This is the text of a letter sent to the Wasco County Planning Commission in reference to the Sept. 6, 2016 public hearing on Union Pacific’s proposed track modifications in and around Mosier.
The letter is not included in the public documents, so we provide it here for the record.
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Dear Chair and Commissioners,
As President of the Mosier Fire District Board, I write on behalf of myself and the Mosier Fire District to express our concerns regarding the proposed Second Mainline Track through the Mosier Fire District.
The Mosier Fire District is responsible for the provision of Fire and Emergency Services for the length of the proposed new track, and therefore we look at the project with an eye to the public safety risks that we anticipate in construction and operation of a proposed second track.
We are particularly concerned about four issues and are interested in the planned mitigation for these risks.
Railroad caused Wildfires
There have been many railroad caused wildfires in the Mosier area over the years, with the most recent being in June of 2016.
Ignition sources have included locomotive exhaust, rail car brakes, wheel / rail friction, rail car derailments, and several of undetermined causes. Our understanding is that the number of potential ignition sources increases with both the number of locomotives and rail cars as well as the speed of the locomotives and cars..
It is stated in the narrative (http://co.wasco.or.us/planning/landuse_actions/UPRR_PLASAR-15-01-0004/02_ProjectNarrative.pdf) that the purpose of the project is to increase ‘efficiency’. Furthermore, this report states that “the vicinity of the City of Mosier yielded the lowest average train speeds.” We presume that this means that there would be more rail cars and higher speeds through the District, leading to an increased risk of wildfire ignition.
The narrative also describes: ‘UPRR typically moves 20 to 30 trains a day through the project area, and anticipates a similar number of daily trains with implementation of the proposed project’ without identifying what ‘similar’ means in this context nor quantifying the absolute number of rail car movements.
The Mosier Fire District’s resources have been overwhelmed by several railroad caused fires in the past. We would like to understand UPRR’s mitigation proposal for this increased fire risk as we struggle to meet the demands of the current situation. It is difficult for us to even quantify the increased risks as we do not have a clear understanding of either the change to the number of rail cars moving through the District, or the speed of these cars.
We are also concerned about the risk in construction work performed during fire season. Movement of heavy equipment, construction techniques such as welding, etc are well understood ignition risks. We would like to understand UPRR’s mitigation proposal for wildfire ignition during construction.
2. Hazardous Material (HAZMAT) Movement
With increased cars per hour, and potentially increased speeds (the narrative describes speed only in terms of ‘to allow for trains to pass at standard operating speed’) there is an increased risk of a HAZMAT release.
We have recently seen the result of a best-case release from a unit oil train where only 16 cars derailed and 4 cars released material. This event occurred with a single train moving at less than 30mph on a piece of track with excellent road access. This incident is considered best case due to the lack of usual wind, the easy access to the derailment site, the capture of much of the leaking oil by the coincidental location of Mosier’s waste water system, and the relatively low speed of the derailment event.
It is not difficult to imagine a derailment event that occurs in a different location on the new double track at higher speed, two trains are involved, there is very difficult access, and the wind is blowing with its usual intensity.
Mosier Fire, and its mutual aid partners were overwhelmed very quickly during the Mosier Unit Train Derailment—which was a best case HAZMAT event. Resources came from all over the US to work on the response. UPRR was (and should be) commended for their willingness to expend resources in cleaning up the material. However for the first several hours, there were not local resources available to prevent material from escaping into the environment. It was a matter of luck that the spill was largely contained by a series of unlikely coincidences.
We would like to understand UPRR’s strategy for mitigating the existing risks for HAZMAT release post the Mosier derailment, and how these mitigation strategies change for the proposed double track.
3. Pedestrian Safety and Emergency Access to the North Side of the Tracks
In section 18.104.22.168 Existing Safety Concerns the project narrative document identifies the risk that pedestrians trespassing on the UPRR right of way to gain access to the Mosier Creek area are at risk of being struck by trains.
One mitigation for this risk is to run fewer trains through that area: ‘Operating fewer and longer trains reduces safety risks associated with collisions at pedestrian or vehicle crossing locations…’ however this seems to contradict the previous assertion that UPRR would be running a ‘similar’ number of trains. This assertion is also contradicted by various statements in meetings by UPRR staff where they mention 20-30% more trains.
We agree that there is a risk of pedestrians being struck in this area. It is a mile walk each way from Mosier Creek to the only designated pedestrian crossing area then back to the beach at the confluence of Mosier Creek and the Columbia River.
Pedestrians regularly illegally cross the tracks at this location to access the Mosier Creek beach.
Similarly, responders who need to access the Mosier Creek beach vicinity must either walk a mile down the path from Rock Creek or cross the tracks. During the Mosier Unit Train Derailment, the Rock Creek access was closed due to the fire and there was no way for responders to access the north side of the tracks. Had anyone been walking or swimming in the area of the mouth of Mosier Creek they would have been unable to return to Mosier as there was a train on the tracks.
Construction of a pedestrian crossing of the rail track(s) at Mosier Creek will help to mitigate both recreational and responder access MFD believes that such an additional crossing would help to reduce potential issues and to create a workable plan for emergency access in this critical location.
At all other locations, a second track will increase the probability that MFD responders would need to access the opposite side of the tracks when a train is between them and the incident. Mosier needs a plan for such access covering the entire length of the double track. That plan should include details on how to safely respond during any construction of a second track.
A significant concern with rail traffic in Mosier is the noise generated by the trains. The World Health Organization website states that “Excessive noise seriously harms human health and interferes with people’s daily activities at school, at work, at home and during leisure time. It can disturb sleep, cause cardiovascular and psychophysiological effects, reduce performance and provoke annoyance responses and changes in social behaviour.” Our responders are invested in the health and safety of our community.
We would like to understand what plans UPRR has for reducing railroad noise levels within the City of Mosier.
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Mosier Fire District is a great supporter of transport by rail. Per unit of goods moved it is safe, efficient, and has fewer associated risks than most other transport modes. In addition, UPRR has been a great neighbor and partner in the development of Mosier as a community over the past hundred years or so.
However Mosier Fire District, without understanding and agreeing with specific and verifiable risk mitigation strategies for the issues described above, cannot at this time support the double track. Until a plan for mitigating risk is developed and agreed upon by local response agencies, we respectfully request that the commission deny the UPRR Second Mainline Track Project
Mosier Fire District Board President