Environmental Assessment and 

Section 4(f) 

Evaluation 

Phase I 

National Gateway 

Clearance Initiative 

Pursuant to the National Environmental Policy Act of 1969 42 U.S.C. 4332(2)(C) 

September 7, 2010

Lead Agencies: 

Cooperating Agencies: 

epartment of Transportation 

Pennsylvania 

Department of Transportation 

West Virginia 

Department of Transportation 

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Table of Contents 

1. Summary 1

1.1 History of the Initiative 1

1.2 Logical Termini 7

1.3 Need and Purpose 9

1.4 Summary of Impacts and Mitigation 11

1.5 Agency Coordination and Public Involvement 18

1.5.1 Agency Coordination 18

1.5.2 Public Involvement 21

2. Need and Purpose of the Action 22

3. Context of the Action and Development of Alternatives 25

3.1 Overview 25

3.1.1 No Build Alternative 25

3.1.2 Proposed Action 26

3.2 Bridge Removal 26

3.3 Bridge Raising 27

3.4 Bridge Modification 27

3.5 Tunnel Liner Modification 28

3.6 Tunnel Open Cut 28

3.7 Excess Material Disposal 29

3.8 Grade Adjustment 29

3.9 Grade Crossing Closures/Modifications 30

3.10 Other Aspects 30

3.10.1 Interlocking 30

3.10.2 Modal Hubs 30

4. Impacts and Mitigation 31

4.1 Corridor-Wide Impacts 31
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Table of Contents 

4.1.1 Right-of-Way 31

4.1.2 Community and Socio-Economic 31

4.1.2.1 Community Cohesion 31

4.1.2.2 Employment Opportunity 31

4.1.2.3 Environmental Justice 34

4.1.2.4 Public Health and Safety 35

4.1.3 Traffic 36

4.1.3.1 Maintenance of Traffic 36

4.1.3.2 Congestion Reduction 37

4.1.4 General Conformity Analysis 37

4.1.4.1 Regulatory Background 37

4.1.4.2 Evaluation 39

4.1.4.3 Construction Emissions 40

4.1.4.4 Conclusion 45

4.1.5 Noise and Vibration 45

4.1.6 Solid and Hazardous Materials 47

4.1.7 Floodplains 48

4.1.8 Water Quality 48

4.1.9 Biological Resources 49

4.1.10 Visual and Aesthetics 50

4.1.11 Parks and Recreational Resources 52

4.1.12 Historic and Cultural Resource Coordination, Schedule and 

Process 54

4.1.12.1 Ohio Projects 55

4.1.12.2 Pennsylvania 55

4.1.12.3 West Virginia 56

4.1.12.4 Maryland 57

4.1.13 Section 4(f) Analysis Schedule and Process 57
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Table of Contents 

4.1.14 Indirect and Cumulative Effects 57

4.1.15 Public Involvement 60

4.1.15.1 Ohio 60

4.1.15.2 Pennsylvania 61

4.1.15.3 West Virginia 61

4.1.15.4 Maryland 62

4.2 State-by-State Component Impacts and Mitigation 62

4.3 Ohio Separately Funded Projects 62

4.3.1 Ohio State Funded Projects 63

4.3.2 Ohio American Recovery and Reinvestment Act Funded Projects 63

5. Net Benefits Programmatic Section 4(f) Evaluation 64

5.1 Introduction 64

5.1.1 Recreational Trails 64

5.1.2 Historic Sites 68

5.1.3 Applicability of the Net Benefits Section 4(f) Programmatic 71

5.1.4 Summary 72

5.2 Summary of Affected Section 4(f) Resources 72

5.2.1 Introduction 72

5.2.2 Rail Corridor History 73

5.2.2.1 B&O Railroad 73

5.2.2.2 Rail Decline and Current Rail Renaissance 77

5.2.3 Contributing Resources 79

5.2.3.1 Pennsylvania - B&O Railroad Pittsburgh Division 79

5.2.3.2 West Virginia and Maryland - B&O Railroad Magnolia 

Cutoff 81

5.3 Proposed Action and Impacts to Section 4(f) Properties 82

5.3.1 Proposed Action 82

5.3.2 Impacts to Section 4(f) Properties 84
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5.4 Alternatives Analysis 86

5.4.1 Do Nothing/No Build Alternative 87

5.4.2 Improve the Transportation Facility in a Manner that Addresses the 

Project's Purpose and Need Without a Use of the Section 4(f) 

Property 88

5.4.3 Build the Transportation Facility at a Location that Does Not 

Require Use of the Section 4(f) Property 89

5.5 Net Benefit Analysis and Finding 90

5.5.1 Net Benefit Finding and Applicability 90

5.5.2 Measures to Minimize Harm 91

5.5.2.1 Project Design Coordination 91

5.5.2.2 Arch Liner and Portal Notching 92

5.5.2.3 Memorandum of Agreement 93

5.5.3 Net Benefit to Section 4(f) Resources 97

5.5.4 Summary 98

5.6 Coordination 98

6. References 101

7. Acronyms 105

 Tables 

Table 1 Phase I List of Obstructions 

Table 1a Track Support Work 

Table 2 General Conformity Rule De Minimis Emissions Levels Summary 

Table 3 Obstructions Location and Associated Nonattainment/Maintenance 

 Status 

Table 4 General Conformity Analysis – Total Emissions for Projects 

Table 5 Summary of Historic Properties and Assessment of Effects 

Figures 

Figure 1 Phase I Corridor National Gateway Clearance Initiative 
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Table of Contents 

Figure 2 Phase I Corridor National Gateway Clearance Initiative Obstructions 

Figure 3 Baltimore & Ohio Railroad’s Pittsburgh Division 

Figure 4 Baltimore & Ohio Railroad’s Magnolia Cutoff 

Figure 5 Pittsburgh and Lake Erie Railroad 

Appendices 

A Approved State NEPA Documentation

B Cost Benefit Methodology in Evaluation of Project Costs and Benefits and 

Economic Impacts

C Federal Cultural Resource Coordination

D Ohio Phase I National Gateway Clearance Initiative Documentation 

E Pennsylvania Phase I National Gateway Clearance Initiative 

Documentation

F West Virginia Phase I National Gateway Clearance Initiative 

Documentation

G Maryland Phase I National Gateway Clearance Initiative Documentation

H Memorandums of Understanding

I State’s Acquisition Brochures

J Air Conformity Modeling

K Photographs of Tunnel Alternatives 
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Phase I National Gateway 

Clearance Initiative 

1. Summary 

The National Gateway Clearance Initiative is an improvement program to achieve a 

minimum of 21 feet of clearance along CSX Transportation Inc’s (CSX) rail corridor so 

that double-stacked intermodal railcars can be transported between Mid-Atlantic States 

and their ports to Midwest markets. Phase I of the National Gateway Clearance 

Initiative includes federally funded clearance improvements and other rail 

improvements between Northwest Ohio and Chambersburg, Pennsylvania, as noted 

subsequently, see Figure 1. The U.S. Department of Transportation (U.S. DOT) 

awarded a Transportation Investment Generating Economic Recovery (TIGER) 

Discretionary Grant to the National Gateway Freight Rail Corridor. The Federal 

Railroad Administration (FRA) and The Federal Highway Administration (FHWA) are 

partnering to administer the implementation of the TIGER grant on behalf of the U.S. 

DOT and in collaboration with the states of Ohio, Pennsylvania, West Virginia, and 

Maryland and CSX. 

1.1 History of the Initiative 

CSX and the State of Ohio publicly 

launched the National Gateway initiative 

on May 1, 2008, in Dublin, Ohio. The 

National Gateway initiative is an effort to 

improve efficiency and expand capacity 

on the nation’s transportation network. 

This public-private partnership consists 

of more than $842 million in rail 

infrastructure and intermodal terminal work that will enhance transportation service 

options along three major corridors: I-95/I-81 in North Carolina, Virginia, and Maryland; 

I-70/I-76/I-80 between Washington, D.C. and Northwest Ohio; and the I-40/Carolina 

Corridor between Charlotte and Wilmington, North Carolina (Figure 1). The National 

Gateway initiative corridor crosses six states and the District of Columbia. These 

states include Ohio, Pennsylvania, West Virginia, Maryland, Virginia, and North 

Carolina. The National Gateway initiative will create a highly efficient rail system to 

connect Midwest producers and consumers with mid-Atlantic ports and world markets. 

These improvements are likely to spur economic growth throughout the region. The 

ability to quickly and efficiently move goods to markets throughout the country is vital to 
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Phase I National Gateway 

Clearance Initiative 

the economy. Part of this initiative proposes to modify existing railroad infrastructure to 

provide sufficient vertical clearance and operating capability for CSX to operate doublestacked, domestic-container, rail traffic cars on the CSX’s intermodal rail network along 

the National Gateway initiative corridor. Using double-stacked freight trains to move 

freely between Mid-Atlantic ports and Midwest markets is one way to increase capacity 

without exceeding the existing capacity of the infrastructure, or using new rail lines with 

additional trains. Completion of this initiative will allow America’s rail network to support 

increased freight volumes, including traffic coming from the East Coast ports. 

Figure 1 Phase I Corridor National Gateway Clearance Initiative 

As part of this larger program, the National Gateway Clearance Initiative will allow for 

double-stacked freight trains between the yards located in Northwest Ohio, near North 

Baltimore; Chambersburg, Pennsylvania; Baltimore, Maryland; Suffolk, Virginia; and 

Wilmington, North Carolina. The State of Ohio on behalf of Pennsylvania, Maryland, 
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Clearance Initiative 

Virginia, and West Virginia, submitted a U.S. DOT TIGER Discretionary Grant 

application for the clearance improvements on September 14, 2009. The application 

requested $258 million to modify existing railroad infrastructure at 61 obstructions to 

provide sufficient vertical clearance and operating capability for CSX to operate doublestacked, domestic-container, rail traffic cars on CSX’s intermodal rail network along the 

National Gateway Clearance Initiative corridor. On February 17, 2010, the U.S. DOT 

awarded Ohio, Pennsylvania, West Virginia and Maryland $98 million in TIGER grant 

funding for Phase I of the National Gateway Freight Rail Corridor. The FRA and 

FHWA will oversee the implementation of the TIGER grant. This grant award will be 

utilized by the four states and CSX for the proposed action to increase the vertical 

clearance at 30 obstructions along Phase I of the rail corridor from the intermodal yard 

near North Baltimore, Ohio, to the yard at Chambersburg, Pennsylvania. The FRA and 

FHWA have concluded that these two railroad yards are logical termini, that the 

corridor has independent utility, and that completion of this Phase I will not foreclose 

reasonable alternatives for future phases of the National Gateway initiative. In addition 

to the TIGER grant, the State of Ohio has pledged state funds to increase the vertical 

clearance at four obstructions and American Recovery and Reinvestment Act (ARRA) 

funds for eight other obstructions (six clearance obstructions and two interlockings). 

The proposed action, the rail corridor clearance improvements between these two 

intermodal yards, is referred to as Phase I. Table 1 notes the 40 clearance 

obstructions and proposed improvements included in the Phase I corridor, and they are 

depicted in Figure 2. It should be noted that the states’ TIGER federal funding request 

did not include the Northwest Ohio Terminal near North Baltimore, Ohio or the CSX 

Chambersburg Terminal in Chambersburg, Pennsylvania and that no federal funding 

was provided in the TIGER grant award for these facilities. 

The projected cost to complete the clearance improvements proposed for Phase I is 

$183 million. These costs will be covered by a combination of federal, state, and 

private funds (CSX). As noted previously, the U.S. DOT awarded the National Gateway 

Freight Rail Corridor $98 million in TIGER grant funding. As part of the National 

Gateway Clearance Initiative, the State of Ohio pledged $30 million ($20 million in 

ARRA funds and $10 million in state funds) in funding, and the Commonwealth of 

Pennsylvania pledged $35 million in a Transportation Assistance Program (TAP) grant. 

The state funds will be utilized for the proposed clearance improvements in Phase I, in 

each respective state. In addition, CSX has approved up to $20 million in capital 

funding to cover the remaining portion of the clearance work, if needed. Estimated 
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Environmental Assessment 

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Phase I National Gateway 

Clearance Initiative 

Example of Rail Interlocking 

costs by obstruction and funding source are included in 

Table 1. Additional track support work required to 

complete the clearance improvements is included in Table 

1a. Track support work consists of interlockings (rail 

crossovers) that are constructed to facilitate the efficient 

movement of trains through improvement locations. In 

Pennsylvania where tunnels are proposed for open cutting 

land will be used for the permanent placement of material 

removed from the open-cutting operations. 

As noted previously, Ohio has separately advanced 

improvements to ten obstructions included in Table 1 with 

funding outside the proposed action supported by the 

TIGER grant award. Four bridge projects are moving 

forward under a $10 million state allocation. The 

improvements will be permitted in accordance with state and federal requirements. 

Additionally, in Ohio, improvements to six obstructions and the two interlockings have 

received a $20 million commitment of Ohio ARRA funds. These improvements were 

approved as Categorical Exclusions (CE). Copies of the approved CEs for the ARRA 

funded projects are provided as Appendix A. These ten Ohio bridges are structurally 

deficient and therefore their replacement or removals possess independent utility. The 

two interlocking projects were necessitated by adjacent bridge projects. Moreover, they 

do not constrain the decision to build or not build the remainder of National Gateway 

Phase 1. Therefore their impacts are not included in this document. 

Table 1. Phase I List of Obstructions 

NAME CITY STATE ID TYPE FUNDING ESTIMATED 

COSTS 

TR 391 Sullivan OH BG 175.70 Replace Bridge State $3,306,923 

CR 150 Sullivan OH BG 175.30 Remove Bridge State $3,428,336 

River Corners Road Pawnee OH BG 169.70 Replace Bridge State $3,196,693 

Pawnee Road Pawnee OH BG 168.70 Remove Bridge State $3,870,702 

Mud Lake Road Westfield OH BG 160.20 Replace Bridge ARRA $4,299,000 

Thornton Street Akron OH BG 131.00 Lower Track TIGER $251,926 
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Table 1. Phase I List of Obstructions 

NAME CITY STATE ID TYPE FUNDING ESTIMATED 

COSTS 

Overhead Walkway Akron OH BG 130.13 Lower Track TIGER $323,919 

Park Street Akron OH BG 129.50 Remove Bridge ARRA $1,984,154 

W&LE Railway Bridge Kent OH BG 118.20 Lower Track TIGER $5,393,803 

Main Street Kent OH BG 117.30 Lower Track TIGER $14,376,894 

Crain Avenue Kent OH BG 117.00 Replace Bridge ARRA Under 

Construction 

Recreational Trail Kent OH BG 115.80 Raise Bridge TIGER $2,579,457 

W&LE Railway Bridge Kent OH BG 115.67 Raise Bridge TIGER Included 

Within 

115.80 costs 

of 

$2,579,457 

NS Railroad Bridge Ravenna OH BG 110.80 Lower Track TIGER $6,347,259 

Knapp Road Ravenna OH BG 107.10 Replace Bridge ARRA $3,096,562 

Rock Spring Road Newton Falls OH BG 105.40 Replace Bridge ARRA $3,086,462 

5th Street Niles OH BG 85.70 Replace Bridge ARRA $4,159,432 

Abandoned Railroad 

Bridge 

Youngstown OH BG 76.60 Remove Bridge TIGER $480,037 

Overhead Walkway Coraopolis PA PLE 10.25 Remove Bridge TIGER/ TAP $852,162 

Ohio Central Railroad McKees 

Rocks 

PA PLE 3.79 Lower Track/ Raise 

Bridge 

TIGER/ TAP $2,751,940 

Chartiers Creek Pittsburgh PA PLE 3.36 Bridge Modification TIGER/ TAP $115,247 

Smithfield Street Pittsburgh PA PLY 0.09 Lower Track TIGER/ TAP $3,006,596 

West End of J&L 

Tunnel 

Pittsburgh PA PLY 1.96 Remove Bridge TIGER/ TAP $190,869 

J&L Tunnel Pittsburgh PA PLY 2.00 Raise Tunnel Roof TIGER/ TAP $27,589,386 

East End of J&L 

Tunnel 

Pittsburgh PA PLY 2.37 Bridge 

Modification/Remove 

Portion of Bridge 

TIGER/ TAP $466,579 

Walnut Street McKeesport PA BF 309.70 Lower Track TIGER/ TAP $865,813 

Benford Tunnel Confluence PA BFJ 5.00 Open Cut TIGER $1,099,278 
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Table 1. Phase I List of Obstructions 

NAME CITY STATE ID TYPE FUNDING ESTIMATED 

COSTS 

Brook Tunnel Confluence PA BF 239.70 Tunnel Liner 

Removal 

TIGER $9,621,460 

Shoo Fly Tunnel Confluence PA BF 236.80 Open Cut TIGER $1,099,278 

Pinkerton Tunnel Pinkerton PA BF 235.40 Open Cut/Tunnel 

Liner Removal 

TIGER $6,082,532 

Church Street Garrett PA BF 220.00 Replace Bridge TIGER/ TAP $4,969,791 

Blue Lick Truss Sand Patch PA BF 212.83 Raise Bridge TIGER/ TAP $328,598 

Sand Patch Tunnel Sand Patch PA BF 210.60 Liner Notching TIGER $5,469,385 

Falls Cut Tunnel Fairhope PA BF 198.40 Tunnel Liner 

Removal 

TIGER $5,422,670 

Railroad Bridge Hyndman PA BF 191.92 Bridge Modification TIGER/ TAP $89,804 

CSX Railroad Bridge Mexico 

Farms 

MD BA 172.70 Remove Bridge TIGER $858,448 

Carothers Tunnel Paw Paw WV BA 147.00 Tunnel Liner 

Removal 

TIGER $12,615,060 

Graham Tunnel Magnolia MD BA 145.80 Tunnel Liner 

Removal 

TIGER $19,022,780 

Stuart Tunnel Hansrote WV BA 144.50 Liner Notching TIGER $7,507,075 

Randolph Tunnel Hansrote WV BA 142.30 Tunnel Liner 

Removal 

TIGER $12,616,677 

Estimated Costs:  Based on the TIGER grant application.

TIGER funding includes the $98 million TIGER grant award, $35 million in Pennsylvania TAP grant assistance, and up

to $20 million in CSX capital funding.

Crain Avenue‐ Separately funded Ohio ARRA grant, not included in Phase I estimated total cost.

Recreational Trail BG 115.80 and W&LE Railway Bridge OH BG 115.67, Kent Ohio share abutments; project costs are combined.  
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Environmental Assessment 

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Clearance Initiative 

Example of Excess Material 

Placement Area 

Table 1a. Track Support Work

NAME CITY STATE ID TYPE 

New Interlocking Kent OH BG 120.00 Support Track Work 

Upgrade Existing 

Interlocking 

Newton Falls OH BG 103.95 Support Track Work 

Confluence EMPA Confluence PA BF 243.10 Material Placement 

Black Township EMPA Rockwood PA BF 226.00 Material Placement 

Sand Patch EMPA Sand Patch PA BF 211.35 Material Placement 

New Interlocking Magnolia WV BA 145.00 Support Track Work 

Costs for the support work are included in the estimated costs for individual obstructions provided in Table 1.

Figure 2 Phase I Corridor National Gateway Clearance Initiative Obstructions 

1.2 Logical Termini 

The termini for Phase I are the Northwest Ohio Terminal near North Baltimore, Ohio 

and the Chambersburg Terminal in Chambersburg, Pennsylvania. These intermodal 
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Clearance Initiative 

Existing Intermodal Yard 

Northwest Ohio Intermodal Yard 

Groundbreaking August 14, 2009 

yards have the facilities and equipment to handle doublestacked, domestic-container, rail traffic freight trains. These 

trains include cars that can carry double-stacked, standardsized, shipping containers. These containers are intermodal in 

that they can be efficiently transported by ship, train or truck. 

Construction of these facilities, as noted subsequently, is either 

completed or on-going and was privately funded. 

The Northwest Ohio Terminal is strategically located in 

southern Wood County, Ohio and will be a 185-acre worldclass freight distribution hub and the nerve center of CSX’s 

nationwide intermodal network. The official groundbreaking for 

this facility was held in August 2009. Work is ongoing at the 

construction site, and the terminal is scheduled to open to 

business in 2011. The construction of the Northwest Ohio 

Terminal is being funded by CSX and its affiliates. 

The Northwest Ohio Terminal, like an air cargo hub, will handle 

freight trains that arrive directly from across the nation and its 

ports. The facility will quickly and efficiently redistribute the 

freight to a network of double-stacked cargo trains to speed final 

delivery across the eastern United States. Specifically, the 

facility will serve as a key connection point for the CSX network 

and will be capable of consolidating and distributing traffic 

throughout the Midwest and Ohio Valley from the Mid-Atlantic 

terminals at Baltimore and Portsmouth, as well as expanding the service capabilities in 

New York and New England. Additionally, the terminal will allow CSX's interchange 

traffic to be expedited through the Chicago region and switched at North Baltimore, 

freeing additional capacity at the Chicago terminals. 

The privately funded, CSX Chambersburg Terminal opened for business on 

September 7, 2007. This terminal is an 85-acre facility close to the center of 

Chambersburg, Pennsylvania. Similar to the Norwest Ohio Terminal, the 

Chambersburg Terminal allows shippers to take advantage of intermodal 

transportation, the ability to move double-stacked freight containers from train to truck 

without any direct handling of the freight itself. This facility is located near multiple 
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Environmental Assessment 

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Phase I National Gateway 

Clearance Initiative 

distribution and population centers and serves as a key link in the movement of traffic 

between the population and manufacturing centers of the Midwest and the East 

Coast’s international deepwater ports and major consumption markets. 

It should be noted that the states’ TIGER federal funding request did not include the 

Northwest Ohio Terminal or the CSX Chambersburg Terminal in Pennsylvania and that 

no federal funding was provided in the TIGER grant award for these facilities. More 

specifically, no work is proposed for the terminals as part of the $183 million to be used 

for clearance improvements along Phase I of the National Gateway initiative corridor. 

These terminals are not part of the proposed improvements for Phase I. 

1.3 Need and Purpose 

The need for the project is to improve 

the existing rail transportation 

capacity. There are 40 vertical 

clearance obstructions (overpasses 

and tunnels) that prevent the 

opportunity for trains carrying doublestacked intermodal cars to pass 

between the termini of the proposed 

action. The U.S. DOT forecasts an 

increase in freight transportation. 

The current capacity of the transportation network will not be able to maintain projected 

increases. The National Gateway Clearance Initiative is a package of rail infrastructure 

improvements that will enhance transportation service options along an existing major 

freight corridor. The improvements will allow trains to carry double-stacked intermodal 

containers which will increase the existing freight capacity, making the corridor more 

marketable to ports and shippers. 

Intermodal transportation combines the long-haul efficiencies of rail with the short-haul 

flexibility of trucks to achieve cost-effective, efficient, and reliable freight transport. The 

Freight Rail Plans for the states of Ohio, Pennsylvania and Maryland support the 

following: 

• Estimated volumes of intermodal freight are projected to increase. 
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Clearance Initiative 

• The level of service along the major freight rail routes will decline if improvements 

are not completed. 

• One key improvement to the rail infrastructure was identified as removing 

chokepoints such as low clearance obstructions that impede the use of doublestack containers. 

Other issues that intersect with the noted need to improve the existing rail 

transportation capacity include: 

• Freight transportation capacity, especially highway capacity, is expanding too 

slowly to keep up with projected demand. 

• The U.S. is increasingly dependent on foreign oil; freight trains are three times 

more fuel efficient than long haul trucks. 

• Greenhouse gas (GHG) emissions from freight transportation are tied closely to 

freight energy use. Both are growing because energy efficiency improvements in 

the truck freight sector have not kept pace with growth in demand. 

Completion of the project will result in benefits that address the projected increasing 

freight capacity demands, as well as, providing other gains for the U.S, such as: 

• Improvements to railroad capacity, thus providing a cost-effective alternative to 

long-haul trucking. 

• Improves U.S. economic competitiveness by reducing the use of inefficient longhaul trucking and increasing use of the more efficient existing rail corridor, which 

will reduce GHG emissions and the Nation’s dependence on oil. 

• Saves in shipper and logistics costs by increasing existing freight capacity. 
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• Reductions in long-haul congestion on the highway system and thus improves 

highway safety for the traveling public. 

• Creation of short-term construction jobs, over half of which are in economically 

distressed areas. 

The purpose of the proposed action is to remove obstacles to vertical clearance and 

complete other necessary improvements to provide for safe passage of double-stacked 

intermodal containers between the Northwest Ohio Terminal and the CSX 

Chambersburg Terminal. The rail line will be kept operational during construction. 

Completion of the proposed action will double intermodal capacity on the existing 

corridor without increasing noise, emissions, or the number of trains. Instead, 

completion of the proposed action allows any given train to more efficiently carry 

freight. 

1.4 Summary of Impacts and Mitigation 

The subsequent discussion is a summary of impacts, both beneficial and adverse, of 

the Phase I proposed action, which was compiled from each of the four states’ 

appropriate level of environmental documentation. Appendix B provides the statistical 

analysis completed for the proposed action. Cultural resource coordination competed 

by the FRA/FHWA is provided as Appendix C. Additional detail concerning each topic 

at a specific obstruction can be obtained by state in Appendix D, Appendix E, Appendix 

F, and Appendix G for Ohio, Pennsylvania, West Virginia, and Maryland, respectively. 

As noted previously, the proposed action will be completed to increase the vertical 

clearance at 30 obstructions along the rail corridor from the Northwest Ohio Terminal to 

the CSX Chambersburg Terminal. The rail corridor improvements between these two 

intermodal yards are referred to in this document as Phase I, and this summary of 

impacts and mitigation is specific to the federally funded clearance and improvement 

locations in this Phase I corridor. 

• The majority of the individual improvement locations occur within CSX railroad right 

of ways (ROWs). For a few individual obstruction improvements, minor land 

acquisition is necessary; however, local land use patterns will not change as a result 

of the implementation of this action. The proposed action will not change the 

cohesion of the neighborhoods in the specific states or communities along the route. 
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Clearance Initiative 

• The proposed action will not have any disproportionately high or adverse human 

health or environmental effects on minority and low-income populations. 

• Job creation for the proposed action has been estimated using metrics established 

by the White House Council of Economic Advisors in which $92,136 of government 

spending creates one job-year. By the end of 2013, Phase I of the National 

Gateway Clearance Initiative will create more that 3,600 jobs, including nearly 

1,300 jobs in economically distressed areas. Information detailing the derivation of 

economic statistics and job projections is provided as Appendix B. 

• Phase I of the National Gateway Clearance Initiative is projected to have the 

beneficial impact of reducing highway congestion by allowing for double-stacked 

freight trains and reducing the need for long-haul trucks on the region’s highways. 

Railroads are more efficient at moving freight than trucks. Completion will allow 

more freight to move on any given train, which will reduce carbon dioxide 

emissions by 1.19 million tons and save nearly 102 million gallons of fuel. 

Information detailing the derivation of environmental benefit statistics is provided 

as Appendix B. 

• The proposed action will provide relief to congested rail and highway corridors by 

enabling trains to more efficiently carry freight. The ability to transport doublestacked containers and the improved economies of scale generated by the 

proposed action will provide a cost-effective solution to long-haul trucking. This will 

directly reduce highway congestion and reduce highway maintenance costs. 

Benefits associated with reduced truck traffic over the next 20 years include public 

roadway congestion cost savings of nearly $33.6 million and public roadway 

pavement cost savings of over $59 million. Local traffic at intermodal facilities is 

influenced by the interaction of the overall rail system, as well as other unrelated 

local conditions. These traffic changes are addressed through the existing 

transportation programs of the local and state government. 

• The majority of work is limited to rail projects with no vehicular traffic detours or 

maintenance of traffic required. Two Pennsylvania obstructions will have traffic 

detours: J&L Tunnel in Pittsburgh and Church Street in Garrett. Traffic plans (e.g., 

detours and traffic management measures) have been developed and coordinated 
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Clearance Initiative 

Church Street Bridge 

J&L Tunnel 

with local representatives. Additional details concerning 

the affected route and maintenance of traffic for these two 

obstructions are included in Appendix E. 

• The General Conformity Rule applies to all federal actions 

not addressed by the transportation conformity rule. 

Therefore, in accordance with 40 Code of Federal 

Regulations (CFR) 93.153 and 93.158, emissions of 

ozone precursor compounds nitrogen oxide (NOx) and 

volatile organic compounds (VOCs) and PM2.5 and PM2.5 

precursor compounds (sulfur dioxide [SO2] and NOx) 

were analyzed in a General Conformity analysis, for 

obstructions within non-attainment areas. Results of the 

air analysis were compared to the de minimis thresholds. 

The worst case for emissions is expected to be the first 

year of operation. The estimated releases of CO, PM2.5, 

NOx, SO2, and VOCs are below the general conformity 

thresholds of 100 tons per year. Based on the air analysis, 

the proposed action meets the requirements of the Clean 

Air Act. 

• The proposed action will not cause an increase in rail 

traffic noise levels because it will not provide additional 

mainline tracks on new alignment, it will not change the 

maximum operating speed of the track and it will not 

substantially change the shielding effects of the 

surrounding area. At one obstruction, Church Street (State Route [SR] 2037) in 

Garrett, Pennsylvania, a minor change of less than 3 feet will be made to the 

vertical alignment of the roadway. At a second obstruction, J&L Tunnel in 

Pittsburgh, Pennsylvania, 26th Street will be shifted to better align two skewed 

intersections (with Tunnel Boulevard and South Water Street). No changes will be 

made to the roadway capacity. These minor changes to alignment do not meet 

FHWA’s Highway Traffic Noise Analysis and Abatement Policy and Guidance

(1995) - Type I, project criteria. Traffic noise levels will not change as a result of 

the proposed improvements at these two roadway locations. 
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Clearance Initiative 

• Vibration from freight trains is generally dominated by the diesel locomotive, which 

is the prevailing weight on most trains and considerably heavier than most of the 

rolling stock. For example, locomotives weigh approximately 200 tons while coal 

or hopper cars weigh 143 tons (73 percent of the weight of the locomotive). By 

comparison, container stack railcars weigh approximately 73-110 tons maximum or 

only 56 percent of the weight of a locomotive. Other factors contributing to 

elevated vibration levels from freight train passbys, other than weight, include 

travel speed, stiffness of the suspension system, condition or trueness of the 

wheels, condition or type of rail, track type, and type of ground. Therefore, the 

potential vibration effects resulting from the introduction of double-stacked 

container cars along the existing corridor are minimal based on the lower weight of 

the container cars compared to the diesel locomotive. 

• The vast majority of the individual improvements are contained within the CSX 

ROW, and based on a records review no hazardous materials should be 

encountered during construction of these improvements. Should hazardous 

materials be encountered prior to or during the construction phase of the proposed 

action, any identified waste will be managed according to applicable federal, state, 

and local laws, ordinances, and regulations. 

• Any excess materials generated during the grading/cut activities that cannot be 

used within the current CSX-owned ROW will be managed appropriately in 

accordance with applicable federal, state, and local laws, ordinances, and 

regulations. Materials excavated during construction are expected to be 

considered nonhazardous. 

• Based on a review of the National Flood Insurance Program Mapping, portions of 

individual obstruction locations are within the 100-year flood boundary; however, 

no encroachment into the 100-year floodplain is required. 

• The proposed action at CSX Railroad Bridge, Mexico Farms, Maryland, will require 

a U.S. Army Corps of Engineers (U.S. ACE) 404 permit, and corresponding 401 

Water Quality Certification from the State of Maryland, for impacts to wetlands and 

jurisdictional streams. It is expected that the proposed action at CSX Railroad 

Bridge will permanently impact approximately 0.26 acre of wetlands and 

temporarily impact 0.37 acre of wetlands and affect 1.0 to 1.5 acres of wetland 
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buffer. Engineering designs to minimize these impacts are ongoing. Coordination 

regarding potential mitigation for the impacts at CSX Railroad Bridge will be 

completed as part of the permitting process. There are no other impacts to 

streams or wetlands at any of the other individual obstruction locations. 

• For those clearance improvements with earth disturbance over 1 acre, a Storm 

Water Pollution Prevention Plan (SWPPP) will be implemented during construction 

to reduce the potential for erosion and sediment runoff during construction 

activities. Best management practices for erosion control during construction will 

be implemented at all improvement locations to minimize pollutants entering 

waterways. The contractors shall follow best management practices. 

• At all locations requiring a SWPPP, a National Pollutant Discharge Elimination 

System (NPDES) construction storm water permit, verified by the State 

Environmental Protection Agency, will be included with the contract plans for 

adherence during construction. All conditions and terms associated with these 

permits will be fulfilled. 

• All improvement locations were reviewed for potential impacts to federally listed 

threatened and endangered species. Coordination with the Ohio Department of 

Natural Resources (ODNR), U.S. Fish and Wildlife Service (U.S. FWS) in 

Pennsylvania, West Virginia, and Maryland resulted in a ‘no effects’ conclusion in 

the states. However, trees suitable for use as Indiana bat (Myotis sodalis) summer 

roosting habitat have been identified in the vicinity of several Pennsylvania and 

West Virginia clearance improvement locations. Removal of these trees has been 

coordinated with the U.S. FWS. Coordination with the U.S. FWS in Ohio is 

ongoing; any comments received by the U.S. FWS will be implemented and 

followed prior to and during construction. 

• The degree to which proposed action area aesthetics and visual character may be 

impacted was assessed. Overall, the Phase I of the National Gateway Clearance 

Initiative proposed action will create changes to the visual and aesthetic character 

of the rail corridor and surrounding area. Some of these changes may be 

perceived as either positive or negative. However, because most of the changes 

will be to existing infrastructure within an existing corridor, the majority of these 

changes will likely be perceived as aesthetically and visually neutral. 
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J&L Tunnel Open Space Area 

• There will be no permanent impacts to parks or recreational 

resources. Portions of the proposed action are in the immediate 

vicinity of two bicycle/pedestrian paths (Kent Hike and Bike Path, 

Kent, Ohio and the Somerset County Rails to Trails Path 

Allegheny Highland Trail, Keystone Viaduct, Sand Patch, 

Pennsylvania) and a publicly owned area designated for openspace (Open Space over the J&L Tunnel, Pittsburgh, 

Pennsylvania). Impacts to the two bicycle/pedestrian paths and 

the publicly owned area designated for open-space will be 

temporary in nature and of short duration; the resource will be 

fully restored at completion of the proposed action, and these 

details been fully coordinated with the officials with jurisdiction 

over each of the three resources. Memorandums of Understanding (MOUs) are 

being completed with the public officials having jurisdiction of these resources. 

Graham Tunnel in Maryland (vicinity of Magnolia, West Virginia) runs through an 

unnamed hill in the Green Ridge State Forest within the CSX-owned ROW. There 

are no recreational features of the State Forest near the Graham Tunnel project 

activity. Figures depicting the tunnel location, the CSX ROW, and the Green 

Ridge State Forest facilities are included in Attachment 6 of Appendix G. 

• No districts or resources eligible for inclusion on the National Register of Historic 

Places (NRHP) will be adversely affected in the state of Ohio. In Pennsylvania, 

portions of proposed action include two historic railroad corridors, which are 

eligible for listing in the NRHP: Pittsburgh and Lake Erie (P&LE) Railroad and 

Baltimore and Ohio (B&O) Railroad Pittsburgh Division; and are in the immediate 

vicinity of three historic bridges of national significance: Smithfield Street Bridge 

(National Engineering Landmark), Pittsburgh; Walnut Street (SR 0048) Bridge 

(Boston Bridge), McKeesport; and Blue Lick Truss, Sand Patch. The following 

contributing resources to the P&LE Railroad are in the immediate vicinity of or will 

be improved by the proposed action: Chartiers Creek Bridge, Pittsburgh & Lake 

Erie Station, and J&L Tunnel all located in Pittsburgh. Through coordination with 

the PHMC it has been determined, under Section 106 of the NHPA, that there will 

be no adverse affects by the proposed action on the P&LE Railroad including 

elements such as the railroad’s vertical and horizontal alignment, tunnels and 

bridges, signal equipment, rock and slide fencing, drainage, stations/stops, cut and 

fill slopes, sidings, switches, right of way/ownership limits, vegetation as well as the 
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Randolph Tunnel West Portal 

Stuart Tunnel East Portal 

noted contributing resources: Chartiers Creek Bridge, Pittsburgh 

& Lake Erie Station, and J&L Tunnel. The B&O Railroad 

Pittsburgh Division stretches from McKeesport, Pennsylvania to 

Cumberland, Maryland. This historic railroad corridor includes 

the following contributing resources Wills Creek Bridge at 

Hyndman, six tunnels in Somerset County and the two unnamed 

bridges over Wills Creek which are the approaches to Falls Cut 

Tunnel. Due to proposed vertical clearance improvements at the 

six tunnels in Somerset County, the PHMC determined that there 

would be an adverse effect by the proposed action on the B&O 

Railroad Pittsburgh Division. There will be no adverse effects on 

many of the other B&O Railroad Pittsburgh Division elements 

such as Wills Creek Bridge at Hyndman; the two unnamed 

bridges over Wills Creek which are the approaches to Falls Cut 

Tunnel; and the railroad’s vertical and horizontal alignment, 

various unnamed bridges, signal equipment, rock and slide 

fencing, drainage, stations/stops, cut and fill slopes, sidings, 

switches, right of way/ownership limits, and vegetation. The 

Smithfield Street Bridge in Pittsburgh, Pennsylvania; the Walnut 

Street Bridge in McKeesport, Pennsylvania and the Blue Lick 

Truss located in Somerset County, Pennsylvania are historic 

bridges of national significance. Through coordination with the 

PHMC it has been determined that there will be no adverse 

affects by the proposed action on the Smithfield Street Bridge, the Walnut Street 

Bridge or the Blue Lick Truss, nor will any property within a historic boundary be 

acquired. In West Virginia and Maryland, the B&O Railroad Magnolia Cutoff has 

been determined eligible of listing on the NRHP. The B&O Railroad Magnolia 

Cutoff is twelve-mile-long, double-track and includes four tunnels (Carothers, 

Graham, Stuart and Randolph), a long cut at Doe Gully, two bridges over the 

Potomac (Kessler and Magnolia bridges), and a concrete retaining wall west of 

Paw Paw, all of which are contributing resources. Due to the proposed vertical 

clearance improvements at the four tunnels it was determined that there would be 

an adverse effect by the proposed action on the B&O Railroad Magnolia Cutoff. 

The proposed action will have no impact on, therefore will not affect the Kessler or 

Magnolia bridges, the long cut at Doe Gully or the concrete retaining wall west of 

Paw Paw and the railroad’s vertical and horizontal alignment, various unnamed 
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bridges, signal equipment, rock and slide fencing, drainage, stations/stops, cut and 

fill slopes, sidings, switches, right of way/ownership limits, and vegetation. 

• Coordination with each State’s Historic Preservation Office (SHPO) has been 

concluded. The SHPOs in the four states have concurred with the submitted 

Eligibility and Effects for Section 106 resources. A Memorandum of Agreement 

(MOA) has been prepared for the proposed action outlining the results of the 

Section 106 process and the agreed to mitigation, and signed by all parties. The 

MOA is included in Appendix C. 

• A Net Benefit Programmatic Section 4(f) Evaluation has been prepared for the 

Phase 1 corridor, for the adversely effected, significant historic resources with input 

from the FRA/ FHWA and the States. The Section 4(f) Evaluation is included as 

Section 5 of this Environmental Assessment. 

1.5 Agency Coordination and Public Involvement 

1.5.1 Agency Coordination 

In preparation for the environmental document, input from the appropriate federal, 

state, and local agencies concerning potential effects of the proposed action to the 

environment was requested. Scoping letters were sent to the appropriate agencies in 

each of the four project states. Coordination was also conducted through verbal and 

written communication, as needed. The agencies with which coordination was 

conducted are listed by state below. Written comments were received from agencies 

noted with an asterisk (*). 

Coordination in Ohio was conducted with the following agencies: 

U.S. FWS 

Ohio Environmental Protection Agency 

Ohio Historic Preservation Office (OHPO)* 

ODNR* 

Ohio Department of Transportation (ODOT)* 

The City of Kent* 

Municipal and private utility stakeholders, as needed 
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Coordination in Pennsylvania was conducted with the following agencies: 

U.S. FWS* 

National Park Service (NPS) – Potomac Heritage National Scenic Trail* 

Pennsylvania Department of Conservation and Natural Resources* 

Pennsylvania Department of Environmental Protection* 

Pennsylvania Department of Transportation (Penn DOT)* 

Pennsylvania Historical and Museum Commission (PHMC)* 

Pennsylvania Public Utility Commission 

Somerset County* 

City of Pittsburgh 

Urban Redevelopment Authority of Pittsburgh (URA)* 

Municipal and private utility stakeholders, as needed 

Coordination in West Virginia was conducted with the following agencies: 

U.S. FWS* 

West Virginia Department of Transportation* 

West Virginia Division of Culture and History (WVDCH)* 

West Virginia Division of Environmental Protection 

West Virginia Division of Natural Resources (WVDNR)* 

Municipal and private utility stakeholders, as needed 

Coordination in Maryland was conducted with the following agencies: 

U.S. FWS* 

National Park Service 

Chesapeake and Ohio National Historical Park 

National Capital Region 

Maryland Department of Transportation 

Maryland Department of the Environment 

Maryland Department of Planning 

Maryland Department of Natural Resources (MDNR)* 

Maryland Historical Trust (MHT)* 

Maryland Commission on Indian Affairs 
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Green Ridge State Forest* 

Municipal and private utility stakeholders, as needed 

Coordination was completed with the following Native American nations and tribes: 

Absentee-Shawnee Tribe of Oklahoma 

Cayuga Nation 

Cherokee Nation of Oklahoma 

Citizen Potawatomi Nation 

Community of Wisconsin Potawatomi Indians 

Delaware Nation 

Delaware Tribe 

Delaware Tribe of Indians 

Eastern Band of Cherokee Indians of North Carolina 

Eastern Shawnee Tribe of Oklahoma 

Keweenaw Bay Indian Community 

Lake Superior Chippewa 

Miami Tribe of Oklahoma 

Oneida Indian Nation 

Oneida Nation of Wisconsin 

Onondaga Nation 

Ottawa Tribe of Oklahoma 

Peoria Tribe of Indians of Oklahoma 

Prairie Band of Potawatomi Indians 

Seneca Nation of Indians 

Seneca-Cayuga Tribe of Oklahoma 

Shawnee Tribe 

Shawnee Tribe of Oklahoma 

St. Regis Mohawk Tribe 

Stockbridge-Munsee Band of the Mohican Nation of Wisconsin 

Tonawanda Seneca Nation 

Tuscarora Nation 

Turtle Mountain Band of Chippewa Indians 

United Keetoowah Band of Cherokee Indians of Oklahoma 

Wyandotte Nation 

Youghiogheny River Band of Indians, Inc. 
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Additionally, coordination has been completed with private stakeholders including the 

Wheeling and Lake Erie (W&LE) Railway, Akron Barberton Cluster Railway (ABCR), 

Norfolk Southern Corporation (NS), and the Ohio Central Railway. 

Received comments and additional details regarding the coordination are provided 

within the state National Environmental Policy Act (NEPA) documentation included in 

Appendices D, E, F and G. The environmental documentation contained in 

Appendices D through G contain the information gathered in each Phase I state to 

support the NEPA process. The documentation was assembled using the appropriate 

preexisting state forms where available and was provided to the FRA/FHWA in support 

of the preparation of the Environmental Assessment and are not intended to serve as 

standalone NEPA documentation. 

1.5.2 Public Involvement 

Public involvement efforts are essential 

to the implementation of transportation 

solutions that improve safety and 

efficiency, protect the natural and 

human environments, and contribute to 

the community. To provide citizens 

with ample opportunities to learn and 

comment about the proposed action, a 

variety of communication techniques 

were employed in the public 

involvement process for the proposed 

action. Public involvement outreach for the proposed action included letters to 

stakeholders, public notices in newspapers in the vicinity of the obstructions, media 

releases, and four informational workshops held in Ohio, Pennsylvania, and Maryland; 

and the National Gateway – Project Updates website 

(http://updates.nationalgateway.org/). Additional details regarding the public 

involvement outreach and a summary of comments received are provided with the 

state NEPA documentation included in Appendices D, E, F and G. 
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2. Need and Purpose of the Action   

The need for the project is to improve the existing rail transportation capacity. There 

are 40 vertical clearance obstructions (overpasses and tunnels) that prevent the 

opportunity for trains carrying double-stacked intermodal cars to pass between the 

termini of the proposed action. 

According to a white paper developed for FHWA (Cambridge Systematics et al. 2005.), 

“The nation is entering the early stages of a freight transportation capacity crisis. The 

last several decades have witnessed steady growth in the demand for freight 

transportation in the United States, but freight transportation capacity, especially 

highway capacity, is expanding too slowly to keep up with demand.” In addition it is 

noted that: “The effects of growing demand and limited capacity are felt as congestion, 

upward pressure on freight transportation prices, and less reliable trip times as freight 

carriers struggle to meet delivery windows.” The Ohio Statewide Rail Plan – Final 

Report (Ohio Department of Transportation 2010), the Pennsylvania Intercity 

Passenger and Freight Rail Plan (Pennsylvania Department of Transportation 2010), 

and the Maryland Statewide Freight Plan (Maryland Department of Transportation 

2009) each note the following: 

• Projected increases in the estimated volume of intermodal freight that are 

anticipated to be moved along rail lines within their respective states through the 

year 2035. 

• Potential reductions of level of service along the major freight rail routes, including 

the National Gateway initiative corridor, within each respective state if 

improvements to the rail infrastructure are not completed. 

Fuel price volatility and supply are another major influence on the cost of moving 

freight. According to the Department of Energy, the United States uses 20 million 

barrels of oil a day, 55 percent of which is imported. The United States imports more 

petroleum and natural gas than any other country. In 2006 trucking accounted for 67 

percent of freight transportation energy consumption, while rail accounted for only 8 

percent (FHWA 2009b). Freight trains are the most efficient component of the 

intermodal system, approximately three times more fuel efficient than long haul trucks. 

Rail can transport a ton of goods more than 436 miles on a single gallon of fuel, and 
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one train can carry the load of 280 trucks. The Association of American Railroads 

estimates that if 10 percent of the nation’s freight were diverted to rail, fuel savings 

would approach one billion gallons annually. 

Dan Brand (FHWA 2009a) notes that “the impacts of recent oil and gasoline price 

swings notwithstanding, the huge impacts of transportation on U.S. energy 

independence and global warming are continuing primary concerns affecting national 

transportation policy. Importing 60 percent of our domestic consumption, much of it 

from quite unfriendly countries, has annual costs for the United States in the hundreds 

of billions of dollars in transfers of wealth, price shocks, military costs in blood and 

treasure, and other costs such as for the Strategic Petroleum Reserve. The current 

economic situation has shown that adding these costs annually to our national debt 

may be unsustainable.” Completion of the National Gateway initiative promotes rail as 

a cost-effective more efficient alternative to long-haul trucking, reducing GHG 

emissions and the Nation’s dependence on oil. 

As discussed in an FHWA research publication, Innovations for Tomorrow’s 

Transportation (FHWA 2009b). “GHG emissions from freight transportation are tied 

closely to freight energy use. The transportation sector in total is responsible for 28 

percent of all U.S. GHGs, as reported in the U.S. EPA Inventory of U.S. Greenhouse 

Gas Emissions and Sinks. Within the transportation sector, freight movement accounts 

for 27 percent of transportation GHG emissions, with the majority of emissions 

generated by trucking. The rapid growth in freight GHGs and the overall decline in 

freight energy efficiency reflect a growing reliance on freight modes, particularly truck 

and air that provide faster, more reliable service but have higher energy intensity. The 

notable exception to freight’s growing energy intensity can be seen in rail shipments.” 

The increased capacity and improved economies of scale provided through completion 

of the proposed action will result in a cost-effective alternative to long-haul trucking, 

directly reducing highway congestion and highway maintenance costs. The project’s 

benefits include reduced GHG and fuel usage, lower transportation costs, improved 

service reliability, shorter transport times, improved highway safety and expanded 

access to rail services. Furthermore, air quality is projected to improve as rail transport 

produces fewer emissions than truck transport. 
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The proposed action is projected to promote highway maintenance and safety cost 

savings in each state by moving long-haul trucks to rail. The Fatality Analysis 

Reporting System states Ohio and West Virginia have increases in truck related 

crashes since 2006. Pennsylvania has one of the highest numbers of truck-related 

accidents and fatalities in the nation. The proposed action is estimated to reduce truck 

miles traveled by more than 14.3 billion miles. Moving long-haul truck freight to the 

railroad will reduce highway traffic, and result in safer traveling for the general public. 

Significant portions of the investments in this corridor are in economically distressed 

areas. Completion of the National Gateway Clearance Initiative will create over 4,000 

short-term construction jobs, 2,600 of which are in economically distressed areas. Job 

creation was estimated using metrics established by the White House Council of 

Economic Advisors. 

The rail line will be kept operational during construction. Upon completion of the 

proposed action no additional public funding will be needed to maintain the 

infrastructure, since it will remain privately owned and maintained. Completion of the 

proposed action will preserve the competitiveness and sustainability of America’s 

railroad. 

The purpose of the proposed action is to remove obstacles to vertical clearance and 

complete other necessary improvements to provide for safe passage of double-stacked 

intermodal containers between the Northwest Ohio Terminal and the CSX 

Chambersburg Terminal. The proposed action will not increase the number of trains 

on the existing corridor. Modifying vertical clearances to allow for double-stack 

intermodal trains will provide relief to congested rail and highway corridors by enabling 

every train to carry more freight. By increasing the capacity of the existing rail 

infrastructure to move freight, the projected increases in domestic and international 

freight transportation can more readily be accommodated. The ability to quickly and 

efficiently move goods to markets throughout the country is vital to the economy, and 

the ability of using double-stacked trains to move freely between Midwest markets and 

Mid-Atlantic ports is a way to increase capacity without additional trains or new rail 

corridors. This action will aid in improving the nations capacity to move freight, 

improve air quality, improve highway safety, create jobs and preserve the 

competitiveness and sustainability of America’s railroad. 
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3. Context of the Action and Development of Alternatives 

3.1 Overview 

The CSX rail line infrastructure on the National Gateway Clearance Initiative corridor is 

not currently equipped to accommodate double-stacked freight trains. The CSX 

Clearance Improvement Feasibility Study between Greenwich, Ohio and 

Chambersburg, Pennsylvania; Baltimore, Maryland and Weldon, North Carolina

(AECOM 2007) details obstructions in the corridor that prohibit the use of doublestacked freight trains and potential alternatives to clearing the identified obstructions 

and describes a proposed action at each individual project location. The identified goal 

in the feasibility study was to achieve vertical clearance improvements by providing a 

minimum 21-foot vertical clearance standard to allow for unimpeded passage of 

second generation, domestic double-stacked containers. The feasibility study 

reviewed available information on the obstructions, conducted field surveys that 

included measurements of the vertical and horizontal clearances at each quadrant of a 

particular obstruction, and made recommendations for the proposed method of 

increasing the vertical clearance at each obstruction. Consideration was given at each 

obstruction to the age and state of repair of the structure, its current use and/or 

closure, the surrounding land use, ownership of the structure, and the distance needed 

to achieve a minimum 21-foot vertical clearance before recommending a method to 

achieve the desired vertical clearance. The obstructions identified in the feasibility 

study can generally be separated into two categories: bridges and tunnels. There are 

four general methods for increasing the vertical clearance of a bridge: raise the 

existing bridge; modify the bridge superstructure (modify or replace); remove the 

bridge; or lower the tracks beneath the bridge. For tunnels, there are two general 

methods for increasing the vertical clearance: open cutting the tunnel (remove the 

overburden over the tunnel) or modifying the tunnel liner. Except for open cutting a 

tunnel, these improvements are generally minor in nature, will consist of reconstructing 

existing infrastructure, and will generally occur within an existing ROW. 

3.1.1 No Build Alternative 

This alternative has been studied, and it does not correct the situation that creates 

chokepoints to the efficient movement of double-stacked freight containers through the 

corridor. The No Build Alternative does not meet the purpose and need of the 
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proposed action. This alternative was analyzed to provide a baseline condition for 

comparison and evaluation of the proposed action. 

The No Build Alternative assumes normal track maintenance retaining the existing 

conditions along the National Gateway Phase I corridor. The states of Ohio, 

Pennsylvania, and Maryland have noted in their respective statewide rail or freight 

plans that an estimated increase in the volume of freight is anticipated through the year 

2035 and that improvement to existing railroads are needed to handle this increased 

volume. Without the improvements to the existing railroad infrastructure, the increased 

volume of freight must be accommodated on the states’ highway systems by 

increasing the numbers of long-haul trucks. Increasing numbers of trucks on the 

states’ highway systems will likely lead to increasing roadway congestion, increasing 

maintenance and construction costs, and decreasing highway safety and decreasing 

air quality. 

3.1.2 Proposed Action 

The work proposed for Phase I federally funded projects to achieve vertical clearance 

includes removing four bridges, raising of four bridges, modifying four bridges, 

modifying the liners of eight tunnels and open cutting three tunnels, and lowering or 

realigning tracks at seven obstructions. One interlocking (rail crossover) will be 

constructed to facilitate the efficient movement of trains through various improvement 

locations. Finally, in Pennsylvania where tunnels are proposed for open cutting, three 

CSX-owned properties will be utilized as excess material placement areas. 

3.2 Bridge Removal 

The following four obstructions have been recommended for bridge removal: 

• Ohio, Youngstown, Mahoning County, Abandoned Railroad Bridge 

• Pennsylvania, Coraopolis, Alleghany County, Overhead Walkway Bridge 

• Pennsylvania, Pittsburgh, Alleghany County, West End J&L Tunnel, Bridge 

Removal 
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Mexico Farms Railroad Bridge Removal 

• Maryland, Mexico Farms, Allegany County, CSX Railroad Bridge 

3.3 Bridge Raising 

The following four obstructions have been recommended for bridge 

raising: 

• Ohio, Kent, Portage County, Abandoned Railroad Bridge and 

ABCR Railroad Bridge (obstructions share abutment) 

• Pennsylvania, McKees Rocks, Alleghany County, Ohio Central 

Railroad Bridge (A track lowering is still being assessed at this 

location.) 

• Pennsylvania, Sand Patch, Somerset County, Blue Lick Truss 

3.4 Bridge Modification 

The following four obstructions have been recommended for 

modification: 

• Pennsylvania, Garrett, Somerset County, Church Street Bridge 

(This bridge will be replaced.) 

• Pennsylvania, Pittsburgh, Alleghany County, Chartiers Creek 

Bridge (The superstructure of this bridge will be modified.) 

• Pennsylvania, Pittsburgh, Alleghany County, East End J&L 

Tunnel, Bridge Modification (Portions of the structure will be 

removed.) 

• Pennsylvania, Hyndman, Bedford County, Railroad Bridge (The 

superstructure of this bridge will be modified.) 

Kent Bike and Hike Trail Bridge Raising 

Hyndman Railroad Bridge Modification 
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Carothers Tunnel East Portal 

Graham Tunnel North Portal 

3.5 Tunnel Liner Modification 

The following eight obstructions have been recommended for tunnel liner 

modification: 

• Pennsylvania, Pittsburgh, Alleghany County, Pennsylvania, J&L 

Tunnel 

• Pennsylvania, Confluence, Somerset County, Brook Tunnel 

• Pennsylvania, Sand Patch, Somerset County, Sand Patch Tunnel 

• Pennsylvania , Fairhope, Somerset County, Falls Cut Tunnel 

• West Virginia, Paw Paw, Morgan County, Carothers Tunnel 

• Maryland, Allegany County, in the vicinity of Magnolia, West Virginia, 

Graham Tunnel 

• West Virginia, Hansrote, Morgan County, Stuart Tunnel 

• West Virginia, Hansrote, Morgan County, Randolph Tunnel 

3.6 Tunnel Open Cut 

The following three obstructions have been recommended for tunnel 

open cutting: 

• Pennsylvania, Confluence, Somerset County, Benford Tunnel 

• Pennsylvania, Confluence, Somerset County, Shoo Fly Tunnel 

• Pennsylvania, Pinkerton, Somerset County, Pinkerton Tunnel 

(Tunnel liner modifications also being assessed at this location.) Shoo Fly Tunnel 
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NS Railroad Bridge Ravenna Track 

Lowering Grade Adjustment 

3.7 Excess Material Disposal 

The following three areas have been recommended for excess material placement 

from tunnel open cutting operations: 

• Pennsylvania, Confluence, Somerset County, Excess Material Placement Area 

• Pennsylvania, Rockwood, Somerset County, Black Township Excess Material 

Placement Area 

• Pennsylvania, Sand Patch, Somerset County, Excess Material Placement Area 

Any excess materials generated during the tunnel liner modifications, and grading/cut 

activities that cannot be used within the CSX ROW or at the three CSX-owned excess 

material placement areas will be managed appropriately in accordance with applicable 

federal, state, and local laws, ordinances, and regulations. 

3.8 Grade Adjustment 

The following seven obstructions have been recommended for grade adjustment (track 

lowering): 

• Ohio, Akron, Summit County, Thornton Street 

• Ohio, Akron, Summit County, Overhead Walkway 

• Ohio, Kent, Portage County, W&LE Railway Bridge 

• Ohio, Kent, Portage County, Main Street Bridge 

• Ohio, Ravenna, Portage County, NS Railroad Bridge 

• Pennsylvania, Pittsburgh, Alleghany County, Smithfield Street 

Bridge 
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• Pennsylvania, McKeesport, Alleghany County, Walnut Street (SR 0048) Bridge 

(Boston Bridge) 

3.9 Grade Crossing Closures/Modifications 

No public at-grade crossing closures or modifications to existing grade crossings are 

proposed. 

3.10 Other Aspects 

3.10.1 Interlocking 

To maintain rail traffic during improvements at the tunnels in West Virginia and 

Maryland, rail traffic must be shifted from one track to another. To facilitate this 

movement of rail traffic, one new interlocking (rail crossovers) is proposed. 

• West Virginia, Magnolia, Morgan County, Magnolia Interlocking 

3.10.2 Modal Hubs 

The TIGER federal funding request did not include the Northwest Ohio Terminal near 

North Baltimore, Ohio (currently under construction) or the newly constructed CSX 

Chambersburg Terminal in Chambersburg, Pennsylvania, and no federal funding was 

provided in the TIGER grant award for these facilities. More specifically, no work is 

proposed for the terminals as part of the $183 million to be used for clearance 

improvements along Phase I of the National Gateway. These terminals are not part of 

the proposed improvements for Phase I. 
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4. Impacts and Mitigation 

4.1 Corridor-Wide Impacts 

4.1.1 Right-of-Way 

There will be no permanent displacements. The majority of the individual improvement 

locations occur within the CSX railroad ROW. For a few individual improvement 

locations, minor land acquisition and/or temporary construction easements are 

necessary. All acquisition activities will be conducted in accordance with the Uniform 

Relocation and Real property Acquisitions Policy Act, as amended. Copies of the 

State’s acquisition brochures are provided in Appendix I. No property will be acquired 

in West Virginia, therefore no acquisition brochure is included. 

4.1.2 Community and Socio-Economic 

4.1.2.1 Community Cohesion 

The National Gateway Clearance Initiative will not provide new access points, public 

at-grade crossings, or additional mainline trackage. The proposed action will improve 

the existing railroad infrastructure within its existing alignment; therefore, the proposed 

action is not expected to impact the overall physical make-up of the surrounding 

communities or neighborhoods. 

The minor change to the vertical alignment at Church Street (SR 2037) in Garrett, 

Pennsylvania and the shift in horizontal alignment of 26th Street at the J&L Tunnel in 

Pittsburgh, Pennsylvania will not impact any building or the overall physical make-up of 

the surrounding communities or neighborhoods. Traffic detours for construction at 

these two locations will be of short duration. The duration for the Church Street detour 

is expected to be 4 months. 26th Street over J&L Tunnel will be detoured for over a 

year. 

4.1.2.2 Employment Opportunity 

Job creation has been estimated using metrics established by the White House 

Council of Economic Advisors in which $92,136 of government spending creates one 
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job-year. By the end of 2013, the Phase I of the National Gateway Clearance Initiative 

will create more than 3,600 jobs, including nearly 1,200 jobs in economically distressed 

areas. The demand for long-haul truck drivers is expected to increase. The use of 

double-stack trains will flatten the rate if increase demand for long-haul drivers by 

diverting loads from long-haul trucks to double stack trains and increase demand for 

short-haul truck drivers near the intermodal facilities. Information detailing the 

derivation of economic statistics, environmental benefits, and job projections is 

provided as Appendix B. 

By providing clearances for double-stacked trains and expanding intermodal terminal 

capacity the National Gateway Clearance Initiative, over the next 30 years will 

• Provide nearly $5 billion in net public benefits or more than $6 in public benefits for 

every $1 spent. 

• Create more than 3,600 jobs by the end of 2013. 

• Enable modal conversion of nearly 18 million truck trips from United States’ 

highways and reduce truck miles traveled by more than 14 billion miles. 

• Provide nearly $590 million in pavement maintenance cost savings. 

• Provide more than $395 million in shipper and logistics cost savings for new and 

existing rail customers. 

• Reduce transit times between western United States population centers and ports 

in the east and Mid-Atlantic by 24 to 48 hours. 

4.1.2.2.1 Ohio Benefits 

Upon completion, the Phase I National Gateway Clearance Initiative will deliver $398 

million of public benefits to Ohio by 

• Expanding rail market access potential for the State. 

• Enhancing rail transportation infrastructure. 
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• Investing directly in short-term construction projects in Ohio; including 836 

additional jobs. 

• Reducing Ohio’s highway congestion and greatly improving public safety by 

shifting freight from trucks to the enhanced rail network, saving nearly $34.1 million 

of highway maintenance costs in Ohio. 

CSX has estimated that 836 jobs will accrue to Ohio for the clearance initiative. These 

jobs require specialized labor because of the nature of the work, which includes 

working over or adjacent to an active railroad, utility relocation, structure 

demolition/erection, and the necessary protective services and inspections. 

4.1.2.2.2 Pennsylvania Benefits 

Upon completion, the Phase I National Gateway Clearance Initiative will deliver $203.1 

million of public benefits to Pennsylvania by 

• Expanding rail market access potential for the State. 

• Enhancing rail transportation infrastructure. 

• Investing directly in short-term construction projects in Pennsylvania creating 978 

additional jobs by 2013. 

• Reducing Pennsylvania’s highway congestion and greatly improving public safety 

by shifting freight from trucks to the enhanced rail network, saving over $17.4 

million of highway maintenance costs in Pennsylvania. 

CSX has estimated that 978 construction jobs will be generated in Pennsylvania for the 

construction of the individual clearance projects. These jobs require specialized labor 

because of the nature of the work, which includes working over or adjacent to an active 

railroad, utility relocation, structure demolition/erection, and the necessary protective 

services and inspections. 

4.1.2.2.3 West Virginia Benefits 
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Upon completion, the Phase I National Gateway Clearance Initiative will deliver $55.4 

million of public benefits to West Virginia by 

• Enhancing rail transportation infrastructure. 

• Investing directly in short-term construction projects in West Virginia creating 433 

additional jobs by 2013. 

• Reducing West Virginia’s highway congestion and greatly improving public safety 

by shifting freight from trucks to the enhanced rail network, saving over $4.8 million 

of highway maintenance costs in West Virginia. 

4.1.2.2.4 Maryland Benefits 

Upon completion, the Phase I National Gateway Clearance Initiative will deliver $33.6 

million of public benefits to Maryland by 

• Enhancing rail transportation infrastructure. 

• Investing directly in short-term construction projects in Maryland creating 246 

additional jobs, all in economically distressed areas, by 2013. 

• Reducing Maryland’s highway congestion and greatly improving public safety by 

shifting freight from trucks to the enhanced rail network, saving over $2.9 million of 

highway maintenance costs in Maryland. 

4.1.2.3 Environmental Justice 

Title VI of the Civil Rights Act of 1964, protects individuals from discrimination on the 

grounds of race, age, color, religion, disability, sex, and national origin. Executive 

Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations provides that each federal agency shall 

make achieving environmental justice part of its mission by identifying and addressing, 

as appropriate, disproportionately high and adverse human health or environmental 

effects on minority and low-income populations. 
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Demographics for populations in the vicinity of the Phase I obstruction locations were 

analyzed to identify minority or low-income communities. Potential minority or lowincome populations were preliminarily identified through the United States 

Environmental Protection Agency’s (U.S. EPA’s) Environmental Justice Geographic 

Assessment Tool (EJGAT). If the results from the EJGAT suggested the potential for 

minority or low-income populations in the vicinity of an obstruction, additional analysis 

of Census data was completed. At two obstruction locations, Thornton Street and the 

Overhead Walkway Bridge both in Akron, Ohio, minority and/or low-income 

populations were identified in the obstruction vicinity. The proposed action at these 

two obstructions is track lowering that will be completed within the rail ROW and will 

not result in an adverse impact to the adjacent residents. The proposed action will 

improve the existing infrastructure within its existing alignment and thus will not change 

the cohesion of the neighborhoods and communities within the vicinity. The proposed 

action will not have any disproportionately high or adverse human health or 

environmental effects on minority and low income populations. Work will be completed 

during daylight hours, and the contractor will follow standard control measures that 

minimize fugitive dust. Additional information concerning these populations is included 

in Appendix D. 

Demolition activities at the J&L Tunnel in Pittsburgh, Pennsylvania are limited to dates 

between January and May unless otherwise mutually agreed upon by CSX, the URA, 

the City of Pittsburgh and the Soffer Organization, Inc. Blasting of the existing 

structures for removal is not permitted. Work will be completed during daylight hours to 

avoid disrupting the nearby residents. 

Information has been provided to the public regarding the proposed action on an 

ongoing basis through the NationalGateway.org website and a series of public 

informational workshops. No concerns regarding minority and/or low income 

populations were identified during the public informational workshops or through 

comments received from the website. 

4.1.2.4 Public Health and Safety 

New capacity, routes, or alignments are not part of the Phase I National Gateway 

Clearance Initiative. The current CSX infrastructure on the Phase I corridor is not 

equipped to accommodate double-stacked freight trains. The volume of freight is 
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projected to increase. Without completion of the proposed action, the line will become 

more congested, raising shipping costs and potentially crowding passenger rail and 

other services. Similarly, while the number of production jobs in the United States has 

decreased 13 percent in the last ten years, the population has continued to grow. This 

indicates fewer products are manufactured in the United States, while more consumers 

create an increased demand for goods, resulting in a strain on the nation’s ports and 

freight transportation. Completion will allow more freight to be moved on any given 

train. Public health and safety benefits include the following: 

• Providing the opportunity for reducing the number of long-haul trucks from the 

highway 

• Reducing carbon dioxide emissions by 1.19 million tons (Appendix B) 

• Promoting attainment of National Ambient Air Quality Standards 

4.1.3 Traffic 

Coordination has been completed for the proposed action in conjunction with the 

individual state Departments of Transportation (DOTs), as well as local and county 

officials. The Phase I National Gateway Clearance Initiative is projected to reduce 

highway congestion by providing the opportunity for reducing the number of long-haul 

trucks. 

4.1.3.1 Maintenance of Traffic 

The majority of work is limited to rail projects with no vehicular traffic detours or 

maintenance of traffic required. Two Pennsylvania obstructions will require traffic 

detours: 26th Street at J&L Tunnel in Pittsburgh and Church Street (SR 2037) in 

Garrett. Traffic plans (e.g., detours and traffic management measures) have been 

developed individually for each route and coordinated with local representatives. 

Vehicular and pedestrian traffic will be detoured during the construction of the 

proposed action at these locations. Details regarding the maintenance of traffic plans 

are included in Appendix E. The maintenance of traffic detour routes for these two 

facilities (26th Street and Church Street) were communicated at the Public Meetings, to 

which local officials including police, fire, and emergency personnel were invited. The 
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detour route will be directly communicated to local officials, including emergency 

personnel, neighborhoods and schools prior to the start of construction. 

4.1.3.2 Congestion Reduction 

The Phase I National Gateway Clearance Initiative will improve existing rail capability 

limitations that currently hinder the efficient flow of freight traffic. Modifying vertical 

clearances to allow for double-stacked intermodal trains will provide relief to congested 

rail and highway corridors by enabling trains to more efficiently carry freight. The 

increased capacity and improved economies of scale generated by the proposed 

action will provide a cost-effective solution to long-haul trucking. This will directly 

reduce highway congestion and reduce highway maintenance costs. Reduced 

maintenance costs will allow public dollars to be used for other necessary 

transportation projects that may not otherwise have available funding. Benefits 

associated with reduced truck traffic over the next 20 years include public roadway 

congestion cost savings of nearly $33.6 million and public roadway pavement cost 

savings of over $59.2 million. 

4.1.4 General Conformity Analysis 

4.1.4.1 Regulatory Background 

Section 176(c) of the Federal Clean Air Act (CAA) provides that Federal agencies 

cannot engage, support, or provide financial assistance for licensing, permitting, or 

approving any project unless the project conforms to the applicable State 

Implementation Plan (SIP). A SIP is a compilation of a state's air quality control plans 

and rules, approved by the U.S. EPA. The State and U.S. EPA's goals are to eliminate 

or reduce the severity and number of violations of the National Ambient Air Quality 

Standards (NAAQS) and to achieve expeditious attainment of these standards. 

Pursuant to CAA Section 176(c) requirements, the U.S. EPA promulgated Title 40 of 

the Code of Federal Regulations Part 51 (40 CFR 51) Subpart W and 40 CFR Part 93, 

Subpart B, "Determining Conformity of General Federal Actions to State or Federal 

Implementation Plans" (see 58 Federal Register [FR] 63214, [November 30, 1993], as 

amended, 75 FR 17253 [April 5, 2010]). These regulations, commonly referred to as 

the General Conformity Rule, apply to all Federal actions except for those Federal 
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actions which are excluded from review (e.g., stationary source emissions) or related to 

transportation plans, programs, and projects under Title 23 U.S. Code or the Federal 

Transit Act, which are subject to Transportation Conformity. The General Conformity 

Rule applies to all federal actions not addressed by the Transportation Conformity 

Rule. 

40 CFR Part 51, Subpart W, applies in states where the state has an approved SIP 

revision adopting General Conformity regulations; 40 CFR Part 93, Subpart B, applies 

in states where the state does not have an approved SIP revision adopting General 

Conformity regulations. 

The General Conformity Rule is used to determine if Federal actions meet the 

requirements of the CAA and the applicable SIP by ensuring that air emissions related 

to the action do not: 

• Cause or contribute to new violations of a NAAQS; 

• Increase the frequency or severity of any existing violation of a NAAQS; or 

• Delay timely attainment of a NAAQS or interim emission reduction. 

A conformity determination under the General Conformity Rule is required if the federal 

agency determines: the action will occur in a nonattainment or maintenance area; that 

one or more specific exemptions do not apply to the action; the action is not included in 

the federal agency’s “presumed to conform” list, the emissions from the proposed 

action are not within the approved emissions budget for an applicable facility; and the 

total direct and indirect emissions of a pollutant (or its precursors), are at or above the 

de minimis levels established in the General Conformity regulations (75 FR 17255). 

Conformity regulatory criteria are listed in 40 CFR § 93.158. An action will be 

determined to conform to the applicable SIP if, for each pollutant that exceeds the de 

minimis emissions level in 40 CFR § 93.153(b), or otherwise requires a conformity 

determination due to the total of direct and indirect emissions from the action, the 

action meets the requirements of 40 CFR § 93.158(c). 
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4.1.4.2 Evaluation 

The General Conformity Rule first involves a conformity evaluation to determine if the 

proposed action requires a conformity determination based on the criteria listed above. 

Since the projects are not classified as “exempt” activities, a “presumed to conform” list 

does not exist for FRA, and there is no applicable facility budget, the last remaining test 

is the de minimis test. For this test, the quantity of the nonattainment or maintenance 

area pollutant from the project during the highest emission year is compared to the de 

minimis emissions level for that pollutant. If the emissions level is exceeded, further 

analysis and a conformity determination are required. The analyses must consider the 

construction emissions and include the total direct as well as indirect emissions as a 

result of the proposed action. Some of the proposed projects will be located in 

designated nonattainment or maintenance areas for particulate matter less than or 

equal to 2.5 microns in diameter (PM2.5) and ozone. A few of the proposed projects 

are located within a mile or less of designated maintenance areas for CO, SO2 and 

PM10. Because of their close proximity to those areas, they were assumed for the 

sake of this evaluation to be in those designated maintenance areas. 

Therefore, in accordance with 40 CFR § 93.153 and 93.158, emissions of the following 

pollutants and precursors are assessed: ozone precursor compounds NOx and VOCs, 

SO2, CO, PM10, PM2.5 (direct) and PM2.5 precursor compounds (SO2 and NOx) are 

analyzed in a General Conformity analysis. The de minimis thresholds for this analysis 

(all areas) are as follows: 

4.1.4.2.1 General Conformity De Minimis Thresholds 

40 CFR § 93.153 defines DE MINIMIS levels, that is, the minimum threshold for 

which a conformity determination must be performed, for the criteria pollutants found 

for various criteria pollutants in various areas. The information for the project area is 

summarized here: 
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Table 2. General Conformity Rule De Minimis Emissions Levels Summary 

Pollutant Area Type Tons/Year 

Ozone (NOx) Maintenance 100 

Ozone (VOC) 

Maintenance within an ozone transport 

region 

50 

Maintenance outside an ozone transport 

region 

100 

Carbon monoxide, SO2 and 

NO2 

All nonattainment and maintenance 100 

PM-10 Moderate nonattainment and 

maintenance 

100 

PM2.5 - direct, SO2, and 

NOx 

All nonattainment and maintenance 100 

4.1.4.3 Construction Emissions 

Construction-related emissions are not covered by Ohio and Pennsylvania’s 

nonattainment New Source Review (NSR) program (i.e., subject to offset 

requirements) and are therefore evaluated under the General Conformity Rule. 

Construction-related emissions occur in calendar years prior to commencement of 

operations. No other project-related emissions will occur simultaneously with 

construction-related emissions. Specific obstructions (listed as projects below) are 

located in areas that are in or near nonattainment or maintenance for ozone, PM10, 

SO2, CO, and PM2.5, as described in Table 3. 

Table 3. Obstructions Location and Associated Nonattainment/Maintenance Status 

M = maintenance; NA = nonattainment

Project Name City State ID Activity Pollutant 

Thornton Street Akron OH BG 131.00 Lower Track 1997 8-hr ozone 

(M) 

PM 2.51 (NA) 
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Table 3. Obstructions Location and Associated Nonattainment/Maintenance Status 

M = maintenance; NA = nonattainment

Project Name City State ID Activity Pollutant 

Overhead Walkway Akron OH BG 130.13 Lower Track 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

W&LE Railway Bridge Kent OH BG 118.20 Lower Track 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

Main Street Kent OH BG 117.30 Lower Track 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

Recreational Trail2 Kent OH BG 115.80 Raise Bridge 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

W&LE Railway Bridge Kent OH BG 115.67 Raise Bridge 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

NS Railroad Bridge Ravenna OH BG 110.80 Lower Track 1997 8-hr ozone 

(M) 

PM 2.5 (NA) 

Abandoned Railroad 

Bridge 

Youngstown OH BG 76.60 Remove Bridge 1997 8-hr ozone 

(M) 

Overhead Walkway Coraopolis PA PLE 10.25 Remove Bridge 1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

Ohio Central Railroad McKees Rocks PA PLE 3.79 Lower Track/ Raise 

Bridge 

1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

Chartiers Creek Pittsburgh PA PLE 3.36 Bridge Modification 1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

Smithfield Street Pittsburgh PA PLY 0.09 Lower Track 1997 8-hr ozone 

(NA) 
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Table 3. Obstructions Location and Associated Nonattainment/Maintenance Status 

M = maintenance; NA = nonattainment

Project Name City State ID Activity Pollutant 

PM 2.5 (NA) 

CO (M) 

West End of J&L Tunnel3 Pittsburgh PA PLY 1.96 Remove Bridge 1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

SO2 (M) 

J&L Tunnel Pittsburgh PA PLY 2.00 Raise Tunnel Roof 1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

SO2 (M) 

East End of J&L Tunnel Pittsburgh PA PLY 2.37 Bridge 

Modification/Remove 

Portion of Bridge 

1997 8-hr ozone 

(NA) 

PM 2.5 (NA) 

SO2 (M) 

Walnut Street McKeesport PA BF 309.70 Lower Track 1997 8-hr ozone 

(NA) 

PM10 (Mod- M) 

PM 2.5 (NA) 

1

 All PM 2.5 areas are nonattainment under both 1997 and 2006 standards. 

2

 Kent Recreational Trail and W&LE Bridge share abutments and were calculated as one construction project. 

3

 West End of J&L Tunnel, J&L Tunnel, and East End of J&L Tunnel were calculated as one construction project.

The main construction activities for the projects within nonattainment (NA) and 

maintenance (M) areas are listed below: 

• Equipment and site mobilization and demobilization 

• Concrete/Asphalt activities 

• Grinding, sanding, abrasive blasting activities 
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• Welding operations 

• Open cutting activities 

• Coatings usage 

• Earth moving activities 

• Onsite equipment 

– Generators 

– Compressors 

– Boilers 

• Landscaping 

• Fugitive dust 

• Utility crew activities 

For each of the projects, emissions from the construction activities were calculated as 

summarized in Table 4 and included in Appendix J of the Environmental Assessment. 

Table 4. General Conformity Analysis – Total Emissions for Projects

 

VOC 

(tons/year) 

PM2.5 

(tons/year) 

PM10 

(tons/year) 

NOx 

(tons/year) 

SO2 

(tons/year) CO (tons/year) 

Akron, OH Non- Attainment Area 

Thornton 

Street (Akron, 

OH) - Lower 

Track 

0.30 0.52 Not Applicable 4.08 Not Applicable Not Applicable 

Overhead 

Walkway 

(Akron, OH) - 

Lower Track 

0.30 0.41 Not Applicable 4.08 Not Applicable Not Applicable 
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Table 4. General Conformity Analysis – Total Emissions for Projects

 

VOC 

(tons/year) 

PM2.5 

(tons/year) 

PM10 

(tons/year) 

NOx 

(tons/year) 

SO2 

(tons/year) CO (tons/year) 

W&LE Railway 

Bridge (Kent, 

OH) - Lower 

Track 

0.37 1.87 Not Applicable 5.22 Not Applicable Not Applicable 

Main Street 

(Kent, OH) - 

Lower Track 

0.37 1.56 Not Applicable 5.22 Not Applicable Not Applicable 

Recreational 

Trail and 

W&LE Railway 

Bridge (Kent, 

OH) - Raise 

Bridge 

0.22 1.13 Not Applicable 3.06 Not Applicable Not Applicable 

NS Railroad 

Bridge 

(Ravenna, 

OH) 

0.25 1.23 Not Applicable 3.48 Not Applicable Not Applicable 

Pittsburgh, PA Non-Attainment Area 

Overhead 

Walkway 

(Coraopolis, 

PA) 

0.00 0.01 Not Applicable 0.01 Not Applicable Not Applicable 

Ohio Central 

Railroad 

(McKees 

Rocks, PA) 

0.30 6.27 Not Applicable 3.89 Not Applicable Not Applicable 

Chartiers 

Creek 

(Pittsburgh, 

PA) 

0.00 2.07 Not Applicable 0.01 Not Applicable Not Applicable 

Smithfield 

Street 

(Pittsburgh, 

PA) 

0.29 1.25 Not Applicable 4.00 Not Applicable 2.56 

J&L Tunnel 

(Pittsburgh, 

PA) 

4.36 18.54 Not Applicable 63.36 9.52 Not Applicable 

Walnut Street 0.26 0.19 0.26 3.63 Not Applicable Not Applicable 
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Table 4. General Conformity Analysis – Total Emissions for Projects

 

VOC 

(tons/year) 

PM2.5 

(tons/year) 

PM10 

(tons/year) 

NOx 

(tons/year) 

SO2 

(tons/year) CO (tons/year) 

(McKeesport, 

PA) 

General 

Conformity 

De Minimis 

Limits 100.0 100.0 100.0 100.0 100.0 100.0 

4.1.4.4 Conclusion 

The worst case for emissions is expected to be the first year of operation. The 

estimated releases of CO, PM10, PM2.5, NOx, SO2, and VOCs are given in 

Appendix J. These emissions are below the general conformity de minimis emissions 

levels; therefore, no further action is required. 

4.1.5 Noise and Vibration 

The proposed Phase I of the National Gateway Clearance Initiative does not include 

new track on a new track location; significant alterations to track alignment; or changes 

in vehicle speed. The proposed action will not cause an increase in rail noise levels 

because it will not provide additional mainline tracks on a new alignment; it will not 

change the maximum operating speed of the track; and it will not substantially change 

the shielding effects of the surrounding area. At two Pennsylvania obstructions, 26th

Street at the J&L Tunnel in Pittsburgh and Church Street (SR 2037) in Garrett, there 

will be minor changes to the alignment of the roadways. The elevation at Church 

Street will be raised by less than 3 feet, and 26th Street will be shifted to correct two 

skewed intersections with Tunnel Boulevard and South Water Street. There will be no 

changes to the roadway capacity. These minor changes in alignment do not meet 

FHWA’s Highway Traffic Noise Analysis and Abatement Policy and Guidance (1995) 

Type I, project criteria. Traffic noise levels should not change as a result of the 

proposed improvements at these roadway locations. The proposed action at J&L 

Tunnel and at Church Street will not move traffic closer to receptors and is capacity 

neutral (train or vehicular). 
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Vibration from freight trains 

is generally dominated by 

the diesel locomotive, which 

is the prevailing weight on 

most trains and considerably 

heavier than most of the 

rolling stock. For example, 

locomotives weigh 

approximately 200 tons 

while coal or hopper cars 

weigh 143 tons (73 percent 

of the weight of the 

locomotive). By comparison, container stack railcars weigh approximately 73-110 tons 

maximum or only 56 percent of the weight of a locomotive. Although double-stacked 

cars could contribute to adverse vibration impacts depending on the weight and 

loading of the shipments, they are not likely to result in higher vibration levels than the 

heavier diesel locomotive, or coal cars. The locomotive engine remains the prevailing 

weight car and highest vibration level on most trains. 

Other factors contributing to elevated vibration levels from freight train passbys, other 

than weight, include travel speed, stiffness of the suspension system, condition or 

trueness of the wheels, condition or type of rail, track type, and type of ground. Wellmaintained double-stacked cars typically result in lower vibration levels than other 

freight railcars as their construction includes softer suspensions that dampen the load 

(which is intended to minimize damage during transit). Double-stacked cars are 

typically grouped in pods of five railcars. They have a shorter wheel base than 

traditional railcars, resulting in lower vibration levels because of the dispersed load. 

Therefore, the potential vibration effects resulting from the introduction of doublestacked container cars along the existing corridor are minimal based their construction 

and on the lower weight of the container cars compared to other cars or the locomotive 

engine. 

 
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4.1.6 Solid and Hazardous Materials 

The vast majority of the individual improvements within the National Gateway 

Clearance Initiative are contained within the CSX ROW, and the ROW has been 

actively used for the movement of freight for decades. No other parties have 

participated or conducted business within the footprints of these proposed 

improvements without CSX’s knowledge. Land acquisition is required for the 

construction of the proposed action in a few individual locations. Site visits have been 

completed to conduct the level of due diligence that meets state guidance and industry 

standards for determining the potential solid and hazardous materials outside the 

current ROW limits. This includes searching state and federal databases for records of 

spills or sites with known contamination in the vicinity of individual obstructions. CSX 

spill records were reviewed from 1991 to the present date. There were no documented 

spills reported at any of the obstructions. 

Should solid and hazardous materials be encountered prior to or during the 

construction phase of the proposed action, any identified waste will be managed 

according to applicable federal, state, and local laws, ordinances, and regulations. 

Furthermore, any excess materials generated during the grading/cut activities that 

cannot be used within the current CSX-owned property will be managed appropriately 

in accordance with applicable federal, state, and local laws, ordinances, and 

regulations. Materials excavated during construction are expected to be considered 

nonhazardous. 

In Ohio, Environmental Site Assessment Screenings were completed in accordance 

with ODOT Office of Environmental Services (OES) Guidelines. Based on these 

assessments, no further environmental site assessments or special material 

management was warranted, except for Portage County, W&LE Railway Bridge, Kent 

and Abandoned Railroad Bridge/ ABCR Railway Railroad Bridge, and Kent Bridge 

Superstructure Raising. Both of these projects had stained soil. A Phase II 

Environmental Site Assessment, limited to soil characterization, will be conducted on 

the stained soils found in these projects prior to the project bid letting to determine if a 

plan note for special material management and proper disposal is required in the 

construction plans. In addition, W&LE Railway Bridge, BG118.20, Kent, Ohio will have 

a plan note for special management for contaminated groundwater that will be placed 
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in the construction plans since contaminated groundwater is located 5 feet below the 

surface and the project will lower the tracks 1.5 feet potentially encountering this 

contaminated water. 

No other obstruction locations requiring additional environmental due diligence were 

identified for the proposed action. 

4.1.7 Floodplains 

Based on a review of the National Flood Insurance Program Mapping, individual 

obstruction work locations have portions within the 100-year flood boundary. The 

majority of these proposed actions are track lowering or bridge modifications; no 

additional fill will be added to the floodplains, and the proposed action will not result in 

an adverse impact to the floodplains. No fill will be placed in the regulated floodway for 

any of the proposed actions, including the CSX-owned properties that will be used for 

the placement of material removed from the tunnel modifications. All fill will be placed 

at least 50 feet from the regulated flood way. 

4.1.8 Water Quality 

Wetlands and/or Waters of the United States have been qualitatively and quantitatively 

assessed in the field to determine location and proximity to the Phase I National 

Gateway Clearance Initiative work areas. If wetlands and waterways were identified in 

the proposed action area, the design was modified to the extent possible to avoid 

these resources. 

One proposed action in Phase I of the National Gateway Clearance Initiative, at CSX 

Railroad Bridge, Mexico, Maryland requires a U.S. ACE 404 permit, and corresponding 

401 Water Quality Certification from the State of Maryland, for impacts to wetlands 

and jurisdictional streams. It is expected that the proposed action will permanently 

impact approximately 0.26 acre of wetlands, temporarily impact 0.37 acre of wetlands, 

and affect 1.0 to 1.5 acres of wetland buffer. Engineering designs to minimize these 

impacts are ongoing. Coordination regarding potential mitigation for the impacts at 

CSX Railroad Bridge will be completed as part of the permitting process. There are no 

other impacts to streams or wetlands at any of the other proposed action locations. 
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For those proposed improvements requiring earth disturbance over 1 acre, a SWPPP 

will be implemented during construction to reduce the potential for erosion and 

sediment runoff during construction activities. Best management practices for erosion 

control during construction will be implemented at all sewer outlets to minimize 

pollutants entering waterways. The contractors shall follow stormwater best 

management practices in accordance with each state’s regulations (as noted in Ohio 

EPA Permit OHC0000003, Pennsylvania 25 State Code Chapter 102 & 102.1, 

Maryland Department of Environment [MDE] et al. 2009, MDE 1994, WVDEP 2006.). 

At all improvement locations requiring a SWPPP, an NPDES construction storm water 

permit, verified by each state’s environmental protection agency, will be included with 

the contract plans for adherence during construction. All conditions and terms 

associated with these permits will be fulfilled. 

4.1.9 Biological Resources 

Background state and federal databases listing threatened and endangered species 

have been reviewed to provide known inventories of protected populations. Field 

reconnaissance of the Phase I National Gateway Clearance Initiative corridor and 

specific improvement areas was completed by ARCADIS field biologists to determine if 

populations of protected species or suitable habitats are present and would possibly be 

affected by the proposed action. The proposed action is within the known range of the 

following federally listed species: Bald Eagle, Eastern Massasauga, Indiana bat, 

Mitchell’s satyr, Northern Monkshood, Northeastern bulrush, Sheepnose Mussel, and 

Harperella. There will be no impact to the federally listed species or their suitable 

habitat. 

In Ohio, there were no records for any of these species in ODNR’s Natural Heritage 

Database within 1 mile of any of the individual obstructions, or within the same 

township or cities (when within an incorporated area) of any of the obstructions. There 

will be no impact to these species or their suitable habitat. There will be no tree 

removal for the obstructions in Ohio. 

In Pennsylvania, Indiana bat suitable trees (living or standing dead trees or snags with 

exfoliating, peeling or loose bark, split trunks and/or branches, or cavities) have been 

identified in the proposed action area. Removal of these trees within the limits of 
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disturbance has been coordinated with the U.S. FWS, and completed in accordance 

with their guidelines. There will be no instream or wetland impacts in Pennsylvania. 

These stipulations are in accordance with correspondence received from the U.S. FWS 

Pennsylvania Field Office, dated March 4, 2010 and included in Appendix E. 

There were no records of threatened and endangered species or natural trout streams 

for any of the obstructions in West Virginia based on correspondence from the 

WVDNR, Wildlife Resource Section for any of the Phase I obstructions in West 

Virginia. In West Virginia, trees suitable for Indiana bat summering roosts have been 

identified in the proposed action area. Removal of these trees within the limits of 

disturbance has been coordinated with the U.S. FWS. This determination is in 

accordance with the correspondence received from the U.S. FWS West Virginia Field 

Office, dated April 20, 2010, which is included in Appendix F. 

According to the MDNR Wildlife and Heritage Service, there are no records for 

threatened or endangered species within or proximal to any of the obstructions. The 

U.S. FWS Chesapeake Bay Field Office determined no federally proposed or listed 

endangered or threatened species are within the Maryland obstruction areas, and no 

further consultation is required as documented in a letter dated October 27, 2009. 

Correspondence regarding protected species in Maryland is included in Appendix G. 

4.1.10 Visual and Aesthetics 

The degree to which proposed action area aesthetics and visual character may be 

impacted depends upon the specific activities being undertaken. There are six main 

types of activities associated with the Phase I National Gateway Clearance Initiative. 

These include removing bridges, raising bridges; modifying bridges, modifying tunnels, 

open cutting tunnels, and lowering track. A brief explanation of the visual and aesthetic 

impacts associated with each activity follows. 

Removing Bridges – There are several bridges within the Phase I corridor that no 

longer provide a useful function. The bridges are no longer used and are in poor 

condition. Such bridges will be removed. The removal of these structures will create a 

positive visual impact to the immediate area and the surrounding area’s aesthetics. 

None of the four bridges in the Phase I corridor proposed for removal are historic 
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resources; therefore, there will be no changes to the historic 

aesthetics of the obstruction’s surrounding area. 

Raising Bridges – Bridge raising involves elevating the existing 

bridge superstructure and adding structural members to the bridge 

substructures. The activities will not substantially change the 

structure, appearance, or location of the bridges. Therefore, no 

visual impacts will occur from these activities. The change to the 

structure’s aesthetics will be minor. During construction contractors 

will attempt to use materials that will blend with the existing structure. 

Modifying Bridges – Bridge modification involves the removal of an 

existing structure and construction of a new structure or 

modifications to existing structures that will remain in place. 

Modifications include removing and adding new wind bracing in 

different locations on undergrade truss bridges carrying CSX trains. 

Bridge replacements associated with the Phase I National Gateway 

Clearance Initiative will generally be done on the existing alignment 

and with similar structures. The bridges will be constructed to meet 

current engineering design and load standards. Because these 

activities will result in essentially the same view after completion, no 

visual or aesthetic impacts are expected. 

Modifying Tunnels – This activity involves portal or tunnel liner 

notching, widening the openings, removal of the existing tunnel 

liner and/or replacing the tunnel’s structural components (total arch 

liner replacement). While the majority of the work associated with 

these activities will be within the tunnels, one evident component, 

the portal, will be visibly changed. The tunnel portals are an 

aesthetic feature to the railroad and will be substantially changed 

by the work. The replacement portals will result in an impact to the 

visual and aesthetic character of the rail corridor. These activities 

are proposed in remote locations that are not viewable by the 

general public. There is very limited opportunity for these changes 

to have an effect on the public. 

Portal Notching 

Tunnel Notching 

Total Arch Liner Replacement 
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J&L Tunnel Open Space Area 

Open Cutting Tunnels – This activity involves removing the overburden from existing 

tunnels and removing all of the tunnel’s structural material, resulting in an open cut for 

the railroad to pass through. These project areas will experience a substantial change 

in the visual character. A corridor of vegetation will be removed from the slope above 

the existing tunnel, and the tunnel will no longer exist. Although open cutting will create 

a change in the visual character of the area, these activities are proposed in remote 

locations that are not viewable by the general public. There is very limited opportunity 

for these changes to have an effect on the public. 

Lowering track – This activity involves the removal of material (ballast, soil, and rock) 

beneath existing track to lower the elevation of the rails. Because the track remains in 

the existing location and there are limited structural changes, the visual character or 

aesthetics of the area does not change based on this activity. 

Overall, the Phase I National Gateway Clearance Initiative will create changes to the 

visual and aesthetic character of the rail corridor and surrounding area. Most 

improvements to aesthetics will occur in areas where the public will have an 

opportunity to realize the improvements. Conversely, the negative effects expected 

from certain activities will be in areas where the general public will not be affected by 

them. Photographs depicting example tunnel modifications are provided in Appendix K. 

4.1.11 Parks and Recreational Resources 

There will be no permanent impacts to parks or recreational 

resources. 

Portions of the proposed action are in the immediate vicinity of 

two bicycle/pedestrian paths (Kent Bike and Hike Path, Kent, 

Ohio and the Somerset County Rails to Trails Path Allegheny 

Highland Trail, Keystone Viaduct, Sand Patch, Pennsylvania) 

and a publicly owned area designated for open-space (Open 

Space over the J&L Tunnel, Pittsburgh, Pennsylvania). Impacts 

to the two bicycle/pedestrian paths and the publicly owned area 

designated for open space will be temporary in nature and of 

short duration. The resource will be fully restored at the 

completion of the proposed action, and these details been fully 
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coordinated with the officials with jurisdiction over each of the three resources. MOUs 

are being completed with the officials with jurisdiction. All stipulations agreed upon in 

the MOUs will be followed. Copies of the MOUs are provided in Appendix H. 

The City of Kent owns the bike path at Abandoned Railroad Bridge Superstructure 

Raising in Kent, Portage County, Ohio. The trail will be kept open during construction. 

Work will be minimal, with no permanent adverse physical impacts or interference with 

use of the trail, and the trail will be fully restored in accordance with the owner’s 

stipulations. 

The J&L Tunnel in Pittsburgh, Pennsylvania, is owned by CSX. The land over the J&L 

Tunnel is owned by the URA of Pittsburgh and is open space that the public are 

permitted to use for community events. The URA is a public entity organized under the 

Urban Redevelopment Law, 35 Pennsylvania Statutes 1701 et seq. The URA is a 

redevelopment organization. The land over the tunnel is open space that the public are 

permitted to use for community events. It has not been dedicated to the City of 

Pittsburgh as a public park, nor are there plans to do so. FHWA and FRA have 

concluded this open space is not a public park or recreation area under Section 4(f). 

An MOU between CSX and the URA is being completed regarding temporary impacts 

to the open space. The structure currently has an unknown load-bearing capacity over 

the tunnel. When the UR A has events on the open space over the tunnel, a section is 

cordoned off to protect the public. Upon completion of the proposed action, the entire 

open space will be available to the public, and larger events can be held. The open 

space will be unavailable to the public temporarily during construction. There will be no 

permanent adverse physical impacts. The area will be fully restored in accordance with 

the owner’s stipulations and replaced in kind or better at the end of construction. 

The Blue Lick Truss, Sand Patch, Pennsylvania is currently functioning as a 

bicycle/pedestrian bridge for the Somerset County rails to trails, and is part of the 

Potomac Heritage Trail Corridor. Coordination is ongoing with the county who owns 

the bike path. Based on Somerset County’s request, the path will be maintained and 

kept open during construction. Work will be minimal, with no permanent adverse 

physical impacts, or interference with use of the trail, and the trail will be fully restored 

in accordance with the owner’s stipulations. 
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Graham Tunnel, in the vicinity of Magnolia, West Virginia, runs through an unnamed 

hill in a peninsula of land bounded by the Potomac River. Graham Tunnel is located 

within the boundaries of the Maryland Green Ridge State Forest. It is also within the 

congressionally mandated boundary for the Chesapeake and Ohio Canal National 

Historical Park. However, according to CSX’s records and those previously obtained 

from Green Ridge State Forest, the tunnel and the land above it are wholly contained 

within CSX property. No impacts to the state forest are expected. There are no state 

forest recreation facilities in proximity to the tunnel. Figures depicting the tunnel 

location, the CSX ROW, and the Green Ridge State Forest facilities are included in 

Attachment 6 of Appendix G. In a letter dated January 25, 2010, Green Ridge State 

Forest was informed of the proposed action at Graham Tunnel (see letter in Appendix 

G). Green Ridge State Forest responded, via email, on July 12, 2010 and this 

correspondence is included in Attachment 6 of Appendix G. There are no recreational 

features on Green Ridge State Forest that are adjacent to Graham Tunnel that warrant 

protection under Section 4(f). It should also be noted that NPS stated in a meeting on 

May 24, 2010, with FRA/FHWA, that it has no official interests in Graham Tunnel. The 

May 24 meeting summary is included in Attachment 3 of Appendix G. 

4.1.12 Historic and Cultural Resource Coordination, Schedule and Process 

All public meetings and/or media advisories have solicited public comments regarding 

the presence of any known cultural resources in the vicinity of the undertaking, in 

compliance with Section 106 of the National Historic Preservation Act of 1966, as 

amended (codified as 36 Code of Federal Regulations 800). Furthermore, invitations 

were submitted to consulting parties that were identified by the SHPO (Appendix C). 

When consulting parties responded, those entities have been apprised of cultural 

resource coordination, including receiving copies of submitted reports. As consulting 

parties provide comment, the team is working through their concerns with the SHPOs. 

Coordination with Native American nations and tribes has been conducted as part of 

the Section 106 process. A list of nations and tribes contacted regarding the proposed 

action, as well as a summary of responses is included in Section 1.5, and the letter 

from FRA/FHWA is included in Appendix C. 

The FRA/FHWA has coordinated with the Advisory Council on Historic Preservation 

(ACHP) regarding the various Adverse Effects determinations and inviting them to 
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Kent Industrial Historic District

participate in the consultation. In a letter dated July 9, 2010, ACHP noted that their 

participation in the Section 106 process is not needed. This letter is included in 

Appendix C. 

An MOA is being developed with FRA/ FHWA, the four state SHPOs, the four state 

DOTs, and CSX. The MOA is included in Appendix C. Table 5 provides a summary of 

historic resources in each state, including their significance, effect determination, and 

impact to the resource. 

4.1.12.1 Ohio Projects 

Coordination has been conducted with the OHPO and ODOT-OES. The 

Portage Main Street obstruction is proximal to the NRHP boundaries of the 

Kent Industrial Historic District. No ROW within the NRHP boundary is 

required to facilitate the undertaking. Work will be temporary in nature and 

will not result in the removal or alteration of contributing features or 

elements. The OHPO concurred Kent Industrial Historic District will not be 

adversely affected by the undertaking. However, the OHPO will be 

provided an opportunity to review and comment on detailed design for the 

project once available. 

ODOT submitted a letter to the OHPO on September 29, 2009, requesting 

concurrence with their determination of effects under Section 106 for the 

proposed action. OHPO agreed with their findings on October 5, 2009. 

Completion of the track lowerings, two bridge raisings, and bridge removal 

will have No Adverse Effect to NRHP eligible resources, districts, or 

archeological sites. No further mitigation or coordination is required. 

4.1.12.2 Pennsylvania 

Coordination has been conducted with PHMC. An Eligibility Report and 

Effects Report have been completed and concurred with by the PHMC. 

PHMC required that the historic resources be evaluated on a corridor 

basis. Two historic corridors are included in the proposed action corridor, 

the former P&LE and B&O railroads. Both historic corridors will be preserved as a 

result of the proposed action. A total of eight contributing resources are within the 

Kent W&LE Bridge Track Lowering 

Grade Adjustment 
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Pinkerton Tunnel 

Stuart Tunnel View from East Portal 

P&LE corridor, and nine contributing resources are within the B&O corridor. It was 

determined that there will be no Adverse Effect to the P&LE corridor. There is an 

Adverse Effect to the B&O corridor. The Adverse Effect is the result of the impact 

to the six tunnels within the B&O corridor. 

Several meetings with PHMC have been conducted since the determination of 

Adverse Effect to discuss mitigation activities. Mitigation has been agreed to and 

will include salvaging the name and date plaques where possible, recordation of all 

contributing resources, and developing a web-based public outreach program. 

Additionally, archaeological investigations were conducted at all locations where 

earth disturbance is expected. These obstruction locations primarily include the 

open cut tunnel locations and excess material placement areas. Background 

research and field investigations were conducted. Based on the studies completed, 

impacts to archaeological resources are not expected. Coordination of these efforts 

has been conducted with PHMC, and a report has been submitted for their 

records. 

4.1.12.3 West Virginia 

Coordination has been conducted with WVDCH. An Eligibility Report and 

Effects Report have been completed and concurred with by WVDCH. 

WVDCH required that the Magnolia Cutoff, which includes Carothers, 

Stuart, and Randolph tunnels, be evaluated on a corridor basis. While the 

Magnolia Cutoff will be preserved an Adverse Effect determination was 

made for the Magnolia Cutoff based on impacts to the three tunnels. 

In their Effects concurrence letter, WVDCH outlined its intentions for 

mitigation of adverse effects. These include recordation of the tunnels and 

a public outreach program. Coordination is underway to discuss and refine 

the mitigation commitments. 

No archaeological studies were required for the undertakings within West Virginia as 

construction activities are confined to the tunnel locations and the excess material 

placement areas where material from the West Virginia tunnels, as well as, Graham 

Tunnel in Maryland will be placed. WVDCH did comment that archaeology studies may 
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be required for the excess material placement areas. These areas are located in 

previously disturbed areas that were used for railroad activities, and no further studies 

are required. Documentation of these conditions is included in Appendix F. 

4.1.12.4 Maryland 

MHT required historic resources be evaluated on a per project basis. Two locations are 

included in Phase I, Graham Tunnel and Mexico Bridge. An Eligibility Report including 

these obstructions has been submitted and concurred with by MHT. Graham Tunnel is 

eligible for inclusion on the NRHP, and the Mexico Bridge is not eligible. MHT 

concurred with an Adverse Effect recommendation for Graham Tunnel. MHT’s 

concurrence is documented in a letter dated June 15, 2010, in which MHT continued 

its coordination for mitigation of adverse effects and commented on the MOA. 

Phase IA archaeological investigations, including background research and site 

walkovers, were conducted for the Mexico Bridge Siding. The areas have been found 

to be previously disturbed by railroad activities and industrial development, and 

therefore, it is recommended that no further archaeological studies are needed. 

Documentation for these activities is included in the Maryland Effects Report. 

4.1.13 Section 4(f) Analysis Schedule and Process 

The Net Benefit Programmatic Section 4(f) Evaluation has been prepared for the 

Phase I corridor for the Adverse Effects to the B&O Railroad Pittsburgh Division and 

the B&O Railroad Magnolia Cutoff, with input from the FRA/ FHWA and the states. 

The Section 4(f) Evaluation is included as Section 5 of this Environmental Assessment. 

4.1.14 Indirect and Cumulative Effects 

Indirect Impacts are caused by an action later in time or farther removed in distance 

but are still reasonably foreseeable. Indirect impacts may include growth-inducing 

effects and other effects related to induced changes in the patterns of land use, 

population density or growth rate, and related effects on air and water and other natural 

systems, including ecosystems [40 CFR 1508.8(b)]. 
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The purpose of the Phase I National Gateway Clearance Initiative is to allow the use of 

double-stacked containers, thereby increasing the capacity of the existing rail corridor. 

Because the proposed action will utilize existing rail corridors, no corridor-wide 

changes to land use or development patterns will be created. Between the logical 

termini of the proposed action, no changes to rail access or support facilities are 

expected. Therefore, the proposed action is not expected to induce any indirect 

impacts to traffic flow or populations. 

The logical termini for the proposed action include intermodal facilities in Northwest 

Ohio and Central Pennsylvania. The existing facilities are not solely associated with the 

Phase I National Gateway Clearance Initiative and serve the CSX rail system as a 

whole. Therefore, they are not considered indirect impacts of this project. 

The Phase I National Gateway Clearance Initiative will create changes to both local 

and regional traffic patterns. The increased capacity of existing trains will have a 

positive effect on regional traffic by reducing long-haul trucking along routes served by 

the rail corridor. Although localized traffic at the intermodal facility locations will change, 

as a result of the projected increase in domestic and international freight traffic, these 

changes would occur whether the Phase I National Gateway Clearance Initiative is 

completed or not. Local traffic at these locations is influenced by the interaction of the 

overall rail system, as well as other unrelated local conditions. These traffic changes 

are addressed through the existing transportation programs of the local and state 

governments. 

Cumulative Impacts are defined as impacts on the environment that result from the 

incremental impact of the action when added to past, present, and reasonably 

foreseeable future actions, regardless of what agency (federal or non-federal) or 

person undertakes such actions (40 CFR 1508.7). 

In beginning the evaluation of potential cumulative impacts, it is necessary to define 

project related impacts that are at a level that have the potential to contribute to a 

cumulative impact. Three main categories of impacts are considered for this evaluation 

including natural resources, social resources, and cultural resources. 

Because the limit of disturbance for the proposed action is largely located within the 

existing disturbed rail corridor, natural resource impacts are not extensive. Additionally, 
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the majority of Phase I of the National Gateway Clearance Initiative runs through a 

rural and often remote corridor. Therefore, the Phase I National Gateway Clearance 

Initiative is not expected to have cumulative impacts to natural resources. 

Social resources include items such as land use, transportation systems, and 

community facilities. The Phase I National Gateway Clearance Initiative is being 

completed on an existing rail corridor, and no long-term impacts are expected to any 

social resources. Short-term changes to traffic patterns during construction may occur 

but will not be permanent. The rural and remote natures of most obstructions preclude 

any widespread impacts to these resources by other unrelated activities. 

Cultural resources are those resources governed by Section 106 and include 

archaeological and historic structures. As presently proposed, the Phase I National 

Gateway Clearance Initiative will not impact any archaeological resources and 

therefore will not have a cumulative impact on them. Completion of the proposed 

action will allow the historic rail corridors to be preserved. If the railroad is prevented 

from taking actions that preserve its competitiveness and economic stability through 

increases in efficiency and reductions in chokepoint delays, the railroad’s long term 

economic viability will be impaired and its ability to sustain itself for the next millennium 

will be highly unlikely. The loss of freight train service along the historic rail corridors 

would be the loss of an icon in the American story since its integrity lies in the railroad’s 

location, feeling and associations which are rooted in this portion of the American 

landscape. 

Construction of a new intermodal terminal is planned for the Pittsburgh, Pennsylvania 

area and CSX is privately funding the construction of the terminal. The intermodal 

terminal will complement the existing National Gateway corridor and will not be 

constructed until after completion of the clearance projects. This facility will be 

constructed in accordance with all applicable permit requirements. 
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4.1.15 Public Involvement 

Public meetings and outreach have been coordinated 

through the state DOTs following their suggested 

guidance. Public feedback comments related to the 

Phase I National Gateway Clearance Initiative 

proposed action have been addressed to the fullest 

extent. The meetings were open house in nature. At 

each public meeting, posters depicting the National 

Gateway Clearance Initiative corridor were 

presented. Posters depicting the individual obstructions were also displayed. This 

allowed attendees to view clearance improvements in their area, relative to the larger 

National Gateway Clearance Initiative. CSX and its consultants were available to 

address attendee questions and concerns. 

4.1.15.1 Ohio 

In Ohio, a meeting was held for the ODOT District 4 projects that include all of the Ohio 

Federally Funded projects. The meeting was held on August 19, 2009, at 

Northeastern Ohio University’s College of Medicine and Pharmacy’s campus in 

Rootstown. A media advisory was submitted to nine print and eight television contacts 

in the area. Notification letters (105) were sent to local property owners; residents; 

interested parties; and local, county, state, and federal officials. The letter notified the 

recipient of the date, time, and location of the meeting, as well as solicited feedback for 

interested consulting parties under Section 106. The format of the meeting was an 

informal open house, and the room was arranged by county, with information on each 

of the obstructions. Handouts were prepared providing obstruction information. Over 

ten representatives from ODOT, CSX, and consulting firms were present to address 

questions on a one-on-one basis. A total of 12 attendees participated in the meeting. 

Three public comments, related to the proposed action moving forward under the 

TIGER award, were received. One was a positive statement. The second comment 

was from the City of Kent related to its bike and hike trail at location BG 115.80 

Abandoned Railroad structure. This comment led to the development of the MOU with 

the City of Kent for this resource. The third comment in reference to drainage in the 

vicinity of POR - NS Railroad Bridge, Ravenna, BG 110.80. Two additional comments 
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were received for one ARRA funded project; these comments were addressed 

separately. Copies of the comments, and comment responses made by CSX are 

provided in Attachment 14 of Appendix D. 

4.1.15.2 Pennsylvania 

Two open houses were completed in Pennsylvania, in Pittsburgh and Somerset on 

February 25, and March 9, 2010, respectively. A media advisory was submitted to 18 

print contacts in the area. Notification letters were sent to local interested parties and 

local, county, state, and federal officials. The letter notified the recipient of the date, 

time, and location of the meeting, as well as solicited feedback for interested consulting 

parties under Section 106. The format of the meeting was an informal open house, 

and the room was arranged by county, with information on each of the obstructions. 

Handouts were prepared providing obstruction information. Over seven 

representatives from CSX and consulting firms were present to address questions on a 

one-on-one basis. A total of 21 participants attended the meeting in Pittsburgh, many 

of whom were representing construction firms interested in the work. One public 

comment, exclusive of requests to bid on the projects, was received. This comment 

was a suggestion for additional parking in the area of J&L Tunnel. A total of 31 

attended the Somerset meeting. Three public comments, exclusive of requests to bid 

on the projects, were received. Two comments pertained to maintaining the Great 

Allegheny Passage, including keeping it open during construction of the Blue Lick 

Truss bridge raising. One of these comments was received from Ms. Linda Boxx, 

President of the Allegheny Trail Alliance, who maintains the Greater Allegheny 

Passage in the area. The third comment was for a company’s product that relates to 

intermodal freight transport. Copies of the public comments, and responses made are 

provided as Attachment 14 of Appendix E. 

4.1.15.3 West Virginia 

Media releases and social advertisements were posted in the Martinsburg, West 

Virginia Journal requesting comments on the three tunnels and the interlocking on 

December 23 and 24, 2009. No comments were received. 
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4.1.15.4 Maryland 

A public meeting was held in Harpers Ferry, West Virginia on March 3, 2010, to 

discuss the proposed modifications to four tunnels in Maryland: Graham, Harpers 

Ferry, Catoctin, and Point-of-Rocks tunnels. Harpers Ferry, Catoctin, and Point-ofRocks tunnels are not part of Phase I. Citizens were invited to participate through a 

social advertisement and media release in the Martinsburg, West Virginia Journal and 

the Fredrick, Maryland Frederick News-Post on February 17, 2010. The meeting 

format was open house, allowing the approximately 20 participants to learn about the 

proposed action through displays, handouts, and agency and railroad representatives. 

Participants were also asked to provide comments about the proposed action. Four 

comments were received; none were specific to Graham Tunnel. 

A public notice was published on May 24, 2010 in local newspapers to notify local 

stakeholders about the improvements proposed at CSX Railroad Bridge in Mexico 

Farms and to solicit comments. One comment was received which mentioned the 

potential historic nature of the bridge. As noted previously, MHT concurred in a letter 

dated June 15, 2010 that the Railroad Bridge at Mexico Farms is not eligible for 

inclusion on the NRHP. 

4.2 State-by-State Component Impacts and Mitigation 

The assessment of the individual obstructions, the proposed action, required 

coordination, and permits for Phase I of the National Gateway Clearance Initiative 

funded by the TIGER grant, Commonwealth of Pennsylvania TAP, or CSX capital 

funds are discussed in the individual State documents provided as Appendices D 

through G of this report. 

4.3 Ohio Separately Funded Projects 

To obtain the vertical clearance required to allow use of double-stacked trains through 

Ohio, seven bridges will be replaced; four will be removed; two bridges will be raised; 

five track lowerings will be completed; and two interlockings will be constructed (total of 

18 obstructions, plus two interlockings). Ten of the clearance projects in Ohio have 

been separately advanced to replace or remove structurally deficient bridges and are 

described below. 
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4.3.1 Ohio State Funded Projects 

Of these projects, four locations are being implemented by ODOT and CSX to move 

forward under a $10 million state allocation funded by Ohio Department of 

Development. These clearance improvement actions have been permitted in 

accordance with state and federal requirements and will include the following: 

Sullivan Ashland County, TR391, Bridge Replacement 

Sullivan, Ashland County, TR150, Bridge Removal 

Pawnee, Medina County, River Corners Road, Bridge Replacement 

Pawnee, Medina County, Pawnee Road, Bridge Removal 

4.3.2 Ohio American Recovery and Reinvestment Act Funded Projects 

Six of the obstructions and two interlockings have received a $20 million commitment 

of Ohio ARRA funds for the double-stacked rail clearance proposed action. These 

projects were separately approved as Categorical Exclusions (some included 

Programmatic Section 4(f) determinations by FHWA) in accordance with the 

Programmatic Categorical Exclusion Agreement between ODOT 

and FHWA on December 10, 2009, and include the following: 

Creston, Medina County, Mud Lake Road, Bridge Replacement 

Akron, Summit County, Park Street, Bridge Removal 

Kent, Portage County, Complete Interlocking, Construct Interlocking 

Ravenna, Portage County, Knapp Road Bridge Replacement 

Newton Falls, Portage County, Rock Spring Road, Bridge 

Replacement 

Newton Falls, Portage County, Upgrade Interlocking 

Niles, Trumbull County, Fifth Street Bridge Replacement 

The Crain Avenue Bridge in Kent, Portage County, Ohio, (Project 

Identification 18466) is an ODOT-led project with a Categorical 

Exclusion approved by the FHWA on June 5, 2007, currently under construction. 

Copies of the approved NEPA documentation for the ARRA-funded projects and Crain 

Avenue are provided as Appendix A. 

Fifth Street Bridge, Eligible to the NRHP 
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Kent Hike and Bike Trail Bridge Raising 

5. Net Benefits Programmatic Section 4(f) Evaluation 

5.1 Introduction 

Section 4(f) of the Department of Transportation Act of 1966, as amended, stipulates 

that the U.S. DOT shall not approve the use of any publicly owned land from a public 

park, recreation area or wildlife or waterfowl refuge of national, State or local 

significance, or land from a historic site of national, State or local significance unless 

there is no feasible and prudent alternative to the use of the land and all possible 

planning to minimize harm resulting from such use is included. Coordination with the 

officials having jurisdiction over the resource has been initiated and will be ongoing 

through the duration of the proposed action. The FRA/FHWA will make the final 4(f) 

determination of use for all eligible resources. 

There are two Section 4(f) resource types in Phase I of the National Gateway 

Clearance Initiative corridor; 1) Recreational trails, and 2) Historic properties. 

Following is a discussion of Section 4(f) resources associated with Phase I of the 

National Gateway Clearance Initiative. 

5.1.1 Recreational Trails 

Two proposed actions are in the 

immediate vicinity of two 

bicycle/pedestrian paths: The Kent 

Hike and Bike Path, Kent, Ohio and 

the Somerset County Rails to Trails 

Path, Sand Patch, Pennsylvania. 

These two resources qualify for 

consideration under Section 4(f) as 

a publicly-owned, public park and/or 

recreation area of local and national 

significance, respectively. Impacts 

to the two bicycle/pedestrian paths 

will be temporary and of short 

duration, the resource will be fully restored at completion of the project and these 

stipulations have been fully coordinated with the officials having jurisdiction over each 
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of the resources. The MOUs with each of the two public agencies with jurisdiction for 

these two resources are included in Appendix H. 

The Kent Hike and Bike Path is a 9.8 mile long, east-west, multi-use trail connecting 

the towns of Kent and Ravenna, Ohio. The Kent Hike and Bike is a rails to trails 

conversion and consists of an approximately 8-foot wide trail of primarily smooth 

crushed gravel and/or, as at the proposed action, asphalt. Northeast of Kent, Ohio, the 

trail crosses over the CSX mainline tracks by utilizing one bay of the 5-bay W&LE 

Railway bridge. The W&LE operating their Akron Barberton Cluster Railroad utilizes 

one bay, the Kent Hike and Bike utilizes one bay and the other three bays carry no rail 

or other traffic. The proposed action will elevate the two actively utilized bridge bays 

and remove the remaining three unused bays. Specifically in regards to the Kent Hike 

and Bike, a temporary run-around trail will be located approximately 34 feet south of 

and parallel to the existing trail and will utilize one of the adjacent unutilized bays to 

cross over the CSX mainline tracks. Approximately 750 feet of the trail will be closed 

and relocated to the temporary trail. An additional 133 feet of the spur extending to 

River Bend Boulevard will also be closed while that portion of the trail is re-built. The 

temporary trail will consist of aggregate or other material. The existing trail bridge will 

be raised approximately 1.78 feet and repairs will be made to the abutments. 

Restoration of the existing trail will consist of removal of the asphalt, regrading, 

placement of the asphalt overlay and grading of the adjoining fill slopes. The turf 

shoulders adjacent to the trail will be seeded and mulched. If limited woody vegetation 

removal is required the area will be replanted in kind. Construction activities are 

estimated to last 10 to 12 weeks but the temporary trail will only be required for 6 to 8 

weeks. The temporary detour of the trail and the reconstruction has been coordinated 

with the City of Kent, the owner of this section of the trail. 

The Blue Lick Truss is located in Somerset County, Pennsylvania. The truss and 

associated Keystone Viaduct, carry the Great Allegheny Passage, a 150-mile system 

of biking and hiking trails that connect Cumberland, Maryland and Pittsburgh, 

Pennsylvania, over the Flaugherty Creek and the CSX mainline. The Great Allegheny 
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Passage is one segment of the larger Potomac Heritage National Scenic Trail. 

Coordination with the NPS has been initiated and will be ongoing through the duration 

of the proposed action. 

The Great Allegheny Passage is a rails to trails conversion and consists of an 

approximately 10-foot wide trail of primarily smooth crushed gravel. The Blue Lick 

Truss and Keystone Viaduct have been refurbished for the multi-use trail and support 

an approximately 10-foot wide concrete path. The northern end of the truss terminates 

at an approximately 15-foot by 30-foot fenced landing that adjoins the gravel hiking 

trail. The southern end of the truss is connected to the Keystone Viaduct. The 

proposed action will elevate the Blue Lick Truss approximately 12 inches to provide 

sufficient vertical clearance for double-stacked intermodal freight trains. Construction 

work to elevate the Blue Lick Truss will be conducted primarily underneath the truss 

from the CSX ROW. The construction will be completed in roughly five phases: 

• Phase 1 will consist of preliminary construction work to release the bridge from its 

abutments and to install the temporary hydraulic jacks that will be utilized to raise 

the bridge. This phase of the work will be completed primarily from the CSX ROW 

beneath the bridge. 

• Phase 2 will consist of closing one-half of the 10-foot 

wide multi-use trail (Side A). Construction fencing 

will be utilized to direct all trail traffic to the open side 

of the bridge (Side B). The trail will be signed to 

direct all bikers to dismount and walk their bikes 

through the construction zone. New concrete 

ramps, to the higher bridge elevation, will be 

constructed on the closed half of the trail (Side A). 

• Phase 3 will consist of raising the bridge. It is 

anticipated that one overnight closure of the trail will 

be needed to jack the truss the necessary 12 

inches. Once the bridge is at the higher elevation, 

bolsters will be placed at the top of the abutments 

and the bridge will be lowered and reattached. 
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• Phase 4 will consist of switching the open and 

closed side of the multi-use trail. Side A, with the 

new ramps at the higher elevation, will be opened 

and Side B will now be closed. Again, construction 

fencing will be utilized to direct all trail traffic to the 

open side of the bridge (Side A). The trail will be 

signed to direct all bikers to dismount and walk their 

bikes through the construction zone. New concrete 

ramps will be constructed on the now closed side of 

the trail (Side B). 

• Phase 5 will consist of completion of construction 

and opening of the full width of the trail over the 

bridge. 

The landing on the north end of the truss will also be renovated to meet the new 

elevation of the truss. The new ramps and landing will be constructed from concrete 

and the red coloring will match the existing concrete of the truss and viaduct trail. 

Construction activities are estimated to last 10 to 12 weeks but that the temporary trail 

constriction will be required for less than one month. It is anticipated that one overnight 

closure of the trail will be needed to jack the truss the necessary 12 inches. The 

closure and temporary constriction have been coordinated with Somerset County, the 

owner of this section of the trail. 

Impacts to the two bicycle/pedestrian paths will be temporary and of short duration, the 

resources will be fully restored at completion of the project and these stipulations have 

been fully coordinated with the officials having jurisdiction over each of the two 

resources. The FRA/FHWA will make the final determination of use under Section 4(f) 

the Department of Transportation Act of 1966, as amended. As such there is no use of 

these resources under Section 4(f) the Department of Transportation Act of 1966, as 

amended. The MOUs with the public agencies having jurisdiction over these resources 

are included in Appendix H. The MOU with Somerset County has been submitted and 

is awaiting final signatures. 
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5.1.2 Historic Sites 

Portions of the National Gateway Clearance Initiative – 

Phase I proposed action include three historic railroad 

corridors, which have been determined to be historic sites of 

national and State significance: P&LE Railroad, 

Pennsylvania; B&O Railroad Pittsburgh Division, 

Pennsylvania; and, B&O Railroad Magnolia Cutoff, West 

Virginia and Maryland; and are in the immediate vicinity of 

three historic bridges of national significance: Smithfield 

Street Bridge (National Engineering Landmark), Pittsburgh, 

Pennsylvania; Walnut Street (SR 0048) Bridge (Boston 

Bridge), McKeesport, Pennsylvania; and Blue Lick Truss, 

Sand Patch, Pennsylvania. 

The Pittsburgh & Lake Erie Railroad stretched from Hazelton, 

Ohio, at its northwest end to 24th Street in Pittsburgh, 

Pennsylvania at its southeast end. The Pittsburgh, 

McKeesport & Youghiogheny Railroad extended the line 

southeast from the terminus of the original main line at 24th 

Street in Pittsburgh to Connellsville, Pennsylvania. These 

two sections form the historic P&LE Railroad corridor. The 

entire alignment is currently owned and operated by CSX. 

The following contributing resources to the P&LE Railroad 

are in the immediate vicinity of or will be improved by the 

proposed action: Chartiers Creek Bridge, Pittsburgh & Lake 

Erie Station, and J&L Tunnel all located in Pittsburgh, 

Pennsylvania. These resources all qualify for consideration 

under Section 4(f) as significant historic sites as they are 

either on, or have been determined eligible for, the NRHP. 

Through coordination with the Pennsylvania SHPO (PHMC) and design modifications, 

it has been determined that there will be no adverse affects by the proposed action on 

the P&LE Railroad including elements such as the railroad’s vertical and horizontal 

alignment, tunnels and bridges, signal equipment, rock and slide fencing, drainage, 

stations/stops, cut and fill slopes, sidings, switches, right of way/ownership limits, 

Smithfield Street Grade Adjustment 

Chartiers Creek Bridge Modification 
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vegetation; as well as the noted contributing resources: Chartiers Creek Bridge, 

Pittsburgh & Lake Erie Station, and J&L Tunnel. 

The B&O Railroad Pittsburgh Division stretches from McKeesport, Pennsylvania to 

Cumberland, Maryland. This historic railroad corridor includes the following 

contributing resources Wills Creek Bridge at Hyndman, six tunnels in Somerset County 

and the two unnamed bridges over Wills Creek which are the approaches to Falls Cut 

Tunnel. These contributing resources are either in the immediate vicinity of or will be 

improved by the proposed action. Due to proposed vertical clearance improvements at 

the six tunnels in Somerset County, the PHMC determined that there would be an 

adverse effect by the proposed action on the B&O Railroad Pittsburgh Division. The 

proposed alterations to these contributing resources constitute a ‘use’ by the proposed 

action under Section 4(f) the Department of Transportation Act of 1966, as amended. 

The Wills Creek Bridge at Hyndman, Pennsylvania is a contributing resource and is 

also vertical clearance obstructions for double- stacked, intermodal, freight cars. 

Through coordination with the PHMC and design modifications, improvements to the 

superstructure of this historical bridge will not adversely impact this contributing 

resource. There will be no impacts to, therefore no effects on many of the other B&O 

Railroad Pittsburgh Division elements such as the two unnamed bridges over Wills 

Creek which are the approaches to Falls Cut Tunnel and the railroad’s vertical and 

horizontal alignment, various unnamed bridges, signal equipment, rock and slide 

fencing, drainage, stations/stops, cut and fill slopes, sidings, switches, right of 

way/ownership limits, and vegetation. 

The B&O Railroad Magnolia Cutoff is a historic, twelve-mile-long, double-track 

extending southwest from Orleans Crossroads in Morgan County, West Virginia to 

Okonoko in Hampshire County, West Virginia, passing through Allegany County, 

Maryland along the way. The Cutoff includes four tunnels (Carothers, Graham, Stuart 

and Randolph), a long cut at Doe Gully, two bridges over the Potomac (Kessler and 

Magnolia bridges), and a concrete retaining wall west of Paw Paw, all of which are 

contributing resources. Due to the proposed vertical clearance improvements at the 

four tunnels it was determined that there would be an adverse effect by the proposed 

action on the B&O Railroad Magnolia Cutoff. The proposed alterations to these 

contributing resources constitute a ‘use’ by the proposed action under Section 4(f) the 

Department of Transportation Act of 1966, as amended. The proposed action will have 

no impact on, therefore will not affect the Kessler or Magnolia bridges, the long cut at 
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Doe Gully or the concrete retaining wall west of Paw Paw and the railroad’s vertical 

and horizontal alignment, various unnamed bridges, signal equipment, rock and slide 

fencing, drainage, stations/stops, cut and fill slopes, sidings, switches, right of 

way/ownership limits, and vegetation. 

The Smithfield Street Bridge in Pittsburgh, Pennsylvania and the Walnut Street Bridge 

in McKeesport, Pennsylvania are historic bridges of national significance. The CSX 

mainline tracks underneath each of these historic bridges will be lowered as part of the 

proposed action. Through coordination with the PHMC and design modifications, it 

has been determined that there will be no adverse affects by the proposed action on 

the Smithfield Street Bridge or the Walnut Street Bridge, nor will any property within a 

historic boundary be acquired. As such there is no ‘use’ by the proposed action of the 

Walnut Street Bridge or the Smithfield Street Bridge under Section 4(f). 

The Blue Lick Truss is a 

historic bridge of national 

significance located in 

Somerset County, 

Pennsylvania. This bridge 

will be raised approximately 

12 inches as part of the 

proposed action, as 

described previously. 

Through coordination with 

the PHMC and design 

modifications, it has been 

determined that there will be 

no adverse affects by the 

proposed action on the Blue Lick Truss nor will any property within a historic boundary 

be acquired. As such there is no ‘use’ by the proposed action of the Blue Lick Truss, 

as a historic resource, under Section 4(f). 

Figure 2 depicts the Phase I corridor and the 30 proposed clearance locations, and 

Figures 3 and 4 depict the two B&O railroad corridors. The P&LE corridor is depicted 

as Figure 5. 

Blue Lick Truss Trail Entrance 
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5.1.3 Applicability of the Net Benefits Section 4(f) Programmatic 

The Net Benefit 4(f) Programmatic has been prepared by the U.S. DOT for federally 

funded transportation projects, which in the view of the Administration and official(s) 

with jurisdiction over the Section 4(f) property, the use of the Section 4(f) property will 

result in a net benefit to the Section 4(f) property. In order to satisfy these criteria the 

following requirements must be met: 

1. The proposed transportation project uses a Section 4(f) park, recreation area, 

wildlife or waterfowl refuge, or historic site. 

2. The proposed project includes all appropriate measures to minimize harm and 

subsequent mitigation necessary to preserve and enhance those features and 

values of the property that originally qualified the property for Section 4(f) 

protection. 

3. For historic properties, the project does not require the major alteration of the 

characteristics that qualify the property for the NRHP such that the property 

would no longer retain sufficient integrity to be considered eligible for the listing. 

For archaeological properties, the project does not require the disturbance or 

removal of the archeological resources that have been determined important for 

the preservation in-place rather than for the information that can be obtained 

through data recovery. The determination of a major alteration or the importance 

to preserve in-place will be based on consultation consistent with 36 CFR Part 

800. 

4. For historic properties, consistent with 36 CFR Part 800, there must be 

agreement reached amongst the SHPO and or Tribal Historic Preservation 

Officer, as appropriate, the FHWA and the Applicant on Measures to minimize 

harm when there is a use of Section 4(f) property. 

5. The officials with jurisdiction over the Section 4(f) property agree in writing with 

the assessment of the impacts; the proposed measures to minimize harm; and 

the mitigation necessary to preserve, rehabilitate and enhance those features 

and values of the Section 4(f) property; and that such measures will result in a 

net benefit to the Section 4(f) property. 
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6. The Administration determines that the project facts match those set forth in the 

Applicability, Alternatives, Findings, Mitigation and Measures to Minimize Harm, 

Coordination and Public Involvement sections of this programmatic agreement. 

Any project that satisfies these criteria may make use of the Net Benefits 4(f) 

Programmatic and will not require an Individual Section 4(f) Evaluation, regardless of 

class of action under NEPA. 

5.1.4 Summary 

This Net Benefits Programmatic Section 4(f) Evaluation will focus on the National 

Gateway Clearance Initiative – Phase I proposed action, the use of the B&O Pittsburgh 

Division and B&O Magnolia Cutoff which are two historic, 4(f) resources and the net 

benefit to historic rail corridors from implementation of the proposed action. A “net 

benefit” is achieved when the transportation use, the measures to minimize harm, and 

the mitigation incorporated into the project results in an overall enhancement of the 

Section 4(f) property when compared to both the future do-nothing or avoidance 

alternatives and the present condition of the Section 4(f) property, considering the 

activities, features, and attributes that qualify the property for Section 4(f) protection. 

This is in accordance with the criteria set forth in the Final Nationwide Programmatic 

Section 4(f) Evaluation and Determination for Federal-Aid Transportation Projects That 

Have a Net Benefit to a Section 4(f) Property issued April 20, 2005 (75 FR 20618-

20630). 

5.2 Summary of Affected Section 4(f) Resources 

5.2.1 Introduction 

Two railroad corridors along the Phase I route, the former B&O Railroad Pittsburgh 

Division in Pennsylvania and the B&O Railroad Magnolia Cutoff in West Virginia and 

Maryland have been identified as eligible for the NRHP. Within these two historic 

railroad corridors are ten tunnels, which are contributing resources to these two historic 

railroad corridors and which are also vertical clearance obstructions for doublestacked, intermodal, freight cars. During coordination for this undertaking with the 

respective SHPOs, it has been determined that both of these historical resources will 

be adversely effected by the proposed action due to proposed improvements at these 
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corridors’ tunnels. Both of these former B&O Railroad corridors are currently owned by 

CSX. 

There are six tunnels on the B&O Railroad Pittsburgh Division. From west to east, the 

tunnels are: 

Benford Tunnel, Confluence, Somerset County, Pennsylvania 

Brook Tunnel, Confluence, Somerset County, Pennsylvania 

Shoo Fly Tunnel, Confluence, Somerset County, Pennsylvania 

Pinkerton Tunnel, Pinkerton, Somerset County, Pennsylvania 

Sand Patch Tunnel, Sand Patch, Somerset County, Pennsylvania 

Falls Cut Tunnel, Fairhope, Somerset County, Pennsylvania 

There are four tunnels on the B&O Railroad Magnolia Cutoff. From west to east, the 

tunnels are: 

Carothers Tunnel, Paw Paw, Morgan County, West Virginia 

Graham Tunnel, in the vicinity of Magnolia WV, Allegany County, Maryland 

Stuart Tunnel, Hansrote, Morgan County, West Virginia 

Randolph Tunnel, Hansrote, Morgan County, West Virginia 

As noted previously, the clearance locations are depicted in Figure 2. Additionally, 

Attachments 1 and 2 within Appendices E, F, and G (Documentation for Pennsylvania, 

West Virginia and Maryland, respectively) include maps of the tunnel locations on a 

smaller scale and each the project’s limits of disturbance (LODs), respectively. 

Correspondence from the PHMC is included in Attachment 12 of Appendix E. 

Correspondence from the WVDCH is included as Attachment 3 of Appendix F. 

Correspondence from the MHT is included as Attachment 3 of Appendix G. 

5.2.2 Rail Corridor History 

5.2.2.1 B&O Railroad 

The following discussions and descriptions of the B&O Railroad Pittsburgh Division 

and the Magnolia Cutoff are primarily from the eligibility determination forms completed 
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by A.D. Marble & Company for those two resources and submitted to the Pennsylvania 

and West Virginia SHPOs, respectively. 

In the 1820s, the fast-growing east coast port city of Baltimore, Maryland faced 

economic stagnation unless it opened routes to the western states. The B&O Railroad 

Company was incorporated on April 24, 1827, a group of prominent Baltimore 

businessmen seeking to remain competitive with the cities of New York and 

Philadelphia. New York and Philadelphia were out pacing Baltimore as trade and 

exploration extended westward via canal and turnpike routes. The B&O Railroad was 

intended to provide not only an alternative to, but also a faster route for Midwestern 

goods to reach the East Coast than the seven-year-old, hugely successful, but slow 

Erie Canal across upstate New York. Railroad transport was limited at that time; 

however, the risky venture was supported because Maryland’s rugged geography 

made a canal impractical and turnpike travel was comparably expensive and labor 

intensive. The first section of the line was laid out entirely in Maryland, beginning in 

Baltimore and following the Patapsco River, crossing Parrs Ridge, continuing through 

the Monocacy River Valley to the Potomac River near Harpers Ferry, and following the 

Potomac River to Cumberland. The first 13 miles of track were completed from the 

station at Pratt Street in Baltimore to Ellicott Mills in May 1830, and the B&O Railroad 

soon after became the first American railroad to offer scheduled passenger service. 

The line was completed to Harpers Ferry in December 1834. The B&O Railroad 

constructed a bridge over the Potomac River at Harpers Ferry in January 1837, and 

began construction to Cumberland along the south bank of the river in 1839. The line 

finally reached Cumberland in November 1842. Expansion westward from 

Cumberland to the Ohio River at Wheeling, Virginia (now West Virginia), began in 1850 

and ended in December 1852. By the outbreak of the Civil War, the B&O Railroad 

included 531 miles of rail line, all located south of Pennsylvania. The B&O Railroad 

continued to expand steadily. As people migrated further west, the cities of Cincinnati, 

Ohio; St. Louis, Missouri and Chicago, Illinois became the new targets for the B&O 

Railroad, with the railroad finally reaching Chicago in November 1874. By the end of 

the nineteenth century, the railroad had achieved almost 5,800 miles of track and 

connected Chicago and St. Louis to Baltimore, Washington D.C., Philadelphia, and 

New York. 
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5.2.2.1.1 Baltimore & Ohio Railroad Pittsburgh Division - Pennsylvania 

By the mid-nineteenth century, railroading had proven to be an efficient means of 

transporting large numbers of passengers and mass quantities of freight over long 

distances and through rough terrain. Rivalry between railroad companies increased as 

expansion continued westward and companies sought new markets in the Midwest. 

The Pennsylvania Railroad became the B&O Railroad’s chief competitor during this 

period. The competition was typified by the companies’ simultaneous attempts to reach 

Pittsburgh, Pennsylvania, starting in the 1840s. 

The Pittsburgh Division of the B&O Railroad originated with the Pittsburgh & 

Connellsville Railroad, with underwriting from the B&O Railroad, and was constructed 

between Pittsburgh, Pennsylvania and Cumberland Maryland from 1847 to1871. The 

Pittsburgh & Connellsville Railroad was leased to the B&O Railroad for a term of fifty 

years starting January 1, 1876. The Pittsburgh & Connellsville Railroad officially 

merged into the B&O Railroad on September 25, 1912 and the line became known as 

the Pittsburgh Division. 

The B&O Railroad viewed most of the route as a thoroughfare rather than a 

destination; however, numerous branch lines were constructed by the railroad and 

other entities to connect major population centers and local industries to the line. 

These branch lines connecting to the Pittsburgh & Connellsville Railroad formed an 

extensive network in Somerset County by the end of the nineteenth century, aiding in 

the development of the county’s coal mining industry. In 1874, three years after the 

completion of the Pittsburgh & Connellsville Railroad, eleven small Somerset County 

coal companies produced 6,500 tons. By 1883, coal production in the county 

increased to nearly 280,000 tons per year, reflecting the enormous impact of the 

railroad. The railroad similarly impacted the coal industry in Fayette County. Thirty coal 

works were established along the Pittsburgh & Connellsville Railroad and branches by 

1882. The number of coke ovens in the Connellsville region jumped from 176 in 1871, 

the year the Pittsburgh & Connellsville Railroad was completed, to 7,211 in 1880. In 

1871, the Connellsville region produced 92 percent of the coke in the country, and as 

late as 1918 Fayette and Westmoreland counties still produced nearly half of the 

nation’s coke. The Pittsburgh & Connellsville Railroad played a significant role in 

transporting that product to Pittsburgh, where it was used to manufacture steel, and in 

transporting steam coal to eastern and western markets. The line joined the B&O 

Railroad’s original main line at Cumberland, Maryland and connected the ports in 
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Baltimore, the steel industry in Pittsburgh, and the Cumberland and Connellsville coal 

and coke regions. The Pittsburgh Division was a freight and passenger line. It carried 

a number of commodities; however, the majority of its tonnage consisted of coal from 

the 1850s through at least the first two decades of the twentieth century. 

A number of improvements were made to the Pittsburgh Division between 1880 and 

1920. The most significant improvements to the Pittsburgh Division were made in the 

late 1890s and early twentieth century as a result of an increase in traffic. The Fort Hill 

Low Grade, completed in 1902, was intended to provide heavy freight trains a lowgrade alternative to the steep original route between Confluence and Fort Hill. In 

addition Falls Cut Tunnel was completed on a new alignment in 1897 to increase 

efficiency at Fairhope. And finally, Sand Patch Tunnel was reconstructed on a new 

alignment between 1911 and 1912, increasing traffic capacity with the addition of 

second track and reducing the grade inside the tunnel. 

5.2.2.1.2 Baltimore & Ohio Railroad’s Magnolia Cutoff - West Virginia and Maryland 

Following construction of the B&O Railroad’s Metropolitan Branch in the 1870s, the 

portion of the original line between Baltimore and Point of Rocks, Maryland became 

known as the “old line” and then the Old Main Line. The portion of the Old Main Line 

between Point of Rocks and Weverton, Maryland was improved and incorporated into 

the Metropolitan Branch, and the section west of Weverton to Cumberland, Maryland 

became known as the East End Subdivision of the Cumberland Division. 

The terrain through which the East End Subdivision passed presented engineering and 

financial challenges to the B&O Railroad, including the winding Potomac River path 

laid astride steep mountainsides between Doe Gully, West Virginia and Paw Paw, 

West Virginia. The problem of maintaining traffic flow along the East End Subdivision 

grew in the late nineteenth century as the route became an artery for ever-increasing 

freight traffic flowing east and west. By the 1900s, the need to improve the facilities 

east of Cumberland, Maryland, was apparent as the increase of bituminous coal 

shipped from the coal fields of Maryland, West Virginia, and Pennsylvania, coupled 

with the movement of passenger and fast freight, taxed the facilities along this section 

of the line. With increasing density and continued lack of facilities, the portion of the 

line between Patterson Creek and Cherry Run came to be known as the “Neck of the 

Bottle.” Between the years 1910 and 1913, there was a 25 percent increase in the 
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Carothers Tunnel East Portal 

amount of tonnage traveling over the line, 

necessitating a change to eliminate 

congestion. The eastbound track between 

Orleans Road (Orleans Crossroads, West 

Virginia) and Okonoko (Little Cacapon, 

West Virginia) was especially problematic 

as it included two single-track tunnels (Paw 

Paw and Doe Gully) and the steepest 

grade remaining between Martinsburg, 

West Virginia and Cumberland, Maryland at 

Hansrote, West Virginia. 

The Magnolia Cutoff, which was constructed between 1913 and 1914, was meant to 

expedite trains traveling along this problematic stretch of tracks that followed the 

Potomac River. The twelve-mile-long double-track Magnolia Cutoff extends southwest 

from Orleans Crossroads in Morgan County, West Virginia to Okonoko in Hampshire 

County, West Virginia, passing through Allegany County, Maryland along the way. The 

line was shaped by the rugged terrain of the heavily forested peninsulas in the Paw 

Paw Bends of the Potomac River, through which it passes. The Magnolia Cutoff 

involved the elimination of several bends around steep ridges, thereby shortening the 

route, as well as improvements in grade over the line. The route includes four tunnels 

(Carothers, Graham, Stuart and Randolph), a long cut at Doe Gully, two bridges over 

the Potomac, and a concrete retaining wall necessary to hold the mountainside back 

where space was limited along the river. 

The Magnolia Cutoff provided the B&O Railroad with four tracks through the area. The 

B&O Railroad moved eastbound freight traffic over the High Line and used the Low 

Line tracks for east and westbound passenger traffic and westbound freight traffic. 

Thus, although it was assigned to the passage of growing levels of freight, the cutoff 

also facilitated passenger traffic movement along the East End of the Cumberland 

Division. 

5.2.2.2 Rail Decline and Current Rail Renaissance 

In the 1820s, the B&O Railroad started as risky "high-tech" investment and overtime it 

developed into a successful enterprise. The B&O Railroad and other railroads 
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economically linked states and cities as they moved passengers and freight. With 

westward expansion and innovations in engine design, the cost of freight dropped 

radically and travel became affordable to a larger segment of the population. Before 

railroads, overland transportation was unreliable and slow. The abundance of raw 

materials, farm products, and industrial output needed a reliable way to get them to 

markets. The railroad became a primary means of transporting finished goods from 

factories in the East to the West and agricultural products, steel, and coal from the 

West to the eastern cities. Goods and people moved with speed and efficiency. The 

railroad industry also had a tremendous impact on the development and economy of 

the cities it connected. It greatly influenced real estate values and spurred regional 

concentrations of industry. 

In the 1900s the B&O Railroad continued to refine their system, focusing on reducing 

grades and curves, addressing bottlenecks, and converting single track to double 

track, instead of adding new additions. Traffic along the B&O Railroad reached its peak 

in 1919, and dropped off significantly during the Great Depression, with its low in 1932. 

Total freight tonnage was cut in half; whole coal traffic dropped 41 percent. Increased 

truck use, and the depletion of coal and lumber resources contributed to this decline. 

Passenger traffic reduced, as Americans became more dependent on personal 

automobile use. Rail freight picked up during World War II as the Nation required 

increase coal use, merchandise movement, including military supplies and troop travel, 

to support the war effort. Post World War II, the Interstate System was introduced 

caused a system wide decline in rail transportation. Changes in transport, storage and 

the handling of freight commodities over the next four decades resulted system wide 

changes, causing many facilities and rail lines to become obsolete. The B&O reached 

its all-time financial low in 1961. The Chesapeake and Ohio Railway took control of the 

railroad shortly thereafter, in 1963. The B&O Railroad was operated under the 

Chesapeake and Ohio Railway’s new corporate structure, the Chessie System, from 

1972 until 1987, when both companies formally merged into CSX Transportation, Inc. 

in 1987, marking the official end of B&O Railroad’s corporate existence. CSX 

Transportation, Inc. continues to own and operate the railroad today. 

Currently, freight railroads are experiencing a Rail Renaissance and are critical to the 

economic well-being and global competitiveness of the United States. “They move 

42 percent of our nation's freight (measured in ton-miles) - everything from lumber to 

vegetables, and coal to orange juices...” (National Atlas, 2009). Railroads currently 
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move more intercity-freight than any other mode of transportation. The rail share of 

intercity ton-miles has been trending upward over the past 10 to 15 years. In addition, 

over the past ten years, intermodal traffic - the movement of truck trailers or containers 

by rail, has been the fastest growing rail traffic segment. Intermodal combines the doorto- door convenience of trucks with the long-haul economy of railroads. Rail intermodal 

transports a huge range of goods - everything from bicycles to automotive parts, lawn 

mowers to glassware, greeting cards to bottled water, and toys to computers. The 

efficiency of intermodal - and of freight railroading in general - provides our nation with a 

huge competitive advantage in the global economy. (National Atlas, 2009). 

5.2.3 Contributing Resources 

5.2.3.1 Pennsylvania - B&O Railroad Pittsburgh Division 

The PHMC and the SHPO determined the B&O Pittsburgh Division rail line in 

Allegheny, Bedford, and Somerset Counties is eligible for the NRHP, and notified CSX 

of this determination in a letter dated February 26, 2010. The B&O Railroad Pittsburgh 

Division is eligible for listing in the National Register under Criterion A for its 

association with late nineteenth and early twentieth century transportation and 

industrial development in Pennsylvania. The Pittsburgh Division was the first major 

route through Bedford, Somerset, and Fayette counties. Its completion in 1871 

prompted the construction of a vast network of branch lines in the counties through 

which it passed, stimulating economic and industrial development. The Pittsburgh 

Division significantly impacted the coal mining and coke production industries in the 

Connellsville region by providing an outlet for coke to Pittsburgh and for steam coal to 

eastern and western destinations. The railroad contributed to the Connellsville region’s 

status as the nation’s coke production center in the late nineteenth century. 

The following six tunnels are contributing resources to the B&O Pittsburgh Division and 

are all located in Somerset County, Pennsylvania. 

• Benford Tunnel was constructed in 1903 and is located in Lower Turkeyfoot 

Township. The tunnel conveys a single track. The tunnel was reconstructed as 

part of the Fort Hill Low Grade. The Fort Hill Low Grade was to increase efficiency 

between Confluence and Fort Hill, Pennsylvania by offering a lower-grade 

alternative route to heavy freight trains. 
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• Brook Tunnel is also in Lower Turkeyfoot Township and was constructed between 

1883 and 1885. The tunnel carries a single-track. The structure is likely named for 

Chauncy Brooks, president of the B&O Railroad from 1855 to 1858. 

• Shoo Fly Tunnel is located in Upper Turkeyfoot Township to the north of a sharp 

bend of the Casselman River. This tunnel was constructed in the 1870s or 1880s, 

and was altered/extended in 1897 and again in 1902 to resolve narrowing at the 

portals. A single track runs through the tunnel. 

• Pinkerton Tunnel, located in Upper Turkeyfoot Township, was originally 

constructed in 1871 as a single-track tunnel. This original tunnel was destroyed by 

fire in November 1879. In July 1885, when the tunnel was reconstructed, 

operations returned to the original alignment. The tunnel carries one track through 

Pinkerton Point on the Casselman River. 

• Sand Patch Tunnel was originally constructed between 1854 and 1871 as a singletrack tunnel through Negro Mountain. In 1911, the B&O Railroad began 

construction of a new double-track tunnel adjacent to the original to accommodate 

increasing traffic and to compete with the Western Maryland Railway, which 

proposed a tunnel nearby. The existing tunnel was built between 1911 and1912 

and with a western extension added in 1918, and it carries two tracks through the 

Negro Mountain. 

• Falls Cut Tunnel is located in Fairhope Township. It was constructed in 1897 and 

carries two tracks. The original Falls Cut Tunnel was approximately 200 feet west 

of the current alignment. The railroad built the current tunnel in 1897 to reduce the 

curve of the original alignment. The realignment project was known as the Falls 

Cut Improvement. Falls Cut Tunnel spans the width of a peninsula created by a Ubend in Wills Creek. The railroad tracks cross Wills Creek at both ends of the 

tunnel on single-span plate girder bridges. 

In addition, this historic railroad corridor includes the following contributing resources, 

Wills Creek Bridge in Hyndman and the two unnamed bridges over Wills Creek at Falls 

Cut Tunnel. These two resources are either in the immediate vicinity of or will be 

improved by the proposed action. 
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Magnolia Bridge Over Potomac 

River, Part of the Magnolia Cutoff 

Correspondence from the PHMC is included in Attachment 12 of Appendix E. 

5.2.3.2 West Virginia and Maryland - B&O Railroad Magnolia Cutoff 

The WVDCH determined that the Magnolia Cutoff was eligible for inclusion on the 

NRHP on December 9, 2009 and Carothers, Stuart and Randolph Tunnels are 

contributing resources. Located in West Virginia, Carothers Tunnel is located just 

north of Paw Paw; Stuart Tunnel is located to the north of Magnolia; and 

Randolph Tunnel is located south of Doe Gully. The tunnels have similar 

configurations: all are approximately 31 feet wide and convey two tracks. 

The B&O Railroad Magnolia Cutoff includes the following additional 

structures as contributing resources: the Kessler and Magnolia Bridges over 

the Potomac River which are the west and east approaches to Graham 

Tunnel, the Doe Gully Cut, and the concrete wall west of Paw Paw. It is 

noted in the West Virginia Historic Property Form for the Magnolia Cutoff, 

that it is eligible for listing under Criterion A in the area of transportation and 

under Criterion C in the area of engineering. Under Criterion A, it is eligible 

for its association with transportation development trends of the early 

twentieth century. The cutoff was designed to eliminate bottlenecks and 

expedite service along the eastern end of the Cumberland Division. By constructing 

the cutoff, the B&O Railroad was able to direct eastbound freight traffic, including coal 

from the fields of West Virginia, Maryland, and Virginia, along this route, thereby 

alleviating congestion along the main line. The Magnolia Cutoff is eligible under 

Criterion C in the area of engineering. The twelve- mile long cutoff was one of the 

largest engineering efforts of the B&O Railroad. The cutoff demonstrates an effective 

solution developed to overcome the restraints of difficult terrain presented by the river 

and surrounding mountains while maintaining operations along the existing tract. 

Correspondence from the WVDCH is included as Attachment 3 of Appendix F. 

The remaining tunnel constructed as part of the Magnolia Cutoff, Graham Tunnel, is 

located on a peninsula in the Paw Paw Bends of the Potomac River in Allegany 

County, Maryland. The tunnel spans the width of a U-bend in the Potomac River. The 

approaches to each side of the Graham tunnel are bridges over the Potomac River; 

Kessler Bridge to the south and Magnolia Bridge to the north, which are contributing 

resources to the Magnolia Cutoff. The MHT determined that Graham Tunnel was 

eligible for inclusion on the NRHP on December 16, 2009. It is noted in the Maryland 
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Eligibility Review Form that Graham Tunnel is eligible for listing under Criterion A in the 

area of transportation and under Criterion C in the area of engineering. Under Criterion 

A, it is eligible for its association with transportation development trends of the early 

twentieth century and for its association with the Magnolia Cutoff. Under Criterion C, 

the tunnel is part of the twelve-mile long Magnolia Cutoff, which was one of the largest 

engineering efforts of the B&O Railroad. Correspondence from MHT is included in 

Attachment 3 of Appendix G. 

The Magnolia Cutoff through the states of West Virginia and Maryland was constructed 

as a direct response to the need to move more freight more efficiently and more rapidly 

along the B&O Railroad Cumberland Division. The Magnolia Cutoff removed the ‘Neck 

of the Bottle’ and increased the efficiency and the economic movement of railroad 

traffic through the area. 

5.3 Proposed Action and Impacts to Section 4(f) Properties 

CSX’s National Gateway Clearance Initiative – Phase I is an effort to improve efficiency 

and expand capacity on the nation’s transportation network. The proposed action 

proposes to modify existing railroad infrastructure to provide sufficient vertical 

clearance and operating capability to operate double-stacked, domestic-container, rail 

traffic cars. The proposed improvements are expected to spur economic growth 

throughout the region. The ability to quickly and efficiently move goods to markets 

throughout the country is vital to the economy. Allowing double-stacked, intermodal 

railcars to move freely is one way to increase capacity without exceeding the existing 

capacity of the infrastructure, or using new rail lines with additional trains. Completion 

of the proposed action will allow America’s rail network to support increased freight 

volumes coming from the East Coast. 

5.3.1 Proposed Action 

The CSX rail line infrastructure on the National Gateway Clearance Initiative Phase I 

corridor is not currently equipped to accommodate double-stacked freight trains. The 

CSX Clearance Improvement Feasibility Study between Greenwich, Ohio and 

Chambersburg, Pennsylvania; Baltimore, Maryland and Weldon, North Carolina

(AECOM, 2007) details obstructions in the corridor that prohibit the use of doublestacked freight trains, potential alternatives to clearing the identified obstructions and 
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describes a preferred alternative at each individual location. The identified goal in the 

feasibility study was to achieve vertical clearance improvements by providing a 

minimum 21-foot vertical clearance standard to allow for unimpeded passage of 

second generation, domestic double-stacked containers. The feasibility study reviewed 

available information on the obstructions, conducted field surveys that included 

measurements of the vertical and horizontal clearances at each quadrant of a 

particular location and made recommendations for the preferred method of increasing 

the vertical clearance at each obstruction. Consideration was given at each location to 

the age and state of repair of the structure, its current use and/or closure, the 

surrounding land use, ownership of the structure, and the distance needed to achieve 

a minimum 21-foot vertical clearance before recommending a method to achieve the 

desired vertical clearance. For tunnels, there are two general methods for increasing 

the vertical clearance: open-cutting the tunnel (remove the overburden over the 

tunnel); or, modify the tunnel liner either by complete replacement or by notching. 

With the exception of open-cutting a tunnel, these improvements are 

generally minor consisting of reconstructing existing infrastructure and 

generally occur within existing ROW. Photos depicting the different 

tunnel options are provided as Appendix K. The feasibility report made 

the following recommendations: 

Open-Cutting 

Due to the lack of high quality overlying rock, the report recommended 

that all rock and soil cover be removed over three tunnels. This process 

is known as open-cutting (sometimes referred to as day-lighting). The 

following three tunnels were recommended for open-cutting: 

Benford Tunnel, Somerset County, Pennsylvania 

Shoo Fly Tunnel, Somerset County, Pennsylvania 

Pinkerton Tunnel, Somerset County, Pennsylvania 

(two alternatives being reviewed) 

(At Pinkerton Tunnel, the original recommendation was a total arch liner 

replacement and mining of the sidewalls. However, based on 

subsequent geotechnical studies, which indicate that the overlying rock is 

Pinkerton Tunnel 

Benford Tunnel 
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of poor quality, open-cutting is also being evaluated.) 

Total Arch Liner Removal and Portal Modifications 

Due to the amount of increased clearance needed to achieve a 

minimum of 21-feet of vertical clearance, total arch liner replacement 

and portal modifications were recommended for the following five 

tunnels: 

Brook Tunnel, Somerset County, Pennsylvania 

Falls Cut Tunnel, Somerset County, Pennsylvania 

Carothers Tunnel, Morgan County, West Virginia 

Graham Tunnel, Allegany County, Maryland 

Randolph Tunnel, Morgan County, West Virginia 

The new liner and modified portal will be reconstructed and/or stabilized, 

as needed, with rock bolts and shotcrete. 

Arch Liner and Portal Notching 

Due to the minimal amount of increased clearance needed to achieve a minimum of 

21-feet of vertical clearance, liner and portal notching was recommended for the 

following two tunnels: 

Sand Patch Tunnel, Somerset County, Pennsylvania 

Stuart Tunnel, Morgan County, West Virginia 

 

The notched liner and modified portal will be reconstructed and/or stabilized, as 

needed, with rock bolts and shotcrete. 

5.3.2 Impacts to Section 4(f) Properties 

As a result of coordination in accordance with the regulations implementing Section 106 of 

the NHPA, the following determinations were made: 

Falls Cut Tunnel 
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• Portions of the proposed action are located within the P&LE Railroad corridor, a 

significant historic resource. The following contributing resources to the P&LE 

Railroad are also either in the immediate vicinity of or will be improved by the 

proposed action: Chartiers Creek Bridge, Pittsburgh & Lake Erie Station, and J&L 

Tunnel all located in Pittsburgh, Pennsylvania. Through coordination with the 

PHMC and design modifications, it has been determined that there will be no 

adverse affects by the proposed action on the P&LE Railroad which includes the 

Chartiers Creek Bridge, Pittsburgh & Lake Erie Station, and J&L Tunnel as 

contributing resources. 

• The PHMC stated in a letter dated February 26, 2010, that the proposed vertical 

clearance improvements to the 6 tunnels, which are contributing resources to the 

B&O Railroad Pittsburgh Division, will adversely affect the eligible rail corridor. The 

B&O Railroad Pittsburgh Division also includes Wills Creek Bridge, Hyndman, 

Pennsylvania which is a contributing resource and which is also vertical clearance 

obstructions for double- stacked, intermodal, freight cars. Through coordination 

with the PHMC and design modifications, improvements to the superstructure of 

this historical bridge will not adversely impact this contributing resource. No 

improvements are proposed for the two unnamed bridges over Wills Creek which 

are the approaches to Falls Cut Tunnel; thus, they will not be affected by this 

undertaking. 

• The WVDCH indicated in correspondence dated March 22, 2010, that the impacts 

from the proposed project to increase the vertical clearance through the three 

West Virginia tunnels will have an adverse effect on the B&O Railroad Magnolia 

Cutoff. 

• The MHT stated in correspondence dated June 15, 2010, that the impacts from the 

proposed project to increase the vertical clearance through Graham Tunnel will 

have an adverse effect on this resource, which is a contributing resource to the 

Magnolia Cutoff. The B&O Railroad Magnolia Cutoff includes the following 

additional contributing resources: the Kessler and Magnolia Bridges over the 

Potomac River which are the west and east approaches to Graham Tunnel, the 

Doe Gully Cut, and the concrete wall west of Paw Paw. The proposed action, as 

designed, will not impact any of these additional contributing resources to the B&O 

Railroad Magnolia Cutoff. 
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• The Smithfield Street Bridge in Pittsburgh, Pennsylvania and the Walnut Street 

Bridge in McKeesport, Pennsylvania are significant historic resources. The CSX 

mainline tracks underneath each bridge will be lowered as part of the proposed 

action. Through coordination with the PHMC and design modifications, it has been 

determined that there will be no adverse affects by the proposed action on the 

Smithfield Street Bridge or the Walnut Street Bridge, nor will any property within a 

historic boundary be acquired. 

• The Blue Lick Truss is a historic bridge located in Somerset County, Pennsylvania. 

This bridge will be raised approximately 12 inches as part of the proposed action. 

Through coordination with the PHMC and design modifications, it has been 

determined that there will be no adverse affects by the proposed action on the 

Blue Lick Truss, as a historic resource, nor will any property within a historic 

boundary be acquired. 

Based on the determinations of eligibility for the NRHP and adverse effects 

determination for impacts to eligible resources, the proposed clearance project is 

subject to Section 4(f) of the United States Transportation Act of 1966, as amended. 

5.4 Alternatives Analysis 

To demonstrate that there is no feasible and prudent alternatives to the use of 

Section 4(f) property, the Net Benefits programmatic evaluation analysis must 

address the following alternatives: 

• Do nothing; 

• Improve the transportation facility in a manner that addresses the project's purpose 

and need without a use of the Section 4(f) property; and 

• Build the transportation facility at a location that does not require use of the Section 

4(f) property. 

This list is intended to be all-inclusive. The Net Benefits programmatic evaluation 

does not apply if a feasible and prudent alternative is identified that is not discussed in 

this document. 
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5.4.1 Do Nothing/No Build Alternative 

This alternative has been studied and it does not meet the project’s purpose and 

need. 

The Do Nothing/ No Build Alternative will not result in an improvement to highway 

congestion and public safety by shifting freight from trucks to the enhanced rail 

network. The Do Nothing Alternative fails to correct the situations that create 

chokepoints to the efficient movement of double-stacked freight containers through 

the corridor. These chokepoints will increasingly cause delays to the movement of 

freight, as the estimated increasing volume of freight is forced to move on a rail 

system with insufficient capacity. Delays in the movement of freight will also cause 

delays in the movement of passenger trains along this corridor, in that they utilize the 

same tracks. Amtrak provides 2 passenger trains per day through these locations. 

The delays to passenger rail service will adversely impact the financial operations of 

Amtrak and cause undue hardship to the train passengers who rely on this service. 

The Do Nothing Alternative will also cause adverse economic impacts to CSX as the 

delays in moving freight, CSX’s primary business, will likely cause a reduction in 

competitiveness and a subsequent decline in the financial status of CSX. The Do 

Nothing Alternative does not recognize that improvements and up-grades are 

necessary to allow this railroad to continue to serve the freight transportation needs of 

the nation, and support passenger rail service, in an economically viable manner. 

If CSX loses economic viability along this corridor due to its inability to resolve 

capacity issues by correcting chokepoint such that it can utilize double-stacked 

intermodal cars, the company will likely need to reduce operations along this line and 

possibly abandon it entirely. If CSX is forced for economic competitiveness reasons 

to abandon operations along these historic railroad corridors, they will cease to 

function in their historic role as significant freight transportation routes. If abandoned, 

the infrastructure will eventually degrade and collapse from lack of maintenance and 

repair. Such a degradation and collapse would constitute a more significant impact 

on Section 4(f) resources by the Do Nothing Alternative than the use from the 

proposed action. 
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5.4.2 Improve the Transportation Facility in a Manner that Addresses the Project's Purpose and 

Need Without a Use of the Section 4(f) Property 

Improving the facility by lowering the tracks was an Alternative that was considered 

and was not recommended in the Feasibility Study. Due to horizontal and vertical 

alignment limitations associated with freight train movement, lowering the track by up 

to 3 feet to gain the minimum 21-foot vertical clearance at these tunnels would require 

extensive vertical realignment of the approaches at each tunnel. Approximately 1,000 

to 2,000 feet of track would need to be vertically realigned outside of each portal to tie 

to the existing line, depending on the existing grade, the controlling grade and the 

curvature. This construction on new vertical alignment would cause increased impacts 

to the natural and/or human environment. These impacts include the loss of 

agricultural lands and/or forested habitats, impacts to wetlands and streams, and 

impacts to community infrastructure. The associated need for engineering design and 

acquisition of new right-of-way would result in considerable additional costs. 

Lowering the tracks, while preserving the tunnels, would not avoid use of Section 4(f) 

resources which contribute to the B&O Railroad Pittsburgh Division and the B&O 

Railroad Magnolia Cutoff. Lowering the tracks would require the demolition and 

replacement of several historic bridges, which are contributing resources to their 

respective railroad corridors, immediately adjacent to tunnels along the route, due to 

the need to also adjust their vertical alignment. These bridges include two historic 

bridges over Wills Creek which function as approaches to Falls Cut Tunnel, and the 

historic Kessler and Magnolia Bridges over the Potomac River which function as 

approaches to Graham Tunnel. 

Extensive rehabilitation would be required on each tunnels’ foundation to maintain a 

track profile at a lower elevation within the tunnels. In order to retain the historic 

integrity of the tunnels during track lowering operations, it would be necessary to 

remove existing portions of the foundation, temporarily brace the existing linear and 

then remove bedrock below the existing tracks. A new foundation would need to be 

constructed to support the retained liner and portals. The repairs to the arch liner and 

portals to maintain structural integrity at a lower elevation will be so extensive that the 

historic integrity of the tunnels is likely to be compromised. This potential loss of 

historic integrity at the tunnels is use of 4(f) resources of similar magnitude as to the 

use of 4(f) resources from the proposed action. 
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In addition, in order to complete the track lowering the line would have to be taken out 

of service and a detour route utilized, due to the extensive work on the foundations and 

removal of bedrock beneath the tracks. Reconstruction of the foundations at each 

tunnel and work to remove bedrock to lower the tracks will take one to several months, 

depending on the length of the tunnel, composition of the bedrock, the fabric of the 

tunnel liners and portals, and the engineering design to tie back into the existing track. 

This would lead to a severe disruption of train operations to a level that could result in 

adverse economic impacts to CSX and the shipping industry. CSX transports 28 to 30 

freight trains per day on this line with an annual gross weight of 74 million tons of 

cargo. In addition, Amtrak provides 2 passenger trains per day at these locations. The 

potential line closures associated with track lowering would create considerable 

hardship for passenger travel. Finally, a detour during construction could involve the 

use of another railroad’s track, at significant cost to CSX with potential for creating 

delays; thus, incurring costs, on the competitors system as well. The need to remove 

the tracks from service during the potential tunnel rehabilitation suggested under this 

Alternative does not meet the purpose and need of the proposed action which is to 

maintain service along the route during the improvements for increasing vertical 

clearance. The preferred action, although adversely affecting some contributing 

resources to the Pittsburgh Division and the Magnolia Cutoff, properties eligible for the 

NRHP, maintains the operations and economic viability of the CSX Railroad which in 

turn leads to the proper maintenance and upkeep of the remaining resources. 

5.4.3 Build the Transportation Facility at a Location that Does Not Require Use of the Section 

4(f) Property 

Investigations have been conducted to construct rail line with tunnels on new 

alignment; however, due to the mountainous terrain and proximity of rivers and 

streams, such as Wills Creek, Casselman River and Potomac River, construction on a 

new location is not prudent. The existing rail alignments, with their tunnels, were 

constructed in the most prudent locations through the area. The locations were 

selected based on an engineering evaluation of quality and quantity of rock to bore 

through, steepness of grade, minimization of tunnel length and minimization of overall 

track length. Due to horizontal and vertical alignment limitations associated with freight 

train movement, construction of new tunnels on new alignments would result in 

extraordinary impacts in the realignment of the existing tracks. Approximately 1,000 to 

2,000 feet of track would be needed to be realigned outside of each portal to tie the 
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existing line into the new tunnel. This construction on new alignment would cause 

increased impacts to the natural and/or human environment. These impacts include 

the loss of agricultural lands and forested habitats, impacts to wetlands and streams, 

and potential impacts to residences and community infrastructure. The associated 

need for engineering design, acquisition of new right-of-way and boring new doubletrack tunnels would result in considerable additional costs. 

For the B&O Railroad Pittsburgh Division, replacing the tunnels on new alignment 

would cause the abandonment of 6 tunnels and two bridges over Wills Creek, which 

are contributing resources to the eligible Pittsburgh Division, and the abandonment of 

approximately 12,000 to 24,000 feet of track. For the B&O Railroad Magnolia Cutoff, 

replacing the tunnels on new alignment would cause the abandonment of 4 tunnels 

and two bridges (Kessler Bridge and Magnolia) over the Potomac River, which are 

contributing resources to the eligible Magnolia Cutoff, and the abandonment of 

approximately 8,000 to 16,000 feet of track. If this new alignment alternative was 

utilized, over time these abandoned resources will degrade and eventually collapse 

from lack of maintenance and repair. The degradation and collapse of contributing 

resources to the Pittsburgh Division and to the Magnolia Cutoff constitutes a greater 

adverse impact to Section 4(f) resources than the use from the proposed action. The 

proposed action, although adversely affecting some of the contributing resources to 

properties eligible for the NRHP, maintains the operations and economic viability of the 

CSX Railroad which in turn leads to the proper maintenance and upkeep of the many 

remaining resources. The remaining resources will retain sufficient number of 

contributing elements that define the P&LE, B&O Pittsburgh Division and B&O 

Magnolia Cutoff as historic resources. 

5.5 Net Benefit Analysis and Finding 

Following is the data to support a finding that the Do-Nothing and Avoidance 

Alternative are not feasible and prudent, a discussion of measures to minimize harm, 

and, an evaluation of the Net Benefit to Section 4(f) resources. 

5.5.1 Net Benefit Finding and Applicability 

None of the avoidance alternatives analyzed for this Net Benefit Analysis are feasible 

or prudent. The Do Nothing Alternative does not meet the purpose and need or the 
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proposed action. In addition, the lack of action in this alternative would likely lead to 

loss of competitiveness and thus loss of economic viability for CSX along this route. 

The foreseeable outcome for the Do Nothing Alternative is the abandonment of a 

historic railroad corridor which would be a greater impact on Section 4(f) resources 

than the proposed action. The Avoidance Alternatives both lead to increased natural 

and human environment impacts, substantially increased cost, and substantial 

economic impacts. In addition, these Avoidance Alternatives do not avoid use of 

Section 4(f) resources. 

5.5.2 Measures to Minimize Harm 

5.5.2.1 Project Design Coordination 

Portions of the proposed action are located within the P&LE Railroad corridor, a 

significant historic resource. The following contributing resources to the P&LE 

Railroad are in the immediate vicinity of or will be improved by the proposed action: 

Chartiers Creek Bridge, Pittsburgh & Lake Erie Station, and J&L Tunnel all located in 

Pittsburgh, Pennsylvania. Through coordination with the Pennsylvania SHPO and 

design modifications, it has been determined that there will be no adverse affects by 

the proposed action on the P&LE Railroad which includes the Chartiers Creek Bridge, 

Pittsburgh & Lake Erie Station, and J&L Tunnel as contributing resources. 

The B&O Railroad Pittsburgh Division includes Wills Creek Bridge, Hyndman, 

Pennsylvania which is a contributing resource and which is also vertical clearance 

obstructions for double- stacked, intermodal, freight cars. Through coordination with 

the SHPO and design modifications, improvements to the superstructure of this 

historical bridge will not adversely impact this contributing resource. 

The B&O Railroad Magnolia Cutoff includes the following additional contributing 

resources: the Kessler and Magnolia Bridges over the Potomac River which are the 

west and east approaches to Graham Tunnel, the Doe Gully Cut, and the concrete wall 

west of Paw Paw. The proposed action, as designed, will not impact any of these 

additional contributing resources to the B&O Railroad Magnolia Cutoff. 

The CSX mainline tracks underneath the Smithfield Street Bridge in Pittsburgh, 

Pennsylvania and the Walnut Street Bridge in McKeesport, Pennsylvania will be 
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lowered as part of the proposed action. Through coordination with the Pennsylvania 

SHPO and design modifications, it has been determined that there will be no adverse 

affects by the proposed action on the Smithfield Street Bridge or the Walnut Street 

Bridge, nor will any property within a historic boundary be acquired. 

Finally, the Blue Lick Truss is a historic bridge located in Somerset County, 

Pennsylvania. This bridge will be raised approximately 12 inches as part of the 

proposed action. Through coordination with the PHMC and design modifications, it 

has been determined that there will be no adverse affects by the proposed action on 

the Blue Lick Truss, as a historic resource, nor will any property within a historic 

boundary be acquired. 

5.5.2.2 Arch Liner and Portal Notching 

In two clearance locations, Sand Patch 

Tunnel in Pennsylvania and Stuart 

Tunnel in West Virginia, it was 

determined feasible to notch the arch 

liner and portal. This process will grind a 

squared corner into the curved arches of 

these two tunnels to create increased 

clearance. The remaining historic fabric 

at these tunnels will be stabilized with 

rockbolts and shotcrete. This process 

will preserve some of the historic fabric 

at these two tunnels which is a 

minimization of impacts; however, their 

visual appearance will be altered. In all other cases, notching of the tunnel liner to 

achieve additional clearance is not feasible, due to the potential of compromising the 

structural integrity of the arch from the depth of the notch required. However, CSX is 

continuing to refine their designs at each tunnel in an attempt to save as much of the 

portal fabric as possible. 

Sand Patch Tunnel Liner Notching 
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5.5.2.3 Memorandum of Agreement 

The FRA/FHWA; the Ohio, Pennsylvania, West Virginia, and Maryland SHPOs; and 

the Ohio, Pennsylvania, West Virginia, and Maryland State Departments of 

Transportation along with CSX have agreed to the following methods to minimize and 

mitigate impacts to the Section 4(f) properties. The following stipulations are included 

in a MOA developed for the projects: 

5.5.2.3.1 Pennsylvania 

1. Prior to the start of construction that could adversely affect them, the Brook, 

Benford, Shoo Fly, Pinkerton, Sand Patch, and Falls Cut tunnels, contributing 

features to the Baltimore & Ohio Railroad, Pittsburgh Division, will be documented 

by CSX to State-level standards established by the Pennsylvania SHPO. The 

documentation of each tunnel will include photographic recordation, a brief 

description, and a historical narrative. The photographic documentation will 

include archival quality, 35 millimeter (mm) black-and-white photographs printed in 

a 5-inch by 7-inch format, with each print labeled in pencil with the name and 

location of the resource, date of photograph, and view shown. The photographic 

documentation will also include digital photographs prepared to National Register 

standards. The photographs will be keyed to site plan/maps. The historical 

narrative of each tunnel will include a discussion of the significance of the tunnel as 

part of the Baltimore & Ohio, Pittsburgh Division. The documentation package will 

also include archival copies of previous documentation and historic photographs. A 

copy of the approved documentation will be made available to the Pennsylvania 

SHPO and the consulting parties in digital and hard copy formats. 

The Pennsylvania SHPO and consulting parties shall have thirty (30) calendar 

days upon receipt of the documentation packages in which to comment. If the 

Pennsylvania SHPO and the consulting parties do not comment within the 30 

days, the FHWA shall assume concurrence and proceed. 

2. CSX shall explore, to the extent feasible using customary engineering practices 

and standards, opportunities to notch the Brook, Sand Patch, and Falls Cut tunnels 

so that the Date Plaques and identification markers may be preserved in place. 
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3. If notching described in I.A.2 above is not feasible, the date plaques or 

identification markers of the adversely affected tunnels, as outlined in Attachment 

2, will be salvaged and offered for reuse to appropriate organizations by CSX. 

Every effort will be made to remove the materials in a manner that is sensitive to 

the historic fabric. The organizations listed in Attachment 2 shall be contacted to 

determine their interest in receipt of the materials. In the case that more than one 

entity responds that they would accept receipt of the materials, the hierarchy of 

distribution will follow the order outlined in Attachment 2. Should any of the 

organizations accept the salvageable materials, the FHWA shall ensure the 

recipient shall accept full responsibility for the removed materials. If a recipient for 

the salvaged materials cannot be identified within nine months of the start of the 

solicitations of interest, then the FHWA shall notify CSX that they (CSX) shall 

assume ownership of the materials. 

4. CSX shall develop materials for a website on the history of the National Gateway 

initiative corridor through Pennsylvania for the information of the general public. 

The website will include a brief history and discussion of the technology of the 

Baltimore & Ohio Railroad, Pittsburgh Division, and the Pittsburgh & Lake Erie 

Railroad, those historic lines that make up the National Gateway initiative corridor. 

The history will highlight the impacts of the rail lines on local communities, 

industries, and regional and State transportation routes. The website will include a 

summary of the National Gateway initiative corridor improvements. The website 

will be illustrated using historic and current photographs and short video clips. The 

website will be developed in coordination with, hosted by, and maintained by the 

Pennsylvania SHPO. An article to be published in a popular historical publication 

will present the history of the National Gateway initiative corridor and publicize the 

release of the website. 

The Pennsylvania SHPO shall have thirty (30) calendar days upon receipt of the 

first and second drafts of the website materials and article in which to comment. If 

the Pennsylvania SHPO does not comment within the 30 days, the FHWA shall 

assume concurrence and proceed. 
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5.5.2.3.2 West Virginia 

1. Carothers, Stuart, and Randolph tunnels, contributing features of the Magnolia 

Cutoff of the Baltimore and Ohio Railroad, will be documented by CSX prior to the 

start of the proposed action. The documentation will include digital photographic 

recordation to National Park Service standards. The photographic documentation 

will be accompanied by updated Historic Preservation Inventory (HPI) forms. A 

digital copy of the approved documentation will be made available to the West 

Virginia SHPO, the West Virginia State Archives, West Virginia University, 

Morgantown, and the Historic Landmarks Commission of Morgan County. 

The West Virginia SHPO shall have thirty (30) calendar days upon receipt of the 

documentation packages in which to comment. If the West Virginia SHPO does not 

comment on the documentation within the 30 days, the FHWA shall assume 

concurrence and proceed. 

2. A brief (approximately 10-page) history of the Baltimore and Ohio Railroad’s 

Magnolia Cutoff will be prepared by CSX. The history will be used to provide 

information on the historic and engineering significance of the line and the 

Magnolia Cutoff to the general public. CSX will research the archives of the B&O 

Railroad Museum, West Virginia University West Virginia and Regional History 

Collection, and CSX holdings in an attempt to locate and copy any original photos, 

construction plans or “as-built” plans for the Magnolia Cutoff. The history will be 

developed in coordination with the West Virginia SHPO and will reuse information 

presented in the HPI form previously prepared for the Magnolia Cutoff. CSX shall 

provide the West Virginia SHPO with one initial and one final draft of the text, 

graphics, and layout of the history for comment. CSX shall develop materials for a 

website on the history of the Magnolia Cutoff for the information of the general 

public, which will include any copies of archival photographs of the cutoff under 

construction and original tunnel plans. The website will be determined in 

coordination with the West Virginia SHPO. CSX will provide a hard copy of the 

history to the West Virginia SHPO, the West Virginia State Archives, West Virginia 

University, Morgantown, and the Historic Landmarks Commission of Morgan 

County. 
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The West Virginia SHPO shall have thirty (30) calendar days upon receipt of the 

history in which to comment. If the West Virginia SHPO does not comment 

within the 30 days, the FHWA shall assume concurrence and proceed. 

3. CSX shall explore, to the extent feasible using customary engineering practices 

and standards, opportunities to notch the Carothers, Stuart and Randolph tunnels 

so that the date and identification markers may be preserved in place. 

5.5.2.3.3 Maryland 

1. CSX shall document the Graham Tunnel prior to any demolition activities and 

provide the documentation to the Maryland SHPO. The documentation shall 

include black-and-white photographs sufficient to portray the tunnel’s interior arch 

liner, exterior portals, its architectural details, and its surrounding context to provide 

an accurate record of the tunnel and its setting. The recordation shall follow the 

MHT’s Standards and Guidelines for Architectural and Historical Investigations in 

Maryland (MHT 2000). The FHWA shall assure that CSX shall submit the 

documentation to the Maryland SHPO for review and comment. 

The FHWA shall assure that CSX make a good faith effort to locate and copy 

original construction plans or “as-built” plans for the Graham Tunnel. Multiple 

repositories, including the CSX archives, shall be examined. If located, CSX shall 

produce 81⁄2-inch by 11-inch black-and-white copies or photographs of the plans 

and submit the documentation to the Maryland SHPO for review and comment. If 

historic plans for the Graham Tunnel are not located, CSX shall inform the 

Maryland SHPO in writing of the methodology used to conduct the research and a 

list of repositories consulted. The Maryland SHPO shall determine if a good-faith 

effort was made and if any additional research is warranted. 

The Maryland SHPO shall have a thirty (30) day review period to respond with 

comments. If the Maryland SHPO does not respond within a 30 day review period, 

then it can be assumed that the recordation package has been accepted by the 

Maryland SHPO. 
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2. CSX shall explore, to the extent feasible using customary engineering practices 

and standards, opportunities to notch the Graham Tunnel so that the date and 

identification markers may be preserved in place. 

3. Per Coordination with the Maryland Historical Trust Act of 1985: The Maryland 

SHPO agrees that the fulfillment of the terms of this MOA will satisfy the 

responsibilities of the Maryland DOT and any other Maryland State agency under 

the requirements of Maryland State historic preservation law (§§ 5A-325 and 5A326 of the State Finance and Procurement Article, Annotated Code of Maryland) 

for the components of the proposed action that require licensing, permitting, and/or 

funding actions from Maryland State agencies. 

 A copy of the fully executed MOA is included in Appendix C. 

5.5.3 Net Benefit to Section 4(f) Resources 

The proposed action will increase the vertical clearance along the National Gateway 

Clearance Initiative – Phase I to allow for the more efficient movement of freight 

through the use of double-stacked, intermodal, freight cars. The integrity of this historic 

railroad system depends on continuing maintenance and upgrades so it can continue 

to efficiently move freight across great distances, the purpose for which it was created. 

The proposed action to increase the vertical clearance, may alter some segments of 

this system, but the railroad corridor will retain its value as a functioning and vital part 

of the U.S. transportation system. The resources will benefit through regular 

maintenance and upkeep as vital part of that transportation network. If the railroad is 

prevented from taking actions that preserve its competitiveness and economic stability 

through increases in efficiency and reductions in chokepoint delays, it will be forced to 

ultimately abandon a historic railroad route that is no longer efficient to utilize and an 

economic drain on the company. The loss of freight train service along these historic 

B&O Railroad corridors would be the loss of an icon in the American story since its 

integrity lies in the railroad’s location, feeling and associations which are rooted in this 

portion of the American landscape. 

Allowing CSX to maintain and upgrade its system will benefit the system and continue 

the historic use for which it was created. The ability to more efficiently move freight 

through utilization of double-stacked freight cars will also benefit the region by creating 
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jobs. It will reduce roadway congestion and air pollution by reducing the regions 

dependency on long-haul trucking. A reduction in the number of trucks on the 

roadways will create safer driving conditions and, in turn, will also reduce the highway 

maintenance costs. 

5.5.4 Summary 

The Section 4(f) Evaluation and Approval for Transportation Projects That Have a Net 

Benefit to a Section 4(f) Property is appropriate as all of the avoidance alternatives 

require the use of Section 4(f) property. The project is a rail infrastructure 

enhancement project. Completion of the proposed action will directly improve and 

maintain the long term viability of the historic rail corridors. Completion of Phase I of the 

National Gateway Clearance Initiative is being developed to enhance the historic rail 

corridors, resulting in a net benefit to these resources from implementation of the 

proposed action. A “net benefit” is achieved when the transportation use, the 

measures to minimize harm, and the mitigation incorporated into the project results in 

an overall enhancement of the Section 4(f) property when compared to both the future 

do-nothing or avoidance alternatives and the present condition of the Section 4(f) 

property, considering the activities, features, and attributes that qualify the property for 

Section 4(f) protection. 

5.6 Coordination 

Coordination has been ongoing with the respective State SHPOs since the project’s 

inception. The coordination has resulted in the designation of the rail corridors as eligible to 

the NRHP, determination of eligibility of contributing resources along the corridors, effects 

determination of the resources, and a project specific MOA for mitigation to minimize the 

effects to the resources. Attachment 12 within Appendix E (Documentation for 

Pennsylvania) and Attachment 3 within Appendices F and G (Documentation for West 

Virginia and Maryland, respectively) includes cultural resources coordination and 

correspondence. 

A coordination meeting was held on September 11, 2009, with the PHMC to introduce the 

National Gateway Clearance Initiative in Pennsylvania and to discuss a proposed schedule. 

Historic Resource Survey Forms were submitted for the undertaking in Pennsylvania, on 

November 23, 2009 by A.D. Marble & Company on behalf of CSX. A second coordination 
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meeting was conducted on November 25, 2009 with PHMC. In a letter dated December 14, 

2009, the PHMC stated the B&O Railroad Pittsburgh Division in Allegheny, Bedford, and 

Somerset Counties; and the P&LE’s Pittsburgh, McKeesport & Youghiogheny Railroad, in 

Lawrence, Beaver, Allegheny, Westmoreland and Fayette counties are eligible for inclusion 

on the NRHP. An additional coordination meeting with PHMC was held on December 23, 

2009. Effects reports for these resources, detailing the corridors, and contributing resources 

that are part of the National Gateway Clearance Initiative were submitted to the PHMC and 

Consulting Parties on February 17, 2010, by A.D. Marble & Company on behalf of CSX. 

The PHMC concurred with the Effects Reports findings, and stated a finding ‘no effect’ to 

the former P&LE line based on the National Gateway Clearance Initiative. However, the six 

mountain tunnels that are contributing resources to the B&O Railroad Pittsburgh Division 

would be adversely affected by the proposed action. Public informational meetings were 

held in Pittsburgh and Somerset on February 25, and March 9, 2010, respectfully, to 

introduce the clearance projects and request comments from the public. No public 

comments were received regarding the B&O Railroad Pittsburgh Division or the planned 

improvements to its tunnels. Meetings were held with PHMC on March 17, and April 16, 

2010, to discuss mitigation for the affected resources. Coordination for archeology has 

been concurrent. A Phase I Archeological Report was submitted to the PHMC, who 

concurred in a letter dated June 10, 2010, that no further archeology work is necessary. 

A coordination meeting was held on September 18, 2009 with the WCDCH and West 

Virginia Division of Highways to introduce the National Gateway Clearance Initiative in 

West Virginia and to discuss a proposed schedule. Based on the outcome these 

discussions with WVDCH, eligibility determination forms were submitted by on 

November 30, 2009 by A.D. Marble & Company on behalf of CSX. A second 

coordination meeting was held with WVDCH on December 3, 2009. The WVDCH 

determined that the Magnolia Cutoff was eligible for inclusion on the NRHP on 

December 9, 2009 and that the three tunnels (Carothers, Stuart and Randolph) are 

contributing resources. Media releases and social advertisements requesting 

comments on the proposed clearance improvements were published in local 

newspapers on December 23 and 24, 2009. No comments were received. On 

February 19, 2010, A.D. Marble & Company, on behalf of CSX, submitted an effects 

recommendation to WVDCH for the Magnolia Cutoff and the three contributing tunnels. 

WVDCH determined on March 22, 2010, that the impacts from the proposed project to 

increase the vertical clearance through the tunnels will have an adverse effect on the 

Magnolia Cutoff. 
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A coordination meeting was held on August 26, 2009 with the MHT and Maryland State 

Highway Administration to introduce the National Gateway Clearance Initiative in 

Maryland and to discuss a proposed schedule. In addition due to Graham Tunnels 

proximity of the Chesapeake and Ohio Canal National Historical Park (and due to 

proposed impacts at other clearance locations which are no longer part of this action), 

a similar coordination meeting was held with the NPS on August 26, 2009. Based on 

the outcome of discussions during the August 26,2009 MHT meeting, eligibility 

determination forms were submitted by on October 28, 2009 by A.D. Marble & 

Company on behalf of CSX. Additional coordination meetings were conducted with 

NPS and MHT on November 19, 2009 (NPS only) and December 17, 2009. MHT 

determined that Graham Tunnel was eligible for inclusion on the NRHP in 

correspondence dated December 16, 2009. An additional coordination meeting was 

conducted with NPS and MHT on January 21, 2010. A public informational meeting 

was held in Harpers Ferry, West Virginia on March 3, 2010 to introduce the clearance 

projects and request comments from the public. No comments were received as on 

outcome of that public meeting that relate to Graham Tunnel. A phone conference call 

was held on March 9, 2010 with MHT and NPS to review the comments from the public 

workshop and to discuss the process for moving forward. A final coordination meeting 

was held with NPS on May 24, 2010 at which time CSX notified NPS of the February 

17, 2010 TIGER grant award and the clearance locations included in that grant. NPS 

stated during this May meeting that they have no official interests in Graham Tunnel. 

On May 27, 2010, A.D. Marble & Company, on behalf of CSX, submitted an effects 

recommendation to MHT for Graham Tunnel. MHT determined in correspondence 

dated June 15, 2010 that the impacts from the proposed project to increase the vertical 

clearance through Graham Tunnel will have an adverse effect on this resource. 

Coordination will continue with the respective SHPOs and other interested parties in 

accordance with the provisions of the MOA. 
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6. References 

AECOM. 2007. CSX Clearance Improvement Feasibility Study between Greenwich, 

Ohio and Chambersburg, Pennsylvania; Baltimore, Maryland and Weldon, 

North Carolina. 

Allegheny County, Pennsylvania. December, 2008. Allegheny County Places: 

Allegheny County Comprehensive Plan Agriculture Map. Allegheny County 

Economic Development – Planning Division, Pittsburgh, PA. 

Cambridge Systematics. October 2007. The National Gateway; Benefits Assessment 

–Final Report. Cambridge Systematics, Inc., Cambridge, MA. 

Cambridge Systematics, Inc. and Battelle Memorial Institute. October 2005. An Initial 

Assessment of Freight Bottlenecks on Highways, prepared for Federal 

Highway Administration, Office of Transportation Policy Studies. 

CSX. 2009. National Gateway website - 

(http://www.nationalgateway.org/content/benefits/communities_westvirginia.cf

m). Accessed July 28, 2009. 

Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual, 

Technical Report Y-87-1. U.S. Army Engineer Waterways Experiment Station, 

Vicksburg, MS. 100 pp. + appendices. 

Minnesota IMPLAN Group, IMPLAN®, 1999. Software Application. 2007 IMPLAN 

State and County Data Files. May. 

Mack, John J. 2001. Ohio Rapid Assessment Method for Wetlands, Manual for Using 

Version 5.0. Ohio EPA Technical Bulletin Wetland/2001-1-1. Ohio 

Environmental Protection Agency, Division of Surface Water, 401 Wetland 

Ecology Unit, Columbus, Ohio. 

Maryland Department of the Environment (MDE) and Center for Watershed Protection. 

2009. 2000 Maryland Stormwater Design Manual Volumes I & II (Revised 

2009). 

MDE. 1994. 1994 Maryland Specifications for Soil Erosion and Sediment Control. 

Water Management Administration, in association with the Soil Conservation 

Service and the State Soil Conservation Committee. 
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Maryland Department of Transportation. September 2009. Maryland Statewide Freight 

Plan. 

National Atlas. 2009. Overview of U.S. Freight Railroads. U.S. Department of the 

Interior. Web site - 

http://www.nationalatlas.gov/articles/transportation/a_freightrr.html. Accessed 

August 9, 2010. 

Ohio Department of Transportation (ODOT). May 2010. Ohio Statewide Rail Plan – 

Final Report. 

ODOT. April 2009. Environmental Site Assessment Guidelines. Office of 

Environmental Services, Columbus, Ohio. 

Ohio EPA. 1989. Qualitative Habitat Evaluation Index (QHEI): Rational, Methods and 

Application. Edward T. Rankin, Division of Surface Water, Columbus, Ohio. 

Pennsylvania Department of Transportation (Penn DOT). February 2010. 

Pennsylvania Intercity Passenger and Freight Rail Plan. 

Penn DOT. 2009. Grant Application for Transportation Investment Generating 

Economic Recovery for the National Gateway Project. 

U.S. Army Corps of Engineers. 2009. Interim Regional Supplement to the Corps of 

Engineers Wetland Delineation Manual: Northcentral and Northeast Region, 

ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-09-19. 

Vicksburg, MS: U.S. Army Engineer Research and Development Center. 

U. S. Army Corps of Engineers. 2008. Interim Regional Supplement to the Corps of 

Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain 

Region, ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-08-

30. Vicksburg, MS: U.S. Army Engineer Research and Development Center. 

U.S. Census Bureau. 2001. 1990 and 2000 Census Data. 

www.americanfactfinder.com. Accessed April through September 2009. 

U.S. Department of Agriculture (U.S. DA). 2009 and 2010. Natural Resources 

Conservation Service online Web Soil Survey at 

http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm. 
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U.S. Department of Transportation (U.S. DOT). Federal Highway Administration 

(FHWA). 2009. Impacts of Higher Fuel Costs by Dan Brand. In Innovations for 

Tomorrow’s Transportation; vol. 1. May 2009. 

U.S. DOT. FHWA. 2009b. Policies to Reduce Greenhouse Gas Emissions Associated 

with Freight Movements by Cristiano Façanha and Jeff Ang-Olson. In 

Innovations for Tomorrow’s Transportation; vol. 1; pgs 24-33. May 2009 

U.S. DOT. FHWA. 2006. Interim Guidance on Air Toxic Analysis in NEPA Documents. 

February 3. 

U.S. DOT. FHWA. 2006. Freight Analysis Framework (FAF) Version 2.2: Commodity 

Origin-Destination Database: 2002-2035. November 20. 

U.S. DOT. FHWA. 2005. HERS-ST, Highway Economic Requirements System – State 

Version, Technical Report. August. 

U.S. DOT. FHWA, Office of Environment and Planning. 1995. Highway Traffic Noise 

Analysis and Abatement Policy and Guidance. 

U.S. DOT. Office of the Secretary. 2010. Notice of Funding Availability for the 

Department of Transportation’s National Infrastructure Investments Under the 

Transportation, Housing and Urban Development, and Related Agencies 

Appropriations Act for 2010. Federal Register. Vol. 75, No. 104. June 1. 

U.S. Environmental Protection Agency (U.S. EPA). March 2010. Transportation 

Conformity Regulations. 40 CFR Parts 52 and 93. Transportation and 

Regional Programs Division, Office of Transportation and Air Quality. 

U.S. EPA. June 2009. The Green Book: Nonattainment Areas for Criteria Pollutants.

http://www.epa.gov/air/oaqps/greenbk/index.html. 

U.S. EPA. 2003. Technical Guidance on the Use of MOBILE6.2 for Emission Inventory 

Preparation. EPA420-R-04-013. August 2004. 

West Virginia Department of Environmental Protection (WVDEP). 2009. 8-Hour 

Nonattainment Areas website: 

(http://www.wvdep.org/item.cfm?ssid=8&ss1id=925). Accessed August 11, 

2009. 

WVDEP. Division of Water and Waste Management. 2008. West Virginia Integrated 

Water Quality Monitoring and Assessment Report. 
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WVDEP. 2008. DRAFT West Virginia 2008 Section 303(d) List. Division of Water and 

Waste Management. March 24, 2008. 

WVDEP. 2008 , Total Maximum Daily Loads for Selected Streams in the Potomac 

Direct Drains Watershed, West Virginia -- Final Approved Report. Division of 

Water and Waste Management, Watershed Branch, TMDL Section. January 

23, 2008. 

WVDEP. 2006. West Virginia 2006 Section 303(d) List and Supplements. Division of 

Water and Waste Management. Updated March 21, 2007. 

WVDEP. 2006. West Virginia Erosion and Sediment Control Best Management 

Practice Manual. Division of Water and Waste Management. 

West Virginia Department of Natural Resources (WVDNR). 2009. Rare, Threatened, 

and Endangered Species: website. 

http://www.wvdnr.gov/Wildlife/RETSpecies.asp). Accessed August 13, 2009. 

U.S. Executive Office of the President (U.S. EOP). Council of Economic Advisors. 

2009. Estimates of Job Creation from the American Recovery and 

Reinvestment Act of 2009. May. 

U.S. EOP. Office of Management and Budget (OMB). 2003. Regulatory Analysis. 

Circular A-4. September 17. 

U.S. EOP. OMB. 1992. Guidelines and Discount Rates for Benefit-Cost Analysis of 

Federal Programs. Circular A-94. October. 
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7. Acronyms 

ABCR Akron Barberton Cluster Railway 

ACHP Advisory Council on Historic Preservation 

ARRA American Recovery and Reinvestment Act 

B&O Baltimore and Ohio Railroad 

CAA Clean Air Act 

CE Categorical Exclusion 

CFR Code of Federal Regulations 

CSX CSX Transportation, Inc. 

DOT Department of Transportation 

EJGAT Environmental Justice Geographic Assessment Tool 

FHWA Federal Highway Administration 

FR Federal Register 

FRA Federal Railroad Administration 

GHG Greenhouse Gas 

HPI Historic Preservation Inventory 

LOD Limits of Disturbance 

M Maintenance Area 

MDE Maryland Department of Environment 

MDNR Maryland Department of Natural Resources 

MHT Maryland Historical Trust 

mm Millimeter 

MOU Memorandum of Understanding 
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NA Nonattainment 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act 

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service 

NOx Nitrogen Oxide 

NRHP National Register of Historic Places 

NS Norfolk Southern Corporation 

NSR New Source Review 

ODNR Ohio Department of Natural Resources 

ODOT Ohio Department of Transportation 

OES Office of Environmental Services 

OHPO Ohio Historic Preservation Office 

Penn DOT Pennsylvania Department of Transportation 

PHMC Pennsylvania Historical and Museum Commission 

P&LE Pittsburgh and Lake Erie Railroad 

PM Particulate Matter 

ROW Right of Way 

SHPO State Historic Preservation Office 

SIP State Implementation Plan 

SO2 Sulfur Dioxide 

SWPPP Storm Water Pollution Prevention Plan 

TAP Transportation Assistance Program 
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TIGER Transportation Investment Generating Economic Recovery 

URA Urban Redevelopment Authority of Pittsburgh 

U.S.ACE United States Army Corps of Engineers 

U.S. DOT United States Department of Transportation 

U.S.EPA United States Environmental Protection Agency 

U.S. FWS United States Fish and Wildlife Service 

VOCs Volatile Organic Compounds 

W&LE Wheeling and Lake Erie Railroad 

WVDCH West Virginia Division of Culture and History 

WVDNR West Virginia Division of Natural Resources