Draft EIS. Comment #6: Missed Goals

Missed Goal

The Tier II draft EIS (Environmental Impact Statement) has the following statement on the first page,

The purpose of the DC2RVA Project is to increase capacity to deliver higher speed passenger rail, expand commuter rail, and accommodate growth of freight rail service in an efficient and reliable multimodal rail corridor.

The project in its current form does not meet the specified goals. Specifically:

  • It does not provide true high speed rail service between Richmond and Washington D.C. High speed trains have a straight away speed of 180 mph or more. This project does not come close to achieving that target.
  • Today’s Amtrak trains are frequently quite empty. “Expanding commuter rail” will merely increase the number of empty trains. A true commuter service would have trains leaving every 20 minutes.
  • The growth in the freight capacity is an assumption that may not hold up. Data published by the Association of American Railroads shows that the number of carloads in the year 2017 to date is below the number for the years 2015 and 2016.
  • The term “multi-modal rail corridor” presumably means that both passenger and freight trains run on the same tracks as they do now. The DRPT goals would be better achieved by separating passenger and freight trains.

I suggest that the DRPT go back to the drawing board and come up with a plan that addresses the goals that it has set for itself.

Draft EIS. Comment #1: Council Letter

Draft EIS DRPT – Trench deficiencies

The DRPT (Department of Rail and Public Transport) has released their Draft Environmental Impact Statement (EIS). The public comment period ends November 7th 2017. I intend to submit a series of comments — of which this is the first.

Please take the time and trouble to submit your comments. Remember the DRPT will not respond to comments made in any other forum, including social media sites and blogs.

Here is the address: http://dc2rvarail.com/contact-us/

As best I can tell the comment software does not allow for embedded hyperlinks. Therefore I suggest that you spell out internet addresses, as shown below. Also, the comment software does not appear to allow for file or picture attachments.


Comment #1: Council Letter

On September 12th 2017 the Ashland Town Council sent a letter to the citizens of Ashland. The letter powerfully describes the multiple deficiencies of the proposed trench option. 

The letter is published at the town web site (http://www.ashlandva.gov/DocumentCenter/View/2176) and can be downloaded here: https://iansutton.com/downloads/Council-Letter-2017-09-12.pdf.

I fully endorse that letter.

Signed, Ian Sutton

Letter to DRPT

Letter Ashland DRPT train safety

John Hodges and I have sent a letter/report to the DRPT expressing our concerns to do with safety and the proposed third track through Ashland. The letter, which was written on Ashland Museum letter head, has three main sections:

1. Vehicle / Train Collisions
Cars frequently drive on to the tracks. Many of these events have been recorded by the organization Virtual Railfan. In some instances the events have led to trains hitting cars. People have been injured — we are fortunate that so far there have been no fatalities. Adding an additional track and many more trains will create a safety situation that is untenable.

2. Highly Hazardous Chemicals
Approximately 6% of the freight traffic consists of tank cars carrying chemicals that are flammable, explosive or toxic. In the process industries it is normal to conduct a Formal Safety Assessment to do with such chemicals. We believe that such a study should be carried out for our community.

3. Engineering Standards
We need more detail to do with the standards for,

  1. Spacing between tracks.
  2. Spacing between the outer edge of the tracks and the first public access point.
  3. Whether modern standards will be applied to the existing tracks.

First CAC Meeting: Notes

High speed rail Ashland VA

The DRPT held its first Community Advisory Committee (CAC) meeting yesterday. A video recording of the meeting will be published at their site. Here are a few informal first impressions based on my notes.

  • The committee was made up of representatives from the Town of Ashland, western Hanover, Randolph-Macon College and CSX.
  • The DRPT team made a series of presentations that gave an overview of the project, why it is needed, and what the constraining parameters might be.
  • It was stressed that the purpose of the project was to improve the reliability, frequency and travel times of passenger trains along the north-eastern corridor. In particular to improve the current reliability from 66% to 90% and to roughly double the number of passenger trains.
  • A secondary goal is not to adversely impact CSX operations. (It was noted that CSX traffic is likely to increase due to the port of Virginia expansion at around 2% per annum.)
  • They are planning on double-stacked trains that could be up to 15,000 ft. (3 miles) long.
  • CSX will continue to own the existing track and will also own any new track. CSX will continue to dispatch all trains.
  • An overview of the Basis of Design was presented. It discussed curves and gradients but did not provide information to do with (1) code for spacing between tracks, (2) code for spacing from the outer edge of the tracks to the first public access, and (3) whether the existing tracks will be upgraded to modern standards. (A figure of 135 ft. for a new Right of Way was provided.)
  • The height of new bridges will be sufficient to allow for electric passenger trains in future.
  • The current speed restrictions through Ashland are 35 mph for freight and 45 mph for passenger. On other sections of the track these numbers are 59 mph and 65 mph respectively.
  • The replacement of jointed rail with welded rail will reduce noise and vibration.
  • All tracks (old and new) are to be inter-operable for both passenger and freight.
  • VA law requires that all new crossings be not at grade.
  • The various options that we have seen in previous meetings were presented. There was also discussion to do with eastern (Buckingham Branch) options. It appears as if linking BB and CSX trains in the Richmond Main St. area will be a challenge.
  • Two options for underground track were presented. One would be a cut-and-cover tunnel, the other would be a deep bore. No discussion of the impact of construction vibration on old homes with weak foundations was provided.
  • They are still carrying out operations modeling with the FRA.
  • Future meeting dates are shown below. Locations have yet to be decided upon.
    • June 26th
    • July 24th
    • August 28th
    • September 25th
    • October 16th (if needed)

To repeat: these are my first impression notes. We will be able to analyze the presentations more thoroughly when the video is published.

Florida Crash

CSX Florida Train Crash 2016

Two CSX trains collided today at a location in central Florida. Although this event did not involved highly hazardous chemicals it does give us an idea as to the impact of such an incident. (The first reports state that there was a 4,000 gallon fuel leak although it appears as if it did not catch fire. It is not clear if this number refers to the actual or potential size of the leak.)

Based on the pictures  and movie clips that have been made available so far some of the derailed cars are at least one a car length away from the tracks. Most freight cars are around 60 ft. long (including their attachments).As the sketch below shows, currently there is a distance of 351 inches or 29.25 ft. from the outer edge of the rail to community property.existing
Therefore, were an event such as this to take place in Ashland, it would impact many homes and businesses.


Draft Tier II EIA: Analysis #1 – What’s Not There: Safety

Toxic East Tennessee train derailment


On November 8th the Commonwealth of Virginia Attorney General’s office released a draft of the Tier II Environmental Impact Statement (EIA). A copy of the document is available at the Town of Ashland web site here. (Due to the size of the document it takes a few minutes to download the document. Be patient.)

The document is lengthy (1426 pages) and is difficult to navigate because the Adobe ‘Find’ function does not work, at least not on the document that we downloaded. I will analyze the document as time permits and publish a set of Analyses.

Disclaimer: Because there is so much material in this document it is possible that some of the early conclusions will have to be adjusted as the analysis proceeds.

My first reaction to the draft EIS is a huge “missing section”. There is no solid discussion about the most important topic of all: Safety.

There are various categories of safety. For the purposes of this analysis we will look at two of them:

  1. A spill of a Highly Hazardous Chemical from a damaged tank car.
  2. A grade crossing event involving either a vehicle or a pedestrian.

Chemical Tank Car Safety

We have discussed chemical tank car safety in many previous posts. Probably the most relevant is the Lynchburg derailment. After all, this occurred in our state just over two years ago.

What Can Happen

The general scenario is as follows.

  1. A tank car is badly damaged, say by hitting another car or by coming off the tracks. (The picture at the top of this post is an example of the second failure mode.It is of  a car carrying toxic chemicals through Tennessee in July 2015. The chemical in question — acrylonitrile — is toxic, flammable and water soluble. This event led to serious contamination of both the soil and groundwater.)
  2. The chemical spill leads to the formation of a cloud of toxic gas that drifts into the local community, or the spilled contents explode and catch fire. One of the tenets of my work is not be alarmist. But, should such an event take place within the town of Ashland, the loss of life and injuries to people could be very high indeed.)

Now the likelihood of such an event is low, but it is not zero. Indeed, an Internet search shows that there have been quite a few of this type of event in recent years. Moreover we know how to analyze events of this type using EPA-approved software. Chemical risk management is a mature topic.


Up until this point we have simply accepted the risks to do with highly hazardous chemicals being hauled through the town of Ashland. “That’s the way it’s always been”. But now that we are looking at new track configurations it would be irresponsible not to select the safest option. And that option is to run chemical tanks cars on a bypass around town. This would improve safety for the following reasons.

  1. The population density would be much lower. Hence the impact would be correspondingly less.
  2. A new track would be built to the latest standards of safety, particularly with regard to track spacing. Hence the likelihood of such an event taking place would be as low as can be achieved.
  3. Emergency vehicle access would be good since all crossings would be bridges, hence the roads would not be blocked by the stopped train.

Traffic Crossing Safety

Amtrak incident Myrtle Street Ashland VA 2012

The second type of safety with which railroads concern themselves is collisions between vehicles or people at grade crossings. (The picture shows the consequence of a train traveling at 9½ mph hitting a car crossing the tracks at Myrtle St.)

Events such as these occur quite frequently. The town of Ashland is a particular concern due to the large number of vehicles that transit England St. and Ashcake Rd. On the other hand the proposed bypass will have only bridge crossings and (presumably) fences to prevent people and livestock from crossing the tracks.

One of the options presented at the recent community meeting at the Ashland theater was to run just passenger trains through Ashland and to direct freight trains (and presumably express passenger trains) on a bypass. Not only would such a bypass option be inherently safer due to the absence of grade crossings, safety will also be enhanced because there would be fewer trains traveling through Ashland. A rough estimate is that around 80% of the trains are freight. If most of these could be diverted we would see a corresponding improvement in safety. Moreover, passenger trains are shorter and can brake more quickly: another safety enhancement.


Ashland VA train tracks — no third rail

Running just passenger trains through town and diverting most of the freight trains to a bypass is unequivocally the safest option.

CTB Meetings: November 1st – Details

Germanna Community College

One of our Ashland neighbors has provided the following additional information to do with the meetings on November 1st.


11:00 am Ashland Theater, OPEN TO THE PUBLIC – CTB and DRPT will be giving a presentation on High Speed Rail and their visit to Ashland. Then, Jim Foley, R-MC President Lindgren and a representative from the County will briefly speak (5 minutes each.) Next there will be a Q&A between the CTB and Town and County representatives… there will be NO PUBLIC COMMENT.

The group of officials will then walk from Lee Street (Library) north to College Ave where they will ride a bus up Center to Ashcake to check out a potential new rail station location. Then, as I understand it, they will drive along the Western Bypass route before leaving for their 4:00 meeting in Fredericksburg.

Let’s show them how much we love our Town… Come to the meeting at the Ashland Theater, beautify your properties for them to see, be out and about Town during their visit and please come to Fredericksburg for public comments during CTB meeting!

Commonwealth Transportation Board Meeting

Tuesday, November 1 @ 4:00

Germanna Community College,
Center for Workforce Development and Community Education
10000 Germanna Point Drive
Fredericksburg, VA 22408

There are already a few people planning on attending/speaking at this meeting, so if you would like to car pool contact kjamkjam at comcast dot net.

If anyone has questions, you can contact Jim Foley jfoley@town.ashland.va.us or Kathy Abbott kabbott@town.ashland.va.us or Josh Farrar (Acting Town Manager)  jfarrar@town.ashland.va.us


If you are planning on speaking at the Fredericsksburg meeting I suggest that you coordinate your comments with Jim Foley or Kathy Abbot.


Historic Properties

Ashland Baptist Church

The following information has been taken from an email from Rosanne Shalf, President of the Ashland Museum. Note that many of the buildings that she refers to will be destroyed if a Third Rail is put through town.


The Virginia Department of Rail and Public Transportation will be coming to Ashland on November 1 at the Ashland Theatre and will tour the town. They will have a meeting, not a public hearing, about their plans for the fast rail. It is important that as many well-behaved, friendly citizens as possible are at the meeting and also strolling the streets, eating outside, etc. so they can see our relationship and proximity to the rail right of way.  Please make no reference to the western bypass. We need to be united. See Jim Foley’s letter.

The Federal Rail people have to take into account any historic properties that might be in the path of the proposed rail.  The way they do that is to do a “Section 106 Study” that identifies the historic properties that any proposed route would affect.


“Contributing structures” within a historic district are ones that fit within the timeframe and architectural styles of the particular district. “Non-contributing structures” are ones like brick ranchers or other 1950s and later buildings or buildings that have been so altered that they don’t have the architectural elements of the period. I’ll point some out below.

“Historic Landmarks” are single buildings that are designated because they have some special significance because of people associated with them or because of their special architecture.

“Historic Districts” are large areas and neighborhoods that have a collection of mostly “contributing structures” of a particular time period. That’s us.

Our Districts

First, Ashland has two National Historic Districts and they contain over 200 buildings that are historic and considered “contributing structures” to the district. Most of the buildings on Center St and Railroad Avenue are within the district.  You can count on your fingers the non-contributing ones—Brock Gym, Ashland Coffee and Tea, and some mid-century homes along there or recently constructed homes. They are obvious, but there aren’t many “non-contributing”.

District #1

RANDOLPH-MACON HISTORIC CAMPUS, designated in 1979, the three oldest buildings that face the tracks built in the 1870s.  It is these that would be negatively affected by the proposed station improvements, to say nothing of having the campus split in two.  There are no non-contributing structures in this district.

District #2

ASHLAND NATIONAL HISTORIC DISTRICT, designated in 1983, contains over 200 buildings most of which are “contributing structures.” The date timeframe for our current district is pre-Civil War (Macmurdo House, The Center, Chopper Dawson’s house) to the 1930s, and “contributing structures” are those built in that time-frame that have not been so altered, especially the front facades, that they are no longer representative styles of their time. Most of the buildings on either side of the tracks are in the district from almost to Patrick St. on the north to Early Street on the south. They include but are not limited to the following, and this is a really rough breakdown. You can see the addresses in the attached file.

Historic Downtown Business District south of Rt 54, including the old Hughes Drug Store (1900), Tiny Tim’s (1901), Caboose (1870s? 1890s?), Iron horse (1913) — all the buildings on the west side of that block except for Bell Book and Candle.  On east side of that block, Cross Brothers, Shear Power, and possibly McCardle Insurance (under the permastone).  On the east side of the block farther south Fin and Feather and Chopper’s house (1858) and storefront (1871).

Historic Downtown Business District north of Rt. 54, including the old Hanover National Bank Building (1919) and the Ashland Train Station (1923). Even Homemades’ building itself was built as the USPO and Barnes Drug Store before the turn of the 20th century.  It has been modified a lot, so it might not be considered “contributing.”

Residential District South of Rt 54, including S Center St: the homes from the 300 block all the way down to Early Street and the Hendrixson’s house.  Some of those are not “contributing structures” such as the Sutton house, the house next to the Dyers that was so modified that it would no longer qualify, and the little brick cape cod on the east side of the street next to the Paces that was built in the 1950s.  The apartments next to The Center are also outside the district’s timeframe. The map extends also to much of Howard Street, part of Race Course, and part of James Street on the west and parts of Virginia St and Maple St on the east.

Residential District North of Rt 54, including the former residences along the tracks that RMC now owns, some of the other college buildings built between 1900 and 1930, such as Mary Branch and Thomas Branch dorms, Peele Hall, the security building on Caroline, the three brick homes on Caroline, the houses on College up to Louisiana St. The houses on Henry Clay Road from the Martins all the way to a couple of houses past Dewey Street. (there are some, maybe 4 or 5, brick 1 1/2 story homes in that area that are not contributing).


Ashland VA railroad tracks 1918
The Tracks in 1918


If you would like to see our estimate as to the impact of this proposed Third Rail please visit Impact of the Third Rail.