Sunday, March 22, 2015

OSA issues “FONSI’s” re AAB SWPA permit testimony.

Wow..this is a target rich post, so we’re probably going to take things in a scattergun format.  How about if we begin with this item:

Whopper of the week in the Forecaster this week by Alison Harris:  "We do appreciate DEP's diligence, so that all can be assured that plans for storm-water management meet the highest standards," Harris added.

This is akin to Alison posting a letter to the IRS, thanking them for thoroughly auditing hers and Bernie’s tax returns to assure they ‘meet the highest standards.’

Yep; rest assured that AAB is ecstatic about DEP’s formal hearing process regarding a permit application ‘that was approved once before.’  AAB probably appreciates as well the diligence of the Legislature’s GOC committee in approving an OPEGA review of NNEPRA operations.  We figure Ms. Harris, Ms, Knox, TRNE’s Poohbah Davis and his attorney, and NNEPRA’s ED and staff were at the hearing on Friday the 13th to visibly demonstrate their appreciation of the committee’s thorough oversight.

To our next item, Other Side has no officially designated stature as an “Authority” in the sense of the Federal Railroad Administration (FRA), or the Northern New England Passenger Rail Authority (NNEPRA.)

Still, as the master of our own publishing domain, we reserve the right to consider ourselves an Authority on matters that relate to our petty personal interests.  For purposes of this post, we’re invoking this freedom to call ourselves the Other Side Authority (OSA), and issuing two FONSI decrees.

The first is a Finding of No Significant Insights, which we’ll call FONSI 1.  The second, which in a blinding flash of creativity we’ll call FONSI 2, is a Finding of No Supportable Information/Impact.

You may be wondering what these decrees apply to, and if so, good for you. 

Because, you see, we believe Side readers fall into two classes.  The first comes here for a different take, hopefully more informative, on subjects important to our ‘shared destiny.’  The second comes here to find out what the enemy is up to; these are the readers who often check the reaction box indicating they think of themselves as an idiot.  Why anyone would do so is beyond us, but we appreciate their confirmation of our suspicions.

The first class of our readers knows, in all likelihood, that the Maine Department of Environmental Protection (DEP) is holding a formal hearing Wednesday, March 25th, at the Brunswick Golf Course.  The hearing relates only, and specifically, to the NNEPRA StormWater Permit Application (SWPA) required to gain DEP licensing before they can begin construction of their proposed Maintenance and Layover Facility in the Brunswick West location adjacent to the Bouchard Drive neighborhood.  The facility would service Amtrak Downeaster train sets, plus others as yet disclosed, such as Massachusetts Bay Transit Authority (MBTA) engines and equipment.  And who knows who and what else?

DEP has established very precise and specific rules for the conduct of the actual hearing, and for preliminary submissions of testimony and comments relevant to the application by both experts and the general public.  The rules are spelled out in passages such as these, which have been made available to all interested parties; emphasis is ours:

From DEP Public Info Release dated March 16, 2015:

The purpose of the hearing is to receive testimony from the parties and the general public on whether the proposed project meets the relevant statutory and regulatory licensing requirements. The statutory and regulatory criteria associated with the Department’s review of this license application are: Storm Water Management law (38 M.R.S.A. § 420-D) and the Department’s rules concerning Stormwater Management (Chapter 500). Testimony at the hearing is limited specifically to the relevant licensing criteria (stormwater standards, including, but not limited to, basic, general, and flooding standards). An outline describing the relevant regulatory review criteria associated with the proposed project is available on the Department’s website at in the document, “Second Procedural Order and attachments.”

From Chapter 3 of Rules governing the conduct of licensing hearings, Page 17 Section 20:

20. Evidence

A. Relevancy. Evidence will be admitted if it is relevant and material to the subject matter of the hearing and is of a kind upon which reasonable persons are accustomed to rely in the conduct of serious affairs. Evidence which is irrelevant, immaterial or unduly repetitious will be excluded. The Department’s experience, technical expertise, and specialized knowledge may be utilized in the evaluation of all evidence.

From the Second Procedural Order, dated January 13, 2015:


In short, per DEP pronouncements, testimony/comments will be accepted only on the specifics of the SWPA itself.  Comments and/or testimony in support of passenger rail service, Amtrak, the Downeaster, NNEPRA, the proposed MLF, snacks served aboard the train, color themes of Maine Street Station, or on any other non-SWPA subject, are out of order and should/will not be entertained in any form, written or spoken. 

Which brings us to FONSI 1: our Finding of No Significant Insights.  Various members of ‘the community,’ whatever that means, have filed statements (emails/letters) supporting SWPA approval with the DEP Project Manager.  Most of these have been posted on the DEP web page pertaining to the hearing process, and we’re confident, were submitted by AAB members, TRNE members, and those with similar inclinations.  Several others have been received by the Project Manager and state delegation members, but not posted to the DEP web site.


We think this opening statement in the message from Claudia Knox exemplifies the very essence of these messages:

“For more than a decade Brunswick residents longed for a return of passenger rail to our community.”

In so many words, every one of the submitted items we refer to embodies abject emotionalism, and nothing more.  No substance, no material evidence related to the SWPA, or any other content compliant with DEP’s Procedural guidelines for the hearing process, and the subsequent adjudication of the permit application.

As we pondered their collective merit, we began to see them as a veritable expression of ‘puppy love.’  If you don’t remember what that is, let us remind you.

Here it is literally:

                     Image result for puppy love quotes

Figuratively speaking, it looks more like this:


Or for older puppies, like this:


In Side’s view, the overall circumstances surrounding the Downeaster, AAB, and TRNE are the transport equivalent of puppy love.  And the love-letters submitted to DEP on the SWPA issue are the culmination of their longings.

In drawing this analogy, we see the sentiments expressed in the messages as irrational, exuberant, infatuated, starry-eyed, and scornful of those who counsel against their fantasies.

Most grow up and get over it, developing adult sensibilities and analytical thinking; but some don’t.  For them we offer this update of the song “Puppy Love,” which we hereby redesignate “Choo-Choo Love:”

I cry each night my tears for you trains,
My tears are all in vain
I hope and I pray that maybe someday
You'll be back (you'll be back) in my town (in my town)
Once again (you'll be back in my town once again)

Someone help me, help me, help me please
Is the answer up above?
How can I, oh how can I tell them
This is not a Choo-Choo  love.

Moving on. let’s take up the focus of FONSI 2: Economic importance.  We hereby issue our Finding of No Supportable Information/Impact, in the economic sense.  Neither Majorette Knox, or the Board Chair of the Southern Midcoast Chamber, or anyone else could put forward any tangible evidence of economic benefit from Downeaster service to Brunswick.  And they completely ignored the recurring expenses necessary to service the service.  Such as the $100,000 our town spends annually to keep the station and the platform operating.

All those gushing supporters of passenger rail service, and the proposed MLF here in Brunswick, didn’t offer one tangible piece of evidence that the train has had a positive economic effect on local circumstances.  No studies, no analysis, no anything.  Just platitudes and hand waving.  Not to mention the economic value of “longing.”  The train has been running to town for more than two years, but nobody has any hard data to substantiate the benefits.

They just mustn’t have time to collect the right information.  Since they can’t and won’t, perhaps their “longing” for days of  yore is the primary focus.  In keeping with this theme, why not get taxpayers to fund dresses and hats from the Music Man era for the ladies of Brunswick?  And require proper attire for ladies and gentlemen riding the train?

How about horses and buggies on Maine Street from April to November?  Clean air and and related benefits should more than make up for the costs of dealing with the increase in local manure footprint.


You might ask, and reasonably so, if emotionalism is supposed to carry the day in local affairs.  Take your pick; but any way you cut it, the testimony offered by the parties involved may look tasty, but every slice looks just like the last one, and leaves a taste in your mouth; black pepper, garlic, pure fat, and the rest.




We’re wearing of completing this story, so let’s see if we can cut to the chase, if only by a very slow path.  It’s too late, and we’re too tired to detail everyone of the letters submitted to DEP supporting approval of the SWPA permit for MLF construction at Brunswick West.   Though as we said above, the Claudia Knox opening line captures the essence of them all.

Other highlights include these:

  • Johnny Protocol’s lengthy discourse reciting his impressive resume of both elective and appointive positions held in Government, reminding readers that he should have been Governor, damn-it, and that he should be Chair of the Brunswick Town Council, damn-it.  His rambling discourse on the number of permits and number of hearings in DEP history ignores the salient fact that in this case, which is most unique, the applicant is the State of Maine, because NNEPRA is a Maine State Government entity,  Which means a State Agency (DEP) is exercising authority on an application from a State Agency.
  • Bernie Breitbart, spouse of Alison Harris, hypes “sold-out” trains heading south as an explanation for low ridership figures  in/out of Brunswick, and why more frequent service is required to our perfect little village.  You may recall that we debunked this notion repeatedly in past months by actually trying to buy tickets for trips heading south, none of which were sold out.
  • The Southern Mid-Coast Chamber of Commerce played the trite card they used in years past to argue that the Downeaster is an economic boon to our area.  They failed to include even a hint of objective evidence for their assertion.

Even some celebrities have a problem with the messages crafted by our local elites.


So in summary, besides labeling the local epidemic a severe case of puppy-love, we raise the Brunswick Sausage flag as well.  And add this reminder:


Which seems apropos the reality that passenger rail has disappeared for a reason.  Unless you find reality to be a myth.


We’re fond of saying that life is one big learning experience, and we’re here to prove it.  So pay attention, class!

This is a train:

This is a bus:


From what we can tell, many folks in our area have never seen or heard of a bus, so we thought it  important to introduce them to the concept.

It turns out that a bus can do just about everything a passenger train can do, faster, more economically, more flexibly, more reliably, and with virtually no capital infrastructure investment.

Imagine, if you will, the possibilities.  Take a look at the schedules for the Downeaster and Concord Coach to get some idea.  And by the way, the latter runs up coast from Brunswick on a regular basis, without any investment in rails or ties or other related infrastructure.  Turns out buses, especially those with rubber tires, can run on the ‘roads’ that the rest of us, in cars and trucks, travel on.

Related to this subtle distinction, one of the letter writers we referred to above seems to believe the only efficient way to get from points south (Portland, etc) to Boothbay Harbor is via rail expansion.  He’s convinced that a major investment in rail service to the area is the only way to avoid the summer traffic jam at Red’s Eats junction.  To which we say “get a map, pilgrim.”  Or grow up; take your choice.

Back to the bus thing.  We’ve read that Amtrak lovers claim the seats on the Downeaster just can’t be compared to those on a bus.  Is that all they’ve got for lobbying to spend tens of millions of public money for specialized, single purpose extensions to rail routes?


We found this photo by searching for Downeaster interior photos.  Excuse us, but these accommodations look no more accommodating or luxurious than modern-day bus seating.  Of course, if you go to the marketing-heavy NNEPRA/Amtrak web sites, you’ll find photos that look like this:


In other words, these are no more standard passenger rail accommodations than first class seating is for air travel.  This is the Downeaster standard, which looks no different or better to us than modern day bus (motor coach) provisions:


For those, however, who believe passenger rail accommodations just can’t be matched by rubber tired motor coaches, we reach out to you with an ‘au contraire, mon chiot amier amis.’

Modern day buses/coaches offer a full range of possibilities, perhaps wider than anything seen in passenger rail service.  Just take a look at these options:

     Image result for prevost bus interior


Or for the more privileged, this:

Suffice it to say that blather about how buses just can’t approach the comfort of rail transit is so  much poppycock.  If you’re willing to pay the price, someone will likely provide the ride you’d really like.

Which brings up the real problem in this discussion.  The puppy love gang isn’t willing to pay the price of their ride; they want everyone else to pay for it.

Let us leave you with a few other relevant images we collected:


In closing out this post, given all the editorial energy we’ve invested in it, we suddenly had an inspiration.  Maybe it’s time for locals to form the Brunswick Reality Association (BRA) to offset the malarkey that issues forth from the BDA, AAB, SMCC, and like organizations.

The BRA, as we see it, should have as a priority assuring that false fronts are no longer the norm in our local discourse.   It will, we’re sure,  be hard to find someone who can fill this role, as titular head of the new organization.

Still, we’re convinced we need pointed analysis of the facts associated with crucial issues that come before us.  Droopy, sagging arguments from yesteryear just don’t pass the test.  Falsifying the story, which has become the norm, is so yesterday.

We’ve got enough boobs in Brunswick.  It’s time to get real.

No comments:

Post a Comment