Attachment C

Response to Comments

 

 

 

 

 

 

 

 

 

Attachment C: Summary of and Responses to Comments Received

on the Environmental Assessment

1.1 INTRODUCTION

This document summarizes and responds to substantive1 comments received during the public

comment period for the Environmental Assessment (EA) for the Brightline West Cajon Pass HighSpeed Rail Project (the Project).

The Federal Railroad Administration (FRA) made the EA available for review and comment by 

agencies and the public for a 30-day period between October 28, 2022 and November 28, 2022. 

A notice of availability of the EA was distributed via email and postcard to the Project mailing list

and local residents in the Project area. The Project area consists of the cities along the rail 

alignment, beginning in Victor Valley and terminating in Rancho Cucamonga. The EA was 

available on FRA’s website2 and Regulations.gov3 and its availability was advertised in the Rancho

Cucamonga Daily Bulletin, The San Bernardino Sun, and Victor Valley News. Public informational

meetings on the EA were held virtually on November 12, 2022 and November 15, 2022. The comment

period remained open until 5:00 PM on November 28, 2022.

Section 1.2 lists the organizations and individuals providing comments substantive to the EA. The

full text of all oral and written comments is included as Attachment D to the Finding of No

Significant Impact (FONSI).

Section 1.3 contains a summary of substantive comments on the EA, with a response to each.

These summaries convey the substance of the comments made, but do not necessarily quote the

comments verbatim. Comments are organized by subject matter and generally parallel the section

and subsection structure of the EA. Where more than one commenter expressed similar views,

those comments have been grouped and addressed together.

Where relevant, in response to comments on the EA, changes have been made and are noted in 

an Errata Memorandum for the EA, which is included as Attachment B to the FONSI. These

changes are noted in the applicable response to comments. 

1.2 LIST OF ORGANIZATIONS AND INDIVIDUALS WHO 

COMMENTED ON THE ENVIRONMENTAL ASSESSMENT

1.2.1 GENERAL PUBLIC

• Doug Sawyer, written testimony delivered November 27, 2022 (Sawyer).

• Elizabeth Lopez, written testimony delivered November 16, 2022 (E. Lopez)

1 Substantive comments are those made in regard to the context of the project and the EA.

2 https://railroads.dot.gov/rail-network-development/environment/environmentalreviews/brightline-west-cajon-pass-high-speed

3 https://www.regulations.gov/docket/FRA-2022-0090/comments

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Brightline West Cajon Pass High-Speed Rail Project

• Robert Lovingood, written testimony delivered November 13, 2022 (Lovingood)

• James Mauge, written testimony delivered November 14, 2022 (Mauge)

• John Husing, written testimony delivered November 16, 2022 (Husing)

• Anthony Titolo, written testimony delivered November 15, 2022 (Titolo).

• Anonymous, written testimony delivered November 27, 2022 (Anonymous 1)

• Anonymous, written testimony delivered November 13,2022 (Anonymous 2)

• Paul Tecson, verbal testimony delivered November 12, 2022 (Tecson)

• Marcus Nelson, verbal testimony delivered November 15, 2022 (Nelson)

• Tricia Almiron, verbal testimony delivered November 15, 2022 (Almiron)

• Andy Kunz, verbal testimony delivered November 15, 2022 (Kunz)

• Otis Greer, verbal testimony delivered November 15, 2022 (Greer)

1.2.2 ELECTED OFFICIALS

• Paul Cook, First District Supervisor, San Bernardino County, written testimony delivered 

November 17, 2022. (Cook)

• Debra Jones, Victorville Mayor, written testimony delivered November 15, 2022. (Jones)

• Art Bishop, Apple Valley Pro Tem Mayor, verbal testimony delivered November 12, 2022. 

(Bishop)

1.2.3 GOVERNMENT AGENCIES

• Daniel Little, Chief Intergovernmental Affairs Officer, San Manuel Band of Mission Indians, 

written testimony delivered November 28, 2022 (San Manuel-Little).

• Curtis Yakimow, Town Manager, Town of Yucca, written testimony delivered November

17, 2022 (Yucca-Yakimow).

• Town of Yucca Valley, written testimony delivered November 17, 2022. (Yucca) 

• John Gillison, City Manager, City of Rancho Cucamonga, written testimony delivered

November 28, 2022 (Cucamonga-Gillison).

• Sean Carlson, Team Manager, Environmental Planning Section, Metropolitan Water 

District of Southern California, written testimony delivered November 21, 2022 (MWDCarlson).

• General Manager, Victor Valley Wastewater Reclamation Authority, written testimony 

delivered November 21, 2022 (VVWRA).

• Joseph Jordan, District Wildlife Biologist, San Bernardino National Forest, Front Country 

Ranger District, written testimony delivered December 7, 2022 (SBNF-Jordan).

• N. Jamahl Butler, Acting Forest Supervisor, San Bernardino National Forest, Front

Country Ranger District, written testimony delivered after the close of the comment period

on December 14, 2022 (SBNF- Butler).

• Nancy Sansonetti, Supervising Planner, San Bernardino Department of Public Works

written testimony delivered on November 28, 2022 (SBPW-Sansonetti). 

1.2.4 BUSINESSES AND ORGANIZATIONS

• Benjamin G. Lopez, Director of Public Policy and Advocacy, Inland Empire Economic 

Partnership, written testimony delivered November 15, 2022 (B. Lopez).

• Steve Roberts, President, Rail Passenger Association of California and Nevada, written

testimony delivered November 25, 2022 (Roberts).

• Inland Action Inc. written testimony delivered November 27, 2022 (Inland Action).

• Inland Empire Biking Alliance, written testimony delivered November 28, 2022 (Inland

Empire).

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1.3 COMMENTS AND RESPONSES

1.3.1 GENERAL

Comment G-1: Commenters expressed support for the Project overall. Commenters 

noted the benefits of the Project, such as improved connectivity 

throughout the region for commuters, reduced carbon emissions, less air

pollution, and positive economic impacts. Commenters also noted that

because there would be fewer vehicles on I-15, the Project would reduce 

vehicle miles traveled, alleviate traffic congestion including reduced

spillover traffic, and as a result enhance safety. Additionally, commenters 

noted that the Project would enhance transit-oriented development by

providing a new travel option for commuters and residents throughout the 

region, improve travel times, and create more jobs and spur economic 

activity. (B. Lopez, Cook, Roberts, Sawyer, Lovingood, Inland Action,

Yucca-Yakimow, Mauge, Husing, VVWRA, Jones, Titolo, Anonymous 1,

Anonymous 2, Yucca, Tecson, Bishop, Nelson, Almiron, Kunz, Greer)

Response G-1: Thank you for your comments. Your support for the Project has been

recorded as part of the record.

Comment G-2: Two commenters asked for an extension to make comments because the

30-day public comment period included the Thanksgiving holiday. (E.

Lopez, San Manuel-Little)

Response G-2: FRA considered this request to extend the established comment period. 

While FRA ultimately decided not to officially extend the comment period, 

comments received after the official close of the period were still 

considered and responses are provided within this document.

Comment G-3: The commenter inquires whether the EA has been completed and 

whether the Project can break ground following issuance of a Record of

Decision (Tecson). 

Response G-3: A Record of Decision (ROD) represents the conclusion of the 

Environmental Impact Statement (EIS) process. For this Project, the 

relevant decision document is the FONSI, which represents the

conclusion of the EA process. Further federal actions and approvals

required prior to breaking ground are presented in Exhibit 1 of the FONSI. 

Comment G-4: The commenter noted that the Project includes areas designated as 

zones D, A, AE, X-shaded, and the Regulatory Floodway based on the 

Federal Emergency Management Agency (FEMA) Flood Insurance Rate

Map and noted that impacts and proposed mitigation associated with 

work in these floodplains should be included in the EA. The commenter

also recommended the continuous use of Comprehensive Storm 

Drains/Master Plans of Drainage to identify the potential alignments of 

future drainage and flood control facilities. The commenter recommended

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Brightline West Cajon Pass High-Speed Rail Project

U.S. Department of Transportation enforce the most current FEMA 

regulations for construction within a Special Flood Hazard Area (SFHA)

and floodplain. Lastly, the commenter requested that FRA continue to

coordinate with the San Bernardino County of Flood Control District

(District) if there are new activities or impacts to during the on-going

review process and noted that District facilities built by the Army Corps of 

Engineers (ACOE) will require the District to obtain approval (408-Permit)

from the ACOE (SBPW-Sansonetti). 

Response G-4: Impacts to floodplains are discussed in Section 4.4 of the EA and in the 

Floodplains Technical Report prepared by HNTB (included as

Attachment E to the EA). The analysis in these documents focuses on 

impacts to Zones A and AE as these have the highest potential for

flooding (1-percent annual chance flood). Zone X (shaded) (minimal flood

hazards) and Zone D (undetermined flood hazards) were not included in

the analysis because they are not considered high-risk flood zones. As

discussed in Section 4.4.6 of the EA, Brightline West will implement

BMPs prior to construction to minimize the temporary effects on 

floodplains, and Brightline West will not store construction equipment or 

materials within the floodplain. Brightline West will return any temporary 

effects on floodplains to preconstruction conditions and no permanent

effects to floodplains would occur. Brightline West will coordinate with the 

District on the alignment of future drainage and flood control facilities and 

will obtain all required permits prior to construction.

1.3.2 SECTION 4.1 AIR QUALITY 

Comment AQ-1 The EA states that the Project will result in emissions of criteria pollutants 

and- GHGs and identifies several mitigation measures to address such

impacts. Mitigation Measure AQ-1 is focused on controlling fugitive dust

during construction. One element of Mitigation Measure AQ-1 to prevent 

Project-related track-out onto paved surfaces is to “[r]educe nonessential

earth-moving activity under high wind conditions.” This measure may not

fully mitigate dust originating from disturbed areas. The commenter

requested that Mitigation Measure AQ-2 be improved to ensure the same

regulatory requirements are applicable to dust mitigation according to the 

South Coast Air Quality Management District requirements and local 

ordinances. (Cucamonga-Gillison)

Response AQ-1 The Errata Memorandum (Attachment B to the FONSI) includes revisions 

to Mitigation Measure AQ-2 to ensure that all regulatory requirements

applicable to fugitive dust mitigation are included according to the South

Coast Air Quality Management District requirements and local ordinances. 

These include but are not limited to submittal of a Fugitive Dust Control Plan 

and permits required by the South Coast Air Quality Management District 

and the City of Rancho Cucamonga.

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1.3.3 SECTION 4.2 NOISE AND VIBRATION

Comment NV-1 The EA identifies nine single-family homes along the northbound side of the

proposed alignment that are projected to have moderate noise impacts, not 

significant enough to require mitigation for noise or vibration. The City of 

Rancho Cucamonga has been contacted by these residents who are 

concerned about the potential impacts on their quality of life and property 

values. The commenter requests that FRA consider requiring Brightline West

to pay for upgraded windows and insulation in these homes to offset any 

potential, even below the level of significance, that vibration or noise may 

have to these residences. 

The EA also assumes minimal impacts due to vibration because the work 

will be at least 100 feet from existing development due to the location in the

median of I-15. However, Final EA should acknowledge that the alignment

of the Project corridor south of Church Street will move to the west and closer 

to existing development. This realignment should also be incorporated into

the FRA’s final determination during final design. (Cucamonga-Gillison)

Response NV-1 The City’s concern regarding noise and vibration impacts on the nearby 

residents’ quality of life and property value is noted and is recorded as part 

of the record. As discussed in Section 4.2.5.3 of the EA, at all locations, the 

impacts due to traffic noise from lanes being shifted closer to sensitive 

receptors would result in a noise increase at nearby sensitive receptors that

would be noticeable, but would not rise to the level of community annoyance.

This finding conservatively assumes that existing traffic trends would persist 

with implementation of the Project. Given that traffic-related noise levels 

during operation of the Project would be lowered due to the reduction in

VMT, the actual change in traffic noise at these locations is expected to be 

negligible. Therefore, additional noise attenuation measures in the form of

upgraded windows and insulation to nearby homes would not be required. 

No impacts from construction or operation of the trains themselves were

identified in this location.

As discussed in Section 4.2.5.2 of the EA, vibration associated with

construction would not result in impacts to existing development because the 

Project footprint is at least 100 feet from the development. The footprint

includes the realignment of the Project corridor south of Church Street,

where construction activities would occur at least 100 feet away from existing 

development. At this distance, vibration from construction activities would

not impact the development. 

1.3.4 SECTION 4.3 WETLANDS AND STREAM AREAS

Comment WS-1 A commenter noted that the EA mentions that the Project crosses the Day

Creek channel but does not discuss any potential impacts due to any such

crossing. The EA notes that proposed bridges over Day Creek and East

Etiwanda Creek would fully span the channels of those features, that is,

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bridge piers would not be placed in the channels. No construction work is 

proposed in the channels of Day Creek and East Etiwanda Creek. Oro

Grande Wash is culverted at the Project crossing, so no construction work is 

expected at this crossing. No construction impacts are expected for these 

crossings. The commenter recommends this detail be included in the EA to

make it clear that the Day Creek crossing was analyzed. (CucamongaGillison)

Response WS-1 The Errata Memorandum (Attachment B to the FONSI) includes revisions 

to the Day Creek discussion to clarify that proposed bridges over Day Creek 

East Etiwanda Creek would fully span the channels and that no construction

work is proposed within the creek channels.

1.3.5 SECTION 4.5 BIOLOGICAL RESOURCES 

Comment BIO-1 One commenter noted that existing undercrossings are used for wildlife 

crossings and there may be some threatened and endangered species 

(TES) wildlife species close to the Project area. The commenter suggested

that surveys be conducted in the area. (SBNF-Jordan)

Response BIO-1 The commenter’s suggestion is noted. As described in Section 4.5.6 of the

EA, preconstruction surveys will be conducted for special status species that

have potential to occur in the Biological Study Area to determine the 

presence/absence of these species. 

Comment BIO-2 Section 4.5, Biological Resources: General Measure (GM) 25- Maintain

Existing Wildlife Crossings indicates existing wildlife crossings will be 

modified or redesigned to ensure crossings are functional. Modified wildlife

crossings should maintain pre-existing characteristics, such as terrain and

natural light, to the maximum extent practicable. (SBNF-Butler)

Response BIO-2 As described in under Section 4.5.5 of the EA, Mitigation Measure BIO-25,

new culverts, bridges, and viaducts will align with all existing culverts, 

bridges and viaducts along I-15 to maintain these wildlife crossing corridors. 

For example, the Project would lengthen the existing I-15 culverts in the

same locations, allowing the culverts to continue to function as wildlife

crossings. The Errata Memorandum (Attachment B to the FONSI) includes 

revisions to Mitigation Measure BIO-25 to reflect that modified wildlife

crossing would be designed to maintain pre-existing characteristics to the

extent feasible.

Comment BIO-3 One commenter questioned how FRA has concluded that there will be no 

significant impacts to resources such as plant and desert tortoise prior to 

conducting their review/assessment, if the EA states that review/assessment

of these resources has yet to be conducted. (San Manuel-Little)

Response BIO-3 FRA consulted with USFWS throughout the development of the EA for all 

threatened and endangered species. The conclusion in the EA is based on 

consultation with the USFWS and their determination that the desert tortoise

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Response to Comments on the Environmental Assessment

is “exceedingly unlikely” to occur in the Project area. As documented in the

Biological Opinion issued on April 6, 2023 (Attachment C to the FONSI), 

USFWS concurred that the Project “is not likely to adversely affect desert

tortoise, Southwestern willow flycatcher and its designated critical habitat, 

yellow-billed cuckoo, coastal California gnatcatcher, Santa Ana River woollystar, and the slender-horned spineflower.” According to USFWS, surveys are

not warranted. 

1.3.6 SECTION 4.7 AESTHETICS AND DESIGN QUALITY

Comment AES-1 The Rancho Cucamonga Station will be elevated on a structure and will

detract from partial views of the San Gabriel Mountains from nearby office 

buildings. In addition to the avoidance and minimization measures already 

identified, the commenter recommends that Brightline West be required to

include a modest open space on the roof of the Rancho Cucamonga Station

which would create a space for users of the station to take their dogs, stretch

their legs, and potentially provide some modest habitat for migrating birds. 

Placing this open space on top of the station would also allow for views of

the mountains that are being diminished from other vantage points and 

thereby mitigate aesthetic impacts from the Project. (Cucamonga-Gillison)

Response AES-1 Given Brightline West’s train station design, it is not feasible to have park or 

open space on the roof of the Rancho Cucamonga Station. The mitigation 

measures described in Section 4.7.6 of the EA require the station area to be 

developed with architecture that complements the surrounding urban

landscape character with flowing lines, form, and muted colors to address 

adverse aesthetic impacts from the station. The station and its associated

surface parking lot will be landscaped with ornamental and native vegetation 

to soften the appearance of structures and hard surfaces. The landscaping

will include drought-tolerant trees, shrubs, and groundcovers, as well as rock 

and stone. Pedestrian elements such as pathways, structures, and signage

will be developed to pedestrian scale and will incorporate patterns, colors, 

and symbols that represent and complement the surrounding landscape.

Comment AES-2 The EA states, “Disturbed areas within Caltrans right-of-way will be regraded

to soften their contours and will be replanted as directed by Caltrans and 

within six months of the completion of construction.” The commenter

recommends this requirement should also apply to areas outside of Caltrans’

right-of-way, such as City-owned property or privately owned property, to be 

regraded and replanted where disturbed. (Cucamonga-Gillison)

Response AES-2 The Errata Memorandum (Attachment B to the FONSI) includes revisions 

to Section 4.7.6 to clarify that city-owned and private property used for TCAs 

would also be regraded where disturbed.

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Brightline West Cajon Pass High-Speed Rail Project

1.3.7 SECTION 4.8 LAND USE AND COMMUNITY FACILITIES

Comment LU-1 A commenter requested revisions to the EA to reflect the terms negotiated

between the City of Rancho Cucamonga and Brightline West and to reflect

the City’s plans for certain property near the station. (Cucamonga-Gillison)

Response LU-1 Brightline West may enter into agreements with other parties; however, 

these agreements are generally outside the scope of FRA’s NEPA analysis, 

which is based on the environmental effects of the federal action. FRA

acknowledges ongoing coordination between Brightline West and the City

and, where relevant for the environmental analysis, has reflected this 

coordination in the EA. Section 4.8 of the EA, Land Use and Community

Facilities, includes an evaluation of the Project for compatibility with future

development envisioned in the Rancho Cucamonga General Plan and

Empire Lakes Specific Plan.

Comment LU-2 One commenter opposed the proposed location of the Traction Power

Substation. The station is proposed to be on City-owned property adjacent

to I-15 off Jack Benny Drive in the City of Rancho Cucamonga. The

commenter states that the proposed property for the substation in the EA is 

not a part of the development and disposition agreement between the City

and Brightline West and that the City has never offered this property for a

traction power substation for the Project. Based on conversations between 

Brightline West and the City of Rancho Cucamonga, the City believes that

the EA’s reference to the substation being located on the City-owned

property is incorrect and that it will be located on non-City owned property 

elsewhere within the Project limits. The commenter stated that Brightline 

West has represented that it will not take City-owned property for Projectrelated use and requested the text to be deleted. (Cucamonga-Gillison) 

Response LU-2 FRA received clarification from the Brightline West that this substation and

City property will not be needed to construct or operate the Project. The 

facility anticipated in this area is a paralleling station which will be located

within the Caltrans I-15 right of way. The Errata Memorandum (Attachment 

B to the FONSI) includes revisions to read "Two traction power paralleling

stations, one in Hesperia and one in Rancho Cucamonga, will be sited in the 

Caltrans right-of-way within the limits of disturbance between the northbound

and southbound lanes of I-15." No traction power substation or paralleling

station will be placed on City-owned property. 

Comment LU-3 A commenter noted that multiple utilities, easements, and an existing SBNF 

communication site also exist within the Cajon Pass and cross I-15. Vehicle

access to the SBNF communication site will need to be maintained. 

Coordination with the utility companies that manage this infrastructure will 

be needed. (SBNF-Butler)

Response LU-3 The Project will maintain access on local roads, including those providing

access to the SBNF communication site, during construction. Where

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necessary, detours will be provided. During operation, access will be the 

same as existing conditions. Additionally, Brightline West will coordinate with

the relevant utility companies in areas where construction of the Project

would temporarily disrupt existing utility operations.

1.3.8 SECTION 4.10 HAZARDOUS MATERIALS

Comment HAZ-1 A commenter requested that the EA be updated to include more detail 

regarding the anticipated demolition and/or removal of buildings near the

Rancho Cucamonga station. The commenter stated that the City of

Rancho Cucamonga is unaware of demolition required near the station 

and thus cannot fully comment on whether there are additional impacts

from this statement. Additionally, reference is made to a property with 

hazardous materials located at 8886 Vincent Avenue in Rancho

Cucamonga. The City of is also unaware of a property with this address.

The commenter requested that the address be confirmed, and the EA 

updated as appropriate. (Cucamonga-Gillison)

Response HAZ-1 The Errata Memorandum (Attachment B to the FONSI) includes a

revision to the second sentence under Section 4.10.5.2 of the EA 

clarifying that demolition and/or removal of buildings is not anticipated 

under the Build Alternative. The information on properties with hazardous 

materials is based on historic records search. Although the records 

search indicates that 8886 Vincent Avenue is the address, the property 

is located at the southern end of White Oak Avenue. Therefore, the 

correct address appears to be 8886 White Oak Avenue and will be 

updated in the Errata Memorandum. 

1.3.9 SECTION 4.11 CULTURAL RESOURCES

Comment CUL-1 A commenter stated that the following is inaccurate: “FRA did not identify

any archeological resources or tribal cultural resources within 200 feet of the 

rail alignment”. The commenter also claimed that several statements about

potential impacts lack of awareness of cultural activities that would occur

within 200 feet of the alignment. (San Manuel-Little)

Response CUL-1 To date, FRA has not identified any cultural resources within 200 feet of the 

Project centerline where the railway has been proposed. 

Regarding cultural activities, FRA has consulted with the Yuhaaviatam of 

San Manuel Nation throughout the development of this EA, and consulted

with the appropriate parties, including with federally-recognized tribes, 

regarding cultural activities consistent with Section 106 of the National 

Historic Preservation Act (Section 106). Section 4.8 of the EA focuses on 

impacts to existing and planned land uses, including traditional tribal uses.

Elsewhere (such as in Section 4.5, Biological Resources, and Section 4.11,

Cultural Resources) FRA evaluated impacts to important resources that are

intrinsically valuable regardless of whether an existing use of that resource

has been identified. In addition, FRA has identified several resources that

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convey Traditional Cultural Landscape (TCL)-type of significance.

Consistent with Section 106, FRA addressed the TCL in the Finding of

Effects report and in the Finding of No Adverse Effect for the Project. FRA 

received no objection from the State Historic Preservation Officer on its

finding (SHPO). 

Comment CUL-2 A commenter recommended that the noise and vibration study should also 

look at the impacts of noise and vibration on archaeological sites and cultural

landscapes, which should include assessment for each of the NRHP-eligible

sites and/or districts noted within the Project area. (San Manuel-Little)

Response CUL-2 FRA has noted the Yuhaaviatam of San Manuel Nation's comments and

continued to consult with the tribe through the Section 106 and NEPA

process. Although the Noise and Vibration technical study did not specifically 

target "each of the NRHP-eligible sites and/or districts" in the APE, the study 

consists of hundreds of observation/measurement points along the

alignment. Based on this data, FRA determined that there will be no noise

impact to any resource beyond 200 feet of the proposed railway and no

vibration impact to any physical structure or entity beyond 25 feet of the

proposed railway. Vibration produced by this kind of project will not affect 

organisms in the open air. In addition to the analysis provided in the EA, 

FRA’s findings are documented in the Finding of Effects report and in the 

Finding of No Adverse Effect. FRA received no objection from the SHPO on

its finding. .

Comment CUL-3 A commenter asserts that FRA continues to focus on impacts to Tribal

activities and practices in their assessment for certain resource categories,

such as noise. Cultural setting is about the overall sensitivity of the 

landscape, from sacred areas to ancestors, that require additional

consideration beyond “activities.” (San Manuel-Little)

Response CUL-3 FRA acknowledges this comment. The focus on impacts to activities and

practices reflects the FRA noise evaluation criteria that evaluate noise and 

vibration impacts to people. As part of the Section 106 consultation, FRA

consulted with federally-recognized tribes regarding cultural setting to inform

its evaluation of potential impacts to cultural resources. FRA identified

several resources that convey TCL-type of significance and considered 

whether the Project would result in impacts to these resources, including 

impacts to the cultural setting. However, FRA found the Project would not

result in significant impacts to these resources. This finding is consistent with 

FRA’s Finding of No Adverse Effect for the Project, prepared in compliance

with Section 106. 

Comment CUL-4 A commentor indicates they continue to be concerned by the premature

assessment concluding that the Project will not have a significant impact to

cultural resources given:

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• FRA continues to struggle with the inclusivity of cultural landscapes 

in their delineation of the Area of Potential Effect (APE) 

• Archaeological due diligence for the Project continues to be a

problem.

• Tribal consultation to both identify and minimize impacts to cultural

resources is still ongoing.

• Lack of specific information prevents FRA from properly identifying

potential impacts to identified resources as a result of the Project, 

specifically those of concern and cultural importance to the Tribe.

(San Manuel-Little)

Response CUL-4 FRA has noted The Yuhaaviatam of San Manuel Nation's comments. 

Regarding APE delineation, FRA incorporated the APE, developed through

the Section 106 process and consultation with, the SHPO, and Consulting

Parties, including the Yuhaaviatam of San Manuel Nation into the EA. The 

APE was defined based on consulting party input and reflects the magnitude 

and nature of the Project, the potential historic properties present, and

potential effects caused by the Project. FRA acknowledges that at the time

the Draft EA was published the Section 106 consultation was ongoing.

However, since publication of the Draft EA, the APE has not changed. FRA

continued to consult with the Consulting Parties and completed the Section

106 consultation on June 30, 2023 with a Finding of No Adverse Effect. FRA

received no objection from SHPO on its finding.

1.3.10 SECTION 4.12 TRANSPORTATION 

Comment TR-1 A commenter noted corrections in Section 6.1.1.4 Active Transportation,

6.1.2.4 Active Transportation, and 6.2.4 Active Transportation of the Traffic

and Transportation Technical Report. These sections state that the Project

is not anticipated to affect active transportation because it is along rights-ofway not believed to be intended for bicycle or pedestrian use. The 

commenter noted that this is not correct since Caltrans allows bicycles the

use of freeway shoulders in areas where there are no other alternatives 

options for travel and the Project encompasses one such portion of Interstate 

15 (I-15). (Inland Empire)

Response TR-1 Bicycle access on I-15 will be maintained during operation and detours will

be included where necessary during construction to maintain access. This 

has been specified in the Errata Memorandum (Attachment B to the

FONSI). 

Comment TR-2 A commenter noted that per the Caltrans District 8 State Highway System

Bicycle Access Map1, bicycles are allowed to use I-15 in the Project area

from Cleghorn Road to Oakhill Road in both directions. Thus, the Project 

should be sure to mitigate any impacts that would be incurred on bicyclists 

for that area to ensure that bicycle travel remains available both during 

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construction and in the after condition once the Project is complete. (Inland

Empire)

Response TR-2 Existing bicycle and pedestrian access will be maintained during both

construction and operation. This point has been specified in the Errata 

Memorandum (Attachment B to the FONSI).

Comment TR-3 A commenter expressed that it seems unrealistic that forecast mode split to

either the Rancho Cucamonga or Hesperia stations would not include

anyone arriving by bicycling or walking. While the commenter agrees that 

many potential customers and employees would arrive by driving, TNC, or

transit, the planned development adjacent the Project which would include

housing is certain to include some individuals who would choose to not drive

to the Rancho Cucamonga station. Furthermore, both bicycling and walking

are not uncommon modes of transportation used to access Amtrak and 

Metrolink services in the region, including at Rancho Cucamonga.

Although it is often understood to be “conservative” to assume a lower use

of alternative transportation options than actual to prepare for a “worst case 

scenario” of drivers, it still is problematic to assume that there would not be 

anyone accessing any of the stations via active means, particularly if that

results in failing to make efforts to change that. As has been demonstrated

by a number of studies, the bike and train combination can be timecompetitive with driving even on regional trains and given that the Project

will be faster, it would greatly increase the range over which the service is

seen as a viable option. (Inland Empire)

Response TR-3 The commenter’s concern regarding the mode split forecast is noted. As 

described in Section 4.3 of the Transportation Technical Report (Attachment 

I), the ridership forecast was developed to analyze a worst-case scenario in

order to allow a conservative analysis of the environmental impacts of the 

Project. This method accounts for impacts from other modes of

transportation including bicycling. Any additional riders that would arrive to

the stations by walking or bicycling would reduce impacts as compared to 

those disclosed in the EA.

Comment TR-4 A commenter noted that overpasses and interchanges often present barriers 

to active travelers and wants to ensure that rebuilding and modifying these 

structures would incorporate the guidance from the FHWA and Caltrans to

ensure that the deficient conditions are not perpetuated even after major 

construction occurs that could correct those issues. (Inland Empire)

Response TR-4 The Project will comply with FHWA and Caltrans guidance to ensure

overpasses and interchanges would not obstruct access of active travelers

after rebuilding and modification. 

Comment TR-5 The commenter noted that National Forest System Roads exist in the Project

area and include 3N21, 3N24, 3N53, and 3N55. Long-term access of these

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roads will need to be maintained. Coordination of short-term impacts with the

SBNF will also be needed. (SBNF-Butler)

Response TR-5 The Project will maintain access to National Forest System roads both during

construction and operation. 

Comment TR-6 A commenter opposed the proposed parking mitigation measures for the 

Rancho Cucamonga Station, citing that there is no City-owned property 

available for the expansion of existing parking facilities or construction of 

additional parking facilities. The referenced City property is being considered 

for development for housing, hospitality, and restaurant uses and is

specifically not available according to agreements with Brightline West for

long-term parking. The commenter recommends this mitigation be removed. 

(Cucamonga-Gillison)

Response TR-6 FRA's analysis assumes that a proposed parking structure with 4,100

parking spaces will be constructed at the Rancho Cucamonga station to

provide shared parking for MetroLink and Project passengers. FRA's

analysis shows that this amount of parking is sufficient for passenger needs 

through 2025, but that by 2045 additional parking may be needed. As 

discussed in Section 4.12.6.4 of the EA, FRA included mitigation for this 

potential future impact which includes multiple measures to be taken by 

Brightline West which would be documented in a parking demand 

management plan to be prepared prior to opening for service. The plan 

would include many measures intended to reduce parking demand and/or 

spread demand beyond peak periods. The very last measure listed is 

expanding existing parking facilities or constructing additional parking

facilities on City-owned property adjacent to the station is one of the many 

optional measures of parking mitigation. This last measure would require 

City approval prior to implementing. As such, FRA has removed this as 

reflected in the Errata Memorandum (Attachment B to the FONSI) as the

other measures listed should adequately reduce and avoid this impact.

Comment TR-7 A commenter requested that Brightline West coordinate and develop

agreements with existing users that have large off-site parking facilities so 

that those large facilities’ often unused parking structures may be partially

repurposed for greater districtwide parking. (Cucamonga-Gillison)

Response TR-7 Section 4.12.6.4 of the EA indicates the following as an 

avoidance/minimization option if needed for future parking needs: Providing

off-site parking at existing underutilized parking facilities within 5 miles of the

station, including a free shuttle for passengers who park at an off-site parking

facility, and identifying any additional off-site parking facilities that are 

anticipated to be required within the next five years based on ridership

forecasts. This avoidance/minimization measure has been revised to require

that Brightline West enter into voluntary parking agreements with public and

private property owners within the 5-mile radius. This revision is shown in

the Errata Memorandum (Attachment B to the FONSI).

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Brightline West Cajon Pass High-Speed Rail Project

Comment TR-8 A commenter noted that the EA states “Reconstruction and I-15 freeway and 

interchange ramp modifications will also occur within the Caltrans right-ofway within the City of Rancho Cucamonga at SR-210, Beech Avenue,

Duncan Canyon Road, and Glen Helen Parkway.” The commenter stated

that the Beech Avenue, Duncan Canyon Road, and Glen Helen Parkway 

interchanges are not in the City of Rancho Cucamonga and recommended 

that the EA be updated to state that fact. (Cucamonga-Gillison)

Response TR-8 Thank you for your correction. The Errata Memorandum (Attachment B to 

the FONSI) reflects that Beech Avenue, Duncan Canyon Road, and Glen

Helen Parkway interchanges are not in the City of Rancho Cucamonga. 

Comment TR-9 A commenter was concerned with potential impacts of the Project to facilities 

and rights-of-way that belong to the Metropolitan Water District of Southern 

California (MWDSC). The commenter noted that the proposed Project would

be located in the median of I-15 where it would cross MWDSC fee-owned

property and the Rialto Pipeline. After reviewing the memorandum dated July 

18, 2022 from HNTB Corporation, Metropolitan's Substructures Team has 

the following comments on HNTB’s memorandum: The proposed singletrack high-speed rail crossing over our Rialto Pipeline and fee-property rightof-way as described in the memorandum, is conceptually acceptable to 

Metropolitan. However, the developer must submit plans and specifications 

for Metropolitan’s review and written approval at least 60 days prior to 

beginning construction. Additional supporting calculations, including a 3D

analysis, will be required to show that the proposed rail crossing will not

adversely affect Metropolitan’s Rialto Pipeline. (MWD-Carlson)

Response TR-9 The commenter’s concern regarding potential impacts of the Project to 

facilities and rights-of-way that belong to the Metropolitan Water District of 

Southern California (MWDSC) has been noted. Brightline West will submit 

plans and specification for MWDSC’s review at least 60 days prior

construction. Additionally, Brightline West will conduct a 3D analysis to 

support the plans during the final design phase.

Comment TR-10 A commenter opposed the proposed mitigation measures for the Milliken

Avenue/7th Street intersection, in which level of service will be degraded as

a result of Project implementation. To address the impact to the intersection 

of Milliken Avenue/ 7th street, the EA states that Brightline West will modify

the intersection at Milliken Avenue/Azusa Court to permit unprotected left 

turns into Azuza Court from northbound Milliken Avenue. The commenter

stated that this mitigation measure is inconsistent with Brightline West’s

commitment to both the City and SBCTA to install a full access traffic signal

at this location. The commenter requested the mitigation measure be

modified to correspond to Brightline West’s commitment and to require a full

access traffic signal at intersection of Milliken Avenue/Azusa Court.

(Cucamonga-Gillison)

Response TR-10 As described in Section 5.1.1.2 of the Transportation Technical Report, the 

traffic analysis included twelve intersections surrounding the Rancho 

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Cucamonga station area, including the intersections cited in the City's

comment. Of the intersections studied only one intersection would be 

impacted by the Project (Milliken Avenue/7th Street). Brightline West will

install a full-access traffic signal at the intersection of Milliken Avenue/Azusa

Court per the commenter’s request. This change has been reflected in the

Errata Memorandum (Attachment B to the FONSI). 

Comment TR-11 Section 4.12.6.1 of the EA also requires that Brightline West "Complete a 

focused engineering study to assess the intersection geometrics and ensure

a safe ingress to the proposed station via the Milliken Avenue/Azusa Court."

This study would allow a more detailed evaluation of this intersection

operation. If the engineering study concludes that a traffic signal is required

for safety, a traffic signal would be required as part of the mitigation measure.

The EA also acknowledges that the Project will contribute traffic to three 

intersections (namely Milliken Avenue/Foothill Boulevard, Milliken

Avenue/4th Street, and Milliken Avenue/1-10 WB ramps) that are projected

to operate at unacceptable levels of service during the 2045 No Build 

conditions. However, the City’s initial estimates for Milliken Avenue indicate

that at some point between opening year and horizon year, the traffic on the

segment of Milliken Avenue between 4th Street and Foothill Boulevard will

exceed the existing capacity only under Project build conditions. The 

commenter requested that Brightline West prepare a traffic study in

cooperation with the City to determine the timing of any potential exceedance 

in capacity and to fund Brightline West’s fair share costs of capacity 

enhancement needs identified in the study. This study is also needed to

better evaluate certain assumptions made in the EA analysis. The

commenter noted that the assumption in Attachment I is optimistic given the

timeline for related projects and the time required to induce a mode shift from

a primarily auto-centric public to using the high-speed rail. Furthermore, the

commenter requests that the impacts to the three intersections projected to 

operate at an unacceptable level of service be mitigated by requiring

Brightline West to provide a fair share contribution to upgrade these

intersections. (Cucamonga-Gillison)

Response TR-11 Section 4.12 of the EA identifies that the Project would contribute traffic to 

intersections that experience unsatisfactory conditions. However, as these 

intersections would operate at unsatisfactory conditions with or without the 

Project, FRA concluded the Project would not result in a significant impact. 

However, to address adverse impacts from the Project, Brightline West will 

comply with the San Bernardino County CMP policies to make fair-share

contributions to regional traffic improvements identified in the latest Nexus 

Study (2018), as described in Section 4.12.6. In addition, the Project’s fairshare contribution may be offset by the value of improvements that the 

Project will make at locations at which it is only partially responsible for the

increased delay. 

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Brightline West Cajon Pass High-Speed Rail Project

Comment TR-12 The EA states that Brightline West will coordinate with SBCTA, Caltrans,

Rancho Cucamonga, and Hesperia to incorporate intersection

improvements to lessen or avoid impacts under the 2045 Horizon Year to

the extent feasible with signal timing optimization. The commenter noted that

signal timing optimization alone may not be sufficient and that modifications 

to the intersections, traffic signals and other measure(s), should also be

required to fully mitigate any impacts from the Project on intersections.

(Cucamonga-Gillison)

Response TR-12 To address adverse impacts from the Project, Brightline West will mitigate 

modify and study the intersection of Milliken Avenue/7th Street as 

documented in Section 4.12.6.1 in the EA. In addition, for the three

intersections that the Project contributes to the unsatisfactory conditions, 

Brightline West will coordinate with the City of Rancho Cucamonga regarding

the improvements and contribute through a fair share arrangement.

Improvements may include signal optimizations and/or physical

improvements.

Comment TR-13 A commenter stated that traffic counts in the EA are inaccurate as they were

based on existing traffic counts conducted in August 2020 during the COVID19 pandemic when most California counties were under “stay-at-home”

orders which resulted in drastic reductions in traffic volumes across the

nation as well as locally in the City of Rancho Cucamonga. The commenter

recommended that the EA be amended to account for the impacts of the

COVID-19 pandemic on the traffic counts and incorporate historical traffic

data into the traffic analysis as appropriate to enable accurate assessment

of traffic impacts. (Cucamonga-Gillison)

Response TR-13 The commenter is correct that the existing conditions in EA are based on 

counts conducted in August 2020. However, the impact analysis and 

subsequent mitigations are based on opening year 2025 and horizon year

2045 traffic volumes. Opening year 2025 No Build intersection traffic 

volumes were estimated by applying annual growth rates to the 2020 counts,

then balanced along adjacent intersections within study corridors. These

growth rates have been applied to each turning movement at every study 

intersection and are generally in the range of 4-8 percent per year, with some

even higher, which is much more than the historical annual growth rate in 

the years leading up to the pandemic. The effect of these growth rates is to 

restore traffic volumes roughly to their levels prior to the pandemic. At the

time the forecasts were developed, the rate of recovery from the pandemic 

was unknown, so this approach resulted in a reasonable set of forecast traffic

volumes.

Year 2045 traffic volumes were developed by adding 25 years of growth

(based on the SBCTA travel demand model) to year 2020 traffic volumes. At

the time the forecasts were prepared, and even now, the long-term change

in travel behavior resulting from increased work-from-home activity was

unknown. It is reasonable to expect that actual 2045 traffic volumes may be

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slightly lower than they would have been without the broad changes in work 

patterns brought on by the pandemic. In addition, since the fair share

calculations are calculated by dividing Project trips by total growth, this

methodology results in a larger fair-share calculation than would be 

calculated using the assumption of higher 2045 traffic volumes. 

Comment TR-14 A commenter stated that the Transportation Attachment to the EA also

requires correction as the Attachment incorrectly states the City’s General 

Plan only requires a Level of Service D for segments and intersections in the

City are not included in the City’s Congestion Management Plan. The 

General Plan requires a Level of Service D or better except at locations 

determined to be acceptable at a worse level of service. No such locations 

have been identified. Therefore, a level of service D or better is required at 

all locations in the City. The commenter requested Attachment I to the EA 

be amended to correctly reflect the City’s level of service standards in the

General Plan. (Cucamonga-Gillison)

Response TR-14 Thank you for your correction. The Errata Memorandum (Attachment B to 

the FONSI) reflects changes to Section 4.1. As reflected in the comment,

Level of Service D is required at all locations in the City of Rancho

Cucamonga. Since all study intersections were held to the standard of LOS 

D or better, the analysis remains unchanged.

Comment TR-15 Section 4.3.1.2 Analysis Time Periods of Attachment I lists the Sunday peak 

time period from 1:00 – 3:00 p.m., but in Section 4.3.1.4 Existing and 

Forecast Traffic Volumes, the traffic counts for the Sunday “peak period”

were conducted between 4:00 – 6:00 p.m. This inconsistency should be

reconciled (Cucamonga-Gillison).

Response TR-15 Section 4.3.1.2 has been revised to state the correct time period of the

counts, which is 4:00 – 6:00 p.m. This correction is reflected in the Errata 

Memorandum (Attachment B to the FONSI). 

Comment TR-16 A commenter recommended that the parking management plan for the

Rancho Cucamonga Station should be done in conjunction and in 

cooperation with adjacent public and private property owners, including the

City, and to ensure the parking management plan is a districtwide solution 

with greater efficacy. (Cucamonga-Gillison)

Response TR-16 By its nature, the parking demand management plan described in Section

4.12.6.4 of the EA will require coordination with the City and other property

owners. 

Comment TR-17 A commenter also recommended that the neighborhood parking protection

plan for neighborhoods near the Rancho Cucamonga station should include

additional parking enforcement officers and be expanded to apply to The

Resort, 6th and 7th Street, Milliken Avenue, Azusa Court, Anaheim Place 

and any new residential subdivision streets. (Cucamonga-Gillison)

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Brightline West Cajon Pass High-Speed Rail Project

Response TR-17 Brightline West will coordinate with the appropriate parties, including the City

to develop and implement the parking demand management plan. . 

Comment TR-18 The EA states that Brightline West will coordinate with SBCTA and

Omnitrans to provide sufficient bus service to serve passengers at the

Rancho Cucamonga Station on Sundays and to provide additional service

during applicable time periods. The commenter requested that Brightline 

West fund either more frequent service for Omnitrans’ West Valley 

Connector and/or help fund a local City circulator using the City’s offsite

parking structures as it would better mitigate local transit impacts.

(Cucamonga-Gillison)

Response TR-18 The City’s suggestions have been added to Section 4.12.6.4 of the EA, as 

further mitigation options to meet future parking needs. This change is

reflected in the Errata Memorandum (Attachment B to the FONSI).

Comment TR-19 The EA states that the rail alignment will require I-15 highway and

interchange ramp modifications at Baseline Avenue. This road is misnamed

and is actually called “Base Line Road.” Additionally, there is no discussion

in the rest of the EA as to the extent, detail or impact of the modification at 

this interchange. The EA should be updated to either add such discussion, 

or, if the reference was included in error, remove the language from the EA.

(Cucamonga-Gillison)

Response TR-19 This sentence has been revised to read "Base Line Road". This correction is

reflected in the Errata Memorandum (Attachment B to the FONSI). The

improvements here are described at a level of detail similar to that used for 

the rest of the Project. As the design progresses and further details about 

these improvements are known, further environmental analysis may be

required if it is determined that construction or operation of the improved 

ramps have not been adequately covered by this EA.

1.3.11 SECTION 4.13 WATER QUALITY 

Comment WQ-1 A commenter is requesting the following amendments to the EA:

Mitigation Measure WQ-1 states, “BMPs will be selected to achieve 

maximum sediment removal and represent the best available technology 

that is economically achievable.” The EA should be amended to clearly state

which regulatory authority will determine whether BMPs represent the

economically achievable best available technology. Mitigation Measure WQ4 identifies a list of agencies that are to be contacted in case of a spill during

construction. This list should be amended to include the Rancho Cucamonga

Fire Protection District (“RCFPD”). RCFPD is the emergency response

agency for hazardous materials in the City of Rancho Cucamonga. Mitigation 

Measure WQ-7 requires BMPs to be sized and designed to “not allow

untreated stormwater runoff to reach to Mojave River, the California

Aqueduct, or any washes along the alignment.” This mitigation measure

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should be expanded to specifically reference the station sites as well as the 

longitudinal rail alignment. (Cucamonga-Gillison)

Response WQ-1 Mitigation Measure WQ-1 has been revised to state which regulatory 

authority will determine whether BMPs represent the economically 

achievable best available technology. Mitigation Measure WQ-4 has been

revised to include RCFPD. Mitigation Measure WQ-7 has been revised to 

include both Hesperia station and the Rancho Cucamonga station as well as 

longitudinal rail alignment. These changes are documented in the Errata

Memorandum (Attachment B to the FONSI).

1.3.12 SECTION 4.14 SAFETY

Comment S-1 A commenter requested that the City of Rancho Cucamonga technical 

development codes and the Rancho Cucamonga Fire Protection District’s 

Fire Standards be listed in the Regulatory Setting section for Section 4.14

Safety, as the Project will have to abide by City development standards and

fire protection codes. (Cucamonga-Gillison)

Response S-1 Brightline West would be expected to comply with all relevant City building,

development and fire codes pertaining to facilities and structure constructed

with the city limits. The Errata Memorandum (Attachment B to the FONSI)

reflects the addition of the City of Rancho Cucamonga technical

development codes and the Rancho Cucamonga Fire Protection District’s 

Fire Standards in the Regulatory Setting section for Section 4.14, Safety of

the EA. 

Comment S-2 A commenter referred to the EA where it says Brightline West will “design, 

construct, operate and maintain the Project in accordance with all relevant

Caltrans requirements” because the Project will be constructed in the

Caltrans right-of-way. To the extent that the Project will impact or have to

rebuild City owned assets in the City’s right-of-way, the commenter

requested that Rancho Cucamonga receive similar treatment as Caltrans.

(Cucamonga-Gillison)

Response S-2 Brightline West would be expected to comply with all relevant City building,

development and fire codes pertaining to facilities and structure constructed

with the City limits. City of Rancho Cucamonga technical development codes 

and the Rancho Cucamonga Fire Protection District’s Fire Standards has 

been listed in the Regulatory Setting section for Section 4.14, Safety of the

EA. This change is reflected in the Errata Memorandum (Attachment B to 

the FONSI).

Comment S-3 The commenter noted that the SBNF signed a decision in 2018 for an ignition

reduction project along I-15 through the Cajon Pass, in coordination with

Caltrans. This project will reduce hazardous fuels along the I-15 corridor with 

the objective to reduce wildfire starts and risk. (SBNF-Butler)

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Brightline West Cajon Pass High-Speed Rail Project

Response S-3 Section 4.14.5 of the EA describes wildfire risks associated with construction 

and operation of the Project. This SBNF ignition reduction project has been 

added to that section. This change is reflected in the Errata Memorandum 

(Attachment B to the FONSI). 

1.3.13 SECTION 4.15 GEOLOGY 

Comment GEO-1 The commenter expressed concerns regarding the specified loading

standard (Cooper E-70) which does not fully encompass the high-speed

rail’s impact to MWDSC’s facilities. The commenter requested the provision

of the following:

a. Maximum free surface horizontal/vertical displacements at the

crossing.

b. Profile of free surface horizontal/vertical displacements along the

pipeline alignment at the crossing, following Metropolitan

Geotechnical Guidelines.

c. Shear wave velocity in the foundation.

d. Dominant frequency (period) of the ground vibration

e. Dominant wavelength.

f. Dynamic load factor for the HST. (MWD-Carlson)

Response GEO-1 The commenter’s request has been noted. Items a and b would be prepared 

concurrent with the 3D analysis. Items c through f were provided to MWDSC 

by Brightline West on December 5, 2022. The shear wave velocity in the

foundation is 600 to 800 ft/sec. The dominant frequency of the ground

vibration is 20 to 40 Hz. The dominant wavelength is 6 to 11 ft based on a

speed of 130 mph-latest per BLW and the above frequency. There are no 

dynamic load factors. 

Comment GEO-2 The commenter requested the provision of at least three experimental/case

study historical data from analysis of similar high speed rail crossings with 

three-component ground acceleration at multiple distances to 100 feet

perpendicular from the railroad. These examples should include soil

properties and have similar rail properties (loading and maximum speed) as 

the proposed railway. (MWD-Carlson) 

Response GEO-2 The commenter’s request has been noted. Brightline West will provide case 

studies to MWDSC during final design. \

Comment GEO-3 The commenter asked for the provision of a site-specific geotechnical report

which should include the shear wave velocity profile and shear strength of

the soil. (MWD-Carlson)

Response GEO-3 The commenter’s request has been noted. Brightline West will perform the

required site geophysical assessment and provide the shear wave and 

Rayleigh wave velocity during the final design phase. 

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Comment GEO-4 Provide a 3D analysis of Metropolitan’s pipeline. Per Metropolitan’s 

Geotechnical Guidelines, the three-dimensional alignment of the pipeline 

should be considered in calculating the vertical and lateral deformations and 

in computing the fiber, hoops, and shear stresses along the pipeline. The 

3D analysis should be performed separately for both the three axles of the 

locomotive and the two axles of the passenger cars and see which one

provides the maximum displacements and stresses. (MWD-Carlson)

Response GEO-4 HNTB will perform a 3D analysis during final design for both the three axles 

of the locomotive and the two axles of the passenger cars to determine which 

one provides the maximum displacement and stresses. 

Comment GEO-5 The commenter requested that a stipulation is included in the plans and/or

specifications to notify Metropolitan at least two working days prior to starting

any work on the subject property. The commenter recommended that Jesse

Franco of our Water System Operations Team, telephone (818) 468-5188, 

be the primary contact. (MWD-Carlson)

Response GEO-5 The commenter’s request has been noted. Brightline West will include the

stipulation in the plans/specifications to notify Metropolitan Water District of 

Southern California at least two working days prior to starting any work on 

the subject property. Brightline West will coordinate with the recommended 

primary contact. 

Comment GEO-6 A commenter noted that the Final Programmatic Environmental Impact

Report for the Prestressed Concrete Cylinder Pipe Rehabilitation Program 

(PCCP) has been certified in January 2017. The commenter stated that 

inspections and repairs to the Rialto Pipeline under the PCCP Program have 

not started and may coincide with construction of the proposed Project.

Additionally, the commenter stated that FRA will need to consider 

Metropolitan’s Rialto Pipeline in its project planning, and that FRA must 

obtain appropriate property rights from MWDSC for any project activities 

within MWDSC property. (MWD-Carlson)

Response GEO-6 Brightline West will submit plans and specification for MWDSC’s review at 

least 60 days prior construction to ensure that the Project does not conflict

with the approved PCCP. Brightline West will continue to coordinate with the

MWDSC throughout the Project planning process. 

C-21 July 2023