referred to earlier analyses conducted by another team 

and indicated that current demand is in line with the earlier forecasts. He then briefly described the DIFT alternatives, 

indicating that Alternative 1, No Action, has already had involvement with state money and this is the background 

situation. Alternative 2 was developed partly in response to comments by Communities for a Better Rail Alternative 

(CBRA) to expand/improve each existing terminal at its current site rather than consolidate at one site. Alternative 3 is 

the consolidation at one site and that place is the Livernois-Junction Yard. 

Analysis of the existing Livernois-Junction Yard shows that although the site is large, it is cut by Central and Lonyo 

Avenues. It would be more effective if one of these streets would be closed and the other likely put under the rail 

platform. 

CP/Expressway, which is located to the east of the Livernois-Junction Yard, is soon to experience a reduction in its 

space due to the cancellation of a lease. It could also be affected by a proposed conversion of two railroad tunnels to 

use by trucks and building a new rail tunnel under the Detroit River, which would emerge in the vicinity of the 

CP/Expressway terminal. Joe Corradino noted, however, that fitting the tunnels and the expanded CP/Expressway 

terminal in the area behind the MC Depot is problematic at this point. 

Regarding the CP/Oak Yard, Joe Corradino noted it would likely be expanded to the north, if expansion occurred. The 

terminal is operated by CP but on property leased to it by CSX. 
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At the CP/Moterm terminal, expansion may go into the industrial area on the east or it may go south into the state 

fairgrounds. 

Alternative 2 involves expanding existing terminals and would likely require acquisition of land at each location with 

the possible exception of Livernois-Junction Yard. Alternative 3 (Consolidation) would require right-of-way 

acquisition at Livernois-Junction Yard. 

Joe Corradino stressed there are two important needs to be addressed by the project: capacity versus demand and 

connectivity. He reviewed analyses indicating that demand for intermodal services outstrips the ability of the capacity 

of the existing terminals. He noted that both the capacity and demand forecasts for each terminal were reviewed by 

representatives of the railroad operating the terminal. He noted the forecasts for 2025 in the DIFT Purpose and Need 

Statement were lower than earlier projections prepared by others. And, the new forecasts were presented in a range 

rather than a single number. The higher end of the range is consistent with growth trends provided by the Intermodal 

Association of North America and the American Trucking Association. The forecast at the low end of the range is 

based upon Reebie data, which show growth in intermodal traffic in Wayne County to 2010 at about 2.6 percent per 

year, compounded. That forecast was extended to 2025. Joe Corradino stressed that, regardless of the low or high end 

of the forecast range, the capacity of existing terminal facilities is exceeded by at least 75 percent. He also noted that 

even if the Triple Crown and Delray terminals continued to be used for intermodal business, the system of terminals 

would not have the capacity to meet the demand. 

Joe Corradino noted other projects in the region, in terms of major infrastructure development, to which connections 

are needed to do a good job in moving intermodal freight. 

Joe Corradino discussed a number of key issues related to the project, in particular economic impacts, environmental 

justice and air quality. On air quality, he noted that for the EIS, there would be a CO hot-spot analysis; ozone analysis, 

sufficient to determine conformity for the years 2015 and 2025; and, a qualitative assessment of air toxics. Economic 

impacts would be developed for the local area around each terminal, the rest of Wayne County and the rest of the 

region. 

Interaction

Representatives of groups that came to the meeting were asked to make comments. This was done by moving 

clockwise around the conference table set up for the meeting. 
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• Sherry Kamke of EPA had no comments at this time. 

• Doug Topolski of the Dearborn Police Department expressed concern about traffic impacts on Michigan 

Avenue. Joe Corradino noted that an intersection analysis would be done indicating the level of service. This 

analysis would include existing (background) traffic and new intermodal truck traffic. The Dearborn 

representative also noted the issue of hazardous waste. 

• Glenn Osowski of Congressman Conyers’ office asked how the project was being coordinated with Homeland 

Security agencies due to the fact that the DIFT was located at an international border location. He also asked 

whether the new crossing itself was vital to the DIFT. Joe Corradino responded the DIFT Project Team had 

met with Wayne County and Detroit Homeland Security personnel. The DIFT Project is being coordinated 

with the Border Crossing study. And, while the location of a new crossing is now unknown, the DIFT was 

largely independent of border issues. Finally, Joe Corradino noted that coordination has also occurred within 

the Canadian Pacific study that is examining the use of the existing rail tunnels under the Detroit River for 

potential truck commerce. 

• Colonel Lundy of the Michigan Department of Military Affairs had no comment at this time. 

• Robert Sills, an MDEQ Air Quality Division representative, asked about the air quality analysis at the 

terminals which would have intermodal traffic moved if consolidation occurred. Joe Corradino responded that 

the analysis assumed that those terminals from which intermodal traffic would be shifted would continue to be 

used for some rail-related function and this would be covered in the analysis of the indirect and cumulative 

impacts. 

• Jerry Fulcher, an MDEQ representative, noted the $10 million to be invested in the Livernois-Junction Yard 

and asked whether this investment affected the outcome of the EIS. Joe Corradino responded that this 

investment would be reflected in the base (i.e., No Action) condition as is ordinarily done in EISs. 

• Robert Johnson of Michigan Consumer & Industry Services noted that the TEA-21 reauthorization was 

coming and wondered how the project fits into that reauthorization. Mohammed Alghurabi noted that MDOT, 

working with the Michigan Congressional Delegation, has provided input to the reauthorization requests for 

additional funding of the DIFT. Joe Corradino added that regardless of the DIFT project outcome, 

transportation legislation covering the next several years will have a strong emphasis on freight movement. 
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• Fred Berry of Wayne County Homeland Security asked how much HAZMAT would be handled by DIFT and 

the kind of communication the DIFT Project has on that issue with Wayne County and similar 

agencies/communities. Joe Corradino responded that less than one percent of intermodal freight is related to 

hazardous materials and that, generally speaking, the nature of hazardous material includes items like auto 

paint. He further noted that the DIFT Project Team had met with Mr. Slaughter of Detroit’s Homeland 

Security agency and Mr. Shannon of Wayne County Homeland Security. Finally, the DIFT Project Team had 

made contact with federal Homeland Security officials and hoped to meet in December when they say they 

will be available. 

• Karen Dumas of Mayor Kilpatrick’s Office asked: 

9 What was the public reaction to the project? 

9 Had there been feedback from the Port Authority? 

9 Who sat on the Local Advisory Council? 

Joe Corradino responded that he would ask Mr. Alghurabi to address the first question. On involvement of the 

Port Authority, he noted its representative has testified in Lansing in support of the DIFT project. But, the 

DIFT Project is not planning on a link to the Port. On the Local Advisory Council, Joe Corradino indicated 

the list of 50+ persons on the Local Advisory Council would be provided to the Mayor’s office. 

Mohammed Alghurabi noted, in response to the question on public reaction to the project, that the best answer 

would come from the community. But, he stated his opinion that there had been a lot of professionalism in the 

interaction with the community. He indicated that MDOT has learned quite a bit and is doing the best it can. 

Mohammed Alghurabi noted that the Local Advisory Council is a community-based group with a good cross 

section. 

Joe Corradino remarked that Alternative 2 basically grew out of public involvement. He also noted he had 

recently met with four local groups (Grandmont, Grandmont I, Rosedale Park and South Jeffries) and that the 

interaction had been positive. The president of the local business association in that area (CP/Oak) has joined 

the Local Advisory Council. 

• Ken Dobson of Congresswoman Carolyn Cheeks-Kilpatrick’s office asked whether asthma would be 

addressed by the air quality analysis. Joe Corradino responded that the DEIS would include some modeling of 

PM2.5, the results of which would be published in a separate document. The data from that analysis could be 
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used to judge the relative effects of different alternatives on asthma hospitalizations through the use of data 

provided by the Michigan Community Health Department. However, he stressed the EIS would not include a 

health risk assessment. It will deal with issues like asthma and air toxics on a qualitative basis. 

• Chuck Tucker of Ferndale had no comments at this time. 

• Bruce King of the Detroit Department of Environmental Affairs noted that diesel exhaust comprises 36 percent 

of PM2.5 so some analysis of PM2.5 should be included in the study. Joe Corradino responded that FHWA will 

follow the conformity rules, which do not now cover PM2.5 or air toxics. If the rules change, then the analysis 

of those pollutants will be included in the EIS. Bruce King then asked that he be provided with information 

related to these issues. Joe Corradino indicated that it would be provided. Don Cameron of FHWA indicated 

that EPA had not designated non-attainment areas and methodologies to use for PM2.5, PM10 or air toxics. So, 

FHWA is using an alternative approach. 

• Paul Max of the Detroit Health Department asked why a health risk assessment would not be done. Joe 

Corradino responded that no rules have been established nor methodologies confirmed for such an analysis. 

He offered one example of one undefined issue as the mix of fuels to be used to generate air quality emission 

factors for diesel engines. 

• Donald-Ray Smith of the Detroit Planning and Development Department asked if the environmental justice 

(EJ) analysis applies to all terminal sites. Joe Corradino noted that EJ effects for each terminal site would be 

addressed in the EIS. 

• Wayne County Public Services representatives had no comments at this time. 

• Chris Gulock of the Detroit City Planning Commission indicated a positive reaction to including Alternative 2 

in the DIFT EIS, but expressed concern that the impacts of expansion on any particular site may cause 

elimination of the entire Alternative 2. It was recommended, then, that a backup site be examined to fill this 

gap. Joe Corradino indicated that the explanation of the use of other potential sites, such as Highland Park, 

would be covered in the EIS. 

• Kathryn Savoie of ACCESS and CBRA questioned the Purpose and Need Statement by indicating that 

Norfolk Southern’s decision to shift Triple Crown and Delray intermodal business to the Livernois-Junction 

Yard allows a private corporation to shape public policy. Also: 
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9 The benefits from the project need to be separated from the mitigation measures. 

9 The Arab community is a distinctly recognized minority in the state of Michigan and needs to be included 

in the Environmental Justice analysis. 

9 The planned PM2.5 analysis is inexcusable. 

9 The exclusion from the environmental impact analysis of a health assessment is unacceptable. 

• Olga Savic of State Representative Tobocman’s office stated that the Livernois-Junction Yard manager 

indicated paving would double capacity. Also: 

9 There seems to be two issues: one, untying “knots” in the rail system, and the second getting more land at 

individual terminal sites. If the “knots were untied,” would that solve the capacity need? 

9 It appears that the alternatives process had already been established and wondered about other alternatives 

with respect to Moroun’s (Riverview-Trenton Railroad) terminal and the use of greenfields. 

9 How will community cohesion be evaluated? What sort of model be used? Is there a model that lists the 

factors the community cares about? 

In response, Joe Corradino noted that paving the Livernois-Junction Yard was part of the plan with 

Alternatives 2 and 3; the railroads are not likely to undertake this by themselves under Alternative 1. Further, 

the “knots” need to be fixed under either Alternatives 2 or 3 to make the system work. Third, greenfields are 

not an option for the consolidation alternative. That had been looked at before and determined not to be 

prudent. Finally, there is no model, as such, that will be used to address community cohesion. In past 

analyses, this issue has been addressed by examining population characteristics, separation of neighborhoods 

from schools, parks and other community facilities by a transportation improvement, and analysis of similar 

issues. 

• Karen Kavanaugh of CBRA and the Southwest Detroit Business Association noted several points: 

9 There should be clarification that the project would primarily benefit the auto companies. 

9 What level of public financing would be required? 

9 What would be the specific economic benefit for facilitating the movement of freight to the City of Detroit 

as opposed to the region? 

9 What would the economic benefits be to the host communities? 

9 What is the increase in truck traffic, not only in Southwest Detroit, but also on Detroit freeways and 

neighborhoods? 

9 What impacts would there be on future land use and development? 
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9 What impacts would there be on existing projects and public investments? 

9 Can a case be made that future manufacturing location and private investment will be favorable to Detroit 

and not just to the region? 

9 What would be the effect on the city’s tax base? 

Finally it was stated: for the record, it’s good to hear that Alternative 2 is consistent with the community 

improvement plan for Junction Yard that the coalition (CBRA) has submitted as an alternative to be evaluated 

under the EIS. That took place ten days ago. That is new information to us, because we had previously 

understood that, if there was no expansion of Junction Yard, there would be no funding to improve the 

infrastructure surrounding it. 

Responses to the above by Joe Corradino indicated that 70 to 90 percent of the outbound shipments at this time 

involve auto-related activity. Inbound traffic involves all sorts of goods being distributed in the region. He 

indicated the EIS economic analysis would attempt to address the issue of impacts on host communities, job 

losses and gains, the effects on the tax base, and the like. Because forecast demand exceeds capacity, it is the 

role of government to improve the transportation system for business, industry and the military. That includes 

improvements to the terminals and outside the terminals. Joe Corradino noted, however, that under 

Alternative 2, it was unlikely that the truck-only road would be built because there would not be a sufficient 

concentration of trucks to justify it. Likewise, certain drainage improvements associated with the truck-only 

road would not then be feasible. But, other improvements are associated with Alternative 2, including 

adjustments to Central and Lonyo, and better access at I-94 at Livernois. 

• Sarah Lile, head of the Detroit Department of Environmental Affairs, stressed that air quality issues should be 

evaluated beyond those covered by conformity. 

Having concluded inquiries of groups sitting at the table, Greg Johnson asked whether there were any individuals from 

the public that cared to ask questions or make comments. 

• Mohan Farhat of the Detroit Water and Sewer Department asked whether impacts to water systems would be 

reflected in the EIS. The response was yes. 

• Josephine Powel of the Department of Environment for Wayne County noted that there are air quality issues of 

industrial sources that should be included in analysis of impacts generated by the DIFT project. She also 

stressed environmental justice was another key project issue. 
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• Martha Gruelle, Director of Southwest Detroit Environmental Vision and a member of CBRA, made several 

comments: 

9 It is impossible to understand the scope of Alternative 2 at this time. There are no conceptual layouts. 

There is nothing to estimate truck traffic on potential truck routes. 

9 The definition of minorities on page 12 of the scoping document is a problem because it does not consider 

Arabs. The USDOT definition of groups covered by environmental justice provisions does not go far 

enough. 

9 National security is listed as a major purpose of the project now, after many years of discussion, when 

there was no mention of the U.S. military earlier. 

9 If Norfolk Southern indeed has a shortfall in terms of capacity, why are they moving Triple Crown and 

Delray to the Livernois Yard? The big part of the need for the project is based on one company’s 

decisions. 

9 Impacts of air toxics and PM2.5 should be considered in terms of lost school days and lost work days, if 

they aren’t included in the EIS as environmental impacts. 

9 It is good to see some air quality analysis will be done for 2015. PM2.5 calculations also should be done 

for 2015. 

9 The people involved in the project’s public meetings have heard many times from the residents and elected 

officials representing Southwest Detroit that the project looks like a disaster for Southwest Detroit, at least 

Alternative 3. 

9 Communities for a Better Rail Alternative is being condemned for being too soft on MDOT, for ever 

talking with MDOT about alternatives because community members and elected officials say to us the 

answer is no. 

• Mickey Blashfield, a representative of Centra, asked if the Riverview-Trenton facility would be included in the 

analysis. Joe Corradino responded that, if his understanding of the Surface Transportation Board’s decision is 

correct, adding the capacity of the Riverview-Trenton facility doesn’t diminish the fact that more intermodal 

capacity is needed in the region. 

• Kathryn Savoie, the representative of ACCESS/CBRA asked if the truck-only road from Springwells is still 

considered viable. Joe Corradino responded that until there is further analysis, both the Schaefer Road and 

Springwells truck-only road options are under consideration for Alternative 3, but that the truck-only road was 

likely not viable based on truck volumes for Alternative 2. 
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Greg Johnson asked if there were any further questions and he noted that the transcript of the meeting would be 

available on the Web site. 

• Robert Sills of the Michigan Department of Environmental Quality-Air Quality Division asked again what the 

scope of analysis would be with respect to PM2.5. Would there be only emissions determined or would impacts 

(concentrations) be estimated? And, what will be included in the EIS? Joe Corradino responded that the 

analysis will only be of emissions, not concentrations. And, PM2.5 would be reported in an appendix to the 

EIS. Air toxics will be discussed in the EIS on a qualitative basis, using calculations of surrogate pollutants, 

like volatile organic compounds (VOCs). 

• Paul Max, the representative of the Detroit Department of Public Health, asked if the hospitalization data 

spoken of earlier were for emergency rooms only. Joe Corradino indicated he believed that those data are for 

emergency hospitalizations by zip code for two time periods. 

The meeting then ended at 12:15 p.m. 
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Detroit Intermodal Freight Terminal Project 

Scoping Meeting 

June 4, 2003, 10:00 a.m. 

Northwest Activities Center 

Attendance

 NAME COMPANY/AGENCY 

Agency Representatives

Abdel Abdalla FHWA 

Heidi Alcock City Planning Commission 

Chris Ammerman City of Detroit Law Dept. 

Fred Berry Wayne Co. Homeland Security 

Don Cameron FHWA 

Michael Darga Wayne County DPS-Eng 

Ken Dobson Congresswoman Kilpatrick 

Karen Dumas Mayor’s Office 

Ajere Evans City of Detroit Mayor’s Office 

M. Farhat DWSD 

Sherrie Farrell City of Detroit 

Fred Feliciano Mayor Kilpatrick’s Office 

Jerry Fulcher MDEQ-GLMP 

Sam Geevarghese PLD 

Christopher Gulock City Planning Comm. 

Ruth Hepfer FHWA 

Robert Johnson Michigan CIS 

Dion Johnson Mayor’s Office 

Sherry Kamke US EPA 

Bruce M. King DEA/City of Detroit 

Ken Kucel Wayne Co. DPS 

Tarik Lester Congresswoman Kilpatrick 

Sarah Lile DEPE/City of Detroit 

R. Daryl Lundy Dept. of Mil. & Vet. Affairs 

Juan Jose Martinez Councilwoman Sheila Cockrel 

Paul Max Detroit Health Dept. 

Glenn Osowski Congressman John Conyers 

Josephine Powel Wayne Co. Dept. of Env. 

Samir Ray PLD 

 

NAME COMPANY/AGENCY 

Agency Representatives (continued) 

Olga Savic Rep. Steve Tobocman 

Robert Sills Michigan DEQ-AQD 

Daljit Singh DWSD 

Donald-Ray Smith Det. Planning & Dev. 

Jim Sype Mayor’s Office 

Doug Topolski Dearborn P.D. Traffic Safety 

Chuck Tucker City of Ferndale 

Jacquelyn Watts Mayor Kilpatrick’s Office 

Other

Mickey Blashfield Centra 

Mario Ferrini Ferrini Contracting 

Victor Ferrini Ferrini Contracting 

Martha Gruelle SDEV/CBRA 

Karen Kavanaugh SDBA/CBRA 

Joanna Ladki ACCESS 

Kathryn Savoie ACCESS/CBRA 

Staff/Consultant

Ari Adler TCG 

Geralyn Ayers MDOT 

Jeff Edwards MDOT Metro Region 

Tom Hanf MDOT 

Randy Henke Benesch 

Stephanie Litaker MDOT Communications 

Bob Parsons MDOT 

Sherry Piacenti MDOT 

Doug Strauss Benesch
Appendix B

Relocation Plan - Conceptual Stage 

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Appendix C

Draft Memorandum of Agreement with SHPO 

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DRAFT 

MEMORANDUM OF AGREEMENT 

BETWEEN THE FEDERAL HIGHWAY ADMINISTRATION 

AND THE MICHIGAN STATE HISTORIC PRESERVATION OFFICER 

SUBMITTED TO THE ADVISORY COUNCIL ON HISTORIC PRESERVATION 

PURSUANT TO 36 CFR PART 800.6(b)(1) 

REGARDING THE DETROIT INTERMODAL FREIGHT TERMINAL 

IN DETROIT, WAYNE COUNTY, MICHIGAN 

WHEREAS, the Federal Highway Administration (FHWA) of the U.S. Department of 

Transportation has determined that improvements to the Detroit Intermodal Freight 

Terminal (DIFT) in Wayne County, Michigan will have an adverse effect upon the 

following historic resource(s), which has/have been listed, declared eligible or which 

appear to meet the criteria for listing in the National Register of Historic Places (NRHP): 

• Specific sites/resources to be determined based on the preferred alternative. 

WHEREAS, the FHWA has consulted with the Michigan State Historic Preservation 

Officer (SHPO) pursuant to 36 CFR Part 800, regulations implementing Section 106 of 

the National Historic Preservation Act (16 U.S.C. 470f) (the Act); and 

WHEREAS, the Michigan Department of Transportation (MDOT) participated in the 

consultation and has been invited to concur in this Memorandum of Agreement (MOA), 

NOW, THEREFORE, the FHWA and the SHPO agree that the improvements to the 

DIFT in Wayne County shall be implemented in accordance with the following 

stipulations in order to take into account the effect of the project on historic properties. 

STIPULATIONS 

The FHWA will ensure that the following measures are carried out: 

I. DOCUMENTATION

Prior to the start of construction activities, MDOT will record the [the agreed 

upon affected properties] to create a permanent record of their history and current 

conditions at the time the project commences. MDOT will contact the SHPO to 

determine the appropriate level(s) of documentation. SHPO may require MDOT 

to provide original copies of the documentation with photos to appropriate local 

archives designated by the SHPO. 
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II. ABOVE GROUND HISTORIC RESOURCES 

It has been determined that no NRHP eligible or listed above-ground historic 

resources are located within the Area of Potential Effects for the CP Oak

location. Additional information and consultation will be required to determine 

appropriate steps to avoid, minimize, and/or mitigate adverse impacts, where 

applicable, to those historic above-ground resources determined to be listed, 

eligible for listing, and/or potentially eligible for listing on the NRHP within the 

CP Expressway, CN Moterm, and/or CSX Livernois-Junction sites. These 

resources are identified in the SHPO letter dated October 18, 2004. 

III. ARCHAEOLOGICAL RESOURCES 

It has been determined that it is unlikely that intact archaeological deposits 

survive at CP Oak, CP Expressway, and CN Moterm and no further action will 

be required for these locations. However, further investigation is required for 

potential archaeological sites that have been identified within the CSX Livernois 

–Junction location. 

Should these sites be determined to be viable it is agreed the sites will be 

important for the information they may yield and not for preservation in place. 

IV. LANDSCAPING AND SITE CONSIDERATIONS

MDOT shall ensure that the frontages of [locations to be identified] are 

landscaped in accordance with a landscape plan designed in consultation with and 

approved by the SHPO and the affected property owners. MDOT will retain an 

historian meeting the Secretary of the Interior’s Professional Qualifications 

Standards (48 FR 44738-9) and trained in historic landscape analysis and design 

to assist in plan development. 

V. Amendment

Any party to this MOA may propose to the other parties that it be amended, 

whereupon the parties will consult in accordance with 36 CFR 800.6(c)(7) to 

consider such an amendment. 

VI. Dispute Resolution

Should the SHPO or MDOT object within 30 (thirty) days to any actions 

proposed pursuant to this MOA, the FHWA shall consult with the objecting party 

to resolve the objection. If the FHWA determines that the objection cannot be 

resolved, the FHWA shall forward all documentation relevant to the dispute to the 
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Advisory Council on Historic Preservation (Council). Within 45 (forty-five) days 

after receipt of all pertinent documentation, the Council will either: 

• Provide the FHWA with recommendations, which the FHWA will 

take into account in reaching a final decision regarding the dispute; 

or 

• Notify the FHWA that it will comment pursuant to 36 CFR 

800.7(c) and proceed to comment. Any Council comment 

provided in response to such a request will be taken into account 

by FHWA in accordance with 36 CFR 800.7(c)(4) with reference 

to the subject of the dispute. 

Execution of this MOA and submission to the Council evidences that FHWA has 

afforded the Council an opportunity to comment on the improvements to the DIFT and its 

effects on historic properties. 

FEDERAL HIGHWAY ADMINISTRATION 

By: Date: 

 James J. Steele, Division Administrator 

MICHIGAN STATE HISTORIC PRESERVATION OFFICER 

By: Date: 

 Brian Conway 

Concur: 

MICHIGAN DEPARTMENT OF TRANSPORTATION 

By: Date: 

 Susan Mortel, Director, Bureau of Transportation Planning 
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Appendix D

Right-of-Way Areas Needed by Alternative 

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Appendix E

Air Quality Protocol 

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Air Quality Analysis Protocol 

Detroit Intermodal Freight Terminal 

Environmental Impact Statement 

Updated March 2005 
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1.0 Introduction 

Under the National Environmental Policy Act (NEPA), federal agencies are required to identify and 

describe the potential impacts to the human and natural environments as a result of their action(s), 

including those to air quality. This paper describes the air quality analysis that will be performed for the 

Detroit Intermodal Freight Terminal project (DIFT) environmental impact statement. 

The DIFT project proposes to enhance development of intermodal (truck/rail) terminals operated by the 

four Class I Railroads3

 that serve Michigan to provide improved intermodal service to business, industry 

and the military. Four intermodal terminals are included in the DIFT EIS: the Livernois-Junction Yard in 

Southwest Detroit (operated by CSX and Norfolk Southern); Canadian Pacific’s Expressway terminal 

behind the Michigan Central Depot just north of Bagley (temporarily closed as of June 2004); the CP/Oak 

Terminal located in the northwest corner of the intersection of I-96 and the Southfield Freeway; and, the 

Canadian National/Moterm Terminal on the Wayne County/Oakland County border north of 8 Mile Road 

between I-75 and Woodward Avenue. 

Because of the concentrated activities of heavy-duty diesel trucks, locomotives, and container-handling 

equipment with the DIFT project, air toxics and fine particulate matter (PM2.5

4

) are of particular interest. 

There are no established regulatory standards specifying harmful concentration levels of air toxics, no 

attainment area designations, and no analysis protocol for evaluating air toxics impacts for transportation 

projects. Nevertheless, given community concern for air toxics, FHWA recognizes the need to address 

several key air toxics along with PM2.5 (fine particulates) and the other NAAQS pollutants, through the 

protocol described here. 

2.0 Analysis Elements 

The DIFT air quality analysis will cover: 

1. The attainment status of the project area with respect to the NAAQS, notably carbon monoxide 

(CO), ozone, and PM2.5. 

2. A CO hotspot analysis at key intersections in the terminal areas that will compare CO 

concentrations in areas of human activity to the 1- and 8-hour NAAQS. 

3. Pollution trends, and a discussion of U.S. EPA measures to improve air quality. 

4. A discussion of air toxics, including a qualitative discussion of health risks and current science. 

5. An estimate of the pollutant burden5

 that will be generated by each terminal under each 

alternative. This burden analysis will include the NAAQS pollutants and several key air toxics. 

6. An estimate of the pollutant burden produced by mobile source activities on the local public 

roadway network near each terminal that would experience traffic volume changes. This burden 

analysis will include the NAAQS pollutants and several key air toxics. 

7. A discussion of air quality conformity. 

8. Potential mitigation that could accompany the proposed project. 

 

3

 A Class I Railroad has at least $250 million in revenue per year. 

4

 PM2.5 refers to particulate matter that is 2.5 micrometers or smaller in size. Sources of PM2.5 include fuel combustion from 

automobiles, power plants, wood burning, industrial processes, and diesel-powered vehicles such as buses and trucks. These fine

particles are also formed in the atmosphere when gases such as sulfur dioxide, nitrogen oxides, and volatile organic compounds 

(all of which are also products of fuel combustion) are transformed in the air by chemical reactions. Fine particles are of concern 

because they are so small they are able to penetrate to the deepest parts of the lungs, where the body has difficulty expelling

them. 

5

 Pollutant burden means the mass of a pollutant produced in a given period of time. In this case pollutant burden is expressed in 

terms of tons per year. 
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The goal of the analysis is to provide decision-makers and the public with information to view the relative 

impacts of each alternative. The results of the analysis will not provide a means for a pass/fail comparison 

to standards (other than carbon monoxide). 

3.0 Regional Attainment Status 

The NAAQS are set at levels that U.S. EPA believes will protect public health and welfare. NAAQS are 

used as the basis for determining an area's air quality designation (i.e., status, as "attainment" or 

"nonattainment"). Generally, a nonattainment area is one that does not meet a particular NAAQS. An area 

may be classified nonattainment for one or more pollutants and attainment for others. It is also possible 

for a nonattainment area to be reclassified as attainment, if it is able to achieve the standard over time. 

Such areas are given a "maintenance" designation, requiring them to demonstrate continued compliance 

with the standard, but not requiring additional controls to reduce emissions. 

The air quality analysis and report will discuss Southeast Michigan’s attainment status. The study area is 

now a maintenance area for the CO standard and is in nonattainment of the 8-hour ozone standard. It was 

designated to be in nonattainment for PM2.5 on December 15, 2004 (effective April 5, 2005). A portion of 

the southwest Detroit area is also a maintenance area for PM10, but this is not a part on the mobile source 

review process on the part of SEMCOG, the Southeast Michigan Council of Governments. 

4.0 Hotspot Analysis 

Carbon monoxide (CO) hotspot analysis is performed to ensure that project-related traffic does not cause 

a violation of the 1- or 8-hour NAAQS for CO. Carbon monoxide is a colorless, odorless, poisonous gas 

produced by incomplete combustion. Traffic information for each alternative is combined with 

information about roadway geometry and traffic flow conditions to determine the concentrations of CO at 

sensitive receptors. Sensitive receptors are locations where humans might be expected to be present. 

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

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

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

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

vehicle fleet mix and age, are drawn from SEMCOG (Southeast Michigan Council of Governments) in 

consultation with U.S. EPA and the Michigan Department of Environmental Quality (MDEQ). 
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5.0 Pollution Trends – NAAQS Pollutants and Air Toxics 

The EIS will provide information on past trends in NAAQS pollutant emissions and regulatory measures 

taken by U.S. EPA to continue the downward trends. Historic data from local monitoring stations nearest 

to the terminals (or with the most complete records) will be documented. 

Future air quality trends will be discussed based on U.S. EPA forecasts of the expected consequences of 

recently implemented regulations related to on-road diesel engines and fuels. Trends in passenger vehicle 

emissions will also be noted. 

Diesel exhaust is a complex mixture of inorganic and organic compounds that occur as a blend of gases 

and particles. The gaseous components include nitrogen oxides, sulfur compounds, and low-molecularweight hydrocarbons, such as the aldehydes, benzene, 1,3-butadiene, and polynuclear aromatic 

hydrocarbons. The particle phase of diesel exhaust consists of elemental carbon, adsorbed organic 

compounds and small amounts of sulfate, nitrate, metals and other trace elements. Diesel particulate 

matter (DPM) has been estimated to comprise about six percent of the total PM2.5 inventory nationwide 

but more in urban areas, excluding natural and miscellaneous sources (U.S. EPA, 2002). 

Compounds of most specific interest for the DIFT project are those found in particulate matter and, to a 

lesser degree, volatile organic compounds (VOCs), which are also emitted by diesel vehicles. Data from 

the 1996 National Toxics Inventory indicate that mobile sources account for approximately 50 percent of 

air toxics emissions (U.S. EPA, 2000). Several of the air toxics that EPA has identified as priority mobile 

source air toxics (MSATs) constitute a subset of all VOCs. The MSATs considered in the DIFT 

environmental impact analysis are benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and acrolein. 

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

because: 1) mobile sources, both on-road and non-road, contribute the majority of annual emissions for 

five of these air toxics (acetaldehyde, acrolein, benzene, 1,3-butadiene and formaldehyde) on a national 

basis; 2) they are representative of the complete list of gaseous mobile source air toxics; and, 3) these air 

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

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

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

the nationwide emissions of these HAPS. 

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

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

gasoline; 3) a national low-emission vehicle program; and, 4) standards for low-sulfur gasoline and diesel 

fuel. By the year 2020, these requirements are expected to reduce emissions of a number of air toxics 

(benzene, 1,3-butadiene, formaldehyde, and acetaldehyde) from highway motor vehicles by about 75 

percent and diesel particulate matter by over 90 percent from 1990 levels (U.S. EPA, 2000). 

EPA issued a regulation in May 2004 to control emissions from diesel-powered non-road engines, such as 

construction equipment and railroad locomotives. EPA also provides assistance in identifying and 

implementing voluntary programs, such as diesel retrofits, to achieve additional reductions. 

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

pollutants and certain air toxics associated with mobile sources. The model accounts for the recent EPA 

regulatory changes. Emission factors vary by speed and type of vehicle. By focusing on representative 

vehicle types and speeds, future emission factors can be related to trends over time (i.e. 2004, 2015, and 

2025). Graphics to illustrate these trends will be developed for the following conditions: 
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• Passenger vehicles and NAAQS pollutants at: a) 10, and b) 30mph 

• Passenger vehicles and air toxic pollutants at: a) 10, and b) 30mph 

• Trucks and NAAQS pollutants at: a) 10, and b) 30mph 

• Trucks and air toxic pollutants at: a) 10, and b) 30mph 

6.0 Air Toxics and PM2.5 – Health Effects and Limitations on Current 

Science 

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

understand their spatial variability in urban settings; evaluate data from mobile-source oriented monitors; 

and, provide data for the National Air Toxics Network maintained by EPA. One of the programs 

sponsored by EPA is the Detroit Air Toxics Pilot Project, which began collecting data from monitoring 

stations in 2001. Data from these programs may ultimately be used to develop standards to address health 

or environmental risks from air toxics. 

Analysis of DIFT air toxics and PM2.5 will qualitatively address health risks, the limitations of the current 

state of the science to quantify such risks, and potential benefits from selected mitigation measures. This 

approach is consistent with the CEQ NEPA regulations (40 CFR 1502.22 and 1502.24) that hold agencies 

accountable for the scientific integrity of sources and procedures relied upon for decision-making. Under 

this regulation, when the means to obtain data are unavailable (in this case, the state of the science for air 

toxics and PM2.5), agencies must acknowledge such limitations, discuss the relevance to impacts on the 

human environment, summarize existing credible scientific evidence, and make reasoned judgments of 

impacts based on theoretical approaches. 

Some health agencies and research institutions have reported on the health effects of air toxics and PM2.5. 

Exposure to these pollutants at sufficient concentrations and durations may result in an increased chance 

of experiencing serious health effects. These health effects appear to include damage to the immune 

system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory and other 

health problems. The health effects from some air toxics may appear following a short period of exposure, 

while others may only appear after long-term exposure. “For these (and other) reasons, it is frequently 

very difficult to conclusively associate environmental levels and potentially linked public health impacts” 

(MDEQ, 2003). Additionally, supporting documents for the health assessment of diesel engine exhaust 

used in the development of EPA’s non-road rules acknowledge that “the assessment's health hazard 

conclusions are based on exposure to exhaust from diesel engines built prior to the mid-1990s”....and ”as 

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

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

In addition to the uncertainty associated with the health risks of air toxics and PM2.5, issues related to 

quantifying impacts and the lack of standards have been raised. There are no NAAQS for air toxics and 

methods for quantifying impacts are subject to scientific debate. Unlike smokestack testing for point 

sources, it is not feasible to directly measure mobile source emissions, given the number of tailpipes that 

would constitute any inventory. Modeling approaches, however, can provide a tool to assess project 

impacts and to compare the relative merits of various control strategies or project alternatives. These are 

the pollutant burden analyses discussed in the following sections. But, although transportation and air 

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

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

regulatory use. 

The limitations preclude at this time the DIFT project from conducting a quantitative pass/fail comparison 

to standards for air toxics and PM2.5. Nevertheless, in order to gain some insights into the relative 
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differences among the alternatives with regard to air toxics and PM2.5, this document proposes estimating 

the pollutant burdens of the proposed alternatives both on terminal sites and on the surrounding roadway 

network. This approach is consistent with the requirements of 40 CFR 1502.22 and 1502.24. 

7.0 Terminal Pollutant Burden Estimates

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

acquisition (Figures 1, 2, 3 and 4). Within these areas the total pollution emitted will be calculated for 

2004, 2015, and 2025. The estimate will cover terminal activity, travel on streets that would be 

incorporated into a terminal (for example John Kronk), and activity on land that would be incorporated 

into a terminal. This approach allows comparison of the burdens generated by the alternatives for a 

common geographic area. More specifically, the pollution estimates will address: 

• Visitor and employee traffic on the rail yard. 

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

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

• Locomotive idling and movement on the yard. 

• Fugitive dust from paved and unpaved yard areas. 

• Vehicular travel on sites of businesses to be acquired. 

• Vehicular travel on streets that would no longer be public streets with project development: John 

Kronk and a section of Lonyo. 

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

The pollutant burden will be calculated for the following NAAQS pollutants and precursors: carbon 

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

(PM10), particulates of 2.5 microns or smaller (PM2.5), and volatile organic compounds (VOC). It will 

likewise be performed for the following air toxics: benzene, acetaldehyde, formaldehyde, 1,3-butadiene, 

acrolein, and diesel particulate matter. 

This information will be estimated for both on-road and non-road mobile sources. The emission factors 

(in grams/mile) for on-road sources (cars and trucks) will come from MOBILE6.2. An emission factor 

for an average speed of 2.5 miles per hour will be used to estimate idling conditions on the terminal yards 

because MOBILE6.2 does not generate emission factors for vehicle idling. The burden for on-road 

activity will be based on vehicle miles of travel on the site. 

 

Emission factors for CO, NOx, HC and PM for locomotives will be obtained from EPA’s 1997 “Emission 

Factors for Locomotives” (EPA420-F-97-051). PM2.5 emissions estimates will be derived using a PM2.5

fraction of 0.97 as recommended by EPA in April 2004. VOC emissions estimates will be calculated 

using a 1.005 VOC/HC ratio. Emission factors for locomotive air toxics will be derived 
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from the 1999 National Toxics Inventory technical documents. A load factor (representing the portion of 

the engine’s horsepower needed for an activity) will be applied to the emission factors in order to obtain 

realistic emission estimates. The burden for locomotives will be based on the number of hours of 

operation on the site. Non-road mobile sources in addition to locomotives include terminal tractors, 

hostlers, and cranes loading and unloading trailers from the trains. Emissions from terminal tractors, 

hostlers and cranes will be estimated using Exhaust and Crankcase Emission Factors for Nonroad Engine 

Modeling – Compression-Ignition, EPA420-P-04-009, April 2004 and other technical guidance that 

support EPA’s NONROAD model. Emission factors for non-road air toxics will be taken from technical 

documents supporting EPA’s 1999 National Toxics Inventory, in consultation with EPA and SEMCOG. 

The burden analysis will include estimates of emission sources located outside the terminal areas, but 

within the expansion areas. For example, traffic on the property of businesses that would be relocated 

would be added to the base-year total, but subtracted from the build alternatives (when such facilities are 

removed by an alternative). And, the emissions from roads that will be closed and included within the 

footprint of a terminal yard would similarly be included in the base year, but subtracted from the 

alternatives that close them. Examples are John Kronk and Lonyo. 

The burden analysis for PM2.5 will consider fugitive dust emissions. Project-related dust emissions are 

important in this analysis because the build alternatives are expected to reduce PM emissions by covering 

unpaved roads and exposed soil in terminal areas. Road/soil dust tends to have a lower percentage of 

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

Livernois-Junction Yard) represents a significant part of the total PM emissions (including PM2.5) that 

could be eliminated or minimized by paving these areas. In the case of the Livernois-Junction 

Yard, analyses may show that PM2.5 from road/soil dust to be more significant to DIFT neighbors because 

road/soil emissions are cool and not as buoyant as diesel emissions so they tend to disperse over a more 

localized area, albeit in higher concentrations. Diesel emissions are hot and buoyant so they tend to rise 

in the atmosphere and disperse over a wider area in relatively lower concentrations. EPA’s “Compilation 

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

(EPA 1995, revised December 2003) will be the source of emission factors for fugitive dust emissions. 

The approximate acreage of unpaved area on each terminal will be calculated using GIS mapping tools. 

The estimates will include individual emission calculations for roads as well as unpaved yards, as 

appropriate. 

8.0 Public Roadway Pollutant Burden Estimates 

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

These include roads that would be used by new DIFT traffic, that would have traffic changes due to the 

closure of Lonyo, or that would experience changes in auto and truck traffic as businesses are relocated to 

make way for the DIFT. 

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

• Alternative 1, No Action 

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

• Alternative 2, Improve/ Expand Existing Terminals 

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

scenario that maintains the Dix/Waterman/Vernor gate, traffic could use Livernois/Dragoon 

south of Dix, but in other scenarios, all traffic would be to/from the north on Livernois and 

connect with and I-94.) 
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9 Expressway Terminal – Traffic would link directly to Michigan Avenue, rather than using 

14th Street. 

9 Oak Terminal – A new entrance direct to Evergreen and the ramps linking to I-96 would be 

created, ending use of the Southfield freeway frontage roads and such local streets as 

Artesian. 

9 Moterm Terminal – Traffic would be eliminated from the residential areas served by Fair 

and Chesterfield Streets as the intermodal yard will be accessed directly south of 8 Mile 

Road into the State Fairgrounds. 

• Alternative 3, Consolidate – DIFT truck traffic would use Wyoming and Livernois (north of the 

yard gate). Local traffic on Lonyo would shift to Central and to a lesser extent Wyoming, when 

Lonyo is closed at the rail yard boundaries. Intermodal traffic would be eliminated at other 

terminals. 

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

consolidated, but expand into the State Fairgrounds. 

Using available information on background traffic levels, traffic shifts will be calculated, with new DIFT 

traffic added, and traffic from displaced businesses removed. The vehicle miles of travel will be available 

by link, and using estimated speeds on each link, the pollutant burden will be calculated. Burden 

estimates will include NAAQS pollutants, plus diesel particulate matter and the previously identified air 

toxics. These estimates will be aggregated for autos and trucks, and then combined to get totals for each 

terminal area under each 2025 scenario. Data will be expressed in tons per year. 

9.0 Air Quality Conformity 

The Clean Air Act requires each state to have a State Implementation Plan (SIP) to demonstrate how it 

will attain and/or maintain federal air quality standards. SEMCOG, the Southeast Michigan Council of 

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

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

source (vehicular) emissions in Southeast Michigan. SEMCOG’s 2030 Regional Transportation Plan

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

implementing planned projects are below designated emissions level limits (budgets) set forth in the SIP. 

In so doing, SEMCOG is managing and facilitating the transportation air quality conformity process in 

Southeast Michigan. The DIFT project is subject to air quality transportation conformity review through 

SEMCOG’s inclusion of any DIFT roadway improvements in its RTP. 

Air quality conformity analyses for mobile sources in Southeast Michigan currently involve two major 

pollutants: ozone (and its precursors, volatile organic compounds and nitrogen oxides) and carbon 

monoxide (CO). A new standard will require such analyses for PM2.5 by April 2006. 

Currently, transportation conformity analyses are required for all regions designated by EPA as either 

nonattainment or maintenance for the one-hour ozone, CO, or PM10 standards. Conformity requirements 

for the two new NAAQS - eight-hour ozone and PM2.5 - are now being established. The DEIS will report 

on the attainment status of the region, as follows: 

One-hour Ozone - In 1995, the region was redesignated from nonattainment to 

maintenance for the one-hour ozone standard. At that time, a maintenance plan was 

developed establishing emissions budgets for the two precursors of ozone: volatile 

organic compounds (VOCs) and nitrogen oxides (NOx). In order for a conformity 

determination to be made with regard to the one-hour ozone standard, VOCs emissions 
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cannot exceed the mobile source emissions budgets of 218 tons/day for years 2004-2014, 

and 173 tons/day for years 2015 and beyond. For NOx, emissions cannot exceed the 

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

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

conformity will be the same as for 1-hour. 

Eight-hour ozone - On April 15, 2004, (effective June 15, 2004) the EPA officially 

designated Southeast Michigan a moderate nonattainment area for the 8-hour ozone 

standard. On September 15, 2004, EPA “bumped down” the designation to marginal, 

which means that the area must attain the new standard by June 15, 2007. A SIP is 

currently being developed to address this issue. As noted, for the time being the test of 8-

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

Carbon monoxide - In 1999, the region was redesignated from nonattainment to 

maintenance for CO. Similar to ozone, a positive conformity determination for CO 

requires that emissions in any future year remain at or below the approved mobile source 

emissions budget of 3843 tons/day. On January 28, 2005, (effective March 28, 2005) 

EPA approved a revised CO budget of 1946 tons /day. 

PM10 - As Southeast Michigan currently meets the NAAQS for this pollutant, a regional 

conformity analysis is not required. 

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

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

by April 5, 2006. 

10.0 Mitigation 

The DIFT analysis will include a discussion of practical mitigation measures that would be considered to 

lessen air quality impacts, including from PM2.5 and air toxics. Mitigation includes new technologies and 

strategies to reduce pollution from heavy-duty vehicles (trucks and locomotives) as well as off-road 

equipment. Some of the major technologies/strategies that will be evaluated are described below: 

 Engine Idling Reduction Programs for trucks and locomotives, such as auxiliary power units 

for trucks and automatic shut-off devices for idling locomotives 

 Use of electrified truck parking areas 

 Use of alternative fuels for handling equipment, e.g. natural gas and hybrids 

The railroads that will participate in the DIFT have expressed an interest in mitigation. In fact, CSX Corp. 

is a Charter Partner in the SmartWay Transport program, which is voluntary program that incorporates 

idle reduction, improved logistics management and other strategies to reduce pollution. 

It is anticipated that the FEIS will contain agreements that mandate specific air quality mitigation 

measures, which will be defined as the project advances. Additionally, the paving of the LivernoisJunction Yard is part of the Alternatives 2, 3, and 4. 

11.0 Technical Report 

The DIFT Air Quality Impact Analysis Technical Report prepared for the DIFT EIS will include results 

from the above-stated methodology that characterize the communities around each terminal site. The 
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report will show the locations of residential areas, schools, day care facilities, parks, and hospitals relative 

to the DIFT terminals. The type of activities that would occur at rail yards that could impact these nearby 

facilities (100 to 300 meters away) will be discussed. An evaluation of the potential health effects on 

population is beyond the scope of this analysis. Nevertheless, to the extent the data will foster a 

productive discussion, the occurrence of asthma hospitalizations for sensitive age groups (i.e. the very 

young and/or seniors) compiled by the Michigan Department of Community Health will be included in 

the report. This discussion will recognize that use of such information does not allow conclusions to be 

drawn about a specific project or alternative. 

L:\Projects\2846-A\WP\reports\Air\ Air Quality Protocol DIFT.doc 
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References 

MDEQ. 2004. “2002 Annual Air Quality Report”. Air Quality Division. 

U.S. EPA. 2000. “Taking Toxics Out of the Air“. Office of Air Quality Planning and Standards. EPA425/K-00-002. August 2000. 

U.S. EPA. 1997. “Emission Factors for Locomotives“. Air and Radiation. EPA420-F-97-051. December 

1997. 

U.S. EPA. 1995. “Completion of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume 1: 

Stationary Point and Area Sources.” Non-road Section updated December 2003. Research Triangle 

Park, N.C. 

U.S. EPA. 2002. “Supplements to the Compilation of Air Pollutant Emission Factors AP-42, Fifth Edition, 

Volume 1: Stationary Point and Area Sources.” Research Triangle Park, N.C. 

 
Appendix F 

Memorandum of Understanding 

between 

Railroads and MDOT 

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DETROIT INTERMODAL FREIGHT TERMINAL PROJECT

MEMORANDUM OF UNDERSTANDING

A. Parties

This Memorandum of Understanding (“Memorandum”), effective this ___________ day of 

________________, 2005, by and between (i) the “DIFT Participants,” as many and such of the 

following entities that execute this Memorandum: Canadian National Railway Company 

(“CN”), Canadian Pacific Railway Company (“CPR”), Soo Line Railroad Company (“Soo”) 

(both CPR and Soo, individually and together, sometimes referred to as “CP”), Consolidated Rail 

Corporation (“Conrail”), CSX Intermodal (“CSXI”), CSX Transportation, Inc. (“CSXT”) (both 

CSXI and CSXT, individually and together, sometimes referred to as “CSX”), Norfolk Southern 

Railway Company (“NSR”), Triple Crown Services Company (“TCS”) (both NSR and TCS, 

individually and together, sometime referred to as “NS”) and (ii) the Michigan Department of 

Transportation (“MDOT”), (also individually, “Party”, and collectively, “Parties”). 

B. Purpose/Steps

The purpose of this Memorandum is to set forth the understandings and intentions of the Parties 

with respect to certain terms of the Detroit Intermodal Freight Terminal project (“DIFT”) and 

related issues more particularly described below. 

The parties envision the following steps (as presented graphically on Attachment A): (i) the 

execution of this Memorandum, (ii) the publication of the Draft Environmental Impact Statement 

(“DEIS”) by MDOT, (iii) the determination by MDOT of a Preferred Alternative, (iv) a PreDevelopment Plan Agreement to be executed by the Parties further refining the understandings 

and intention of the Parties, (v) the publication of the Final Environmental Impact Statement 

(“FEIS”) by MDOT, (iv) the signing of a Record of Decision (“ROD”), (vii) the preparation of a 

detailed DIFT Development Plan, and (viii) the execution of individual DIFT Implementation 

Agreements between MDOT and the individual DIFT Participants, as appropriate. 

C. Legal Effect

The following paragraphs are controlling in determining the legal effect of any part of this 

Memorandum. 

The Parties expressly acknowledge that at this point in the pre-design and construction process 

all of the rights and obligations of each Party with respect to the other Parties and the DIFT have 

not been agreed to or determined and that in order to implement and complete the DIFT, further 

negotiation, agreement, and documentation, including selection of a Preferred Alternative, the 

publication of the FEIS, signing of the ROD, and development of a joint governance structure to 

coordinate and oversee the DIFT, will be required in a manner typical for preliminary 

engineering, final engineering and construction ventures of the size and scope contemplated. 

As such, this Memorandum will serve only as a memorialization of the present understandings 

and intentions of the Parties with respect to the DIFT, which shall not be legally binding, but 

DRAFT 
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shall be subject to further agreements by the Parties (as set forth generally in Section B). 

However, if the ROD is not signed by the federal government by December 31, 2006, this 

Memorandum shall automatically terminate. 

Further, the Parties acknowledge that any financial commitment provided by MDOT in connection 

with the DIFT is subject to approval by various agencies including, without limitation, the State 

Transportation Commission, the State Administrative Board, the Attorney General (as to legality 

and form), Department of Civil Service, Department of Management and Budget, and the Federal 

Highway Administration and that no assurance can now be given that such approval will or will 

not be forthcoming regarding such commitment. MDOT will make every reasonable effort to 

ensure funding and completion of the DIFT. MDOT funds or assets that are utilized in the DIFT 

must be for a transportation purpose and provide public benefits. However, if MDOT does not 

obtain the necessary financial commitment or otherwise provide funds to advance the DIFT by 

December 31, 2007, this Memorandum shall automatically terminate. 

D. Project Description

The purpose of the DIFT is to enhance the economic competitiveness of Southeast Michigan and 

the State by improving the rail intermodal transportation service capability and efficiencies for 

business, industry, and the military. The goal is to provide a regional facility, or facilities, owned 

and/or operated by one or more of the DIFT Participants, with sufficient capacity and 

interconnectivity to provide for existing and future intermodal demand and to reduce time, 

monetary costs and congestion to support the economic competitiveness of Southeastern 

Michigan. This will be done by providing necessary intermodal terminal capacity and by 

improving the related rail and highway infrastructure within Wayne and Oakland Counties to 

meet projected intermodal freight demand through 2025. The Parties will work together to: 

• Develop new and expanded rail intermodal terminal capacity for intermodal operations of 

the Class I railroads and their corporate affiliates serving Southeastern Michigan. 

• Make necessary rail infrastructure efficiency and capacity enhancements to facilitate 

intermodal rail freight train operations in Southeastern Michigan. 

• Improve highway infrastructure to facilitate and improve the efficiency of trucking 

operations from and to the intermodal terminals. 

• Secure public and private funding needed to complete the DIFT plans, as generally 

defined in the project’s FEIS and ROD. 
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E. Background

The DIFT has been in development for several years. The growth of U.S. intermodal traffic, the 

enormous influx of double-stack trains and marine containers, and the even more recent 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, the railroads consolidated their intermodal service networks into fewer, larger hub 

terminals. Railroads saw an opportunity to consolidate enough volume in one location to justify 

dedicated intermodal train service and improve the efficiency of their terminals through 

mechanization and elimination of smaller inefficient terminals. 

To respond to the challenge of providing adequate intermodal terminal capacity and in response 

to the Michigan Legislature’s initiative to address intermodal transportation in the Greater 

Detroit Area, MDOT in 1993 and 1994 undertook a review. 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). 

• Because of the auto industry, Detroit leads the nation in its use of carless or RoadRailer 

intermodal technology, i.e. a system wherein the truck trailer is placed directly on rail 

wheels and the trailer becomes an integral part of the rail train. 

• One third of Detroit’s intermodal traffic is trucked to and from other cities. This means 

that it travels by rail to Chicago, Toledo or Windsor, Ontario, for example, and then it is 

trucked to Detroit rather than arriving in Detroit directly by rail. 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, improve air quality, and help ease the need for added 

capacity on the roadway network. 

• The improvement of the Detroit-Windsor rail tunnel and the construction of a new Port 

Huron-Sarnia rail tunnel enhances intermodal access to and from the Detroit area. 

It is important to facilitate and enhance the movement of freight which, in turn, drives jobs and 

economic development growth in Southeast Michigan and plays a key role in national defense. It 

is also important to respect the quality of life of the residents in neighborhoods where terminals 

exist and may expand. In that regard, and consistent with the role of ensuring that business and 

industries involved in the freight transportation segment of the economy continue to have access 

to their markets, MDOT decided in December 2001 to prepare an Environmental Impact 

Statement (EIS) to evaluate alternatives to improve intermodal transportation. 

The DIFT is proposed for the enhanced development of intermodal terminals of the Class I 

railroads (CN, CP, CSXT, and NS) and/or their corporate affiliates serving Southeast Michigan 

and nearby rail and highway infrastructure to provide improved rail intermodal service to 
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business, industry, and the military in the State. Presently, there are four intermodal terminals in, 

or in close proximity to, Southwest Detroit: the separate NS and CSX terminals at DetroitLivernois Yard, and NS’s terminals in Delray and Melvindale. NS also has a fourth terminal 

located at Willow Run, located predominantly in Washtenaw County. There is another 

intermodal terminal in Wayne County, CP/Oak terminal, located in the northwest corner of the 

intersection of I-96 and the Southfield Freeway. The CN/Moterm intermodal terminal is on the 

Wayne County / Oakland County border north of 8 Mile Road between I-75 and Woodward Ave. 

CP/Expressway operated for four years at a terminal near the Michigan Central Depot. 

CP/Expressway service was temporarily suspended in June 2004. 

MDOT has been in the process of developing a Draft Environmental Impact Statement on four 

alternatives: Alternative 1, No Action; Alternative 2, Improve/Expand Existing Terminals; 

Alternative 3, Consolidation of all four Class I Railroads’ intermodal activity (at the LivernoisJunction Yard area); and Alternative 4, Composite Option which involves consolidation of 

intermodal activity of CSX, NS and CP at the Livernois-Junction Yard area and CN remaining 

at its Moterm terminal.6

 In reviewing the various improvements that might be associated with the 

four alternatives, and various development scenarios and options possible with regard to those 

alternatives, MDOT has consulted with representatives of the DIFT Participants. The DIFT 

Participants support the DIFT concept as described in Section D; are willing to continue to 

consult with MDOT as MDOT studies and reviews the four alternatives (i) to complete and 

promulgate its DEIS; (ii) to select a Preferred Alternative; and, (iii) to proceed to a Final 

Environmental Impact Statement and the Record of Decision; however, the Parties acknowledge 

that a Preferred Alternative has not been selected by MDOT and approval of any specific 

alternative by any DIFT Participant cannot occur until after such selection, if ever, and no such 

approval is made or implied by this Memorandum. 

F. Local Area Considerations/Governance

Each of the Parties to this Memorandum will meet at least quarterly once the DIFT’s Record of 

Decision embracing the Final Environmental Impact Statement is signed by the federal 

government to discuss the implementation of the course approved in the ROD, particularly those 

items which affect the local area surrounding the terminal(s) at which investments will be made. 

A public-private governance structure will be formed among the Parties who execute an 

Implementation Agreement to oversee the implementation, operation, and maintenance of the 

DIFT over the life of the project. 

 

6

 At this time, it is not CN’s intent to relocate its intermodal activity to the Livernois-Junction Yard area. 
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G. Terms of MDOT’s Participation

Following approvals by the agencies identified in Section C, MDOT expects to participate in the 

DIFT upon the following general terms: 

1. MDOT will complete the FEIS and ROD process and meet any other requirements 

necessary to qualify for project approval and funding, subject to the cooperation of the 

DIFT Participants with MDOT in the completion of these requirements. 

2. MDOT will make all necessary applications and take other necessary steps to secure 

federal and state approval and funding for the DIFT, subject to the cooperation of the 

DIFT Participants with MDOT in securing state and federal approval and funding. 

3. MDOT will establish the necessary loan/grant programs and procedures to enable 

awarding of loans/grants to DIFT Participants for development of elements of the 

DIFT. 

4. MDOT, in collaboration with and subject to the approval of the DIFT Participants, will 

prepare the DIFT Development Plan. 

H. Terms of DIFT Participants’ Participation

The DIFT Participants, which may at the option of a specific DIFT Participant include that 

company’s wholly-owned railroad or non-railroad subsidiaries, expect to participate in the DIFT 

upon the following general terms and as more fully delineated in a Pre-Development Plan 

Agreement to be negotiated between the Parties based on selection of a Preferred Alternative to be 

documented in the FEIS and ROD: 

1. DIFT implementation will include only those projects that are described in the FEIS, ROD, 

and the subsequently-approved DIFT Development Plan. The primary goal of the FEIS 

and the DIFT Development Plan is to provide the DIFT Participants with individual 

intermodal facilities and related infrastructure improvements satisfactorily sized, 

conditioned, and located for their individual long-term needs which will improve 

intermodal rail movement through the region. The FEIS and the DIFT Development Plan 

will include the following types of projects: 

a. DIFT Intermodal Facilities: The construction of new facilities and the improvement and 

expansion of existing facilities in the Detroit area for the transfer of truck trailers, 

including RoadRailers, and containers between rail and highway modes of 

transportation. 

b. DIFT Rail Access Improvements: Improvements to existing railroad lines in the 

general vicinity of the DIFT Intermodal Facilities to facilitate efficient rail access and 

enhance overall intermodal rail movement through the region. 
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c. DIFT Road Access Improvements: New public roads and/or improvements to existing 

public roads linking the DIFT Intermodal Facilities to other public highways. 

d. DIFT Rail Yard Relocations: The relocation, replacement, or modification of existing 

non-intermodal facilities within the Livernois-Junction Yard terminal area owned by 

Conrail, or other DIFT Participants, as needed to accommodate the DIFT Intermodal 

Facilities. The DIFT Rail Yard Relocations shall provide capacity and capability at 

least equal to the existing facilities being displaced by the DIFT Intermodal Facilities. 

2. The DIFT Development Plan will be a more-detailed version of the FEIS Preferred 

Alternative Engineering Report. Its preparation shall be financed by MDOT, in one or 

more drawings, plans, and/or renderings to be prepared by MDOT and the DIFT 

Participants together; provided, however, that each DIFT Participant will bear the 

respective costs of its review and comment in the preparation of the Plan. Each component 

of the DIFT Development Plan, with the exception of the DIFT Road Access 

Improvements, will be allocated on the DIFT Development Plan to a specific DIFT 

Participant(s). The DIFT Development Plan shall not be considered complete and valid 

until it is approved in writing by each DIFT Participant. 

3. With regard to DIFT Rail Yard Relocations, the fair market value for property belonging to 

DIFT Participants that may be acquired by MDOT for DIFT consistent with the DIFT 

Development Plan will be established by mutual agreement of MDOT and the applicable 

DIFT Participant, using an appraiser mutually agreed to from MDOT’s standing list of 

approved appraisers and using professional independent appraisal techniques and 

considering the highest and best use for the property, pursuant to the provisions and 

requirements of Michigan law and the Federal Uniform Relocation Assistance and Real 

Property Acquisition Policies Act of 1970, as amended, 42 U.S.C. §4601 et seq. (“URAA”) 

and regulations promulgated pursuant thereto. The valuation applied shall be exclusive of 

existing non-intermodal facilities if the existing non-intermodal facilities are to be replaced 

as part of DIFT at no cost to the owner. 

4. The lease rate for property that may be acquired by MDOT for DIFT consistent with the 

DIFT Development Plan and leased to a DIFT Participant, will be established by mutual 

agreement of MDOT and the DIFT Participant, using an appraiser mutually agreed to from 

MDOT’s standing list of approved appraisers and using professional independent appraisal 

techniques and considering the highest and best use for the property, pursuant to the 

provisions and requirements of Michigan law and the Federal Uniform Relocation 

Assistance and Real Property Acquisition Policies Act of 1970, as amended, 42 U.S.C. 

§4601 et seq. (“URAA”) and regulations promulgated pursuant thereto; provided, however, 

that (i) the lease rate is to be based upon the land valuation only, without improvements; 

(ii) the lease rate for all property to become part of the DIFT facilities at or near the 

Livernois-Junction Yard shall be based on the fair market value of the Livernois-Junction 

Yard property; and, (iii) no property will be leased to any DIFT Participant for an amount 

per acre less than the per acre rental rate applied to the Livernois-Junction Yard property. 
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5. In order to receive public funding, each DIFT Participant will, following the approval of the 

DIFT Development Plan, enter into a separate agreement (“DIFT Implementation 

Agreement”) with MDOT to cover the construction cost sharing, construction schedule, 

operation, maintenance, and ownership of those portions of the DIFT Development Plan 

allocated to it or on its property. No DIFT Participant is required to enter into a DIFT 

Implementation Agreement, but each agrees that it will not unreasonably prevent another 

DIFT Participant from progressing with MDOT its individual portions of the DIFT 

Development Plan. 

6. In the case in which DIFT Alternative 2, 3 or 4 is designated in the FEIS and the ROD as 

the Preferred Alternative, and except where a DIFT Participant determines to self-fund its 

own property improvements, the DIFT Pre-Development Plan Agreement will generally 

include the following provisions and/or address the following issues: 

a. Property acquisition cost, construction cost, ownership and timetables of DIFT 

Intermodal Facilities: 

 (i) Subject to the appropriation of sufficient funds, MDOT will, at its sole cost and 

expense, acquire and clear for construction all property not owned by any DIFT 

Participant that is required for a DIFT Intermodal Facility as defined by the 

DIFT Development Plan. Such property will then be leased to the DIFT 

Participant by MDOT at a lease rate based on the fair market value of the 

adjoining railroad terminal property determined in accordance with paragraph 

H.4. 

 (ii) MDOT and the DIFT Participants will share in: (a) paving-related construction 

cost; and, (b) the other construction cost of the DIFT Intermodal Facilities 

allocated to the various DIFT Participants. 

 (iii) Each DIFT Intermodal Facility will be solely controlled, operated, and 

maintained by the DIFT Participant to which it is allocated. Subsequent to the 

completion of additions and improvements and at its discretion and expense, the 

DIFT Participant may make modifications to the DIFT Intermodal Facility and 

may lease or sublease the DIFT Intermodal Facility to other parties. 

Nevertheless, for any property leased by MDOT to the DIFT Participant, 

MDOT concurrence will be required before the property is subleased, which 

concurrence will not be unreasonably withheld. 

 (iv) The timetables for the type of work covered by this subsection will be as 

provided for in the DIFT Development Plan, which will follow approval of the 

DIFT Record of Decision. 

 

b. Construction cost, ownership, and timetables of DIFT Road Access Improvements, 

DIFT Rail Access Improvements, and DIFT Rail Yard Relocations: 

 (i) DIFT Road Access Improvements: MDOT will be responsible for securing all 

funds (with the exception of the Central Avenue underpass) from non-DIFT 

Participant sources for all construction and property acquisition cost of the 

DIFT Road Access Improvements. MDOT or local road agencies will own and 

maintain the DIFT Road Access Improvements as public roads. 
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 (ii) DIFT Rail Access Improvements: MDOT and the DIFT Participants will share 

in the construction cost of the DIFT Rail Access Improvements allocated to the 

various DIFT Participants, which allocation will be negotiated for each such 

improvement. The DIFT Participant who owns or leases the property to which 

a specific DIFT Rail Access Improvement is allocated shall own and maintain 

that DIFT Rail Access Improvement. 

 (iii) DIFT Rail Yard Relocations: Subject to the appropriation of sufficient funds, 

MDOT will fully fund all construction and property acquisition cost for DIFT 

Rail Yard Relocations depicted on the DIFT Development Plan. The DIFT 

Participant who owns or leases the property to which a specific DIFT Rail Yard 

Relocation is allocated shall own and maintain that DIFT Rail Yard Relocation 

and control its use consistent with the lease agreement with MDOT. 

(iv) The timetables for the type of work covered by this subsection will be as 

provided for in the DIFT Development Plan, which will follow approval of the 

DIFT Record of Decision. 

c. If the DIFT Development Plan includes an expanded Central Avenue underpass 

 (i) MDOT and the DIFT Participants will share in the cost of the Central Avenue 

underpass if the DIFT Participant is (a) located at the Livernois-Junction Yard 

terminal in its current form; or, (b) located north of John Kronk Street. The 

Parties have not yet agreed upon their respective shares of the cost of the 

expansion of the Central Avenue underpass. 

 (ii) The timetable for this work will be as provided for in the DIFT Development 

Plan, which will follow approval of the DIFT Record of Decision. 

d. Certain trackage rights may be necessary to carry out the improvements in this section. 

Where so required, DIFT Participants will, subject to STB authorization, negotiate 

bilateral agreements for the movements involved. Such agreements, subject to the 

provisions of confidentiality agreements, will be incorporated into the DIFT 

Development Plan and will also address needed capacity enhancement and/or operating 

issues required to accommodate such trackage rights requirements. 

7. In the case in which the DIFT FEIS and ROD designate either Alternative 3 or Alternative 

4 as the Preferred Alternative, the DIFT Pre-Development Plan Agreement will generally 

include the following provisions and/or address the following issues: 

a. Conrail’s agreement to negotiate a trackage rights agreement with CN and/or CP, 

subject to STB authorization, to connect the existing CN and/or CP railroad lines with 

the DIFT Intermodal Facility to be allocated to CN and/or CP. The agreement will 

include terms customary in trackage rights agreements and provide for the payment of 

trackage rights fees reasonable and customary for such movements. 

b. Property acquisition cost and ownership of DIFT Intermodal Facilities: 

 (i) If Conrail property is needed for a DIFT Intermodal Facility to be allocated to 

CN and/or CP, MDOT will pay Conrail an amount per acre equal to the 

Livernois fair market value determined in accordance with paragraph H.3. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

F - 9

MDOT will then lease the property to CN and/or CP at a lease rate based on the 

Livernois-Junction Yard fair market value as provided in paragraph H.4. 

 (ii) If Conrail property is needed for a DIFT Intermodal Facility to be allocated to 

CSX or NS, Conrail, CSX and/or NS, as appropriate and/or applicable, will 

agree to arrange for the property to be sold, transferred, or exchanged by 

Conrail to CSX or NS, as applicable, for an amount per acre equal to the 

Livernois-Junction Yard fair market value. 

8. If an applicable DIFT Implementation Agreement calls for consolidating at the LivernoisJunction Yard area CN and/or CP intermodal operations, then MDOT will establish [a] 

Michigan Rail Infrastructure Development Fund[s], covering the reimbursement of certain 

qualified railroad and other investments, for such DIFT Participant[s] with intermodal 

facilities presently located at the Livernois-Junction Yard area. The details of such fund[s] 

will be more fully delineated in the Pre-Development Plan Agreement. 

NOW, THEREFORE, it is the intent by and between the Parties hereto to be committed to 

partner together toward completing the DIFT planning as described, subject to the terms of 

future agreements between MDOT and the participating DIFT Participants, to continue this 

partnership as deemed mutually beneficial, and to move forward to enhance the competitiveness 

of Southeast Michigan and the State by developing necessary intermodal rail terminal capacity 

and improving the supporting rail and highway infrastructure. 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

F - 10

IN WITNESS HEREOF, the Parties have caused their respective officers, duly authorized, to 

execute this Memorandum to be effective as of the date first written above. This Memorandum 

may be executed in counterparts with separate execution pages and different effective dates for 

each of the DIFT Participants; provided, however, that each counterpart shall be executed by 

MDOT, and the date of MDOT’s execution shall be the effective date of that counterpart. 

CANADIAN NATIONAL RAILWAY MICHIGAN DEPARTMENT 

COMPANY OF TRANSPORTATION 

BY: BY: 

TITLE: TITLE: 

CANADIAN PACIFIC RAILWAY 

COMPANY 

BY: 

TITLE: 

CONSOLIDATED RAIL CORPORATION 

BY: 

TITLE: 

CSX INTERMODAL 

BY: 

TITLE: 

CSX TRANSPORTATION, INC. 

BY: 

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

F - 11

NORFOLK SOUTHERN RAILWAY COMPANY 

BY: 

TITLE: 

SOO LINE RAILROAD COMPANY 

BY: 

TITLE: 

TRIPLE CROWN SERVICES COMPANY 

BY: 

TITLE: 

L:\Projects\2846-A\WP\MOU Rev 4-26-05 clean.doc 
DIFT Draft Environmental Impact Statement and Draft Section 4(f) Evaluation 

F - 12
INDEX 

Page

Act 451, Part 361 .................................................................................................................. 1-40, 1-66, 4-99 

Air Quality ......................................................................................................................................1-41, 4-99 

Alternatives.........................................................................................................................................1-3, 3-1 

Alternatives Eliminated from Further Study.....................................................................................1-30, 3-2 

Archaeological Resources......................................................................................................................4-152 

Bicycle Considerations ............................................................................................................................4-50 

Clean Water Act...........................................................................................................1-64, 1-66, 4-182, 5-3 

Community Cohesion .....................................................................................................................1-38, 4-35 

Community Facilities...............................................................................................................................4-45 

Construction Noise.....................................................................................................................................5-6 

Contaminated Sites .......................................................................................................................1-58, 4-164 

Cost ...............................................................................................................................................1-66, 4-184 

Crashes............................................................................................................................................1-33, 4-35 

Cultural Resources............................................................................................................................1-56, 5-8 

Description of the Proposed Project...........................................................................................................1-1 

Early Coordination ....................................................................................................................................7-1 

Ecological Resources ...............................................................................................................................1-49 

Economics.......................................................................................................................................1-40, 4-89 

Emergency Response....................................................................................................................1-64, 4-182 

Energy...........................................................................................................................................1-65, 4-184 

Environmental Consequences....................................................................................................................4-1 

Environmental Justice.....................................................................................................................1-38, 4-70 

Executive Order 11990 ......................................................................................................... 1-66, 4-150, 5-3 

Executive Order 11998 ..........................................................................................................................4-150 

Executive Order 12898 ............................................................................................................................4-70 

Farmlands........................................................................................................................................1-38, 4-99 

Federal Agency Coordination ....................................................................................................................7-1 

Floodplains.............................................................................................................................................4-150 

Floodways..............................................................................................................................................4-150 

Groundwater .....................................................................................................1-49, 1-58, 4-149, 4-171, 5-4 

Historic Resources ................................................................................................................ 1-56, 4-152, 6-3 

Land Use .........................................................................................................................................1-38, 4-96 

Lighting.........................................................................................................................................1-65, 4-183 

List of Preparers.........................................................................................................................................8-1 
INDEX (continued)

Page

Maintaining Traffic...........................................................................................................................4-53, 5-5 

Mass Transit.............................................................................................................................................4-52 

Mitigation...................................................................................................................................................5-1 

Need ...........................................................................................................................................................2-3 

No Action Alternative............................................................................................................... 1-3, 3-2, 4-88 

Noise ............................................................................................................................................1-47, 4-128 

Ozone ................................................................................................................................ 1-41, 4-101, 4-103 

Parkland .................................................................................................................................................4-162 

Particulates........................................................................................................................ 1-41, 4-115, 4-124 

Pedestrian Considerations........................................................................................................................4-50 

Permits .................................................................................................................................. 1-66, 4-184, 5-3 

Property Taxes .........................................................................................................................................4-93 

Public Involvement ....................................................................................................................................7-1 

Purpose.......................................................................................................................................................2-1 

Relocations......................................................................................................................................1-38, 4-88 

Safety ..............................................................................................................................................1-33, 4-35 

Scoping .....................................................................................................................................................A-1 

Section 4(f) ................................................................................................................................................6-1 

Section 401 Permit............................................................................................................................1-66, 5-3 

Section 404 Permit............................................................................................................................1-66, 5-3 

Sedimentation ............................................................................................................................................5-2 

Social Impacts..........................................................................................................................................4-35 

Soils ..............................................................................................................................................1-65, 4-184 

State Agency Coordination ........................................................................................................................7-1 

Surface Water.............................................................................................................................................5-5 

Terminal Security..........................................................................................................................1-65, 4-182 

Threatened and Endangered Species......................................................................................................4-149 

Title VI............................................................................................................................................1-40, 4-53 

Traffic ...............................................................................................................................................1-33, 4-1 

Vibrations......................................................................................................................................1-47, 4-128 

Visual Conditions..........................................................................................................................1-56, 4-163 

Water Quality.........................................................................................................................................4-149 

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

Wetlands ................................................................................................................................................4-150 

Zoning......................................................................................................................................................4-96