Environmental Assessment and Draft Section 4(f) Evaluation March 2017
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Table of Contents

EXECUTIVE SUMMARY (ES) ..................................................................................................................v

ES – Purpose and Need.............................................................................................................................v

ES – Alternatives Analysis .......................................................................................................................v

ES – Affected Environment .....................................................................................................................vi

ES – Environmental Impacts...................................................................................................................vii

ES – Agency Coordination and Public Involvement ................................................................................x

ES – Section 4(f)......................................................................................................................................xi

1.0 INTRODUCTION ............................................................................................................................1

1.1 Purpose and Need .........................................................................................................................1

1.2 Existing Conditions.......................................................................................................................1

1.3 Proposed Action Area ...................................................................................................................3

1.4 Applicable Regulations and Permits.............................................................................................4

2.0 ALTERNATIVES.............................................................................................................................5

2.1 Proposed Action............................................................................................................................5

2.2 No-Build Alternative.....................................................................................................................6

2.3 Alternatives Considered but Eliminated from Detailed Analysis.................................................7

2.3.1 Maintain Bryn Mawr Substation...........................................................................................7

2.3.2 Improve Former Pennsylvania Railroad Line .......................................................................7

2.3.3 Eliminate Electric Service.....................................................................................................7

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ..........................7

3.1 Location and Land Use .................................................................................................................8

3.1.1 Affected Environment and Existing Conditions ...................................................................8

3.1.2 Environmental Consequences...............................................................................................9

3.2 Cultural Resources........................................................................................................................9

3.2.1 Participants............................................................................................................................9

3.2.2 Archaeology........................................................................................................................ 11

3.2.3 Historic Resources .............................................................................................................. 12

3.2.4 Draft Memorandum of Agreement...................................................................................... 15

3.3 Parks and Wildlife Refuges......................................................................................................... 16

3.3.1 Affected Environment......................................................................................................... 16

3.3.2 Environmental Consequences............................................................................................. 17

3.4 Transportation ............................................................................................................................. 18

3.4.1 Affected Environment......................................................................................................... 18

3.4.2 Environmental Consequences............................................................................................. 18

3.5 Noise and Vibration .................................................................................................................... 19

3.5.1 Affected Environment......................................................................................................... 19
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3.5.2 Environmental Consequences............................................................................................. 19

3.6 Electric/Magnetic Fields............................................................................................................. 19

3.6.1 Affected Environment......................................................................................................... 20

3.6.2 Environmental Consequences............................................................................................. 20

3.7 Air Quality .................................................................................................................................. 21

3.7.1 Affected Environment......................................................................................................... 21

3.7.2 Environmental Consequences............................................................................................. 22

3.8 Hazardous Materials and Waste.................................................................................................. 22

3.8.1 Affected Environment......................................................................................................... 22

3.8.2 Environmental Consequences............................................................................................. 23

3.9 Property Acquisitions and Easements......................................................................................... 23

3.9.1 Affected Environment......................................................................................................... 23

3.9.2 Environmental Consequences............................................................................................. 23

3.10 Communities............................................................................................................................... 23

3.10.1 Affected Environment......................................................................................................... 23

3.10.2 Environmental Consequences............................................................................................. 24

3.11 Environmental Justice ................................................................................................................. 24

3.11.1 Affected Environment......................................................................................................... 25

3.11.2 Environmental Consequences............................................................................................. 25

3.12 Visual .......................................................................................................................................... 25

3.12.1 Affected Environment......................................................................................................... 26

3.12.2 Environmental Consequences............................................................................................. 26

3.13 Floodplains.................................................................................................................................. 29

3.13.1 Affected Environment......................................................................................................... 29

3.13.2 Environmental Consequences............................................................................................. 29

3.14 Water Quality.............................................................................................................................. 30

3.14.1 Affected Environment......................................................................................................... 30

3.14.2 Environmental Consequences............................................................................................. 30

3.15 Endangered Species .................................................................................................................... 30

3.15.1 Affected Environment......................................................................................................... 30

3.15.2 Environmental Consequences............................................................................................. 30

3.16 Public Safety ............................................................................................................................... 31

3.17 Construction................................................................................................................................ 31

3.17.1 Timing and Sequencing ...................................................................................................... 31

3.17.2 Property Acquisitions and Easements................................................................................. 31

3.17.3 Transportation ..................................................................................................................... 32

3.17.4 Noise and Vibration ............................................................................................................ 32
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3.17.5 Air Quality .......................................................................................................................... 32

3.17.6 Tree Trimming .................................................................................................................... 33

3.17.7 Water Quality...................................................................................................................... 33

3.17.8 Contingency Planning......................................................................................................... 33

3.18 Indirect Impacts .......................................................................................................................... 33

3.19 Cumulative Impacts .................................................................................................................... 33

3.20 Mitigation.................................................................................................................................... 36

4.0 DRAFT SECTION 4(F) EVALUATION....................................................................................... 38

4.1 Section 4(f) Requirements .......................................................................................................... 38

4.2 Section 4(f) Resources................................................................................................................ 40

4.3 Section 4(f) Use .......................................................................................................................... 40

4.3.1 Public Parks and Wildlife Refuge ....................................................................................... 40

4.3.2 Historic Resources .............................................................................................................. 41

4.4 Alternatives Considered to Avoid Section 4(f) Resources.......................................................... 42

4.4.1 No-Build Alternative........................................................................................................... 42

4.4.2 Alternatives Considered but Eliminated from Detailed Analysis....................................... 42

4.5 All Possible Planning to Minimize Harm ................................................................................... 43

4.6 Section 4(f) Conclusion .............................................................................................................. 44

5.0 AGENCY, PUBLIC, AND CONSULTING PARTY INVOLVEMENT....................................... 44

5.1 Agency Coordination .................................................................................................................. 44

5.2 Public and Consulting Party Involvement................................................................................... 45

5.2.1 Public Activities and Section 106 Meetings ....................................................................... 45

5.2.2 Public Comments................................................................................................................ 47

6.0 ENVIRONMENTAL COMMITMENTS ....................................................................................... 50

7.0 NEXT STEPS ................................................................................................................................. 51

8.0 LIST OF PREPARERS................................................................................................................... 51

9.0 DISTRIBUTION LIST ................................................................................................................... 52

10.0 REFERENCES ............................................................................................................................... 53
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List of Appendices

A. Topographic Maps

B. Aerial Photographs

C. Design Plans (C1. Paoli to Bryn Mawr & C2. Bryn Mawr to Zoo)

D. Cultural Resources Mapping and Correspondence

E. Report on Electric, Magnetic Fields and Radio Noise

F. Soil Management Plan

G. Public Officials, Public, and Consulting Parties Meetings Summaries

H. Flood Insurance Rate Maps

I. Threatened and Endangered Species Correspondence

List of Tables

Table ES-1: Mitigation Measures

Table ES-2: Environmental Commitments

Table 1: NRHP-Eligible and NRHP-Listed Resources in the APE

Table 2: Electric and Magnetic Fields

Table 3: Mitigation Measures

Table 4: Public Involvement and Section 106 Meetings

Table 5: Questions and Concerns Noted at Public Involvement Meetings

Table 6: Environmental Commitments

List of Figures

Figure 1: Catenary Structure Photograph

Figure 2: Existing and Proposed Transmission Right-of-way

Figure 3: Substations and Passenger Stations within the Proposed Action Route

Figure 4: Municipalities within the Proposed Action Route
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EXECUTIVE SUMMARY (ES)

This Environmental Assessment (EA) has been prepared for the Philadelphia Zoo to Paoli 

Transmission Line Project to provide the Federal Railroad Administration (FRA) and the public 

with a full accounting of the environmental impacts of proposed improvements to the 

deteriorated electrification system on 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 (Mile Post 20.5) and the construction of new transmission lines in 

Amtrak right-of-way to replace the existing transmission lines in the former Pennsylvania 

Railroad right-of-way (Proposed Action). This EA serves as the primary document to facilitate 

review of the Proposed Action by federal, state, and local agencies and the public. This EA was

produced pursuant to the Council on Environmental Quality’s implementing regulations (40 

C.F.R. Parts 1500-1508), FRA’s Procedures for Considering Environmental Impacts, 64 Federal 

Register [FR] 28545 (May 26, 1999), 49 CFR § 260.35, and other applicable laws and 

regulations.

ES – Purpose and Need

Pennsylvania’s Keystone Corridor East is a rail route owned by Amtrak, extending from 

Philadelphia to Harrisburg. The Proposed Action involves improvements to the deteriorated 

electrification system on 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 (Mile Post 20.5). The Proposed Action would cross through Philadelphia,

Montgomery, Delaware, and Chester counties in Pennsylvania. The Proposed Action involves 

construction of new transmission lines, replacement of 276 and addition of 49 catenary structures

(325 total), construction of one additional gantry at Paoli Substation, and replacement of the 

obsolete substation at Bryn Mawr (Bryn Mawr Substation). 

The purpose of the Proposed Action is to maintain and improve passenger train service using 

electric-powered 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 also the location of transmission lines on former Pennsylvania 

Railroad right-of-way that complicate maintenance of these lines.

ES – Alternatives Analysis

This EA evaluates a No-Build Alternative and a Build Alternative, referred to as the Proposed 

Action.

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 former Pennsylvania 
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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. The NoBuild Alternative would result in no change in environmental impacts to resources compared to 

existing conditions. The No-Build Alternative is not recommended as it does not meet the 

Proposed Action’s stated purpose and need. 

The Proposed Action includes the following components:

 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 existing transmission lines would be deactivated, but the existing 

infrastructure would not be physically altered.

 Replacement of 276 and addition of 49 catenary structures (325 total) 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 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, but 49 additional catenary structures would also 

be added at new locations for a proposed total of 325 catenary structures. The additional 

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 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.

Beyond the aforementioned replacements of the Bryn Mawr Substation and 276 catenary 

structures, none of the extant train stations or other major built elements of the railroad corridor 

would be demolished or otherwise physically affected.

ES – Affected Environment

This EA focuses on those resources that have a reasonable likelihood to be impacted by the 

Proposed Action. Navigable waterways, coastal zones, wetlands, farmlands, and critical habitats 
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are not present within the Proposed Action area and are therefore not addressed in this document. 

Resources present within the Proposed Action area were identified using a combination of 

agency review/coordination, secondary and on-line resource reviews, and field surveys. 

Resource areas addressed in the EA include: 

 Location and Land Use

 Cultural Resources

 Parks and Wildlife Refuges

 Transportation

 Noise and Vibration

 Electric/Magnetic Fields

 Air Quality

 Hazardous Materials and Waste

 Property Acquisition and Easements

 Communities

 Environmental Justice

 Visual 

 Floodplains

 Water Quality

 Endangered Species

 Public Safety

 Construction

ES – Environmental Impacts

This EA evaluates anticipated direct, indirect, and cumulative impacts of the Proposed Action to 

the resources present within the Proposed Action area to determine if these impacts would be

significant. The impacts evaluation is based on appropriate federal and state laws, regulations, 

and agency guidelines. Evaluation methodologies and impacts to resources are discussed in 

detail in Section 3.0. 

This EA concludes that the Proposed Action, which includes mitigation measures and 

environmental commitments discussed below, would have no potential significant environmental 

impacts. Mitigation measures are listed in Table ES-1. Table ES-2 details environmental 

commitments, which have been incorporated into the planning and design of the Proposed 

Action in order to avoid, minimize, or mitigate potential impacts.

Table ES-1: Mitigation Measures

Potential Impact Mitigation

Cultural Resources: 

The Proposed Action would 

have an adverse effect on the 

National Register 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 Draft Memorandum of Agreement (MOA) has been developed

between the FRA, Amtrak, Railroad Museum of Pennsylvania

(RRMPA), SEPTA, and the Pennsylvania State Historic Preservation 

Office (PA SHPO), which includes commitments by Amtrak to

minimization measures and mitigation measures to minimize impacts 

and to mitigate potential adverse effects to the Pennsylvania Railroad 

Main Line and its contributing resources. 

Minimization Measures:

A. Limit catenary structure heights (60-75 feet at most 

locations);

B. Implement targeted tree trimming program to avoid universal 

trimming or clear cutting;
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Table ES-1: Mitigation Measures

Potential Impact Mitigation

C. Place new catenary structures as near as practicable to existing 

catenary structures; and

D. Avoid physical impacts to train stations along the Proposed 

Action corridor.

Mitigation Measures:

A. Documentation

1. Record the Bryn Mawr Substation and related catenary 

system to Historic American Engineering Record 

Documentation Level II.

B. Intepretation

1. Provide an interpretive sign inside the Bryn Mawr station 

building.

2. Donate materials and elements of the catenary system that 

Amtrak or its contractors remove from the historic Bryn 

Mawr Substation to RRMPA.

3. Make financial contribution to RRMPA dedicated to the 

conservation of donated materials.

4. Make reasonable efforts to provide to RRMPA contact 

information for current or former Amtrak Electric Traction 

Department employees for the purpose of conducting oral 

history interviews.

C. Design

1. Design new substation to be consistent with the materials, 

color, and texture of the existing Bryn Mawr Substation 

(e.g. buff brick exterior walls), but will not mimic the 

historic building to make it clear that the new buildings are 

non-historic and do not create a false sense of history. 

Amtrak will submit the proposed design to PA SHPO for 

review and approval prior to construction; PA SHPO will

provide comments within 30 days of receipt of the draft 

design.

2. Incorporate the “Bryn Mawr Substation” sign currently on 

the historic building into a new retaining wall or other 

landscape feature adjacent to the Bryn Mawr Substation 

site.

3. Offer the bricks from the historic Bryn Mawr Substation 

for salvage upon removal of the building. 

An Unanticipated Discoveries Plan has also been created and 

appended to the Draft MOA, in case any unanticipated archaeological 
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Table ES-1: Mitigation Measures

Potential Impact Mitigation

resources are encountered during construction.

The Draft MOA’s stipulations for minimization, mitigation, and design

measures will minimize impacts and mitigate the adverse effect of the 

Proposed Action.

Transportation: Parking spaces 

would be lost at the Bryn Mawr 

Train Station.

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.

Visual: Taller catenary poles, 

tree trimming, and the 

replacement of the Bryn Mawr 

Substation were identified as 

concerns for potential impacts 

to the area adjacent to the 

Proposed Action during the 

public involvement process.

While the Draft MOA for Cultural Resource impacts serves to 

minimize and mitigate potential impacts to cultural resources, some of 

the same Draft MOA minimization and mitigation measures serve to 

minimize and mitigate visual impacts. Minimization measures 

include:

A. Limit catenary structure heights (60-75 feet at most locations);

B. Implement targeted tree trimming program to avoid universal 

trimming or clear cutting;

C. Place new catenary structures as near as practicable to existing 

catenary structures; and

D. Design new Bryn Mawr Substation to be consistent with the 

materials, color, and texture of the existing Bryn Mawr 

Substation (e.g. buff brick exterior walls), but will not mimic 

the historic building to make it clear that the new buildings are 

non-historic and do not create a false sense of history.

Table ES-2 details the environmental commitments that Amtrak would incorporate during the 

final design and construction phases, to avoid, minimize and/or mitigate potential impacts, as 

appropriate.

Table ES-2: Environmental Commitments

Environmental Commitment

 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.
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Table ES-2: Environmental Commitments

Environmental Commitment

 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. 

 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 Pennsylvania Game Commission (PGC), 

the Pennsylvania Department of Conservation and Natural Resources (PA DCNR), the 

Pennsylvania Fish and Boat Commission (PFBC), and the U.S. Fish and Wildlife Service (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. This plan specifies waste management procedures and precautions for construction 

activities within areas of environmental concern within the construction zone.

ES – Agency Coordination and Public Involvement

Agency coordination was conducted with the FRA, Amtrak, RRMPA, SEPTA, and the PA 

SHPO regarding cultural resources. The comments received from these agencies were 

incorporated into the cultural resources analyses, as well as the Draft MOA. Agency 

coordination was also conducted with the PGC, the PA DCNR, the PFBC, and the U.S. FWS 

regarding threatened and endangered species, with a response from each of these regulatory 

agencies that no impacts to threatened and endangered species were anticipated.

Feedback on the Proposed Action was also solicited from public officials, stakeholders, 

Consulting Parties, and the general public at 10 stakeholder and public meetings held between 

April 2012 and September 2015. Information was presented and handed out, with comments 

solicited/provided through question-and-answer discussions and written surveys. The primary 
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areas of concern identified from public involvement are visual impacts caused by higher catenary 

poles and tree trimming, as well as impacts related to cultural resources, construction 

noise/lights, fate of retired equipment, public outreach, the demolition of Bryn Mawr Substation, 

and vibration. This EA evaluated these, as well as other, potential impacts of the Proposed 

Action. A public meeting will be held to present this EA to the public for comment on the EA 

and on the Proposed Action itself. 

The outcome from agency coordination and concerns raised during public involvement activities 

were considered and incorporated, as appropriate, during the design and environmental review 

processes. This resulted in elevating the National Environmental Policy Act document for the 

Proposed Action from a Categorical Exclusion to an EA, altering the pole height design,

establishing mitigation measures, and establishing the environmental commitments.

ES – Section 4(f)

Chapter 4.0 provides the Draft Section 4(f) Evaluation for the Proposed Action. A Section 4(f) 

Evaluation determines if an action requires the use of a Section 4(f) resource. The Draft Section 

4(f) Evaluation determined that:

 There would be no temporary or permanent 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.

 The Proposed Action will require use of five individually eligible or listed historic 

resources: Merion Station, Haverford Station, Villanova Station, Wayne Station, and 

Strafford Station. It appears that the Proposed Action will take place within the 

boundaries of these five historic properties. 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. Therefore, pursuant to 49 U.S.C. § 303(d), a Section 4(f) finding 

of de minimis impact is applicable to the 5 resources with findings of no adverse effect 

within the Proposed Action work area. PA SHPO concurred with this Section 4(f) de 

minimis use finding on March 7, 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, with all of these properties being outside of the Proposed Action 

work area. Section 4(f) requirements are considered satisfied for these 21 historic 

resources.
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 FRA has determined that the removal and replacement of the catenary structures and the 

demolition of the Bryn Mawr Substation would amount to a use of the Pennsylvania 

Railroad Main Line. Through Section 106 consultation, FRA made a finding of adverse 

effect for the Pennsylvania Railroad Main Line. The Pennsylvania Railroad Main Line 

would be adversely affected 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 Pennsylvania Railroad Main Line. PA SHPO has concurred 

with this finding. Because the Proposed Action will result in a use of and an adverse 

effect on the Pennsylvania Railroad Main Line, avoidance alternatives and measures to 

minimize harm were considered as part of the Section 4(f) process. The analysis 

determined 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 the measures to minimize harm in 

accordance with the consultation process under 36 CFR Part 800.
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1.0 INTRODUCTION

Amtrak proposes improvements on the Keystone Corridor East, within the existing Amtrak rightof-way between the Zoo Substation (Mile Post 2.5) in central Philadelphia and the Paoli 

Substation (Mile Post 20.5), including 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

(Proposed Action). Because the Federal Railroad Administration (FRA) anticipates funding the 

Proposed Action, it has prepared this Environmental Assessment (EA) to evaluate the Proposed 

Action’s environmental impacts in compliance with the National Environmental Policy Act (42 

U.S.C. § 4321 et seq.) (NEPA). NEPA requires federal agenceis to consider the impacts of their 

action on the natural, social, economic, and cultural environment and to disclose considerations 

in a public document. The purpose of this NEPA document is to provide the FRA and the public 

with a full accounting of the environmental impacts of the alternatives developed to meet the 

Proposed Action purpose and need. The EA serves as the primary document to facilitate review 

of the Proposed Action by federal, state, and local agencies and the public. This EA was 

prepared in compliance with NEPA, Council on Environmental Quality’s implementing 

regulations (40 C.F.R. Parts 1500-1508), the FRA’s Procedures for Considering Environmental 

Impacts, 64 Federal Register [FR] 28545 (May 26, 1999) and 49 CFR § 260.35, and other 

applicable laws and regulations.

1.1 Purpose and Need

The purpose of the Proposed Action is to maintain and improve passenger train service using 

electric-powered 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 former Pennsylvania 

Railroad right-of-way that complicate maintenance of these lines.

1.2 Existing Conditions

The Proposed Action is recommended in response to substantial deterioration and frequent, 

extensive, emergency repairs to 276 existing catenary structures on Amtrak’s Keystone Corridor 

East. 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 (see Figure 1). These catenary 

structures are approaching 100 years in age and are beyond their useful life.
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Figure 1: Catenary Structure Photograph

Additionally, low voltage conditions are currently experienced in the middle of the 18 mile 

stretch between Zoo Substation and Paoli Substation, as this is the only segment of the Keystone 

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

slower, less reliable operation.

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-ofway, but are located along the former Pennsylvania Railroad right-of-way (see Figure 2). The 

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. Catenary Pole Catenary Pole

Wire Head Span
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Figure 2: Existing and Proposed Transmission Right-of-way

1.3 Proposed Action Area

The Proposed Action would occur entirely within the existing Amtrak right-of-way along an 

existing 18 mile section of the Keystone Corridor East between the Zoo Substation (Mile Post 

2.5) in central Philadelphia, PA, and the Paoli Substation (Mile Post 20.5) in Chester County, 

PA. The Amtrak right-of-way width varies throughout the Proposed Action area. Typically, it is 

between 90 and 150 feet, but is wider at stations and is as wide as 250 or 300 feet where the track

grading required significant cut or fill.

Figure 3 shows the route between the Zoo and Paoli substations, including Amtrak and/or 

Southeastern PA Transportation Authority (SEPTA) passenger stations.
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Figure 3: Substations and Passenger Stations within the Proposed Action Route

Land uses surrounding this section of the corridor consist mainly of residential and commercial 

uses (see Section 3.1 for details). Topographic maps are included as Appendix A, and aerial 

photographs are included as Appendix B.

1.4 Applicable Regulations and Permits

The following statutes, Executive Orders, and regulations were considered during the preparation 

of the EA:

 NEPA of 1969, 42 U.S.C. § 4321 et seq. 

 Endangered Species Act, 16 United States Code (U.S.C.) § 1531 et seq. 

 Clean Water Act, 33 U.S.C. § 1251 et seq. 

 Section 404 of the Clean Water Act, 33 U.S.C. § 1344

 Clean Air Act, 42 U.S.C. § 7401 et seq. 

 Sections 9 and 10 of the Rivers and Harbors Act of 1899, 33 U.S.C. § 401

 Section 106 of the National Historic Preservation Act of 1966, as amended, 54 U.S.C § 

3016108

 Section 4(f) of the U.S. Department of Transportation Act of 1966, 49 U.S.C. § 303 

 Section 6(f) of the Land and Water Conservation Act of 1965, 16 U.S.C. § 460 

 Executive Order 11988, Floodplain Management, 42 FR 26951, May 24, 1977 

 Executive Order 11990, Protection of Wetlands, 42 FR 26961, May 24, 1977 

 Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, 59 FR 7629, February 11, 1994 
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 FRA Procedures for Considering Environmental Impacts, 64 FR 28545, May 26, 1999 

and 49 CFR § 260.35 

 Regulations for Implementing the Procedural Provisions of the NEPA, 40 CFR Parts 

1500-1508, November 29, 1978

 Migratory Bird Treaty Act, 16 USC § 703-712

 Bald and Golden Eagle Protection Act, 16 USC § 668-668d

 Federal Register, General Provisions; Revised List of Migratory Birds; Final Rule, 50

CFR Parts 10 and 21, November 1, 2013

 Federal Register, Taking, Possession, Transportation, Sale, Purchase, Barter, Exportation, 

and Importation of Wildlife and Plants, 50 CFR Part 22 – Eagle Permits. 39 FR 1183, 

January 4, 1974

The following permits or clearances are required for the Proposed Action: 

 Threatened and Endangered Species Consultation (see Section 3.15)

 Section 106 Consultation Process (see Section 3.2)

 Erosion and Sedimentation Control Plan (ESCP) or National Pollutant Discharge 

Elimination System (NPDES) Permit - General (contractor’s responsibility)

2.0 ALTERNATIVES

2.1 Proposed Action

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 existing transmission lines would be deactivated, but the existing 

infrastructure would not be physically altered.

 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 
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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.

There would be no additional demolition or physical changes to the train stations or built 

elements of the railroad corridor under the Proposed Action. 

Designs for the Proposed Action are included as Appendix C. Funding for construction of the 

Proposed Action has not yet been awarded. It is anticipated that construction would take place 

between Fall 2017 to Fall 2022.

2.2 No-Build Alternative

Under the No-Build Alternative, no catenary structures, catenary wires, or 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 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. A consequence of the location of transmission lines within the 

former Pennsylvania Railroad right-of-way is that the existing trains operated by Amtrak and

SEPTA experience low-voltage conditions in the middle of this section of railroad during periods 

of higher train density. This problem is likely to worsen over time, as train traffic is projected to 

increase in the future. These future increases in train traffic may be limited by the available 

power supply.

The No-Build Alternative would result in no change in environmental impacts to the resources 

described in Section 3.0, compared to existing conditions. Because it would fail to meet the 

Proposed Action’s stated purpose and need (see Section 1.1), the No-Build Alternative is not 

recommended.
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2.3 Alternatives Considered but Eliminated from Detailed Analysis

The following alternatives to the Proposed Action were considered but eliminated from detailed 

analysis because they would fail to meet the Proposed Action’s purpose and need and/or proved 

to be impractical due to cost or land use constraints.

2.3.1 Maintain Bryn Mawr Substation

One alternative was similar to the Proposed Action, except instead of demolishing the existing 

Bryn Mawr Substation, a new traction power substation would be built elsewhere in Bryn Mawr. 

However, finding several acres of available land near Bryn Mawr adjacent to the Main Line and 

utilizing it for a traction power substation proved difficult. The surrounding area is densely 

developed and acquiring land for the substation construction would likely result in costly legal 

fees, possible public opposition, and displacement of existing building occupants. Amtrak owns

the land used for a parking lot adjacent to the current Bryn Mawr Substation; however, using this 

land for a new substation would result in the loss of many well used commuter parking spaces.

2.3.2 Improve Former Pennsylvania Railroad Line

A second alternative considered but eliminated from detailed analysis involved replacing the 

catenary poles and incorporating new transmission lines on the former Pennsylvania Railroad 

rights-of-way (see Figure 2 in Section 1.2). This alternative would be much more costly to 

complete due to route length and would not resolve the accessibility issue for Amtrak 

maintenance crews.

2.3.3 Eliminate Electric Service

The third alternative considered but eliminated involved removing the deteriorated catenary 

structures and all catenary wires and transmission lines, and returning the railroad system to one 

that supports a diesel line. This alternative would result in a functionally obsolete system and 

would not result in the improvement of electric passenger train service for Amtrak and SEPTA.

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES

This EA focuses only on those resources that have a reasonable likelihood to be impacted by the 

Proposed Action. Navigable waterways, coastal zones, wetlands, farmlands, and critical habitats 

are not present within the Proposed Action area and are therefore not addressed in this document. 

The anticipated direct, indirect, and cumulative impacts of the Proposed Action to the resources 

present and evaluated in this EA are discussed in this chapter.

The No-Build Alternative would result in no change in environmental impacts to the resources 

described in this Section compared to existing conditions, so it is not discussed in each of the 

following sections. However, 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. In turn, 

the frequent repairs increase safety risk for Amtrak’s maintenance crews. The No-Build 
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Alternative would also affect projected increases in train traffic, as the spacing of traction power 

substations would remain unchanged and would limit the available power supply.

3.1 Location and Land Use

County and municipal maps, land use maps, United States Geological Survey (USGS) maps, 

aerial photographs, and on-line GIS mapping were consulted and reviewed. These maps were 

used to identify municipalities and characterize the setting within and surrounding the Proposed 

Action area. These maps were also used to identify the location of public facilities, parks, and 

wildlife refuges in or adjacent to Proposed Action area. 

3.1.1 Affected Environment and Existing Conditions

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 4, 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).

Figure 4: Municipalities within the Proposed Action Route

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 can also be found 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. Topographic maps are included 
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as Appendix A, and aerial photographs are included as Appendix B for more detail on land use 

within the Proposed Action area.

3.1.2 Environmental Consequences

The Proposed Action is located within an existing railroad corridor. Under the Proposed Action, 

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. No impacts on land 

use or zoning are anticipated.

3.2 Cultural Resources

This subsection evaluates the Proposed Action’s effects on historic, architectural, and 

archaeological resources. Section 106 of the National Historic Preservation Act of 1966, as 

amended (54 U.S.C § 306108), and implementing regulations codified in 36 CFR Part 800, as 

amended require Federal agencies to consider the effect of undertakings on resources that are 

listed or eligible for listing on the National Register of Historic Places. Because FRA has 

determined that if it provides financial assistance to construct the upgrades and replacements 

required under the Proposed Action, the Proposed Action would be an undertaking subject to 

Section 106, it authorized Amtrak to engage in the Section 106 consultation process, including 

identification of historic resources, assessment of adverse effects in consultation the 

Pennsylvania State Historic Preservation Officer (PA SHPO), and resolution of adverse effects 

with the PA SHPO and other consulting parties.

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. The APE for historic resources was delineated to include

properties for which there could be potential direct physical effects from the proposed

construction work and also to include properties for which there could be potential indirect 

effects (primarily visual) on historic properties. Identification of resources within the APE was 

performed between 2011 and 2016, utilizing guidance from the Advisory Council on Historic 

Preservation (ACHP) set forth in 36 CFR Part 800, as amended, and Executive Order 11593.

Following identification, the potential impacts of the Proposed Action on both archaeological 

and historic resources were investigated in consultation with the PA SHPO. 

3.2.1 Participants

As described in 36 CFR § 800.2, participants in the Section 106 process may include the agency 

officials, the ACHP, Consulting Parties, and the public. Consulting Parties may include the PA 

SHPO; Indian tribes; representatives of local governments; and applicants for Federal assistance, 

permits, licenses, and other approvals. Additional Consulting Parties may include individuals 

and organizations with a demonstrated interest in the undertaking due to the nature of their legal 

or economic relation to the undertaking or affected properties or their concern with the 

undertaking’s effects on historic properties.
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Representatives from 52 organizations (see Appendix D) were invited to participate as 

Consulting Parties in the Section 106 process and were sent eligibility, effects, and mitigation

recommendations for review. Amtrak received and considered comments from the following 14

organizations:

 Historic Preservation Section, Delaware County Planning Department

 Haverford Township Historical Commission

 Lower Merion Township Historic Architectural Review Board (HARB)

 Lower Merion Township

 Wynnewood Civic Association

 Haverford Station Historic District Neighborhood Coalition

 Lower Merion Historical Society

 Preservation Alliance for Greater Philadelphia

 National Railway Historical Society - Philadelphia Chapter

 Railroad Museum of PA (RRMPA)

 Delaware Valley Association of Rail Passengers

 PA SHPO

 Tuscarora Nation

 Delaware Tribe of Indians

Coordination with federally recognized Native American tribes was initiated in April 2012 

(Tuscarora Nation) and August 2015 (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 Stockbridge-Munsee Band of the Mohican Nation of 

Wisconsin) in order to begin Government-to-Government consultation on the Proposed Action. 

The purpose of the consultation was first to incorporate tribal concerns for locations of 

traditional or cultural significance into the cultural resource survey process and, second, to 

provide an opportunity for participation in the process of identifying cultural resources, effects of 

the Proposed Action on significant resources, and resolution of any adverse effects, which may 

result from the Proposed Action. The Tuscarora Nation and the Delaware Tribe of Indians asked 

to be included on the Consulting Parties distribution list, and the Delaware Tribe of Indians 

asked to receive copies of the cultural resources reports, but did not provide any comments on 

the Proposed Action. The Tribal Consultation letters are included in Appendix D.

Coordination with Consulting Parties is summarized in Section 5.2 and is detailed in the 

Determination of Effects Report (August 2015). Section 106 Consulting Parties meetings were 
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held in June 2013, September 2014, June 2015, and September 2015. Coordination with the 

Consulting Parties occurred throughout the Proposed Action development to obtain input and 

comments on the APE, the historic resource identification, effects determinations, and possible

minimization and mitigation measures of the adverse effect of the Proposed Action on historic 

properties.

3.2.2 Archaeology

In 2012, a Phase IA geomorphology and archaeology reconnaissance survey was completed for 

the Proposed Action, the results of which are presented in the Phase 1A Geomorphology / 

Archaeology Reconnaissance Report (November 21, 2012). The survey included background 

research and a field survey of the entire APE for archaeology to determine the probabilities for 

the presence of intact, significant historic and pre-contact archaeological resources that might be 

adversely impacted by the Proposed Action construction. The 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.

3.2.2.1 Affected Environment

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. 

3.2.2.2 Environmental Consequences

Based on the above analysis, the Proposed Action, as currently designed, would not impact any 

known National Register of Historic Places (NRHP) -listed or -eligible archaeological properties. 

The PA SHPO concurred with this finding in a letter dated January 15, 2013 (see Appendix D). 

Subsequent design changes for the Bryn Mawr Substation demolition and new Bryn Mawr 

Substation construction prompted additional archaeological investigation and submission of 

findings to PA SHPO of no additional work required. The PA SHPO concurred with this finding 

in a letter dated January 7, 2016. 

Additionally, an Unanticipated Discoveries Plan has been prepared for the Proposed Action and 

is appended to the Draft Memorandum of Agreement (MOA) (see Appendix D). The 

Unanticipated Discoveries Plan stipulates that in the event that unanticipated archaeological 

resources are encountered during construction, Amtrak shall cease work in the affected area and 

PA SHPO and FRA would be notified immediately. The discovery of human remains requires 

notification of the coroner and PA SHPO, and FRA would determine when it is appropriate to 

notify Native American groups.

Cultural resources correspondence is included as Appendix D.
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3.2.3 Historic Resources

In order to assess the impact of the Proposed Action on historic properties, a historic resource 

APE for historic architectural resources was defined in consultation with the PA SHPO and 

Consulting Parties. The APE was delineated to include properties for which there could be 

potential direct physical effects from the proposed construction work. The APE also accounted 

for potential indirect effects on historic properties; potential indirect effects are primarily visual

due to the increased heights of the new catenary structures and the tree trimming that would be 

performed in certain areas at the edge of the right-of-way for the new catenary structure 

installation.

PA SHPO’s Cultural Resources Geographic Information System (CRGIS) was consulted in order 

to identify previously recorded historic properties - those that are eligible for listing or are 

already listed in the NRHP within the historic resources APE. A survey of the historic resources 

APE was conducted to confirm or refute the presence of the previously surveyed resources and 

to identify additional resources in the APE that could potentially be eligible for listing in the 

NRHP. 

3.2.3.1 Affected Environment

According to PA SHPO’s CRGIS, there were 26 previously recorded resources identified as 

NRHP-eligible or NRHP-listed within the APE. Five additional resources were surveyed and 

evaluated for NRHP eligibility in the Historic Resources Study/Determination of Eligibility

Report (February 2015). The report recommended two resources – the Clonmel-Rosslevyn 

Residence and the Devereux Foundation - as eligible for listing in the NRHP. The PA SHPO

concurred that these two additional resources are eligible for the NRHP either individually or as 

contributing resources on March 16, 2015 and April 24, 2015 (see Appendix D).

Subsequent to these studies, it was discovered that one of the 28 historic properties, the 

Villanova Station, was only determined NRHP-eligible as a contributing resource to the 

Pennsylvania Railroad Main Line (Philadelphia to Harrisburg), not as an individual resource. 

Therefore, only 27 individually NRHP-eligible or -listed resources are located within the APE. 

As shown in Table 1, 27 historic resources within the historic resource APE are listed on or 

individually eligible for the NRHP. Cultural resources mapping and correspondence are 

included as Appendix D.

Table 1: NRHP-Eligible and NRHP-Listed Resources in the APE

Status Resource Status Resource

Listed Fairmount Park Historic District Eligible Radnor Station

Eligible 40th Street Bridge over Amtrak Eligible Louella Court Historic District

Eligible 42nd Street Bridge over Amtrak Listed Wayne Station
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Table 1: NRHP-Eligible and NRHP-Listed Resources in the APE

Status Resource Status Resource

Listed Parkside Historic District Listed North Wayne Historic District

Eligible Belmont Avenue Historic District Listed Downtown Wayne Historic District

Listed Overbrook Farms Historic District 

(incl. Overbrook Station)

Listed Strafford Station

Eligible SR 1 Bridge over Amtrak Listed Cramond

Eligible Merion Station Eligible Grove Avenue Service Station

Eligible Wynnewood Station Eligible Pennsylvania Railroad (Philadelphia to 

Morrisville/New York)

Eligible Ardmore Commercial Historic

District

Eligible Pennsylvania Railroad (Philadelphia to 

Harrisburg)

Eligible Haverford Station Eligible The Philadelphia & Western Railroad

(Norristown High Speed Line)

Eligible Our Mother of Good Counsel 

Roman Catholic Church

Eligible William Penn Mile Markers (only Ardmore 

marker out of 12 total is within the APE)

Eligible Villanova University Campus Eligible Devereux Foundation

Eligible Clonmel-Rosslevyn Residence

3.2.3.2 Environmental Consequences

According to the regulations set forth in 36 CFR Part 800, because historic properties are located 

within the APE for the undertaking, it is necessary to assess whether the undertaking may affect 

these properties. Historic resource effect findings can be categorized as No Historic Properties 

Affected, No Adverse Effect, or Adverse Effect. If the agency official finds that there are no 

historic properties present in the APE or if there are historic properties present but the 

undertaking will have no effect on them, a finding of No Historic Properties Affected will be 

made.

If it is found that the undertaking may affect historic properties in the APE, the Criteria of 

Adverse Effect are applied. An Adverse Effect is found when an undertaking may alter, either 

directly or indirectly, the characteristics of a historic property that qualify it for inclusion in or 

eligibility for the NRHP in a manner that would diminish the integrity of the property’s location, 

design, setting, materials, workmanship, feeling, or association. 

The initial effects analysis to the 2014 Historic Resources Study, resulted in a finding of Adverse 

Effect because of the Proposed Action’s direct physical effects to the NRHP-eligible

Pennsylvania Railroad Main Line (Philadelphia to Harrisburg), due to the removal and 

replacement of catenary structures with taller structures and the demolition of the Bryn Mawr 

Substation (both of which are contributing resources to the Pennsylvania Railroad Main Line). 
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As part of the public involvement meetings during the design process, Amtrak reduced the 

catenary structures heights and prepared a tree trimming plan to be implemented prior to 

construction of the Proposed Action. The Determination of Effects Report for the refined 

Proposed Action resulted in a finding of:

 No Historic Properties Affected for 16 historic properties

 No Adverse Effect on 10 historic properties

 Adverse Effect on 1 historic property

An assessment of the Proposed Action’s indirect visual effects on each identified resource in the 

APE resulted in the finding that none of the potential visual impacts, including the introduction 

of the increased catenary structure heights and the limited tree trimming, would adversely affect 

the characteristics that qualify the resources for listing in the NRHP. The railroad infrastructure, 

including its catenary system, has historically been an integral component of the railroad system 

and its overall physical setting. Furthermore, the nineteenth- and early twentieth-century siting 

and construction of the historic properties in the railroad’s immediate vicinity were a direct result 

of the railroad’s presence. The properties have historically had the railroad and its 

accompanying infrastructure within their view. Thus, the presence of new catenary structures, 

including the height addition, would not present an adverse effect.

The finding of adverse effect on one historic property is a result of the direct physical effects of 

the Proposed Action to the 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, both of which are contributing resources to the Pennsylvania Railroad Main Line.

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.

Measures to mitigate the adverse effects of the Proposed Action have been identified at the 

Section 106 Consulting Parties meetings, and the agreed upon mitigation measures for the 

Proposed Action are included in a Draft MOA between FRA, Amtrak, RRMPA, SEPTA, and the 

PA SHPO. RRMPA and SEPTA participated in the consultation and have been invited to be 

signatories to the MOA, because they will be responsible for executing portions of the mitigation 

stipulations (see Section 3.2.4).

On October 8, 2015, the PA SHPO concurred with these effects determinations and stated that 

there has been adequate consultation with the PA SHPO and the Consulting Parties regarding 

ways to avoid, minimize, or mitigate effects on historic properties. 
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An Addendum to the 2015 Determination of Effects Report was submitted to the PA SHPO on 

June 17, 2016, to address the potential effect of the re-design of certain catenary poles to avoid 

trimming vegetation outside of Amtrak right-of-way. On July 19, 2016, the PA SHPO further 

concurred that the proposed design revisions (tree trimming plan and 10’ to 15’increase in some 

catenary pole heights) would not adversely affect any other historic properties within the APE.

Cultural resources correspondence is included in Appendix D.

3.2.4 Draft Memorandum of Agreement

FRA, Amtrak, RRMPA, SEPTA, and the PA SHPO have drafted an MOA to memorialize the 

agreed upon mitigation measures to address the potential adverse effect of the Proposed Action 

on the Pennsylvania Railroad Main Line (Philadelphia to Harrisburg) and its contributing 

resources. The Draft MOA includes commitments regarding documentation, interpretation, and 

design. Documentation and interpretation commitments include:

 Recordation of the Bryn Mawr Substation and related catenary system;

 Provision of an interpretive sign inside the SEPTA-leased Bryn Mawr Station that 

focuses on the history of the PA Railroad Main Line;

 Donation of elements of the catenary system that are removed from the Bryn Mawr 

Substation to RRMPA, with an accompanying conservation allowance; and

 Provision of an opportunity for RRMPA to conduct oral history interviews of current or 

former Amtrak Electric Traction Department employees. 

Design commitments include:

 Designing the new Bryn Mawr Substation to be consistent with the materials, color, and 

texture of the existing substation, without mimicking the historic building; 

 Incorporating the existing Bryn Mawr Substation sign into a landscape feature in the 

vicinity of the new substation site design; and

 Offering the bricks from the historic substation building for salvage by Consulting Parties 

and/or the public.

The Draft MOA also references an Unanticipated Discoveries Plan, which has been prepared for 

the Proposed Action. The Unanticipated Discoveries Plan stipulates that in the event that 

unanticipated archaeological resources are encountered during construction, Amtrak shall cease 

work in the affected area and PA SHPO and FRA would be notified immediately. The discovery 

of human remains requires notification of the coroner and PA SHPO, and FRA would determine 

when it is appropriate to notify Native American groups.

Following distribution on August 17, 2015, Consulting Parties had 30 days to review and 

comment on the Draft MOA. Comments were received prior to and during the September 2015 

Section 106 Consulting Parties meeting. The Draft MOA’s stipulations for minimization, 

mitigation, and design measures would minimize impacts and mitigate the adverse effect of the 
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Proposed Action. The Draft MOA, last revised on February 24, 2017, is included in Appendix 

D. Additional comments can be made on the Draft MOA during the 30 day public review period 

for this Environmental Assessment.

3.3 Parks and Wildlife Refuges

County and municipal maps, land use maps, USGS maps, aerial photographs, and on-line GIS 

mapping were consulted and reviewed. These maps were used to identify the location of parks 

and wildlife refuges in or adjacent to Proposed Action area. 

3.3.1 Affected Environment

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

the Proposed Action area, as mapped in Appendix B.

The Merion Botanical Park (Appendix B - aerial photograph sheet 4, Mile Post 5.8) is an 11.6

acre park located in Lower Merion Township, Montgomery County. The park was created in 

1944 adjacent to the Pennsylvania Railroad Mainline and includes paths, a stream with 

footbridge, benches, and numerous species of plants native to the area. The Botanical Society 

donated the park land to the Township in exchange for a maintenance arrangement, stipulating 

that general maintenance is performed by the Township of Lower Merion while care and 

replacement of the botanical collection is completed by the Botanical Society of Lower Merion. 

Deed restrictions limit the type of development that is possible in the park, with requirements 

that the property be forever kept as a botanical garden and public park but not include 

playground equipment or sports fields. In addition to the land owned by the Township (10.2

acres), a strip of land adjacent to the rail line (1.4 acres) is leased by the Township from Amtrak; 

under the Proposed Action there would be tree trimming in this area but no construction 

stockpiles. The Merion Botanical Park is referenced in The Greater & Greener Plan 2012-2021: 

Parks & Recreation Plan Update (2012) and is further detailed in Merion Botanical Park: 

Master Plan (September 2014).

Narberth Playground (Appendix B - aerial photograph sheet 5, Mile Post 7.1) is the largest 

public park (5.5 acres) in Narberth Borough, Montgomery County. This park includes a 

multipurpose field, two basketball courts, three tennis courts, playground equipment, benches, 

picnic tables, a gazebo, and a field house with snack bar and restrooms. The park is also 

programmed with youth sports leagues and community events, such as summer concerts. 

According to An Open Space Master Plan for Narberth (2006), the park was created in the 1920s 

and remains under Borough ownership and management.

The Sharpe Park and Bird Sanctuary (Appendix B - aerial photograph sheet 7, Mile Post 9.2) is 

located in Lower Merion Township, Montgomery County and is owned by Lower Merion 

Township. At 2.3 acres, the wildlife refuge is classified as a “mini” park type in The Greater & 

Greener Plan 2012-2021: Parks & Recreation Plan Update (2012). Sharpe Park and Bird 

Sanctuary includes paths, benches, and a picnic table. Sharpe Park and Bird Sanctuary also hosts 
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community events such as “Twilight in the Park” (food, entertainment, prize drawings), “Art in 

Sharpe Park” (food, artists, craftsmen), and Easter egg hunts. Sharpe Park has been designated 

as an Audobon Society "Bird Town" and is considered a wildlife refuge. Bird Town is a working 

partnership of Audubon Society and municipalities to promote conservation and communitybased actions to create a healthy, more sustainable environment for birds and people by making

more ecologically-friendly decisions and conserving energy. A Bird Town makes efforts to 

restore valuable ecosystem services to create a culture of conservation where everyone is a 

potential steward of nature in their backyard and beyond. 

North Wayne Park (Appendix B - aerial photograph sheet 12, Mile Post 14.7) is a 4.6 acre park 

owned by Radnor Township School District, leased by Radnor Township (Delaware County) for 

$1 a year, and open to the public. It is also known as Seneca Egbert Field and Merryvale Park 

and includes a multipurpose field, a baseball field, and a playground. North Wayne Park is 

referenced but not detailed in the Radnor Township Comprehensive Plan (2003).

3.3.2 Environmental Consequences

Since all construction would occur within existing Amtrak right-of-way under the Proposed 

Action, there would be no direct impacts to any of these publicly-owned parks and wildlife 

refuge. The Proposed Action would not convert these publicly-owned parks and wildlife refuge

to a transportation use.

Section 6(f) of the Land and Water Conservation Act of 1965 regulates the direct conversion of 

recreational facilities purchased or improved through 6(f) funding. None of these four facilities 

are listed in the National Park Service’s Land & Water Conservation Fund (LWCF) project list 

or are included in the PA Department of Conservation and Natural Resources (PA DCNR) 

LWCF mapping. The Proposed Action would not convert any Section 6(f) properties to a nonrecreational use; therefore there is no impact to Section 6(f) properties. 

Section 4(f) of the U.S. Department of Transportation Act of 1966 also regulates the use of 

publicly-owned parks and wildlife refuges. Uses can result from permanent incorporation, 

temporary occupancy, or proximity impacts so severe that the protected activities, features, or 

attributes of the property are substantially impaired (the latter is referred to as a “constructive 

use”). No park or wildlife refuge would be permanently or temporarily occupied as part of the 

Proposed Action. Construction information is detailed in Section 3.17 and explains that 

construction activities at any given location on the rail line would last for several days or nights, 

would generate minimal airborne dust, and would not include blasting. None of these parks and 

wildlife refuge are near the Bryn Mawr Substation (see Appendix B), where construction would

be longer and more intensive. Therefore, proximity impacts to the parks and wildlife refuge

during construction would not be so severe that the protected activities, features, or attributes of 

the property are substantially impaired. Long-term visual impacts to the parks and the wildlife 

refuge caused by the installation of taller catenary structures and tree trimming are described in 

Section 3.12 and, after taking into account measures to minimize and mitigate harm, would not 
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be so severe that the protected activities, features, or attributes of the property would be 

substantially impaired. Also, the Proposed Action does not involve any changes in rail service, 

such as speed or number of trains, so there would be no potential constructive use based on 

service. In summary, there would be no temporary or permanent use of the public parks or the 

public wildlife refuge resulting from permanent incorporation, temporary occupancy, or 

proximity impacts so severe that the protected activities, features, or attributes of the property 

would be substantially impaired. No impacts to the parks and the wildlife refuge are anticipated.

Refer to Section 4 for the Draft Section 4(f) Evaluation.

3.4 Transportation

3.4.1 Affected Environment

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 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.

3.4.2 Environmental Consequences

Replacement of the Bryn Mawr Substation, located approximately 500 feet southeast of the Bryn 

Mawr Station on Amtrak property, under the Proposed Action would permanently impact 12 

parking spaces within the lot that Amtrak leases to SEPTA.

Avoidance is not feasible, because the existing substation is obsolete and must be replaced, and 

alternative locations to construct a new traction power substation proved impractical. The 

surrounding area is densely developed and acquiring several acres of land adjacent to the Main 

Line for the substation construction would likely result in costly legal fees, possible public 

opposition, and displacement of existing building occupants. Amtrak owns the land used for a 

parking lot adjacent to the current Bryn Mawr Substation; however, using all of this land for a 

new substation would result in the loss of many well used commuter parking spaces. As 

avoidance is not feasible, the impact is being minimized by designing the substation to have the 

smallest possible footprint without losing its intended functionality. While this compact 

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

permanently lost parking spaces from 36 to 12. The plan is included as Appendix C, drawing ET0117 of the Paoli to Bryn Mawr plans. 

Rail service would also be impacted, because the Proposed Action would provide a more reliable 

energy supply while also upgrading traction power. While this would improve existing rail 

service, the Proposed Action would not include an increase in the speed or frequency of trains.

Transportation impacts during construction are discussed in Section 3.17.
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The impacts to parking and rail service are considered minor. No impacts to bus, bicycle, or 

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

3.5 Noise and Vibration

Noise and vibration impact assessment was conducted following FRA policy. It is FRA policy 

to use the Federal Transit Administration’s Transit Noise and Vibration Impact Assessment

manual for conventional rail noise and vibration impact assessments and to use the FRA’s HighSpeed Ground Transportation Noise and Vibration Impact Assessment manual for projects with 

train speeds of 90-250 mph. 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. Accordingly, the noise and 

vibration assessment used both manuals to examine the potential impacts that the Proposed 

Action may have on sensitive noise and vibration receptors.

3.5.1 Affected Environment

Based on a review of USGS maps and aerial photographs, 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. 

3.5.2 Environmental Consequences

Under the Proposed Action, maximum allowable train speeds would not be increased, type of 

train would not be changed, and the rail lines would not be shifted. The proposed upgrades to 

the electrification system, all within the existing Amtrak right-of-way, would not affect rail 

traffic noise and/or vibration levels throughout the Proposed Action area. Short-term noise 

and/or vibration levels that may occur during construction are discussed in more detail in Section 

3.17.

The Proposed Action would not change train speed, alter rail line alignments, nor change the 

type of train. Therefore, the Proposed Action would not have any noise and vibration impacts.

3.6 Electric/Magnetic Fields

An electromagnetic field is an invisible area of energy produced by electrically charged objects. 

An electromagnetic field is a combination of an electric field produced by stationary charges and 

a magnetic field produced by moving charges, also called currents. Electric fields are easily 

shielded or weakened by walls or other objects, while magnetic fields can pass through most 

materials. The strength of both electric fields and magnetic fields decreases rapidly with 

increasing distance from its source. Electromagnetic fields are found near power lines, electrical 

wiring, and electrical appliances (refrigerators, vacuums, etc.). Electromagnetic interference 

(often called radio noise) is a disturbance generated by an external source that degrades 

performance of an electrical, magnetic, or electromagnetic device. Electromagnetic interference 

can be caused by sources such as automobile ignition systems, cell phones, thunderstorms, and 
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the sun. 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 

included as Appendix E.

3.6.1 Affected Environment

As part of the electric and magnetic field study, base line, field measurements were conducted to 

document the existing magnetic and electric fields along the Proposed Action corridor. This line 

is currently configured with a four track, 12 kV, 25 Hz, catenary system. In existing conditions, 

the mean magnetic field (at 25 Hz) is 24 mG and the mean electric field (at 25 Hz) is 500 V/m, 

as measured on train station platforms along the Proposed Action corridor.

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. Google 

Earth indicates that facilities with medical equipment are also located in the vicinity of the 

Proposed Action area, such as Centennial Healthcare (Mile Post 3.2), PHA Pediatrics (Mile Post 

5.3), Bryn Mawr Medical (Mile Post 7.9), Main Line Allergy (Mile Post 8.0), NovaCare 

Ardmore (Mile Post 8.0), Dentistry at Suburban Square (Mile Post 8.5), Louis P. Bucky, MD

(Mile Post 8.9), Penn Dental Center at Bryn Mawr (Mile Post 10.0), Cardiology Consultants 

Bryn Mawr (Mile Post 10.2), Golden LivingCenter Rosemont (Mile Post 10.8), Radnor 

Veterinary Hospital (Mile Post 14.2), Mainline OB/GYN (Mile Post 15.4), Daniel Rubino, MD 

(Mile Post 15.9), Devon Dental Arts (Mile Post 16.1), Devon Veterinary Hospital (Mile Post 

16.3), Ufberg Dental (Mile Post 17.6), Wilkes & Buttenbaum Orthodontics (Mile Post 18.8),

Paoli Vetcare (Mile Post 18.8), MinuteClinic (Mile Post 19.3), and Amsterdam Dental Group 

(Mile Post 19.4).

3.6.2 Environmental Consequences

Pennsylvania requires that transmission lines be built in accordance with the requirements of the 

National Electrical Safety Code, which cites no restrictions for electric or magnetic fields; the 

Federal government also has no national standard in this regard. In the absence of established 

criteria standards for electric and magnetic fields generated by electric facilities, the latest 

guidance document from the International Commission on Non‐Ionizing Radiation Protection 

was referenced.

Based on 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 (see Table 2). These fields are small by comparison to utility transmission lines where 

the right-of-way magnetic fields are an order of magnitude larger and the electric fields are two 

orders of magnitude larger than what is anticipated adjacent to the tracks through the Proposed 

Action area. Table 2 summarizes the findings of the study.
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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)

Changes in electromagnetic interference were also modeled as part of the attached study and 

were found to be well below levels that interfere with standard radio services, both in dry and 

wet weather.

Therefore, the Proposed Action would have minor impacts on the electric field, the magnetic 

field, and electromagnetic interference. 

3.7 Air Quality

The Clean Air Act of 1990 gives the federal government the authority to implement and enforce 

regulations intended to reduce air pollutant emissions nationwide. Under the Clean Air Act, the 

U.S. Environmental Protection Agency (U.S. EPA) sets standards for six common air pollutants 

called criteria pollutants. The criteria pollutants include particulate matter, ground-level ozone, 

carbon monoxide, sulfur oxides, nitrogen oxides, and lead, which can harm human health, the 

environment, and property. The limits set by the U.S. EPA for the criteria pollutants are known 

as National Ambient Air Quality Standards (NAAQS). Locations that persistently exceed the 

NAAQS may be designated as nonattainment, while those that meet the NAAQS may be 

designated as attainment. Maintenance areas are those that had a history of nonattainment but 

are now consistently meeting the NAAQS and have a maintenance plan in place.

The U.S. EPA promulgated the General Conformity Regulations in 1993 in order to implement 

Section 176(c) of the Clean Air Act. The purpose of the General Conformity Rule is to ensure 

that federally supported or approved activities do not cause or contribute to a new violation of 

the NAAQS, worsen an existing violation, or delay attainment of the NAAQS. General 

conformity de minimis levels, the minimum thresholds for which a conformity determination 

must be performed, are identified in 40 CFR § 93.153(b).

3.7.1 Affected Environment

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

following exceptions:

 Non-attainment areas

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

o Ozone (Philadelphia, Montgomery, Delaware, and Chester counties)
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 Maintenance areas

o Carbon monoxide (Philadelphia County)

Activities that currently contribute to emissions in the four counties within the Proposed Action 

area include traffic and industry.

3.7.2 Environmental Consequences

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. Air quality impacts during construction are discussed in Section 

3.17.

3.8 Hazardous Materials and Waste

Hazardous Materials and Waste assessment was conducted by utilizing the PA Department of 

Environmental Protection (PADEP) eMapPA tool to search for land recycling cleanup locations, 

mine drainage treatment land recycling projects, and U.S. EPA Toxic Release Inventory sites in 

the Proposed Action area. Additionally, a senior environmental manager at Amtrak answered 

questions regarding known hazardous waste sites in the immediate vicinity (Paoli Railyard 

Superfund site), the most likely soil contaminants that could potentially exist within the Proposed 

Action area, and Amtrak’s procedures for working with old electrical transformers.

3.8.1 Affected Environment

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. These firms have experience with and are 

qualified to handle PCB containing electrical equipment safely. They would follow all state and 

federal regulations regarding safe handling and disposal procedures.

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. 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 provided (Appendix F). The Soil Management Plan specifies waste 

management procedures and precautions for construction in areas of environmental concern 

within the construction zone.

Contamination from adjacent land uses, such as the current residential and commercial uses, has 

not been identified. The most likely soil contaminant onsite may be PCB oil in the area of the 

transformers, and the PCB oil may be encountered during excavation of the catenary structures. 

Elevated levels of volatile organic compounds and semi-volatile organic compounds present in 
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native soil and elevated levels of metals and semi-volatile organic compounds associated with 

historic urban fill material (slag, cinders, brick, etc.) could also be encountered during excavation 

for construction. Petroleum Hydrocarbons, Poly Aromatic Hydrocarbons and metals could also 

be present from coal ash that was often used as fill in the past.

3.8.2 Environmental Consequences

Amtrak has established procedures for testing and draining transformers prior to disposal, 

maintains contracts with multiple firms for emergency response and waste hauling services, and 

has created a Soil Management Plan in case contaminated soil is encountered during 

construction. There would be no property acquired for the Proposed Action, so there would be 

no transfer of risk to Amtrak. Therefore, it is anticipated that the Proposed Action would not 

result in any impacts from hazardous materials or wastes.

Any areas of environmental concern encountered during construction require special waste 

management practices, health and safety considerations, and/or precautions during construction. 

Soil materials excavated from these areas of environmental concern would require special 

handling and on-site management. Procedures for managing excavated soil within these areas of 

concern are detailed in the Soil Management Plan.

3.9 Property Acquisitions and Easements

3.9.1 Affected Environment

The majority of the surrounding land uses consist of residential and commercial properties, but 

several schools, universities, public parks, and one wildlife refuge can also be found directly 

adjacent to the Amtrak right-of-way. More details on land use can be found in Section 3.1 

Location and Land Use.

3.9.2 Environmental Consequences

The Proposed Action would not require permanent property acquisition or temporary 

construction easements (see Section 3.17).

3.10 Communities

3.10.1Affected Environment

The municipalities and communities within the Proposed Action area are shown in Figure 3

(Section 1.3) and Figure 4 (Section 3.1), as well as in the attached aerial photographs (Appendix 

B). 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 rightof-way. In some cases, these residences and other facilities are as close as 100 feet (unobstructed 

by buildings) from the Proposed Action area. 
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3.10.2Environmental Consequences

No major impacts to communities are anticipated from the Proposed Action due to noise and

vibration (Section 3.5), electric/magnetic fields (Section 3.6); or relocation of businesses or 

individuals (Section 3.9). See Section 3.12 for a discussion of minor visual impacts to adjacent 

communities.

Community impacts were also considered in terms of the potential for destruction or disruption 

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

services. Community cohesion refers to the degree of interaction among the individuals, groups, 

and institutions that make up the community and the degree to which residents have a sense of 

belonging to their neighborhood. 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 (Section 3.18), which could potentially improve economic vitality for 

communities with train stations in the Proposed Action area. No impacts on communities, land 

use, or zoning are anticipated.

3.11 Environmental Justice

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations (1994), requires federal agencies to incorporate 

consideration of environmental justice into their planning processes. The executive order 

prohibits federal financial assistance for programs and activities that use criteria, methods, or 

practices that discriminate based on race, color, or national origin and requires all federal 

agencies to “develop an agency-wide environmental justice strategy that identifies and addresses 

disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations and low-income populations.”

In order to satisfy federal environmental justice requirements, 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 U.S. Department of Transportation’s Updated Environmental Justice Order 5610.2(a), dated 

May 2, 2012, states that the term “minority” includes American Indian and Alaskan Native, 

Asian American, Black, Hispanic or Latino, and Native Hawaiian and Other Pacific Islander 

persons. The Order states that a “low-income” designation is applicable for a person whose 

median household income is at or below poverty guidelines. The Order defines a 
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“disproportionally high and adverse effect on minority and low-income populations” as “an 

adverse effect that: (1) is predominately borne by a minority population and/or a low-income 

population, or (2) will be suffered by the minority population and/or low-income population and 

is appreciably more severe or greater in magnitude than the adverse effect that will be suffered 

by the non-minority population and/or non-low-income population.”

3.11.1Affected Environment

The U.S. EPA’s NEPAssist website was used to analyze the populations within 1/8 mile to either 

side of the 18 mile long Proposed Action corridor, using U.S. Census Bureau data from the 2010 

American Community Survey (the latest available data set in NEPAssist). Within this 1/8 mile 

buffer, there are census block groups ranging in composition from 0 to 100% minority 

populations. Most of the Proposed Action area west of Merion Station (see Figure 3 and 

Appendix A, sheet 2) crosses through census block groups with minorities representing 10-20% 

of the total population. Moving east of Merion Station and into the City of Philadelphia, the 

percentage of minorities present increases to comprise 40-100% of the total population. The 

poverty data illustrates a similar divide at Merion Station. Nearly all of the Proposed Action area 

west of Merion Station crosses through census tracts with poverty rates of 0-10%. Moving east 

of Merion Station and into the City of Philadelphia, the poverty rate increases to 10-100%. As a

basis of comparison, minorities comprise 17.1% of the total population of Pennsylvania, and 

8.5% of families in Pennsylvania have income below the poverty level, according to the 2010 

American Community Survey.

3.11.2Environmental Consequences

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

income populations. 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 5.2. No negative impacts on environmental justice populations are 

anticipated.

3.12 Visual

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 can also be found adjacent to 

the Amtrak right-of-way. The buildings in the vicinity of the Bryn Mawr Substation appear to be 

commercial use. Aerial photographs are included as Appendix B.

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

the Bryn Mawr Substation were identified as concerns during the public involvement process.
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These visual impacts are described below. Related mitigation and environmental commitments

associated with visual impacts are detailed in Section 3.20 and Section 6.0, respectively.

3.12.1Affected Environment

3.12.1.1 Catenary Poles

The majority of the existing catenary poles are approximately 45 to 55 feet in height and are 

painted a shade of green that looks like weathered copper; the paint is aging, faded, and failing, 

with many poles having patches of exposed rusted steel. The poles are spaced at a distance of 

150 feet to 300 feet apart, depending on track curvature.

3.12.1.2 Trees

As evident in aerial photographs (Appendix B) and in Google Earth, trees line a majority of the 

Proposed Action corridor. Trees currently act as screens, to some extent, to shield each of the 

three parks and one wildlife refuge, as well as many residences and some businesses from the 

rail line and catenary structures.

3.12.1.3 Historic Resources

Refer to Section 3.2.3.1 for a description of the historic resources within the APE of the 

Proposed Action.

3.12.1.4 Residences, Parks, and Wildlife Refuge

Refer to Section 3.10.1 and Section 3.3.1 for a description of the existing residences, parks, and 

wildlife refuge in the vicinity of the Proposed Action.

3.12.2Environmental Consequences

3.12.2.1 Catenary Poles

The majority of the proposed new catenary poles would be between 60 and 75 feet high. An 

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 catenary structures 

at overhead bridges would require an increased height, ranging between 82 feet and 95 feet, in 

order to meet the mandatory distances between structures and power sources provided in the 

National Electric Safety Code. The proposed catenary structure height is higher than the current 

catenary structures, but much lower than many cell towers that exist today, and has been kept as 

short as possible at each location. Amtrak has minimized visual effects by removing proposed 

PECO commercial transmission lines from the design in order to minimize catenary structure 

heights. In accordance with Amtrak’s typical practice, the new structures (steel I-beams) would

have a galvanized zinc coating to retain their grey color and prevent rusting. Use of paint was 

considered but would fail in approximately two to five years on galvanized finish and in 

approximately five to ten years on bare steel. All new catenary poles would be constructed 

within the railroad right-of-way, typically within ten feet of the existing structures. Detailed 

construction plans for the poles and associated structures are included as Appendix C, with a 
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comparison of the existing and proposed catenary structures on drawings ET-0042 to ET-0043 of 

the Paoli to Bryn Mawr plans. Proposed catenary structure heights at specific locations along the 

Proposed Action corridor are shown in the Appendix D mapping.

3.12.2.2 Tree Trimming

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 (see Section 3.17). 

Trees and vegetation must be kept clear of the power lines in order to reduce the potential for 

fires. Tree trimming plans are included in Appendix C, 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. These plans were generated by the design team using aerial photographs, site photographs, 

and field views in order to minimize impacts and illustrate the amount of tree trimming required

prior to constructing the Proposed Action. 

The design team went through three rounds of analysis to minimize the amount of preconstruction tree trimming. First, the designers ran an analysis on the base design using a 15’ 

clearance envelope to the conductors. Locations that impacted trees located on private property 

were noted, and avoidance options were suggested to Amtrak. The first option which was used 

at select locations was to decrease the trimming to a 10’ clearance envelope, which resolved 

roughly 40% of the impacts. The remaining 60% of the impacts were addressed with the second 

option, redesigning the transmission lines at those locations to a stacked configuration. As a 

result of these efforts, tree trimming would be confined entirely within existing Amtrak right-ofway.

Typical construction plans may have provided a blanket statement that construction crews should 

trim trees along the entire Proposed Action corridor or even clear cut trees along the corridor. 

Instead, construction tree trimming plans and design modifications were implemented to avoid 

direct impacts to trees located on private properties while also minimizing the visual impacts of 

the tree trimming from these private properties. Therefore, the Proposed Action may result in 

potential minor, long-term visual impacts.

3.12.2.3 Historic Resources

Photographic mock-ups of the catenaries are included in Appendix G within the meeting 

materials for the Section 106 Consulting Parties meeting held on June 1, 2015. As seen in the 

mock-ups, there would be a change in the physical features due to the increase in catenary 

structure height. However, the change of the catenary structures within the railroad’s setting 

would remain compatible with the current setting. Catenary structures have been a part of the 

railroad’s setting and operation since this 18 mile segment of the rail line was electrified in 1915. 

Changing the catenary structure height would not adversely affect the setting of historic 

properties in the APE or their ability to convey historic significance. The Determination of 
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Effects Report (August 2015) describes the process by which visual impacts were assessed at the 

location of each of the NRHP-eligible or -listed historic resources within the APE. Where it was 

found that the Proposed Action could affect historic properties, the Criteria of Adverse Effect (36 

CFR § 800.5) were applied to determine if the taller catenaries, tree trimming, and/or 

replacement of the Bryn Mawr Substation would alter the characteristics of the historic property 

that qualify it for inclusion in the NRHP in a manner that would diminish the integrity of the 

property’s location, design, setting, materials, workmanship, feeling, or association.

As detailed in Section 3.2.4, PA SHPO concurred that the Proposed Action would have an 

adverse effect to one of the 27 historic properties: the Pennsylvania Railroad Main Line 

(Philadelphia to Harrisburg). The adverse effect is attributed to the removal of 276 catenary 

structures as well as the Bryn Mawr Substation, which are considered contributing resources. 

The installation of the new catenary structures would introduce new visual elements in the 

district; however, they would remain compatible with the resource and would not diminish the 

overall integrity of the railroad and its significant features. 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, 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. In response, 

instead of using a prefabricated structure or constructing a purely utilitarian-looking Signal 

Power House and Control House Building, the Proposed Action designers would incorporate 

characteristics of the original building into the new design. As a result of mitigation measures 

proposed through a Draft MOA to mitigate adverse effects (see Appendix D), minor impacts on 

cultural resources are anticipated.

3.12.2.4 Residences, Parks, and Wildlife Refuges

Residences, parks, and one wildlife refuge would also experience minor visual impacts from the 

increase in catenary structure height. Amtrak has minimized visual effects by removing PECO 

commercial transmission lines from the design in order to minimize catenary structure heights. 

The new catenary structures would be higher than the existing structures, but catenary structures 

have been part of the railroad’s setting since the rail line was electrified in 1915. Also, the 

design for the new catenary structures calls for the poles to be placed within 10 feet of the

existing structures, which would reduce the change to the viewshed. Furthermore, the new 

catenary poles would be grey, which is believed by the design team to be visually unobtrusive.

Residences, parks, and one wildlife refuge would also experience minor visual impacts from the 

proposed tree trimming. Trees would be trimmed where they interfere with construction work 

and where the trees present a fire hazard due to proximity to the power lines. Tree trimming 

plans are included in Appendix C, 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. These plans 

were generated by the design team in order to illustrate the miminum amount of tree trimming 
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required prior to construction, rather than providing a blanket statement that construction crews 

should trim trees along the entire Proposed Action corridor or clear cut trees along the corridor. 

Instead, the tree trimming plans were created to minimize the visual impact.

There do not appear to be any residences, parks, or wildlife refuges in the vicinity of the Bryn 

Mawr Substation; therefore its replacement is not anticipated to have visual impacts on 

residences, parks, or wildlife refuges.

3.13 Floodplains

No adverse impacts to floodplains or regulatory floodways are anticipated. Federal Protection of 

floodplains is afforded by Executive Order 11988, “Floodplain Management,” and by 

implementation of federal regulations under 44 CFR Part 9. These regulations direct federal 

agencies to undertake actions to avoid impacts on floodplain areas by structures built in floodprone areas. A floodplain is a low land adjacent to a river, lake, or ocean. Floodplains are 

designated by the rarity of a flood that is large enough to inundate them (e.g., 1-percent-annualchance).

The Federal Emergency Management Agency (FEMA) has primary responsibility for identifying 

flood-prone areas and utilizes Flood Insurance Rate Maps (FIRMs) to illustrate waterways and 

associated floodplains.

3.13.1Affected Environment

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

floodplain, in this case a Zone A floodplain without base flood elevations or floodway. This 

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

Post 7.1 (FIRM 42091C0369E), where the creek travels under the rail line via a culvert. The 

Zone A floodplain is mapped at a width of approximately 50 feet (0.009 mile) under the 

Proposed Action corridor, which is 0.05 percent of the total Proposed Action length. Hardings 

Run crosses through a culvert underneath the Proposed Action area within Delaware County 

around Mile Post 12.5 (FIRM 42045C0036F) but does not have a FEMA-designated floodplain.

These FIRMs are attached as Appendix H.

3.13.2Environmental Consequences

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

placement of fill 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 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 1-percentannual-chance floodplains or regulatory floodways, and the Proposed Action is in compliance 

with Executive Order 11988.
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3.14 Water Quality

This section provides an overview of surface and groundwater resources and the water quality of 

those resources in the Proposed Action area.

3.14.1Affected Environment

Online mapping tools including NEPAssist, eMapPA, PADEP Water Attribute Viewer for the 

Enterprise (WAVE), and Google Earth were queried to identify sole source aquifers and 

waterways. Sole source aquifers are not present within the Proposed Action area. 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 (WWF) stream. Hardings 

Run is a designated Cold Water Fishes (CWF) stream, which crosses through a culvert below the 

Proposed Action area within Delaware County around Mile Post 12.5. The WWF and CWF 

designations are provided in Title 25, Chapter 93 of the Pennsylvania Code.

3.14.2Environmental Consequences

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 contractor’s implementation of an 

ESCP or NPDES Permit, as applicable. Sole source aquifers would not be impacted by the 

Proposed Action.

3.15 Endangered Species

Various species receive federal and state protection. Agency records and databases were 

reviewed to determine if federal or state-listed threatened or endangered species are known to 

exist in the Proposed Action area. Threatened and endangered species coordination has been 

conducted with the Pennsylvania Game Commission (PGC), the PA DCNR, the Pennsylvania

Fish and Boat Commission (PFBC), and the U.S. Fish and Wildlife Service (U.S. FWS). 

3.15.1Affected Environment

PGC, PA DCNR, and PFBC 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. U.S. FWS indicated that no federally listed species under U.S. FWS 

jurisdiction are known or likely to occur in the Proposed Action area.

3.15.2Environmental Consequences

All four agencies indicated that no impacts to threatened and endangered species are anticipated. 

These determinations are valid for two years from the date of response, which ranges from 

August 9, 2016 to September 8, 2016.

Because these determinations will expire before the Proposed Action has been constructed, 

Amtrak will update the clearances, prior to construction.
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Agency correspondence is included in Appendix I.

3.16 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-of-way both during 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. The soil management plan is provided in Appendix F. No negative 

impacts to public safety are anticipated. 

3.17 Construction

3.17.1Timing and Sequencing

Depending on funding availability, construction may take place between Fall 2017 to Fall 2022. 

The Proposed Action may be completed in three phases, 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 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 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.

3.17.2Property Acquisitions and Easements

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 

either. Track-mounted construction equipment would be used for the catenary structure 

replacements, and there is adequate space in the Bryn Mawr Substation right-of-way for 

construction vehicle parking. There are open spaces at various locations within the existing 

Amtrak right-of-way, which could be used for construction stockpiles and staging areas. Three 

potential locations for construction stockpiles and staging areas are indicated on the aerial 

mapping included as Appendix B. These three potential sites are located near the Zoo 
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Substation, the Bryn Mawr Substation, and the Paoli Substation, with no parks, wildlife refuges,

or other sensitive resources in the immediate vicinity. 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. This area is also being used for a construction stockpile/staging area for the Paoli 

Station construction project. It is anticipated that existing access points already under Amtrak’s 

control would be utilized and that access through private property would not be needed. 

Therefore, it appears that temporary construction easements would not be necessary for 

stockpiling, staging, or access.

3.17.3Transportation

No parking spaces would be utilized during construction for construction stockpiling or by 

construction vehicles, which would have other options within the Bryn Mawr Substation 

construction zone. An increase in traffic from construction vehicles at Bryn Mawr Substation, 

and elsewhere within the Proposed Action area, is not anticipated to be an issue. 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 

and occupancy by the contractor. As the construction activities would take place largely 

overnight and would involve one outer rail line at a time, rail service would be maintained 

throughout construction. The impacts to parking and rail service are considered minor. 

No impacts to bus, bicycle, or pedestrian access and use are anticipated during or after 

construction, including at the Bryn Mawr Station parking lot.

3.17.4Noise and Vibration

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

management practices concerning construction activities including, but not limited to noise, 

vibration, and light emissions. 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.

3.17.5Air Quality

Construction of the Proposed Action 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, there would be minimal earth disturbance and therefore minimal dust is 

expected. Dust control measures would be part of the construction contractor’s responsibilities

and will follow best management practices typically observed or recommended by the 

Commonwealth of Pennsylvania. It is anticipated that the construction of the Philadelphia Zoo 

to Paoli Transmission Line Project would not cause violations of the NAAQS or exceed the 

general conformity de minimis levels.
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3.17.6Tree Trimming

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 miminum 

amount of tree trimming required prior to constructing the Proposed Action. These plans are 

included in Appendix C, 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. Amtrak typically uses a 

wood chipper and dump truck to break down and remove tree limbs from the work area.

3.17.7Water Quality

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

infiltration, would be minimized through the contractor’s implementation of an ESCP or NPDES 

Permit, as applicable.

3.17.8Contingency Planning

An Unanticipated Discoveries Plan (see Appendix D) and a Soil Management Plan (see 

Appendix F) have been created, in case unanticipated archaeological resources or contaminated 

soils are encountered during construction.

3.18 Indirect Impacts

“Indirect impacts” are those that are caused by the action and are later in time or farther removed 

in distance, but are still reasonably foreseeable. Indirect impacts may include growth-inducing 

effects and other effects related to induced changes in the pattern of land use, population density 

or growth rate, and related effects on air and water and other natural systems, including 

ecosystems.

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

indirect impact of increasing ridership on the Keystone Corridor. Any additional ridership could 

increase use of parking and roadways near train stations. An increase in train ridership could 

reduce vehicular traffic on arterial roadways with corresponding benefits by reducing traffic

congestion and gasoline consumption. 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 on land 

use, water, sewer, and traffic. Because the Proposed Action will not increase service but only 

service quality, the potential for increased transit-oriented development is not anticipated to be 

significant.

3.19 Cumulative Impacts

A “cumulative impact" is the impact on the environment that results from the incremental impact 

of the Proposed Action when added to other past, present, and reasonably foreseeable future 
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actions regardless of what agency (Federal or non-Federal) or person undertakes such other 

actions. Cumulative impacts may include ecological (such as the effects on natural resources 

and on the components, structures, and functioning of affected ecosystems), aesthetic, historic, 

cultural, economic, social, or health, whether direct, indirect, or resulting from smaller actions 

that individually have no significant impact. Determining the cumulative environmental 

consequences of an action requires delineating the cause-and-effect relationships between the 

multiple actions and the resources, ecosystems, and human communities of concern.

For purposes of this discussion, cumulative impacts were considered for rail projects along 

Amtrak’s Keystone Corridor East (Philadelphia to Harrisburg), between 2006 and 2026 (10 years 

pre and post 2016).

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

Corridor East (Philadelphia to Harrisburg). Examples include:

 infrastructure program to repair bridges, construct new power substations, install 

continuous welded rail and concrete ties, and improve communication and signaling 

systems (completed in 2006)

 upgrades to the Lancaster, Elizabethtown, and Mount Joy train stations (Lancaster and

Elizabethtown construction completed in 2013, Mount Joy bid in 2016)

 three at-grade crossing eliminations in Lancaster County (construction completed in 

2014)

 signal system upgrades (proposed from Philadelphia to Paoli, underway from Paoli to 

Parkesburg, completed from Parkesburg to Harrisburg)

 interlocking improvements at several locations throughout the Keystone Corridor East (in 

various stages from planning to construction)

 proposed relocation or upgrade of the Philadelphia, Ardmore, Villanova, Paoli, Exton, 

Downingtown, Coatesville, Parkesburg, Middletown, and Harrisburg train stations 

(planning or design underway)

Within the Paoli area, located at the western terminus of the Proposed Action area, there are five 

projects with independent need and utility in various stages of development on Amtrak’s 

Keystone Corridor East.

The following is a brief summary of each project:

 Americans with Disabilities Act (ADA) Compliant Passenger Train Station – The 

design and construction for this project is funded by PennDOT, SEPTA, Amtrak, and 

FTA and will be in construction from 2016 to 2019. The purpose of this project is to 

bring the existing Paoli Amtrak station into ADA compliance with a high level center 
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platform and an overhead pedestrian bridge with elevators. All work will be within 

existing right-of-way.

 Interim Interlocking Improvements – PennDOT and FRA fund the conceptual design 

for this project, with no funding or time frame currently in place for construction. The 

purpose of this project is to replace the functionality of the existing interlocking in the 

proximity of Paoli but not in the existing location. All work will be within the existing 

right-of-way.

 New Darby Road Bridge – PennDOT funds the design and construction for this project, 

and construction is anticipated to start in spring 2019. The new Darby Road Bridge will

replace the existing Valley Road Bridge. This new bridge, on new alignment, will 

require the acquisition of right-of-way. The relocated bridge will address the immediate 

safety concerns associated with poor sight distance, pedestrian/vehicular conflicts, and 

poor traffic circulation in the area of Paoli surrounding the station.

 Completion of the Paoli Transportation Center – The design and construction for this 

project is currently unfunded and unscheduled. The completion of the Paoli 

Transportation Center will involve construction of a new level boarding westbound 

platform to accommodate a new 3rd track (local) through Paoli Station.

 Final Interlocking Build Out – The design and construction for this project is currently 

unfunded and unscheduled. The Final Paoli Interlocking Build Out Project would add an 

additional track on the north side of the current tracks and new crossovers.

The infrastructure, signal system, at-grade crossing, interlocking, and Philadelphia Zoo to Paoli 

Transmission Line projects will improve reliability, speed, and/or safety on the Keystone 

Corridor East (Philadelphia to Harrisburg). The station projects will bring facilities into ADA

compliance and will enhance customer amenities. All of these improvements are expected to 

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

ridership. As detailed above, all of 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 

above-referenced projects. This process requires that any adverse impacts be considered and 

minimized and mitigated, to the extent possible. For work that potentially has limited federal or 

state environmental documentation, such as the transit-oriented development around train 

stations with strong ridership, it is assumed that local review boards will review and require 

mitigation for resultant impacts to water, sewer, and vehicular traffic. Therefore, it is concluded 

that any adverse cumulative impacts from these projects on Amtrak's Keystone Corridor East

will be minor.
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3.20 Mitigation

This EA concludes that the Proposed Action, which includes mitigation measures and 

environmental commitments, would have no potential significant environmental impacts. Table 3

details impacts and the mitigation measures which have already been incorporated into the 

planning and design of the Proposed Action in order to avoid and/or minimize potential impacts.

Table 3: Mitigation Measures

Potential Impact Mitigation

Cultural Resources: 

The Proposed Action would 

have an adverse effect on the 

National Register 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 Draft MOA has been developed between the FRA, Amtrak, 

RRMPA, SEPTA, and PA SHPO, which includes commitments by 

Amtrak to minimization measures and mitigation measures to 

minimize impacts and to mitigate potential adverse effects to the 

Pennsylvania Railroad Main Line and its contributing resources. 

Minimization Measures:

A. Limit catenary structure heights (60-75 feet at most 

locations);

B. Implement targeted tree trimming program to avoid universal 

trimming or clear cutting;

C. Place new catenary structures as near as practicable to existing 

catenary structures; and

D. Avoid physical impacts to train stations along the Proposed 

Action corridor.

Mitigation Measures:

A. Documentation

2. Record the Bryn Mawr Substation and related catenary 

system to Historic American Engineering Record 

Documentation Level II.

B. Intepretation

5. Provide an interpretive sign inside the Bryn Mawr station 

building.

6. Donate materials and elements of the catenary system that 

Amtrak or its contractors remove from the historic Bryn 

Mawr Substation to RRMPA.

7. Make financial contribution to RRMPA dedicated to the 

conservation of donated materials.

8. Make reasonable efforts to provide to RRMPA contact 

information for current or former Amtrak Electric Traction 

Department employees for the purpose of conducting oral 

history interviews.

C. Design

4. Design new substation to be consistent with the materials, 
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Table 3: Mitigation Measures

Potential Impact Mitigation

color, and texture of the existing Bryn Mawr Substation 

(e.g. buff brick exterior walls), but will not mimic the 

historic building to make it clear that the new buildings are 

non-historic and do not create a false sense of history. 

Amtrak will submit the proposed design to PA SHPO for 

review and approval prior to construction; PA SHPO will

provide comments within 30 days of receipt of the draft 

design.

5. Incorporate the “Bryn Mawr Substation” sign currently on 

the historic building into a new retaining wall or other 

landscape feature adjacent to the Bryn Mawr Substation 

site.

6. Offer the bricks from the historic Bryn Mawr Substation 

for salvage upon removal of the building. 

An Unanticipated Discoveries Plan has also been created and 

appended to the Draft MOA, in case any unanticipated archaeological 

resources are encountered during construction.

The Draft MOA’s stipulations for minimization, mitigation, and design 

measures will minimize impacts and mitigate the adverse effect of the 

Proposed Action.

Transportation: Parking spaces 

would be lost at the Bryn Mawr 

Train Station.

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.
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Table 3: Mitigation Measures

Potential Impact Mitigation

Visual: Taller catenary poles, 

tree trimming, and the 

replacement of the Bryn Mawr 

Substation were identified as 

concerns for potential impacts 

to the area adjacent to the 

Proposed Action during the 

public involvement process.

While the Draft MOA for Cultural Resource impacts serves to 

minimize and mitigate potential impacts to cultural resources, some of 

the same Draft MOA minimization and mitigation measures serve to 

minimize and mitigate visual impacts. Minimization measures 

include:

A. Limit catenary structure heights (60-75 feet at most locations);

B. Implement targeted tree trimming program to avoid universal 

trimming or clear cutting;

C. Place new catenary structures as near as practicable to existing 

catenary structures; and

D. Design new Bryn Mawr Substation to be consistent with the 

materials, color, and texture of the existing Bryn Mawr 

Substation (e.g. buff brick exterior walls), but will not mimic 

the historic building to make it clear that the new buildings are 

non-historic and do not create a false sense of history.

Additionally, during the final design and construction phases, Amtrak would incorporate 

environmental commitments described in Section 6.0 to minimize and mitigate potential impacts. 

4.0 DRAFT SECTION 4(F) EVALUATION

4.1 Section 4(f) Requirements

The impacts of the Proposed Action were considered in relation to Section 4(f) of the U.S. 

Department of Transportation Act of 1966 (49 U.S.C. § 303), and subsequent revisions and 

amendments (hereafter referred to as “Section 4(f)”). The intention of Section 4(f) is to protect 

certain resources, including publicly owned wildlife and waterfowl refuges, publicly owned park 

and recreation areas that are open to the public, and public or privately owned historic sites. 

FRA may approve a transportation project that proposes to use a Section 4(f) resource only if the 

use will have a de minimis impact on the property, or if there is no prudent and feasible 

alternative to using that land and the project involves all possible planning to minimize harm.

FRA may determine that a transportation program or project that uses a historic resource will 

have a de minimis impact on the historic resource only if, pursuant to the Section 106 

consultation process: 

 The transportation program or project will have no adverse effect on the historic site; or 

 There will be no historic properties affected by the transportation program or project; and 
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 FRA’s finding has received written concurrence from the applicable State historic 

preservation officer; and

 FRA has developed its finding in consultation with parties consulting as part of the 

Section 106 consultation process.

With respect to parks, recreation areas, or wildlife or waterfowl refuges, FRA may make a 

finding of de minimis impact only if: 

 After public notice and opportunity for public review and comment, FRA finds that the 

transportation program or project will not adversely affect the activities, features, and 

attributes of the park, recreation area, or wildlife or waterfowl refuge eligible for 

protection under this section; and 

 The finding has received concurrence from the officials with jurisdiction over the park, 

recreation area, or wildlife or waterfowl refuge.

A feasible and prudent avoidance alternative is defined as follows: 

(1) A feasible and prudent avoidance alternative avoids using Section 4(f) property and does 

not cause other severe problems of a magnitude that substantially outweighs the 

importance of protecting the Section 4(f) property. In assessing the importance of 

protecting the Section 4(f) property, it is appropriate to consider the relative value of the 

resource to the preservation purpose of the statute.

(2) An alternative is not feasible if it cannot be built as a matter of sound engineering 

judgment.

(3) An alternative is not prudent if:

(i) It compromises the project to a degree that it is unreasonable to proceed with the 

project in light of its stated purpose and need;

(ii) It results in unacceptable safety or operational problems;

(iii) After reasonable mitigation, it still causes:

(A) Severe social, economic, or environmental impacts;

(B) Severe disruption to established communities;

(C) Severe disproportionate impacts to minority or low income populations; or

(D) Severe impacts to environmental resources protected under other Federal

statutes;

(iv) It results in additional construction, maintenance, or operational costs of an 

extraordinary magnitude;

(v) It causes other unique problems or unusual factors; or
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(vi) It involves multiple factors in paragraphs (3)(i) through (3)(v) of this definition, that 

while individually minor, cumulatively cause unique problems or impacts of 

extraordinary magnitude.

All possible planning means that all reasonable measures identified to minimize harm or mitigate 

for adverse impacts and effects must be included in the project.

4.2 Section 4(f) Resources

As described in Section 3.3, there are three publicly owned parks and one publicly owned 

wildlife refuge located adjacent to the Proposed Action area, including Merion Botanical Park, 

Narberth Playground, Sharpe Park and Bird Sanctuary, and North Wayne Park.

As detailed in Section 3.2.3, 27 historic resources within the APE were deemed individually 

NRHP-eligible or listed. Accordingly, Section 4(f) uses of the 27 historic resources are

considered individually.

4.3 Section 4(f) Use

A Section 4(f) “use” can result from permanent incorporation or easement, temporary 

occupancy, or constructive use. Permanent incorporation involves right-of-way acquisition of 

Section 4(f) land as part of a transportation project, typically converting the land from a Section 

4(f) property to a transportation facility. When a transportation agency acquires a permanent 

easement, the underlying ownership of the land may remain with the original owner but the 

transportation owner acquires a permanent interest in the use or maintenance of some portion of 

the property that disrupts its Section 4(f) function; examples include maintenance access, utility 

access, and drainage features. Temporary occupancy may be necessary during construction of 

the transportation project; examples include staging or access areas. A constructive use does not 

involve physical use of a Section 4(f) property but involves proximity impacts so severe that the 

protected activities, features, or attributes of the property are substantially impaired; examples 

include noise, vibration, and visual impacts, or access restrictions.

4.3.1 Public Parks and Wildlife Refuge 

There would be no use of the three publicly owned parks and one publicly owned wildlife refuge

adjacent to the Proposed Action area. No park or wildlife refuges would be permanently or 

temporarily occupied as part of the Proposed Action. Construction information is detailed in 

Section 3.17 and explains that construction activities at any given location on the rail line would 

last for several days or nights, would generate minimal airborne dust, and would not include 

blasting. Neither the parks nor the wildlife refuge are near the Bryn Mawr Substation, where the 

Proposed Action includes the construction of a new traction power substation and demolition of 

the existing substation. Additionally, proximity impacts to the parks and wildlife refuge during 

construction would not be so severe that the protected activities, features, or attributes of the 

property are substantially impaired. Long-term visual impacts to the parks and the wildlife 

refuge caused by the installation of taller catenary structures and tree trimming are described in 
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Section 3.12, and would not be so severe that the protected activities, features, or attributes of the 

property would be substantially impaired. Also, the Proposed Action does not involve any 

changes in rail service, such as speed or number of trains, so there would be no potential 

constructive use based on service. In summary, there would be no temporary or permanent use 

of the public parks and the wildlife refuge 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.

4.3.2 Historic Resources

The Proposed Action will require use of five individually eligible or listed historic resources: 

Merion Station, Haverford Station, Villanova Station, Wayne Station, and Strafford Station. The 

Proposed Action will take place within the boundaries of Wayne and Stafford Stations. The 

boundaries of the other historic properties are unclear, and the Proposed Action will occur in 

close proximity to these historic properties and could be construed as within the historic property 

boundaries. The PA SHPO concurred with FRA’s finding, developed through the Section 106 

consultation process, of no adverse effect on these five historic properties within the boundaries 

of the Proposed Action work area. Furthermore, 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, on July 19, 2016 (see 

Section 3.2.3). Consulting Parties were involved in the effects determination in June 2013, 

September 2014, June 2015, and September 2015 (see Section 3.2.1). Therefore, pursuant to 49 

U.S.C. § 303(d), a Section 4(f) finding of de minimis impact is applicable to the 5 resources with 

findings of no adverse effect within the Proposed Action work area. PA SHPO concurred with 

this Section 4(f) de minimis use finding on March 7, 2017. There is no Section 4(f) use of the 

other 5 resources with findings of no adverse effect or the 16 historic properties with findings of 

no historic properties affected, with all of these properties being outside of the Proposed Action 

work area. Section 4(f) requirements are considered satisfied for these 21 historic resources.

The Proposed Action will also require Section 4(f) use of the existing catenary structures and the 

Bryn Mawr Substation. Through the Section 106 consultation process, FRA has made a finding 

of adverse effect for one historic property within the APE (see Section 3.2.3.2), the Pennsylvania 

Railroad Main Line. The Pennsylvania Railroad Main Line (Philadelphia to Harrisburg) would 

be adversely affected due to the removal and replacement of the existing catenary structures and 

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

Pennsylvania Railroad Main Line. PA SHPO has concurred with this finding. Because the 

Proposed Action will result in a use of and an adverse effect on the Pennsylvania Railroad Main 

Line (i.e., the Proposed Action will result in more than a de minimis impact), the Draft Section 

4(f) Evaluation (Evaluation) below was prepared to determine if there is a prudent and feasible 

alternative (avoidance alternative) to using that land and the Proposed Action involves all 

possible planning to minimize harm.
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4.4 Alternatives Considered to Avoid Section 4(f) Resources

To meet the requirements of Section 4(f), this Evaluation considers feasible and prudent 

avoidance alternatives to avoid the use of Section 4(f) resources, including the Pennsylvania 

Railroad Main Line (Philadelphia to Harrisburg). 

4.4.1 No-Build Alternative

Under the No-Build Alternative, no replacements or upgrades would be completed for catenary 

structures, catenary wires, and transmission lines. However, this alternative is not prudent 

because 1) it would compromise the Keystone Corridor to a degree that is unreasonable to 

proceed in light of the Proposed Action’s purpose and need; and 2) it would result in 

unacceptable operational problems. 

The purpose of the Proposed Action is to maintain and improve passenger train service using 

electric-powered 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 also the location of transmission lines on former Pennsylvania 

Railroad right-of-way that complicate maintenance of these lines.

The No-Build Alternative would not achieve this purpose but risk a breakdown of the system and 

loss of service, as these components are showing signs of substantial deterioration and frequently 

require extensive repairs that increase safety risk for Amtrak’s maintenance crews. A system 

breakdown and loss of service along this stretch of the corridor would likely incapacitate the 

Keystone Corridor, therefore causing unacceptable operational problems. The No-Build 

Alternative would also leave the Bryn Mawr Substation standing, with no upgrades completed. 

Amtrak typically spaces traction power substations every 10 miles, but there are no traction 

power substations in the 18 mile segment between the Zoo Substation and the Paoli Substation. 

Trains operated by Amtrak and SEPTA could still experience low-voltage conditions in the 

middle of this section of railroad during periods of higher train density. 

Given its inability to meet the Proposed Action’s purpose and need and result in unacceptable 

operational problems, the No-Build Alternative is not a feasible and prudent avoidance

alternative. 

4.4.2 Alternatives Considered but Eliminated from Detailed Analysis

Three alternatives to the Proposed Action were considered but eliminated from detailed analysis, 

as described in Section 2.3. One alternative would leave the existing Bryn Mawr Substation in 

place, would build a new traction power substation elsewhere in Bryn Mawr, and would replace 

the existing catenary structures. A second alternative would replace the catenary poles and 

incorporate new transmission lines on the former Pennsylvania Railroad right-of-way rather than 

on the Amtrak right-of-way. A third alternative would involve removing the catenary structures 
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and all catenary wires and transmission lines and reverting to use of diesel trains. None of these 

three alternatives would completely avoid using Section 4(f) resources. Because the existing 

catenary structures within the Proposed Action area have far exceeded their original design life 

and are in danger of structural failure, they would need to be removed for safety reasons under 

each alternative.

In addition to the fact that these alternatives would not completely avoid use of Section 4(f) 

resources, they would also fail to meet the Proposed Action’s purpose and need. Additionally, 

alternatives two and three would result in unacceptable safety or operational problems. 

Therefore, none of these three alternatives constitute a feasible and prudent avoidance

alternative.

4.5 All Possible Planning to Minimize Harm

Because there is no feasible and prudent avoidance alternative and only one feasible and prudent 

alternative (the Proposed Action), the Proposed Action will be pursued but will incorporate

reasonable measures to minimize harm and mitigate for adverse impacts and effects to the 

Pennsylvania Railroad Main Line. 

Coordination with the PA SHPO and Consulting Parties has occurred throughout the course of 

the NEPA process (see Section 3.2.1). Amtrak has incorporated Consulting Party feedback 

about minimization measures into the Proposed Action, keeping the height of the new catenary 

structures as low as possible while meeting safety requirements, locating new catenary structures 

within close proximity to the existing ones to reduce changes to the visual landscape, and 

producing construction tree trimming plans to minimize the amount of tree trimming along the 

right-of-way. It was determined that with these measures, the introduction of the increased 

catenary structure heights and the limited tree trimming would not result in visual effects that 

would adversely affect the characteristics that qualify any of the historic resources in the APE for 

listing in the NRHP.

Additionally, FRA, Amtrak, RRMPA, SEPTA, and the PA SHPO drafted an MOA to 

memorialize the agreed upon mitigation measures to address the potential adverse effect of the 

Proposed Action on the Pennsylvania Railroad Main Line (Philadelphia to Harrisburg) and its 

contributing resources. The Draft MOA includes commitments regarding documentation, 

interpretation, and design (Section 3.2.4). Documentation and interpretation commitments relate 

to the recordation of the Bryn Mawr Substation and related catenary system, the provision of an 

interpretive sign inside the Bryn Mawr Station that focuses on the history of the Pennsylvania

Railroad Main Line, the donation of elements of the catenary system that are removed from the 

Bryn Mawr Substation to be used by RRMPA with an accompanying conservation allowance, 

and an opportunity for RRMPA to conduct oral history interviews of current or former Amtrak 

Electric Traction Department employees. Per the design commitments, Amtrak will design the 

new Bryn Mawr Substation to be consistent with the materials, color, and texture of the existing 

substation without mimicking the historic building; will incorporate the existing Bryn Mawr 
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Substation sign into a landscape feature in the vicinity of the new substation; and will offer the 

bricks from the historic substation building for salvage by Consulting Parties and/or the public

(see Section 3.2.4).

On October 8, 2015, PA SHPO concurred with the effects determination and stated that there has 

been adequate consultation with PA SHPO and the Consulting Parties regarding ways to avoid, 

minimize, or mitigate effects on historic properties. Cultural resources correspondence is 

included as Appendix D.

4.6 Section 4(f) Conclusion

There would be no use of the three publicly owned parks and one publicly owned wildlife refuge

adjacent to the Proposed Action area 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.

Pursuant to 49 U.S.C. § 303(d), a Section 4(f) finding of de minimis impact is applicable to the 5 

resources with findings of no adverse effect within the Proposed Action work area. There is no 

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

properties with findings of no historic properties affected, with all of these properties being 

outside of the Proposed Action work area. Section 4(f) requirements are considered satisfied for 

these 26 historic resources.

The Proposed Action will require use of the existing catenary structures and the Bryn Mawr 

Substation. Through Section 106 consultation, FRA made a finding of adverse effect for one 

historic property within the APE (see Section 3.2.4). The Pennsylvania Railroad Main Line 

would be adversely affected 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 

Pennsylvania Railroad Main Line. PA SHPO has concurred with this finding. Because the 

Proposed Action will result in a use of and an adverse effect on the Pennsylvania Railroad Main 

Line, avoidance alternatives and measures to minimize harm were considered as part of the 

Section 4(f) process. The analysis above determined 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. 

5.0 AGENCY, PUBLIC, AND CONSULTING PARTY INVOLVEMENT

5.1 Agency Coordination

Agency coordination was conducted with the FRA, Amtrak, RRMPA, SEPTA, and the PA 

SHPO regarding cultural resources, as detailed in Section 3.2 and enclosed as Appendix D. The 

comments received from these agencies were incorporated into the cultural resources analyses, 

as well as the Draft MOA. Agency coordination was also conducted with the PGC, the PA 
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DCNR, the PFBC, and the U.S. FWS regarding threatened and endangered species, as detailed in 

Section 3.15 and enclosed as Appendix I. Each of these regulatory agencies replied that no 

impacts to threatened and endangered species were anticipated.

5.2 Public and Consulting Party Involvement

Feedback on the Proposed Action was solicited from public officials, stakeholders, Consulting 

Parties, and the general public at stakeholder and public meetings. Information was presented 

and handed out, with comments solicited/provided through question-and-answer discussions and 

written surveys (see Sections 4.2.1 and 4.2.2).

5.2.1 Public Activities and Section 106 Meetings

Public involvement and Section 106 meetings are listed in Table 4 and are described in the 

following text.

Table 4: 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

To review and discuss archaeology investigation, historic 

resources data collection, and mitigation options.

9/15/2014 Section 106 Consulting 

Parties Meeting #2

To review and discuss revised APE, eligibility, and potential 

effects.

6/1/2015 Section 106 Consulting 

Parties Meeting #3

To 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.
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Table 4: Public Involvement and Section 106 Meetings

Date Event Purpose

9/2/2015 HARB/ Section 106 

Consulting Parties

Meeting #4

To review and discuss the Draft MOA. 

8/2/2016 Public access provided to 

cultural resources reports

To 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

To publish the EA and Draft Section 4(f) Evaluation on the 

FRA website and to post hard copies for public access. To 

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 To present the EA and Draft Section 4(f) Evaluation to the 

public and provide opportunity for comment.

Meetings for both public officials and community organizations were held on April 25 and April 

30, 2012, at Harcum College (near the Bryn Mawr Station) and at Radnor Middle School (near 

the Wayne Station). An information packet including a Proposed Action summary, catenary 

drawings, and maps of the cultural resources was mailed or emailed to a total of 137 public 

officials and community organizations. These media outlets were notified of the meeting: Daily 

Local News of Chester County, the Daily Times of Delaware County, The Main Line Times

which covers the Philadelphia area, The Philadelphia Inquirer/Daily News, and The Times 

Herald of Montgomery County. Surveys were provided in order to solicit comments from 

attendees. Questions and answers from these meetings were compiled and distributed at 

subsequent meetings.

A third public meeting was held on June 6, 2012, at Villanova University (near the Villanova 

Station). A notice announcing the public meeting was published in Daily Local News, The 

Philadelphia Inquirer/Daily News, The Main Line Times, the Mainline Suburban Media News, 

Radnor Patch, Ardmore Patch, Tredyffrin-Easttown Patch, and Bryn Mawr Patch.

Two more public officials and stakeholders meetings were held on May 28 and May 29, 2013, at 

the Lower Merion Township Building and Radnor Township Building. An information packet 

was emailed to 77 public officials and stakeholders and mailed to 115 contacts in advance of the 

meeting. A notice announcing the meeting was published in Daily Local News, Daily Times, 

Mainline Suburban Media News, The Philadelphia Inquirer/Daily News, and The Times Herald. 

A public meeting was held on June 6, 2013 at the Villanova University Connelly Center Cinema. 

In preparation for the meeting, flyers were posted at 17 railroad stations and a news release was 
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sent to the the Daily Local News, the Mainline Suburban Media News, The Philadelphia 

Inquirer/Daily News, The Main Line Times, Radnor Patch, Ardmore Patch, Tredyffrin-Easttown 

Patch, and Bryn Mawr Patch.

Section 106 Consulting Parties meeting #1 was held on June 6, 2013, at the Villanova University 

Connelly Center Cinema. In preparation, 35 invitation packets were mailed to Consulting 

Parties, with follow-up phone calls and email messages. The purpose of the meeting was to 

review and discuss archaeological studies, historic resources data collection, and mitigation 

options.

Section 106 Consulting Parties meeting #2 was held on September 15, 2014, at the Lower 

Merion Township Building. In preparation, a meeting notice was mailed to 39 Consulting 

Parties, with follow-up emails to 7 Consulting Parties. The purpose of the meeting was to review 

and discuss revised APE, eligibility, and potential effects.

Section 106 Consulting Parties meeting #3 was held on June 1, 2015, at Bryn Mawr College. In 

preparation, a meeting notice was mailed to 39 Consulting Parties, with follow-up emails to 7 

Consulting Parties. The purpose of the meeting was to 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. Attendees were provided 

with comment forms, and it was agreed to hold a final Section 106 Consulting Parties meeting in 

September to review the Draft MOA and receive comments.

Section 106 Consulting Parties meeting #4 was held on September 2, 2015 at Radnor Township 

HARB. In preparation, a meeting notice was mailed to 41 Consulting Parties, with follow-up 

emails to 12 Consulting Parties. The purpose of the meeting was to review and discuss the Draft 

MOA.

Detailed notes from these meetings are provided in Appendix G, and the questions and concerns 

discussed at the meetings are summarized in Table 5 in Section 5.2.2.

5.2.2 Public Comments

Members of the public provided numerous comments on the Proposed Action. Table 5 lists each 

of the meetings detailed in Section 5.2.1 and categorizes the comments received at these 

meetings. Comment categories are sorted by prevelance, with the comments most frequently 

made appearing higher in the table. The concerns most commonly noted were visual impacts 

and cultural resources impacts.

Table 5 also describes how and where the comments have been discussed in this EA. For 

example, visual impacts were discussed during the referenced meetings (see Appendix G for 

meeting summaries) and also in this EA document in Sections 3.2.4 (Draft Memorandum of 

Agreement), 3.12 (Visual), 3.20 (Mitigation), and 6.0 (Environmental Commitments).
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The noted concerns were considered during the design and environmental review processes. 

This resulted in:

 Alterations to the design, in terms of pole height;

 Changes to the level of NEPA documentation from Categorical Exclusion to EA;

 Creation of mitigation measures (Section 3.20); and

 Generation of environmental commitments (Section 6.0).
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Table 5: Questions and Concerns Noted at Public Involvement Meetings 4/25/12 & 4/30/12 (PO) 6/6/12 (P) 5/28/13 & 5/29/13 (PO) 6/6/13 (P) 6/6/13 (CP)

9/15/14 (CP)6/1/15 (CP)9/

2/15 (CP)

Meeting ReferencesDiscussion

Visual impacts ● ● ● ● ● ● ● ● 8 Meetings; Sections 3.2.4, 3.12, 3.20, 6.0.

Cultural resources impacts ● ● ● ● ● ● ● 7 Meetings; Sections 3.2, 3.12.2.1, 3.20, 6.0.

Construction noise and lights ● ● ● ● ● ● 6 Meetings; Sections 3.17.4, and 6.0.

Construction sequence / schedule ● ● ● ● ● 5 Meetings; Sections 2.1, 3.17.1, and 6.0.

Fate of retired equipment ● ● ● ● ● 5 Meetings and Section 2.1.

Continuation of public outreach ● ● ● ● ● 5 Meetings; Sections 4.2 and 6.0.

Bryn Mawr Substation impacts

● ● ● ● ●

5 Meetings; Sections 3.2.3.2, 3.2.4, 3.4.2, 

3.12.2.1, 3.20, 6.0.

Vibration ● ● ● ● 4 Meetings; Sections 3.5 and 3.17.4.

Costs and funding type ● ● ● ● 4 Meetings and Section 2.1.

Electro-magnetism and electrical 

current safety ● ● ●

3 Meetings and Section 3.6.

Construction access through private 

property

● ● ● 3

Meetings; Sections 3.9 and 3.17.2.

Right-of-way ● ● ● 3 Meetings; Sections 3.9 and 3.17.2.

Maintenance and cleaning of Amtrak

drainage facilities ● ● ●

3 Discussed at meetings as a track maintenance 

issue. Not related to Proposed Action.

Long-term noise ● ● 2 Meetings and Section 3.5.

Level of environmental 

documentation (initially considered a 

Categorical Exclusion)

●

1 Discussed at meeting, and level of 

documentation was subsequently changed to 

an EA.

Purpose and need ● 1 Meeting and Section 1.1.

Dead tree limbs over Cricket 

Condominiums ●

1 Message has been relayed within Amtrak. 

Not related to Proposed Action.

Impact on Sharpe Park ● 1 Meeting; Sections 3.3, 3.12.2.2, and 5.3.

PO: Public Officials/Stakeholders P: Public CP: Consulting Parties
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6.0 ENVIRONMENTAL COMMITMENTS

Mitigation measures have already been incorporated into the planning and design of the 

Proposed Action in order to avoid and minimize potential impacts. These mitigation measures 

are described in Section 3.20. As detailed in Table 6, Amtrak would incorporate these mitigation 

measures as environmental commitments during the final design and construction phases to 

minimize and mitigate potential impacts.

Table 6: Environmental Commitments

Environmental Commitment

 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 

Draft MOA is enclosed in Appendix D. 

 The Draft 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, 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.

 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). This plan specifies waste management procedures and precautions 

for construction activities within areas of environmental concern within the construction zone.
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7.0 NEXT STEPS

A public meeting will be held to present the EA to the public for comment on the EA and on the 

Proposed Action itself. The EA will be available on FRA’s project website and in hard copy at 

several locations near the Proposed Action. A distribution list is in Section 9.0. Public 

comments will be considered and incorporated into the FONSI and/or the Proposed Action’s 

design, as appropriate. The NEPA process will conclude with either a FONSI, evidencing the 

FRA’s NEPA decision, or a determination to proceed to preparation of an EIS.

8.0 LIST OF PREPARERS

Federal Railroad Administration

David Valenstein, Chief, Environmental and Systems Planning – document review

Michelle Fishburne, P.E., Environmental Protection Specialist – document review

Brandon Bratcher, Environmental Protection Specialist – document review

Amtrak

Joanna Pardini, P.E., Senior Manager, Catenary Design – document review

Johnette Davies, Senior Historic Preservation Specialist – document review

Craig Caldwell, Senior Manager, Environmental – document review

Michael Stern, VP and Managing Deputy General Counsel – document review

Burns Engineering, Inc.

Herbert Wescott, III, P.E., Senior Project Manager – document review

Daren Petroski, P.E., Vice President, Transit Design Group Leader – document review

Stell Environmental

Allen Heist, PMP, Project Manager – document review

Patricia Baker, Cultural Resources Group Manager – document review

Alison Ross, M.S., Architectural Historian – document review

Michael Baker International

Angela Bard Welt, Environmental Specialist – document writing
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9.0 DISTRIBUTION LIST

A digital copy of the EA will be posted on FRA’s website1to provide an opportunity for public 

review and comment.

Printed copies of the EA will also be provided to the 22 following entities, in order to facilitate 

public access:

 Lower Merion Township Municipal Building (75 E. Lancaster Avenue, Ardmore, PA 

19003)

 Tredyffrin Township Municipal Building (1100 Duportail Road, Berwyn, PA 19312)

 Delaware County Courthouse (201 West Front Street, Media, PA 19063)

 Montgomery County Courthouse (2 E. Airy Street, Norristown, PA 19401)

 Philadelphia City Planning Commission (1515 Arch Street, Philadelphia, PA 19102)

 Chester County Planning Commission (601 Westtown Road, Suite 270, West Chester, 

PA 19380)

 Philadelphia City Hall (City Hall, Room 313, Philadelphia, PA 19107)

 Narberth Borough Municipal Building (100 Conway Avenue, Narberth, PA 19072)

 Haverford Township Municipal Building (2325 Darby Road, Haverford, PA 19083)

 Radnor Township Municipal Building (301 Iven Avenue, Wayne, PA 19087)

 Easttown Township Municipal Building (566 Beaumont Road, Devon, PA 19333)

 Willistown Township Municipal Building (688 Sugartown Road, Malvern, PA 19355)

 Bryn Mawr's Ludington Library (5 S. Bryn Mawr Avenue, Bryn Mawr, PA 19010)

 Tredyffrin Public Library (582 Upper Gulph Road, Strafford, PA 19087)

 Paoli Library (18 Darby Road, Paoli, PA 19301)

 Easttown Library & Information Center (720 First Avenue, Berwyn, PA 19312)

 Ardmore Library (108 Ardmore Avenue, Ardmore, PA 19003)

 Bala Cynwyd Library (131 Old Lancaster Road, Bala Cynwyd, PA 19004)

 Penn Wynne Library (130 Overbrook Parkway, Wynnewood, PA 19096)

 Charles L. Durham Branch - Free Library of Philadelphia (3320 Haverford Avenue, 

Philadelphia, PA 19104)

 

1 https://www.fra.dot.gov/Page/P0810
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 Wynnefield Branch - Free Library of Philadelphia (5325 Overbrook Avenue, 

Philadelphia, PA 19131)

 Overbrook Park Branch - Free Library of Philadelphia (7422 Haverford Avenue, 

Philadelphia, PA 19151)

An informational flyer will accompany the EA hard copies, as well as a cover letter inviting the 

recipient to announce the availability of the EA for public review and comment on their 

municipal or library website. 

Postcards or emails announcing the availability of the EA for public review and comment will be 

sent to 163 entities, including Consulting Parties, Tribes, and other identified stakeholders.

A notice will also be published in the Radnor Patch, the Ardmore Patch, the Tredyffrin-Easttown 

Patch, the Bryn Mawr Patch, The Daily Local, Delcon News, Daily Times, The Times Herald, 

Main Line News / Main Line Times, City Suburban News, Philadelphia Daily News, and The 

Philadelphia Inquirer. Newspapers will be asked to post the notice in their hard copy edition as 

well as on their website.

10.0 REFERENCES

"Amtrak Zoo to Paoli Re-Electrification Project." Message to the Consulting Parties. 20 July 2016. 

E-mail. Re: Effects Addendum.

Bannan, Pete. "Video: Sharpe Park Cleanup." Mainline Media News. Mainline Media News, 26 Apr. 

2011. Web. 22 Sept. 2016. 

<http://www.mainlinemedianews.com/articles/2011/04/26/main_line_times/news/doc4db7112227a40970

503267.txt>

Bowen, Rebecca H. "PNDI Number 22357: Update - Philadelphia Zoo to Paoli Transmission Line for 

High Speed Rail Line.” Letter to Angela Welt. 31 July 2014. MS. PA DCNR, Harrisburg, PA.

Brown and Keener Bressi. An Open Space Master Plan for Narberth. Rep. Narberth Open Space 

Committee, Mar. 2006. Web. 20 Apr. 2016. <http://www.montcopa.org/DocumentCenter/View/3353>.

Cahill Associates, Simone Jaffe Collins Landscape Architecture, Urban Partners, and McMahon 

Associates, Inc. Radnor Township Comprehensive Plan - Section 6: Open Space and Recreation. Rep. 

Radnor Township, 2003. Web. 20 Apr. 2016. <http://www.radnor.com/DocumentCenter/View/2239>.

DiBiase, Anthony A. "Electromagnetic Interference Sources and Their Most Significant Effects." 

Interference Technology. Interference Technology, 5 May 2011. Web. 6 Oct. 2016. 

<https://interferencetechnology.com/electromagnetic-interference-sources-and-their-most-significanteffects/>.
Environmental Assessment and Draft Section 4(f) Evaluation March 2017

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"Electromagnetic Fields and Cancer." National Cancer Institute. 27 May 2016. Web. 06 Oct. 2016. 

<https://www.cancer.gov/about-cancer/causes-prevention/risk/radiation/electromagnetic-fields-factsheet>.

Federal Emergency Management Agency. "Flood Insurance Rate Map 42045C0036F." N.p.: n.p., 

November 18, 2009. N. pag. FEMA Flood Map Service Center. Web. 10 Mar. 2015.

Federal Emergency Management Agency. "Flood Insurance Rate Map 42091C0369E." N.p.: n.p., 

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