Comment EI-14173
Received or sent (printed as 9/30/2008)
Ref: STB Finance Docket No. FD 35087 Regarding the purposed purchase of the EJ&E railroad by the Canadian National railroad, as a resident of Frankfort, IL and a citizen of the U.S.A., I strongly oppose the acquisition. The rationale for my position is based on two primary factors. TRACS Act: With the House Transportation and Infrastructure Committee’s recent approval of the Taking Responsible Action for Community Safety, or TRACS, Act (H.R. 6707), a decision on the CN-EJ&E transaction should be postponed until this updated legislation or similar legislation goes before Congress. The current rules that the STB follow are antiquated and are in desperate need of updating: thus TRACS. TRACS would properly require the STB to consider a rail expansion projects' effects on local communities. It would do all citizens an great injustice to pass an approval to CN with the TRACS Act pending. There is a high likelihood that if the CN-EJ&E transaction were looked at under TRACS, it would not be approved or at least would be sufficiently analyzed. DEIS Inadequate: There are many ways in which the DEIS is inadequate. One major flaw is that the study does not examine the competitive advantage that CN will gain with the purchase of EJ&E and, therefore, severely overestimates the benefits to the communities that are expected to experience decreased CN rail traffic (ex. Blue Island, Markham, Riverdale, and many others). The main purpose that a private company such as CN has to purchase EJ&E is economics. The CN has clearly stated that their trains will be able to flow more quickly through the Chicago area on the EJ&E rail lines. Then, isn’t it reasonable to conclude that they will then be able to attract additional customers? The CN has stated and the DEIS does not challenge that the projected utilization of the EJ&E lines by CN will be at or near full capacity in the near-term post-purchase. Therefore, if they are able to utilize their new competitive advantage (shortened delivery times) to win new customers, where will the additional rail traffic run? The answer: It will run through the very neighborhoods and communities that the trains go through today. The very communities that believe that this acquisition is good for them will be very disappointed in due time when they again see many CN trains blocking their roadways. When that day comes, the entire Chicago area will be choked by the trains of a foreign company. How long will this prediction take to come true? Likely only a year or so. Why else would CN want to do this EJ&E deal if not to give themselves a competitive advantage? While in the short-term there may appear to be a slight net advantage, in the intermediate- and long-terms, the net impact to the entire Chicago area will likely be resoundingly negative. Why would the DEIS take such a limited view of CN’s operations and ignore the impact to their ability to win new customers? How can the STB make a decision based on a DEIS that holds certain a critical element static (i.e. CN’s competitive position) when that element is central to the transaction? The STB should not render a decision regarding the proposed CN acquisition of EJ&E until the true and full, long-term impact on the entire Chicago area is properly scoped and analyzed. Further, the STB’s decision should be based on the most current laws, which may be TRACS. Thank you for your attention to this important issue. Sincerely, Terry Briese
Submitted by: Terrence Briese · Frankfort, 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.
FD 35087 STB DEIS Comment.doc ↓
Permanent address docketyard.org/d/FD-35087/comment/EI-14173
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