Appendix 4: Public and Agency Coordination

APPENDIX 4: PUBLIC AND AGENCY COORDINATION

4-A: Correspondence with NJ TRANSIT

1– Letter from FRA to NJ TRANSIT, November 6, 2018

2 – Letter from NJ TRANSIT to FRA, December 21, 2018

3 – Letter from FRA to NJ TRANSIT, June 4, 2019

4-B: Correspondence with U.S. Army Corps of Engineers

1 – Letter from FRA to USACE, November 6, 2018

2 – E-mail from FRA to USACE, July 12, 2019

4-C: Distribution List
Sawtooth Bridges Replacement Project

Appendix 4 – A

CORRESPONDENCE WITH NJ TRANSIT
Sawtooth Bridges Replacement Project

Appendix 4 – A – 1

LETTER FROM FRA TO NJ TRANSIT, NOVEMBER 6, 2018
U.S. Department 1200 New Jersey Avenue, SE

of Transportation Washington, DC 20590

Federal Railroad 

Administration

November 6, 2018

NJ Transit

Attention: Jeremy Colangelo-Bryan, Chief Planner

One Penn Plaza East

Newark, NJ 07105

Re: Invitation to accept NEPA Participating Agency status for the Federal Railroad 

Administration-led Sawtooth Bridges Replacement Project

Dear Mr. Colangelo-Bryan:

The National Railroad Passenger Corporation (Amtrak) is proposing to replace Amtrak 

Bridges No. 7.80 and No. 7.96, collectively referred to as the “Sawtooth Bridges,” which 

are critical links and existing bottlenecks on Amtrak’s Northeast Corridor (NEC). The 

NEC is one of the busiest transportation systems in the world. The Sawtooth Bridges are 

in the Town of Kearny, Hudson County, New Jersey between Newark Penn Station and 

Secaucus Junction (see Figure 1-1). The Federal Railroad Administration (FRA) is 

serving as the lead agency for the Environmental Assessment (EA) pursuant to the 

National Environmental Policy Act (NEPA) of 1969, as amended, for the proposed 

Sawtooth Bridges Replacement Project. The FRA invites New Jersey Transit Corporation

(NJ Transit) to be a Participating Agency on the proposed Sawtooth Bridges Replacement 

Project, as you may have an interest in the project based on your operations along the 

Sawtooth Bridges and other rail infrastructure within the study area and special expertise.

The increasing age of the Sawtooth Bridges, their poor structural condition, and their two 

tracks (which are restricted to 60 miles per hour [mph]) limit the efficiency and reliability 

of rail operations throughout this segment of the NEC. The purpose of the Sawtooth 

Bridges Replacement Project (Proposed Project) is to achieve a state of good repair and 

to improve the reliability and resiliency of rail service along this critical segment of the 

NEC. The Sawtooth Bridges do not cross any bodies of water; rather, they span over 

other rail tracks. Amtrak Bridge No. 7.80 carries two NEC tracks over four NJ Transit

rail tracks that serve the NJ Transit Morris & Essex Line. Amtrak Bridge No. 7.96 carries 

the two NEC tracks over one Port Authority Trans-Hudson Corporation (PATH) 

Newark–World Trade Center (WTC) rail track and one Consolidated Rail Corporation 

(Conrail) freight rail track.

In accordance with the Council on Environmental Quality (CEQ) final implementing 

regulations for NEPA (42 USC § 4370m(17)), the FRA requests your assistance and 
2

participation in the NEPA process in the following ways: 

(a) Attendance at and input during agency coordination meetings (as appropriate); 

(b) Comment and feedback on the enclosed administrative draft EA; 

(c) Guidance on relevant technical studies included as part of the EA; 

(d) Identification of issues related to your agency’s special expertise; 

Please provide your written acceptance or declination of this invitation and comments on 

the enclosed EA on or before December 3, 2018. If you have any questions or would like 

to discuss our respective roles and responsibilities during the NEPA process in more 

detail, please contact me at (202) 493-0844 or brandon.bratcher@dot.gov. 

Sincerely, 

Brandon Bratcher

Environmental Protection Specialist

enclosure
Sawtooth Bridges Replacement Project

Appendix 4 – A – 2

LETTER FROM NJ TRANSIT TO FRA, DECEMBER 21, 2018
December 21, 2018

Brandon Bratcher

Federal Railroad Administration

1200 New Jersey Avenue, SE

Washington, DC 20590

Re: NJ TRANSIT comments on the Federal Railroad Administration-led Sawtooth 

Bridges Replacement Project Administrative Draft EA

Dear Mr. Bratcher:

Thank you for granting NJ TRANSIT the opportunity to act as a Participating Agency 

and review the Administrative Draft of the Sawtooth Replacement EA. Our attached 

comments are offered with the intent of helping Amtrak provide a clear picture of this 

complex section of right-of-way, bringing more focus on the needs of many operators, 

track connections, future plans, and coordination challenges that this project must face.

With this transmittal we are recommending consideration of refinements to Amtrak’s 

approach that might help ensure that the work most needed in the near term has the 

best chance of advancing without unnecessary interruption or delay.

From our perspective it may be more prudent to design the new alignments for the 

project in such a way that the functionality of the current bridges can be replaced, 

essentially attaining a state of good repair (SOGR), while making sure not to preclude a 

third and fourth track that would have separate utility under the Gateway Program. As 

currently defined in the EA, in advancing one alternative to meet multiple needs, Amtrak 

runs the risk of overcomplicating the critical SOGR project elements, which may pose a 

significant risk to their successful and timely implementation. This is because conflating 

SOGR needs with capacity and speed considerations likely will result in elevating the 

project cost and extending its schedule for implementation. What is needed is a project 

that can be implemented quickly and at a cost that is reasonable to fund.

NJ TRANSIT is recommending that this EA more fully explore the environmental, cost, 

and temporal impacts of constructing replacement alignments that support 90 mph MAS 

versus a slower MAS. We are also recommending that the first phase, the SOGR 

portion, of this project be defined independently so that the timing and funding of the 

second phase, the capacity/redundancy portion, does not prevent the SOGR project 

from rapid advancement and implementation.
It is possible that Federal Transit Administration funding will be sought for one or both 

proposed phases of this project. As such, issues like design speeds must be fully 

understood from the perspective of “commuter” service such as that operated by NJT, 

with a focus on maintaining SOGR and reliability.

Again, thank you for the opportunity to participate in the development of this EA; we 

look forward to our continued engagement in the process.

Sincerely,

Jeremy Colangelo-Bryan

Cc. Jeannie Kwon

Justin Davis

Paul Wyckoff

Eric Daleo
“Administrative Draft” Sawtooth Bridges Replacement Project 

Environmental Assessment and Draft 4(f) Evaluation (EA)

PRELIMARY DRAFT COMMENTS

General/ Support/Need

NJT strongly supports replacing the Sawtooth Bridges and is appreciative of the opportunity to 

engage with Amtrak on this project. The bridges are over 100 years old and were not designed 

to the higher engineering standards of the rest of the NEC since freight trains never used this 

portion of the NEC (something not brought out in the EA). 

NJ TRANST has a vested interest in not having a capacity constraint imposed on the trains we 

can operate while these bridges are being replaced or upgraded. We appreciate that the 

proposed plan avoids causing NJT to limit its services which use the NEC and that a meaningful 

attempt was made to limit temporary impacts to the M&E while the new bridges are being 

constructed. 

NJ TRANSIT also appreciates that the plan is to construct bypass tracks in advance of replacing 

the existing bridges to reduce impacts on existing operations.

In support of the purpose and need for the project, NJT recommends that more emphasis be 

placed on the fundamental need to sustain the existing functionality of the NEC and to 

minimize disruptions, in order to better inform the public of the criticality of this project.

Environmental Process

In the purpose and need, it is stated that the proposed project will meet the intent of the NEC 

Future Tier I EIS and ROD for improved intercity rail services. To this end, the project will allow 

trains to travel at a maximum authorized speed of 90 mph and will provide a four track railroad 

from Newark into Midtown Manhattan. The arguments in favor of advancing the project do 

not emphasize enough the fundamental need to sustain the existing functionality of the NEC 

and minimize disruptions to existing Amtrak and non-Amtrak train services. These are among 

the most compelling arguments in favor of what is proposed.

In the goals and objectives 90 mph MAS is stated as a critical element that would be used to 

eliminate potential candidate alternatives. NJ TRANSIT believes a more appropriate analysis 

would permit consideration of alternatives that are designed to a slower MAS, such as 60 mph 
MAS. This could provide a more through context related to environmental impacts and 

potential costs.

Operations

The necessity of a 90 mph MAS in this section of the railroad is not clear. The EA notes that the 

area is constrained by a number of physical issues that limit speeds. The EA also notes that the 

“poor structural condition... and... two tracks (which are limited to 60 miles per hour... limit the 

efficiency and reliability of rail operations through this segment of the NEC.” It is not clear if 

this is stating that it is the speed limitation or the condition that limits the efficiency/reliability 

of the railroad. We would suggest that the speed “restriction” is not the limitation. Please 

provide technical documentation that supports the suggestion that a 90 mph MAS will improve 

the efficiency and reliability of this track segment and quantifies the difference between the 

two speeds.

Given trends in freight rail clearance requirements do your designs meet the 17’ car under wire 

Plate F standards?

Cost

NJ TRANSIT notes that there is no discussion of the overall capital cost of this project, nor of 

potential funding sources. 

Although not generally required in an EA, we recommend that you update the document to 

include general capital assumptions in relative terms (such as “high/medium/low” cost) when 

comparing alternatives and incremental approaches to advancing the project. 

How would the alternatives considered compare if they all assumed a 60 mph MAS? Would the 

alternatives be less complicated and costly? Would the limits of the work area, and associated 

construction impacts, be as large? 

Funding

This project is but one of several in the mix of State of Good Repair projects within the State of 

New Jersey that may require financial action by NJ TRANSIT and/or the State of New Jersey, as 

well as the Federal Transit Administration. The yet to be identified additional cost associated 
with providing the proposed 90 mph MAS on the Sawtooth Bridges would need to be 

understood in this funding context. 

Impacts

The proposed plan as already noted avoids causing NJ TRANSIT to limit its services which use 

the NEC. There are some temporal impacts which may be felt on the M&E while the new 

bridges over the M&E are put in place.

We would ask that more detail be provided regarding the degree to which the existing services 

(especially the M & E) will be impacted

Speed

NJ TRANSIT does not require that the maximum authorized speed (MAS) be 90. Designing for 

trains to travel at this MAS imposes addition design constraints on the project which add to the 

capital cost and subsequent maintenance costs.

While NJ TRANSIT staff understands that there is a desire on Amtrak’s part to reduce travel 

times between Washington and NYC it is unclear to us the degree to which increasing the MAS 

through this congested section of the NEC will help in that goal. The segment of track proposed 

for improvement in this EA is approximately 1⁄2 mile in length and it is speed constrained to the 

west by 60 mph track along the curve at HUDSON interlocking. The EA needs to specifically 

define the operational benefits associated with the use of 90 mph MAS through this very short 

section of track that is so close to Newark Penn Station and the curve at HUDSON, including 

expected travel time and reliability benefits. With the current level of detail provided it would 

appear that the benefits would be marginal compared to the cost. 

We disagree, unless further documentation can be provided, with primary goal #3 that 90 mph 

MAS is a critical need to improving service efficiency and reliability, and do not believe that it 

should function as a fatal flaw criteria when developing or screening otherwise viable 

alternatives. Attempting to reach this speed would not be easy during peak operating hours

given the variety of vertical and horizontal curves, and crossovers in this general area.

Given that Secaucus Station is generally walled-off along both longitudinal sides, effectively 

creating a tunnel within which trains will pass along passenger tracks, there will likely be safety 

concerns related to trains traveling through at a high rate of speed. We recommend that 
Amtrak update a study on this issue performed for NJ TRANSIT during the design phase of the 

Secaucus Station (that study can be provided at Amtrak’s request).

Coordination

Given that the proposed alternative would impact both services, we would recommend 

reaching out to PATH and Conrail in advance of publishing this EA.

Although perhaps outside of the bounds of the EA specifically, an understanding of how this 

project factors into the NECC Major Projects (Backlog) process, in Amtrak’s view, would be 

useful in addressing some of the cost and operational issues identified above.

Timing/Phasing

Given the proposed schedule for this project, Portal North Bridge, and the Hudson River Tunnel 

(HRT), Amtrak will need to be able to sufficiently support each of the projects – as abundantly 

as possible with flag protection and force account personnel – in order to not impede on the 

progress of any of the 3 projects, and have the ability to support the daily, routine maintenance 

needs and requirements of the NEC. NJ TRANSIT suggests that preliminary, draft staffing 

projections be made of the numbers of Amtrak personnel that will be needed of each union 

craft if all 3 projects (HRT, Portal, and Sawtooth) are proceeding at the same time. 

Given that this project is a critically important and time sensitive SOGR project that, if delayed, 

would increase the chance of a catastrophic failure on the NEC, NJ TRANSIT recommends 

considering a phased approach, and that Amtrak consider coordinating phase 2 with target 

implementation after the opening of Portal Bridge North and before the start of construction 

on Portal Bridge South. The benefits of the four tracks at Sawtooth are most meaningfully 

realized once Portal South is complete. If there are significant benefits to the four tracks in the 

absence of Portal South then the details of those should be clearly documented in this EA

Construction

Given the limited space to do work in this area of the NEC, Amtrak should be give consideration 

to working with Conrail to deliver by rail the large steel beams that will be erected as part of 

both Sawtooth North and South bridges. Additionally, utilizing NJ Transit’s M&E Line off hours–

might also be a good alternative for delivery of large materials. 
Connectivity

For the Eastbound Waterfront Connection it is important to remember that beside the role it 

can play to offer a more resilient rail service allowing some NEC trains to access Hoboken 

Terminal, it also is a means of ingress and egress from the MMC. NJ TRANSIT requests that 

Amtrak consider the likelihood of a second eastbound connecting track to facilitate two-way 

train traffic through this area. This EA should also outline the potential impacts that the 

proposed alternatives might have to NJ TRANSIT’s desired improvement to the speed of 

Eastbound Waterfront connection in the future.

The Westbound Waterfront Connection, aside from increasing the ability of NJ TRANSIT to send 

some trains to/from Hoboken when there is a loss of train capacity on the NEC, will also play a 

role with train movements in and out of the MMC and responding to the long term desire not 

to have westbound trains cross in front of eastbound NEC trains.

Both the current (Eastbound Waterfront) and future (Eastbound and Westbound Waterfront) 

connections will provide resiliency and redundancy in the case of service disruptions east of 

Sawtooth and additional capacity in advance of the completion of the Gateway Program

Similarly, NJ TRANSIT would appreciate it if the Sawtooth EA explicitly state that the Sawtooth 

design is and will be consistent with the work of the NEC Initiatives project. This can at least 

partially be accomplished by modifying section 1.4.1 of the document by including the NEC 

Initiative and its findings into that section. That section could also outline the steps proposed 

to prevent the preclusion of future changes to the existing (eastbound waterfront) and future 

(westbound waterfront) connections between the NEC and the M & E to Hoboken as described 

above.

The EA should be updated to include the milepost location, makeup, and functionality of the 

Red Bridge, and how it ties in to the Sawtooth Bridges reconstruction proposals.

Independent Utility

Figures of alignments reference “Gateway Tracks.” This would seem to run counter to 

statements in the text about independent utility.

Historical & Environmental

• Cumulative Impacts should discuss broader set of projects that helps “justify” the full 

option 2A.
• Chapter 3, page 32, the reference to the spur of the NJ Turnpike built in 1976 should be 

the Western Spur. Also, that spur was started in 1968 and finished in 1970. The Eastern 

Spur was completed as noted in 1954. 

Specific Comments

Executive Summary

p. 2 – Primary goal 3 indicates that service can be improved by increasing design speeds. This 

should be explained. It may not improve service for NJ TRANSIT.

p. 4 – NJ TRANSIT Red Bridge should be explained – should also be consistently referenced in 

the photographs (see 1-3D).

Section 1 (should this be Chapter 1?): Purpose and Need

p. 3 – What is the basis for the stated passenger projections?

p. 6 – The description of the need and utility of the proposed Westbound Waterfront 

Connection and its existing Eastbound counterpart is missing important aspects of what roles 

both connections must play. On the second paragraph from bottom of the page discussion the 

WB is characterized as a way to “meet expected passenger demand” on several lines. This is 

incorrect.

Section 2 (should this be Chapter 2?)

P 8 – Would the relocation, realignment, or removal of HUDSON Interlocking, be required under 

Option 2A (selected option) be necessary if a 60 mph MAS were assumed? Please provide more 

detail on how these various modifications to HUDSON might be laid out and the operational 

and environmental impacts that might result.

P 10 – Please clarify your statement that service transfer to the new M&E track 5 can occur with 

no effect to NJ TRANSIT service.

P 11 – In Section 2.5.5 Amtrak’s apparent, new turnout standard proposed to be implemented 

between SWIFT Interlocking and the modified ALLIED (existing), EARLY (new) and LIGHT (new) 

Interlockings located east of Secaucus Junction Station is the “#24 Turnout”. Since HUDSON

Interlocking is composed of several #15 Turnouts and Crossovers, and since HUDSON is to be 

relocated in a railroad west direction, would future engineering protocol incorporate the 

installation of #24’s into HUDSON? And, is there enough room length-wise to accommodate 
the longer turnouts? Please provide clarification on how this interacts with the recommended 

MAS.

P 12 – In Section 2.7 - Bridge Span Design: Given the skew of the various tracks that will cross 

underneath both Sawtooth North and Sawtooth South, careful layout of the piers and 

abutments will have to be well thought-out. Side and vertical clearances will weigh heavily on 

the depth of the superstructure of both bridges, irrespective of whether or not short-span or 

long span options are considered. This will need to be vetted-out during the future design 

phases of the project

Also in this section, Will there be a current or future need to increase the vertical clearance at 

each bridge location? If so, will property be available length-wise along the NEC to introduce 

longer vertical curves on both the east and west ends of the new structures? 

Chapter 3

P 2 – Please provide more detail on how the proposed construction will affect NJ TRANSIT

service.
Sawtooth Bridges Replacement Project

Appendix 4 – A – 3

LETTER FROM FRA TO NJ TRANSIT, JUNE 4, 2019
U.S. Department 1200 New Jersey Avenue, SE

of Transportation Washington, DC 20590

Federal Railroad 

Administration

June 4, 2019

Jeremy Colangelo-Bryan

Chief Planner

Capital Planning and Programs

New Jersey Transit

One Penn Plaza East

Newark, NJ 07105

Re: Amtrak Sawtooth Bridges Replacement Project 

Dear Mr. Colangelo-Bryan:

Thank you for your comments dated December 21, 2018 regarding the Administrative 

Draft Environmental Assessment (EA) for Amtrak’s Sawtooth Bridges Replacement 

Project (Project). The Federal Railroad Administration (FRA) and Amtrak appreciate New 

Jersey Transit’s (NJ TRANSIT) ongoing productive dialogue and continued involvement

in the conceptual engineering and environmental planning process for the Project. NJ 

TRANSIT’s input informed the development of the alternatives evaluated in the EA. Many 

of NJ TRANSIT’s questions were discussed over the past year, and our coordination 

meeting on July 12, 2018 helped to further shape the EA. The attached correspondence 

from October 8, 2018 documents many of the topics discussed during our ongoing 

coordination. The purpose of this letter is to provide FRA’s and Amtrak’s responses to NJ 

TRANSIT’s comments on the Administrative Draft EA.

General/Support/Need

Comment 1: NJ TRANSIT strongly supports replacing the Sawtooth Bridges and is 

appreciative of the opportunity to engage with Amtrak on this project. The bridges are 

over 100 years old and were not designed to the higher engineering standards of the rest of

the NEC since freight trains never used this portion of the NEC (something not brought out 

in the EA). 

Response 1: The comment underlines the need for the Sawtooth Bridges Replacement 

Project, which is explained in Chapter 1 of the EA. This section of the Northeast Corridor 
2

(NEC) was more lightly engineered than other parts of the NEC that accommodated freight 

traffic hauled by steam locomotives. The very large dynamic forces resulting from the 

reciprocating driving machinery found on steam locomotives necessitated use of more 

robust bridge structures than would be needed to support the all-electric fleet operating 

into/from New York. The Pennsylvania Railroad (PRR) chose a design standard of a 

Cooper Rating of E-40, which was less than the standard used on contemporaneous freight 

lines. As a result, the structure has a smaller margin of safety as it aged. The replacement 

Sawtooth Bridges will have a Cooper Rating of E-80, which has become the standard 

applied across the NEC. 

Comment 2: NJ TRANSIT has a vested interest in not having a capacity constraint 

imposed on the trains we can operate while these bridges are being replaced or upgraded. 

We appreciate that the proposed plan avoids causing NJT to limit its services which use 

the NEC and that a meaningful attempt was made to limit temporary impacts to the M&E 

while the new bridges are being constructed. NJ TRANSIT also appreciates that the plan 

is to construct bypass tracks in advance of replacing the existing bridges to reduce impacts 

on existing operations. In support of the purpose and need for the project, NJT recommends 

that more emphasis be placed on the fundamental need to sustain the existing functionality 

of the NEC and to minimize disruptions, in order to better inform the public of the 

criticality of this project.

Response 2: FRA and Amtrak agree with NJ TRANSIT’s underlying point. We understand 

that maintaining NEC capacity is critical to both NJ TRANSIT and Amtrak operations. 

The need to sustain NEC functionality and minimize disruptions is presented throughout 

the EA document and is specifically emphasized in the Project’s goals: “Maintain service 

and connectivity along the NEC during construction” and “Accommodate current and 

planned future rail operations” (Chapter 1, page 8; Chapter 2, page 3). 

Project alternatives that would have resulted in prolonged service disruption were 

eliminated from further evaluation. The Rehabilitation Alternative was considered and 

eliminated because it would not allow for continued rail use due to the infeasibility of 

reconstructing the bridges to a state of good repair without significant cost and disruptions 

to rail operations. The narrow skew angle of the NEC crossing over the Morris & Essex 

Line (M&E) along with very restrictive vertical clearances influenced the PRR to choose 

a bridge design where each floor beam supports both main tracks with little to no resiliency 

available from adjacent structure. Component replacement under these conditions is not 

possible without the complete shut-down of all NEC operations and the likely removal of 

two M&E tracks from service during the replacement period. Replacing identified 

deficiencies without a new adjacent bridge already in service would result in prolonged 

and unacceptable shutdowns of rail operations during rehabilitation and would 
3

significantly and adversely impact the operations of Amtrak, NJ TRANSIT, PATH, and 

Conrail.

Environmental Process

Comment 3: In the purpose and need, it is stated that the proposed project will meet the 

intent of the NEC Future Tier I EIS and ROD for improved intercity rail services. To this 

end, the project will allow trains to travel at a maximum authorized speed of 90 mph and 

will provide a four-track railroad from Newark into Midtown Manhattan. The arguments 

in favor of advancing the project do not emphasize enough the fundamental need to 

sustain the existing functionality of the NEC and minimize disruptions to existing 

Amtrak and non-Amtrak train services. These are among the most compelling 

arguments in favor of what is proposed.

Response 3: FRA and Amtrak appreciate NJ TRANSIT’s suggestion to modify the purpose 

and need statement (EA Chapter 1). FRA and Amtrak propose amending the purpose and 

need statement as follows: “The purpose of the Proposed Project is to achieve a state of 

good repair and to improve the reliability and resiliency of rail service along this critical 

segment of the NEC, while preserving the current functionality of Amtrak’s NEC service 

and NJ TRANSIT’s commuter rail service.”

As stated in Response 2, FRA and Amtrak recognize that maintaining NEC capacity is 

critical to both NJ TRANSIT and Amtrak operations and the desire to minimize passenger 

rail service disruptions is thoroughly understood. Also, as mentioned in Response 2, 

maintaining service and connectivity along the NEC during construction are included in 

the Project goals (Chapter 1, page 8; Chapter 2, page 3). 

Amtrak recognizes that with some 60,000 average weekday trips on the Morris and Essex 

Lines, these tracks host a significant share of NJ TRANSIT’s rail ridership and are critical 

to overall network operations. The extended construction duration associated with the 

Project (6 to 7 years) is intended to maintain Amtrak, NJ TRANSIT, and other railroad 

operations. Project cost and schedule were evaluated in the context of passenger rail service 

disruptions. The Project could be completed in a far more compressed timeframe if impacts 

to NJ TRANSIT service had not been so highly prioritized.

Furthermore, Amtrak thoroughly understands the desire to minimize passenger disruptions 

as evidenced by the chosen strategy to construct a new parallel series of spans adjacent to 

the existing bridges. A wide variety of recent bridge replacement projects along the NEC 

plan to use this strategy of constructing the replacement spans next to the existing ones, 

including the completed Niantic River Bridge replacement, and the planned Connecticut 

River, Pelham Bay, Portal North, and Susquehanna River Rail Bridges, among others. 
4

Often, the parallel spans would operate as temporary bridges in order to allow replacement 

of the existing bridge; however, in the instance of Sawtooth, the cost to build the temporary 

structure comes close to the cost of building a permanent bridge due to the physical site 

constraints and bridge directly crossing over other operating railroads. As discussed in 

Response 2, the design of the current Sawtooth Bridges precludes the use of one track 

during construction; a two-track by-pass design was therefore necessary. The chosen

strategy for this project is cost-effective and reduces risk to maintaining rail traffic, as NJ 

TRANSIT points out is fundamental.

Comment 4: In the goals and objectives 90 mph MAS is stated as a critical element that 

would be used to eliminate potential candidate alternatives. NJ TRANSIT believes a more 

appropriate analysis would permit consideration of alternatives that are designed to a 

slower MAS, such as 60 mph MAS. This could provide a more through [sic] context related 

to environmental impacts and potential costs. 

Response 4: Neither FRA nor Amtrak find this suggested change to be reasonable or 

consistent with FRA’s NEC FUTURE Program (FRA’s initiative to improve the passenger 

rail corridor from Boston, MA to Washington, DC). The first of four key components of 

FRA’s NEC FUTURE Selected Alternative is “Improve Rail Service: Corridor-wide 

service and performance objectives for frequency, travel time, design speed, and passenger 

convenience.” FRA’s Selected Alternative establishes design speed targets in order to 

improve rail services, including a “general track operating design speed for the existing 

NEC [of] 160 mph, except where physical constraints or other operating constraints limit 

speed.” (NEC FUTURE ROD, Section 3.2.1). FRA further elaborates on these objectives, 

stating: “New high-speed track capacity is necessary to achieve service, frequency, and 

travel time objectives between Washington, D.C., and New York City” (NEC FUTURE 

ROD, pg. 37). 

Other bridge replacement projects in this region emphasize the need for increasing design 

speeds on the NEC. For example, in the Portal Bridge Capacity Enhancement Project FEIS 

issued by FRA and NJ TRANSIT, the importance of achieving 90 mph across the bridges 

was stressed for several reasons, including compatibility with adjacent segments of the 

NEC (page 2-6). This project, now called the Portal North Bridge Project and sponsored 

by NJ TRANSIT (who also managed the project’s design phase, which maintained the 90 

mph speed), notes in the June 2018 financial plan submitted by NJ TRANSIT to the Federal 

Transit Administration that the permanently restricted 60 mph speeds on the existing Portal 

Bridge cause bottlenecks in the corridor and notes that the new bridge will allow speeds to 

be raised to 90 mph (PNB Financial Plan p 17). 

Amtrak, together with FRA and NJ TRANSIT, chose a 90-mph design speed for the 
5

Sawtooth Bridges in order to be consistent with FRA’s overall goal to improve the NEC, 

as well as to be compatible with other NEC improvement projects in this immediate area. 

It should also be noted that the High-Density Interlocking System (HDIS), the high 

capacity signal system that was funded by NJ TRANSIT through the Newark-New York 

territory, is designed for higher speeds. Imposing a permanent 60 mph speed will likely 

reduce capacity, which is counter to the Project’s purpose and need. 

Operations

Comment 5: The necessity of a 90 mph MAS in this section of the railroad is not clear. 

The EA notes that the area is constrained by a number of physical issues that limit speeds. 

The EA also notes that the “poor structural condition... and... two tracks (which are limited 

to 60 miles per hour... limit the efficiency and reliability of rail operations through this 

segment of the NEC.” It is not clear if this is stating that it is the speed limitation or the 

condition that limits the efficiency/reliability of the railroad. We would suggest that the 

speed “restriction” is not the limitation. Please provide technical documentation that 

supports the suggestion that a 90 mph MAS will improve the efficiency and reliability of 

this track segment and quantifies the difference between the two speeds.

Response 5: Please see Response 4 detailing the need to increase the speeds on this corridor 

to 90 mph. 

The Sawtooth Bridges are located along a curved portion of the NEC alignment referred to 

as Curve 242. It is a long radius curve of over 12,000 feet and, in railroad engineering 

terms, is a 0 degree, 30 second curve. With one inch of superelevation and three inches of 

unbalance (consistent with the most conservative equipment designs NJ TRANSIT 

operates), trains may operate at speeds up to 106 mph through it. Trains able to operate at 

higher levels of unbalance can achieve faster speeds through the curve. A train traveling at 

90 mph covers 132 feet in one second. Conversely, a train traveling at 60 mph travels 88 

feet in one second—which is 33 percent slower. For the approximate 5,000-foot-distance 

between the midpoints of SWIFT and HUDSON interlockings, the 60-mph train would 

consume an additional 19 seconds, or approximately 15 percent of one two-minute train 

slot would be lost in traveling through this short distance. 

Establishing a 60 mph maximum speed through this territory would place the NEC—at 

its busiest point—as among the slowest operating passenger rail lines in the nation. All 

commuter rail systems connecting to the NEC, including NJ TRANSIT, operate at higher 

maximum speeds along virtually every connecting route.

Comment 6: Given trends in freight rail clearance requirements do your designs meet the 

17’ car under wire Plate F standards?
6

Response 6: No. Freight traffic does not currently and is not anticipated to traverse this 

segment of the NEC. The Project would, however, maintain existing clearances on the 

Conrail Center Street Branch, PATH, and the Morris & Essex Line. 

Cost

Comment 7: NJ TRANSIT notes that there is no discussion of the overall capital cost of 

this project, nor of potential funding sources. Although not generally required in an EA, 

we recommend that you update the document to include general capital assumptions in 

relative terms (such as “high/medium/low” cost) when comparing alternatives and 

incremental approaches to advancing the project.

Response 7: Ranking alternatives based on cost at this early stage would be premature.

The cost of the Project is highly dependent on the availability of work windows for 

foundation construction and the availability of Amtrak Engineering workforce. Working 

with NJ TRANSIT’s Operations and Engineering personnel will be a priority to ensure 

construction costs remain reasonable. Cost estimates will be refined during the preliminary 

engineering phase. It should be noted that the incremental cost to go from 60 mph to 90 

mph on the approaching track is insignificant compared to the cost of building the bridges. 

Comment 8: How would the alternatives considered compare if they all assumed a 60 mph 

MAS? Would the alternatives be less complicated and costly? Would the limits of the 

work area, and associated construction impacts, be as large?

Response 8: Please see Responses 4 and 5 for the reasons a 60 mph MAS is not reasonable 

or consistent with FRA’s NEC FUTURE Program. See Table 2-2 and Section 2.5.1 in 

Chapter 2 of the EA. The Alignment Options vary in their ability to allow 90 mph speeds 

for all permanent and temporary NEC tracks. The great majority of costs associated with 

any of the alternatives is associated with the new two-track structures over the M&E, 

Conrail and westbound (WB) PATH tracks. The new bridges must be constructed clear of 

all existing girders and columns and will be located on the north side (where there is 

sufficient room), nearly parallel to the existing bridges. Clearing the existing structure 

elements is the critical dimension to locating the new bridges. The alignment of the new 

structure conforms with the existing alignment and can support 100 mph+ speeds and is 

not the limiting factor. The maximum speed is determined by the permissible speeds trains 

will be able to run through the curved tracks approaching the new bridge. This is the 

limiting factor. The 90 mph speed versus a 60 mph speed is accommodated by changing 

the radius lengths of the respective curves and corresponding amounts of superelevation 

for the tracks leading to/from the new bridge. Establishing the longer radius curves for the 

90 mph design speeds requires minor embankment widening and minor lengthening of the 

curved track sections. The costs for the modified approach track sections with respect to 
7

the overall project costs are not significant. Overall, the project’s cost and complication 

would not be meaningfully reduced if 60 mph had been the design speed.

Funding

Comment 9: This project is but one of several in the mix of State of Good Repair projects 

within the State of New Jersey that may require financial action by NJ TRANSIT and/or 

the State of New Jersey, as well as the Federal Transit Administration. The yet to be 

identified additional cost associated with providing the proposed 90 mph MAS on the 

Sawtooth Bridges would need to be understood in this funding context.

Response 9: As mentioned in Response 7, the incremental cost to increase from 60 mph to 

90 mph on the approaching track is insignificant compared to the cost of building the 

bridges. A more refined cost estimate will be developed during the preliminary engineering 

phase of the Project, which is expected to include substantial involvement from NJ 

TRANSIT.

Impacts

Comment 10: The proposed plan as already noted avoids causing NJ TRANSIT to limit 

its services which use the NEC. There are some temporal impacts which may be felt on the 

M&E while the new bridges over the M&E are put in place. We would ask that more detail 

be provided regarding the degree to which the existing services (especially the M&E) will 

be impacted.

Response 10: The service impacts to NJ TRANSIT service were analyzed while 

developing the Amtrak Sawtooth Conceptual Design Alternatives Analysis Report, dated 

June 18, 2013. Amtrak has previously provided that report to NJ TRANSIT. To determine 

the track outage windows that could be available for construction on NJ TRANSIT tracks, 

a network simulation operations analysis was performed using a Rail Traffic Controller 

(RTC) model of the Project site1. The results of the analysis were included in an appendix 

to the Amtrak Sawtooth Conceptual Design Alternatives Analysis report, which was 

provided to NJ TRANSIT.

The model assessed weekday and weeknight track outages on the Morris & Essex Tracks 

2 and 3, and two-track outages during weekends on any combination of Tracks 1, 2, and 3. 

The RTC model results showed that taking one track out at a time would not adversely 

impact NJ TRANSIT weekday schedules. On weekends, two tracks could be out of service 

for the entire weekend without significantly impacting NJ TRANSIT scheduled service 

and scheduled non-revenue equipment movements. In addition, train volumes are light 

enough to allow single tracking and predicted delays for any combination of track outages 

 

1 Model based on the June 2, 2013 NJ Transit’s Hoboken Division Operating Plan
8

were found to be negligible. Regarding Track 5, its reconstruction would require only a 

weekend outage to cut-over to the new alignment.

Separate from the NEPA process but as part of advancing the engineering for the Project, 

Amtrak suggests coordinating with NJ TRANSIT to perform a new simulation to reflect 

the existing Operation Plan closer to the construction phase to evaluate the operational 

impacts and identify available work windows.

Speed

Comment 11: NJ TRANSIT does not require that the maximum authorized speed (MAS) 

be 90. Designing for trains to travel at this MAS imposes addition design constraints on 

the project which add to the capital cost and subsequent maintenance costs. While NJ 

TRANSIT staff understands that there is a desire on Amtrak’s part to reduce travel times 

between Washington and NYC it is unclear to us the degree to which increasing the MAS 

through this congested section of the NEC will help in that goal. The segment of track 

proposed for improvement in this EA is approximately 1⁄2 mile in length and it is speed 

constrained to the west by 60 mph track along the curve at HUDSON interlocking. The EA 

needs to specifically define the operational benefits associated with the use of 90 mph MAS 

through this very short section of track that is so close to Newark Penn Station and the 

curve at HUDSON, including expected travel time and reliability benefits. With the current 

level of detail provided it would appear that the benefits would be marginal compared to 

the cost.

Response 11: Responses 4, 5, 7, 8 and 9 outline why a 90-mph design speed was chosen

for the Project. As explained previously, the NEC FUTURE plan defines overall 

operational benefits from integrated operations and standardized train performance at 

higher speeds across the NEC. Additionally, restricting this portion of the corridor to 60 

mph would limit the ability of trains to take full advantage of the new 90 mph Portal North 

Bridge. Finally, reinstating the original 90 mph speed along this portion of the NEC will 

accelerate recovery time in the event of unplanned service disruptions.

We note the 60 mph restriction cited above for Hudson Interlocking is not due to geometric 

limitations. Hudson Interlocking is located on tangent track. The speed limitation stems 

from the bridge condition as well as certain signal system restrictions associated with 

historic operations no longer in effect. Notably, Hudson Interlocking was designed as a 

temporary measure to shorten the blocks during Portal Bridge construction. Once Portal 

North Bridge is completed, high-speed Tracks 2 and 3 within Hudson Interlocking (and the 

accompanying switches) will be substantially removed. The construction of four NEC 

tracks as part of the Project would provide redundant capacity for operations and would 

improve reliability and resiliency to the west of Swift Interlocking. The temporary (run-
9

around) tracks as well as all four permanent tracks would have a design speed of 90 mph 

each, and would result in an operational improvement, as compared to the existing 

condition over the speed-restricted Sawtooth Bridges.

Comment 12: We disagree, unless further documentation can be provided, with primary 

goal #3 that 90 mph MAS is a critical need to improving service efficiency and reliability, 

and do not believe that it should function as a fatal-flaw criterion when developing or 

screening otherwise viable alternatives. Attempting to reach this speed would not be easy 

during peak operating hours given the variety of vertical and horizontal curves, and 

crossovers in this general area.

Response 12: Please see Responses 4 and 11. The design concepts for the Sawtooth 

Bridges have followed the guidance and goals developed by FRA regarding speeds and are 

consistent with the HDIS. Amtrak agrees with these goals and believes they have been 

considered appropriately but not to the exclusion of other critical criteria. We do not believe 

there are any speed restrictions associated with the main track horizonal alignment 

geometry through the project territory and the special trackwork (switches) have been 

designed to provide for high speed diverging operations at Swift Interlocking for primary 

routes to sustain full utilization of track capacity. Secondary routes, such as at Hudson 

Interlocking, provide for 45 mph operations but these secondary routes are currently not 

critical to daily operations except during emergencies or track work. High speeds for these 

secondary routes are neither necessary nor cost effective. Furthermore, reverting to a 60 

mph limitation in this portion of the corridor would be counter to the agreements between 

Amtrak and NJ TRANSIT to construct the New Initiatives Program.

Comment 13: Given that Secaucus Station is generally walled-off along both longitudinal 

sides, effectively creating a tunnel within which trains will pass along passenger tracks, 

there will likely be safety concerns related to trains traveling through at a high rate of speed. 

We recommend that Amtrak update a study on this issue performed for NJ TRANSIT 

during the design phase of the Secaucus Station (that study can be provided at Amtrak’s 

request). 

Response 13: Safety of proposed infrastructure and operations is fundamental. According 

to the Amtrak February 1, 2018 Timetable, 90 mph maximum speeds are authorized from 

Mile Post 3.0 to Mile Post 7.7 for Tracks 2 and 3. This territory encompasses both Secaucus 

Transfer Station as well as the Sawtooth Bridges. These speeds have existed since the 

inception of Secaucus operations a decade and a half ago and no safety issues identified 

with the operating speeds are known. Daily operations with speeds as high as 150 mph on 

tracks adjacent to station platforms can be found on the NEC and they have not presented 

problems. Amtrak will review the study referred to, but because nothing has changed since 
10

that time, Amtrak does not believe the existing and proposed speeds are safety concerns. 

Coordination

Comment 14: Given that the proposed alternative would impact both services, we would 

recommend reaching out to PATH and Conrail in advance of publishing this EA.

Response 14: We agree. Amtrak has coordinated and will continue to coordinate with the 

appropriate agencies and railroads. Amtrak will provide all interested parties with the 

opportunity to review and comment on the EA. 

Comment 15: Although perhaps outside of the bounds of the EA specifically, an 

understanding of how this project factors into the NECC Major Projects (Backlog) process, 

in Amtrak’s view, would be useful in addressing some of the cost and operational issues 

identified above.

Response 15: As noted in the comment, the EA does not discuss the NECC processes 

because they are outside the scope of NEPA. Generally, though, development of the 

Sawtooth Bridge Replacement Project has proceeded following NECC guidelines. 

Timing/Phasing

Comment 16: Given the proposed schedule for this project, Portal North Bridge, and the 

Hudson River Tunnel (HRT), Amtrak will need to be able to sufficiently support each of 

the projects – as abundantly as possible with flag protection and force account personnel –

in order to not impede on the progress of any of the 3 projects, and have the ability to 

support the daily, routine maintenance needs and requirements of the NEC. NJ TRANSIT 

suggests that preliminary, draft staffing projections be made of the numbers of Amtrak 

personnel that will be needed of each union craft if all 3 projects (HRT, Portal, and 

Sawtooth) are proceeding at the same time. 

Response 16: Amtrak recognizes that force account plans must be developed for any 

project before going to construction. Given the advanced status of Portal North Bridge 

design, permitting, local funding commitments, and early construction work, it is 

reasonable to assume that Portal North Bridge construction will likely precede Hudson 

Tunnel and Sawtooth Bridges. Force account plans will be rigorously developed when 

there are better estimates regarding construction timing.

Comment 17: Given that this project is a critically important and time sensitive SOGR 

project that, if delayed, would increase the chance of a catastrophic failure on the NEC, NJ 

TRANSIT recommends considering a phased approach, and that Amtrak consider 

coordinating phase 2 with target implementation after the opening of Portal Bridge North 
11

and before the start of construction on Portal Bridge South. The benefits of the four tracks 

at Sawtooth are most meaningfully realized once Portal South is complete. If there are 

significant benefits to the four tracks in the absence of Portal South then the details of those 

should be clearly documented in this EA.

Response 17: The new, four-track Sawtooth Bridges are not predicated on the construction 

of the new Portal Bridges. One of the initial steps of the design for the new Sawtooth 

Bridges will be to finalize the conceptual design of tying into both the existing Track 2 and 

Track 3 and the future Track 2 and Track 3 for the Portal North Bridge Project. This will 

enable the two projects to connect, regardless of whether the Sawtooth or the Portal North 

Bridge project moves forward to construction first. A final layout to allow for the “full 

build-out” of a future Portal South Bridge, including future Tracks 1, 4, will not be 

precluded at Swift Interlocking. The configuration continues with the track alignment 

concepts established as part of the Access to the Region’s Core (ARC) Project between 

Swift and Hudson Interlockings as agreed to by NJ TRANSIT and Amtrak. The EA makes 

it clear that the construction of four NEC tracks as part of the Project would provide 

redundant capacity for operations and would improve reliability and resiliency to the west 

of Swift Interlocking. Moreover, the train volumes over the Sawtooth Bridges would not 

increase until other projects along the corridor (including Portal South Bridge) are 

implemented. The four tracks constructed as part of the Project would result in operational 

benefits to Amtrak and NJ TRANSIT regardless of when Portal South Bridge is 

constructed.

Construction

Comment 18: Given the limited space to do work in this area of the NEC, Amtrak should 

be give consideration to working with Conrail to deliver by rail the large steel beams that 

will be erected as part of both Sawtooth North and South bridges. Additionally, utilizing 

NJ Transit’s M&E Line off hours– might also be a good alternative for delivery of large 

materials. 

Response 18: FRA and Amtrak agree. The ability to take one track out of service at a time 

on the Morris & Essex Line would be extremely beneficial to the Project as the construction 

staging is refined as part of future design efforts. Furthermore, the use of the Conrail Center 

Street Industrial Track would facilitate this staging and will be considered moving forward.

Connectivity

Comment 19: For the Eastbound Waterfront Connection it is important to remember that 

besides the role it can play to offer a more resilient rail service allowing some NEC trains 

to access Hoboken Terminal, it also is a means of ingress and egress from the MMC. NJ 

TRANSIT requests that Amtrak consider the likelihood of a second eastbound connecting 
12

track to facilitate two-way train traffic through this area. This EA should also outline the 

potential impacts that the proposed alternatives might have to NJ TRANSIT’s desired 

improvement to the speed of Eastbound Waterfront connection in the future.

Response 19: The Sawtooth Bridges Replacement Project conceptual plans have been 

developed so as not to preclude reasonably foreseeable projects, including speed 

improvements on the Eastbound Waterfront. Amtrak is not aware of a second eastbound 

connecting track but would be pleased to review any available plans. 

Comment 20: The Westbound Waterfront Connection, aside from increasing the ability 

of NJ TRANSIT to send some trains to/from Hoboken when there is a loss of train capacity 

on the NEC, will also play a role with train movements in and out of the MMC and 

responding to the long term desire not to have westbound trains cross in front of eastbound 

NEC trains. 

Both the current (Eastbound Waterfront) and future (Eastbound and Westbound 

Waterfront) connections will provide resiliency and redundancy in the case of service 

disruptions east of Sawtooth and additional capacity in advance of the completion of the 

Gateway Program.

Similarly, NJ TRANSIT would appreciate it if the Sawtooth EA explicitly state that the 

Sawtooth design is and will be consistent with the work of the NEC Initiatives project. 

This can at least partially be accomplished by modifying section 1.4.1 of the document by 

including the NEC Initiative and its findings into that section. That section could also 

outline the steps proposed to prevent the preclusion of future changes to the existing 

(eastbound waterfront) and future (westbound waterfront) connections between the NEC 

and the M & E to Hoboken as described above.

Response 20: As noted in Response 19 from Amtrak’s letter dated October 8, 2018 to NJ 

TRANSIT, the Westbound Waterfront Connection has not been precluded by the Project. 

Amtrak understands the importance of the WWC to regional mobility and has incorporated 

information about the Waterfront Connections (provided by NJ TRANSIT in 2013) into 

the Project design. If NJ TRANSIT changed or further developed the plans for the WWC, 

the Sawtooth Bridges’ design team would be pleased to coordinate with NJ TRANSIT. 

FRA and Amtrak will incorporate the findings of the NEC Initiatives report into Section 

1.4.1 of the EA and will state that the proposed Project will not preclude the planned 

improvements described in the NEC Initiatives report. 
13

Comment 21: The EA should be updated to include the milepost location, makeup, and 

functionality of the “Red Bridge”, and how it ties in to the Sawtooth Bridges reconstruction 

proposals.

Response 21: Please see Chapter 2 of the EA and references to potential effects to the Red 

Bridge in the Alignment Options comparison discussion (see Table 2-2 and Section 2.5.2). 

Independent Utility

Comment 22: Figures of alignments reference “Gateway Tracks.” This would seem to run 

counter to statements in the text about independent utility.

Response 22: Figures 2-3 through 2-6 have been modified for clarification. 

Historic and Environmental

Comment 23: Cumulative Impacts should discuss broader set of projects that helps 

“justify” the full option 2A.

Response 23: Chapter 4 discusses a broad array of relevant projects, including Hudson 

Tunnel Project, the new Moynihan Train Hall at New York Penn Station, the new Portal 

Bridges, Secaucus Junction, and Bergen Loop. The chapter also discusses the benefits of 

creating four mainline tracks as part of the overall Gateway Program, including improving 

system resiliency and connectivity and increasing capacity.

Comment 24: Chapter 3, page 32, the reference to the spur of the NJ Turnpike built in 

1976 should be the Western Spur. Also, that spur was started in 1968 and finished in 1970. 

The Eastern Spur was completed as noted in 1954.

Response 24: The text in Chapter 3 has been revised accordingly. 

Specific Comments

Executive Summary

Comment 25: p. 2 – Primary goal 3 indicates that service can be improved by increasing 

design speeds. This should be explained. It may not improve service for NJ TRANSIT.

Response 25: Please see Responses 4 and 11.

Comment 26: p. 4 – NJ TRANSIT “Red Bridge” should be explained – should also be 

consistently referenced in the photographs (see 1-3D).
14

Response 26: Edits made. Photograph 1-3D now refers to the bridge as “NJ Transit Red 

Bridge”.

Purpose and Need

Comment 27: p. 3 – What is the basis for the stated passenger projections?

Response 27: Various trend analyses have supported this forecast. For purposes of clarity, 

the reference in Chapter 1 will be modified to specifically quote the Northeast Corridor 

Infrastructure Master Plan, dated May 2010, which projects 412 million annual NEC 

riders by 2030. Similarly, FRA’s NEC FUTURE Tier I Final EIS estimates that by 2040, 

approximately 439 million annual passenger rail trips will be made.

Comment 28: p. 6 – The description of the need and utility of the proposed Westbound 

Waterfront Connection and its existing Eastbound counterpart is missing important aspects 

of what roles both connections must play. On the second paragraph from bottom of the 

page discussion the WB is characterized as a way to “meet expected passenger demand” 

on several lines. This is incorrect.

Response 28: Existing language in the EA appears to be correct. According to NJ 

TRANSIT, the Westbound Waterfront Connection will increase NJ TRANSIT’S ability 

“to send some trains to/from Hoboken when there is a loss of train capacity on the NEC”

as well as facilitate the movement of trains in and out of the Meadowlands Maintenance 

Complex so that westbound trains do not have to cross in front of eastbound NEC trains. 

Both the Eastbound and Westbound Waterfront Connections “will provide resiliency and 

redundancy in the case of service disruptions east of Sawtooth and additional capacity in 

advance of the completion of the Gateway Program”. In addition, according to the New 

Jersey State Rail Plan published in 2015, the Westbound Waterfront Connection “could 

have the effect of increasing NEC capacity and connectivity for NEC, [Raritan Valley 

Line], and [North Jersey Coast Line] line customers” (page 5-14).

https://www.njtransit.com/pdf/NJStateRailPlan.pdf

Alternatives

Comment 29: P 8 – Would the relocation, realignment, or removal of HUDSON 

Interlocking, be required under Option 2A (selected option) be necessary if a 60 mph MAS 

were assumed? Please provide more detail on how these various modifications to 

HUDSON might be laid out and the operational and environmental impacts that might 

result.

Response 29: Option 2, which assumes 60 mph, would not require the relocation of 

Hudson Interlocking. Assuming a 90 mph MAS and based on conceptual Project design, 
15

Amtrak would need to remove the interlocking or relocate it approximately 500 feet to the 

west. Relocating the interlocking requires minimal infrastructure changes, including 

relocating two crossovers and a signal bungalow within the existing Amtrak ROW.

Whether Amtrak would remove or relocate the Hudson Interlocking depends on the timing 

of Project construction and the timing of the construction of Portal North Bridge. If the 

construction of Portal North Bridge is complete before the phase of the proposed Project 

that involves the construction that would tie the new NEC tracks to the Hudson 

Interlocking, Amtrak would remove the interlocking. Otherwise, Amtrak would relocate 

the interlocking. Please note the majority of the restored Hudson Interlocking was 

undertaken only to temporarily support the construction of Portal North Bridge (and, 

potentially, the Westbound Waterfront Project). Absent these projects, it would not have 

been restored. Except for the switches associated with the Eastbound Waterfront 

Connection and one crossover to Track 2, long-term plans call for its retirement.

Comment 30: P 10 – Please clarify your statement that service transfer to the new M&E 

track 5 can occur with no effect to NJ TRANSIT service.

Response 30: The reconstruction of Track 5 would only require a weekend outage to cutover to the new alignment. The text in Chapter 2 has been modified to the following: 

“Amtrak anticipates that service could be transferred to the new Morris & Essex Line 

Track 5 viaduct with minimal effect to NJ TRANSIT service.”

Comment 31: P 11 – In Section 2.5.5 Amtrak’s apparent, new turnout standard proposed 

to be implemented between SWIFT Interlocking and the modified ALLIED (existing), 

EARLY (new) and LIGHT (new) Interlockings located east of Secaucus Junction Station 

is the “#24 Turnout”. Since HUDSON Interlocking is composed of several #15 Turnouts 

and Crossovers, and since HUDSON is to be relocated in a railroad west direction, would 

future engineering protocol incorporate the installation of #24’s into HUDSON? And, is 

there enough room length-wise to accommodate the longer turnouts? Please provide 

clarification on how this interacts with the recommended MAS.

Response 31: Please see response to comment 29. The issue of turnout size is moot.

Comment 32: P 12 – In Section 2.7 - Bridge Span Design: Given the skew of the various 

tracks that will cross underneath both Sawtooth North and Sawtooth South, careful layout 

of the piers and abutments will have to be well thought-out. Side and vertical clearances 

will weigh heavily on the depth of the superstructure of both bridges, irrespective of 

whether or not short-span or long span options are considered. This will need to be vettedout during the future design phases of the project.

Sawtooth Bridges Replacement Project

Appendix 4 – B

CORRESPONDENCE WITH U.S. ARMY CORPS OF ENGINEERS
Sawtooth Bridges Replacement Project

Appendix 4 – B – 1

LETTER FROM FRA TO USACE, NOVEMBER 6, 2018
U.S. Department 1200 New Jersey Avenue, SE

of Transportation Washington, DC 20590

Federal Railroad 

Administration

November 6, 2018

U.S. Army Corps of Engineers

Environmental Analysis Branch Planning Division

Attention: Peter Weppler, Chief

26 Federal Plaza

New York, NY 10278

Re: Invitation to accept NEPA Cooperating Agency status for the Federal Railroad 

Administration-led Sawtooth Bridges Replacement Project

Dear Mr. Weppler:

The National Railroad Passenger Corporation (Amtrak) is proposing to replace Amtrak 

Bridges No. 7.80 and No. 7.96, collectively referred to as the “Sawtooth Bridges,” which 

are critical links and existing bottlenecks on Amtrak’s Northeast Corridor (NEC). The NEC 

is one of the busiest transportation systems in the world. The Sawtooth Bridges are in the 

Town of Kearny, Hudson County, New Jersey between Newark Penn Station and Secaucus 

Junction (see Figure 1-1). The Federal Railroad Administration (FRA) is serving as the 

lead agency for the Environmental Assessment (EA) pursuant to the National 

Environmental Policy Act (NEPA) of 1969, as amended, for the proposed Sawtooth 

Bridges Replacement Project (Proposed Project). FRA invites the US Army Corps of 

Engineers (USACE) to be a Cooperating Agency on the Proposed Project, as your agency 

may have an interest in the Proposed Project based on your jurisdiction by law, including 

Section 404 of the Clean Water Act, and special expertise.

The increasing age of the Sawtooth Bridges, their poor structural condition, and their two 

tracks (which are restricted to 60 miles per hour [mph]) limit the efficiency and reliability 

of rail operations throughout this segment of the NEC. The purpose of the Proposed Project 

is to achieve a state of good repair and to improve the reliability and resiliency of rail 

service along this critical segment of the NEC. The Sawtooth Bridges do not cross any 

bodies of water; rather, they span over other rail tracks. Amtrak Bridge No. 7.80 carries 

two NEC tracks over four New Jersey Transit Corporation (NJ Transit) rail tracks that serve 

the NJ Transit Morris & Essex Line. Amtrak Bridge No. 7.96 carries the two NEC tracks 

over one Port Authority Trans-Hudson Corporation (PATH) Newark–World Trade Center 

(WTC) rail track and one Consolidated Rail Corporation (Conrail) freight rail track.

Construction of the Sawtooth Bridges Project would result in temporary disturbance of up 

to one acre of wetlands and open waters. Based on the preliminary wetland delineation 

conducted in the study area and the available conceptual designs, Amtrak anticipates that 
2

the Proposed Project may permanently affect approximately 1.04 acres of regulated 

wetlands. Amtrak and FRA would identify exact mitigation measures and wetland 

compensation ratios in collaboration with your agency and other regulatory agencies during 

the subsequent preliminary design and permitting phase. At this time, Amtrak anticipates 

that mitigation requirements would be satisfied through a combination of restoration-inplace and purchasing mitigation credits from an available wetland mitigation bank.

In accordance with the Council on Environmental Quality (CEQ) final implementing 

regulations for NEPA (40 C.F.R. § 1501.6 and § 1508.5), FRA requests your assistance 

and participation in the NEPA process in the following ways: 

(a) Attendance at and input during agency coordination meetings (as appropriate); 

(b) Comment and feedback on the enclosed administrative draft EA; 

(c) Guidance on relevant technical studies included as part of the EA; 

(d) Identification of issues related to your agency’s jurisdiction by law and special 

expertise; 

(e) Adoption of the FRA EA, when needed, to fulfill your independent NEPA 

obligations related to your Federal action and to reduce duplication with other 

Federal, State, Tribal and local procedures.

Please provide your written acceptance or declination of this invitation on or before 

December 3, 2018. Should you decline to accept our invitation to be a cooperating 

agency, we advise that you provide a copy of your response to CEQ as specified at 40 

C.F.R. § 1501.6(c). We look forward to working with your agency on the preparation of 

the EA. If you have any questions or would like to discuss our respective roles and 

responsibilities during the NEPA process in more detail, please contact me at (202) 493-

0844 or brandon.bratcher@dot.gov. 

Sincerely, 

Brandon Bratcher

Environmental Protection Specialist

enclosure
Sawtooth Bridges Replacement Project

Appendix 4 – B – 2

E-MAIL FROM FRA TO USACE, JULY 12, 2019
7/23/2019 The Calladium Group Mail - Fwd: Sawtooth Bridges Replacement Project

https://mail.google.com/mail/u/0?ik=e01c674e80&view=pt&search=all&permmsgid=msg-f%3A1638888223982407554&simpl=msg-f%3A16388882239... 1/1

Hannah Spierer <hannah@calladiumgroup.com>

Fwd: Sawtooth Bridges Replacement Project

Leslie Mesnick <leslie@calladiumgroup.com> Fri, Jul 12, 2019 at 5:06 PM

To: Hannah Spierer <hannah@calladiumgroup.com>

---------- Forwarded message ---------

From: Bratcher, Brandon (FRA) <brandon.bratcher@dot.gov>

Date: Fri, Jul 12, 2019, 4:11 PM

Subject: RE: Sawtooth Bridges Replacement Project

To: James.H.Cannon@usace.army.mil <James.H.Cannon@usace.army.mil>

Cc: Leslie Mesnick <leslie@calladiumgroup.com>, Mielke, Matthew S [USA] <mielke_matthew@bah.com>, Messick, Petra T

<petra.messick@amtrak.com>

Hi again Jim.

Sorry again for the phone tag – but I got your message that, at this time, USACE does not wish to join as a Cooperating Agency. Please

let us know if you change your mind.

Otherwise, we’ll keep you on our distribution list when the EA comes out, for situational awareness.

Have a great weekend!

[Quoted text hidden]
Sawtooth Bridges Replacement Project

Appendix 4 – C

DISTRIBUTION LIST
Amtrak Sawtooth Bridges Replacement Project

Environmental Asssessment Distribution List

Sal First Last Title Agency/Organization Department/Division/

Office Address 1 Address 2 City State Zip Email

Mr. Brandon Bratcher Environmental Protection 

Specialist

Federal Railroad 

Administration

Office of Railroad Policy and 

Development, 

Environmental & Corridor 

Planning Division (RPD-13)

1200 New Jersey 

Avenue, SE (MS-20) Washington DC 20590 brandon.bratcher@dot.gov

Ms. Marlys Osterhues Chief, Environmental and 

Corridor Planning

Federal Railroad 

Administration Office of Program Delivery 1200 New Jersey Avenue, SE (W36-37) Washington DC 20590 marlys.osterhues@dot.gov

Mr. Peter Weppler Chief, Environmental Analysis 

Branch Planning Division U.S. Army Corps of Engineers 26 Federal Plaza New York NY 10278 peter.m.weppler@usace.army.mil

Mr. Stephen Goodman Regional Administrator, 

Region 2

Federal Transit 

Administration - Region 2 One Bowling Green Room 428 New York NY 10004 stephen.goodman@dot.gov

8ik Dave Kluesner Acting Director, Region 2 U.S. Environmental 

Protection Agency - Region 2 290 Broadway New York NY 10007 kluesner.dave@epa.gov

Ms. Jennifer Anderson

Assistant Regional 

Administrator for Protected 

Resources

NOAA National Marine 

Fisheries Service

Protected Resources 

Division

55 Great Republic 

Drive

Gloucester MA 01930 jennifer.anderson@noaa.gov

Mr. Christopher Boelke NE Field Office Supervisor NOAA National Marine 

Fisheries Service

Habitat Conservation 

Division

55 Great Republic 

Drive

Gloucester MA 09130 christopher.boelke@noaa.gov

Ms. Michaela Noble

Director, Office of 

Environmental Policy and 

Compliance

Department of Interior MIB-MS 2340

1849 C Street 

NW (MS 2462) Washington DC 20240

Mr. Andrew Raddant Regional Environmental 

Officer Department of Interior

Office of Environmental 

Policy and Compliance, 

Northeast Region

15 State Street 8th Floor Boston MA 02109 andrew_raddant@ios.doi.org

U.S. Fish and Wildlife Service New Jersey Field Office 4 East Jimmie Leeds 

Road Suite 4 Galloway NJ 08205 NJFO_ProjectReview@fws.gov

Ms. Ruth Foster Acting Director NJ Department of 

Environmental Protection

Office of Permit 

Coordination and 

Environmental Review

401 East State Street PO Box 420 Trenton NJ 08625 Ruth.Foster@dep.nj.gov

Ms. Sharon Mascaro

Deputy Director of Land Use 

Management & Deputy Chief 

Engineer

New Jersey Sports and 

Exposition Authority

One Dekorte Park 

Plaza PO Box 640 Lyndhurst NJ 07071 smarscaro@njsea.com

Ms. Francesca Giarratana Division Chief Hudson County Division of 

Planning

Bergen Square 

Center

830 Bergen 

Avenue, Suite 6A Jersey City NJ 07306 fgiarrantana@hcnj.us

Mr. Jonathan Broder

Vice President - Corporate 

Development and Chief Legal 

Officer

Consolidated Rail 

Corporation

1717 Arch Street Suite 1310 Philadelphia PA 19103 jonathan.broder@conrail.com

Mr. Ryan Hill Director - Design & 

Construction

Consolidated Rail 

Corporation

100 Howard 

Boulevard Mount Laurel NJ 08054 ryan.hill@conrail.com

Mr. Bill Kaeser Assistant Chief Engineer Consolidated Rail 

Corporation

100 Howard 

Boulevard 4th Floor Mount Laurel NJ 08054 william.kaeser@conrail.com

Mr. Vincent Milano Design and Construction Consolidated Rail 

Corporation

100 Howard 

Boulevard Mount Laurel NJ 08054 vincent.milano@conrail.com

Mr. John Keller Executive Director New Jersey Turnpike 

Authority PO Box 5042 Woodbridge NJ

07095-

5042
Amtrak Sawtooth Bridges Replacement Project

Environmental Asssessment Distribution List

Sal First Last Title Agency/Organization Department/Division/

Office Address 1 Address 2 City State Zip Email

Mr. Kevin Corbett Executive Director NJ Transit One Penn Plaza East Newark NJ 07105

Mr. Jeremy ColangeloBryan

Chief Planner NJ Transit One Penn Plaza East Newark NJ 07105 jcolangelo-bryan@njtransit.com

Mr. Todd Discala Director, Trans-Hudson 

Intermodal Planning NJ Transit One Penn Plaza East Newark NJ 07105 tdiscala@njtransit.com

Ms. Katherine Marcopul Deputy State Historic 

Preservation Officer

NJ Department of 

Environmental Protection Historic Preservation Office Mail Code 501-04B 501 East State Street, 4th Floor Trenton NJ 08625 kate.marcopul@dep.nj.gov

Mr. Michael Farbiarz General Counsel Port Authority of New York 

and New Jersey Law Department 4 World Trade Center

150 Greenwich 

Street, 23rd 

Floor

New York NY 10007 mfarbiarz@panynj.gov

Ms. Elizabeth Rogak, Esq. Port Authority of New York 

and New Jersey Law Department 4 World Trade Center

150 Greenwich 

Street, 25th 

Floor

New York NY 10007 erogak@panynj.gob

Ms. Mary Murphy Director Port Authority of New York 

and New Jersey

Planning and Regional 

Development 4 World Trade Center

150 Greenwich 

Street, 23rd 

Floor

New York NY 10007 mkmurphy@panynj.gov

Ms. Clarelle DeGraffe Executive Director Port Authority of New York 

and New Jersey - PATH 1 PATH Plaza Jersey City NJ 07306

Ms. Kelly Pollard, P.E. Manager of Technical 

Services

PATH Capital Project 

Management Division 1 PATH Plaza 6th Floor Jersey City NJ 07306 kpollard@panynj.gov

Mr. Francis Sacr Interim Executive Director Gateway Program 

Development Corporation

C/O Port Authority of New 

York and New Jersey 4 World Trade Center 15th Floor New York NY 10007 fsacr@panynj.gov

Ms. Mary D. Ameen Executive Director North Jersey Transportation 

Planning Authority One Newark Center

1085 Raymond 

Boulevard, 17th 

Floor

Newark NJ 07102 lgoldman@njtpa.org

Mr. James Bruno, Esq. Town of Kearny Castano Quigley LLC 155 Passaic Avenue Suite 340 Fairfield NJ 07004 jbruno@cq-law.com

Mr. Christopher Wilson Program Analyst Advisory Council on Historic 

Preservation

401 F Street NW Suite 308 Washington DC 20001 cwilson@achp.gov

Ms. Kim Penrod Director, Cultural Resources Delaware Nation 31064 State Highway 

281

PO Box 825 Anadarko OK 73005 kpenrod@delawarenation.com

Ms. Tonya Tipton

Director, Enrollment and 

Tribal Historic Preservation 

Office

Shawnee Tribe of Oklahoma PO Box 189 Miami OK 74354 tonya@shawnee-tribe.com

Mr. Chester Brooks Chief Delaware Tribe of Indians 5100 Tuxedo 

Boulevard Bartlesville OK 74006 cbrooks@delawaretribe.org

Ms. Diane

GutierrezScaccetti Commissioner NJ Department of 

Transportation

David J. Goldberg 

Transportation 

Complex

1035 Parkway 

Avenue

Trenton NJ 08625