On Thursday, August 24, 2023, the Africatown Heritage Preservation Foundation (AHPF) was CC’d on a Determination Letter from the US Department of Transportation’s Federal Railroad Administration (FRA) for an Alabama State Port Authority Port of Mobile project called the “Chickasaw Railroad Lead Line”. The AHPF, nor any of its key Africatown resident leadership or its community partners had heard anything about this project.

AHPF then called on community partners to familiarize themselves with all the documents the FRA included in the initial email:

• FRA’s Determination Letter,
• “Chickasaw Railroad Lead Line Phase I Cultural Resources Survey”, the project’s archeology report, and
• the Alabama Historic Commission‘s Section 106 Project Consultation Review Form for Chickasaw Lead Line (with construction scale layouts).

A map of the Africatown railyard expansion project area by Volkert

Because despite what the project name would imply, the “Chickasaw Railroad Lead Line” project is contained entirely within the City of Mobile’s Africatown Planning Area and comes within 160 feet of occupied residences within the Africatown Historic District, as can be seen in the above figure contained within the FRA’s Determination Letter supporting documents, MEJAC has decided to refer to the project by what it is – a Port of Mobile railyard expansion project within Africatown, the Africatown Railyard Expansion Project.

Based on the invitation for public interveners by the FRA in its Determination Letter, the AHPF took the opportunity to intervene as the first consulting party on behalf of the National Park Service’s Africatown Historic District, which is protected by the National Historic Preservation Act and its Section 106, requiring, among other things, that projects with impacts on national historic districts to consult with parties representing the interests of those districts to ensure that potential impacts are appropriately quantified and mitigated, if necessary.

The AHPF also shared the information and documentation they received with MEJAC and many other community partners. In response, MEJAC, residents, and partner groups produced the following “Key Concerns about the Port of Mobile’s Africatown Railyard Expansion Project” brief to provide as much context to partners as well as the project management team at ASPA, Volkert (the project’s engineering consultants), and US FRA, through which the federal grant dollars paying for the project are administered.

A preliminary meeting was held with AHPF, ASPA, Volkert, and US FRA on Thursday, November 2, 2023 at which all parties agreed to further community engagement. Some questions contained within the following brief were answered during that meeting but most questions are outstanding, as are critical questions about how the project will impact both the Africatown Historic District, its residential integrity, and its residents.

Flyer for a Railroad Community Meeting in Africatown

The AHPF, the Mobile County Training School Alumni Association, First Hopewell Missionary Baptist Church, Yorktown Missionary Baptist Church, the Africatown~CHESS group, and MEJAC all agreed to host a Railroad Community Meeting on Thursday, January 4 at the Robert Hope Community Center at 850 Edwards Street in Plateau Africatown from 5:30-7:30p, the flyer for which you can see to the right.

Additional community meetings hosted by ASPA and US FRA will happen soon, as well, though dates haven’t been finalized just yet.

In the interest of sharing as much information ahead of the meeting as possible, MEJAC is publishing the entire “Key Concerns about the Port of Mobile’s Africatown Railyard Expansion Project” brief here without dramatic amendment since its original assembly.

To its credit, the Alabama State Port Authority has been forthcoming with all requested information since the FRA’s August letter was shared, which has been very helpful for advocates and residents. Reflecting the additional information and context, an ADDENDUM to this “Key Concerns about the Port of Mobile’s Africatown Railyard Expansion Project” brief is forthcoming.

Key Concerns about the Port of Mobile’s Africatown Railyard Expansion Project

Table of Contents:

1. Critical Outstanding Questions about ASPA’s Africatown Railyard Expansion Project
2. Africatown Background – Africatown Organizes for Much Better Environmental Justice Community Engagement from Federal, State, and Local Authorities
   1. The Africatown Historic District (est. December 4, 2012)
   2. The Africatown Neighborhood Plan (adopted January 2016 by the City of Mobile)
   3. Africatown Public Comment to ASPA’s Mobile Harbor GRR Ship Channel Enlargement Project (January 2016-June 2019)
   4. The Africatown Connections Blueway Place of Baptisms Point Of Interest (est. by Spring 2018)
   5. The Africatown and Africatown Safety Zone Overlays (est. July 2022)
   6. AHPF EPA EJ Collaborative Problem Solving Grant Application (January 2023)
3. Assessing Where the Goals of Federal Environmental Justice (EJ) Programs and the Justice40 Initiative (Justice40) Fit Into the Project
   1. EJ & Justice40 Background
   2. Africatown Environmental Profile
      1. The Africatown Planning Area Is Overburdened by Industrial and Mobile Pollution Sources
      2. The Closest Mobile County NAAQS Air Monitor is More than 3 Miles Away from Many Africatown Residences
      3. Africatown Contains a Huge Concentration of Title V Permitted Facilities and Mobile Sources of Air Pollution
      4. EJ Screen Mapping Data for Africatown Should Raise Concerns for Federal Grant Applicants and Reviewers Alike
      5. Despite Multiple Critical Rail Incidents in Africatown since 2000, Mobile County Apparently Lacks a Chemical Incident Emergency Response Plan
         1. Early 2000s – A Chlorine Derailment and Release
         2. May 2018 – A Polyacrylamide Emergency, Release, and Evacuation
         3. July 2023 – A Large Warehouse Fire Burns for Weeks but Africatown is told the Chickasaw Air Monitor Says Africatown Air is Fine
   3. Rail Project-Specific Relevant Federal Data and Information Gaps
      1. Justice40 Rail Explorer Mapping Data Raises Pollution Concerns
      2. Africatown Railyard Expansion CRISI Proposal was Never Offered to Africatown Stakeholders for Review
      3. Regular Information Channels Curated by the FRA and ASPA Failed to Provide Information about the Africatown Railway Expansion Project
      4. On “Fair Treatment”, “Meaningful Involvement”
      5. On “40% of the Overall Benefits”
4. Working with Available Data (The Phase 1 Archeological Survey & Alabama Historical Commission State Historic Preservation Office Section 106 Project Review Consultation Form)
   1. A Closer Look At Proximity to Homes and Assets of the Africatown Historic District
      1. Historic 308 Chin Street, Less Than 160 Feet from the Railroad Tracks
      2. Historic Mobile County Training School Athletic Field, Less than 310 Feet Away from the Tracks
      3. Historic 1133 Jakes Lane, Furthest Away, Still Less Than 1,320 Feet Away
   2. Archeological Report Assertions Regarding Locomotive Traffic Levels Potentially Contradict the Project Purpose
   3. Contrary to the Project’s Phase I Cultural Resources Survey, Project Noise Concerns Warrant Mitigation Both During Construction and After
   4. Potential Visual Impacts to the Africatown Historic District Viewshed Appear Totally Unacknowledged in Phase I Cultural Resources Survey
   5. Increased Railyard Traffic Means Increased Air Pollution from Locomotive Engines and their Uncovered Contents
5. ADDENDUM – FORTHCOMING

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