Appendix F3 NYSHPO Correspondence
1 July 3, 2020 

Western Rail Yard Platform Project

Section 106 Documentation

Proposed Area of Potential Effects (APE)

 July 3, 2020 

A. PROJECT OVERVIEW AND BACKGROUND 

WRY Tenant LLC and the National Railroad Passenger Corporation (Amtrak) are partnering in a joint 

venture (the Project Sponsor) to seek Federal financial assistance through the Railroad Rehabilitation and 

Improvement Financing (RRIF) Program, which is administered by the U.S. Department of Transportation 

(DOT) Build America Bureau (Bureau). The Federal Railroad Administration (FRA) is the lead agency 

preparing the environmental impact statement (EIS) to ensure compliance with the National Environmental 

Policy Act of 1969 (NEPA) and other environmental laws. The Project Sponsor has expressed an interest 

in seeking financial assistance provided by the Bureau to fund the construction of a Platform and a Tunnel 

Encasement on the 13-acre Western Rail Yard site located on the western half of the Metropolitan 

Transportation Authority (MTA) Long Island Rail Road (LIRR) John D. Caemmerer Yard (aka “Hudson 

Yards”) (Block 676, Lot 3) in New York County (Manhattan), New York (Figure 1). The Proposed Action 

would include: (1) a structural Platform (Platform); and (2) a railroad right-of-way preservation Tunnel 

Encasement (Tunnel Encasement) (the “Proposed Action”, also referred to here as the “Project”) to allow 

for privately-funded mixed-use development and public open space above the Platform as described below. 

The two components of the Project have previously been reviewed in accordance with local, state, and 

federal environmental planning requirements as follows: 

 The Platform and mixed-use development (Overbuild) were reviewed in accordance with Section 14.09 

of the New York State Parks, Recreation and Historic Preservation Law during the State Environmental 

Quality Review Act (SEQRA) and City Environmental Quality Review (CEQR) review for the Western 

Rail Yard Project (08PR03724, 08PR04116) in the 2009 Western Rail Yard Project Final 

Environmental Impact Statement (2009 SEQRA/CEQR FEIS). As part of that evaluation, New York 

State Office of Parks, Recreation and Historic Preservation (SHPO) determined that construction near 

and around the High Line in Western Rail Yard is appropriate (since historically buildings have been 

located in this manner) subject to the stipulations in a Letter of Resolution developed with MTA and 

the New York City Planning Commission. For archaeological resources, the 2009 SEQRA/CEQR FEIS 

relied on the assessment of potential archaeological sensitivity prepared for the 2004 No. 7 Subway 

Extension-Hudson Yards Rezoning and Development Program FGEIS, which concluded that the 

Western Rail Yard was not sensitive for archaeological resources. In a comment letter dated April 29, 

2009, SHPO confirmed it had no further archaeological concerns with the Western Rail Yard Project. 

The Overbuild was approved in 2009 by the New York City Planning Commission and adopted by the 

New York City Council as zoning text and map amendments to the New York City Zoning Resolution. 

The Overbuild development is now as-of-right development, since it will be built in accordance with 

the New York City Zoning Resolution’s existing zoning controls, which regulate type of use, building 

envelopes, publicly accessible open space areas, street wall controls, retail continuity, and maximum 

floor area ratio (i.e., the ratio of floor area to lot size). 

 The Tunnel Encasement is the third and westernmost segment of the entire right-of-way preservation 

concrete casing that previously underwent environmental reviews1 led by FRA, which included reviews 

 

1 Finding of No Significant Impact, Environmental Assessment for Construction of a Concrete Casing in the Hudson 

Yards, New York, New York. (FRA and Amtrak, May 2013); and Finding of No Significant Impact, Supplemental 

Environmental Assessment for Construction of a Concrete Casing Extension in the Hudson Yards, New York, New 

York. (FRA and Amtrak. November 2014).
HUDSON

RIVER

Convention

Center

Eastern

Rail Yard

Western

Rail Yard

Hudson

Yards

Tenth Ave

W 34th St

Twelfth Ave

W 31st St

W 33rd St

Dye

r Ave

Eleventh Ave

W 30th St

W 29th St

W 27th Dr

W 36th St

Hudson River Greenway

High Line

W 28th St

W 27th St

WESTERN RAIL YARD INFRASTRUCTURE PROJECT

Project Location and Area of Potential Effect

Figure 1

Essex

Hudson

Manhattan

Bergen

Brooklyn

Queens

Bronx

NJ

NY

!\

6.23.20

0 400 FEET

W 35th St

Data source: NYS ITS GIS Program Offce; NYS Digital Orthoimagery Program (NYSDOP), 2018 Imagery

Project Site (Western Rail Yard)

Area of Potential Effect (see accompanying APE Memo)

Hudson Yards

Approximate Terra Firma Area

Proposed Platform

Existing Concrete Encasement

Proposed Tunnel Encasement

Existing High Line Park (Remains Unaltered)
Western Rail Yard Platform Proposed Area of Potential Effects (APE) 

2 July 3, 2020 

in accordance with Section 106 of the National Historic Preservation Act of 1966 (as amended). In a 

letter dated April 1, 2013, SHPO confirmed the agency had no archaeological concerns regarding the 

concrete encasement. In a letter datedc July 22, 2014, SHPO concurred with FRA’s determination that 

the undertaking would have no adverse effects on historic properties provided that construction 

monitoring of the High Line would occur per the New York City Building Code Technical Policy and 

Procedure Notice #10/88 (14PRO2712). 

As described in the Notice of Intent (Federal Register [June 15, 2020/Vol. 85, No. 115), the purpose of the 

Proposed Action is to cover and protect the active railroad tracks and LIRR support facilities in the Western 

Rail Yard so that the Project Sponsor can provide additional new capacity for real estate development and 

house critical life safety and mechanical, electrical and plumbing support services for the Yard, including 

new lighting, sprinklers, and an extensive platform ventilation system. The purpose of the Tunnel 

Encasement is to preserve a right-of-way through the Western Rail Yard to support the future construction 

of a trans-Hudson passenger rail crossing into New York Penn Station. 

FRA is coordinating the NEPA process for the Project with compliance with Section 106 of the National 

Historic Preservation Act (Section 106). FRA intends to identify a Preferred Alternative for the Project in 

the Draft EIS. The Project, which is also the undertaking for purposes of Section 106, would include the 

following major components: 

PLATFORM COMPONENT

 Construction of a 425,000 square foot (9.8 acre) structural platform on the Western Rail Yard site, to 

be supported by approximately four hundred (400) caissons drilled up to 120 feet deep into bedrock 

below. The Platform would serve as the support for the as-of-right Overbuild of approximately 5.7 

million gross square feet of new commercial, residential, and school uses and public open space. 

 Installation of life safety and mechanical, electrical and plumbing support services for the Western Rail 

Yard, including new lighting, sprinklers and an extensive platform ventilation system, which would be 

integrated into the system for the Eastern Rail Yard site, across Eleventh Avenue. 

 Reconstruction and upgrades to other LIRR support services including existing emergency electrical 

equipment, approximately 20,000 square feet of railroad staff facilities and rail car cleaning services. 

At its northern end, the Western Rail Yard contains a 12-car cleaning platform used to service and clean 

railroad equipment that is currently not in use because operations were moved offsite before 

construction of the adjacent Eastern Rail Yard. The cleaning platform and three LIRR service buildings 

on the western edge of the Western Rail Yard will be demolished to allow for the Platform construction. 

These structures have been built since the rail yard was reconstructed in 1986 and are not historic. Once 

construction of the Platform is completed, the cleaning platform will be reconstructed in its former 

location. Interim service buildings will be constructed on the western portion of the terra firma (at 

grade solid ground) site, adjacent Twelfth Avenue; LIRR’s security fence would be extended around 

the interim service buildings site and would be controlled by LIRR. The service buildings will be 

reconstructed in approximately the same footprint, and in accordance with LIRR program requirements. 

The service buildings will be designed to comply with applicable codes for an enclosed rail yard, New 

York State Building Code requirements, and to meet accessibility requirements. 

TUNNEL ENCASEMENT COMPONENT (RAILROAD RIGHT-OF-WAY PRESERVATION)

 The Tunnel Encasement would be an extension of the existing concrete casing, and would extend from 

Eleventh Avenue to 30th Street, to preserve railroad right-of-way through the southern portion of the 

Western Rail Yard site. This segment of Tunnel Encasement would connect to the recently constructed 

underground right-of-way preservation concrete casing, which begins just east of Tenth Avenue 
Western Rail Yard Platform Proposed Area of Potential Effects (APE) 

3 July 3, 2020 

(between 30th and 32nd Streets), runs beneath the Eastern Rail Yard, and terminates at the eastern edge 

of Eleventh Avenue just north of 30th Street (completed in 2015). The Tunnel Encasement would be 

605 feet long, between 50 and 65 feet wide and between 27 and 38 feet high beneath Western Rail 

Yard. This Tunnel Encasement would be constructed through a terra firma portion of the Western Rail 

Yard site that will not be covered by the new platform. The Tunnel Encasement would originate at the 

western end of the underground concrete casing in the Eastern Rail Yard, extend under the Eleventh 

Avenue viaduct, and continue diagonally across approximately two-thirds of the Western Rail Yard, 

underneath a portion of the High Line2, and end at 30th Street. 

B. DEVELOPMENT OF THE AREA OF POTENTIAL EFFECTS 

Section 106 of the National Historic Preservation Act requires Federal agencies to consider the effects on 

historic properties of projects they carry out, assist, fund, permit, or approve. If a federal or federallyassisted project has the potential to affect historic properties, a Section 106 review is required. Federal 

agencies carry out their Section 106 obligations according to the regulations issued by the Advisory Council 

on Historic Preservation at 36 CFR Part 800. Section 106 is a four-step decision-making process; one 

required step is to define the Area of Potential Effects (APE), which is “the geographic area or areas within 

which an undertaking may directly or indirectly cause alterations in the character or use of historic 

properties, if such properties exist” (36 CFR § 800.16[d]). Historic properties are buildings, structures, sites, 

objects, or districts that are listed in or eligible for listing in the National Register of Historic Places 

(NRHP). The APE is influenced by the scale and nature of an undertaking. 

The proposed APE described herein and depicted in Figure 1 has been developed by FRA to account for 

potential effects of the Project on historic properties, based on the conceptual design for the Project 

available at this time. In general, potential effects on historic properties can include demolition, physical 

alteration, or damage, including effects caused by vibration; isolation of a historic property from its 

surrounding environment; and the introduction of visual, audible, or atmospheric (e.g., pollutants) elements 

that are out of character with a historic property or that alter its historic setting and context.3 Effects may 

include reasonably foreseeable effects caused or enabled by the Project that may occur later in time, be 

farther removed in distance, or be cumulative with other effects from other projects. Adverse effects can 

occur when a project may alter any of the characteristics of a historic property that qualify the property for 

inclusion in the National Register of Historic Places (NRHP) in a manner that would diminish the integrity 

of the property's location, design, setting, materials, workmanship, feeling, or association. 

FRA anticipates that the following types of construction activities and permanent features would be 

necessary for the Project: 

PLATFORM COMPONENT

 Construction of a 425,000 square foot (9.8 acre) structural platform, including new lighting, sprinklers 

and an extensive platform ventilation system, to be supported by hundreds of caissons drilled up to 120 

feet deep into bedrock below; 

 Reconstruction and upgrades to other LIRR support services including existing emergency electrical 

equipment, approximately 20,000 square feet of railroad staff facilities and rail car cleaning services. 

 

2 The High Line is an historic elevated former freight rail line, which has been converted into a public aerial linear park 

and greenway. The High Line was determined eligible for listing on the State and National Registers of Historic 

Places in 2004.

3 National Register Bulletin, Defining Boundaries for National Register Properties, prepared by the National Park

Service.
Western Rail Yard Platform Proposed Area of Potential Effects (APE) 

4 July 3, 2020 

At its northern end, Western Rail Yard contains a 12-car cleaning platform used to service and clean 

railroad equipment. The cleaning platform, and service buildings, will be demolished to allow for the 

Platform construction, and will be reconstructed as part of the Project, as described above. The interim 

service buildings will be constructed on the western portion of the terra firma site, adjacent Twelfth 

Avenue. 

 Construction staging areas for the construction of the Platform (most staging is planned to occur on the 

Project site; possibly extending into some adjacent sidewalks and parking lanes during certain phases 

of construction). No off-site staging is anticipated. 

TUNNEL ENCASEMENT COMPONENT

 Excavation of approximately 66,000 cubic yards of soil and 14,000 cubic yards of rock for the 

construction of the Tunnel Encasement for the preservation of rail right-of-way. The volumes of soil 

and rock to be excavated have been estimated by Amtrak based on the Tunnel Encasement design; these 

volumes will be more precisely determined during the bid process for procuring the Tunnel Encasement 

construction contractor. 

 Demolition of LIRR’s Emergency Services Building (ESB) (a structure that primarily houses utility 

infrastructure) in the Western Rail Yard, temporary relocation of ESB functions, and reconstruction of 

the building following completion of the Tunnel Encasement. The temporary ESB functions will be 

located in the southeast corner of the Western Rail Yard on a small portion of existing elevated concrete 

(at street level to maximize flood protection). This relocation will provide redundant fire water sourcing 

to the yard, eliminating the need for the existing secondary water tank and fire pump room. Therefore, 

the interim emergency services facility will function essentially as a substation for emergency facility 

(not train) power and communications. 

 Temporary underpinning of the High Line. Temporary underpinning may be required where the Tunnel 

Encasement would cross beneath a portion of the High Line that runs along West 30th Street between 

Eleventh and Twelfth Avenues. This work will include approximately 280 feet of underpinning and resupport onto new foundations of either total (both) columns or partial (one) columns, as described in 

more detail below. The westernmost 80 feet of underpinning on 30th Street will re-support columns of 

the High Line that would require re-support for the Hudson Tunnel mining approach. 

 Construction staging areas for the construction of the Tunnel Encasement. Most staging is planned to 

occur on the Project site; possibly extending into some adjacent sidewalks and parking lanes during 

certain phases of construction. No off-site staging is anticipated. 

In addition, the privately-funded Overbuild, which would be enabled by the Project, includes 5.7 million 

gross square feet of residential, commercial, school, and open space uses on top of the Platform and on the 

terra firma portion of the Western Rail Yard site. Construction of the Overbuild would introduce new, 

permanent visual components on the Western Rail Yard site. 

The proposed APE for the Project is discussed in greater detail below. Existing conditions in the proposed 

APE are depicted in Figures 2 through 5. 

C. DESCRIPTION OF THE PROPOSED AREA OF POTENTIAL EFFECTS 

The proposed APE (depicted in red-and-white dash in Figure 1) encompasses the area 800 feet in all 

directions from the Western Rail Yard site boundary (depicted in yellow in Figure 1). The proposed APE 

takes into account construction-related effects as well as the visibility of permanent above-grade Project 

components, including the proposed Platform and Tunnel Encasement. The proposed APE also accounts 

for the potential indirect effects of the Overbuild. The proposed APE encompasses a sufficiently large area 
6.15.20

Figure 2

View south from West 34th Street and Eleventh Avenue 2

View south from West 34th Street and Hudson Boulevard East 1

Photographs of Proposed APE

WESTERN RAIL YARD INFRASTRUCTURE PROJECT Source: AKRF Source: AKRF
6.15.20

Figure 3

Photographs of Proposed APE

WESTERN RAIL YARD INFRASTRUCTURE PROJECT

View southeast from northern end of High Line, near 

Twelfth Avenue and West 34th Street

3

Eleventh Avenue, view north from West 30th Street 4

South side of West 30th Street, west of Eleventh Avenue 5

Source: AKRF Source: AKRF Source: AKRF
6.15.20

Figure 4

Photographs of Proposed APE

WESTERN RAIL YARD INFRASTRUCTURE PROJECT

West 30th Street, view west from Eleventh Avenue 6

View east toward project site, from Route 9A at West 30th Street 7

North side of West 29th Street, west of Eleventh Avenue 8

Source: AKRF Source: AKRF Source: AKRF
6.15.20

Figure 5

Photographs of Proposed APE

WESTERN RAIL YARD INFRASTRUCTURE PROJECT

View southeast from High Line, from roughly 

West 31st Street

9

Eleventh Avenue looking north from near West 33rd Street 10

Route 9A, looking north from near West 33rd Street 11

Source: AKRF Source: AKRF Source: AKRF
Western Rail Yard Platform Proposed Area of Potential Effects (APE) 

5 July 3, 2020 

to account for permanent visual impacts of the Project. The APE takes into consideration topography, 

vegetation, and the existing built environment that diminish sight lines. Field reconnaissance conducted by 

AKRF and information provided by the Project Sponsor regarding the characteristics of the Project 

components were utilized to help define the proposed APE. The analysis of potential effects to belowground (archaeological) resources will be limited to the area of anticipated ground disturbance, which is 

within the Western Rail Yard site boundary. 

The proposed APE for the Project is consistent with the APE developed for the 2009 SEQRA/CEQR FEIS 

for the Western Rail Yard site, and encompasses the smaller APE developed for FRA’s previous evaluation 

of the entire right-of-way preservation concrete encasement (of which the Tunnel Encasement is the 

westernmost third segment, as described above). 

PLATFORM COMPONENT 

Potential effects as a result of construction of the Platform are included in the proposed APE. Construction 

effects could include noise and vibration effects to nearby architectural resources from construction 

activities, including heavy truck movements. The Platform development would involve subsurface ground 

disturbance on the site, which could directly impact archaeological resources if any are present. Once 

constructed, the Platform would not introduce any permanent visual components; it would be covered by 

the privately-funded, as-of-right Overbuild (described above). 

TUNNEL ENCASEMENT COMPONENT

Construction of the railroad right-of-way preservation Tunnel Encasement is included in the proposed APE. 

Construction effects could include noise and vibration effects to nearby architectural resources from 

construction activities, including heavy truck movements. Construction of the Tunnel Encasement would 

involve subsurface ground disturbance on the site, which could directly impact archaeological resources if 

any are present. Once constructed, the Tunnel Encasement would not introduce any permanent visual

components above grade. 

CONSTRUCTION STAGING AREAS 

The proposed APE includes the construction staging areas for the Platform and the Tunnel Encasement. 

At-grade and subsurface ground disturbance would occur in these areas, which could directly impact 

archaeological resources if any are present. The construction staging areas would not have permanent visual

impacts. Therefore, the potential for construction-related impacts for these two Project components would 

be limited to a 100-foot buffer around the Western Rail Yard site boundary, that falls within the 800-foot 

APE. 

UNDERPINNING OF STRUCTURES 

Underpinning, which consists of the re-supporting of the below-grade foundations of an existing building

or structure on new foundations, may be required beneath the High Line where the Tunnel Encasement 

would cross beneath a portion of the High Line that runs along West 30th Street between Eleventh and 

Twelfth Avenues. In general, beams will be installed across the proposed open cut (one on each side of the 

columns), the High Line columns will be supported on those beams utilizing brackets mounted to the 

columns, new foundations will be built down to the concrete casing roof of other new deep foundations, 

and support of the High Line will be transferred onto these new, permanent foundations.4 Underpinning 

 

4

 In accordance with High Line Park’s easement to utilize the rail structure, which states that the original rail 

use must be able to be restored, the underpinning for permanent re-support of the High Line incorporates 

full historic rail live loading, which is significantly greater than the current park use. 
Western Rail Yard Platform Proposed Area of Potential Effects (APE) 

6 July 3, 2020 

the High Line would not have permanent visible impacts. The potential for construction-related impacts for 

this work, which could occur as a result of vibration from construction activities, falling debris, and/or 

inadvertent damage caused by heavy machinery, among other things, would be limited to a 100-foot buffer 

around the portions of the High Line to be underpinned, that falls within the 800-foot APE. 
U.S. Department 1200 New Jersey Avenue, SE 

of Transportation Washington, DC 20590

Federal Railroad 

Administration 

 

July 3, 2020 

Mr. Daniel Mackay 

Deputy Commissioner 

Division for Historic Preservation 

New York State Historic Preservation Office 

Peebles Island State Park, P.O. Box 189 

Waterford, NY 12188 

Re: Western Rail Yard Platform Project, New York County, NY 

Initiation of Section 106 Consultation 

Proposed Area of Potential Effects 

Preliminary List of Consulting Parties 

Dear Mr. Mackay: 

WRY Tenant LLC and the National Railroad Passenger Corporation (Amtrak) are partnering in a 

joint venture (Project Sponsor) to seek Federal financial assistance through the Railroad 

Rehabilitation and Improvement Financing (RRIF) Program, which is administered by the U.S. 

Department of Transportation (USDOT) Build America Bureau (Bureau). The Project Sponsor has 

expressed an interest in seeking financial assistance provided by the Bureau to fund the 

construction of a Platform and a Tunnel Encasement on the 13-acre Western Rail Yard site located 

on the western half of the Metropolitan Transportation Authority (MTA) Long Island Rail Road 

(LIRR) John D. Caemmerer Yard (aka “Hudson Yards”) (Block 676, Lot 3) in New York County 

(Manhattan), New York (Figure 1). 

The Proposed Action includes: (1) a structural Platform (Platform); and (2) a railroad right-of-way 

preservation Tunnel Encasement (Tunnel Encasement) (the “Proposed Action,” also referred to 

here as the “Project”) to allow for privately-funded mixed-use development and public open space 

above the Platform. The USDOT’s Federal Railroad Administration (FRA) is the lead federal 

agency preparing an environmental impact statement (EIS) for the Project to ensure compliance 

with the National Environmental Policy Act of 1969 (NEPA) and other applicable environmental 

laws.

The purpose of the Project is to cover and protect the active railroad tracks and LIRR support 

facilities in the Western Rail Yard so that the Project Sponsor can provide additional new capacity 

for real estate development and house critical life safety and mechanical, electrical and plumbing 

support services for the yard, including new lighting, sprinklers and an extensive platform 

ventilation system. The Platform would serve as the support for privately-funded mixed-use 
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Western Rail Yard Platform Project 2 

development and public open space above. Construction of the Platform would include the 

reconstruction and upgrades to other LIRR support services including existing emergency 

electrical equipment, approximately 20,000 square feet of railroad staff facilities, and rail car 

cleaning services. Once complete, the entire yard would contain comprehensive state-of-the-art 

life safety systems, securing this critical infrastructure and protecting both the workers and the 

railroad equipment in the yard. The Tunnel Encasement would be constructed underneath the 

Western Rail Yard site. The purpose of the Tunnel Encasement is to preserve a right-of-way 

through the Western Rail Yard to support the future construction of a trans-Hudson passenger rail 

crossing into New York Penn Station. New rail infrastructure is part of Amtrak’s effort to maintain 

a functional, resilient, and improved trans-Hudson passenger rail crossing into New York Penn 

Station, maintain existing Amtrak intercity and NJ TRANSIT commuter rail service on the 

Northeast Corridor, and to support future increases in the capacity of the regional rail system 

should they be pursued. The Project does not include any efforts to make the encasement 

operational. This preserved right-of-way may be used by a new Hudson River Tunnel that is being 

evaluated by FRA as part of the separate and independent Hudson Tunnel Project, which is the 

subject of an on-going Environmental Impact Statement (EIS). 

The two components of the Project have previously been reviewed by your office in accordance 

with local, state and federal environmental planning requirements as follows: 

x The Platform and mixed-use development (Overbuild) were reviewed in accordance with 

Section 14.09 of the New York State Parks, Recreation and Historic Preservation Law 

during the State Environmental Quality Review Act (SEQRA) and City Environmental 

Quality Review (CEQR) process in 2009 for the Western Rail Yard Project in 2009 

(08PR03724, 08PR04116) in the 2009 Western Rail Yard Project Final Environmental 

Impact Statement (2009 SEQRA/CEQR FEIS). Your office determined that construction 

near and around the High Line in Western Rail Yard is appropriate (since historically 

buildings have been located in this manner) subject to the stipulations in a Letter of 

Resolution (LOR) developed with MTA and the New York City Planning Commission. 

Your office suggested developing the LOR because the design details for the Overbuild 

were not yet available. The Overbuild was approved in 2009 by the New York City 

Planning Commission and adopted by the New York City Council as zoning text and map 

amendments to the New York City Zoning Resolution. The Overbuild development is now 

as-of-right development, since it will be built in accordance with the New York City 

Zoning Resolution’s existing zoning controls, which regulate type of use, building 

envelopes, publicly accessible open space areas, street wall controls, retail continuity, and 

maximum floor area ratio (i.e., the ratio of floor area to lot size). For archaeological 

resources, the 2009 SEQRA/CEQR FEIS relied on the assessment of potential 

archaeological sensitivity prepared for the 2004 No. 7 Subway Extension-Hudson Yards 

Rezoning and Development Program FGEIS, which concluded that the Western Rail Yard 

was not sensitive for archaeological resources. In a comment letter dated April 29, 2009, 

your office confirmed it had no further archaeological concerns regarding the Western Rail 

Yard project. 
Western Rail Yard Platform Project 3 

x The Tunnel Encasement is the third and westernmost segment of the entire right-of-way 

preservation concrete casing that previously underwent environmental reviews led by 

FRA, which included reviews in accordance with Section 106 of the National Historic 

Preservation Act of 1966 (as amended) and its implementing regulations at 36 Code of 

Federal Regulations (CFR) Part 800. In a letter dated April 1, 2013, your office confirmed 

it had no archaeological concerns regarding the concrete encasement. In a letter dated July 

22, 2014, your office concurred with FRA’s determination that the undertaking would have 

no adverse effect on historic properties provided that construction monitoring of the High 

Line would occur per the New York City Building Code Technical Policy and Procedure 

Notice #10/88 (14PRO2712). 

FRA is preparing an EIS for the Project in compliance with NEPA, the Council on Environmental 

Quality (CEQ) regulations implementing NEPA (40 CFR parts 1500‐1508), 23 U.S.C. § 139, and 

23 CFR part 771 and 774. The Notice of Intent was published on June 15, 2020 (Federal Register, 

Vol. 85, No. 115). Consistent with regulations issued by the Advisory Council on Historic 

Preservation (36 CFR part 800), FRA intends to coordinate compliance with Section 106 of the 

NHPA with the preparation of the EIS. By way of this letter and in accordance with 36 CFR 800.3, 

FRA is initiating Section 106 review for the Project (which is also the Undertaking for purposes 

of Section 106). The Overbuild that would be supported by the Platform is within the development 

envelope adopted by the New York City Council as zoning text and map amendments to the New 

York City Zoning Resolution. The Project site, including construction staging areas, have not been 

expanded from what was previously reviewed by your office. The design for the Platform has not 

changed substantively, although minor refinements have been made as MTA-LIRR review of the 

design has progressed. As the Section 106 process for the Project advances, FRA will update your 

office if there are any changes in conditions related to the construction of the Tunnel Encasement 

from the 2014 no adverse effect determination. 

In addition to initiating Section 106 consultation, FRA requests your review of the enclosed 

preliminary list of entities to be invited to participate in the Project’s Section 106 review as 

consulting parties in accordance with 36 CFR. 800.2(c) (Attachment A). In accordance with 36 

CFR 800.4(a)(1), FRA has also developed the proposed Area of Potential Effects (APE) for the 

Project, to account for potential effects on historic properties based on the conceptual design for 

the Project and potential indirect effects of the Overbuild. A memo providing additional 

background and an overview of the Project and detailing the proposed APE is enclosed for your 

review. 

Due to the ongoing coronavirus disease 2019 (COVID-19) public health emergency, and consistent 

with the Centers for Disease Control and Prevention’s guidance regarding large events and mass 

gatherings, FRA will conduct a virtual public scoping for the Project. FRA will also hold other 

Project meetings virtually, including Section 106 Consulting Party meetings, and encourages 

submission of comments for the Project electronically. Such meetings will be advertised as 

required. The EIS is being prepared on an accelerated schedule. The schedule for the 

environmental review and other Project information is posted at 

www.westernrailyardinfrastructure.com and at Regulations.gov, Docket Number: FRA-2020-
Western Rail Yard Platform Project 4 

0039. 

If you have any questions please contact me at laura.shick@dot.gov, or (202) 366-0340. 

FRA looks forward to consulting with your office on this Project and receiving your comments on 

potential consulting parties and the proposed APE. 

Sincerely, 

Laura Shick 

Supervisory Environmental Protection Specialist

Office of Railroad Policy and Development

Enclosures 

cc: Stephanie Perez-Arrieta, Supervisory EPS, FRA 

Andrea Poole, EPS, FRA 

Rebecca Blatnica, EPS, Volpe, The National Transportation Systems Center 
ATTACHMENT A:

Western Rail Yard Platform Project 

Section 106 Consultation – Potential Consulting Parties 

New York State Historic Preservation Officer 

Mr. Daniel Mackay 

Deputy Commissioner for Historic Preservation / Deputy SHPO 

Peebles Island Resource Center 

P.O. Box 189 

Waterford, NY 12188 

Amtrak 

Johnette Davies 

Senior Historic Preservation Specialist 

Amtrak 

30th Street Station 

2955 Market Street, Mailbox 55 

Philadelphia, PA 19104 

Advisory Council on Historic Preservation (to be invited) 

Jaime Loichinger 

Assistant Director, Federal Permitting, Licensing, and Assistance Section 

401 F Street NW, Suite 308 

Washington, DC 20001 

Sarah Stokely 

FRA Liaison, Federal Permitting, Licensing, and Assistance Section 

1100 Pennsylvania Avenue NW 

Washington, DC 20004 

FEDERALLY RECOGNIZED NATIVE AMERICAN TRIBES 

Delaware Nation 

Ms. Neckole Alligood 

Tribal Historic Preservation Officer 

Delaware Nation 

ATTN: Cultural Preservation Department 

PO Box 825 

31064 State Hwy 281 

Anadarko, OK 73005 

Delaware Tribe 

Blair Fink 

Delaware Tribe Historic Preservation Office 

Temple University, Department of Anthropology 

Gladfelter Hall, Room 207 

1115 W. Polett Walk 

Philadelphia, PA 19122 
2 

Delaware Tribe of Indians, Oklahoma 

Chester Brooks, Chief 

Delaware Tribe of Indians, Oklahoma 

Delaware Tribal Headquarters 

5100 Tuxedo Blvd. 

Bartlesville, OK 74006 

Stockbridge-Munsee Community of Mohican Indians of Wisconsin 

Shannon Holsey, President 

Stockbridge-Munsee Community of Mohican Indians of Wisconsin 

N8476 MoHeConNuck Road 

Bowler, WI 54416 

Shinnecock Indian Nation 

Bryan Polite, Daniel S. Collins, Sr., Eugene Cuffee, II, Trustees 

Shinnecock Indian Nation 

Shinnecock Indian Nation Tribal Office 

PO BOX 5006 

Southampton, NY 11969-5006 

OTHER NATIVE AMERICAN TRIBES 

Eastern Delaware Nation 

Corrine Remington, Secretary 

Eastern Delaware Nation 

corrine.remington@yahoo.com

Eastern Lenape Nation of Pennsylvania 

Doris Pieschel, Secretary 

Eastern Lenape Nation of Pennsylvania 

21 Cedar Land 

Mountville, PA 17554 

REPRESENTATIVES OF LOCAL GOVERNMENTS WHERE THE UNDERTAKING 

MAY TAKE PLACE 

New York City 

New York City Landmarks Preservation Commission 

Sarah Carroll, Chair 

New York City Landmarks Preservation Commission 

David N. Dinkins Municipal Building 

1 Centre Street, 9th Floor, North 

New York, NY 10007 

New York City Department of Parks and Recreation 

Mitchell J. Silver, Commissioner 

The Arsenal 
3 

Central Park 

830 Fifth Avenue 

New York, NY 10065 

OTHER AFFECTED PARTIES 

Hudson River Park Trust 

Noreen Doyle 

Executive Vice President 

Hudson River Park Trust 

Pier 40, 2nd Floor 

353 West Street 

New York, NY 10014 

Friends of the High Line 

Robert Hammond 

Co-Founder and Executive Director 

820 Washington Street 

New York, NY 10014 
4 

OTHER ARCHAEOLOGICAL AND HISTORIC RESOURCE INTEREST GROUPS 

Archaeology Interest Groups 

Society for Industrial Archeology 

Sandy Needham, President 

Roebling Chapter 

Society for Industrial Archeology 

235 West End Avenue, Apt. 14C 

New York, NY 10023-3648 

Professional Archaeologists of New York City (PANYC) 

c/o S. Spritzer 

P.O. Box 1503 

Murray Hill Station 

New York, NY 10156-1503 

Railroad History Interest Groups 

Anthracite Railroads Historical Society 

Kermit Geary Jr., President 

P.O. Box 519 

Lansdale, PA 19446 

Erie Lackawanna Historical Society 

Michael J. Connor, President 

c/o David Start, Membership Chairman 

Erie Lackawanna Historical Society 

22 Ice Plant Road 

Lafayette, NJ 07848-2403 

National Railway Historical Society, Inc. 

Albert L. Papp, Jr., President 

New York Chapter 

P.O. Box 254 

Basking Ridge, NJ 07920 

Railway & Locomotive Historical Society 

Tommy Meehan, Chapter Chair 

New York Chapter 

42 Portland Pl., Fl. 2 

Yonkers NY 10703-2206 

Tri-State Railway Historical Society, Inc. 

Michael DelVecchio, President 

P.O. Box 1217 

Morristown, NJ 07962 
Division for Historic Preservation

P.O. Box 189, Waterford, New York 12188-0189 • (518) 237-8643 • parks.ny.gov

ANDREW M. CUOMO ERIK KULLESEID

Governor Commissioner

August 3, 2020

Laura Shick

Supervisory Environmental Protection Specialist, Office of Railroad Policy and Development

USDOT, Federal Railroad Administration

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: FRA

Western Rail Yard Platform Project

20PR03990

Dear Ms. Shick:

Thank you for requesting the comments of the New York State Historic Preservation Office (SHPO). 

We have reviewed the provided documentation in accordance with Section 106 of the National 

Historic Preservation Act of 1966. These comments are those of the SHPO and relate only to 

Historic/Cultural resources. They do not include other environmental impacts to New York State 

Parkland that may be involved in or near your project. Such impacts must be considered as part of 

the environmental review of the project pursuant to the National Environmental Policy Act and/or the 

State Environmental Quality Review Act (NY Environmental Conservation Law Article 8). 

We note that the project area contains a portion of the High Line Freight Railroad, which is eligible 

for listing in the State and National Registers (S/NR) of Historic Places. We further note that the 

following historic resources are located just outside of the project area: the West Chelsea Historic 

District, which is eligible for listing in the S/NR and is also a locally designated LPC Historic District; 

the former W&J Sloane Warehouse and Garage at 541-561 West 29th Street, which is eligible for 

listing in the S/NR; and the Hudson River Bulkhead, which is eligible for listing in the S/NR. We have 

reviewed the Section 106 initiation letter and the project overview and Area of Potential Effect (APE)

memorandum that were submitted to our office on July 6th, 2020. Based upon our review, we concur 

with the proposed Area of Potential Effect and with the proposed list of Consulting Parties. We 

further note that our office has no archaeological concerns with the proposed undertaking.

If additional information or correspondence is required regarding this project it should be uploaded to

our Cultural Resource Information System www.nysparks.com/shpo/online-tools/. Once on the CRIS 

site, you can log in as a guest and choose "submit" at the very top menu. Next choose "submit new 

information for an existing project". You will need this project number and your e-mail address. If 

you have any questions, I can be reached at (518) 268-2182.

Sincerely,

Olivia Brazee 

Historic Site Restoration Coordinator

olivia.brazee@parks.ny.gov via e-mail only

cc: Gina Santucci and Amanda Sutphin, NYC LPC

Jennifer Morris and Stephen Holley, AKRF, Inc.
Division for Historic Preservation

P.O. Box 189, Waterford, New York 12188-0189 • (518) 237-8643 • parks.ny.gov

ANDREW M. CUOMO ERIK KULLESEID

Governor Commissioner

November 13, 2020

Laura Shick

Supervisory Environmental Protection Specialist, Office of Railroad Policy and Development

USDOT, Federal Railroad Administration

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: FRA

Western Rail Yard Platform Project

20PR03990

Dear Laura Shick:

Thank you for continuing to consult with the New York State Historic Preservation Office 

(SHPO). We have reviewed the provided documentation in accordance with Section 106 of the 

National Historic Preservation Act of 1966. These comments are those of the SHPO and relate 

only to Historic/Cultural resources. 

We cannot concur with FRA’s proposed determination. We agree that a there are five historic 

properties eligible for listing in the National Register of Historic Places in the APE” the New 

York Improvements and Tunnel Extension of the Pennsylvania Railroad (North River Tunnel), 

the High Line, Hudson River Bulkhead, the former W & J Sloane Warehouse and Garage and 

the West Chelsea Historic District. We further agree that we have no archeological concerns.

We cannot concur with the proposed determination as we have no details regarding potential 

impacts to the High Line which is near the project. We acknowledge that in 2010 we signed a 

Letter of Resolution (LOR) under section 14.09 of our State Historic Preservation Act. However, 

the stipulations of this LOR have not been fulfilled and cannot substitute for review under 

Section 106. Please provide the following additional information:

1. Design plans for the proposed development project as it may affect the High Line.

2. A construction protection plan, protecting all historic resources within 90 feet of the 

proposed construction.

Documentation requested in this letter should be provided via our Cultural Resource Information 

System (CRIS) at https://cris.parks.ny.gov/ Once on the CRIS site, you can log in as a guest 

and choose "submit" at the very top menu. Go to “Other Options” and choose "submit new 

information for an existing project". You will need this project number and your e-mail address. 

If you have any questions, I can be reached at 518-268-2181.

Sincerely,

Beth Cumming

Senior Historic Site Restoration Coordinator

e-mail: beth.cumming@parks.ny.gov via e-mail only
U.S. Department 1200 New Jersey Avenue, SE

of Transportation Washington, DC 20590

Federal Railroad

Administration

January 12, 2021

Mr. Daniel Mackay, Deputy Commissioner

Division for Historic Preservation 

New York State Historic Preservation Office

Peebles Island State Park, P.O. Box 189

Waterford, NY 12188

RE: Western Rail Yard Infrastructure Project, New York County, NY (20PR03990)

Section 106 Consultation: Determination of No Adverse Effect with Conditions

Dear Mr. Mackay:

This letter continues the U.S Department of Transportation (USDOT) Federal Railroad 

Administration’s (FRA) consultation with your office pursuant to Section 106 of the National 

Historic Preservation Act and its implementing regulations (36 CFR 800) for the Western Rail 

Yard Infrastructure Project (20PR03990). The Project Sponsor, which is a joint venture between 

WRY Tenant LLC1and the National Railroad Passenger Corporation (Amtrak), is seeking 

Federal financial assistance through the Railroad Rehabilitation and Improvement Financing 

(RRIF) Program, a loan program administered by the USDOT’s Build America Bureau (Bureau).

FRA is performing the necessary analyses and consultations in accordance with the National 

Environmental Policy Act (NEPA), Section 106, and other federal environmental review 

requirements. The Project includes construction of (1) a structural Platform (Platform) and (2) a 

railroad right-of-way preservation Tunnel Encasement (Tunnel Encasement) to allow for 

privately-funded mixed-use development and public open space (Overbuild) above the Platform

which would be constructed by WRY Tenant LLC.

FRA initiated Section 106 consultation on July 03, 2020, via an online submission to your 

office’s Cultural Resource Information System; our submission included the proposed Area of 

Potential Effects (APE) for the undertaking, and a list of potential Consulting Parties. On August 

03, 2020, your office concurred with the proposed APE. On October 15, 2020, FRA submitted a 

Historic Architectural Resources Background Study and Effects Assessment (HARBS/EA). On 

November 13, 2020, your office concurred with the HARBS/EA’s findings regarding the 

eligibility of historic properties within the APE. However, your office was unable to concur with 

FRA’s finding of no adverse effect. FRA has subsequently reevaluated the potential effects of 

the undertaking as outlined below.

 

1 WRY Tenant LLC is an affiliate of the Related Companies LP.
Western Rail Yard Infrastructure Project

Section 106 – No Adverse Effect with Conditions 

2

Assessment of Effects

As detailed in the HARBS/EA report, FRA identified five historic properties eligible for listing 

in the National Register of Historic Places (NRHP-eligible) in the APE: the New York 

Improvements and Tunnel Extension of the Pennsylvania Railroad (North River Tunnel), the 

High Line, Hudson River Bulkhead, the former W & J Sloane Warehouse and Garage, and the 

West Chelsea Historic District. No NRHP-listed historic or archaeological properties were 

identified in the APE. One of the NRHP-eligible historic properties, the West Chelsea Historic 

District, is locally designated by the City of New York.

FRA has applied the criteria of adverse effects to the Hudson River Bulkhead, W &J Sloane 

Warehouse and Garage, and the West Chelsea Historic District. FRA finds that the Platform and 

future Overbuild is consistent with the built environment and setting in which these properties 

currently exist and that the undertaking will have no direct or indirect; physical, auditory, or 

visual effect on these historic properties. 

FRA has applied the criteria of adverse effect to the New York Improvements and Tunnel 

Extension of the Pennsylvania Railroad (North River Tunnel). Because the Tunnel is completely 

underground through the APE, FRA has determined that the undertaking will have no direct or 

indirect; physical, auditory, or visual effect on this historic property. FRA recognizes that the 

nature of the work is such that there is the potential for inadvertent effects to the North River 

Tunnel caused by construction-related vibration. 

FRA has applied the criteria of adverse effect to the High Line and determined that the 

construction of the Platform and Tunnel Encasement will have no direct; physical, auditory, or 

visual effect on this historic property. FRA recognizes that the nature of the work is such that 

there is the potential for inadvertent effects to the High Line due to construction related vibration 

and underpinning activities. FRA has determined that the undertaking could result in adverse 

effects to the High Line from the future Overbuild on the Platform, proposed by WRY Tenant 

LLC. These potential effects to the High Line were identified during development of the 2009 

SEQRA/CEQR FEIS pertaining to the Western Rail Yard site and are fully described in the 

subsequent Letter of Resolution Among Metropolitan Transportation Authority, New York City 

Planning Commission, New York State Office of Parks, Recreation and Historic Preservation, 

and WRY Tenant LLC Regrading The Western Rail Yard Project Manhattan, New York County

(LOR), which states:

“Whereas, the Development Project could affect the High Line in the following ways: 1) 

by providing at least one access point a minimum of 12 feet in width to the High Line 

from the corner of West 30th Street and Twelfth Avenue; 2) physically altering the 

portion of the High Line along Twelfth Avenue to provide direct access between the High 

Line open space and the adjacent Western Open Space that would be located on the 

Development Site. Access would be provided along a minimum length of 75 feet and a 

maximum length of 150 feet of High Line frontage, requiring the removal of a portion of 

the High Line's eastern railing along Twelfth Avenue; 3) including a building at the 

southwest corner of the Development Site that could, in accordance with the zoning text 

amendment, be located adjacent to and above the High Line (provided that no portion of 
Western Rail Yard Infrastructure Project

Section 106 – No Adverse Effect with Conditions 

3

the building is located within five feet of the edge of the High Line and any portion of the 

building above the High Line be located above a height of 50 feet above the High Line 

bed); 4) designing the two proposed buildings on the north side of the High Line along 

West 30th Street to extend under the High Line with a low-rise extension of the buildings' 

shared podium (none of the High Line's structural columns would be removed to 

accommodate such an extension); and 5) creating potential connections between adjacent 

buildings on the Development Site and the bed of the High Line.”

Determination of Effects

FRA has determined that the potential effects of the undertaking are as follows: possible 

inadvertent effects to the North River Tunnel and High Line during construction of the Platform, 

Tunnel Encasement, and/or Overbuild, and possible indirect physical and/or visual effects related 

to construction and operation of the Overbuild. USDOT/FRA will include conditions as part of 

its environmental decision regarding the Project, i.e., in the Record of Decision (ROD) for the 

Environmental Impact Statement in accordance with NEPA, and in any loan agreement to be 

negotiated between the Bureau and the Project Sponsor, to ensure that these potential effects to 

historic properties are not adverse. These conditions include: requiring the Project Sponsor to 

develop a Construction Environmental Protection Plan (CEPP) for the construction of the 

Platform and Tunnel Encasement in order to protect the North River Tunnel and High Line. The 

CEPP will be required to meet the guidelines set forth in the New York City Department of 

Buildings (DOB) Technical Policy and Procedure Notice #10/88, the Protection for Landmarked 

Buildings guidance document of the New York Landmarks Preservation Commission, and the 

National Park Service’s Preservation Tech Notes, Temporary Protection #3: Protecting a 

Historic Structure during Adjacent Construction. The ROD and loan agreement will also require 

the Project Sponsor (which includes WRY Tenant LLC, a signatory to the LOR) to meet all of 

the conditions of the LOR which includes review of Overbuild design by the New York State 

Historic Preservation Office and New York City Landmarks Preservation Commission as well as 

development of a CEPP to protect the High Line during construction of the Overbuild. 

Based on the application of the above conditions to the Project, FRA finds that the undertaking 

will have no adverse effect on historic properties (36 CFR 800.5(b)).

Request for Review and Comment

FRA respectfully requests that your office provide comment and concurrence on FRA’s

determination that the undertaking will have No Adverse Effect on historic properties because 

sufficient conditions will be imposed on the undertaking, through the ROD and loan agreement, 

to avoid adverse effects (36 CFR 800.5(b)). Based on your concurrence with FRA’s No Adverse 

Effect finding and in consideration of the views of consulting parties, FRA intends to make a de 

minimis impact determination for the minor Section 4(f) use of The High Line. Should you 

disagree with FRA’s finding, please notify us within 30 days. An e-mailed response is preferred 

to ensure timely receipt of your communications; FRA is working remotely at this time, and has 

limited access to mailed responses.
Western Rail Yard Infrastructure Project

Section 106 – No Adverse Effect with Conditions 

4

By copy of this letter, FRA is also providing its finding of effect to Consulting Parties for their 

review and comment concurrent with your office.

FRA recently requested an update from WRY Tenant LLC regarding the proposed Overbuild 

and has been reassured that the Overbuild is still very much in the conceptual design stage. At

FRA’s request, WRY Tenant LLC’s consultant, AKRF, will reach out to your staff in the next 

couple of weeks to provide an informational update on the current concept for the Overbuild. 

If you have any questions or wish to discuss this undertaking, please contact me at 

WRYProject@dot.gov or (202) 366-0340.

Sincerely,

Laura A. Shick

Supervisory Environmental Protection Specialist

Environmental & Corridor Planning 

Division Office of Railroad Policy and 

Development

cc: Nathan Allison, Tribal Historic Preservation Office, Stockbridge-Munsee Mohican Tribe

 Marie Corrado, Senior Director, Gateway Program, Amtrak

 Timothy Frye, Director of Special Projects & Strategic Planning NYC Landmarks

 Preservation Commission
Division for Historic Preservation

P.O. Box 189, Waterford, New York 12188-0189 • (518) 237-8643 • parks.ny.gov

ANDREW M. CUOMO ERIK KULLESEID

Governor Commissioner

February 11, 2021

Laura Shick

Supervisory Environmental Protection Specialist, Office of Railroad Policy and Development

USDOT, Federal Railroad Administration

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: FRA

Western Rail Yard Platform Project

20PR03990

Dear Laura Shick:

Thank you for continuing to consult with the New York State Historic Preservation Office 

(SHPO). We have reviewed the provided documentation in accordance with Section 106 of the 

National Historic Preservation Act of 1966. These comments are those of the SHPO and relate 

only to Historic/Cultural resources. 

We have reviewed your letter dated January 12, 2021. Based upon this review, it is the SHPO’s 

opinion the proposed platform project will have No Adverse Effect provided the following 

conditions are met:

1. A construction Environmental Protection Plan (CEPP) shall be developed for the 

construction of the Platform and Tunnel Encasement to protect the historic North 

River Tunnel and High Line.

2. During design of the development project, the developer shall consult with the SHPO 

regarding those aspects of the design that relate to the High Line. Designs shall be 

submitted at the preliminary and pre-final design stages. If the SHPO makes 

substantive comments during the review stages, they may request the opportunity to 

comment on the final design plans.

3. If during design review, there are unavoidable adverse impacts to the historic 

resources, mitigation measures shall be developed in consultation with SHPO.

If you have any questions, I am best reached via e-mail.

Sincerely,

Beth Cumming

Senior Historic Site Restoration Coordinator

e-mail: beth.cumming@parks.ny.gov via e-mail only