Letter requesting Red Line environmental statement
July 22, 2014
Brigid Hynes-Cherin, Administrator
Federal Transit Administration – Region III
1760 Market Street, Suite 500
Philadelphia, PA 19103-4124
RE: New location for the Harbor East Station
for the Baltimore Red Line Project
Dear Administrator Hynes-Cherin:
We are writing to request that the Federal Transit Administration (FTA) require that the Maryland Transit Administration (MTA) prepare a Supplemental Environmental Impact Statement (SEIS) with regard to its recent decision to change the location of the Harbor East Station for the Baltimore Red Line Project. This request is being made pursuant to the provisions and requirements of NEPA regulations: Environmental Impact and Related Procedures (23 CFR Part 771), specifically 23 CFR s. 771.130 “Supplemental Environmental Impact Statements.”
Here are the background facts which form part of the basis for this request, laid out below in chronological order:
1) Between September 2010 and May 2012, there were ten meetings of the original Harbor East Station Area Advisory Committee (SAAC), which were regularly attended by roughly 16 persons officially chosen by the MTA to serve on that Committee. These meetings were held pursuant to the 2008 Red Line Community Compact to address the planning and design of already-located stations, and to develop Vision Plans, not to consider change in location (see FEIS, Volume 1, pages 8-2 and 8-3). The original Harbor East Station (Station #14) Vision Plan was prepared on November 1, 2011.
2) On December 14, 2012, the MTA published the Final Environmental Impact Statement (FEIS) on the Baltimore Red Line Project, which had been signed by you on December 4, 2012. The Preferred Alternative proposed by the FEIS is 14.1 miles long, with two tunnels, and 14 surface and five underground stations. The original Harbor East Station is one of the underground stations.
3) The original Harbor East Station was discussed or mentioned in the FEIS in eight of the nine chapters and the Executive Summary in Volume I, and all seven chapters of the Volume 2 Plate Series. The original Harbor East Station was also discussed or mentioned in many of the FEIS technical reports and technical memorandums. The Station was to be located at the southeast corner of Central Avenue and Fleet Street.
4) The period for public comment on the FEIS ended on January 28, 2013.
5) The FTA, over your signature, issued the Record of Decision (ROD) for the Baltimore Red Line Project on February 28, 2013. The original Harbor East Station was discussed or mentioned in ROD Attachments B and D.
6) Fourteen months after the ROD was issued, the public was first made aware through an April 25, 2014 press report in the Baltimore Brew online newspaper that the MTA was working on changing the location of one of the 19 stations proposed by the FEIS for the Baltimore Red Line Project, to move it to a location a little over one block west along Fleet Street. This was the Harbor East Station. [See the internet link]
7) As a result of this change, new engineering and environmental evaluations will be necessary for both the new proposed location of the station, and the new proposed location of the tunnel which approaches the newly-located station from the northwest. Some of this work has already been underway. There will also be need for a public review of this work, along with an opportunity for public comment, in assessing the environmental impact.
Principal Basis for the SEIS Request: The original Harbor East Station was to be located underground in the middle of an industrial area at the southeast corner of Central Avenue and Fleet Street. The location for the new Harbor Street Station will be underground at the northwest corner of Exeter and Fleet Streets, a little over one block to the west of the originally-proposed location. This location is in a highly residential and historical neighborhood in Baltimore City known as “Little Italy.”
According to MTA engineers, each underground station will go seventy feet down into the ground and its ventilation tower will extend about three stories above ground. As such, it will have a number of significant new environmental and other impacts on this Little Italy area. With the deep excavation required for this underground station, there will have to be new and extensive evaluation of the environmental effects on the dense residential and other conditions in Little Italy. These include the following parameters: land use, zoning, demographics, neighborhoods, community facilities, environmental justice, economic activity, visual and aesthetic resources, parks, recreation, open space, air quality, energy, noise, vibration, trees, other ecological resources, water quality, groundwater, and hazardous materials (see FEIS, Volume 1, Chapter 5, and the pertinent accompanying technical reports and memorandums). This new location will also impact some historical properties such as the Bagby Furniture Company Building, the Little Italy Historic District, and the South Central Historic District. There may also be archeological impacts, since the Little Italy area is located contiguous to an important Baltimore City urban archeological site. Members of the local Little Italy Community Organization (LICO) have already voiced strong objections to the proposed new location for the Harbor East Station.
Because the location of the Downtown Tunnel proposed for the Red Line would also have to be moved to accommodate the shift in location for the new Harbor East Station, in addition to the significant environmental parameters cited above to be considered for the shifted location of the station, it will also be necessary to make environmental and engineering findings pertaining to the effect of the tunnel’s new location on wetlands, water bodies, navigable waterways, and the Chesapeake Bay Critical Area (again, see FEIS, Volume 1, Chapter 5, and the pertinent accompanying technical reports and memorandums).
Because these are significant environmental impacts which were not considered in either the 2012 FEIS or the 2013 ROD, both the Little Italy Community Organization (LICO) and the Right Rail Coalition are convinced that merely conducting an Environmental Assessment (EA) under 23 CFR 771.119 and making a FONSI under 23 CFR 771.121 would not be sufficient in this situation. Accordingly, both the Little Italy Community Organization (LICO) and the Right Rail Coalition request that the FTA require the MTA to prepare an SEIS for both the newly-located Harbor East Station and also that portion of the Downtown Tunnel which will have to be moved in order to accommodate the shifted station.
Sincerely,
Giovanna Blattermann, President
Little Italy Community Association (LICO)
Martin S. Taylor, President
Right Rail Coalition
cc:
Therese W. McMillan, Deputy Administrator, FTA
John P. Sarbanes, Member of U.S. Congress, 3rd District of Maryland
Elijah E. Cummings, Member of U.S. Congress, 7th District of Maryland
Barbara Mikulski, U.S. Senator for Maryland
Benjamin Cardin, U.S. Senator for Maryland
Governor Martin O’Malley
James T. Smith, Jr., Secretary, MDOT
Robert L. Smith, Administrator, MTA
Henry Kay, Executive Director for Transit Development and Delivery, MTA
Edward J. Kasemeyer, Chair, Senate Budget and Taxation Committee
Norman H. Conway, Chair, House of Delegates Appropriations Committee
Verna L. Jones-Rodwell, Chair, Baltimore City Delegation, Senate
Curtis S. (Curt) Anderson, Chair, Baltimore City Delegation, House of Delegates
Katherine A. Klausmeier, Chair, Baltimore County Delegation, Senate
John A. Olszewski, Jr., Chair, Baltimore County Delegation, House of Delegates
William C. Ferguson, IV, Senator, 46th Legislative District
Luke Clippinger, Delegate, 46th Legislative District
Peter A. Hammen, Delegate, 46th Legislative District
Brian McHale, Delegate, 46th Legislative District
Stephanie Rawlings-Blake, Mayor, Baltimore City
Bernard C. “Jack” Young, President, Baltimore City Council
James B. Kraft, Councilperson, District 1
Bill Henry, Councilperson, District 4 – Chair of the Housing and Community Development Committee
Helen Holton, Councilperson, District 8
William “Pete” Welch, Councilperson, District 9
William H. Cole IV, Councilperson, District 11
Carl Stokes, Councilperson, District 12 – Chair of the Taxation, Finance and Economic Development Committee
Kevin Kamenetz, County Executive, Baltimore County
Cathy Bevins, Chair, Baltimore County Council
Kenneth N. Oliver, Baltimore County Councilperson, Fourth District