Second Public Comment in Opposition to Union Pacific Second Mainline Track Proposal

 

This is the text of a letter sent via email September 13, 2016 to the Wasco County Planning Commission.

Volunteers Kris McNall and Charles Young, Board member Phil Evans, and advisor Craig Funk contributed to this effort.

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Dear Chair and Commissioners,

This letter is the second public comment on the proposed Union Pacific Second Mainline Track from Mosier Fire District (MFD).

After further study of the proposal and its impacts, I am writing as MFD’s risk management professional, supplementing and amplifying comments made previously from the Board.

Our previous letter raised four categories of concerns:

  1. Railroad caused Wildfires
  2. Hazardous Material (HAZMAT) Movement
  3. Pedestrian Safety and Emergency Access to the North Side of the Tracks
  4. Noise

The sum of my comments is that the west segment of the project, from Mosier Creek to the Hood River County line, poses unacceptable risk to MFD in each of these four categories and must be disallowed. The middle and east segments of the project described under Alternative C, Option 2, might be considered if the issues raised in our letter of August 25 are addressed in a transparent and verifiable manner. However, until a plan for mitigating risk is developed and agreed upon by local response agencies, we respectfully request that the commission deny all segments of the UPRR Second Mainline Track Project.

There are two main reasons for my focus on the west segment of the project:

First, the majority of MFD, including City of Mosier, is downwind of the west segment, so issues created by the project as a whole are magnified for this segment. Fire moves downwind, hazmat blows downwind. The west segment increases upwind risk to our school, downtown core, and many more homes than the middle and east segments. (See Mosier Fire District Map, attached; note that purple dots represent built properties, the reason the fire district exists, and that our prevailing wind is typically from the west-northwest.) Second, the west segment runs through the downtown core of Mosier so the proposed double track would directly affect access to the north side of the tracks and increase noise in the city.

In addition, the following operational and safety concerns were not fully explored in the August 25 letter.

Opposing train traffic at operating speeds creates the risk of accidents involving higher kinetic energy and greater potential damage from fire and/or hazardous materials release than if a single train has an accident. Placing that risk upwind of the majority of MFD, including the City of Mosier, and at the bottom of a slope which will accelerate fire behavior (http://www.hoodrivernews.com/news/2012/sep/28/milepost-66-fire-contained/), while cutting off our access via Interstate 84 and the Twin Tunnels Trail, sets the Mosier Fire District up for a disaster far worse than the one we narrowly escaped last June 3 (http://www.spokesman.com/stories/2016/sep/04/fire-chief-jim-appleton-lesson-of-derailment-ban-o/).

The City of Mosier and the Fire District are interdependent. The Fire District draws both its tax base and its volunteers from the Mosier area. Although technically outside the jurisdiction of the Planning Commission, the safety, vibrancy, and resilience of the City of Mosier must be factored into your decision and I aim to give you a basis to do so. Boundaries assumed by the Scenic Act aren’t relevant when assessing risk or fighting fires. Risk is risk, and the increased risk imposed by a double main line through and to the west of the City of Mosier creates an unmanageable responsibility for the Fire District.

The double main line would impact the City of Mosier with economic damages and permanent harm to a right of quiet enjoyment, in a way that has not happened since Interstate 84 was built sixty years ago, and, indeed, only a handful of times prior going back to the 1840’s. If the core of our community becomes less desirable both for residents and visitors, that negatively affects the fire district’s ability to provide services district-wide, and cannot be allowed to happen. It is a flaw of the planning process that these externalities are not factored at all into the proposal or your decision, and so the emphasis here necessarily focuses on safety, but MFD cannot ignore the consequences of harm to our tax base.

Mosier is deep into a planning process which stands to bolster transportation and development well into the foreseeable future, a new fire station and City civic center being but one example. All of this investment in our future will be put at risk by the added safety concerns, noise and other impacts of a double main line.

In conclusion, I uphold and restate our concerns for the project as a whole, while categorically rejecting the west segment for the reasons stated. In my opinion, it is not possible to mitigate the increased risk of the west segment of the project to render it acceptable. The remaining segments should be evaluated under the considerations raised in MFD’s August 25 letter. Under Alternative C, Option 2, Union Pacific achieves at least 60% of its efficiency goals while saving the cost and remediation requirements of the west segment, without significantly changing the negative impacts of idling trains in the City of Mosier. Moreover, Alternative C, Option 2 results in Union Pacific’s longest passing zone (15,682 feet) between Portland and The Dalles, clearly shifting any concept of “bottleneck” elsewhere.

/s/

Jim Appleton, Mosier Fire Chief

Letter in Opposition to Union Pacific Second Track

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 2.2.4.2 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.

4. Noise

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

Regards,

/s/

Darin Molesworth

Mosier Fire District Board President

Fire Season in Effect

Effective 12:01 a.m., PDT, June 3, 2016, Oregon Department of Forestry declared Fire Season was in effect.

Effective immediately, Mosier Fire District will be restricting all issued burn permits. The restriction will prohibit all outdoor  burning operations.

This restriction on issued burn permits is a result of recent observed fire behavior and current fire danger indicators. Mosier Fire District will not be issuing any new burn permits until after this year’s fire season.

Please note that failure to follow all the rules on their permit or violate the burning restriction could result in individuals being liable for all costs associated with a response to their operation.

For questions regarding this restriction or any burn permit questions, please contact Kris McNall at 541 478 3333 or kris.mcnall@mosierfire.com

Open Burning Allowed 10/28

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As of 7:00 AM Wednesday, October 28, open burning will be allowed in the Mosier Fire District.

No inspection will be required.

Burning permits are required.

Please read and follow the terms of the permit.   In particular, use good judgment, don’t burn on windy days, don’t burn garbage or plastics, and be sure burn piles and barrels have proper clearance – forty feet from buildings and twenty feet from trees or shrubs, and ten feet cleared down to mineral soil.

Daylight hours only.  Please be sure your piles are down to coals by sunset.

For further information, or to request a free, automatically renewing burn permit, contact the Fire Chief at 541-478-3333, mosierfire@gmail.com.  Residents of the City of Mosier please call the City Hall to request a permit.  541-478-3505.

Please burn safely.

A very special thank you to all the fine folks in Mosier who helped keep this remarkably dry year remarkably free from fires.  Good fortune and a community effort kept us safe for another year.  On behalf of the Fire District Board and Volunteers, thank you all for doing your part.

And please don’t forget to ensure fire safety in and around your home in winter, especially overloaded extension cords and other electrical hazards, which account for a high percentage of preventable house fires.

See our website for tips on electrical and home heating safety from the State Fire Marshal.

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Controlled Burn on Washington Side 10/9/2015

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Subject to conditions, USDA Forest Service has announced they will conduct a controlled burn across the Columbia River from Mosier today.

The proposed fire is located on Courtney Road, just west of the Syncline and directly across the River from the City of Mosier.

If the burn proceeds, it should be much like last year’s controlled burn near Tom McCall Point.  Expect considerable smoke and open flame visible from much of the Mosier area.  The same teams have an excellent track record for safety and caution.

BURN RESTRICTIONS REMAIN IN EFFECT IN HOOD RIVER AND WASCO COUNTIES.

OUTDOOR BURNING IS FORBIDDEN UNTIL OREGON DEPARTMENT OF FORESTRY LIFTS THE SEASONAL BURN BAN.

If you have any questions or concerns, please contact the Fire Chief at 541-478-3333.

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Grass Fire to the East, on the Washington Side

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At about 12:30 PM today, Sunday, September 13, a fire was reported on the Washington side, well east of the Mosier area.

The origin is reported to be at least one mile east of Hwy 197 and north of Hwy 14.  That’s over fifteen miles east of the City of Mosier.  Winds are strong from the west, blowing away from us.

No indication at this time of size or cause.

A large column of smoke may be seen from parts of the Mosier area, and may appear closer than it is.

At this time the fire is not a threat to the Mosier community.  None of our resources are responding at this time. Local crews are well-seasoned in fire fighting over the same ground.

This site will not update unless relevant to the Mosier Fire District.

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Smoke, no fire

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UPDATED AUGUST 26, 2015:

Here is a link to a Washington State University website showing a graphic, animated forecast of smoke conditions in Oregon and Washington.  Many thanks to Cliff Mass at UW for the tip.  The smoke page is now added to our blogroll of links.

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The heavy smoke settling over much of the area is coming from fires in Washington.

There is no cause for concern in Mosier at this time, other than the air quality issue.  Exposure to this level of smoke can be an irritant, and some people may risk breathing difficulties.  Residents are advised to avoid exposure if possible.

Looking at the forecast, we may experience this level of smoke or greater over the next few days.

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