Three Dover residents, who are LSPs (Licensed Site Professionals), took it upon themselves to assess the current Dover Greenway proposal and provide feedback on voiced environmental concerns. This letter is their assessment…
Citizens of Dover are currently considering a proposal to convert the abandoned MBTA rail bed that traverses Dover into a mixed-use recreational trail, The Dover Greenway. A “yes” vote on May 2 will authorize the Board of Selectmen to enter into a 99-year lease with the MBTA to enable the conversion process to proceed. Some citizens have suggested that environmental concerns associated with the former railroad-bed could result in town liability or health or environmental risks. As registered Massachusetts Licensed Site Professionals (LSPs) with more than 75 years of combined experience addressing environmental contamination issues, and as Dover residents, it is our opinion that these fears are groundless and not borne out by the facts of rail-trail conversions elsewhere in Massachusetts.
Railroad beds in semi-rural areas like Dover are simply transportation corridors, equivalent to Center St. but with less traffic. As such, the contaminants likely to be associated with the corridor are similar to the materials found on and adjacent to our roads. The presence of these contaminants is typically managed on roadway projects without the fanfare or public concern associated with rail trail projects and, in our opinion, this increased concern regarding rail corridors is not based on risk, science or regulations.
When rail trail conversions started becoming common after 2000, the Massachusetts Department of Environmental Protection (“MassDEP”) developed a Best Management Practices document (the “BMP”) to provide guidance for rail-trail conversions. The BMP provides a practical approach that is also protective of health and the environment. Rail-lines like the Dover corridor are categorized in the lowest risk category for which the only recommended pre-construction requirements are visual inspection and a MassDEP file review with pre-construction environmental testing recommended only if specific spill areas are identified. The relevant elements of the BMP have been incorporated into the feasibility study in the Beals & Thomas report commissioned by the town, which is available at on the town website. Those elements include removal of the rotting creosote-laden railroad ties that are the major continuing source of contamination on the railway bed followed by capping with a suitable barrier. These measures will effectively eliminate both a continuing source of contamination and prevent contact with contaminants in existing soils.
Since 2004 the BMP guidance has been successfully implemented on rail trail projects across the state and Paul Locke of MassDEP, who developed the guidance, reported to us that he is not aware of any projects where problematic environmental contamination was discovered during or following the rail-to-trail conversion process in a rural right-of way environment such as Dover. However, despite the low risk of environmental liability associated with the rail trail conversion, we understand that the town (with private funding) will be purchasing an environmental insurance policy to mitigate this already low risk. Thus, we are convinced that the proposed conversion will not represent an environmental liability for the town. It will also provide a net environmental benefit through removal of the treated railroad ties and by capping the rail-bed soils.
Because of these reasons, The Dover Greenway has our support! As fellow Dover residents, we believe this project has significant recreational benefits for us and for Dover’s future generations and that it has no environmental downside. In fact, it is an Environmental Plus! since it is the only plan that addresses existing environmental conditions. We urge you to join us and vote “yes” for Article 18 on May 2.
Ronald E. Myrick, Jr., PE, LSP, CHMM
Paul McKinlay, PG, LSP
Nancy C. Roberts, MS, LSP