Mary Pattock’s Letter – LRT-Done Right

Mary Pattock’s Letter

The following letter from Mary Pattock is the introductory letter to LRT-DONE RIGHT’s response to the Southwest LRT Supplemental SDEIS.  A link to that 46 page response has been posted on Park Watch earlier.

LRT-Done Right

2782 Dean Parkway
Minneapolis, MN 55416

July 21, 2015

Nani Jacobson
Assistant Director, Environmental and Agreements Metro Transit
Southwest LRT Project Office 6465 Wayzata Blvd, Suite 500
St. Louis Park, MN 55426

Dear Ms. Jacobson:

LRT-Done Right is a grassroots organization of some 500 Minneapolis residents and taxpayers who have conducted exhaustive research and advocacy on the effects of light rail transit and freight lines on community well being. We hereby submit to you our comments on the Southwest LRT Supplemental Draft EIS. They are the product of literally thousands of volunteer hours of research, analysis, and writing. As citizens of Minneapolis and the Metro area, we hope and expect that they will receive appropriate respect, attention, and response.

The 2012 Draft Environmental Impact Statement clearly recommended that the best course of action was to relocate freight out of the Kenilworth Corridor.

This position was reversed in 2013, and the Metropolitan Council’s recommendation is now to “co-locate” freight and light rail in the Kenilworth Corridor. We consider this a significant breech of public trust and the low point of a deeply flawed planning process. We are an organization that seeks to represent concerns of those most impacted by this unfortunate decision.

The current Supplementary Draft Environmental Impact Statement is partly intended to assess the impact of co-location in the Kenilworth Corridor. It fails to do so on many levels, summarized in the following points:
First, it considers the temporary freight rail part of the existing condition. Freight rail service that runs through the corridor would be both upgraded and made permanent; this is a new project that needs a full analysis. Because new permanent freight infrastructure is being added to the corridor, all visual, noise, vibration, safety and other environmental impacts should be measured from a basis of no freight and no light rail.

Second, this SDEIS is silent on the safety implications of locating freight trains carrying hazardous materials through an urban environment within feet of homes, parks, trails, passenger trains, and live overhead electrical wires. The new and serious impacts created by this situation would continue to grow as transport of ethanol and other volatile materials expands and freight trains grow longer.

Third, this SDEIS is significantly flawed in it findings regarding environmental impact, safety concerns, and disturbance of livability, if not outright danger, to those living within a half mile of the route, which we will refer to as the “Blast Zone.” This is a real issue that was not as prevalent in the news when the alignment was first proposed. In the context of current discussions regarding the increased number of freight accidents across the United States and Minnesota, we are seriously concerned about the safety of families and loved ones who would live in a Blast Zone zone surrounding ethanol trains and sparking LRT wires. 

Fourth, we are disturbed by the promises of unspecified remediation activities found throughout the SDEIS. As the Department of the Interior says in its Handbook on Departmental Review of Section 4(f) Evaluations: “Reviewers are alerted that a general statement indicating that the sponsor will comply with all federal, state, and local standards and specifications to minimize harm is not acceptable…. Reviewers should make sure that all possible site-specific planning has been done to identify and list the measures which will be undertaken, at project expense, to minimize harm to Section 4(f) properties.” Such general promises are not acceptable to the federal government. Nor are they acceptable to us.

Finally, the SDEIS fails to address the significant costs associated with the many design and construction, safety, and environmental remedies that it will, based on our assessment, be required to implement — the relocation of a sewer force main that the Met Council installed only months ago, and sound and vibration remediation measures for area residents are but two. Nor does it recognize long-term costs of lost property tax revenue that would erode the tax base of the City of Minneapolis in perpetuity. We estimate that these combined costs would initially total at least $13 million to $24 million, and much more over the years.

When Hennepin County and the Met Council chose the present route for SWLRT between the Chain of Lakes through the Kenilworth Corridor — including “co-location,” thus making the temporary freight rail permanent — they accepted the responsibility to respect the natural and built environments that it travels through as well as the people who bicycle, walk, recreate, and live there. LRTDR does not see evidence that this responsibility has been taken as seriously as necessary and the following pages, which respond to specific elements of the SDEIS, articulate some of the reasons why.

Mary Pattock
On behalf of LRT-Done Right