Comment EI-13249
Received or sent (printed as 9/25/2008)
As a Village Trustee and our Village Board’s Liaison for Transportation issues, I offer these comments on behalf of the roughly 44 thousand residents of the Village of Buffalo Grove and, further, in an effort to provide a voice for the more than 60 communities with a combined population of 4.1 million residents who will benefit from changes resulting from the acquisition of the EJ&E West Company by the Canadian National Railway Company (“CN”). I recognize that all politics are local, and we certainly have seen our fair share of political theater in connection with this proposal. However, I also believe that as representatives of the U.S. Surface Transportation Board, you have a higher calling -- to view the “big picture” and focus on the proper development and appropriate evolution of our regional and national transportation system, for the greater good. I hope that by making these comments today I can at least help to add depth to your understanding of the broader interests involved. By Resolution 2008-1, Board of Trustees of the Village of Buffalo Grove previously, formally expressed the Village’s strong support for the proposed acquisition of the EJ&E. So, why does the Village of Buffalo Grove and other like-situated communities, support the transaction? There are many reasons. And, I urge the STB in the strongest terms possible to take these benefits and the perspective of supportive communities into account, in proper perspective, along with the detriments claimed by those communities and individuals who urge impairment or rejection of the transaction. The proposed acquisition would allow freight train traffic to be diverted away from the core of the metropolitan area and onto underutilized rail capacity around the perimeter of the Chicago area, thereby improving the surface transportation system for the region as a whole. On a macro level, the acquisition and related improvements will yield substantial transportation, environmental and economic benefits to the region and the nation. It can be a major step toward unclogging our rail system, which will reduce shipping costs, spur investment and add jobs. Efficiency in transportation is absolutely essential to keeping the U.S. productive and to allow our own industries to compete in the global economy. And, finally, CN’s private investment would confer these benefits without the interminable delay and public funding challenges associated with the nearly-dormant CREATE plan. ▫ The ability to move freight traffic more efficiently means having fewer trains tying up traffic and belching diesel fumes while standing in the existing rail gridlock. ▫ Efficient use of rail also offers an inexpensive way to improve the environment without harming the economy. The EPA estimates that a typical truck emits three times the amount of greenhouse gasses and particulates than a locomotive, per ton-mile. Because railroads are, on average, three times more fuel efficient than trucks, railroads also have a smaller carbon footprint. Every ton-mile of freight that moves by rail instead of truck reduces fuel consumption and greenhouse gas emissions by a factor of two-thirds. If just 10% of the freight that currently moves by truck were diverted to rail instead, fuel savings likely would exceed one billion gallons per year. ▫ Moving more freight by rail also helps to reduce highway congestion, which costs $78 billion per year in wasted time (4.2 billion hours) and wasted fuel (2.9 billion gallons), according to the 2007 Urban Mobility Report from the Texas Transportation Institute. A typical train takes the freight equivalent of hundreds of trucks off roads. As such, moving freight by rail enhances mobility and helps reduce the cost of maintaining roads and the pressure to build costly new roads. ▫ By significantly relieving rail congestion, the transaction will help protect the Chicago region’s status as the rail hub of North America. According to the CREATE feasibility study, rail transportation in the Chicago region impacts 5 million jobs nationwide, each year, $782 billion in output and $217 billion in wages. The same study forecasts that if rail capacity is not improved, studies suggest that the Chicago area will lose $2 billion in production and as many as 17,000 jobs will be lost over the next two decades. On a more localized basis, CN’s proposed shifting of trains to a more efficient route on the underutilized EJ&E would result in fewer trains each day for more than 60 communities and their 4.1 million residents, compared with fewer than 30 (with 1.5 million residents) that would see an increase. At present, CN runs the same twenty freight trains per day down the existing CN line that would be diverted to the EJ&E. The purported “increase” in freight traffic on the EJ&E is thus nothing more than moving existing trains from one track to another and the impacts from one group to another. Millions of people in towns that abut the existing CN lines stand to benefit from reductions in rail and highway congestion and delay, a decrease in train noise and relative improvements to safety, if the transaction proceeds. ▫ The number of train accidents on existing CN lines would decrease significantly ▫ The number of train accidents on existing CN lines and the EJ&E line combined would see a net decrease ▫ The risk to pedestrians and bicyclists on existing CN lines would decrease significantly ▫ The combined risk to pedestrians and bicyclists on CN lines and the EJ&E would see a net decrease ▫ The impact of freight traffic on highway congestion and delay at grade crossings for communities along the existing CN lines would decrease significantly ▫ The impact of train noise from freight traffic along the existing CN lines would decrease significantly ▫ From an environmental justice standpoint, minority and low income communities adjacent to existing CN lines would experience significant reductions in freight traffic, resulting in decreases in noise, congestion, delay at grade crossings and noise impacts. The proposed acquisition also would allow for better utilization of the existing CN tracks, upon which Metra operates its North Central Service commuter line. It would set the stage for possible enhancements to the North Central Service, overdue improvements that would take cars off area roads, but which are stalled due to conflicts with freight traffic. The improved and expanded Metra service would address unmet weekday demand and commencement of weekend service, thereby improving the quality of life in the region, enhancing the utility and viability of the North Central Service and adding value to the past federal, state and local investments made in capital improvements to the line. CN acquired the Wisconsin Central in 2001. Prior to that time, freight traffic through our community was relatively light, not unlike volumes seen presently on the EJ&E. Since then, CN has increased traffic on the line substantially. The rapid build up of freight traffic was unprecedented and unexpected for our town and others along the line. Would we prefer to have less freight traffic? Yes we would, absolutely. The additional freight traffic has contributed to increased roadway congestion, and has been the source of significant annoyance and frustration for many. I should add, however, that the increase in CN freight traffic has not caused a cataclysm, civilization as we knew it has not come to an end, and our community continues to adapt and move forward in spite of those changes. In that regard, there are a couple of specific points I want to touch upon briefly. One of the issues raised repeatedly is a concern over potential impairment of emergency responses. I can offer some real life insight into that issue. Despite the quick and unexpected expansion of traffic on the CN Line, we have not experienced those kinds of problems. I have asked this question more than once, and repeatedly have been told we cannot identify even a single instance of an emergency response being materially impaired by the presence of freight traffic. That is in spite of the fact that all of our emergency response facilities are located on the west side of the tracks and a significant portion of the community is located to the east. We have contingency plans to construct an additional facility to the east but as of now, we have been told it is not necessary to do so. Aside from the lack of experiential impacts, we have in place Mutual Aid Agreements with neighboring towns, including several to the east of the tracks, which would allow us to call upon them in the event the need ever arises due to freight interference. Another “big ticket” concern is the claimed need for construction of “dozens” of grade separations along the EJ&E. While I note the draft EIS has identified a handful of specific intersections where mitigation is warranted and I am not here to quarrel with those points or the possibility that separations will be deemed warranted at those locations. The point of contention is the true need for large numbers of new grade separations. In our area, most towns along the existing CN line do not have any grade separation within their boundaries. In fact, along the CN line there are only a total of three separations in all of Lake County, and none are located south of Mundelein. Over more than 40 miles of track from the Wisconsin state line to I-90 at O’Hare Airport, moreover, there are a grand total of six grade separations. Over that distance, the CN tracks pass through nearly two dozen towns, villages and unincorporated areas, including Antioch, Venetian Village, Lake Villa, Round Lake Beach, Libertyville, Grayslake, Mundelein, Vernon Hills, Lincolnshire, Prairie View, Buffalo Grove, Wheeling, Prospect Heights, Mount Prospect, Des Plaines and Rosemont. Even if you average them out, that comes to only one grade separation for every 7 or 8 miles of track. It is hard to imagine that this very large and well-developed area has adapted to the volume of CN freight with so few grade separations while an enormous amount of infrastructure is “essential” to mitigate the move to the EJ&E. In fact, the CREATE program would have provided funding for only 25 grade separations across the entire region. Why are the towns along the EJ&E entitled to more consideration than dozens of other Chicago-area communities that have long lived with as many as 100 trains a day? Even where it is deemed appropriate, moreover, holding the project hostage to a demand that CN pay all, or most, of the related costs, is both unreasonable and unprecedented, not only according to the Chicago Tribune but common sense as well. I started with the proposition that a federal-level agency must view the “big picture,” focusing on regional and national interests. I understand that you have and will continue to hear from individuals, communities and elected officials who oppose the transaction because of concerns about the potential impact on communities along the EJ&E. Decisions of this magnitude should not be made based on who screams the loudest or has the most political currency. I must ask you, therefore – are the cities and towns along the existing CN lines not also entitled to the same considerations as those along the EJ&E? Is our residents’ quality of life inconsequential? Are our interests somehow less significant to this process than those of the towns along the EJ&E? I respectfully submit they are not. And, I must believe that you agree. As such, my challenge to the Surface Transportation Board, as the agency moves forward with the EIS process, is to keep your eye on the big picture – discharge your duties according to the statutory mandates and avoid the traps of politics. Please take the time to cut through the rhetoric, to understand the benefits to regional transportation efficiency, the economy and the environment and recognize the interests of the vast number of communities and literally millions of residents who stand to benefit from changes resulting from the proposed acquisition. The proposed acquisition presents a rare and valuable opportunity to create a more efficient surface transportation system, not only for the benefit of the Village of Buffalo Grove, but for the entire region. As such, on behalf of the Village of Buffalo Grove and more than 3 score like-situated communities, I respectfully request that the Surface Transportation Board approve as soon as possible the proposed acquisition of control of the EJ&E West Company by the Canadian National Railway Company, currently filed as STB Finance Docket No. 35087. Thank you. Jeffrey Berman Village Trustee Village of Buffalo Grove Telephone: 847-909-7091 E-mail: jberman@vbg.org
Submitted by: Jeffrey Berman · Village of Buffalo Grove (Village Trustee) · Buffalo Grove, IL
The Board publishes this comment in its environmental-comment table for this proceeding. It is quoted here as printed; nothing is inferred from it, and it states the commenter's own position in their own words, not this record's.
Permanent address docketyard.org/d/FD-35087/comment/EI-13249 · back to the docket sheet