Comment EI-18359
Received or sent (printed as 9/28/2010)
September 24, 2010 Surface Transportation Board 395 E Street, SW Washington, DC 20423 Attention: Danielle Gosselin Section of Environmental Analysis Environmental Filing FD 35116 RE: Environmental Filing FD 35116 Dear Ms. Gosselin: This is a follow up to the oral comments I made at the September 14, 2010, public meeting. As I stated at the meeting, I am extremely disappointed with the Draft Environmental Impact Statement (EIS), most of which is based on incomplete or outdated information. Following are my concerns with the Draft EIS: 1. The assertion is made that the U.S. Corps of Engineers (COE) and the Federal Highway Administration (FHWA), along with the Surface Transportation Board (STB) have prepared the EIS. However, there is no documentation in the Draft EIS to support this degree of involvement by the COE or FHWA. In fact, I am aware that as of September 1, 2010, the COE has officially notified the STB that they have withdrawn as a Cooperating Agency for the EIS. The FHWA will probably limit its comments to highway related matters. 2. The STB refuses to recognize that the potential environmental impacts of the rail construction, reactivation, and operation and the proposed uses are connected actions under the National Environmental Policy Act (NEPA). This view is shared by many of the other federal agencies and I am confident that several will make this point in their comments. I don't think anyone believes that the railroad would be built if not for the landfill and associated uses. 3. To support its analysis, the Draft EIS treats the proposed uses as though they are set in stone. On page E-1, it states: “‘these facilities are currently being developed.” Although there are proposed uses, there is NOTHING “currently being developed”—no landfill, no industrial park, no wastewater treatment plant, no 200,000 tons-per-year quarry, no coal mining operations, and no infrastructure of any kind. Resource Recovery, LLC has tried for six years without success to get the necessary permit approvals from local, state, and federal agencies to move their project forward. And now they are starting over. An article published August 31, 2010, in the local area newspaper, the Centre Daily Times, reported that: The developer who had proposed building a landfill in Rush Township said the project has changed direction and the company is now working on plans for a waste to ethanol plant. Further, the Draft EIS states that 99 rail road cars of frac water could be transported daily; however, the frac water plant that is mentioned in the Draft EIS has never been permitted. 4. No mention is made in the Draft EIS of the possibility of gas well drilling on the site. Yet, numerous wells are either planned for the area or operating in the vicinity. As we all know, mountain hydrology is not an exact science. Possible spills of frac water and piercing of underground aquifers point to the possibility of unmitigated disasters. These potential adverse consequences are not addressed in the Draft EIS. Black Moshannon State Park Lake is only three miles from the proposed site and Cooper Township’s municipal water supply is close by. These issues should be addressed in the EIS section dealing with Water Resources. Given all of the unknowns, how can the Draft EIS conclude that there are only moderate environmental impacts? I urge the STB staff to take these issues under consideration before issuing the final EIS. Thank you for considering my comments. Michael T. Savage 130 Teaberry Drive Philipsburg, PA 16866
Submitted by: Mike Savage · North Run Homeowners Association · Philipsburg, PA
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.
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