Open group--anyone can post
Alix Kepner
Thanks very much,
--Alix
reisnere51
I t seems to me that an effort needs to be focused on convincing legislators that it is not in the interest of the Commonwealth to permit this change because Global Oil and its subsidiary Alliance Energy (that operates the terminal) have developed a legal structure to protect them from risk. The legislature must vote to approve or reject the license request. I would urge anyone interested in preventing these changes to write to their legislators and ask them to demand a public hearing on the license so that the legislators (many of whom have no idea about this) know what they are voting on. There are residents of communities along the Fitchburg and Lowell lines that are completely unaware that there may be trains running through their communities loaded with ethanol.
Ellin
Dear Mr. Nelson,
I have attended the public meetings in East Boston and Somerville held by the Department of Transportation regarding the proposal by Global Oil Corp. to ship Ethanol by rail through densely populated communities along the railroad routes. From the meetings I understand that the Commonwealth does not have regulatory authority over rail transport of Ethanol. However, the Commonwealth does have the legal authority to issue a Chapter 91.
I have major concerns about how the
residents of our community and local government including the cities of Revere and (East)
Boston and Chelsea would be protected and compensated by Global Oil Corporation if there
are any spills, fires, accidents. I have
reviewed the March 15, 2013 Annual Report of Global Oil LP (10K) and have serious
concerns about how this corporation is structured to protect it from financial risk. Global Oil has acquired Alliance Energy which is the operator of the Global Oil facility in Revere.
The annual report references an agreement with Alliance Energy to limit
its liability. Alliance Energy
officers are also officers of Global Oil LP.
The corporate structures of these corporations are designed to protect them financially from costs incurred from problems in their operation. It is my hope that DEP and the legislators who will be asked to vote on the Chapter 91 license required to renovate the facility to accommodate rail delivery of Ethanol, rather than barge delivery (currently in use) will carefully examine the legal arrangements of the corporation with regard to compensating the cities and residents in case of an accident, spill or fire.
I
am concerned about who has the
legal liability to compensate victims and property owners because of a
serious
accident or fire and whether there is sufficient insurance to address
this
risk. The state should not issue a permit if this is not addressed by
Global Oil LP and its subsidiary Alliance Energy. It would appear that
the Commonwealth and its taxpayers will bear a significant cost for
accidents that could result from changes to the Chapter 91 license
allowing train delivery.
As a resident of Somerville I am concerned that the proposed Ethanol trains passing through Somerville will be noisy and present risks of accidents, including derailments and, possibly fires. I understand that Ethanol is now the largest volume hazardous material transported by rail in the US. In rural areas when train derailments occur that cause ethanol fires, the fires are generally allowed to burn out. In the most densely populated city in New England any ethanol fire would have to be put out using chemical foam.
In addition to the transportation risks associated with this highly volatile product, I have major concerns about how residents and communities can be assured that they are protected from deliberate terrorist attacks that could devastate the most densely populated region of our state.
The cities and town where
the trains will operate will bear the financial costs of training firefighters
and the financial and environmental cost of purchasing and storing the fire
suppressant foam. It is not clear how much foam would be needed to put
out a large Ethanol train fire if one did occur along this route, or how
long it would take to mobilize the foam from multiple storage locations. This
necessitates regional coordination to fight fires and conduct evacuations from
an ethanol fire. Special arrangements would need to be made to rescue
people with mobility challenges such as the residents of the Visiting Nurse
Assisted Living Center that is next to the Lowell Line tracks.
In Somerville, the majority of the population lives
within 1/2 mile of the commuter rail routes which will be used. Other
densely populated communities along the rail lines including Waltham, Cambridge, Allston, East Boston, Everett and Medford are also impacted.
The proposed Ethanol trains
will add to the already huge burden from regional transportation that is
imposed upon our dense environmental justice neighborhoods With the highways
that run through Somerville - I93, R28 and R38 - we already have the most
vehicle miles traveled per day per square mile - over 200,000. Because of
the diesel commuter rails that run through - all those that go to North Station
- Somerville has the most trains per year per
square mile - 15,000.
The trains will operate through the Inner Belt area of Somerville where all northern commuter rail trains pass as well as being the location of the Boston Engine terminal. Additionally, this area will be under construction for several years with the new Green Line extension and the construction of maintenance tracks and a new maintenance facility. Transport of freight in this area of construction is of great concern because of the need for careful coordination, increased noise and pollution from the diesel trains, and the risk of an accident.
While the use of Ethanol trains
may be a great financial decision for Global Oil LP, associated
with changing from barge delivery to train delivery seem to greatly outweigh
the benefits given the risks imposed on the communities and residents affected
by this change. I hope that costs and benefits of this change in Ethanol delivery are carefully considered in making a decision about about the Chapter 91 license request.
Sincerely,
Ellin Reisner,
51 Mt. Vernon St.
Somerville, MA 02145
Jan Devereux
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