On Thursday, February 29 from 5:30-8pm at the Robert Hope Community Center in the historic Africatown community, the US Department of Transportation’s Federal Railroad Administration (FRA), the Alabama State Port Authority’s Port of Mobile (ASPA), the Volkert project engineering firm, and CSX railroad will conduct a town hall about the proposed Africatown railyard expansion project they named the “Chickasaw Lead Line”.

If you are a member of the public who CAN’T ATTEND THIS MEETING but you or your organization cares to submit a question, concern, or comment about the impacts this proposed railyard expansion might have on the Africatown Historic District, you can submit your questions, concerns, and comments to be delivered to the FRA and ASPA via Volkert by following the instructions on this flyer from the FRA and ASPA:

MORE INFO:
As explored in MEJAC’s “Key Concerns about the Port of Mobile’s Africatown Railyard Expansion Project” brief, many shocking revelations have been made about the nature of the project since the Africatown Heritage Preservation Foundation (AHPF) was made aware of its existence by the FRA in Augustin 2023.

Following two Africatown community meetings held in January and some door-to-door canvassing of Africatown residents, questions and concerns about the project were compiled and submitted to the FRA and ASPA through the AHPF.

Based on our “Key Concerns” brief, MEJAC submitted the following questions:

1. The Phase 1 Cultural Resources Survey (archeological study) undertaken by All Phases Archeology reported on August 3, 2023 failed to follow federal guidelines described in the Federal Transit Administration’s (FTA) Noise and Vibration Impact Assessment process. For instance, in the case of 308 Chin Street, existing noise conditions are intolerable for residents of the Africatown Historic District currently. The Phase 1 Cultural Resources Survey prepared for Volkert dating August 3, 2023 asserts, “According to the Federal Transit Administration’s (FTA) Noise and Vibration Impact Assessment, there would be no moderate impact or severe impacts to residential or industrial land uses due to noise.” This assertion in particular lacks credibility simply due to the 160 feet distance between 308 Chin Street and the Terminal Railway Alabama State Docks Railroad (TASD) tracks and workspace in question. Construction noise is certainly going to have impacts.

   Within the FTA guidance document referenced, “moderate” noise impacts are defined as “project-generated noise . . .considered to cause impact at the threshold of measurable annoyance”. Is suggestion that a resident living within 160 feet of the heavy construction zone won’t feel “measurable annoyance” during the construction phase not patently ridiculous? Please explain.

   That guidance further defines “severe” noise impacts as “project-generated noise . . . likely to cause a high level of community annoyance”. How in the world could the Phase 1 Cultural Resources Survey author think a person living 160 feet away couldn’t possibly experience a “high level of community annoyance” at the noise of heavy construction?

   In the AHC 106 Form provided to us by the Federal Railroad Administration (FRA), under the “Area of Potential (APE)” section on page 3 of the document, the Alabama Historic Commission (AHC) provides guidance suggesting that “the APE might include the viewshed”, but the project’s Phase I Cultural Resources Survey doesn’t once mention the proposed project’s visual impacts to the Africatown Historic District at all. Industrial blight is the visual evidence of industrial land use and it very often has severe impacts on perceptions of an area, particularly on a vulnerable community like Africatown’s ability to undergo meaningful revitalization and redevelopment in its residential neighborhoods.

   As mentioned previously, concerns over industrial blight are referenced in Africatown planning documents going back to the City of Mobile’s Africatown Neighborhood Plan. Concerns over the use of the additional tracks, how frequently, and the quantity of railcars to be parked on them, as well as the type of railcars to be moved across them are all valid concerns for any historic district or residential neighborhood struggling to earn “fair treatment” and “meaningful involvement” against a seeming pattern and practice of dehumanization. The available documentation also does not demonstrate any plan for the landscaping that is proposed to be removed by the expanded footprint of the rail tracks. Industrial zone landscaping requirements were something that Africatown residents and stakeholders fought for years to be included in the Mobile zoning code rewrite process that birthed the Africatown Safety Zone, which boasts stronger, more protective buffer zone requirements between Industrial and Residential zones precisely for the reasons that Africatown residents and stakeholders are upset with the proposed TASD railyard expansion.

   Will the Phase 1 Cultural Resources Survey be redone to adequately consider the project’s obvious noise impacts and viewshed impacts upon the Africatown Historic District residents from both active construction of the project and routine use of the project after construction, including its use as a railyard parking lot? What landscaping requirements will be included to minimize viewshed impacts to the Africatown Historic District from traffic and use of the extra line as a railyard where chemical tanker cars or cars covered with graffiti may be parked indefinitely?

2. Will a National Environmental Policy Act (NEPA) review be undertaken for the project? Has it already started? Will the public be given opportunity for public participation in the scoping of the NEPA review? When?

3. 5 years ago when ASPA underwent the GRR/SEIS for the Mobile Harbor Ship Channel enlargement, Africatown community members and advocates including the Mobile Environmental Justice Action Coalition (MEJAC) requested that the Army Corps of Engineers undertake a formal cumulative impact study of air quality impacts the project would cause. This was rooted in the concern that increasing overall shipping traffic would result in direct pressures to expand roads and railways serving the Port of Mobile and would therefore impact environmental justice communities of concern like Africatown. We’re less than 5 years since the Record of Decision was signed on that project and this project is before us. Will cumulative impacts from mobile and non-mobile air pollution sources be considered in the federal review of the project?

4. The FRA’s Consolidated Rail Infrastructure and Safety Improvement Program (CRISI) is the program proposed to provide funding for this project. According to federal guidance, CRISI is subject to the Biden Administration’s Justice40 whole-of-government environmental justice initiative. How does the Chickasaw Lead Line project achieve Justice40 goals?

5. The FRA’s Justice40 Rail Explorer mapping tool shows serious concentrations of toxic Diesel and Particulate Matter (PM) 2.5 pollution in Africatown homes within 160 feet of the tracks that are proposed to be expanded through the Chickasaw Lead Line project. How will data from the FRA’s Justice40 Rail Explorer mapping tool be considered?

6. It’s been stated by ASPA that the Chickasaw Lead Line project would decrease harmful air emissions in Africatown. Can that data be demonstrated or is it purely theoretical? If purely theoretical, can ASPA explain why it is appropriate to assert such facts without a scientific basis rooted in quantifiable and publicly available data?

7. Even without the project, rail traffic on the ASPA Terminal Railway spur through Africatown is hugely disruptive to the rest and quality of life of residents of the Africatown Historic District. Will ASPA make any substantial commitments to restricting overnight traffic on the line?

8. After repeated inquiries in person and through email and phone to the Mobile County Emergency Management Agency, it appears that Mobile County lacks a Chemical Emergency Response Plan. Given the amount of harmful and hazardous materials that travels on ASPA’s Terminal Railway spur through Africatown, recent chemical-by-rail emergencies like that of the May 2018 Kemira polyacrylamide release in Africatown, and the recent disastrous chemical-by-rail emergency response in Palestine, Ohio, what is ASPA’s commitment to securing the development of a Chemical Emergency Response Plan for Africatown that would guide an emergency in that case of a derailment of hazardous materials on ASPA’s Terminal Railway spur?

9. How will ASPA incorporate into its expansion plans their new awareness of the Africatown Neighborhood Plan and the Africatown Connections Blueway project Point of Interest known as the Africatown Place of Baptisms supported by the Plan at the land adjacent to ASPA’s Terminal Railway spur crossing on Three Mile Creek?

10. In the Alabama Historical Commission State Historic Preservation Office Section 106 Project Review Consultation Form (AHC 106 Form), under the “Effects Determination” section on page 5 of the document, ASPA asserts “[TASD] rail traffic is not anticipated to change as a result of the proposed project.” But is that not the anticipated outcome of the project? To allow more efficient traffic flow on the railway? And wouldn’t that be a change? How is this section not contradictory to the logical justification underlying the proposed railyard expansion?

AGAIN, if you are a member of the public who CAN’T ATTEND THIS MEETING but you or your organization cares to submit a question, concern, or comment about the impacts this proposed railyard expansion might have on the Africatown Historic District,

you can submit your questions, concerns, and comments to be delivered to the FRA and ASPA via Volkert by following the instructions on this flyer from the FRA and ASPA:

###