PENN DOT Meeting April 12, 2017

APRIL 12, 2017 1:00 pm until 3:30 pm … Meeting with Dennis Toomey, Brian ? (PennDOT) and Jim Voser (PSIP, property owner) and John Wichner, Brian Deviosi (McMahon, property developer) … and Harry, Victor, Chris, Alice and Daniel Becker, Solicitor.

In attendance was Christine Verdier from Senator Argyle’s office. At the end of the meeting, she briefly spoke to us about what they can and cannot do on our behalf.  Pretty much (in a nutshell) she told us the State is not going to get involved in this project, this is why the state has local governments, for them to handle these types of situations.  She said as a “stand alone” township, we must have the different zoning areas and if our township leaders chose this particular site to be industrial, it is up to the community to petition the Greenwich Township Board of Supervisors for reconsideration based on our current ordinances.

PS:  The new ordinances dated 2014 still have not been put up on the website as of today.  This was discussed at the April 3 BoS meeting and is an open “action item” as promised to us by our Board Solicitor, Daniel Becker.

Also in attendance were approximately 37 members of our community.  YAY FOR THAT! Although I did notice that many of the residents left the meeting feeling defeated, I am hoping that ALL the residents stay focused and stay passionate because as a group we can do this!!!

FOR THE RECORD!  I recorded this meeting, all 2.5 hours of it. It is a huge file, not easily put onto this blog, however, it is a big help in getting the facts straight and in pursuing the “action items” listed at the end of this blog.

PennDOT’s interest in this project is as follows:  They are reviewing the HOP (Highway Occupancy Permit) application from McMahon.  They assess On-Site layouts and Off-Site layouts.

ON-SITE: This application is for creating a “driveway” from the property onto a state owned road (Route 737).  They did a good presentation of what they are proposing to do with their exit/entrance and changing the routing of Long Lane (also a state owned road).  The Greenwich Township BoS and Planning Commission stated they have countered that proposed plan with McMahon and PennDOT as they do not want to change the routing of Long Lane.  Greenwich Township would like the entrance to be on the south side of the 550′ of road frontage for two reasons.

  1. Changing Long Lane will make it more accessible to trucks to exit the warehouse and travel on Long Lane.  We all know that the intersection of Long Lane and Old 22 has no line of sight up Old 22 west bound as the hill from the church blocks the road as traffic comes up and over the hill.  It is also deadly as several people have died at that intersection (not to mention the numerous injury accidents at that intersection.)
  2. PennDOT has a formula they work for line of sight exiting a driveway.  Currently, with the farmers field to the north of the proposed exit and the possiblity that the farmer could have a tall crop planted, there would not be a clear 400′ feet line of sight for truckers exiting the warehouse property, or for drivers south bound on Route 737 to see those truckers exiting as the driver clears the turn.

Mr. Toomey states they will review the line of sight issue first, then make a final decision on whether they will ask for the driveway to be moved.  As for the new intersection (re-routing of Route 737), PennDOT is all for the change as they prefer intersections to be clearly defined 90 degree angles. McMahon already has easement permits from the Thompson family to change the Long Lane intersection.  Our goal is to prove that allowing this change will put tractor trailers onto Long Lane heading south, feeding them towards our deadly intersection.

Mr. Toomey also stated that although the proposed rerouting will put tractor trailers onto Long Lane, through a residential community towards a dangerous intersection, there is no law forbidding tractor trailer traffic through a residential area when it is on a state road (which are considered public, and therefore usable by all traffic. PennDOT can place signs across from the warehouse driveway stating NO TRUCKS onto Long Lane.  However, PennDOT cannot be responsible for policing those signs.  Our goal is to petition Greenwich Township to provide the residents safety by hiring a local police force to enforce traffic laws.

OFF-SITE: PennDOT reviews the road conditions and intersections outlying the parcel to be developed.  Off-site layouts can, and do, include the surrounding areas can handle the proposed traffic patterns up to a half a mile away from the on-site parcel. The requested, from McMahon, a traffic study.  McMahon did a one day traffic Impact Study on Wednesday, March 16, 2016.  PennDOT stated that based on that study, and the proposed increase in traffic of 160 tractor trailers per day, no changes to Krumsville roads were necessary. We protested this study stating a one day study of the traffic patterns in Krumsville we not all encompassing of daily traffic patterns during summer months, during a detour off I-78, during a snow day, and we requested that PennDOT do a comprehensive Impact Study per their Policies and Procedures as related to Highway Occupancy Permits.  Mr. Toomey stated they were satisfied with the study done by McMahon.  It is our goal to petition Greenwich Township to have PennDOT do another study prior to giving final approval for the HOP.  A PennDOT study is a 30 to 45 day, continuous study, which involves counters and in some cases, even cameras.

One of the biggest concerns for ALL residents is the increased traffic through the tiny intersection of Krumsville.  Mr. Toomey admitted that this intersection is a current problem and they do not have any plans at this time to make changes.  He said because this intersection is already a traffic hazard, PennDOT cannot ask the developer to be responsible for upgrades to the intersection.  He also said that because the four corners of this intersection are closely captured by homes and businesses, there really isn’t anything that could be done to it at this time.  We requested a Impact Study for a Signal and he agreed to have that done! (Action Item #1)

He said that there will be a Post Development study done by PennDOT and if there is a perceived safety issue at that time with the increase traffic, then PennDOT will get involved in changing the intersection or other roads being affected by the increased traffic.  It is our goal to petition Greenwich Township to have PennDOT review this in more detail prior to the development because a Post Study could warrant changes which will require eminent domain over properties to make the necessary changes.  We need to prove PRIOR TO development that this will happen so that we do not lose our historic homes and business on the corners of Old 22 and Route 737, or lose our property frontage along Long Lane to accomodate tractor trailer traffic.

Admittedly, adding the proposed 160 inbound and 160 outbound tractor trailers a day (these are the numbers as presented from McMahon to PennDOT and Greenwich Township) is daunting.  Based on phone calls and research to four local warehouses in New Smithville, Orefield and Fogelsville, and based on this National ITE Trip calculation publication (High Cube Warehousing) we believe that number will be around 556 trips (278 inbound, 278 outbound) which is almost double if the warehouse is running at full capacity for 44 bays. This is assuming the warehouse is actually a High Cube Automated warehouse.  If the warehouse is a simple distribution center, the numbers will be 754 trips (377 inbound, 377 outbound). This is a question for the Planning Commission meeting, will the developer be building the automation into the warehouse, or just building the shell with the capability of having automation installed by the leaser/purchaser of the warehouse.  The answer to that question will dramatically change the perspective of how much traffic will be generated and should be of concern to Greenwich Township and to PennDOT.

Lower Macungie learned the hard way what damages, health problems and increased costs to the township arose after allowing warehousing into their district and they have said ENOUGH IS ENOUGH (see Morning Call Article) Our Board of Supervisors needs to study the safety issues, health issues, and property damage issues that will arise once this heavy a volume of traffic is added to our small rural community, on roads that are in now way prepared to handle the weight of the trucks nor the size of the trucks.  Our ordinances guarantee us that we will be properly protected and we need to petition Greenwich Township to uphold those ordinances.

Now let’s take a look at the intersection of Old 22 and Route 737.  A narrow square intersection between four historic buildings that make up the “center of town” for Krumsville with a four way stop and a blinking red light.  Traffic, on a normal day, queues up at this intersection, sometimes as many as eight vehicles deep in all four directions.  We brought this to the attention of PennDOT who stated that the intersection has always been an issue and there is no current resolution to this issue.

Per the PennDOT Policies and Procedures Transportation Impact Study, Level of Service Requirements, queuing traffic at an intersection cannot block parking areas, driveways, highway exits or back up onto highway overpasses.  At this time, normal traffic is backing up past the west bound on ramp and onto the bridge overpass.  When brought to PennDOT’s attention, Mr. Toomey responded that he was unaware that the traffic was queuing to that extent and he said he would look into getting a traffic impact study of the traffic on Route 737 north into the intersection.  (Action Item #2)

Bringing up some more issues with the intersection, regarding turning trucks, Mr. Toomey stated he had no idea why trucks would even be on Old 22 turning onto Route 737 south.  We offered to show him photos, taken over the persiod of an hour, showing not less than 31 trucks on Old 22, turning onto Route 737 or on Route 737 turning onto Old 22.  These photos are taken during normal traffic periods, and not during an I-78 detour.  Mr. Toomey declined to view the photos, stating that he believed me that there were tractor trailers on Old 22.  He did not percieve this to be an issue (see below photos of the one truck that I could reach out and touch, on the opposite corner, when he turned!) Again, we need to direct our Greenwich Township Board of Supervisor to enlist the aid of PennDOT to do a detailed traffic study of this intersection BEFORE approving the HOP to McMahon.

I was effectively cut off from asking the rest of my questions at this point by Solicitor Daniel Becker and they moved onto questions from the rest of the residents present.  Unfortunately, many of those questions were either already asked at the Board of Supervisors meeting April 3, or they were not related to PennDOT issues, or they were argumentative comments and suggestions which alienated the PennDOT representatives.

One interesting item did come up that is not related to PennDOT areas of expertise, but were answered by Jim Voser.  The question was “What about the swamp and marsh areas of the property?  Were they willing to provide natural habitat to the wildlife living in there. He stated they already had their DEP Permit to cross the swamp. In reading the March 16, 2017 notes from Chris Noll, Engineering Representative of Greenwich Township, it states that the DEP permits are still pending.  SO! We need to request a copy of that permit.

Just as a side note.  There are wild breeding pairs of Bob White quail on that property.  I know because they come onto my property and eat from my bird feeders.  While Bob White are not in the protected class of fowl in Pennsylvania, they are a disappearing bird and Pennsylvania is dedicated to protecting their numbers and their breeding ranges.  Read about it here. We need to reach out to DEP about the wild Bob White Quail living on this parcel of industrial land.

I did manage to gather more information (as listed above) to the rest of the questions I had to ask and although two of my questions were not answered at this meeting, directly, indirectly they were answered by either Mr. Toomy or Mr. Wichner.  I will save those two questions for the next BoS meeting on May 1, 2017.


Action item #1 – Dennis Toomey stated he would put in for a traffic light study to be done for the intersection of Old 22 and Rt 737.

Action item #2 – Dennis Toomey stated he would put in for a traffic impact study regarding the queuing of traffic at the intersection of Old 22 and Route 73 which blocks the westbound interstate exit and creates a line of traffic up onto the bridge over I-78.

Action item #3 – We want a copy of the DEP Permit acquired by McMahon to cross the swamp land on the parcel of property.  John W. stated that a DEP study was done and the permit was approved.

Action item #4 –


(prior to meeting ) We are building a list of questions and concerns to be addressed at this PENN DOT meeting, which will be at the Township Building on April 12th at 1:00 pm.  I will be there to represent those residents that cannot attend the meeting.  PLEASE, list your questions and concerns on this page of the Blog.

We have compiled additional complaints to be filed with Greenwich Township. This one is regarding Township Ordinance 802.0 Prohibited Nuisances. complaint4_form

My presentation of questions as follows:

The road structure in our small village of Krumsville is not able to handle any significant increase in traffic, specifically tractor trailer traffic.  At this time the blinking red light allows for vehicles to stop at the intersection proper.  If traffic is stopped several cars deep and a tractor trailer of any length over 30 feet needs to turn, the entire line of traffic either needs to pull out in front of the tractor trailer, or the entire line needs to back up to allow the tractor trailer to make the turn.  The wheel of the trailer are well into the oncoming traffic lane as the tractor trailer completes the turn.

Greenwich Township expressed concern for the safety of its residents with the increased traffic, both in cars for employees working in a 44 to 109 bay warehouse and in the amount of tractor trailer traffic.

Let’s address the intersection of Old 22 and Route 737 in this series of questions.

PennDOT states “A signal is not close to being warranted at the intersection, and there are no other reasonable fixes due to the structures on all corners of the intersection.”

Our questions:

  1. Does PennDOT and Greenwich Township agree that a 44 to 109 bay warehouse build on the proposed site will generate traffic well in excess of what this intersection in its current form can handle?
  2. Does PennDOT and Greenwich Township agree that the amount of tractor trailers passing through this intersection will pose a serious safety concern to the local citizens and to their property?
  3. Does PennDOT and Greenwich Township agree that any additional tractor trailer traffic through this intersection poses a serious safety concern to the local traffic?

Here’s some photos taken on April 4, 2017.  Normal traffic during the mid-afternoon, prior to school letting out and prior to the afternoon and evening coming home traffic starts.

The tractor trailer turning left at the light entered into the parking area in front of the Krumsville Inn and his trailer tires missed me (standing on the corner) by a mere foot.  The cars coming north on Route 737 had to back up to allow him to make the turn.  He made gestures out his window with his arm to direct those cars to back up, because he knew he could not make the turn safely.

040417_tt_turn1040417_tt_turnNow, let’s address the intersection as tractor trailers come off the newly designed westbound ramp of I-78 onto Route 737 north.  The ramp opens onto Route 737 a mere 120 feet from the intersection.  Take note of the telephone pole listing to the side.  Last week, on March 30, 2017, a tractor trailer came off the ramp too sharply and clipped the pole.

rampLet’s look at that 120 feet from the ramp, with one tractor trailer and one car, there is only enough room for one more car to exit off the ramp onto Route 737.  Imagine two, three or four tractor trailers merging off I-78 onto Route 737 north going to a warehouse.  The traffic will be backed out onto the ramp and any traffic coming north on Route 737 from the east bound exit or from Kutztown will be stopped on the bridge waiting their turn to go through the intersection.

ramp1And if another tractor trailer is wanting to turn from Old 22 onto Route 737 south to get onto I-78, he will have to wait until traffic is able to back up (see above scenario) which will now cause another backup on Old 22.

Let’s take a look at this tractor trailer making the left hand turn onto Old 22.  His trailer tires cross through the east bound traffic on Old 22.  In this case, one car was there waiting to cross the intersection and that car backed up to allow the tractor trailer to make the turn.

ramp2Due to the congestion that already happens at this intersection, during a weekday mid-afternoon, before the high volume begins, we have more questions:

  1. Is it even possible to allow tractor trailers, on a regular basis, to pass through this intersection to the proposed warehouse?
  2. What safety measures will PennDOT use to ensure that the tractor trailer traffic generated by the warehouse will not injure pedestrians or cars in this intersection?
  3. What type of enforcement will Greenwich Township put into place to ensure that the tractor trailer traffic adheres to safety measures put into place by PennDOT?

Let’s look at the other side of this intersection.  The south bound Route 737 has a small local road, Rhoades Road, which merges onto Route 737 just before the Route 737 and Old 22 intersection.  Currently, in normal traffic, especially during peak travel times in the morning and in the late afternoon, a resident at this stop sign to merge onto south Route 737 could be waiting as long as five minutes until traffic clears.

Greenwich Township expressed concern that congestion during peak hours create unsafe conditions at the intersection, and specifically for vehicles coming out of Rhoades Road.

PennDOT Responded: With or without the warehouse development, SR737/Old 22 is an existing concern within the Township.  There are no realistic physical improvements to the intersection due to the structures on all corners of the intersection.

The developer McMahon Responded: Site generated traffic is not projected to have significant impact on peak hour volumes at the intersection since the warehouse will likely be a 2 or 3 work shift operation with relatively consistent traffic to/from the site throughout the day.

Really???  REALLY???  Let’s look at some local warehouse distribution centers.

Orefield, 18 bays, 5 bay Que.  Open 6:00 am to 8:00 pm Monday through Saturday.  Handles an average of 802 trailers during that week.

Fogelsville, 32 bays, no Que.  Open by appointment only, 8:00 am to 6:00 pm Monday through Saturday.  Handles an average of 1014 trailers during that week.

Fogelsville, 40 bays with a 10 bay Que.  Open 6:00 am to 7:00 pm Monday though Friday and 6:00 am to Noon on Saturday.  Handles an average of 1300 trailers during that week.

Macungie, 66 bays with a 30 bay Que.  Open 6:00 am to 10:00 pm Monday through Friday. closed to trailers on Saturday and Sunday.  Handles an average of 1800 trailers during peak season.  And average of 1200 trailers off peak season.

Our questions regarding the Rhoades Rd intersection onto Route 737.

  1. Does PennDOT agree that currently there is a traffic pattern problem for local residents to safely merge onto Route 737 off Rhoades Rd? And then can we agree that any additional traffic generated by the warehouse for employee cars and tractor trailer traffic will create a safety hazard for those same local residents?
  2. If PennDOT cannot make any changes to the intersection, will Greenwich Township agree that the additional traffic generated by a warehouse will cause safety issues for the local residents and for travelers heading north through the intersection towards Kempton?
  3. PennDOT states a post-development study traffic study is typically required for these types of projects where the tenant in unknown during permitting.  We ask that a pre-development study be performed on the traffic already happening at this intersection.  What is the required steps to make this request official?
  4. SALDO 402.1 PennDOT Highway Occupancy Permit is required
  5. SALDO 515 Emergency access shall be provided in the event the entrance is obstructed for any reason.
  6. SALDO 516.1 Traffic impact study shall be provided in addition to PennDOT study