Citizens Against the SCMagLev (CATS) and the Maryland Coalition for Responsible Transit

(MCRT) assembled a team of experts from various fields and disciplines to review the SCMagLev

Draft Environmental Impact Statement (DEIS). We have found the DEIS significantly deficient in

many critical areas, including in addressing Federal and State Laws.

To read the entire MCRT-CATS submission, go to: www.mcrt-action.org, click on the SCMaglev

Opposition tab, and select MCRT SCMagLev DEIS Comments.

Findings:

• The DEIS fails to adequately address the requirements of federal and state law.

• The DEIS Statement of Purpose and Need and Alternatives Analysis impermissibly favor the

SCMagLev project over Viable Transit Alternatives outlined in the No Build Alternative.

• The DEIS violates National Environmental Policy Act Segmentation Principles by limiting the scope of

analysis to the Washington-to-Baltimore Corridor and ignoring the Project’s sponsor’s clear plan to

eventually extend the SCMagLev to the New York and Boston.

• The DEIS fails to adequately address the greenhouse gas impact of the Project.

• The Draft Section 4(f) Report to assess the Project’s use of parkland and historic resources was

inadequate.

• The DEIS fails to adequately analyze the Project’s impacts on meeting the Chesapeake Bay clean-up

goals.

• The DEIS inappropriately relies on future compliance with federal and state Water Quality and

Wetlands Permitting, a burden that will be difficult to meet given the Project’s substantial impacts.

• The DEIS seriously understates the Project’s impact on federal and state listed rare, threatened, and

endangered species and their habitat.

Conclusion:

A comprehensive and independent expert assessment identifying the serious and irrecoverable environmental and ecological damage and destruction that building the SCMagLev will bring to one of the last preserved research spaces on the East Coast so that the full cost to our state, counties, communities, and residents will be known is needed.

Recommendations:

Given:

 The many legal requirements the DEIS must, yet failed, to address;
 The disruption, destruction, and fragmentation of hundreds of acres of protected and fragile environment areas; and
 The industrial levels of pollution released in our watersheds and communities.

The recommendations are the following:

(1) Best Option: The Federal Railroad Administration Should Select the No Build Option.

Over $28 million of taxpayer dollars have already been spent studying the cost and benefit

of building the SCMagLev. The costs far outweigh any benefit. Stop the Project now and

invest the saved tax dollars into fixing and upgrading existing transportation infrastructure

(roads, bridges, tunnels), including Amtrak and regional rail systems such as MARC and VRE.

(2) Alternative Option (1 of 2): Establish Rules of Particular Applicability.

If the Federal Railroad Administration (FRA) decides to continue its consideration of building

the SCMagLev, U.S. Safety Standards (Rules of Particular Applicability [RPA]) must be

established. The RPA MUST INDEPENDENTLY assess, evaluate, and test support structures

and support and operating systems, especially cybersecurity strength and the

crashworthiness and survivability of the train, and provide these analysis and findings to the

public—with a 180-day review and comment period—BEFORE deliberating on a decision to

begin construction of the SCMagLev is even considered.

(3) Alternative Option (2 of 2): Prepare a Supplemental DEIS.

A supplemental Draft Environmental Impact Statement (DEIS) should be assembled to

address the comments, concerns, and questions identified and provided to the Federal

Railroad Administration. The supplemental DEIS would address the deficiencies, missing and

obfuscated information, and missing analyses and data identified during the review and

analysis of the SCMagLev DEIS by numerous teams of experts, including those affiliated with

local city and county governments, community, civic, and environmental organizations. This

supplemental DEIS needs to be provided to the public—with a 180-day review and

comment period—BEFORE deliberating on a decision to begin construction of the SCMagLev

is even considered.

The Maryland Coalition for Responsible Transit (MCRT) a nonprofit organization formed in 2020. MCRT’s mission is to evaluate transit projects for social equity, environmental justice, economic viability, and community accessibility. See MCRT’s Facebook page https://www.facebook.com/MCRTaction and our website at www.mcrt-action.org. Contact the MCRT at mcrtaction@gmail.com.

Citizens Against the SCMagLev (CATS) is an organization formed in 2016 when the initial Baltimore-Washington Rapid Rail (BWRR) and Northeast Maglev proposal to build the first phase of Japan’s SCMagLev train between Baltimore, Maryland, and Washington, D.C. As many questions were raised and not answered by the BWRR, community concerns arose. Residents came together to represent the interests of their communities and form CATS. CATS has evolved into a confederation of scientists, engineers, experts, community organizations, and citizens in support of transportation infrastructure improvements that benefit our communities, state, and nation. CATS has written numerous articles and provided testimony on legislation in Annapolis and has met with elected officials in Washington, D.C.,

CATS has identified better high-speed rail and commuter rail alternatives. See our CATS Facebook page at www.facebook.com/groups/citizensagainstscmaglev and our website at www.stopthistrain.org.