20090629Environmental, Historic Reports.pdf

BALL JANIK LLP
KARL MORELL
1455 F STREET, NW, SUI 225
VVASffGTON, D.C. 20005
ww.baljan.com
TELEPHONE [phone]
FACSIME 202-783-6947
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ATTORNEYS
June 25, 2009 ~~L-l¿ - oct -o(
Commission Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, ID 83720-0074
RE: STB Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City
Railroad, Inc. - Abandonment Exemption - In Latah County, Idaho
Dear Sir/Madam:
On or shortly after July 15, 2009, Palouse River & Coulee City Railroad, Inc. ("PRCC")
wil be filing with the Surface Transportation Board ("STB") a Notice of Exemption seeking
authority to abandon its rail lines located between: (1) milepost 84.0. at the Washington-Idaho
State Line and milepost 85.91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in
Moscow; and (3) milepost 85.5 and the end of the line at the intersection of A Street and Almon
Street, in Moscow (the "Lines"). Attached are an Environmental Report and Historic Report
describing the proposed action and any expected environmental and historic effects, as well as a
map of the affected area.
We are providing these reports so that you may review the information that wil form the
basis for the STB' s independent environmental and historic analyses of this proceeding. If any
of the information is misleading or incorrect, if you believe that pertinent information is missing,
or if you have any questions about the STB's environmental review process, please contact the
Section of Environmental Analysis (SEA), Surface Transportation Board, 395 E Street, S.W.,
Washington, DC 20423-0001, Telephone [phone], and refer to the above Docket No.
AB-570 (Sub-No. 3X). Because the applicable statutes and regulations impose strngent
deadlines for processing this action, your written comments to SEA (with a copy to the
undersigned) would be appreciated within 3 weeks.
PORTLAD, OREGON WASHIGTON, D.C.BEND, OREGON
BALL JANIK LLP
June 25, 2009
Page 2
Your comments wil be considered by the STB in evaluating the environmental and/or
historic preservation impacts of the contemplated action. If there are any questions concerning
this proposal, please contact the undersigned by telephone at [phone] or by mail at Ball
Janik LLP, 1455 F Street, N.W., Suite 225, Washington, DC 20005.
Sincerely,'¡td~
Karl Morell
Attorney for Palouse River & Coulee City
Railroad, Inc.
Enclosures
1,-..
PRe- -fZ -oCj--1
RECEIVED
2009 JUH29 AM 8: 19ENVIRONMENTAL REPORT
(49 C.F.R. 1105.7) IDAHO PUÐUG
8TB Docket No. AB-570 (Sub-No. 3X) UTILITIES CO~\;M¡SSlON
PALOUSE RIVER & COULEE CITY RAILROAD, INC.
--ABANDONMENT EXEMPTION--
IN LATAH COUNTY, IDAHO
(l) Proposed Action and Alternatives. Describe the proposed action, including
commodities transported, the planned disposition (if any) of any rail line and other
structures that may be involved, and any possible changes in current operations or
maintenance practices. Also describe any reasonable alternatives to the proposed action.
Include a readable, detailed map and drawings clearly delineating the proJect.
Palouse River & Coulee City Railroad, Inc. ("PRCC"), proposes to abandon its rail lines
located between: (l)milepost 84.0. at the Washington-Idaho State Lineand milepost 85.91, in
Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3) milepost 85.5 and the
end of the line at the intersection of A Street and Almon Street, in Moscow (the "Lines"). Upon
receipt of abandonment authority, PRCC intends to remove the rail, track material, and ties.
There is one small bridge on the Lines located at milepost 84.3, near the Washington-Idaho State
Line. Local entities are interested in rail-baning all or most of the Lines. Consequently, PRCC
wil not remove or disturb the bridge and wil leave the ballast in place.
The salvage process begins with the unbolting of the track materials and rails. With the
use of specialized machinery placed on the railroad right-of-way, the rails and related track
materials (angle bars, tie plates, spikes, switches and any other metal parts) arexemoved. Next
the wooden ties are raised from the ballast with a tool designed for minimum disruption of
ground materiaL. The ballast, bridges and right-of-way wil remain intact so as not to alter the
prevailing water flows along the Lines. In addition, PRCC salvage contractors are required to
limit their activities to the width of the right-of-way and not to place fill or other material in
water bodies. When the salvage process is complete, water flows in the area wil not be
disrupted.
The proposed abandonment will not change rail freight operations or maintenance
practices on the Lines. No local or overhead traffc has been handled on the Lines for over two
years. There currently are no active rail shippers located along the Lines.
The only alternative to abandonment would be not to abandon the Lines and force PRCC
to absorb the opportnity costs of retaining these inactive Lines. This would not be a prudent use
of carrer resources. The Lines are in poor condition and in need of substantial rehabilitation.
A map of the proposed abandonment is attached hereto as Exhibit i.
(2) Transportation System. Describe the effects of the proposed action on regional
or local transportation systems and patterns. Estimate the amount of traffic (passenger or
freight) that wil be diverted to other transportation systems or modes as a result of the
proposed action.
No passenger or freight traffic will be diverted to other modes as a result of the proposed
abandonment. No local or overhead traffic has been handled on the Lines in over two years.
Since the Lines no longer handle rail traffic, the proposed abandonment wil have no adverse
effects on regional or local transportatìon systems and patterns. ,
(3) Land Use. (i) Based on consultation with local and/or regional planning agencies
and/or a review of the official planning documents prepared by such agencies, state
whether the proposed action is consistent with existing land use plans. Describe any
inconsistencies. (ü) Based on consultation with the U.S. Soil Conversation Service, state the
effect of the proposed action on any prime agricultural land. (ii) If the action affects land
or water uses within a designated coastal zone, include the coastal zone information
required by 1105.9. (iv) If the proposed action is an abandonment, state whether or not the
right-of-way is suitable for alternative public use under 49 U.S.C. § 10905 and explain why.
2
(i) PRCC dges not consider the proposed abandonment to be inconsistent with existing
land use plans. PRCC contacted the Latah County Commissioners. See Exhibit 2. No response
to this inquire has been received to date. A copy of this Report has been mailed to the
appropriate local and state agencies for their information and comment.
(ii) PRCC notified the USDA Natural Resources Conservation Service ("Conservation
Service") of the proposed abandonment and requested assistance in identifyng any potential
effects on prime agrcultural land. See Exhibit 3. The Conservation Service "has no comments
or concerns with the listed resources for the abandonment of these raìllines through the city of
Moscow, Idaho." See Exhibit 4. A copy ofthis Report is being supplied to the Conservation
Service for its information and further comment.
(iii) The Lines do not pass through a designated coastal zone.
(iv) The Lines traverses an urban area that has an adequate road and highway network.
Therefore, there is little or no likelihood that the rail corrdors are needed for a transit or highway
corrdor:
(4) Energy. (i) Describe the effect of the proposed action on transportation of
energy resources. (ii) Describe the effect of the proposed action on recyclable commodities.
(iü) State whether the proposed action wil result in an increase or decrease in overall
energy efficiency and explain why. (iv) If the proposed action wil cause diversions from
rail to motor carriage of more than: (A) 1,000 rail carloads a year; or (B) an average of 50
rail carloads per nule per year for any part of the affected line, quantify the resulting net
change in energy consumption and show the data and methodology used to arrive at the
figure given.
3
(i) The proposed abandonment wil have no effect em the transportation of energy
resources.
(ii) The proposed abandonment wil have no effect on the transportation of recyclable
commodities.
(iii) The proposed abandonment wil have no effect on overall energy efficiency as no
local or overhead traffic has been handled on the Lines for over two years.
(iv) The proposed abandonment wil not cause any diversions of rail traffic to motor
carrage, since no local or overhead traffic has been handled on the Lines for over two years.
(5) Air. (i) If the proposed action wil result in either: (A) An increase in rail traffic
of at least 100 percent (measured in gross ton mies annually) or an increase of at least eight
trains a day on any segment of rail line affected by the p,roposal, or (B) an increase in rail
yard activity of at lease 100 percent (measured by carload activity), or (C) an average
increase in truck traffic of more than 10 percent of the average daily traffic or 50 vehicles a
day on any affected road segment, quantify the anticipated effect on air emissions. For a
proposal under 49 U.S.C. § 10901 (or § 10505) to construct a new lie or reinstitute service
over a previously abandoned line, only the eight train a day provision in sub-section
(5)(i)(A) wil apply. (ii) If the proposed action affects a class I or nonattainment area under
the Clean Air Act, and wil result in either: (A) an increase in rail traffic of at least 50
percent (measured in gross ton mies annually) or an increase of at least three trains a day
on any segment of rail line; (B) an increase in rail yard activity of at least 20 percent
(measured by carload activity); or (C) an average increase in truck traffic of more than 10
percent of the average daily traffic or 50 vehicles a day on a given road segment, then state
whether any expected increased emissions are within the parameters established by the
State Implementation Plan. However, for a rail construction under 49 U.S.c. § 10901 (or
49 U.S.C. § 10505), or a case involving the reinstitution of service over a previously
abandoned line, only the three train a day threshold in this item shall apply. (ii) If
transportation of ozone depleting materials (such as nitrogen oxide and freon) is
contemplated, identify: the materials and quantity; the frequency of service; safety
practices (including any speed restrictions); the applicant's safety record (to the extent
available) on derailments, accidents and spils; contingency plans to deal with accidental
spils; and the likelihood of an accidental release of ozon"e depleting materials in the event
of a collision or derailment.
4
(i) The proposed abandonment wil not result in meeting or exceeding the specified
thresholds.
(ii) The proposed abandonment wil not result in meeting Of exceeding the specified
thresholds.
(iii) The proposed abandonment wil not affect the transportation of ozone depleting
materials.
(6) Noise. If any of the thresholds identifed in item (5)(i) of this section are
surpassed, state whether the proposed action will cause: (i) an incremental increase in
noise levels of three decibels Ldn or more; or (ü) an increase to a noise level of 65 decibels
Ldn or greater. If so, identify sensitive receptors (e.g., schools, libraries, hospitals,
residences, retirement communities, and nursing homes) in the proJect area, and quantify
the noise increase for these receptors if the thresholds are surpassed.
Not applicable
(7) Safety. (i) Describe any effects of the proposed action on public health and
safety (including vehicle delay time at railroad. grade crossings). (ü) If hazardous materials
are expected to be transported, identify: the materials and quantity; the frequency of
service; whether chemicals are being transported that, if mixed, could react to form more
hazardous compounds; safety practices (including any speed restrictions); the applicantfs
safety record (to the extent available) on derailments, accidents and hazardous spils; the
contingency plans to deal with accidental spils; and the likelihood of an accidental release
of hazardous materials. (ii) If there are any known hazardous waste sites or sites where
there have been known hazardous materials spils on the right-of-way, identify the location
of those sites and the types of hazardous materials involved.
(i) The proposed abandonment will have no detrimental effects on public health and
safety. The removal of grade crossings and the associated signs and structures wil enhance
public safety by eliminating distractions to vehicular traffic crossing the Lines.
(ii) The proposed abandonment wil not affect the transportation of hazardous materials.
5
(iii) There are no known hazardous materal waste sites or sites where known hazardous
material spils have occurred on or along the rail corrdors of the Lines.
(8) Biological Resourc.es. (i) Based on consultation with the U.S. Fish and Wildlife
Service, state whether the proposed action is liely to adversely affect endangered or
threatened spe.cies or areas designated as a critical habitat, and if so, describe the effects.
(ti) State whether wildlife sanctuaries or refuges, National or State parks or forests wil be
affected, and describe any effects.
(i) PRCC notified the U.S. Fish and Wildlife Service ofthe proposed abandonment and
requested assistance in determining whether endangered or threatened species or areas designated
as a critical habitat are likely to be adversely affected. See Exhibit 5. The U.S. Fish and Wildlife
Service has identified one threatened species (Spalding's catchfly) in the project area. See
Exhibit 6. The proposed abandonment and salvage operations wil have no adverse effect on this
threatened species. PRCC will not salvage the bridge and the ballast wil remain intact.
Consequently, the prevailing water flows wil not be altered, or impacted. Also the salvage
contractor wil be required to limit its activities to the width of the right-of-way and not to place
fills or other material in the water bodies. A copy of this Report is being supplied to the U.S.
Fish and Wildlife Service for its information and further comment.
(ii) PRCc does not believe that any wildlife sanctuaries or refuges, National or State
parks or forests would be adversely affected by the proposed abandonment. PRcc notified the
National Parks Service of the proposed abandonment and requested assistance in identifyng any
potential effects on wildlife sanctuaries or refuges, National or State parks or forests. See
Exhibit 7. To date, no response to this request has been received. A copy ofthis Report is being
supplied to the National Park Service for its information and comment.
6
(9) Water. (i) Based on consultation with State water quality officials, state
whether the proposed action is consistent with applicable Federal, State or local water
quality standards. Describe any inconsistencies. (ii) Based on consult~tion with the U.S.
Army Corps of Engineers, state whether permits under section 404 of the Clean Water Act
(33 U.S.C. § 1344) are required for the proposed action and whether any designated
wetlands or 100-year flood plains wil be affected. Describe the effects. (iü) State whether
permits under section 402 of the Clean Water Act (33 U.S.c. § 1342) are required for the
proposed action.
(i) PRCC is confident that the proposed abandonment will be consistent with applicable
water quality standards. PRcc contacted the Idaho Departent of Environmental Quality
("DEQ") and the U,S. Environmental Protection Agency concerning this matter requesting
assistance in determining whether the proposed abandonment is consistent with applicable
Federal, State, or local water quality standards. See Exhibit 8. To date, no response to these
requests has been received. Nevertheless, PRCc continues to believe that the proposed
abandornent and salvage operations wil be consistent with applicable Federal, State and local
water quality standards. The proposed abandonment will result in the removal of the rails, ties
and track materials. The bridge and ballast wil remain in place. Also, the salvage contractor
will be required to limit its activities to the width of the right-of-way and not to place fill or other
material in water bodies. A copy of this Report is being supplied to the U.S. Environmental
Protection Agency and the DEQ for their information and cOmment.
(ii) PRCC is confident that no designated wetlands or 100-year flood plains wil be
adversely affected by the proposed abandonment. PRcC contacted the Corps of Engineers
concerning these matters. See Exhibit 9. The Corps noted that an Ary permit would be
required for this project if it involved the discharge of dredged or fill material in waters of the
United States. The Corps suggested that PRCc have the project area inspected by a qualified
7
wetland consultant. See Exhibit 10. The proposed ahandoament wil result in the removal of the
rails, ties and track materials. The bridge and ballast wil remaìn in place. Also, the salvage
contractor wil be required to limit its activities to the width of the right-of-way and not to place
fill or other material in water bodies. Consequently, there will be no discharge of dredged or fill
into waters of the United States. A copy of this Report is being supplied to the U.S. Army Corps
of Engineers for its information and fuher comment.
(iii) PRcC contacted the u.s. Environmental ProtectÌon Agency concerning this matter
and requested assistance in identifying any potential effects on applicable water quality standards
and determining whether the proposed abandonment is consistent with applicable Federal, State,
or local water quality standards. See Exhibit 8. To date, no response to this request has been
receìved. Nevertheless, PRcC contìnues to believe that the'proposed abandonment and salvage
operations wil not require permits under Section 402. The proposed abandonment wil result in
the removal of the rails, ties and track materials. The bridge and ballast wil remain in place.
Also, the salvage contractor wil be requìred to limit its activities to the width of the right-of-way
and not to place fill or other material in water bodies. A copy of this Report is being supplied to
the U.S. Environmental Protection Agency for its information and comment.
8
(10) Proposed Mitigation. Describe any actions that are proposed to mitigate
adverse environmental impacts, indicating why the proposed mitigation is appropriate..
PRCC does not expect any adverse environmental impact from thé proposed
abandonrent and, therefore, sees no need for any mitigating actions. PRCc wil, of course,
adhere to any remedial actions suggested by the recipients of this Report and required by the
Board.
9
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EXHfflT2
BALL JANIK LLP
ATTORNE Y 5
1455 F STREET, NW. Sun£ 225
VVASffGTON. D.C. 20005
ww.baljancom
TELEPHONE [phone]
FACSIMILE 202.783.6947
KA MORELL
OF COUNSEL
kinorell€jbjllp.com
May 8, 2009
Latah County Commissioners
P.O. Box 8068
Moscow, iO 83843
RE: Docket No. AB-570 (Sub~No. 3X), Palouse River & Coulee City
Railroad, Inc.-Abandonment Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PReen) is planning to file a Notice of
Exemption with the Surface Transportation Board (flSTB"), on or about June 22, 2009, for PRCC
to abandon the raíllînes located between: (1) milepost 84.0, at the Washington-Idaho State Line
and milepost 85.91, in Moscow, 10; (2) milepost 86.11 and milepost 86.9, in Moscow; and(3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment Îs attached.
Pursuant to the STB's environmental regulations at 49 C.F.R., Part 1105, we. are advising
you of this proposed action so that you may assist us in identifying any potential effects on
existing land use plans. We must determine whether the proposed abandonment is inconsistent
with existing land use plans.
We would appreciate your review of the proposed abandonment and any comments you
may wish to offer. We would also appreciate you providing us with a written response so that we
can forward it to the STB.
PORTLA. OREGON WASHINGTON. D. C.BENu. OREGO",
,
BALL JANIK LLP
May 8, 2009
Page 2
Thank you in advance for your prompt assistance. If you have any questions concerning
this matter, please contact me.
K:;~
Karl Morell
Attorney for:
Palouse River & Coulee City Railroad, Inc.
BALL JANIK
EXHBIT 3
LLP
,ATTORNEYS
1455 F STR. NW, SUITE 225
WASffGTON, D.C. 2005
ww.baan.com
Ti:PHoNE [phone]
FACSIMLE 202.783.6947
KA MORELL
OF COUNSEL
kmorell(lbjllp.coin
May 8,2009
USDA Natural Resources Conservation Service
9173 West Barnes Drive, Suite C
Boise, ID 83709
RE: Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City
Railroad, Inc.--Abaiidonnient Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planning to fie a Notice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22, 2009, for PRCC
to abandon the rail lines located between: (1) milepost 84.0, at the Washington-Idaho State Line
and milepost 85,91, in Moscow,. ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment is attached.
Pursuant to the STB's environmental regulations at 49 c.F.R., Part 1105, we are advising
you of this proposed action so that you may assist us in identifying any potential effects on prime
agrcultural land.
We would appreciate your review of the proposed abandonment and any comments you
may wish to offer. We would also appreciate you providing us with a written response so that we
can forward it to the STB.
POlnL'\. OREGON WASHINGTON. D.C.BEND, OREGON
BALL JANIK LLP
May 8, 2009
Page 2
Thank you in advance for your prompt assistance. If you have any questions concerning
this matter, please contact me.
1?J~
Karl Morell
Attorney for:
Palouse River & Coulee City Railroad, Inc.
United States Department of Agriculture
EXHIBIT 4
~NRCS
Natural Resources Conservation Servic
9173W. Barnes Dr., Ste C
Boise, Idaho 83709
Phone: [phone]
Fax: [phone]
May 19,2009
Karl Morell
Attorney for: Palouse River & Coulee City RR, Inc.
Ball Janik LLP
1455 F. Street, N\V, Suite 225
Washington, D.C. 20005
Re: Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City Railroad, Inc.-
Abandonment Exemption-In Latah County~ Idaho.
Dear Mr. Morell,
This letter is in response to your May 8, 2009 request for information and comments on the
above referenced project.
The resource impacts that the Natural Resources Conservation Service (NRCS) typically
reviews and provides comments for, if necessary, include the following:
. Soil Suitability and limitations
. Erosion, sediment and dust control
. Water discharge from project area to off-site locations - Impact to water quality
and irrigation systems
. Effects of disruption to natural drainage patterns
. Consideration for soil and water conservation management systems and measures
on project and adjacent lands; and, Impacts on previously installed soil and water
conservation management systems
. Prime and Unique Farmland
. Impacts on Ecosystems
. Impacts on other NRCS-related projects
The NRCS has no comments or concerns with the listed resources for the abandonment of
these rail lines through the city of Moscow, Idaho. The proposed abandonment will occur
within an existing transportation right-of-way. Soil suitability and effects to prime and
unique farmland wil not be changed nor otherwise affected. Erosion, sediment, dust and
Water control should be included within normtll operating plans as required by federal and
Helping People Help the Land
An Equal Opportunity Provider and Employer
state regulatory agencies. It is unlikely that there would be additional effects to plant
communities, terrestrial and aquatic ecosystems, biodiversity, or fuel loads. There are no
current or planned NRCS-related proj.ects in that area.
If you have any questions, please contact Mark Weatherstone, Assistant State
Conservationist - Technical Services at [phone] or email at
mark.weatherstoneßYìd ..usda.gov.
Sincerely,
GJRWELL
State Conservationist
cc:
Bob Tribelhom, Assistat State Conservationist ~ Operations West, NRCS, Moscow, iO
Mark Weatherstone, Assistant State Conservationist - Techncal Services, NRCS, Boise,
ID
Darin Vrem, Cultural Resource Specialist/Archaeologist, NRCS, Boise, iO
Hal K. Swenson, Assistant State Soil Scientist, NRCS, Boise, iD
Bruce Knapp, Resource Soil Scientist, NRCS, Moscow, iO
Patrick Evans, District Conservi;tionist, NRCS, Moscow, ID
BALL JANIK LLP EXHfflT5
ATTORNËYS
1455 F STRE, NW, SUIE 225
VVASffGTON. D.C. 20005
ww.balan.com
TELEPHONE [phone]
FACSIM 202-783-6947
KARL MORELL
Or COUNSEL lcoreU€!bjllp.com
May 8,2009
U.S. Fish and Wildlife Service
1387 S. Vinnell Way, Room 368
Boise, Idaho 83709
RE: Docket No. AB-570 (Sub-No. 3X), Palouse Ríver & Coulee City
Railroad, Inc.--Abandonment Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planning to file a Notice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22,2009, for FRee
to abandon the rail lines located between: (1) milepost 84.0, at the Washington-Idaho State Line
and milepost 85.91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment is attached.
Pursuant to the STB's environmental regulations at 49 C.F.R., Part i LOS, we are advising
you of this proposed action so that you may assist us in determining whether it is likely to
adversely affect endangered or threatened species or areas designated as a critical habitat.
We would appreciate your review of the proposed abandonment and any COIIents you
may wish to offer. We would also appreciate you providing us with a written reSponse so that we
can forward it to the STB.
PORTLAND. OREGON WASHIGTON, D.C.BEND. OREGON
BALL JANIK LLP
May 8, 2009
Page2
Thank you ìn advance for your prompt assistance. If you have. any que.stìons concerning
this matte.r, please contact me.
Sincerely,KJ~
Karl Morell
Attorney for:
Palouse River & Coulee City Railroad, Inc_
EXHfflT6
United States Department of the Interior
IDAHO FISH AN WIDLIFE OFFICE
1387 S_ Vinnell Way, Rom 368
Boise lda 83709
Telephoe [phone]
htt://ww.fWs.gøv/idaho
MAY 2 9 l009
Karl Morell
Ball Janik LLP
1455 F Street, NW Suite 225
Washington, D.C. 20005
Subject:Palouse River and Coulee City Railroad, Inc. Abandonment Exemption-La
County, Idaho-Species List
970.3000 14420~2009-SL-0390
Dea Mr. Morell:
The Fish and Wildlife Servce (Service) is providing you with a list of endangered, threatened,
proposed, and/or candidate species, and designated critical ha.bitat which may occur in the area
of the abandonment exemption. You requested this list by letter on May 8, 2009. Pleas refer to
the speies list nuiber 14420-2009-SL-0390 shown above in all correspondence and reports.
Non-Federal Lads and Section 7
Section 7 of Endangered Species Act of 1973 (Act), as amended, requires Federal agencies to
assure that their actions do not Jeopardize any listed species and provides a process for
exemption of tae for Federal agencies. Although your project is located on non-Federal lands,
if there is a Federal action (funding, permitting, or direct action) associated with your project, the
Federal agency is required to consult with the Service if the action may affect a listed species.
Section 7 regulations also aUow for applicants to be involved in the consultation process. For
instace, a Federal agency may designate you or another nOÌl-Federal entity to represent them in
an infonnal consultation.
The enclosed list fulfills the requirements for a species list under section 7(c) of the Act. If the
proj.ect decision has not been made within 180 days of this letter, regulations require that you
request an updated list. More inormation on the regulations and procedures. for section 7
consultation, including the role of permit or license applicants, can be found in the "Endagered
Species Consultation Handbook" at
http://ww.fws.gov/endangeredconsultations/s7hndbk/s7hndbk.htm (last acessed May 26,
2009). Section 7 consultation information specific to Idaho.listed species can also be found on
the Idaho Fish and Wildlife Office website at htt://ww.fws.gov/idaho/agencies.htm (last
accessed May 26,2009).
TAK-PRIDE ~ J
'NAMEFUCA~
.Kl Morell
Palouse River and COulee City Railroad, In. Abandonmnt Exemptìon
Volunta Agreements for Species Conservation on Pnvate Lands
The Act includes provisions for the conservation of listed species on both Federal and non-
Federalands. A pnvate landowner may wish to enter into an agreement with the Service under
section 10 of the Act for activities that benefit listed proposed, and candidate species. Volunta
agreements such as Safe Haror Agreements or Candîdate Conservation Agreements contribute
to the conservation of listed, proposed or candidate species while allowing for management
activities on non- Federal lands. . In addition, Section 9 of the Act prohibits the "taing" of any
listed species without an exemption (issued by the Service) for that tael. For private
landowners. that exemption is developed though the permt process of Section 10 (though a
Habitat Conservation Plan) of the Act. More information on the vanous mechanisms for tae
exemption available to pnvate landowners under the Act can be found at
htt://ww.fws.gov/idao/Ldowners.htm (last accessed May 26, 2009).
If you have any questions about your responstbilities under the Act, or require further
information, pleae contact Barbar Chaney at the Idaho Fish and Wildlife Offce at (208) 378-
5259. For information on conservation opportunities under section 10 of the Act, contact
Conservation Planing Branch Chief Kendra Womack at the Idaho Fish and Wildlife Offce at
[phone]. Than you for your continued interest in endagered specìes conservation.
Sincerely,
Enclosure
I Take of threaened or endangered animal species is defined as; haras, har pursue, hunt, shot, wound, kill, tr, capture or
collect, or to atempt to engage in any such conduct. Har is furter defined by the Servce to include significant habitat
moification or degration that results in deah or injury to listed species by significantly impairing essntial behavioral patterns,
including breeding, feeding, or sheltering. Harass is defined by the Service as an intentional or negligent act or omission which
creates the likelihood of injury to wildlife by annoying it to such an extent as to signi ficant! y disrupt norml behavior patters
which include, bvt are not limited to, breeding, feeing, or sheltering.
2
PALOUSE RIER AN COULEE CITY RAILROAD, INC.
ABANONMENT EXEMPTION
LATAH COUNY, IDAHO
SPECIES LIST 14420-2009-SL-0390
LISTED SPECIES STATUS
Spalding's catchfly (Silene spaldingii)Listed Theatened
PROPOSED SPECIES & PROPOSEDIDESIGNATED CRITICAL HABIT AT
None
CANIDATE SPECIES2
None
Information on the above species and their management can be found on the
Environnental Conservation Online System (ECOS) website at
htt://ecos.fws.gov/ecos public/index.do (last accessed May 26, 2009) and the Idaho Fish
and Wildlife Offce website at htt://ww.fws.govlidaho/agencies.htm (last accessed
May 26, 2009).
2Cadidate spcies have no protection under the Act, but are included for your early plannng
consideration. Candidate species could be proposed or listed durg the project plang period, and would
then be covered under Section 7 of the Act. The Service advises an evaluation of potential effects on
candidate species tht may occur in the project area.
May 2009
EXlIBIT7
BALL JANIK LLP
ATTORNE Y 5
1455 F STREET, NW, SUI 225
WASffGTON, D,C. 20005
ww.baIan.com
TELEPHONE [phone]
FACSIM 202'783-6947
KARL MOR£LL
OF.CoUNSEL
kmorelll§bjllp.com
May 8, 2009
Natìonal Park Service
One Jackson Center
1111 Jackson Stree~ Suite 700
Oakland, CA 94607
RE: Docket No. AB-570(Sub-No. 3X), Palouse River & Coulee City
Railroad, lnc.--Abandonment Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planning to file a Notice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22, 2009, for PRCC
to abandon the rail lines located between: (1) milepost 84.0, at the Washington-Idaho State Line
and milepost 85.91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment is attached.
Pursuant to the STB's environmental regulations at 49 C.F.R., Part n05, we are advising
you of this proposed action so that you may assist us in identifyng any potential effects on
wildlife sanctuanes or refuges, National or State parks or forests.
We would appreciate your review of the proposed abandonment and any COIIents you
may wish to offer. We would also appreciate you providing us with a wntten response so that we
can foiward it to the STB.
PORTLAND, OREGON WASHINGTON, D.c.BEND. OREGON
BALL JANIK LLP
May 8,2009
Page 2
Thank you in advance for your prompt assistance. If you have any questioIl concerning
this matter, please contact me.
~:¿(JLl, //
Karl Morell' /vr .
Attorney for:
Palouse River & Coulee City Railroad, Inc.
EXHmlT8
BALL JANIK LLP
ATTORNEYS
1455 F STRE, NW, SUIE 225
VVASHITON. D.C. 20005
ww.balan.com
TELEi-NE 202.6$8-3307
FACSIMLE 202.783.6947
KA MORELL
OF COUNSEL
kmocell~bjUp.com
May 8, 2009
Administrator
Department of Environmental Quality
1118 F Street
Lewiston, 1083501
RE: Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City
Railroad, Inc.-Aban.donment Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("'PRCC") is planning to fie a Notice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22,2009, for PRCC
to abandon the rail lines located between: (I) milepost 84.0, at the Washington-Idaho State Line
and milepost 85.91, in Moscow, 10; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end ofthe line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment is attached.
'Pursuant to the STB's environmental regulations at 49 C.F.R., Part 1105, we are advising
you of this proposed action so that you may assist us in identifying aoy potential effects on
applicable water quality standards. We also seek your assistance in determining whether the
proposed abandonment is consistent with applicable Federal, State or local water quality
standards. PRCC does not believe any permits under Section 402 of the Clean Water Act will be
required.
We would appreciate your review of the proposed abandonment and any comments you
may wish to offer. We would also. appreciate you providing us with a written response so that we
can forward it to the STB.
PORTL.Al'ID. OREGON WASHINGTON. D. C BEND. OREGON
BALL JANIK LLP
May 8, 2009
Page 2
Thank you in advance for your prompt assistance. If you have any questions concerning
this matter, please contact me.
i2'Karij1~
Attorney for:
Palouse River & Coulee City Railroad, Inc.
~
BALL JANIK LLP
ATTORNE Y S
l455 F STRE. NW. SUITE 225
VVASHmGTON, D.C. 20005
ww.balan.com
TELEPHONE [phone]
FACSIMILE 202.783.6947
KAL MORELL
OF COUNSEL 1c0reii~bjUp.com
May 8, 2009
U.S. Environmental Protection Agency
1200 Sixth Avenue
Seattle, WA 98101
RE: Docket No. AB-S70 (Sub-No. 3X), Palouse River & Coulee City
Railroad, Inc.--Abandonment Exemption~In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planing to fie a Notice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22,2009, for PRCC
to abandon the rail lines located between: (1) miÌepost 84,0, at the Washington-Idaho State Line
and milepost 85,91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. A map of the proposed abandonment is attached.
Pursuant to the STB's environmental regulations at 49 C.F.R., Part 1105, we are advising
you of this proposed action so that you may assist us in identifyng any potential effects on
applicable water quality standards. We also seek your assistance in determining whether the
proposed abandonment is consistent with applicable Federal, State or local water quality
standards. PRCC does not believe any permits under Section 402 of the Clean Water Act will be
required.
We would appreciate your review of the proposed abandonment and any comments you
may wish to offer. We would also appreciate you providing us with a written response so that we
can forward it to the STB.
PORTL-\O. OREGON W.'\HlNGTON. D.C.BEN. OREGON
BALL JANIK LLP
May 8,2009
Page 2
Thank you in advance for your prompt assistance. If you have any questìons concerning
this matter, please contact me.
SKal,
KarlMoreU ~
Attorney for:
Palouse River & Coulee City Railroad, Inc.
BALL JANIK LLP
EXBIBIT9
ATTORNEYS
1455 F STR, NV, SUIE 225
WASffGTN, D.C. 20005
wv.balar.com
TELEPHONE [phone]
FACSIM 202-783.6947
KARL MORELL
OF COUNSEL
knorel(§bjllp.com
May 8, 2009
U.S. Army Engineer District, Walla Walla
201 North Thrd Avenue
Walla Walla, WA 99362-1876
RE: Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City
RailrC)ad, Inc.-Abandonment Exemption-In Latah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planing to fie a Nntice of
Exemption with the Surface Transportation Board ("STB"), on or about June 22, 2009, for PRCC
to abandon the rail lines located between: (I) milepost 84.0, at the Washington-Idaho State Line
and milepost 85.91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3J
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah CountY1 Idaho. A map of the proposed abandonment is attached.
Pursuant to the STB's environmental regulations at 49 C.F.R., Part 1105, we are advising
you of this proposed action so that you may assist us in identifying any potential effects on
designated wetlands or l OO-year flood plains. PRCC does not believe any permits under Section
404 of the Clean Water Act will be required.
We would appreciate your review of the proposed abandonment and any comments you
may wish to offer. We would also appreciate you providing us with a written response so that we
can forward it to the STB.
PORTLAN. OREGON WASHl"lGrON. D.C.BENu. OREGON
BALL JANIK LLP
MayS, 2009
Page 2
Thank you in advance for your prompt assistance. If you have any questions concerning
this matter, please contact me.spcu~
L~~eu
Attorney for:
Palouse River & Coulee City Railroad, Inc.
-,l, --'
DEPARTMENT OF THE ARMY
WALLA WALLA DISTRICT, CORPS OF ENGINEERS
201 NORTH THIRD AVENUE
WALLA WALLA, WASHINGTON 99362-1876
EXHIßITI0
REPLY TO
ATTENTIN OF June 5, 2009
Regulatory Division
SUBJECT: NWW-2009..322-W04
Mr. Karl Morell
Ball Jank, LLP
1455 F Street, NW
Suite 225
Washington, D.C. 20005
Dear Mr. Morell:
This is in response to your May 8, 2009 letter requesting our comments on the Palouse
River & Coulee City Railroad's abandonment of rail lines between: (1) milepost 84.0, at the
Washington-Idaho State Line and milepost 85.91, in Moscow, Idaho; (2) milepost 86. U and
milepost 86.9 in Moscow; and (3) mile post 855 and the end of the line at the intersection of A
Street and Almon Street in Moscow, in Lata County, Idaho. Section 404 of the Clean Water Act
(33 U.S.c. 1344) requires aDeparment of the Army permit be obtained for the discharge of
dredged or fill material into waters of the United States. This includes most perennial and
intermittent rivers and streams, natural and man-made lakes and ponds, and wetlands, as well as
irrigation and drainage canals and ditches that are tributaries to other waters, requires a
Deparment of the Ary permit be obtained for any structures or work in or affecting navigable
waters of the United States. Paradise Creek is a water regulated under Section 404. Activities
regulated under Section 404 include excavation and mechanized land clearing activities which
result in the discharge of dredged material and destroy or degrade waters of the United States.
Based on the information provided, we are unable to determine if the proposed project will
involve any work subject to our jurisdiction. We would suggest you have the project area
inspected by a qualified wetland consultant to determine if the proposed project wil involve
work in such areas. If it does, you should then have these areas identified and delineated and
submitted for our review and approval. We would also suggest you select someone who is
knowledgeable in the methods we use for delineating jurisdictional wetlands. Enclosed for your
information are our requirements for preparing wetland delineations and a list of consultants who
may be able to assist you.
If the proposed project win involve the discharge of dredged or fill material in waters of the
United States, including wetlands, a Deparment of the Ary permit may be required prior to the
star of construction. If so, you wil need to complete and submit a permit application for
processing and evaluation. Please be advised that starting work before obtaining the required
~ ¡"..:') 1
-2-
Department of the Ary permit constìtutes a violation of Section 404 and could result in legal
action. If you have any questions concernng these regulatory matters, please contact me at
509-527-7156 (fax [phone]).
Sincerely,
D~~~
Duane E. Mitchell
Regulatory Project Manager
Enclosures
PRc--~-oq-o(
R!lCE,t\'r:O"C ' ¡','
HISTORIC REPORT
(49 C.F.R. 1105.8)
STB Docket No. AB-570 (Sub-No. 3X), ',' mAHO P~§LI~(" ,
PALOUSE RIVER & COULEE CITYRAILROAD!-lMT1ES CO¡,n.41~)vION
--ABANDONMENT EXEMPTION--
IN LATAH COUNTY, IDAHO
2009 JUN29 Al18:19
The Historic Report should contain the information required by 1 105. 7(e)(I) of the
Environmental Report. The following is excerpted from the Environmental Report prepared for
th~ proposed abandonment:
Proposed Action and Alternatives. Describe the proposed action, including
commodities transported, the planned disposition (if any) of any rail line and
other structures that may be involved, and any possible changes in current
operations or maintenance practices. Also describe any reasonable
alternatives to the proposed action. Include a readable, detailed map and
drawings clearly delineating the project.
Palouse River & Coulee City Railroad, Inc. ("PRCC"), proposes to abandon its rail lines
located between: (1) milepost 84.0. at the Washington-Idaho State Line and milepost 85.91, in
, Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3) milepost 85.5 and the
end of the line at the intersection of A Street and Almon Street, in Moscow (the "Lines"). Upon
receipt of abandonment authority, PRCC intends to remove the rail, track material, and ties.
There is one small bridge on the Lines located at milepost 84.3, near the Washington..Idaho State
Line. Local entities are interested in rail-banking all or most of the Lines. Consequently, PRCC
wil not remove or disturb the bridge and wil leave the ballast in place.
The salvage process begins with the unbolting of the track materials and rails. With the
use of specialized machinery placed on the railroad right-of-way, the rails and related track
materials (angle bars, tie plates, spikes, switches and any otl1er metal parts) are removed. Next
the wooden ties are raised from the ballast with a tool designed for minimum disruption of
ground materiaL. The ballast, bridges and right-of-way wil remain intact so as not to a.lter the
prevailng water flows along the Lines. In addition, PRCC salvage contractors are required to
limit their activities to the width of the right-of-way and not to place fill or other material in
water bodies. When the salvage process is complete, water flows in the area wil not be
disrupted.
The proposed abandonment wil not change rail freight operations or maintenance
practices on the Lines. No local or overhead traffic has been handled on the Lines for over two
years. There currently are no active rail shippers located along the Lines..
The only alternative to abandonment would be not to abandon the Lines and force PRCC
to absorh the opportnity costs of retaining these inactive Lines. This would not be a prudent use
of carer resources. The Lines are in poor condition and in need of substatial rehabilitation.
A map of the proposed abandonment is attached hereto as Exhihit 1.
HISTORIC REPORT
1. A U.S.G.S. topographic map (or alternate map drawn to scale and
sufficiently detailed to show buildings and other structures in the vicinity of
the proposed action) showing the location of the proposed action, and the
locations and approximate dimensions. of raJlroad structures that are 50
years old or older and are part of the proposed action;
A map and the identification of all structures on the Lines that may be 50 years old or
older have been supplied to the Idaho State Historical Society ("IHS"). See Exhibit 2.
2. A written description of the right of way (including approximate widths, to
the extent known), and the topography and urban and/or rural
characteristics of the surrounding area;
2
The rights-of-way are of varng widths. The Lines are located within the city limits of
Moscow, Idaho near the University of Idaho. The Lines are located between: (1) m.ilepost 84.0.
at the Washington-Idaho State Line and milepost 85.91, in Moscow, in; (2) milepost 86.11 and
milepost 86.9, in Moscow; and (3) milepost 85.5 and the end ofthe line at the intersection of A
Street and Almon Street, in Moscow.
3. Good quality photographs (actual photographic prints, not photocopies) of
railroad structures on the property that are 50 years old or older and of the
immediate surrounding area;
In the May 8,2009, letter to the IHS PRCC mistakenly stated that there were two bridges
on the Lines. Upon further review, there is actually only one bridge on the Lines located at
milepost 84.3, or 0.3 miles east of the Washington-Idaho Sts.te line. The two pictures attaçhedfo
the May 8th letter are actually of the same bridge. See Exhibit 2. The bridge and the Lines were
originally constructed in 1890. Most of the components of the bridge have been replaced over
the years. Attached as Exhibit 3 is a map showing the location of the bridge. There is a former
railroad bridge adjacent to the western end of the Lines associated with a former parallel rail line.
That bridge, however, is now part of the Latah Trail and is not associated with the abandonment
of the Lines. A picture of that bridge is attached as Exhibit 4.
4. The date(s) of construction of the structure(s), and the date(s) and extent of
any maJor alterations, to the extent such information is known;
The bridge located on the Lines was originally constructed in i 890, but most of the
components have been replaced over the years. PRCC is n~t in possession oraiiy engineering
documents regarding the maintenance or repairs of this bridge.
3
5. A brief narrative history of carrier operations in the area, and an
explanation of what, if any, changes are contemplated as a result of the
proposed action;
No traffic has moved over the Lines for over two years. The last active rail shipper on the
Lines was Ferrell Gas. As a result, the involved Lines are no longer required for rail operations.
PRCC is ofthe opinion that rehabilitation of the Lines cannot be economically justified. Since
the Lines are not being used, no change to current transportation patterns are anticipated upon the
abandonment ofthe Lines.
6. A brief summary of documents in the carrier's possession, such as
engineering drawings, that might be useful in documentig a structure that is
found to be historic;
There are no available individual drawings for the bridge on the Lines. The bridge is
quite common in design and construction and are of no historical significance. It is typical of
many small bridges and underpasses found throughout North America. In any event, the bridge
wil remain undisturbed as a result of the proposed abandonment.
7. An opinion (based on readily available information in the railroad's
possession) as to whether the site and/or structures meet the criteria for
listing on the National Register of Historic Places (36 C.F.R. 60.4), and
whether there is a likeliood of archeological resources or any other
previously unknown historic properties in the p.roJect area, and the basis for
these opinions (including any consultations with the State Historic
Preservation Office, local historical societies or universities);
In PRCC's view, the bridge is quite common in design and construction. It has no
historical significance as to the history of railroad construction or operation. It is a common
strcture found on numerous railroads throughout North America. There are also no known
4
archeologicàl resources in the project area. Attached as Exhibit 5 is the response PRCC received
from the IHS.
8. A description (based on readily available information in the railroad's
possession) of any known prior subsurface ground disturbance or nii,
environmental conditions (naturally occurring or manmade) that might
affect the archeological recovery of resources (such as swampy conditions or
the presence of toxic waste), and the surrounding terrain.
There are no existing records as to the nature of any known subsurface ground
distubance or fill, or environmental condition that might affect the archeological recovery of any
potential resources.
9. Within 30 days of receipt of the historic report, the State Historic
Preservation Ofncer may request the following additional information
regarding specifc non railroad owned properties or groups of properties
immediately adJacent to the railroad right-of-way: photographs of specifed
properties that can be readily seen from the railroad right-of-way (or other
public rights-of-way adJacent to the property) and a written description of
any previously discovered archeological sites, identifying the location and
type of the site (i.e. prehistoric or native A.merican).
PRCC does not foresee the likelihood that any additional information wil need to be
supplied in association with the proposed line abandonment other than that information
previously submitted. But, if any additional information is requested, PRCC wil promptly
supply the necessar information.
5
EXHIT 1
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BALL JANIK LLP
EXHIBIT 2
ATTORNEYS
1455 F STREET, NW, SUITE 225
WASHINGTON, D.C. 2005
ww.balljanik.com
TELEPHONE [phone]
FACSIMILE 202.783.6947
KARL MORELL
OFCOUNSËL kmorcll§bjllp.com
May 8, 2009
Idaho State Historical Society
2205 Old Penitentiary Road
Boise, ID 837 t 2
RE: Docket No. AB-570 (Sub-No. 3X), Palouse River & Coulee City
Railroad, Inc.--Abandonment Exemption-In I"atah County,
Idaho
Dear Sir/Madam:
Palouse River & Coulee City Railroad, Inc. ("PRCC") is planning to file a Notìce of
Exemption with the Surface Transportation Board ("STB"), on or about June 22,2009, for PRCC
to abandon the rail lines located between: (i) milepost 84.0, at the Washington-Idaho: State Line
and milepost 85.91, in Moscow, ID; (2) milepost 86.11 and milepost 86.9, in Moscow; and (3)
milepost 85.5 and the end of the line at the intersection of A Street and Almon Street in Moscow,
in Latah County, Idaho. One of the requirements for this filing with the STB is that the owner of
the rail lines contact the State Historic Preservation Offce regarding the proposed abando:nment.
Enclosed is a map depicting the area where the rail lines are located. The proposed
abandonment wil involve the removal of the rail, track material, and crossties; however, there
are currently no plans to remove any existing structures along the track.
The lines to be abandoned are within the city limits of Moscow, Idaho. The first linebegins at milepost 84~0, at the Washington-Idaho State Line, and extends eastward past the
sewage treatment plant, then parallel to the Latah Trail and then runs adjacent to the University
of Idaho to milepost 85.9 t west of Highway 95. The second line begins at milepost 86.11,
immediately east of Highway 95 and extends eastward to Blaine Street. The third line begins at
milepost 85.5 of the first line, and extends generally in a northeasterly direction to the
intersection of A Street and Almon Street.
There are two bridges On the first line of unknown age. There are no bridges or other
railroad structures on the second or third line. A photograph of each bridge is attached. The first
PORTLAD. OREGON WASHINGTON. D.C.BEND. OREGON
'BALL JANIK LLP
May 8, 2009
Page 2
bridge is located at milepost 84.3.. The second bridge is located between the State Line and the
sewage treatment plant. Both structures are quite common in design and construction and, in
PRCC's view, have no historical significance.
We wil send you a copy of the Historic Report as soon as it is completed. If I can of
further assistance regarding this matter, please can me at [phone].Siati+
Karl Morell
Attorney for
Palouse River & Coulee City Railroad, Inc.
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EXHIBITS
May 18, 2009
Kal Morell
Ball Janik LLP
1455 F Street NW, Ste 225
Washington DC 20005
"The History and Preservatìon People"
Our mission: to educate RE: Docket No. AB-570 (Sub-No. 3X), Palouse River &. Coulee Cìtythrough the identifkation, Raioad, Inc.- Abandonment Exemption - in Lata Coun, Idao.
preservation, and interpretation
of Idaho's cultural heritage.
www.idahohistory.net Dear Mr. Morell,
.:.
C.L. "Butch" Otter
Governor of Idaho
Janet L. Gallmore
Executive Dìrector
Administration
220-5 Old Penitentiar Road
Boise. Idaho 83712-8250
Offce: [phone]
Fax: [phone]
Ardlaeol6gical Survey oJ ldalio
210 Main Stret
Boise. Idaho 83702-7264
Office: [phone]
Fax: [phone]
Histurical Museum amI
Education Programs
610 Nort JuJia ÐavisDr'ive
Boise. Idaho 83702.7695
Offce: [phone]
Fax: (208)334'4059
Hislôric PrcservatìonOffce
21:0 Maili Street
Boise. Idaho 83702-7264
Qffc(': [phone]
Fax: [phone]
Historic Sites Offce
24450Jd Peniteniiary Road
Boise,ldaho.837J2-8254
Omce: [phone]
Fax: [phone]
Public Archi\'cs and
Research Library
2205 Old Penitentiary" Road
Boise. Idaho 83717-8250
PublÎc Archives
omcc: [phone]
Fax:.(208) 334~2626
Research. Lihury
Officc:(2D8). 334~335ó
Fax: (708) :;34-3198
On! History
Ofìce:[phone]
Fax: [phone]
Thank you for your letter and inormation of May 8 regarding the proposed
abandonment and the eligibilty of the two bridges for the National Register
of Historic Places.
Although ìt appears that neither bridge meets Natìonal Register eligibìlity
critena, we wi nee to receìve completed historic site forms (Idaho Historic
Sites Inventory form or equivalent) for the two bridges as well as the stretch
of lie to be abandoned hefore we ca complete the evaluaoR At a
mium, we wi nee approxite daes of conseton (of the raioad
line and the hndges) and maps which pinpoint the locations of the bridges.
As soon as we recive the abve inormation, we can complete our review.
Sincerely,
£Jó~~
Deputy State Histonc Preservation Offcer
The lclaho State Historical Socìety is an Equal Opportunity Employer.