Baltimore-Washington Superconducting Maglev Project Draft Environmental Impact Statement and Department of Transportation Act Section 4(F) Evaluation

Baltimore-Washington Superconducting Maglev Project Draft Environmental Impact Statement and Department of Transportation Act Section 4(f) Evaluation Comments by the City of Greenbelt Comments also adopted by the City of College Park and the Town of Landover Hills MAY 24, 2021 I. INTRODUCTION The City of Greenbelt (Greenbelt) was created in 1937 by the federal government as the first of three New Deal “greenbelt towns” which pictured a union of city and country life as an attempt to solve social and economic problems confronting the nation. The city’s design integrated natural and built elements in a “unified plan for complete community life.”1 In the historic core of Greenbelt, homes are arranged in superblocks with the fronts of houses facing internal parks, gardens, and wooded areas designed to be the focus for the families living in the community. Internal walks lead residents from their homes through these parks and down to the community’s center, instead of routing pedestrians along streets. While the “belts of green between neighborhoods . offer easy contact with nature,” another of the defining features in the original design of the city is the belt of green surrounding the core and protecting it from encroaching development.2 In literature produced at the time, the U.S. Resettlement Administration noted: Around the town’s edge is the greenbelt, the distinctive feature of all the Resettlement Administration’s suburban communities. This girdle of permanent open space is intended to protect the town forever from overcrowding and undesirable building on neighboring land. In addition, it offers special opportunities for both recreation and gardening. Part of the area is reserved for parks and playgrounds. Other tracts are set aside as gardens . Still other sections are allotted to full-time farmers.3 The Resettlement Administration intended that once construction was finished, the federal government would withdraw, “except for insisting on competent management to protect its 1 Greenbelt: History of a New Town, 1937-1987, at 31 (Mary Lou Williamson ed., 1997). 2 Greenbelt City Link, History of Greenbelt, Maryland, “A National Historic Landmark”, https://www.greenbeltmd.gov/home/showdocument?id=2656, visited April 28, 2021. 3 United States Resettlement Administration, Greenbelt Towns, Washington, D.C. 1936. Additionally, in siting the greenbelt towns, the Resettlement Administration chose locations close to urban centers, but far from main thoroughfares. They write, “To protect it from the danger and annoyance of heavy traffic, the town has been located, where possible, a considerable distance from all arterial highways.” 1 investment and interests . and [that] care will be taken that the towns will be permanently administered as planned communities.”4 Greenbelt has retained large portions of its original green belt, although the city has grown beyond its historic core, with the surrounding farmland of the 1930s being bisected by highways and divided into privately owned parcels and developed. It has been stated that the Greenbelt of today looks “a bit like some of Europe’s medieval towns that have been recently surrounded by new modern neighborhoods.”5 Greenbelt East and Greenbelt West are comprised of detached housing subdivisions, small and large apartment communities, regional shopping centers and office parks, as well as many community assets including recreation centers and parks that reflect Greenbelt’s focus on community and the natural environment. Although they differ in design, the older and newer portions of Greenbelt are tied together through human institutions, civic spirit, and excellent community facilities. The federally planned and constructed portion of Greenbelt, the Greenbelt Historic District, is now designated as a National Historic Landmark. As is evident from the map below, see Figure I.1, the proposed Baltimore-Washington Superconducting Maglev Project (SCMAGLEV or Project) would alter and divide the city with no integrating or unifying features proposed in mitigation. This Project would have serious and substantial impacts on Greenbelt, without providing any benefits to the city or its residents. On the contrary, the Project would harm human health and the environment, destroy parkland, and reduce residents’ quality of life and property values. The SCMAGLEV would also cost billions of dollars, likely to be subsidized by the public, but provide benefits to only a small minority of people who are wealthy enough to afford the high fares and fortunate enough to live near one of its stations, of which there are only three, none of which is in Greenbelt. Making matters worse, the SCMAGLEV would negatively impact the true public transit options that serve the area, and the communities such as Greenbelt that rely on them. Furthermore, the negative impacts from the SCMAGLEV would disproportionately fall on environmental justice communities along the proposed routes. 4 Id. 5 Greenbelt: History of a New Town, 1937-1987, at 12 (Mary Lou Williamson ed., 1997). 2 Figure I.1: SCMAGLEV Build Alternatives within the City of Greenbelt and BARC 3 More generally, the draft environmental impact statement (DEIS) prepared by the Federal Railroad Administration (FRA) violates every law that applies to it, namely, the National Environmental Protection Act (NEPA), the National Historic Preservation Act (NHPA), the Department of Transportation Act (DOTA), and laws and policies implementing principles of environmental justice. As discussed in more detail below: • The DEIS is inadequate from the start. It does not evaluate all reasonable alternatives to the Project, largely because the FRA adopted a purpose and need that would first and foremost advance the Project Sponsor’s interests. The DEIS also improperly limits its evaluation of the environmental impacts of the Project to only the Washington, D.C. to Baltimore segment, even though Baltimore Washington Rapid Rail (BWRR), the Project Sponsor, has made clear that it plans to build the SCMAGLEV all the way to New York. • The DEIS presents artificially inflated economic benefits and at the same time it obscures the costs of the Project and who will bear those costs, including jobs lost from cuts to other public transit. Of particular concern, the DEIS relies on undisclosed methodologies to predict wildly inflated ridership figures and savings in travel time. Based on reasonable ridership assumptions, it is unlikely the SCMAGLEV would be profitable. The DEIS also does not present a reasonable estimate of construction costs, nor address who would pay for them. • Although the DEIS acknowledges that the Project would have massive impacts to waterways, wetlands, and floodplains, it does not describe the resource degradation that would occur. The DEIS largely ignores how tunnel construction and operation could impact groundwater, including aquifers that are sources of public drinking water. The FRA also has not provided information on how the Project will comply with important water and wetland permit requirements or the Maryland Chesapeake Bay Critical Area requirements, and the floodplain analysis that is provided fails to meet federal standards. • The DEIS does not sufficiently identify impacted wildlife species, including rare, threatened, and endangered species, forest interior dwelling species, migratory birds, and wetland species. Additionally, the DEIS does not adequately evaluate the impacts the Project would have on these species’ habitat. • The DEIS recognizes the massive energy resources that would be needed for construction and operation of the SCMAGLEV but largely ignores the greenhouse gases and other harmful air emissions that would increase if the Project were built. Information in the DEIS appendices shows that the Project Sponsor’s claims regarding air quality benefits are false, but the presentation of this information in the DEIS obscures this fact. • For the Project to be properly designed, the length of the proposed tunnels, the complexity of the geology within the region, and the high-water tables present along the proposed alignments would all need to be taken into account. The DEIS nevertheless fails to provide site-specific geological and geotechnical analyses and supporting data that would explain the FRA’s selection of the two Project alignments and fails to assess the impact of existing soil strata on the tunneling design and construction plans. The 4 DEIS also fails to provide site-specific geological and geotechnical data and analyses to support the construction and operation decisions documented within the DEIS. The DEIS inappropriately postpones further geotechnical review until later in the design phase, which would not occur until after completion of the NEPA process. • The DEIS does not address important issues pertaining to Project safety, such as maintenance of way activities during operating hours, breakdowns, malfunctions, power losses, switches, and crashworthiness. The DEIS is therefore insufficient under NEPA and also is premature because the safety requirements for the Project have not yet been established. Although the Project Sponsor suggests that it will begin construction before the FRA decides whether and how the SCMAGLEV could operate safely, the FRA must make clear that it is unacceptable to proceed in this fashion, which would preclude conducting a full NEPA analysis and would likely result in billions of wasted taxpayer dollars. • The DEIS does not adequately evaluate the Project’s impacts on property along the proposed

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