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NEC FUTURE

Tier 1 EIS

Tier 1 Final EIS

Volume 1

10. Phasing and Implementation

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Table of Contents

10.1 Introduction

The Preferred Alternative described and evaluated in this Tier 1 Final EIS is the Federal Railroad Administration’s (FRA) recommendation, which does not constitute a final decision for selecting an alternative for NEC FUTURE. This chapter, therefore, provides information on phasing and implementation of the NEC FUTURE investment program to be selected by the FRA in the Record of Decision (ROD); the term “Selected Alternative” in this chapter refers to that alternative selected in the ROD.1 The system-wide benefits of the Selected Alternative will only be realized with implementation of numerous interrelated projects. The scope, complexity, and interrelatedness of these projects will require thoughtful and well-coordinated planning over time. While individual projects can address specific chokepoints or other localized needs, it will take groups of projects stretching across the Northeast Corridor (NEC) to generate the desired corridor-wide benefits.

Given the scale of this effort, the FRA identified a set of principles for the incremental implementation of the Selected Alternative vision (see Section 10.2). These principles are intended to guide further coordination and collaboration with the stakeholder states, Washington, D.C., and railroad operators regarding project phasing and implementation.

Chapter 10 of the Tier 1 Draft Environmental Impact Statement (Tier 1 Draft EIS) (Volume 2) presented a representative initial phase of projects that would be implemented with any of the three Action Alternatives.2 Public and stakeholder comments on this chapter and more generally on implementation phasing emphasized the importance of achieving near-term improvements through incremental phases and the need for a process to develop a list of projects to be included in an initial phase of the NEC FUTURE investment program.

The FRA has not defined an initial phase for the Preferred Alternative described in this Tier 1 Final EIS, nor does the FRA intend to define an initial phase in the ROD for the Selected Alternative.

The FRA will work collaboratively with the NEC states, railroad stakeholders, and the Federal Transit Administration (FTA) to develop a list of projects to be implemented in an initial phase of the Selected Alternative (Initial Phase). Participation by these key stakeholders in defining an Initial Phase is critical to establishing a framework for working together to achieve common goals. The list of projects to be implemented in this Initial Phase will be documented in the Service Development Plan (SDP).3

This chapter describes the FRA's proposed approach to working with stakeholders to define an Initial Phase as well as FRA's proposed approach to carrying out subsequent Tier 2 project studies or other planning processes necessary to implement the Initial Phase.

10.2 Principles for Phasing and Program Implementation

The pace of implementation and phasing of the Selected Alternative will depend on many factors, including funding and financing availability, environmental approvals, market growth, regional cooperation, and practical operating constraints.4 However, each phase will require extensive coordination between the NEC stakeholders to plan and fund projects, as well as to implement them in an organized and sequential way that achieves benefits and allows for continued operation on the NEC. The FRA proposes the following set of key principles to guide the collaboration and development of incremental phases:

  • Stakeholder Collaboration - The FRA will collaborate with the NEC states and Washington, D.C., railroads, and the FTA, to achieve service objectives. As a first step in this process, the FRA established an NEC FUTURE SDP Working Group, described below, to focus on developing the Initial Phase to be included in the SDP. The FRA expects to carry this collaboration forward to advance future phases of the Selected Alternative.
  • Building an Integrated Rail Network - The FRA's focus is on developing an integrated rail network, offering coordinated and complementary Intercity and Regional rail services. This network approach would shape the definition of service outcomes and scope for each incremental phase of improvements. The scope and sequencing of projects would generate corridor-wide service benefits for all users of the rail network. For example, while adding trans-Hudson capacity would improve service between New York City and New Jersey, other improvements would be required across the NEC to achieve the full benefits of that new capacity for both Intercity and Regional travelers.
  • Leveraging Current and Planned Investments - The Initial Phase, and subsequent phases of the Selected Alternative, should build on ongoing and planned investments in the NEC to replace aging infrastructure and eliminate chokepoints. These investments include funded or committed projects identified in the No Action Alternative as well as Related Projects with less certain funding status but which are equally essential to the NEC.5 Examples of ongoing or planned projects include the following:
    • Ongoing/current construction activity:
      • Third-Track Expansion in Delaware
      • High-Speed Rail Improvement Project in New Jersey
      • Harold Interlocking in New York
    • Planned improvements:
      • Baltimore and Potomac (B&P) Tunnel and Susquehanna River Rail Bridge in Maryland
      • Baltimore-Washington International (BWI) Station in Maryland
      • Portal Bridge in New Jersey
      • Hudson River Tunnel in New Jersey/New York City
      • Norwalk River Bridge in Connecticut
      • Providence Station in Rhode Island
      • Boston South Station Expansion in Massachusetts

These projects alone will not fully address the reliability and capacity constraints currently faced on the NEC, but combined with other upgrades will achieve corridor-wide objectives.

  • Achieving Meaningful Service Benefits - Each phase should achieve specific service benefits, broadly defined to include one or more of the following:
    • Accommodation of Intercity and Regional Rail Demand - Each phase should address measurable service objectives in response to underlying demand for passenger rail service projected at the completion of the phase and support future phases with minimal reconstruction.
    • Increase in Connectivity - Phases should enhance connectivity and integration within the NEC and its connecting corridors-such as easier and more-timely transfers between NEC Intercity and Regional trains and across the broader Northeast region with more-frequent connections to other rail corridors and transportation services. These enhancements will require increases in capacity, additional equipment, and improvements at stations, as well as efforts by railroad operators to coordinate the scheduling of trains.
    • Improvement in Service Reliability - Phases should focus on addressing specific groups of chokepoints and other causes of system-wide failure that undermine reliability, such as improvements to the electrification and signal systems or replacement of movable bridges prone to failure. Replacement of aging infrastructure and elimination of chokepoints will significantly improve the on-time performance of train service, and minimize system failures and safety risks. In addition, with a more reliable railroad, the "schedule pad," built into Intercity and Regional train schedules to accommodate possible delays, can be reduced to improve trip time.
    • Reduction in Travel Time - Phases should support Intercity and Regional trip-time objectives identified for the Selected Alternative. These trip-time improvements require chokepoint relief, curve modifications, and capacity improvements to generate faster train speeds and travel-time benefits. Specific chokepoint improvements, elimination of schedule pad, and reduced dwell time at stations could also improve Regional rail travel times.
    • Customer Enhancements - All phases should include the benefits associated with making travel across the NEC network seamless and more convenient for rail passengers-from planning for travel to paying for tickets, and making connections and transfers to trains. This may include a common fare medium for all NEC train services; integrated schedules for the NEC rail operations; or coordinated transfers between different Regional operators and between Regional and Intercity trains.
    • Operational Efficiencies - Stakeholders should further investigate opportunities to reduce capital and operating costs. Articulating service benefits for each phase will ensure that the public understands the rationale for work elements and the associated improvements to rail travel.Examples of concepts warranting further investigation include the following:
      • Slot-based train operations to regularize schedules and operations
      • Improvements to standardize dwell time at stations
      • Through-service at Washington Union Station and Penn Station New York to reduce the number of train movements
      • Standardization of train equipment across the NEC to optimize performance, maximize carrying capacity, and reduce the cost of buying and maintaining train equipment
  • Accommodating the Full Build Configuration - Program phasing may require the incremental implementation of individual projects (e.g., adding only one of the two tracks required to complete the Selected Alternative within a certain timeframe). In implementing an incremental approach, project studies should consider future infrastructure necessary to achieve the full benefits of the Selected Alternative. In some cases, this may mean building for the future infrastructure configuration even if not fully required at the time. In other cases, it may require a design that can accommodate the changes necessary to achieve the final configuration. The FRA, key stakeholders, and project sponsors should discuss and seek agreement on ways to preserve this ability to implement fully the Selected Alternative.
  • Providing Flexibility to Accommodate Future Options - The Study Area travel market is dynamic. Opportunities may arise to use public-private partnerships and other approaches to enhance or leverage specific segments of the Selected Alternative. Allowing for flexibility in program phasing to accommodate public-private partnerships that have defined commercial objectives, may lead to prioritizing phased improvements focused on specific market segments.
  • Minimizing Construction Impacts on Rail Traffic - The design and sequencing of project work should minimize adverse impacts on ongoing rail passenger and freight operations. Minimizing impacts may require building off-corridor segments of work first, adding run-around tracks, and, in some cases, shutting down operations to permit a concentrated, shorter period of disruption compared to working around limited track outages.

10.3 Stakeholder Collaboration

Advancing the Selected Alternative will involve a diverse set of public- and private-sector entities, including railroad owners and operators, federal, state, regional, and local governments, and potential private-sector partners. Therefore, planning and design for the Selected Alternative will require diligent coordination and long-term collaboration among these stakeholders to ensure that each project benefits from and works in tandem with others. Minimizing construction impacts to ongoing train operations requires disciplined management of resources and track outages. The FRA will work with key stakeholders on phasing, funding, and construction of the improvements, as well as on how best to manage train operations with improvements to achieve the full benefits of investment.

In June 2016, the FRA established the NEC FUTURE SDP Working Group (Working Group). Its members include the Northeast Corridor Commission (NEC Commission) and staff from the NEC states, Washington, D.C., and railroads with experience in capital planning and project delivery. The Working Group will provide information to help the FRA define and advance an Initial Phase. This work includes defining service increment objectives for the Initial Phase, the sequencing of improvements, and a schedule for implementation. Upon publication of the FRA's ROD, which will complete the Tier 1 National Environmental Policy Act (NEPA) process, the Initial Phase for the Selected Alternative will be detailed in the SDP. The SDP, scheduled for completion in 2017, will address several issues relating to implementation of the Selected Alternative and will:

  • Summarize the transportation and economic benefits.
  • Quantify the net benefits (benefit cost analysis).
  • Lay out an implementation approach.
  • Detail the Initial Phase and how it would be implemented.
  • Quantify annual funding requirements.

The Working Group will be an important platform to integrate and coordinate the Initial Phase with other activities of the NEC Commission and the individual railroads, states, and metropolitan planning organizations (MPO).

10.4 Initial Phase Next Steps

The FRA recognizes the commitment, cooperation, and resources necessary to implement the Selected Alternative and the effort necessary to build consensus among the various stakeholders, differing local priorities, and variety of projects involved, particularly when considered in light of funding limitations. Advancing an Initial Phase in this complex environment will require the commitment of NEC stakeholders to the following:

  • Determining the objectives and scope of the Initial Phase and on how best to fund, implement, and sequence the work
  • Addressing institutional and legal issues regarding the planning, funding, and construction of corridor-wide improvements
  • Developing construction staging plans to minimize impacts on existing train service and customers
  • Ensuring that individual projects included in the Initial Phase, advanced as Tier 2 project studies or as separate planning studies, are consistent with the service objectives for the Selected Alternative

As noted above, the FRA will collaborate with the Working Group to make constructive progress on these issues.

10.4.1 Initial Phase Objectives and Scope

As described in Section 10.3, the Working Group, established as a forum for stakeholder and FRA collaboration, will work together to define an Initial Phase. As a first step in this process, the Working Group will identify measurable service objectives and projects necessary to achieve the service benefits associated with an Initial Phase. Defining, at a high level, individual project scopes will require careful consideration of the ways in which individual projects are related with one another, identifying those that should be considered together and those that can advance independently. In working through the best sequencing of projects to achieve desired service benefits, the Working Group will also consider how to sequence the projects to minimize impacts to existing railroad operations. Additionally, specific scopes of each project or packages of projects and their sequencing will take into account the availability and timing of funding or financing options.

10.4.2 Institutional and Legal Issues

Successfully planning for, funding, and building infrastructure will require an unprecedented level of additional cooperation and coordination by key NEC stakeholders. The FRA envisions an integrated network of Regional and Intercity services that provide passengers with a more convenient, faster, and seamless traveling experience to more destinations than they can reach today. Advancing this integrated network will involve extensive discussion and coordination between the NEC stakeholders. Numerous legal, governance, and organizational issues may present particular challenges that will require discussion, planning, and negotiation between railroad operators and states; some may require legislative and statutory changes at federal and state levels. The following are examples of the types of issues requiring resolution in support of implementation of the Initial Phase and the Selected Alternative:

  • Expenditure of state funds on corridor-wide improvements
  • Operation of trains beyond an operator's service area and/or into another state
  • Use of access rights agreements, public-private partnerships, and special purpose entities
  • Cost-sharing agreements for multi-state or multi-regional projects (for example, those requiring funding through more than one metropolitan planning organization)
  • Development of phasing plans and prioritizing projects across phases
  • Coordination on future rolling stock specifications and possible corridor-wide equipment purchases
  • Management of operations across the NEC, particularly during construction when capacity may be most constrained

The degree and depth of coordination and planning by the NEC stakeholders will largely determine the success and pace for implementation of the Selected Alternative. The efforts of the Working Group to define an Initial Phase represent an important first step in this long-term process. The FRA intends to take an ongoing leadership role in facilitating resolution of the many issues involved in advancing the Selected Alternative.

10.4.3 Construction Staging and Planning Strategies

Railroad operators have only limited ability to take tracks out of service to make repairs or to implement projects without shutting down or severely limiting ongoing operations. With the NEC already at capacity in numerous key locations, implementing improvements to the NEC without adversely affecting train operations will be challenging. Moreover, construction work must be implemented safely and without impinging on annual maintenance activities and other state-of-good-repair work and priority projects (such as those included in the No Action Alternative). It is essential for the NEC railroads and states to coordinate and plan how and when to implement projects, and to understand and mitigate potential adverse impacts on railroad operations.

The FRA anticipates that the Working Group will be the forum for this planning effort. The NEC railroads have decades of experience planning major work on the NEC, such as the electrification of the New Haven-Boston segment of the NEC in the 1990s, and the recent replacement of the Niantic River Bridge in Connecticut. How much service is affected, the degree to which impacts are acceptable to passengers, and how to conduct construction safely would be important factors in scheduling construction activities. Engagement with passengers through a comprehensive communications program is essential to finding the appropriate balance between the efficient scheduling of construction activities, continued railroad operations, and safe and reliable passenger service.

Chapter 8, Construction Effects, describes typical construction sequencing and potential construction effects. Many of the same approaches and effects would be applicable to implementation of an Initial Phase. Implementation planning should include the following key strategies to minimize impacts to customers:

  • Complementary Projects - Separate projects in an Initial Phase may benefit from coordinated implementation. For example, the projects between Newark, New Jersey and New Rochelle, New York, could be designed to function together to eliminate major chokepoints and increase capacity. Therefore, it would be beneficial to sequence implementation of these projects to achieve desired results. Planning projects together helps to leverage planned track outages, reduce construction time, minimize disruption to service, and optimize benefits upon completion.
  • Minimizing Service Disruptions - Many of the largest and more complex projects considered in NEC FUTURE are new segments. These projects include several major bridge or tunnel replacements, including the New Baltimore Tunnel (B&P Tunnel Replacement) and new tracks in tunnel under the Hudson River (Hudson River Tunnel). Construction of this new infrastructure would not entirely eliminate operational impacts-the new infrastructure must be built in close proximity to and connect with the NEC-but extended impacts could be minimized through night-time and weekend scheduling of work and shorter-term track outages as required.

In contrast, projects such as repair or replacement of electric catenary systems or station improvements would require careful planning and staging to manage any service disruptions. Strategies for managing adverse effects include the following:

  • Coordinating schedules of major projects to reduce extended service disruptions in the same area
  • Sequencing work to maximize the use of available track outages
  • Temporarily suspending service for specific periods to permit the acceleration of work
  • Off-site fabricating and constructing of project components
  • Implementing a public outreach and communications program to ensure passengers are aware of scheduled work and potential service disruptions

    Construction of new parallel segments of track provides the opportunity to relocate existing trains to new tracks before beginning work on upgrades to the existing NEC. Such phasing of construction could provide capital cost efficiencies and reduce impacts. For example, new tracks between Bayview, MD, and Wilmington, DE, could ease replacement of the Bush and Gunpowder Bridges; similarly new tracks could ease replacement of bridges between Stamford and New Haven, CT.
  • Enhancing Train Movement Flexibility - Adding interlockings and signal blocks in proximity to construction areas can greatly enhance the dispatch flexibility to mitigate operational impacts from track outages. During the electrification of the NEC between New Haven, CT, and Boston, MA in the mid-1990s, the addition of a number of permanent and temporary interlockings facilitated the timely dispatching of trains across a 157-mile construction zone in which crews simultaneously worked in up to 12 geographic areas at any given time. This required lengthening trains and adjusting some frequencies; however, the added flexibility enabled train dispatchers to meet performance objectives and keep the trains running.

10.5 The Tier 1 Decision and Transitioning to Tier 2 Studies

Throughout the public comment period for the Tier 1 Draft EIS, stakeholders and the interested public asked the FRA to clarify the next steps after completion of the Tier 1 NEPA process and issuance of a ROD. Additionally, there were several questions about what decisions the FRA will make in the Tier 1 ROD, how those decisions relate to subsequent planning processes, and what role the FRA will play in implementing the Tier 1 decision as memorialized in the ROD.

A benefit of tiering in NEPA is that certain programmatic issues are resolved in the Tier 1 study and therefore do not have to be revisited in Tier 2 project studies. In this way, the Tier 2 project studies are streamlined. The diversity of interests and stakeholders participating in the implementation of the Selected Alternative will require a clear definition of terms and a set of guidelines as to how the Tier 1 decision applies to subsequent Tier 2 project studies. The guidelines will be developed following the completion of the Tier 1 process, through collaboration within the U.S. Department of Transportation (including the FRA and FTA), as well as with the stakeholders who would sponsor subsequent Tier 2 project studies.

In the ROD, the FRA may define the service and performance aspects of the Selected Alternative as a starting point for subsequent Tier 2 project studies. It is the FRA's intent to define these characteristics in such a way as to set standards for use in developing alternatives in Tier 2 project studies. In addition to bringing the NEC and Hartford/Springfield Line to a state of good repair, the following are examples of the types of service and performance characteristics that the FRA may identify as part of the Selected Alternative in the ROD:

  • The service capacity, frequency, type, and travel-time targets along the NEC between Washington, D.C., and New York City, New York City and Boston, and New York City and Springfield
  • Design speed goals of 220 mph for new segments and 160 mph for new and upgraded track on the existing NEC
  • Station function and capacity features

In addition to requiring consideration of specific aspects of the Tier 1 decision in subsequent Tier 2 project studies, the FRA's ROD may identify specific commitments. These commitments would reflect stakeholder and regulatory agency input received during the Tier 1 process. Proposed commitments include the following:

  • Avoiding substantial crossings of National Wildlife Refuges (such as the crossing shown in Alternative 3 in the area of Patuxent Research Refuge) and minimizing impacts to National Wildlife Refuges6
  • Avoiding use of an aerial structure in the historic district of Old Lyme, CT

With the selection of an alternative in the ROD, the FRA will define a roadmap for future investment on the NEC, helping to ensure that investments made by a variety of stakeholders contribute to progress toward the shared NEC FUTURE vision. As appropriate, feasibility studies may be conducted prior to advancing Tier 2 projects to consider location-specific constraints and opportunities. A Tier 2 project study is the next step in the process to advance any project within the Selected Alternative that receives federal funding or requires federal approval, from the FRA or another federal agency such as the FTA. The FRA or another federal agency providing funding for a particular project will not make decisions in the ROD about specific alignments, infrastructure, facilities, or equipment. The FRA or another federal agency providing funding for a particular project will evaluate specific locations for new segments as part of the Tier 2 project studies, prior to making any decisions regarding new segment locations.

As a cooperating agency in the Tier 1 NEPA process, the FTA may issue its own Tier 1 ROD. In its ROD, the FTA could include any particular caveats or limitations that may be important to the FTA based on its statutory authority or regulatory requirements. Of particular relevance are the FTA requirements for coordination with MPOd as part of its grant-making process. Regardless of the nature of an FTA ROD, ongoing coordination with MPOs in the Study Area will be necessary for candidate Tier 2 project studies funded by the FTA.

10.6 Role of the FRA

Beyond the influence of the Tier 1 decision on subsequent Tier 2 project studies, a key element of success for NEC FUTURE is ongoing leadership. The FRA is committed to a continued leadership role to advance the NEC FUTURE investment program laid out in the Selected Alternative. The previously referenced Working Group exemplifies this ongoing commitment of the FRA to work with states, railroads, and other stakeholders to transition from this environmental planning process to project-specific actions.

The FRA will review projects requesting FRA funding for consistency with the near-term objectives of an Initial Phase and the longer-term vision described in the ROD. The FRA anticipates an ongoing role in working with stakeholders to balance individual needs and resolve disagreements where stakeholder priorities are in conflict with one another or with the Selected Alternative. The FRA will encourage recipients of FRA funds to consider consistency with the ROD for those projects on or affecting the NEC and Hartford/Springfield Line whether or not they are seeking federal funding.

The FRA has a long history in planning and leading upgrade initiatives on the NEC. In 1976, it completed the first Northeast Corridor Programmatic Environmental Impact Statement, evaluating plans for rebuilding the NEC following transfer of the NEC from the Penn Central Railroad to Conrail and Amtrak. Between 1977 and 2003, the FRA directly managed the Northeast Corridor Improvement Project, investing some $1.8 billion in new NEC infrastructure. Between 1994 and 2000, the FRA oversaw Amtrak's work to complete NEC electrification between New Haven and Boston, upgrade the northern end of the corridor, and introduce Acela Express high-speed trains to NEC operations. Since 2009, the FRA has led or supported numerous initiatives on the NEC funded through the American Recovery and Reinvestment Act and under the High-Speed Intercity Passenger Rail Program, including NEC FUTURE.

Following completion of NEC FUTURE, the FRA intends to continue in a leadership role in advancing implementation of the Selected Alternative. The FRA will work with the NEC Commission, the NEC states, Washington, D.C., railroads, and other stakeholders to define the need for federal funding to support implementation of the Initial Phase, as well as to explore other funding and financing options. The Tier 1 EIS makes clear the critical importance of the NEC to the economic vitality and competitiveness of the Northeast, and by extension to the global competitiveness of the United States. Developing a national program to implement the Selected Alternative will be an important priority for the FRA and the U.S. Department of Transportation. In the event Congress provides a source of federal funding for implementation of the Selected Alternative, the FRA could lead the planning and application of that funding and help to facilitate the coordination with stakeholders necessary to advance the work.

The FRA will lead or participate in efforts to implement the Selected Alternative, including the following:

  • Develop the SDP for implementing the Tier 1 decision.
  • Convene an NEC FUTURE SDP Working Group to define the Initial Phase.
  • Work with the NEC Commission to advance and implement their 5-Year Capital Plan and to ensure its consistency with the Selected Alternative.
  • Work with NEC states, Washington, D.C., and railroads, as well as with the FTA, to plan and prepare for subsequent Tier 2 project studies required to implement the Selected Alternative.
  • Serve as lead agency in the Tier 2 process for individual projects when FRA funding or other FRA approval is required.
  • Serve as a cooperating agency (if invited) when the FTA or another federal agency is serving as the lead agency for a Tier 2 project.
  • Make the data developed in the Tier 1 process available to other agencies and railroad stakeholders for their use in future project-level and planning studies.
  • Monitor all NEC projects, however funded and advanced, to promote consistency with the Selected Alternative and the long-term vision of NEC FUTURE. This will be particularly important where multiple Tier 2 studies are advancing simultaneously for projects included in the Selected Alternative.
  • Facilitate discussions between NEC stakeholders to support agreements on funding, planning, project implementation, construction phasing, and management of work.
  • Work with NEC operators to implement projects and improvements that enhance the customer experience.
  • Participate in the development of programmatic approaches to environmental mitigation for the Selected Alternative.
  • Implement the FRA's commitments under the Section 106 Programmatic Agreement.
  • Lead or support other future studies (outside the Tier 2 process) for longer-term improvements (such as alternative technologies) that go beyond the investment program approved in Tier 1.

Along with its railroad partners, the FRA is a steward of the NEC. The FRA intends to continue to lead efforts to fund, manage, and oversee improvement of the nation's busiest rail corridor and to promote and advance efforts to achieve the corridor-wide benefits that result from implementation of the Selected Alternative.

Footnotes

1 The Selected Alternative documented in the ROD may or may not be the same as the Preferred Alternative described in this Tier 1 Final EIS. As in any National Environmental Policy Act process, it is also possible that the Record of Decision will result in selection of the No Action Alternative.

2 The Tier 1 Draft EIS referred to this initial phase as the Universal First Phase. The term "Universal" was used to indicate that the projects included in this first phase were common to all three Action Alternatives.

3 Refer to Chapter 1, Introduction, or Chapter 13, Glossary, for definition.

4 Passenger service on the NEC operates in excess of 18 hours per day in some sections of the railroad. In addition, most freight service on the NEC runs at night—as does a significant amount of the inspection and maintenance work that railroad operators must perform on their portions of the railroad. As a result, railroad operators have only limited ability to take tracks out of service to make repairs or to implement projects without shutting down or severely limiting ongoing operations.

5 Related Projects are ongoing independent rail projects located within the Study Area that are not included in the No Action Alternative. Related Projects have independent utility and many are currently undergoing their own separate NEPA processes.

6 The Representative Route for Alternative 3 in the area of Patuxent Wildlife Refuge is described in Volume 2, Chapter 4.