Appendix A1 - Track and Catenary Pole Project Suffolk to Wye - NEPA.pdf

National Park Service U.S. Department of the Interior

Lowell National Historical Park

Date: 12/11/2023

Letter of Compliance Completion

To: George Little

From: Juliet Galonska

Subject: NEPA and NHPA Clearance: ATS-Rehabilitate Trolley System-Repair Track Suffolk to Wye (Design+Construction) (PEPC: 116625)(PMIS: 256839)

NEPA and NHPA Compliance Complete. For complete compliance information see PEPC Project 116625.

The Superintendent and Interdisciplinary team have reviewed the scope of work and supporting documentation provided in the Planning, Environment, and Public Comment (PEPC) system, and all applicable associated compliance documentation and consultation (e.g. National Environmental Policy Act, National Historic Preservation Act, Endangered Species Act, Clean Water Act, Clean Air Act, Wilderness Act, Tribal consultation under EO13175, and other related laws and policies).

The subject proposed project/action(s), therefore, is/are now cleared for all compliance requirements. Project plans and specifications are approved, project funds may be released, and construction and/or project implementation can commence with the following mitigations and conditions/stipulations.

There are no required mitigations identified.

NHPA Recommendations for Conditions or Stipulations:

No Assessment of Effect mitigations are associated with this project. 9d. Maintenance of above-ground infrastructure.

Superintendent: _______________________________________ Date:__________________________ Juliet Galonska

Lowell National Historical Park Date: 12/11/2023

Categorical Exclusion Documentation Form (CE Form)

Project: ATS-Rehabilitate Trolley System-Repair Track Suffolk to Wye (Design+Construction) PEPC Project Number: 116625 Description of Action (Project Description):

Lowell National Historical Park (LOWE), a unit of the National Park Service (NPS) operates a 1.5 mile electrified trolley system. LOWE's trolley system has been in operation for 40+ years and is the principal way the park moves visitors and school groups between its scattered historical sites. The trolley is part of LOWE's visitor experience and essential to the park's operation. LOWE completed a trolley system condition assessment in 2018 and concluded it is critical for NPS to implement a crosstie and pole replacement program as soon as possible to continue to safely operate the trolley.

This project will replace approximately 850 timber crossties in kind, remove and replace approximately 13,000 SF of fouled ballast in conjunction with storm water management improvements along this 1/4 mile of trolley track. Additionally, this project will resurface rail a needed, replace two in-kind an at-grade street crossings in poor condition. This project includes vegetation management as needed.

Contract and project management services will be provided by The Volpe National Transportation Systems Center (Volpe) of the U.S. Department of Transportation (DOT) The scope of work for the pole replacement project includes the following:

Below are excerpts from the 2018 Lowell Trolley System Condition Assessment justifying the purpose and need for this project along with the proposed Scope of Work.

SUMMARY PURPOSE AND NEED FOR TRACK REPAIR "TRACK: With the exception of a few areas along the Swamp Locks to Wye Branch between the Wye and Mack Plaza, LOWE has confirmed most of the ties in use were installed when the Lowell Trolley was constructed 34 years ago. That age closely matches the average life expectancy of timber crossties in this climate under this type of loadings. Approximately 25% to 33% of the ties currently in track are either defective or are likely to fail within the next two to three years. The remainder of the original crossties are virtually certain to fail within the 10-year planning horizon of this investigation. A significant program to replace defective crossties should be initiated as soon as possible to keep the percentage of defective ties in track at an acceptable level... Track Ballast and Drainage: Much of the ballast stone in the track is fouled with silt and other debris due to inadequate drainage systems. Storm water runoff from other properties and from public streets is frequently directed toward the trackway. In many cases there are no drainage systems to conduct that water out of the trackway. Among other things, this lack of drainage creates an environment conducive to crosstie decay. It is recommended that steps be taken to improve drainage systems concurrent with a program to replace defective crossties and replace or clean fouled ballast stone. POST OFFICE CROSSING: Several crossings on the Lowell Trolley are likely to require reconstruction within the 10-year planning horizon of this investigation...The most problematic crossings are located at the Post Office, and Jean Arc. These crossings will need ties , ballast and rubberized crossings.

SCOPE OF WORK TRACK SUFFOLK TO WYE The following work or types of work need to occur along the Suffolk Mills Branch between its terminus and up to but not including the Wye: Replacement of defective crossties; Reconstruction of the Post Office Crossing ; Drainage improvements including both measures to prevent storm water from reaching the trackway and measures for properly handling storm-water within the trackway.; Replacement of fouled ballast stone in conjunction with both crosstie replacement and storm-water management improvements. Replacement of incorrect joint bars on 115-pound rail, including possible replacement of rails which are incorrectly drilled; Replacement of defective and missing rail joint bonding cables.; Vegetation control including both removal of brushy vegetation that is too close to the tracks and application of herbicides to control grass and weeds in the vicinity of the tracks.

Project Locations:

Location County: Middlesex State: MA

There are no required mitigations identified.

CE Citation: 3.3.C.3 Routine maintenance and repairs to non-historic structures, facilities, utilities, grounds and trails.

CE Justification:

3.3.C.3 Routine maintenance and repairs to non-historic structures, facilities, utilities, grounds and trails. The project replaces in-kind 850 timber crossties and 13,000 SF of fouled ballast along the park's alternative transportation trolley system for the purposes to cyclic maintenance (35 years) and to lower deferred maintenance. The trolley track locations are lands owned by the Government and/or where the Government owns maintenance easements to maintain the trolley system. While part of the downtown historic district and within the park boundary, there is no change or adverse impact to the cultural landscape in the referenced section of trolley tracks.

Decision: I find that the action fits within the categorical exclusion above. Therefore, I am categorically excluding the described project from further NEPA analysis. No extraordinary circumstances apply.

Signature

Superintendent: Date:

Extraordinary Circumstances:

If implemented, would the proposal... Yes/No Explanation

A. Have significant impacts on public health or safety? No No impact

B. Have significant impacts on such natural resources and unique geographic characteristics as historic or cultural resources; park, recreation, or refuge lands; wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands; wetlands (Executive Order 11990); floodplains (Executive Order 11988); national monuments; migratory birds; and other ecologically significant or critical areas?

No No impact

C. Have highly controversial environmental effects or involve unresolved conflicts concerning alternative uses of available resources (NEPA section 102(2)(E))?

No No impact

D. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks?

No No impact

E. Establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects?

No No impact

F. Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects?

No No impact

G. Have significant impacts on properties listed or eligible for listing on the National Register of Historic Places, as determined by either the bureau or office?

No No impact

H. Have significant impacts on species listed or proposed to be listed on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat for these species?

No No impact

I. Violate a federal, state, local or tribal law or requirement imposed for the protection of the environment?

No No impact

J. Have a disproportionately high and adverse effect on low income or minority populations (EO 12898)?

No No impact

K. Limit access to and ceremonial use of Indian sacred sites on federal lands by Indian religious practitioners or adversely affect the physical integrity of such sacred sites (EO 130007)?

No No impact

L. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area or actions that may promote the introduction, growth, or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)?

No No impact

Lowell National Historical Park

Date: 12/11/2023

ASSESSMENT OF ACTIONS HAVING AN EFFECT ON HISTORIC

PROPERTIES

A. DESCRIPTION OF UNDERTAKING

1. Park: Lowell National Historical Park

2. Project Description:

Project Name: ATS-Rehabilitate Trolley System-Repair Track Suffolk to Wye (Design+Construction) Prepared by: David Lieb Date Prepared: 12/11/2023 Telephone:

PEPC Project Number: 116625 Locations:

County, State: Middlesex, MA Describe project:

Lowell National Historical Park (LOWE), a unit of the National Park Service (NPS) operates a 1.5 mile electrified trolley system. LOWE's trolley system has been in operation for 40+ years and is the principal way the park moves visitors and school groups between its scattered historical sites. The trolley is part of LOWE's visitor experience and essential to the park's operation. LOWE completed a trolley system condition assessment in 2018 and concluded it is critical for NPS to implement a crosstie and pole replacement program as soon as possible to continue to safely operate the trolley.

This project will replace approximately 850 timber crossties in kind, remove and replace approximately 13,000 SF of fouled ballast in conjunction with storm water management improvements along this 1/4 mile of trolley track. Additionally, this project will resurface rail a needed, replace two in-kind an at-grade street crossings in poor condition. This project includes vegetation management as needed.

Contract and project management services will be provided by The Volpe National Transportation Systems Center (Volpe) of the U.S. Department of Transportation (DOT) The scope of work for the pole replacement project includes the following:

Below are excerpts from the 2018 Lowell Trolley System Condition Assessment justifying the purpose and need for this project along with the proposed Scope of Work.

SUMMARY PURPOSE AND NEED FOR TRACK REPAIR "TRACK: With the exception of a few areas along the Swamp Locks to Wye Branch between the Wye and Mack Plaza, LOWE has confirmed most of the ties in use were installed when the Lowell Trolley was constructed 34 years ago. That age closely matches the average life expectancy of timber crossties in this climate under this type of loadings. Approximately 25% to 33% of the ties currently in track are either defective or are likely to fail within the next two to three years. The remainder of the original crossties are virtually certain to fail within the 10-year planning horizon of this investigation. A significant program to replace defective crossties should be initiated as soon as possible to keep the percentage of defective ties in track at an acceptable level... Track Ballast and Drainage: Much of the ballast stone in the track is fouled with silt and other debris due to inadequate drainage systems. Storm water runoff from other properties and from public streets is frequently directed toward the trackway. In many cases there are no drainage systems to conduct that water out of the trackway. Among other things, this lack of drainage creates an environment conducive to crosstie decay. It is recommended that steps be taken to improve drainage systems concurrent with a program to replace defective crossties and replace or clean fouled ballast stone. POST OFFICE CROSSING: Several crossings on the Lowell Trolley are likely to require reconstruction within the 10-year planning horizon of this investigation...The most problematic crossings are located at the Post Office, and Jean Arc. These crossings will need ties , ballast and rubberized crossings.

SCOPE OF WORK TRACK SUFFOLK TO WYE The following work or types of work need to occur along the Suffolk Mills Branch between its terminus and up to but not including the Wye: Replacement of defective crossties; Reconstruction of the Post Office Crossing ; Drainage improvements including both measures to prevent storm water from reaching the trackway and measures for properly handling storm-water within the trackway.; Replacement of fouled ballast stone in conjunction with both crosstie replacement and storm-water management improvements. Replacement of incorrect joint bars on 115-pound rail, including possible replacement of rails which are incorrectly drilled; Replacement of defective and missing rail joint bonding cables.; Vegetation control including both removal of brushy vegetation that is too close to the tracks and application of herbicides to control grass and weeds in the vicinity of the tracks.

Area of potential effects (as defined in 36 CFR 800.16[d]) The area of potential effect is from Suffolk Street along Father Morrisette Blvd to the system Wye located at the intersection of Father Morrisette Blvd and Post Office Square at Merrimack Canal/Lucy Larcom Park and the Lowell High School.

3. Has the area of potential effects been surveyed to identify historic properties?

No

X Yes

Source or reference:

4. Potentially Affected Resource(s):

Archeological Resources Present: No

Historical Structures/Resources Present: No

Historical Structures/Resources Notes: Tremont Gatehouse, CRIS-HS 040597, Cultural Landscapes Present: No

Cultural Landscapes Notes: Lowell National Historical Park and Preservation District; Cultural Resources Inventory, Lowell National Historical Park: Historic Resource Study

Ethnographic Resources Present: No

5. The proposed action will: (check as many as apply)

No Destroy, remove, or alter features/elements from a historic structure

No Replace historic features/elements in kind

No Add non-historic features/elements to a historic structure

No Alter or remove features/elements of a historic setting or environment (inc. terrain)

No Add non-historic features/elements (inc. visual, audible, or atmospheric) to a historic setting or cultural landscape

No Disturb, destroy, or make archeological resources inaccessible

No Disturb, destroy, or make ethnographic resources inaccessible>

No Potentially affect presently unidentified cultural resources

No Begin or contribute to deterioration of historic features, terrain, setting, landscape elements, or archeological or ethnographic resources

No Involve a real property transaction (exchange, sale, or lease of land or structures)

Other (please specify):

6. Supporting Study Data:

(Attach if feasible; if action is in a plan, EA or EIS, give name and project or page number.)

B. REVIEWS BY CULTURAL RESOURCE SPECIALISTS

The park 106 coordinator requested review by the park's cultural resource specialist/advisors as indicated by check-off boxes or as follows:

[ X ] 106 Advisor Name: David Lieb Date: 12/11/2023 Comments: The scope of work is cyclical maintenance repairs and rehabilitation of the alternate transportation trolley system track ties and ballast along the Suffolk Street to system Wye at Merrimack Canal and Father Morrisetts Blvd. The trolley trackway lands have been previously disturbed and there is no concern or requirement for archeological monitoring.

GC will follow standard procedures through the Volpe Center should any unexpected finds be discovered when removing or disposing of fouled ballast and rotted wood track ties.

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect X Streamlined Review Recommendations for conditions or stipulations: No stipulations or conditions placed on construction activities in the areas of this track section.

Doc Method: Streamlined Review (PA) Streamlined Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

4. Health and Safety Activities

[ X ] Historical Architect Name: David Lieb Date: 12/11/2023 Comments: The scope of work is cyclical maintenance repairs and rehabilitation of the alternate transportation trolley system track ties and ballast along the Suffolk Street to system Wye at Merrimack Canal and Father Morrisetts Blvd. The trolley trackway lands have been previously disturbed and there is no concern or requirement for archeological monitoring.

GC will follow standard procedures through the Volpe Center should any unexpected finds be discovered when removing or disposing of fouled ballast and rotted wood track ties.

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect X Streamlined Review Recommendations for conditions or stipulations: No recommendations or stipulations placed on construction activities.

Doc Method: Streamlined Review (PA) Streamlined Activity:

2. Rehabilitation and/or Minor Relocation of Existing Trails, Walks, Paths, and Sidewalks

4. Health and Safety Activities

No Reviews From: Curator, Archeologist, Historian, Other Advisor, Anthropologist, Historical Landscape Architect

C. PARK SECTION 106 COORDINATOR'S REVIEW AND RECOMMENDATIONS

1. Assessment of Effect:

No Potential to Cause Effects

No Historic Properties Affected

X No Adverse Effect

Adverse Effect

2. Documentation Method:

[ ] A. Standard 36 CFR Part 800 Consultation Further consultation under 36 CFR Part 800 is needed.

[ X ] B. Streamlined Review Under the 2008 Servicewide Programmatic Agreement (PA) The above action meets all conditions for a streamlined review under section III of the 2008 Servicewide PA for Section 106 compliance.

Applicable Streamlined Review Criteria (Specify 1-16 of the list of streamlined review criteria.)

9. Maintenance or Replacement of Non-Historic Utility Lines, Transmission Lines, and Fences.

[ ] C. Undertaking Related to Park Specific or Another Agreement The proposed undertaking is covered for Section 106 purposes under another document such as a park, region or statewide agreement established in accord with 36 CFR 800.7 or 36 CFR 800.14.

[ ] D. Combined NEPA/NHPA Process Process and documentation required for the preparation of an EA/FONSI or an EIS/ROD to comply with Section 106 is in accord with 36 CFR 800.8.c.

[ ] E. Memo to Project File

3. Consultation Information

SHPO Required:

SHPO Sent:

SHPO Received:

THPO Required: No THPO Sent:

THPO Received:

SHPO/THPO Notes:

Advisory Council Participating: No Advisory Council Notes:

Additional Consulting Parties: No

4. Stipulations and Conditions: Following are listed any stipulations or conditions necessary to ensure that the assessment of effect above is consistent with 36 CFR Part 800 criteria of effect or to avoid or reduce potential adverse effects.

No Assessment of Effect mitigations are associated with this project. 9d. Maintenance of above-ground infrastructure.

5. Mitigations/Treatment Measures: Measures to prevent or minimize loss or impairment of historic/prehistoric properties: (Remember that setting, location, and use may be relevant.)

No Assessment of Effect mitigations identified.

6. Assessment of Effect Notes:

No Assessment of Effect mitigations are associated with this project. 9d. Maintenance of above-ground infrastructure.

D. RECOMMENDED BY PARK SECTION 106 COORDINATOR:

Compliance Specialist:

NHPA Specialist

David Lieb

Date:

E. SUPERINTENDENT'S APPROVAL

The proposed work conforms to the NPS Management Policies and Cultural Resource Management Guideline, and I have reviewed and approve the recommendations, stipulations, or conditions noted in Section C of this form.

Signature

Superintendent:

Date:

Basic Information Form

Park Name: Lowell NHP

PEPC Project ID: 116625

Other Project ID:

PMIS ID: 256839

Project Status: Proposed

Compliance Status: Closed Complete

Sensitive: No

Project Target Start: 09/15/2023

Project Creation Date: 04/25/2023

Project Title: ATS-Rehabilitate Trolley System-Repair Track Suffolk to Wye (Design+Construction)

Secondary Title:

Project Description: Lowell National Historical Park (LOWE), a unit of the National Park Service (NPS) operates a 1.5 mile electrified trolley system. LOWE's trolley system has been in operation for 40+ years and is the principal way the park moves visitors and school groups between its scattered historical sites. The trolley is part of LOWE's visitor experience and essential to the park's operation. LOWE completed a trolley system condition assessment in 2018 and concluded it is critical for NPS to implement a crosstie and pole replacement program as soon as possible to continue to safely operate the trolley.

This project will replace approximately 850 timber crossties in kind, remove and replace approximately 13,000 SF of fouled ballast in conjunction with storm water management improvements along this 1/4 mile of trolley track. Additionally, this project will resurface rail a needed, replace two in-kind an at-grade street crossings in poor condition. This project includes vegetation management as needed.

Contract and project management services will be provided by The Volpe National Transportation Systems Center (Volpe) of the U.S. Department of Transportation (DOT) The scope of work for the pole replacement project includes the following:

Below are excerpts from the 2018 Lowell Trolley System Condition Assessment justifying the purpose and need for this project along with the proposed Scope of Work.

SUMMARY PURPOSE AND NEED FOR TRACK REPAIR "TRACK: With the exception of a few areas along the Swamp Locks to Wye Branch between the Wye and Mack Plaza, LOWE has confirmed most of the ties in use were installed when the Lowell Trolley was constructed 34 years ago. That age closely matches the average life expectancy of timber crossties in this climate under this type of loadings. Approximately 25% to 33% of the ties currently in track are either defective or are likely to fail within the next two to three years. The remainder of the original crossties are virtually certain to fail within the 10-year planning horizon of this investigation. A significant program to replace defective crossties should be initiated as soon as possible to keep the percentage of defective ties in track at an acceptable level... Track Ballast and Drainage: Much of the ballast stone in the track is fouled with silt and other debris due to inadequate drainage systems. Storm water runoff from other properties and from public streets is frequently directed toward the trackway. In many cases there are no drainage systems to conduct that water out of the trackway. Among other things, this lack of drainage creates an environment conducive to crosstie decay. It is recommended that steps be taken to improve drainage systems concurrent with a program to replace defective crossties and replace or clean fouled ballast stone. POST OFFICE CROSSING: Several crossings on the Lowell Trolley are likely to require reconstruction within the 10-year planning horizon of this investigation...The most problematic crossings are located at the Post Office, and Jean Arc. These crossings will need ties , ballast and rubberized crossings.

SCOPE OF WORK TRACK SUFFOLK TO WYE The following work or types of work need to occur along the Suffolk Mills Branch between its terminus and up to but not including the Wye: Replacement of defective crossties; Reconstruction of the Post Office Crossing ; Drainage improvements including both measures to prevent storm water from reaching the trackway and measures for properly handling storm-water within the trackway.; Replacement of fouled ballast stone in conjunction with both crosstie replacement and storm-water management improvements. Replacement of incorrect joint bars on 115-pound rail, including possible replacement of rails which are incorrectly drilled; Replacement of defective and missing rail joint bonding cables.; Vegetation control including both removal of brushy vegetation that is too close to the tracks and application of herbicides to control grass and weeds in the vicinity of the tracks.

Project Leader: George Little

NEPA Specialist: David Lieb

NHPA Specialist: David Lieb

External Agency/Applicant:

Division/Office:

Designer:

Conceptual Design Date:

Project Type: Cyclic Maintenance

Project Category: Alternative Transportation Systems Cultural Landscape Deferred Maintenance Railroad System

General Notes:

Locations

County/Borough, State District, Section Geo. Marker Other Tract ID

Middlesex, MA

File List

Title

PMIS256839_detail StoWYE.doc (111.6 KB, Word file) LOWE Summary Presentation 021523.pptx (20.7 MB, .pptx file) 2018_08_02_Final Track Plans-SUFFOLK TO WYE HIGHLIGHTED.pdf (1.7 MB, PDF file) LOWE Trolley system map.pdf (214.3 KB, PDF file) Cultural Reource Inentory4.pdf (21.5 MB, PDF file) Locks and Canal Nat register1.pdf (1.4 MB, PDF file)

Last Updated Date: 12/11/2023

Last Updated By: dlieb

Justification Form

Park Name: Lowell NHP

Project Number: 116625

Project Title: ATS-Rehabilitate Trolley System-Repair Track Suffolk to Wye (Design+Construction)

Public Safety: Yes

Energy Conservation:

Employee Health/Safety: Yes

Sustainable design:

Partnership/Community Development:

Legal Mandate/Policy:

Citations/Violations/Court Orders:

Resources at Risk:

Other:

Brief Justification:

Below are excerpts from the 2018 Lowell Trolley System Condition Assessment justifying the purpose and need for this project along with the proposed Scope of Work. SUMMARY PURPOSE AND NEED FOR TRACK REPAIR "TRACK:

With the exception of a few areas along the Swamp Locks to Wye Branch between the Wye and Mack Plaza, LOWE has confirmed most of the ties in use were installed when the Lowell Trolley was constructed 34 years ago. That age closely matches the average life expectancy of timber crossties in this climate under this type of loadings. Approximately 25% to 33% of the ties currently in track are either defective or are likely to fail within the next two to three years. The remainder of the original crossties are virtually certain to fail within the 10-year planning horizon of this investigation. A significant program to replace defective crossties should be initiated as soon as possible to keep the percentage of defective ties in track at an acceptable level... Track Ballast and Drainage: Much of the ballast stone in the track is fouled with silt and other debris due to inadequate drainage systems. Storm water runoff from other properties and from public streets is frequently directed toward the trackway. In many cases there are no drainage systems to conduct that water out of the trackway. Among other things, this lack of drainage creates an environment conducive to crosstie decay. It is recommended that steps be taken to improve drainage systems concurrent with a program to replace defective crossties and replace or clean fouled ballast stone.

POST OFFICE CROSSING: Several crossings on the Lowell Trolley are likely to require reconstruction within the 10-year planning horizon of this investigation...The most problematic crossings are located at the Post Office, and Jean Arc. These crossings will need ties , ballast and rubberized crossings. SCOPE OF WORK TRACK SUFFOLK TO WYE The following work or types of work need to occur along the Suffolk Mills Branch between its terminus and up to but not including the Wye: Replacement of defective crossties; Reconstruction of the Post Office Crossing ; Drainage improvements including both measures to prevent storm water from reaching the trackway and measures for properly handling storm-water within the trackway.; Replacement of fouled ballast stone in conjunction with both crosstie replacement and storm-water management improvements. Replacement of incorrect joint bars on 115 pound rail, including possible replacement of rails which are incorrectly drilled. ; Replacement of defective and missing rail joint bonding cables.; Vegetation control including both removal of brushy vegetation that is too close to the tracks and application of herbicides to control grass and weeds in the vicinity of the tracks. The trolley system is the principle way the park moves visitors and school groups around its scattered sites and is part of the visitor experience in Lowell. This project will address high priority safety and maintenance needs of the trolley. According to the park's recently completed condition assessment failure to act on repairs within the next 5-10 years will result in a closure of this section of track. As of 2018 there is a 1/3 default rate of the timber crossties, within 5-10 years this is projected to increase to 2/3. NPS cannot operate at that rate for derailment risk.

Measurable Result:

Upon project completion, the deferred maintenance of the trolley system, which is an OB1 asset will be reduced and visitors and employees will continue to operate safely without risk of derailment. This project will bring this segment of trolley track into a state of good repair for approximately 35 years and will ensure the safety of all using the system.