Comment EI-14028
Received or sent (printed as 9/29/2008)
Ms. Johnson-Ball: This correspondence will serve as follow up public comment from the Village of Park Forest on behalf of its citizenry to the proposed acquisition of the EJ&E railroad by Canadian National (CN). Park Forest is a community of more than 24,000 residents that straddles the current EJ&E rail tracks. A fully developed community with a number of residential neighborhoods immediately adjacent to the tracks, Park Forest is deeply concerned about the potentially severe impacts to the quality of life for its residents. A detailed list of Park Forest concerns was shared with the Surface Transportation Board (STB) in January of this year. Upon review of the Draft Environmental Impact Study (D-EIS), the Village of Park Forest would like to point out several concerns as follows. The D-EIS includes no reference to the clearly expected adverse impacts to Park Forest’s Emergency Services Operations (Table ES-2 on page 45) that will be seen with a conservatively estimated 400% increase in rail traffic, 500% increase in rail cars and tonnage, and a 700% increase in transported hazardous materials. While the table references the two nearest hospitals to Park Forest as being impacted, it would only stand to reason that a quadrupling of train traffic crossing Western Avenue will adversely impact emergency response times in getting citizens with life-threatening injuries and/or other health matters to critical medical care. With CN’s self-admission of a seven-fold increase in hazardous materials to be traveling through Park Forest with the proposed merger, the potential for a catastrophic hazmat incident increases proportionately. With several residential neighborhoods in close proximity to the rail tracks in our community, Park Forest respectfully requests that additional considerations be made to the equipment and staffing needs of the Park Forest Fire Department. The Village appreciates the STB’s designation that the Western Avenue rail crossing is a prime location in need of mitigative attention by CN. The D-EIS recommends and encourages mutually acceptable negotiated agreements to mitigate adverse environmental impacts should the Board approve this acquisition. Although the Village has had several meetings with Canadian National representatives, no substantive progress has been made in dealing with the most significant issues facing Park Forest. Additionally, CN has made it clear that they will only do what is absolutely required by the STB’s findings as they relate to the potential for a separated crossing of rail tracks at Western Avenue. CN has made it clear to the Village that they will not provide funding for a separated crossing at Western. Additionally, the STB suggests that CN join the Village to seek funds for a separated crossing at Western Avenue through the Department of Transportation. Why should Park Forest and, ultimately, Illinois tax payers be faced with this burden given the fact that this would not have been an issue but for the CN (a for-profit company) proposal? In our negotiations with CN, their representatives stated that their allegiance is solely to the company’s shareholders rather than being concerned about adverse impacts that might be pending to Park Forest residents, the interest group that Village Officials are bound to represent. To date, the Village still stands waiting for CN to follow up on our requests to resume negotiations related to mitigation. The D-EIS references that the proposed acquisition will include the construction of six new rail connecting tracks between existing rail lines and the EJ&E arc, one of which is at the corporate borders of Park Forest and Matteson. Park Forest can foresee two negative impacts as a result of this new track connection. First, in order to facilitate such a connection, CN will need to purchase an approximate 12-acre parcel of property currently owned by Park Forest. This parcel currently includes a commuter parking lot with a capacity for 740+ cars. The Land Use section of the D-EIS does not account for CN’s need to purchase portions, if not all, of this property to allow for constructing the connection from the east/west bound EJ&E tracks to the CN lines which travel north/south bound. In addition to the lost commuter parking, this construction will have a severe impact on the Village’s revenues from the lot, if these revenues are not altogether eliminated. The second issue Park Forest has with the proposed new connecting tracks in Park Forest/Matteson is that the concept has not been fully explored in the draft report. Park Forest, along with Matteson, will be faced with even longer delays than those reported in the D-EIS. Since train speeds will be further restricted due to the configuration of the connection, the negative impact of that slow down is not addressed in the D-EIS. Park Forest’s experience (actual video footage) will show that track speed or complete stoppage on the tracks is greatly understated in the D-EIS, as evidenced by your statements found on page ES-10 of the report, and by CN in any of their presentations being made to the unsuspecting public. The Village of Park Forest has invested a significant amount of resources (staff time and financial) to purchase a deteriorated and tax delinquent Norwood Square Shopping Center, which is immediately adjacent to the rail crossing at Western Avenue. Efforts have included the creation of a TIF district, remediation of brownfield problems, and a diligent search to find a private shopping center developer to purchase the property. Now that a private owner/developer of this property has been found, Nassimi Realty, who is committed to investing $1 million in initial improvements, and $3-5 million over time, they are reconsidering their investment in this property because of the uncertain impacts that this proposed purchase will have on their investment. This is a 129,000 square foot shopping center that has the potential to generate significant property tax and sales tax revenue for Park Forest. It could easily represent the single largest sales tax generator in the community when it is fully redeveloped and tenanted. Now, its future is uncertain unless CN is made to provide a grade-separated crossing at Western Avenue. It has been alleged that CN’s proposed acquisition will help relieve major traffic congestion and reduce environmental impacts for the aggregate Chicago-land area. Quite to the contrary, Park Forest believes the proposed acquisition merely shifts the entire congestion and environmental impact burden to the communities along the EJ&E rail arc. In particular, the numbers point to a tremendous burden being shifted to Park Forest. CN estimates that the number of trains traveling through Park Forest as a result of the proposed acquisition would increase from 8 to 32 per day – or, on average, one train every 43 minutes. The Village believes this is a conservative estimate, at best, and encourages the STB to assess longer range estimates and how much worse the adverse environmental impacts will be on the citizens of our community. Even with these conservative estimates, Park Forest stands to suffer perhaps the most severe impacts of any community along the EJ&E rail arc. CN has provided a public position that their intent is to move rail traffic as quickly as possible through communities along the EJ&E rail arc. It has been suggested that their trains will pass along these lines at rates of speed between 30 – 45 miles per hour. While this is an admirable goal to help mitigate traffic blockage and idling impacts, the next train that travels through Park Forest at such a rate of speed will be the first. Train traffic crossing Western Avenue in Park Forest averages no more than 5 – 8 MPH, at best. Additionally, trains routinely crossing through Park Forest do so at a speed of less than 5 MPH. Worse yet, it is a very routine occurrence where train traffic comes to a complete stop across Western Avenue. Please know that these details are not mere anecdotal references. The Village purchased video surveillance equipment and has documented evidence for more than a 30-day period. This video footage is readily available should it be desired by the STB. During the public comment sessions established by the STB, Village Officials convened at one gathering in particular (Matteson Holiday Inn on August 25) to provide additional feedback regarding the D-EIS. In a conversation with CN Officials on hand (Senior Manager James Kvedaras, to be specific), the question was posed by Village Elected Officials: “With a conservatively projected 400% increase in train traffic expected to impact Park Forest, what are the positives that this proposed acquisition will bring to the community?” Mr. Kvedaras’ response was evasive, at best, as he noted that “While there are no positives for Park Forest, the positives are for the region and not necessarily your community.” This was the second time that Village Officials had to listen to such a flippant response on an issue with such severe impacts on the citizenry of Park Forest. That a representative from CN, a foreign-based company with multi-billion dollar annual profits, would take such a position is unconscionable. In closing, the Village respectfully appreciates the difficult task before the STB in conducting the environmental impact study associated with this proposed acquisition. And while Park Forest may fully understand the regional benefits being sought by such a shifting of train traffic in the northeastern Illinois region, it is painfully clear that all perceived positives are direct shifts of burden onto the residents and businesses of Park Forest and the municipality’s emergency operations. The end result is a dramatically impacted quality of life for our community and a locale that is much less desirable in which to live and/or conduct business. Should you have any questions regarding this correspondence or any of the previous documentation submitted by the Village of Park Forest, please feel free to contact Village Manager Tom Mick at your convenience. He can be reached directly at 708-748-1129.
Submitted by: Deputy Village Manager Mary Dankowski · Village of Park Forest · Park Forest, Illinois
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-14028 · back to the docket sheet