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 Finance and Ridership Issues.

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 provide the financial, ridership, job creation, and other required data and
analyses needed to substantiate the Project sponsor’s claims about the benefits and
viability of their financial model and forecasts.
The DEIS economic and ridership analysis is based on inaccurate assumptions and outdated traffic data. In particular, the Federal Railroad Administration provided a heavily redacted ridership and demand study that makes it extremely challenging to provide meaningful comments and analysis.
The DEIS provides insufficient information on ticket pricing and the relationship of ticket
revenue to financial requirements to operate, maintain, and service debt and taxes.
The DEIS does not provide information on the Project’s risk management, Project failure,
and decommissioning costs, including financial responsibility for these significant costs
should the Project fail.
The DEIS traffic analyses during construction and operation are seriously inadequate,
significantly underestimating traffic impacts and overestimating any net traffic
improvements.
The DEIS does not provide any analyses or estimates on the impact on ridership demand
and traffic reductions resulting from the massive use of telework during the COVID-19
pandemic.

Conclusions

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 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; 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—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.