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By way of background, Norfolk Southern and PennDOT have been holding closed meetings only for “consulting parties” to determine the potential effects of the Pittsburgh Vertical Clearance Project on historic properties, and whether an agreement can be reached on mitigation pursuant to the Pennsylvania History Code. These meetings are overseen by the Pennsylvania State Historic Preservation Office (PA SHPO.) Because of the lack of transparency, we are sharing an abbreviated version of the most recent “Comments” submitted by Rail Pollution Protection Pittsburgh (RP3) to the 3rd Merchant Street Bridge Meeting:
Stated simply, the way the historic impact analysis public outreach process is being handled is perplexing.
What was decided at earlier meetings, or contained in a Historic Preservation Office letter, is either ignored or given short shrift by Norfolk Southern, and then accepted by the Preservation Office and PennDOT.
Big picture, with respect to Merchant St Bridge, all of us fully understand Norfolk Southern’s need to expedite the bridge’s replacement, but we are still being told it is not part of the PVCP. Saying that does not make it so. Every written document from the outset of the PVCP says otherwise. 

The process required a determination of both the Area of Potential Effect, and whether both the historic Commons and the historic rail corridor were adversely affected. 
At our early meetings it was agreed that the replacement of the Merchant St Bridge facilitated the PVCP, which impacted the Commons. That led to an April 30 Preservation Office letter directing Norfolk Southern to provide data on direct and indirect impact on the Commons (atmospheric, noise, vibration, visual.) That directive was ignored— even though neighbors know that monitors had been used to gather that very data. Instead, we were told that another undisclosed preliminary study indicated that there would be 4 fewer trains running/day on the proposed PVCP route in year 2045 justifying the both the replacement of the Merchant St Bridge and the approval of the PVCP. 
The Preservation Office accepted the claim at face value and opined, in its September 16 letter that there was therefore no atmospheric or noise pollution that would adversely impact the historic Commons. 

How a 4-train difference between build/no build could be determined 25 years in advance along a route with four tracks each with a capacity of 70-80 trains/day was never explained. Idling lower priority trains in Manchester was never considered because the game plan throughout has been to isolate and segregate each segment of the Project to limit both its area of potential effect and to minimize mitigation. 
By letter dated 4/30
the PA SHPO previously determined as follows:
“At the April 2020 consulting party meeting the local consulting parties expressed an interest in measures to minimize visual effects to the community through an increase in the height of the retaining wall that runs along the railroad and the addition of landscaping along the railroad corridor. The retaining wall and the decorative fencing atop it are contributing features to both the railroad corridor district and the Allegheny Commons Historic District. If elevation of the retaining wall is introduced into the project design, then it will be necessary to reassess the potential effect of the project on both historic properties.”
At Meeting # 3 Norfolk Southern maintained that raising the walls in the trough would not impact the Merchant Street Bridge (without responding to the impact on the historic Commons). The response was accepted and the matter dropped. 
Next, we were told that a Memorandum of Agreement would be negotiated and signed between the Preservation Office and Norfolk Southern —and only then shared with Consulting Parties who would have no input into those negotiations or into 
the Agreement’s terms. 
It is significant that only after our collective objections at Meeting #3 did the Preservation Office acknowledge that the routine practice was to provide a draft MOA to all parties for input before any party signed, and that their office would now re-examine the issue of adverse impact on the Commons. None of the foregoing provides any confidence at all in the Section 106 public outreach, or the historic review process that is occurring under PennDOT’s auspices. 
Moreover, on parallel tracks (forgive the pun), community and individual voices are being suppressed.   In the last 2 1/2 years PennDOT has held only one (placard) public meeting and cancelled the contract with a moderator to hold 27 community meetings. At the same time Norfolk Southern has spent well over $200,000 to litigate excluding RP3, the NSLC and the Manchester community (MCC) from intervening in PUC bridge and highway crossings safety proceedings. That money should have gone to mitigation. 

Finally, the Preservation Office directed Norfolk Southern to respond in writing and at meeting # 3 to both RP3’s and the Simm’s corrosion data:
“which questions the condition of other bridges along the line in comparison to Merchant Street. The response should provide an understanding of the condition of other structures along the line and why it is necessary to replace the Merchant Street bridge before and independent of others along the Pittsburgh Vertical Clearance Project Corridor. “
Norfolk Southern provided no written response. Instead, we were told at Consulting Party Meeting #3 to take comfort in the fact that we were all safe and that Norfolk Southern was inspecting properly. 

There is ample reason to doubt Norfolk Southern’s reassurances.
Contact your city, state, and federal representatives to ask them to ask the PUC and the Federal Rail Administration for special inspection oversight of Norfolk Southern’s bridge and rail lines.
Congressman Doyle’s Transportation Lead
Congressman Lamb’s Transportation Lead
How to find your representatives:


Rail Pollution Protection Pittsburgh
Rail Pollution Protection Pittsburgh
Copyright © 2020 Rail Pollution Protection Pittsburgh (RP3), All rights reserved.

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