Paoli

Substation

Paoli Daylesford

Berwyn Devon

Strafford

Wayne St.ADavids Radnor

Norristown High Speed Line

476 BlueARoute

Villanova

Rosemont

Bryn

Mawr

BrynAMawr

Substation

Haverford

Ardmore

Wynnewood Narberth

Merion

Overbrook 32nd St. Bridge

Zoo

Substation

Finding of No Significant Impact

for,the Philadelphia,

_________________________________________________

Zoo,to,Paoli,Transmission,Line,Project

September 2017 July 2017
i

U.S. Department of Transportation, 

Federal Railroad Administration 

FINDING OF NO SIGNIFICANT IMPACT 

Philadelphia Zoo to Paoli Transmission Line Project 

Philadelphia, Montgomery, Delaware, and Chester Counties, Pennsylvania 

Table of Contents 

A. Introduction .............................................................................................................................................. 1

B. Purpose and Need ..................................................................................................................................... 2

C. Alternatives .............................................................................................................................................. 2

Proposed Action .................................................................................................................................... 2

No-Build Alternative ............................................................................................................................. 4

D. Environmental Consequences .................................................................................................................. 4

No-Build Alternative ............................................................................................................................. 4

Proposed Action .................................................................................................................................... 4

Location and Land Use ......................................................................................................................... 7

Cultural Resources ................................................................................................................................ 7

Parks and Wildlife Refuges ................................................................................................................... 8

Transportation ....................................................................................................................................... 8

Noise and Vibration .............................................................................................................................. 8

Electric/Magnetic Fields ....................................................................................................................... 9

Air Quality ............................................................................................................................................ 9

Hazardous Material and Waste ............................................................................................................. 9

Property Acquisitions and Easements ................................................................................................. 10

Communities ....................................................................................................................................... 10

Environmental Justice ......................................................................................................................... 10

Visual Effects ...................................................................................................................................... 11

Floodplains .......................................................................................................................................... 11

Water Quality ...................................................................................................................................... 12

Endangered Species ............................................................................................................................ 12

Public Safety ....................................................................................................................................... 12

Construction ........................................................................................................................................ 12

Indirect and Cumulative Impacts ........................................................................................................ 13

Final Section 4(f) Evaluation and Determination ............................................................................... 14

E. Public Involvement ................................................................................................................................. 15
Philadelphia Zoo to Paoli Transmission Line Project

 ii 

F. Agency and Public Comments ................................................................................................................ 17

G. Findings .................................................................................................................................................. 17

Appendices: 

Appendix A: Environmental Commitments 

Appendix B: Memorandum of Agreement 

Appendix C: Public Meeting Materials (May 4, 2017) 

Appendix D: Comments Received 

Appendix E: Response to Comments 
Finding of No Significant Impact 

 1 

A. INTRODUCTION

The Federal Railroad Administration (FRA) prepared an Environmental Assessment (EA) and draft 

Section 4(f) Evaluation in March 2017 to evaluate the potential environmental impacts for the 

Philadelphia Zoo to Paoli Transmission Line Project (Proposed Action). The Proposed Action includes 

improvements to the deteriorated electrification system along the portion of the Keystone Corridor East, a 

rail route owned by the National Railroad Passenger Corporation (Amtrak) extending from Philadelphia 

to Harrisburg, Pennsylvania. The Proposed Action involves an 18-mile portion of the Keystone Corridor 

East within the existing Amtrak right-of-way between the Zoo Substation (Mile Post 2.5) in central 

Philadelphia and the Paoli Substation in Chester County, PA (Mile Post 20.5), as seen in Figure 1. The 

Proposed Action would cross through Philadelphia, Montgomery, Delaware, and Chester counties in 

Pennsylvania (see Figure 2). Proposed improvements include the construction of new transmission lines, 

replacement of 276 deteriorated catenary structures and addition of 49 catenary structures, construction of 

one additional gantry at Paoli Substation, and replacement of the obsolete substation at Bryn Mawr. FRA 

is the lead federal agency and Amtrak is providing engineering designs, acting in coordination with FRA. 

Figure 1: Substations and Passenger Stations within the Proposed Action Route 

Figure 2: Municipalities within the Proposed Action Route 
Philadelphia Zoo to Paoli Transmission Line Project

 2 

Amtrak has proposed these improvements because the existing catenary structures are approaching 100 

years in age and are beyond their useful life. Additionally, trains experience low voltage conditions in the 

middle of the 18-mile stretch between Zoo Substation and Paoli Substation, as this is the only portion of 

the Keystone Corridor East that has not had a traction power upgrade. Low voltage conditions result in 

slower, less reliable operation, hence the proposed construction of two new traction power substation 

buildings to replace the existing Bryn Mawr Substation. Finally, the existing transmission lines that feed 

electrical power to Amtrak’s Keystone Corridor East overhead contact system are not located along 

Amtrak’s Keystone Corridor East right-of-way, but are located along another former Pennsylvania 

Railroad right-of-way. The other former Pennsylvania Railroad right-of-way is difficult for Amtrak 

maintenance crews to access. There are no public access points, and vegetation along this abandoned rail 

line is overgrown. 

FRA prepared the EA to comply with the National Environmental Policy Act (NEPA) of 1969 (42 USC § 

4321 et seq.). FRA makes this Finding of No Significant Impact (FONSI) based on the information in the 

EA in compliance with NEPA, FRA’s Procedures for Considering Environmental Impacts (64 FR 28545, 

May 26, 1999), and other related laws and regulations. 

FRA signed the EA on March 24, 2017, and made the document and associated technical reports available 

for public comment and review on April 13, 2017. The Project Team posted the EA to the project website 

at https://www.fra.dot.gov/Page/P0810; circulated electronic copies to a broad mailing list; and 

distributed hard copies to review agencies, local libraries, and municipal buildings. The public comment 

period for the EA closed on May 12, 2017. FRA incorporated comments received on the EA into this 

FONSI and its appendices, as applicable. 

B. PURPOSE AND NEED

The purpose of the Proposed Action is to maintain and improve passenger train service using electricpowered trains on the Keystone Corridor East between the Zoo Substation (Mile Post 2.5) in central 

Philadelphia and the Paoli Substation (Mile Post 20.5). In addition, a goal of the Proposed Action is to 

simplify maintenance, including maintenance access. The needs addressed by the Proposed Action 

include deteriorated catenary poles and related electrical equipment, insufficient traction power, and the 

location of transmission lines on another former Pennsylvania Railroad right-of-way that complicates 

maintenance of these lines. 

C. ALTERNATIVES

The Project Team identified the Preferred Alternative, referred to as the Proposed Action, through a 

rigorous alternatives development and screening process. In addition to the Proposed Action and the NoBuild Alternative, three other alternatives were considered but eliminated from detailed analysis (see 

Section 2.0 of the EA). FRA identified the Proposed Action as the only Build Alternative that would meet 

the stated purpose and need. 

Proposed Action

As discussed, based on the alternatives development and screening process, the Project Team retained one 

Build Alternative, the Proposed Action, for detailed study in the EA. FRA identified the Proposed Action 

as the Preferred Alternative. 

The Proposed Action involves improvements to the electrification system within the existing Amtrak 

right-of-way between the Zoo Substation and the Paoli Substation on the Keystone Corridor. Components 

include: 

 Construction of new 138 kilovolt transmission lines within Amtrak right-of-way to replace aging 

and inaccessible transmission lines that are not on Amtrak right-of-way. The power feed to the 
Finding of No Significant Impact 

 3 

existing transmission lines would be deactivated, but the existing infrastructure would not be 

physically altered. To be clear, this means no alteration or removal of existing facilities along the 

other former Pennsylvania Railroad right-of-way. 

 Replacement of 276 deteriorated catenary structures and construction of an additional 49 catenary 

structures within Amtrak right-of-way. The new catenary structures would carry both the catenary 

lines and the new transmission lines. The existing catenary structures consist of a pair of vertical 

poles on the field side of the outermost track that are joined together by wire head-spans. Only the 

catenary poles and head-spans would be replaced, because the existing overhead contact system is 

in good condition. An approximately 15-foot increase in catenary pole height is necessary to 

accommodate the new Amtrak transmission line and meet Amtrak and National Electric Safety 

Code required clearances. The 276 existing catenary structures would be replaced within 10 feet 

of their current locations, and 49 additional catenary structures would also be added at new 

locations for a proposed total of 325 catenary structures. The additional 49 structures are needed 

to reduce spacing, to avoid station canopies, and to add catenary structures adjacent to overhead 

bridges where there are currently none. 

 Construction of an additional gantry (a structural framework for supporting high-voltage 

switches) at Paoli Substation. 

 Demolition of the obsolete Bryn Mawr Substation and construction of two new traction power 

substation buildings on a footprint roughly 7,000 square feet larger than the current footprint, as 

seen in Figure 3. 

Figure 3: Bryn Mawr Substation Footprint 
Philadelphia Zoo to Paoli Transmission Line Project

 4 

No‐Build Alternative

Under the No-Build Alternative, no catenary structures, catenary wires, and transmission lines would be 

upgraded. The existing Bryn Mawr Substation would be left standing without upgrades. There would be 

no change to the transmission lines within the other former Pennsylvania Railroad right-of-way. 

The No-Build Alternative involves risks, including a breakdown of the system and loss of service, as the 

catenary structures, catenary wires, and transmission lines are showing signs of substantial deterioration 

and frequently require extensive repairs that increase safety risk for Amtrak’s maintenance crews. Amtrak 

and the Southeastern Pennsylvania Transportation Authority (SEPTA), which both operate over this 

segment, would still experience low-voltage conditions in the middle section, which would likely worsen 

over time. 

D. ENVIRONMENTAL CONSEQUENCES

No‐Build Alternative

In the short term, the No-Build Alternative would not adversely affect the existing social, economic, or 

environmental conditions in the Proposed Action study area. 

In the long term, if left unaddressed, the catenary poles and related electrical equipment would continue to 

deteriorate, with breakdowns of the system and loss of service becoming more frequent. The No-Build 

Alternative would not provide any transportation benefits or meet the purpose and need of this Proposed 

Action. 

Proposed Action

Based upon the EA, FRA has concluded that the Proposed Action, including mitigation measures, is not 

likely to result in significant adverse environmental impacts. The potential for environmental impacts 

with the Proposed Action is summarized for each resource category and outlined in Table 1. All 

associated environmental commitments are outlined in Appendix A. 
Finding of No Significant Impact 

 5 

 Table 1: Proposed Action Impact Summary 

Resource Effects 

Location and Land 

Use  No right-of-way acquisitions, or changes to land use type or zoning would be 

required 

Cultural 

Resources 

 Would not impact any known National Register of Historic Places (NRHP) -

listed or -eligible archaeological properties 

 No Historic Properties Affected for 16 historic properties 

 No Adverse Effect on ten (10) historic properties 

 Adverse Effect on one (1) historic property 

 Memorandum of Agreement (MOA) developed to implement mitigation 

measures 

Parks and Wildlife 

Refuges  No temporary occupancy, permanent occupancy, or severe proximity impacts 

to the three publicly-owned parks and one publicly owned wildlife refuge 

Transportation 

 Improvements to rail service reliability resulting from an upgraded energy 

supply system 

 Permanent loss of 12 parking spaces from Bryn Mawr Substation replacement

 No impacts to bus, bicycle, or pedestrian access and use 

Noise and 

Vibration  No change in train speed, rail line alignments, or type of train 

 No new noise and vibration impacts anticipated 

Electric/Magnetic 

Fields 

 Proposed electric and magnetic levels would be less than 10% of the level 

warranting concern, per the International Commission on Non‐Ionizing 

Radiation Protection (ICNIRP) 

Air Quality  No impacts to air quality anticipated 

Hazardous 

Materials and 

Waste 

 No impacts from hazardous materials or wastes anticipated 

 Procedures for testing and draining transformers prior to disposal are in place 

 Procedures for managing excavated soil within areas of environmental 

concern are detailed in a Soil Management Plan 

Property 

Acquisitions and 

Easements 

 Permanent property acquisition or temporary construction easements are not 

required 

Communities  No major impacts to communities anticipated 

 Transit-oriented development could potentially increase as an indirect impact, 

potentially improving local economic vitality 

Environmental 

Justice 

 No disproportionately high impacts to minority or low-income populations, 

because all populations along the corridor would experience similar impacts 

 No variances in the receipt of Proposed Actions benefits 

Visual 

 Impacts of replacing historic Bryn Mawr Substation to be mitigated by 

incorporating characteristics of the original substation into the new design. 

 Increased catenary structure height minimized during design 

 Construction tree trimming plans and design modifications minimize impact 

of tree trimming/removal (all within Amtrak right-of-way) where trees would 

interfere with construction 
Philadelphia Zoo to Paoli Transmission Line Project

 6 

 Table 1: Proposed Action Impact Summary 

Resource Effects 

Floodplains  No impacts on floodplains or floodways 

Water Quality  No direct impacts to waterways; no construction within waterways is required 

 Erosion and sedimentation during construction would be minimized 

Endangered 

Species 

 No impacts to threatened and endangered species anticipated 

 If applicable, FRA and the Project Team would update the coordination prior 

to construction 

Public Safety  Standard precautions to prevent the public from entering Amtrak right-of-way

 A Soil Management Plan specifies waste management procedures and worker 

health and safety precautions in areas of environmental concern 

Construction 

 Most construction would be completed during temporary, overnight track 

outages, so no significant traffic or rail service impacts expected 

 Temporary construction easements not necessary 

 Temporary exhaust emissions and airborne dust from construction 

 Community Notification Plan would be developed and implemented to 

communicate construction timing and phasing to the community 

 Amtrak would follow the U.S. Environmental Protection Agency (U.S. EPA) 

restrictions if they use the Paoli Railyard Superfund site for a construction 

stockpile/staging area 

 Best management practices concerning noise, vibration, light emissions, and 

dust control would be followed 

 Minimal earth disturbance expected (other than Bryn Mawr substation) 

 Tree trimming/removal within existing Amtrak right-of-way 

 Permit to minimize erosion, sedimentation, and infiltration impacts 

 An Unanticipated Discoveries Plan and a Soil Management Plan have been 

created in case archaeological resources or contaminated soils are encountered 

Indirect and 

Cumulative 

Impacts 

 Improvements to service reliability could result in increased ridership and 

transit-oriented development. Positive transportation and economic 

development impacts could potentially result. 

Section 4(f) 

 No Section 4(f) use of the three publicly-owned parks and one publicly owned 

wildlife refuge 

 No Section 4(f) use of 21 historic resources 

 De minimis use for five (5) historic resources 

 Section 4(f) use of the Pennsylvania Railroad Main Line, due to replacement 

of catenary structures and demolition of the Bryn Mawr Substation 

 Avoidance alternatives and measures to minimize harm were considered as 

part of the Section 4(f) process, but analysis determined that there are no 

feasible and prudent avoidance alternatives 

 All possible planning to minimize harm incorporated into the Proposed Action

to preserve the historic attributes of the railroad 
Finding of No Significant Impact 

 7 

Location and Land Use

The Proposed Action spans 18 miles along Amtrak’s right-of-way between the Philadelphia Zoo 

Substation (Mile Post 2.5) in central Philadelphia and the Paoli Substation (Mile Post 20.5). As shown in 

Figure 2, this route passes through the City of Philadelphia (Philadelphia County), Lower Merion 

Township (Montgomery County), Narberth Borough (Montgomery County), Haverford Township 

(Delaware County), Radnor Township (Delaware County), Tredyffrin Township (Chester County), 

Easttown Township (Chester County), and Willistown Township (Chester County). 

The Proposed Action passes through developed land consisting of urban and suburban uses. The majority 

of the surrounding land uses include residential and commercial properties, but several schools, 

universities, public parks, and one wildlife refuge are adjacent to the Amtrak right-of-way. In some cases, 

these residences and other facilities are as close as 100 feet (unobstructed by buildings) from the Proposed 

Action area. The Proposed Action is located within an existing railroad corridor, and all construction 

would occur in the existing Amtrak right-of-way. The Proposed Action does not require any right-of-way 

acquisitions, or changes to land use type or zoning. Accordingly, FRA anticipates that the Proposed 

Action would not impact current land use. 

Cultural Resources

The Area of Potential Effects (APE) for archaeology was defined as the area in which the proposed 

construction activities may disturb existing soils and landforms and was contained within existing railroad 

right-of-way. One previously recorded historic archaeological site noted as adjacent to the existing 

Proposed Action right-of-way was field checked and determined to be located entirely outside the current 

APE. No other areas suitable for subsurface testing were found within the APE for archaeology. In 

consultation with the PA State Historic Preservation Office (PA SHPO), FRA determined that the 

Proposed Action would not impact any known NRHP-listed or -eligible archaeological properties. An 

Unanticipated Discoveries Plan has been appended to the MOA and stipulates that in the event that 

unanticipated archaeological resources are encountered during construction, Amtrak would cease work in 

the affected area and PA SHPO and FRA would be notified immediately. 

FRA delineated the APE for historic resources to include properties for which there could be potential 

direct physical effects from the proposed construction work and properties for which there could be 

potential indirect effects (primarily visual) on historic properties. Desktop research and field survey 

identified 27 individually NRHP-eligible or -listed resources located within the APE. The assessment of 

effects resulted in a finding of: 

 No Historic Properties Affected for sixteen (16) historic properties 

 No Adverse Effect on ten (10) historic properties 

 Adverse Effect on one (1) historic property 

Amtrak has incorporated Consulting Party feedback into the Proposed Action to minimize effects, 

including keeping the height of the new catenary structures as low as possible while meeting electrical 

code requirements, locating new catenary structures near the existing ones, and producing tree trimming 

plans to indicate locations where overhanging tree limbs within the right-of-way would be trimmed to 

enable catenary structure replacement. However, the Proposed Action would still have an adverse effect 

on the NR-eligible Pennsylvania Railroad Main Line (Philadelphia to Harrisburg) due to the removal and 

replacement of the catenary structures and the demolition of the Bryn Mawr Substation. 

A MOA has been developed between the FRA, Amtrak, Railroad Museum of Pennsylvania, SEPTA, and 

the PA SHPO, which includes FRA and Amtrak’s commitments to minimization and mitigation measures 
Philadelphia Zoo to Paoli Transmission Line Project

 8 

for potential adverse effects to the Pennsylvania Railroad Main Line and its contributing resources. The 

MOA is included as Appendix B. 

FRA anticipates that the resulting Proposed Action effects would not be significant. 

Parks and Wildlife Refuges

There are three publicly-owned parks and one publicly-owned wildlife refuge located adjacent to the 

Proposed Action area. The Merion Botanical Park (Mile Post 5.8) is located in Lower Merion Township, 

and Narberth Playground (Mile Post 7.1) is located in Narberth Borough, both owned by their respective 

municipalities. North Wayne Park (Mile Post 14.7) is owned by Radnor Township School District, but 

leased to Radnor Township. The Sharpe Park and Bird Sanctuary (Mile Post 9.2) is located in Lower 

Merion Township and is owned by the township. 

There would be no temporary, permanent, or constructive use of the public parks or the public wildlife 

refuge resulting from temporary occupancy, permanent incorporation, or proximity impacts so severe that 

the protected activities, features, or attributes of the property would be substantially impaired. The 

Proposed Action is not anticipated to interfere with any current use of the parks/refuges and therefore the 

Proposed Action would not result in significant impacts to parks or refuges. 

Transportation

The Proposed Action area is comprised of an 18-mile-long section of Amtrak’s Keystone Corridor East 

and SEPTA’s Paoli/Thorndale Regional Rail Line. The rail line contains 15 SEPTA stations, one Amtrak 

station, and one joint SEPTA-Amtrak station. Currently, the Bryn Mawr Station is not a stop for Amtrak, 

but it is a stop on SEPTA’s Paoli/Thorndale Regional Rail Line. According to SEPTA’s website, the Bryn 

Mawr Station has 46 daily parking spaces (full), 153 monthly permit spaces (full), and 55 spaces in the 

Lower Merion Municipal Parking Lot (not full, 45 available). All three lots are paid parking. 

Replacement of the Bryn Mawr Substation would affect parking that Amtrak leases to SEPTA at the Bryn 

Mawr Train Station. Impact avoidance is not feasible, so the impact would be minimized by designing the 

substation to have the smallest possible footprint without losing the intended functionality. While this 

compact substation design would result in higher construction costs, it would reduce the number of 

affected parking spaces from 36 to 12. 

Rail service would be improved by the Proposed Action. The installation of a more reliable energy 

supply would upgrade traction power and reduce the occurrence of low voltage conditions along the rail 

corridor. The improved service reliability could have an indirect impact of increasing ridership on the 

Keystone Corridor. In turn, additional train ridership could increase use of parking and roadways near 

train stations, while reducing vehicular traffic on arterial roadways. The Proposed Action would not 

include an increase in the speed or frequency of trains. 

FRA does not consider the impacts to parking and rail service to be significant. No impacts to bus, 

bicycle, or pedestrian access and use are anticipated, including at the Bryn Mawr Station parking lot. 

Noise and Vibration		

Sensitive receptors (such as residences, parks, one wildlife refuge, churches, and schools) are present 

adjacent to the rail corridor along much of the Proposed Action area. Some sensitive receptors are as close 

as 100 feet (unobstructed by buildings) to the Proposed Action area. According to Amtrak’s track charts, 

the maximum allowable speed between Mile Post 2.5 and Mile Post 20.2 varies between 30 mph and 80 

mph. The maximum allowable speed between Mile Post 20.2 and 20.5 is 90 mph. 

The Proposed Action would not increase maximum allowable train speeds, change the type of train, or 

shift rail lines. The proposed upgrades to the electrification system, all within the existing Amtrak right-
Finding of No Significant Impact 

 9 

of-way, would not affect rail traffic noise and/or vibration levels throughout the Proposed Action area. 

Therefore, the Proposed Action would not have any long-term noise and vibration impacts. 

Electric/Magnetic Fields

Land uses with sensitivity to electric and magnetic fields are present along the Proposed Action corridor. 

Residences are present adjacent to the rail corridor along much of the Proposed Action area, some as 

close as 100 feet (unobstructed by buildings) to the Proposed Action area. Facilities with sensitive 

medical equipment are also located near the Proposed Action area. 

To evaluate electric and magnetic field impacts associated with the Proposed Action, AECOM Energy 

produced a “Report on Electric, Magnetic Fields and Radio Noise Along the Zoo-Paoli Rail Line” 

(October 21, 2011), in association with Burns Engineering. This study is appended to the EA. Based on 

modeling and a comprehensive review of the available scientific and medical literature, the study 

concluded that the fields expected from the Proposed Action would be below any level that is of concern. 

Table 2 summarizes the findings of the study. 

FRA anticipates that the resulting Proposed Action effects would not be significant. 

Table 2: Electric and Magnetic Fields 

Field Existing Level Proposed Level Level Warranting Concern 

Electric 500 V/m (at 25 Hz) 804 V/m (at 25 Hz) 10,000 V/m (at 25-60 Hz) 

Magnetic 24 mG (at 25 Hz) 65 mG (at 25 Hz) 2,000 mG (at 25-60 Hz) 

Air Quality

All counties within the Proposed Action area are in attainment for all NAAQS criteria pollutants, with the 

following exceptions: 

Non-attainment areas: 

 Particulate matter (PM-2.5) (Delaware County) 

 Ozone (Philadelphia, Montgomery, Delaware, and Chester counties) 

Maintenance areas: 

 Carbon monoxide (Philadelphia County) 

No impacts to air quality are anticipated from operation of the new Bryn Mawr Substation and new 

transmission lines or from the replacement of deteriorated catenary structures within existing Amtrak 

right-of-way. 

Hazardous Material and Waste

The Proposed Action would involve the use or handling of hazardous materials. Old electrical 

transformers, which may contain polychlorinated biphenyl (PCB) oil, would be removed and replaced as 

part of the Proposed Action. Amtrak has established procedures for testing and draining transformers 

prior to disposal. Amtrak also maintains contracts with multiple firms for emergency response and waste 

hauling services. 

Additionally, the area near the Paoli Substation is part of the Paoli Railyard Superfund site. If Amtrak 

chooses to use this site for a construction stockpile/staging area, then Amtrak would need to coordinate 

with U.S. EPA and to follow their restrictions. 
Philadelphia Zoo to Paoli Transmission Line Project

 10 

As a precaution, in case hazardous waste is encountered at any location within the Proposed Action area 

during construction, a Soil Management Plan has been developed. The Soil Management Plan specifies 

waste management procedures and precautions for construction in areas of environmental concern within 

the construction zone. 

With the appropriate measures/coordination specified above, FRA does not anticipate the Proposed 

Action would result in significant impacts related to hazardous material or waste. 

Property Acquisitions and Easements

The Proposed Action would not require permanent property acquisition or temporary construction 

easements. 

Communities

The Proposed Action area passes through developed land consisting of urban and suburban uses. Most of 

the surrounding land uses include residential and commercial properties, but several schools, universities, 

public parks, and one wildlife refuge are next to the Amtrak right-of-way. In some cases, these residences 

and other facilities are as close as 100 feet (unobstructed by buildings) from the Proposed Action area. 

The Project Team considered community impacts in terms of the potential for destruction or disruption of 

community cohesion, economic vitality, and the availability of public or private facilities or services. 

Since no property acquisition or changes in vehicular or pedestrian access would occur, the Proposed 

Action would not displace or segment any communities and therefore would not affect community 

cohesion. Businesses would not be displaced and transit-oriented development could potentially increase 

as an indirect impact of the Proposed Action, which could potentially improve economic vitality for 

communities with train stations in the Proposed Action area. Because the Proposed Action would not 

increase service but only service quality, the potential for increased transit-oriented development is not 

anticipated to be significant. Accordingly, no significant impacts on communities are anticipated. 

Environmental Justice

The Proposed Action was designed to avoid disproportionately high and adverse human health and 

environmental effects, including social and economic effects on minority and low income populations. 

Communication and outreach about the Proposed Action was designed to ensure full and fair participation 

by all potentially affected communities in the transportation decision making process and to prevent the 

denial of, reduction in, or delay in the receipt of benefits by minority and low-income populations. 

The Proposed Action would cross through areas with above-average levels of minority and low income 

populations according to U.S. Census Bureau data from the 2010 American Community Survey. These 

populations are most evident where the Proposed Action affects census tracts in the City of Philadelphia, 

where minorities comprise 40-100% of the total population and poverty rates rise to 10-100%. However, 

there would be no disproportionately high impacts to minority or low-income populations, because all 

populations along the Proposed Action corridor would experience similar impacts (primarily minor, 

visual impacts). 

Likewise, there would be no variances in the receipt of benefits across populations, as all Amtrak and 

SEPTA users would benefit equally from the Proposed Action. Outreach efforts for all affected 

populations are detailed in Section E. Public Involvement. 

No significant, negative impacts on environmental justice populations are anticipated. 
Finding of No Significant Impact 

 11 

Visual Effects

The Proposed Action area passes through developed land consisting of urban and suburban uses. The 

majority of the surrounding land uses include residential and commercial properties, but several schools, 

universities, public parks, and one wildlife refuge are also adjacent to the Amtrak right-of-way. The 

buildings in the vicinity of the Bryn Mawr Substation appear to be commercial use. 

Visual impacts caused by taller catenary poles, tree trimming, and the replacement of the Bryn Mawr 

Substation were identified as concerns during the public involvement process. The majority of the 

existing catenary poles are approximately 45 to 55 feet in height, while the majority of the proposed new 

catenary poles would be between 60 and 75 feet high. The catenary structures at overhead bridges would 

require an increased height, ranging between 82 feet and 95 feet. Trees line a majority of the Proposed 

Action corridor, and selected trees within existing Amtrak right-of-way would be trimmed or potentially 

removed where they would interfere with construction work. 

As for visual impacts to historic resources, the catenary poles and tree trimming would not introduce 

visual elements that would diminish the integrity of the property’s significant historic features. The 

Proposed Action would, however, remove historic catenary poles, demolish the existing Bryn Mawr 

Substation (a contributing resource) and introduce a new substation that would diminish the integrity of 

the setting and feeling of the railroad property at Bryn Mawr. Additionally, residences, parks, and a 

wildlife refuge would experience minor visual impacts from the increase in catenary structure height and 

the tree trimming. 

While the MOA adopted under Section 106 serves to minimize and mitigate potential impacts to cultural 

resources, some of the same MOA minimization and mitigation measures serve to minimize and mitigate 

visual impacts. These minimization measures include: 

 Limiting catenary structure heights (60-75 feet at most locations); 

 Targeting tree trimming to avoid universal trimming or clear cutting; 

 Locating new catenary structures as near as practicable to existing catenary structures; 

 Designing the new Bryn Mawr Substation consistent with the materials, color, and texture of the 

existing Bryn Mawr Substation (e.g. buff brick exterior walls), but not mimicking the existing 

historic building to make it clear that the new buildings are non-historic and do not create a false 

sense of history; and 

 Including an arborist on the construction team to direct trimming activities. 

With the implementation of these minimization measures, FRA believes the Proposed Action would 

result in minimal impacts on visual resources. 

Floodplains

There is one location within the corridor where the rail line crosses the 1-percent-annual-chance 

floodplain (Zone A floodplain without base flood elevations). 

This floodplain is associated with the East Branch Indian Creek in Montgomery County, around Mile 

Post 7.1, where the creek travels under the rail line via a culvert. Additionally, Hardings Run crosses 

through a culvert underneath the Proposed Action area within Delaware County around Mile Post 12.5 

but does not have a Federal Emergency Management Agency (FEMA)-designated floodplain. 

The proposed improvements do not include the widening of existing railroad embankments, placement of 

fill or catenary structures within floodplains, or new or modified stream and floodplain crossings. The rail 

line is on a tall, steep embankment in the vicinity of the Zone A floodplain associated with East Branch 
Philadelphia Zoo to Paoli Transmission Line Project

 12 

Indian Creek, and neither existing catenary structures nor proposed catenary structures would be located 

in the FEMA-designated floodplain. Therefore, the Proposed Action would have no direct or indirect 

permanent or temporary impacts on FEMA mapped floodplains or regulatory floodways. 

Water Quality

East Branch Indian Creek passes through a culvert below the Proposed Action area within Montgomery 

County around Mile Post 7.1 and is a designated Warm Water Fishes stream. Hardings Run is a 

designated Cold Water Fishes stream, which crosses through a culvert below the Proposed Action area 

within Delaware County around Mile Post 12.5. There would be no direct impacts to these waterways, 

because there would be no construction within waterways. Impacts caused by erosion and sedimentation 

during construction activities and/or changes to infiltration, would be minimized through the 

implementation of an Erosion and Sediment Control Plan (ESCP) or National Pollutant Discharge 

Elimination System (NPDES) Permit, as applicable. Accordingly, FRA does not anticipate that the 

Proposed Action would have any significant impacts to water quality. 

Endangered Species

The PA Game Commission, PA Department of Conservation and Natural Resources, and the PA Fish and 

Boat Commission indicated that threatened and endangered species are in the vicinity of the Proposed 

Action area, but that no threatened and endangered species are within the Proposed Action area. The U.S. 

Fish and Wildlife Service (USFWS) indicated that no federally listed species under USFWS jurisdiction 

are known or likely to occur in the Proposed Action area. All four agencies indicated that no impacts to 

threatened and endangered species are anticipated; therefore, FRA concludes that the Proposed Action 

would not result in significant impacts to threatened or endangered species. 

The determinations from PA Game Commission, PA Department of Conservation and Natural Resources, 

PA Fish and Boat Commission, and USFWS are valid for two years from the date of response, with all 

responses dated August or September 2016. If necessary, FRA and the Project Team will update these 

clearances prior to construction. 

Public Safety

The Proposed Action would occur within existing Amtrak right-of-way, and safety would be maintained 

through the standard regulations and precautions taken to prevent the public from entering the right-ofway during both construction and operation of the upgraded catenary system. Additionally, a Soil 

Management Plan was developed to specify waste management procedures and worker health and safety 

precautions for construction in areas of environmental concern within the construction zone. 

No negative impacts to public safety are anticipated. 

Construction

Depending on funding availability, construction may take place between Fall 2018 to Fall 2023. 

The Proposed Action will likely be completed in three phases, potentially starting with the Bryn Mawr 

Substation, followed by the transmission line between Paoli and Bryn Mawr, and finally the transmission 

line between Bryn Mawr and Zoo. 

The construction of the new Bryn Mawr Substation would be continuous and would take approximately 

18 months. 

The catenary structure replacements would be rolled out along the rail line. At each new structure 

location, it would take a few days or nights for foundation construction and then, later, a few nights for 

erection of the structures. These two activities could be weeks or months apart depending on track time 
Finding of No Significant Impact 

 13 

and final construction schedule. After all new structures are in place, a wire train would work its way 

along the route, detaching the overhead contact system from the old structures and attaching it to the new 

structures. The wire train would be able to cover multiple spans per day or night shift. 

A similar process would occur for the installation of the new transmission line, which would also cover 

ground at a rate of multiple spans per shift. The old steel poles would then be torched at the base or in 

sections from the top down, and the foundations left in place. 

Amtrak would develop and implement a Community Notification Plan to communicate construction 

timing and phasing to the community well in advance of any construction activities. 

All construction would occur in the existing Amtrak right-of-way, so permanent right-of-way acquisition 

would not be necessary. Temporary construction easements would not be necessary for stockpiling, 

staging, or access. 

Potential transportation impacts during construction would be minor. No parking spaces would be utilized 

during construction for construction stockpiling or by construction vehicles. Track-mounted equipment 

would be used for the catenary structure replacements, and traditional wheel-mounted construction 

equipment would be used only for the Bryn Mawr Substation replacement. Therefore, traffic from 

construction vehicles would result in minor disruption at Bryn Mawr, but no significant effect. Impacts to 

rail service would also be minimized. If track time is available, some work may be completed during the 

day, but most construction would be completed during temporary, overnight track outages. The impacts to 

parking and rail service are considered minor. No impacts to bus, bicycle, or pedestrian access and use are 

anticipated during construction, including at the Bryn Mawr Station parking lot. 

During construction, Amtrak would be responsible for conforming to all applicable best management 

practices concerning construction activities including, noise, vibration, light emissions, and dust control. 

Track-mounted equipment would be used for the catenary structure replacements, which would prevent 

vibrations that traditional wheel-mounted construction equipment creates when driving past residences. 

Blasting would not be allowed. 

Construction may temporarily result in exhaust emissions of particulate matter and nitrogen oxides, in 

addition to generation of airborne dust. Except for the work at Bryn Mawr substation, minimal earth 

disturbance and dust is expected. It is not anticipated that the construction would cause violations of the 

NAAQS or exceed the general conformity de minimis levels. 

No trees outside Amtrak right-of-way would be removed or trimmed as part of the Proposed Action. 

However, selected trees within existing Amtrak right-of-way would be trimmed or potentially removed 

where they would interfere with construction work. Tree trimming plans were generated by the design 

team in order to minimize impacts and illustrate the minimum amount of tree trimming required prior to 

constructing the Proposed Action. The construction team will also include an arborist to direct trimming 

activities. 

Impacts caused by erosion and sedimentation during construction activities and/or changes to infiltration, 

would be minimized through the implementation of an ESCP or NPDES Permit, as applicable. 

FRA concludes that construction impacts related to the Proposed Action would not be significant. 

Indirect and Cumulative Impacts

The Proposed Action’s improvements would improve service reliability and could have an indirect impact 

of increasing ridership on the Keystone Corridor. Additional ridership could increase use of parking and 

roadways near train stations. An increase in train ridership could also reduce vehicular traffic on arterial 

roadways with corresponding benefits by reducing traffic congestion and gasoline consumption. 
Philadelphia Zoo to Paoli Transmission Line Project

 14 

The Proposed Action could also indirectly cause expansion in transit-oriented development around train 

stations with strong ridership. Some of the stations are already in highly developed areas, while others 

currently have green space in the immediate vicinity. Local review boards would assess potential 

environmental impacts related to any new development on land use, water, sewer, and traffic. Because the 

Proposed Action would not increase service but only service quality, the potential for increased transitoriented development is not anticipated to be significant. 

Several rail projects have been recently completed or are underway throughout Amtrak's Keystone 

Corridor East (Philadelphia to Harrisburg). Infrastructure, signal system, at-grade crossing, interlocking, 

and Philadelphia Zoo to Paoli Transmission Line projects would improve reliability, speed, and/or safety 

on the Keystone Corridor East (Philadelphia to Harrisburg). The station projects will bring facilities into 

Americans with Disabilities Act compliance and will enhance customer amenities. These improvements 

are expected to encourage the transit-oriented development already occurring around stations and to 

increase ridership. These projects, including the proposed Philadelphia Zoo to Paoli Transmission Line 

Project, are anticipated to have positive cumulative transportation and economic development impacts. 

A NEPA document, or the state equivalent, was completed or will be required for each of the abovereferenced projects. This process requires that any adverse impacts be considered and minimized and 

mitigated, to the extent possible. Therefore, it is concluded that any adverse cumulative impacts from 

these projects on Amtrak's Keystone Corridor East will be minor. 

Final Section 4(f) Evaluation and Determination

The EA included a Draft Section 4(f) Evaluation, pursuant to the requirements of Section 4(f) of the U.S. 

Department of Transportation (USDOT) Act of 1966.1

 FRA did not receive any comments on the Draft 

Section 4(f) Evaluation following release of the EA and, as discussed below, received concurrence on its 

analysis from relevant entities. Accordingly, FRA incorporates by reference the analysis included in the 

Draft Section 4(f) Evaluation and deems this analysis the Final Section 4(f) Evaluation for the Proposed 

Action. Based on this Evaluation, FRA makes the following determination: 

FRA determines that the Proposed Action would not result in any temporary, permanent, or constructive 

use of public parks or public wildlife refuges resulting from temporary occupancy, permanent 

incorporation or easement, or proximity impacts so severe that the protected activities, features, or 

attributes of the property are substantially impaired. 

FRA determines that the removal and replacement of the catenary structures and the demolition of the 

Bryn Mawr Substation would cause a use of the Pennsylvania Railroad Main Line Historic District. 

Through Section 106 consultation, FRA made a finding of adverse effect for the Pennsylvania Railroad 

Main Line Historic District due to the removal and replacement of the catenary structures and the 

demolition of the Bryn Mawr Substation, both of which are contributing resources to the district. PA 

SHPO has concurred with this finding. Because the Proposed Action would result in a use of the 

Pennsylvania Railroad Main Line, avoidance alternatives and measures to minimize harm were 

considered as part of the Draft Section 4(f) Evaluation. The analysis indicated that there are no feasible 

and prudent avoidance alternatives, but all possible planning to minimize harm would be incorporated 

into the Proposed Action to preserve the historic attributes of the railroad. FRA and the official with 

jurisdiction over the Section 4(f) resource (the PA SHPO) have agreed to measures to minimize harm in 

accordance with the consultation process under 36 CFR Part 800. The U.S. Department of Interior 

 

1

 In 1983, Section 4(f) of the USDOT Act was codified as 49 U.S.C. § 303(c), but this law is still 

commonly referred to as Section 4(f). 
Finding of No Significant Impact 

 15 

provided concurrence on June 14, 2017. Therefore, FRA determines that there is no feasible and prudent 

alternatives that would avoid use of all Section 4(f) resources and the Proposed Action includes all 

possible planning to minimize harm. 

In addition, FRA determines that the Section 4(f) use of five individually eligible or listed historic 

resources (Merion Station, Haverford Station, Villanova Station, Wayne Station, and Strafford Station) 

would result in de minimis impacts. The PA SHPO concurred with FRA’s Section 106 finding of no 

adverse effect on these five historic properties within the boundaries of the Proposed Action work area. 

Consulting Parties were involved in the effects determination. FRA made this de minimis impact 

determination after providing the opportunity for review through the Section 106 process. PA SHPO 

concurred with this Section 4(f) de minimis use finding on March 7, 2017, and the U.S. Department of 

Interior concurred with this finding on June 14, 2017. 

PA SHPO also concurred with FRA’s finding of no adverse effect on an additional 5 historic properties 

and no historic properties affected for 16 historic properties, all outside of the Proposed Action work area. 

There is no Section 4(f) use of these 5 resources with findings of no adverse effect or the 16 historic 

properties with findings of no historic properties affected, because these properties are outside of the 

Proposed Action work area. 

E. PUBLIC INVOLVEMENT		

The Project Team has undertaken public and community outreach efforts for the Proposed Action, along 

with federal, state, and local agency coordination. Numerous meetings informed the public, stakeholders 

and agencies about Proposed Action milestones and sought public and agency input. The Project Team 

created a website for the Proposed Action: https://www.fra.dot.gov/Page/P0810. Public notices, 

postcards, and email blasts notified stakeholders prior to public outreach information sessions. All 

meetings included an opportunity for attendees to comment on the Proposed Action and ask questions of 

the Project Team. Table 3 outlines all public involvement and Section 106 meetings and their purpose: 

Table 3: Public Involvement and Section 106 Meetings 

Date Event Purpose 

4/25/2012 Public Officials and 

Stakeholders Meeting 

Introduce the Proposed Action, discuss and receive 

input on the Proposed Action from the community. 

4/30/2012 Public Officials and 

Stakeholders Meeting 

Introduce the Proposed Action, discuss and receive 

input on the Proposed Action from the community. 

6/6/2012 General Public Meeting Introduce the Proposed Action, discuss and receive 

input on the Proposed Action from the general public. 

5/28/2013 Public Officials and 

Stakeholders Meeting 

Inform attending parties of Proposed Action summary, 

status, and updates. 

5/29/2013 Public Officials and 

Stakeholders Meeting 

Inform the public of Proposed Action summary, status, 

and updates. 

6/6/2013 General Public Meeting Inform the general public of Proposed Action 

summary, status, and updates. 

6/6/2013 Section 106 Consulting 

Parties Meeting #1 

Review and discuss archaeology investigation, historic 

resources data collection, and mitigation options. 
Philadelphia Zoo to Paoli Transmission Line Project

 16 

Table 3: Public Involvement and Section 106 Meetings 

Date Event Purpose 

9/15/2014 Section 106 Consulting 

Parties Meeting #2 

Review and discuss revised APE, eligibility, and 

potential effects. 

6/1/2015 Section 106 Consulting 

Parties Meeting #3 

Provide an update of the Final Determination of 

Eligibility report, discuss the Draft Determination of 

Effects Report, and discuss potential mitigation options 

for impacts to historic resources. 

8/14/2015 Public access provided to 

cultural resources reports 

Publish draft Determination of Effects report and draft 

MOA, and notify consulting parties of document 

availability for review and comment. 

9/2/2015 HARB/ Section 106 

Consulting Parties Meeting #4 

Review and discuss the Draft MOA. 

7/20/2016 Public access provided to 

cultural resources reports 

Publish the Effects Report and the Addendum to the 

Effects Report on the FRA website for public access. 

4/13/2017 Public access provided to the 

EA and Draft Section 4(f) 

Evaluation 

Publish the EA and Draft Section 4(f) Evaluation on 

the FRA website and post hard copies for public 

access. The EA included the revised draft MOA. 

Distribute notices of EA and Draft Section 4(f) 

Evaluation and public meeting to Consulting Parties, 

Tribes, stakeholders, and the general public. 

5/4/2017 Public Meeting Present the EA and Draft Section 4(f) Evaluation to the 

public and provide opportunity for comment. 

In addition to notifying the public, the Project Team sent letters to elected officials with constituents 

within the Proposed Action study area to inform them of project updates and meetings. 

The EA was available for public review and comment from April 13, 2017 to May 12, 2017. The Project 

Team posted the EA to the Project webpage (https://www.fra.dot.gov/Page/P0810) and distributed hard 

copies to the following 22 repositories:

 Lower Merion Township Municipal Building 

 Tredyffrin Township Municipal Building 

 Delaware County Courthouse 

 Montgomery County Courthouse 

 Philadelphia City Planning Commission 

 Chester County Planning Commission 

 Bryn Mawr's Ludington Library 

 Tredyffrin Public Library 

 Paoli Library 

 Easttown Library & Information Center 
Finding of No Significant Impact 

 17 

 Ardmore Library 

 Bala Cynwyd Library 

 Penn Wynne Library 

 Charles L. Durham Branch Library 

 Wynnefield Branch Library 

 Overbrook Park Branch Library 

 Philadelphia City Hall 

 Narberth Borough Municipal Building 

 Haverford Township Municipal Building 

 Radnor Township Municipal Building 

 Easttown Township Municipal Building 

 Willistown Township Municipal Building 

Members of the public attended the final public meeting held on May 4, 2017. See Appendix C for these 

meeting materials. Themes and inquiries from the informal question-and-answer period during the May 4, 

2017 meeting included: 

 Tree trimming 

 Access through private property 

 Construction schedule and timing 

 Project funding 

 Electromagnetic impacts 

 Past public involvement 

See Appendix D for comment submittals. Responses to written comments on the EA received from the 

public are included in Appendix E. 

F. AGENCY AND PUBLIC COMMENTS

See Appendix D “Comments Received,” and Appendix E “Response to Comments.” 

G. FINDINGS

FRA finds that the Philadelphia Zoo to Paoli Transmission Line Project Environmental Assessment 

satisfies the requirements of NEPA (42 USC § 4321 et seq.), the Council on Environmental Quality 

(CEQ) regulations (40 CFR parts 1500-1508), FRA’s Procedures for Considering Environmental Impacts 

(64 FR 28545, May 26, 1999), and FRA’s Update to NEPA Implementing Procedures (78 FR 2713, 

January 14, 2013). 

If constructed, the Proposed Action would maintain and improve passenger train service on the Keystone 

Corridor East between the Zoo Substation (Mile Post 2.5) in central Philadelphia and the Paoli Substation 

(Mile Post 20.5), while simplifying maintenance access. 

The main impacts of the Proposed Action would be visual impacts and an adverse effect on the National 

Register eligible Pennsylvania Railroad Main Line (Philadelphia to Harrisburg). Numerous mitigation 

      Appendix A 

Environmental Commitments 
Appendix A 

Environmental Commitments 

 Amtrak would comply with the cultural resources MOA, which includes minimization and 

mitigation measures that require documentation, interpretation, and design elements to be 

included as part of the Proposed Action and in the Proposed Action Design Plan Notes. The 

signed MOA is enclosed in Appendix B of this FONSI. 

 The MOA includes an Unanticipated Discoveries Plan that Amtrak would implement if any 

archaeological resources are encountered during construction. 

 Tree trimming plans have been included in the Proposed Action’s Design Plans. The tree 

trimming plans identify specific tree trimming locations, to avoid universal tree trimming or 

clearcutting throughout the Proposed Action area prior to construction. The tree trimming plans 

are enclosed in Appendix C of the Environmental Assessment, as drawings C-0200 through C0232 of the Paoli to Bryn Mawr plans and drawings C-0217 through C-0232 of the Bryn Mawr 

to Zoo plans. 

 Amtrak would develop and implement a Community Notification Plan to communicate 

construction timing and phasing to the community. 

 Applicable best management practices concerning construction activities including, but not 

limited to, vibration, noise, and light emissions would be incorporated into the Proposed Action’s 

Design Plan Notes, as appropriate. Design plan notes would prohibit blasting constrution 

activites. The contractor would be responsible for conforming to all plan note requirements 

during construction. 

 Threatened and endangered species clearances with the PGC, the PA DCNR, the PFBC, and the 

U.S. FWS would be re-coordinated by Amtrak, as needed or required by state and federal 

regulations prior to construction. 

 The construction contractor would follow Amtrak’s established hazardous materials and waste 

procedures during the Proposed Action. Old electrical transformers, which may contain 

polychlorinated biphenyl (PCB) oil, would be removed and replaced as part of the Proposed 

Action. Amtrak’s established procedures for testing and draining transformers prior to disposal 

would be implemented. Amtrak maintains contracts with multiple firms for emergency response 

and waste hauling services. 

 In case hazardous waste may be encountered during construction, a Soil Management Plan has 

been created (Appendix F of Environmental Assessment). This plan specifies waste 

management procedures and precautions for construction activities within areas of 

environmental concern within the construction zone. 
      Appendix B 

Memorandum of Agreement 
1 Zoo to Paoli Electrification Transmission Line MOA

MEMORANDUM OF AGREEMENT

AMONG

THE FEDERAL RAILROAD ADMINISTRATION,

THE NATIONAL RAILROAD PASSENGER CORPORATION,

THE RAILROAD MUSEUM OF PENNSYLVANIA, SOUTHEASTERN PENNSYLVANIA 

TRANSPORTATION AUTHORITY, AND THE

PENNSYLVANIA STATE HISTORIC PRESERVATION OFFICE

REGARDING THE AMTRAK ZOO TO PAOLI ELECTRIFICATION

TRANSMISSION LINE PROJECT

IN PHILADELPHIA, MONTGOMERY, DELAWARE, AND

CHESTER COUNTIES, PENNSYLVANIA

WHEREAS, the National Railroad Passenger Corporation (Amtrak) proposes the Amtrak 

Zoo to Paoli Electrification Transmission Line Project (Project) to modernize and upgrade the 

electrification system on a 20-mile section of Amtrak’s Keystone Corridor between the Philadelphia 

Zoo Substation (Zoo Substation) in Philadelphia and the Paoli Substation in Paoli, extending through 

portions of Philadelphia, Montgomery, Delaware, and Chester Counties, Pennsylvania; and

WHEREAS, Amtrak has determined that implementation of the Project requires upgrades or 

replacement of the 80- to-100-year-old system elements with approximately 325 new catenary 

structures, transmission lines, signal power lines, and replacement of the existing 100-year-old Bryn 

Mawr Substation; and

WHEREAS, the Federal Railroad Administration (FRA) provided funding for design and 

review of the Project pursuant to the National Environmental Policy Act (42 U.S.C. § 4321 et. seq.)

(NEPA), and anticipates providing financial assistance for construction of the Project; and

WHEREAS the Project would be an “Undertaking” under Section 106 of the National

Historic Preservation Act, as amended (54 U.S.C. § 306108) (Section 106) if FRA provides 

financial assistance for construction of the Project; and

WHEREAS, FRA, and Amtrak on behalf of FRA, has consulted with the Pennsylvania 

Historical and Museum Commission, which acts as the State Historic Preservation Office (PA 

SHPO), pursuant to authority provided by the Advisory Council on Historic Preservation (ACHP) 

regulations implementing Section 106 (36 CFR Part 800), including participating in the consultation

process; and

WHEREAS, in a letter dated February 9, 2012, FRA and Amtrak invited 41 organizations,

institutions, governmental agencies, elected officials, and individuals to participate as Consulting

Parties for the purposes of Section 106, including the resolution of adverse effects of the Project, and

the following Consulting Parties actively participated in consultation:

Preservation Alliance for Greater Philadelphia

Delaware Valley Association of Rail Passengers, Inc.

Haverford Township Historical Commission

Lower Merion Township Historic Architectural Review Board

Radnor Township Historic Architectural Review Board

National Railway Historical Society, Philadelphia Chapter, Inc.

Haverford Station Historic District Neighborhood Coalition 

Railroad Museum of Pennsylvania; and 
2 Zoo to Paoli Electrification Transmission Line MOA

WHEREAS, in a letter dated August 26, 2015, FRA invited potentially interested Native 

American Tribes to consult and sought comments from the following Tribes for the purposes of 

complying with Section 106 and the requirements of government-to-government consultation:

Absentee-Shawnee Tribe of Oklahoma; Delaware Nation; Delaware Tribe of Indians; Eastern 

Shawnee Tribe of Oklahoma; Onondaga Nation; St. Regis Mohawk Tribe; Shawnee Tribe; and the 

Stockbridge-Munsee Band of the Mohican Nation of Wisconsin; and only the Delaware Tribe 

provided comments; and

WHEREAS, the Railroad Museum of Pennsylvania (RRMPA) and Southeastern 

Pennsylvania Transportation Authority (SEPTA), the latter of which is the lessee of the Bryn Mawr 

Station from Amtrak pursuant to that certain Lease Agreement between National Railroad Passenger 

Corporation and Southeastern Pennsylvania Transportation Authority dated January 1, 1987, as 

amended, participated in the consultation and have been invited to be Signatories to this 

Memorandum of Agreement (MOA) because they will be responsible for executing portions of the 

mitigation stipulations herein; and FRA, Amtrak, and PA SHPO are also Signatories to this MOA;

and

WHEREAS,FRA is the lead federal agency for the Project under NEPA and is preparing an 

Environmental Assessment for the Project, and under 36 C.F.R. § 800.8 FRA has coordinated the 

Section 106 and NEPA processes; and

WHEREAS, FRA and Amtrak have established the Area of Potential Effects (APE), as 

defined in 36 CFR § 800.16(d), to include the segment of the right-of-way (roughly 100 feet in 

width) from its point of departure from Amtrak’s Zoo Substation in Philadelphia, Pennsylvania, to 

Paoli Substation, in Paoli (Tredyffrin and Willistown Townships), Pennsylvania, for a distance of 

approximately 20 miles, as described and shown in the report entitled Historic Resources 

Study/Determination of Eligibility, Zoo to Paoli Electrification Transmission Line Project, Chester, 

Delaware, Montgomery, and Philadelphia Counties, Pennsylvania, E.R. #2012-0005-42 dated 

February 2015, and PA SHPO concurred with Amtrak’s efforts to identify historic properties within 

this APE on April 24, 2015; and

WHEREAS, FRA and Amtrak have identified 27 historic properties in the APE, and the PA 

SHPO concurred with this identification on March 16, 2015, and April 24, 2015; and

WHEREAS, one of the identified historic properties in the APE is the Pennsylvania Railroad

Main Line (Philadelphia to Harrisburg) (Key No. 105675), which was determined eligible for listing 

in the National Register of Historic Places (NRHP) by the PA SHPO on September 14, 1993, and 

again on November 16, 2007; and

WHEREAS, the existing catenary structures and the Bryn Mawr Substation building are 

Contributing Resources to the NRHP-eligible Pennsylvania Railroad Main Line (Philadelphia to 

Harrisburg); and

WHEREAS, through consultation, FRA determined that the Project will have an Adverse 

Effect on one historic property within the APE, namely, the Pennsylvania Railroad Main Line 

(Philadelphia to Harrisburg), because of the removal of the existing catenary structures and the Bryn 

Mawr Substation building, as discussed in the Determination of Effects Report, dated August 2015; 

and the same report describes the no adverse and no effect findings regarding other historic 

properties in the APE; and the PA SHPO concurred with these findings on October 8, 2015; and

WHEREAS, through consultation, FRA determined that revisions to the design of certain 
3 Zoo to Paoli Electrification Transmission Line MOA

catenary structures associated with the Project would have no additional adverse effects on historic 

properties, as discussed in an Addendum to the Determination of Effects Report, dated June 2016, 

and the PA SHPO concurred with this finding on July 19, 2016; and

WHEREAS, FRA and Amtrak have explored options to avoid the adverse effect to the 

Pennsylvania Railroad Main Line and concluded that such options are not practicable, as discussed 

in the August 2015 Determination of Effects Report; and

WHEREAS, all actions necessary to implement the Project will occur in areas disturbed by 

previous construction, as documented in the Phase IA Geomorphology/Archaeology Reconnaissance 

Survey Report dated December 2012 and in a subsequent letter to PA SHPO dated December 22, 

2015; and FRA determined and PA SHPO concurred on January 25, 2013 and January 7, 2016, 

respectively, that no archaeological investigations are necessary for the Project; and

WHEREAS, FRA and Amtrak conducted public involvement meetings from 2012 through 

2015, which included meetings with public officials, general public meetings, and meetings with the 

Section 106 Consulting Parties; and

WHEREAS, FRA received a request for additional information from the Delaware Tribe of 

Indians in a letter dated October 2, 2015 and FRA submitted the requested information on December 

22, 2015, which included a copy of the Phase IA Geomorphology/Archaeology Reconnaissance 

Survey Report, the Unanticipated Discoveries Plan, and mapping showing the proposed footprint 

and construction entrance at the Bryn Mawr Substation; and no other tribes provided comments or 

requested additional information regarding the Project; and

WHEREAS, on June 21, 2016 FRA notified the ACHP of the determination of adverse effect

in accordance with 36 CFR § 800.6(a)(l), and in a letter dated June 27, 2016, the ACHP declined to

participate in the consultation process;

NOW, THEREFORE, FRA, Amtrak, RRMPA, PA SHPO, and SEPTA, only to the extent 

these stipulations are applicable to SEPTA, (each, a Signatory and together the Signatories) agree

that the Project, if it becomes an Undertaking, will be implemented in accordance with the following

stipulations in order to minimize impacts and mitigate adverse effects on historic properties, and that

these stipulations will govern the Undertaking and all of its parts until this MOA expires or it is

terminated.

STIPULATIONS

FRA will ensure that the following measures are carried out:

I. Applicability 

A. This MOA would apply to FRA’s Undertaking and would only bind FRA if FRA 

provides financial assistance for the construction of the Project.

B. This MOA may apply should another Federal agency have an Undertaking as part 

of the Project; that agency may agree to comply with the terms of this MOA and 

become a Signatory to fulfill its Section 106 responsibilities as provided for in 

Stipulation V.E.
4 Zoo to Paoli Electrification Transmission Line MOA

II. Professional Qualification Standards

Amtrak will ensure that all historic preservation and documentation work carried out

pursuant to this MOA will be done by or under the direct supervision of a qualified 

professional or qualified professionals in the discipline of architectural history who meet[s] 

the relevant standards outlined in the Secretary of the Interior's Professional Qualification 

Standards for Architectural Historians (48 FR 44738-9).

III. Minimization Measures

A. As a result of consultation, Amtrak has decreased the proposed catenary structure 

heights to the extent feasible without adversely impacting railroad safety and 

operations.

B. Amtrak commits to a tree trimming program to facilitate Project construction in lieu 

of removing multiple trees. Selected trees may be removed within Amtrak’s right-ofway. Trimming will adhere to the program outlined in tree trimming plans dated 

March 17, 2016, and appended to this MOA as Attachment 1.

C. Amtrak commits to the placement of new catenary structures as near as practicable

to the existing structures, and that existing catenary structures will be removed, to 

minimize visual effects. 

D. Amtrak commits to avoiding physical impacts to the following historic train stations 

located along the Project corridor: Overbrook, Merion, Wynnewood, Haverford, 

Villanova, Radnor, Wayne, and Stafford.

IV. Mitigation Measures

A. Documentation

1. Amtrak will record the existing Bryn Mawr Substation and related catenary 

system to Historic American Engineering Record (HAER) Documentation 

Level II, as outlined in the publication, Secretary of the Interior’s Standards 

and Guidelines for Architectural and Engineering Documentation: 

HABS/HAER Standards, available at 

http://www.nps.gov/hdp/standards/standards.pdf. Documentation Level II

includes a narrative with the history and description of the resource, archival 

photographs, and copies of selected existing historic drawings. Amtrak’s

current existing conditions drawings may be supplemented with new 

measured drawings, to the extent that it is necessary to sufficiently document 

the resources. The documentation will describe the design of the existing Bryn 

Mawr Substation as well as the design of the catenary system in the Project 

APE, including all four types of catenary structures present along the railroad 

right-of-way. Amtrak will consult with PA SHPO to determine the extent of 

the documentation (e.g., format and length of narrative, quantity of 
5 Zoo to Paoli Electrification Transmission Line MOA

photographs, and extent of documentation using historic or new measured 

drawings) prior to beginning the work. Prior to beginning field 

documentation, Amtrak will consult with RRMPA to use its collections and 

expertise as described in Stipulation IV.A.2. Amtrak will provide the draft 

documentation to PA SHPO for review and comment as described in

Stipulation V.B. Amtrak will complete the agreed-upon photographic 

documentation prior to beginning demolition activities. Amtrak will deposit 

the final documentation of the existing Bryn Mawr Substation and related 

catenary system at RRMPA, the State Museum of Pennsylvania, and the 

Lower Merion Historical Society. 

2. RRMPA will provide Amtrak with access to its collections and technical 

expertise to inform the content of the documentation effort described in 

Stipulation IV.A.1, including important views or details to capture in 

photographs and drawings. RRMPA may, at its discretion, provide historic 

images or drawings to Amtrak for inclusion in the documentation package.

B. Interpretation

1. Interpretive Signage - Amtrak will provide an interpretive sign inside the Bryn 

Mawr Station building that focuses on the history of the Pennsylvania 

Railroad Main Line, with particular attention to the importance of the 

electrification of the route. Amtrak will submit the draft content of the sign to 

PA SHPO, SEPTA, and Lower Merion Township Historic Architectural 

Review Board for review and comment as described in Stipulation V.B. 

Amtrak will address any comments received as described in Stipulation V.B., 

and circulate the revised draft sign content to the aforementioned parties for 

review and comment. Once the content of the sign is agreed upon and 

finalized, Amtrak will provide it in electronic PDF format to FRA, PA SHPO, 

SEPTA, and Lower Merion Township. Amtrak will install the agreed-upon

sign in the Bryn Mawr Station in a specific location that is agreed upon by 

SEPTA, and Amtrak will be responsible for the maintenance of the sign, and

the replacement or repair of the sign should it be damaged for any reason or 

vandalized after installation for a period of five years after Project 

construction is complete. SEPTA has no responsibility for sign maintenance 

or replacement.

2. Equipment Donation - Amtrak will donate materials and elements of the 

catenary system that Amtrak or its contractors remove from the existing Bryn 

Mawr Substation to RRMPA for use in their upcoming new exhibits about the 

history of railroad electrification or for other exhibits, or to achieve other 

preservation purposes, as RRMPA may determine at its discretion. To the 

extent available, and at its discretion, Amtrak may also donate other materials, 

such as a pantograph, hangers, insulators, signage, and digital photographs for 

use in RRMPA exhibits. Acceptance of materials will be at the discretion of 

the RRMPA. RRMPA will appropriately credit all photographs and other 
6 Zoo to Paoli Electrification Transmission Line MOA

donations provided by Amtrak. The donation of documents, photographs, and 

other corporate records will be governed by Amtrak’s Records Management 

and other applicable policies. Amtrak will accompany RRMPA staff on a tour 

of the existing Bryn Mawr Substation prior to demolition so that RRMPA can 

identify materials it would like to receive as donations. Amtrak will make 

items available and RRMPA will retrieve them from the existing Bryn Mawr 

Substation property at its own expense. Because the construction schedule 

for the Project is uncertain, Amtrak will work with RRMPA and FRA to 

coordinate the timing of Project activities and donations for exhibits to the 

extent possible. All donated materials will be provided to RRMPA on an “asis, where-is” basis. Prior to removal of any materials, RRMPA will provide 

Amtrak with a full release from all claims, suits, damages, costs, etc. for the 

donated materials.

3. Conservation Allowance - Once the nature and extent of donated materials is 

determined as set forth in Stipulation IV.B.2 above, FRA, Amtrak, RRMPA, 

and PA SHPO will consult to determine an appropriate one-time financial 

contribution from Amtrak to RRMPA dedicated to the conservation of 

donated materials. 

4. Oral History Opportunity - Amtrak will make reasonable efforts to identify 

and provide to RRMPA contact information for current or former Amtrak 

Electric Traction Department employees who are willing to participate in oral 

history interviews. RRMPA will provide to Amtrak a description of the oral 

history process and proposed discussion topics for Amtrak to share with 

potential interviewees so that they can make an informed decision about their 

participation in an interview. Amtrak does not guarantee the participation of 

any current or former employee in the interviews. Amtrak retains the right to 

screen contents of the interviews intended for public access to ensure that 

sensitive security and operations information is not shared with the public. 

RRMPA will deposit transcripts and other relevant documentation of the 

interviews, subject to Amtrak security approval, at RRMPA, the PA State 

Archives, and Amtrak.

C. Design 

1. Amtrak will replace the existing Bryn Mawr Substation building with two 

new substation buildings. Amtrak will design the exterior of these two new 

buildings with buff brick walls consistent with the brick of the existing Bryn 

Mawr Substation building. The design will be consistent with the materials, 

color, and texture of the existing Bryn Mawr Substation building, but will not 

mimic the historic building to make it clear that the new buildings are nonhistoric and do not create a false sense of history. Amtrak will submit the 

proposed design to PA SHPO for review and comment as described in

Stipulation V.B. Design documents will be shared at 30%, 60%, and 90% 

design. 
7 Zoo to Paoli Electrification Transmission Line MOA

2. Amtrak will incorporate the “Bryn Mawr Substation” sign currently on the 

existing Bryn Mawr Substation building into a new retaining wall or other 

landscape feature adjacent to the new Bryn Mawr Substation site. Amtrak will 

submit its proposed conceptual design to PA SHPO and the Lower Merion 

Township Historic Architectural Review Board for review and comment, and 

Amtrak will address any comments received, as described in Stipulation V.B.

3. Amtrak will offer the bricks from the existing Bryn Mawr Substation building 

for salvage upon removal of the building. Amtrak will notify Consulting 

Parties and the public when the bricks will be available and will take requests 

for the materials. Amtrak will not deliver the brick, but will make it available 

for pick-up for a specified, reasonable period of time. Amtrak cannot 

guarantee the amount or number of salvageable bricks. Amtrak will provide 

all materials for salvage on an “as-is, where-is” basis, and will make no 

warranty as to condition, suitability, serviceability, or degree of 

contamination for any intended subsequent use. Amtrak will prepare and 

deliver a written receipt to that effect to every recipient for their review and 

signature, and the receipts will become a part of the official Project record. 

Recipients will sign a release indemnifying Amtrak and Signatories of this 

Agreement against any and all claims arising from the acquisition and use of 

salvaged materials. At the end of the retention period, Amtrak may sell or 

dispose of the remaining unused materials in accordance with applicable 

statutes and regulations.

V. General Provisions

A. Effective Date

This MOA will be effective as of the date of obligation of Federal financial assistance 

to construct the improvements and upgrades required for the Project following 

execution of this MOA by all Signatories.

B. Document Review

Unless otherwise stated in the stipulations, the Signatories and Consulting Parties, 

where applicable, will provide comments on the documents they review as set forth 

below:

1. The Signatories and Consulting Parties specified in each item under 

Stipulation IV above will have up to thirty (30) calendar days from the date 

of receipt to review and provide written comments to Amtrak on documents 

stipulated in this MOA.

2. Amtrak will ensure any written comments received within the timeframe are 

considered and incorporated, as appropriate, into the documentation.

3. If the specified Signatories and Consulting Parties do not submit written 

comments to Amtrak within thirty (30) calendar days of receipt of any 

document, it is understood the non-responding parties have no comments on 

the submittal.
8 Zoo to Paoli Electrification Transmission Line MOA

4. If the Signatories and Consulting Parties object to or recommend extensive 

revisions to submissions stipulated in the MOA, Amtrak will work 

expeditiously to respond to the recommendations and resolve disputes.

5. If Amtrak cannot resolve a dispute, and if further consultation is deemed 

unproductive by any party, the parties will adhere to the dispute resolution 

procedures detailed under Stipulation V.G. 

6. The Signatories and Consulting Parties acknowledge the timeframes set forth 

in this MOA will be the maximum allowed under normal circumstances. In 

exigent circumstances (e.g., concerns over construction suspensions or 

delays), all parties agree to expedite their respective document review and 

dispute resolution obligations.

C. Project Changes

If Amtrak proposes changes to the Project that may result in additional or new effects 

on historic properties, Amtrak will notify FRA and the PA SHPO of such changes. 

Before Amtrak takes any action that may result in additional or new effects on historic 

properties, Amtrak, FRA and PA SHPO will consult to determine the appropriate 

course of action. 

D. Amendment

Any Signatory to this MOA may request that it be amended. The amendment will 

be effective on the date a copy signed by all of the Signatories is filed with the ACHP.

E. Use of this MOA by Other Federal Agencies

In the event that a Federal agency other than FRA is considering financial assistance, 

permits, licenses, or approvals for the Project, such Federal agency may become a 

Signatory to this MOA as a means of complying with Section 106. To become a 

Signatory to this MOA, the agency official must provide written notice to the 

Signatories that the agency agrees to the terms of the MOA, specifying the extent of 

the agency’s intent to participate in the MOA, and identifying the lead Federal agency 

for the Undertaking. The participation of the agency is subject to approval by the 

Signatories, who must respond to the written notice within 30 days or the approval 

will be considered implicit. Any other modifications to the MOA will be considered 

in accordance with Stipulation V.D.

F. Termination

If any Signatory to this MOA determines that its terms will not or cannot be carried 

out, that Signatory will immediately consult with the other Signatories to attempt to 

develop an Amendment per Stipulation V.D. If within thirty (30) days (or another 

time period agreed to by all Signatories) an amendment cannot be reached, any 

Signatory may terminate the MOA upon written notification to the other 

Signatories.
9 Zoo to Paoli Electrification Transmission Line MOA

Once the MOA is terminated, and prior to work continuing or initiating on the 

Undertaking, FRA must either (a) execute an MOA pursuant to 36 CFR § 800.6 or 

(b) request, take into account, and respond to the comments of the ACHP under 36 

CFR § 800.7. FRA will notify the Signatories as to the course of action it will 

pursue.

G. Dispute Resolution

Should any Signatory to this MOA object at any time to any actions proposed or the 

manner in which the terms of this MOA are implemented by providing written notice 

of such objection to FRA, FRA will consult with the Signatory to resolve the 

objection. If FRA determines that the objection cannot be resolved, FRA will: 

1. Forward all documentation relevant to the dispute, including the FRA’s 

proposed resolution, to the ACHP and request that the ACHP provide FRA 

with its advice on the resolution of the objection within thirty (30) calendar 

days of receiving the documentation. FRA will prepare a written response to 

the objection, which will constitute the FRA’s decision regarding the 

objection, that takes into account any timely advice or comments regarding 

the dispute from the ACHP and the Signatories and provide the ACHP and

Signatories with a copy of this written response. FRA will then proceed 

according to its decision. 

2. If the ACHP does not provide its advice regarding the dispute within the thirty 

(30) calendar day time period, FRA may make a decision on the dispute and 

proceed accordingly. FRA will document this decision in a written response 

to the objection that takes into account any timely comments regarding the 

dispute from the Signatories and provide the ACHP and Signatories with a 

copy of such written response. 

3. The Signatories remain responsible for carrying out all other actions subject 

to the terms of this MOA that are not the subject of the dispute.

H. Duration

This MOA will be valid for five (5) years following the Effective Date, or when the

Signatories have agreed to terminate the MOA, whichever comes first. If the terms

of this MOA have not been implemented within five years of its Effective Date, this

MOA will be considered null and void. In such event, FRA or Amtrak will notify the

other Signatories to this Agreement, and if FRA chooses to continue with the

Undertaking, will reinitiate review ofthe Undertaking in accordance with 36CFR Part 

800. Prior to such time, FRA may consult with the other Signatories to reconsider the 

terms of the MOA and amend it in accordance with Stipulation V.D above.

I. Monitoring and Reporting

Each year following the Effective Date of this MOA until it expires or is terminated, 
10 Zoo to Paoli Electrification Transmission Line MOA

Amtrak will provide all Signatories to this MOA a summary report detailing work 

undertaken pursuant to its terms. Such report will include any scheduling changes 

proposed, any problems encountered, and any disputes and objections received in 

FRA’s efforts to carry out the terms of this MOA. 

J. Unanticipated Discoveries Plan

In consultation with FRA, Amtrak has developed an Unanticipated Discoveries Plan

for human and non-human archaeological resources in the event that any

unanticipated archaeological resources are encountered during construction of the

Project. The Unanticipated Discoveries Plan is appended to this MOA as Attachment 

2. In the event of the Unanticipated Discovery of human or non-human

archaeological resources, Amtrak will cease work in the affected area and implement 

the Unanticipated Discoveries Plan. 

EXECUTION of this MOA, and implementation of its terms, evidences that FRA, Amtrak, and 

PA SHPO have taken into account the effects of the Project on historic properties, and that FRA

and Amtrak have satisfied their responsibilities under Section 106 of the Act and implementing

regulations codified in 36 CFR Part 800 with regard to a future Undertaking. 





ATTACHMENT 1:

TREE TRIMMING PLANS
PAOLI STATION

PAOLI

SUBSTATION

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100% DESIGN SUBMISSION

“”“”
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DAYLESFORD

STATION

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BERWYN STATION

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DEVON

STATION

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STRAFFORD STATION

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ST. DAVIDS STATION

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RADNOR STATION

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VILLANOVA STATION

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ROSEMONT

STATION

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BRYN MAWR

SUBSTATION

BRYN MAWR STATION

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ATTACHMENT 2:

UNANTICIPATED DISCOVERIES PLAN
Amtrak Page 1 of 3 Zoo to Paoli Electrification Transmission Line 

Unanticipated Discoveries Plan

July 31, 2017

UNANTICIPATED DISCOVERIES PLAN

AMTRAK’S PHILADELPHIA ZOO SUBSTATION TO PAOLI 

SUBSTATION ON THE PENNSYLVANIA MAIN LINE RAILROAD 

ELECTRIFICATION TRANSMISSION LINE PROJECT

Chester, Delaware, Montgomery, and Philadelphia Counties,

Pennsylvania

National Railroad Passenger Corporation (Amtrak)

60 Massachusetts Avenue, N.E.

Washington, D.C. 20002

PART 1 - GENERAL

This document is prepared pursuant to the requirements of a Memorandum of Agreement 

(MOA) among the Federal Railroad Administration (FRA), the Pennsylvania State Historic 

Preservation Office (PA SHPO), the National Railroad Passenger Corporation (Amtrak), the 

Southeastern Pennsylvania Transportation Authority (SEPTA), and the Railroad Museum of 

Pennsylvania (RRMPA).

This document provides the procedure to be followed in the event human or non-human 

archaeological resources are encountered during construction of the project.

This document pertains to the work of the Contractor, the Contractor’s subcontractors, the 

Contractor’s material suppliers, the Contractor’s equipment suppliers, and all individuals and 

companies associated with the Contractor’s performance of the project (hereafter collectively 

referred to as Contractor). Contacts for Amtrak, the Contractor, and other appropriate parties will 

be provided prior to construction.

This document shall remain in force until the formal completion of the project, or the termination 

of the MOA, whichever comes first.

PART 2 – IDENTIFICATION OF RESOURCES

The following are considered examples of potential archaeological resources to be included in 

this Unanticipated Discoveries Plan (Plan):

- Human skeletal remains, including individual bones, groups of bones, bone fragments,

dental fragments, etc.

- Articles of clothing, including cloth, leather, shoe leather, buckles, buttons, etc.

- Personal items, including rings, jewelry, beads, toys, coins, gun parts, funerary items, etc.

- Household and kitchen items, including intact or broken pieces of ceramics, glass and 

metal containers, cutlery, butchered bones and oyster shells, tobacco pipe remnants, etc.
Amtrak Page 2 of 3 Zoo to Paoli Electrification Transmission Line 

Unanticipated Discoveries Plan

July 31, 2017

- Architectural items, including window glass, nails, bricks, shaped building stones, etc.

- Possible prehistoric objects, including chipped stone tools (i.e, projectile points, drills, 

etc.), ceramics, groundstone, lithic debitage, animal bone, personal adornment items, etc.

- Areas of darkened soil that suggest possible cultural features, such as firepits, garbage 

pits, privies, foundations, postholes, etc.

- Unusual objects not identified herein that suggest human occupation.

It is possible any combination of these resources may be found during earthwork operations at 

locations where drilling occurs for pole footings, temporary fences, gates, signs and other 

appurtenances, and at locations where soil is disturbed, removed, relocated, or displaced along 

the right-of-way, such as at access points, staging areas, and the Bryn Mawr Substation 

construction location. The Contractor’s supervisory personnel present during hours of 

construction should be provided with minimal training in the identification of archaeological 

resources. 

PART 3 – PROCEDURE FOR IDENTIFYING UNANTICIPATED DISCOVERIES

1. If one or more of the potential archaeological resources (listed above) are 

encountered by the Contractor during earthwork operation, stop work in the vicinity 

of the resource immediately and notify the Amtrak Project Manager (to be named 

prior to construction). Do not resume work in the vicinity of the resource until 

specifically directed by the Amtrak Project Manager. The Contractor will ensure that 

any discoveries are protected from destruction, looting, and vandalism during stopwork episodes while a determination is made as to the importance of a find.

2. The Amtrak Project Manager will notify the Project’s Environmental Consultant 

(including a Secretary of the Interior [SOI]-qualified archaeologist and the Project 

Manager), who, in consultation with the Amtrak Project Manager, will determine if it 

is necessary to conduct a field visit to inspect the encountered potential 

archaeological resource.

a. Should the Amtrak Project Manager and the Project’s Environmental 

Consultant conclude it is not necessary to investigate the encountered 

potential archaeological resource any further, the Amtrak Project Manager 

will authorize work in the area to resume.

b. Should the Amtrak Project Manager and the Project’s Environmental 

Consultant conclude it is necessary to further investigate the encountered 

potential archaeological resource, the SOI-qualified archaeologist with the 

Project’s Environmental Consultant will conduct a field visit within 24 hours.

3. Should the field visit indicate the encountered materials are not potential

archaeological resources, the Project’s SOI-qualified archaeologist will notify the 

Amtrak Project Manager, who will authorize work in the area to resume.
Amtrak Page 3 of 3 Zoo to Paoli Electrification Transmission Line 

Unanticipated Discoveries Plan

July 31, 2017

4. Should the field visit confirm the encountered materials are potential archaeological 

resources, the Project’s SOI-qualified archaeologist will inform the Amtrak Project 

Manager and then notify:

- the PA SHPO (Douglas McLearen, Chief, Archaeology and Protection, 

Bureau for Historic Preservation at 717.772.0925), and

- FRA (Laura Shick, Federal Preservation Officer at 202.366.0340).

a. FRA will determine if it is appropriate to notify Native American groups to 

invite consultation and review of any discovered potential pre-contact human 

remains. Per PA SHPO guidelines for the treatment of human remains, work 

will stop and the coroner and SHPO will be notified. 

b. FRA, in consultation with Native American tribe(s), will determine the 

appropriate treatment of the discovered potential pre-contact human remains 

and associated funerary objects. The Project’s SOI-qualified archaeologist 

will notify the PA SHPO and Amtrak’s Project Manager of the treatment.

- The treatment of all encountered pre-contact human remains and 

associated funerary objects will be subject to the regulations promulgated 

in the Native American Graves Protection and Repatriation Act 

(NAGPRA), 25 U.S.C. 3001 et.seq.

- The treatment of all encountered archaeological resources will be subject 

to the regulations stipulated in the Guidelines for Archaeological 

Investigations by the PA SHPO.

c. Amtrak’s Project Manager will notify the Contractor of any required 

modifications to the project timetable or aspects of the contract.

d. FRA will notify the Project’s Environmental Consultant when work in the 

area of the potential archaeological resource may resume. The Project’s 

Environmental Consultant will notify the Amtrak Project Manager, who in 

turn will notify the Contractor.

- End of Document -
      Appendix C 

Public Meeting Materials (May 4, 2017) 
      Presentation
Zoo to Paoli Transmission Line Project

Public Meeting

May 4, 2017

5:00-8:00 PM

Lower Merion 

Township 

Administration 

Building
Location

• Amtrak’s Keystone Corridor East between:

• Zoo Substation (Mile Post 2.5) in central Philadelphia

• Paoli Substation (Mile Post 20.5)
Purpose and Need

• Purpose: to maintain / improve passenger train service using electric powered 

trains while simplifying maintenance access to the electrical transmission lines.

• Need: to bring the deteriorated catenary poles and related electrical 

equipment into a state of good repair and upgrade traction power, while 

relocating the transmission lines from former PA Railroad right-of-way 

to Amtrak right-of-way.
Proposed Action Description

• Construction of new transmission lines within Amtrak right-of-way to replace 

aging and inaccessible transmission lines outside of Amtrak right-of-way.

proposed transmission line, in Amtrak 

Keystone Corridor East right-of-way

existing transmission line, in former 

Pennsylvania Railroad right-of-way
Proposed Action Description (Cont.)

• Replacement of 276 and addition of 49 catenary structures (325 

total) within Amtrak right-of-way.

• Construction of one additional gantry (a structural framework for 

supporting high-voltage switches) at Paoli Substation.

• Demolition of the obsolete Bryn Mawr Substation and construction of 

two new traction power substation buildings at the same location on 

a slightly larger footprint.

• No changes to existing stations or major built elements of the 

railroad corridor.
National Environmental Policy Act Process

• Federal Railroad Administration anticipates funding the Proposed Action

• Environmental impacts must be evaluated under the National Environmental 

Policy Act (NEPA)

• NEPA requires federal agencies to consider natural, social, economic, 

and cultural impacts

• Environmental Assessment (EA) serves as primary environmental document 

reviewed by government agencies and the public
National Environmental Policy Act Process

Develop the 

Proposed 

Action

Evaluate 

environmental 

impacts and 

draft the EA

Incorporate 

mitigation 

measures and 

draft the 

environmental 

commitments

Solicit public 

review and 

comment

Prepare the 

Finding of No 

Significant 

Impact 

(FONSI)
Draft the Environmental Assessment

• Alternatives

• Proposed Action

• No-Build Alternative

• Other Alternatives

• Affected Environment and Environmental Consequences

• Cultural Resources

• Visual Impacts

• Noise and Vibration

• Air Quality

• Hazardous Materials

• Parks and Wildlife Refuges

• Endangered Species

• Construction

• Electric / Magnetic Fields

• and more....
Draft the Environmental Assessment (Cont.)

• Agency, Public, and Consulting Party Involvement

• Draft Section 4(f) Evaluation

• Public Parks and Wildlife Refuges

• Historic Resources

• Mitigation Measures

• Environmental Commitments
Visual Impacts

• Catenary poles

• Existing: 45 to 55 feet tall, green paint / rusted steel

• Proposed: 60 to 75 feet tall, galvanized zinc (grey)

• Tree trimming

• Existing: trees line much of the corridor

• Proposed: targeted tree trimming

• Residences, parks, and wildlife refuge

• Existing: many residences, 3 public parks, and 

1 wildlife refuge

• Proposed: new, taller catenary poles, but visual 

impacts minimized during design
Cultural Resources - Impacts

• The National Register of Historic Places-eligible Pennsylvania Railroad 

Main Line (Philadelphia to Harrisburg) would be adversely affected

• Catenary structure removal and replacement

• Demolition of Bryn Mawr Substation

• Coordination between FRA, Amtrak, 

RRMPA, SEPTA, PA SHPO, and other 

consulting parties to minimize and mitigate

adverse effects through an MOA
Cultural Resources - Minimization Measures

• Decreased height of new catenary 

structures

• Placement of new structures as 

close as possible to existing 

structures

• Targeted tree trimming program

• Avoidance of physical impacts to 

train stations
Cultural Resources - Mitigation Measures

• Documentation

• Record Bryn Mawr Substation and related catenary system

• Interpretation

• Provide interpretive sign inside Bryn Mawr Train Station

• Donate salvaged materials and provide conservation 

funds to the RRMPA

• Assist RRMPA in efforts to conduct oral history interviews

• Design

• Design new substation to be consistent with historic substation

• Incorporate “Bryn Mawr Substation” sign into landscape feature

• Offer bricks from Substation for salvage
Additional Mitigation Measures

• Transportation mitigation measures:

• Loss of 12 parking spaces at Bryn Mawr Train Station

• Design substation to have the smallest possible footprint

• Visual mitigation measures:

• Taller catenary poles, tree trimming, and replacement of Bryn Mawr Substation

• Limit catenary structure heights (60-75 feet at most locations)

• Place new catenary structures as close as possible to existing catenary structures

• Implement targeted tree trimming

• Design new Bryn Mawr Substation to be consistent with historic substation 
Environmental Commitments

• Cultural resources MOA and Unanticipated Discoveries Plan

• Targeted tree trimming plans 

• Community Notification Plan re: construction timing and phasing

• Design Plan Notes for construction (vibration, noise, and light emissions)

• Threatened and endangered species coordination updates

• Hazardous waste handled per Amtrak’s established procedures and 

project’s Soil Management Plan
Solicit Public Review and Comment

• Hard copies provided at 22 public libraries and municipal buildings

• Project website (https://www.fra.dot.gov/Page/P0810)

• Public notices published in newspapers

• Postcards mailed to stakeholders

• Public meeting
Preparation of FONSI

• After the 30 day public comment period

• If no significant impact is identified:

• Environmental Impact Statement (EIS) not required

• EA and FONSI documentation is sufficient

• FONSI incorporates public comments
Thank You!

• The involvement of the public is fundamental to the NEPA process.

• Project website https://www.fra.dot.gov/Page/P0810

• Contact for comments brandon.bratcher@dot.gov

• Comment deadline of May 12, 2017

Thank you for your participation!
      Display Boards 
CITY OF

PHILADELPHIA

LOWER MERION

TOWNSHIP

TREDYFFRIN

TOWNSHIP

RADNOR

TOWNSHIP

UPPER MERION

TOWNSHIP

WILLISTOWN

TOWNSHIP

MARPLE

TOWNSHIP

NEWTOWN

TOWNSHIP

EDGMONT

TOWNSHIP

MIDDLETOWN

TOWNSHIP

WHITEMARSH

TOWNSHIP

HAVERFORD

TOWNSHIP

EASTTOWN

TOWNSHIP

SPRINGFIELD

TOWNSHIP

UPPER DARBY

TOWNSHIP

UPPER

PROVIDENCE

TOWNSHIP YEADON

BOROUGH

LANSDOWNE

BOROUGH

MEDIA

BOROUGH

CONSHOHOCKEN

BOROUGH

NARBERTH

BOROUGH

DELAWARE

COUNTY

MONTGOMERY

COUNTY

CHESTER

COUNTY

PHILADELPHIA

COUNTY

2

4 3

1

Norristown

Quadrangle

Valley Forge

Quadrangle

Lansdowne

Quadrangle

Germantown

Quadrangle

Philadelphia

Quadrangle

Media

Quadrangle

Sheet 1 of 4:

Philadelphia Zoo

to Paoli Electrification

Transmission Line Design

25 East Main Street (610) 286-0100

Elverson, PA 19520 www.stellee.com

 ̄

0 0 0.25 .5 1

Miles

7.5 Minute USGS Topographic

Quadrangle: Philadelphia, PA

1 in = 1,500 ft

Project Location

ZOO SUBSTATION
NORRISTOWN QUADRANGLE

LANSDOWNE QUADRANGLE

PHILADELPHIA QUADRANGLE

GERMANTOWN QUADRANGLE

BRYN MAWR SUBSTATION

CITY OF

PHILADELPHIA

LOWER MERION

TOWNSHIP

TREDYFFRIN

TOWNSHIP

RADNOR

TOWNSHIP

UPPER MERION

TOWNSHIP

WILLISTOWN

TOWNSHIP

MARPLE

TOWNSHIP

NEWTOWN

TOWNSHIP

EDGMONT

TOWNSHIP

MIDDLETOWN

TOWNSHIP

WHITEMARSH

TOWNSHIP

HAVERFORD

TOWNSHIP

EASTTOWN

TOWNSHIP

SPRINGFIELD

TOWNSHIP

UPPER DARBY

TOWNSHIP

UPPER

PROVIDENCE

TOWNSHIP YEADON

BOROUGH

LANSDOWNE

BOROUGH

MEDIA

BOROUGH

CONSHOHOCKEN

BOROUGH

NARBERTH

BOROUGH

DELAWARE

COUNTY

MONTGOMERY

COUNTY

CHESTER

COUNTY

PHILADELPHIA

COUNTY

2

4 3

1

Norristown

Quadrangle

Valley Forge

Quadrangle

Lansdowne

Quadrangle

Germantown

Quadrangle

Philadelphia

Quadrangle

Media

Quadrangle

Sheet 2 of 4:

Philadelphia Zoo

to Paoli Electrification

Transmission Line Design

25 East Main Street (610) 286-0100

Elverson, PA 19520 www.stellee.com

 ̄

0 0 0.25 .5 1

Miles

7.5 Minute USGS Topographic

Quadrangle: Valley Forge, PA

1 in = 1,500 ft

Project Location
VALLEY FORGE QUADRANGLE

NORRISTOWN QUADRANGLE

CITY OF

PHILADELPHIA

LOWER MERION

TOWNSHIP

TREDYFFRIN

TOWNSHIP

RADNOR

TOWNSHIP

UPPER MERION

TOWNSHIP

WILLISTOWN

TOWNSHIP

MARPLE

TOWNSHIP

NEWTOWN

TOWNSHIP

EDGMONT

TOWNSHIP

MIDDLETOWN

TOWNSHIP

WHITEMARSH

TOWNSHIP

HAVERFORD

TOWNSHIP

EASTTOWN

TOWNSHIP

SPRINGFIELD

TOWNSHIP

UPPER DARBY

TOWNSHIP

UPPER

PROVIDENCE

TOWNSHIP YEADON

BOROUGH

LANSDOWNE

BOROUGH

MEDIA

BOROUGH

CONSHOHOCKEN

BOROUGH

NARBERTH

BOROUGH

DELAWARE

COUNTY

MONTGOMERY

COUNTY

CHESTER

COUNTY

PHILADELPHIA

COUNTY

2

4 3

1

Norristown

Quadrangle

Valley Forge

Quadrangle

Lansdowne

Quadrangle

Germantown

Quadrangle

Philadelphia

Quadrangle

Media

Quadrangle

Sheet 3 of 4:

Philadelphia Zoo

to Paoli Electrification

Transmission Line Design

25 East Main Street (610) 286-0100

Elverson, PA 19520 www.stellee.com

 ̄

0 0 0.25 .5 1

Miles

7.5 Minute USGS Topographic

Quadrangle: Valley Forge, PA

1 in = 1,500 ft

Project Location
PAOLI SUBSTATION

CITY OF

PHILADELPHIA

LOWER MERION

TOWNSHIP

TREDYFFRIN

TOWNSHIP

RADNOR

TOWNSHIP

UPPER MERION

TOWNSHIP

WILLISTOWN

TOWNSHIP

MARPLE

TOWNSHIP

NEWTOWN

TOWNSHIP

EDGMONT

TOWNSHIP

MIDDLETOWN

TOWNSHIP

WHITEMARSH

TOWNSHIP

HAVERFORD

TOWNSHIP

EASTTOWN

TOWNSHIP

SPRINGFIELD

TOWNSHIP

UPPER DARBY

TOWNSHIP

UPPER

PROVIDENCE

TOWNSHIP YEADON

BOROUGH

LANSDOWNE

BOROUGH

MEDIA

BOROUGH

CONSHOHOCKEN

BOROUGH

NARBERTH

BOROUGH

DELAWARE

COUNTY

MONTGOMERY

COUNTY

CHESTER

COUNTY

PHILADELPHIA

COUNTY

2

4 3

1

Norristown

Quadrangle

Valley Forge

Quadrangle

Lansdowne

Quadrangle

Germantown

Quadrangle

Philadelphia

Quadrangle

Media

Quadrangle

Sheet 4 of 4:

Philadelphia Zoo

to Paoli Electrification

Transmission Line Design

25 East Main Street (610) 286-0100

Elverson, PA 19520 www.stellee.com

 ̄

0 0 0.25 .5 1

Miles

7.5 Minute USGS Topographic

Quadrangle: Valley Forge, PA

1 in = 1,500 ft

Project Location
Catenary Structures

Example Rendering Example Overlay

Height of existing structure to be removed = 50’-2”

Height of new structure T-147 = 60’-2

The existing structures are visible in the background, with the 

proposed structures overlaid in yellow. The proposed structures 

will have a grey, galvanized zinc coating.

 
Typical Tree Pruning Detail 
      Appendix D 

Comments Received 
 Resource Agency Comments
 United States Department of the Interior 

OFFICE OF THE SECRETARY

 Office of Environmental Policy and Compliance 

 Custom House, Room 244 

 200 Chestnut Street 

 Philadelphia, Pennsylvania 19106-2904 

 

 June 14, 2017 

9043.1 

ER 17/0211 

Brandon Bratcher 

Federal Railroad Administration 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Subject: Environmental Assessment and Draft 4(f) Philadelphia Zoo to Paoli 

Substation Transmission Line Project, Philadelphia, Montgomery, Delaware, 

Chester Counties, PA 

Dear Mr. Bratcher: 

The Department of the Interior (Department) has reviewed the Environmental Assessment and 

Draft Section 4(f) evaluation for the proposed project to improve deteriorated electrification 

system on an 18-mile portion of the Keystone Corridor East within the right-of-way between the 

Zoo substation in central Philadelphia and the Paoli Substation. The purpose of the project is to 

improve passenger train service using electric-powered trains within the project area and to 

simplify maintenance of the electrical system. 

Section 4(f) Evaluation Comments

The Department concurs that there is no prudent and feasible alternative to the proposed use of 

4(f) lands, which consist of the Bryn Mawr Substation and associated catenary system, which are 

both contributing resources within the Pennsylvania Railroad: Mainline Historic District, which 

is eligible for listing in the National Register of Historic Places. The demolition of these 

contributing resources will be an adverse effect to the historic district, which constitutes a 4(f) 

use. De minimis impacts have also been identified for 5 resources within the Area of Potential 

Effect, including Merion Station, Haverford Station, Villanova Station, Wayne Station, and 

Strafford Station. The measures to minimize harm must be explicitly consistent with the draft 

Memorandum of Agreement (MOA) developed in consultation with the Pennsylvania State 

Historic Preservation Office, the National Railroad Passenger Corporation, the Southeastern 

Pennsylvania Transportation Authority, and the Railroad Museum of Pennsylvania. We note that 

IN REPLY REFER TO: 
2 

a draft copy of the MOA has been included in the documentation of compliance for the project 

and is currently under public review. It reflects appropriate procedures for mitigating the adverse 

effects to cultural resources. 

We appreciate the opportunity to provide these comments. 

 

Sincerely, 

 Lindy Nelson 

 Regional Environmental Officer 

cc: SHPO-PA 

 
 Stakeholder Comments 


 Public Comments 
1

Welt, Angela

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

Sent: Thursday, April 13, 2017 9:17 AM

To:

Subject: FW: Zoo to Paoli Transmission Line Project: Final Tree Trimming Plans (March 17, 2016)

FYI.

Brandon L. Bratcher 

Environmental Protection Specialist 

From: Bratcher, Brandon (FRA) 

Sent: Thursday, April 13, 2017 9:15 AM 

To: 'David Stewart' 

Subject: RE: Zoo to Paoli Transmission Line Project: Final Tree Trimming Plans (March 17, 2016) 

Much appreciative of your comments, Mr. Stewart. As someone who’s lived near transit option (I moved to DC from 

Chicago, where I lived 100 yards from the elevated train station), I understand your concerns. 

I will pass along these concerns to the folks at Amtrak and we will discuss any follow-up. 

Brandon L. Bratcher 

Environmental Protection Specialist 

From: David Stewart 

Sent: Thursday, April 13, 2017 8:46 AM 

To: Bratcher, Brandon (FRA) 

Subject: Zoo to Paoli Transmission Line Project: Final Tree Trimming Plans (March 17, 2016) 

Mr. Bratcher: 

I recently received a postcard from the firm of Michael Baker International announcing a Public Meeting on 

May 4, 2017 regarding the Zoo to Paoli Transmission Line Project. In addition to the announcement, the 

postcard also showed a website where project documents may be reviewed. My particular interest was in the 

Final Tree Trimming Plans (March 17, 2016). Our property is next to AMTRAK's ROW. 

When reviewing the "Tree Pruning Site Plan," I was particularly interested in Notes 2 and 5 on Page C-0200. 

Having lived at this location for nearly 33years, we have experienced many AMTRAK tree pruning sessions 

over the years. Our experience has been the opposite of Notes 2 and 5. 

- The Crew shows up un-announced and walks through our properties to get to the ROW, without permission. 

Since I keep our gate locked on the backyard fence, the crew uses my neighbor's yard for access to the ROW. 

(Note 2)
2

- There have been many pruning sessions on the ROW behind our house and the crew just leaves the debris 

where it falls and it is not removed. (Note 5) 

I hope the trimming crew will abide by the notes on this Tree Pruning Site Plan. 

In addition, I would hope that the crew trims the minimum amount possible. We really appreciate the tree 

foliage to screen the train activity. 

Thank you for taking the time to read my comments. If you are not the appropriate person to address these 

issues, I would be grateful if you would forward this e-mail to the proper person. 

With kind regards, 

David Stewart 
1

Welt, Angela

From: Mielke, Matthew S [USA] 

Sent: Thursday, May 04, 2017 5:21 PM

To: Welt, Angela; Daren Petroski, PE

Subject: Fwd: [External] FW: Presentation at lower merion

Public comment/question 

Sent from my iPhone 

Begin forwarded message: 

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

Date: May 4, 2017 at 9:27:15 AM EDT 

To: "Mielke, Matthew S [USA]" 

Subject: [External] FW: Presentation at lower merion

Hey Matthew.

Not going to make it tonight. Take plenty of notes for me.

Can you check into this and get back to me in the next few days?

Brandon L. Bratcher

Environmental Protection Specialist

From: Bratcher, Brandon (FRA) 

Sent: Thursday, May 04, 2017 9:26 AM 

To: 'Darren Clipston' 

Subject: RE: Presentation at lower merion

Good morning, Mr. Clipston. I will look into this and get back with you.

Brandon L. Bratcher

Environmental Protection Specialist

From: Darren Clipston 

Sent: Wednesday, May 03, 2017 4:30 PM 

To: Bratcher, Brandon (FRA) 

Subject: Presentation at lower merion

Brandon

Hi. You are listed as the contact for the Amtrak zoo to paoli transmission project. There is a 

presentation at lower merion township's offices tomorrow (May 4th). 
2

I may not be able to attend. Our property backs up to the train line I wanted to ask if Amtrak 

will be needing to go through our yard as part of this project? Our address is 

Also the is a large fallen tree at the back of our property which I believe is on the Amtrak 

easement. I wanted to inquire about the possibility of Amtrak clearing it away during this work? 

Thanks

Darren Clipston

Get Outlook for iOS




1

Welt, Angela

From: Ilana Margolin 

Sent: Tuesday, May 09, 2017 2:59 PM

To: Bratcher, Brandon (FRA)

Subject: Bryn Mawr PA electrical substation

Dear Brandon,

My name is Ilana Margolin and I am considering to move my office to bryn Mawr, located right next to the Bryn Mawr

Amtrak electric substation . I understand that there has been a new proposal to the Philadelphia Zoo to Paili

Transmission line project and the bryn Mawr substation will be effected. I am concerned with the potential health

effects working right next to the high voltage powered substation and power lines . Will you be kind enough to call me

to discuss it at or email me your thought on it. I have also read that Amtrak is proposing to replace the

existing Bryn Mawr substation with a more powerful substation. Please address that as well. I greatly thank you for your

input.

Thank you,

Ilana Margolin

Sent from my iPhone


      Appendix E 

Response to Comments 
 E-1 

Appendix E Response to Comments 

A. INTRODUCTION 

This appendix contains a listing of the comments received during the public and agency review 

period for the Philadelphia Zoo to Paoli Transmission Line Project Environmental Assessment 

and Draft Section 4(f) Evaluation (hereafter referred to as Environmental Assessment or EA). The 

EA public review period spanned from April 13, 2017 to May 12, 2017. The resource agency 

review period extended to June 15, 2017. Feedback received during this time frame is included in 

Appendix D “Comments Received.” Comments were received via letter, email, or comment forms 

submitted at the May 4, 2017 public meeting. 

The May 4, 2017 public meeting included an informal question and answer period to enable a 

productive dialogue. The presentation and the display boards are included in Appendix C “Public 

Meeting Materials (May 4, 2017).” Since the public meeting was not a formal public hearing, there 

is no transcript. Attendees were informed that comments and questions discussed during the 

meeting would not become part of the formal public record unless submitted in writing through a 

comment form, letter, or email. Comment themes from the public meeting included: 

 Tree trimming 

 Access through private right-of-way 

 Construction schedule and timing 

 Project funding 

 Electromagnetic impacts 

 Past public involvement. 

The following text quotes relevant excerpts of the written comments verbatim. The FRA noted 

and carefully evaluated all of the comments received on the EA (including the Draft Section 4(f) 

Evaluation and the MOA) before issuing a FONSI. None of the comments raised concerns that 

warranted changing the conclusions reached in the EA regarding potential impact or the selection 

of the Preferred Alternative. 

B. RESOURCE AGENCY COMMENTS 

Lindy Nelson, Regional Environmental Officer, U.S. Department of the Interior, letter dated June 

14, 2017 

Comment 1: The Department concurs that there is no prudent and feasible alternative to 

the proposed use of 4(f) lands, which consist of the Bryn Mawr Substation 

and associated catenary system, which are both contributing resources within 

the Pennsylvania Railroad: Mainline Historic District, which is eligible for 

listing in the National Register of Historic Places. The demolition of these 

contributing resources will be an adverse effect to the historic district, which 

constitutes a 4(f) use. De minimis impacts have also been identified for 5 

resources within the Area of Potential Effect, including Merion Station, 

Haverford Station, Villanova Station, Wayne Station, and Strafford Station. 

The measures to minimize harm must be explicitly consistent with the draft 

Memorandum of Agreement (MOA) developed in consultation with the 

Pennsylvania State Historic Preservation Office, the National Railroad 
E-2 

Passenger Corporation, the Southeastern Pennsylvania Transportation 

Authority, and the Railroad Museum of Pennsylvania. We note that a draft 

copy of the MOA has been included in the documentation of compliance for 

the project and is currently under public review. It reflects appropriate 

procedures for mitigating the adverse effects to cultural resources. 

Response 1: FRA acknowledges the need for explicit adherence with minimization and 

mitigation measures in the draft Memorandum of Agreement (MOA). The 

project team notes and appreciates the concurrence. 

C. STAKEHOLDER COMMENTS 

Angela N. Murray, AICP, Lower Merion Township staff, comment form dated May 4, 2017 

Comment 2: What is the status of the funding of the project? 

What is the proposed start date for construction? 

Please conduct a survey and confirm property lines. 

Please identify trees to be removed on plans. 

All adjacent property owners should be notified of the project. 

Response 2: Funding has not yet been secured for the project. 

Once funding is allocated, the earliest possible start date for construction 

would be spring of 2018. No firm start date is known at this time. 

Property boundary data on current project plans was derived from Interstate 

Commerce Commission railroad valuation maps, the primary source 

documentation for railroad rights of way, and verified against current records 

through Amtrak’s Real Estate department. This is standard practice for 

Amtrak project planning, and no new right-of-way survey is planned for this 

project. 

Tree trimming plans are included in Appendix C of the Environmental 

Assessment as drawings C-0200 through C-0232 of the Paoli to Bryn Mawr 

plans and drawings C-0217 through C-0232 of the Bryn Mawr to Zoo plans. 

The Environmental Assessment and plans are available on the project 

website at https://www.fra.dot.gov/Page/P0810. 

A Community Notification Plan with public outreach for notice to residents 

during construction will be incorporated into the construction process. 

Carole Strickland, Lower Merion Historical Society & Wynnwood Civic Association, comment 

form dated May 4, 2017 

Comment 3: Advanced notification to neighboring residential areas regarding scheduling 

of overnight work is critical. 

Response 3: The project team is sensitive to community impacts to neighbors along rail 

corridors. A Community Notification Plan with public outreach for notice to 
E-3 

residents during construction will be incorporated into the construction 

process. 

D. COMMENTS FROM THE PUBLIC 

David Stewart, email dated April 13, 2017 

Comment 4: I recently received a postcard from the firm of Michael Baker International 

announcing a Public Meeting on May 4, 2017 regarding the Zoo to Paoli 

Transmission Line Project. In addition to the announcement, the postcard 

also showed a website where project documents may be reviewed. My 

particular interest was in the Final Tree Trimming Plans (March 17, 2016). 

Our property is next to AMTRAK's ROW. 

When reviewing the "Tree Pruning Site Plan," I was particularly interested 

in Notes 2 and 5 on Page C-0200. Having lived at this location for nearly 33 

years, we have experienced many AMTRAK tree pruning sessions over the 

years. Our experience has been the opposite of Notes 2 and 5. 

- The Crew shows up un-announced and walks through our properties to get 

to the ROW, without permission. Since I keep our gate locked on the 

backyard fence, the crew uses my neighbor's yard for access to the ROW. 

(Note 2) 

- There have been many pruning sessions on the ROW behind our house and 

the crew just leaves the debris where it falls and it is not removed. (Note 5) 

I hope the trimming crew will abide by the notes on this Tree Pruning Site 

Plan. 

In addition, I would hope that the crew trims the minimum amount possible. 

We really appreciate the tree foliage to screen the train activity. 

Thank you for taking the time to read my comments. If you are not the 

appropriate person to address these issues, I would be grateful if you would 

forward this e-mail to the proper person. 

Response 4: The project team is sensitive to access concerns and notes the need for prior 

contact to property owners adjacent to the proposed project. The tree 

trimming will be monitored in accordance with the contract plans. The 

construction contractor’s team will also include an arborist to direct 

trimming activities. Tree trimming plans are included in Appendix C of the 

Environmental Assessment as drawings C-0200 through C-0232 of the Paoli 

to Bryn Mawr plans and drawings C-0217 through C-0232 of the Bryn Mawr 

to Zoo plans. The Environmental Assessment and plans are available on the 

project website at https://www.fra.dot.gov/Page/P0810. 
E-4 

Darren Clipston, email dated May 3, 2017 

Comment 5: Hi. You are listed as the contact for the Amtrak zoo to paoli transmission 

project. There is a presentation at lower merion township's offices tomorrow 

(May 4th). 

I may not be able to attend. Our property backs up to the train line I wanted 

to ask if Amtrak will be needing to go through our yard as part of this project? 

Our address is ___. 

Also there is a large fallen tree at the back of our property which I believe is 

on the Amtrak easement. I wanted to inquire about the possibility of Amtrak 

clearing it away during this work? 

Response 5: It is the intent of the construction contract that no construction access will be 

allowed through private property. The individual tree mentioned will need 

to be reviewed as part of the pre-construction site planning. 

Craig Fox, comment form dated May 4, 2017 

Comment 6: My property is along the Amtrak ROW. There is an easement about 10 ft. 

What is the impact to the trees on the border of the property? How close is 

the new pole? 

My property! 

Response 6: Tree trimming plans are included in Appendix C of the 

Environmental Assessment as drawings C-0200 through C-0232 of the Paoli 

to Bryn Mawr plans and drawings C-0217 through C-0232 of the Bryn Mawr 

to Zoo plans. The Environmental Assessment and plans, including proposed 

pole locations, are available on the project website at 

https://www.fra.dot.gov/Page/P0810. Your property appears to be between 

T-225 and T-224 on the Bryn Mawr to Zoo plans. Adjacent to your property, 

the existing pole is 31.5’ inside the Amtrak property line, and the new pole 

will be 25’ inside the Amtrak property line. All tree trimming will be within 

Amtrak right-of-way, and tree trimming at this location will be 

approximately 6.5 feet inside the Amtrak property line. The construction 

contractor’s team will include an arborist to direct trimming activities. 

Patrick Yough, comment form dated May 4, 2017 

Comment 7: Will this project clear sufficient trees and brush to minimize travel 

disruptions due to falling trees and branches? Based on recent storms in the 

past few years, service disruptions due to falling trees is a concern. 

Response 7: Tree trimming is intended to alleviate potential future service 

disruptions as part of the project. 

Laura Goetsch, comment form dated May 4, 2017 

Comment 8: I’m concerned about the height of the catenary poles. It would be nice to 

keep the height less than 75 feet where possible. Although my property does 
E-5 

not border the tracks, the overall visual appeal of LM Township is important 

to all residents for maintaining property values. POST NOTE- you have 

addressed this concern 

Thank you for considering conservative approaches to tree trimming. 

Thank you for the detailed presentation and the attention to detail in the 

design. 

Response 8: We appreciate your concerns and have taken every effort in the design to 

minimize the height of the new catenary structures and minimize any visual 

impacts. Related mitigation and environmental commitments associated 

with visual impacts are detailed in Section 3.20 and Section 6.0 respectively 

of the Environmental Assessment. The Environmental Assessment and plans 

showing catenary height (Appendix C) are available on the project website 

at https://www.fra.dot.gov/Page/P0810. 

Frank G. Tatnall, comment form dated May 4, 2017 

Comment 9: What are the prospects for starting construction in 2017? 

Response 9: Construction funding has not yet been allocated for this project. As of this 

finding, the earliest possible start date for construction would be spring of 

2018 – if funding is approved soon. 

Ilana Margolin, email dated May 4, 2017 

Comment 10: My name is Ilana Margolin and I am considering to move my office to bryn 

Mawr, located right next to the Bryn Mawr Amtrak electric substation. I 

understand that there has been a new proposal to the Philadelphia Zoo to 

Paili Transmission line project and the bryn Mawr substation will be 

effected. I am concerned with the potential health effects working right next 

to the high voltage powered substation and power lines. Will you be kind 

enough to call me to discuss it at ___ or email me your thought on it. I have 

also read that Amtrak is proposing to replace the existing Bryn Mawr 

substation with a more powerful substation. Please address that as well. I 

greatly thank you for your input. 

Response 10: An analysis of the effects of electromagentic fields was conducted as part of 

the design. The report, which is included in the Environmental Assessment 

determined, “From the perspective of the regulator, oversight or official 

guidance concerning the “safe” levels of electric or magnetic fields, the 

levels of both electric and magnetic fields observed both by measurement 

and modeling are significantly below any level generally discussed as a 

criteria warranting concern.” A comparison of the proposed electric and 

magnetic field levels and associated levels of concern according to the 

International Commission on Non‐Ionizing Radiation Protection is provided 

below. 
E-6 

Field Proposed Level Level Warranting Concern 

Electric 804 V/m (at 25 Hz) 10,000 V/m (at 25-60 Hz) 

Magnetic 65 mG (at 25 Hz) 2,000 mG (at 25-60 Hz) 

Section 3.6 and Appendix E of the Environmental Assessment address 

concerns associated with electric and magnetic fields. These documents are 

available on the project website at https://www.fra.dot.gov/Page/P0810. 

Karen Cosentino & Donald Smolenski, comment form submitted via email dated May 9, 2017 

Comment 11: 1) VERY CONCERNED about the HEIGHT of the new catenary structures 

between the Wynnewood Train Station and the Church Road Bridge. The 

north side transmission profiles in Appendix C2 of the EA detail that these 

structures will be 75' 2" high while the south side is 60' 2". Specifically, our 

home is located on the north side at ___. With the pole being dead center of 

our lot. Why the extra height on the north side? The span between the 

Wynnewood Train Station and Church Road is 100% residential on the north 

side. A US DOT, Federal Railroad Administration Meeting Notice dated 

8/14/15 stated " ... a majority of the proposed new catenary poles will be 

between 60' 0" and 70' 0" high, with most poles measuring 60' 2". A few 

poles reach 80 feet high at overhead bridges to achieve adequate clearance." 

If the drawings in C2 are correct, this statement is EXTREMELY 

misleading/inaccurate. We are on an open route, not at a bridge. The new 

height will be 50% higher than our current catenary structure which is 

approximately 50' in height according to Appendix C2. There are many other 

lengths of track near residences that have catenary structures of 60' 2" on 

both sides of the track. Why can't the pole heights be reduced along this 

length of track between the Wynnewood Train Station and Church Road 

Bridge? 

2) Can there be a decibel limitation established that contractors MUST abide 

by for nighttime work throughout the duration of this project? 

3) What is the order of construction and electrification? When will the 

project begin? 

4) What is the source of the funding for the project? 

Response 11: 1) The increased height through this area is driven by the narrow width of the 

right of way. In order to maintain the new transmission lines on Amtrak’s 

right-of-way, the transmission lines on the north side needed to be designed 

so that both conductors are on the inside of the structure. The use of this 

design requires the pole heights to be increased to keep the proper electrical 

clearance between conductors 

2) Construction contractors will be required to work within prescribed 

decibel limits for construction noise within the townships where work is 
E-7 

performed. As noted in construction contract specification section 01566: 

“Noise and Vibration Control: The Contractor shall take every action 

possible to comply with noise regulations. The Contractor shall abide by all 

applicable local, state, and federal noise and vibration limits/restrictions as 

they pertain to construction equipment and construction operations. Hauling 

route through residential area should be selected only when other routes are 

not determined practical. All haul routes must be approved by Amtrak’s 

Environmental Manager. All costs associated with this compliance shall be 

the responsibility of the Contractor.” 

3) The specific order of construction has not yet been determined. The 

earliest site work could begin is the spring of 2018 – though, as of the date 

of this finding, no construction funding has yet been allocated. 

4) The funding source for the construction has not yet been established.