Re: Draft Environmental Impact Statement and Draft Section 4(f) Evaluation for the Baltimore-Washington Superconducting MAGLEV Project

Dear Brandon:

Environmental Review, Inc. has reviewed the Environmental Impact Statement Draft (EIS), and has the following comments:

Comments 

1. Section 4.11.51 titled, Minimization, states that to minimize the impact of wetlands located within Maryland City Park, west of BWP (Baltimore-Washington Parkway), the design of the SCMAGLEV Project will avoid direct placement of viaduct piers within this system, however, this section does not describe or give reference to where the piers will be constructed. According to the Wetland Location Map in Appendix D.7 Attachment E (pp.13), the elevated viaduct for both build alternatives (J-01 thru J-06/ J1-01 thru J1-06) will span over 2000 feet of continuous wetlands. Given this reasonable length, the viaduct pier locations should be properly identified, especially within a form of visual context such as the Wetland Location Map, to completely assure project design feasibility and minimization of impact to these high-quality Wetlands of Special State Concern.

2. According to Table 4.12-1, 575 to 627 acres of forest will be impacted by as they are located within boundaries of the Project Affected Environment of build alternatives J-01 thru J1-06. Much of the impact on these forests will involve forest clearing, grading, and land development which would directly remove forest and FIDS habitat (4.12.4.2). The removal of forests will have a large impact on existing air quality in the local environment, as one acre of forest is capable of sequestering approximately 2.5 tons of carbon annually.1 Carbon dioxide is the leading contributor to global warming2, thus, the deforestation that occurs in this project will have a significant impact in reducing the total amount of carbon sequestration provided by these forests per year. This impact to existing air quality, however, is nowhere mentioned in Section 4.16 titled Air Quality, which focuses solely on the emission production of the SCMAGLEV Project itself. An analysis on the indirect impact of deforestation on the local, existing air quality of the SCMAGLEV Project would capture a fuller scope of the project and its potential impact to climate change. In addition, it would be appropriate for this analysis to also be included within Chapter 4.23 titled, Indirect and Cumulative Effects.

3. In correspondence to the previous comment (Comment #2), the three TMF (Train Maintenance Facility) location options would result in substantial impacts to forests as each design requires at least 90 acres of forest habitat removal (4.12.4.2). Figure 4.5-1, which depicts Environmental Justice Population Areas, shows that all three TMF build options (BARC West, BARC Airstrip, and MD 198) are located within population areas consisting of mostly minorities. In addition to carbon sequestration, forests also remove harmful pollutants such as sulfur dioxide, ozone, and nitrogen oxides1, which levels will likely increase after extensive deforestation occurs. Minority communities in the United States are already exposed at a disproportional rate to polluted air compared to non- minorities3, thus, the proposed TMF locations would further inflate this issue.

4. Section 4.5.6 states that the Project Sponsor “identified and incorporated reasonable and feasible design elements in the Build Alternatives with the goal of avoidance or minimization of impacts to the natural and human environment, with targeted considerations for EJ (Environmental Justice) populations.” Given the targeted considerations for EJ populations, was a Build Alternative consisting of a TMF location outside of minority population areas ever considered? If so, why was a TMF location as such not included within this Draft Environmental Impact Statement, especially for the avoidance of impact to minorities?

5. A) In chapter 4.19 titled, Energy, Figure 4.19-5 depicts the demand profile of energy on a standard weekday. It is important to recognize, however, that the demand profile of energy on a standard weekday may differ during the winter season of a given year. The average low temperatures of Washington D.C and Baltimore, Maryland during the winter season is 29 °F and 27 °F respectively45, below the freezing temperature of 32 °F. At these sub-freezing temperatures, the aerodynamics of the train would be impacted as water that freezes on the train would ultimately increase its drag and weight6. Thus, the demand profile of energy on a standard weekday may increase during the winter season as efficiency would be negatively impacted. Figure 4.19-5 may prove misleading as it does not depict how seasonal temperature variability may affect the overall energy demand profile on a standard weekday during the winter season and should be considered.

   B) In addition, the eastern coast of the United States is expected to experience more frequent, stronger snowstorms as the effects of global warming continue7. Heavy snowfall also poses an issue to energy efficiency as it may limit the movement of the train if filling the gap level between the track and the levitating train itself 6. What proper mitigation techniques will the SCMAGLEV system utilize in order to mitigate snow disturbances to maintain energy efficient operation? Current use of viaduct hoods and/or sprinklers utilized in the maglev train by the Central Japanese Railway company seems to be a most fitting option.

6. Section 4.3.2.2 titled Methodology, states that the SCMAGLEV Project Affected Environment for land use is defined as “the area within a 500-foot buffer around the proposed alignments and ancillary facilities of the Build Alternatives and within a 1⁄4-mile around stations and Trainset Maintenance Facilities (TMF) locations” adding that “these buffers were considered to capture potential impacts.” A 500-foot buffer, equivalent to roughly two city blocks, does not seem adequate to capture all potential impacts of a project of this magnitude. Because potential impacts relating to visual/ aesthetics and noise/vibration would be reasonably expected to extend beyond 500 feet, consider increasing the buffer area.

7. Section 4.10.4 titled Environmental Consequences, identifies significant permanent impacts of the project to water resources, particularly from the construction of the Transportation Maintenance Facilities (TMF). For example, construction of the TMF sites is expected to degrade water quality, causing Little Patuxent River and its tributaries, as well as Beaverdam Creek to become impaired. To mitigate these consequences, we strongly encourage the Federal Railroad Administration (FRA) and the Project Sponsor to be diligent in their efforts to mitigate potential runoff by (1) reducing the area of impervious surfaces, and (2) seriously consider stormwater treatment trains to manage stormwater pollutants. With regards to reducing the area of impervious surfaces, Build Alternatives J1-04, J1-05, and J1-06 should be given greater preference over Build Alternative J-03 (the Project Sponsor’s preferred configuration), since J1-04, J1-05, and J1-6 have considerably less total permanent acres of impact according to Table D.7-10 (718, 714, 712 acres respectively compared to J-03’s 822 acres).

8. Section 4.15.3.1 titled Hazardous Materials Sites, identified hazardous materials sites within the SCMAGLEV Project Affected Environment. After identification, these sites were given a numerical Risk Ranking from 1 to 5 based on the potential of the site to pose threats to human health and the environment, with FRA focusing on sites with a Risk Ranking of 3 or higher. Two sites had a Risk Ranking of 4 for Build Alternative J-03: the Beltsville Agricultural Research Center Site 32 (BARC 32), and the Patuxent Research Refuge (PRR) High Explosive Impact (HEI) Area. The Project Sponsor, Baltimore-Washington Rapid Rail, LLC (BWRR), has indicated its preferred configuration to be Build Alternative J-03; however, it should be noted that J-03 has one of the highest number of sites with Risk Rankings of 3 or higher of all the Build Alternatives, as summarized in Table 4.15-1 Page 4.15-8. Conversely, Build Alternatives J1-04, J1-05, and J1-06 have the lowest number of sites with Risk Ranking of 3 or greater. 

When responses to these comments are available, please email those to me at This email address is being protected from spambots. You need JavaScript enabled to view it.

Sincerely,

Kobe Ramirez (Associate in California)
Environmental Reviewer 

Aubrey Glynn P.E (Associate in California)
Sr. Reviewer

Environmental Review Workshop

(Environmental Review, Inc., a 501(c)(3) Nonprofit Public Benefit Organization)

1792 Rogers Ave, San Jose, CA  95112

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