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, includinga National Environmental Policy Act requirement to compare the

SCMagLev to existing transportation systems. Doing so would result in a Superior Alternative -

Amtrak and MARC.

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 ignores the existence of high-speed, ground-based transportation systems
alternatives, namely Amtrak, Amtrak Acela, and MARC. Comparison of the SCMagLev to
these alternatives is a requirement of the National Environmental Policy Act process. Not
including this analysis, evaluation, and comparison is a fatal flaw in the DEIS.
The Federal Railroad Administration completed a costly, multi-year assessment of the
Amtrak Northeast Corridor Future Plan and found that the enhancement and upgrade plans
outlined by Amtrak would meet the current and projected ridership requirement of the
Northeast Corridor. It concluded that an additional alignment was too expensive, too
disruptive, and not needed.
The DEIS makes no mention nor does it provide a comparison of the superior financial
solvency of Amtrak operations versus the SCMagLev.
The DEIS makes no mention of or discuss the West Baltimore MARC Express proposal that
would provide the same service as proposed by the SCMagLev. This option would use
existing MARC equipment and rail, with more convenient stations, at a far lower cost to the
ridership, which makes the MARC Express a far more attractive option for most residents in
and around Baltimore and Washington, D.C., who commute between the two cities.

Conclusion:

U.S. expert assessment of the safety of the train system, in a manner akin to the safety and
crashworthiness assessments of Amtrak and other U.S. rail transportation systems, is
needed.
The Federal Railroad Administration (FRA) must develop Rules of Particular Applicability
(RPA) allowing public comment for the independent assessment of the SCMagLev system
BEFORE their Record of Decision is completed and published.
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.
A comprehensive and independent expert assessment of the potential danger to human
and wildlife health from emissions and pollution that building and operating the SCMagLev
will bring so these impacts are known and quantified is needed.
A comprehensive and independent expert assessment of the financial viability of building
and operating the SCMagLev without the infusion of government subsidiaries (unlikely)
must be conducted. If government subsidies are required (likely), the full scope and size of
the required subsidies needs to be quantified and the source of funds identified.
A comprehensive and independent expert assessment comparing the capabilities, negative
consequences, costs, and benefits of building the SCMagLev versus continuing the
enhancement and integration of the FRA’s approved Amtrak Northeast Corridor Future Plan
is needed. This assessment needs to include identifying, quantifying, and weighing the
levels of integration these two competing systems have (or will have) with regional rail, bus,
and other commuter services (such as the D.C. Metro), as well as the level of access and
scope of the services offered to communities along their respective system’s routes.
A comprehensive and independent expert assessment of the impact on Amtrak from ridership and financial losses with the building and operating of the SCMagLev is needed. To maintain Amtrak viability, such ridership and financial loss will need to be addressed through increased government subsidies. The level of increased subsidies, identifying the source of funding for increased subsidies, and the impact the loss of these funds will have when addressing other higher-priority transportation infrastructure projects (e.g., roads, bridges, tunnels) needs to be identified and quantified.

Recommendations:

Given:

The many legal requirements the DEIS must, yet failed, to address;
The obvious financial uncertainties of the SCMagLev project and operation;
The failure to provide the full scope of information required for independent analyses to
ascertain the viability of the Project;
The disruption, destruction, and fragmentation of hundreds of acres of protected and
fragile environment areas;
The industrial levels of pollution released into our watershed and communities;
No independent assessment and evaluation of the train, structures, and systems to U.S.
safety standards apart from a system currently running on a test and development track;
and
No required National Environmental Policy Act (NEPA) side-by-side comparison to existing
ground-based, high-speed transportation systems, such as Amtrak, Amtrak Acela, and
MARC, which are the far better alternatives than building an expensive, and likely to be
subsidized by tax dollars, transportation system only the wealthy can afford to use on a
regular basis.

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.