Comment EI-18363
Received or sent (printed as 9/28/2010)
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: The proposed Resource Recovery, LLC (RRLLC) landfill will not proceed without rail access. The No-Build Alternative (Local Road System Upgrade) carried forward in the Draft Environmental Impact Statement (EIS) cannot be considered as a legitimate alternative. The Point of Access Study referenced in the Draft EIS clearly demonstrates that the local road network is incapable of handling the anticipated traffic and was not planned, intended, or designed to accommodate the anticipated traffic or the required improvements that would be necessary for the No-Build Alternative (Local Road System Upgrade). Given that the improvements are inconsistent with local and regional transportation plans, particularly Snow Shoe Township, the Local Road System Upgrade would not receive the approvals necessary to implement the upgrades (e.g., condemnations). There is also an agreement in force between RRLLC and Snow Shoe Township (Cooperation Agreement, February 2006) in which RRLLC agreed not to use Gorton Road for trash hauling. Because the No-Build Alternative (Local Road System Upgrade) is not a legitimate alternative, the only access that could accommodate the projected uses (1,100 truck trips per day) is one of the Build Alternatives. Without access, the proposed landfill cannot advance past its suspended status (effective October 2006) and cannot be approved, constructed, or operated. Approval of the proposed rail line project would provide access. Thus, the proposed landfill is dependent on the rail line project taking place. The approval sought by the Surface Transportation Board for the proposed rail line can reasonably be said to cause the related actions of landfill approval, and subsequently, construction and operation. Therefore the rail line and landfill should be considered a connected action and alternatives for the landfill must be considered to ensure a comprehensive and just environmental review. Thank you for considering my concerns.
Submitted by: JoAnn Gillette · Clarence, 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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