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

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

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 sponsored by the Africatown Heritage Preservation Foundation, First Hopewell Missionary Baptist Church, Yorktown Missionary Baptist Church, the Mobile County Training School Alumni Association, the Africatown~CHESS group, and MEJAC.

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

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Africatown Studios and Substantial Justice: The Good, The Bad, and the Ugly

If any one message has remained consistent coming from both Africatown residents and stakeholders since MEJAC was founded 10 years ago in 2013 by Africatown residents in partnership with community stakeholders and regional advocates, it is the recognition that the community needs systematic economic development that is neither polluting nor disrespectful to the community’s residential heritage as having developed from a group of survivors who were illegally trafficked as enslaved people into the United States in 1860.

The Africatown Studios artistic rendering, as offered on the Africatown Studios website

An Africatown Studios artistic rendering, as offered on the Africatown Studios website

An idea is being shopped to the community that claims it would do exactly that and with no down sides, and it is was presented to the community as “Africatown Studios” in a meeting that presented an exciting promise of jobs and economic stabilization to some and a deeply problematic boondoggle to others. The roll out has been nothing short of polarizing, and many long-term advocate Africatown community organizations are praying the polarization isn’t the point of the project promotional exercise.

Several Africatown residents attended and community stakeholders the meeting held by Africatown Studios proponents on Saturday, March 4 at the Robert Hope Community Center. The meeting won support from some of those present but easily just as many were left with lingering questions and concerns while a few rejected the proposal outright. Some residents left unhappy with how the meeting was conducted while many residents simply couldn’t make the meeting due to not hearing about it until a day or two before it was conducted.

Another presentation of Africatown Studios was made to the Africatown Redevelopment Corporation monthly meeting on the evening of Tuesday, March 7, which reinforced some concerns from residents and stakeholders unhappy with the public engagement process for the project.

MEJAC encouraged all those who came to our organization with concerns to write them down, think about them, and seek feedback from friends and family. We discussed them and decided what questions we would simply publish on our blog in this fashion to the developers and promotional team of Africatown Studios and the broader interested public.

This isn’t simply a gish gallop debate tactic for us but we wish to seriously consider the proposal with the goal of there being a respectful prospective partnership conversation between hesitant residents and the developers and also to make what our members have learned so far from Africatown Studios developers and promoters transparent to others.

To hear more and to better understand not just the potential economic benefits and burdens of the project but also its cultural purpose is critical, because that reflects the values with which we feel prospective community developers should engage Africatown.

If we have misinterpreted or mischaracterized previous statements made by the Africatown Studios project promoters, we invite them to help us better understand.

We also want residents and stakeholders to have a clear understanding of their right to public participation well before and during any permitting phase for the Africatown Studios project, as we would for any project of this scope and magnitude in any environmental justice community in our region. Where zoning designations must be changed or variances sought to make the project conform with protective standards for vulnerable Africatown neighborhoods, the Substantial Justice of the changes must be proven.

We invite the Africatown Studios project promoters to not jump to any conclusions about where MEJAC stands.

This post is broken up with narrative background and questions generally falling under the following headings:

  1. Why Is Africatown Studios Being Proposed?
  2. Substantial Justice: What all does the Africatown Studios Flyer Say?

    1. Location Background
    2. Land Use and Zoning Background
  3. How’s Community Engagement Been So Far?
  4. The Good: Who Will Africatown Studios Benefit and How?
  5. The Bad: What Risks would there be for Residents?
  6. The Ugly: Why Was the Community Told Houses Can’t Be Built There?
  7. What’s Next? How Does the Community Weigh in?

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