APPENDIX C RESPONSE TO COMMENTS … Appendix C - Summary of non-MOS...organization of the response to comments can be complex. ... Comment Sheet General Support ... Comment Sheet Engineering

APPENDIX C

RESPONSE TO COMMENTS REGARDING THE NON-MOS PROTION OF THE ENVIRONMENTAL ASSESSMENT

(Formerly Appendix W of the September 12, 2008 FONSI)

New Jersey – Pennsylvania Lackawanna Cut-Off Passenger Rail Service Restoration Project Supplemental Environmental Assessment

NJ TRANSIT June 2009 1

Appendix W

Summary of Comments and Responses to Comments Regarding the Non-MOS portion of the

New Jersey – Pennsylvania Lackawanna Cut-Off Passenger Rail Service Restoration Environmental Assessment



The following section presents the comments regarding the non-MOS portion of the project, as well as general comments received during the Environmental Assessment’s public comment period and the responses to these comments. Comments related specifically to the MOS portion of the Project were addressed in the MOS FONSI issued September 2008, and have not been included in this document, which addresses only the non-MOS portion of the Project (the portion between Andover, NJ and Scranton, PA). Due to the inter-related nature of an environmental document, the categorization of comments and organization of the response to comments can be complex. It is often the case that one issue may apply to multiple subject areas of study. In addition, correspondence received during the public comment period often addresses more than one issue of concern. For the purpose of organization, it is important to relate each comment back to the individual, organization, or resource agency that provided it, and it is also important to present together all comments on a particular issue so that the responses to the remarks address the full scope of the concern. To accomplish this, an index has been provided to associate each comment with the party who provided it. Each piece of correspondence is given an identification number, which is repeated, along with the commenter’s name or agency, in the response to comments section. In the instances where one piece of correspondence contains only one issue, that issue is identified with a number identifier, even if the issue applies to more than one subject area. For example, a letter from Joe Smith containing only one comment about railroad horn noise would be identified as “Smith (1)” and would be addressed in both the noise and safety sections of the response portion of this chapter. Conversely, if Sue Jones’ letter presented three unrelated issues about cost, traffic congestion, and habitat protection, these comments would be identified as “Jones(2A), Jones(2B), and Jones(2C),” respectively. The number refers to the order in which the comments were received and logged. The letters identify the order of the issues as raised in each correspondence. See the example index below. Example: ID# Date Name Affiliation Comment Form Subject Area Comment ID 1 7/10/2008 Joe Smith Resident Noise Smith(1)

Letter Safety Smith(1)

2 7/11/2008 Sue Jones Resident Cost Jones (2A) Traffic Jones (2B)

Letter

Habitat Jones (2C) The full text of the comment letters are provided at the end of this section. Each individual comment within the comment letters are highlighted and identified with their unique identification code to facilitate the association between the response section and the comments as provided. The responses address only comments pertaining to issues with the EA text or EA development process. General remarks expressing support or disapproval, but not containing issues warranting additional explanation, are discussed immediately below.



Table 1 Summary of Comments

Correspondence ID #

Date Name Affiliation Comment Form Area of Concern Comment ID

1 7/10/2008 Susan Zellman Freeholder, Sussex County & Chairman, NJTPA

Spoken comments at meeting and Letter

General Support Zellman(1)

2 7/10/2008 John DiMaio Warren County Freeholder, Second Vice Chair, NJTPA, Chairman, Planning and Economic Development Committee

Letter General Support DeMaio(2)

3 7/10/2008 Rodney P. Frelinghuysen

U.S. Congressman Letter General Support Frelinghuysen(3)

4 7/10/2008 Eric Snyder Resident-Newton, NJ Open House Comment Sheet

General Support Snyder(4)

5 7/10/2008 Gail Phoebus Mayor of Andover Twp, NJ Open House Comment Sheet

General Support Phoebus(5)

6 7/10/2008 Norbert G. Hornstein

Resident-Denville, NJ Open House Comment Sheet

Rail Operations Hornstein(6)

7 7/10/2008 Paul R. Hart Resident-Scranton, PA Open House Comment Sheet

General Support Hart(7)

8 7/10/2008 Paul Buckley Resident-Hopatcong, NJ Open House Comment Sheet

Engineering Buckley(8)

9 7/10/2008 Paul Buckley Resident-Hopatcong, NJ Open House Comment Sheet

Cost Buckley(9)

10 7/10/2008 Margaret McGarrity

Resident-Andover, NJ Open House Comment Sheet

• Cost • Air Quality

• McGarrity(10A) • McGarrity(10B)

11 7/10/2008 James & Judith Crawford

Resident-Blairstown, NJ Open House Comment Sheet

• Noise • Ecology

• Crawford(11A) • Crawford(11B)

12 7/10/2008 Don Dorflinger Resident-Blairstown, NJ Open House Comment Sheet

General Support Dorflinger(12)

13 7/10/2008 John Hastie Resident-Sparta, NJ Open House Comment Sheet

General Support Hastie(13)

14 7/10/2008 John Reed Resident-Lafayette, NJ Open House Comment Sheet

General Support Reed(14)

15 7/10/2008 Glenn Habrial Resident-Blairstown, NJ Open House Comment Sheet

General Support Habrial(15)



Table 1 (continued) Correspondence

ID # Date Name Affiliation Comment Form Area of Concern Comment ID

16 7/10/2008 Ann Miller Resident-Phillipsburg, NJ Open House Comment Sheet

General Support Miller(16)

17 7/10/2008 Keith Smollin Resident-Maywood, NJ Open House Comment Sheet

General Support Smollin(17)

18 7/10/2008 Kevin & Debra McCarthy

Resident-Andover, NJ Open House Comment Sheet

• Noise • Freight • Rail Operations

• McCarthy(18A) • McCarthy(18B) • McCarthy(18C)

19 7/3/2008 John Nordell Jr. Resident-Old Forge, PA Email Not an EA comment Nordell(19)

20 7/3/2008 Mike Hessmiller Email General Support Hessmiller(20)

21 7/7/2008 Kermit Koch Resident-Waretown, NJ Email General Support Koch(21)

22 7/8/2008 Shawn A. Payne Resident-Poconos, PA Email General Support Payne(22)

23 7/10/2008 Ron Troy Resident-Northport, NY Email General Support Troy(23)

24 7/10/2008 John Bodner Resident-Andover, NJ Email General Support Bodner(24)

25 7/11/2008 Timothy W. Apgar

Resident, Newton, NJ Email General Support Apgar(25)

26 7/13/2008 Wayne Gotsch Email General Support

Gotsch(26)

27 7/15/2008 Jim Finan Resident-Roaring Brook, PA Email General Support Finan(27)

28 7/10/2008 James Crawford Stenographer Comment

Noise Crawford(28)

29 7/10/2008 Keith Smollin Stenographer Comment

General Support Smollin(29)

30 7/10/2008 Peter Palmer Freeholder, Somerset County, NJ

Stenographer Comment

General Support Palmer(30)

31 7/10/2008 James Crawford Stenographer Comment

Amendment to Comment 28 • Noise

Crawford(31)





32 7/10/2008 Patrick Reilly United Transportation Union Stenographer Comment

General Support Reilly(32)

33 7/15/2008 Rosalie Murray Resident-Blairstown, NJ Stenographer Comment

• General Support • Rail Operations

• Murray(33A) • Murray(33B)

34 7/15/2008 Dominic Keating Vice Chairman of the Pennsylvania Northeast Regional Rail Authority

Stenographer Comment

General Support Keating,D(34)

35 7/15/2008 Kathleen Keating

Resident-Dunmore, PA Stenographer Comment

General Support Keating,K(35)

36 7/15/2008 Joseph Cimini Stenographer Comment

General Support Cimini(36)

37 7/15/2008 Thomas Shore Stenographer Comment

General Support Shore(37)

38 7/15/2008 Michael Bender Resident-Stanhope, NJ Open House Comment Sheet

• Data Standards • Data Standards

• Bender(38A) • Bender(38B)

39 7/15/2008 Ronald Gatti Resident-Blakeslee, PA Open House Comment Sheet

Stations Gatti(39)

40 1/17/2007 Arlen Specter & Bob Casey

U.S. Senators from Pennsylvania

Statement of Support

General Support Specter/Casey(40)

41 7/15/2008 James Phillips Resident-East Stroudsburg, PA

Open House Comment Sheet

Support- Noted Revisions Made to EA

Phillips(41)

42 7/15/2008 Tim Carbone Resident-Shawnee-on-Delaware, PA


General Support Carbone,T(42)

43 7/15/2008 Dale Welsch Resident-Stroudsburg, PA Open House Comment Sheet

General Support Welsch(43)

44 7/16/2008 Savitri Pancham Resident-East Stroudsburg, PA

Email General Support Pancham(44)

45 7/18/2008 Norman H. Ressler

Resident-Lake Hopatcong Email General Support Ressler(45)

46 7/20/2008 Mitch Sullivan Resident-Florence, NJ Email General Support Sullivan(46)

47 7/19/2008 Nancy Michael Shuikaitis

Former Monroe Co. Comm./ Former Chairman of Railroad Task Force

Email General Support Shuikaitis(47)





48 7/22/2008 Martha Carbone Resident - Shawnee On Delaware, PA

Email • General Support

• Ecology

• Carbone,M(48A) • Carbone,M(48B)

49 7/29/2008 David Dech Planning Director, Warren County

Email Technical Error in EA

Dech(49)

50 7/29/2008 Jeff Tittel Director, New Jersey Sierra Club

Email • Development • Process • Air Quality • Data Standards • Process • Water Quality • Freight • Rail Operations

• Sierra Club, NJ Chapter(50A), (50D), (50H), (50K), (50L)

• Sierra Club, NJ Chapter(50B) • Sierra Club, NJ Chapter(50C) • Sierra Club, NJ Chapter(50E) • Sierra Club, NJ Chapter(50F) • Sierra Club, NJ Chapter(50G) • Sierra Club, NJ Chapter(50I) • Sierra Club, NJ Chapter (50J)

51 7/30/2008 Kyle Wiswall/ Zoe Baldwin

Staff Attorney/NJ Coordinator, Tri-State Transportation Campaign

Email • Traffic • Rail Operations • Development • Process • Traffic

• Tri-State(51A) • Tri-State(51B) • Tri-State(51C), (51F) • Tri-State(51D) • Tri-State(51F)

52 7/30/2008 Grace Musumeci Chief, Environmental Review, US Environmental Protection Administration – Region 2

Letter • Air Quality • Air Quality • Process

• EPA(52A) • EPA(52B) • EPA(52C)

53 7/10/2008 Betty-Jane Lindsay

Resident-Harwick, NJ Open House Comment Sheet

• Development • Freight

• Lindsay(53A) • Lindsay(53B)

54 7/15/2008 Jack Wilson Resident-Stanhope, NJ Open House Comment Sheet

• Rail Operations • Ecology

• Wilson(54A) • Wilson(54B)

55 7/4/2008 Anthony Davis Resident-Pike County, PA Email • Rail Operations • Davis(55) 56 7/11/2008 Miguel Ortiz Resident-Poconos, PA Email • Cost

• Additional Infrastructure

• Ortiz(56A) • Ortiz (56B)





57 7/10/2008 Robert Simpson Stenographer Comment

• Rail Operations • Rail Operations

• Simpson(57A) • Simpson(57B)

58 7/15/2008 Chuck Negron Resident-East Stroudsburg, PA


• Rail Operations • Negron(58)

59 7/15/2008 Charles Negron Resident-East Stroudsburg, PA


• Traffic • Stations

• Negron(59A) • Negron(59B)

60 7/16/2008 Nicole Mehta McGalla

Resident-Pocono Pines, PA Email • Rail Operations • Rail Operations

• McGalla(60A) • McGalla(60B)

61 7/29/2008 Frank Whalen Resident-Tobyhanna Email • Process • Ecology • Traffic • Cost

• Whalen(61A) • Whalen(61B) • Whalen(61C) • Whalen(61D)

62 7/28/2008 Linda Melvin Transportation Chair, NE PA Group, Pennsylvania Chapter Sierra Club

Letter • Process • Development • Process • Data Standards • Development • Process • Cost • Development

• Sierra Club, PA Chapter(62A) • Sierra Club, PA Chapter(62B),

(62C), (62G), (62J), (62K), (62L)

• Sierra Club, PA Chapter(62D) • Sierra Club, PA Chapter(62E) • Sierra Club, PA Chapter(62F) • Sierra Club, PA Chapter(62H) • Sierra Club, PA Chapter(62I),

(62N) • Sierra Club, PA Chapter(62M)

63 9/30/2008 Kenneth Koschek

New Jersey Department of Environmental Protection

Letter • Noise • Noise • Construction • Air Quality

• NJDEP(63A) • NJDEP(63B) • NJDEP(63C) • NJDEP(63D)

64 10/1/2008 Willie Taylor U.S. Department of the Interior

Letter • Historic • Ecology • Ecology • Ecology • Ecology

• USDOI(64A) • USDOI(64B) • USDOI(64C) • USDOI(64D) • USDOI(64E)



Comments Expressing Support, Technical Revisions, or Non-Applicable Remarks The purpose of the response to comments chapter is to address matters of concern raised by the reviewing public and demonstrate how the EA addresses these concerns. The sections following the Table of Contents provide responses to comments addressing the technical content of the EA, such as inquiries regarding historic resources, air quality, and ecology. In addition to these comments, for which a technical response is required, the project team also received a variety of comments that were not pertinent to the content of the EA. All comments received during the comment period must be logged, but only those comments that can be answered by reference to the EA or the environmental process are addressed. Comments that do not require a technical response are described below. General Comments Expressing Support During the public comment period, 64 individuals or interest groups provided comments on the EA related to the non-MOS portion or the Project. Of these 64 individuals, 29 expressed unconditional support for the Project, citing a variety of quality of life issues that would be improved through the implementation of the Lackawanna Cut-Off Project. Supportive comments include: Zellman(1), Frelinghuysen(3), Snyder(4), Phoebus(5), Hart(7), Reed(14), Habrial(15), Miller(16), Smollin(17)(29), Hessmiller(20), Payne(22), Troy(23), Bodner(24), Apgar(25), Gotsch(26), Finan(27), Palmer(30), Keating,D(34), Keating,K(35), Cimini(36), Shore(37), Specter/Casey(40), Phillips(41), Carbone,T(42), Welsch(43), Pancham(44), Ressler(45), Sullivan(46), Shuikaitis(47) Additional comments expressed support for the Project but also expressed a desire for the Project to extend beyond the MOS phase and connect through to Warren County and to Pennsylvania as quickly as possible. These remarks include: DiMaio(2), Dorflinger(12), Hastie(13), Koch(21), Reilly(32), Murray(33A) One other comment expressed support for the Project but also asked that natural resources and habitat areas be respected (Carbone,M(48A)). The habitat preservation aspect of this remark is addressed in the “Ecology” section of the response to comments. Technical Revisions One comment noted that the EA identified County Route 521 roadway and bridge improvements as a planned project, although it is now complete (Dech(49)). This remark does not affect the content of the EA and is not addressed further. Another comment noted that the EA was modified between the previous draft and the July 2008 version to address additional issues raised in the last public comment round (Phillips(41)). This comment did not require further response. Non-Applicable Remarks One comment was submitted to inform the project management team that the individual will not attend further public outreach meetings, as the Project has been ongoing for many years without resolution (Nordell(19)). This remark does not affect the content of the EA and is not addressed further.



Comments by Subject Area The remaining comments have been sorted by subject area. The following table of comments identifies the starting page of each subject area. Table of Contents

Additional Infrastructure.................................................................................................................... 10 Air Quality ......................................................................................................................................... 10 Construction ....................................................................................................................................... 11 Cost .................................................................................................................................................... 12 Data Standards and Statistical Basis .................................................................................................. 13 Development ...................................................................................................................................... 14 Ecology and Habitats ......................................................................................................................... 16 Engineering ........................................................................................................................................ 19 Environmental Assessment Process ................................................................................................... 19 Freight ................................................................................................................................................ 23 Historic............................................................................................................................................... 24 Noise .................................................................................................................................................. 24 Rail Operations .................................................................................................................................. 26 Stations............................................................................................................................................... 28 Traffic................................................................................................................................................. 28 Water Quality ..................................................................................................................................... 29



Additional Infrastructure

Comment 1: Has anyone looked at the alternative rail service recommended by Harvard Graduate School of Design (which makes use of the I-80/380 ROW)? Ortiz(56B) Response 1: A review of the submitted materials describing the alternate proposal concluded that the I-80/380 alignment has physical constraints, including varied grades, right-of-way width, and overhead bridges that preclude consideration as a cost effective alignment option for commuter rail. Conversely, the proposed alignment in Pennsylvania is an existing rail right-of-way currently in use and designed to accommodate rail passenger service.

Air Quality Comment 2: The statistics on which the purported need for the project is based are antiquated… and they do not address the broad issues of carbon footprint and global warming. McGarrity(10B) Response 2: The air quality mesoscale analysis described in Section 3.8 of the EA, Air Quality, identifies the net effects of the project on air quality emissions. Although not specifically addressing the impacts to global warming, it does compare the reduction in vehicle miles traveled of automobiles to the increase in train miles to determine the net change in pollutants identified by the USEPA as being of national concern. As noted in the table the project would result in a reduction of hydrocarbons and carbon monoxide, and a slight increase in particulate matter and nitrogen oxides. As described in Section 3.8.4 “measures will be implemented during construction and operation to reduce particulate matter and NOx emissions such as the following: implementing idle reduction technology at the Scranton yard; options to purchase new locomotives that meet or exceed USEPA’s emission standards; retrofit and/or rebuild of older locomotives to achieve a better air quality rating; repowering equipment with generator set/hybrid technology; and, use of cleaner diesel fuel or alternative fuel.” Comment 3: The EA does not mention impacts on air quality from diesel locomotives, people driving to park-and-rides, or from secondary development. Sierra Club, NJ Chapter(50C) Response 3: Diesel soot, which is defined as a black substance consisting chiefly of carbon particles formed by the incomplete combustion of burning matter, is discharged from the train primarily while it warms up in the rail yard. The rail yard is thus the primary source of concern for diesel pollution, and would demonstrate the highest pollutant potential. To analyze this worst-case, a stationary source analysis was prepared to evaluate the impacts the project would have at the Scranton Yard. The National Ambient Air Quality Standards (NAAQS) for each pollutant are 35 ppm for one-hour CO, 9 ppm for eight-hour CO, and 150 µg/m3 for PM10. Given that the worst-case emissions would not cause an impact, the emissions associated with travel along the alignment would also not cause an impact to neighboring residents of the alignment. Additionally, Section 3.8.3 of the EA discusses the regional air quality analysis performed to assess the effects of commuters driving to and idling at stations, the idling of trains at the yard, the reduction in VMT caused by commuters using the train, and the increase in train VMT. The analysis revealed that the project



would result in a reduction of hydrocarbons and carbon monoxide, and a slight increase in particulate matter and nitrogen oxides. Comment 4: We recommend NJ TRANSIT record in its project findings statement the latest information from NJTPA, as the NJTPA Board of Trustees is scheduled to adopt the FY2009-2012 TIP on July 29, 2008. EPA(52A) Response 4: The latest information from NJTPA regarding the FY2009-2012 TIP is included in the project findings statement (the FONSI). Comment 5: The portion of the project in Morris County should be evaluated to determine if there is a need for a PM2.5 hot-spot analysis. EPA(52B) Response 5: The portion of the project in Morris County was evaluated for a hot-spot analysis in the Draft EA that NJ TRANSIT published in December 2007. The findings of the evaluation concluded that a hot-spot analysis was not required. Since that date, Morris County has been delisted as being in a nonattainment area for PM2.5. Thus the hot-spot analysis evaluation was removed from the revised EA. Comment 6: Impacts from diesel vehicles need to be examined on a local scale, where the health impacts can be considerable. NJDEP(63D) Response 6: A local level air quality assessment was conducted to determine whether diesel exhaust combined with idling cars at stations and grade crossings would result in an adverse impact to local air quality. The investigation determined that the project would not cause or contribute to exceedances of the National Ambient Air Quality Standards. Although no impact was found, NJ TRANSIT will implement procedures to maintain minimal impacts on air quality, particularly in regard to NOx and particulate matter emissions. These procedures will include:

• Implementing idle reduction practices at the Scranton yard; • Options to purchase new locomotives that meet or exceed USEPA’s emission standards; • Retrofit and/or rebuild of older locomotives to achieve a better air quality rating; • Repowering equipment with generator set/hybrid technology; and, • Use of cleaner diesel fuel or alternative fuel.

Construction

Comment 7: Temporary sound barriers should be installed along any active construction areas in close proximity to residents. …Residents within 200 feet of any proposed construction sites should be notified in advance of the start and finish times and the potential for excessive noise when applicable. …Construction hours should be curfewed during the evening and early morning hours when near existing residential developments. …All motorized equipment used during construction should be equipped with factory-installed mufflers. … The Air Quality Program recommends the use of retrofits on construction equipment needed to complete the project… Retrofits for construction vehicles should be verified by either the U.S. Environmental Protection Agency or the California Air Resources Board. NJDEP(63C)



Response 7: The EA describes several measures to reduce disruption to the surrounding communities during the construction phase of project development. Impacts will be mitigated using Best Management Practices, which includes the measures recommended in Comment 63C. Ongoing coordination with the affected municipalities, NJDOT, PennDOT, and DLRC will ensure that construction plans are developed in such a way as to minimize construction-related noise and air-quality impacts. Plans will be revisited and modified.

Cost Comment 8: Should overruns be encountered … how will additional funding be secured? Buckley(9) Response 8: A line item for contingencies is included in the capital cost estimate to cover unexpected expenses. Comment 9: The costs versus ridership clearly illustrate the wastefulness of both the full project and the route to Andover. McGarrity(10A) It is not economically or environmentally prudent to restore passenger rail service along this rail line. Whalen(61D) Response 9: Consistent with FTA procedure, The Northwest New Jersey-Northeast Pennsylvania Major Investment Study, dated December 2000, assessed the cost effectiveness, including capital cost and operating and maintenance, of the short-listed alternatives, which included the bus alternative and the rail alternative. The MIS makes the following conclusion in reference to the rail alternative: “Given the level of population and economic activity within the study area, the project is an excellent candidate for transportation investment in the states of Pennsylvania and New Jersey. The use of federal aid for the project within the guidelines of TEA-21 is consistent with federal policies encouraging a balanced, multimodal approach to transportation investments.” The evaluation in the EA is limited to the identification of environmental impacts and mitigation measures that would occur as a result of the Project. Comment 10: Has a cost analysis been done in 2008? Ortiz(56A) Response 10: A cost analysis has not been done for the year 2008, the latest cost analysis for the full Build Alternative was performed in 2006 and is described in Chapter 2 of the EA. Comment 11: The Commonwealth and all counties served by the train should thoroughly repair all existing bridges before FTA funds this train project. This should be a condition of obtaining funding for the train. (Sierra Club, PA Chapter, 62I) The two states who will operate this train must devise a reasonable plan to pay to operate and maintain it and show that they can continue to maintain the existing transportation network before taking on the obligation of the train project. We cannot afford to build the train and then let it lapse into decay because the states are not committed to maintaining it. Taxpayers have a right to know the costs and how these



costs will be funded throughout the lifetime of the train. The plan must be spelled out and in place before FTA agrees to fund the train so that neither state can evade its responsibility and so that FTA as well as taxpayers can evaluate the plan. We want to make sure that adding this responsibility does not detract from our ability to manage the rest of our transportation system. (Sierra Club, PA Chapter, 62N) Response 11: The Lackawanna Project was developed to address a broad range of goals and objectives in a combined PA and NJ study area, as explained in Chapter 1 of the EA. The EA does not make judgments on the relative merits of the wide range of projects under consideration throughout the region, including bridge repair projects unaffiliated with the Lackawanna Cut-Off. While there is value in a comprehensive perspective, and it is true that all facets of transportation and commerce are to some degree inter-related, there are reasonable and practical limits on the extent to which the effects of the larger region can be tied to a discreet project. The purpose of the EA is to disclose the potential for impacts of this specific project, which seeks to improve mobility along the I-80 corridor by providing transportation alternatives. Implementation of the Project will necessitate the identification of funds for operation and maintenance. Specifically, a financial arrangement will be necessary between New Jersey and Pennsylvania that will identify how costs will be shared that are not covered by revenues from passenger fares and any other revenues that can be identified. NJ TRANSIT operates rail service in Rockland and Orange counties in the State of New York under an agreement with the Metro-North Railroad. That agreement provides an example that can be utilized in defining an agreement between New Jersey and Pennsylvania for the future extension of rail service on the non-MOS portion of this project.

Data Standards and Statistical Basis Comment 12: The Cutoff services an area in the “Highlands” which has virtually shut down all construction & growth, so no future growth will happen. Bender(38B) The EA anticipates the same population growth trends and household growth trends, whether or not the Lackawanna Cutoff [sic] is constructed. Sierra Club, NJ Chapter(50E) An analysis of the changes in population should be included in the study. (Sierra Club, PA Chapter, 62E) Response 12: As described in Section 3.1 of the EA, Land Use, Zoning and Consistency with Local Plans, project-induced development will not occur in the vicinity of the proposed station sites. The proposed service is being offered as an alternative commuting method for those residents that are already located near the stations and to address improved access and projected growth. Predicted growth would occur independent of the proposed Project. Comment 13: Busses [sic] are handling all needs presently and economically. Bus takes 70 minutes to NYC. Bender(38A) Response 13: As described in Section 1 of the EA, Purpose and Need, bus service is currently a major mode of travel for the region’s commuters. Martz has continually added additional buses to their fleet and expanded their service plan to accommodate the continual growth in riders. However, these buses must use Interstate 80 as well as other approaches into Manhattan that are congested in many places. Additionally, the Exclusive Bus Lane (XBL) on I-495 feeding the Lincoln Tunnel in the AM peak period is currently near or at capacity with limited room for growth of future demand.



Development

Comment 14: The current EA fails to look at impacts to land use and secondary growth from the rail line, claiming that there will be no land use impacts because the line meets local zoning…. We believe that its real intention is to promote sprawl and overdevelopment in environmentally sensitive and rural areas… it will …encourage more traffic because of the development and the need by companies to service the expanding populations in Sussex Counties and the Poconos. Sierra Club, NJ Chapter(50A), (50D), (50H) The EA does not make a comparative projection of anticipated increases in population, households and motor vehicle trips if the Lackawanna Cutoff is constructed versus if the Lackawanna Cutoff is not constructed. Sierra Club, NJ Chapter (50K) In addition, there is every indication that a commuter rail link would promote more development in the Pocono Mountains. Sierra Club, NJ Chapter (50L) The document does not take into account development pressures in the area, which were voiced in the concerns of many local residents in the comments portion of the document. Tri-State(51C) Development patterns and construction will result in the environmental degradation of the area’s watershed. The EA did not evaluate the potential detriment to larger swathes of wetlands due to increased runoff pollution from secondary growth. The direct impacts of rail are comparatively negligible; however, changing development patters will negatively impact the sensitive communities through which the project runs. Tri-State(51F) The Study should also analyze the indirect effects and their significance. (Sierra Club, PA Chapter, 62B) The area of study in this present EA does not represent the full area of concern nor does it amply reflect the true nature of secondary and cumulative impacts foreseeable with the implementation of this project. (Sierra Club, PA Chapter, 62C) We view sprawl as the most significant environmental hazard faced in the planned service area. To ignore it is to deny the intent of NEPA. Therefore, an EIS should be conducted to fully examine this environmental impact. (Sierra Club, PA Chapter, 62G) The EA reports that there will be positive economic impacts from the new train. … The cost of maintaining the train and caring for the road network once the “economic” development occurs should be projected in an EIS. We citizens should know how we will be asked to pay for it. This secondary impact has not been addressed in the current EA. (Sierra Club, PA Chapter, 62J) Adopted transit friendly land use plans ought to be a condition met before funding is granted. (Sierra Club, PA Chapter, 62K) It is our belief that this project will promote population migration away from employment centers. To offset this shift, the project must include incentives for municipalities to manage the shift so that the migration does not unduly or adversely affect the quality of life and environment in the regions served. (Sierra Club, PA Chapter, 62L)



Response 14: Sections 3.1, Land Use, Zoning and Consistency with Local Plans, and 3.20, Cumulative Effects and Indirect Impacts, evaluated the Project’s potential impacts upon land use and development within the corridor and region. As noted within those sections of the EA, land use and zoning authority is controlled at the local municipal level. The NJ State Municipal Land Use Law NJ 40:55D-1 et.seq. clearly legislates that Comprehensive Master Planning and Zoning Regulations are developed and enforced by local municipalities. Development in this portion of New Jersey is further guided by the Highlands Planning Act. Warren and Sussex Counties experienced growth rates of 12% and 10%, respectively between 1990 and 2000. This growth is expected to continue, with NJTPA forecasting a 30% and 32% growth by 2030, respectively for Warren Sussex Counties, without the rail project in place. The reported and projected growth rates for these counties are among the highest rates in the State, along with those of Monmouth and Ocean Counties. Similarly for Pennsylvania, although Carbon and Lackawanna Counties experienced minimal change in population between 1990 and 2000, with similar changes expected between 2000 and 2030, the counties of Monroe, Pike and Wayne experienced increases of 20 to 65% between 1990 and 2000, with their future change expected to range between 10 and 101% over the next 30 years. Most of these counties have limited rail service yet remain as the fastest growing areas within the State. Conversely there are a number of other factors that contribute to a strong real estate market including the provision of infrastructure beyond transportation, for example, the availability of sanitary sewers and potable water systems. The EA evaluated the compatibility of the proposed action with the long range development plans of the various counties and municipalities within the corridor and concluded that the proposed passenger rail line is consistent with those locally developed plans. As described in Section 3.1, project-induced development will not occur. Predicted growth would occur independent of the proposed project; however it is possible that new growth will be allocated to areas closer to proposed stations. Comment 15: Congestion mitigation on Route 80 is not directly listed as a primary purpose for the project, it is referenced throughout the document yet never analyzed. Tri-State(51A) Response 15: The EA does not include an evaluation of the potential traffic reductions on Interstate Route 80 since this is beyond the scope of the traffic analysis performed under NEPA. The purpose of the Project is in part to provide an alternative to Route 80 for travelers within the corridor. Based on the socioeconomic and transportation trends and projections, previous feasibility studies, and results of the Project scoping process activities, it was determined that the major transportation issues that need to be addressed include:

Weak links between activity centers and attractions; Poor accessibility to New Jersey and New York City work destinations; Underutilized transportation right-of-way; Disruption of communities and environment from transportation improvements; Lack of corridor mobility; Uncoordinated modal network of private and public transportation services that are segregated by state

boundaries rather than market boundaries; and, Untapped economic development potential in the region.

Further discussion of these Project needs can be found starting in Section 1 of the EA, Purpose and Need.



The Major Investment Study (MIS) completed in 2000 addressed the traffic situation within the region including the Route 80 corridor. The travel demand forecasting effort calculated the reduction in vehicle miles traveled (VMT) resulting from the project (see Section 3.8 of the EA, Air Quality). Comment 16: People who oppose the project are concerned about people moving out to Warren County. Lindsay(53A) Response 16: The proposed service is being offered as an alternative commuting method for those residents that are already located near the stations. Warren and Sussex Counties experienced growth rates of 12% and 10%, respectively between 1990 and 2000. This growth is expected to continue, with NJTPA forecasting a 30% and 32% growth by 2030, respectively for Warren and Sussex Counties in the No Build (without the project). Local municipalities have jurisdiction over specific land use development issues. To guide development to cause the least impacts, local municipalities have zoning and master plans. NJ TRANSIT has no control over individual town/municipality land use issues. Comment 17: To ensure that the money invested in this train service is worthwhile, appropriate land use plans and zoning must be in place. Therefore, we believe municipalities throughout the area served by the train should adopt legislation within their municipalities requiring these items before funding is granted. (Sierra Club, PA Chapter, 62M) Response 17: Zoning and master plans of each station community were analyzed and discussed in Section 3.1 of the EA and in Appendix A, Land Use Technical Report. All station communities have local regulatory mechanisms in place to guide development. The project will not cause additional growth over the No-Build growth. Comment 18: We want to know if the train will have an adverse impact on existing businesses in our region. Senator Casey has publicly stated, during his appearance on WYOU News, that the train will make it easier for our local residents to shop, go to the theater and dine in New York City. Will this luxury drain business from our local restaurants, shops and theaters? Will people be commuting to work in New Jersey and New York City shop in New York rather than supporting local establishments? (Sierra Club, PA Chapter, 62F) Response 18: The proposed service is being offered as an alternative commuting method for those residents that are already located near the stations. Residents are currently traveling via bus and car. Local businesses are not anticipated to be affected by this new transit option.

Ecology and Habitats

Comment 19: …we are concerned about wildlife. Crawford(11B) I would only ask that sensitive habitat/species be respected as you go forward. Carbone,M(48B) The diverse wildlife population… in and around Mill Pond #1 will be negatively effected [sic] by the increased auto and train traffic. Whalen(61B)



To avoid adverse affects to the Indiana bat, tree clearing activities should be prohibited between April 1 and September 30. …Provide a construction schedule to the NJFO for review and protection of the Indiana bat, if tree clearing is proposed for railroad track re-building in New Jersey. USDOI(64C) Response 19: Coordination with wildlife resource agencies has been ongoing at both the Federal and State levels since 2004. The EA identifies the potential floral and faunal species that may inhabit areas within the study area. This inventory was compiled through consultation and correspondence with the USFWS New Jersey field office, USFWS Pennsylvania field office, Pennsylvania Department of Conservation and Natural Resources, Pennsylvania Game Commission, Pennsylvania Fish and Boat Commission, and NJDEP Natural Heritage Program. In November, 2008, NJ TRANSIT submitted to FTA a Supplemental Threatened and Endangered Species Assessment for the Project area between Andover and Scranton (the non-MOS), which includes the area in and around Mill Pond. The supplemental analysis was performed by qualified environmental professionals and focused on the suitability of habitat for any of the identified faunal species, and to identify if any of the specified floral species were located within the Project limits. This assessment has been submitted to FTA, posted on NJ TRANSIT’s website and appended hereto. The results of this supplemental analysis for the non-MOS concluded, as a result of the construction or operation of the Project, there are no significant impacts to federal or state-listed threatened or endangered species, or state-listed species of concern. Coordination with wildlife resource agencies has been ongoing at both the Federal and State levels since 2004. In May, 2004 USFWS requested that bog turtle habitat surveys be conducted in areas with emergent and shrub/scrub wetlands along the proposed project route and additionally information regarding potential impacts to the Indiana bat. In August, 2004, USFWS met with NJ TRANSIT and agreed to an appropriate plan for continued consultation. NJ TRANSIT committed in writing (via its September 2, 2004 letter) to future coordination and consultation with the USFWS for the protection of federally listed threatened and endangered species and their habitats. USFWS noted in their November 12, 2004 letter that due to the timing of project planning and development, NJ TRANSIT may perform necessary surveys and studies during the final design and development stages of the proposed project, and that NJ TRANSIT would document this ongoing consultation in the EA. Coordination continued in May, 2007, with the USFWS reiterating their request for a Bog turtle habitat study. A Bog turtle habitat study was performed, as described above, in October, 2008. We are awaiting a Section 7 Consultation Summary from the New Jersey and Pennsylvania offices of the USFWS. It is anticipated that given the study’s findings, “monitoring during construction” could be performed by a qualified bog turtle surveyor, as well as buried double silt fencing. for the duration of project activities in these areas, a recognized, qualified bog turtle surveyor will place the double silt fence and monitor fence conditions every week from March 15 through October 15 and immediately after storm events. For construction activities during the remainder of the year, the surveyor will monitor every two weeks and immediately after storm events. Should a bog turtle be found, the surveyor will immediately contact the USFWS. Additionally, regarding the Indiana bat, April 1st and September 30th west of Andover Station and from April 1 to November 15th east of Andover Station for potential summer roosting areas would be implemented in connection with any tree removal associated with the project. Should tree removal be proposed during the restricted season, further consultation with the USFWS will be required. Comment 20: Clearing the railroad of 100’s of trees will not help the environment and spoiling wetlands will destroy critical habitat for threatened and endangered species. Wilson(54B)



Response 20: The right-of-way under consideration is an existing transportation corridor and as such the majority of it is currently cleared of trees. NJ TRANSIT plans to limit tree removal to only that which is necessary to safely construct and operate the project. The Lackawanna Cut-Off alignment in New Jersey, across the Delaware River and to Slateford Junction, is a previous operating railroad which has not been maintained in recent years. The remaining portion of the alignment in Pennsylvania is an operating freight railroad. The extent of mature vegetation requiring removal is mainly that which has grown along the track bed since operations ceased in the 1970’s. As described in Section 2.2 of the EA, Alternatives for Advancement, all grubbing work (clearing of the under story) will be done so as to minimize impacts. As described above, habitat surveys and surveys for individual threatened and endangered species have been performed for the Project. Restoration of service on the former and current railroad right-of-way under consideration for this Project will not have any unmitigated impact on habitats for threatened and endangered species. Impacts to the 6.4 acres of wetlands that will be impacted by the Project will be mitigated through restoration, creation and/or enhancement of wetlands, as described in Section 3.14 of the EA, Wetlands and Streams. Comment 21: In New Jersey, there are two project areas of concern. The first is in the Andover Ponds area near Benchmark 705, Andover Borough, Sussex County, requiring a Phase 2 survey. The second is in Green Township, Sussex County, from the Pequest River crossing to Turtle Pond. A Phase 2 survey should be conducted to determine the extent of the known bog turtle occurrence in the general area. USDOI(64B) Response 21: Issues raised in the letter received on October 6, 2008 (USDOI 64) were resolved in a teleconference with the Department of Fish and Wildlife Service of the United States Department of the Interior on September 9, 2008. The letter was drafted prior to the teleconference and received subsequent to the resolution of the issues. Please refer to US DOI, Department of Fish and Wildlife letter dated September 12, 2008 in Appendix F, which states “The Service has determined that ‘monitoring during construction’ can be recommended in lieu of Phase II surveys in Areas B, E, and F. We recommend a toed-in (buried) double silt fence to exclude the bog turtle from construction areas. For the duration of project activities in these areas, a recognized, qualified bog turtle surveyor should place the double silt fence and monitor fence conditions every week from March 15 through October 15 and immediately after storm events. For construction activities during the remainder of the year, monitoring should occur every two weeks and immediately after storm events.” A teleconference with the Department of Fish and Wildlife on October 15, 2008 confirmed that the above quoted statement about construction monitoring instead of a Phase II survey is how the Service would like to resolve their concerns about the presence or absence of bog turtles. Comment 22: Contact the New Jersey ENSP to avoid potential adverse impacts to bald eagle foraging habitat. USDOI(64D) Response 22: The Project is not likely to affect the foraging habitat of the bald eagle, as the alignment is already in place and has previously been cleared. Any additional clearing that would be required would be to undergrowth vegetation that would have spread into the right-of-way. Preliminary contact has been made with the New Jersey Endangered and Nongame Species Program (ENSP); NJTRANSIT will continue to work with them during the final design phase to ensure that the project will not impact the bald eagle.



Comment 23: Complete the required wetland delineations and provide the results and the proposed wetland mitigation to the NJFO. USDOI(64E) Response 23: The wetlands in the non-MOS were delineated in October, 2008 and a report was submitted to the New Jersey Field Office (NJFO) of the Department of Fish and Wildlife, as requested. As previously agreed with the NJFO, wetland mitigation will be identified in the final design phase of the Project.

Engineering Comment 24: To what degree have the structures been evaluated, eg stability and integrity? Buckley(8) Response 24: As noted in the EA in Section 2.2.2.4, Infrastructure, a component of the Project planning and EA was to perform a detailed inventory and analysis of the existing infrastructure found throughout the corridor. A full technical report describing the existing conditions and improvements required for passenger rail service implementation has been prepared and is titled Structures and Inventory Analysis Report, prepared by Edwards and Kelcey, Inc. dated August 2003.

Environmental Assessment Process Comment 25: An environmental assessment type of study is not, by its nature, a thorough enough study when considering the number of people and enormous quantity of land and committees that will be affected by the proposed project. (Sierra Club, PA Chapter, 62D) Response 25: This EA has been performed in accordance with the:

• National Environmental Protection Act (NEPA) • Section 4(f) of the Department of Transportation Act • Section 106 of the National Historic Preservation Act • Land and Water Conservation Fund • The Federal Clean Water Act, • The Federal Clean Air Act • The Rivers and Harbors Act • The Federal Endangered Species Act • The Executive Orders pertaining to the protection of wetlands, flood plain management, and

environmental justice. The proper level of technical analysis has been performed to identify any potential environmental impacts from the Project and appropriate mitigation has been identified and committed for those identified impacts. The analyses undertaken have been performed in accordance with the prescribed methodologies adopted by many federal and state agencies, including the Federal Transit Administration (FTA), the Army Corps of Engineers (USACE), and the State Historic Preservation Offices (SHPO) of New Jersey and Pennsylvania, U.S. Fish and Wildlife Service (USFWS), New Jersey Department of Environment Protection (NJ DEP), Pennsylvania Department of Environmental Protection (PA DEP) Pennsylvania Department of Conservation and Natural Resources, Pennsylvania Game Commission, Pennsylvania Fish and Boat



Commission. The USACE has determined the level of analysis to be sufficient in determining potential impacts upon wetlands and Waters of the United States. In addition, a Programmatic Agreement addressing cultural resources within the corridor has been executed with the State SHPO, NJTRANSIT and FTA. The EA has thoroughly analyzed the effects of the Project on the natural and built environments and has committed mitigation measures to ensure that the Project will not have significant environmental impacts. Comment 26: The EA states that this assessment is only preliminary, and they will conduct a more thorough investigation after the project is approved. Tri-State(51D) We recommend that [a wetlands delineation and a threatened and endangered species habitat field survey] be completed prior to making a findings statement regarding project impacts. EPA(52C) The EA fails to look at impacts to wetlands and endangered species habitat. Sierra Club, NJ Chapter(50B) Response 26: After considering the public and agency comments and further consultation with Federal resource agencies, it was determined that wetland delineation and a threatened and endangered species field surveys for the Project would need to be conducted. Both were completed and the results are included in the Supplemental EA. Wetland impacts, which will result from the construction of this Project, will be mitigated pursuant to the New Jersey Freshwater Wetlands Protection Act (N.J.S.A. 13:9B), administered by the NJDEP, the Pennsylvania State Chapter 105 under the Dam Safety and Waterway Management Rules and Regulations, administered by the PADEP and the Federal Clean Water Act, Section 404 and the Rivers and Harbors Act, Section 10 administered by the USACE and USEPA. Compensatory mitigation will be undertaken to offset the loss of wetland functions resulting from the non-MOS. These compensatory measures may include restoration, creation and/or enhancement of wetlands. Coordination with wildlife resource agencies has been ongoing at both the Federal and State levels since 2004. The EA identifies the potential floral and faunal species that may inhabit areas within the study area. This inventory was compiled through consultation and correspondence with the USFWS New Jersey field office, USFWS Pennsylvania field office, Pennsylvania Department of Conservation and Natural Resources, Pennsylvania Game Commission, Pennsylvania Fish and Boat Commission, and NJDEP Natural Heritage Program. In November, 2008, NJ TRANSIT submitted to FTA a Supplemental Threatened and Endangered Species Assessment for the portion of the project between Andover and Scranton. The supplemental analysis was performed by qualified environmental professionals and focused on the suitability of habitat for any of the identified faunal species, and to identify if any of the specified floral species were located within the project limits. This assessment has been submitted to FTA, posted on NJ TRANSIT’s website and appended hereto. The results of this supplemental analysis concluded that there are no significant impacts to federal or state-listed threatened or endangered species, or state-listed species of concern, associated with the operation or the construction of the project. Coordination with the USACE, USEPA, and NJDEP has been ongoing since January, 2007. Meetings were held in April, 2007 to discuss the potential impacts to wetlands and to agree on the methodology that would be used to estimate the extent of wetland impacts. Additional coordination meetings and conference calls were held between May and August 2007, with concurrence that wetlands would be delineated and mitigation measures developed during final design. At the later request of USEPA, wetland delineations



were performed for the areas in the non-MOS. In October 2008 the wetland delineation was performed for the non-MOS. This delineation was then forwarded to the USACE, the USEPA, and the USFWS. Coordination with wildlife resource agencies has been ongoing at both the Federal and State levels since 2004. In May, 2004 USFWS requested that bog turtle habitat surveys be conducted in areas with emergent and shrub/scrub wetlands along the proposed project route and additionally information regarding potential impacts to the Indiana bat. In August, 2004, USFWS met with NJ TRANSIT and agreed to an appropriate plan for continued consultation. NJ TRANSIT committed in writing (via its September 2, 2004 letter) to future coordination and consultation with the USFWS for the protection of federally listed threatened and endangered species and their habitats. USFWS noted in their November 12, 2004 letter that due to the timing of project planning and development, NJ TRANSIT may perform necessary surveys and studies during the final design and development stages of the proposed project, and that NJ TRANSIT would document this ongoing consultation in the EA. Coordination continued in May, 2007, with the USFWS reiterating their request for a Bog turtle habitat study. A Bog turtle habitat study was performed in October, 2008. We are awaiting a Section 7 Consultation Summary from the New Jersey and Pennsylvania offices of the USFWS. It is anticipated that given the study’s findings, “monitoring during construction” could be performed by a qualified bog turtle surveyor, as well as buried double silt fencing, The monitoring during construction would involve the following: between March 15 and October 15 the qualified bog turtle surveyor would monitor the fence conditions weekly and immediately after storm events; between October 15 and March 15, monitoring would take place every two weeks and immediately after storm events. Additionally, regarding the Indiana bat, the USFWS recommends prohibiting the removal of trees between April 1 and September 30, to which NJ TRANSIT agreed. Should tree clearing be proposed during the restricted season, further consultation with the USFWS will be required. NJ TRANSIT will continue its communications and consultation with these agencies during project design and implementation. Comment 27: Agencies shall rigorously explore and objectively evaluate all reasonable alternatives. The EA presented to FTA fails in this regard. It also fails to fully address the no action alternative as required by NEPA. In addition to this shortcoming, the study fails to fully explore other mitigation measures that could be employed to relieve traffic on Interstate 80. The EA fails to recognize these mitigation measures such as HOV lanes, public subsidy to existing mass transit, employee/employer incentives for ride sharing programs, etc. (Sierra Club, PA Chapter, 62H) Response 27: As discussed in Section 2.1 of the EA, Alternatives Development and Selection Process, the Lackawanna Cut-Off Right-of-Way Use and Extension Study, completed in 1989 and the Transportation Options in the Pocono Corridor Study, completed in 1995 considered the following alternatives:

• Carpool/vanpool • Bus/high occupancy vehicle (HOV) • Guided bus • Light rail transit • Passenger/commuter rail • Modified/advanced rail • Maglev/monorail • Commuter bus • Multimodal (mix of rail and bus) • Highway



The Morris County Northwest New Jersey-Northeast Pennsylvania Major Investment Study, completed in 2000, further refined a shorter list of alternatives:

• No-Build Alternative • Bus Alternative • Rail Alternative • Multi-Modal Alternative

In August 1999, the findings of the MIS were presented to the Technical Advisory Committee and the public. As a result of these meetings the MIS Rail Alternative was selected as the proposed Build Alternative. In light of the findings of the MIS, the North Jersey Transportation Planning Authority’s (NJTPA) Draft Final Regional Transportation Plan, dated December 2000, included restoration of rail service on the Lackawanna Cut-Off as a key alternative to single occupancy vehicle usage on Interstate 80. Based on these actions, the rail service alternative was analyzed in the EA along with the No Build Alternative. And finally, in 2008, the NJTPA approved the advancement of the Lackawanna Cut-Off project as a railroad use. Comment 28: [The EA] does not look at the relationship between this project and the Highlands Protection Act. Sierra Club, NJ Chapter(50F) Response 28: Sections 1.5, Area Development Pattern Description, 3.1, Land Use, Zoning and Consistency with Local Plans, 3.12, Geology, Soil, and Topology, and 3.20, Cumulative Effects and Indirect Impacts, address the relationship between the project and the August 2004 Highlands Water Protection and Planning Act. Additionally, NJ TRANSIT believes that the proposed Project supports Section II of the bill as a transportation component that provides a plan for “transportation system preservation, includes Federally- mandated projects or programs and recognizes smart growth strategies and principles…” In addition, the proposed Project is also consistent with the exemption for reactivation of rail lines and rail beds as discussed in Section IV of the Act. As described in the Section 1.5.3 of the EA, future development in much of the area to the east of Blairstown will be limited, as the area falls within the Highlands Region, as designated by the Act. Comment 29: There was insufficient time for public input to officials of Coolbaugh Township Pennsylvania after the open house meeting by NJ Transit and the regularly scheduled meetings of the Coolbaugh Township Supervisors. Whalen(61A) Response 29: As required by NEPA, a 30-day comment period was given for the review and comment of the EA, from July 1, 2008 to July 30, 2008. Letters were sent to interested parties notifying them of the EA’s availability and notice was given for the two public meetings. The Coolbaugh Township Supervisor was mailed a CD of the EA for his review and comment. Comment 30: We request that the lead agency comply with the National Environmental Policy Act (NEPA) by conducting and Environmental Impact Statement (EIS) expanding the geographic area in the study scope…Without the wider area and more in-depth study one cannot be reasonably satisfied about the conclusions drawn regarding the secondary impacts of the train. A superficial examination of the



cumulative impacts robs municipalities of the information they require to plan for the train and determine if the train is necessary. (Sierra Club, PA Chapter, 62A) Response 30: According to the CEQ Regulations for Implementing NEPA (40 CFR, Section 1508.9), the purpose of an environmental assessment is to “briefly provide sufficient evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact.” The Lackawanna EA provides sufficient analysis to make the determination that there are no unmitigatable significant impacts. Section 3.20 of the EA, Cumulative Effects and Indirect Impacts, provides a description of the cumulative effects and indirect impacts of the project, including the combined effect of the project with other past, present, and reasonably foreseeable major actions. The analysis was performed in accordance with CEQ’s guidance, Considering Cumulative Effects Under the National Environmental Policy Act. The analysis included projects from a larger geographic area, including Marshalls Creek Bypass in Monroe County, Interstates 80 and 380 Interchange project, as well as NJ TRANSIT’s Access to the Region’s Core project.

Freight Comment 31: …major concern… with DOT changing the route from passenger trains to freight trains carrying garbage. Lindsay(53B) There are no guarantees that this will not evolve to hauling trash at other times. McCarthy(18B) When the line was purchased by New Jersey DOT, it was for freight rail, rather than passenger service. Sierra Club, NJ Chapter(50I) Response 31: The following language is entered here to respond to these comments concerning freight service. It is repeated from a letter sent by former NJ TRANSIT Executive Director George Warrington to the Morris County Freeholder Director on February 17, 2006.

“The Lackawanna Cut-Off project scope being developed by NJ TRANSIT only includes railroad infrastructure for passenger rail service. While there are no absolute guarantees that freight service will never run on the Lackawanna Cut-Off, the prospect of freight service on the line is highly unlikely for a number of reasons. Generally speaking, freight railroads would find it both operationally difficult and cost prohibitive to operate on the Lackawanna Cut-Off Line.

• The line is not well connected to the national freight network and NJ TRANSIT knows of no freight operator interested in this market. Most port-related freight either utilizes the Lehigh Valley Line along I-78 to connect to points south and west, or the West Shore Line in Bergen County to connect to points north and west.

- On the east, the Lackawanna Cut-Off connects with the NJ TRANSIT Morristown

Line. This rail line carries a very high volume of commuter train traffic and has numerous clearance obstacles (bridges and overhead electric catenary system) that would limit the utility of this route for freight service. The Morristown Line does not serve the Port areas of New Jersey



- On the west, the Lackawanna Cut-Off route continues to Scranton, PA. Along the way there is another low clearance tunnel and a significant grade to crest the Pocono Mountains.

• The height limitation on the Morristown Line is 15 feet, 6 inches, while modern double

stack container cars normally used to handle port-related traffic require 20 feet, 2 inches of clearance. Double-stacked container cars cannot fit under our overhead electrical system that provides power to our electrified passenger trains.

• Presently, NJ TRANSIT operates nearly 200 of its own trains on the Morristown Line at

Summit each weekday. Freight train operations would need to be restricted to a very short time window making major freight service operation difficult and expensive.

• The freight companies would need a trackage rights agreement from NJ TRANSIT and

approval from the Surface Transportation Board to operate on the Lackawanna Cut-Off, both of which are complex processes.

• NJ TRANSIT’s lines are limited to handling freight cars weighing up to 263,000 pounds.

Most freight cars today carry up to 286,000 pounds. Consequently, freight railroads prefer routes with no restriction on the operation of the heavier cars.

The facilities and service being planned for the project are intended to accommodate passenger service only. There is no freight service being planned for this project by NJ TRANSIT. NJ TRANSIT does not and cannot operate freight service. Also, the Environmental Assessment document being prepared by NJ TRANSIT for the Federal Transit Administration will not include an evaluation of the impacts related to the operation of freight service on the line.”

Historic

Comment 32: The Department recommends that the Section 4(f) Evaluation for the historic properties be completed as a separate document that will draw heavily upon the Section 106 compliance process that has taken place to date. USDOI(64A) Response 32: Issues raised in the letter received on October 6, 2008 (US DOI 64) were resolved by the National Park Service of the United States Department of the Interior comment. NPS agreed that a separate Section 4(f) Evaluation was not required. The EA does discuss the applicability of Section 4(f) and that there would be no use of parklands. Since a Programmatic Agreement was in place agreeing that there were no adverse affects to historic resources, the September 12, 2008 FONSI should include a statement that the historic resources would have a de minimus impact with regard to Section 4(f). This language was included in the September 12, 2008 FONSI, as necessary, during the course of construction to minimize impact of unforeseen circumstances.

Noise

Comment 33: We would like to see a site map of the RR tracks from Kerrs Corner thru Lanning Rd to Blairstown. And would like to know how this will impact our property which is approximately 300 yards from the present tracks and overpass. We are concerned about… noise. Crawford(11A), (28),(31)



Response 33: The distances at which residences would be moderately or severely impacted by the project are summarized in the EA in Table 3.9-2 on page 114, (which is also provided below for reference). It is important to note that the analysis considered that the majority of the alignment between Lanning Road and the Blairstown Station is located in cut, which leads to a natural buffering between the railroad and the adjacent residents. The geographical area discussed by the Crawford comment is identified as the Western New Jersey (with natural buffering) category. As noted, moderate wayside impacts would occur at distances of 50 feet from the alignment, and severe wayside impacts would occur at 20 feet from the alignment. Near the station, the impact distances would increase to 80 feet for moderate and 30 feet for severe, and where the alignment is at grade as it nears the station, the impact distances would increase to 280 for moderate and 110 feet for severe.

EA Table 3.9-2: Impact Distances for Wayside and Whistle Noise for Residences

Project Moderate Impact Distance (ft) Project Severe Impact Distance (ft) Section Wayside

Alone Near Station Near Grade Crossing

Wayside Alone Near Station Near Grade

Crossing

Western Pennsylvania 90 140 270 25 40 70

Eastern Pennsylvania 110 160 320 25 40 70

Western New Jersey (without natural buffering) 160 280 460 60 110 180

Western New Jersey (with natural buffering) 50 80 130 20 30 50

Eastern New Jersey (without natural buffering) 350 500 900 130 190 380

Eastern New Jersey (with natural buffering) 100 150 270 45 60 100

Source: Edwards and Kelcey, 2006 As shown on the attached noise contour maps there are no residences or habitable buildings located in the area between Lanning Road and the Blairstown Station within the impact contours described above. Comment 34: On July 3, 2007 a new rule was adopted in the State’s Noise Control Regulations… The Rule allows qualified municipalities to regulate noise from railcar coupling and idling locomotives by citing the Federal Regulations under 40 CFR Part 201 and 49 CFR Part 210. NJDEP(63A) Response 34: Except under emergency circumstances, which by their nature are infrequent and unpredictable, the Lackawanna alignment and service plan allows for idling or consist changes only at the Scranton Yard facility and Port Morris Yard. These facilities are located away from sensitive receptors and would be unlikely to trigger the provisions of the new State Noise Control Regulations. The Lackawanna Cut-Off EA noise study examined potential noise impacts to communities along the alignment and identified two types of noise generated by railroad operation: wayside and whistle noise. Mitigation measures to reduce the impact of wayside and whistle noise are included in the EA.



Comment 35: The construction of “Quiet Zones” at some of the highway grade crossings where the required signaling by train horns would have a significant impact on local residents should be considered. NJDEP(63B) Noise abatement is not being fully addressed. McCarthy(18A) Response 35: The EA assessed the potential for noise impacts as a result of the project, and using FTA guidelines, categorized them into moderate and severe impacts. Moderate impacts do not require mitigation, while severe impacts do. All of the severe impacts were caused by warning whistles at grade crossings. To mitigate all of the severe impacts, Quiet Zones were proposed for the following six location in the non-MOS area:

• Stokes Avenue (Gravel Place) in East Stroudsburg, PA; • North Cortland Street in East Stroudsburg, PA; • Burson Street in East Stroudsburg, PA; • East Broad Street in East Stroudsburg, PA; • Analomink Street in East Stroudsburg, PA; and, • Wolf’s Corner Road in Green Township, NJ.

Rail Operations

Comment 36: Will there be express service trains that skip local stations? Will some trains run on the Morristown Line? Hornstein(6) ...scheduling [should] be done so that there would be an express train in to New York City in the morning, at least one… and two or three express trains every day [would be more efficient]. Murray(33B) Has anyone proposed express service from the Pocono Mountain station McGalla(60B) Response 36: The proposed trains to Scranton are extensions of NJ TRANSIT Morris & Essex and Montclair-Boonton Lines trains. The number of stations skipped would vary, depending upon which trains were extended to Scranton. Comment 37: There is no mention of weekend service when demand for recreational activities is greatest, except to state that the MOS will not include service on the weekends. Tri-State(51B) Response 37: As described in Section 2.2 of the EA, Alternatives for Advancement “annual ridership figures were calculated based upon typical weekend and holiday service, and include recreational weekend riders”. The annual operating costs and revenue estimates in the EA were calculated based on the operation of weekend service. Weekend service would be provided with the full build project to Scranton. Comment 38: No impact study done for the additional train traffic between Port Morris and New York City. No noise mitigation or anything for that. Simpson(57B)



Response 38: No impact study was required. From Port Morris to Hoboken/Midtown Manhattan, there will be no project related impacts in any of the analysis areas because there will be no change to NJ TRANSIT rail operations or infrastructure as a result of the Build Alternative, as compared to the No Build Alternative. Comment 39: Train counts are excessive during peak travel, making this even less desirable by local residents. McCarthy(18C) I would hope that when rail service begins out of the Poconos that the schedule would accurately reflect the needs of the Pocono commuters. Davis(55) Response 39: The service schedule is a balance between ridership demand and costs. As noted in Section 2.2 of the EA, Alternatives for Advancement, there will be nine eastbound and nine westbound trains. The first train will leave Scranton at approximately 4:00 AM and the last train will return to Scranton at approximately 1:00 AM. Comment 40: Railroads don’t work for people in rural areas. ...The train stations are to [sic] few and far apart and then there isn’t any other transportation that is affordable to get to work. Wilson(54A) Response 40: As noted in Section 1 of the EA, Purpose and Need, one of the project’s needs is to provide better access from northeastern Pennsylvania and northwestern New Jersey to the employment centers of New Jersey and New York City. Bus service needs throughout northwest New Jersey are currently the subject of a separate NJ TRANSIT study. These efforts will be coordinated to determine future shuttle opportunities. The addition of more train stations would increase travel time with little to no increase in ridership. Parking lots are provided at each of the stations to allow commuters to drive from their homes to the nearest station. Comment 41: How do they expect anybody from Scranton to commute to New York City when it takes three and a half hours? Simpson(57A) Why does it take 2 hours to get to Hoboken from Analomink Station? Shouldn't train be faster? Negron(58) …is there any way to build a higher speed train? McGalla(60A) Response 41: Travel time is a function of many factors, including maximum attainable track speeds, equipment acceleration/deceleration rates for station stops, number of tracks/sidings, and density of train movements on those tracks. The travel time presented is the best attainable time given these considerations. Comment 42: Notably, the proposed Lackawanna Cut-off Project would place commuters originating in Scranton, Pennsylvania in a position of deciding whether to take a one-way train commute that would take three and one-half hours, or an express bus commute that takes two and one-half hours. Accordingly, there is a serious need to consider whether commuters will be willing to give up the usage of express buses and spend an additional ten hours in commutation status each week. Sierra Club(50J)



Response 42: Ridership demand for the Lackawanna Cut-off Project was estimated using the North Jersey Transit Demand Model, as detail in Section 2.2 of the EA, Alternatives for Advancement. This model attempts to assign a decision of what mode travelers would use, which incorporates travel time, parking fees, rail fares, bus schedules, and the 2000 Census Journey to Work data, supplemented by bus survey data for riders to Manhattan. Based upon this model, it is estimated that there would be 40 eastbound daily boardings in Scranton.

Stations Comment 43: The East Stroudsburg Station lacks parking. The Analomink Station is well situated but needs to be built from scratch. Gatti(39) 225 parking spaces [at Analomink] seems light to me. Will expansion be possible? Negron(59B) Response 43: The concept design for the East Stroudsburg station provides for 228 parking spaces along the right-of-way and south of Bridge Street, in accordance with projected demand. It is agreed that the Analomink station is well situated to serve the forecast local demand and will require construction of new facilities, as will several of the other proposed stations. Ridership was estimated using the North Jersey Transit Demand Model, as detail in Section 2.2 of the EA, Alternatives for Advancement. Based upon the ridership demand, parking facilities were identified for each station location, sized to meet the projected demand. Future expansion could be possible at Analomink given that the property is owned by Pennsylvania DOT.

Traffic Comment 44: Under the 2030 build scenario, mitigation conditions still show level of service (LOS) failures surrounding several stations. (Tri-State(51E) Response 44: As discussed in Section 3.7, Transportation, traffic accessing the following station sites would cause impacts at nearby intersections: Tobyhanna, Pocono Mountain, East Stroudsburg, Delaware Water Gap and Blairstown (although the traffic analysis assumes a series of conservative, worst case assumptions, which are not likely to occur). To minimize impacts at these intersections, a combination of signal installation, geometry modifications, and signal timing changes are proposed. Although several intersections surrounding the stations do still show level of service failures, when compared to the No Build Conditions, they are not significantly worse. Comment 45: Will 447/191 (near Analomink Station) be expanded to handle increase in traffic? Negron(59A) Response 45: As noted in Appendix E of the EA, Traffic, due to the relatively low traffic volumes resulting from implementation at this station, 74 in the peak hour, compared with the total volumes 1611 vehicles in the AM peak hour and 2,034 vehicles in the PM peak hour, no increase in delays are anticipated at the 447/191 intersection. Therefore, expansion of 447/191 would not be necessary as part of this project.



Comment 46: The tranquility and quality of life for many residents in the area [of Tobyhanna, PA] will be negatively affected by the increase in traffic. Whalen(61C) Response 46: As discussed in Section 3.7, Transportation, the proposed project, with its mitigation would not cause a significant impact to traffic. Approximately 43 vehicles are estimated to access the Tobyhanna Station for the peak train, which will depart Tobyhanna at 5:22 AM. During the morning peak period, delay on the eastbound approach of PA Route 423 will increase by approximately 60 seconds. During the afternoon peak period, delay on the westbound approach will increase by approximately 10 seconds. With signal timing modifications, delay at both approaches would be reduced to below No Build levels.

Water Quality Comment 47: The secondary impacts from this project will mean more impervious cover and more flooding. Sierra Club, NJ Chapter(50G) Response 47: At present the rail roadbed located within NJ contains the remains of what was an operating railroad abandoned in the mid 1970’s. This rail bed was constructed as all rail roadbeds were, utilizing various infrastructure components including stone ballast as a stabilizing subsurface. While this stone ballast is not completely impervious, as is a paved surface, it does allow only a limited amount of absorption due to the years of natural compaction that have taken place. When the original Lackawanna Cut-Off was constructed in the early 1900’s no stormwater or water quality management measures were put in place. Stormwater from the railroad was directed as overland flow to drainage swales along the right of way and ultimately to downstream receiving waters, i.e. streams, rivers and lakes. Stormwater was not managed or controlled in any manner and in the case of the Lackawanna Cut-Off it remains this way today. The Project calls for the rehabilitation of the former Lackawanna Cut-Off including reestablishing the abandoned railbed to meet current standards. This rehabilitation will consist of removal of the former ballast and subsurface replacing it with a new roadbed including stone ballast. The overall amount of “impervious” surface resulting from the rehabilitation of the railroad will not increase. In addition the project will include stormwater management and water quality provisions as required by NJDEP. Since the project will not result in additional impervious surface coverage for the alignment and will meet all current NJDEP criteria for stormwater management the EA has correctly concluded that there will be no impact to floodplains resulting from railbed rehabilitation. The design for the non-MOS calls for the construction of seven (7) parking lots and associated station platforms, a maintenance-of-way area (MOW) and a yard. The conceptual design plans for the stations, MOW, and yard incorporate stormwater management/water quality basins. This basins will be designed to meet all applicable regulations as required by NJDEP and PADEP. These basins are utilized to accomplish two purposes: (1) stormwater management that is controlling the rate of runoff to ensure that runoff leaving the site is at a rate equivalent to the post construction rate; and (2) for water quality improvements. These systems will result in no project impacts to the floodplains. The design and construction of all project drainage infrastructure fall under the regulatory oversight of the NJDEP and PADEP. The design and construction of the project is regulated under the NJDEP Flood Hazard Control Program. PADEP is currently in the process of drafting stormwater rules. These facilities will be designed and constructed in accordance with all applicable storm water treatment requirements, as noted above and in the EA.



Consequently, there will be no “excess storm water runoff” resulting from the non-MOS. Furthermore, improvements to the Lackawanna Cut-Off railroad drainage features will comply with applicable regulations as enforced by NJDEP and PADEP. The EA has evaluated the potential impacts of the Project on floodplains and has determined that there will be no impacts. The results of the floodplains analysis are found in Section 3.15 of the EA, Floodplains, as well as within Appendix K. Following are the full text of the comment letters. Each individual comment within the comment letters are highlighted and identified with their unique identification code to facilitate the association between the response section and the comments as provided.

Zellman 11

2DiMaio

Frelinghuysen 3

Snyder 4

Phoebus 5

Hornstein 6

Hart 7

Buckley 8

Buckley 9

McGarrity 10

10A

10B

10B

Crawford 11

11A

11A 11B 11A

Dorflinger 12

Hastie 13

Reed 14

Habrial 15

Miller 16

Smollin 17

McCarthy 18

18A

18B

18C

19Dear Mr. Truncellito:

I received in the mail today a letter from New Jersey Transit concerning a report -- issued jointly with the Federal Transit Administration of the U.S. Department of Transportation -- on the "New Jersey - Pennsylvania Lackawanna Cut-Off Passenger Rail Service Restoration Project Environmental Assessment (EA)." Whew! That sure is a bureaucratic mouthful. Luckily, I already knew what it was about. In what now seems like an eternity ago, my wife Marianne and I drove to the Ramada Inn in Delaware Water Gap, Pennsylvania to attend a public hearing on a feasibility study on restoring passenger train service betweeen northeastern Pennsylvania and New York City. The date was August 31, 1999. It was projected that service might be resumed by 2005 or 2006. Nearly five years later, on July 1, 2004, we went to another meeting on the same subject that was held at the Hilton Hotel in Scranton, Pennsylvania. The air was thick with enthusiasm and many political bigwigs were in attendance, among them former Pennsylvania Governor William Scranton, Representative Paul Kanjorski, and Senator Arlen Specter. Now, four years later, we are invited to attend yet another meeting: an "informal open house" with members of a project team who will be available to discuss the new "EA" which identifies a "Minimal Operational Segment (MOS) of the project for advancement." Whow! That sounds like exciting stuff. But I think I will pass this time. You see I have already attended one too many meetings at which people said that something serious was going to be done in the not too distant future about restoring train service from Scranton to New York City. Thanks anyway.

John R. Nordell, Jr. Old Forge, Pennsylvania

Nordell

20Hello,

My name is Mike Hessmiller. I would like to express my opition on the rail service from Scranton to NJ. I feel this project is a great idea especally since gas is to high these days. I have expresse that I do beleieve you will get a high amount of ridership from Scranton and surrounding area. I believe that more then ever with energy problems we have . I would take my family on a Newyork vacation useing the train not using a car due to gas prices.

Hessmiller

21Please restore train service to the Poconos. I will gladly help. thank you, Kermit Koch 65 Bonita Rd. Waretown,N.J. 08758 732-312-2070

Koch

22Hello my name is Shawn A. Payne. I have worked as an Amtrak Test Maintainer in the Communication & Signal Departement for the past twelve years. I have lived in the Pocono area for the past five years and find it a great place to live as well as raise a family. My family and I have been very curious about rail service coming to this area because it would greatly improve my commute. It would lessen the now heavy traffic that has arisen in the time that I have been here. It also would provide an alternative mode of transportation to New York and New Jersey for the thousands of commuters in the area, including myself. The current bus system is right now the major mode of transport in this area. But you and I both know that the railroad would better provide a more effiecent means of transportation, especially in the winter months where Interstate 80 has a habit of becoming a frozen parking lot. The cur rent bus fare is 35 dollars one way to NY. I am absolutely sure the rail fare would be signifigalntly less! I plan to attend the meeting on July 15, to find out the future of rail service in this area. Who knows, I may be able contribute in some way! Maybe in the near future I may be able to use my Railroad knowledge and expertise to one day be a NJT employee providing excellent service in the area I now call home. Please feel free to contact me on any and all information regarding rail service in the Pocono area, as well as any Job opportunities. I can be reached by email at [email protected] or by cell, 646 533 9971. Thank you.

Sincerely,

Shawn A. Payne

Payne

23The restoration of the Lackawanna Cutoff is decades overdue. There is massive traffic through the Poconos and western NJ that will never get remedied by added capacity for I80. People commute from Scranton and vicinity to New York City on a daily basis. Numerous people travel to the Poconos for skiing and other attractions. I'm a native of Scranton, working in Manhattan, living first in Manhattan and now on Long Island, and for years I'd periodically traveled to Scranton by bus and later by car, a long and slow trip. Decent train service (into Penn, not terminating on the wrong side of the Hudson) would make a huge difference. Choice of the right equipment (NJT's proposed dual modes with diesel and pantographs) could take skiiers directly from Long Island to the Poconos in winter. Baseball fans could go from NYC to see the Yankees AAA farm club in Scranton. Steamtown National Historic Site would get a great tourism boost. And with all the firms that have established call centers and the like in the Scranton area, executives could easily get there by train - as opposed to renting a car. There is no viable air service.

Ron Troy 2 Crystal Lane East Northport, NY 11731-5028 631 368-4935 [email protected]

Troy

24Vincent,

I attended the informational meeting earlier today at Perona Farms in Andover NJ - regarding the 7.2 mile extension of the existing rail line into Andover, and would like to express to you the importance of this project. Having multiple choices of transportation in a region is vital to it's success, and having a railroad to add to the choices is the right way to proceed!

I have no vested interest in whether the railroad is built, however I do know that it is necessary.

THE RAILROAD NEEDS TO BE BUILT TOMORROW!!!

Thanks for listening.

John R. Bodner 11 Liberty Trail Andover, NJ

Bodner

25Dear Vince:

Thank you for the public presentation last night at Perona Farms. We spoke last year in January 2007 but I did not get the chance to chat with you last night. I am a local Andover Twp resident who strongly favors the project, especially the MOS into Andover Township.

I am having a debate with someone over the desirability of the location of the Andover Station.

My argument is that the proposed location was chosen because it is one of the few places where the rail bed and the road are at equal grade. If one goes east the rail bed descends into the deep Roseville Tunnel and if one goes west the rail bed is elevated by the Pequest Fill such that it is over 100 feet above Andover Borough and Rte 206.

His argument is that the station should have been located 1.5miles to the west in Andover Borough and made the center of a transit village at Rte 206 complete with multi-level parking deck etc.

I say that perhaps the Andover Borough Council rejected this option to the County Freeholders (like Susan Zellman) and County Planner Tom Drabic.

Can you comment on some of the reasons why the Andover Township Station location was chosen in its current form?

Thank you very much.

Best regards,

Timothy W Apgar 3 Howard Dr Newton NJ 07860-6017

Sr Staff Engineer Broadband Business Segment ANADIGICS141 Mount Bethel Rd Warren NJ 07059-5128

Cell: 201 230 7225 Email1: [email protected]: [email protected]

Apgar

31The Lackawana Cutoff restoration is a good move toward improving commuter vehicle traffif in Sussex County. My concern is that the proposed 65 parking spaces in Andover may be very inadequate. If there is a rail line within several miles of rural Sussex County the demand will I think be much greater. Plan on a larger commuter population if and when this rail line becomes active.

Regards, Wayne Gotsch

Gotsch 26

27July 15, 2008

Thank you for taking written comments on our long anticipated “Lackawanna Cutoff” project. First, I want to say, that I am a 100% advocate of restoring passenger and freight service to this line. And, I see no adverse environmental impact associated with the project. I believe that we are finally seeing some progress on this project evidenced by the fact that NJT is going forward with restoring a 7.3 mile section between Pt. Morris and Andover. As your chief planner so aptly put it … “a toe hold.” Long ago I was an advocate of doing this project in pieces, as the consultants had originally recommended. But, our people on this side of the river demanded the project come to Scranton in one shot. That was not practical, but our people would not hear of it, and invoked the names of Senators and Congressmen that allegedly demanded it go all the way to Scranton. I never knew if that was true or not, to be honest. I feel their actions cost us valuable time, and federal money. But, that’s over – NJT, FTA and the consultant are now on the same page, and even if the projected date is some 20 years out for eventual train service to Scranton, at least it’s believable and a doable target. We have many obstacles to overcome – laying new track on the 28 miles that was ripped up – and, then the bridge over the Delaware. When that’s completed we still have a mile or so to restore on the PA side that runs behind people’s houses, that some have claimed for swimming pools, garages and playgrounds. After that it’s just upgrading to handle the projected 65mph trains. And, of course, building stations, and who pays for all this! I am also a proponent of using this line for all types of freight service. We have hundreds of trucks pounding the pavement daily between NJ and PA, a very large portion of which are coming to Scranton. Just getting some of those trucks off the road would be a major accomplishment. Some say that restoring, or building new passenger lines, does nothing to relieve the congestion that is already in place … but, it does prevent further congestion. I think we’re about 10 years behind the congestion curve, but I believe this project when completed will help reduce further congestion. Our roads and bridges will still demand constant care and upgrading – a huge bill in PA, and I’m sure NJ, but people will have an option.

Jim Finan 110 Jonslea Lane Roaring Brook, PA 18444

Director of Transportation, Lackawanna County – 2004-08 Executive Director, County of Lackawanna Transit – 1990 – 1999 Investigator, ICC & NTSB – 1980-90 Erie Lackawanna/Conrail – 1969-80

Finan

28 24 JAMES CRAWFORD: I would like to ask

25 them what the impact will be on our property. I'm

1 probably the second house past the bridge, coming from

2 Kerrs Corner Road. And when you turn on Lanning,

3 L-A-N-N-I-N-G, Road, we're the second house on the

4 right-hand side. And I think it's about 900 feet from

5 the tracks.

6 And I'm trying to find out what is going

7 to be the impact on this train because, obviously, I'm

8 not happy about it, but I guess we'll see. But I

9 would like to have someone answer or look -- at the

10 map here it's like a half inch away from -- it's cut

11 off, so I can't see it from the map, and they don't

12 have anything else here. So that's what I would like

13 to see. That's all. Thank you.

Crawford

29 14 KEITH SMOLLIN: I am a full supporter of

15 this project. It is desperately needed to relieve

16 congestion off of Route 80, and it's also needed

17 because of high gas prices. We need this

18 transportation alternative, and the sooner, the

19 better. That's all. Thank you.

Smollin

30 20 PETER PALMER: In this era of exorbitant

21 gasoline prices, Northwest New Jersey desperately

22 needs real transit service, and this is a very

23 important first step in that direction.

Palmer

31 24 JAMES CRAWFORD: I previously said

25 900 feet, I think, and it's just slightly less than

1 300 yards.

Crawford

See Comment28

32 2 PATRICK REILLY: United Transportation

3 Union is definitely 110 percent behind this project.

4 The only belief that we have that should change is

5 that we feel that phase one should be extended to

6 Stroudsburg where there should be located a yard and

7 terminal. The majority of the traffic will show that

8 Stroudsburg is a key hub for this project.

9 We feel that bringing it to Andover, the

10 ridership will be low, and we'll question the -- we'll

11 raise questions about the anticipated ridership from

12 thereon. If the project is extended to Stroudsburg,

13 we feel that the ridership will be strong enough to

14 show support to finish the project in through

15 Scranton. Thank you.

Reilly

33C O M M E N T S From Meeting in Stroudsburg, PA on July 15, 2008

10 MS. MURRAY: My name is Rosalie

11 Murray. I live in Blairstown, New Jersey. I

12 have two important requests. One, that the

13 initial phase have the train go to Blairstown.

14 Andover is only 12 miles away. There are a lot

15 of people in the Blairstown area, which would

16 include Knowlton, Belvidere, the whole area,

17 that could use the train from Blairstown. That

18 is my first concern.

19 The second concern that I have is

20 that scheduling be done so that there would be

21 an express train in to New York City in the

22 morning, at least one, if not more, and

23 returning from New York City in the evening.

24 Express, a train that won't stop at every little

25 stop through Morristown. Because one of the

1 criticisms of the initial scheduling was that it

2 takes so long to get from Stroudsburg to New

3 York.

4 And it would -- it strikes me as

5 being much more efficient if we can have two or

6 three express trains every day. I guess those

7 are the most important things. And the sooner

8 the better.

Murray

33A

33B

33B

34 9 MR. KEATING: My name is Dominic

10 Keating. I'm a resident of Dunmore,

11 Pennsylvania. I've given my business address

12 here. I'm the Vice Chairman of the Pennsylvania

13 Northeast Regional Rail Authority. We're the

14 owners of the trackage from Slateford Junction

15 to Scranton.

16 And we're absolutely thrilled, I am,

17 that the Environmental Assessment has been so

18 positive. So little negative impact, almost

19 miniscule negative impact on the environment in

20 both Pennsylvania and New Jersey.

21 I'm thrilled that the actual

22 construction of the -- reconstruction of the

23 cut-off to Andover is likely to take place and

24 look forward very much to the completion of the

25 entire project to Scranton. I'm just very happy

1 with the turnout here. And an excellent job

2 done by TRANSIT and the people who are helping

3 to make a very nice program.

Keating,D

35 4 MS. KEATING: My name is Kathleen

5 Keating. I am from Dunmore, Pennsylvania. And

6 my comment is that I am very anxious to see this

7 train come about, especially with the current

8 price of gas. And also with family living down

9 there, it's so much easier to get to them than

10 to drive on that interstate that is so

11 overcrowded, and so uncomfortable to drive on.

12 So I'm thrilled with the prospect of

13 getting to New York without having to take a

14 car.

Keating, K

36 15 MR. CIMINI: I'm Attorney Joseph F.

16 Cimini, C-I-M-I-N-I. My only comment is I would

17 like to congratulate the efforts that NJ TRANSIT

18 has put forth on the fine presentation here

19 today. I hope that their leadership will

20 continue. And I would hope that my own

21 resources, in Pennsylvania, our own government,

22 and our leaders in Pennsylvania will follow the

23 lead and example that has been well set here by

24 New Jersey Transit, again on the efforts and the

25 real concrete progress that we're seeing on this

1 end of the project.

Cimini

37 4 MR. SHORE: I am Thomas D. Shore. I

5 am for the project. I've commented in a six

6 page letter in the past on the first go-around

7 here.

Shore

Bender 38

38A

38B

Gatti 39

Specter/Casey 40

Phillips 41

Carbone 42

Welsch 43

44This project is a positive one...I’m for the train. I moved to the Poconos over two year ago moving with the intention that the train will be here soon. I live in East Stroudsburg and they have to be some form of transportation. I pay over nine thousand dollars in taxes in one year and cant travel to work without driving or taking Martz bus which is too expensive ($464.00). It need to get here much sooner. The people who are against it are the older forks and do not have to travel to work, if the politicians need to see the Poconos build up they need to bring the train.

Savitri PanchamSupervisor,Data Control Municipal Credit Union Tel: 212-238-3313 Fax: [email protected]

Pancham

45Name: Norman H. Ressler Address: 11 Felter Place: Lake Hopatcong, NJ 07849 Phone #: 973-663-3022 e-mail: [email protected]

Comments: The final form of the presented EA is very complete and certainly deserves to have a FONSI issued promptly.

I attended both the Andover 7/10 and Stroudsburg 7/15 hearings and did not hear much in the way of objections to the project except for a couple of "die-hards" that would object to any change of any kind. Those who did object were mostly saying that the service would not justify the money expended, but then again, neither did the Brooklyn Bridge when it was first proposed.

Even the Sierra Club of NJ (as differentiated from PA and the National), could not offer any specific objections that made any sense whatsoever. I suspect the NJ Director is voicing his objections more to justify his job than anything else. I could not pin him down to any specifics. He (Jeff Tittle) was at the Andover meeting but I didn't see him at Stroudsburg, and I was at both for at least 4 hours.

When the first phase of the project, the MOS, is completed, I predict there will be over the projected ridership, and within ten years will require significant expansion of the parking lot. Part of my reason for this is the anticipation that the newly ordered dual-mode locomotives will be available and will make "Mid Town Direct" service from Andover a reality. Within six months of this happening, you won't be able to expand the parking lot fast enough. The same for the Mt. Arlington station where the parking lot is daily at over 95% of capacity. I check it several times each week, and have noticed that the Lake Hopatcong station parking lot is never over 3/4 filled since Mt. Arlington opened. I believe this is the source of most of the new Mt. Arlington parkers.

When the following phase(s) is/are completed to Scranton, I believe that all ridership figures will be at least 50% higher than predicted within 5 years of opening, especially if the dual-mode locomotives can be used.

This project must be pushed with as much urgency as possible, since other worthy projects driven by the ever increasing fuel prices will be competing for federal and state monies. (MOM line, the West Trenton line, and the I-78 study that will probably encourage the extension of passenger service past High Bridge to Phillipsburg or Easton).

I have been working on pushing the Lackawanna Cutoff project for over ten years, and have seen credible opposition crumble and disappear except for the few usual crack-pots. Some will always object to anything new. We have delayed too long with this project and in those ten years have seen costs escalate from $200 to $551 million. Further delay will cost us dearly in terms of direct dollars, air pollution, fuel consumption, and forever lost economic waste caused by sitting in traffic.

Thank you.

Ressler

46I wanted to comment on the proposed passenger rail line that will tentatively runbetween Scranton and Hoboken. I believe it is a great idea. I would use it, I wouldsupport this project in any way I can, and I would be willing to help you make this line areality in any way I could. If there is a way to keep me informed of the progress of thisproject, please do so.

Thank You,Mitch Sullivan5 Acorn CourtFlorence, NJ [email protected]@amtrak.com

Sullivan

47TO THE SPONSORS AND PROMOTERS OF THE NEW JERSEY-PENNSYLVANIARAIL SYSTEM RENEWAL::

As a former Monroe County, PA County Comissioner for 16 years and former Chairmanof the PA multi-county Railroad Task Force (we beat ConRail in the Three-R Court inWashington, D. C.) from obliterating the tracks through our side of the Delaware River toSecranton, ) I add my support for restoration of this transportation mode.

From the 1900's fiorward, studies have proven that rail transport is the least costlymeans of mass movement of goods and people. Our studies disclosed that passengerservice alone would make the system cost prohibitive. As it happened at that time in theearly 1980's in our affected counties, we had operating industries that wanted tocontinue their use of this rail line. This included Tobyhanna Army Depot. which facilitydepends upon all modes of transportation and specifically moreso during this era of highsecurity and transport alternatives in the event of nationwide mobilization. The Depotwas cognizant of that fact in the 1980's so would be moreso today.

The Railroad Task Force members met with the Delaware & Hudson President atAlbany and found favorable reception with the concept of the NJ/PA proposal for linkagewith D&H for rail freight. A rail passenger tourist package between New York City andCanada was on the table for our consideration. Piggybacking for trucks was anessential of our planned program. There was also potential contract with lines to themidwest. Important papers and minutes of Monroe County Task Force should be on fileat the Monroe County Commissioners Office in Stroudsburg. Rail freight that may nothave been sought in the 1980's would very likely be valued at the present and in thefuture.

When this program is fully explored to sign up every potential rail freight user:factory, industry, warehouse, distributor of goods - and this is an energetic,comprehensive search in itself- your organization may be very encouraged to moveahead and the respective States and Federal fund investments would be more-quicklymade availabhle. By adding monetary-credit to the line for lessening the present andcontinually increasing freight load on the Interstates and State two-lane roads, thegeneral public also will become more more vocal in pressing all decision-makers tomake public reality out of a very good public plan.

In all the years that our effort for this purpose was ongoing, we received excellentcooperation from New Jersey executives at Port Morris and all associated parts of therail line. In any overview, now or in the future, the restoration and use of the oldDelaware-Lackawanna for rail and passenger service will prove itself worthy and moreworthy with each passing year.

Sincerely and with Best Wishes to All,July 19, 2008Nancy Michael Shuikaitis

Shuikaitis

48I support this project. I would only ask that sensitive habitat/speciesbe respected as you go forward.

Martha CarboneShawnee On Delaware, PA

Carbone,M48A

48B

49

Dech

Dech 49 cont'd

Dech 49 cont'd

NEW JERSEY CHAPTER145 West Hanover St., Trenton, NJ 08618

TEL: [609] 656-7612 FAX: [609] 656-7618www.SierraClub.org/NJ

Sierra Club: For Our Families, For Our Future

50

July 29, 2008

Richard R. Sarles, Executive DirectorNew Jersey TransitOne Penn Plaza EastNewark, New Jersey 07105-2246

Re: Environmental Assessment for Lackawanna Cutoff

Dear Mr. Sarles:

In accordance with published notice, the New Jersey Sierra Club would like to submit thefollowing comments regarding the Environmental Assessment (EA) for the Lackawanna Cutoff.We believe that the EA is so inadequate as to be insulting, and we are requesting a fullEnvironmental Impact Statement (EIS) on this project. Given the significant environmentalimpacts that will result from this project and the completely unacceptable EA, a full EIS iswarranted.

Holes in the Environmental Assessment

The current EA fails to look at impacts to land use and secondary growth from the rail line,claiming that there will be no land use impacts because the line meets local zoning. In fact, NewJersey Transit’s own statement on the reason for the rail line includes promoting developmentand serving a future population brought in by projected growth in the rail corridor. With NewJersey Department of Transportation (DOT) encouraging development at rail stops through“transit villages,” there will clearly be land use impacts that result from this project.

The EA also fails to look at impacts to wetlands and endangered species habitat. There aresignificant wetlands along and in the rail line itself, including many vernal ponds. The proposedtrain station for Byram is not only in the Highlands Preservation Area, it is also between twoCategory 1 streams, meaning there will be significant impact to both wetlands and endangeredspecies habitat. Virtually the entire rail corridor is in Landscape 4, 5, and 6 with significantsitings for federally-protected bog turtle, red shouldered hawk, barred owl, and a range of otherspecies.

The EA does not mention impacts on air quality from diesel locomotives, people driving to park-and-rides, or from secondary development.

Impact on Public Policy

This project will not enhance mass transit. Instead we believe that its real intention is to promotesprawl and overdevelopment in environmentally sensitive and rural areas. The numerous stops

Sierra Club, NJ Chapter

50A

50B

50C

50D




that would be proposed throughout the Highlands and Skylands Region of New Jersey are thereto promote development around the train line, not to promote transit. The proposeddevelopments along the transit line and at train stops will be dominated by the use ofautomobiles not rail. Studies across the country have shown that more than 90% of the peopleworking or living in new transit-based developments will use automobiles, which would addmore traffic along already congested highways and secondary roads. To spend this amount ofmoney on a railroad that will undermine good transit and land use planning makes no sense.

The proposed Lackawanna Cut-off Project would create a 133-mile-long commuter railconnection between Scranton, Pennsylvania and Hoboken, New Jersey in anticipation of 40eastbound daily commuters boarding at Scranton, Pennsylvania by 2030. By New JerseyTransit’s own assessment, this will be less than 1% of commuters, which will have noameliorating effect on traffic in the region. The proposed expenditure of more than a half billiondollars in project funds that will be subject to inflation, cost escalation and the anticipatedvaluation of future dollars in order to encourage 40 daily riders from Scranton, Pennsylvania by2030 is a cavalier expenditure of vital transportation funding, especially at a time when the stateof New Jersey is in a fiscal crisis.

Furthermore, New Jersey Transit’s Draft Environmental Assessment anticipates a one-way traveltime of three hours and twenty minutes between Scranton, Pennsylvania and Hoboken, NewJersey. With transfer times, the one-way trip from Scranton, Pennsylvania to downtown NewYork, New York would exceed three and one-half hours. New Jersey Transit estimates that thevast number of eastbound commuters would be routing to Hoboken, New Jersey or New York,New York. From a conceptual standpoint, the establishment of a 133-mile-long commuter railline that is predicated on the creation of a commute that exceeds seven hours daily strains thelimits of good public transit policy and presents significant practical considerations.

Practicality and Limited Potential for Transit Growth

Notably, the proposed Lackawanna Cut-off Project would place commuters originating inScranton, Pennsylvania in a position of deciding whether to take a one-way train commute thatwould take three and one-half hours, or an express bus commute that takes two and one-halfhours. Accordingly, there is a serious need to consider whether commuters will be willing to giveup the usage of express buses and spend an additional ten hours in commutation status eachweek.

Furthermore, although the route formerly provided access to long-distance rail service toBuffalo, New York and Chicago, Illinois, the creation of an eighty-eight-mile-long extension ofcommuter service from Port Morris, New Jersey to Scranton, Pennsylvania would present alimited potential for future transit growth, because of intensive existing commuter rail service onthe connecting NJT Morris & Essex Line and Montclair-Boonton Line. As an example, SummitStation on the Morris & Essex Line currently has almost 200 commuter trains running througheach weekday. In addition, despite the intensive existing commuter schedule, the service

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extension to Scranton, Pennsylvania would recreate a freight connection between the RahwayValley Railway, scheduled for reconstruction of a freight connection to Summit, New Jersey, andthe Delaware & Hudson freight line at Scranton, Pennsylvania and the Canadian Pacific mainlineat Binghamton, New York. The combination of expanded commuter rail service and the creationof through-freight service on already crowded commuter lines would invite delays and potentialdisruption of service on the Midtown Direct. Overall, the existing intensive commuter railschedule would tend to limit the potential for expansion of either commuter or freight services.

Problems in Methodology

The EA for the Lackawanna Cutoff project creates issues in the application of urban mass transitmethodologies to areas of rural growth. In this regard, the EA anticipates the same populationgrowth trends and household growth trends, whether or not the Lackawanna Cutoff isconstructed. Although urban mass transit projects may encounter a limited potential for thegrowth of population and motor vehicle trips, transportation projects in rural areas tend to beaccompanied by a corresponding surge in residential and business development.

The EA does not make a comparative projection of anticipated increases in population,households and motor vehicle trips if the Lackawanna Cutoff is constructed versus if theLackawanna Cutoff is not constructed. An EA could not for example, presume that all membersof newly constructed homes would commute by rail, even if one household member decided thatspending seven hours a day on the train was worthwhile. Furthermore, additional motor vehicletraffic would tend to be created by individuals who would briefly endure a three-and-one-half-hour, one-way commute in order to avail themselves of lower habitation costs in Pennsylvaniauntil they could transfer to employment with a more convenient commute.

In addition, there is every indication that a commuter rail link would promote more developmentin the Pocono Mountains. The development will lead to more secondary impacts such as trafficassociated with more people living in the region, construction, delivery and service vehicles, etc.However, even the limited traffic assessment in the indicates that the Delaware River Joint TollBridge Commission’s 2006 report on the Northerly Crossings Corridor Congestion MitigationStudy concluded that typical summer day Interstate 80 Delaware Bridge crossings would risefrom 62,000 to over 100,000 by 2030. The Lackawanna Cutoff would not mitigate this level ofgrowth. Significantly, the Northerly Crossings Corridor Congestion Mitigation Study alsoconcluded that: “Based on the traffic capacity analyses, I-80 eastbound and westbound willcontinue to operate in excess of capacity after implementation of the Lackawanna Cut-Off.”Accordingly, instead of pursuing a commuter rail project through rural areas that would tend toexacerbate local traffic growth, there appears to be a more immediate need to address adequacyof infrastructure on Interstate 80 and the need to address traffic issues at point of origin.

Conclusion

We believe that the Environmental Assessment is flawed and technically incomplete. It does notlook at the relationship between this project and the Highlands Protection Act. We believe it is

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inconsistent with New Jersey State Plan especially the Highlands Special Resource AreaDesignation, as well as the secondary and cumulative impacts from this project. This projectwill promote development and growth in the Delaware Basin, which has had three major floodsin the last two years. The secondary impacts from this project will mean more impervious coverand more flooding. This project will also push the NY Metropolitan Area further out to theScranton area and those impacts to our region will be significant.

This project will not reduce car traffic on Rt.80. It will instead encourage more traffic becauseof the development and the need by companies to service the expanding populations in SussexCounty and the Poconos. Every car that is replaced by someone taking the train will be replacedby at least two cars from all the new development. We believe that New Jersey Transit’s timeand money should not be subsidizing sprawl in the Poconos. There are much better places forour money and resources to be spent such as the West Shore or Northern Branch projects inBergen County, reopening the West Trenton line to Somerville, expanding the River line intoGloucester County, the Union County light rail line, and many others.

When the line was purchased by New Jersey DOT, it was for freight rail, rather than passengerservice, due to the fact that lack of ridership and the long commute made passenger serviceimpractical on this line. The Sierra Club believes that if this line is to be reactivated, it should beused for freight, which would get trucks, a major source of pollution and traffic, off the road.

Sincerely,

Jeff Tittel, DirectorNew Jersey Sierra Club

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Vincent TruncellitoNJ TransitOne Penn Plaza EastNewark, NJ 07105-2245

Dear Mr. Truncellito,

Thank you for this opportunity to comment on the Environmental Assessment for the proposedLackawanna Cut-Off Rail Service Restoration Project. Tri-State Transportation Campaign hasbeen closely following the project since the initial proposal, and remains concerned with thelevel of analysis and preparation. Given these concerns, we strongly believe that NJ Transitproceed with a full Environmental Impact Statement before proceeding further. Below pleasefind an enumeration of Tri-State’s concerns:

1. Project lacks demonstrable purpose and needAfter reviewing the Environmental Assessment (EA), it is difficult to identify adefensible need for the Lackawanna Cut-Off project (the project). Projected ridership forthe line is questionably low, especially for the portion in New Jersey and the MinimalOperable Segment (MOS), and a lack of specificity in the EA fails to demonstrate theproject will fulfill its stated purpose and need.

While congestion mitigation on Route 80 is not directly listed as a primary purpose forthe project, it is referenced throughout the document yet never analyzed. Section 1.3.4states that the only alternative to reduce peak traffic on Rt 80 is roadway expansion;however, NJ Transit (NJT) did not conduct a traffic analysis of Rt 80 or cite how manycars will be diverted from the roadway. Furthermore, according to recent media coverage,NJT has already stated that this line will not carry freight1, despite the acknowledgementin Section 1.3.5 of truck traffic tripling in the corridor over the next 15 years. One way tobattle the rising tide of truck traffic and in turn reduce overall congestion is to increaserail freight. Unlike passenger freight, reactivating freight rail lines has a negligible impacton development in the rail corridor and will remove thousands of trucks from ourhighways.

The traffic analysis presented in the EA does not include major corridor highways, onlyexamining the streets in the immediate vicinity of the station. Moreover, under the 2030build scenario, mitigated conditions still show level of service (LOS) failures surroundingseveral stations2:

- Tobyhanna station shows 12 road segments at level F, three at level E, andfour at level D;

1 NJ Transit: Lackawanna Cutoff rail line won't carry freight. Jim Lockwood. The Star-Ledger. Wednesday June18, 20082 The Lackawanna Cut-Off Passenger Rail Service Restoration Project Environmental Assessment, Tables 3.7-1through 3.7-26.

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- Analomink will have one am and two pm peak roadways at LOS F;- East Stroudsburg has one D and one F in the am peak, which jumps to six F,

two E and two D in the pm peak;- Delaware Water Gap shows one pm peak segment and one am peak segment

failing, even with mitigation. There are also three segments at level D;- Andover station shows one failure and one level D service in the am peak, and

the two failures in the pm peak.

At no point in its considerable length, does the EA quantitatively demonstrate theproject’s efficacy. Due to the emphasis given to traffic reduction on Rt 80, the lack ofanalysis is disquieting. In terms of car-reduction in the corridor, the closest estimates arein the parking analysis, which anticipates 953 vehicles will be parking at stations alongthe corridor by 2030 – of those, only 93 will park at stations in New Jersey.

Section 1.3.2 states the need for improved accessibility to New York and New Jerseywork destinations, yet section 1.7.3 fails to support this notion, where it states that serviceto Manhattan is “provided by frequent bus service.”

Finally, final service as it relates to "recreational activities" in the Monroe County, PAregion, the facilitation of which is listed as a primary purpose of the project, is leftunstated. There is no mention of weekend service when demand for recreationalactivities is greatest, except to state that the MOS will not include service on theweekends.

The points above bring to light NJT’s dearth of meaningful analysis, and inability toproperly substantiate this project. If this project were indeed worth the taxpayers' $551million, one would expect that NJT would have calculated the reduction in cars alongmajor highways in the corridor and anticipated weekend service. This lack of analysis castsdoubt on the project’s claims to reduce congestion and achieve the needs set out in the EA.Further study and documentation is required before an informed decision can be made byNJ Transit and the states of NJ and PA as to the true value of the project.

2. The Minimal Operable Segment does not advance project purpose and need orprovide value for its costThe MOS segment, the only portion of the project with current funding, completes therail line only to the Andover station, a 7.3 mile section. The choice to proceed with thissegment alone is irrational in terms of the stated purpose and needs for the project as awhole and in terms of ridership and potential for adverse secondary impacts. Nowhere inthe EA does the agency describe the process used to determine the value of proceedingwith the MOS. The only metric used in the determination appears to be fundingavailability and a vague policy directive to complete rail projects in a piecemeal fashionas funding is available.

The MOS to Andover will serve an estimated 160 passengers daily upon opening in2012.3 In no scenario does this ridership justify the projected $36.6 million cost. Since

3 Id. at p.38.

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the non-MOS portion of the project currently has “no projected schedule and no capitaland operating funding identified,”4 it is a very real possibility that the MOS will be onlysection built indefinitely. As outlined in the EA, PennDOT and NJDOT will talk aboutfunding full reactivation after implementation of the MOS portion of the buildalternative. This timeline is counter-intuitive given that construction of the Andoverstation does not fulfill the stated purpose and need, and its location is the mostenvironmentally sensitive (with 4.1 acres of the project's 6.4 acres of impacted wetlands).

Common sense dictates that $36.6 million can be better spent. NJ Transit needs to betterdefine the selection of the MOS and either justify the choice of Andover station orredefine the selection.

3. Reinstatement of this service will promote sprawl developmentThe project’s right-of-way runs through small towns in sparsely populated areas knownfor their natural beauty, like the Pocono Mountains, the Delaware Water Gap, and theNew Jersey Highlands. By constructing several new stations and bringing service tostations long abandoned, the Lackawanna Cut-Off would create a transit route for NYC-area bound commuters from rural Morris, Sussex, and Warren Counties. While theproject is not projected to draw large numbers of current residents, the new capacity willencourage more people to migrate to some of the state's largest and most environmentallysensitive undeveloped tracts.

The EA boldly states that “Ridership projections for proposed rail service are notsufficiently high to suggest impacts on land use and zoning5,” and then to absolve NJTfrom responsibility by stating local and regional bodies ultimately control land use. Thedocument does not take into account development pressures in the area, which werevoiced in the concerns of many local residents in the comments portion of the document.Building a commuter-oriented rail line through the region will greatly increase thesepressures.

Development around the proposed Andover site could have major impacts on theHighlands Preservation Area adjacent to the Borough, injecting sprawl into one of themost beautifully rural parts of the New Jersey Highlands. The location of the Andoverstation – the section most likely to be built as the MOS – cannot allow transit-orienteddevelopment, and therefore discourages the cluster-style development promulgated in therecent Highlands Regional Master Plan, and incentivizes sprawling, low-densitydevelopment.

While current zoning in the corridor may provide a useful baseline to determine potentialdevelopment caused by the project, zoning is not static. When development pressuresincrease, as will likely occur with increased transit accessibility, pressure to changezoning designations and boundaries increases and can occur. The project should receive afull analysis of its impacts on regional development patterns.

4 Id. at p.285 Id. at p.163.

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4. Development patterns and construction will result in the environmental degradationof the area’s watershedThe EA did not evaluate the potential detriment to larger swathes of wetlands due toincreased runoff pollution from secondary growth. The direct impacts of rail arecomparatively negligible; however, changing development patterns will negatively impactthe sensitive communities through which the project runs. Although the majority of theproject is contained in Pennsylvania, the most sensitive parts of the project area arecontained within New Jersey. For example, the project will incur 6.4 acres of wetlandsdisturbance, 6.2 of which are in NJ, and 4.1 of which are in the MOS portion of the project.Two of those acres are in Byram Township, a protected Highlands community that recentlypassed a resolution against reactivation.

The entire proposed Andover station falls within threatened and endangered specieshabitat, and twenty species in all, including Bald Eagles, inhabit the project corridor. TheEA states that this assessment is only preliminary, and they will conduct a more thoroughinvestigation after the project is approved. However, a project of this magnitude shouldhave these important details mapped before moving ahead. This omission furtherillustrates the need for a full Environmental Impact Statement.

ConclusionMany factors contribute to Tri-State’s trepidation with respect to the Lackawanna Cut-Off project.The EA’s fails to illustrate that the project will fulfill the stated purpose and need, especially whenthe only foreseeable construction will build the MOS, which does not address the goals of theproject and holds the greatest potential for adverse secondary impacts. A lack of traffic andsecondary impacts analysis only drives home the need for more study.

Tri-State urges NJ Transit to take the time to conduct a full Environmental Impact Statement,examining the development implications of the project, alternatives to improve regionaltransportation a nd reduce congestion along the corridor, and ensure the ultimate sustainability ofthis expensive, expansive project.

Thank you for your consideration. Please do not hesitate to call if you have any questions.

Respectfully submitted,

Kyle WiswallStaff Attorney

Zoe BaldwinNJ Coordinator

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55Hello Mr. Truncellito,

My name is Anthony Davis and I am a NJ Transit Bus Operator who lives in the Poconos (Bushkill - Pike County, Pa) and work at the Market Street Facility in Paterson NJ. Because of the increased cost of gasoline, I started driving to Hackettstown and Mount Olive to catch the train to work. I utilize the Montclair-Booton line to Little falls and transfer to the #704 bus to Grand and Spruce in Paterson NJ. My mode of transportation varies with my changing work schedule. In doing so, I have noticed that service from the Poconos would require very early service towards NY/Hoboken and very late service returning. When I am scheduled to report to work prior to 6:00am, I'm forced to drive my truck. And if I were scheduled to work very late, I would have to do the same. It's given me the opportunity to notice the traffice patterns to and from the Poconos at various hours of the day. Rush hour out of the Poconos begins a little before 4;00am. There are quite a few vehicles heading east on Interstate 80 at such an early hour. I would hope that when rail service begins out of the Pocono Mountains, that the schedule would accurately reflect the needs of the Pocono commuters.

Sincerely,

Anthony Davis

Davis

56Hi Vincent Truncellito:

I’m one of 40,000 commuters from the Poconos.

We have created a committee in Northeast PA and we would like to be actively involved in this project.

We have a couple of question:

Has a cost analysis been done in 2008? $551 million (2006 Estimate).

Has anyone looked at the alternative Rail Service recommended by Harvard

Graduate School of Design?

According to the Harvard University Graduate School of Design we need to rethink

the path these tracks take.

Ortiz

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Harvard University Graduate School of Design

Change: Railroad Service

Change: Railroad Service How Might the Landscape and Infrastructure Policies of the County Change?

Rail service is planned for re-establishment, linking Monroe County and the New Jersey/New York area. The existing proposal and several other rail possibilities for the County were studied, including technical, service, and economic considerations. Although reconstruction along the existing Erie-Lackawanna rail road right of way, shown in gray in the lower right map, is feasible for slower freight and tourism service, it is unsuitable for higher-speed commuter service which requires wide radius curves. Because of this, several alternatives were considered. The recommended alternative proposes a new rail alignment which would be capable of handling state of the art higher-speed trains.

The new alignment proposal, shown in yellow in the lower right map, would take advantage of the existing Interstate 80-380 right of way, between Interchange 8 near Mount Pocono and Interchange 47 near Stroudsburg. It uses the existing right of way north of Mt. Pocono, The rail line is located within the existing Interstate median strip. Further south, from Stroudsburg to the Delaware Water Gap, the alignment will need to leave the Interstate median and proceed along a new right of way until re-joining the existing track east of Stroudsburg.

The best estimate of the cost for upgrading the old rail alignment is $327 million, including regrading, track, bridges, and underpasses. Our estimate for the new I-80 alignment is $239 million, a difference of approximately $100 million. The new alignment has the added benefit of moving the potential development that would accompany rail stations farther to the west, away from the sensitive areas of Broadhead Creek and Paradise Valley.

Sincerely,

Miguel Ortiz Verizon Business 560 Lexington Avenue, 8th floor New York, NY 10022 Solutions Engineer Office: 212-295-6019 New Cell: 917-699-0274 Fax: 212-295-6042

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57 16 ROBERT SIMPSON: I wanted to say that

17 they expect 6,700 hundred riders by the year 2030, 85

18 percent would be from Pennsylvania. They would be

19 going to New York City. And it's going to cost New

20 Jersey $12 and a half million to operate. That

21 doesn't sound good at all.

22 And how do they expect anybody from

23 Scranton to commute to New York City when it takes

24 three and a half hours to get there? There was no

25 impact study done for the additional train traffic in

1 other towns between Port Morris and New York City.

2 There's no noise mitigation or anything for that? I

3 probably have a lot more, but that's enough, I think.

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60Hello,

I am wondering if there has been any study or surveying of the community to find out if people will utilize the proposed train service. I think people are thinking this will be a high speed train service or at least much speedier than what is being proposed. Most people that I know that commute travel off hours to avoid rush hour delays. I used to go in a few times per week from East Stroudsburg on the Martz bus and it took much less time than 2 hours and it dropped me right in midtown! This seems like a big waste of time and resources if it is going to provide slow passenger service. In any case, I applaud the efforts of people trying to make train service happen, but it needs to fulfill a need. If it is going to add an hour plus to the time it currently takes to ride the bus, I doubt it will be a viable option unless the ticket is much less expensive than the bus. Even with a less expensive option, the train option just seems very slow and not viable. Has anyone proposed an express service from the Pocono Mountain station or is there any way to build a higher speed train?

Sincerely,

Nicole Mehta McGallaPocono Pines Resident

McGalla

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61Frank Whalen658 Lakeside DriveTobyhanna, PA [email protected]

July 29, 2008

Vincent Truncellito,Manager, Project DevelopmentNJ TRANSITOne Penn Plaza East,Newark, NJ 07105-2245(973)491-4142

Dear Vincent Truncellito,Manager, Project Development,

Please add the following to the record regarding the NJ Transit Public EA open house meeting held inStroudsburg, PA on Tuesday July 15, 2008.

1. There was insufficient time for pubic input to officials of Coolbaugh Township Pennsylvaniaafter the open house meeting by NJ Transit and the regularly scheduled meetings of theCoolbaugh Township Supervisors. The supervisors meetings are set for the first and thirdTuesday of each month. The Open house meeting was on the same night of the last supervisorsmeeting in the month of July. No discussion or comments from the public to the supervisors orany potential comments or actions by the twsp. supervisors to N.J. Transit could be added tothe record before the close date for public comments.

2. The diverse wildlife population of Bald Eagles, Osprey, Otters, Heron, White Tail Deer, BlackBear and other wildlife in and around Mill Pond #1 will be negatively effected by the increasedauto and train traffic.

3. The tranquility and quality of life for many residents in the area will be negatively affected bythe increase in traffic.

4. It is not economically or environmentally prudent to restore passenger rail service along this railline.

Thank you,

Frank Whalen

Whalen

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Documents

APPENDIX C RESPONSE TO COMMENTS … Appendix C - Summary of non-MOS...organization of the response to comments can be complex. ... Comment Sheet General Support ... Comment Sheet Engineering